ML19326D049
| ML19326D049 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 03/26/1973 |
| From: | Finn F ENVIRONMENTAL & ENERGY SYSTEMS, INC. |
| To: | US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 8004300669 | |
| Download: ML19326D049 (3) | |
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U. S. Atomic EncW,y Commission V
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Ilashing, ton, D. C. 20545 N!.M Re: Arkansas Nuclear One, Unit 1 Lake Dardenelle, Arkansas AEC Docket No. 50-713 Madam Chair an and Centlemen:
The Final Environnental Inpact Statement dated February 1973 prepared by your staff in respect of the proposed Nuclear Pouer Station at Lake Dardencile, Arkansas does not, in our opinion, fully comply with Section 102 (2) (C) of the National Environmental Protection Act, Section 6.24 (a) of the Interim Guidelines promulgated thereunder by the Environmental Protection Ar,ency on January 17,197'l or the Corntonion's own rules (which cicarly require an " Independent assessment" of availabic geothermal power alternativer).
NEPA requires not only a " rigorous exploration" ar.d description of alternative courses of action but also "an analysis of their costs and inpact on the environment." President's Council On Environmental Quality, Environmental Oualitv-- Third Annual Report, p. 243 (August 1972). EPA requires that "S pecial carc" must be taken to respond " fully" to comments that are at variance with the staff's position.
An analysis of the staff's evaluation of geothermal alternatives as set forth in six sentencea at page 12-11 of the EIS discloses that no " independent assessment" has been made and that r.o full response to my comnents of October 27, 1972 has been offered.
We note that no commen*a have been obtained from the United States Ccological Survey office in Arkansas nor from the State Geological Survey itself.
It does not appear that the extent and nature of geothermal potential in Arkansas has been determined by professional evaluation nor have availabic references been cited for the benefit of the Commission and reviewing parties.
The staff argues (without referenced authority or documentation) that
" geothermal sources did not provide an economic alternative" at the time the applicant " decided regarding the energy sources" (i.e., in 1967)' The applicant's stated view in 1971, however, as set forth in its own environmental report uns 1
that a) technology was not available for geothermal power generation and b) there were no geothermal sources in its service area. The staff now concedes the i
possibility of geothermal development in Arkansas - but again cites no authority I
for its view and simply ignores any substantive assessment.
The staff apparently refers to binary cycle power systems and argues that only they constitute the t'chnology which can harness the geothermal sources in Arkansas. Putting aside the fact that this approach constitutes a failure to assess the technology available from helical screw or bladeless turbine systems, we focus on tvo aspects of the staff's argument 1) the assumption that binary cycle technology is not available and 2) the assu ption that 102 F-147 F temperatures of hot springs measured at the surface are different from the "400 F" temperatures at The Geysers in California (actually about 3800F) which are nwran m 2nung
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ENVIRONMENTAL & ENERGY SYSTEMS,INC, produced from depths of 6,000-9,000 feet!
Ilot springs at the Ccysers have been measured at temperatures of 104 P-200 F, not t ou di f ferent from the
- turf ace temperatures of Arkansas. The sta f f does not reference any geo-chemient measurements which would indicate temperatures at depth. I have personal knowledge of tests suggesting temperatures comparable to those found at the Ceysers. Nor does the staff reference available geothermal gradient temperatures or heat flou mensrurements. The failure to independently collect and assess such objective scientific information does not indicate the " rigorous exploration" required by NEPA.
The staf f suggests that the " lower-temperature springs found in Arkansas" require development of turbine technology before a successful geothermal power plant could be constructed.
The staff does not assess the two binary cycle geothermal power plants whfch have been operating in the U.S.S.R. since 1967. B. F. Shubin, E:<nerInental Freon Geothermal Power Station, Elecktricheskiyestantsii No. 5, p.20-22 (1967). Cf. Geothermal Resources Council, Geothermal Power Pinnts In The USSR, Volume 2, No.1 (February 1973). These plants have been successfully operating on thermal waters uith tecperatures of 830C.
Nor does the staff assess the binary pouer plant being constructed in California by the San Diego Gas & Electric Company or the possibility of using other technologies. Cf. U.S. Senate Interior Committee, SERIAL NO. 92-31 (1972).
The hot springs of Arkansas are not a phenomena unknown of in 1967 uhen the applicant " decided regarding the energy sources" for its proposed 850 m plant. See, e.g., J. C. Danner, The Mineral Waters of Arkansas (1892);
Cutter's Guide To The Hot Sprines of Arkansas (1902); Ueed, Notes on Certain llot Snrines of The Southern United States, U.S.G.S. Water-Supply Paper 145 (1905).
Sinply said, the applicant lacked the perspective necessary to think of geothermal sources as an alternative fuel supply - a failure of management perspective it shared with all other domestic utilities other than Pacific Cas & Electric Company in California.
The staff references a Rand Report which refers only to the 30,000MJ potential of the Imperial Valley of California and does not attempt to assess the other 20 known geothermal areas of California (which include the Geysers whose total capacity is estimated at 4,000 MJ by the State and 25,000 EJ by private interests).
The staff also references the Peck report (published on Septmober 25, 1972 by the U.S. Department of The Interior) - a report with which the majority of industry panel members did not concur with.and uhich makes no assessnent of the research actually being performed by private industry.
But Rand and the distinguished Dr. Peck notwithstanding, the staff has simply failed to independently assess geothermal alternatives in Arkansas with the rigor and care required by the applicable statutes and regulations. No alternative costs are even considered. All in all we find a cursory skim across the surface of available information uhich we do not believe is satisfactory for administrative adjudication.
Very truly yours, h %dk T Nt ts A _
Donald F. X, Finn as E:<ccutive Director Geothermal Energy Institute 680 Beach S reet t
San Francisco, California 94109
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-- m, UNITED STATES OF AMERICA ATOMIC ENERGY CoteiISSION In the Matter of
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ARKANSAS POWER & LIGilT COMPANY )
Docket No. 50-313 (Arkansas Nuclear One, Unit 1
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CERTIFICATE OF SERVICE I hereby certify that copies of a letter from Finn to AEC dated March 26, 1973, in the captioned matter have been served on the following by deposit in the United States mail, first class or air mail, this 2nd day of April:
Horace Jewell, Esq.
William Massar, Esq.
Philip K. Lyon, Esq.
Regulatory Staf f Counsel House, liolmes and Jewell U. S. Atomic Energy Commission 1%0 Tower Building Washington, D. C.
2054":
Little Rock, Arkansas 72201
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Of fpe of theiecrptary of thf pommission cc:
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