ML20032B256

Affidavit Discussing Operation of Cooling Water Pumps & Effects on Ecology in Area

ML20032B256
Person / Time
Site:	Diablo Canyon
Issue date:	10/29/1981
From:	Jaffer J AFFILIATION NOT ASSIGNED
To:
Shared Package
ML20032B251	List: ML20032B250 ML20032B256
References
NUDOCS 8111050355
Download: ML20032B256 (5)

Text

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M Of CAbiffbMO, 2

CI1T Alt COUN1T W IDE A3CEta$)

3 AFFIDAVIT OF JML S..IAFFU 4

CISMS NOW The Affiant, Joel S. Jaffer, and does under penalty 2%

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of perjury and pursuant to the laws of the United States affirm 6

the fonowirs in support of the Asmoded Motion for Br liminary e

7 Irdunction in the United States D6 strict Court for the Dentral 8

District of California, in that case sty &ed Joni Jaffar me si..

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9 wA-ina c. mmun. Jr.. er mi., CV-81-4958-R(G), t 10

1. I am the named plaintiff in that certain cause above-11 referended now pending in the U.S. District Court, Central District 12 of California.

13

2. I am personally familiar with the documentation submitted 14 to, by and for the Cafifornia Hagional Water Quality Control

-4 51 Board by Pacific Gas & Electric Co., 77 Beale St., San Fransisco, 16 CA, pursuant: to section 402 of the Federal Water Pollution Control 17 Act Amendments of 1972 for a National Ibilutant Discharge Elimination 81 Barmit (NIVES) (FWPCA) CA3751 effective April 19,1976.

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3. I am personally familiar with the general design concepts 20 of Pressurized Water Haactora utilizing nuclear fission for the 21 production of steam generated electricity, particularly the West-22 inghouse Pressurized Water Raactors(PWR) now present at Turkey 23 Ibint Plant Units 3 & 4, operated in Dade County, Florida by Florida Power & Light Co.under licenses DPR-31 ap DPR-41 from 24 25 the United States Nuclear angulatory Cnandesion.

26

4. Pacific Gas & Electric Co. (PG6E) has commenced construction 27 of two PWR 4-loop coolant system Westinghouse nuclear reactors 28 (Unit 4s 162) at the site commonly known as "Diablo Canyon" s

y Joel Jaffar received a LA. deg:e: dr. !h'Wtics fro:s the University of Chiensa l

197d, His enurse of study includea alaulcal p!;ysics and general and a'='d=1~-

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1 in San Emis Geispo comaty, California. h best awhangers for 2

same consist of 58,216 recently installed titanium tubes 40' E 29/32" l

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decay of 2K 10 mils / year under normal operating conditions flow 7 fys. l 6

5. h natural abb and flow of the tide.in Diablo Covo, 7

wherein is located the did-ege outfall for the, main once-throgh 8

secondary coolant system for the plant produces a total volume 9

turnover in such cove of from. I to.211 billions. gallons per day (bsd) 10 during ebb and from 1.4 to 1.8 bad during flood. tides according to 11, studies of the California Department of Fish & Gama.

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6. Diablo Gove is, and/to a greated extent prior to constsetion 13 of the Flant, a natural habitat and spawnirs grounds for over 120 14 discernable species of plant,and animal life, including the abalo'ne 15 clan specially indigenous to the area. It is a habitat prone to 16 supporting life in immersed soil and vegetation habitats, including 17 bull kepp, soo and phyto plankton and small fin fish.

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7. After the operation of the circulating coolits water pumps 19' -in 1975 a significant portion of the abalans population was found 20 to have. died from increased exposure to heavy metals including copper 21 due to concentrations of approximately 0.010 mg/l in the ambimit water, 22 by the calfiornia Department of Fish & Game as subsequently consented 23 to in a settlement of enforcement action between Calfernia, h U.S.

24 Invioramental Protection Agency, and 1U63.

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8. hre exist.in the Northern end. central regions of Diablo 26 Cove unusual gyres producing sluggish circulation of ambient. water or tide 27 accordi% to such proceedings.

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9. h construction of intake water inist breakwaters in the

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I cov e immediately to the south of Diablo cove (" inlet cove")

2 was found to have completely reduced and eliminated its ability 3

to sustaen acquatic life by increased tsubidity and siltation 4

still existing in the obient water at this time where not weahdd 5

off with tidal action in the south part of the' cove, or where 6

exposed to the recirculation of discharged water to the north.

l The natural current in the ambient ocean is from norr a to south.

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10. h inlat cove is also the site of dischare outfallt 9

of the reactor's domineraliser regenerants, makeup water system 10 and other auxibiary systems. Backmash from the resia domineral-12 idsers can produce up to 300 gallons per minute flow with the following properties conductivity 400 micromhos/ca, pH' (from sulphuric 14 -

acid) 9-11, calcium sulfate prweipitates and condensates powdex 0.01-0.06 ga11ons/1000 lb. of water treated (125 gallone). Prior 16 to treatment in a pond on site, the regenerant contains calcium 17 carbonate 185 ppe, negative Chlorine ions 96 ppa, negative Floatine 18 ions 0.16 ppa, sufstes 980 ppm, 3.75 toxicity units. The make up water system is respensib1m for discharging 216,000 gallons /dg 20 containing suspended solids of 0.05 parsa per million. Beth 21 discharges have to potenti s1. of containirg chlorine sad residual 22 chlorine of 0.5 mg/l.

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11. REE proposes to discharge several internal systems 24 into the main secondary coolant wLthout monitoring or measuring 25 such streams at the point at which they enter the main outfall.

26 The radweste system willi discharge 30,000 spd with concentrations 27 of hydrazine, ammonium hydroxide, lithium hydroxide and sodium sulfate.

Non-filterable resideas will be present in 3.0 mg/l concentrations.

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1 The main discharge will conside of 2.67 billions gallons per day 2

at a temperature 20 degrees Fahrentdit higher than at intake, and 3

up to 50 degrees higher for stated periods of demusseling, will 4

contain strontium, uraninsu and zirconium, titanium 1.1 lbs/ day, 5

foam, oil and grease in concentrations of 10 mg/l and mercury 6

in concentrations of 9 microcuries/ml. In addition, the following 7

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elements can be discharged in the followisql masses; from said 8

main discharges arsenic -8500 pounda per day, dadmium -3500, Total 9

chra=fum-2300, copper-5300, lead-9300, mercury-150, nickel-23,000, 10 sildver;480, sinc-21,000, cyanide-5800, phenolic compounds-35,000, 11 ammonia (as nitrogen)-695,000, total chlorinated pesticides and 12 P$CB's-90, and trace amounds of rhodamine dye.

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12. IG&E has an offered testimony before the said Water Board j

10 that all emergency and other core coolios systems will cease f

15 operation issnediately upon aqy seianic disturbance or break in Ib containment, or reactor vessel.

17

13. IG&E has stated its intedded schedule for low-level 18 testing of the Diablo Plant to include hot testing at 57. levels 19 and diverties and venting the heated secondary coolant throughi l

20 a new valve as steam to the atmoshpere ambddnt to the plant. T is f

h 21 procedure and operation was not engineered or included in the 22 4

NPDES permit CA-3751 aforesaid.

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FUErHER, Affiant sayeth naught. I reaffirm che foregoing as true 26 and correct to the beat of my knowledge and belief, under penalty of f

!27 perjury and pursuant to the Laws of the q

pates.

5 28 Signed October h,1981, R

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