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 EnclML19225A509 |
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Site: |
Palo Verde ![Arizona Public Service icon.png](/w/images/9/93/Arizona_Public_Service_icon.png) |
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Issue date: |
06/20/1979 |
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From: |
Grueneich D, Urban M CALIFORNIA, STATE OF |
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To: |
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References |
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NUDOCS 7907190479 |
Download: ML19225A509 (10) |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217E1551999-09-28028 September 1999 Comment Supporting Pr 10CFR50 Re Elimination of Requirement for Licensees to Revise ISI & IST Programs Beyond Baseline Edition & Addenda of ASME B&PV Code ML17313B0651999-07-30030 July 1999 Comment on Draft Rg DG-1076, Service Level I,Ii & III Protective Coatings Applied to Npps. ML17313B0161999-07-0101 July 1999 Comment on Draft Rg DG-1074, SG Tube Integrity. ML20196K5631999-06-29029 June 1999 Comment Supporting Proposed Rule 10CFR50.55a Re Elimination of 120-month Requirement to Update ASME Code ISI & Inservice Testing Program ML20207D1591999-05-20020 May 1999 Comment on Proposed Rules 10CFR21,50 & 54 Re Use of Alternative Source Terms at Operating Reactors ML17313A9791999-05-20020 May 1999 Comment Opposing Draft Reg Guide DG-1084, Qualification & Training of Personnel for Nuclear Power Plants. as General Comment,Util Believes That Many of Proposed Changes Will Limit Ability to cross-train Mgt Level Personnel ML20205A4271999-03-18018 March 1999 Comment on Petition for Rulemaking PRM-50-64 Which Requested Greater Clarification by NRC Re Possible Financial Obligations of NPP Licensees as Reflected in NRC Final Policy Statement on Restructuring & Economic Deregulation ML17313A8521999-03-0505 March 1999 Comment Supporting Proposed Change to NRC Enforcement Policy.Suggested Rewording of Sections Provided ML17313A8191999-02-24024 February 1999 Comment Supporting Secy 99-007, Recommendation for Reactor Oversight Process Improvements, & Comments Provided by NEI & Regional Utility Group Iv.Offers Comments on NRC Approach to Using Performance Indicators in Assessment Process ML20198J4031998-12-11011 December 1998 Comment Opposing Proposed Rule 10CFR50 Re Requirement for Monitoring Effectiveness of Maint at NPPs ML20217B9761998-04-0909 April 1998 Comment Re Draft RG DG-1029, Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safey-Related Instrumentation & Control Sys ML20216A9091998-04-0303 April 1998 Comment Opposing Proposed Rule 10CFR50.55a Re Industry Codes & Stds ML17313A3361998-03-27027 March 1998 Comment Opposing Proposed GL Re Lab Testing on Nuclear-Grade Activated Charcoal. Believes That Proposed 60 Day Implementation Schedule Would Severely Challenge Resources of Limited Number of Qualified Vendors ML20217E8781998-03-27027 March 1998 Comment Supporting Proposed GL, Lab Testing of Nuclear- Grade Activated Charcoal ML17313A2511998-03-0303 March 1998 Comment on Proposed GL 98-XX Re Yr 2000 Readiness of Computer Sys at Npps. ML20203L5521998-02-25025 February 1998 Forwards Comments on Draft Reg Guide DG-5008, Reporting of Safeguards Events ML20202E4251998-01-30030 January 1998 Comment on Draft RG DG-1070, Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for Use in Npps. Draft RG Should Be Revised to Clarify That Alloy Analyzer Can Be Used Consistent W/Guidance in EPRI NP-5652 ML20199E0871998-01-17017 January 1998 Comment Opposing PRM 50-63A by Pg Crane Re Amending Emergency Planning Regulations to Require Consideration of Prophylactic Use of Potassium Iodide for General Public ML20202G4461997-12-0101 December 1997 Comment on Proposed Final Rule 10CFR50.Licensee Requests That Effective Date Be Delayed from 980101 to 0601,in Order to Provide Enough Time to Request & Obtain NRC Review of Exemption from Rule ML20212D1391997-10-17017 October 1997 Comment on Pr 10CFR55 Re NUREG-1021,Interim Rev 8, Operator Licensing Exam Stds for Power Reactors ML17312B4241997-04-23023 April 1997 Comment Supporting Draft Rg DG-1068 (Proposed Rev 3 to Rg 1.134, Medical Evaluation of Licensing Personnel at Npps) ML20134J9671997-02-0606 February 1997 Comment Supporting Proposed Rule 10CFR50, Draft Policy Statement on Restructuring & Economic Deregulation of Electric Util Industry ML20134N2521996-11-14014 November 1996 Comment on Draft RG DG-1012,proposed Rev 3 to RG 1.8, Qualification & Training of Personnel for Npp ML20117E3871996-08-0707 August 1996 Comment Supporting Proposed Rule 10CFR26 Re Mod to fitness-for-duty Program Requirements ML20113C6981996-06-24024 June 1996 Comment Supporting Proposed Rule 10CFR50, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors. Cautions NRC Not to Adopt Rules That Are Too Restrictive & Could Lead to Premature Decommissioning ML20117P1261996-06-24024 June 1996 Comment on Proposed Rule 10CFR50, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors. Urges NRC to Approach Rulemaking Re Decommissioning Costs in Manner That Will Facilitate Federal Legislative Solution ML20095A8461995-11-28028 November 1995 Comment on Petition for Rulemaking PRM-50-62 Re Proposed Changes to 10CFR50.54.Util Endorses Industry Petition & Response Provided by NEI ML17311B2931995-11-27027 November 1995 Comment Opposing Draft NUREG/CR-6354, Performance Testing of Electronic Personnel Dosimeters. ML17311B1601995-08-31031 August 1995 Comment Opposing Review of Revised NRC SALP ML20087H7241995-08-16016 August 1995 Comment Opposing Proposed Rule 10CFR2 Re Comment on Revision of NRC Enforcement Policy ML20087H7501995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Std Design Certification for ABWR Design & Std Design Certification for Sys 80+ Design ML20087H7331995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Standard Design Certification for ABWR Design & Standard Design Certification for Sys 80+ Design.Concurs w/ABB-CE Comments & NEI Recommendations ML17311B0071995-06-27027 June 1995 Comment on Proposed Review of NRC Insp Rept Content,Format & Style. Insp Detail Should Be Brief & Ref Previous Rept by Section or at Min IR Number ML20083N5031995-05-0505 May 1995 Comment on Proposed Rev to 10CFR50,app J, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors. Proposed Rev Will Result in Highly Efficient Regulation ML20082P7461995-04-19019 April 1995 Comment Supporting Proposed Rules 10CFR170 & 171 Re Proposed Revs of NRC Fee Schedule for FY95 in Fr ML20082H0971995-04-10010 April 1995 Draft Policy Statement Re Freedom of Employees in Nuclear Industry to Raise Safety Concerns W/O Fear of Retaliation ML20081B5721995-03-0808 March 1995 Motion of Plains Electric Generation & Transmission Cooperative,Inc to Withdraw,W/Prejudice,Petition for Leave to Intervene,Request for Finding of Significant Change & for Antitrust Hearing & Comments.* W/Certificate of Svc ML17311A6691995-02-0202 February 1995 Comment Supporting Draft Rg DG-8014 (Proposed Rev 3 to Rg 8.13, Instruction Concerning Prenatal Radiation Exposure) ML20078H0671995-01-20020 January 1995 Comment Supporting NUMARC Position on Proposed Rules 10CFR20,30,40,50,51,70 & 72 Re Radiological Criteria for Decommissioning of Lands & Structures ML20077M5471995-01-0404 January 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Nuclear Power Reactor Proposed Rule ML17311A2461994-08-25025 August 1994 Comment on Draft Reg Guide (DG-1031), Monitoring Effectiveness of Maint at Npps. Term Maint Preventable Failure Needs to Be Defined & Compared to Term Maint Preventable Functional Failure. ML17310B1911994-04-12012 April 1994 Petition to Intervene of Public Utility Commission of Texas. W/Certificate of Svc ML17310B2041994-04-12012 April 1994 Petition to Intervene of Public Utility Commission of Tx ML20062M4141993-12-27027 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Procurement of Commercial Grade Items ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML17306B2461993-01-15015 January 1993 Comment Supporting in Part,Draft Reg Guide DG-1020, Monitoring Effectiveness of Maint at Npps. ML17306A9571992-09-0808 September 1992 Comments on Proposed Rev to Staff Technical Position on Radwaste Classification.Supports Rev ML20099E0621992-07-29029 July 1992 Comment Opposing Proposed Rule 10CFR50.63, Loss of All AC Power ML20090F9661992-03-0909 March 1992 Comment Supporting Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant Personnel ML17306A4501992-02-0404 February 1992 Comment on Draft Reg Guide Task DG-8007 (Proposed Rev 1 to Reg Guide 8.7) Re Instructions for Recording & Reporting Occupational Radiation Exposure Data 1999-09-28
[Table view] Category:PLEADINGS
MONTHYEARML20081B5721995-03-0808 March 1995 Motion of Plains Electric Generation & Transmission Cooperative,Inc to Withdraw,W/Prejudice,Petition for Leave to Intervene,Request for Finding of Significant Change & for Antitrust Hearing & Comments.* W/Certificate of Svc ML20092H1231992-02-0303 February 1992 Licensee Answer in Support of Notice of Voluntary Dismissal of Petition for Leave to Intervene.* Informs That Licensees Do Not Object to Dismissal of Proceedings. W/Certificate of Svc ML20086K4441991-12-10010 December 1991 Licensee Answer in Opposition to Petition for Leave to Intervene & Request for Hearing.* Petition Should Be Denied Due to Petitioner Failure to Advise Appropriate Parties Re Hearing.W/Certificate of Svc & Notices of Appearance ML20082N9211991-08-30030 August 1991 Licensee Motion to Compel Response to Licensee First Set of Interrogatories.* Requests That Board Compel Intervenors to Respond to First Set of Interrogatories & That Motion Be Considered on Expedited Basis.W/Certificate of Svc ML20077G2201991-06-0707 June 1991 Brief of Petitioners on Appeal of LBP-91-19.* Licensee Appeal Should Be Denied in Entirety,Because of Foregoing Reasons.W/Certificate of Svc ML20073A9351991-04-17017 April 1991 Licensee Motion to Dismiss Petitioners & Terminate Proceeding.* Board Should Dismiss Petition Because Petitioners Have Failed to Comply W/Board Order.W/ Certificate of Svc ML20076N0871991-03-21021 March 1991 Licensee Response to Supplemental Petition of Mitchell Petitioners.* Contention Proposed by Petitioners Fails to Satisfy Requirements of 10CFR2.714(b)(1) & Should Be Dismissed ML20076N0971991-03-21021 March 1991 Licensee Response to Scott/Bush/Cree Supplemental & Amended Petition.* Petition Does Not Demonstrate Petitioners Standing to Intervene as Matter of Right or Present Admissible Contention.W/Certificate of Svc ML20215K9271987-05-0707 May 1987 Comments of Plains Electric Generation & Transmission Cooperative,Inc,On Issuance of Facility OL to Operate at Five Percent of Full Power.* Commission Must Consider Antitrust Issues.W/Certificate of Svc ML17303A4091987-04-27027 April 1987 Petition Under 10CFR2.206 Re Alleged Unauthorized Disabling of Engineered Safety Sys on 870120,mgt Response to Event & Failure of Personnel & Mgt to Fully Appreciate Significance of Events.Show Cause Order Warranted ML20207S5971987-03-17017 March 1987 Reply of Plains Electric Generation & Transmission Cooperative,Inc to Response of El Paso Electric Co to Comments of Plains Electric Generation & Transmission Cooperative,Inc on Antitrust Info....* W/Certificate of Svc ML17300A6501986-11-28028 November 1986 Comments on Antitrust Info & Requests for Finding of Significant Change,For Antitrust Hearing & Imposition of License Conditions to Prevent El Paso Electric Co anti- Competitive Activities.Certificate of Svc Encl ML17299B0661986-02-26026 February 1986 Corrected Views & Comments on Petition Filed by Coalition for Responsible Energy Educ. Suspension of OL Unwarranted Due to Aggressive Responses to IE Suggestions for Improvement ML17299A9821986-02-0303 February 1986 Petition to Show Cause Per 10CFR2.206(a) Requesting Suspension or Mod of Unit 1 OL for Containment Sys Retesting (Ilrt).Supporting Documentation Encl ML20137P6561986-02-0101 February 1986 Petition for Emergency Relief Per 10CFR2.206(a) & Order to Suspend Operation of Unit & OL Issued on 851209 Until NRR Responds to 860117 Petition to Show Cause & 860121 Addendum ML17299A9701986-01-21021 January 1986 Addendum to 860117 Show Cause Petition,Per 10CFR2.206, Requesting Suspension of OLs Pending Completion of Specified Regulatory & Corrective Actions & Institution of Proceeding on Mgt Competence ML20117L1881985-05-0606 May 1985 Show Cause Petition Requesting Suspension of License NPF-34 Pending Completion of Corrective Actions Re Spray Pond Piping Corrosion & Institution of Proceeding on Corrective Actions ML20077Q3281983-09-12012 September 1983 Answer Opposing West Valley Agricultural Protection Council, Inc 830827 Motion for Directed Certification of ASLB 830711 Order Denying Council 830202 Motion for Suppl to Fes. Certificate of Svc Encl ML20076G8561983-08-27027 August 1983 Motion for Directed Certification of ASLB 830711 Order Denying West Valley Agricultural Protection Council Motion for Declaration That EIS Inadequate & for Continuance of Proceeding ML20076G8681983-08-27027 August 1983 Memorandum Supporting West Valley Agricultural Protection Council Motion for Directed Certification of ASLB 830711 Order Denying Council Motion for Declaration That EIS Inadequate & for Continuance.Certificate of Svc Encl ML20077H9761983-08-0808 August 1983 Response Opposing West Valley Agricultural Protection Council 830721 Request That ASLB 830711 Memorandum & Order Be Referred to Aslab.Stds for Referral Not Satisfied. Certificate of Svc Encl ML20077J0571983-08-0808 August 1983 Motion for Exemption from Page Limitation Requirements of 10CR2.788 for Answer to West Valley Agricultural Protection Council,Inc 830722 Motion Seeking Stay of ASLB Decision to Proceed W/Hearing.Certificate of Svc Encl ML20077H9341983-08-0808 August 1983 Answer Opposing West Valley Agricultural Protection Council Motion for Stay of ASLB Decision Re Validity of Fes.Question Cannot Be Put Before Aslab While Same Issue Pending Before Aslb.Certificate of Svc Encl ML20077F9281983-07-29029 July 1983 Response Opposing West Valley Agricultural Protection Council 830715 Motion to Compel Response to Interrogatories. Matl Protected by work-product Doctrine But Is Available for in Camera Insp.Certificate of Svc Encl ML20024D2261983-07-29029 July 1983 Response Opposing Joint Applicants Motion to Compel Answers to interrogatories.Wide-ranging Fishing Expedition Should Not Be Allowed.W/Certificate of Svc ML20077D1661983-07-22022 July 1983 Motion Seeking Stay of ASLB 830711 Decision Permitting Hearing to Proceed W/Inadequate Eis.Certification of Appeal & Completion of Adequate EIS Requested ML20077D1741983-07-22022 July 1983 Memorandum in Support of Motion Seeking Stay of ASLB 830711 Decision Permitting Hearing to Proceed W/Inadequate Eis. Exhibits & Certificate of Svc Encl ML20076L1961983-07-15015 July 1983 Motion to Compel Responses to Second Set of Interrogatories 2-4,7 & 9.Legitimacy of Joint Applicant Objection May Be Resolved by Identifying Each Document Specifically ML20076L2081983-07-15015 July 1983 Memorandum in Support of Motion to Compel Responses to Second Set of Interrogatories 2-4,7 & 9.Objections Are Overbroad.Confidentiality Waived Re Fog Model Since Model Used in Proceeding.Certificate of Svc Encl ML20076L5531983-07-15015 July 1983 Answer Opposing West Valley Agricultural Protection Council, Inc (West Valley) 830629 Motion for Protective Order.Order Unnecessary Since No Motion to Compel Interrogatory Response Filed ML20076L5661983-07-15015 July 1983 Motion to Compel West Valley Agricultural Protection Council,Inc to Answer Interrogatories.Interrogatories Relevant or Will Lead to Discovery of Admissible Evidence. Certificate of Svc Encl ML20085A2871983-06-29029 June 1983 Motion for Protective Order Against Joint Applicants & NRC Interrogatories Requesting Info on West Valley Agricultural Protection Council,Inc Members,Acreage,Crop Yields & Profits ML20085A2921983-06-29029 June 1983 Memorandum Supporting West Valley Agricultural Protection Council Motion for Protective Order.Question Relates to Potential Salt Damage to Area Crops,Not Council Member Crops.Certificate of Svc Encl ML20074A7961983-05-16016 May 1983 Memorandum Supporting West Valley Agricultural Protection Council,Inc Motion for Discovery Schedule.Projected Date for Crop Study Completion 6 Wks Later than Original Date ML20074A7471983-05-13013 May 1983 Motion for Mod of ASLB 830323 Discovery Schedule,Per 830309 Stipulation on Discovery.Depositions Scheduled for 830718 Should Be Rescheduled for 830829.Discovery on Univ of Arizona Crop Study Should Begin on 831220 ML20074A7451983-05-13013 May 1983 Supplemental Motion to 830202 Motion for Declaration That NEPA Analysis Inadequate & for Continuance of Proceedings. Joint Applicant Responses to Interrogatories Lacked Meaningful Data on Salt Deposition ML20074A7891983-05-0606 May 1983 Memorandum Supporting West Valley Agricultural Protection Council,Inc Supplemental Motion for Declaration That NEPA Analysis Inadequate & for Continuance.No Attempt Made to Identify/Analyze Salt Drifts.W/Certificate of Svc ML20073J8671983-04-16016 April 1983 Supplemental Response to Joint Applicants Motions to Strike Pl Hourihan 830223 Motion for Leave to File Response.Motion to File Response & West Valley Agricultural Protection Council Motion Re NEPA Should Be Granted ML20072F7091983-03-20020 March 1983 Response Opposing NRC & Joint Applicants Motions to Strike Pl Hourihan Motion for Leave to File Response to West Valley Agricultural Protection Council,Inc Motion for Ruling on Contentions.Certificate of Svc Encl ML20065R6691982-10-26026 October 1982 Response of West Valley Agricultural Protection Council to Joint Applicants 821022 Motion for Extension of Time to Answer Council Petition to intervene.Ten-day Extension Should Be Granted.Certificate of Svc Encl ML20065Q4411982-10-22022 October 1982 Motion for 2-wk Extension of Time to Answer West Valley Agricultural Protection Council,Inc 821013 Petition to Intervene.Complete Petition Not Received.Certificate of Svc Encl ML20058H6611982-08-0505 August 1982 Response Opposing Pl Hourihan Motion for Reconsideration of ASLB Admission Into Evidence of Joint Applicants Exhibit DD Exhibit Correctly Entered Into Evidence,Meets Reliability Test & cross-examination Was Allowed.W/Certificate of Svc ML20058G3991982-07-29029 July 1982 Answer Opposing Pl Hourihan 820716 Motion for Reconsideration of ASLB Admission Into Evidence of Joint Applicants Exhibit Dd.Exhibit Authenticated & Cannot Be Excluded Under Hearsay Objection.W/Certificate of Svc ML20055B9491982-07-19019 July 1982 Page 11 Inadvertently Omitted from Applicant 820716 Response to Intervenor Petition for Directed Certification Per 10CFR2.718(i) ML20055A4711982-07-15015 July 1982 Answer Opposing Pl Hourihan 820621 Petition for Directed Certification of Two ASLB Evidentiary Rulings.Stds of Irreparable Harm & Pervasive Effects on Basic Structure of Proceeding Not Met.Certificate of Svc Encl ML20054H2501982-06-21021 June 1982 Petition for Directed Certification Re ASLB Exclusion of Evidence About Invalidity of Util Contract for Effluent & Likely Effects of Pima-Maricopa Indian Lawsuit on Assured Water Supply ML20052G9601982-05-14014 May 1982 Motion for Reconsideration of ASLB 820427 Ruling of Inadmissibility of Claims of Pima-Maricopa Indian Community Re Water Source.Nepa Analysis Must Consider Significant Uncertainties About Assured Water Supply ML20052B6711982-04-26026 April 1982 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 ML20054E0461982-04-19019 April 1982 Response to Pl Hourihan 820407 Motion for Order Requiring Admission of Genuineness of Nov 1977 Effluent Document.Ee Van Brunt Affidavit Answering Motions Encl ML20054C6841982-04-13013 April 1982 Motion for Protective Order Re Joint Applicant Subpoena Duces Tecum.Certificate of Svc Encl 1995-03-08
[Table view] |
Text
.--s,.-..NRC PUDLIC - a v.'.ZG ROOM
'., p UNITED STATES OF AMERICA
-', NUCLEAR REGULATORY COMMISSION 7-Y. s's 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--m gp ,n 3,-79071got,7c7 ti Lv 7-
...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.
7 fG L'>}T)Of-2-Jt/<-
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? 3hh b
.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 to be available in the 1990's for use in i 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? ..,qg b4g/La t 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 lproposed 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?
~~bik(lL 27."o the extent a coal-fired power plant 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?
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?
3 ri'!O I) b' ' -
.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?
_,.-
I I 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 [)/4(){O8
'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 P.O. Box 631 Washington, D.C.
20555 Burbank, CA 91503 Victor Gilinsky Samuel Corlick Concissioner U.S. Nucler Regulatory Commission City Attorney P.O. Box 6459 Washington, D.C.
20555 Burbank, CA 91510 Dr. Quenti t J. Stober Research Associate Professor James L. Mulloy, Chie f Elec t rical Fishe ries Research Institute Engir.eer & Assistant Mana:er
~Edward C. Farrell, Chief University of Washington Assistant City At torney fc r 4C0 No rtheast 15th Avenue Wa te r and Powe r Seattle, Washington 98195 P.O.Box 111 Los Angeles, CA 90051 George Campbell, Chairman 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.
Assistant Attorney Gene ral El Paso, Texas 79999 2C0 State Capitol David N.Ba r ry III, Esq.
1700 West Washington 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-b&i LUl 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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