ML19241A723
| ML19241A723 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 06/26/1979 |
| From: | Bard L AFFILIATION NOT ASSIGNED |
| To: | |
| References | |
| NUDOCS 7907090328 | |
| Download: ML19241A723 (13) | |
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_m In the matter of ) 2ccket dos. ST;, 50-592 Arizona Public Service Co. 5 0~ 5 O et al.
(?alo 'brde "uclear Generating )
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Comments of the intervenor, larry Eard, on the Graft invironnental Statement of the above mentionec docket nos.
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The following are my comments on the L3S of PV 415 They are section by section cc=ments pertaining specifically to the information presented in the numbered section being discussed at that point.
1.1 The proposed project In the middle of the first paragraph it is stated that " Secondarily treated sewage effluent from the city of Phoenix, Arizona, 91st .-
Avenue sewage treatment plant will be the sole source of cooling water."
This statement would seem to indicate a major weakness in the planning and design of these large central station electrical power plants.
A constant source of cooling water is required at these plantrdue to the fuel used to supply electricity, uranium. iven when shut down the reactors require substantial quantities of water to remove residual heat generated by waste products created in the fission process.
To depend on a single source of this cooling water would seem to require rigid standards in both planning anc design. ..o failures ir the 91st Avenue sewage treatment plant, the transmission line from the treatment plant to the nuclear site, or the treatment plant on site can be tolerated. It is unreasonable to expect this will be the case for the JC year life of the P7 4a5 The intervenor believes that a more flexible cooling water supply system is more appropriate and such a system can 'ce designec and constructed for reasonable costs. I also believe that benefits from such a design would far outweigh any additional costs.
3y using Irainage water frca irrigation districts, tail. vater frc=
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eG these same districts, low quality droundwater that is in the vicinity of the plant, all supplementec by effluent, the Palo Verae plant can assist the central Arizona region in na2ing maximum use of her scarce resources such as water by reusin o this resource as many times as possible before it is consume; by Palo Verde.
1.2 Status of reviews and approvals In the last paragraph it is stated that the applicant will not be required to meet Federal, State, or local water Quality effluent discharge limits because there will be no discharges. The intervenor wouAu like to point out this is only true if all ponqson the site are adequately sealed to prevent seepage and any deposits, of chemicals removed during treatment of water or evaporation in ponds are adequately stabilised to prevent erosion from flash floods or wind erosion which are common occurancea in +ne deser+o environment of the site.
2.2.2.1 Ccamunity Characteristics The intervenor would like to emphasis two points mentioned in this section. In the secona paragraph on Lemography: " Future growth of this western area and many areas of Arisona depends upon the .
nondepletion of water resources." In the seconc paras raph on Imployment: "2conomic growth of all of .Maricopa County, Particularly manufacturing, has and will be limited by the lack of an ample and reliable source of water."
The staff conceAfs these important points in the total water management picture of central Arisona but when it comes down to analysing the impact of diverting and consuming vast quantities of this valuable resource to cool Palo Verde, they are remiss.
2.2.4 later use The staff contributes to confussion in this section. .. the second paragraph they use three different units in discussing water use within communities in the Phoenix area. It woul; clarify matters if consistent units were usec, where this would facilitate ccmparisons o$ data.
Also in this section is the statement"The CAP water will ee used primarily for agricultural purposes." It woul be wise if the staff became aware of effortsby municipal ani industrial use s to change this allocation scheme.
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Table 2.11 Cultural racources listad in the national ragister Tha intervenor woul like the addrass of ar Lady of .lount Carmel Catholic Church checked.
2.4.3 Seismicity The lata on earthqua2es discusseu is from recorle epicenters as of 1:57 near the site and Arisona in general since 1327 Ihe intervenor questions this information as to its adequacy.. As cf 197c, Arisona did not have enough instruments in place to accurately record seismic activity and triangulate to find epicenters. The state has been relying on neighbor states to assist in earthquake monitoring.
With this situation in mind it seems that the data base useu in the-
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21scussion in .one a:S 13 Inaaaquate.
232 .'ater Quality 01st Avenue effluent In this section the staff discusses the toxic effects of some soluble loads that are treated at ?lst Ave. This results in plant shut down and poorer quality water during these periods . This correlates with my discussion on Sec 1.1.
2 5 3 Groundwater The applicant contends that 255 of water infiltratec into the perched ,
sone via irrigation (or rather 255 of water pumped for irrigation) returns to the groundwater reservoir. If this were the case woulu it not be wise to dewater this perched sone consisting of 3COC to 10,C00 ppm dissolved solids, and use it to cool Palo Verde rather than let it seep tnrough the' permeable layer to the ground wat;r, m.. i,. , .- ,., u_, a. .. ., c u, ..m
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2 3.4 Groundwater quality
- n this statament on quality phenols are mentioned as ;eing present in quantities excessive of USPHS. The intervenor wonders where these ara coming from and if the staff or applicant has made any efforts to detarmine this.
2.5.2 local "etecrology In tha last paragraph, it is stated wind data was collecte; for 1 year.
Toes the staff actually believe that this is in adequate data case?
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The staff mentions that aftar laaving the on site treatment olant
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4 of cooling watar capacity or at 12act 2 vcluna so that the length of time that tha plant can be coolsi with on cite reservoir aater can ba 12tarnined. This woul_ hel,a aEeviato questions and confusion e
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3 4 daat liasipation Syctea Appro::iaately 2/3 of the heat generata by PT.;GS will be wasta2.
Hac the staff or applicant consi;ered using this waste heat to purify poor quality aatar which coula then be used to cool P'/;;GS.
This wouli odeviata ru1tiple pollution problems. By using the wacte heat3 1 css would need to be dissipated to the atmosphere, r?ducing thermal pollution. 3y using low quality water, selective groun: water pollution problems could be solved n[ a structurally ani valuable affluent could be used and reused for other purposes.
In the third paragraph it is stated that the water will be cooled to 31 5 F via the cooling towers; This figure is then repeated in Table 3 2. This is a numerical error in converting C to F.
It is listressing to the Intervonor that such a obvious error was misse; in the st1ff's review, in such a simple sumerical calculation. The intervenor can only wonder as to what other errors -
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nave coon missac in other auch more cri ical calculations. o 3.6.1 'clater cupply
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... applicant states that the treatment processes will markedly re:uce the numbers of any such agents (bacteria, viruses, protoccans,etc) pfasant in ths2 influent sewage affluent (SRia),Supp.3)." The intervencr wonders if any recent analysis or reanalysis of this
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3.6 5 zvaporation ponds There is no mention of the effect of dissolved salt concentration on the rate of evaporation frca open bodies of water. The staff and applicant hayebeen negligent in its analysis by not including all variablec in the avaporation nechanica.
In the lact paragraph of this section the staff states that no actimate of aeolian erosion can be senerated due to lack of data.
The inpraccion is given that no problem will ariac, but thic is inappropriate and wrong. 2ecauce thare ic a lach of data, only vo _+ '.m. . _i ..,
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3 3 7.1 Sanitary wastes Ihara is a ciccussion of the soli waste misposal area on site but
..ithout any description of this area. It is difficult to revita this raport for adequacy of design of syst:as, if liscussion on them is limitec to the fact that they re thare but .othing on how they work.
4.1.1.2 .:onagricultural considerations.
In the last paragraph soil stabilising of disturbed areas is discussec.
For larga areas ravegetation is mantioned as the mothed to be use if climata permits. It would seem that the staff is unaware of the f.ifficultias of r2 Vegetation in low rainfall areassuch as the plant site. It is unlikely that much grount cover can be maintained unless a major committment of time and water are spent on this stabilisinea method. A contingency plan woulu seem appropriate if revegitation is unsuccessful.
4.2 Impacts en water use and impacts to waterways This entire section is inadequate. There is no discussion of the impact of using the sewage effluent on the water balance of the entire region, as the title of this section would lead one to .
believe.
4.2.2 Groundwater The discussion here talks about dewatering the perched cone if it is necessary. Frca my understanding the excavations of the first three reactors required such dewatering. Also units 425 are closer to evapor ation ponds, which woula lead to higher perched cones.
Also in this section the depth to the perched cone given is different from the depth cited in sec. 2 5 3 Whi6h is accurate?
4.2 3 dater quality IT the discussion on water quality effects, some concern f,ould A
be given to contamination of the perched cones leading to contamination of the deep groundwater via seepage through old abandoned well holes either onsite or offsite.
4.4.3 1 Ihe number and distribution of newcomers.
In this section the case is made about the availability of large numbars of ccnstruction workers in the area. How does this relate to the recent press releases by the applicant concerning celays on ani 1. Ihis is supposedly ue to large turnover rate of emp6cyees and insufficient numbers of skillac employees.
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6 4.4.3 2 Impact to population and employment "when compared to the total number of nuw people e.;pects; in the area, will not produce any unique problems to an area that will be crowing rapialy in the next decade." Thi., mayb2 so, cut what is the acaei impact on a city that has c.o contro. over this growth, or an a-iequate.-planning program as it is?
"There may be some attempt on the part of local workers to leave their cresent o. ositions and tr"s to s2 cure positions in the P'6-G3
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construction force." If this were true why is the applicant having difficulty attracting adegtate numbers of skilleu workers
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4.4.3.2 Applicants purchase of materials The applicants purchase of effluent is considereu a benefit in this section, without consideration of options for effluent usa el iminatec
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There is no discussion on options eliminate by the contract fcr .
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erriuent frca the City of $hoenix. Any discussion is inccmplete unless intaagible costs, benafits, or options are discussec.
Ir th2 last paragraph, the applicant propos33 to store effluent on site if extended c.tutdowns occur. ihat capacity of water storage is plarn'd, that is,how many days of effluent can be storeu on site before capacity is reached?
,.~.a~ , n --s.v.~ , , c : ,J. a +u e s There is no discussion of impacts on 6rcunawater recharge at upstream locations, when all siwage is divertec to 31st Avenue.
"any prime recharge points have been i entifiec on the east side of the basin that are unuseable when all the sewage is pipe; to th a. ,La a., n + 0aa a. o .o r. .u. u, . - an .s . . .
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The intervencr questions if the regulatory agency is doing an acequata job, when it allows the applicant to ao its own monitoring.
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7 Accumption 2 totally ignores Indian .vatar rights anc there claim on sewa;2 efflu2nt from Phoeni... Assumption 3 is base- on the acolicants projections of affluent. There has been no inuepe:..ent analysis by the staff in this area of contention, as is r2quiraa by 'R4 r2gulations.
In the seconi paracraph, it is assumea that only water from
^1st .sv 2 will be divertea, hence no adverse impact between 23rd and Olst AVI. Recent actions by the Applicant indicate that this may not be the case. Cue to the Applicants own projections on availability of effluent for the first summers of operation, they will not have enough water available to cool the reactor 'n Unit 4 To alleviate this situation, the applicant is sb$ching sources, such as trade offs with the Buckeye Irrigation uistrict for more water in the summer for P7TGS ana and repayment during winter months.
Also, direct transfer from 23rd to 91st Ave is being corsicered.
This would then effect this sectir.n of the "iver. Snvironmental 7
damages must be considered for thi ossible solution to the water
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"Cn the basis of the projected population growth for tho ,
of Phoenix area, a linear increase in sewage effluent is assumed." _
This statement has two faults. First it accepts the applicants population projections with no statement on the rigorousness of staffs evaluation of these projections. Second it assumes a linear increase in effluent production which is a simplistic approach to a major point of contention in these proceedings.
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The work force for P7 4*5 will be about 230 full time employees during operation. They are not expected to affect traffic arteries.
The intervenor wonders how this interreacts with the present situation where an interchange on Interstate 10 is being proposea to accommodate construction workers at P'/:iGS. .s4L. There seems to be traffic problems nowrequiringStatetaxpayersto(hrect,throughFederalsubsiaies, to build this structure in the Feueral Interstate system. Ihen in a few years it will only be used for a handful of regular employees most of which will be from out of state, imported as experts to Operata the plants.
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6 5 6.1.2 ust and noise Zoes the applicant propose me thods of citigation for the " noise (that) may be considere; a nuisance by scae humans within this radius" assumed to de ' effected area around the plan:
5.6.1.4 .iate .se The it '
strongly opposes the statement that "various allocations of water in the area are discussed in aetail" in previous sections of the :53. This statement points cut what is probably the most insufficient aspect of the applicant data and the staffs analysis
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of this data. Until further studies are conductec on the projects impact on water resources and their management in the Phoenix area this draft statement is as y3t incomplete.
5 8 5 Radioactive Iffluents The eighth paragraph discusses assumptions usec for radon releases frcm stabilized tailings piles. What is the basis for this assumption?
By stating basis of assumptions the staff can help facilitate areas of confusion and contention.
5.e.6 Radioactive wastes
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. . .high-level and transuranic wastes are to be buried at a Federal
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Repository, and no release to the environment is associated with such disposal....Jo radiological environmental impact is anticipated from such disposal." This statement would seem to be a little premature. As et no wastes have been acequately disposec of, neither militar; or comercial. These statements are design objectives and hopes of the engineers, not necessarily the cata base of experience thus far gained.
Table 6.2 '.iater Quality Parameters (for groundwater monitoring systems)
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/ does this table not include grease and oils ? In the text of this aase and oil is discusse;, yet no document monitoring of 6gU monitoring of these produdw,3bich iP'3"adtly related to construction of
?73GS shcw up in the proposed acnitoring program sponsored by the applicant and supportec by the staff.
6.1 3 Meteorological The applicant has collected one years of data at the site. Ihe staff has then ccapared this to data from the city of Phoeni.x ana concluded that it represents average metereclogical conuitions.
This has two problems, first one years :ata is far from an acequate 311 146
9 iata bcse, and seconi 30 milss is a significant distance to judge meteorological conditions. Ispecially when cifferent tcpography ard wir' patterns are considered. s.ctrapolation of this data would seem to be beyor' .ormal statis;ical n=c;. a;i a. .
4.1.4 Ecology 6.1.4.1 Initial base line studies The intervanor wishes to support the staff's evaluation of the appitant baseline studies. The applicant seems unaware of statistical methods such as Styne's tw(stage aample size test to determine adequacy of data base in basic ecological measurements and statistical analysis, This would point to either inexperience in such ecological monitoring or the anplicant lack of concern with such monitoring.
6.1.4.2 Construction-?hases icological Studies Terrestrial It wouli seem much work needs to be done in this ar m prior to construct and must be available for review before permits are granted.
Chapter 7 2nvironmental impact of Postulated acciaents It seems incredible that this chapter is only four pages long.
Especially when it vias release in April, after the accident at Three Mile Island II. Any environmental statement released after '
TMI and not consider +It's effects and experiences on postulated accidents can only be viewed as incomplete. The intervenor will reserve his rights to coment on this ak are;) after this sectior. is supplemented by more up to date information on reactor accicents.
8.1.1 Applicants Service area "their sales are preponderantly to commercial and industrial establishments." The intervenor would like to make evident that often in discussions 'on need for power the buraen to the residential consumer is frequently ignored in the costs yet incluaed in the I
benefit to industry andccamerce.
Table S.4 Generating capacity by fuel use ana equipment type for eacis aarticicant o - in ?V::GS Units 425 The intervenor is shockec that the applicant .sPS has no projectec capacity frem any alternative, energy source. They are content to use conventional sources snch as fossil, nuclear, hycro, an: cca'oinea cycles. I:, a state that burns off million cu'cic feet of natural gas per day from one sewage treatment plant the local gas company oroject no futura use of biogas. In a state that has plentiful wind 31] i47
10 energy sites both in the northern plateau and the southern areas of the state, the local electric company projects ao capacity feasible before 1992. In a state that has more Jays of 26Ghp insolation than any other state in the country the local utility pro;ects nc capacit-( in the next 13 years. This is a conceanation of the applicant: analysis of future energy strategies.
S .2.2 Reserve :.:argin "15d reserve is " prudent practice" for their incividual operations" Aps reserve margin (5 of peak demand) is 19 2 which is the lowest margin in the conglomerate that constitute the Applicant. This is above the 155 limit se?f imposed upon the utilities. In comparison to the other utilitien, it would appear that a?5 requires an increase in peak power. It should be noted that P7bGS supplies base load, not peak power.
E.2.3.2 lead characteristics This three sentence paragraph is all that the intervenor can finc in ..is document that deals with the applicants neea for base load.
This niscussion is entirely inadequate. Just stating that base load is needed is no justification for bullaing a large central
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station power plant.
8,3 2 Impacts of energy conservation and substitution on the need fx power Tata in this sectian deal with reductions in useage from 1973 to IC77 It would seem appropriate to update this data as it is now 1979 8.4 conclusions "Forcasts which are too high can lead to construction of underutilized generating and transmission capacity, which leads to hisher costs of electricity and inflationary pressures on the cost of the capital financing as well as hi6 h interest charges if construction is stretched out over a large period to avoid underutilization of capacity." This statement has direct relevence to P7 lgs especially since Unit 1 has already . en delayed 1 year, leading to cost overruns similiar to those mentioned above. Jhat is confusing is a later statement in this section: "This can be advantageous unter conditions of nationwide capital shortages such as occurrea in the recent past, md which are continuing." There is no mention that cart of this problem results from construction of large central 311 148
It station power plants which tie up large sums of capital, making it less available for other market invstments, causing capial shortages.
? hat is realy confusing in this aiscussion for nee; for power b that most of the discussion deals with peak power and the need for it, and very little discussion on need for base load power. tihen
?7::03 is being constructed for base loac, shoulcn't the discussion deal with need for base load power?
o.l.2.1 Solar Energy.
Thisdiscussionfailstomentionthatsolardodhticwaterheaters and pool heaters have a effect of reducing base load, directly reducing need for ?V:;GS. Solar space heaters are totally ignorec-Also the upgrading of building construction to incluce passive solar design for space heating has been omitted, as a possible reducing force on need for base load power.
9 1.2.2 lind energy There is no mention of a proposal by S;G5 to install wind machines on existing power transmission towers to add directly to the generating capacity. .
9.1.2.7 Coal fired 1 nt A recent study by Extn, identified in the June 6 dashington Post and the June 19 Esquire conclude that there is no advantages of nuclear over coal. This would seem to contracict the incependent studies identified in table 9 1. It seems that the economic comparison depends upon capacity factors used in comparisons.
The applicant routinely uses 755, which is unrealistic if ccmpared to actual experience with reactors of the size of ?714GS.
It would seem appropriate if economic comparisons used figures for capacity that are more in line with actual experience.
9 1.2.8 Health effects
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. . . (the current experience for serious accidents is zero) ."
Is this statemcat still correct now that we have experiencea TMI?
c.2 Alternative sites
. Socioeconomic factors landowner dislocations The intervenor wonders if the staff has investigatec lend ownership 311 149
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/4 patterns in the vicinity of the site. It has recently been learned that tha family cf the Presi ent of th2 applicantrA 5, has ma;or 12 "c - r:hi: -> _ 2r:2, 2:. in fac; 301- par: of thi: lan which
.c 1 Ir the site for p7:.GS. There woula seem to be some conflict of interest.
2.2.h Staff's analysis "Ir tha staff's judg:-ment, the severity of _mpact of plant operation on water resources is directly aroportional to the percent of groundwater utilized." Ihe intervenor would like to add that this is proportional to the quality of the groundwater used, which the staff has overlocked.
10.1 Unavoidable adverse environmental effects 10.1.1.2 Uater this sectinn mentions how much will be used but fails to consider the impact of this consumption as woula be expected by the title of this section.
10.1.2.2 Aquatic The two statements in this section seem to conflict with each other.
Cn the one hand divarsion of effluent will improve quality of aquatic
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habitats in the Salt River, and the secona statement says that aquatic habitats will be reduced. The intervenor is confused by these seemingly contradictory statements.
10.1.3 Radiological effects The staff uses 1980 population projections for determining losages for reactor that will not be operating until 1990. c.oula it not be better to use 1990 population projection figures.
10.2.2 Inhancement of productivity "it is expected that plant operation employees will recieve special training for their positions and thus will enhance labor productivity."
T"I has experienced trouble finding enough qualified operators in thedenselypopulatedeastcdhtarea,whichlelAtooverworkedstaff on possibly to operator error auting the acciaent. .. hat will be the effect en finding enough qualifiad operators in a more sparsly populated region sdch as the desert of Arizona, where 5 reactors are being constructed, requiring many more operators.
"Since the profits of the utilities are regulated, it is expected that the capital rescurces will yeil- a return a: .eas equal to 311 150
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'3 that of other uses with similar risks." The intervenor wonders whose risks are being discussed when considering a regulated T.onopoly, The consumers or the stockholders?
10.2 3 1 Uses Adverse to productivity 13.2 3 2 Mater use There is no discussion of how this use will effect options eliminated by the consuption at ?VIGS.
10 3 Irreversible and irretrievable commitments of resources There is ri discussion of the consumption of water that is irreversible and irretrie table, 2nd how it effew; tha to tal water balance of the region.
10.4.2 33condary benefits
- 1. Nages paid to construction and operating personnel
- 2. Taxes said to local nolitical subdivisions
- 3. Taxes paid to local ' school districts Inclusion of these benefits contradicts public Service Cocoany-of 7ew H2moshire (Seabrook Station, Units 1 and 2), a&AS-471, 7 JRC 477, (April, 197c). .lhich ruled that increased employment ad tax revenues to the affected community may not be counted on the benefit side of the cost-benefit balance. .
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10.4.3 2 Environmental costs It seems inadequate that these costs are summarised in a table without any discussion on their impact. Benefits rective ample discussion so why not discuss the costa?
10.4.3 3 Radiological costs Where do t'he estimates of radwaste cost come from. Just stateing a projected cost without reference would seem to be inappropriate.
The above are the comments section by section on the s23. Jue to time constraints, no attempt will be made to integrate all these comments into a logical presentation, but this will be attempted for presentation at a later date. To conclude the intervenor would like to state that the 325 has major difficiencies in many areas that need attention before construction permits can be grantec.
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