ML20050J448

Motion for Order Requiring Admission & Production of Documents within 10 Days.Related Correspondence

ML20050J448
Person / Time
Site:	Palo Verde
Issue date:	04/07/1982
From:	Hourihan P HOURIHAN, P.
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8204140183
Download: ML20050J448 (14)

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_y UNITED STATES OF AMERICr. g REcy, EM ,.73 gp ,

NUCLEAR REGULATORY C0!/J4ISSION dp

. 4 BEFORE THE ATOMIC SAFETY AND LICENSING BOARQ y In the Matter of ARIZONA PUBLIC SERVICE .

CO:f?ANY, et al. Docket Ncs. STN 50-528 STN 50:529 (Palo Verde Nuclear Generating } STN 50-530 Station, Units 1, 2 and 3) '

MOTION FOR ORDER REQUIRING ADMISSION AND RODUCTIDM CF DOCUMENTS WITHIN TEN DAY _S The Intervenor moves for an order requiring The Applicant to admit' the genuiness of a document and to produce 10cuments at its offices in Phoenix within ten days after serv.:e on

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the Applicant of this motion or on April 16, 1982.

Attached to this motion is an APS report dated : ovember 17, 1977 entitled "Use of Effluent at Palo Verde". The :ntervenor needs to be able to identify this report and requests that APS be required to admit that it is genuine.

I On page 7 of this report it says that the effluent re-quirements during peak summer months are about 2,600 A-F/ unit.

We wish to examine and copy the engineering report on which this statement is based and to examine and copy all other reports on water requirements that APS has.

Intevenor has just obtained a copy of this repor; from a person who refuses to be identified. This report is contrary to the testimony of the Staff expert so obviously the Staff does not know about it.

b 8204140183 820407 f0

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l Respectfully submitted this 7th day of April, '.982,;

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By_ IJh!;t., M1 J 1

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Patricia Lee Houritsn 6413 sodth 26th Street Phoenix, Arizona E3040 l

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laIZONA 17JCEAR PD.ER PRQJFLT i PAID VERDE IUCEAR GEERATING STATION

USE OF EFFWETT AT PAID VERDE We at Arizona Public Service, along with every responsible utility executive in Arizona, fully appreciate th2 need for prudent, comprehensive mnagenent of our liarited j

eter resources. Without mter w simply cannot generate the i electric power that the public needs. We also recognize that '

o:hcr sectors of our economy and the public at large have

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de-ands on car wter resources that are just as legitimate E" o

as oars. We understand that if these other de ands for uter are mt met, there won't be nuch need for electric powr because  ; ,

a th2:e wn't be any public around to use it.

Consecuently, we are anxious to assist and cooperate 2 1 with MAG and every other organization that is concemed with the . t i

usc. g 2 nager nt f water in Arizona. We offer our assistance L -

mt because we unt to establish a claim for priority status dcugh w h)pe everyone recognizes that reaso:ubly priced electric j

, po,cr is an irportant ingredient in irrigation, cournerce and 'E I

Wtry and the pleasant amenities of life such as swimning pools.

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c Tnerefore, we offer assistance and cooperation not to get =i a leg up on sacrebody else, but to assure that infortred judgents i ,

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) are cade on the use and mnagerent of mter -- judgnents that are -

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> fded upon correct informtion with goals that are achievable in

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i the real wrld.

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4 Tcxiay, we are concernc-j nore ,.-ith tFe infornation recuired to make those inforned judgenen:< rath.r than -ith the establishrent of specific goals, such as water for recreation As we see it, in order to trake sound judgaents in this cery ccrplex subject, ym nust g

have sound information. LTnat they say sbmt enter progrrrr.s --

" Garbage in, garbage out" -- is e ;ually applicab' e to water use ~

B and nanagcaent studies. -S4

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di Unfortunately, several r.isccr :eptions hr/e surfaced that need correction if 5.e are t: a coid ccafusi: and uninfor e:i

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judgnents that could lead to serirus ccr. sequences not only for k 5

2 L Palo Verde and other generating p ojects, 'mt for other ele:ents of hi' m L cur scciety as well. :t

-j t Before addressing Palo 'Jerde directl;.

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_et me explain ,

Ms 1 briefly has water considerations m er 2:o a u:i_ity's planning eV g

ard operations.

- I It all starts with si:Sg -- etre do we put cur j 1 h l new generating resources? Imredi.arely, e are fac ed with a cFoice -- n v G

will it be coal or nuclear? Each al:er .stive 'r.:.s its cun special considerations, but both require +ter.

In selecting a site for a cos_ electri s enerating plant, the prime parrereters are (~_ , Oc ::urce c f -he coal and (2) the availability of water Ir cr.tainms Arizona with ^

abost non-existent north-south rail co ections it is far rore - "

econmtical to nove energy by wire than 'c:. rail. Cc .secuently, I

tcday Arizonans rely for the bulk :f thei electri; requireaents on I long transmission lines to coal piants ga-.erall:, si uated near or in g

the northeast corner of the State, r:re 20-400 -l'.es away fran the mjor load centers where the elecric rc.nr is need--d.

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-l Another characteristic of Arizona coal generating

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plants is that each one involves the first and sole use of f

mter. The sources are the Colorado River or scre tributary 1 cr a gathering systern of w11s tapping underground reservoirs. 5 There is no other choice. E There are no large semge treatrent j-plants on the Indian resenations. Ibr is there any tailmter or drainage frce irrigation faming. So, reuse of m ter for

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coal generating plants is out of the question.

Enen it came to siting our Palo Verde nuclear plant, a

'y a were presented with scnc different problems and also scue ne. opportunities.

f Transportation of uranitrn fuel presents no -

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i restraints on the location of nuclear plants so w could rcdace 1 M

relir.nce tqcn very long transaission lines and locate the plant 3 near our load centers. 7 L

We fcr:tl a new restraint, hncver. We had to be 3 i

e able to prove for the cost questioning minds that the nucler site ms seimiically stable. Oar gcological siting studies, 3 started in the Spring of 1972, told us that there are tw 1

areas in the State diere we would be rest likely to find a j site with der.castrable evidence of seismic stability: (i)

E the Ibvajo plateau in the northeast corner and (ii) a relatively

]z narrcr.e band lying to the wst of Phoenix running in a 2l northmsterly-southeasterly direction. This w s precisely i

k dat we wre lookmg for -- a site near the Phoenix metropolitan i area, the load center dure more than half of the powr to be a

generated muld be used and diere a previously unused mter resource - semge effluent - was available. -

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t Tne 91st Avenue Sewage plant presented not only a l new potential source, but the opportunity to reuse a resource which was t

I i then going largely to mste. Tnis is a prine exanple of good

, j l I wter managment undertaken by private industry at substantial i

i expense wit' rout any goverrmental or bureaucratic prodding.

Obviously, if we were going forward with a multi- , g billion dollar project, it us vital that w do what ms necessary I

to secure a cocmit2nent of the needed water supply. Here, we found I that w had no alternative but t're reuse of effluent. Tnere was and there is nw no unappropriated surface water available. Tnere ms tren and is now no irrigation tailwaters or drainage water i

available in sufficient dependable quantities to met our needs. }j And there was not and is not sufficient grounduater available which, j it if appropriated for our use, wuld not severely dislocate agricultural Jf activities over a very large area.

Accordingly, in early 1973 m started negotiations to X'

acquire effluent, and in April, 1973 we signed a contract with the six cities which own the 91st Avenue Semge Trcatment Plant.

Having acquired the rig;ht to use such effluent w t, j

then lud to learn how to use it. Tnere really as not nuch experience e

to fall back on with cnly a few instances wMre semge effluent has been used for cooling electric generating plants. But we did knw that tertiary treatment -- or what we call a reclanation facility -- I 3

t would be required. We also knew that this facility would have to be k

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designed to handle the quality of wter that wuld be delivered to Palo Verde. 4 4

i To determine the kind of tertiary treatment and the functice.a1 require:ents of our reclanation facility, w built a pilot plant at s.

the 91st Ave. plant in 1973 and operated it for about 15 nonths at a y y k'

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I cos; cf $1,100,000. One of the things w learned from this

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pilot operation ms that the tertiary tmment had to be designed it i to hrdie mter within a certain range of chcmical characteristics i

h ard tc:al dissolved solids ('DS). We'lcarned that it is rx>re practical to design a facility to process mter wi:h a li .ited range of TDS -

say frx 500 to 1500 ppm - than a very w'de range of 0 to 5,000 -

ppa. *'e also learned that it is not feasible to process mter with CS in the range of 3,0C0 to 4,000 ppn in a facility designed to trcat wter in the 500 to 1500 ppm rec.ge.

Using the criteria established by the pilot operation, j

w thr. proceeded with the design of our recimaticn facility I

an; i: is dependmt upon LN receipt and rocessing of mter with t'..e gaality approxi:rati .g the efflue.: frcr. tM 91st Avenue i

plant.

1, The design is ncv virtually ecdete and sre purchase c:ders l

l pave : w. placed. Grading of the mter rec 1 ration arca is cccple:e I

e a :artion of the on site underground cistributien systcm has

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bee ::alled. Constniction of the water recla atir, pipeline fra: Es: Avenue and constniction of the .mer rec 1 ration plant is scheduled to start April,1978. Ccgle. ion of these systems is res;rei in 1980 in order to eet the schaaule for cperation of Palo Verde ;ni: 1.

In all, the recimation facility and the transport systen

, represent an investncat of ab7at $150,000.000.

11 Any redesign effort undertaken at this late date in order to prc. cess wter beyond the design range of 'DS or with new characteristics t;ach as pesticides ard new organics wald x only cause extensive delays bri ci .g about exorbitant increases in cost, they coc1d also scrimsly m

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4,ir our ability to neet the electric energy needs of our s r custarers.

r Each of the thits at Palo Verde is inportant in 5 i

meting the State's energy needs in the tine frane in which

(' they care on line.

Any delay in that schcdule muld raise i

[ the prospect of electrical sMrtages for Arizona, j

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l- Tnere is another part of our story tMt should be ~

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of interest to you.

i I Eecause the total cost of the reclaimed effluent

• L will be great and because there are limits on the availability 1 of effluent, w wre cmpelled to design our cooling systen p

, to raximize the use of the available effluent. Tne result r is that we Mve been able to design our system to operate 4 h.

at DS concentrations up to 14-15 tir,es the original levels. Ib

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In contrast, four other electric generating plants -

tMt use effluent for cooling, tm in Las Vegas, one in Amrillo ,

and one in Lubbock only achieve a level of 4-5 concentrations.

y A nore dricatic my of getting this point across is [.

to cite the progress we have made since we started. 'inen we 'I i started, w estirated we muld consrce about 35,000 A-F/yr. for 'b

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cach of the Palo Verde Units. When we had ccupleted our pre-I limiracy design, we were able to reduce this esti; rate to about l' 25,000 A-F/yr.

Now with our design substantially ccnplete our i>

best estirrate is that our effluent requircrents will only be i0 i 21,000 A-F/yr/ unit. 0 Accordingly, for the first three units at Palo Verde, total effluent requirarents would be about 63,000 A-F/yr.

J i mis annual mint will not be requircd until 1987, the first &

I, full year, when all three units are operating. Tnis muld L

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gaunt to abcut one-third of all of the effluent discharged '

P frcn the 23rd and 91st Avenue plants in 1987. i s

If Units 4 & 5 are built then our needs will be about 105,000 A-F/yr. in the year 1991 and beyond. This u uld be 517.  ;  ;

i of all the effluent expected to be discharged in 1991 and a sraller percentage cach year as the mount of effluent gows. (4,400 A-F/yr. .

is the projected grcrath rate in the 90's).

We think it is very inportant that you get these rmbers cicarly in mind --- 63,000 A-F/yr for three units in 1987 and 105,000 A-F/yr. for five units in 1991. We consider thcm to be conservative, but realistic estimtes.

Ue also want to nake clear to you the distinction I bet. men the comts of effluent we expect to consrc anmally _E F

ard the ancm that nust be contracted for on an amual basis. ];

Tne average nonthly usage will be about 1,750 A-F per unit. )1,1 a

e But 1bther Ihtu e does not permit us to use averages. Evaporation j I; r.

rates increase with rises in temeratures. Consequcntly, in the f  :

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average adverse sinner nonths we expect our effluent requirewnts tc peak at about 2,600 A-F/ unit.

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Tnese nunths also coincide with (, 7 i

the period sen the public needs electric power the nnst. Tnerefore, ,

it is pradent, and necessary to avoid cutting hack electric generation

&n it is r.eeded nost, to contract for effluent, .;hich is done on

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an annual basis, in sufficient quantities to cover our peak nonth f<

requircants with a sufficient allowance to account for expected ?i I

' variaticas frcra average atrospheric conditions.

1j Tcus, we see a need to secure ccmitr,r.ts for abcut 4 .ti .J

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' 93,600 A-F/yr. for three units at Palo Verde and 156,000 A-F/yr. '1

. for five units. But, I want to stress that irrcspective of the $!.

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contract anounts, actual conm ption annually will be ap,:roximtely 63,000 A-F for three units and 105,000 A-F for five t:dts. The difference betwen tle contracted aacunt of effluent and the 1

actual arount used will be available for other uses.

i With these facts in mind, you will recognue that the statenent in the Corps of Engir.cers' Septc.ber 28, 1977 report -

that "the current p]ans call for Pv'K;S to consne sore 75,000 j q

acre-feet per year of semge effluent in 1982 and about 1990 1 increase their consuaption to 140,000 acre-feet' is absolutely erroneous.

t There are several other misconceptions contained in )

this report which rust be clarified. First, it is reparted that w feel w "have no trandate or authority to investigate g mdv.nter use my further" We categorically deny this statetent.

M our studies for Units 1, 2, & 3 which are describrd in the Pala Verde l Enviromental Report and the Final Faviromcatal State:ent, w considered several alternative mter sources and concludec that the use of seage effluent ms the best choice for Palo Verde " nits 1, 2, &3.

In var present activities relating to Palo N ?e Units 4 '. 5, we are

{i continuirc to investigate the quantities and qualities of poundmter available, the feasibility of its use at Palo Verde and the impact of such use.

In this context w do raintain that changing ar reclarration  !

facility design for units 1, 2 and 3 at this late date to '.andle saline unter wuld be disastrous to the utilities and the public @.o

' vill need the Palo Verde powr.

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> Tne report goes on to state that 'Nr[ Weigold me.tioned I ii th,t about 150,000 acre feet of mter per year are punged cut of the '

gound in the Buckeye area through their combined irrigaticr. and I

% r dc.ntering programs". We deny th3t Mr. ',le18 o1d ever said rc.y f

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such thirc, and we add that the fac .s are substantially different.

l i The records show that in 197'- groundater pmped for irrigation f

I ms 53,600 acre-feet and pumped drainage mter am3unted 11,500 acre-feet, or a total of about 65,000 acre-feet. It has been reported to us that e in 1976 drainage pw. ping had increased fran 11,500 acre-feet to about i

w 20,000 acre-feet. 'Ihus, it is cler t'at all of the irrigation and

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l drainage wter in the Buckeye Irripti: ; District (BID) is not 2

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3 sufficient to reet our requirements. -

The Corps of Engineers re;-r also represents that :t. Weigold

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stated that BID would prefer effluent i exchange for groundater if f

this were possible. Mr. Ueigold said .: such thing. The facts are (1)

Iuckeye has offered its drainar;c water for use at Palo Verde, and (2)

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s Iusrye has never suggested or propcsed :o substitute effluent for the h

grcrdmter it uses for irrigation. B=keye must continue to pmp this a y

ground.mter in order to mintain a pro;er hydrological balance. i It is also purported that 'W. Weigold expressed the opinion

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a thn the fertili2er value of the effluem: is indeed recognized by the g g

far;crs of the BID, scue of whan fa M vi-h no additional fertilizer." '

Even if it were true, this statement is possly misleading. '

The facts are that the irrira:ica wells in Buckeye area have b

' p.crally produced water with a high mirate content. Indeed, a N[

capariscn of sanples of the water dicer:ed from the river into the t 7 f Suseye Canal (nostly effluent) with sa-les from the Buckeye i irrigation wells shows that the nitrate content of the well wter to r F

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be the src as in the effluent. >

A study is currently being ccr.i.rted by tlu University

of jeinona to detennine whether sewge effluent used in tie hi

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f. a;ckeye Valley has had significant or substantial effect on crop f yicids or farming practices. Tnis study is not co nlete. H2.ever, I w can say that, since 1967 . hen effluent first beuce available t.

i in significant a ounts, there has been no report cf any drrcatic

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i increase in yields.

Finally, w wre som. hat concerned by t.o state.uns rade ~

in the letter of October 26, 1977', inviting us t o dis cceting. Tne first of these uns to the effect that the quality of the grounauter in the Buckeye area is deterioratira. k'c wre concerned by this statement, because it was directi-, contradictory to the data which we had revic.'ed in 1974 and advice .c h,d i rare recently received frcm cur water consultants Pr. we consider to be (rainently quali fied experts. l i

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Since w receiva! your letter, we have dr.a sone rare 1

i checking and this is what we have been told.

1. Tne ground.nter quality in the ;ckeyu Area '

has always been bad.

2. Frcea 1935 to 1955 there as a cr=cm1 deterioration of qa lity.

3. Frcra 1955 to the present the qua'ity has i.mproved.

Tne second staturax in the letter wt.ich cancerned us sus to the effect tint the only solution to i. prccing the

, c.nlity of tre eckeye grods.er uns to use this 12.: cuality uner as coolant for t're Palo Verde generating units. Tr.e letter goes en to state that ycur engineers do not have sufficient inforration to ccxthde whether such a plan wald be feasible and re yested us to give you such informtion today.

l We have attugted to cogly with this request by asking

w. Ironard Halpenny to prepare a report on this subject. He is r

present with us tcxiay and is available to answr any questions you ray have. -

Tnis gist of his report is (1) continuance of groundmter -

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pr; ping is and will continue to be necessary to raintain the hydrological .

t h,larce in the Buckeye Valley, and (2) there muld be no significant ,

I benefits to the Buckeye farners in exchmging their irrigation I goundmter for effluent. '

Tne second part of the feasibility equation is that wuld '

the use of the Buckeye groundwater do to the Palo Verde plant.

One result is that we cannot achieve 14-15 levels of concentrations with highly saline water. Instead, the ra.v.i=n levels of concentrations uuld probably be in the range of 4-5 ccatentrations j at best. Tnis wuld nean that our constaption of water w.:Id increase 3 tw or three fold. Consequently, our mter requirer,ents for Units 4 & 5 -;

t uuld increase from about 42,000 /i-F/yr. to about 80,000 to 120,000  ?

A.7/yr -- substantially core than tre Euckeye .rells can sgply.

v Other inpacts of c' ranging the mter source for Lhits 4 & 5 j wald be changes in the design and result in increased costs for the  :

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1. 1 Evaporation ponds - they m uld have to be enlarged. g I

2. Cooling towers - they muld have to be redesigned and the j size or nuniber trey have to be increased. i Z

3. Reservoir - a larger size muld be required because of the 3 increase in the cooling water require ents. j v

4. Rec 1 nntion facility - a new pilot operation ray have to be conducted and a new design developed.

5. Gathering systen - for collecting and transporting groundwater )

separate fran the effluent muld have to be 4 3

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Operation wuld be nore difficult and caplex, i because the cooling water for Units 4 6 5 wald j hwe to be controlled separately from the cool- i ing unter for Units 1, 2 & 3. -1

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I hope that what I have said and the infonration I hwe given or corrected will be useful to the Ccmnittee.

j If you hwe any questions at this tine, either I or Mr. Halpenny will try to be responsive.

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If there are questions which occur to you later, we will do our best to -

-e answr those too. As I said earlier, we share your ir.terests in sound 9 mter rnnagerent. Since our interests are nutual, we ., ant to be J helpful and ccoperative. d t

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