ML20052B671

Motion for Leave to Submit New Contentions or Alternatively, to Amend Current Contention on Inadequate Assurance of Water.Motion Based on Recently Discovered Info.Certificate of Svc Encl

ML20052B671
Person / Time
Site:	Palo Verde
Issue date:	04/26/1982
From:	Bernabei L HARMON & WEISS, HOURIHAN, P.
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8205030433
Download: ML20052B671 (49)

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Ma UNITEL STATES OF AMERICA NUCLEAR REG 11LATORY CCILMISSION

'C2 [C 29 10 O BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter'of )

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ARIZONA PUBLIC SERVICE ) Docket Nos. STN 50-528 COMPANY , ET AL. ) STN 50-529

) STN 50-530 (Palo Verde Station, Nuclear Units 1, 2Generating and 3) ))

f(OTION OF INTERVENOR TO ADD NEW CONTENTIONS OR ALTERNATELY AfAEND HER CURRENT CONTENTION ON INADEQUATE ASSURANCE OF WATER Intervenor, Patricia Lee Hourihan, pursuant to 10 C.F.R. 2.711 (b) and through undersigned counsel, hereby moves for t

leave to submit two new contentions, or in the alternate, amend her contention on the water issue to promote a clearer focusing of the issues in this licensing hearing. The new contentions she seeks to submit include a refinement of her contention concerning an adequate assured supply of water f ."

the plant, the normal safe shutdown of the plant, and 6

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safe shutdown of the plant required by an accident. N

q D*. ,OQg,%q I. BACKGROUND p- C  ;

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On t0 arch 17, 1982, the Licensing Board denied J t D '

Applicants' Motion for Summary Disposition on Interven j Contention No. 5 which reads as follows:

" Applicant will not have an assured supply of usable treated municipal effluent for cooling purposes for Unit 3 of PVNGS during months of peak reactor need for the first five years of operation."

f In its II.cmorandum Order the Board relied on a -letter from b Mr. Bill Stephens which indicated that Agreement No. 1390f t 1

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.3 820 5 0 3 0 c/35 pp y Sfl.

a e under which Applicants contend they can obtain sufficient .

1 effluent tc operate Palo Verde Unita 1, 2 and 3 was currently being renegotiated. Among wie issues the Board noted were '

being negotia'ted were:

1) The extent to which the cities could, pursuant to the Agreement refuse to deliver effluent to Palo Verde when the cities critically needed the water;

2) the amount, if any, available for cooling purposes i

for Falo Verde Units 1, 2 and 3: l

3) Permissible uses of the effluent other than for coolinF purposes for Palo Verde:

4) Cost of effluent for Palo Verde Units 1, 2 and 3:

5) Source of effluent for Palo Verde Units 1, 2 and 3 On April 7, 1982, Intervenor moved for an extension of time on the ground that she had discovered new evidence which indicated that Applicants could not ensure an adequate supply of water of an adequate quality for use at Palo Verde. She submitted, in support of that motion, a legal brief of the Salt River Project which argued that City of Phoenix was not entitled to sell effluent outside the Salt River Project boundaries, precisely what the cities propose here in their sale of effluent to Applicants for use at Palo Verde. She also cubmitted a letter from the Solicitor of the Pepartment of Interior, dated February 25, 1980, which states that Uniteo States government maintains control over all water, including all re turn flow within the boundaries of the Salt River Project boundary, and therfore its use at Falo

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.erde is illegal, especially in light of possible prior claims of Indians residing within the Project area.

The Board, on April 13, 1982, denied Intervenor's request for a 30-day postponement on the ground that it should not subordinate its licensing process to issues which were the subject of litigation. However the Board did request that counsel present argument on Intervenor's new evidence which suggested that the City of Phoenix was not legally entitled to sell effluent outside the Project boundaries.

On April 22, 1982, Ms. Hourihan retained counsel to represent her in the licensing hearing.

For about 90 minutes on April 23, 1982, and in a second short session on April 26, 1982, Intervenor deposed Mr. Van B ru nt , vice-president of the Arizona Public Service Company.

Applicants' counsel also provided some of the documents relevant to the water issue formerly presented to-Intervenor for inspection, but which were not copied for financial reasons.

II. INTERVENOR HAS FET THE STAI4DARC SET GUT IN 10 C.F.R. 2.713 FOR GRANT OF LEAVE TO FILE NPF, OR IN THE ALTERNATIVE, AMENDED CONTENTIONS CN THE CRUCIAL MATER ISSUE.

Petitioner has met the standard set out in 10 C.F.R. 2.714 for leave to file in an untimely manner new contentions or amendments to petitions to intervene.

Intervenor, prior to April 22, 1932, did no t have legal

v 3s counsel, to aid her in phrasing contentions in legal terms, s

with' specificity and basis. More importantly, the information upon which Intervenor bases her water-related contentions was discovered onl'y recently through her own initiative. Appli-cants, although cognizant of the importance of the water issue, failed to inform the Board of the possible legal restrictions on their use of effluent from the 91st Avenue Treatment Plant at Palo Verd e. Furthermore, the NRC staff did not adequately investigate the matt r to inform the Board of the crucial conflicting claims to this effluent. The Staff also failed to bring to the Board's attention the position of a coor-dinate branch of the government, the Department of the In-terior, whose position appears to be that the contract bet-ween Applicants and Phoenix for effluent is illegal.

Under these circumstances, the public interest in en-suring that Palo Verde Units 1, 2 and 3 can be operated efficiently and safely can be protected only by a full ex-amination of the possible legal restriction on Applicants' use of effluent from the 91st Avenue Treatment Plant.

It is clear that Intervenor appears to be the only party in the proceeding willing to bring the matter to the Board 's attention, and that Intervenor has attempted thus far, with few financial resources, to develop a full record l on the entire water issue for the Board.

Finally, Intervenor is attempting, in submitting new l

contentions, to focus the Board 's attention on probably the

~5-most important issue this Board will consider in deciding whether to license for operation Palo Verde Units 1, 2 and 3 Applicants' ability or inability to obtain adequate water for operation and safe shutdown of the reactors should be deter-mined now, before the reactors go on line.

This Board, in its prior rulings, has focused broadly on the " water issue," especially in its consideration of evidence from Bill Stephens, involving not only the operation of Unit 3 during peak summer months, but the safe operation and shutdown of all three units at any time.

Because Intervenor did not retain counsel until a few days ago, she requests an extension of time for disccvery on her new contentions. In the alternative, Intervenor requests that she be allowed to present direct testimony of witnesses on the contentions even though she failed to file such testimony 15 days prior to the hearing date, as required by 10 C.F.R.- 2 743 Intervenor has presented today a motion for two subpoenas, to Philip Shea, Esquire, and to Bill Stephens. Intervenor also requesto leave to present direct testimony from water resource engineer William Lorah, who can testify as to the adequacy of the quality and quantity of water to be used at Palo Verde.

In addition, Intervenor requests that the Board order the NRC staff to present testimony subject to cross-examination of an official of the Department of the Interior, who can 4

> ' state the position of the Department as to the validity of the contract between Applicants and the City of Phoenix regarding the sale of effluent for use at Palo Verde.

Finally'Intervenor requesta leave of this Board to submit the following new, or amended, contentions:

CONTENTION 1:

1. (a) Applicant has not demonstrated that it has an adequate assured supply of water to ensure that it can op-erate Palo Verde Units 1, 2 or 3 during the periods when the reactors need the greatest quantity of water.

1. (b) Applicant has not demonstrated that it has an adequate assured supply of water to ensure that it can safely shut down Palo Verde Units 1, 2 and 3 during normal, non-accident shutdown conditions during the period when the reactors need the greatest quantity of water.

1. (c) Applicant has not demonstrated it has an ade-quate assured supply of water to ensure that it can bring Palo Verde Units 1, 2 or 3 to safe shutdown after a serious accident during the period when the reactors need the greatest quantity of water.

BASIS:

In subsections 3 3 and 5.6 of the Appliennts' ER10L submitted to the NRC, Applicants claim that they have ade-quate water to operate Palo Verde Units 1, 2 and 3 through a contract APS has with the Arizona Municipal Water Users Association ("AMWUA"), the organization which represents the

! Cities of Phoenix, Glendale, Mesa, Scottsdale and Tempe in water matters. Applicants state simply that they can-obtain l

sufficient effluent through their contract for effluent from l

the 91st Avenue Treatment Plant. In Applicants' Motion for Summary Lisposition, Applicants submitted the Affidavit of l

William Bingham which states that the effluent necessary for cooling Palo Verde Units 1, 2 and 3 will come from the Tolleson Plant as well as the 91st Avenue Treatment Plant.

The Bingham affidavit, the latest submission by the Applicant on the water issue, claims that the amount of effluent need-ed per year per unit will be about 21,350 acre-feet of treated wastewater effluent, based on the following assump-tions:

a) Each unit will operate at a capacity factor of 95 percent of rated power for eleven months each year:

b) The blowdown water will not be retreated and re-used; c) Concentrations of total dissolved solids in the effluent will increase no more than by a factor or 15 Mr. Van Brunt, in a deposition taken by Intervenor on April 23, 1982, stated that " average meteorological condi-tions" meant that 21,350 acre-feet was reached by assuming average temperature and humidity conditions, and average wind direction. Tr. at 40-41.

Mr. Van Brunt also stated that any increase 1.1 the TLS in the effluent required would require an increase in the quantity of effluent required. Tr. at 57-58.

Applicants havn not demonstrated that they can ensure an adequate assured supply of water for the three nuclear plants during period of peak demand, through their current contracts for effluent from the 91st Avenue Treatment Plant

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and from the Tolleson Plant for the following reasons:

(a) The Applicants' present estimates of "need" are based on " average meteorological conditions," not need during months with peak temperatures and unfavorable humidity and wind conditions. Nor do Applicants' estimates take into account hot or drought years.

APS has in the past attempted to obtain contractual commitments for amounts far in excess of 21,350 acre-feet per year per unit when it used assumptions of need based on peak period temperature and humidity conditions. For ex-ample, Mr. Van Brunt said in November, 1977 that effluent requirements during adverse summer months would be 2,600 acre-feet per unit per month. See also July 12, 1978 Van Brunt letter to Worthington; August 10, 1978 Van Brunt letter to Worthington. Attachments A, B and C.

(b) Bill Stephens, the executive director of the Arizona Municpal Water Users Association (AMWUA) with whom Applicants have contrac ted for effluent from the 91st Avenue Treatment Plant in Agreement Mo. 13904, has indicated that AMWUA and Applicants are currently renegotiating the following terms of the contracts (1) the cities' right to refuse to deliver effluent when they critically need the water for domestic purposes; (2) the amount of effluent, if any, available for cooling purposes at Falo Verde Unita 1, 2 and 3:

(3) cost and cource of effluent for use at Fale Verde Unita 1, 2 and 3

. . Mr. Stephens subsequently has said that he believes the current contract allows the cities represented by AMWUA to withdraw as much water as they need at times of critical need.

Thus the' Applicant cannot demonstrate it has an assured supply of effluent from the 91st Avenue Treatment Plant, much less the 140,000 acre-feet per year for which it claims it has a definite contract right.

(d) The amount of effluent treated and available at the 91st Avenue Treatment Plant is dependent on so-called sat-ellite treatment plants built. The location of the treat-ment plants to be built, and the source of sewage wastes flowing to them have long been a subject of dispute between AFS and those agencies developing the MAG plan for water management since 1978. If certain satellite treatment plants are built, the 91st Avenue Treatment Plant may not produce the projected increasing quantities of effluent able to be supplied to Palo Verde. See July 20, 1978 letter from Worthington; liotes apparently from August 23, 1978 APS meeting; Letter dated September 20, 1978 from APS and Salt River Project to Worthington. Attachments D, E and F.

(e) The Salt River Pima-Maricopa Indian Community filed suit against the Department of the Interior and the Secretary of the Interior on January 19, 1982 claiming that it is entitled to be provided water by the Salt River Project since it resides within the Salt River Project boundaries before water is transported outside the Project boundaries.

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_11_ 1 The plaintiff requests that the court mandamus the Secretary of the Interior to assert his authority over the federal reclamation waters to ensure their distribution acording to the law. If the Indians prevail in their suit the contract to provide effluent outside the Project bound-aries to Palo Verde may be declared invalid by the Secretary ,

at least until the needs of the Indian Community for water have been met.

(f) Mr. Van Brunt stated that; the amount of water or effluent required by Palo Verde for use in the cooling towers depends to come extent on the quality of water provided. Therefore, if the quality of the effluent were to change, either due to an unanticipated increase in the TLS level or an accumulat.on of new chemicals not currently in the effluent, the three units' need for water could in-crease beyond supposedly available supplies. See November 17, 1977 Van Brunt oral presentation. Att. A.

CCNTENTION 2:

Applicants have not demonstrated the Kater Reclamation Plant located at the Palo Verde site will provide a suffi-cient quantity of water of an adequate quality to meet the needs for cooling water for Falo Verde Units 1, 2 and 3 BASIS:

In the affidavit of Mr. Bingham submitted by Applicants as an attachment to their Motion for Summary Disposition, it is stated that the Mater Reclamation Plant ('t.'RF ) is d esigned l

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s i to treat effluent containing TDS within a certain range. See also Van Brunt Deposition at 56: Van Brunt Oral Presentation of November 17, 1977 Applican'ts have done analyses of the TDS levels and characteristics of effluent for the 91st Avenue Treatment Plant beginning only in 1973 or 1974. See Bingham Affidavit and Van Brunt Deposition at 53 Applicants have assumed in designing their on-site 't1RP that the quality of effluent will remain substantially the same over the life of the plant, and therefore designed the treatment plant to that quality level.

See Bingham Affidavit. However, the Applicant has failed to consider the following factors which may increase the TDS, chemical, or salinity levels in effluent from the 91st Avenue Treatment Plant; (a) The cities may use sources of water, such as water from the Central Arizona Project or the Colorado River which are likely to increase the salinity level in the effluent from the 91st Avenue Treatment Plant:

(b) At least some of the water feeding into the 91st Avenue Treatment Flant will come from aquifers which his-torically tend to greater salinity over time; (c) Applicants have not considered the following factors in designing their I'lRP:

(1) plans or measures to conserve water required of and undertaken by city and regional governments; (2) an economic decline which affects water usage;

. . (3) a decreasing rate of population growth; (4) A widespread change in life-styles which encourage use of less water; (5) greater amounts of industrial wastes flowing into the 91st Avenue Treatment Plant.

III. CONCLUSI0H For the foregoing reasons, Intervenor requests that the Board grant her leave to submit new contentions, grant her a period of time in which to conduct discovery relevant to these contentions, and allow her an opportunity to present direct testimony from the witnesses named above about the unavailability of effluent lor use at Palo Verde, and the inadequate design of the onsite effluent treatment plant.

Respectfully submitted,

[ -O b/[/!e/.t ( ' ?t - , cx (? c_

Ly\nne Bernabei Harmon & Weiss l'1725 "I" Street , N.W.

(Suite 506 Washington, D.C. 20006 (202) 833-9070 DATED: April 26, 1982 1

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11/17/77 ARI20;A WCEAR POWER PRWECT

'G N 2; e rg PAW VERD~ NUCLEAR GE2EPATEC STATION USE OF EFF wENT AT PA W VERDE We at Arizam Public Service, along with every responsible utility executive in Arizcoa, fully appreciate the need for prudent, coq cehensive mnagcinent of our limited meer resources. Without m ter w simply cannot generate the electric power clut the public needs. We also recognize that other sectors of our economy and the public at large have dmunds on our water resources that are just as legitinnte as ours. We understand that if these other dmunds for wter are not met, there wn't be nuch need for electric pomr because there wn't be any public around to use it.

Consequently, w are anxious to assist and cooperate with W1G and every other organization that is concerned with tl-

• use and nunagcnent of mter in Arizona. We offer our assistance not because w mnt to establish a c]2im for priority status cluugh w Inpe everyone recognizes clut reasonably priced electric powr is an inportant ingredient in irrigation, ccumerce and industry and the pleasant amenities of life such as swimning pools.

Therefore, m affer assistance and cooperation not to get a leg up on scmebcdy else, but to assure tlut informed judgments are nude on the use and nunagaamt of mter -- judgments that are founded uren correct infonmtion with goals that are achievable in the real wrld.

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Today, we are concerned nore with the infonnation required to make those infonned judgements rather than with the establish,rnt of specific goals, such as water for recreation. As we see it, in order to unke sound judgants in this very cccplex subject, you uust have sound information. What they say abcut ecuputer programs --

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" Garbage in, garbage out" -- is equally applicable to water use

,7 and managcnent studies.

Unfortunately, several misconceptions have surfaced that need correction if m are to avoid confusion and uninformed judgments that could lead to serious consequences not only for Palo Verde and other generating projects, but for other elenents of 1

cur society as mil. -

Before addressing Palo Verde directly, let me explain briefly hcu mter considerations enter into a utility's plarning and operations. It all starts with siting -- e ere do we put our new generating resources? Immediately, we are faced with a choice --

Will it be coal or nuclear? Each alternative has its own special considerations, but both require water.

In selecting a site for a coal electric generating plant, the prime parameters are (1) tir source of the coal

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and (2) the availability of mter. . In nountaincus Arizona with alnest non-existent north-south rail connections it is far more economical to move energy by wire than by rail. Consequently, tcday Arizonans rely for the bulk of their electric requircrents on long transmission lines to coal plants generally situated near or in the northeast corner of the State, sane 200-400 miles away frcm the tmjor load centers where the electric pcrmr is needed.

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Another characteristic of Arizona coal genera' ting plants is that each one involves the first and sole use of m eer. The sources are the Colorado River or see tributary or a gathering system of wils tapping underground reservoirs.

There is no other choice. There are no large semge treatment plants on the Indian reservations. Nor is there any tailmter or drainage from irrige ion faming. So, reuse of water for coal generating plants is out of the question.

When it came to siting our Palo Verde nuclear plant, w wre presented with sane different problens and also some 4

new opportunities. Transportation of uraniun fuel presents no

, restraints on the location of nuclear plants so w could reduce reliance upon very long transnission lines and locate the plant near our load centers.

We found a new restraint, Imever. We lud to be able to prove for the nnst questioning mirris that the nuclear site m s seisnically stable. Our geological siting studies, started in the Spring of 1972, told us that there wre tm i

areas in the State where we wuld be unst likely to find a site with dmunstrable evidence of seismic stability: (i) the Navajo plateau in the northeast corner and (ii) a relatively narrow band lying to the wst of Pirenix running in a nortluesterly-southeasterly direction. This m s precisely t what w wre looking for -- a site near the Flucnix nutropolitan  :

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area, tir load center shcre nore than half of the powr to be i

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generated m uld be used and where a previously unused m ter resource - semge effluent - ms available. I 1 <

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The 91st Avenue Sem ge plant pre'sented not only a 1

. new potential source, but the vyguttuaity to reuse a resource which ms then going largely to mste. This is a prime example of. good mter managenent undertaken by private industry at substantial expense without any govemnental or bureaucratic prodding.

Obviously, if m were going forward with a nulti-billion dollar project, it was vital that we do what was necessary -

to secure a cmmitrent of the needed mter supply. Here, w found that m had no alternative but the reuse of effluent. There was and there is nw no unapproprinted surface meer available. There ws then and is now no irrigat'.on tailmters or drainage mter available in sufficient dependable quantities to meet our needs.

] - And there ms not and is not sufficient groundmter available which, j if appropriated for our use, w uld not severely dislocate agricultural

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activities over a very large area.

Accordingly, in early 1973 m started negotiations to j acquire effluent, and in April,1973 we signed a contract with the six cities which om tin 91st Avenue Semge Treatment Plant.

l Having acquired the right to use such effluent m then had to learn how to use it. There really m s not nuch experience I to fall back on with only a few instances where sem ge effluent has I been used for cooling electric generating plants. But-we did knw that

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tertiary treatment -- or what m call a reclamation facility --

muld be required. We also knew that this facility m uld have to be' d designed to handle tir quality of mter that muld be delivered to Palo Verde.

To detennine the kind of tertiary treatnent and the functional requiranents of our rec 1zrration facility, m built a pilot plant at the 910t Ave plant in 1973 and operated it for about 15 mnths at a

cost of $1,100,000. One of the things we Icarned frcxn this pilot operation was that the tertiary treatnent had to be designed to handle wter within a certain range of cheraical characteristics j and total

• dissolved solids (IDS). We learned that it is mre practical to design a facility to process water with a limited range of TDS -

say frcxn 500 to 1500 ppn - than a very wide range of 0 to 5,000 ppm. We also learned that it is not feasible to process water with TDS in the range of 3,000 to 4,000 ppm in a facility designed to treat meer in the 500 to 1500 ppm range.

Using the criteria established by the pilot operation, we then proceeded with the design of our reclamation facility and it is dependent upon the receipt and processing of water I with the quality approximating the effluent frcm the 91st Avenue plant.

The design is n:ra virtually ccuplete and scme purchue orders a M ve been placed. Grading of the water reclamation area is ccnplete and a portion of the on site undaground distribution systcm has, been instafled. Construction of the w ter reclamation pipeline frcm 91st Avenue and construction of the water reclamation plant i .. is scheduled to start April, 1978. Ccupletion of those syst s is required in 1980 in order to meet the schedule for operation of Palo-1 Verde Unit 1. In all, tM reclamation facility and the transport system represent an investment of c'out $150,000,000.

Any redesign effort undertaken at this late date in order to process mter beyond the design range of IDS or with new characteristics such as pesticides and ncw organics muld not only cause extensive delays bringing about exorbitant increases in cost, they could also seriously i;

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' impair our ability to meet the' electric energy needs of our customers. Each of the thits at Palo Verde is important in

~ meeting the State's energy needs in the time frame in which they come on line. Any delay in that scivvble muld raise

.the prospect of electrical shortages for Arizona.  ;

There is another part of our story that should be of interest to you.

Because the total cost of the reclaimed effluent

'will be great and because there are limits on the availability of effluent, w wre canpelled to design our cooling systen

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to maximize the use of the available effluent. The result is that w have been able to design our systen to operate at TDS concentrations up to 14-15 times the original levels.

In contrast, four other electric generating plants that use effluent for cooling, tw in las Vegas, one in Amarillo, and one in Lubbock only achieve a level of 4-5 concentrations.

A trore dramatic way of getting this point across is to cite the progress w have made since w started, khen we started, w estimated w wuld consume about 35,000 A-F/yr. for each of the Palo Verde Units. khen w had caipleted our pre-

.liminary design, w wre able to reduce this estimate to about 25,000 A-F/yr. Now with our design substantially canplete our best estimate is that our effluent requironents will only be 21,000 A-F/yr/ unit.

! . Accordingly, for the first three units at Palo Verde, total .cffluent requironents muld be about 63,000 A-F/yr.

This annual aaount will not be required until 1987, the first ftdl year, when all tlree units are operating. 'ntis muld t' o

anount to about one-third of all of the effluent discharged fran the 23rd and 91st Avenue plants in 1987.

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

of all the effluent expected to be discharged in 1991 and a analler ,

percentage each year as the amant of effluent grows. (4,400 A-F/yr.

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

We think it is very important that you get these numbers clearly in uund --- 63,000 A-F/yr for three units in 1937 and 105,000 A-F/yr. for five units in 1991. We consider tien to be i,

conservative, but realistic estimates.

We also w nt to make clear to you the distinction betwen the mounts of effluent we expect to consuic annually and the amount that nust be contracted for on an annual basis.

The average nonthly usage will be about 1,750 A-F per unit.

l-But bbther Nature does not permit us to use averages. Evaporation rates increase with rises in taiperatures. Consequmtly, in the average adverse su:nner nunths w expect our effluent requirarents to peak at about 2,600 A-F/ unit. These conths also coincide with the period when the'public needs electric power the nost. Therefore, it is prudent, and necessary to avoid cutting back electric generation when it is needed nost, to contract for effluent, which is done on an annual basis, in sufficient quantities to cover our peak nonth requiraTents with a sufficient allowance to account for expected variations frcrn average atmospheric conditions.

'Ihus, w see a need to secure ccmnitments for about 93,600 A-F/yr. for three. units at Palo Verde and 156,000 A-F/yr.

l l for five units. But, I wnt to stress that irrespective of the l

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contract aannts, actual consmption annually will be approximately 63,000 A-F for three units and 105,000 A'-F for five units. 'Ibe difference between tha contracted arount of effluent and the actual amount used will be available for other uses.

With these facts in mird, you will recognize that the statment in the Corps of Engineers' September 28, 1977 report that "the current plans call for FWGS to consuae scxm 75,000 acre-feet per year of se mge effluent in 1982 and about 1990 increase their consuapticn to 140,000 acre-feet' is absolutely erroneous.

l l-There are several other misconceptions contained in this report which nust be clarified. First, it is reported that w feel we "have no mandate or autlurity to investigate groundmter use any further". We categorically deny this statment. In our studies for Units 1, 2, & 3 which are described in the Palo Verde Environmental Report and the Final Enviromental Statemnt, we consiliered several alternative water sources and concluded that the use of sewage effluent ms the best choice for Palo Verde Units 1, 2, &3.

In'aur presmt activities relating to Palo Verde Units 4 & 5, w are continuing to investigate the quantities and qualities of groundmter available, t'm feasibility of its use at Palo Verde and the inpact of

-such use. In this context w do nnintain that changing our reclamtion facility design for units 1, 2 and 3 at this late date to handle saline mter muld be disastrous to the utilities and the public so will need the Palo Verde pomr.

The report goes on to state that "Mr. Weigold mcntioned that about 150,000 acre feet of water per pr are pmped out of the ground in the Buckeye area through their combined irrigation and demtering programs". We deny that Mr. Weigold ever said any

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such thing, and w add that the facts are substantially different.

The records sh u that in 1974 groundwater pumped for irrigation was 53,600 acre-feet and pmped draint.ge meer aaounted 11,500 acre-feet, or a total.of about 65,000 acre-feet. It has been reported to us that

- in 1976 drainage pmping had increased fran 11,500 acre-feet to about ,

20,000 acre-feet. Tius, it is cicar that all of the irrigation and drainage water-in' the Buckeye Irrigation District (BID) is not sufficient to meet our requiranents.

The Corps of Engineers report also represents that Mr. Weigold stated that BID w uld prefer effluent in exchange for groundwater if this were possible. Mr. Weigold said no such thing. The facts are (1) ,

Buckeye has offered its drainage water for use at Palo Verde, and (2)

Buckeye has never suggested or proposed to substitute effluent for the groundwater it uses for irrigation. Buckeye must continue to pmp this groundwater in order to maintain a proper hydrological balance.

It is also purported that 'Mr. Weigold expressed the opinion that the fertilizer value of the effluent is indeed recognized by the fanners of the BID, some of whom farm with no additional fertilizer."

Even if it were true, this statement is grossly misleading.

The facts are that the irrigation w lls in. Buckeye area have generally produced water with a high nitrate cont mt. 'Indeed, a carparison of samples of the water diverted from the river into the Buckeye Canal (mostly effluent) with sanples from the Buckeye irrigation wells sl m that the nitrate content of the well water to be the s:rne as in the effluent.

A study is currently being conducted by clu University -

of Arizona to deternune whather sewage effluent used in the a

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Buckeye Valley has had significant or substantial effect on crop yields or faming practices. This study is not ccuplete. Ikra ver, we can say that, since 1967 when effluent first became available in significant amounts, there has been no report of any dramatic

. increase in yields, i Finally, we were somewhat concerned by two statsents made in the letter of October 26, 1977' inviting us to this meeting. The first of these was to the effect that the quality of the groundwater in the Buckeye area is deteriorating. We were concerned by this statement, because it was directly contradictory

'to the data which we had reviewed in 1974 and advice we had nore recently received fran our water consultants whom we consider to be aninently qualified experts.

Since m received your letter, we have done some nore checking and this is wint m have been told.

1. The groundwater quality in the Buckeye Area has always been bad.

2. From 1935 to 1955 there was a gradual deterioration of quality.

3. Fran 1955 to the present the quality Ins inproved.

The second statenent in the letter which concerned us was to the effect that the only solution to inproving the quality, of the Buckeye groundwater ms to use this 1cra quality water-as coolant for th' Palo Verde generating units. The letter goes on to state' that your engineers do not- have sufficient information to -

conclude whether such a plan wtuld be feasible and requested us to .

give you such infonmtion poday.

~

We have attspted to ccaply with this request by askmg j

_ Mr. Ironard Halpenny to prepare a report on this subject. He is present with us today and is available to ansmr any questions you may have. ,

This gist of his report is (1) continuance of:groundwter pumping is and will ccntinue to be necessary to maintain the hydrological balance in the Buckeye Valley, and (2) there muld be no significant benefits to the Buckeye farmers in exchangirg tlwir irrigation ,

groundw ter for effluent.

The second part of the feasibility equation is *. hat muld the use of the Buckeye grcundwater do to the Palo Verde plant.

One result is that we cannot achieve 14-15 levels of ,

F concentrations with highly saline water. Instead, the maxina levels of concentrations muld probably be in the range of 4-5 concentrations at best. This m uld rean that our consumption of w ter would. increase '

two or three fold. Consequently, our weer requircments for Units 4 & 5 would increase from about 42,000 A-F/yr. to about 80,000 to 120,000 A-F/yr, -- substantially more than tm Buckeye wils can supply.

Other impacts of changing the water source for Units 4 & 5 wuld be changes in the design and result in increased costs for the l follcwing: i

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

2. Cooling towers ~

they muld have to be redesigned and the ,

size or rmiber ecy have to be increased. '

3. Reservoir - a larger size muld be required because of the increase in the cooling water 'requirenants.

4. Reclanation facility - a new pilot operation my hwe to be conducted and a ncw design developed. h '

5. Gathering systan - for collecting and transporting gmrdelter separate frcm the effluent wuld have to be:

. developed.

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6. Operation muld be more difficult and ccuplex, <

because the cooling water for Units 4 & 5 w uld r have to be controlled separately frcxn the cool-ing water for Units 1, 2 & 3.

.I hope that what I have said and the information I have given l e

- or corrected will be useful to the Comittee. If you have any questions at this time,.either I or Mr. Halpenny will try to be responsive. If ,

there are questions which occur to you later, we will do'our best to  ;

answer those too. As I said earlier, we share your interests in sound water managanent. Since our interests are mutual ~, ce want to be (

i  :

helpful and cooperative.

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ARIZONA NUCLEAR POWER PROJECT Post Office Box 21666 Phoenix. Arizona 85036 Er k

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July 12, 1978

' ANPP-11340 t

Mr. H. W. Worthington Chief, Urban Studies ,

Department of the Army Phoenix Urban Study Office 2721 North Central Avenue Suite 800 Phoenix, Arizona 85004

Dear Mr. Worthington:

Thank you for your letter of June 20, 1978, apprising us of the status of the MAG 208 studies and planning. Obviously, we are vitally inter-ested in the wastwater. management planning for Phoenix metropolitan area since our ability to meet the public's demand for electric service

- - is tied directly to the availability of wastewater effluent at the 91st Avenue and 23rd Avenue plants. Accore .4 gly, we appreciate receipt of any planning information which may have any impact upon effluent avail-ability or the ability of the six cities who are obligated to supply such effluent. For exampic, we are very concerned over the comment in your letter that it is quite possible that the Regional Council will adopt a final plan which would make effluent unavailabic at the 91st Avenue and 23rd Avenue plants for Palo Verde Unit 5 until after the [

year 2000. If this possibility arises from the potential installation of new subregional plants, it clearly raises some serious legal issues.

Your 1ctter requests our opinion respecting "the amount of effluent p*

that is Icgally committed for power plant cooling by the existing contract." Our view on this matter is that the contract is unmistakably cicar that the Cities are obligated to sell and deliver wastewater effluent from the 91st Avenue and 23rd Avenue plants in the total amount of 140,000 acre-feet per year. This commitment is irrespective t#

of the number of units to be constructed at the Palo Verde Station or i any other location.

' The contract is subject to the following conditions:

1. Such amount of effluent is availabic after prior commitments for effluent have been satisfied; c,

2. Construction of ANPP units shall have commenced '

(. . prior to December 31, 1995; i

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( Y e l,

Mr. !!. W. Wor.thington Chief, Urban Studies Department of the Army (j Phoenix Urban Study Office ANPP-11340 July 12, 1978 Page 2

3. The options granted shall have been exercised on or before December 31, 2000; and

4. The options granted shall not have been released or J

surrendered in whole or in part.

The contract further ceplicitly provides Arizona Public Service Company (APS) and Salt River Project (SRP) may transfer all or any portion of the options for use in connection with the construction, operation and maintenance of any other electric generating units .wherever located, but subject to the same terms as are applicable to the ANPP units (e.g. , construction of any other generating unit for which any portion of the option effluent may be transferred must be commenced not later than December 31, 1995.) The right of transfer given to APS and SRP would be meaning 1 css, of course, if the amount of option effluent committed were limited to the requirements of the Arizona Nuclear Power Proj ect (ANPP) units only.

{

Your letter also inquires whether we could use the effluent availabic from subregional wastewater treatment plant. in the vicinity of Reams /

Citrus Roads and the Gila River. The anwer to this question is that we know of no reason why we could not use such effluent.

There would, of course, be some engineering problems to be resolved and additional construction and pumping costs incurred to tie an effluent pipeline from the Reams / Citrus plant into the pipeline now under construction. Nevertheless, we don't consider the problems to

.e be insurmountable and we would be willing to evaluate and discuss this possibility with any interested parties.

With respect to the study involving alternate sources of water for the Palo Verde plant, we will do our best to furnish you a copy before the end of this month.

Your letter also asks the question respecting the likelihood that Palo Verde will operate at an annual capacity factor lower than 75%, and, if so, to what extent will if affect the average annual water consump-tion. The annual water consumption will vary directly with the annual capacity factor in any year, though not precisely in the same amount because of changing efficiency at different periods of the year. The same principles apply equally to the relationship of monthly capacity factors and monthly water consumption. In our view, the requirements

. for effluent are controlled by our needs during the summer months when the demands for electric capacity are the greatest and evaporation losses are also the largest. Consequently, we consider any analysis

7

. s Mr.11. W. Worthington i Chief, Urban Studies Department of the Army ,

Phoenix Urban Study Office

, ANPP-11340 t July 12, 1978 Page 3 i

based upon either an average annual or average monthly water consumption ,

L to be inadequate if it does not also evaluate peak month requirements.

With respect to the 75% capacity factor we have used for the Palo Verde units for some purposes, it is an annual average for the life of the

+

plant. It is not an arbitrary number, but is based on reasoned judgments covering a substantial amount of experience and recognizes that during l the early years of plant operation the capacity factor will be less than average because of normal shakedown problems which should be expected. -t l

If you have any questiom relating to this letter, please don't hesitate

/ to contact me.

Very truly yours, j

i k

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• , Nt W E. E. Van Brunt, Jr.  !

APS Vice President, Construction Projects ,

ANPP Project Director ,

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AHli.ud A NUGLEAR PuWhd PHOJtiCT Post Of fice Box 21666 Phoenix. Arizona 85036 E.

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( ~O August 10, 1978 ANPP-11535 L

Mr. H. W. Worthington Chief, Urban Studies Department of the Army 2721 North Central Avenue l Suite 800 Phoenix, Arizona 85004

Dear Mr. Worthington:

Your letter of July 20, 1978, and the status report of your studies is I

appreciated very much. The list of potential wastewater treatment plants which have been selected for further study is of considerable interest, particularly since it includes some alternatives which we were not aware were under consideration. In order that we may more c1carly understand their potential impacts we would like to have additional information re-specting each of these alternatives, particularly their contemplated I

( capacities, the schedules for development and a more definitive descrip-tion of the areas which each of them would serve.

We would also like to explore with you the bases for your estimates of high and low flows of effluent from the 91st and 23rd Avenue wastewater treatment plants since such estimates are substantially different from the projections which the City of Phoenix has given us.

The conment in your letter that "even under the option which produces minimum flow at 91st and 23rd Avenues there will be sufficient effluent to meet the average annual requirements of 5 reactors by the year 1990 7

using the currently estimated needs of 21,400 acre-feet per year per reactor" indicates a possible misunderstanding of the effluent require-ments of the five Palo Verde units. The 21,400 acre-feet is an estimate of the annual requirement not an " average annual" statement of the amount of effluent that will be constraed by each Palo Verde unit over a 12-month period.

f This estimate of annual requirements, however, does not reficct the peak requirements for cooling water which will occur during the summer months when atmospheric conditions result in highest evaporation rat es. During these periods we estimate that the effluent required for each Palo Verde Sh [M6 AMPP participants: Arizona Public Service Company . Salt River Project . Public Service Company of New Mexico n ri pne n rtnet ric rn.,n,nv . o,.m n.n r,mn r n;, ra;-n, rn mn,ny

Mr. H. W. Worthington Department of the Army ANPP-11535

(- August 10, 1978

( Page 2 unit will be in the range of 2,200 - 2,600 acrc-feet per month. In order to supply effluent at such monthly rates to five units, one or more waste-water treatment plants with total effluent capacity of 11,000 - 13,000 acre-feet per month, or 130,000 - 156,000 acre-feet per year, will have to be available.

Your letter includes two questions relating to the terms of the contract h between the six citics that are participants in the 91st Avenue Plant and APS and SRP. Assuming all of the options arc duly exercised before December 31, 2000, this contract requires the six cities to deliver to APS and SRP, after first satisfying prior commitments to Buckeye Irrigation District and Arizona Game and Fish Department, all of the effluent availabic at the 91st and 23rd Avenue plants up to the maximum amount of 140,000 acrc-C feet per year. The contract expressly disclaims any warranty that 140,000 acre-fect will become availabic at any time or in any year. But, whenever that quantity does become available, either before or after the year 2000, the obligations to deliver such amount are cicar.

In lieu of a warranty as to the amount and time when effluent would become I ( availabic, the six cities committed not to install any new plants that would impair the ability of the citics to deliver effluent pursuant to the Agreement. The contract specifically exempts from this commitment the new treatment facilities planned for installation in the Gila and lower Litchfield tributary basins as identified and described in the

" Wastewater Report for the Valley Metropolitan Arca of Phoenix, Arizona,"

3 by John Carollo Engineers, dated December, 1968. The contract further provides it is not intended to grant to APS and SRP "any rights or interests in wastewater co11ceted in the Gila and lower Litchfield Tributary Basins, and treated at such envisioned new facilitics," which are cicarly identified and described on Plates 1 and 2 of the Carollo Report.

Accordingly, the contract commitment respecting new facilitics relates to defined boundaries of tributary basins, rather than political boundaries of municipalities. Since we do not have any specific information respecting the subregional plants included in your on-going studies, we are unable to c

give a direct answer to your question relating to " flows from existing county lands which are planned . . . to be part of Glendale or Mesa."

A;afinal comment related to your questions, once the amount of effluent availabic from the 91st Avenue and 23rd Avenue Plants is sufficient to satisfy the 140,000 acrc-feet annual commitment and the prior commitments to B.I.D. and Arizona Game and Fish, the restrictive covenant on new facil-g ities would be satisfied, assuming that the 91st Avenue and 23rd Avenue

(" Plants continue to be operated and maintained to keep these commitments.

. , Mr. II. W. Worthington Department of the Army 1 ANPP 11535

(

August 10, 1978 Page 3 If the 1977 projections of the City of Phoenix prove to be accurate, this point would be reached in 1985.

We will be pleased to furnish you any additional information that we have and which you might find useful. In this connection, we understand that a meeting has been scheduled between Arizona Public Service Company, Salt p River Proj ect and your of fice on August 23, 1978 for an exchange of infor-mation.

Very truly your,s

, ~

CLC_b 'A M ( N E. E. Van Brunt, Jr.

• APS Vice President, Construction Projects ANPP Project Director

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t_oS A NGEL ES otS THICT, COM P5 of C *d G I N E r. H S

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\g . % -f v/ 2721 N o H T H C C N T R A t., A V E N U C, S U I T C 2900 PH OC NI X, A RI2 oN A e*sOO4 g.k S PLED-W 20 July 1978 Mr. E. E. Van Brunt, Jr.

AIG Vice President, Construction Projects ANPP Project Director Arizona Uucicar Power Project Post Office Box 21666 Fncenix, Arizona 85036

Dear Mr. Van Brunt:

Thank you for your letter of July 12, 1978. I would like to bring you up to date on the progress of the Maricopa Association of Goverreents (MAG)

{ 208 study, particularly as it nicht affect or be affected by water avail-able for cooling at ANPP.

On July 12, 1978, the Regional Council reviewed our work to dat.: and selected the following plants for further study:

, 1. A northeast area plant to be located on the Salt River Pina Marie .pa Intilan Con.ninity to treat wastewater from Phoenix, Paradise Ys1? ey, and Scottsdale and to provide effluent for farming on the Indian Cc rcunity in exchange for fresh water;

2. A plant in Gilbert to treat Gilbert's and possibly some of " future" Mesa's wactewater and provide effluent for farming; 3 A pinnt either in Chandler or on 'ae Gila Indian Bese:<ation to treat Chandler's wastewater and provide effluent for farming; 14 A plant located near Luke Air Force Ease to treat wastewater fron I, uke, El Mirage, Surprise and " future" Glendale and to provide effluent for farming the clearzone of the Air Force Base; l S. A plant at either Roams or Citrus roads to treat wastewater from Goodyear, Avondale, Litchfield Park and Luke AFB for farming or power plant cooling; I

6. A plant in Tolleson to treat wastcwater from Tolleson, Peoria, and Sun City East or Glendale and provide effluent for a turf growing operation; i

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oFLED-WU 20 July 197c I Mr. E. E. Van Erunt, Jr. l l

(- 1 i 7 A plant at 23rd Avenue to treat wastewater frc= Phoenix and l provide effluent for farming, for power plant cooling, or for exchange; 4

4

3. Finally, a plant at 91st Avenue to treat vastewater from the

, multi-city psrtners and provide effluent for farming, power plant cooling, 3 or exchange.

Following farther study we will return to the Regional Council in October and ask them to ma're a final selection. Since the Tolleson, Gilbert, and

, Chandler plants appear in all the alternatives selected by the Regional f Council on July 12, they will necessarily become part of the final plan.

) The other subregional plants may or ray not be included in the adopted pisn.

M Nevertheless, we are abic to estimate a range of possibic flows from the d 91st and 23rd Avenue plants. The picture looks like this:

t<

l Year 1990 Year 2000 g ,. High estimate, total flow 150 mgd 175 med Low entbnte, total flow 135 med 150 med j As you know, the Buckeye Irrigation District has entitlement to approxirately

'; 27 med of effluent from the 91st Avenue wastewater treatment plant and the

Arizona Cane and Fish Department has a committment for an additional 6.5 ngd.

k -

'Ibus, another set of numbers reficcting the amount of effluent availabic for coolant p.trpenes can be estirrated:

Year 1990 Year 2000 r

HiCh estimte, available for coolant 116.5 ngd 141.5 med Low estinate, available for coolant 101 5 mgd 116.5 ccd

[ These figures are of particular interest as they relate to the full optien anount for AUPP coolant of 125 mcd (lh0,000 acre feet per year). Under the alternative producing a I:2ximum unount of effluent at 9)st and 23rd Avenue, th e u . .-city partners can not deliver the full 125 mgd option amount of effluu;. until sometime after 1990 and it would be beyond the year 2000 before 125 med would be available under the alternative which provides the minimum flow to 91st and 23rd Avenues. on the other hand, however, it should be pointed out that even under the option which produces minLT.um flow at 91st and 23rd Avenues there will be sufficient effluent to meet the averace

! annual requirements of 5 reactt *s by the year 1990 using the currently i estinated needs of 21,400 acre feet pur year per reactor.

I.I b 2 l 1 l 1 1

5?2D-M1 M uly 1973 l'r. E. E. Yr.n h ant, Jr. ,

I feel that ye z.ast advise the H'G 4 Regional Council as to how their

. de:icion in 0:t:bar vill be affected by the'eristing effluent ~ option con-

'4 tract betvcen the Arizona Public Service Compe.ny,, the Ssit River Project l

' end the cities of Facesix, G1codale,1:esa, Septtsdale, Ten,e; and I

l E.

Y:<angt:ren. Yo:: letter of July 12, 1978 ststes thst in y:ur opinion

' the citics .'a sre psrty to the contract are "obliEsted to cell eqd

- - t'eitver vsste. .ter effluent fror. the 91ct Avenue'end 23rd !ccanue plents in the toisi t. count of 140,0% acre feat per ye1r". Yo : h*. ee also p:' .ted out thit the opticas Ersated i: st te exercised on or before

.e:anar 31, 23 s3. D3es thic :.aan .then that the MAG Eegie..s1 cean:11 3

r. y not adopt sny subregiere.1 p!snt vhich treats the f1ws of one of the

r..- .itories to the option contrict if that subracionsi p*_!. t contributes

( .

i, '- -he insbiU.ty of the culti-city pr.rty-s to deliver the full option

4 r

r.t by the ysir '2D37 Dotz this also can that flovs fr. _ existing l

w...ty 12.nis vh".ch are pirt.ned before the year 2003 to be p:rt of i

• ((

O*.e.nhie or Mens my siribrly not be ple.nned to ficv to either the.. e Gilbert or Luhe /.rB pir.nta if the overall f1ws frcs 9!st and 23rd J

l, f.ven*:es can non :.eet the full 125.tc.d by the yesr 20307 -

s

> .~nt e r.re 'ry -t?.nt questiens bat?ure they vill i .7.ct on n t only the  !

• ong nr.ge rs;ienst *. caste.n.ter pitaning b.:t also the Ioni; r.- . a h nd t.t.:

. '.an .ing n .i

.nnenstion policies of a nunbar of the citle: tho e.re

& signatorier to the option contact. Ycur opinions and the :.aeds of .G?p k

should be c'.erified ,for the benefit of the Ecgionsi Council as they cake

( their deci:::n in 0:tober. -

?'.c2cc call if you b5.ve any questiona..' - .

~

ll .  ? Sincerely,.

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. :: Miyor 52ica, Ch51rnsn H k*. it'.P.1ir:GTO::

hiG Eegic:n1 Council Chief, U: ban Stuiit:

DIST:

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3cndir.E file thru DE ED

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Urbe.n Studies Sec d

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..r G75 TOPICS FOR APS )GETING

( -

}. . IMSIS FOR ESTDMTES OF F1&'S:

a. Show 1990 & 2000 flows table by plants + high & low flows @

23rd &.91st

b. Show existinc IMG projections & flows @ 23rd & 91st

c. Compare to City of Fhoenix growth of 30 M3D/5 yrs

d. Compare to other projections - old !MG, DES, 01.!'RS (discuss other determinations ie. employment,trans, air)

c. Discuss our use of flow reduction & IMG's plans for flow reductions

2. SHO'4 AREAS WHICH ARE TRIBUTARY TO EACH PLANT (approximate service arcas) 3 DISCUSS OPPOSITION & SUPPORT FOR EACH PIANT:

a. Economic s

b. Wastewater reuse

c. Indian water claims

d. Ability to control own growth

e. Timing of construction 14 GROUh%'ATER QUALITY STUDY:

a. Long term trends in BIC

b. Long term trends cast & north of BIC r i

c. Solutions to latter prob? crc:

1) Do nothing

2) Do nothing + CAP to Goodyear & Avondale

3) 1bdify irrigation:

. cease

. use effluent

! . use CAP

( . use other

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b) Devater south of Goodyear Fams

. ANPP

(., . Irrigation

(. . Effluent + Groundwater for irrigation 5 ANPP PIANT OPERATION VS OTER REUSES

6. ALTER!MTE SOURCES FOR ANPP:

a. Tail waters & drainage water from Buckeye Irrigst5 on Cce.pany, Arlington Irrigation District & other Irricators expected ^.a be approximately 50,000 ac-ft/yr (Mgt Research Inc Report, Jun 78)

b. Dewater high TDS vater north of Gila River & south of Goodyear Farms

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2I *.,;.::t iF'S  ;

(' POIVIATION PROJECTIONS ,

MARICOPA COUNTY

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4 OEPAD (1975)

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1/AG (1973)

DES (1975 & 1977) 30 ,,

b 03ERS SERIES c (1975) 7 4,

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1.0  : 4- ,  :  : r 1975 1980 1985 1990 1995 2000 (DATE) l(

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F.* ALT FIDWS (IGD):

r

(- PIAb7S 1980 1990 2000 Total E 117.0 139 1 162 9 Total W 15 9 23.8 34.h TOTAL 132.9 162.9 197.3 Committed l

Tolleson 5.4 4.0 7.2 .

^

Chandler 3.0 5.4 8.2 E. County 5 .8 1.0 Gilbert 1.1 2.3 3.6 TOTAL 10.0 12.5 20.0 Uncomitted 4

NE 55 7.4 91 sw 13 29 5.4 W .8 1.0 1.2 TOTAL 7.6 11 3 15.7 11153, 91st & 23rd 122 9 150.4 177 3 Iov ,

91st & 23rd 115.3 139 1 161.6

-,. , .n ., -

. o k'ASTEJATEF. FI/J43 AT 91st & 23rd VGSUS 'JASTEJATE FZJSE DEMNDS k!

250_ 280 1 '

m Increase 6MGD/Y u -

N y High 91st + 23rd h b Low 91st + 23rd O d - - 157. Flow Beduction I I

200 t 224 ..... Peak Monthly Flow

• 173 MGD 177,000 AF/Y or 158 M3D f ]3 150 1 168 /n - -t

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j'16' *l.di)*' ~~ neactor #5 144,000 AF/Y or 129 M3D 4 - -2 ra N) *

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112

Reactor #4 123,000AF/Y or 110 M3D N

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. M3D v

Pcactor #3 102,000 AF/Y or 91 M3D ]

I

• 61 M3D Reactor #2 80,000 AF/Y or 72 M3D t

50: _ 56 >

\l I Reactor #1 59,000AF/Y or 52 M3D 37,000 AF/Y or 33 M3D {

f AZ Game & Fish Department .

30,000 AF/Y or 27 MGD Suckeye Irrigation Company

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1985 1990 1995 2000 1980 (DATE)

- r- e r p3ge t g- 3 3 ^ f'\

SUBREGIONAL PLANTS 2000 Flow Plants (MGD) Uses Support Opposition Comments CO:CiTTTED:

Chandler 8.2 Bogle Farms Chandler (strong) None - Most expensive off Indian land SRP Gilbert - Least expensive on Indian land E'vtCD - Revenue for reuse Gila Indians - Satisfy future Indian claims

- Lagoon + Land treatment good $

- Plant expansion needed soon Gilbert 3.6 Irrigation Gilbert (strong) None - Gilbert needs plant soon

. Chandler - Revenue for reuse

- Lagoon & Land treatment good $

- Possible nuisance

- Gilbert must operate Tolicson 7.2 Turf Everyone None - Relieves 91st Ave Plant production - Relieves westside sewers

- Additional Plant near major metro plant

23 August 19/d

.s n Page 2 c>%3 pv.es O

SUBREGIOraL PLU;TS -

2000 Flow Plants (MGD Uses Support Opposition Com:nents 2ZI?iG CONSIDERED:

ITE 91 Exchangew/ Scottsdale (strong) Fnoenix (undecided) - Provides future fresh water Salt River Paradise Valley - Chro:: tium in Scottsdale groundwater

- Increased treatment $ ($52/ac-ft)

Indians

- Requires negotiation w/ Indians

- Also trade CAP water

- Chromium in Scottsdale groundwater

- Possible problem w/AITP

- Scottsdale er Phoenix must operate

- Possible nuisance IN 1.2 to . Luke AFB El Mirage Unknown - Protects Luke AFB from encroachment 2.6 Buffer Luke AFB - Lagoon + Land treatment good $

Discharge Surprise (?) - Use EPA $ Buy land to Agua Fria - Possible nuisance

- El iirage must operate SW 5.h RID Goot/ car (strong) Unknown - Lagoon + Land treatment good $

Local IRR Avondale (?) - Provides for future growth AsiPP Litchfield Park (?) - Use EPA $ Buy land Multi-city Partners - Possible nuisance will support - Goodyear or Avondale must operate

- Revenue from reuse

- May be used to satisf'y AITP needs

s r n r n d o i o e o - l t e i n i i a p v s t s t t i e c u r u r

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'- act e a n ll A e o o wai dPo w a l a t d f t/l iP t r od n e aa o l0 u sNt l gg .Tn r v e el 3 a3M tAs an e/e e A u ra d aS eym u SiAvwl S$ s h e o PPA s G t u

t s $ oo g eft wfse emE t eo o 1P ri a co cu u pM s r t S 9Pt tR P u s eil rt a d 41 e s Nn e dkt rerAe mo ecn tuad er19fe rc oco m t raa nt sn o

ro$ r opg br au oao j Gena t ai fnfht a t a or lf ov $s$ie f e tm P tA t mt snsr wrt t uM r dome riio ue AuA i

ra d p8 nodr e/9nenP pnp s ew e/1 ofeo E E ed t es s sw$t zried sw$vesur u

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• PH OCNI X, ARIZ ON A 0 5036 September 20, 1978 b Mr. 11 . W. Worthington Chief, Urban Studies Department of the Army 2721 North central Avenue Suite 800 Phoenix, Arizona 85004 g

Dear Mr. Worthington:

At our meeting with you and representatives of the Maricopa Association of Governments (MAG) on August 23, 1978, you requested our views concerning certain alternatives 7.

being considered to provide additional sewage treatment capacity needed to serve the growing communities in the Phoenix metropolitan area, extending from Chandler on the South to El Mirage and Surprise on the north and from Mesa on the east to Goodyear on the west. The alternatives which p( you identified at such meeting are:

1. Expansion of the 91st Avenue and/or 23rd Avenue plants.

2. Expansion of the Tolleson plant.

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3. A new subregional plant to serve Chandler.

4. A new subregional plant to serve eastern portions of the area, principally Sun Lakes.

t; 5. A new subregional plant to serve Gilbert.

6. A new subregional plant to serve northeast portions of the area, including Phoenix, Scottsdale and Paradise Valley.

F 7. A new subregional plant to serve southwest portions of the area, including Goodyear, Avondale and Litchfield Park (Reams Road Plant).

8. A new subregional plant to serve northwest portions of the area, principally El Mirage and Surprise.

a-b bagrAM

AR420N A PUDUC SERVICC COMPANY Mr. H. W. Worthington page Two September 20, 1978

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At such meeting, as well as in Mr. E. E. VanBrunt's letter to you, dated August 10, 1978, letter no. ANPP-ll535, we expressed our views respecting Agreement No. 13904 be-tween the Cities of Phoenix, Glendale, Mesa, Scottsdale and Tempe and the Town of Youngtown (the "Six Cities") and Arizona Public Service Company (APS) and Salt River Project Agricultural Improvement and Power District (SRP). Specifi-cally, we stated that such agreement -

1

1. Obligates the Six Cities to deliver up to 140,000 acre-feet of wastewater effluent from the 91st Avenue and 23rd Avenue Plants when available;

2. Disclaims any warranty that such

, amount of wastewater will become available at any time; and

3. In lieu of such warranty, commits each of the Six Cities not to install any new sewage treatment plants that would impair the ability of such' cities to deliver effluent

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• pursuant to Agreement No. 13904.

We also acknowledged that the latter commitment.

not to build new plants did not apply to plants envisioned in the 1968 Carollo Report, entitled Wastewater Report for the Valley Metropolitan Area, to treat wastewater collected from the Gila and lower Litchfield Tributary Basins as defined in that report. Accordingly, APS and SRP have no object' ion to the development of' either the proposed Chandler plant to treat sewage collected from the Gila Tributary Basin or the proposed Reams Road plant to treat sewage collected from the lower Litchfield Tributary Basin.

On the other hand, the Gila and lower Litchfield Tributary Basin exception clearly does not apply to the pro-posed northeast plant which, we were advised, would not only treat sewage collected from new areas being developed in Phoenix and Scottsdale, but would also divert sewage pres-ently being treated at the 91st Avenue Plant. Accordingly, APS and SRP will vigorously oppose development of the northeast plant until.such time as (i) the. capacity-of the 91st Avenue and 23rd Avenue Plants has been expanded to l permit fulfillment of all outstanding commitments for f.

ARIZONA PUBLIC $E RVICE COMPANY Mr. H. W. Worthington Page Three

(,. September 20, 1978 i

delivery of wastewater effluent from such plants and (ii) effluent flows are sufficient to meet such commitments.

Our position with respect to the remaining pro-posed alternatives is not so clear cut, primarily because we do not fully understand them or because their proposed function has not been finally fixed. For example, your letter of July 20, 1978, to Mr. E. E. VanBrunt, Jr., de-scribes the northwest plant as "a plant located near Luke

, Air Force Base to treat wastewater from Luke, El Mirage, Surprise and ' future' Glendale . . . ." However, at our meeting on August 23, 1978, it was stated that this proposed plant would serve only El Mirage and Surprise. To the extent that this plant would serve only the existing com-munities of El Mirage and Surprise, which would appear to be in the Litchfield (if not the " lower" Litchfield) Tributary Basin, we would not oppose its development. However, if its purpose is expanded to tr' eat sewage collected from areas cast of the Litchfield Tributary Basin, and particularly

" future" Glendale, then APS and SRP would object to it.

('

Similarly, the proposed Gilbert plant has been described as designed "to treat Gilbert's and possibly some of ' future' Mesa's wastewater." Again, if the Gilbert plant would result in the diversion of sewage collected from areas north of the Gila Tributary Basin (e . g. " future" Mesa), APS and SRP would consider that the development of this plant would contravene Agreement No. 13904.

The plans for the Tolleson sewage treatment plant are unique. It is our understanding that there is presently excess capacity at this plant because operation of the meat packing plant that supplied a major portion of the load on the treatment plant has been terminated. We also understand that this excess capacity is sufficient to meet the present needs of both Tolleson and Peoria and, at least for some period of time, of Sun City-East and portions of Glendale, as well. We have also been told that an expansion of the Tolleson plant is contemplated to meet the future needs of Tolleson and Peoria and also those of Sun City-East, but that Glendale's use of existing capacity would only be temporary.

l With respect to these plans for the Tolleson I plant, we appreciate the desirability of fully utilizing l r

A k t ? ON A PU Bt.tC SE R V sC E C OYe AN Y a ,

Mr. H. W. Worthington Page Four 0

( September 20, 1978 existing capacity, particularly since by doing so, currently critical needs of Glendale and Sun City-East can be met and the demands on the 91st Avenue Plant can be eased until its

(-

expansion can be accomplished. Nevertheless, we have serious reservations about any " temporary" solution which might become permanent. Specifically, we are concerned about expansion of the Talleson plant which would permanent-ly divert sewage from Glendale or sewage collected from Sun City-East that is presently being treated at the 91st n Avenue Plant. In summary, our positions respecting the plans for the Tolleson plant are (i) we have no objections to the " temporary" diversion of the wastewater collected from Glendale and Sun City-East, provided we can obtain either an assurance that such diversion will not become permanent or a right to acquire wastewater effluent from the

[

Tolleson plant equivalent to that diverted from the 91st Avenue Plant, and (ii) we are opposed to the expansion of Tolleson plant to permanently divert Sun City-East waste-water until the effluent flows from the 91st Avenue and 23rd Avenue Plants are sufficient to meet all outstanding commit-ments. ,

In closing, we wish to make the following points respecting water conservation and management and the reuse of water.

1. The growth in the Phoenix metropolitan area f that requires increases in sewage treatment capacity also requires increases in electric generation capacity.

2. The required increases in electric generation capacity cannot be achieved without water.

3. The reuse of wastewater effluent for electric generation permits the maximum conservation of the only other water sources available, i.e. groundwater ar.d surf ace water.

4. The reuse of wastewater effluent for electric generation will provide more economic benefits to Maricopa County and the State of Arizona than any other potential j reuse.

Apart from the conservation and economic I

5.

l benefits achievable from the reuse of effluent for electric

! generation, the revenues to the Six Cities from the sale of l l

. . Anizosa cuauc sc avicE COYPANY Mr. H. W. Worthington Page Five

(, September 20, 1978

(

effluent will significantly reduce the sewer use charges which the residents of the Six Cities would otherwise have to pay.

If you have any questions respecting our positions on the several alternative plans under consideration, we will be pleased to respond to them.

Respectfully submitted ARIZONA PUBLIC SERVICE COMPANY B _

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SALT RI ER PROJECT AGRICULTURAL IMPROJ' MENT AND POWER DISTRICT By 't9 ,4c, ( Q

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cc: Jack DeBolske Ken Driggs Marvin Andrews City Managers of Scottsdale - Frank D. Aleshire Tempe - Kenneth A. Mcdonald Glendale - Stanley F. Van de Putte Mesa - J. A. Petric Mayor of Youngtown - Norman B. Shrenk Bill Stephens k

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[

United States of America Nuclear Regulatory Commission

~ i Before the Atomic Safety and Licensinc Poard g yj j/

f In the Matter of )

)

ARIZONA PUBLIC SERVICE ) Docket Nos. STN 50-528 COMPANY, et a1 ) STN 50-529 STN 50-530 (Palo Verde Nuclear Generating )

S ta tion, Units 1, 2 and 3) )

)

Certi ficate of Service I hereby certify that copies of Intervenor's Supplemental Response to Intervenor's Response to Joint Applicants' Request for Admissions, Application for Issuance of Civil Subpoena Duces Tecum (to Philip Shea), Application for Issuance of Civil Subpoena Duces Tecum (to Bill Stephens), Motion of Intervenor to add New Contentions or Alternately Amend Her Current Contention on Inadequate Assurance of Water, have been served on the following individuals by deposit in the U.S. Mail, properly addressed and with po6tage prepaid, this 26th day of April, 1982.

Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, D.C 20555 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Robert M. Lazo, Esq.

Chairman, Atomic Safe ty and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Dr. Richard F. Cole

. , Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Dr. Dixon Callahan Union Carbido Corporation P.O. Box Y Oak Ridge, TN 37830

• Lee Scott Dewey, Esq.

Office of the Exe'cutive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Arthur C. Gehr, Esq.

Charles Bischoff, Esq.

Snell and Wilmer 3100 Valley Bank Center Phoenix, Arizona 85073 Rand L. Greenfield Assistant Attorney General P.O. Drawer 1508 Santa Fe ,New Mexico 87504-1508 Atomic Safety and Licensig Board Appeal Panel U.S. Nuclear Regulatory Commission Washington,D.C. 20555

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Lynne Bernabei t-

• hand delivered