ML20009B861
| ML20009B861 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/13/1981 |
| From: | Fouke R CITIZENS FOR FAIR UTILITY REGULATION |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0775, RTR-NUREG-775 NUDOCS 8107170259 | |
| Download: ML20009B861 (3) | |
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- m CITIZENS FOR FAIR UTILITY REGULATION (CFUR) A'V
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'S 1668 d CARTER DRIVE g
ARLIfMTON, TEXAS 76010 ft'
.A July 13,1981 g
to Office of Nuclear Reactor Regulation
,pb 3'
U.S. Nuclear Regulatory Comnission p
' D 'cb Washington, D. C. 20555 C[T9 g i.
Re: NUREG-0775 DEIS Conanche Peak Dear Sirs CFJR would like to take this opportunity to coment on the two sections of the DSIS that it has examined in detail.
PURPOSE AND NEED FOR THIS ACTION 1)
Table 2.3 presents Capacity Resources, Peak-Hour Demands, and Reserve Margins for TUCS. The last paragraph on page 2-6 indicates that differing projections of demanc^ yowth exist. Nevertheless, the NRC Staff has chosen to present outdated data in Table 2.3.
The following figum presents a conpi3ation of projected demands for i
TUCS obtained by adding together the seperate demand projections of each TUCS sister conpany fron their nost recent rate increase requests to the Texas Public Utility Comission. As can be noted, these conbined demand orojections are consistently lower than that presented in the DEIS. By sinply adding the saperate projections, it is presumed that the individual conoanies denand projections are coincident - a situation not necessarily true and which tends to overstate the demand projections.
TUCS PEAK DEMAND PROJECTIONS (MW) 1 Year TESC0 TPL DPL TOTAL 1981 4280 5620 2850 12,750 1982 4495 5910 2950 13.355 1 - Docket 3250 June,1980 1983 4715 6220 3050 13,985 2 - Docket 3780 Mar.,1981 1984 4945 6560 3150 14,655 3 - Docket 3460 Sept.,1980 1985 5185 6940 3250 15.375 l
1986 5435 7320 3350 16,105 Substitution of these demand projections in Table 2.3 yields the following reserve margins (%).
WITH COMANCHE PEAK WITHOUT COMANCHE PEAK 1981 40.8 40.8 1982 41.9 34.1 1983 35.3 27.9 9 03 1984 35.0 20.9
_r 1985 36.6 23.1 1986 33.3 20.5 f
9107170259 810713 PDR ADOCK 05000 D
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l CFUR recommends that the NBC Staff obtain projections for TUCS made 1
in 1981 to include in the EIS published in 1981.
r 2)
Table 2.2 presents the TUCS Projected Annual Fbel Costs through 1986.
6 The estinated increase in Puel Price ($/10 BTU) from 1979 to 1986 is 178%
for Lig.'ito and 96% for nuclear fuel. No substantiation for this projection i
is supplied. Lignite (and/or coal) is the more abundant fuel in the.U.S..
There is a great deal of uncertainty about the suoply of U.S. uranium (Liebernan, "U.S.
Uraniun Resources - An Analysis of Historical Data".
Science, Aoril 30, 1976 and Ietters in Science, Ma: 6,1976). Sone measure l
of independent substantiatirn would seem to be in order.
On page 2-2, the following aopears: "The applicant states that by 1990 it will have fully exoloited the lignite deposits of central and eastern Texas.* *
- Furthur fossil-fuel expansion beyond 1990 will have to be based on coal." Yet the applicant has attemoted to sell a lignite facility to Houston Lighting and Power and has just succeeded in selling water fron Lake Fork in East Texas (impounded for the purpose of constructing a lignite facility) to the City of Dallas while retaining future options on part of the water rights.
The applicant has purchased a large quantity of coal deposits in New Mexico and has announced preliminary plans for a large coal facility located in Texas near the New Mexico border. In addition, the applicant is engaged in a vigorous developmant program in an attempt to utilize gas produced in deep-basin lignite deposits in central and eastern Texas.
For these reasons, it appears unreasonable for the staff to conclude that the replacenent of any energy not produced by CPSES Units 1 and 2 through 1990 would have to cone from lignite and gas in about a 50:50 pronortion.
If there is any basis for this conclusion, it has materialized through default of alternatives until such time that a remedy is not practical - not because of any overriding naad to construct Conanche Peak.
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PRORABALISTIC ASSESSMENT OF SEVEREACCIDENTS and DOSE AND HEALTH IMPACTS 1)
Table 5.20 presents a Summary of Environmental Inpacts and Probabilities.
Footnote (a) states that there is only a 30-year period over which latent Cancer i
Fatalities might occur. It is not clear from the text whether this 30-year l.
period is an age or disease related period or whether it is the expected l
period of operation of Comanche Peak (the license request is for 40 years).
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Clarification would be helpful.
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2)
Table 5.20 indicates that 2,800/2,800 Latent Cancer fatalities occur at the 10-0 probability level.
Footnote (b) states that this number (2,800) is related to thyroid cancer fatalities only and that cancer fatalities of all other organs do not contribute, An exanination of Figure 5.6 (upon which the table relies) indicates that the graph for Latent Cahcer Fatalities excluding Thyroid has not been extended to intersect with the 10 probability coordinate. CFUR is not aware of any physical phenomena which prohibits this from being done. It appears to CFUR that the conclusion that only latent Thyroid Cancer Fatalities exist at the 10 probability level is not correct and should be corrected.
3)
CFUR has additional reservations concerning this section but will rely on the intervention process to resolve them.
Sincerely, Richard L. Fouke
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