ML19270G806

Submits Joint applicant-consultant Comments on Des

ML19270G806
Person / Time
Site:	Palo Verde
Issue date:	06/11/1979
From:	Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	Gilbert R Office of Nuclear Reactor Regulation
References
PVNGS-299-TRM-J, NUDOCS 7906200338
Download: ML19270G806 (30)

Text

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1 P. oL sox 21666 PMoENIX, ARIZON A R5036 June 11, 1979 PVNGS-299-JRM/JMA Dr. Robert A. Gilbert U. S. Nuclear Regulatory Com:nission Office of the Nuclear Reactor Regulation Washington, D. C.

20555

Subject:

Docket Nos. STN 50-592/593, Draft Environmental Statement (DES), Related to Construction of Palo Verde Nuclear Generating Station, Units 4 and 5 File: FF-79-054-026

Dear Dr. Gilbert:

Enclosed, are the Joint Applicants' and their Consultants' comments on the subject DES, pursuant to 10CFR51 and NRC Notice Number 7590-01, dated April 19, 1979.

Very truly ours I

f. E. 6w ouA E. E. Van Brunt, Jr.

APS Vice President Nuclear Projects ANPP Project Director EEVBJr/JRM:ske Enclosure q7 aq r-mu

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COMMENTS ON DES FOR PVNGS UNITS 4 AND 5 4

DOCKETS STN 50-592, 593 Page 1:

Item 2, Second Paragraoh:

1270 megawatts is nominal net electrical capacity Item 3.a:

Evaporation ponds for Units 4 and 5 will require up to 450 acres, not 800 acres. This figure should be used throughout the DES.

Although 550 acres of potential cropland will be disturbed for construction of PVNGS 4 & 5, the land was originally excluded from agricultural produc-tivity for construction of PVNGS 1, 2 & 3.

Item 3.e:

A 1 ft/yr drawdown is less than that previousiv used for agriculture.

Page 2-2,3:

Highway between Phoenix and Gila Bend is now State Highway 85, rather than U.S. 80.

(Also on page 2-7.)

Page 2-5:

Last Paragraph:

"A petrolet:m refinery and energy research park is also proposed for development and may be located....."

Page 2-6:

Table 2.2:

Transpose colu=ns under 1977 and 1980.

Page 2-7:

Figure 2.4 Legend:

"% Construction" should read "% Construction Work Force",

"% Population Change" should indicate what time frame is being considered, and the source of the infermation should be added. The relationship between the two columns is not clear.

2340 06 Page 2-15:

First Paracraoh:

"U.S. 80" should be changed to " State Highway 85".

".... Interstate 10 is complete to Goodyear".

. Page 2-15:

Section 2.2.4 - Water Use - Paraeraoh 2, Line 3:

The term " unusable" might connote contaminated or polluted to some readers.

Suggest:

"Without reservoirs, most of Arizona's surface-water runoff would be of little use."

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Delete all but first sentence and substitute the following:

The CAP was conceived in the 1940's and will provide 9

a means for utilizing a major portion, 1.5 x 10 m3/

year (1,200,000 acre-feet / year), of the State of Arizona's adjudicated share of Colorado River water in Central and Southeastern Arizona. Basically, CAP provides an aqueduct system starting at the Colorado River near Parker Dam, passing North and East of Phoenix and continuing South to Tucson. The project, authorized by Congress in 1968, is partially com-pleted and is scheduled to commence operation in 1985.

Allocations of the water transported will be allocated for various uses, including municipal and industrial, agricultural irrigation, Native Americans reservations and power production, by the Secretary of Interior after receipt of recommendations by the Governor of Arizona. The recommendations made to date and under consideration by the appropriate State agency (Arizona Water Commission) contemplate that initially the major portion of CAP will be allocated for agricultural; however, such allocations would be reduced over the life of the project so that af ter 50 years the amount allo-cated for municipal and industrial uses and power pro-duction would exceed the amount allocated to agriculture.

It should be noted that a major portion of the Phoenix Metropolitan area is situated within the Salt River Project (SRP) and has access to water available to the lands within SRP. However, there are also large portions of the Phoenix Metropolitan area that are outside the boundaries of SRP and that are currently experiencing rapid growth.

It is expected that CAP water will be required to prsvide the necessary water resources to support such growth.

2240 07

. Page 2-16:

Section 2.3.1, Second Paragraph:

Delete the words "an Indian Reservation" from the last sentence.

Table 2.11:

The Tempe and Scottsdale resources are outside of the 50-mile radius of PVNGS.

Table 2.11:

Add to National Register List: Cashion Ruin, Prehistoric Archaeological Site (12-19-78)

Page 2-17:

Section 2.3.3:

Add description of mitigation work already done:

e.g.

An impact mitigation program for five prehistoric and four historic sites located in the pipel,ne corridor was initiated under the Construction Permit of PVNGS Units 1, 2 and 3.

Antieau24 prepared a detailed research proposal to direct the data re-covery programs at these sites and expanded upon the research problems set forth in several other reports (see Section 2.3).

Data recovery commenced in January, 1978 and is now virtually completed with the exception of one 1-mile segment of the corridor. Procedures used included backhoe test trenching, collection of surface artifacts, removal of sterile overburden with heavy equipment, hand excavation of houses, burials, and other features, and monitoring of various phases of construction activity. Substantial data was recovered from the Cashion Ruin (NA14,690), now on the National Register of Historic Places, somewhat less data from the more extensively disturbed Van Liere site (NA12, 552), and even less from the remaining prehistoric and historic sites. A draft report is in preparation.

Inasmuch as data recovery is virtually completed, further pipeline construction will have little further impact on these resources. The staff Lelieves the data recovery program for these sites is adequate to mitigate the direct impacts of construction.

Page 2-18:

Section 2.4.3:

This subject is discussed extensively in the SER.

Suggest adding this as a reference.

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e Pace 2-24:

Section 2.7.1.3:

Because the U.S. Fish and Wildlife Service list of proposed endangered species of plants within the United States is no longer current, the following changes are suggested:

The last paragraph of this section should be modified to read "The U.S. Fish and Wildlife Service has listed endangered species of plants within the United States.53 None of these species are known to occur in Arizona.

None of these species have been encountered during the applicants' ecological monitoring of the site."

Reference 53 should also be changed to "U.S. Fish and Wildlife Service", List of Endangered and Threatened Wildlife Plants.

Republication Fed. Reg. 44.3636-3645, 1979.

Section 2.7.1.5, Amphibians and Reptiles, Third Paragraph:

The desert tortoise is classified on the Arizona Game and Fish Threatened and Unique Wildlife List of Arizona, re-vised October 21, 1978, as Group III, the same grouping in which Gila Monster is classified.

Page 2-26:

Section 2.7.1.5, Amphibians and Reptilesi States:

"To the staff's k2owledge, the chuckwalla has not be:n observed on the site."

Several chuckwalla have taen cdytured within the construction area and relocated in nonconstruction areas.

Page 2-27:

Section 2.7.1.7, Fifth Lise from Bottyg i tI D.'

Change to read:

" Current ly the policy is to retain....

Green Belt, because of recent floodin,;."

Page 2-28:

Table 2.13:

Last subtotal under "Out. flows" should be 63.5, not 63.6.

Page 2-30:

Second Paracraph, Third Line:

Delete "via the water ct.nveyance pipeline for PVNGS Units 1, 2 and 3 (Appendix B)."

Change " Buckeye Irrigation Canal" to " Buckeye Irrigation District".

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. Page 3-1:

Section 3.2, Second Paragraph, Fourth Line:

" Core" should be " coolant".

4 Third Paragraph, Second Line:

Add " reactor coolant" between "the" and " pumps".

Page 3-3:

Section 3.3, Fifth Parseraph:

Since the applicant does not intend to line the reservoir, references to a soil cement liner should be deleted. Add: "However, seepage losses will remain at or below 300 acre-feet per year."

Page 3-7:

First Paragraph, Second Sentence:

Delete "As with the reservoir."

Page 3-10:

Section 3.6.2:

The second paragraph of this section does not correctly summarize the predicted impacts associated with the round mechanical draf t cooling tcwers for Units 4 & 5 (DES Figures 3.3 and 3.4) and for all five units (DES Figures 3.5 and 3.6).

The rates and areas stated in the DES for total solids deposition pertain only to the area or areas bordered on the map insert for each figure. In actuality some of the isopleths would extend beyond the borders of the figures. The associated rates and areas contained within these isopleths are not considered in the PVNGS 4 & 5 ER write-up because of the low predictions of salt de-position. A suggested revised write-up for this DES paragraph is as follows:

The distance to which drift droplets are transported and dispersed before reaching the ground is dependent upon their release height, their size and meteorological con-ditions. Table 3.4 indicates the drift droplet size distribution as used by the applicants. The applicants predicted total ground deposition of drif t from Units 4 & 5 are illustrated in Figures 3.3 and 3.4 for onsite and offsite areas. Figure 3.3 shows a maximum isopleth 20 lb/ acre /yr (22 kg/ha/yr) covering a very small area near the towers.

Figure 3.4 shows a maxi =um isopleth of 4 lb/

acre /yr (4.4 kg/ha/yr) to the northeast of the site.

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. Presented in Figure 3.5 and 3.6 are the applicants predicted total ground deposi-tion of drift from Units 1-3 (dashed lines) and Units 1-5 (solid lines) for onsite and offsite locations. Figure 3.5 shows maxi-mum isoplechs of 50 lb/ acre /yr (55 kg/ acre /

yr) to the northeast in the immediate vicinity of the cooling towers. Figure 3.6 shows two maximum isopleths of 10 lb/ acre /yr (11 kg/ha/

yr) occurring to the northeast of the towers.

The predicted maximum total offsite deposition is 13 lb/ acre /yr (14.3 kg/ha/yr).

Page 3-17:,

Section 3.6.5, Second Paragraph, Second Line:

Delete " soil cement" and "however".

Third Line:

Delete "in addition to soil cement."

Page 3-18:

Section 3.7.1, Fourth Line:

Add "except for that produced in chemical toilets which is disposed of in an approved offsite area."

Page 3-19:

Section 3.7.3, Second Paragraph:

Delete " licensed."

Section 3.8.1, First Paragraph, First Sentence:

Add:

1, 2 & 3 after PVNGS ; and " Arizona Public Service Company and San Diego Gas and Electric Company." after " Nevada Power Company."

Second Sentence:

Change to read. "An additional 500 KV transmission line will be required to deliver power...."

Last Sentence:

Change to read, "The proposed route for this trans-mission line can be....."

Footnote:

The staff's conclusion that eventual use of the route across the Morongo Reservation may be possible is valid, however, future negotiations with the Indians for right-of-way permission are not necessarily dependent on issuance of federal permits for the plant.

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. Page 3-21:

Section 3.8.2.1, Structures, Second Paragraph, Third Sentence:

The minimum height of conductors above ground should read "but the minimum will not be less than approxi-mately 10.5m (35 ft.)."

The conductor height can be lower under certain conditions.

Page 3-22:

Alternate Route, Table 3.7:

The number of miles of primary roads associated with paralleling utilities should read "29 (18)".

l' ace 3-25:

First Paragraph:

The results of additional limited field surveys conducted for the proposed and alternate routes from Valley to Mira Loma should be included here.

Section 3.8.3.3, Last Paragraph:

The words " Lamb Valley" should read " Lamb Canyon".

Section 3.9.1.1, Second Line:

Add "for PVNCS 1, 2 & 3" between " constructed" and "from".

Section 3.9.2, Second Paragraoh, Last Line:

Add "except in a few places where the width is 100 ft."

(Also applies to Section 4.1.6, First Paragraph.)

Page 4-1:

Section 4.1.1.2, Last Two Sentences:

No site runoff is directed to East Wash. East Wash has been carefully and deliberately isolated from the active construction area on the site to ensure that no runoff leaves the site or enters East Wash or Winter's Wash.

Site runoff is directed to a sedimentation basin or holding pond where it is allowed to evaporate.

Third Paragraoh, Last Sentence:

See previous comment.

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7'"1 Page 4-2:

Section 4.1.2:

Delete reference to a reservoir lining.

. Page 4-2:

Section 4.1.3, First Sentence:

Change " constructed" to " evaluated".

4 Section 4.1.3, First Paragraph, Last Sentence:

Add "the Western participants" af ter "Therefore".

Section 4.1.3, Fifth Sentence, Third Paragraoh and Third Sentence. Fourth Paragraph:

These sentences are misleading. Less than 1% of cropland will be removed from production by the towers and no permanent access roads will be con-structed in farming areas.

Section 4.1.5:

States: "During the clearing for the roads, tree stumps and other organic material will be buried within the right-of-way (ER(a), Section 4.1.1)."

This is not done presently due to engineering speci-fications and disturbing additional areas to bury the material. Material is disposed of in the onsite landfill or burned in the burn pit.

It is suggested that this statement be omitted.

Page 4-3:

Section 4.2.2, Last Paragraph, Last Sentence:

The applicant has no intention of allowing any construction runoff to leave the site or enter any natural water courses. This is spelled out in the permit issued under 40CFR423.45 shown in DES Appen-dix A.

Page 4-5:

Section 4.3.1.2, First Paracraph, Last Sentence:

The staff recommends that the applicant revegetate the disturbed areas of the pipeline route with native or other appropriate species. Justification for revegeta-tion is based on erosion control, acceleration of native habitat recovery, etc.

Attention should be drawn to the

" Secondary Succession Study Along Major Transmission Line Rights-of-Way, 1977", in which studies of revegeta-tion in Sonoran Desert plant communities indicated that reseeding had little, if any, effect on disturbed areas.

Thus, the recommendation would be difficult to justify on a cost-benefit basis and should be deleted.

Section 4.3.1.3:

Biological information supplied for the Valley to Mira Loma portion of the proposed route should be indicated here.

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i3 Page 4-5:

Section 4.3.1.3, Fourth Sentence, Second Paragraph:

This sentence indicates clearing of land for batch plants, pulling stations and storage areas. Most vegetation will not be cleared in these areas, but rather will be crushed. Some minor clearing may be necessary to facilitate equipment operation.

Section 4.3.1.3., Second Paragraoh, Last Sentence:

Change to read "The staff recoc= ends that wherever possible, the applicant... intercepted by temporary access roads."

Page 4-6:

The ninth and tenth lines on this page indicate medium and high impacts from new road construction and in-creased accessibility to the palm oasis and Chuckwalla dune thicket. No new roads will be constructed in these areas, thus, no increased accessibility will result.

Devers to Vallev Substation. Secor d Paragraph, Last Sentence:

The requirement of no construction between February 15 and June 30 in highly sensitive habitats due to breed-ing is unreasonable. Close biological monitoring of each area on an individual basis with possible cur-tailment of construction as determined by the authorized officer would be more acceptable than a blanket shut-down for 4 months in several areas.

Page 4-7:

First Paragraoh, Second Line:

Change to read "....along the proposed and alternate routes".

Page 4-8:

Section 4.4.2.1, Last Paragraph, Last Sentence:

The staff recommendation appears to be unnecessary in view of the extremely low incidence of valley fever among PVNGS construction workers since the start of the project. Also change "three cases" to "four cases".

Page 4-14:

Section 4.4.5, First Paragraph:

Change "of" to "on" in the first line.

" Persistence" to

" Persistent" in the fourth line. Change the sixth line to read " reviews of ethnographic, historic and archaeo-logical data".

Delete the words " field surveys" in the sixth and seventh lines.

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. Page 4-18:

Table 4-10:

Revise as follows:

Mitigation Site Number Status Recommendation

1. NA12,482 Data Recovery Completed No Further Action

2. NA12,484 Data Recovery Completed No Further Action

3. NA12,489 Data Recovery Completed No Further Action

4. NA12,495 Data Recovery Completed No Further Action

5. NA12,496 Data Recovery Completed Rock Rings and Trails Remain and Should Be Protected

6. NA12,500 Data Recovery Completed Trail Remains and Should Be Protected

7. NA12,501 Data Recovery Completed No Further Action j

8. MA12,502 Data Recovery Completed No Further Action

9. NA12,503 Data Recovery Completed No Further Action

10. MA12,504 Data Recovery Completed No Further Action

11. NA12,578 Data Recovery Completed No Further Actica

12. MA12,579 Data Recovery Completed A Few Glyphs Remain and Should Be Protected

13. NA14,369 Data Recovery Completed No Further Action Page 4-19:

First Paragraph, Second Sentence:

The applicant cannot be responsible for activities conducted on property not owned by the applicant.

The applicant can commit to keeping its contractor equipment out of the areas, but it has no control over others.

Section 4.5.3:

Suggest re-writing as follows:

"An impact mitigation program for five prehistoric and four historic sites located in the papeline corridor vac initiated under the construction permit of PVNGS 24 Units 1, 2 & 3.

Antieau prepared a detailed research proposal to direct the data recovery programs at these sites and expanded upon the research problems set forth in several other reports (see action 2.3).

Data recovery commenced in January,1978 and is now virtually completed, with the exception of one 1-mile segment of the corridor.

Procedures used included backhoe test trenching, collection of surface artifacts, removal of sterile overburden with heavy equipment, hand excavation of houses, burials, and other features, and monitoring of various phases of r

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, construction activity. Substantial data was recovered from the Cashion huin (NA14,690), now on the National Register of Historic Places, somewhat less data from the more extensively distrubed Van Liere site (NA12, 552), and even less from the remaining prehistoric and historic rites. A draft report is in preparation.

Inasmuch as data recovery is virtually completed, further pipeline construction will have little further impact on these resources. The staff believes the data recovery program for these sites is adequate to mitigate the direct impacts of construction."

Page 4-19:

Section 4.6.1, Item 3:

Add to the end of the sentence "if authorized by the landowner, or otherwise disposed of."

Item 7:

Delete, since all runoff will be retained onsite.

i.

Page 4-21:

Item 24.a:

Though this is stated as it was in the (ER(a), page 4.2-23), the major water crossing for that pipeline was placed underground. This section should read:

"All water crossings will be underground."

Section 4.6.2.1, Item 5:

Delete.

Page 4-22:

Section 4.6.2.2, Item 8:

See second comment on Page 4-6 above.

Page 5-5:

Table 5-3:

It is suggested that the table be revised as shown by adding the site boundary annual mean value:

TABLE 5 -3 : Estimated Concentrations of Airborne Particulates Emitted Per Unit from the Station Cooling Tower Systems Location Concentration, ug/m3 Cooling Tower Moutha 775 b

476 9]'

~}6 Site Boundary

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Site Boundaryc 123 Site Boundaryd 1

2-Mile Radiuse 0.36 3.6x10-2 10-Mile Radiuse

.

• Applicant Esti= ate; Maximum Instantaneous Value 4

Applicant Estimate; Maximum Predicted Offsite Hourly Concentration c Applicant Estimate; Annual Maximum 24-Hour Value d Applicant Estimate; Annual Mean Value

• Staff Estimate; Mean Annual Value Con"ersion Factor:

1 Mile = 1.609 km Page 5-14:

Section 5.5.1.1:

The discussion under Soils should be modified on the basis of the maximum predicted salt drift deposition of 13 lb/ acre /yr (14.3 kg/ha/yr) (refer to comments on Chemical Ef fluents, Cection 3.6.2, page 3-10).

During the projected 30-year life span of the station, an additional 300 to 390 lb/ acre (330 to 429 kg/ha) of salt would be deposited on some offsite areas (refer to Figure 3.6).

This accumulation of salts will not detectably affect soil chemistry or physical properties.

Soil conductivities range from 1-60 taho/cm (soil survey of Maricopa County, Arizona Central Part, USDA/SCS, September, 1977).

In surface soils con-ductivity commonly ranges from 1-8 mmho/cm.

Page 5-15:

Section 5.5.1.1:

Vegetation communities in the vicinity of the station are expected to receive no more than 13 lb/ acre /yr (14.3 kg/ha/yr) of drift salt. This level of salt deposition and associated levels of airborne salts are not predicted to affect vegetation or wildlife habitat in the vicinity of the station either by leaf uptake, root uptake or inhibition of germination.

The applicant has designed, initiated and will continue a qualitative monitoring program to monitor any major changes in vegetation. It is the applicants judgement offsite monitoring of vegetation is not warranted.

Page 5-16:

First Paragraoh:

Delete the last sentence since the reservoir will not be lined.

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w Page 5-16:

Seventh Paragraph:

Delete first sentence. Change second sentence to read: "With a seepage rate of 300 acre-feet / year, an increase in vegetation.....

Page 5-17:

Section 5.5.1.2, First Paragraph:

47,000 acre-feet / year should be 42,700 acre-feet /

year.

115,000 acre-feet / year should be 107,000 acre-feet / year.

Second Paragraph, Fourth Sentence:

Delete.

Pages 5-19 Tables 5-12 and 5-13:

and 5-20:

There are several errors in Table 5-12.

Most were small and not extremely important. However, the data for the year 1990 were substantially off.

En-closed is a copy of Table 5-12 with the errors cor-rected, and copies of four work sheets which show the arithmetic involved in checking the Table.

There were also several errors on Table 5-13 which were carried over from Table 5-12.

Enclosed is a copy of Table 5-13 accompanied by four work sheets.

The NRC calculations set forth in Tables 5-12 and 5-13 are, in effect, an exercise in arithmetic. All but one of the assumptions embodied in the exercise are acceptable. The editorial suggested changes in fig-ures in Table 5-13 are based on the premises utilized by NRC. However, it is important to realize that, beginning in 1980 and continuing through 2000, the figures given in the work sheets for Table 5-13 for Segments B, C and D are not truly accurate. The error is that the figures under the column "To Pipeline" in the work sheet for Segment B (Table 5-13) in ef fect assume all the water goes to ANPP. In fact, 30,000 acre-feet per year goes to BIC. Therefore, when we get to Segment C (years 1980-2000), the outflow should be reduced by 30.0 from 96.4 to 66.4.

Otherwise, di-version by BIC would increase by 30.0 from 89.0 to 119.0.

If this correction were made, outflow from Segment C (Table 5-13) would be as follows:

Year Net Flow 1980 47.4 Jsq,,)

_ fb 1985 25.7 t

1990 0

1995 13.0 2000 35.0

. The corrected f',ures for Segment D should then be as follows:

Year Inflow Net Flow 1980 135.8 72.3 1985 122.6 59.1 1990 122.6 59.1 1995 122.6 59.1 2000 127.6 64.1 r~ n n

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Table 5.12.

Predicted Water Availability frois 23rd Avenue to Gillespie Dam f

f f fio Water is Diverted for PVf4GS Units 1. 2.1. 4. and 5 and for the fluc6cye Irr atice District *

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Prgdteted Wat r Avat lab 111ty,.103 _a c re-f.tfyr River Segrtnt A R ver S gment B

River Segment C E n er Segment D Year Inflow Datflow Net Flow Inflow Outflow Net Floq Inflow Outflow tiet Flow Inflow Outflow feet flow 1955 25.0 25.0 0

4.'

15.2 9.

39.7 39.7 0

64.6 63.5 1.1 1970 33.9 33.9 0

55.

15.2 40.

69.7 69.7 0

75.1 63.5 11.6 1976 51.2 34.2 17.0 117.9 15.2 102.7 113.0 96.4 16.6 02.0 J63.5

@ 38 3 L

1930 54.2 34.2' 20.0 149.'O 15.2 133.8 diEIi>

96.4 h

j f *Zd l 5.0 63.5 1.

i 54.2__,h 20.0 173.6 15.2 158.4 57.7 96.4

@i 63.9 63.5

/0/* Y 1985 h

15.2 qh 207.4 63.5 (143.9 } /d*9

?ol.9 96.4 1990 54.2 34.2 20.0 I99,l~~T995 54.2 34.2 20.0 220.9 15.2 205.7 216 96.4 119.6 212.2 63.5 148.7 N *-.

2000 54.2 34.2 20.0

< '242.9 15.2 d7.7 238 96.4 141.6 t

234.2 63.5 170.7 -

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a See Figure 2.8 for description of river segments. 5 arces of inf1 w and o st flow are g iven i able 2.13 to arrive

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f at the values in this table, the values in Table 2. 3 =.ere adjuste to act 4

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vels for e age effluent.

and drainage i. ell inflows.

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I'surces: Table 2.7.2-1 of this report; " '

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L. C. Halpenny and D. K. Greene. " Water Balan'ce Investigations of River Bed. Salt and Gila' Rivers, 23rd]ver.ui, % w.'

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to Gillespie Dam. Arizona," Water Devebpn.ent Corp., Tucson,1975;

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Rivers. 23rd Avenue to Gillespie Dam. Artzona " Water Developnsent Corp., Tucson,1977.

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'. f

'..n W.:.~.. l-Q,:-N N. ' h,~.!!?.O?p{$ &[:5.Y.V.Yr.'(yl.%%1',]~6 jh.k' l.'

. ~. d.; W, e-f ' ' '. ' ' '. ; -

'G lt.W '. :. V ' ', ".., ili r:{,.* - 1 $n':

7 2*

Lg Ij W.

O

. %. :;'e

.,v.',,-.

Lp.pnyg.7uy,. % g.wa;,.y 4 y.sx.y,83ym..yyv.;eq.\\g glM g. & gy..

m : w w.u.,:.a.m.a.

x - m..m a

. v... On a...w.c.n,.:. m..* v s. w u.v x..v..-..c

.. m._ n.

+ e.:.: r - v;. i,- ;. :s. am~<w -v_-.,<

~. n.

.*. ~. x

.n.:. z ;q ; _

Sheet 1 of 4 WCRK SHEET FOR SEGMENT A, Table 5-12 i

1976 Inflow:

Tailwater

8. 8 Cutflow:

Diversion G. 2 Rainfall

.2 Evapo et ran-Unde rflow

.1 spiration

3. 9 Groundwater Groundwater seepage

.3 recharge 30.1 Subtotal 9.4 Total 34.2 23 rd A ve.

Use 34. 2 for outflow in all sewage 41.8 future years.

Total 51.2 NRC FIGURES Cther 23rd Total Net Year Inflow Effluent Inflow Cutflow Flow 1965

9. 4 15.6 25.0 25.0 0

1970

9. 4 24.5 33.9 33.9 0

1976

9. 4 41.8 51.2 34.2 17.0 1980

9. 4 44.8 54.2 34.2 20.0 1985

9. 4 44.3 54.2

34. 5 X 20.0 1990

9. 4 44.8 54.2 34.2 20.0 1995

9. 4 44.8 54.2 34.2 20.0 2000

9. 4 44,8 54.2 34,2 20.O All CK except for typ marked "X" it should be 34,2.

a n,

.[h b -

's d LCII 5-12/13-79

,u =,,_..:

- n.

. : u. a:. 4...,5

.. : -. g-

- c -. ~

..~

, ;.. 5

;._.. x Sheet 2 of 4 4

WORK SHEET FOR SEGMENT B. Table 5-12 1976 Inflow:

Other sewage

0. 8 Outflow:

Diversion 0

Tailwater 0

Evaportran-Upper Gila spiration 11.9 River

.1 Groundwater Rainfall

1. 4 recharge

3. 3 -

Underflow

.4 Total 15.2 Groundwater seepage

1. 7 Use 15. 2 for outflow in all Buckeye feed-future years.

er canal 14.5 Subtotal 18.9 91st A ve.

sewage 82.0 From Seg-ment A 17.0 Total 117.9 NRC FIGURES Other 91st Segment Total Ne Year Inflow Effluent A

Inflow Cutflow Outf1 19S5 18.9 25.7 0

44.5 1/

15.2 29.

1970 18.9 55.7 0

55.7 T/

15.2 40.

~

1976 18.9 82.0 17.0 117.0 15.2 102.

1980 18.9 110.1 20.0 149.0 15.2 133.

1985 18.9 134.7 20.0 173.6 15.2 158.

1990 18.9 159.2 20.0 216.1 3/

15.2 201.

1995 18.9 182.0 20.0 220.9 -

15.2 205.

2000 18.9 204.0 20.0 242.9 15.2 227.

9-3

')

t.

d L.

Figure should be: 1/

44.6 4/

29.4 T/

74.6 T/

59.4

_3 198.1 T/

182.9 LCII 5-12/13-70

~.

~.p.

s. a........ s. f.c s w -

. p w

-e

.r.........:..

....n.. n.

. ~

Sheet 3 of 4 4

WORK SHEET FOR SEGMENT C. Table 5-12 1976 Inflow:

A gua Fria Cutflow:

Diversion 89.0 River 0

E vapo rt ra n-Rainfall 4.1 spiration 7.4 Underflow 1.1 Total 96.4 Groundwater recharge 5.1 Use 96.4 for outflow on all Subtotal 10.3 future years.

From Seg-ment B 102.7 Total 113.0

{

NRC FIGURES Cther Segment Total Net Year Inflow B

Inflow Cutflow Flow 1965 10.3 29.3 1/

39.7 39.7 0

1970 10.3 4 0. 5 '57 69.7 69.7

.0

~

1976 10.3 102.7 113.0 96.4 16.6 1980 10.3 133.8 143.0 4/

96.4 46.6 7/

1985 10.3 ISS. 4 157.7 T/

96.4 61.3'57 1990 10.3 201.9 3/

211.2 6/

.96.4 114.8 T/

1995 10.3 203.7 216.0 96.4 119.6 2000 10.3 227.7 238.0 96.4 141.6 Figure should be:

1/

29.4 4/

144.1 7/

47.7 T/

59,4 57 168.7 8/

72.3

]

182.9

{

193.2

]

96.8 q.

- qr lb ll.,

L LCH 5-12/13-79 m -

c,... w.. +. -......~

-+...-: w u. ;--e.. rwpw.,. ~

. n e.ma n..

a..,

., :. s _.,,.; 9 ; g, -

_19_

Sheet 4 of 4 WORK SHEET FOR SEGAIENT D.

Table 5-12 1976 Inflow:

Hassayampa Cutflow:

Diverson 8'. 2 River

6. 5 Pumping

7. 5 Tailwater 23.2 Evapot ra n-Centennial spiration 47.8.

Was h

5. 2 Total 63.5 -

Rainfall 11.9 U nde rflow

3. 2 Use 63. 5 for outflow on all G roundwater future years.

seepage 14.6 Subtotal 64.6 Drainage wells 20.6 From Segment C

16.6 Total 101.8 NRC FIGURES Other Drainage Segment Total Net Year Inflow Wells C

Inflow Outflow Outflov 1965 64.6 0

0 64.6 63.5 l ',' 1 1970 64.6 10.5 0

75.1 63.5 11.6 1976 64.6 20.6 16.6 102.0 4/

63.5 38.5 1930 64.c 23.8 46.6 1/

135.O V 63.5 71.5 1985 64.6 28.0 61.3 2/

163.9 '6'7 63.5 100.4 1900 64.6 28.0 114.8 T/

207.4 W 63.5 143.9' 1995 64.6 28.0 110.6 212.2 63.5 148.7 2000 64.6 28.0 141.6 234.2 63.5 170.7 Figure should be:

1/

47.7 5/

136.1 9/

72.6 3

72.3 T/

164.9 10/

101.4 T/

06.8 W

189.4 11/

125.0 T/

101.8 3

38.3 9'.3 dd U

LCII 5-12/12-79

L y

.g,

.o...---.-....-

... ~ -

--~

w.

6 h.

WmAL K~l$ "Y

,e Table 5.13.

Predicted Water Availability from 23rd Avenue to Gillespie Dam if Ef fluent is Diverte d f or WhG5 Units 1, 2. 3. 4. an.d 5 and for r 1q,6 the Buckeye irrigation Distrit.td

-59. V s/V.6 c 19 'l e-II3B

^

Predicted Wat l e Ava labilit h 0' acre-ft/yr 1

River Segir.cnt A ltver 5etent i

Ri er Seament C River Segn.ent 0 Year inflow outflow Net flow Inflow Outflow et flow Inflow Outflow flet flow inflow Outflow Net flow 1965 25.0 (

25.0 --

0*

44.5 l '. 2 39.7 39.7 0

64.6 61.5 1.1 1970 23.9 r 33.9 e 0*

55.

15.2 69.7 69.7 0

15.1 63.5 11.6 1916 51.2 7 34.2 y 17.0

• 117.9 15.2 102.7 113.0-96.4 16.6 102.0 l63.5 h 38.3 1980 54.2 34.2 v' 20.0 e 149.0 45.5 7 103.5 12.7 96.4 Q

04.7 63.5 h //2, ~,5 p

1935 54.2 34.2 v 20.0 s-173.6 91.E v 81.8 91.

M 0 17. Y 92.6

,6L5 29.1

/3 y

h f51.4 MI

/5.6 0

92.6 f' 63.5 29.1

?

1%0

54. 2 e-34.24 20.0 v 1995 54.2r 34.2,

20.0, 26).9 151.8

69.1 r

.<l. 4 0

9?.6 61.5 49.1 2000 54.2/

34.2, 20.0, 242.9 151.8

j 101.4 96.4 5.0 9 7. t.

(. 3. 5 34.1

{

t

• 5ee figure 2.8 for description of river segm1 ots. Source of is flow d oi, low arei a

i i en in Table 2.I'.

fo arrive at the values in this table, the values in T.

r.le 2.13 wer4 adj ted to ict a or ant i i ated levels for.c. age ef fluer.t and drainage well inflows and for diversion a f effluent f ir Pkt.S and t e iL.Leyeir

] tion District.

• /0/.S Conversion factor: I acre-ft = 1233.5 m l 92*I

"-92I y

j f,7 Ljgg Sourcts: Table 2.7.2-1 of t hi". repoi t; 7

Table 5.7-1 of f R(b);

y/*I

" 77, #/ bOh L. C. Italpenny and D. K. Greene, "Watei-Balance Investigations of Kiver lied. Silt (D7 Q, Y and Gila Rivers, 23rd Avenue to Gillespie Dam, Arltora, ' Water Development Corp., Tuc.on, 1975; L. C. Halpenny and 5. 4. Clark, "1977 Supplur.cnt to Water Balance lovestigations of River Bed, Salt and Gila Rive.rs, 23rd Avenue to Gillespie Dam, ArizonJ," lie ter Developinent Corp., Ibt son,1977.

TM

.j

.r. 1

=

a

' 9)1, J

m L ;..,.

a.

=

t

. f...'

=

x N

i Ln

.UL i

3

~

K 3

n v.

- % d :: Q*,W p ? D b ?:~

Sheet 1 of 4 4

WCRK SHEET FCR SEGMENT A. Table 5-13 All figures are CK.

q ro q(

',j LU c_,

t LCII 5-12/13-79

.--c.

....-..,~..

.,4 Sheet 2 of 4 WORK SHEET FOR SEGMENT B. Table 5-13 1976 InGow:

Other innow 18.9 Outflow:

Other inflow 15.2 91st A ve.

To pipeline 0

sewage 82.0 Total 15.2 From Seg-ment A 17.0 Total 117.9 NRC FIGURES Total Other To Total Net year Inflow Outflow Pipeline Outflow Flow 1935 44.5 1/

-15.2 0

15.2 29.3 4 1970 55.'T 3 15,2 0

15.2 40.5 3 1976 117.9 15.2 0

15.2 102.7 1980 149.0 15.2 30.3 45.5 103.5 1985 173.6 15.2 76.6 91.8 81.8 1990 216.1 3/

15.2 136.2 151.4 64.7 6 1995 220.9 15.2 136.6 151.8 69.1 2000 242.9 15.2 136.6 151.8 91.2 7 Figure should be:

1/

44.6 4/

29. 4 7/

91.1 3

74.6

'57 59.4 T 198.1

_'_57_46.7 u.

.'. )

Lt LCH 5-12/13-79

• vh.y

-x

. t.e-.

. :. ;: -is.c sw v. =. s v +.a.n.6.:: w - ? >. u-,

" ~, ~. -. -;t n n:

Sheet 3 of 4 WORK SIIEET FOR SEGMENT C. Table 5-13 1976 Inflow:

O the r 10.3 Outflow:

96.4 Segment B 102.7 Total 113.0 NRC FIGURES Cther Segment Total Net I

Year Inflow B

Inflow Outf" low Flo w 1965 10.3 29.3 1/

39.7 39.7 0

1970 10.3 40.5 T/

69.7 69.7 0

1976 10.3 10.1.7 -

113.0 96.4 16.6 1930 10.3 103.5 113.7 5/

96.4 16.3 11 1985 10.3 81.8

-92.4 T/

92.4 9/

0 1990 10.3 64.7 3/

75.0 Tl 75.010/

0 1995 10.3 69.1 79.5 8/

79.4 -

0 2000 10.3 91.2 _4/

101.4 -

96.4

5. O Figure should be:

1/

29.4 5/ 113.3 9/

92.1 T/

59.4 6/

92.1 10/

57.0 T/

46.7 77 57.0 11/

17.4 T_/

91.1

_T/

79.4

'i' LCH 5-12/13-79

.. y,._., y,...

. x w =;cn....

u.c.....y,w w.r:w ~tw g v:. w:.u._;;,.:g.,s.;~,, g -

Sheet 4 of 4 4

WORK SIIEET FOR SEGMENT D.

Table 5-13 1976 Inflow:

Other 64.6 Outuow:

63.5 Drainage wells 20.6 Segment C 16.6 Total 101.8 NRC FIGURES Other Jrainage Segment Total Ne I

Year Inflow Wells C

Inflow Cutflow Ou t n.

I 1955 64.6 0

0 64.6 63.5 1.

1970 64.6 10.5 0

75.1 63.5 11.

1976 64.6 20.6 16.6 102.0 2/

63.5 38.

1930 64.6 23.8 16,3 1/

204.7 T/

63.5 41.

1985 64.6 28.0 0

92.6 63.5 29.

1990 64.6 23.0 0

92.6 63.5 29.

1995 64.6 28.0 0

92.6 63.5 29.

2000 64.6 28.0

5. 0 97.6 63.5 34.

Figure should be:

1/

17.4 4/

38.3 3

101.8 3

42,3 T/

105.3

~

.: 1 21 LCH 5-12/13-70

.... _., Page 5-21:

Last Paragraph, Third Sentence:

Existing access roads from the PVNGS-Devers Line No. I are expected to be used, therefore, no increased access e

for construction of the portion of the PVNGS-Mira Loma transmission system paralleling the No. I line is antic-ipated.

Section 5.5.1.3, Last Paragraph on Page, Fourth Sentence Access roads of the Western participants' transmission lines will remain open unless ordered to close by the landowner.

Page 5-22:

Last Paragraoh:

No 345 KV transmission lines are to be constructed.

Also applies to first sentence on page 5-23.

Pages 6-2 Figures 6.1 and 6.2:

and 6-4:

It is suggested that wells shown in the Figures which are not listed in Table 6-1 be removed, since they are not pertinent to the program under discussion.

Page 6-5:

Section 6.1.3, Second Paragrach:

The applicant has been collecting meteorological data continuously since 1974. It should be explained that these data still substantiate the 1973-1974 sample used in all met. calculations.

Page 6-8:

The discussion under Staf f Evaluation of Baseline Studies should be modified on the basis of the predicted drift deposition maximum of 13 lb/ acre /yr (14.3 kg/ha/yr) and NRC Regulatory Guide 4.11.

The baseline studies were designed to be qualitative in nature with a minimum de-tailed sampling effort to characterize parameters including soil chemistry and vegetation cover. Quantitative baseline sampling was not designed since no important species are expected to be adversely affected by station construction and operation. On the basis of these considerations, the applicant is of the opinion that modification of the base-line studies is not necessary.

Page 6-9:

Third Paragraoh:

Because of the extremely low values for salt deposition, the five points made in the staff's evaluation of the baseline studies are not appropriate.

The applicant feels that no modification to the baseline studies is necessary.

This also applies to the second paragraph under Section 6.1.4.2.

O-*1 7 1

,J

.;J

.e

. Pages 6-9 Section 6.1.4.3:

~

Consideration of the preoperational-phase monitoring program for Units 4 & 5 (as provided in Table 6-5)

+

was presented to indicate areas of possible minimal-effort monitoring. Few adverse impacts are foreseen at this time and the description of parameters likely to be sensitive to vague effects or changes is not possible. The applicant feels that the qualitative program being conducted for construction phase moni-toring (Units 1, 2 & 3) should be continued with only minor modification during the preoperational-phase monitoring.

Section 6.1.4.3:

Table 6-5 requires a successional observation on the wildlife habitat quality for transmission line opera-tion. Detailed studies in both Arizona and California on post-construction evaluation for plant, bird, insect, and small enmmal communities to assess natural series of biological events that occur which modify the disturbed area have been conducted.

Because construction practices for 345 and 500 KV lines do not differ significantly and because the specific habitat types occurring in the proposed transmission line rows have already been carefully investigated in the studies noted above, further explication of the impact associated with the PVNGS lines beyond that which can be predicted or for which five years of sampling would provide is minimal and certainly not cost beneficial.

It is suggested that the requirement be deleted.

Also in Table 6-5, yearly data monitoring and evaluation of the phreatophytes to assess seepage from the evaporation ponds is required. This evaluation would provide little, if any, additional information than would be provided by perched groundwater monitoring. It is reco= mended that this indicator be deleted as an unnecessary expense.

J}

7

• n s

2,,d

. Page 9-2:

Section 9.1.1.3, Voltage Reduction, Paragraph 2, Line 7:

SCE test results have shown savings from voltage reduction programs, and these savings are reflected in SCE load fore-casts.

I Page 9-5:

Section 9.1.2.3, Second Line:

~1 Change "Memez" to "Jemez".

Page 9-7:

Section 9.1.2.7, Second Paragraph, Second Line:

Add Nevada between New Mexico and Arizona.

Third Line:

i Change to read, "The Mohave Plant (1500 MWe) is located I

la the southern tip of Nevada and uses coal..."

Fifth Sentence:

Should read, "The Navajo Plant (2257 MWe), located near Page, Arizena, uses coal also mined....."

Page 9-8:

Eighth Paragraoh, Third Sentence:

Change to read, "However, the applicants' figures reflect the benefits of replicating Units on the same site and are comparable....."

4 Page 9-12:

Table 9-5:

(1) Western coal contains a radon content, which results in significant radioactivity released equivalent to that from nuclear generating stations.

(2) There are no planned releases to surface waters from normal operation of PVNGS 4,5.

(3) PVNGS will not consume twice as much water as a coal-fired plant.

Page 9-21:

Section 9.2.1;(Also Section 9.2.3, Page 9-25):

Although the California State laws, used as a basis for eliminating the State of California from the region of interest for siting Units 4 & 5, were declared unconsti-tutional by U.S. District Court Judge William Enright of San Diego on March 6, 1979, a substantial amount of legal effort and time would be required to test the ultimate legality of Judge Enright's decision. Various governmental entities and environmental groups have indicated an intent to test this decision in every available legal forum, f

" a a m

q a

e r s

)

, The projected electrical demands of the participants service areas, requires that Units 4 & 5 be on line by 1988 and 1990. Legal delays, which would be encountered if a California site was selected, would make it impossible to meet these dates. Therefore, the applicant is of the opinion that nuclear sites in California are not licensable in the present state regulatory climate.

Page 9-23:

Section 9.2.2.1, Third Paragraph, Third Line:

The !iUS Siting Study assumed a 1980 completion date for Unit 1.

This date should be the same throughout this discussion.

Page 9-25:

Section 9.2.3, First Sentence:,

Change to read, "It was the original intent of the applicant, based on several statewide siting studies performed for APS and SRP, to site Units 4 & 5 within the boundaries established for PVNGS 1, 2 & 3, since this appeared to be the most environmentally acceptable site. Further, the land area was committed for power plant use, and was large enough....."

Page 9-29:

First Paragraph:

The first footnote should either be deleted or expanded to indicate that this is only one of several applicable geological criteria.

Page 9-30:

Table 9-13:

Footnotes e and d are missing.

Page 9-35:

Fourth Paragraph, Lines 14-16:

Change 46,000 acre-feet / year to 42,700, and 1,840,000 acre-feet / year to 1,708,000.

Page 9-37:

Fourth Paragraph, Third Line from Bottom:

" Unit 1" should read " Unit 4".

Page 9-39:

Table 9-16:

Since the PVNGS site is already dedicated to power plant use, the symbols under " Competing Land Use" should all be " ".

q

~; ]

A J

-.)J La

, Page 9-40:

First Paragraph, Sixth Line:

Change " Colorado" to "Coronado".

4 Second Paragraph, Last Line:

Since PVNGS is dedicated to power plant use, it no longer carries a designation of " prime" land. This should be explicit in this discussion.

Sixth Paragraph, Fifth Line:

Roads leading into the Gillespie Dam site are hardly adequate. Mention should be made of the fact that several miles of existing dirt road would have to be considerably improved.

Page 9-44:

Fourth Paragraph:

See previous comments regarding pages 9-39 and 9-40.

Ninth Paragraoh:

Archaeological mitigation has already been completed for the PVNGS site. Therefore, PVNGS should be rated superior in this aspect.

Page 9-52:

Lakeview West, Land Use. Next to Last Paragraph:

Change the word " semipermanent" to " permanent" and delete the words " access roads and".

Page 10-1:

Section 10.1.1.2, Second Line from Bottom:

Seepage figure is not consistent with earlier stated seepage rates.

Page 10-3:

Section 10.2.3.2, Last Sentence:

Change to read, "Use of this erf.uent would make it unavaiable to support wildlife areas or agricultural irrigation.

Page 10-24: Table 10-8, Footnote a:

The acreage for Units 4 & 5 is already lost to agricultural production from Units 1, 2 & 3.

O

'1 J}

~

t t.oo

..