ML18192A327

Submits Comments and Appendices on the Draft Environmental Statement Related to Construction(NUREG-75/022) for Inclusion in Final Environmental Statement and to Become Part of the Record of PVNGS Proceedings

ML18192A327
Person / Time
Site:	Palo Verde
Issue date:	06/09/1975
From:	Arizona Clean Energy Coalition (ACEC-PHX)
To:	Office of Nuclear Reactor Regulation
References
NUREG-75/022
Download: ML18192A327 (109)

Text

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~ ~. NU~ gEGU!hTOX5 CogN$ 5QN Arizona Clean Energy Coalitio pg mum q Statement and Comments on the c'~

OI Draft Enuizonmenta7 Statement ReEated To The Construction, of PaZo Ve2'de Nuelem'enes ating Station Doe%et Numbers STN 50-528, 529, and 530 (NUREG-75/022)

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June 197S Arizona Clean Energy Coalition The Environment Center 74S East Sixth Avenue Tucson, Arizona 8S719 67Ll2

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ARIZONA CLEAN ENERGY COALITION THE ENVIRONMENT CENTER ~ 745 EAST FIFTH STREET e TUCSON, ARIZONA 8571 9 (602) 624-9644

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June 9, 1975 U. S. Nuclear Regulatory Commission Office of .Nuclear Reactor Regulation washington, D. C. 20555 Regarding: Docket No. STN 50-528;529 and 580 Gentlemen:

The Arizona Clean Energy Coalition (ACEC) summits the following comments and appendices on the "Draft Environmental Statement Related to Construction of Palo Verde Nuclear Generating Station Units 1, 2, and 3"

'(NUREG-75/022) for inclusion in the final environmental statement and to become part of the record of the PVNGS proceedings.

ACEC feels that the "Draft Environmental Statement" (DES) does not show or prove the need for PVNGS, is inadequate and incomplete as an environmental analysis of this project, and does not justify the staff's draft conclusion that "issuance of construction permits for the facility" are "called for". It is not a complete, conclusive, or adequate "analysis and evaluation . . . weighing the environmental, economic, technical, and other benefits of PVNGS . . . against environmental and other costs and considering available alternatives". The DES ignores or neglects many important areas which must be considered in the final statement'. The DES also makes many unsupported statements in support of PVNGS which can be shown to be wrong or are misleading.

ACEC feels that a complete analysis of the costs and benefits would show the costs outweighing the benefits and a lack of need for PVN GS. ACEC feels, therefore, the request for issuance of construction permits should be denied. If the permits are not denied then they should be subject to the following conditions;

1) until the problems of waste disposal are solved the project should be delayed,

2) until firm commitments for reactor fuel for the life of the plant can be obtained the project should be delayed,

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3) strict conservation measures should be required and large users placed on intexruptable service and their loads counted towards the. reserve margins so that the plant size can be reduced and the schedule delayed,

4) dry or wet/dry cooling towers should be required to reduce the water requirement,

5) water for cooling should be taken at Gillespie Dam instead of at the 91st Avenue sewage plant to allow use in the Fred J. Weiler Greenbelt,

6) enlarge site boundries in the east-west direction to reduce boundry rad-doses due to wind patterns on site, and

7) require double containment to reduce hazards of aircraft impact at reactors.

Following are, the detailed comments on the DES:

The predicted availability of, water for PVNGS (section 5) is based on the .assumptions that population, growth will continue as it has in the past and .the per capita production of effluent:,i'll 'remain constant.

Neither is the case. In the last two years the growth rate has decreased from over '12> per year to less than 4>o .per year. In addition, most of the municipalities other than Phoenix presently charge for the amount of effluent produced by industrial users. When Phoenix adopts .this procedure, in order to raise revenues, it could. amount to as much, as a 42>o decrease in the industrial effluent (Water Resources Research, 9(5), pages 1121-1131, Oct. 1973).

The DES states that, the effects of the water use on the area will probably be minimal. The effects of the plant will be substantially worse than predicted. Predictions by the staff assume that figure 2.8 is approximately accurate and xeflects the conditions in the area. In fact, only one-half of the 23rd Avenue water reaches, the 91st Avenue plant now and about 60~a of the evaporation and seepage occurs before it reaches the veiler Greenbelt and all users take their water pxior to the greenbelt.

Therefore it is inaccurate to portray this water as being available for the greenbelt. Also the DES assumes there will .be no additional contracts for water before the year .2000 when there has already been another contract

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USNRC June 9, 1975 for up to 20,000 acre feet per year by the Roosevelt Irrigation District.

In addition, the Buckeye Irrigation District is presently using more than twice what it has contracted for. It is very likely that Buckeye will either contxact for the total water they are presently using or signifi-cantly increase groundwater pumping. This will substantially reduce the groundwater table and therefore invalidate the assumption in section 5.5.1.1 that the ceders in the greenbelt will be able to use the groundwater. In addition, as the groundwater tables in the area decrease, there will be pressure .on the other groundwater users to find an alternative source of water which will probably be effluent water. Since ANPP will only use 75,800 acre feet per year the fact .that ANPP has,an option for 140,000 acre per year makes no difference to other users and then will probably contract even if the amount of water available doesn't reach 140,000 acre feet per year. The DES assumes that the amount of .effluent will increase as predicted when this is almost guaranteed to be false.

Due to these facts, it seems that rather than having only a few minor detrimental impacts,"the proposed .plant is likely .to- completely destroy the greenbel't and the proposed state .natural, area in .the same area (see "Natural Area in the Salt River .Between 91st and 115th",." Report 87, Office of, the Governor).

As a result ACEC proposes that the applicants be required to take the water they have contracted for from .the Gillispie Dam rather than the 91st,Avenue plant. This will not only save substantial amounts of construction costs but will also save the greenbelt and proposed natural area that would otherwise be destroyed.

The use of WASH-1400,as the only reference in section 7 shows a lack of in depth analysis of a most important problem area, one that must be throughly. examined. This section treats NASH-1400 as a nearly finished and accepted product. This, is not the case. NASH-1400 is not a generally accepted study and is the focus of much controversy. Studies such as those by the American Physical Society, the Union of Concerned Scientists, EPA, and others point out. the many weaknesses of WASH-1400 and give results differing by large factors. Comments and evaluation of these studies must be included in the final report before the staff's conclusions of the

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gSNRC June 9, 1975 impact's of accidents can be a meaniful decision making tool. Appendix III details many of the weaknesses that the staff need to discuss if WASH-1400 is to be a basi,s for the DES. Related to section of appendix III 6, NASH-1400 estimates assume evacuation in case of severe accident, no where in the DES or PSAR is there any indication of any evacuation plans for the area near PVNGS or in the. Phoenix area.

Materials limitations related to nuclear, power plants greatly effect plant safety and yet are ignored by this section as well as by WASH-1400. One example is given by a metallurgical engineer (see appendix IV) in the June Bulletin of the Atomic Scientists:

After 25 years of research and'evelopment work on the chemical and metallurgical properties of metals and: alloys used in nuclear power plants, I have come to the conclusion. that the current design and materials cannot give .us a safe and well-engineered nuclear power plant. It now appears that there are serious limitations for some of the materials used in nuclear reactors.

The information in tables 7'.2 and 7'.3 need to be supported by the text and the information;by non-WASH-1400 studies needs.to be taken into account.

The section on transportation neglects many serious problems and ignores several other studies done on this problem (see appendix III).

In 1973 the Illinois Atomic Energy Commission warned'. . . 'of all the types of shipments, spent fuel'ods and high-level waste present potentially the highest risk to the citizens, of the State." Yet the staff glosses over the entire transportation issue.

The nuclear safety issue is not the resolved issue the DES portrays.

Informed and competent scientists disagree widely. on the safety and health/

environment impacts of nuclear plants. Until this issue is resolved, alternatives to PVNGS are to be preferred and conflicting views must be incorporated in the final Environmental Statement.

The ACEC finds .that the Staff's rubber stamping of the Applicant's traditional straight-line extrapolation of historical growth trends in Section 8, Need For Power, does not fulfillthe requirement for a rigorous

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5SNRC June 9, 1975 analysis of the need for PVNGS power.

The Staff's analysis describes the Applicant's demand forecasts as xeasonable and xecommends that the proposed construction schedule be accepted but fails to note which schedule is being endorsed: the 1974 plan to put Unit 1 on line in 1981 or the February 1975 revised plan to delay Unit 1 until 1982 because of lower demand forecasts for the 1980's.

ACEC strongly disagrees with Staff assertions that (1) construct-ion can be "stretched out" as the time approaches for on-line use and a better forecast of need is available, and (2) this can be advantageous under conditions of capital shortages. Such relaxed attitudes toward showing a need for power, toward the expenditure of funds and accrued debt service, and toward, the'mplied lack of financial qualification of an applicant caught short, of capital funds bode ill for applicants, share-holders, and ratepayers..

Even before APS'nnounced its decision to delay Unit 1, TG5E began looking for buyers for its share of PVNGS. TG5E apparently could not justify a need for 15.4~~ of PVNGS power to .the satisfaction of the Arizona, Corporation, Commission during its 1974 rate. case.

The Staff 1'ists the participants 'ombined: capacity in'973 as 5859 Ml'lei without any indication of planned additions or retixements during 1974 through 1982. Additions are planned during'this period to the Navajo. and San Juan plants. No impacts on the need for PVNGS power are identified for .the, planned 1975 construction start on the previously delayed SRP/APS pumped storage project nor,for APS'ole in the massive Kapairowitz plant 'for which, an APS subsidiary will supply coal.

Elasticit of Demand. The 9.8~~ combined'xowth rate experienced by Arizona Utilities from 1964 .to 1973 was largely due to increased per capita consumption and to a few large users, particularly copper mines.

High demand forecasts during that decade because .self-fulfilled. prophecies, thanks to effective advertising campaigns and promotional rate structures which are no longer permitted. Advertising must now emphasize wise energy management. A modified rate structure covering life necessities for small consumers was introduced, in 1974, a year of spiraling rate increases.

Since 1973, TGGE rates, including fuel escalators, rose about

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IJSNRC June 9, 1975 52~o SRP has increased rates 25~a so far in 1975 ~ APS is still presenting its 1975 rate case before the Arizona. Corporation Commission. During TG5E's 1974 rate case, the mines and a cement manufacturer told the Commission of their plans to generate their own power,, utilizing waste heat as a by-product if rates went higher. Rates did rise and they will continue to rise. The Staff can not ignore their effect on. the need for PVNGS power, given the threats. posed by TG5E's large base-load customers.

Anticipated higher seasonal rates beginning in June, 1975, have already spurred more vigorous conservation efforts by citizen groups, like the newly formed Pima Energy Management Council. Some significant energy savings in electrical consumption have already been reported for 1974: (1) ANAMEX mines, 17~~; (2) Hughes Aircraft 'Co., 17~a, (3) Pima Community College, 14'o (December); (4) Levy's Department Store lopped one million KWH annually and saved installation of a 250-ton chiller.

These savings were made in spite of a very hot summer with 22 consecutive days over 100'F. 'The Staff can estimate effects of weather variations on power consumption by comparing degree-d'ays of heating and cooling recorded by the utile:ties. .Economic incentives to save are strong.. A one per cent saving in electric consumption: by,'Hughes Aircraft, for instance, represents an $ 18,000 saving.

.An additional increment of 3 to 5>o peaking power could result if Arizona joined .the rest of the nation in observing daylight saving time, thus displacing. local peak periods by one hour from California's daily peak period., A jo'int recommendation by Arizona utilities to the Arizona legislature would probably be successful. The Legislature and the Governor are very receptive to solar energy alternatives to fossil-fuel water and space heating and'ooling which should soon have major impact in the Southwest,(see comments on solar energy alternatives, elsewhere in this report).

Economic Conditions. Arizona's unemployment rate hit 10.2~a in May, 1975, reflecting substantial layoffs in manufacturing, mining, smelting, and tourism. The value of construction permits declined dramatically statewide and in-migration slowed. APS and TG5E announced a moratorium in natural-gas hookups, further depressing construction plans.. Construction of all-electric homes as an alternative to .gas heating is not likely to fill

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USNRC June 9, 1975 the gap in an area known for its escalating electric rates. Arizona dropped from first to third place as the fastest growing state. The nation's low fertility, rate, 1.86,and-falling, is expected to slow the state's long-term growth rate. Gains in personal income were consumed'- by inflation, with some families (150 in the Tucson area alone) unable to afford utility services.

The 1960's saw an unprecedented boom in housing subdivisions.

Empty subdivisions, many victims of bankrupt or fraudulent developers, which failed to fulfillgrowth expectations, now litter the state. Recent construction has been concentrated more in mobile home. parks, condominiums, townhouses, and apartments, all lower energy consumers than single family dwellings.

Market saturation in electrical appliances following a decade of increased per capita .consumption, will dampen future demand. The boom in air conditioners which often produced monthly electric .bills substantially higher than home mortgage payments is expected to slow as fai;led units are replaced with evaporative coolers to save money. Lower energy consuming coolers may well meet OSHA requirements in some facilities. Increased female employment may reduce the daily residential'peak-d'emand. Demand by customer category can be determined from each utility's cost-of-service study, at least for trend identification.

Premature Construction. Without showing a. clear need for PVNGS power., the Staff .points to five !favorable impacts" derived from building nuclear capacity "earlier than needed," a practice neither Arizona utilities nor their ratepayers can'fford:

(1) Earlier retirement of inefficient hi h-cost eneratin units.

PVNGS participants'ase-load plants are relatively new, most dating from the 1960's with expected plant lives of 30 years or more. Compared to commercial nuclear plants now in service, these base-load plants are clearly more efficient on the average, having more efficient heat cycles, and higher average capacity factors. Higher-cost units are generally peaking units which PVNGS is not designed to replace anyway.

(2) Reduction in air ollution APS claims to have demonstrated successful operation of a scrubber at its Cholla plant. Ne are told that fossil-fuel plants can and are meeting EPA standards. PVNGS and the additional

I USNRC June 9, 1975 units 'expected to follow it >vill deposit daily near the heart of Arizona's irrigated farm land salts, heavy metals, and entrained biocides plus possible unexpected radioactive emissions.

(3) Savin s of scarce fuels. Uranium .has become a scarce fuel, largely controlled by a foreign cartel, the Uranium Producers Forum, not unlike OPEC. The June 16, 1975, Business Week .(p. 60). states: "The spot price of U308 or yellowcake--refined unenriched uranium-- has jumped from

$ 9.50 per lb a year ago to $ 21 today . . . Analysts predict the price could be anywhere between $ 25 and $ 40 by the end of the year." Given the critical shortage of reprocessing capacity in the U.S. today, uranium is a scarce fuel.

Coal, on the other hand, is, plentiful with the three major parti-cipants, each owning subsidiary coal companies or long-term leases on -.

strip-mined coal.. Switching from coal to uranium under these circumstances amounts to a leap from the frying pan into..the fire.

.(4) Increased'utlook 'for electricit sales to nei hborin utilities.'The Four Corners states are already supplying large blocks of power to;California, the Pacific Northwest, and Mexico. The plan to make the Southwest into the "boiler room" of the west is meeting with consumer resistance. Arizona utilities are issued certificates of convenience to provide energy within their own service areas.

SRP now has contracts with Pacific Northwest utilities for the exchange of, Arizona winter power for summer peaking power.

Colorado has excess power to peddle now.,-

(5) Increase, Reserve- Mar ins. The Staff's comment that "failing this" (sales), the participants can always, increase. their already high reserve margins, hardly an inducement to undertake an expensive 10-yr project like PVNGS. During its 1974 rate case, TGGE's reserve margins were so high (over 34~a), that the Arizona Corporation Commission required the company to file a document detailing alternative scheduling for capacity additions.

The Commission wanted to review .the impact of delaying. additions to the Navajo 4 and San Juan plants as, well as reducing TG5E participation in PVNGS.

by 50'o. Once before, TGGE built too much too soon and was forced .to leave Unit 4 at its Irvington plant out of rate base for a year after it was ready to go on-line. Such hi:gh reserve margins were not reduced much by

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VSNRC June 9, 1975 the 1~~ growth in 1974 consumption after years of 13-.14~a growth by TG5E.

Compared with eastern utilities which count their large inter-ruptible contract loads as reserves, all the participants have more than adequate margins and will have fox some time to come. Even with a two-year delay in building PVNGS Unit 1, with a postulated' or 9~~ peak-demand growth, the combined xeserve margins are larger than many other comparable utilities find adequate.

The Benefit-Cost Analysis of Alternatives (section 9) does not begin to fulfillNEPA or NRC requirements of an in depth analysis of the possible alternatives. It neglects conservation efforts, current trends of consumption, and the effects of combining alternatives to reduce or eliminate the need for 'PVNGS. It, at the same time, over 'estimates the performance of PVNGS .and the avai:.lable supply of cooling.:water.

Section 9.1.1. is entirely inadequate as an analysis of alter-natives to new generating capacity.'-The 600 to 700 MNe in the "early 1980's" would "fall short of the new capacity needed" if considered alone. This 600 or 700 Mle represents about, one-third.,of-the production which could be expected from the three units of PVNGS, thereby eliminating the, need for at least one of the proposed, units.

The load in the service area is not Lexpected to be growing about 8.6~a,,in the early 1980's .(see analysis of section 8) this statement ignores all current trends, analysis, and'easonable estimates available and is the, basis for attempting to commit the rate payers to a large unneeded, and expens'ive project. The staff projections are based on absolute econometric,model's based on a period of .atypical energy growth. According to the testimony of Environmental Policy Center analyst Mare Messing before the Senate Interim Committee (see Science News, pg 369, June 7, 1975) the ratio of total enexgy consumption to GNP has decreased sharply and as prices rise, people become aware of more efficient alternatives. "Since the 1973 oil embargo, energy resource costs", have risen to, the. level at which demand appears to be price-elastic." According to a xigorous study of price elasticity at the Princeton Center for Environmental Studies by L. S. Mayer and J. A. Robinson, energy prices have risen hi:gh enough that people are reducing their consumption. They show that residential consumers have reduced their gas consumption, by 12~~ and their electric consumption by 6~~.

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,Detailed analysis of the use of placing large users on inter-ruptable load service would greatly increase reserve margins and further reduce the need for PANGS. Also the effect of peak load pricing and a host of othex alternatives have not been analyized. Detroit Edison has equipped 200,000 hot water heaters with radio-equipped shut off/turn on controls so at peak periods there is a reserve of 200M<e avai'lable. This type of proposal needs to be examined as does the impact of hydro-storage for peak periods. As stated by University of Arizona economist, Dr. Helmut Frank, in Arizona Ener Inventor (Arizona State Fuel and Energy Office,. Feb. 1975, page 72):

The importance of adhering to strong conservation policies is particularly great in the electric sector.

Our projections indicate that energy inputs of that sector in 1985 would be reduced by over 40 percent the. annual growth rate were cut to half the historical if rate. Such a reduction would',save energy and water resources and hold down environme'ntal damages. It i~ould also ease the pressure on the utilities'inan-cial position, and thus the need for higher rates.

Appropriate demand policies, such as revision of elec-tric rates to correspond more .closely to actual .costs during various seasonal periods (and perhaps even times of'ay) would do more to improve Arizona's energy pos-ition than any feasible measures on the supply side of the energy equation.

ACEC feels that any massive project for, new generating capacity based on non-stringent conservation measures is detiimental to the well being of Arizona. PVNGS represents such a threat.

The section on the solar alternative is inaccurate and misleading in the first paragraph, "when the sun is blocked . . . no heat can be collected" shows a complete lack of technical knowledge on this subject.

This statement is only true for one class of collectors, concentrators.

Also high technology is not needed for many important forms of solar use.

According to Dr. Frank, 41'o of residential energy consumption in Arizona is for heating with heating water alone consuming more than cooling. This large portion of our needs could, according to Frank,, "be easily handled by solar power."

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QSNRC June 9, 1975 The 10~~ market penetration by 1985 instead of an upper limit should be considered a lower limit for the south-west as the 10>o figure is based on the national .market and the introduction, in the south-west will be much sooner and more massive than elsewhere in the .nation.

Further the studies upon, which the 10~a figure appear unduly pessimistic according to testimony before the Senate Select Committee on Small Bussiness .(May 13, 1975) as reported in Conservation Re ort (National Wildlife Federation, May 30, 1975 pg 256-257).

The initial witness, Dr. Jerry Plunkett, president of a small R 5 D firm'n Denver, accused Federal agencies of failing, to exploit the benefits .of solar power.

"Rather than assisting us, we have, found Federal employ-ees unable to understand the solar state-of-the-.technology, unable to formulate reasonable plans for moving, solar technology ahead, and in fact engaging in projects that were designed to keep university professors employed and off the street, and to use study contracts. granted to large firms to make solar energy appear long, term, remote, and unlikely to respond to os present energy crisis. Further, incredibly expensive solar heating projects, were conducted that seemed designed'o explore the upper .bounds of costs,, not to demonstrate .cost effectiveness.".

Plunkett stressed during the question-and-answer period that solar energy does not require more research, repeatedly observing that "you don't haveato re-invent the wheel." The government is spending more money and getting less results, he said, because they are spending funds in the wrong place. .In addition, Plunkett suggested the solar energy "is ideal for small businesses because individual innovators have been so successful in develop-ing the technology and because solar equipment does not require the enormous capital expense of equipment such as nuclear reactors.

Similar views came from other witnesses that day.

Jim Piper, president of Piper Hydro, Inc., of Anaheim, California, enumerated the various practices discouraging energy conservation in, general and use of solar energy equipment specifically. Piper also noted that large corporations such as Westinghouse that have given pessi-mistic predictions of solar energy's future also have a vested interest in maintaining the status quo; General Electric, he noted, is going to make a large profit on nuclear reactors, not, solar collectors. A spokesman for

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USNRC June 9, 1975 12 the National Environmental Systems Contractors Assoc-iation, Barney Menditch,"testified that predictions of solar energy's becoming competitive by 1985-1990 could be beaten "by a substantial margin" i'f the government gives funding support to educational programs for local building contxactors. "Give us the help we -need to get us involved in this effort," he said, "and we guarantee you a friendly market for solar heating and cooling systems in the very near future."

Review, with intensive solar energy R g D program, residential space heating and water heating in favorable areas (i:e. the south-west) could first come into use by 1978 and would be in "extensive use" by 1988, total energy systems for commercial plants available, by 1980 and extensive use by 1990 and large scale power generation. by 1985, and .extensive use by 1995. Indeed, at least one Tucson builder and'everal Phoenix builders are already offering "competitively priced" solar heated homes to potential customers (see Tucson Daily Citizen, March ll, 1975).

Al'so the solar alone replacing the need'or 'PVNGS by 1985 is a straw man and should not be a basis for staff analysis '(9.1.2.1 paragraph 6).

It is the combination of many alt'ernatives andeprograms .which can eliminate the need for PVNGS unti.'1 cleaner, safer and'ess expensive al'ternatives will be available. In, analyzingg solar the staff needs to. estimate how much solar could reduce, not eliminate, the need for 'PVNGS and combine this reduction with, other possible reductions of need.

The section comparing cooling systems (9.2) neglects the time water situation in Arizona (see comments on water) and'eeds to, be reworked.

The Replaceable Components and Consumable Materials .section (10.3.4.2) is inadequate and misleading. More discussion. of the cost and supply of enriched fuel must be included in the final statement to permit a rational decision. It is very unlikely that $ 8 .per pound 'U308 wil'1 be available for PVNGS. 'One U.S. producer recently offered U308 for delivery in the middle 1980's at a price of $ 24 per pound plus an annual escalator of about 7~m starting this year. H. 1<eed of Anaconda uranium division warns that the U.S.

will have to start importing uranium around 1979. ,(See Forbes "It worked for the Arabs. . ." Jan. 15, 1975, pg. 19-21; also see pg. 5, Public Power Weekly Newsletter, May 9, 1'975).

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~ ~ The Benefit/Cost Balance (Section 10.4) is completely inadequate to justify such a massive and expensive project. Much of it is based on wrong or misleading information. Nowhere is it shown that system relia-bility will be increased or that a plant capacity of 70~~ is reasonable to expect. Factors such as the net energy balance have not even been men-tioned when comparing alternatives. A paper presented at the April, 1975 Arizona Academy of Sciences Nineteenth Annual Meeting comments on these problems, problems which the staff must address.

The prohibitive costs of nuclear plants are causing many utilities to reconsider investing in nuclear.

Nuclear costs are rising much faster than other sources such as fossil. For example, the price of an average sized 1000 -MWe nuclear station. doubled in price from

$ 212 million in 1972 .to $ 500 million in 1973 and about

$ 600 milli:on/1000 MWe'for PVNGS compared to an increase for fossil fuel .plants of about'one-third as much.

Utilities nationwide are experienceing unwelcomed rate increases, not the predicted unmetered boom nuclear energy was supposed to provide.

The high dollar cost is an indication of the huge

'mounts of energy that nuclear plants consume. Conser-vation of an energy source to, a useful form requires a certain expenditure of energy to,,upgrade and'ransfer.

the resource into-a usablke commodity. Thus, the Mega-watt figures of electricity are not a true indication of the amount of energy a nuclear plant adds to society's "net energy balance."'r.. Howard T. Odum of the Univer-sity of'lorida has studied this concept and has con-cluded that "nuclear .energy is now: subsidized by fossil fuels and barely yields a net surplus of -energy."

In,a recent repor't, Odum, Bolch, and: Lem calculate that the energy required'or fuel enrichment., uranium mining, steel and .zirconium manufacture, plant construc-tion and the rest exceed's the total'ccumulated energy output of a 1000 MWe reactor for the first ten years of its operation. Adding an average of 8 years for con-struction, a nuclear project requires 18, years before it begins to add to our net energy balance.

Studies made by Prof. E. J., Hoffman of,the University of Wyoming t'end to confirm Odum's findings. Hoffman estimates that roughly half of the energy yield .from the uranium fuel cycle must be plowed back into enrichment, mining, milling, transportation, etc. A clear demonstration

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8SNRC June 9, 1975 of this lies in the fact that not until 1971 did the electrical output of commerci'al nuclear reactors exceed the total electric consumption of the U.S. gaseous dif-fusion plants where the uranium is enriched.

A recent study by the Oregon office of Energy Res-earch and Planning report compares energy requirements of different means of electrical- production., (Transition, Office of the Governor, State of Oregon, 1975). The report on energy policy and alternatives, which includes the comparison, indicated that Nuclear Plants (LWR) require 8188 BTUs of energy for every 1000 BTUs of electricity, while strip-mined coal-fired plants need only 4490 BTUs and 1454 BTUs for hydroelectric plants. This. was based on a 1000 W light water reactor operating for 30 years at 75~~ capacity.

Net energy production of nuclear plants may be worse because of the overly optimistic capacity figures like 75~a being used. 'Capacity is the amount of power actually generated compared to the amount the, plant is designed to deliver. tamil'e coal plants normally run at 80 -- 90~o capacity, nuclear plants are much lower. The, Bulletin of Atomic Scientists;,,(D'.. D. 'Comey,, Bulletin of Atomic Scientists, Nov,. 1974, Feb. 1975) using U.S~A~EEC.. data, reports the average capacity factor for all'.S. Commer-cial plants for 1973 was 57.3~os This dropped to 51.6~~

for the first 10 months of 1974. Larger plants are having more problems -- the ten largest plants since. their start of operation have a mere 43.5w capacity, figure. Most economic studies assume an70, --,80~~ capacity, which has been shown not to be a reasonabl'e expectation. Early hopes of nuclear energy as an unlimited resource have been contradicted., According to a leading U.S., energy resource scienti'st, M. King Hubbert, "All present, evidence indicates that without a transition to the .breeder reactor an accur-ate shortage of low cost ore is likely to develop before the end of the century." Present day makes use of uranium

.oxide enriched with U235 -- the isotope of uranium that is fissionable and makes up ..7~o of all uranium. The AEC estim'ates $ 8/lb reserves of uranium oxide to, be 273,000 tons and $ 10/lb reserves of the world to be 840,000 tons.

Between now and'980 the U.S. will need 206,000 tons and non-communist nations, according to the International Atomic Energy agency, will require over 430.,000 tons. AEC predicts that additional reserves of more than 1 million tons will need to be .discovered and developed by 1985. The Palo Verde Nuclear Generating Station has merely 36 to 48 months assured supply of uranium fuel. Beyond that, pot-ential fuel supplies are uncertain for the rest of the reactor's 30 year life.

Thus, doubt has been cast upon nuclear power's ability

VSNRC June 9, 1975 15 to supply a substantial amount of net energy. to society.

Yet that bargain, like Faust's,,offers an illusion not reality. Instead of limitless, clean and cheap energy; nuclear power has distracted us from better hopes, has given us many major problems, and may leave us with a deadly legacy. [From: Nuclear Power: The Myth of Free Energy; K. Dahl and D. E. Osborn; Arizona Academy of Science Nineteenth Annual Meeting; Apri'1 12, 1975].

The low capacity factors large nuclear plants have shown indicate that a 70~~ capacity factor is much too high to calculate Benefit/Cost.

ACEC urges that a capacity factor, of 50~~ be used or, at minimum, included for comparison, in calculating the Benefit/Cost Balance. Staff must also take into account the effect of proposed EPA fuel cycle standards announced May 23, 1975.

It is the AGEC's hope that these comments will prove useful to the staff in preparing a final statement which will reflect the realities of the need for and effect of PVNGS.

Sincerely, Donald E. Osborn Director -- ACEC DEO:ckg

Attachment:

For inclusion with this statement in the record and Final Environmental Statement are Appendices I thru IV.

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THE ENVIRONMENT CENTER 745 EAST FIFTH STREET

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TUCSON, ARIZONA 85719 (602) 624-9644

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~~ pgggL +gpss June, 1975 Arizona Clean Energy Coalition (ACEC) is a statewide coalition of environmental organizations, consumer groups, and concerned citizens.

ACEC opposes the construction of nuclear power plants and supports the rapid development and implementation of clean alternatives including energy conservation and solar power.

.Member organizations include the Arizona Consumer Council, Arizona Friends of the Earth, Arizona Nuclear Responsibility and Safety Committee, Arizona Public Law Advocates, Concerned Arizona Students for the Environment, Center for Social Change, Energy Research Group, Environmental Conscience, Project Survival, Saquaro Ecology Club, The Environment Center, Tucson Consumer. Council, and Tucson Public Power.

ACEC is the intervener in the Nuclear Regulatory Commission's licensing proceedings on the Palo Verde Nuclear Generating Station (PVNGS).

PVNGS would be a 3800 N< power plant 36 miles west of Phoenix, near l'tintersburg. The six utilities participating in this project are Arizona Public Service Company, Salt River Project, Tucson Gas and Electric Company, El Paso Electric Company, Public Service Company of New Mexico, and Arizona Electric Power Cooperative. APS is the project manager and operating agent of PVNGS.

ACEC opposes PVNGS on economic, environmental and safety grounds..

PVNGS will mean higher bills for, consumers because of the greater costs of nuclear plants and their poor performance. Dispite enjoying many federal. subsidies, including the Price-Anderson limit on accident liability and not having to include the cost of waste disposal, nuclear power costs are rising much faster than other sources of power. Further, much of the energy produced by a nuclear reactor must be plowed back into the fuel cycle, thus greatly reducing the ne't output of a reactor.

PVNGS would also pose grave safety and environmental problems from the transportation and disposal of hundreds of tons of radioactive wastes, sabotage and theft, and intensive water usage. These problems could all be avoided by the use of clean alternatives and a serious program of energy conservation. PVNGS is not needed and would prove to be a burden on the consumers and residents of Arizona.

The contentions raised by ACEC and accepted by NRC as issues for the hearings to begin late this summer or in the fall are:

MEMBER OF NATIONALINTERVENERS

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Contention I'CEC contends Applicants have not shown that they will comply with 10 CFR 50.34a and 20.106 or'roposed 10 CFR Part 50, App. I, when and if adopted by the Commission. IE: The levels and concentrations of radioactive materials snay exceed safe levels and present a health and safety hazard;,

Contention'1 ACEC contends that the Environmental Report (ER) fails to adequately consider the effects of the proposed transmission lines in that electromagnetic fields emanating from these lines may have an adverse effect upon the health of persons and animals living in the vicinity of the rights-of-way.

Contention 222'CEC contends that the cost-benefit analysis in the ER is def-icient in that:

(1) the escalation rate of 10~a per year per capital costs is too low, 12-15'o being more realistic; (2) the assumed'plant availability factor of 80~~ is too high, a more realistic figure being 65~o for the first three years and 32-34~~ for the next four years, based upon experience at other nuclear plants; (3) capacity factors of present nuclear plants average 50~~ and lower; I

(4) the adverse impact from, fossil-fuel plant particu-late emissions is overemphasized as a 99~~ reduction in such emissions is achievable; (5) the analysis fails to adequately consider the impact of the facility's use of water on agricultural and residential uses and overestimates available water.

The cost of replacement water to Arizona consumers may range from $ 100 to $ 190 per acre foot, and replacement water may not be available at all; (6) the long-range estimates of the availability of uranium ore, fuel reprocessing plant capacity and the lack of long-tenn storage facilities for nuclear wasteth indicate that PVNGS's operation may be curtailed or ended before the presently estimated plant life expires.

(7) salt-laden vapor plumes will tend to corrode nearby

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transmission lines, increasing maintenance costs and decreasing system reliability; and (8) the costs of the future decommissioning of the facility have been underestimated.

Contention 2'V ACEC contends that the ER Sails to adequately establish a need for the facility in that:

(1) the need for power analysis is based on trend extrapolation which fails to take adequately into account:

(a) the potential for conservation of energy; (b) the elasticity of demand for electricity; (c) the potential for large industrial users generat-ing their own electricity is great.

(d) the population growth rate in Arizona is projected to be smaller in the future; (2) the need for power analysis fails to adequately consider instituting different rate structures such as flat rates and time-of-day metering; (3) the need for power analysis fails to adequately consider the possibility of. load staggering or selective load shedding; and (4) the need'or power analysis is premised on the continued existence of overly large reserve, margins, as high as

42. 8'o.

Contention V ACEC contends that the ER fails to adequately consider alternate sources of generating electricity, such as:

(1) small and medium-sized fossil fuel plants which will have greater reliability than the proposed facility;

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(2) solar energy; (3) geothermal energy; and (4) purchased power and sharing arrangements and'ther utilit-ies.

ontention VI ACEC contends that the probability of aircraft impact is such that the containment for PVNGS should be built to .adequately withstand such impact and is,not presently so designed.

Contention VIZ ACEC contends that the proposed site does not meet the require-ments of 10 CFR 100.10 from a safety standpoint, in that:

(1) the aquifers and perched water zone under the proposed site are particularly susceptible to contamination from raidonuclides eminating from the facility.

(2) the proposed site is particularly susceptible to subsidence caused by natural forces as well as the potential lowering of the water table as demand for water in the area increases; and (3) the proposed site is too close to major population centers (Phoenix and Tucson) and major installations serving a national security function.

Contention VIII ACEC contends that the application fails to adequately consider

.additional safeguards for the rail transport of hazardous materials, any, to and from the facility in that the proposed carrier of such materials, if the Southern Pacific Railroad, has an extremely poor safety record in Arizona.

Contention IX ACEC contends that the application fails to adequately consider alternate means of transporting hazardous materials, if any.

Contention X ACEC contends that the site does not satisfy 10 CFR 100, App. A, in that there are capable faults which .can be extended to a close proximity of the proposed site.

Contention XI'CEC contends that the ER fails to adequately discuss the adverse impacts of the deposition of salt and heavy metals by cooling tower plumes and the loss of water for agricultural and residential uses caused by plant consumption of cooling water.

Contention XII'CEC contends that Bechtel Power Corporation (Bechtel) is not

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('echnically qualified to design and construct the facility in light of the history of Bechtel's quality assurance program such as the Midland facility, as set forth in Consumers Power ~Com an (hiidland Plant, Units 1 and 2) ALAB-106, RAI-73-3, 182 (March 26, 1973).

Contention XZIZ ACEC contends that'ombustion Engineering (C-E) is not techni-cally qualified to design and construct the nuclear steam supply system for the facility, in that:

C-E has minimal operating experience with pressurized water reactors I

which it has constructed, and (2) operating experience with C-E steam supply systems at the Palisades and Main Yankee facilities has brought to light problems with the integrity of steam generator tubes and basic internal reactor structures, as well as with corrosion of the reactor head bolts. 'essel Contention XXV ACEC contends that Arizona Public Service (APS) is not technically qualified to act as Project Manager for the design and construction of the facility in that:

(1) APS's past operating liistory with fossil fuel plants and natural gas pipe lines has deomonstrated its inadequate concern with public health and safety and its inability to reliably meet the power needs of its consumers; and (2) APS intends to delegate the responsibility for quality

.assurance during construction to Bechtel Corporation and Combustion'Engineering.

Contention XV ACEC contends that APS and Tucson,Gas and Electric (TG5E) are not financially qualified to construct the facile:ty, in that:

(1) APS and TG5E are presently making an inadequate rate of return on equity to provide them with reasonable assurance that they will be able to finance their share of the construction costs, and sufficient rate relief is unlikely; (2) increasing costs of fuel and pollution control devices wi:ll further reduce their rate of return in the future;

(3) increased electricity costs may motivate the copper mines which operate with an 86~ load factor and provide a large stable base load to generate their own electricity,;

(4) increased electricity, costs will .not increase revenues as much as expected because of the elasticity of demand for electricity; and (5) any decrease in participation by TG6E would further increase the financial burden on the other participants.

BEFORE THE ATOMIC ENERGY COMMISSION IN RE THE APPLICATION OF ARIZONA PUBLIC SERVICE CORPORATION, THE SALT RIVER PROJECT AGRICULTURAL Docket Nos. STN 50-528 IMPROVEMENT AND POWER DISTRICT~ STN 50-529 TUCSON GAS &: ELECTRIC COMPANY~ STN $ 0-530 EL PASO ELECTRIC COMPANY OF NEW MEXICO AND ARIZONA ELECTRIC POWER PETITION TO INTERVENE COOPERATIVE, INC. TO CONSTRUCT AND OPERATE ARIZONA NUCLEAR POWER PLANT.

Arizona Clean Energy Coalition, on behalf of its members, hereby petitions the Atomic Energy Commission ("AEC") for leave to 10 intervene in the above-captioned proceeding pursuant to 10 CFR I2.714. In support of this petition, the petitioner state the 12 following facts:

13 I. The Risk to Health and Safety 14 Health Considerations 15 Applicants have failed to consider the impact on dis-persal of the releases of radionucleides occuring at roof level 17 rather than at ground level (10CFR50.35(a)(3)).

18 The impact, of'adionucleide dispersal upon the graze 19 utilized by cattle on surrounding ranches as well as on irrigated 20 cotton crops in the area was not adequately considered. Since cot-21 ton seed is a ma/or feed for both dairy and beef cattle in the 22 immediate vicinity as well as for animals to which the feed is 23 shipped, contamination of'iber crops by salts, heavy metals and 24 radionucleides must be considered.

25 The Applicants fail to show that adequate measures will be ;,

26 taken to prevent seepage into the perched water zone under the 27 PVNGS site and hence to the groundwater table by contaminants 28 leached from the evaporation ponds, and by burial of solid wastes 29 in the waste disposal area on site.

30 Alternative Reactor T, es The Light Water Reactor (LWR) type proposed for PVNGS 32I is considered by many experts to be the most unsafe reactor now on:

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I II the market. Lord HInton, former chairman of Britain's Central Electricity Generating Board and former member of Britain's Atomic Energy Authority, said on January 9, 1974'.

"Of all the nuclear plants at present on the market, Che ones whose safety can be most strongly questioned are the Light Water Reactors" (Weekly Energy Report, Jan. 28, 1974).

The United Kingdom Select Committee on Science and Technology advised against the purchase of LWRs or pressurized water reactors designed in. the U.S. for reasons of safety.

10 The applicants'R, however, fails to discuss any re-11 actor of'lternative type, size,,design or manufacture. The al-12 ternative reactor types differ in several ways that may substantial-13 ly alter their impact on the public health and safety as well as I 14 on Che environment. Safety margins associated with different de-I

'15 signs and sizes of reactors may vary considerably. In view of the different impact of differing reactor types on the potential risk 17 to persons and the environment, benefit=cost analysis to provide 18 the basis f'r selection of a reactor type is .mandated. No weighing 19 of the costs and benefits of smaller, lower-power-density plants 20 is considered by the Applicants, nor is a gas-cooled, graphite 21 moderated reactor considered as an alternative to the proposed 22 design.

23 Alternative Safet Features 24 Alternativesto the facility must Include consideration 25 of alternative designs for the required safety systems. Consid-,

26 erations of alternative. designs may show Chat the benefits in terms 27 of environmental protection of design alternatives outweigh the 28 costs and should therefore, reasonably be incorporated. The Ap-29 completely fails.,to consider design alternatives that will 32'plicant 30 ,'Improve the protection of She public.and the environment. Various 4

31" ,'design alternatives that should be considered are:

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(a) Modified desi ns for the emer enc core coolin

~s stems: to improve their peryormance capability and their relia-bility. Obvious modification that might be considered are differ-.,

ent methods for emergency core cooling system infection, design 1

features to alleviate steam binding, design features to include increased protection against small breaks, design features to re-lieve the effects of steam generator tub'e failure during a loss-of-coolant-accident, and design features that would reduce the need to rely on sophisticated computer models.

10 (b) Core catcher: the development of a capability to control a largely molten core has been .an urgent recommendation 12 from the ACRS for several years. Such a device would increase the 13 margin of safety against uncontrolled loss-of-coolant accidents by 14 providing a backup to the emergency core cooling system.

15 (c) Devices to miti ate effects of ressure vesse3.

16 failure: The ACRS, in their January, 1974, report recommended de-17 velopment of systems to minimize the effects of disruptive vessel 18 failures. Development And installation of devices such as those 19 noted by the ACRS would better protect the pub3.ic and the environ-20 ment from pressure-vessel failures and should be considered.

21 (d) Under round sitin : The costs and benefits of 22 underground siting as an alternative to the proposed prospect should 23 be considered as a way to increase chances of safe nuclear power-24 plant operation. The October, 1973, AEC Task Force Report, "Study 25 of the Reactor Licensing Process", called for a review of under-26 ground siting. (p. 65).

27 Containment desi n: Containment designs ensuring (e) 28 increased protection of the reactor against penetration. by turbine 29 missiles and alternative, containment designs capable of withstanding

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31 Containment Structure (Sec. PSAR 3.8,.Vo1 X) 32 s,~s The standards covering concrete mater'ial proper ies and 3~

the placing and curing of concrete are not included in the PSAR.

The said specifications, prepared by Bechtel for the containment, are said not to deviate from the applicable industry standards.

Some special considerations may be necessary depending upon the time of year in which the containment construction is scheduled 6 in order to compensate for the diurnal temperature swings which 7 may range from 30 to 50 deg F. under varying humidity conditions.

8 No mention is made in Sec. 3.8 (pg. 3.8-10) of special care being 9 taken overcome extreme conditions common to a desert environment 10 which may, produce deviations from accepted standards for concrete 11 material properties or curing procedures.

12 These alternatives which have not been considered by the 13 Applicants demonstrate that the ER and PSAR failed to offer para-I 14 metric design studies as a basis for determining optimal plant 15 design along with the appropriate benefit-'cost analysis as required 16 by 10CFR Part 50, Appendix D.

17 The Applicants failed Co consider alternative types of'c-18 cident analysis techniques. which could contribute to the safe t

19 design of the facility. Reliance on a form of analysis which con...

2o siders multiple failures rather Chan a single-failure criterion I

21 would be more conservative as well as )ustified by'xperience with

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I 22 multiple failures at operating nuclear plants.

The Applicants'R report does not consider as a prudent I

24 alternative the delay of the PVNGS prospect until more experience with the commercial operation of the plants designed by CE can be 26 evaluated. A safety research program on the outstanding generic h

27 'safety problems applicable to the facility which have been noted l

by the ACRS should be designed and completed before undertaking 2 <construction of PVNGS.

30' Transmission Lines Ih 31

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I 32 The Applicants failed to specifically treat the meance posed 4

1 to the extensive military, private and commercial air traffic of

'2 the transmission lines emanating from the PVNGS.

The Applicants did not adequately treat the impact of 4 the transmission lines on the residents of the various Indian 5 reservations.

No mention is made by the Applicants of the effects on 7 the health and safety of persons and livestock exposed to the high

'8 energy fields surrounding the conductors of the 525-KV EHV trans-9 mission lines. The effects of the electromagnetic fields existing round EHV conductors has become a matter of concern for utility 11 companies and others in Europe, Russia, and more recently, the 12 United States.

13 Special consideration must be given to EHV transmission

'~" facilities in the vicinity of salt-laden water-vapor plumes as-

.15 sociated with the cooling towers proposed for PVNGS, because such 16 conditions tend to increase corona discharge and to decrease equipment life, resulting in higher maintenance costs and lowered 18 ystem reliability.

'19 Technical Com etence of Bechtel Co oration:

ZO Bechtel Corporation will serve as constructor-engineer 21 for PVNGS (PSAR 1.4.1), but that vendor has demonstrated previously a lack of technical and managerial competence to serve in a manner onsistent with the protection of public health and safety.

chtel's quality assurance program has been found repeatedly de-25 icient in recent AEC reviews (AEC Docket Nos. 50-329 and 50-330).~

26 pecifically, Bechtel was found to be impropeply placing, testing,;

27 nd sampling concrete while inspection personnel failed to promptly 28 dentify and correct the faulty procedures.

29 Concern with the technical competence of the Bechtel Corp-30 oration arises from the utter disregard with which Bechtel handled 31 the quality assurance program required by the Midland Construction 32 5.

1 Permit application of'onsumer's Power Company (ALAB-106, p. 9).

2 On March 26, 1973, the ASLAB reported that Bechtel's quality as-3 surance performance caused them "serious concern". Contrary to 4 Bechtel's assertion that their onsite construction personnel were qualified in the areas of batch plant operations of concrete place-6 ment, the AEC inspectors noted:

"1. improper use of vibrators during concrete pours;

2. improper testing of the concrete by the site's testing laboratory; 10 3. improper sampling of the concrete for slump tests; and finally 12 'the QA and QC inspection personnel present at 13 the concrete pour location did not promptly 14 identify and correct apparent deviations from 15 the ACX-301 Standard regarding consolidation of 16 concrete.'" (CO Report No. 329 and 330/70-6) 17 The ASLAB conclusion stated that (ALAB-106, pgs: 13-14) 18 Bechtel did not have properly trained personnel to 19 handle the vibration of the concrete.

20 2 ~ Neither Bechtel nor the Applicant had quality as-21 surance engineers on-site who were sufficiently 22 knowledgeable to recognize deficiencies in the pro-23 cedures.

24 3~ Even though both had experience in building reactors, 25 neither the Applicant nor Bechtel provided reasonableI 26 assurance that the quality assurance program would 27 be implemented properly, that quality assurance 28 programs, would. be, properly synchronized with 29 construction programs, nor that they would have 30 properly trained personnel on-site to implement the, 31 quality assurance programs.

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In view of these deficiencies, the ASLAB imposed additional quality 2 assurance procedures on construction at Midland, but Bechtel con-tinued to violate QA requirements.

AEC inspectors found that:

l. Inspection techniques were inadequate.

2. Acceptance criteria used for QA requirements were being misapplied.

The ASLAB considered the violations blatant enough that, had the construction permit proceeding still have been pending be-10 fore the Board, they would have almost certainly ordered construo- ~

tion to stop until properly trained quality assurance inspectors, 12 "fully independent" of Bechtel, could be available on the site.

13 Bechtel apparently was more interested in building the plant quickly 14 than in building it properly.

15 Technical Com etence oi Combustion En ineerin 16 The Applicants'SAR fails to establish the competence of 17 CE to design and manufacture and test under full power operation 18 the nuclear steam supply System for a facility as large as PVNGS 19 (3817 MWt output for each three units). Limited experience with 20 smaller CE plants (2440 and 2472 MW), has demonstrated problems 21 exist with respect to the integrity of the steam generators, basic 22 reactor structures, and corrosion of the main flanger 'nternal 23 studs.

Because of'E's limited experience and because of'pparent 25 defects in its previous work products, Petitioners contend that a 26 technically competent vendor for the nuclear steam supply system 27 has not been identified as yet. (PSAR 1.4.2).

28 Specifically, CE has supplied the nuclear steam supply system 29 for two commercial reactors: the 2472-MW Palisades Nuclear Power

30. Plant (South Haven, Mich) and the 2440-MW Maine Yankee Nuclear 31 Power Station (Wiscasset, Maine). Very minimal experience with 32 70

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1 with even smaller PNR is all the operating experience available.

CE's Palisades reactor has suffered from problems relating 3 to the integrity of its steam generators, problems relating to the 4 integrity of basic internal reactor structures, as well as problem 5 due to corrosion of the main flanger studs. Because of brcen sup-6 ports in the core support barrel, the reactor core vibrated enough to cause shi ts in power level while further abrading the support 6 strucutre. For this reason, the Palisades facility was shut down and remains so at this time.

10 Combustion Engineering has not demonstrated the technical

>~ and managerial competence to design and manufacture nuclear steam

>2 supply systems of the size and design proposed for PVNGS that will

~3 operate in a manner to ensure the protection of the public health

>4 nd safety.

15 Technical Competence of General Electr'ic 16 In 1974, 20 nuclear generating stations containing piping upplied by General Electric were forced to shutdown to test for racks produced by ".stress-assisted corrosion" in bypass cooling ipe. Similar cracks were found in September, 1974, in the bypass ooling pipe of the Commonwealth Edison Dresden No. 2 nuclear 21 enerating station, and later, at two of the company's other nuclea 22 ower stations, all supplied with reactors made by General Electric 23 Cracks in the quarter-inch-thick stainless steel walls of 24 os.ing system pipes were found in three boiling water reactors in 25 ten-day period, the possibility that all the suspect reactors 26 may suffer similar failures.

27 Technical Com etence of APS:

28 APS is acting as Prospect Manager and Operating Agent f'r 29 PVNGS "with full authority and responsibility to engineer, design, 30 construct, operate, and maintain PVNGS and all related facilities I

31 Il'ther than transmission and switchyard fac41ities." (PSAR 1.1) .

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'I But APS lacks the technical and managerial competence to perform these functions in a manner consistent with protecting the public and safety. 'ealth One example of the lack of. technical competence on the part l of APS occured in the final weeks of l974. On December 26, 1974, APS advertised a $ 2,500 reward for information leading to the con-viction of those responsible for turning off a main valve control-'ing the El Paso gas supply to Bisbee, Viarren, Lowell and Naco, Sonora. The cutoff, deprived 3',500 to 3,700 APS customers of heat 10 for 36 to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> over Christmas, the third such cutoff in as many weeks. Each individual meter had to be turned off and on 12 again after pressure in the line was restored; 100 service people 13 were required to relight the pilots in sub freezing cold tempera-14 tures.

15 A competent utility would have taken steps to prevent a 16 second occurrence, let alone a third cutoff in the area since the 17 affected valve was clearly indentifiable.and should, could, and 18 have been protected from tampering.  !

19 APS, the manager of the Four Corners fossil fuel plant near 20 Farmington, New Mexico, also grossly underestimated the ash handl-,

t 21 ing capability of the plant, forcing shutdown of the generators in 22 l97l/2.

23 Additional shutdowns and/or curtailments resulted from fail-24 res to maintain operation of the scrubbers and fans required to I

25 Q.imit stack particulate emmissions at the Four Corners and Navago 26 lants.

27'8 APS lacks the competent staff'nd lacks experience in the management of' nuclear facility. Failure of APS to respond prompt-29 ly to a serious and highly visible safety problem; with the well-s I

30 known and simpler problems of natural-gas piping and valves is a II 31( clear indication of APS management's lack of attention to safety 32 problems. APS management practices have allowed ma)or design de-fects in its fossil-fueld facilities. Petitioners have little

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reason to expect that APS will exhibit the higher levels of tech-nical and managerial competence required for operation of a nuclear facility in a manner ensuring public and health and safety.

APS, rather Chan fulfilling its safety analysis responsibil-ities is merely relying on vendor and AEC safety evaluations. In taddition, APS also intends to delegate responsibility for quality assurance during construction of PVNGS to the Bechtel Corporation and to Combustion Engineering. Since Licensing Boards must in-quire whether there is reasonable assurance that the Applicants 10 will carry out the proposed prospect under the terms of its license, 1 the absence of a positive finding that such reasonable assurance 12 of a willingness and desire to adopt a positive managerial attitude 13 to carry out such a prospect in accordance with AEC regualtions 14 should result in a denial of the construction permit.

15 Decommission of the PVNGS 16 The Application is deficient in treating the uture decom-17 mission of the PVNGS. The unique problems associated with nuclear'ower 18 plants and the desert environment require particularly de-19 tailed attention to this aspect prior to the licensing of the 20 plant. The method must be appropriate to the site and future con-21 ditions in the area.

22 23 II. Lack of Technical Data 24 Informational Basis of Che Decision 25 It has been demonstrated that the AEC, on a number of oc-26 casions, has withheld or misrepresented substantial information 27 related Co the safety and licensing of nuclear power plants, thus 28 calling into serious question the validity and completeness of the 29 body of information upon which the petition of the Applicants is 30 debased.

I In view of the present reorganization .of the governmental apparatus pertaining to this field, no decision should be rendered 31 l'n 32 this case until all material relevant to this proceeding which 10.

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was supplied by the AEC is determined to be correct and complete.

III. Financial Stability of the Applicants Financial Qualifications of the A licants Arizona Public Service Corporation and Tucson Gas 8c Electric, two of the ma3or participants in these proceedings are not finan-6 cially able to expend the vast amounts of money required to build 7

this plant at this time.. Bo'th companies are having difficulty 8

in the current money market attracting funds, and as a result have had to seek extensive rate increases and emergency rate increases 10 from the Arizona Corporation Commission. Salt River pro3ect, the third ma3or participant, has already had to greatly increase ratesI 12 to provide for current needs.

13 A. Financial Ca abilit of Arizona Public, Service Co oration 14 On the fall of 1974, Arizona Public Service Corporation 15 (APS) petitioned the Arizona Corporation Commission (ACC) for a 16 hearing on their 18 per cent rate increase request. Since the ACC 17 18 could not hear the APS case until February, 1975, APS represented their need as so great as to require an immediate interim rate in-19 crease. The case did not .go to a decision but was ad3ourned, to be 20 decided with the regular hearing in February 1975.

21 22 The regulatory climate in Arizona is such that it is likely 23 that the full amount. of the APS rate increase will not be granted and/or the effective date of any increase granted may be consider-24 25 ably delayed due to the ACC's heavy schedule and the action of intervenors in the APS case..

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- 27 EXAMPLE 1. In. 1972, APS requested a rate increase amounting to $ 21.9 Million. ACC granted only 51 percent or $ 1.3 28 29 million.

30 EXAMPLE 2. In 1973, APS requested a $ 12.1 million increase, 1

31 but was granted only 74 per cent of the request, or 49.0 32 million.

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APS, as manager of the Four Corners and Navago generating stations, has a heavy financial commitment to provide equipment for protection of the environment at those and other plants under their management. This financial commitment may weaken, at any time, the Corporation's ability to meet its commitments for the proper construction, Cooperation, and maintenance of the Palo Verde generating station. Since none of the Arizona applicants have in-volved the ACC in their planning for the Palo Verde NGS, and since the Chairman of the ACC has publicily expressed his irritation 10 and displeasure at being ignored by the planners of the PVNGS, timely rate relief in the future is by no means assured.

12 B. Financial Ca abilit of Tucson Gas and Electric Com an TG&E 13 TG&E has applied to the ACC for permanent or energy rate 14 relief in each of the years 1971, 1972, and 1974. The 1971 TG&E 15 request for $ 5.3 million was vigorously, opposed by intervenors 16 representing the City of Tucson, the United State Government on 17 behalf of Davis Monthan Air Force Base, the mining customers of 18 TG&E, and the Arizona Consumers Council. The ACC denied the rate 19 increase request in full.

20 The 1971 TG&E request for $ 5.8 million in additional revenue 21 was again opposed by several of the same intervenors. The ACC 22 granted 79 percent of the requested increase or $ 4.6 million.

23 On January 29, 1974, TG&E applied for a 30,1 percent rate 24 increase to bring the Company's revenues up to $ 149 million. The 25 hearing before the ACC began on April 15, 1974, with intervenors 26 opposing the increase on behalf of the residents and government of 27 the City of Tucson, Pima County Board of'upervisors, the mines,

.28 and consumers. The hearing adjourned on Nay 9, 19'(4, and on June 29 ',5, 1974, the ACC directed TG&E.to revise 12 month test period l

30 lending Dec. 31, 1973 to a 12-month test period ending July 31, 1974, 31

~with the hearing rescheduled to reconvene on October 15th, 1974.

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Sk On November 12th, the 17th day of the reconvened hearing, TG&E requested an emergency interim increase by November 13th of 13.6 percent increase, in addition to a 10.5 percent increase granted in May, 1974 subject to later review and eventful refund, was the I ~

minimum necessary to ensure TG&E's financial survival, according I to Mr. T. M. Welp, Chief financial officer. Without the immediate interim increase, Welp testified that TG&E could not meet its cash needs "i.n the next,six weeks", which amounted to $ 11 million in debts due by Nov. 1. The emergency rate increase 'was needed 10 to float a:.P4 million bond issue in Mid-December which had been recalled by TG&E in October when the ACC refused to allow the in-,

12 clusion of the San Juan transmission lire in the rate base.

13 On November 13, the ACC granted an interim rate increase

~ ! 14 to raise additional revenues in the amount of $ 17,640,000, subject 15 to review and possible eventual refund in 1975. TG&E immediatley 16 obtained a $ 12 million loan from the Bank of America to pay-the I

h 17 $ 11 million debts jue November 1st by mortgaging its oil invent-18 ories. The loan pushed TG&E's short term back credit lines to 19 their maximum of $ 126 million.

20 Since its application for 15.4 per cent share in the $ 2.2 21 billion Palo Verde prospect, TG&E has onsidered cutting its partio-22 ipation to 8 per cent. The petitioners urge the Hearing Board Co 23 re-examine most closely Che financial capability of TG&E to guar-24 antee adequate resources Co participate in the Palo Verde Prospect.

, 25 Should TG&E be found to be financially incapable of partic-26 ipation, at the 8 percent or lower rate, the'inancial capability I

27 of the other participants may render Chen unable to assueg TG&E's 28 I hare. APS, i/view of its pleas for interim rate relief pending 29 its 28.4 per cent participation, let alone some higher percentage t

30 to take up the loss of TG&E in the prospect.

31 TG&E's franchise with the city of'ucson will be up for re-negotiation in April 1976. The outcome may influence the financial 13 ~

condition the city has the option to condemn the utility in whole or in part and has indicated opposition. to TG&E's participation in PVNGS. TG&E has considered dropping 50$ of their 15.4$ part-icipation in PVNGS and may have to reduce their participation further.

Due to rapidly increasing energy costs the mines are con-sidering in-house generation'. This would cause the participants P

to become completely incapable of financing PVNGS since they depend on tQe mines for a ma5or portion of their baseload (TG&E depends 10 on the mines for baseloads of 86/ load factor).

Xn light of the past performance of similar nuclear plants, 12 low capacity and availability factors, and unusally rapid nuclear 13 plant costs, which can be expected to continue, this prospect will 14 further endanger the financial stability of the participants,

.15 rendering them financially incapable to build and operate PVNGS as 16 well as causing damage to their stockholders and increased rates to their customers.

'18 'TG&E~s .stock prices are now at their lowest levels in the 19 company's history.

20 TG&E has shown no interest in developing an efficient plan 21 of'conomic dispatcher for 9 generators under their management 22 more efficient use of present equipment could result in savings in 23 power and money. Resources are now mismanaged.

24 Salt River Prospect has extended by nearly a year it's con-I+4 25 struction schedule for the Coronado Generating S~ near St. John',

26 an increment of purchased power for the summer of 1978 will meet 27 demand without the 1st in line till Spring 1979.

28 350 biW will go on. line in 1979 with 2 additional 350 Ni 29 generators still to be scheduled to go on line after 1979, 30

,eliminating the need for additional power until 1980's 31 Higher capital costs and cash of money penalizes present 32 rate payers, costs being borne by rate payers who may not benefit

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from the investments.

Higher rates will further decrease consumption, requiring higher revenues which will further construct demand.

Benefit-Cost Anal sis The Applicants'enefit-cost analysis. (Table 11.3-1) suffer from many deficiencies .including; A. The escalation rate of 10$ /year for required capital cost of the combined facility and transmission lines should be higher to be more realistic, perhaps as high 10 as 12K.and, 15$ .

B. PVNGS will not supply "almost 4000YiH of capacity" 12 (ER 11.2.2) as Applicants claim. The nominal net, 13 generating capacity for the three 1270 MWe units would be 3810 MWe. Neither would the 80>+ availability 15 capacity be likely to be reached. Less than of'icensed 16 65$ is a much more realistic estimate during the first 17 three years of opera'tion. Thereafter, availability 18 steadily declines to an average of 32 to 344 between 19 the third and seventh year of operation for plants of 20 the PVNGS type. (see Comey, D., Bulletin of Atomic 21 Scientists, Nov., 1974). This decline in power avail-22 ability places a crushing economic burden on the utilit 23 and its rate payers who are heavily committed to nuclear 24 generation.

25 C. Applicants fail to show either that coal is an scarce 26 or as high priced as alleged. APS> TG&Z and. PSNM, 27 among others, hhve represented their extensive 35-yr 28 coal leases in the Four Corners area as Justification 29 for such remote mine-mouth plants. Participants in 30 Four Corners area fosil-fuel plhnts claim 994 effective 31 emmission control devices. If accurate, plants equip-32 ped with such controls represent a smaller long-term 15.

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threat to fragile desert environments than PVNGS with all its unresolved safety problems.

3 Xndirect Costs D. Applicants fail to include under indirect costs, the costs of replacing 104,000 Acre-ft/yr to the Phoenix aquifers. The effluent water, needed by PVNGS, variously cited as 35,000A'-ft/yr/unit, 78,000 A-ft/yr total for three units, and 104,000 A-ft/yr, has been returned to the Salt River where it recharged, the aquifer system 10 or filled other consumptive needs. Granting that the Applicants receive all .the water needed for PVNGS at a I 12 cost of $ 20 to $ 30 per acre-ft, the taxpayers in Phoenix 13 (and Arizona) may have to replace that water at the es-14 timated .CAP urban cost of $ 100 to $ 190/A-ft p?us tax 15 assessments. Reliance on the CAP is risky since Congress it 1

16 may not fund fully, water may be unavailable once I

17 Indian allotments are firm, and water importation after'978 18 may not materialize.

19 To the costs of PVNGS must also be added the loss of op-20 portunity costs to invest the capital expenses in alternative 21 energy programs which could remain viable sources of energy beyond 22 the life of PVNGS or its fuel-supply guarantees. Xn the long-23 range view of energy alternatives, nuclear power generation must 24 be considered a stop-gap measure dependent upon rapidly exhaustible 25 uranium ore.

26 Fuel Availabilit 27 Given the sudden upsurge in numbers of proposed nuclear 28 plants, current estimates of available uranium ore, the continuing 29 lack of fuel reprocessing plant capacity, and the lack of long-30 term storage facilities for nuclear wastes, investment in PVNGS,,

31 which has only a 24 to 36timo. firm commitment for fuel> represents 32 a poor financial .risk to prudent investors.

Fossil Fuel Alternative:

The Applicants fail to analyze. adequag.ey the fossil-fuel alternative to nuclear power (ER 9.2.1 and ER 9.2.2.3.1). No benefit-cost analysis of using smaller fossil-fueled plants to-gether with intensive energy conservation measures to meet pro-

/ected needs is given. The fact that, without PVNGS, the reserve margin is still estimated for 1981 to be over 20 per cent indicates

~ 8 that a prospect as large as PVNGS is not needed now.

No mention of the higher capacity factors of small- and 10 medium sized fossil fuel plants is made. The 'availability and costs of coal in this region as estimated by the Applicants may be 12 open to question, since many coal leases are controlled and priced 13 by the Applicants themselves.

14 Need for the Facilit 15 The Applicants'nvironmental Report has not established 16 the need for the facility. The purpose of'VNGS is given as the 17 need for power to "provide the load requirements forecast" which 18 are based on a "combined average annual growth for the 11-year 19 period ending in 1984 of approximately 8.6$ ." (ER 3..2). The Ap-20 plicants review of the need for power within the Applicant's 21 service area is inadequate and overlooks or rejects without anal-22 ysis a wide range of'elevant factors that are receiving extensive 23 consideration from energy-policy planners in this country.

24 Specifically, the Applicant's analysis of the need for 25 power consists of crude trend extrapolation. No model analyzing 26 any type of 'need's presented. The Applicant fails to seperate 27 out wasteful and inefficient consumption of electric power from 28 necessary consumption for some useful end. The Applicant fails to 29 consider the effect of promotional rate structures and the in-

,30 flated energy use they create on the alleged need'or power. l 31 The Applicants fail to analyze the revised rate structure 32 (a "Flat Rate Structure" ) proposed by TGRE to the Arizona Coroora-17.

tion Comnd.ssion and accepted on Dec. 26, 1974 Chat, among other:;

effects, would reduce energy demand. The Applicants fail to ana-lyze the impact of the large industrial users, due to TG&E's pro-posed flat rate structure, generating their own power and thereby greatly reducing the need for added capacity and making PUNGS a very great inancial burden on the Applicants, their stockholders, and their customers. TG&E d'epends for baseload (86/ of load factor (1971 TG&E rate case)) on the mines, primarly copper mines. Fore- ~

casts for copper production are being reduced and will fall further.

10 Lower copper prices, lower grade ore bodies, higher labor costs, and greatly increased energy rates (up over 305 in the proposed 12 TG&E rate structure) are making Che copper companies look at In-13 House generation of electric power.

14 The Applicants mention (ER 9.1.6.1) but fail to evaluate I

15 other rate structures that would further tend to reduce the pro-16 /ected need for power and the effects of Energy conservation I 17 measures such as, developing new standards for insulating new and 18 old residential and commercial office buildings, by the introduc- j 19 tion of heat pumps in place of resistance heating, developing new 20 lighting standards for buildings, adopting energy efficiency label-k 21 ing of new appliances, developing new standards for appliance 22 efficiency, restricting wasteful use of electricity for space heat-'

23 ing, air conditioning, promoting efficient industrial,and commercial

.24 operations and processes, and the widespread use of solar heating 25 and cooling, which would have a ma)or effect in Southern Arizona, 26 and Southwest in general, during the period in question.

27 The Applicants fail to consider measures designed to flatten 28 peak loads, including time of day metering (charging more for elec-29 ~tricity used during periods of peak demand), load staggering, and 30 I selective load shedding (by claim of'ustomer or category of use).

31 Rather than an investigation of the aforementioned factors 32 that influence the demand for electric power, the Applicants rely 18.

on forecasts which simply prospect modified past growth rates with out taking intb account the nationwide need and effort to conserve energy and greatly lower the energy growth rate. What, basis, if any, exists for what specific assumptions, if any, that lie behind the applicants forecasts is not analyzed in the applicants'n-6 vironmental report. Historical accuracy, (or Inaccuracy), alone 7 does not lend validity to the Applicants'orecasts. Its validity 8 would have to be based on a comprehensive analysis considering factors noted above, an analysis completely lacking in the Appli-10 cants'eports.

There is little Justification for the risk to the public 12 health and safety and to Che natural environment of nuclear power 13 plant operation power for activities'of little or no value to the 14 society. The considerable public and governmental attention being 15 given to Che role of energy conservation in planning our soci'ety's 16 energy policy contrasts markedly with a complete lack of attention 17 to this vital subject in the Applicant's Environmental Report.

18 The NEPA mandate .to inc1ude consideration of alternatives to the

>8 proposed action plainly requires the active consideration of energ 20 conservation being urged by the Petitioner.

21 Further doubt is cast upon the Applicants'eed for PVNGS by the overly great reserve margins the participants wish to main-23 Cain, margins in excess of 28 percent (ER 1.4} and as high as 42.84 24 Reduction of reserve margins to less excessive amounts more in line 26 with FPC recommendations, along'with existing interconnections, 26 would reduce the need for PVNGS great1y. The over creation of re-

- 27 serve margins would cause a severe financial drain on the utilities 28 and their stockholders as well as force higher rates for the con-29 sumer. In addition the use of such large units as proposed for 30 iPVNGS would cause a loss of system reliability due to their size 31 ,'and the low availability and capacity factors that can be expected 32 ,from nuclear generating stations of this type. Delay or denial of" 19.

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1 PVNGS would not cause undue hardship on the participants or their 2 consumers and indeed would be to thei'r benefit.

Finally according to a report of Theordore Berry h Associ-4 ates dated Oct. 28, 1974, TG8fE's sales of KWH sales rate growth 5 which had averaged 134 for 10 to 20 years before 1974, grew at 6 only 1+<in 1974. Clearly conservation measures and increased cost 7 to the consumers has slowed the demand for electricity. On a national basis the average 7g annual growth rate in peak demand was reduced to lg in 1974. Secretary of the Interior Rogers B.

10 Morton now publicily supports a 2g growth rate per year to avoid wasteful consumption of electricity. None of these factors have 12 been fully analyzed by the Applicants here.

13 Additions: Need for Power 14 The Edison Electric Institute figures for the 48 contiguous 15 states show that production of electricity in 1974 equaled 1973 16 production figures due, to conservation efforts and sharply higher 17 electric rates. Wall Street analysis expect 1975 production to 18 rise only 1 to 3 per cent. above 1974 figures, although EEI is still 19 predicting a 7 per cent yearly growth in consumption and peak 20 demand from 1975 to 1979. The 7 per cent annual growth prediction 21 is the traditional utility industry's prediction, leading to the doubling every decade figures of which they are so fond. Mr..

23 Thomas Burband, an EEI statistician and vice president said the 3 per cent growth rate is -probably more realistic because of the 25 yearend worsening of the economy; the EEI figures were based on 26 predictions made in October, 1974. (The Wagl Street Journal, p. 2, 27 Jan. 9, 1975) t 28 The City of Phoenix reported that its energy conservation 29 programs during the last 10 months of 1974 reduced consumption of l

30 electricity and natural gas by nearly 30 per cent from 1973 usage.

31 The 30 percent reduction was evidently painless since it was 32 achieved by eliminating night lighting and lowering thermostat 20.

1 Isettings.

Population growth rate is clearly falling in Arizona as in 3 the rest of the nation, the number of five year olds having drop-ped by 4,000 in gust the Tucson area over the past few years (CAP I

,testimony, TCC, Jan. 9, 1975).

In July, 1974, the state's population was estimated by the U.S. Census Bureau to be 2,153,000: At the rate of 1,000 MN de-mand estimated for each 500,000 people, Arizona would need slightly 9 more than 4,300 MN to serve its population. It is generally ac-10 cepted that the economic downturn will cut the estimated population I

figures predicted on historical trends over the past decade; the 12 estimated 2.8 million by 1980 and the 4 million expected by 1990 13 are no longer trustworthy.

14 If the Applicants'lanned additions are all met on schedule, 15 the following additions would obviate the need for the PVNGS as 16 now .planned. APS, .through its subsidiary, .Resources Co., plans 1I to begin construction of a coal mining complex to serve the Kai-18 iparowits power prospect, along with three other companies. The 19 rogect involving Southern California Edison, Arizona Public Service, 20 SRP, and San Diego Gas and Electric will serve the Southwest with 21 the first of four 750 hà units scheduled for operation in 1980; 22 3,POO MW operations are scheduled by the end of 1982.

23 In addition, SRP announced on Jan. 9, 1975, sold $ 60 mil-24 lion in bonds at 8.1 percent interest rate, the highest in company.

I 25 history as part of a $ 170 million bond sale Sor 1975. Proceeds J

>S trill finance construction on the NavaSo Generating Station, the I

second unit of the Hayden Generating Station in northwest Colorado

'and the Coronado Generation Station near St. Johns.

Since 24 per cent of the Navago Generating Station is com-mitted for pumping CAP water, a highly tenuous prospect not favored 31~by a maJority of the citizens heard at Tucson's public hearing on Jan 9, 1975, that power may yet be available for sale in Arizona.

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Failure of the CAP to win congressional funding would clearly make 2 the PVNGS unnecessary at this time to meet Arizona's pro)ected electrical energy needs.

Alternatives to the Facilit As previously noted, the Applicant failed to consider energ conservation as well as other energy sources as alternatives af-fecting the need for the f'acility.. Given the need for additional energy, the'pplicant would further be required to show that there was a need for additional electric energy. The costs and benefits 10 of meeting energy needs for specific energy sources must be eval-uated.

12 For example, with present technology, space heating can be 13 accomplished in different ways. The advantages and disadvantages 14 of'roviding the space heating using heating plants located in 15 individual buildings, versus central station supply or electricity 16 for heating purposes, .must .be considered. Additionally, the"devel-17 opment of alternative technologies to meet additional energy. needs 18 versus reliance on the nuclear alternative would have to be con-19 sidered. The costs and benef'its of developing solar, geothermal,

'20 and other sources in a,:timely way to meet incremental energy needs versus reliance on the facility would have to be determined.

22 Through the use of energy conservation and solar heating and cool-r 23 ing, the need for additional electric power can be delayed until solar electric generating stations will be available in the South-25 west. Commercial solar plants can, according to studies by AEC, 26 NASA, NSF and various other agencies, could be in operation in the 27 same general time frame as PVNGS and would involve far less risks i

28 while providing benefits to the area greatly in excess of'hose 29 PVNGS. The Applicants 'nvironmental report fails to discuss these 30 alternatives in depth much less to analyze them in the manner're- I 31 Iquired under NEPA. Mere mention and dismissal of alternatives 32 22

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(ER 9.2) can not be considered an adequate analysis. The use of interim measures, such as conservation and solar heating, would allow the lead time to develop alternatives, such as solar-thermal (not even .mentioned in the Applicants'analysis" of solar energy (ER 9.2.2.5)) to the point that firm planning could be safely base on them.

7 ZV. Effects on Community Defense, Security, Health and Safety of the Public Securit of the Pacilit 10 Neither the PSAR nor the AEC regulations adequatley address t'e problems of maintaining security to counter theft, sabotage and other acts of aggression against he facility and the systems supporCing it. Xn addition, procedures for handling hazardous 14 materials appear to be quite deficient. Requirements for the phys-15 ical security of special nuclear materials and accounting methods 16 designed to keep Crack of them are not included, a serious defi-17 ciency. Measures stringent enough to guarantee public health and 1S safety in these areas may be impossible to enforce under the 19 American system of constitutional guarantees. Certainly a federal 20 police force would be offensive to most Arizonans.

21 S~aboea e A federal investigation has shown commercially operated 23 nuclear powerplants to be vulnerable to sabotage. Licensee and I

24 AEC officials agree that a security system at a licensed nuclear I

powerplant could not prevent a takeover for sabotage by a small 26 number as few-perhaps, as two or three of armed individuals. Such 27 a takeover could threaten public health and safety, if radioactive 28 materials were released to the environment as a result of succes-29 ,sful .sabotage.

I 30 National Securit Considerations The Applicants fail to treat the danger to national security I

31 II

'32 posed by the possibility of an accident or incident affecting an I

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area within a l0 to 15-mile radius of the site which could disrupt" vital national security functions dependent. upon the area's nat-ural gas compression station and four pipelines; the S. P. petro-leum product pipeline and railroad; Luke Air Force Base; and Tnterstate Highway 10 (now under construction).

Xn time of war, the facility would be prime target. Damage to the facility by enemy action or sabotage could prevent use of highway and rail evacuation routes from the heavily populated Phoenix metropolitan area.

10 Arizona also has l8 Titan missiles situated in the state.

These Titan missiles, along with the Air Force bases throughout 12 Arizona places it very high on an enemy's target list.

13 Aircraft 14 Contention 15 The Applicants have failed to treat adequately (PSAR 2.23.6) 16 the danger to the PVNGS posed by the activitie's of military, private 17 and commercial aircraft over and around the proposed site. The 18 Phoenix area airspace contains l9 prohibited, restricted, warning 19 alert areas specifically listed on FAA charts. MLlitary get t'nd i

20 fighters and trainers as well as commercial get traffice continual-21 ly traverse the air space with,the potential for collision with 22 the PVNGS facility or with each other in the vicinity of the site.

23 -

Concentrated student get transition training, including .-

24 steep power dives and "dogfight" maneuvers, near the PVNGS site 25 may expose the containment vessel to serious danger of penetration 26 by sharp-nosed get fighters.

27 The December 17, 1974, midair collision between a T-38 28 trainer and an F-4 Starfire get fighter during a practice dogfight' 29 near a Gila Bend demonstrated the danger.

30 Should double containment be fudged necessary, the effect 31 upon the benefit/cost ratio,'.would have to be examined.

32 24.

Trans ortation of Hazardous Materials The Applicants have failed to propose additional safeguards for the rail transportation of radioactive and hazardous materials they propose to ship to and from the facility over the Southern Pacific railroad. The SP was singled out by the Arizona Corpora-Commission for its extremely poor safety record within the

'ion 7 state.

8 Xn the first nine months of 1974, 19 accidents on the South em Pacific Railroad in. Arizona resulting in approximately $ 1.7 10 million in damages. On January 9, 1975, Senator Bob Hungerford of Scottsdale announced that he will investigate charges that i

12 outhern Pacific has destroyed evidence of signal failures at dan-13 erous railroad crossings. Depositions by 0. N. Carter and E. M.

14 ardner in a Maricopa County Superior Court case in 1974 stated 15 hat Southern Pacific "burned a safety survey of their possession 16 hat showed that the company "strips damaging evidence from their 17 iles in lawsuits", Carter's depositions states that accident re-18 ords were destroyed so that the SP could win the 1971 Harriman 19 ward for Safety among the nations ma)or railroads. Southern 20 acific won the award that year.

21 Carter's deposition; further states: "The Southern Pacific 22 pparently does nothing to correct improper wiring until the fed-23 ral government, using taxpayers'oney, pays for the gates at SP 24 rossings".'rnest 25 Garfield Said the Arizona Corporation Commission will 26 ook into the charges.

27 The Commission sought to have the operating speeds reduced 28 n the company's lines in an effort to cut the high accident rate 29 I on the SP system. A recent accident near GT& Bend resulted in 30 Ii extensive damage from carloads of explosive shells and bombs; other 31 I ccidents involved spillage of toxic materials partial evacuation 32 25.

1 of a town dut to the release of a poisonous gas, and an engineer 2 accused of being asleep at the time of an accident. The Applicant 3 simple statement that all applicable regulations will be satisfied 4 (PSAR 11.5.7) is clearly insufficient assurance.

Transportation of nuclear materials occurs between each 6 stage of the nuclear fuel cycle. This widens the opportunity for 7 accident or theft, "There's no question transportation is our 6 weakest line, " says a spokeman for the AEC'. "lf a terrorist is 9 going to make an attempt, that's where he'l make it."

10 Most nuclear materials now travel by truck. Truck routes 11 often involve thousands of miles. of freeways, turnpikes, and other 12 public roads. While theft is a ma/or concern of the AEC, the

>3 threat of a radioactive spill is the deepest concern of the rail-

>4 roads. Radioactive materials such as spent fuel rods are hauled 15 from plants in train cars mixed with other freight moving at high 16 speeds along regular rail routes.

17 These "very hot" fuel shipments might be damaged in col-

>6 lisions, derailments or fires, causing their contents to spill out. The countryside and the right of way would be contaminated 20 with radioactivity for long periods of time.

21 Price-Anderson considerations 22 It is clear that in the present economic climate, the finan cial condition of both TG&Z and APS, originally responsible for a total of 43.5.per cent .participation, may preclude their abilities 25 to compensate for damages beyond the Price-Anderson liability 26 limitation, although such damages may occur as the 1964/5 AEC/

Brookhaven study and other, recent studies documented. It is un-reasonable to expose the population living in the vicinity of the if facility to a safety risk the Applicants will not or can not accept the attendant financial risk.

31 The financial qualification is further shown to be in doubt 32 by the possibility that the Price-Anderson Act may not be extended 26.

forcing the applicants to provide coverage which, if available at all, will raise the costs of PVNGS greatly. En addition, the Ap-plicant has failed to demonstrate that it has the financial cap-ability for paying damages in the event of a ma5or accident in the event of repeal of the Price-Anderson Act.

The citizens of Arizona are covered only by the Price-Anderson Act which set a ceiling on payment of $ 560 million for one catastrophe.regardless of the size of the real damage. About 80$ of the $ 560 million is to be paid by the taxpayer not the AEC 10 or the utility. We, %he taxpayers, have underwritten the costs of insurance for the nuclear-power industry. We feel that the utilit 12 who builds the nuclear plant should assume greater financial res-13 ponsibility in case of a nuclear accident.

14 Xn as much as the damages which could arise due .to the PVNGS 15 subs'tantially exceed the $ 560 million limit set by the Price'-

16 Anderson Act, it is -clear that the available financial protection 17 for Arizonans is alarmingly inSufficient. The existence of such 18 a condition is anathema to the wellbeing of the citizens of this 19 state. No license should be granted until sufficient protection 20 is provided.

21 V. Environmental Problems 22

~Sf t'. 1n 23 The site for PVNGS Is not acceptable, since by the Applicants'wn 24 population-growth-rate estimate, the number of people which th 25 26 facility is supposed to serve will exceed the upper 2-million-persons-within-49-miles of the plant criteria before the plant is 27 28 fully on line. A recently released AEC study, which determined that a ma/or reactor accident could have the potential to create 29

'a disaster area equal to the area of the state of Pennsylvania, 30 I appears to rule out the PVNGS proposed-site as being too close to 31 the state's ma)or urban area. The .dusty arid area surrounding the "

32 facility could magnify the danger in a nuclear accident, since 27

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blowing dust could act as a vehicle for transporting hazardous substances over great, distances and/or'hold hazardous substances in suspension during a temperature inversion of the type common to the region.

No Justification was offered by the Applicants for poten-tially exposing Arizona's largest population concentration to such hazards.

In particular, the close proximity of'he PVNGS to one of the largest metropolitan areas in the Rocky Mountain region when 10 so many more remote locations are available is reckless and ir-11 responsible in view of the vast destructive capabilities associate 12 with the PVNGS. Any economic advantage this site may give to the 13 Applicants is far out eighed by the inability of the applicants to 14 protect the lives of local residents or to provide adequate com-15 pensation for damage in the event of possible mishaps.

16 The Applicants, in their haste to screen possible Arizona 17 sites, have not shown that more advantageous sites do not exist 18 in the service areas of'ublic Service of New Mexico or the El 19 Paso Electric Company.

20 No thought was evidently given to the long range consider-21 ations of establishing a nuclear park area for long range future 22 expansion and isolation of nuclear facilities.

23 The Applicants consistently cite their need for new gener-24 ation by 1981 as a reason for hasty preparation of the draft en-25 vironmental report without firmly establishing proof of that need.

26 ,Site To o ra h 27 The Applicants have failed to consider the effect of the 28 two mountain ranges, one to the north and one to the south, of 29 Interstate 10 (now under construction). With all main population i 30 centers lying either east, southeast or northwest of the PVNGS 31 site, these mountain ranges would help funnel gaseous releases 32 both planned and accidental, toward those population centers.

'8.

Contention The Applicants have failed to adequatley evaluate the po-tential risk of seismic activity at the PVNGS site, (ER Vol. V, Sec. 92.3.1.2) choosing, instead "to rank regions on the basis of the expected ease of demonstring the suitability of the sites to regulatory authorities within the time frame specified for the prospect."

On December 27, 1974, Dr. William Sauck, an Assistant Pro-9 fessor of geology at Arizona'State University, issued a warning 10 to planners of nuclear prospects in the Phoenix area (Tucson Daily Citizen). Dr. Sauck cited two recent seismic events, the first 12 such occurances in 104 years centered at New ~ver, '20 miles north 13 of Phoenix on 1-17 on a heretofore unidentified fault located in an area of broken rocks. The first event which occured on December 15 19, 1974 measured 2.5 on the Richter scale; the second event; on 16 December 23, 1974, measured 3.0 on the same scale.

17 The licensing board should require a rigorous examination 18 of the proposed PVNGS site for compliance with seismic criteria.

19 Water Re uirements 20 The Applicants predicate the feasibility of PVNGS in an ari, 21 water-short area upon the standard forecasts for continued pop-22 ulation growth in the Phoenix area. In 1974, only about 69,000 23 acre-feet of effluent is available to the applicants from the two 24 treatment plants. When PVNGS is in full operation with three 25 units on line, at least 104,000 acre-feet per year will be require 26 a total of 1,400,000 acre-feet over the life of the plant. The 27 Applicants have no assurance that either the water will be avail-28 able as needed to meet the needs of the facility or that no legal 29 challenges by earlier contractors will develop to prevent purchasing 0

30 the water at the expected $ 20 to $ 30 an acre-foot.

31 The Applicants mention in ER Vol V, pg. 12.1-7, Table 12.1-32 1, contact made with the State of Arizona Land Department seeking i 29.

authorization to construct a dam without further detailed mention of any such planned construction elsewhere. Petitioners request 3 clarification of Che plans regarding a dam in the Applicants scheme for PVNGS. Should such a dam be connected with the Arizona Prospect, petitioners request full information about the Central'0 proposed prospect. Funding for the CAP is considered tenuous at best in 1975. Under the act establishing the CAP, any discussionsI even without firm figures for portions of water to be allotted to various Indian tribes, is oversubscribed. As the applicants them.

selves state, groundwater pumping is not a viable alternative for the PVNGS water requirements, especially. in view of the danger to l

12 Che. facility f'rom subsidence resulting from pumping operations.

13 The Applicants fail Co consider and describe",any plans 14 they may have f'r ensuring the security of the effluent pipeline I

I 15 (s) supplying the facilities water requirements. Forty to fifty 16 miles of pipeline would be hard to patrol,.less alone guard. to 17 prevent sabotage, which could shut down PVNGS eventually. Any in-18 terruptton or break Xn the plpellne(s)'r Pallure of the treat-19 menC plant(s) could produce shutdown of PVNGS in a short time.

20 The Applicants have not adequately accounted f'r loss held in ponds and the reservoir on site due to evaporation of'ater 21 22 under worst day conditions, given a loss of'ater through the 23 pipeline(s) or failure of the treatment plant(s) to maintain ade-24 quate water quail.ty.

25 Under worst day conditions of high summer humidity during 26 summer rainy season, loss of cooling tower effectiveness has not l 27 been adequatley treated by the applicants, nor have estimate of 28 cutback in power production to accomodate Sor such conditions been 29 lARd e ~

30 ~ER Re ort h31 The Environmental Report shows throughout a great haste on 32 the part of the Applicants who have not given su ficient data to 30.

support their contentions. (ER 2.6.2.1) -For instance, the data supporting ER sections on ecology, 'meterology, and hydrology were collected from August, l973, to February, 1974 without data for the months March to August being available. Since conditions bet ween March and August vary greatly in this harsh arid region from those of the milder fall and winter months, Applicants are asking for decisions to be based on insufficient data from the site pro-posed.

Applicants are not consistent in the use of the meteorolog-10 ical data, since they regect Che wind data gathered at Luke Air Force Base as being from defective, improperly maintained instru-12 ments, while at the same time selectively choosing to use some 13 Luke Air Force data as the basis for a NUS computer program MZNDlF 14 (pg. 2.6-10, ER Vol. XX). Applicants claim the wind rose data 15 from LAFB yields an excessive number of calms.

16 Applicants fail to show that dispersion of gaseous releases 17 would meet AEC requirements at site boundaries during fall and 18 winter seasons when a quasistationary anticycl'one has developed.

19 (ER pg. 2.6-9). Under such conditions, according Co Holzworth, 20 there is a 48 per cent probability that a stagnating high will 21 persist for more than two days, and a 20 per cent probability it 22 will persist for more than four days, with wind speeds less than 23 or equal to 5 miles per hour and MMMD less Chan 500 meters, with 24 average wind speeds as low as 4.7 mph.

25 Temperature "inversions" are peculiar to desert areas like 26 the PVNGS site, with nocturnal inversions occuring during over 27 one-third of both summer and winter nights.

28 No discussion of the effects of the localized dust devil 29 phenomena peculian to desert areas is given. Such dust devils 30 frequently raise clouds of dust thousands of feeC in the air and 31 disperse the dust over wide areas; they have been known to lift 32 small buildings and tear roofs from others. Should Che solid 31.

J waste, the sludge left from the evaporation process or other haz-ardous substances be exposed to a dust devil, dispersion over a wide area is possible. Dust-devils arise spontaneously and at random under summer heating conditions.

Applicants did not indicate spectral bands for noise measur ments estimated for the PVNGS'site boundaries. Db(A) measure-ments alone are not significant without ref'erence to the frequenci measured.

Com leteness of the A lication 10 Based on the foregoing, the Application and supporting data qubmitted to the AEC by the Applicant is lacking in necessary in-12 formation and fails to comply with 10 CFR 50.34, Appendix D to 10 13 CFR 50, Regulatory Guide 4.2, and to the standard format for pre-14 liminary saf'ety analysis reports.

15 Conclusion 16 Based on the f'oregoing, Petitioner contends that:

17 18

1. The Application f'r the facility does not comply with 19 the provision of'0 CFR 950.35(a);

2. The Applicant is not technically qualif'ied to design 20 and construct the f'acility; 21 22

3. That Applicant is not financially qualified to design and construct the f'acility.

23

4. The issuance of a permit for the construction of the 24 25 f'acility will be inimical to the common defense and securi'ty,.to the health and safety, and to the economic well being of'he peti-26 27 tioners and the public; and 28

5. In accordance with the requirements of Appendix D of 29 10 CFR Part 50, the construction permits should not be issued as 30 proposed.

31 Q.J, BARBARA E F S R 32 Arizona Public Law Advocates Attorney for Arizona Clean Energy Coalition 201 North Stone Avenue, Suite 210 Tucson, Arizona 85701

I

C' 1

BEFORE THE ATOMIC ENERGY COMMISSION 2

IN RE THE APPLICATION OF ARIZONA 3 PUBLXC SERVICE CORPORATION~ THE

'SALT RIVER PROJECT AGRICULTURAL IMPROVEMENT AND POWER DISTRICT,

,"TUCSON GAS t% ELECTRIC COMPANY'AEL AFFIDAVIT OF PASO ELECTRIC COMPANY OF NEW DONALD OSBOR jlMEXICO AND ARIZONA ELECTRIC POWER ICOOPERATIVED INC. TO CONSTRUCT AND OPERATE ARIZONA NUCLEAR POWER PLANT STATE OF ARIZONA, I

ss COUNTY OF PIMA 10 DONALD E. OSBORN, being duly sworn deposes and says:

The Petitioner Arizona Clean Energy Coalition (hereinafter 12 ACEC) is a coalition of individuals residing in the State of 13 Arizona who would be directly affected by the health, safety, en-vironmental and economic issues involved in the construction and operation of'his nuclear plant. Members of the coalition include 16 persons living within 50 miles of the plant site and throughout 17 the Phoenix area whose health, safety and property would be direct y 18 affected by this facility 'and persons throughout Southern Arizona 19 health, safety .and property may be affected by this facility. ,I.

'hose 20 and by any moethods used for transportation of radioactive materi-21 als to and from the plant. Members include consumers of food 22 products produced in the immediate geographic area of the facility 23 The adverse affects of the facility on the members of'he 24 coalition include possible contamination by radioactive materials 25 of foods produced in the area, as well as possible contamination 26 of the environment with radioactive wastes.

27 In addition, the transportation of radioactive materials 28 , resents a serious hazard to all the public, as well as members of 29 'CEC.

30 Members may be affected adversely by the reprocessing of 31 'spent fuel from the facil'ity.

32 ACEC includes members who are long time residents of Southern

Arizona and have an interest in the quality of the environment i.n this area that may be adversely affected by the facility.

Members have financial interests that may be affected.

Members'roperty may be damaged in the event of abnormal operation I

'of the facility to an extent for'which compensation will not be available as a result of the Price-Anderson Act liability limit;a-tion.

ACEC includes members who are stockholdersor shareholders n various participants in PVNGS. They have an interest in the 10 nonomic viability of the utilities and may be adversely affected ecause the facility may reduce the value of their holdings.

I 12 Members, are consumers of electricity of various participants 13 nd are rate payers who may be adversely affected by the economic ssues of PVNGS which would trend to increase electric rates. They 15 re, as well, directly affected by the policies and conditions overning en'ergy consumpti.on.

17 AECE membership includes, among others:

18 Donald E. Osborn; TG&E customer, Tucson resident 1802 East Linden Street 19 Tucson, Arizona 85719 20 Theresa Korn; TG&Z customer, Tucson resident 6801 Opatas Place TG&E stockholder Tucson, Arizona 05715 22 Jan Herwick; APS customer, Phoenix area resident 6321 North 52 Place Paradise Valley, Arizona 85253 Jonathan Marshall; APS customer, Phoenix area resident 7302 East Earll Drive Scottsdale, Arizona 85251 Paul W. Huddy; TG&E customer, Tucson resident 2233 East 5th Street Tucson, Arizona 85719 Peggy Spaw; APS customer, Phoenix area resident 1505 East Cherry Lynn Phoenix, Arizona 85713 Mike .Morris; APS customer, Phoenix area resident 334 West State Avenue, APS stockholder, SRP shareholder 31 Phoenix, 'Arizona 85021 24

Kevin Dali; APS customer, Phoenix area resident 615 Hardy f29 Tempe, Arizona 85281 Jim Hoganson, APS customer, Phoenix area president 6130 North Camelback Manor Drive Paradise Vally, Arizona 85253 Lois Becker; APS customer, Phoenix. area resS. dent 811 West 17th Place Tempe, Arizona 85281 James R. Fitsimone; APS customer, Phoenix area resident 425 East Fillmore Street Tempe, Arizona 85281 Dr. Andre Bruwer; TG&E customer, Tucson resident 4122 East 6th Street 10 Tucson, Arizona 85711 Pat Malchow; TG&E customer, Tucson resident 7150 East 30th Street 12 Tucson, Arizona 85710 13 Sue Wilkerson; APS customer, Phoenix area resident 2518 North 27 Place, within 50 miles of site Phoenix, Arizona 85008 15 and among others, following groups:

16 Arizona Friends Of The Earth P.O. Box 1893 17 Scottsdale, Arizona 85252 18 Tucson Consumer Council 1043 South Duguesne Drive 19 Tucson, Arizona 85710 20 Saguaro Ecology Club 6130 North Camelback Manor Drive 21 Paradise Valley, Arizona 85253 22 Arizona Nuclear Responsibility And Safety Committee 6321 North 52 Place 23 Paradise Valley, Arizona 85253 24 25 S 0 26 27 SUBSCRXBED and SWORN to before me this I/ day of January, 28 1975 by DONALD OSBORN.

29 30 o ry u ic 31

'My Commission Expires:

32 ~7$

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'~)p~z)()( ~ QG66 COND('rrS

~w Pv~&S NS6 TG: Reactor Safety Study October 31, 197$

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c r.0?~: Ca therine Z. ~uigg Vicepre sicient Pollution .~ Wvi onvenial Problems, Inc 5$ S. Brock'ray, -

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SUBJECT:

Zxe A- -Rasxussen Report: A Critioue 1 have many cuestions and cc.-.cerns regardir ~ the AZ-Rasmussen Reactor Safety Study. he follo~~ing ar just some of Chem:

'2he Scope Xs 1co Limited o 3e Rel>>'able The 'study 'oes not a6czess '-self +--large areas oX'isk arising out of the ope ation of U.S. com~ercial nuclear po".~er reactors Z'hese include the storage and disposal of radioactive vastes, transportation accid nts, s-",bof~ze re rocessi - of fuel or possible clandestizs thef' dive. sion of plu, onium that is created in all reactors.

Let 's take a look at jus one of these neglected areas--transaor tat'on accidentso Zhe Illinois Atomic Z-.ergy Co-..;-..~>>ssion in their 1973 report to the legislature earns "..oof'l" tl e tyoes of shipments, spent fuel ro "s and high-level ~aste p esent potentially the hipAest risk to tne citizens of .the State Accicents in the transportau. on o spent nuclear Xbel could not only cause great damage to land values but could be very dangerous for everyone living c.owwvind many miles of an acc dent. A rec nt

1~

University of M.chigan study finds that such an accid6nt ia likely'o release largeauantities of cesium as a gas ox'ex'osol.

'I Undex stable aeather conditions~ with wind only one mile per

'our, a person about one-half'ile downwind could x'eceive.a dose of about 160 rems Deaths of infants, voung children and .

susceptible pe'ople will occur at, this 'mseo . About 2 percent of'he people under the invisible radioactive plume of cesium will die of cancer A substantial area auld have to be evacuated Land would remain contaminated for many years, Pith a stronger wind~ the dose and the damage 'to life and property would be even

-more devastating t

'he

-Yiichigan repox estimates;that a baxe minimum of 162 serious accidents involving spent fuel casks will occur in the U.S. during a ten-year pexiod 20 to 25 years from now if r actcr s are-'built at the rate the AiB prospects.

Fas"=3 eeders Hot Considered

'Ihe study does not investigate the additional risk invo1ved in fast-breedex reactor s 'Hzxor mechanical ma1functions could lead to explosions in breeder reactors, and the;:.unavoidable release of plutonium 'during. normal,opera<on of breeders could 1~ "The Possibility of'e1ease of Cesium in a Spent-Fuel. Zransporta&o:

Accident." By 2v Y~rc Boss, Physics Dept ~ Univ. of'mchigan.

'.Prom Fallout on the Zreewa, by. IKriam Anderson, 1$ 7$ .

1' expose local populations to the risk of cancer. Many scientists, including Edward Teller, continue to have grave reservations about the b'reeder program. 'There <11 be some 2,500 lbs. of plutonium inside the core of 'he typical commercial-sized reactor envisioned for the 1980's, enough to make hundreds of Hiroshima-sized atomic bombs. If an accident scattered only a small portion of this highly lethal and durable substance (half-life:

2$ ,000 years) around the surrounding area, it would pose a grave threato When ~7's An Incident Become An .Accident?

The AZC-Rasmussen Study defines accident too narrowly. It states that "although there are, about 50 nuclear poMer plants now operating,

~

there have been no nucL ar accidents to date." Phis,is misleading...and the AW knows .it ~

2.

Here's what the AZD Pask Force Report has to say:

"Review of %he owerating history associated with 30 operating nuc3e ar reactors indicated tie t during the period 1/1/72 to 5/30/73 approximately 850 abnozmal occurrences were reported to the AZC. iiany of the occurrences were significant and of a. generic na ture requiring follow-up invest@ ations at othez plantso For ty percent of the occurz'ences were traceable to some extent to design and/or fabrication-rela ted defidiencies ~ The remaining incicents were caused by operator error, improper main tenaQc e ~ inadequate erec tion control, administrative deficiencie s, random failure and combination. thereof ~ . ~

Source:A~ iask Force erort: Study of Aeactcr Licensir. Process, bv AW Asst Director of regula tion, L.V. Gossick and 7 additional Ar experts, the Oc tober 1973 version; see also Stud of Qgalitv Verific aMon, ArD, Jan. 197$ , p15-17) ~

"The large number'of reactor incidents, coupled with the fact Cha C many of them had z'eal safety signiQcance, were generic in nature, and were not identified during the no'rmal design,'. Xabz'ic ation, erec tion, and pre-operational testing phases, raises a sez ious ouestion'egard.zx the current review and inspec'Cion pract'ices both on .

the part of the, nuclear industry and the AE Analvsis

.'ault-.tree Xs Faultv 7

Fault-tree analysis was developed" many years ago for -the Dept.

of'efense and NASA where- it.is now considered obsolete fhe fault-trees in this stuDy were'not developed enough The trees extend the ugh all the safety devices but not to .quality assurance.

Failures in quality assurance are assumed to be incorporated in the eauipment failure rate Ihe same goes for design, inspection and mainCanance errors (Fault tree analysis attempts Co =

list a13. of the possible causes of an accid ent in a diagram,resenbling an organ.zaQ.on chart, and Chen attempts to determine the lihlihood'f each possib3s fai1ure,')

William Bryan, formerly a zeliability expert' Ch the space program and now with the National Institute for Applied Research told a subcommittee of the California State Assembly that Che fault tree method is void only to "compare one desi:gn against another."

Reliability estimates are so soeculative, Bryan said that "the number is totally meaningless Zhere is just no way that number can mean anything in term's of Che real-world probability of fai'lure

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The insurance !level proyiaed by the Price-Anderson Act would. not meet all claims resulting from a, serious accident in a small, . I

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150-megawa t t r eac tor; I

A chart in the'tudy's sunznary..shows Basnnxssen 's maximum property damage figure Is $ 1,7 bill'ion. 'Yet, the= Price-Anderson extension gl will provide -only ~560 million 'for a total of 100 reactors..This amount is. supposed .to cover not only property damage but fatalities costso What. Evacuation Plans?

The Rasmussen I'

Report assumes P

population is.evacuated'-in time, that C

anQ Inguri:es as well as urtility "legal fees and: AH administrative 90 C

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percent of the endangered.

3 ~ ." 'K'A, a June, 197@report on e iacuaticns f'ound that a major obstacle to large scale evacuations is not getting people out in an orderly fashion, but persuading them to leave. in'the first. place, We Hasmussen report's summary states' Since nuclear. po>rm plants. have e'vacuation plans and sim,e there is warning time before radioactivity would be released 'to the envir-onment, it seems highly likely, that evacuation

.wou3d be eff'ective in the case of'uclear .

accidents 3~ vacua tinn .=.Isks-.~m valua tion, U. S. Environmental. Pro tec tion agency, Cf fi ce o~ .".aeia ticn iro.grams, June, 1971>.

In fact, the report recommends that:

the importance of evacuation in reducing accident conseauences suEgests that 'steps, be taken to ensure that these 'plans including the requirements for instr'umentation and monitoring are carefully worked .out.

However, state and local authorities have been told so many times that an accident won't happen that they have no plans at all in the event of a nuclear plant accident or a train, truck or plane accident involving r'adioac tive ma terials, The Ar confronts a minor problem here: How can it convince people Co-prepare themselves for an event it wants them to believe can't happen'? r Given the non-existent status 'of most plans, it hardly seems reasonable to assume 90.percent of the popu1ation would be evacua ted 1iemoers of'~ and 1 have queried our local northwest suburban civil def ense officials, fire depar trna nt s, police depar t ments

-~nd emergency hospital personnel regarding preparations for evacuation .in the- event of a 'serious radiation accident o Zheir response invariably '4s, ""hat evac'uation plans?"

'Q7 7 -Bdooonoentration in Food and Water'Vot Assessed rtasmussen estimates the exposure to people on the ground from the passi~ radioactive cloud, from material it deposits on

.the ground and from materia1 inhaledo He does not recognize radioactive exposure thru food and water,

1

r. ~ S Moconcentrationis not mentions d excep't for inhaled ma teri of genetic.'defects is.-limited 'to 20 years, or '. ala,'onsideration one generation. Injuries "++" are defined. as people nee.ding immedia te medical attention, Y

'hese narrow definition show a bias towards minimizing ths hazards of nuclear power, Whot about the Tlind?:..- ','Z.E

'asnnissep assumes that:the-wind direction is xand'om relative te 4

cities -and. tha.t.

r wiolent,weather -Xs ~o t,likely .'to. be .'a con-

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tributing" factor in a'arge scale 'accident, But;. th wind at

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• 4 some sites blows Bre" tly. to~iarDs popu1ated areas and.violent weathex can c ertainly affect:the. escape and distrkbution oX i

racK o ac tive ma ter al, Past Nuclear Ezaerience Too Limited 5

.nz; V The xisk projections rest on a very small experience base. Studies based on the design of just t~u light water coOled nuclear po~er plants were applied. to-gg others mow on line- in the U.S. and extrapolated. to cover the 100 or so which will .be- on line by 1980. Current projections call for. 1,000 nuclear reactors in operation in the U.S. by the year 2,000.

'ice figures "one-chance-in-a-billion" per plant per year of an accident have no meaning. Why not~,

~+ma cc xngury figures are oasea on eva uation o, a 1 0-megawat t reactor and not on the 1,000 megawatt reactors the t are built; today.

1 6

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I The first reason is the difficulty of predicti~ either the f'r ecpency or the conseouences of'uman error and malice. Error or malice

=

instantXy 'reduce thq catastrophe-odds from 1-per-billion to

~

near certainty,'stimates about the small chance of" a nuclear disaster depend on the assumption that operators of nuclear plants will make no serious errors duzi'pg emergencies; also, that no demented, or hostile people vill try, to destrov plants.

Second reason is,the lack of experience i4.th operating nuclear hard-ware Rcperts can do little better than guess when they as'sign reliability estimates to nuclear hardware, Furthermore, for g years the AW has had to 'scold and. to fine nuclear equipment firms, engin-eering f'irms, and utilities for unacceptably'loppy quality-control9 but according to a report in tl Ias Angeles Hmes, Dec 26, 1973, ~

the. industry is still unresponsive, Zhird reason is the unjustifiable assumption that nuclear safety-systems (some never tested) have been properly designed, This assumption denies all the recent nuclear surprises which show that nuclear engineers are failing to foresee all the design problems.

If 'the design of =a safety-system is defective, even perfectly work-ing hardware will no.t make -it effectiv.e, How Can You Be Saved b~ a Backup Svstem'ha t Doesn't 'lork~

Despite glib reassurances in the ?asrrussen study~ the f'act remains that a basic safety feature of all U.S. conurercial nuclear power plants - the emergency core coo1ing sys tern - has never 'been tested.

C k Results of the X'irst test, now in ~eparation, won't be known fora couple of'ears,-

Thyroid Illness Pinimized Barry Commoner has written: "Iodine-133. is a short-lived atom; in a matter of' few weeks any of it rele.ased "nto the environment decays of its own accord. However, . "iYjdine " is an essential

=

part of the hormone produced in t?I; thyroid gland; m that an animl - or 'child - expo ed M even low cow entrations of gydine:-131 quickly builds the atom into the substance of'ts thyroid gland, When iodine-131 is incorporated into the thyroid, Eland, and then decays, it leaves behind it in the cells of that gland microscopic tracks of severe molecular dam,ge which may in time lead to harmful biological chases,- avang which the most serious is thyroid cancer."

'Ahat do the Ar -Rasmussen people say'? . M.s: "Ihyroid illnesses that might result from a large accident are the formation of nodules on the thyroi'd gland that can be treated by medical procedures and rarely le ad to ser iou s mons equenc e s. "

Actually, the AM ?mows better. It has been financing studies of'he cErvonic, long term. or delayed effects of'rraC.ation in man and. animals A;..ong othe groups, informa tion is being gathered from the ?'i~rshallese people who were exposed to fal1out during a weapons test in the Pacif'ic Ocean in 195$ . Zhe mes t signifK ant

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C fixding of their exposure'o radiation was the development of thyroid gland abnormalities were'iscovered in children who wire less than 10 years old when exposed. Ho such abnormalities were found in children not exposed .-

3xe Federal Radiation Council's staff report "Background Material for the Development .of Radiation Protection Standards" states, "the child's thyroid is more sensitive to the carcinogenic effects of'adiaC an than the adult thyroid Ibis canelusion is based on

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several studies in recent years of the occurrence of thyroid carcinoma in children who had previously received th.raputic x-irradia Mon in 'the.'neck .regian for enlarged thymus, or for other benign head and neck con'tiors Zhe incidence of'hyroid carcinoma in these chilcxen was significantly higher than in control groups who had not been previously irradiated. In these studies cancer of the thyroid was observed in children after exposures as low as approximately 150 rems. Similar effects have been observed in adults only a much higher dosages Although these cata do not provide a quantitative relationship, they do indicate that the child's thyroid is more sensitive to the carcin-ogenic effects of'ani ation than is that of the am1t VH.shin Mesn't i~:ake It So Zhe A& has used a high-handed and deceptive approach in this study. It is essentially an in-house study, in no sense an Report iso 2, '.3~ckr.round i':ateria1 for the Development of Had'-~ tion Protection Stan"'er;:s, Se t., 19 1, 'Staff ikeport o" the Federal Radi ation C ounc il.

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I an 'hand'eaendent evaluation" of, the AK ~s performance or policie.s

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in nuclear reactors.. Xt.-is instead a def'ense,of them., 'The I

4 is doing the public.'c;a disservice bv'ortraying the risk-of'n 4

ABC accident's very small"on" the basi s of'unsupp'or ted calculations,- .

'4 The Ford'a(iministration and .the public .is bei'ng led, oown the 4

~

gaarden:. pa& of'uclear energy. 'hey should be told, insthead~ .

that solar,.wi'nd and'geotherma1 power can be developed faster than nuclear power, since ela3orate,safety precautions'need not

.energy sources.. at each sCape of'evelopmento be'aken.with-..the.se

~id,'

Not Safe Enough I read with great concern the state-ment given by 32, leading scientists on the metal at the grain boundaries, nuclear power, coal and America' which could reduce the effectiveness energy future. of zirconium alloys ks a'cladding mate-The major point of the statement is =

rial. At 400'elsius the, diffusion cdef-that we should move on to nuclear ficient for oxygen. Du. at thc grain, i power since power based on uranium boundaries in zirconium was about "is an engineered reality for generat- 10 " square centimeters per second .

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ing electricity today." The scientists ,compared to a value of 2.1 times also state that "th'e safety of civilian centimeters per second for the 10-"'quare nuclear power, has been under public .bulk diff'usion coefficient Dv.,

'urveillance without parallel in the his- At temperatures above 1,100'el-tory of technology" and that "on any. 'sius zirconium r'eacts rapidly ivith scale the benefits of a clean. expensive steam with a large evolution of heat and inexhaustible domestic fuel far and.the formation of free hydrogen,-

outweigh the possible risks." with most metals to form intermetallic After, 25. years'of research and de- compounds and with other metallic-velopment ivork on the chemical and oxides to form, its own oxide. Once zir-metallurgical properties of metals conium is heated to 1,100'elsius, used in nuclear power phnts., I which'could occur in loss of coolant and'lloys have come to the conclusion, that the accidents, it is difficult to prevent fur-current design and materials cannot ther reaction. failure of the tubing and

. give us a safe and wellwngineered . of the reactor. It is difficult,to define nuclear poiver plant. It now appears ~

reaction conditions under loss of 'the that there'are serious limitations for coolant conditions and good kinetic,

'ome of the, materials used in measurements for the reaction of zir-ivith steam at 1,100'elsius.

nuclear'eactors.

'onium-The use of zirconium allo'ys as a and higher do not exist.

cladding material for the hot uranium Many, of the recent difficulties in,

.oxide fuel pellets is a very hazardous the operation of.our,present nuclear design concept since-zirconium;is one 'ower pla'nts are due to mateiiaf prob-

~ of our most:reactive metals chemically. lems in the reacior, steam, generator For a safe reactor the cladding materi- and turbine. There appears to be no al should'be relatively inert to ivater. way to overcome the inherent material impurities in the water and to the sup- problems associated with zirconium porting structure under any possible alloys and the current design of, the reaction condition. which may occur in reactor.

.a nuclear reactor. 'Greater wall thicknesses for the At the operating temperature of cladding and lower operating temper-nuclear poiver reactors zirconium atures of the fuel may help but the cladding,allo'ys'eact ivith oxygen in chemical and metallurgical behavior 'f water to form an oxide layer which zirconium alloys cannot'be over-partially dissolves in the'metal enibrit- come. No backup or alternative design

.tling and weakening the metal tubing. is available, if the present design and Part of thc hydrogen formed in the materials. prove unreliable. It is there-zirconiuni-water reaction dissolves in fore most important to question the the metal and may precipitate as,a, statements made by the 32 scientists hydride'hase also embriitfing and 'before it is too late to change.

iveakening, the metal tubing. Recent'work

'Earl A. Gulbransen reported- last summer in France Department of Metallurgical and-has shown rapid solution of oxygen hfatenals Engineering from the zirconium oxide layer into University of Pittsburgh June 1975 Bulletin'f the Atomic Scient ists

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. 'NUcliii'owii'.. LIistjois' Engineers for the Arizoiia Nudear'm product of recycling'plants dareseven Power"Project, a combine. of.five corn-'e shipped because"of.its.'deadly. potency

. mercial and cooperative energy produc- and its vulnerability to piracy,'the govern- 'q

', . ers, are banking on unbuilt nuclear recycl-ing plants and government. storage, vaults, where to 'store the..wastes of recycling

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ment is looking for a salt c'avern some-

~ ~ to'andle "the waste -'products of. the pl'ants ..'aste that will rem'ain:,radioac-

' .. planned Palo Verde generating plant when, tive for thousands of years. To find just

.: it begins operating in 1983.'It will be locat-':.the right spot. takes,'a type. of 'geologic

~,,': ed 50 miles west'of phoenix..:.,

It is in their'financial'interest 'and that ,to scien'ce;, '.:":,

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~ .'.-, ...,projection:that may not even be available:

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of their. customers,for'the'power project,~ . There is even'inore controversy "over,

, partners; ', Arizona, Public Service,, Salt 'the.safety."of "the govenunent's. multi-bil-,-'

River,'Project,"'Arizona 'Electric'ow'er 'lioa4ollar project to develop a breeder Cooperative, Inc'.;'El Paso Electn*c Co..'. 'reactor one th'at will produce, energy, ~

.-'nd Public Service Co. of New Mexico,'- more fu'el'for itself and very'little waste to wait until such recyding and storage all at one site. Again,.the fuel, product-

, .facilities an,'lentifully and safely avail- '. of a breeder reactor would be plutonium.

able before committing themselves to large, construction exPenditures.,

'ent.

The two recycling plants built so fa'r -. . the basic nuclear- fuel',source .have problems of health, safety,and environ-surrounding the mining. of uranium.

in Buffalo, the other in -.(one Chicago),:notbeertresolved,satisfactorily..'c',,

have 'both been dosed, down one.Per'- ~: Nudear.weapons prog'rams have left a

';, '-;"haPS P ~gently'- bembs'e'of ted. M 'egacy of 79 alton,gals of K dioactive "

.rN"" ns" .waste1fo<<r the 'govemmeiit to store. over

. for emPIoyes A, thrd Plant, in South. Caro' the last 30 years. Underground tanks built" is not yet oPen and will not come near to store it in the I940s at Hanford;,Wash., ~

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handlirrg the wastes of the nation's 56 were. expected to iast 500,years. In'I9M operating nuclear Power Plants 'when it. leaks developed that have, only recently.,

does o n.' ~ I been brought under control. "'.:,',

.Untrl'then,'astes are being stored at ': >>Nuc]ear energy m'ayindeed one day be Power Plant sites. Withn.,a;year,"'14; of .the most desirable alternative to pfoduc- .

! those 56 Plants'-will'h'ave to shut down . tion of electrical energy through the'burn.

'because there. is no more'afe storage,:ing of-fossii fuel.'Nuclear resources, are

~,, 'While room. TWentywlgh're have a: year s 'more availaMe, cleaner, and,.in the long rag capa rty "

nuclear sdentists and politicians

~ 'un, cheaper. But they are'also, at thIs, point, far more dangerous to 811 hving,

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' continue debate over whether the plutoni- things:

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