ML18192A280
| ML18192A280 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 06/03/1975 |
| From: | Emrick R, Garcia J - No Known Affiliation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML18192A280 (6) | |
Text
I NRC STRIBUTION FOR PART EO DOCV MATERIAL (TEMPORARY FORM)
(
CONTROL NO:
60o3 FILE.
Enviro FROM: J.D. Garcia
NRC ORIG l<<signed CC 'THER SENT AEC PDR VENT I OCAL PDR xxxx CLASS UNCLASS PROPINFO INPUT NO CYS REC'D DOCIiET NO:
1 STN- '50-52
- 529, and 530 DESCRIPT.IOiV:
Ltr furn comments on the DES'oncerning Palo Verd'e Nuclear Generating Station.Units 1,2 and 3
~ ~ ~ ~ ~.
~ ~..
,ENCLOSU R ES:
II
~ ~
" PLANT'NAME:
Pal V
d I
h 3
FOR ACTION/liVFOR f'1ATIOjV V.
~
I)
.l lg 6-9-75 JGB BUTLER'L)
W/ Copies CLARK (t )
/ Copies
,Ann il!
W/ICopies KNIEL (L)
W/ Copies SCHWEr CER (L)
W/ Copies STOLZ (L)
W/ Copies vASSAi i i ) li 1 W/ Copies PURPLE {L)
W/, Copies Z I EMAMIV (L')
W/ Copies-DICKER (E)
W/ Copies
, II.'hllciH I Qhl (E'i bY/ Copies YOUMGBLOOD (E)
W/ Copies EGAN (E)
WIJ Copies LEAR (L)
W/ Cooies
~
SPED '
W/ Copies LICENSING PROJECT HANAGER W/ Copies PG TECH REVIE'.".'R SCHROEOER QGC, ROOM P-506A g MACCARY MGOSSI CK/STAF F KNIGHT CASE l'AWL'ICKI GIAMBUSSO SHAO BOYD STELLO MOORE (L')'HOUSTON DEYOUf'IG'L)
NOVAK SKOVHOLT (L)
ROSS GOLLER {L) (Ltr)
IPPOLITO P. Cot LINS TgDESCO DENISE COLL1NS I'ILE5 REGION (B)
BENAROYA
.HPIC','OLLiViER STEE LE INTERNAL'DISTRI BUTION DENTOiV
~R liViES
~AMMILL RASTMER
.MALLARD
~ANGLER EXTERNAI DISTRIBUTION LIC ASST R. DIGGS (L)
H. GEARIN (L)
E. GOULBOURiVE (L)
- p. KR E UTZE R (E)
- j. LEE (L)
M: MAIGRET (t )
ENVIRO
.S. REED (E)
MULLER IA'. SERVICE (L)
DICKER s'. s~~~~A~D (L):
KNIGHTOM M. SLATER (E)
YOUNG BLOOD H. S)KIITH (L)
EGAN S. TEETS (I )
ROJECT LDR G.
'I LLIAi";1S(E)
+S
. wit soiv (t)
AR LESS'. INGRAM.(L) 4/T IMlD.
BRAI I i~,lAxI SA LTZ)~IA" ME LTZ'L'ANS MCDOiT!ALD
~ CHAPMAN DUSE (Ltr)
E COUPE PETE RSONi HARTFIELD (2)
KLECKER EISENHUT
',WIGGINTON LOCALPDR
- PBoenix, Az TIC (ABERNATHY)~))Bid)
NATIONALLABS~L NSI C (8 UCHA)VAN)
W. PENMI >GTOiV, Rm E-201 GT ASLB 1 '
COiNSUL,I AiVTS Newton Ar.derson
~
NEW)%1ARK/8LUIXIE/AGBABIAN ACRS HOL.DIiVG/SENT 1
'DR-SAN/LA'NY BROOKHAVEI~IfIAT LAB 1 G ULRIKSOII'RI'L, 1 AGMED (RUTI! CUSS;.IAM)
Rm 8.127 GT
,1-'. D. RUMKLES. Rm E.201
- . ';GT
Ip IN
'V, P': 2Z
~
~
June 3, 1975 U.S.
N.
R.
C.
Office of Nuclear Reactor Regulation Washington, D.
C.
20555
~ c'>
Gentlemen:
Docket No.
STN 50-528, 529 + 530 We would like the following comments to become par t of the record concerning the Draft.Environmental Statement related to construction of Palo Verde Nuclear Generating Station Units 1, 2 and 3, Docket Nos.
STN 50-528, 529 and 530.
The construction of these generating units is, at this time, premature.
The safety of reactor operation, i'uel transportation, waste transportation and storage remains a subject of great con-troversy.
This draft, in section 7, treats the subject as non-controversial.
The only reference for section 7 is the WASH 1400
'raft.
'e believe that other, perhaps more objective, viewpoints should be considered.
For example, the American Physical Society initiated an independent reactor safety study a year ago.
Some of the conclusions of this study, reported at the APS meeting in Washington, D.C. on April '28-May 1, 1975, differ from those in the WASH 1400 draft.
This would affect some entries in tables 7.2 and 7.3.
We would like to see this information taken into account.
Since the case for nuclear reactors is not clear-cut, we feel that an overwhelming need for power must be demonstrated before such plants are constructed.
This need must be one dictated by the basic we')fare of society; not merely by the desire for conveniences.
Such a need has not been demonstrated for the immediate future.
Section 8.3 considers various influences which would alter (invariably reduce) the historic growth rate of electricity demand.
- Indeed, they concede that in the past year, the growth rate has. been drastically reduced.
In 8.3.2.3, it is implied that there is a
consensus that a change in rate-structure will reduce the consumption rate.
However, since all studies do not yield a unique model for predicting the decrease,.
they reject this particular influence on demand.
il 0
Ig I C
4 r
Indeed, their projections ignore al 1 of these considerations and use the historic-projection method.
Then, despite the use of the business-as-usual growth rate, we come to table 8.19 which.shows the Reserve t1argin With and Without a Two-Year Delay, in Palo Verde Units 1 and 2.
The magic number for reserve margin is 15/.'ith the two-year delay, the margin dips below this (arbitrary) minimum only twice by 1985.
Without the delay, the margin is nearly double.the minimum in two'ears before 1985.
We do not feel that an 17% dip below the minimum really constitutes a grave.threat to society, when there are so many factors which would mitigate the upper-bound'emand'igures used by the applicant.
Two more comments are in order.'n important factor in the pro-jected demand is the construction of the Central Arizona -Project'CAP).
This project itself,has generated considerable controversy and it is not yet certain that it will:be completed.
It would be irresponsible to ignore the CAP in.planning for power needs.
On the other hand, the fate of CAP should be much more certain in two years
- and, as we have
'bserved, the risk involved in a two-year wait is not excessive.
It would be, equally irresponsible to overcapitalize on the basis of a project which is terminated.
Finally, the margin is predicated.
on peak demand.
We feel that the alternatives leave out'one plan which is significant to a system whose load factor is 58%.
(This plan has,
- however, been circulated by the local. press.)
That plan is. pumped water storage.
The water now committed for.cool'ing purposes coul.d be pumped to an"elevated reservoir during off-peak hours and: then allowed to, flow. through the turbines in the reverse direction during peak hours.
'Sincerely,
. Garcia R., N., Emr' J.
D. Garcia 5141 E. Hawthorne
- Tucson, Arizona 85711 Roy N. Emrick 2220 N. Norton
- Tucson, Arizona 85709
C
'P