ML19225A465
ML19225A465 | |
Person / Time | |
---|---|
Site: | Palo Verde ![]() |
Issue date: | 06/20/1979 |
From: | Kerr J, Mackenzie V, Simpson J CALIFORNIA, STATE OF |
To: | |
References | |
NUDOCS 7907190379 | |
Download: ML19225A465 (36) | |
Text
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UNITED STATES OF AcIERICA IiUCLEAR REGULATORY COMMISSION EEFORE THE ATOMIC SAFETY AliD LICENSI:iG E0ARD NRO PUBLIC D0Cara gogy
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In the Matter of )
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ARIZONA PUBLIC SER' LICE COMPA iY, ) Docket lio s . STM 50-592 ET AL. ) STN 50-593
)
(Palo Verde Nuclear Generating ) March 6, 1979 Station, Units 4 and 5) )
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STATEMENT OF ISSUES OF T:iE PEOPLE 4
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5066 State Building San Francisco, California 94102 Attorneys for the People of the State of California and the Public Utilities June 20, 1979 Cr.:niscion cf the State of California YZ7 060
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i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING ECARD
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In the Matter of )
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ARIZONA PUBLIC SERVICE CCMPANY, ) Dceket Nos. STN 50-592 ET AL. ) STN 50-593
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(Palo Verde Nuclear Generating ) March 6, 1979 Station, Units 4 and 5) )
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OF THE STATE OF CALIFORNIA AND THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Introduction The People of the State of California and the Public Util-ities Commission of the State of California (CPUC) hereby submit to the Atomic Safety and Licensing Board (ASLB or " Board") its Statement of Issues pursuant to the Ecard's " Order Following Special Pre-tiearing Conference" (Order) dated Liarch 6, 1979 The Order cf the Board directed the Interested State partic-ipants to " file a statement cf issues it wishes to raise within sixty (60) days after One [NRC] staff issues the Draft Environ-mental Impact Statement (DES)."
The CPUC wishes to point out to the parties and to the NRC
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2.715(c) there is no requirement upon the interested states to
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"take a position with respect to [those] issues." Thus, the issues the CPUC sets forth in this statement are those subject matters it wishes to raise as relevant and pertinent to this proceeding which it desires to participate in through possible introduction of evi-dence, interrogation of witnesses, and offer of " advise to the Commission" as provided in 2.715(c). : o attempt will be made to "take a position or assbrt a " contention" on those issues raised as permitted by 2.715(c) and the Board's Order. Every effort will be made to state the issues we wish to raise and participate in during the orcceedings in " sufficient detail and preciseness to define ... concrete issue [s] ... appropriate for adj udication in this proceeding" pursuant to the Board's Order.
The following statement is an informational list of issues on which the CPUC may comment, testify, submit evidence, cre ss exam-ine, on otherwise participate in. Active CPUC participation on each item is dependent upcn information presently under development. In submitting this statement of issues to the A.S.L.B., the CPUC does not assume the burden of proof which properly rests with the j oint applicants to submit evidence in support of the application.
Therefore, any issue set forth herein, which needs first be adequately demonstrated by Joint-Applicants as part of a prima facie case, must await that proof before becoming a viable issue in this case on which PUC would intend to introduce evidence.
- 1. Are Capital, cperating, and maintanance costs of the proposed Palo 7erde :iuclear Generating Staticn, Jnits 4 and 5 (PV:MCUL5), as prev nted by the .ipplicants and quoted frcm a.q 3
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Energy Information Agency of D.O.E. and the " CONCEPT" code, and as presented by the NRC Staff, reliable and accurate representa-tions of what actual project costs are likely to be? What exactly is the basis for e'ch of these estimates and how was each devel-oped? What other data was relied upon in developing each and in what way was it used? What is the detailed breakdown of costs reflected in the total capital, operating and maintenance cost estimates presenced by each source? Are these estimates reasonable when ccmpared to estimates for other nuclear units currently being made? Are these estimates reasonable when compared with costs which have been incurred for nuclear units which have already been constructed? Are these estimates reasonable when compared to the estimates used by these parties for the alternatives to the pro-ject which each has discussed?
- 2. Are capital, operating, and maintenance costs of the coal-fired alternative to PVUGS4&5, as presented by the HRC staff and those quoted from EIA and the Concept code, and as presented by the Applicants, reasonable and accurate representations of what the actual costs for a coal-fired alternative would really be? What exactly is the basis for each of these estimates and
'cw ias each developed?
. What other data was relied upon fcr dev-eloping each and in what way was it usedo What is the detailed breakdcwn of costs reflected in the capital, cperating and m1in-tenance cost estimates presented by each cource? Are these es-timatec reascnable wher ccmpared to estimates for cther coal pro-jects currently under concideration? Are these estimates reason-able when ecmpared to ccats which have been incurred for coal-fired 3
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projects which have already been constructed? Are these estimates reasonable when compared to the estimates used by these parties for the ?'INGS4&5 proj ect ?
3 What are reasonable capital, cperating, and maintenance cost estimates for non-nuclear and non-coal alternatives to the p"oposed PVUGS4&5 units? What should serve as the basis for each estimate and how should_each be developed? What data should be "elied upon and in what way should it be used? What is the detailed breakdown which should be Jeflected by the total capital, operating and maintenance cost estimates for each alternative?
What estimates for the alternatives are reasonable for comparison against the estimates for the nuclear and coal options which are found to be reasonable? What use should be made of cost estimates currently being made for projects utill:1ng the various alternative technologies to the nuclear and coal options? What use should be T.ade of ecsts actually incurred fcr proj ects already built which utilize the various alternatives to the nuclear and coal options?
4 What disecunt rates should be ased in computing " level-ined" cr "present wor:r" cost estimates for the PV:;332&5 and alter-natives to it? What 2pproach and bazi~ should be used for develop-ing a discount rate percentage? Should the discount rate used re-flect the point of view of ratepayeas, society at large, the util-ities and their owners, the perspectives and principles en which regulato"y processes and decisions are based, scme combination of these poir.ts of view, or scme other fac;crs and points of view. <lnat data and parameters a-a'- 0---
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to be appropriate for development of a discount rate? Precisely what methodology should be used to calculate the discount rate?
What factors should be reflected in the discount rate? How do the methods, approaches, results, bases, points of view, etc.
used by the NRC and its staff, the Applicants, EIA and the CONCEFT code compare to those used in serious and scholarly eco-nomic research and analysis and in professional practice?
What are the effects and implications of various discount rate levels, approaches, etc.? Are the approaches, points of view, methods and results used by the NRC staff, the Applicants, EIA and the CONCEPT code reasonable and appropriate here?
5 Are capacity factors of the proposed PVNGS4&5 and the coal alternative, as presented by the Applicants and qucteu from EIA, and as presented by the NRC staff, reliable, accurate and reasonable estimates for each of these technologies? A' ? the capacity factors used reasonable in light of both specific system design and general operational experience with similar units?
dhat exactly is the basis for the estimate used by each party and what cught to be the basis for esti;ating capacity factor? dhat approaches, methcds, laca and points of view oupht to be used for projecting capacity factors and what approaches, methods, data and pointe of view were employed by each party'. What is the breakdown by year for the capacity factor projections used and what variations are likely' Are the estimates ased reasonable when compared to performance for units which have already been constructed? Are the estimates used by each party consistent for one technolocy, as compared to the estimates used for other
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technologies? What are the effects and implications of the capa-city factor estimates used by the various parties?
- 6. What are reasonable estimates for capacity factors for the non-nuclear and non-coal generating alternative.s? What should be the bases, approaches, methods, data and points of view employed in developing these capacity factor estimates? What is the break-down, year by year, for the capacity factor projections for the alternatives and what variations are likely? What role should che performance of existing units of each technology type play in determining the capacity factors and what role should be played by projections which have been made for similar proj ects being planned or under construction? What capacity factor levels for the alternatives are reasonable to compare with the levels for the nuclear and coal options found to be reasonable? What are the effects and implications of various capacity factor levels which might reasonably be made?
- 7. Are fixed charged rates used for the PVNGS4&S and the coal alternative, as presented by the Applicants, as quoted from the EIA and the CONCEPT code, and as presented by the NRC staff, reliable, accurate and reasonable estimates for each of these tech-nologies? What fixed charge rates should be used for the ncn-nuclear and non-coal alternatives? In determining fixed charge rates, what points cf view, approaches, methods, mcdels, data, parameters and estimates shculd be employed and what factors estimates which wer- presented here? What is the breakdown by year fcr the fixed charge rates for each technclogy and .2at varia-tiens are likely? What are the effects and i.vnlications of the fixad charge rate estinates used by each party?
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- 8. Are nuclear fuel cost estimates used for the PVNGS4&5, as presented by the NRC staff, as quoted from EIA, and as presented by the Applicants, reliable, accurate and reasonable? Are the costs reasonable in light of specific system design and general operational experience with similar units? In determining the fuel costs, what points of view, approaches, methods, models, data, parameters and esbimates should be used and what factors should be recognised and given weight? Which of these were used and recognised by the various parties who have developed estimates which are presented here? What is the breakdown, year by year for the fuel costs and what variations are likely? Upon what fore-casts are assumptions concerning supply, demand, prd'e, cost avail-ability for the various commodities and processes in the nuclear cost assessments based and on what forecasts or assumption should they be based?
9 '4ha t 're the supply, demand, price, cost and availability prospects for the various steps in the nuclear fuel " cycle" by fear throughout the duration of the project in terms of both likely results and v2riations which may reasonably be expected?
What assumptions, data, parameters, estimates, forecasts and pre-dicticns, models, results and conclusions were relied upcn by the Applicants and the NRC staff ir formulating their assessments on the demar;d , sunply, price, cost and availability outlock and aow were these uticck assessments incorporated into the overall economic, r'f li 2b ili t y 2:.d planning assessments of those parties to i
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evalute the proposed project? Are these assumptions, data, parameters, estimates, forecasts and predictions, models, analyses, results, conclusion and uses appropriate, accurate, reliable and reasonable? Precisely, how were the assumptions, data, parameters, estimates, forecasts and predictions, models, analyses, results, and conclusions used at each stage of the a:.alytical process and exactly how were the the outlook assess-ments used in the planning and anaJyses for the proposed project and are those uses reaLonable, accurate and appropriate? Are these assumptions, data, parameters,, estimates, forecasts and predictions, models, analyses, results, conclusions and uses reasonable and supportable as the best assumpticas, etc. in light of historical data and published research and analysis on the subj ect ? Are these assumptions, etc. acceptable when ccmpared with and consistent with corresponding assumptions, etc. which were used by the parties for the coal a.'ternative? Are they acceptable when Ocmpared with and consistent with the assumptions, etc. found to be reasonable for the coal and non-nuclear and non-c o a .~ alternative? Wha; are the effects and implications for the planning, economic and reliability analyses o f the assumptions ,
etc. used by the parties and are those acceptable effects and implications?
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- 10. What are fuel costs, as seen by the ratepayers, likely to
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in this case, and exactl.y in what way were they used and given weight? What is the breakdown, year by year, for the fuel costs and what va"lations are likely? On what forecasts of or assumptions concerning supply, demand, price, cost and availability for the various cctmodities :d services involved in the coal fuel " cycle" are the coal fuel cost assessments based and cn what forecasts or assumptions should they be based? What are the effects and implications on fuel costs of the points o f ziew, methods, m a ." c . .a . e ." ,c -' . .d a ' m' o ". .a 'u m a c _'-~m "m s"t .".a. n' ^-g y '. ' o. a n m' .A~ " ..b. a.
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Precisely how were the assumptions, etc. used at each stage of the analytical process and exactly how were the outlook assessments used in the planning for the PV:!GS L&5 project and in analyzing the coal alternative to it? Are these uses and analyses reasonable, accurate and appropriate? Are these assumptions, etc. reasonab' and support-able as the best assumptions, etc. in light o f historical data and published research and analysis? Are t he;. reasonable when compared to those which are found to be reasonable for the nuclear fuel " cycle" and are the ccal and nucl'ar assumptiens, etc. used by each party ccn-sistent and reasonable in a comparative sense? .ihat are the implications for and effects on the planning, economic and reliability analyses of the assumptions, etc. made by the parties and are these acceptable ?
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- 12. What would be the costs seen by retepayers for fuel for non-nuclear, non-coal alternatives to the proposed project? What bases, points of view, approaches, metlods, models, data, parameters, assumptions, and estimates should be used and what factors should be given weight? In what way should they be used and given weight?
What breakdown, year by year, is likely for the costs for these alternatives and what variations are likely? On what forecasts of er assumptions concerning supply, demand, price, cost and availability for the varicus cc=modities and processes and services involved in each fuel " cycle" or technology shoald the cost calculations for ratepayers be based?
13 What are the supply, demand, price, cost and availability prospects for the various steps in the fuel " cycle" or utilisation technology for each alternative by year throughout the duration of the p roj e ct life for each alternative which are reasonable, in terms both of likely results and variations which may reasonably be expected'.
What assumptions, data, parameters, estimates, forecasts and predic-tions, models, methods, analyses, results, conclusions and uses are appropriate, accurate and reasonable for each?
13 Do alternative power sources exist to the PVNG3 4&5 which are 1Ner or similar in coct, more reliable and environmentally sound?
The feasibility of utilizing the fclicwing supply technologies shculd be ecncidered: cil- or natural gas-fired stelm-electric, internal-combusticn, gas-turbine, actoined cycle generating plants, ".ydroelectr_
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plants, conventional coal- and solvent-refined coal-fired steam-electric plants, gasified coal-fired, combined cycle plants, fluidisec-bed coal plants, magnetohydro-dynamic combustion of coal, biomass-fired s team-elect ric plant s , geothermal plants, wind-powered, and tidal-pcwered electrical generation , solar water - and space-heating, solar thermal staam-electric generation, photovoltaic cell , fuel cells, nuclear fusion, cogeneration, reconditioning or repowering existing power plants, uprating existing plants and operating existing peaking or intermediate plants as baseload? In addition, the feasibility of utilising the following non-generational alternatives should be considered'. energy conservation, load management, purchases of capacity and energy, and power pooling.
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- 15. Are the Proj e ct Applicants able to finance the proposed PVUG3 4&5? What are the Applicants' capital structures as presently constituted? Can they issue sufficient debt and equity to finance PVNG3 4&5? For each Applicant, what percentage of project financing will be internal, and what percentage external? What kind of external financing does each applicant anticipate" Is it reasonable? Is conventional financing optimal? Has "proj ect financing" been con-sidered? If the Apolicants are proposing to use project financing for FVNGS 4&5, what are the details of the arrangement ? What are construction expenditures for PVMGS 4&5 likely to be on a year by year basis? What else is each Applicant financing in that same time frame? Given the capital structure of each Applicant, can they issue sufficient debt and equity to finance both FVNGS 4&5 and their other construction projects and still maintain adequate financial ratios? What would be the impact on each Applicant of unknown delays in licensing and construction en their financing program?
- 16. Is PVNGS h&5 or equivalent capacity necessary to meet the energy and power requirements of the Applicants? What are the estimated loads, available capacity and energy, and energy and_capacit' reserve margins an d reliability criteria cn which such a conclusien should be based?
17 What forecasts o f energy and power demand are most appro-priace for uce in this case fcr the Applicants? What approaches, nethcds, data, mcdels, 230urctions, and estimates should be used to develop these forecasts an; what factcra chould be given weight? How de the appr3 aches, data, 2nd the resulting fcrecasts found to be apprcpriate ecmpare to those used by the Applicants and by the MRC Staff
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- 13. What levels of reliability and reliability criteria are appropriate for the Applicants planning? What is the basis for these levels and the criteria chosen? What levels and criteria were employed by the Applicants in its planning and analytical work that led to choosing to build PVHGS 4&5 and exactly how were these used in those processes? Exactly what Todela, data, assumptions, approaches, analyses and results are reasonable for use in making these reliability assessments for planning nuclear generating units and comparing them to other alternatives? How do the Applicants' models, etc. compare to theae? What are the implications and effects of the choices made by the Applicants for reliability levels and criteria and for models ,
e.nv.o 1 19 Ccnsidering the proposed proj ect and all alternatives to it T.ent ioned here , what effect would the size and unit performance and operating characteristics of each alternative have on system reliability, performance and planning? How should these effects be considered in comparing the alternativec in terms of economic and system reliability compariscns and other planning characteristics?
What assumptions, approaches. methods, models, data and estimates should be used to reflect these size, perfcrmance and cperating
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- 20. Exactly what models, approaches, assumptions, data, and analyses should be employed in making cost assessments for comparing each of the alternatives (including the PVNGS 4&5) under consideration here and what factors should be considered in each assessment and in what way? How do these models, etc. and factors and treatments compare to those used by the NRC Staff and the Applicants? What are the effects and implications of the models, approaches, etc. used by the NRC Staff and the Applicants?
- 21. What sources, estimates , data assumptions , models and methods are appropriate to re c.agnition of the costs of power plant decommissioning in the aconomic comparison approaches found useful here and what factors should be recognized and considered in this analysis? Precisely what sources, etc. were used by the Applicants and the NRC Staff in their assessments here and how do these compare to those found reasonable and preferable here? What are the effects and implications of the treatment on this matter made by each party?
- 22. What sources, estimates, data, assumptions, models and methods are appropriate tc recognition of the costs of all fuel cycle "back-end" processes and requirements in the economic compariscn approaches found useful here and what factors should be recognized and considered in these analyses? Precisely what sources, etc. were ased by the Applicarts and the NRC Staff in their as sessments and hc'<. do these Ocmpare to those found reascnable here9 What are the e f fe c t s anc irclinations of the t re atme nt on this matter made by each ; arty" f
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23 Exactly how should planning and operating flexibility for utility systems be considered when comparing the proposed PVNGS 4&5 project and the alternatives to it? What factors, criteria, approaches, points of view and analyses are appropriate to this comparison? Precisely how did the Applicants and the NRC Staff address considerations of flexibility in their assessments and what factors, etc. did they use? What are the implications and effects of the approaches taken by each of these parties?
24 Is there reason to believe that the proposed project would provide cheaper energy at the time it comes on line than could be cbtained from existing resources? What approaches, assump-tions, methods, points of view, factors, criteria, data and analyses should be used to address this question? What are the implications of any result or conclusion on this matter? More generally, is there reason to believe that utility ratepayers or society at large will be better off in the long run if the plant is completed as early as possible (even if there is no need for the plant at the time it is completed to provide reliable service at that time)"
What apprcaches, etc. shcu d be used to make this determination?
What are the irclications of an-j conclusions or resulta en this matter.
25 .! hat will be the ap propriate or be st mi.: cf facilitiee for eccn;mic and reliable aervice and cperating and planning flex-ib ilit y far the Arclicants at the time the F'/N C 3 4L5 units or alter-native: to the. wcula be expected to be operational? What will be i
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the actual mix for each alternative? Mix should be de fined to include type of unit (steam turbine, storage device, gas turbine, etc.) and the use generall; to which each unit is suited (peaking, inte" mediate, fast start, etc.). What are the implications for the license being sought here of the e mparison between the appropriate or best mix and that which would result under each alternative?
- 26. What will be the appropriate or best mix of facilities for economic and reliable service and for operating and planning flexibility for the Applicants at the time the PVNGS 4&5 units or alternatives to them would come on line in terms of the fuels used to run the ur.its owned by the Applicants? What will be the actual mix under ea ch alternative ? In particular, will the Applicants be too dependent on :.aclear generation if the proposed PV.'!GS 415 units are constructea, and what impact would an extremely long forced cutage of the PVNGS 415 units have on ratepayer and social costs, on reliability and on flexibility? What are the implications for the license being sought here of the answers to these questions?
- 27. What wc .1d be the actual capacity and energy outputs of the PVNGd 4&S units to the electrical grias o f the Applicants ? In
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s reasonable alternative? How do the Applicants' and the NRC Staff's schedules assumed here compare to other crojections used for such assessments by the HRC? dhat are the implications on pcwer costs, reliability, and planning and operating flexibility of the schedule found to be most reasonable? What schedules are equally reasonable or likely for each of the alternatives and what effects and implica-tions do these have? What delays are possible er likely in the various schedules for all alternatives anc what effects would these have,on costs, financing, re liability , and flexibility?
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29 Whether Arizona Public Service (APS) is sufficiently experienced and capable to act as proj ect manger and operator for PVNGS 4 & 5 Does APS' previous general experience indicate it would be competent to handle the technical, financial, and managerial functions associated with project management of PVNGS 4& 5? How does APS propose to train its reactor operators? Will the operators for P7NGS 4 & 5 be dedicated solely to those units or will they be part of an operator pool associated with PVNGS Units 1 through 5?
- 30. Whether responsible and accurate descriptions have been provided of pertinent aspects of PVNGS site, alternative sites, and Western Participants transmission line corridor, inclucing regional ge olo gy , soils descriptions, and siesmicity. Are descriptions adequate to allow prediction of the effects of construction, vulner-ability to long term and flash erosion, foundation s tability under predictable seismic disturbance, and geologic determinants of other impactc?
What are the effects of the establishment of evaporation ponds and the terminaticn of existing effluent discharges on migratory and local wildlife? What measures will be required to protect surface and groundwater from the ccncentrated salt deposits of the evaporation pcnds over the geological life of the disposal site?
In addition tc specific described sites , what areas of proposed site and transmissicn line constructicn are sensitive tc .cotential archaeclsgi:al disturbance? What provisicas fcr identification of previously unrecognized areas will be taken during acnstruction?
dhat strategies and actions will be required tc prevent the lors or A' a,
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destruction of significant sites and of material significant to the past and present Native American culture ? How will sites be pro-tected from unnecessary public identification during consideration of site risks and mitigation measures?
What information and techniques are available and will be used to identify and quantitatively estimate permanent and significant transient air quality hazards, flash flood hazards to proposed desert construction, and anticipated water balance of aquifers to be tapped by proposed well fields?
Are the sources for population data used to estimate electric power demand, vulnerability to effects of construction and operation, and cptimum siting plans for dispersed and centralized alternative supply systems compatible with population data used for related federally required plans such as water supply, wastewater treatment, solid waste disposal, and transportation plans?
Do considerations of aesthetic effects of proj ect , cooling water, and transmission line construction sufficiently take account of and documen" areas affected, " view sheds" and related scenic values, severity of effects, and available citigat n measurss?
Do discussions of ecology include reviews by ccmpetent specialists of the potential effects of proposed construction on endangered species of plants and animals? Is adequate attenticn given to the effects of roads, fences, pipelines, well fields, and evapcration ponds in modifying desert bicmes? What mitigation measures are considered to mitigate wildfowl diseace prcpagation in evaporation pondc?
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Are systematic accounts presented of the mining and industrial health effects of selection of specific fuel alternatives? Are health and safety discussions coupled to systems accident analyses in such a way as to adequately identify the population at risk for specific classes of project-associated accident?
What soctceconomic displacements are specifically attributable to project effects, direct job creation or elimination, and associated investment required per job created? What are the indirect effects of project implementation which impinge on rate setting determinations?
- 31. Whether the environmental impacts of the construction, operation, maintenance, and decommissioning of the proposed PVNGS 4 &
5 project have been adequately considered. Have the environmental setting of the project and the technical characteristics of all com-ponent systems and other related facilities of the project been described in sufficient detail to allcw an adequate assessment of all environmental impacts? Have the cumulative effects of five units at the PVNGS site been fully considered in relation to each other and to other related elements of infrastructure? bihat primary and secondary environmental effects may result from the project's con-struction, cperation, maintenance, and deacmmissicning, and what will be the extent and significance of sucP environment al ef fect s ? dhat primary and secondary effects en economic and regulation growth may result from the project's canstructic: , operation, maintenan:e, and s actmiccioning? To what exten" aru ;he mitigaticn me as u re .3 grapcsed by the applicants and the NP.C capable of reducing or eliminating adverse envircnmental impacts? Would alternative cr supplenental
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mitigation measures be capable of further reducing or eliminating adverse environmental impacts? What are the effects of mitigation requirements on the project's cost and reliability? Are the mitiga-tion measures proposed by the applicants and the NRC appropriate in view of the envircnnental and econcm!c benefits and disbenefits of the proposed and alternative or supplemental mitigation measures?
What primary and secondary effects on economic and population growth may result from the use of power generated by PVMGS 4& 5?
What will be the environmental impacts of these effects on economic and population growth? What effects will the investment of capital in an out-of-state powerplant have on economic and population growth in California? Can there be any aitigation of adverse growth-related impacts implemented directly or indirectly by either the NRC or the Applicants? In terms of the environmental impacts of PVNGS 4 & 5 construction, operation, maintenance, and decommissioning and the extent to which adverse impacts will be mitigated, is the prcpused proj ec t justifiable?
- 32. Whether the Western Participants 500 K7 Transmissicn System will be a feasible means of transmitting cower from PVMGS 4 & 5 Have all ccsts of the transmissicn system been determined in a corriete and acceptable manner o Can all necessary approvals be obtained for the transmission system, including approvals b/ federal, state, and local governmental agencies and Native American tribal organizations? Will the transmission syster have sufficient public acceptance for its implementation" we
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Have the environmental setting of the transmission corridor and the technical characteristics of all component systems and other rela;3d facilities been described in sufficient detail to allow an adecur te determination of all environmental impacts of transmiss'on s" stem ccn-struction, operation, maintenance, and deccmmissioning? What will be the primary and secondary environmental effects of transmission eyrten construction, operation, maintenance, and decommissioning, and what cill be the extent and significance of such environmental effects?
Have the cumulative effects of parallel transmission systems been fully considered in relation to each other and to other related elements of infrastructure? To what extent are the mitigation measures proposed by the Applicants and the NRC capable of reducing or eliminating adverse environmental impacts? Would alternative or supplemental mitigi ' !.cn rea-sure be capable of further reducing or eliminating adverse environmental e 4 a + , ,
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Does the latter project obviate the need fo" the destern Participants line?
Should the San Diego-Arisona Project be considered as a full or partial alternative to the Western Participants Project.
What are the health effects of 500 hv transmission systems? To what extent wculd any health ef fects be compounded by placing a 500 K7
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33 Whether sufficient cooling water will be available for FVNGS 415 Is availability of sewage treatment plant e f flue n t dependent cn realization of uncertain predicticns of demographic growth? What is the net effect of creation of a major demand for cooling water on the overall water supply and water economics of the region? Given the Maricopa Association of Governments Water Quality Management Plan ("200 Plan") and other docunents, are predictions of usable effluent volume reliable? What are the upper and lower limits of reasonably expected variations in the water supply predictions and how might these problems affect pro-ject construction and operation? What volumes and services of reliable alternative water supplies are available, and what are the expected effects of commitment of such supplies of the project? If Central Arizont Project (CAP) commitments to local Native American groups are met, what level of groundwater overdraft may be created by cperation of the proposed project throughout its design life?
What modifications of the existing sewage treatment system will be required to provide reliable service to the power plant complex?
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e 4&5? How mignt improper treatment, toxic wastes, or other treatment irregularities affect the suitability of the waste-water for cooling systems? What monitoring systems are planned and what p"ocedures are available to miticate the effects or the project of treatment plant failures? dhat are the specific water quality problems associated with alternative cooling water sources, what mitigation measures will be required to make these waters suitable for cooling system use, and what will be the net e f fe c t en blowdown and effluent water quality of the required water treatment programs? What are the effects of use of groundwater as an alternative or supplemental source? In what ways would ground-water quality, availability, and recharge balance be affected by such use? Taking into account existing hydrologic records, water rights, and other associated concerns, can groundwater se"ve as a reliab le supply for the proposed project? What ecological and water quality effects are associated with termination of the existing treatment plant effluent discharges?
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Why do SRC and Joint-Applicants safety reports and environmental documenta describ e PVNGS 1, 2, 3, 4 and 5 radicall different mapped locatiens and areas for reservoir storage and evaporation ponds? What is the explanation of the various descript ior.s supplied, what degree of confidence can be placed in the last supplied description, and what changes in evaporative regimen, water use rates, and associated water quality are implied by the design changes indicated in successive documents?
What are the capacities of the various reservoirs and evaporation ponds? Numbers and maps given in diagrams so far published.by project prcponents and the MRC are usuall; areas, not volumes. What actions are available to mitigate interrup' ions in water supply which exceed the margins provided by reservcir capacity?
Ecw were safety allowances in water supply systems determined and what is the expected frequency and nature of events which may cause supply interruptions to exceed safety margins?
What are the costs and operating problems associated with failure of the wastewater treatment plants to maintain designed standards of water quality? Can allowances be made tc encourage water conservation in the .hcenix area without jeopardising the required water supply increase necessary to sustain the p.coosed project? How can ope ation of the prcposed project be made con-siatent with incentives tc inc ease water conservaticr* Tc what e .x o a. _ n. . -.-a.
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- 34. now are Pro *ect Applicants proposing to take care of property damage and liab ilit y insurance associated with the entire range of PVI;GS " elated accidents ? Is insurance ob tainable? How much dces it cost? Is an offshore insurance arrangement under ccncideration?
35 .lnat does the 23 .4 arch 1979 accident at the Three
- 411e Island Nuclear. Generating Station, Unit 2, imply as to the accuracy of the Joint-applicants and the NRC staff's estimates of capital costs, capacity factor, start-up dates, and energy costs for FVNGS 4&5? The NRC staff and the ACRS made some reactor safety re commendations in NUREG-0560 and "Interin Reports on Three mile Island Nuclear Sta; ion Unit 2", re s pe c t ive ly , upon review of the accident sequence. What associated additional c ap it al investment, delay in start-up time, and reduction in capacity factors T.ay "e caused by implementation of each reccmmendation for changes in plant design, plant instrumentation, plant operation and maintenance procedures, operator training, and control rocm laycut during either the design stage or the construction stage of r,,...,-.oc -<,-s ; ,,
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What bearing should the Three Mile Island accident have upcn the need for a NEPA review of " Class 9" events for individual reactors? What impact would the requirement of such review by the NRC staff have upon.the timing of this licensing procedure? 'dh a t inplication does the potential for a Three Mile Island " type" accident with its associated consequences on plant cperation have for the continued ability of the utilities involved to finance PVMGS 4L5 as well as any other nuclear plants in which they may invest? dhat problems are associated with continued naintenance and operation of other facilities and with maintenance of service when severe financial strains or insolvency are created by the nassive failure of a specific project such as the Three Mile Island accident?
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- 36. The NRC staff has identified, in MUEEG-0410, 133 gene"ic tasks whose resolutions af fect reactor safety, environmental impacts, or safeguards . Cf these generic issues, 22 have been combined into 17 " unresolved safety issues", each being, in the view of the NRC vtaff, "potentially significant frca a public safety standpoint" and, for each, resolution is "likely to result in MRC action on the a'fected plants." (SER, Appendix H, p. 12)
The NRC staff will develop recommendations for changes in plant design, instrumentation, operation, maintenance, and operato" training, de"ived from resolution of these generic issues. What reasonably predictable capital investments, delays in start-up times, and reduc-
-ior; in capacity factors may be caused by irclementation of these recommendations during the design, construction, and operation of m .m
. .Jwq M' b 9 Are there additional generic issues which do not fall within
".he scope of the amended section 210 of the Energy Reorganisation Act, but whose resolution or lack thereof may have significant bea"ing upon the accuracy of the j oint applicants' or NRC staff's estimates of capital costs, capacity factors, start-up dates, ene"gy ccsts, and asscciated envircrr. ental impacts f o r F '?.'G 2 4 L :?
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- 33. Has there teer adequate assessment of the range of potential accidents at P7MG3 4 a 5? For each potential accident has there been sufficient consideration o f the resulting impacts to the environment?
What bearing does a consideration of the most severe accident class have upon the adequacJ" of proposed emergencJ" evacuation plans?
39 4hether sufficient quantities of uranium fuel will be avail-able at a reasonable cost over the anticipated project lifetime. How will the issues surrounding mining, milling, conversion, enrichment, fabrication, and transporting of nuclear fuel af fect the rost, relia-bilit3, and environmental impacts associated with PVHG3 4 & 5? How will both large and small uranium reserves affect the cost o f cre, availability, the regional environmental impacts and cost of mining, and the ability to mitigate significant environmental effects? How will dif ferent tailinc assay factors af fect the cost and availabilit" J of fuel for P7MGS h ?< 5? What are the implications of low and high oi' cs~". o ". . v . . "o*a",
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- 40. Will sufficient quantities of circonium be available to ensure an adequate supply of nuclear grade circonium for fabrication of fuel tubing for PVNGS 4 and 5? How many supnliers of nuclear grade circonium can current consurrtion support? Will an adequate number of suppliers be available to fulfill demands? How will the health hazards and safety practices in these plants, and their relation to circonium production, affect the supply of fuel tubing' How might price and availability be affected by mitication of any hacards and practices? How will the radioactive tailings disposal problems be handled in the plants? How will the current " :ircon sands" tailings disposal problems affect the cost, reliability and en-vironmental impacts associated with this project?
- 41. What effect will prospectf ve spent fuel storage modes have on plant costs and reliability, and environmental impacts, and what modelling techniques were used to compute these factors? What are the consequences associated with the Federal Government not resolving the spent fuel storage issue by 1933? What are the current spent fuel storage modes under consideration? 4 hat provisions have been made at FVN33 4 and 5 to enable it to cope with the possibility that "no Federal deci:icn" will be made when on-site 3 crage capacity is filled? What cost will be incurred by the applicant in case (1) the spent fuel is shipped to a Federal storage site? (ii) the spent fuel continues to te stored cn-site? What will be the impact on project costs and operation if the Federal government decides on ar
" Interim Storage C,ation" as opposed to termanent dispcsal?
What measures will the Federal Government have to take to ensure ample interim storage capacity?
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- 42. Are the low-level radioactive disposal sites capable of accommodating all the low-level wastes that will be generated by currently operating pcwer reactors, as well as those that are anticipated to come on-line in the future including Palo Verde 4 and 5? If so, for how long will these sites be capable of receiving these eastes? What are the transportation costs involved? Does PV::GS 4 and 5 have sufficient low-level radioactive waste disposal capability on-site? Alternately, is there sufficient interim storage capacity until Federal sites become available?
43 Given the current " state-of-the-art" knowledge, what are the most probable modes of decommissioning for PVNGS 4 and 5? What are the time period and coats involved? Are these reasonable? How will the decomnissioning costs be financed? Will they be financed through negative salvage, or through a requirement for a bond or other type of "upfre t financing"? What quantities of radioactive material will be generated and what will their radicactivity levels be? Are there enough disposal sites for disposing of the radioactive wastes generated during decommissioning and decontaminaticn? What are the current gaps in knowledge 2nd what steps are being taken to resolle these? How might any gaps ir -m owl ed ge affect decommissioning costs?
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- . s 44 Does the existing " Participation Agreement" between the Joint-Applicants provide an adequate arrangem.ent to assure reasonable costs, reliability, environmental and safety standards?
Respectfully submitted,
/s/ VINCENT V. MacKENZIE Vincent V. '4ac Ke nz ie Counsel for the People of the State of California and the Public Utilities Commission of the State of California June 20, 1979 M
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I hereby certify that I am a citizen of the United States, vver the age of 13 years, with business address at 5066 State Building, San Francisco, California, and am not a party to nor interested in Arizona Public Service Compan;, et al. (Salo Verde Nuclear Generating Station, Units 4 and 5), Dockets Nos. STN 50-592 and STN 50-593 before the Atomic Safety and Licensing Board.
On June 20, 1979, in San Francisco, California, I personally deposited in the United States mail copies of STATEMENT OF ISSUES OF smame av ML.v. Vh n.I.sn A".. t D 1 n.L Cn"Unr m
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-a-T U - "L*T*TmTra A. L- prUpr m .u .ww e Up .m. u.r m v new U. . s u1 U L.A.-Q COMMISSION OF THE STATE OF CALIFORNIA, addressed as follows:
Robert M. Lazo, Esq., Chairman Donald G. Gilbert Atomic Safety and Licensing Executive Director Board Panel Arizona Atomic Energy U.S. Nuclear Regulatory Ccrmission Commission 2929 Indian School Road Washington, D.C. 20555 Phoenix, AZ 85017 o.
Commissioner Victor Gilinsky George Campbell, Chairmar U.S. Nuclear Regulatory 'daricopa County Board of Commission Supervisors Washington, D.C. 20555 111 Scuth Third Avenue Phoenix, AZ 35003 D". Quentin J. Stober Research Associate Professor Larry Eard Fisheries ResearcP Institute P.O. Box 793 University of Washington Tempe, AZ 85231 400 Northeast 15th Avenue Seattle, WA 93195 Dr. Stanley L. Dolins n<-u~- c . , r. ..
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- , . . . o-Arthur C. Gehr, Esq. Office of the Governor Snell 1 Wilmer 17 0 0 '.le s t Washington 3100 Valley Center Executive Tower - Room 507 Phcenix, AZ 35073 Phoenix, A: 35007 Charles S. Piersen, Tom Diancnd, Esq.
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. . .. . c_ . .. .e . . -a < -- e 200 State Capitol El Paso, TX 79901 1700 West Washington Phoenix, AZ 35207 mO n
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.. s Kathryn Eurkett Dickson, Esq. Steven Fahinki, Esq.
Mark J. Urban, Esq. NRC Legal Staff Counsel for the California U.S. 'Iuclear o.egulatory Commissicn Energy Commission Washington, D.C. 20555 1111 Howe Avenue Sacramento, CA 95825 Michael M. Grant, Esq.
Assistant Attorney General 200 State Capitol 1700 West Washington Phoenix, AZ 85007 Each copy was enclosed in a sealed envelope and all postage thereon fully prepaid.
I certify under penalty of perjury that the foregoing is true and correct.
/s/ S ANDRA REDD Sandra Redd
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