52
IpacaXe-.Gas-.b-Electric Company .Sf'xe Eeanciaco, .Gati~a'94106 -'; Frederick T, Sear1a~ OATS OF OOCUMEN+ + DATE RECEIVED ~ „NO : I48 71.-; - ~- -'- - -10-19='71 " LTR MEMO: REPORT; OTHER CLASS IFI POST OFFICE REG. NO: ORIG. &gg ACTION NECESSARY~Q NO ACTION NECESSARY Q FILE CO D El OTHER: CONCURRENCE COMMENT Q DATE ANSWERED: Q ov: -275 50-323 (ESXRO PZXR) DEscRIpTIDN: (Must Be Unclassified) REFERRED TO DATE RECEIVED OY DATE ltr .re Sec. 3, App 9 l0 CFR 50 re SHOP ChUSE....trans the fo1lomingz ENCLOSURES Statement, notarized 10-18-71 - ~@as tushy the Const Permits for Mab1o Canyon Units I & 2 should not be suspended in whole ox'art pending completion of SEPA review. Huller 10" 1 c s for ACTKO S BUTION ~Rog piles(ltr o ly 50 tr n 50-3 Compliance (2) 'DO NOT R qv MISlMKEIIN 323) aeYoung 3 nton Clare Biles, C-459 C o ter 201 Cg ', 170 GT., F-309 C {3 Orig notarized & 47 conf'd cys recsd) pelton 0 Blanc u hli EIAARicS. Holding (3) cys for ACES I-X.ocal PQR{San Luis Oblisco, Cal) 1- SAm Pm 1- ZA PDR Morris/Schroede /TEfi I ~ 0, Case J. Johnson, SXR son HSXC(Suc '8 Yore " ~s'4 Q " St fod U.S. ATOMIC ENERGY COMMISSION * U.5, GOVERNMENT PRINTING OFFICE:" IQFIM24W02 MAlLCONTROL FORM FDRM'AEGGkss,

IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

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Page 1: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

IpacaXe-.Gas-.b-Electric Company.Sf'xe Eeanciaco, .Gati~a'94106

-'; Frederick T, Sear1a~

OATS OF OOCUMEN+ + DATE RECEIVED ~ „NO:I48 71.-; - ~- —-'- - -10-19='71 "

LTR MEMO: REPORT; OTHER

CLASS IFI POST OFFICE

REG. NO:

ORIG.

&ggACTION NECESSARY~QNO ACTION NECESSARY Q

FILE CO DEl

OTHER:

CONCURRENCE

COMMENTQ DATE ANSWERED:

Q ov:

-275 50-323 (ESXRO PZXR)DEscRIpTIDN: (Must Be Unclassified) REFERRED TO DATE RECEIVED OY DATEltr .re Sec. 3, App 9 l0 CFR 50 re

SHOP ChUSE....trans the fo1lomingz

ENCLOSURES

Statement, notarized 10-18-71 - ~@as

tushy the Const Permits for Mab1oCanyon Units I & 2 should not besuspended in whole ox'art pendingcompletion of SEPA review.

Huller 10"1c s for ACTKO

S BUTION~Rog piles(ltr o ly 50

tr n 50-3Compliance (2)

'DO NOT R qvMISlMKEIIN323) aeYoung3 nton

Clare Biles, C-459 Co ter 201 Cg ',

170 GT.,F-309 C

{3 Orig notarized & 47 conf'd cys recsd) pelton 0 Blancu hli

EIAARicS.

Holding (3) cys for ACESI-X.ocal PQR{San Luis Oblisco, Cal)1- SAm Pm1- ZA PDR

Morris/Schroede /TEfi

I~ 0, CaseJ. Johnson, SXR

son HSXC(Suc'8 Yore "

~s'4 Q

" St

fodU.S. ATOMIC ENERGY COMMISSION

*U.5, GOVERNMENT PRINTING OFFICE:" IQFIM24W02MAlLCONTROL FORM FDRM'AEGGkss,

Page 2: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

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Page 3: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

PA.CIF IC GA.S A.ND ELECTRIC COMPS.NTlPW~~lE ~ 77 B EALE STREET ~ SAN F RANG I SCO, CALIFOR N IA 94 106 ~ (415) 781 ~ 4211

FREDERICK T. S EARLSVICE PRESIDE N'I AND OfNEIIALCOVNStL

JOHN C. MORRISSKYASSOCIATE OENEAAL COVNSfL

WILLIAMS. KVOSRWILLIAMe, JOHNS

MALCOLMH.IIVRBVSHcHARLes T,YAN oevseN

JOHN A.SPROVLMALCOI M A, MACKILLOP

PHILIP A. CRANe, JR.AISIITAATSTOICAL CDVAIIL

October 18, 1971

Regulate TY File Gy.

HOCC KELLYHEH1Y J LAPLANTCRIDNAAOA CLAIIKCOILS EIIT L HA111DKCOTIAADJ MSDANNCYJOHN S,COO@El ~

JOHN S Dl~ OONCLEAN WC ~ T JA

~ CHION OOVNSCL

AATHV*LHILLNAN,JA,CHA1LCS W THIOSELLRODENT CHLOAOHSANTOAO M SKAOO ~STANLEY T, SKIHHE1DAHICI,E DISOONJ, OAADLEYSVNNIHSC1NAAO J, DELIASAHTAJADK F FALLIH,JADONALDL FICITASJANET C LOOSDONJOSESH S CHOLCAT JA

ATTO 1 N CY~

U. S. Atomic Energy CommissionWashington, D. C. 20545

Attention:

Re:

Director, Division ofReactor Licensing

Dockets 50-275 50-323Units 1 and 2Diablo Canyon Site

4 rggfgp,DJ

ug~tr

p ~!y%, I<--JI

D

Gentlemen:

Enclosed for filing in accordance with para-graph E. 3. of Appendix D to 10 CFR 50 are 3 signed and47 conformed copies of a statement by Pacific Gas andElectric Company outlining the reasons why the construc-tion permits for the- two units at our Diablo Canyon siteshould not be suspended pending the environmental re-va.ew.

Kindly ac'knowledge receipt, of this material onthe enclosed copy of this letter and return it to me inthe enclosed addressed envelope.

Very truly yours,4W"

«LO'

PAC:TCEnclosures

Oi

DOCKETEOUSAEC

30CTlg1971 ~

REGUlATPRy tl'+IL SECnpnOOCKET QQK

0

Page 4: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

A

C

Page 5: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

BEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION

In the Matter'fPACIFIC GAS AND ELECTRIC COMPANY

(Diablo Canyon Units 1 and 2)

Regulatory File Cy.

Docket Nos. 50-2750=32 3

STATEMENT OFPACIFIC GAS AND ELECTRIC COMPANY

REQUIRED BYPARAGRAPH E. 3. OF 10 CFR 50, APPENDIX D

A. Introduction

This statement is submitted in connection with Paragraph

E. 3. of 10 CFR 50, Appendix D, and sets forth the reasons why,

with reference to the criteria in Paragraph E. 2. of 10 CFR 50,

Appendix D, the construction permits for Units 1 and 2 at PacificGas and Electric Company's Diablo Canyon site (the Units) should

not be suspen'ded, in whole or in part, pending completion of the

National Environmental Policy Act (NEPA) environmental review.

The design of the Units is substantially identical,and they incorporate pressurized water reactors manufactured by

the Westinghouse Electric Corporation. Together the Units have

a warranted net electrical 'output of 2,120 megawatts and ultimatelyare expected to have a net electrical output. of 2,287 megawatts.

The planned commercial operating dates are Spring 1974 and Spring

1975, respectively.The other major facilities at the site are two reactor

containment structures, a common auxiliary and fuel handling

Page 6: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

4

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Page 7: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

building, and a turbine-generator building housing the two

Westinghouse turbine-generators. Cooling water for the Units

will be pumped through 'a common intake structure from the Pacific

Ocean and circulated through the condensers. The water will then

be returned to the ocean via the discharge structure at Diablo

Cove.

On April 23, 1968 the Commission issued a construction

permit for Unit 1 at the Diablo Canyon site. The construction

permit for Unit 2 was issued by the Commission on December 9, 1970.

Copies of the permits are appended to the Environmental Report

covering the Units, which was filed with the Commission August 9,

1971, as Exhibits B and E, respectively.

B. Continued Construction Durin the Pros ective Review PeriodWill Not Give Rise to a Si nificant Adverse Effect on theEnvironment

Continued construction of the Units will not cause any

significant adverse effect on the environment'.. In fact, continued

construction will improve the Units'ffect, on the environment

because it will lead to completion of 'partially completed'truc-

tures resulting in a continually improving visual effect as the

architectural goal is achieved.

PGandE's Environmental Report for the Units includes a

detailed discussion of the environmental effects of plant construc-

tion. Construction activities that have disturbed topography,

vegetation, and wildlife are substantially complete. The siterestoration program consisting of reseeding disturbed areas with

Page 8: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

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Page 9: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

native vegetation and landscaping is already underway. Upon com-

pletion of the program the remaining impact of the Units on the

environment will be insignificant. With the exception of the

intake structure continued construction at the plant site willnot affect any new areas and, consequently, continued construction

will not adversely affect the site environment.

Below is a more detailed review of the different construc-

tion activities discussed in the report and the expected effect on

the environment of continued construction:

l. Access Road and Tem orar Facilities:The access road and temporary facilities are now in

place, and no future changes are anticipated. The

temporary facilities include laydown areas, storage

areas, concrete batch plant, warehouses, construction

offices and workcamps, and sanitary disposal facilities.These facilities and the access road were located and

constructed to blend in with the natural surroundings.

Because no further additions or modifications to these

facilities are expected there will be no continued

construction of these facilities to affect the environ-

ment.

2. Gradin Excavation and Fill 0 erations:Grading, excavation and filloperations for the Units

are essentially complete, and thus the maximum impact on

the environment of this work has already been realized.

Page 10: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

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Page 11: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

Continued construction of the Units will involve only

minor amounts of excavation, grading, and fillopera-

tions, which will have an insignificant effect on the

environment. ' major portion .of the earth-moving

operations was involved in the construction of the

230 kv and the 500 kv switchyards. These are now

complete. To help mitigate the environmental effectsof grading, excavation, and filloperations PGandE

has implemented an extensive site restoration program.

A main part of this program, which is fully described

in the Environmental Report., is the reseeding of cut

and fillslopes with native vegetation.

3. Breakwater Construction:

The breakwaters, which are designed to protect the

cooling water intake structure, are now nearly complete.

Construction of them has been carried out in a manner

to cause the least effect on the marine environment.

A photograph of the breakwaters showing status ofliconstruction as of October 4, 1971 is contained in

Figure 1 attached. The California Department. of Fish

and Game reviewed and approved the breakwaters and

construction methods employed in building them. Priorto construction about 13,000 abalone were removed from

the construction zone and transplanted to other areas.

As can be seen in Figure 1 continued construction will

Page 12: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)
Page 13: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

not add any substantial impact on the marine environment.

In fact, any delay now in the completion of the break-

waters will mean it will be that much longer before the

ocean can finish its natural restoration already underway

in the affected areas. In addition, if construction were

suspended now the normal, adverse winter weather wouldI

damage the unfinished portions of the west breakwater.

4. Circulatin Water S stem:

(a) Dischar e Structure:

The cofferdam and access road for the discharge

structure are complete, and the structure itself,which will serve both Units 1 and 2, is betterthan half finished. All excavation is done, and

much of the concrete has been placed. Furtherk

construction, therefore, will cause littleadditional effect on the environment. When the

structure is complete the cofferdam and access

road will be removed and the cove restored to

(b)

its original condition where possible.Inta'ke Structure:

Work on the inta'ke structure has begun and

the cofferdam is almost complete. (See Figure 1)

Completion of the intake structure will permitremoval of the cofferdam. This will allow marine

life to re-establish itself in the affected area.

In any event an intake structure of the type now'I,under construction will be required for any type

of cooling method using ocean waters.

Page 14: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

N

I

11

Page 15: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

5. Containment Structure Turbine-GeneratorBuildin and Auxiliar Buildin

Erection of the steel liners for the containment,

structure for Unit 1 is essentially complete and

concreting of the exterior is well underway. Overall,

the structure is about one-half finished. Excavation

for the Unit 2 containment structure is complete, and

the foundation is being installed. The turbine-generator building for Unit l.is about two-thirds

complete. Essentially all the major concrete work

and erection of structural steel is complete.

Foundation excavation for the Unit 2 turbine-generator\

is finished, and concrete is being poured. The

auxiliary building complex for the Units is about

two-thirds 'complete. The status of construction ofthese facilities as of October 4, 1971 is shown in

Figure 2 attached.

Suspension of construction of these facilitieswould appear to-be simply a wasteful act. As can

be seen from Figure 2 most of these structures areN

essentially in existence, and continued construction

will'ot adversely affect the environment. In fact,as stated previously, construction will improve the

visual aspect of the Units by leading to completion

of partially completed structures. Furthermore,

there are no viable alternatives to these structures,

Page 16: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

~ ~

Page 17: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

~ ~

short of removal from the site, 'which would not, be a

rational alternative.6. Transmission Lines:

The transmission outlets for the Units consist of

84 miles of two single circuit parallel 500 kv lines

to Midway Substation in Kern County (Midway Lines)

and one single circuit 500 kv line 79 miles long to

Gates Substation in Fresno County (Gates Line).

Practically all of the rights-of-way for these lines

have been acquired, mostly by voluntary purchase.

PGandE has cooperated with local, state, and federal

agencies, conservation groups, property owners, and

other interested groups concerning the .design, loca-

tion, and environmental impact of the lines. In two

eminent domain proceedings in which the'location ofa portion of the lines was in issue, the Court held

that the location selected by PGandE was compatible

with the, greatest public good and least private

injury.Construction of the first Midway circuit is well

underway:. the access'oads are over 90% complete;

over 80% of the tower foundations have been placed;

more than 60% of the towers have been erected; and

~ over 20/.-of the conductor has been strung. Less

than 60% of the right-of-way requires clearing and

7 ~

Page 18: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

1

Page 19: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

of this over 60% has been completed for the firstcircuit. Clearing is performed in accordance withall applicable regulations. Construction of the

Gates line is getting underway.

The location, proposed construction methods, andIdesign of the transmission lines were reviewed and

approved by the California Public Utilities Commission

(CPUC) after a total of 23 days of public hearings held

in connection with the granting of certificates ofpublic convenience and necessity for the plant and

transmission lines. Such certificates were granted

November 7, 1967 and March 25, 1969 for Units 1 and 2,respectively, and are appended to the Environmental

Report as Exhibits G and H. Twenty-five days ofpublic hearings were held by the CPUC early in 1971

to hear a complaint by several property owners andr

conservation groups concerning the location of a

portion of the Gates and Midway Lines. Over 3,000

pages of testimony were developed at these hearings,and PGandE's proposed construction methods, the loca-tion of the line, and the design of the towers were

considered exhaustively. During these hearingsformal motions made to enjoin or stop constructionwere denied by the CPUC. Alternate routes were alsoconsidered, and the matter is pending before the CPUC

Page 20: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)
Page 21: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

for decision.

In addition, the route of the lines was reviewed

by the planning commissions of San Luis Obispo, Fresno,

Monterey, Kern, and Kings Counties. Approvals were

also obtained from the U. S. Forest'ervice and the

Bureau of Land Management of the U. S. Department

of the Interior..In short, the environmental effects of the proposed

transmission lines have already been considered at

great length by the CPUC and other local, state, and

federal agencies so no useful purpose would be served

in again reviewing the matter, and construction of the

lines along the proposed routes should continue.

C. Continued Construction Durin the Pros ective Review PeriodWould Not Foreclose Subse ent Ado tion of Alternatives inFacilit Desi n of the T e That Could Result From the On-oin NEPA Review

The conservative design of the Units, the review it has

had before state and federal regulatory officials, and the changes

made as a result of the review lead to the conclusion that the

additional environmental review will indicate few, if'ny, changes

to be made to lessen the effect of the Units on the environment.

However, if the Commission directs that changes be made, PGandE

will ma)re them, as it is already bound to do under 10 CFR 50.109.

The design and construction of the Units have progressed

to the point where any change would require backfitting, even if

9

Page 22: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)
Page 23: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

imposed today. However, continued construction would not make

impossible a change which may be feasible today.

Two areas of greatest prominence in considering the

environmental impact of nuclear plants are the effects of thermal

and radiological discharges. The Environmental Report. includes a

comprehensive discussion of the expected environmental impact ofthese two items.

1. Thermal Effects:Units 1 and 2 will utilize a once through cooling

system. This system is being designed and constructedto meet present State of California Water QualityStandards which were approved by the State Water

Resources Control Board on October 13, 1971. These

standards are expected to be approved by the Environ-mental Protection Agency. If, subsequently, these

standards are changed so that the present coolingsystem does not meet applicable standards, the.facilities will be modified to meet the new require-ments.

PGandE has been investigating the effects of the

cooling water discharge from thermal electric generatingplant's on the aquatic ecology since 1951. Detailedenvironmental studies have been conducted at nine power

plants, and PGandE has operated a nuclear-fueled plantat Humboldt Bay since 1962. PGandE's experience, the

10

Page 24: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

H

Page 25: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

studies it has conducted, at the Diablo Canyon siteand the testimony developed during the public hearings

before the CPUC all indicate that the thermal discharge

from the Units will have only a minor effect on marine

ecology in a very limited area. It is anticipated thatin Diablo Cove, which has a surface area of about 40

acres, some of the cold water species of flora and

fauna will be replaced by warm water species. Thus,

there may be some reduction in species diversificationnear the discharge but no reduction in numbers. (De-

tailed information on the species present in the cove

is contained in the Environmental Report.) Therefore,

the thermal impact of the Units on the environment willbe negligible.

2. Radiation Effects:The Units will be equipped with an extensive radio-

active waste handling system. This system has been

designed to meet existing and proposed regulations on

radioactive emissions for normal operations as containedI

in Appendix I to 10 CFR 50. The liquid and .gaseous

portions of the waste system incorporate the closed

loop recycle concept in their design. The, syst: em isdesigned to reduce radioactivity levels in the carrierfluids either by decay or processing into solid waste

and then to return the fluids to the primary system,

11

Page 26: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

0

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Page 27: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

thereby virtually eliminating radioactive releases to

the environment. Solid waste will be packaged in a

manner that essentially eliminates the possibilitythat radioactivity will ever enter the environment

either during packaging or during eventual off-siteshipment and disposal. A more complete description

of the waste handling system can be found in the

Preliminary Safety Analysis Report or the Environ-

mental Report.

Although the existing system is believed to in-corporate the best features currently available for

the management of radioactive waste, present design

and continued construction of the Units do not

eliminate the possibility of including reasonable

alternatives should current, regulations on thissubject be changed. Therefore, decisions on the

possible need for future modifications of thissystem can be deferred while construction continues.

In addition to considering the probable environ-

mental impact of normal operations, the possible

impact of abnormal or accident conditions has been

thoroughly analyzed and is discussed at length in

the Preliminary Safety Analysis Report. Here again

PGandE's design conforms to applicable criteria and

regulations, but changes can be made if required.,

Page 28: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

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Page 29: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

3. Other:

The environmental effects of other plant discharges,

such as chemical and sanitary, are anticipated to be

so negligible that, it is doubtful alternative means of

handling them would be required. However, again, no

reasonable alternative would be foreclosed by continued

construction.

D. Dela of the Diablo Can on Units Will Have an AdverseEffect U on the Public Interest

A delay in the proposed operating dates for the Units

would have an adverse effect on the over 8,000,000 p'eople in

PGandE's service area and on the public served by other utilities,both publicly-owned and investor-owned, with which PGandE is

interconnected.

l. Power Needs:

Between now and 1975 planned additions of resources

to the integrated area system in northern and central

California include the following:

a. Several geothermal units totaling 530 Mw (PGandE);

b. A 735 Mw gas-and-oil-fired unit (PGandE);

c. Sacramento Municipal UtilityDistrict's (SMUD)

Rancho Seco nuclear unit (approximately 900 Mw);

and

d. PGandE's nuclear Units 1 and 2 at Diablo Canyon,

each 1060 Mw.

13

Page 30: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

~'

Page 31: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

The Rancho Seco unit is scheduled for operation in

May 1973 while, as stated previously, the Diablo Canyon

Units are planned for commercial operation in the Spring

of 1974 and the Spring of 1975.

In addition to power from the new units shown above

continued reliance will be placed upon power imported

to the area system over the intertie from the PacificNorthwest for part of the resources required to serve

the public. In 1974, this will be in excess of 800 Hw.

For the years 1975 and 1976, imported power will be over

5'00 Nw.

Table 1 attached shows for the years 1974, 1975, and

1976 estimated loads, resources, and reserve capacity

for the two months of the year with the. highest peak

loads, August and December, and for the average of the

twelve months during the year. These reserve capacitylevels are considered necessary and required by prudent

planning to provide adequate margins for reliable ser-

vice to the public during the early years of operation

of the three nuclear units planned for initial operation

during this period.As pointed out, in the Federal Power Commission's

1970 National Power Survey, Part III:In planning generation, it is realized

that first-of-a-kind units will continue torequire: more test time prior to commercialoperation and substantially more lead time

Page 32: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

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Page 33: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

because of lengthy licensing process andunpredictable construction delays. Shake-down of the more complex generating unitsrequires temporarily increased amounts ofreserve capacity until a mature, more re-liable performance status is achieved(p. III — 3-10)

Table 2 attached indicates the serious reduction in

reliability if both the Units are delayed. 'able 2

shows that without the Units PGandE's reserve capacity

margins would be substantially reduced. Moreover, the

reserve capacity shown assumes that all other planned

additions to area resources will be completed on

schedule and that imports of firm capacity will not

be jeopardized by delays of resource'dditions inother interconnected areas. Recent experience in the

PGandE area, li'ke that, elsewhere, has demonstrated the

extreme difficulty in bringing new units on line when

scheduled. Therefore, the margins are probably opti-mistic.

Table' attached shows C'he margins in 1974 and '197S

if both Rancho Seco and the Diablo Canyon Units are

delayed. With these low levels of reserve capacity,

the ability to render reliable electric service would

be seriously impaired with resulting adverse effectson persons within and adjacent to PGandE's service

area.

2. Interconnections:

PGandE is interconnected with utilities in the

Page 34: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

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Page 35: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

Pacific Northwest and in Southern California through

the Pacific Northwest-Southwest Intertie. In 1961,

PGandE entered into an agreement known as the California

Power Pool Agreement, (FPC Rate Schedule No. 27) with

Southern California Edison Company and San Diego Gas

6 Electric Company. One of the purposes of the

Agreement was to furnish more dependable, economic,

and efficient service to the public by providing for

the purchase, sale, and exchange of electrical capacity

and energy among the participating systems.

PGandE is a member of the Western Systems Coordinating

Council which consists of 40 investor-owned, publicly-

owned, and cooperatively-owned electric utilitiesengaged in bulk power generation or transmission in

the 13 western states and western Canada. Its purpose

is to increase reliability of service to the public

by coordinating electric planning and operations.

Any reduction in PGandE's resources would in turn

adversely affect the reliability of these other

utilities along the West Coast, which have several

times in the past few years found it, necessary to

call upon PGandE for substantial amounts of power to

supply their customers. These deliveries were possible

because of PGandE's long-term policy of maintaining

adequate reserves.

Page 36: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

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Page 37: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

3. Alternative Sources of Power:

If, the Units are delayed the only alternative

resource that might be added in time to bring the

reserve margins to an adequate level is gas turbine

capacity. No other sources of generation would be

available. If gas turbines are a feasible alter-native, it would be necessary to have such capacity

available by the end of 1974 at the latest. The

amount of such capacity that would be required

would depend on the extent of delay of the Units,

considerations of loads and resources of inter-connected utilities, and available sites for locating

gas turbines. Because of the number of un'knowns itis impossible to give a reliable estimate of the

extra costs that, would be incurred by PGandE, and

ultimately its customers, in installing this capa-

city, but they would be sizeable.

Additional costs resulting from delays willultimately be borne by the public.

If the Units were delayed by only six months,

PGandE estimates that such a delay would increase

the cost of constructing the Units by at least

$ 16,000,000. Any additional delay would, of course,

increase this cost. Other elements to be considered

17

Page 38: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

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Page 39: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

in assessing costs of delay include the necessary

start-up time, re-establishment of a smoothly co-

ordinated engineering team and contractor force,

and the possible economic effects on the local area

due .to lay-offs of construction wor'kers;

A major impact of a delay in construction of the

Units would be the increase in the amount of naturalgas and low-sulphur oil to be burned in fossil-fueledpower plants to replace the generation planned to be

available from the Units. Since the supply of both

of these fuels is limited it is not known how much

of the replacement generation would be furnished by

each. However, assuming that the lost nuclear energy

is replaced by generation supplied by the burning oflow-sulphur oil, the additional amounts of oil re-quired would be 6.8 million barrels in 1974, 17.5

million barrels in 1975, and 21.4 million barrelsin 1976. At current price levels of low-sulphur oilthe estimated additional cost of energy would be

$23,700,000, $61,100,000, and $ 74,800,000 in 1974,

1975, and 1976, respectively. These avoidable

additional costs to the public as well as the

increased consumption of fossil fuels would not

be in the public interest.

18

Page 40: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

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Page 41: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

E. Conclusion

In summary, PGandE submits that it is not necessary to

suspend in whole or in part either of the construction permits

for the Units to permit the AEC to conduct the environmental

review required under NEPA for the following reasons:

1. Continued construction of the Units will not give

rise to a significant adverse impact on the environment because

owing to the progress of the work to date the maximum impact ofconstruction has already occurred. Further work, which consists

of completing partially completed structures, will enhance the

appearance of the site.

2. Suspending the construction permits would prolong

the environmental impact, of construction by prolonging construc-

tion itself and by delaying the restoration of the native flora.

3. The design and construction of all plant systems

are so far along that even changes decided upon today would re-quire backfitting. Continuation of construction will not, ma'ke

impossible a change that might be feasible today.

4. The electric energy to be supplied by the Units isrequired in the years indicated to permit, PGandE to maintain

19

Page 42: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

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Page 43: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

adequate reserves for the protection of the public's need forreliable electric service not only within northern and central

California but also within the service territories of adjacent,

interconnected utilities.

5. Based upon the evidence adduced at administrative

proceedings held to date, the work of PGandE's independent con-

sultants and itsin designing and

own staff, and the objectives PGandE has followed

constructing the Units, it is unlikely that, the

NEPA review will indicate the need for any changes in the Units.

Xt thus would be pointless to suspend construction,to take stillmore evidence.

6. The additional costs which would have to be borne

by the public as a result of a suspension would be tremendous

and completely unnecessary as there would be no offsettingbeneficial effects on the environment.

7. Suspension of work would require the laying offof several hundred construction workers, would require a nearlycomplete rebuilding of the present well-functioning constructionorganization, and would have an adverse effect on the localeconomy, which has benefited from the project.

8. The additional consumption of fossil fuels

20

Page 44: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

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Page 45: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

required to replace the Units would not be in the public interest.

Subscribed in San Francisco, California, this 18th day

of October, 1971.

Respectfully submitted,

PACIFIC GAS AND ELECTRIC COMPANY

ByJ. Dean Wor ington

Senior Vice President

FREDERICK T. SEARLSJOHN C. MORRISSEYPHILIP AD CRANE, JR.

Philip . Crane, Jr'.

Subscribed and sworn to before methis 18th day of October, =-1971,.

Theodora Cooke, Notary Public inand for the City and County ofSan Francisco, State of California:a

J

My Commission expires January 28, 1973.

Page 46: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

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Page 47: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

TABLE 1ESTIMATED LOADS AND RESOURCES~

WITH DIABLO CANYON UNITS

MEGAWATTS

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,tt

2

1974 '1975 1976.Avg e

~Au . " Dec. ~Monthl A~u

Avge

Dec. ~nonthl ~Au .

Estimated Load 12662 12329 11650 13496 13149 12412 14371

Resources:

Imports from Pacific Northwest 805 805 805 550

Planned Additions:

550 624- 543

Existing in Area '(As of 9/71) 12463 12308 12401 12463 12308 12401 12463

Avg.Dec. ~Monthl

14009 13217t

12308 12401

543 543

Unit 1 —Diablo CanyonUnit ? —Diablo Canyon

. Other

1060 1060 61& / 1060 . 1060'060 1060 1060 10601060 '; 1060 618& 1060 1060 1060

1795 1827 1766 1890.~ 1932. 1859 2097 2234 2051

Total Additions 2855 2887 2384 4010 4052 3537 4217 4354 4171

Total - Existing and Planned

Planned Maintenance Outage

Net Reserve Capacity

0 of Estimated Load

16123 16000 15590 17023 16910 16562 17223 17205 17115

181 359 1016 46 239 1024 0 124 1074

3280 3312 2925 3481 3522 3127 2852 3072 2825

25. 9 26. 9 25. 1 25.8 26.8 25. 2 19.8 21.'9 21.4

P

TABLE 2ESTIMATED RESODRDES AMD RESERVES

WITHOUT DIABLO CANYON UNITS

Resources

Planned Maintenance Outage

Net Reserve .Capacity

% of Estimated Load

15063 14940 14972 14903 14790 14884 15103 15085 14995

0 159 1016' 0 936 0 0 895

2401 2452 2306 1407 1641 1536 732 1076 883

'19.0 19.9 19.8 10.4 12.5 12.4 5.1 7.7 6.7

TABLE 3'STIMATEDRESERVES WITHOUT DIABLO CANYON UNITS

AND RANCHO SECO UNIT 1

Net Reserve Capacity

0 of Estimated Load

1571 1670 1546 577 811 776

12.4 13.5 13.3 4.3 6.2 6.3

Canpany' latest estimate~2 Imports for first three months higher than rmainder of year

Not in for full year

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Page 48: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

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Page 49: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

FlGURE 2

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Units 1 and 2 area looking west. Concrete andreinforcing bars placed in the Unit 2 containmentstructure foundation are at the left. Unit 2turbine-generator foundations and the initialreinforcing bars for the turbine pedestal arein place. Unit, 1 area shows the containmentstructural steel liner with concrete partiallyplaced and the containment equipment accessopen. Structural steel erection for the Unit 1turbine-generator building is essentially com-pleted and work is progressing on the auxiliaryand fuel handling building in the center.(October 4, 1971)

Page 50: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

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Page 51: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

FIGURE 1

Intake cove looking west. The intake cofferdamis in the center. The east breakwater (on theleft) is now complete including all tribarplacement and the concrete protection cap. Thewest breakwater is now nearing completion withonly the final installation of the tribars andthe forming and pouring of the concrete capremaining to be done. (October 4, 1971)

Page 52: IpacaXe-.Gas-.b-Electric .Gati~a'94106 ~- FrederickBEFORE THE UNITED STATES ATOMIC ENERGY COMMISSION In the Matter'f PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Units 1 and 2)

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