ML18192A283

Attached Applicants Comments to Palo Verde Nuclear Generating Station Environmental Statement in Accordance with Letter Dated 4/14/1975

ML18192A283
Person / Time
Site:	Palo Verde
Issue date:	05/28/1975
From:	Van Brunt E Arizona Public Service Co
To:	Regan W Office of Nuclear Reactor Regulation
References
ANPP-2481
Download: ML18192A283 (26)

Text

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'ATTRIBUTION FOR PART 50 DOC' MATERIAL (TEMPOR'ARY FOR(bi)

CONTROL NO:W+g~

FILE'ROM.

Arizona Public Service Co, Phoenix, Ariz.

Edwin ED Van Brunt, =-Jr.

DATE OF DOC 5-28<<75 DATE R EC'D 6-3-75 LTR TWX RPT OTHER TO:

W.

H Regan, Jr.

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1 Signed CC OTHER 'ENT AEC PDR SENT I.OCAL P CLASS

.UNCLASS PROP INFO INPUT NO CYS REC'D 1.

DOCKET N 50-52 /529/530 DESCR IPTIO(V:

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H. Regan, Jr., Chief Environmental Projects Branch 4

Division of Reactor Licensing U. S. Nuclear Regulatory Commission washington, D. C.

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REFERENCE:

Docket Nos.

STN 50-528 NRC Letter of April 14, 1975 STN 50-529 STN 50-530

Dear Mr. Regan:

Attached are the Applicant's comments to the Palo Verde Nuclear Generating Station Draft Environmental Statement in accordance with your letter of April 14, 1975.

Very truly yours, EEVBJr/l&1P/pk Encl,.

Edwin E. Van Brunt, Jr.

Vice President, Nuclear Services ANPP Project Director

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Mr.

17.

H. Regan, Jr.

U. S. Nuclear Regulatory Commission ANPP.-2481 CC:

Ms. Barbara E. Fisher, Esq.

Arizona Public Law Advocates 201 North Stone Avenue, Suite 21'0

Tucson, Arizona 85701 Mr. Carmine F.

Cardamone, Jr.

1415 North Third Avenue Tucson, Arizona 85705

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COMMENTS TO DRAFT ENVIRONMENTAL STATEMENT SECTION 2; Pa e i:

Change "Corporation" to "Company."

Change 3800 and 1240 to 3817 and 1270.

SECTION f; Page i:

The least amount of uncommitted effluent will'e in 1984-1985, not 1985-1986.

Any Gila topminnow populations that might be affected would be those which were introduced in a recent stocking program.

See comment under SECTION 2.7.1.

SECTION 1.1; Pa e l-l:

Change 1239 to 1270.

SECTION 2.2.1; Pa e 2-1, Para ra h 3, Line 3:

The population figure for the Phoenix Standard Metro Statistical Areas (SMSA) for 1970 should be 967,522 as indicated in the 1970 census'ECTION 2.2.1; Pa e 2-4, Fi ure 2.3:

A revised site plan was provided in Figure S1-3.6.2-1, and should be used in pl'ace of ER Figure 2.1-2.

SECTION 2.4'.2, Pa e 2-9:

Line 2 Change "6000 to 7000'eet of Miocene volcanics" to read "1400 to 1500 feet of Miocene volcanics"

'Line 4 Line 6 Change "lies at the base." to read "lies at the base of the Miocene volcanic sequence."

Change "a Tertiary conglomerate" to read "a Tertiary fanglomerate" SECTION 2.6.2; Pa e 2-14:

In Section 2.6.2, under local meteorology, the average wind of 5.5 mph is listed at 100 feet; this height should be 35 feet.

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SECTION 2.6.3; Pa e 2-14:

It is stated that the tornado recurrence interval, using Thorn's method and tornado frequency data, is 4700 years.

'This is 25 times more frequent than that stated in the ER where the interval is 116,000 years.

It is submitted that the assessment of tornado recurrence as presented in the ER is more realistic since it is based on a more recent data period and on the tornadoes that occurred in the vicinity of the PVNGS site.

This is demonstrated by the following analysis of the difference.between the ER and DES computations.

The probability of a tornado striking a point within a given area may be estimated by the following:

where, z t P

=

A

,mean probability per year (recurrence interval in years is 1/P), year 1;,

-geometric mean tornado, path area, squaie miles; mean number of tornadoes per year;, and area of concern, square miles.

The NRC used a value of z of 2.8209 square miles based on Reference 1 which was based on the geometric.mean path area based on Iowa tornadoes for the period 1953-1962..

NUS utilized a value of 0.065 square miles based on tornadoes occurring within a 50-mile radius of the PVNGS site for the period 1951-1972 as determined from Reference 2.

In addition, the NRC used a value of t of 0 '

based on the number of tornadoes occurring, within a one-degree square containing the site for the 1953 to 1962 period (Reference 1).

NUS used a value of t of 1.04 based on the number of tornadoes occurring within a 50 mile radius of the PVNGS site for the period of 1951-1972 (Reference 2).

Finally,, the NRC used a value of A of approximately 4000 square miles based on Reference 1, while

'NUS used a value of A,of approximately 7800 square miles using a 50 mile radius of the PVNGS site.

SECTION 2.7.1; Page 2-14, Paragra h 6; Lines 8-13:

According to Dr.

19.

L. Minckley of Arizona State University and Mr. Silvey of the Arizona Game and Fish Department, there is a high probability that the Gila topminnow occurs in the Gila River below Gillespie Dam.

The reason, for its occurrence, however, is that prior to the elevation of the Gila topminnow to endangered

status, the Arizona Game and Fish Department had,been propagating and distributing the fish to health departments in Pinal,, Maricopa, and Pima Counties which, in turn, stocked the fish in availabl'e waters for mosquito control.

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SECTION 2.7.1; Pa e 2-14, Para ra h 6, Lines 8-13:

(continued)

Both Dr. Minckley and Mr. Silvey agree that there is a very low possibility of the d'esert pupfish occurring in the Gila River south of Gillespie Dam.

The appl'icant i;s unaware of the existence of documents for DES statements on occurrence of these fishes in the study area, nor for the "known occurrence" of the Gila spinedace in the Cottonwood Canyon drainage area of the Gila River.

The accepted common name Bor Meda ~fnl ida is spikedace, not "Gila spinedace."

knowledge, been recorded in the Gila watershed.

Consequently, it is unclear which species the "Gila spinedace" refers to.

SECTION 2.7; Pa e 2-18, Paragra h 2, Line 2.:

thorn which is a State-protected plant is Holacantha

~emor l not Koeberlinia

~eicosa.

SECTION 2.7.2.3; Pa e 2-18:

and abundance of arthropods,,

much information was provided on.the important function of arthropods in the ecosystem.

In ER Section 2.7 alone, over 50 references are made to arthropods indicating their importance in food chains of mammals, birds, and reptiles.

SECTION 2.7.2.4.;

Pa e 2-18, Lines 1 and 2:

The two snakes should be included.

Some references (Lowe, 1962 and Stebbins, 1954) place the toad's range to the east of PVNGS.

SECTION 2.7.2.4; Pa e 2-19:

Birds-typos:

~Lo hortyx Sambeli, ~Sizella breweri..

SECTION 2.7.2'.4; Pa e 2-19:

Mammals:

The desert cottontail is the most abundant game mammal on the site, not the most abundant mammalian species.

The survey of rabbits occurred in

March, 1974 not March,. 1973.

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SECTION 2.7.2.4; Pa e 2-19:

"Two mammalian species which may possibly occur on the PVNGS site are possible on the PVNGS.

The spotted bat (Euderma maculatum) is in.the USDI 1973 Red Book as a threatened species.

The desert kit fox (Vu'l~es,:macrotis arsi~us) is not on the U. S. list of endangered species and is not li'sted in the USDI 1973 publication "threatened wildlife of the U. S."

A different subspecies, the San Joaquin kit fox (V., m. muticus), is an endangered subspecies and does not occur in Arizona.

'The kit fox that occurs on or in the vicinity of the PVNGS is considered rare in the state by local ecology.sts (See Section 2.7..2.,2.8, page 2..7-73 of.the ER);..

~Pa e 3-1:

Third,paragraph

-,Delete reference to visitor's overlook.

Fifth paragraph

- Change "Company" to "Inc."

Last paragraph

- Add "Company" after G.E.

SECTION 3.3; Pa e 3-4:

By removing the Blowdown Treatment Facility box as shown in Figure 3.3-1 of the ER, the numbering system of the noda'1 system has been confused.

Number 32 in the figure should read 29; 33 should be 30 and 34 should be 31.

These numbers should be corrected on pages 3-8 where Number 29 has:been corrected,

'ut 33 should be changed to 30 and 34,to 31.

SECTION 3.3; Pa e 3-9:

In Table 3.1 the columns 5 and 6 are not consistent with the data given in ER Table 3.6.1.

'~Pa

e. 3-11:

Change 62000 to 620,000 and drift rate to

~62 m.

~Pa e 3-18:.

Fifth paragraph

- Correct infant thyroid dose - Table 5.3-1 ER shows

.679 mrem, DES states 20 mrem.

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SECTION 4.1.3; Pa e 4-2, Para ra h 4, Line 4:

I Project 2 should be Project 3 since none of Project 2 is in New Mexico.

SECTION 4.2.1; Pa e 4-4:

It would be very difficult to determine TSS by preconstruction surveys or to monitor TSS during construction.

Most sediment would be carried in flash floods which are very difficult to measure,

and, moreover, the data would be very difficult to interpret.

SECTION 4.3.1.1; Pa e 4-5, Para ra h 3, Lines 4-6:

"In addition the probability of occurrence of locally rare, threatened, or endangered species is low at the si:te..."'Thi's statement cannot be supported, and contradicts the statement

.on Page,2'-19 under Mammals, Paragraph

2. "It is ~hi hly ~likel that this mammal (kit fox, rare in Arizona) visits the site..."

See also DES page 5-16 "The spotted bat, an endangered

species, is likely to visit the site..." -,.

SECTION 4.3.1.1; Page 4-5, Paragra h 4, Lines 2-,4:

Winter's Wash parallels the western

edge, not the eastern edge of the site.

"This, as well as a small tributary section..."

"This" refers to Winter' Wash and is incorrect.

It is East Wash which will be disturbed.

SECTION 4.3.1.2; Page 4-7:

Surveying corridors for endangered or threatened-annual perennial herbaceous plants:

This is an impractical requirement for several reasons.

Many, if not most, of the herbaceous plants might be overlooked since the growth of the majority is extremely rain dependent and many are short-lived.

Good rains are scattered, come irregularly (about once every 40 years) and are impossible to predict.

SECTION 4.4.4; Pa e 4-12, Second Para ra h:

It is implied that an additional 500 high school students could be accommodated in the schools at Buckeye, Gila Bend, Avondale, Goodyear, Litchfield Park and Tolleson.

Actually only 200 additional high school students can be accommodated at these schools.

500 can be accommodated at the above plus Sun City, El Mirage, Youngtown and Peoria.

There is an additional error in Table 4.4 which is also incorrect in our Table Sl-8.2.2-.1.

The figure 5,230 in the last column should be 5,235.

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SECTION 5.3.2; Pa e 5-3:

The sentence in the second paragraph:

"Relative humidity increases at ground level are calculated to be less than 1~~ within roughly one-mile radius."

should be changed to:

"Relative humidity increases at ground level are calcu-lated to be less than l~o beyond 0.5 mile of the towers, and less than O.l~~

beyond one mile."

SECTION 5.3.2; Pa e 5-3:

In the second paragraph a statement is made that the "staff" is not in agree-ment with the applicant concerning plume characteristics in the immediate vicinity o'f the towers.

They indicate that during an occurrence of plume

downwash, a relative humidity increase of'50,percent can result.

Although the ER does not present predicted relative humidity increases cl'ose to the towers during a single downwash occurrence, the effects of downwash occurrences are included in the mean annual predicted relative humidity increases as presented in the ER.

SECTION 5.3.2; Page 5-3:

In the fourth paragraph, a statement is made that "

~..about 65 tons of dry salt per day will be dispersed to the atmosphere by the towers."

A more correct statement would 'be "about 65 tons per day of salt, calculated on dry basis."

SECTION '5.3.2; Page 5-3:

In the last paragraph, second

sentence, the phrase "...at a point on the eastern site boundary.

~." should read "...at a point on the western site boundary..."

SECTION 5.5.1.j:;

Page 5-14, Para ra h 2, Line 12:

"57,000 acre ft/acre/yr" should be "57,000 acre-ft/year".

SECTION 5.5.1.1;

'Pa e 5-14:

Least amount of effluent will be available in 1984 as shown in Figure 5.3 (Not 1986).

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SECTION 5.5.1.1; Pa e 5-15, Para ra h 2, Lines 1-3:

See comment under Section, 2.7.1.

SECTION 5.5.1.2; Pa e 5-15, Para ra h 4, Lines 1-4:

"Several brown pelicans..."

Actually, records. of the California Brown Pelican at Painted Rock Reservoir are considered unusual noteworthy occur-rences.

The bi'rds sighted're a few erratic wanderers, commonly juveniles, sometimes blown in by storms.

'(See ER pg.

40 of Supplement 1 under 2.7).

The statement as given in the DES may be subject to misinterpretation.

SECTION 5.5.1.2; Page 5-16, Paragra h 3, Lines 5-8:

"...the staff is.reasonably certain that there will be increases in resident populations of Fowler's toad, Bufo woodhousei fowleri...; and Couch's of Bufo woodhousei that has its westernmost range limits in S.

E., Texas.

Two subspecies of Bufo woodhousei 'exist in Arizona:

Rocky Mountain Toad, Bufo woodhousei woodhousei and'he Southwestern 1Uoodhouse's

Toad, B.

1U.

australis.

The geographic ranges -of these two western subspecies approach the PVNGS site..

Couch's spadefoot should Qe S. couchi, not S.

hammondi.

SECTION 5.5.1.2; Pa e 5-16, Para ra h 3, Lines 8-10:

not aware of any documentation that would indicate that the bat is likely to visit the site.

If some spotted bats did visit the site to capture insects, there is little basis to speculate that the probable increase in food would be beneficial to the species.

The existing irrigated croplands probably provide more insects than the reservoir and associated seepage possibly could.

See comment under Section 2.7.2.4.

SECTION 5.5..2; Pa e 5-16:

Delete "with the exception of the,terrestrial effects...in Section 5.3.3."

since Section 5.3.3 refers to Section 5.5.

SECTION 5.5.2; Pa e 5-18, Paragra h 5, Lines 1-3:

Since the specific salt tolerances to annuals in the Sonoran Desert are largely unknown, the applicant is unaware of any documentation to support the statement that there is "high probability" that some desert annuals will germinate less frequently.

The references given in the DES do not support thi0 statement.

Reference number 40 is evidently misplaced.

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SECTION, 5'.5.-2.1; Pa e 5-18:

Microorganisms (Paraphrase)

- The staff suggests that the applicant gather baseline data on soil microflora - namely, data on "species composition, abundance,

ecology, and physiology."

Staff presents the argument that "such data may prove to be of future value in understanding the mechanisms of possible salt deposition impacts on other communities related to the soil microflora."

The staff's suggestions are premature and would be extremely costly to implement.

The design specifications of the cooling towers are not yet known, therefore, the actual salt deposition could be considerably different from the highly conservative estimates that are presented in the DES.

To quote the NRC, 3.6.2, page 3-23, "...the amount and size distribution of the drift are speculative.

The provisional value used by the applicant...is considerably higher than that usually guaranteed by...manufacturers."

The appropriate time to design preoperational baseline programs for salt d'eposition studies is after the tower specifications are known - probably in time for the Environmental Technical Specifications.

It seems more reasonable to monitor soils for increases in salts and to study the soil microflora only if long-term, large-scale, and obviously unacceptable damage could be predicted from a worst-case model.

SECTION 5.5.2.1; Page 5-18, last aragra h:

In Table 6.2-5 of the ER, the applicant has committed to monitoring salt sensitive plant species.

Details of the monitoring program for possible salt damage to offsite vegetation will be developed after the design specifications of the cooling tower are finalized.

SECTION 5.5.2.1.;

Pa e 5-19, Invertebrates:

"In view of the importance of invertebrates to the desert ecosystem, the effects of salts on this group should be investigated if adverse impacts on associated higher trophic levels are found to occur during operation of the PVNGS."

There appears to be little justification to set up a program to monitor higher trophic levels for effects of salt deposition (See 5.4.2.3 of ER).

SECTION 6.1.1.1; Pa e 6-1:

See comment on Section 4.2'.

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SECTION 6.1.2; Pa e 6-2:

The applicant is considering the institution of a limited air quality baseline program.

However, the feasibility of some of the staff recommendations for measurements is being evaluated in the light of very low concentrations of suspended particulates jn the ambient air at the site.

SECTION 6.1.3';

Pa e 6-5:

The NRC requests a plan for.additional soil sampling stations and additional.

sampling stations for all biota to the east of the site.

lichen final.tower drift specifications are available, a program for baseline data for salt effects will be proposed by the applicant.

See comment on Section 5.5.2.1.

SECTION 6.1.3.1; Page 6-5:

Arthropod sampling program:

With respect to baseline Arthropod, see comment on Section. 5.5.2.1 above.

SECTION 6.1.4; Page 6-6, (DES) Radiological Monitoring (Preoperational):

The DES is consistent with the ER.

There appears to be one.error in the third paragraph of the 'DES.

Reference is made to Section 5.3.4.

The reference shoul'd be Section 5.4.2.3.

SECTION 8:

Comments to this section of the DES are reflected in Supplement 84 to the ER.

SECTION 9.3.1;;

Page 9-16, Paragraph 1, Line 4, Transmission Lines:

"which is...43 miles..."

SECTION 9.3.2;

'Pa e 9-17, l(ater Conveyance Pi eline:

Assuming that staff route numbers are the same as the, applicant's, the following corrections should-be made in Table 9-6:

Alternate 'pipeline route 1 Agricultural Land, miles 23 latest, version Alternate pipeline route 1 Residential, miles.3 of ER

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10 SECTION 9.3.2; Pa e 9-17, lYater Conveyance Pi eline:

(continued)

Alternate pipel'ine route Alternate pipeline route Alternate pipeline route Alternate pipeline route 3 Residential, miles 0

6 Residential,, miles.3 1'ndustrial, mil'es

.2 6 Industrial, miles.3 latest version of ER APPENDIX C..l; No., 8:

It may be extremely difficult to close access roads 'from ORV.

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