ML18192A829

Notice of Service of Interrogatories

ML18192A829
Person / Time
Site:	Palo Verde
Issue date:	08/29/1975
From:	Fisher B Arizona Public Law Advocates
To:	Atomic Safety and Licensing Board Panel
References
Download: ML18192A829 (24)

Text

0'NITED

-STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Q'~P BEFORE 'THE ATOMIC SAFETY AND LICENSXNG BOARD gb

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Xn the Matter of ) /

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ARIZONA PUBLIC SERVICE ) Docket Nos. STN 50-528 COMPANY, et al. ') 50-529

) 50-530 (Palo Verde Nuclear Generating . )

Station, Units 1, 2 and 3) )

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TO: Applicant,. ARIZONA PUBLIC SERVICE COMPANY, and.its attorneys, SNELL 6 WXLMER, Arthur Gehr and Bruce Norton.

Under authority of l9 CFR 5 2.750,'0 CFR 2, App. A and the Federal Rules of Civil Procedure, Intervenors ARIZONA CLEAN ENERGY 'COALXTION, hereby demand that Applicant Arizona Public Company (hereinafter APS) or their attorney answer in writing

'ervice and under oath and within thirty (30). da'ys from receipt hereof, the following interrogatories:

PaUL1TB) g0".,~~pay~, .

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gs<t'C UNITED STATES OF 'AMERICA

.NUCLEAR REGULATORY COMMISSION,'.

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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ARIZONA PUBLIC SERVICE ) Docket Nos. STN 50-S28 COMPANY, et al. ) 50-529

) 50-530 (Palo Verde Nuclear Generating )

Station, Units 1, 2 and 3) )

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'OTICE OF SERVICE OF INTERROGATORIES Intervenor hereby give notice that non-uniform interrogatories nos. 1-17 have been served on Applicant APS this 29th day of August, 1975.

ARIZONA PUBLIC LAW ADVOCATES BARBAR'A E. r ISHER 201 North Stone Avenue,. Suite 210 Tucson, Arizona 85701 Attorney for Intervenor COPY OF the foregoing mailed this 29th day of August, 1975, to:

Frederic S. Gray Thomas M. Bruen U. S. Nuclear Regulatory Commission Office of Staff Counsel Washington, D.C. 20555 Andrew W. Bettwy Assistant Attorney General 1700 West Washington Phoenix, Arizona 85007 Carmine F. Cardamone, Jr.

1415 North Third Avenue Tucson, Arizona 85705

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Bruce Norton, Esq; Arthur Gehr, Esq.

SNELL & WXLNER 3100 Valley Center Phoenix, Arizona 85073 Docketing and Service Section Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D.C. 20555

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4. 1 (a) , What, populate,on growth'ate is assumed for the Phoenix Metropolitan Area for the next ten years?

(b) .What population growth rate is assumed for the total service area of the applicants?

4.2(a) Site references to support the assumption that construction costs will increase by 7% to 8% per-year during con truction.

(b) What would the capital costs of PVNGS be if the escalation rate for capital costs was 15% per year?

4.3(a) When are the projected costs and the fraction of the total projected costs (in present dollars) of PVNGS for 1982, 1984, 1986, and '1988 that is represented by (1) 0 6 M except fuel (2) Fuel yellowcake (ii) enricluuent and fahrication (iii) spent fuel transportation (iv) spent fuel roprocessing.

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(v) . waste 'disposal (vi) other

"(3) Capital and interest.

(i) labor (ii) site materials (iii) purchased equipment (iv) other construction costs (v) 'nterest

, $ b) What is. the projected revenue from sale of plutonium?

(c) What type of waste disposal was contemplated in answer to 4. 3 (a) (2) (v)?

(d) What is the average projected cost (in current dollars) and fraction of the total projected cosi s per-1000 NW I

coal fired capacity for. 1982, 1984, 1986, and 1988 that is prepresented by (1). 0 6 N except: fuel (i) sulfer control equipment (ii) parti.culate control equipment (iii) other (2) Fuel (i) Coal (ii) land reclamation (iii) other (3) Capital and interest (i) labor (ii) site

. materi.als (iii) purchased equipment (iv) other construction costs (v) interest

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(e) List what'catagories of costs,(if ~

a~ were included

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under "other" in questions 4.3(a) and (d).

4. 4 (a) What is the present Loss of Load Probability (LOLP) and the present Loss of Energy Probability (LOEP) of the present power network owned by the applicants-'P (b) Calculate the LOLP and LOEP for 1982, 1984, 1986 and 1988 capacity factor of PVNGS was 708,.61.4%, 50.5.o, and 39.3%

and the availability factor was 69.4;-. List capacity factor and availability factor assumed for the non-nuclear base load plants.

(c) Calculate the LOLP and LOEP for 1982, 1984, 1986, and 1988 if PVNGS were replaced with coal fired plants with.

the operating characteristics of Cholla 1. List the capacity factor and availability factor assumed.

(d) What amount of generating capacity would'e necessary in 1982, 1984, 1986, and 1988 in order to maintain an LOLP of 1 and 2 if PVNGS had a capacity factor of 70%, 16.4-,

and 50.5- and an availability factor of 69.4%.

(e) What, amount of generating capacity would be necessary xn 1982, 1984, 1986, and 1988 in order to maintain an LOLP of 1 if PVNCS- wero replaced with coal-fired plants with

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operating characteristics- of Cholla 'l.

.(f) Show equations used to calculat'e LOLP and LOEP.

4.5 (a) What is. the present average percentage of total powe'r that is generated by (1) Base-load'units (2) Intermediate-load, units (3) Peak-load units (b). What percentage of total power output.

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'(1) Base-load units (2) Intermediate-load units (3) Peak-load units for 1982, 1984, 1986, and 1988'f PVNGS has a capacity factor of 70% and, 50.5% and an availability factor of 69.4%'?

(c) What.'units planned to be in commercial operation between 1982 and 1988 are considered base-load units?

List, (1) Name (2) Capacity (NW)

(3) assumed capacity factor (4) planned date of operation (5) type of fuel'used 4.6 List, for each major piece of air pollution control equip-ment (e.g. electrostatic parcipitator) which is in tailed or is planned to be installed by 1980, on any coal-fired plant owned in whole or in part: by any participant (a) Name of unit (b) Size of unit (c) Manager of unit

(d), 'Type'of device (e) Average or predicted efficiency'f device (either percentage removal by .weight or what ever is the normal definition of efficiency for that type of device).

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(f) Average 'or predicted cost (present dollars)

(g) Date of installation

'4..7(a) Calculate the cost (present dollars) of generating

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for the years 1982, 1984, 1986; and 1988

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power'Mills/kwkr) if PVi'$GS was built with capital costs of $ 700/KNe, yellowcake costs in 1980 were $ 38/lb increasing yearly .to $ 46/lb 'in 1985 then leveling out at that level,'nd each unit had the following capacity factors 1st year of operation '8% capacity factor 2nd year of operation 38% capacity factor 3rd year of operation 41-o capacity factor 4th year of operation 47% capacity factor 5th year of operation 42% capacity factor

't 6th year of. operation 38'-o- capacity factor 7th year of operation '1% capacity factor The capital cost is estimated from an'rticle by Raymond Bennett in the March-April issue of Ebasco News. The fuel cost is estimated by Nuclear Exchange Corp. as reported in the August 18, 1975 issue of Business Nock p.29. The capacity factors are obtained by using the average 1st year capacity Pactor without refuclinq for the 3 nuclear reactors with steam/stems provided by C-H, Tlute other capacity factors were scaled from that figurc according to the relationship

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.between capacity, factox and number of years of operation for all commercially operating nucleai reactors .in the US larger than 100 MWe as'escribed in "Will Idle Capacity Kill Nuclear Power" by David Comey; Nov. 1974; Bulletin of the Atomic Scientist, p.23-28.

(b) Calculate the cost (in present dollars) of generating power (Mills/kwhr) for the years 1982, 1984, 1986, and 1988 if PVNGS were replaced by coal-fired plants, with the average

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capacity factor and availabi3.ty factor and projected con-struction cost of Cholla 1. Include as part of the cost estimate, the current worth cost of the best available pol-lution control equipment, listed in answer to question 4.6 Include as part of the fuel cost an additional 5% of the fuel cost (in present dolla s) for land reclamation. List the estimated capital cost, escalation rate of capital, interest rate, fuel cost e>:elusive *of land reclamation costs used in calculating the co t of power (c) Calculate 4.7(b) assuming PWi. GS were replaced with coal-fixed units of the size, estimated cost, and estimated capacity factor and availability factor planned for between 1975 and 1982. In addition to the .information xequested in 4.7(b), list the average size and capacity factor of the units used.

(d) Calcu3.ate the amount of replacement power (compared to a 3.005 needed to meet the projected demand for 1'982, 1984, 1986, and 1988 for oach of tho above cases. What percentage will come fx'om (1) other base-load units

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(2). Intermediate-load units (3) Peak-load units (e) What are the. projected costs of power fiom Intermediate-load -units and Peak-load units for 1982, 1984, 1986, and 1988.

4. 8 (a) Is any member of ANPP presently a participant in any coal-fired plant where land reclamation is presently being done or planned'P (b)'f the answer to 4.8(a). is yes list the following (1) Name of unit (s)

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(2) Operation of unit(s)

(3) Amount being spent or contemplated to be spent per ton of coal for land reclamation 4.9 (a) What major species of animals, including,all endangered species, live in the Fred J. Weiler Greenbelt on the pro-posed state natural area and in what numbers?

(b) What studies done for applicants or what outside refer-'nces were used in answering 4.9(a)P

{c) What species listed in 4.9(a) are endangered'2 4.10(a) Calculate the amount of water that would be available to the Fred J. Weiler Greenbelt anQ the proposed state natural area if applicants projections of s7ater availability are correct. Assume the Roosevelt Irrigation District uses its full allotment. List the growth rate in water availability assumed.

(b) Calculate the water lost Quc to evaportranspiration and to groundwater recharge in each of t:.he four .sections shown

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in figure 2.8 of the DES.

(c) What outside references or studies conducted b'y applicants were used to justify the model(s) and/or data used to answer'uestions 4. 10 (a) and (b)?

4. 11 Calculate 4.10 (a) and (b) if the availability of water grows 'at the same rate as the population growth rated listed in 4.1(a)?

4'.12(a) calculate any significant effects (increases or decreases) t the water availability listeQ in 4. 10 (a) would have on the species listed 'as endangered in question 4.9(a) .

(b) Calculate 4.12(a) using the water availability listed in

4. 11.

(c) List references -to support the models or conclusions listed in 4. 12 (a) and (b)

Cal'culate the change in the groundwater tables in the

.'.13(a) areas og the Fred J. Weiler Greenbelt and proposed state natural area due to the water availability 'listed in. 4.10(a).

(b) Calculate 4.13(a) Que to,the water availability listed in

4. 11.

(c)'ist references to support the calculations and models used in 4. 13 (a) and (b) .

4. 14 Site the references used in determining 'that only about 700 workers anQ their families will- live in the general area of the plant.

4. l5 (a) Estimate the number of or amount of and the cost of providing the additional facilities and services necessary to main-tain, at present percapita levels, the facilities and

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servi ces needed zor.

(1) 1400 workex's =and their- families (2) '2100 workers and their ',families Include estimates for medical care {hospitals and doctors),

roads, education facilities (elementary and secondary),

police and fire protection, .and sewers and sewage treat-ment facilities.

{b) . What are the estimated bonding capacities for'intersberg, Buckeye, Arlington, Hassayampa, Tonopah., and Palo Verde in 1980?'.

(c) What is the estimated bonded indebtedness for the towns listed in 4.15'(b) for 1980?

16 What would the reserve margin for 1982, 1984, 1986, and 1988 for each applicant and for the whole system owned by the applicants be (with and without PVYGS) .if the present trends in electrical consumptions (Jan. to June 1974 or to Jan. to June

'I 1975) continued until December 31, 1975, 1976, 1977, and 1980 and then increased to 7%, 8% and 9S per year? List the present electrical growth rate for each applicant.

4.17(a) What were the electric x'ates for each participant in August 1973 for a residential user using 600 IU/hr/month?

{b) What is the present electric rate (August 1975) for each participant for a residential user using 600 KW hr/month?

(c) What rate increases are presently planned or formally requested bye each of the participants?

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