ML19225A509

CA Energy Resources Conservation & Development Commission Statement of Issues,Per ASLB 790306 Order,Indicating That Commission Is Entitled to Participate in Hearing as Interested State.Certificate of Svc Encl

ML19225A509
Person / Time
Site:	Palo Verde
Issue date:	06/20/1979
From:	Grueneich D, Urban M CALIFORNIA, STATE OF
To:
References
NUDOCS 7907190479
Download: ML19225A509 (10)

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NRC PUDLIC - a v.'.ZG ROOM .,

p UNITED STATES OF AMERICA -

NUCLEAR REGULATORY COMMISSION 7

. s's Y BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '/

In the Matter of )

)

ARIZONA PUBLIC SERVICE ) Docket Nos. STN 50-592 COMPANY, ET AL. )

) STN 50-593 (Palo Verde Nuclear Generating )

Station, Units 4 and 5) )

)

)

STATEMENT OF ISSUES The California Energy Resources Conservation and Develop-ment Commission (" California Energy Commission") submits this Statement of Issues, as an interested state in the pending hearings to be held before the United States Nuclear Regulatory Commission pertaining to the Arizona Public Service Company, et al., application for construction permits for the Palo Verde Nuclear Generating Station Units 4 and 5. This statement is submitted pursuant to the assigned Atcmic Safety and Licensing Board's Order dated March 6, 1979, directing the California Energy Commission to file a statement of issues indicating with reasonable specificity, the subject matters on which it desires to participate.

As an " interested state", not a party, the California Energy Commission is ent i tle to a reasonable opportunity to participate in the hearings and advise the Ccmmission without taking a posi-

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tion on any of the issues. (10 CFR S 2.715(c).) Accordingly, the California Energy Commission's Statement of Issues has been framed with sufficient detail and preciseness to define concrete issues, pursuant to the ASLB 's March 6, 1979, Order, but does not set forth any specific position of the Califoria Energy Commission with respect to any of the issues in this proceeding.

Rathe r , the California Energy Commission's statement raises those issues which neither the Applicants nor the NRC staf f have thus far adequately addressed. Of particular concern is the failure to assess fully the need for and alternatives to Palo Verde Units 4 and 5 for the California participants. Since the Applicants retain the burden of demonstrating that the matters raised by the California Energy Commission are adequately addressed and have been satisfactorily resolved prior to Board action on the permit, the California Energy Commission anticipates that addi-tional information will be presented in these areas by the Applicant, subject to cross-examination by participants in the proceeding. In addition, the California Energy Commission may provide testimony in a number of areas of interest during this proceeding.

The California Energy Commission has successfully used statements of issues similar to this filing in its own licensing proceedings. These issue statements have provided adequate notice to all parties of the issues in dispute without unduly restricting the parties in presenting their case. If the Applicant, NRC Staff or any other party has questions about this filing, the California Energy Commission counsel would be happy to discuss the matter informally and attempt to resolve any differenceu without the need for ASLB intervention.

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California Energy Commission Statement of Issues

1. What forecast of capacity and energy demand through 1995 should be used in this proceeding to determine the need for each California participant for Palo Verde Units 4& 5?

2. To what extent do California's mandatory building and appliance conservation standards (Pub. Res. Code S 25402; 20 Cal. Admin. Code SS 1400, et seq.) reduce the need of each California participant for Palo Verde Units 4 & 5?

3. To what extent do federal, state, and local programs and incentives to promote the use of solar energy (e.g., tax credits and lcw interest loans) reduce the need of each California participant for Palo Verde Units 4 & 5?

4. To what extent does California's mandatory load manage-ment program (Pub. Res. Code S 25403.5) reduce the need of California participants in Palo Verde Units 4& 5?

5. To what extent do other feasible and cost effective conservation activities reduce the need of each California participant for Palo Verde Units 4& 5?

6. What electrical energy resources are needed by each California participants to meet forecasted energy needs through 1995? '

7. What capacity resources are needed by each California participant to meet forecasted capacity needs through 1995?

E. Are Palo Verde Units 4 & 5 necessary to meet the foreccsted energy and capacity needs of the California partici-pants?

9. Do the California participants need at least e 15%

reserve margin to ensure reliable supplies of electricity?

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10. What electric generating facilities are reasonably likely ro be available to each California participant by the time Palo Verde Units 4 & 5 are planned to come on line?

11. If Palo Verde Units 4 & 5 are not needed to meet forecasted demand, would operation of Palo Verde Units 4 & 5 reduce oil and natural gc.s use in each of the California participants' systems?

12. What benefits, if any, would necessarily result from any such reduction in oil and gas use?

13. Is construction of the proposed project the most cost effective and environmentally benign method of producing these benefits from reduced oil use?

14. Are there any other benefits, other than reduced oil use, which justify participation in Palo Verde Units 4 & 5 by California utilities, if it is not needed to meet projected capacity and energy requirements?

15. Are there alternate fuels, such as methanol, biomass derived from fuel, shale oil, and oil from tar sands,taich are reasonably likelr i to be available in the 1990's for use in California's oil-fire' power plants whose use would be a better method to displace existing oil use than Palo Verde Units 4 55?

16. Tc what extent can increased power pooling among California utilities reduce the need for Palo Verde Units 4& 5?

17 To the extent increased pcwer pooling can reduce the need for Palo Verde Units 4& 5, is it a better option (i.e.,

more economical, reliable, and environmentally sound) than the proposed facilities?

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18. To what extent can cogeneration reduce the need for Palo Verde Units 4 & 5?

19. To the extent cogeneration can reduce the need for Palo Verde Units 4 & 5, is it a better option (i.e., more economical, reliable, an l environmentally nound) than the l proposed facilities?

20. To what extent can geothermal electric generation reduce the need for Palo Verde Units 4& 5?

21. To the exten" geothermal electric generation can reduce the need for Palo Verde Units 4 & 5, is it a better option (i.e., more economical, reliable, and enviro- ntally sound)

, than the proposed facili'ies?

22. To what extent can repowering of Silvergate for San Diego Gas & Electric reduce the need for Palo Verde Units 4& 5?

23. To the extent repowering of Silvergate for San Diego Gas & Electric can reduce the need for Palo Verda Units 4 & 5, is it a better option (i.e., more economical, reliable, and environmentally sound) than the proposed facilities?

24. To what extent can power purchases from Mexico reduce the need for Palo Verde Units 4& 5?

25. To the extent power purchases from Mexico can reduce the necd for Palo Verde Units 4 & 5, is it a better option (i.e.,

more economical, reliable, and environmentally sound) than the proposed facilities?

26. To what extent can a coal-fired pcwer plant reduce the need for Palo Verde Units 4 & 5?

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27. "o the extent a coal-fired power plant can reduce the need for Palo Verde Units 4& 5, is it a better option

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(i.e., more economical, reliable, and environmentally sound) than the proposed facilities?

28. Does the NRC health impact analysis for a coal alternative to Palo Verde Units 4 & 5 accurately account for the fol:owing:

a, Health impacts from a facility sited in a remote, unpopulated area in California.

b. Health impacts from a f acility complying with Clean Air Act New Source Review requirements, including attain-ment of ambient air quality standards by 1992.

c. Health impacts from a facility using scrubbers, electrostatic percipators or baghouses, and selective catalytic reduction to reduce sox, NOx, TSP, and hydrocarbon emissions.

29. What are the comparative financial risks to California participants of Palo Verde Units 4 & 5 and a coal-fired alterna-tive?

30. What is the comparative energy consumption in con-strucring and fueling Palo Verde Units 4 & 5 and a coal-fired alternative?

31. What cost estimates (capital, fuel, operations, maintenance, e tc . ) for Palo Verde Un.ts 4 & 5 should be used in this proceeding?

32. What cost estimates (capital, fuel, cperations, maintenance, etc.) of a coal-fired alternative should be used in this proceeding?

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33. Except as already provided in NRC Rules (Table S-3 and S-4), what is a reasonable assessment of the health and safety risk and impacts from the proposed facility, including its complete fuel cycle for comparison with alternatives?

34. Do the Applicants' capital cost estimates include a reserve for possible required design changes in nuclear facili-ties as a result of studies of the Three Mile Island Unit II accident?

35. To what extent will Applicants' estimated capital costs be increased as a result of the Three Mile Island Unit II accident?

3t Have the Applicants reasonably estimated the costs of spent fuel storage and disposal for Palo Verde Units 4 & 5?

37. Have the Applicants reasonably estimated the costs cf decommissioning Palo Verde Units 4 & 5?

38. What are the economic and reliability consequences to the California participants if no off-site storage of Palo Verde Units 4 & 5 spent fuel is available when needed?

39. Do the California participants have an adequate and acceptable method of financing deccmmissioning costs?

40. Is there a sufficiently assured uranium supply at a reasonable cost, taking into account mining, milling, enrich-ment, and fabrication, for Palo Verde Units 4 & 5?

41. Are the Applicants' estimates of Palo Verde Units 4 & 5 plant reliability (annual capacity f actor) reasonable given recent nuclear power plant operating f t :ilities?

42. Would the California participants be able to provide reliable service in the event of s simultaneous outage of all five Palo Verde units?

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43. What is the financial obligation of California participants in the event of a nuclear accident at Palo Verde Units 4 & 5?

44. What is the financial obligation of the California utilities for Arizona Public Services ' activities?

45. What impacts would delays in operation of Palo Verde Units 4 & 5 have on California participants' ability to finance the project and provide reliable electrical service?

46. What is the ability of the California participants to attract adequate and acceptable financing given the events at Three Mile Island Unit II?

Dated: June 20, 1979. Respectfully submitted, A j' MARK J. URBAN Deputy General Counsel

(<t' iab:Vtb DIAN M. GRUENEICH Legal Counsel Attorneys for the California Energy Commission

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'442B:21 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIrN BEFORE THE ATOMIC SAFETY AND LICaNSING BOARD In the Matter of: )

)

ARIZONA PUBLIC SERVICE ) Docke t Nos. STN-50-592 COMPANY, et al. ) STN-50-503

)

(Palo Verde Nuclear Generating )

Station, Units 4 and 5). )

)

)

CERTIFICATE OF SERVICE I hereby certify tint copies of the foregoing Califo rnia Energy Cc mission Statement of Issues have been mailed, postage prepaid, or hand delive red this June 20, 1979 to the following:

James D. Woodburn, Chie f Robert M. Lazo, Esq., Chairman Atomic Safety and Licensing Board Engineer U.S. Nuclear Regulatory Commission Public Service Department Washington, D.C. 20555 P.O. Box 631 Burbank, CA 91503 Victor Gilinsky Concissioner Samuel Corlick U.S. Nucler Regulatory Commission City Attorney Washington, D.C. 20555 P.O. Box 6459 Burbank, CA 91510 Dr. Quenti t J. Stober James L. Mulloy, Chie f Elec t rical Research Associate Professor Engir.eer & Assistant Mana:er Fishe ries Research Institute Edward C. Farrell, Chief

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University of Washington Assistant City At torney fc r 4C0 No rtheast 15th Avenue Seattle, Washington 98195 Wa te r and Powe r P.O. Box 111 George Campbell, Chairman Los Angeles, CA 90051 Maricopa County Board of Supervisors R.E. York 111 South Third Avenue Phoenix, Arizona 85004 Senior Vice President El Paso Electric Company P.O. Box 982 Michael M. Grant, Esq. El Paso, Texas 79999 Assistant Attorney Gene ral 2C0 State Capitol 1700 West Washington David N. Ba r ry III, Esq.

Phcenix, Artsona 85007 James A. Be o le t to , Esq.

Southe rn Calif o rnia Edison Cc apany P.O. Box 800 Rosemead, CA 91770 O 'T O Q

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4423: 22 Byron L. Miller Jack E. Thomas Assistant Vice President Vice President Nevada Power Company San Diego Gas & Electric Co.

P.O. Box 230 P.O. Box 1831 Las Vegas, Nevada 89151 San Diego, CA 92112 Cary E. Craythorn, Engineer Arthur C. Gehr , Esq.

City of Glendale Snell & Willme r 119 North Glendale Avenue 3100 Valley Cente r Glendale, CA 91206 Phoenix, Arizona 85073 Ronald V. Stassi, Enginee r Janice E. Kerr City of Pasadena J. Calvin Simpson, Esq.

100 North Garfield Avenue Vincent V. MacKenzie, Esq.

Pa sade na , CA 91109 Califo rnia Public Utilities Coacission Everett C. Ross 5066 State Building Public Utilities Director San Francisco, CA 94102 City of Riverside 3900 Main Street Mr. Larry Bard Riverside , CA 92501 P.O. Box 793 Tempe , Arizona 85281 Atomic Safety and Licensing Appeal Board Atomic Safe ty and Licensing U.S. Nuclear Regulatory Cocaission Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Conaission Washing ton, D.C. 20555 Docke ting and Service Section U.S. Nuclear Regulatory Commissior Dr. Stanley L. Dollins Washington, D.C. 20555 Assistant Director Energy Programs (OEPAD)

Ton Diamond, Esq. Office of the Governor 1208 First City National 1700 West Washington Bank Building Executive Towe r - Roon 507 El Pa so , Texas 79901 Phoenix, Arizona 85007 Co rdon W. Hoyt Stephen M. Schinki Utilities Director Counsel for NRC Staf f City of Anahein U.S. Nuclear Regulatory Commission P.O. Box 3222 Washington, D.C. 20555 Anaheim, CA 92803 Kathryn Burkett Dickson, Esq.

Ma rk J. Urban, Esq.

Counsel for the Ca lifo rn ia Energy Conaiss ion 1111 Howe Avenue, Suite 610 Sacramento, CA 95825

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