ML20071H054
| ML20071H054 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 05/18/1983 |
| From: | Bischoff C, Gehr A, Platt W SNELL & WILMER |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8305240482 | |
| Download: ML20071H054 (61) | |
Text
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1 UNITED STATES OF/ RP 2 NUCLEAR REGULATORYi COMMI5 ~
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4 BEFORE THE ATOMIC SAFETY AND $ ' S1)IF 0 5
6 In the Matter of )
6 ) Docket Nos. STN 50-529 ARIZONA PUBLIC SERVICE ) STN 50-530 7 COMPANY, et al. )
)
8 (Palo Verde Nuclear )
Generating Station, )
9 Units 2 and 3 ) )
)
10 11 JOINT APPLICANTS' RESPONSE TO WEST VALLEY'S SECOND SET OF INTERROGATORIES 12 13 GENERAL OBJECTIONS 14 l. Joint Applicants object to Petitioner's In-15 struction No. 19 to the extent it purports to alter the ap-16 plicable rules and regulations relating to the duty of a 17 party to supplement its responses. See 10 CFR $2.740(e).
18 2. Joint Applicants object to Interrogatories 2, 19 3, 4, 7 and 9 on the grounds that, as phrased, they would 20 require identification of documents and correspondence sub-21 ject to the attorney work product privilege and/or the at-l 22 torney client privilege. Joint Applicants are in the pro-23 cess of identifying the documents described in the above-l 24 referenced interrogatories and to the extent not pr.ivileged 25 will identify such documents when review is completed. Due 26 to the number of entities involved and the number of docu-I 8305240482 830518 i
PDR G ADOCK 050002]
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L l 1 ments to be reviewed, Joint Applicants were unable to com-2 plete such review prior to the date required for the sub-3 mission of these responses.
4 INTERROGATORIES 5 INTERROGATORY NO. 1. Identify all oral communications con-6 cerning any delays in the projected date for fuel loading 7 Unit 2 which occurred:
8 a. before filing of the Petition; 9 b. subsequent to filing of the Petition.
10 ANSWER 11 1. Joint Applicants object to Interrogatory No.
12 1 on the grounds that it would be burdensome and oppressive, 13 if even possible, to identify all oral comnunications con-14 carning any delays, or possible delays, in the projected 15 fuel loading date for Unit 2. Further, such information is 16 irrelevant to the subject matter of this proceeding and to 17 the contentions set forth in the parties' Stipulation of l
18 March 30, 1983, and is not likely to lead to the discovery l
19 of admissible evidence. The fuel loading date has not been 20 delayed beyond the August, 1984 date previously established, 21 but there obviously are continuous discussions concerning 22 the scheduling of work and materials and the completion of 23 the Unit 2 construction in a timely manner to meet the 24 August, 1984 date. It would be virtually impossible to 25 isolate and identify such communications as requested in 26 this interrogatory.
b 1 INTERROGATORY NO. 2. Identify all documents, including but 2
not limited to all reports and correspondence, relating or 3 referring to cooling tower salt emissions, prepared:
4 a. between completion of the EIS-OS and 5 filing of the Petition (but not including Marley Telecon 6 Memo, dated September 29, 1982, listed in response to Peti-7 tioner's First Set of Interrogatories, No. 3(b));
8 b. subsequent to filing of the Petition, 9 ANSWER 10 2.a. None, other than as identified in re-11 sponse to Petitioner's First Set of Interrogatories.
12 b. Object. See General Objection No. 2.
13 14 INTERROGATORY NO. 3. Identify all documents, including but 15 not limited to all reports and correspondence, relating or 16 referring to spray pond salt emissions, prepared:
17 a. between completion of the EIS-OS and 1
18 filing of the Petition; 19 b. subsequent to filing of the Petition.
20 ANSWER 21 3.a. None.
22 b. Object. See General Objection No. 2.
23 t
24 INTERROGATORY NO. 4. Identify all documents, including but 25 not limited to all reports and correspondence, relating or 26 referring to evaporation ponds salt emissions, prepared:
l t
s 1 a. between completion of the EIS-OS and 2 filing of the Petition; 3 b. subsequent to filing of the Petition.
4 ANSWER 5 4.a. None.
6 b. Object. See General objection No. 2.
7 8 INTERROGATORY NO. 5. The Answer to Petitioner's First Set of 9 Interrogatories, No. 9(a), states that 1971 data from Re-10 search Cottrell, Inc. were the basis for the salt drift 11 droplet size distribution analysis in the ER.
12 a. Identify the documents which present 13 those data; 14 b. State the reasons for choosing Research i
15 Cottrell's 1971 size distribution rather than Marley's size 16 distribution.
17 ANSWER 18 5.a. The document presenting the data ob-l 19 tained from Research-Cottrell is the " FOG Model Descrip-20 tion," July, 1974, by George Fisher.
t 21 b. Research-Cottrell's size distribution 22 was chosen because at that time a cooling tower vendor had 23 not been selected.
24 25 INTERROGATORY NO. 6. The Answer to Petitioner's First Set of 26 Interrogatories, No. 11, states that the rate of blowdown to
$s__
6 1
the evaporation ponds exceeds the evaporation rate from the 2 ponds.
3 a. Identify the documents which support that 4 conclusion; 5 b. State any other basis for reaching that 6 conclusion.
7 ANSWER 8 6.a. Bechtel Proprietary Study No. 13-CS-204; 9 Custodian: Bechtel. The ER-OL and the FSAR also describe 10 the flow rate to the evaporation ponds.
11 b. The basis for the conclusion stated in 12 answer to Petitioner's Interrogatory No. 11 (First Set) is 13 that the annual blowdown rate exceeds the annual evaporation 14 rate.
15 16 INTERROGATORY NO. 7. Identify all documents, including but 17 not limited to reports and correspondence, relating or re-18 ferring to salt drift deposition patterns, prepared:
19 a. between completion of the EIS-OS and the 20 filing of the Petition; 21 b. subsequent to filing of the Petition.
22 ANSWER 23 7.a. None 24 b. Object. See General Objection No. 2.
25 26 . . . . .
k
9 6
1 INTERROGATORY NO. 8. NUS used its proprietary model, " FOG,"
2 to describe salt drift deposition patterns.
3 a. State when the " FOG" model was first 4 used; 5 b. Identify all documents concerning appli-6 cation of the " FOG" model to power plants other than PVNGS.
7 ANSWER 8 8.a. " FOG" represents a computer model, the 9 development and use of which has extended over several 10 years. The initial version of the model was first utilized 11 in 1972.
12 b. NUS has employed different versions of 13 the FOG model at several fossil and nuclear plants, some of 14 which ht.ve not been built. Joint Applicants object to this 15 interrogatory on the grounds that the identificatien of 16 these proprietary documents sought by this interrogatory 17 would be oppressive and unduly burdensome and expensive. In 18 addition, the information sought by this interrogatory is 19 irrelevant to the subject matter of the instant proceeding 20 and to the contentions set forth in the parties' Stipulation 21 of March 30, 1983.
22 23 INTERROGATORY NO. 9. Identify all documents, including but 24 not limited to reports and correspondence, relating or re-25 ferring to effects on crops, prepared:
26 . . . . .
L
L 1 a, between completion of the EIS-OS and 2 filing of the Petition; 3 b. subsequent to filing of the Petition.
4 ANSWER 5 9.a. None.
6 b. Object. See General Objection No. 2.
7 8 INTERROGATORY NO. 10. The Answer to Petitioner's First Set 9 of Interrogatories, No. 29, states that six samplers for 10 radiological monitoring have collected salt data since Oc-11 tober, 1982. Identify all documents which present or ana-12 lyze those salt data.
13 ANSWER 14 10. " Report of Analysis," dated 2/22/83, 3/8/83, 15 and 5/5/83, from CEP (Controls for Environmental Pollution) 16 Present the data obtained from the samplers described in 17 answer to Petitioner's Interrogatory No. 29 (First Set).
18 19 IifTERROGATORY NO. 11. The Answer to Petitioner's First Set j 20 of Interrogatories, No. 30, describes monitoring devices 21 which are being used or planned to be used. Identify:
22 a. all documents that relate to the accur-23 acy and reliability of each device; 24 - - - - -
25 - - - - -
26 - - - - -
A
1 b. all documents (other than those identi-2 fied in response to the preceding interrogatory) that pre-3 sent or analyze salt data collected to date; 4 c. state when and in what form monitoring 5 data will be reported hereafter from each type of device.
6 ANSWER 7 ll.a.l. Dustfall Samplers: American Society of F Testing and Materials (ASTM) Standard Method for Collection 9 and Analysis of Dustfall (Settleable Particulates) D1739-70, 10 Annual Book of ASTM Standards, Part 26, Philadelphia, PA.
11 2. Low-Volume Samplers:
12 (a) " Instruction Manual, Schmidt Model 13 2-AXP-0, Constant Flow Air Sampler (Preliminary Copy),"
14 Schmidt Instrument Co., P.O. Box 111, San Carlos, California 15 94070.
16 (b) " Air Sample Collection (Environ-17 mental), PVNGS, Station Manual Procedure No. 75RP-9ZZl9, 18 Rev.0," DRAFT.
19 (c) Letter from Schmidt Instrument Co.
20 to APS, dated March 29, 1983, regarding calibration of 21 Fischer and Porter Flowrators supplied on Order No. 10011798, 22 Dec. 24, 1982.
23 (d) Letter from Schmidt Instrument Co.
24 to APS, dated July 29, 1982, regarding accuracy of Schmidt 25 Model A-60 Precision Fortable Flowmeter with 2.5 scfm Float.
26 . . . . .
L
1 (e) Field log books for the air sampler 2
collection filter.
3 (f) Maintenance and calibration sched-4 ule for environmental air samplers.
5 (g) CEP Proposal No. CEP-83-03035 6
" Proposal to NUS, Corp. for laboratory services associated 7
with salt deposition and impact monitoring plan for PVNGS, 8 Units 1, 2 & 3,"
9 (h) Results of laboratory analysis 10
(" Reports of Analysis" identified in answer to Interrogatory 11 No. 10, above.)
12 3. Camera / Film: NUREG/CR-1231, " Remote 13 Sensing for Detection and Monitoring of Salt Stress on Vege-14 tation: Evaluation and Guidelines," Final Report, Sept.
15 1976 - March 1979, Published March, 1980. Prepared by In-16 tera Environmental Consultants, Inc. for U.S. Nuclear Reg-17 ulatory Commission.
18 b. The only documents currently available 19 are those identified in answer to Interrogatory No. 10 20 above.
21 .
- c. Information concerning the reporting of 22 l sampling data is contained in the Salt Deposition and Impact 23 Monitoring Plan for PVNGS, Units 1, 2&3, February, 1983.
24 25 INTERROGATORY NO. 12. The Answer to Petitioner's First Set 26 of Interrogatories, No. 42, identifies 12 month cooling s , )
l 1 tower operation as an off design condition considered before 2 completion of the EIS-OS.
3 a. State whether any additional off design 4 conditions were considered; 5 b. Describe any such conditions and their 6 influence upon evaluation undertaken in the ER; 7 c. State whether any off design conditions 8 have been considered since completion of the EIS-OS and 9 filing of the Petition; 10 d. State whether any off design conditions 11 have been considered subsequent to filing of the Petition; 12 c. Describe any off design conditions iden-13 tified in response to c. and d. above and your plans to take 14 them into account in operating PVNGS; 15 f. Identify all documents that describe or 16 analyze any off design conditions identified in response to 17 this interrogatory.
18 ANSWER 19 12.a,b. Joint Applicant's answer to Peti-f 20 tioner's Interrogatory No. 42 (First Set) also identified i
21 the off design operating condition of the assumption that 22 the circulating water chemistry concentrations would exceed 23 those expected at 15 cycles of concentration. That assump-24 tion led to the over-estimation of the salinity of the salt 25 drift from the cooling towers.
26 c. None, other than those previously identified.
l l L
6 1 d. None, other than those previously iden-2 tified.
3 e. N/A.
4[ f. ER-CP; ER-OL.
5 INTERROGATORY NO.13. Identify the documents that serve as 6 as a basis for the figures contained in the ER and EIS con-7 cerning the salinity of effluent to be used for cooling at 8 PVNGS.
9 ANSWER l0' 13. Joint Applicants' Exhibit BB, Water Reclama-11 tion Studies, PVNGS, Units 1, 2 and 3, by Bechtel Power 12 Corp.
13 14 INTERROGATORY NO. 14. The Answer to Petitioner's First Set 15 of Interrogatories, No. 48, identifies documents relating or 16 referring to PVNGS cooling tower drift elimination.
17 a. State whether this answer includes docu-18 ments relating to both the structure and the operation of 19 the drift eliminators; 20 b. If the Answer fails to include the l
21 former, identify all such documents.
22 ANSWER 23 l 14.a,b. The answer to Petitioner's Inter-24 rogatory No. 48 (First Set), includes documents relating to 25 both structure and operation of the drift eliminators. In 26 addition, the Marley Cooling Tower Company's Operation and l
l W ._. _____
i 1 Maintenance Instructions Manual identified in answer to 2 Petitioner's Interrogatory No. 47 (First Set), relates to 3 the operation and structure of the eliminators.
4 5 INTERROGATORY NO. 15. State whether the cooling tower 6 vendor:
7 a. makes or has made cooling towers of the P. type being installed at PVNGS incorporating a system that 9 removes more drift than the system chosen for PVNGS; and l
10 b. can make such a system.
l.: ANSWER 12 15.a. Marley does not make a cooling tower of 13 the type installed at PVNGS which incorporates a drift f
14 elimination system that removes more drift than the system 15 being utilized at PVNGS.
16 b. Marley continuously investigates and 17 researches drift elimination system designs which may prove 18 to be more effective than the system installed at PVNGS. At 19 the present time, however, Marley does not have a system 20 which has proven capable of removing more drift than the 21 system utilized at PVNGS.
22 23 INTERROGATORY NO. 16. If your answer to the preceding in-24 terrogatory is yes, describe:
25 a. the drift elimination systems; 1
26 b. the places of their use; and l
l L
s 1 c. state the basis for choosing the drift 2 elimination system us'ed in the PVNGS cooling towers.
3 ANSWER 4 16.a.-c. Not Applicable.
5 INTERROGATORY NO. 17. Identify which of the documents iden-6 tified in response to Petitioner's First Set of Interroga-7 tories, No. 50, specifically address alternatives to the 8 cooling tower drift elimination system chosen for PVNGS.
9 ANSWER 10 17. Letter, Wilson to Van Brunt, December 19, 11 >
1975, (Proprietary). Custodian: APS.
12 13 INTERROGATORY NO. 18. For each individual identified in 14 response to Petitioner's First Set of Interrogatories now or 15 previously affiliated or involved with:
16 a. NUS:
17 b. Bechtel; 18 c. Marley; 19 d. APS; 20 e. University of Arizona Crop Study state:
21 state:
22 a. a summary of his formal education; 23 b. the name and address of each school 24 where he received any special education or training relevant 25 to the subject matter of the interrogatory in response to 26 . . . . .
1 which his name was identified and a description of the 2 training; 3 c. the name or description of each degree 4 he has received, including the date each was received, and 5 the name of the school from which he received such degree; 6 d. the books, papers, and articles which he 7 has authored; 8 e. his employment over the past ten years, 9 including employer, dates, and duties.
10 18. NUS:
11 1. George E. Fisher l
l l 12 a.-c. New York University, 13 M.S., Meteorology, 1968; Florida State University, B.S.,
14 Meteorology, 1963.
i 15 d.(1) " Changes in Levels of 16 Atmospheric Oxygen and Carbon Dioxide Proi;ced by Burning 17 Fossil Fuels and by Changes in Land Usage," 68th Meeting of 18 the Air Pollution Control Association, Boston, Massachusetts, 19 June, 1975.
l 20 (2) " Statistical Prediction 21 of Eventual Trac'ts of Hurricanes," M.S. thesis, New York Un-I 22 iversity, New York, 1968.
23 e.(1) NUS Corporation, 1973 -
24 82; Manager of Air Quality Assessments Department.
25 (2) GEOMET, Inc., 1971-1973; 26 Research Scientist.
( L
4 1
(3) The Center for the En-2 vironment and Man, Inc., 1965-71; Work in development and 3
application of numerical prediction model for planetary 4
boundary layer and low level cloud prediction techniques.
5 (4) The National Hurricane 6
Research Laboratory, 1963-65; Collect and analyze meteoro-7 logical data.
8 2. Morton I. Goldman 9 a.-c. Massachusetts Institute 10 of Technology, Sc.D., 1960; Massachusetts Institute of Tech-11 nology, M.S., Nuclear Engineering, 1958; Massachusetts In-12 stitute of Technology, M.S., Sanitary Engineering, 1950; New 13 York University, B.S., Civil Engineering, 1948.
14 d. See attached.
15 e.(1) NUS Corporation, 1961 -
16 Present; Technical Director.
17 (2)(a) U.S. Public Health 18 Service; Division of Radiological Health, 1950-1961; Tech-19 nical consultation and assistance to federal government.
20 (b) Nuclear Installa-21 tions Consultant, 1959-1961; Technical consultations and as-22 sistance.
23 (c) MIT Nuclear Engi-24 neering Department, 1956-1959; Reactor Safeguards Committee, 25 Secretary and Radioactive Waste Disposal Project, Project 26 Leader.
w.
1 (d) ORNL Waste Disposal 2
Research Activity 1954-1956; Soils and Engineering Section, 3 Chief.
4 (e) Sanitary Engineering 5
Center, 1950-54; Radiological Health Training Section.
6 (3) MIT Sanitary Engineering 7
Department, 1949-1950; Radioactivity Research Laboratory, 8 Research Assistant.
9 (4) New York University, 10 Sanitary Engineering 1948-1949; Research Laboratory, Re-11 search and Teaching Assistant, 12 3. Marilyn K. Bland 13 a.-c. Principia College, 14 Elsah, Illinois, B.A., Biology and Education, 1966; Univer-15 sity of Colorado, Institute of Arctic and Alpine Studies, 16 Boulder, Colorado, 1966 (Summer); University of Michigan, 17 Ann Arbor, Michigan, M.S., Botany, 1968; University of Costa 18 Rica, Organization of Tropical Studies, San Jose, Costa 19 Rica, 1968 (Summer); University of Michigan, Ann Arbor, 20 Michigan, Ph.D., Botany, 1972.
21 d.(1) Bland, M. D. and P. D.
22 Kilburn, 1966, " Bluff prairie vegetation and soil texture."
23 Trans. Ill. State Acad. Sci. 59: 25-28.
24 (2) Bland, M. K. 1970, 25 " Prairie establishment at the Michigan Botanical Gardens."
26 . . . . .
m
P 1 Proc. Symp. on Prairie and Prairie Restoration. Knox Col-2 lege, Galesburg, Ill. pp. 46-47.
3 (3) Bland, M.K. 1972. "Elsah 4 Bluff prairies: ecolo.gical antiques." Historic Elsah Foun-5 dation Leaflet No. 3, 11 pp.
6 e.(1) NUS Corporation, 1972-78; 7 Biologist.
8 .
(2) Principia College, 1971-9 1975; (position / duties presently unknoun; will supplement) .
10 (3) Matthaei Botanical 11 Gardens, 1968-1971; (position / duties presently unknown; will 12 supplement).
13 (4) University of Michigan, 14 1966-1971; (position / duties presently unknown; will supple-15 ment).
16 4. Ronald R. Stoner 17 a.-c. Pennsylvania State Uni-18 versity, B.S., Meteorology, 1966; Air Pollution Control Ad-19 ministration Training, U.S. Public Health Service Fellowship 20 Course, Pennsylvania State University, 1965; Ohio State Uni-21 versity, undergraduate courses in science, 1962-1964.
i 22 d.(1) " Tropical Oil Soill 23 Contingency Planning: Requirements and Applications," Con-l 24 ference on Petroleum and the Marine Environment, EUROCEAN, l 25 Monaco, 1980.
26 . . . . .
1 (2) "A Software Package for 2 Real Time Offsite Dose Calculations" (coauthor), Nuclear 3 Science Symposium of IEEE, October, 1978.
4 (3) "The Use of Field Wind 5 Measurements in Applying Atmospheric Diffusion Techniques" 6 (coauthor), APCA Paper No. 70-51, June, 1970.
7 (4) "A Flexible Fast Fourier 8 Transform Algorithm," ECOH-6046, Atmospheric Sciences Labor-9 atory, August, 1969.
10 (5) " Spectra of Atmospheric 11 Fluciu&tions Over a Frequency Range from 0.02083 to 30 12 Cycles / Hour" (coauthor), .itmospheric Sciences Laboratory, 13 June, 1969.
14 (6) " Procedures for Com-15 puting Variance Spectra" (coauthor), ECOM-6041, Atmospheric 16 Sciences Laboratory, April, 1969.
17 e.(1) NUS Corporation, 1969-18 Present; Principal Environmental Meteorologist.
19 (2) U.S. Army, Atmospheric 20 Sciences Laboratory, 1967-1969; Research.
21 (3) Pennsylvania Bureau of 22 Air Pollution Control, 1967; Analyzed local and regional 23 meteorological and air quality sampling data.
24 (4) U.S. Weather Bureau, 25 ESSA, 1965; Observation and evaluation of meteorological 26 data.
1 5. Thomas F. Iaccarino 2 a.-c. Rutgers -
The State 3 University, M.S., Meteorology, 1975; Rutgers - The State 4 University, B.S., Meteorology, 1973.
5 d.(1) " Final Site Selection 6 and Instrument Exposure Criteria Document," NUS-3571, NUS 7 Corporation, Rockville, MD., April, 1980.
8 (2) " Prevention of Signifi-9 cant Eeterioration Application for the Inctallation of a 10 26,000 BPSD Petroleum Refinery in Chesapeake, Virginia, 11 NUS-3193 NUS Corporation, Rockville, MD., July, 1978.
12 (3) " Prevention of Signifi-1 13 cant Deterioration Application for the Construction of a 14 184,000 DPSD Petroleum Refinery in Portsmouth, Virginia 15 NUS-3194, August, 1978.
16 (4) " Monthly Supplementary i
l 17 Control System Report for the Kincaid Generating Station,"
l l 18 Report No. 11, June, 1977, Environmental Research and Tech-19 nology, Inc., August, 1977.
20 (5) "An Investigation of 21 Sea and Lake Breezes," M.S. thesis, Rutgers - The State Uni-22 versity, 1975.
1 23 e.(1) NUS Corporation, 1978 -
24 Present; air quality analyst and environment meteorologist.
l 1
25 (2)
Environmental Research 26 and Technology, Inc., 1975-78; Senior Staff meteorologist.
I 1 (3) Rutgers -
The State 2 University, 1974-75; Graduate Assistant.
3 6. Philip M. Altomare 4 a.-c. University of Maryland, 5 B.S., in Physics, 1958; University of Maryland, M.S. in Nu-6 clear Engineering, 1967.
7 d.(1) "The Application of 8 Meteoro'ogy in Determining the Enviromenta.1 Effects of 9 Evaporative Heat Dissipation Systems," prescnted at the 64th 10 Annual Meeting of the Air Pollution Control Association, 11 June 27 - July 1, 1971.
12 (2) " Transport of Vapor and 13 Aerosols Through An Inhomogeneous Atmosphere," presented at 14 the American Meteorological Society's Fourth National Con-15 ference on Aerospace Meteorology, May 4-7, 1970.
16 i (3) "A computer Study of l 17 Nuclear Characteristics of the University of Maryland Reac-18 tor," M.S. thesis, University of Maryland, 1967.
t 19 (4) " Analysis of the KIWI-1 j 20 TNT Experiment," (coauthor), presented at the American Nu-i 21 clear Society meeting, June, 1965.
22 e.(1) NUS Corporation, 1963-23 1976; Manage data collection, reduction and model develop-24 ment concerned with atmospheric and thermal pollution pro-25 gram.
26 . . . . .
1 (2) Martin-Marietta Corpo-2 ration, Nuclear Division, 1959-1963; Reactor Engineer.
3 (3) United States Depart-4 ment of Interior, Bureau of Mines, 1956-1959; Physicist.
5
- 7. John H. Taylor 6
O a.-c. Florida State Univer-7 sity, M.S.,
Meteorology, 1957; Western Kentuckey University, 8 A.B.,
Mathematics, 1953; University of Chicago, Tropical 9
Meteorologi, 1951; University of California at Los Angeles, 10 Meteorology, 1948.
11 d.(1) " Meteorological Influ-12 ences on Air Pollution from Recket Propellents," Invited 13 paper presented at the 49th Annual Meeting of the Air Pol-14 lution Control Association, San Francisco, California, 1966.
15 (2) "The Ice Fog Problem at 16 Eielson Air Force Base, Alaska" (coauthor), AF Survey in 17 Geophysics, No. 176, AFCRL-66-230, Air Force Cambridge Re-18 search Laboratory, 1966.
19 (3) " Diffusion of Rocket 20 Exhaust," Invited paper presented at the Conference of 21 Atmospheric and Industrial Hygiene, National Academy of 22 Science, Washington, D.C., 1964.
23 (4) " Project Sand Storm:
24 An Experimental Program in Atmospheric Diffusion," Environ-25 mental Research Report No. 134, AFCRL-65-649, Air Force 26 Cambridge Research Laboratory, 1955.
i
- l l
i l
l 1 , ,
(5) "Some Aspects of Diffu-2 sion from Quasi-Instantaneous Sourcer." Presented at the 3
National Conference on Micrometeorology, American Meteor-4 ological Society, Salt Lake City, Utah, 1964.
5 (G) uThe Ocean Breeze and 6 Dry Gulch Diffusion Program" (coautnor), '
- l. II, Research 7 Report, AFCRL-63-791(II), Air Force Cami- ~.dge Research 8 Laboratory,-1963.
9
( "i ) "Results of Recent 10 Field Programs in Atmospheric Diffusion" (coauthor), Journa.1 11 of Meteorology, Vol. 2, No. 1, 1963.
12 (S) " Design and Development 13 of a Micrometeorological Data Observing and Processing Sys-14 tem for Air Pollution Applications at Cape Canaveral and 15 Vandenberg Air Force Base" (coauthor), presented at the 16 Fourth Conference on Applied Meteorology, American Meteor-17 ological Society, Hampton, Virginia, 1962.
t I 18 NUS e.(1) Corporation, 19 1973-81; Manager, Meteorological Programs Department.
20 (2) U.S. Air Force, 21 1943-1973; 22 (a) Research and Devel-23 opment Director, Headquarters, Air Force Systems Command, l 24 Andrews Air Force Base, Maryland, 1969-1973; Chief Systems 25 Inspection Division.
26 . . . . .
t 1 (b) Pilot, Commander of )
2 Operational Units, Viet Nam, Southeast Asia, 1967-1969.
3 (c) Diffusion Meteor-4 clogist, Air Force Cambridge Research Laboratory, Bedford, 5 Massachusetts, 1960-1967; Planned and conducted field ex-6 periment in atmospheric diffusion.
7 (d) Climatological Ana-8 lyst, Enviro.nment Technical Applications Center, Washington, 9 D.C., 1957-1960; Performed climatologiccl studies.
10 (e) Weather Officer 11 (Forecaster), 1948-1955; Provided aviation forecasts.
12 (f) USAF Pilot 1944-1973.
13 8. Henry Firstenberg 14 a.-c. Columbia University, 15 M.S., Engineering Sciences, 1963; Polytechnic Institute of 16 Brooklyn, B.Ch.E., Chemical Engineering, 1957; City Col-17 lege of New York, graduate courses in Nuclear Engineering, 18 1959.
19 d.(1) " Environmental Factors 20 in Siting LNG Facilities" (coauthor), Proceedings of the i 21 Fourth International Conference on Liquefied Natural Gas, l 22 Algiers, Algeria, June 24-27, 1976.
l 23 (2) " Burnout in Fog Flow:
24 A Droplet Diffusion Model" (coauthor), Journal of Heat 25 Transfer (Series C of Transactions ASME), May 1962.
2e . . . . .
l l
1
1 (3) " Boiling Songs and Asso-2 ciated Mechanical Vibrations, NDA 2131-12, June 30, 1960.
3 e.(1) NUS Corporation, 1963-4 1969, 1970-Present; Executive consultant to Environmental 5 Systems Group.
6 (2) Consultant, 1969-70 7 (3) United Nuclear Corpora-8 tion, Development Division (formerly NDA), 1957-1963; Ana-9 lytical engineer.
10 9. Michael Septoff 11 a.-c. New York University, 12 M.S., Meteorology, 1968; City College of New York, B.S.,
13 Meteorology and Oceanography, 1966; University of Maryland, 14 graduate courses in meteorology, 1968-Present.
15 d.(1) " Atmospheric Dispersion 16 at a Coastal Rough-Terrain Nuclear Plant Site" (coauthor),
17 Annual Meeting, American Nuclear Society, San Diego, Cali-18 fornia, June, 1978.
19 (2) "Results of an Offshore
- 20 Dispersion Program Conducted at the San Onofre Nuclear Gen-21 erating Station," Joint Conference on Applications of Air 22 Pollution Meteorology, Salt Lake City, Utah, November, 1977.
23 (3) "A Rational Approach to 24 Accident Dose Assessment," 1975 Annual Meeting, American Nu-25 clear Society, New Orleans, Louisiana, June, 1975.
26 . . . . .
1 (4) uA Survey of Cloud 2 Seeding Technology," M.S. thesis, New York University, New 3 York, N.Y., 1968.
4 e.(1) NUS Corporation, 1970-5 Present; Principal Meteorologist.
6 (2) GEOMET, Inc., 1968-7 1970; Analysis of problems in atmospheric diffusion and air 8 pollution control and abatement programs.
9 (3) New York University, 10 1967-1968; Research Assistant.
11 (4) City College of New 12 York, 1966-1957; Teaching fellowship.
13 (5) U.S. Weather Bureau, 14 summer, 1966; Participated in experimental use of trans-15 missometer network to test feasibility to measure visibility 16 in fog.
17 10. Terry A. Ritter 18 a.-c. Loyola University of 19 Los Angeles, M.S., Sanitary and Environmental Engineering, 20 1975; Loyola University of Los Angeles, B.S., Civil Engi-21 neering, 1967.
22 d. None.
l l 23 e.(1) NUS Corporation, 1977 -
24 Present; Management of environmental impact programs and l
l 25 preparation of environmental reports.
26 . . . . .
t 1 (2) Los Angeles Department 2 of Water and Power, 1967-1969, 1972-1977; Liaison with state 3 and federal regulatory agencies; prepared water quality 4 studies.
5 (3) U.S. Army, Engineer 6 Command, 1969-1972; Consulting and supervisory engineer.
7 11. Lawrence T. Klein 8 a.-c. Polytechnic Institute 9 of Brooklyn, B.Ch.E., Chemical Engineering, 1958; Oak Ridge 10 School of Reactor Technology (ORSORT), Certificate in Nu-11 clear Reactor Scienca and Technology, 1963.
12 d. None.
13 e.(1) NUS Corporation, 1964-14 1966, 1972-Present; Technical and managerial responsibili-15 ties.
16 (2) General Electric Com-17 pany, 1966-1972; Requisition and sales; also technical re-1 18 sponsibilities.
19 (3) Tennessee Valley Au-20 thority, 1961-1963; Nuclear hazards control engineer.
21 (4) Martin Company, Nuclear 22 Division, 1959-1961; Analysis of nuclear hazards involved in 23 isotope-powered thermoelectric generators.
I 24 (5) U.S. Atomic Energy Com-25 mission, 1958-1959; Review and evaluation of research and 26 development programs.
[
1 12. Joseph J. Dinunno 2
a.-c. University of Maryland, 3 M.S., Electrical Engineering, 1954; The Pennsylvania State 4 University, B.S., Electrical Engineering, 1942; Oak Ridge 5 School of Reactor Technology, 1956-1957.
6 d. None.
7 e.(1) NUS Corporation, 1972-8 Present; Technical Director, Environmental Systems Group.
9 (2) U.S. Atomic Energy Com-10 mission, 1959-1972; Various responsibilities associated with 11 the engineering, safety analysis and pub.lic protection cs-12 pects of nuclear facilities.
13 (3) U.S. Navy, 1942-1959; 14 Engineer.
15 (4) Westinghouse Electric l 16 Co., 1942; Engineer.
17 13. Carl G. Mattsson 18 a.-c. University of Southern 19 California, M.S., Candidate, Environmental Engineering, 20 1973; Western Washington State College, B.A., Mathematics 21 and Physics, 1967.
22 d. None.
23 e.(1) NUS Corporation, 1973-77; 24 Assisted in project coordination and management of siting 25 studies and environmental reports and programs.
26 , . . . . .
1 (2) Puget Sound Naval Ship-2 yard, Radiological Engineering Division, 1968-1972; Project 3 leader.
4 14. Paul V. Morgan 5 a.-c. University of Pitts-s burgh, Pittsburgh, Pennsylvania Garduate Studies in Environ-7 mental Health, 1967; University of Pittsburgh Graduate 8 School of Public Heal.th, Pittsburgh, Pennsylvania, M.S.,
9 Bygiene, Water Pollution Control, 1961; University of Pitts-10 burgh, Pittsburgh, Pennsylvania, M.S., Microbiology, 1958; 11 University of Pittsburgh, Pittsburgh, Pennsylvania, B.S.,
12 Bacteriology, 1950.
13 d. See attached.
14 e.(1) NUS Corptsration, 1967-80; 15 Management of aquatic and terrestrial ecological programs.
16 (2) University of Pitts-17 burgh, 1950-1954, 1961-1967; Conducted studies of the en-18 vironmental impact of nuclear power station.
19 (3) Mellon Institute of In-20 dustrial Research, 1954-1961; Research and field investiga-21 tion.
22 BECHTEL 23 1. W. G. Bingham, Jr.
24 a.-c. B.S., Engineering, Uni-25 versity of California at Los Angeles; Business Management 26 - - -
1 Certificate, University of California; Masters Business Ad-2 ministration, Golden Gate University.
3 d.(1) " Makeup Water Supply 4
for Dry Site Power Plant," ASME Conference, 82-JPGC-PWR-49.
5 (2) " Management Science Ap-6
. plications in the Planning and Design of a Water Supply Sys-7 tem for Nuclear Power Plants," The Institute for Management 8 Science, February 15, 1979; 9
(3) " Design Innovations 10 Palo Verde Nuclear Generating Station," ANS Topical Confer-11 ence, Cleveland, Ohio, August," 1981.
12 (4) " Design for Plant Main-13 tainability and Operability," Id.
14 (5) " Utilization of Design 15 Change control to Reduce Cost and Schedule Impacts on Power 16 Projects," ASME Conference.
! 17 (6) "Will Nuclear Power 18 i
l Plant Standardization Reduce the Licensing Impact on Con-19 ctruction," ANS Topical on Nuclear Plant Construction, 20 1976.
21 e. Bechtel Power Corpora-22 tion; Project Engineer and Project Engineering Manager, 23 responsible for all engineering on PVNGS and water reclama-24 tion facilities (May 1973-Present).
25 . . . . .
26 . . . . .
l I-
F 1 2. Robert R. Stiens 2 a.-c. M.S., Engineering, Cali-3 fornia State University, Northridge, 1968; B.S., Chemical 4 Engineering, Washington University, St. Louis, Missouri, 5 1956.
6 d. " Makeup Water Supply for
^
7 Dry Site Power Plant," ASME Conference 82-JPGC-PWR-49.
8 c.(1) Bechtel Power Corpora-9 tion; Nuclear Group Supervisor, Alvin W. Vogtle Nuclear 10 plant (May 1973-May 1974);
11 (2) Assistant Project Engi-12 neer and Project Engineer responsible for power plant engi-13 neering on the PVNGS (1974-Present).
f 14 3. Dennis G. Keith 15 a.-c. B.S., Mathematics, 16 Stanford University, Palo Alto, 1961; U.S. Navy Submarine
.' 7 School, 1961; U.S. Navy Nuclear Power School, 1962; M.S.,
18 operations Research, Stanford University, 1969.
19 d.(1) " Experience in Licens-20 ing a Replicate Plant at the Same Site," American Power Con-21 ference, 1978.
22 (2) "Will Nuclear Power 23 Plant Standardization Reduce the Licensing Impact on Con-24 struction," ANSW Topical on Nuclear Power Plant construc-25 tion, 1976.
1 26 . . . . .
u i d
1 e. Bechtel Power Corpora-2 tion; May 1973-August, 1977, Nuclear Group Supervisor, Palo 3 Verde Nuclear Generating Station; August 1977-August 1978, 4 Project Coordinator PVNGS Units 4 and 5; August 1978-May 5 1983, Assistant Project Engineer, responsible for preparation 6 of construction permit licensing documents and review of 7 Operating license licensing documents.
8 4. Paul Barbour 9 a.-c. B.S., Engineering, 10 University of California, Los Angeles; 1955; M.S., Chemical 11 Engineering, University of Southern California, 1966; M.S.,
12 Znvironmental Engineering, University of Southern Califor-13 nia, 1972.
14 d. None.
15 e. Bechtel Power Corpora-16 tion; May 1973-August 1979, Nuclear and Environmental Staff 17 Specialist engaged in analysis, design and evaluation of 18 nuclear and fossil power stations; August 19',J-September 19 1980, Licensing Engineer for San Onofre Units 1, 2 and 3;
- 20 September 1980-October 1981, Engineering Specialist for l
21 SONGS Units 2 and 3; October 1981-December 1982, Deputy Nu-22 clear Group Supervisor for PVNGS; December 1982-Present 23 PVNGS Nuclear Group Supervisor.
24 5. William W. Bolec 25 a.-c. B.S., Chemical Engi-26 neering, Cornell University, Ithaca, New York, 1968.
1 d. " Power Plant Wastewater 2 Disposal at the Palo Verde Nuclear Generating Station," EPRI 3 Zero Discharge Symposium, 1981.
4 e.(1) Dow Chemical Company, 5 May 1973-October 1973, Service Engineer; 6 (2) Bechtel Power Corpora-7 tion; October 1973-November 1974, Mechanical Staff Engineer 8 for water treatment and management; November 1974-April 9 1975, Mechanical Engineer, Harry Allen Station; April 1975-10 September 1977, Mechanical Engineer, Palo Verde Nuclear 11 Generating Station; September 1977-April 1978, Mechanical 12 Group Leader PVNGS Units 4 and 5 responsible for mechanical 13 review of PSAR and ER-CP; April 1978-August 1981, Mechanical 14 Group Leader, PVNGS responsible for contract adminis tration, l 15 water treatment, and licensing interfaces; August 1981-i i 16 Present, Deputy Mechanical Group Supervisor.
1 17 6. John W. Kluesener i
18 a.-c. B.S., Chemical Engi-19 neering, Northwestern University, 1964; M.S., Water Chemis-20 try, University of Wisconsin, 1969; Ph.D., Water Chemistry, 21 University of Wisconsin, 1972.
22 d.(1) "A Demonstration of 23 Wastewater Treatment for Reuse in Cooling Towers at Fifteen 24 Cycles of Concentration," AICHE Water Resuse Conference, 25 Chicago, IIIinois, May, 1975.
26 i . . . . .
1
1 (2) " Process and Design 2 Considerations for a 90 MGD Wastewater Reclamation Plant,"
3 ASCE Convention, Portland, Oregon, April, 1980; 4 (3) " Management of Power 5 Plant Water and Wastewater in Water Short Regions," Ameri-6 can Power Conference, Chicago, Illinois, April, 1980..
7 e. Bechtel, Inc. (Also 8 Bechtel Civil and Minerals, Inc.), May 1973-Present; Assis-9 tant Project Engineer / Assistant Project Manager for the 10 PVNGS Water Reclamation Facilities.
11 7. Stephen H. Shepherd 12 a.-c. B.S., Chemistry, B.S.,
13 Physics, Willamette University, Salem, Oregon, 1974; M.S.,
( 14 Nuclear Engineering, Oregon State University, 1976; Business 15 Certificate, Golden Gate University, 1982.
l 16 d.(1) "The Environmental Im-l 17 Pact of Integrated Joint Nuclear - Hydrogen Electrical Gen-18 eration Parks," ANS Transactions, 1976.
19 e.(1) United States Depart-20 ment of Agricultural - Forest Service; May 1973-September, 21 1973; Lookout, Umpqua National Forest.
22 (2) Agripac, Inc.; July i 23 1974-October 1974; Cannery Worker.
l 24 (3) Oregon State Univer-25 sity; January 1975-August 1976; Research Assistant.
26 - - -
l l
L
JJJ D
1 (4) Bechtel Power Corpora-2 tion; September 1976-May 1978, Nuclear and Enviromental 3 Engineer engaged in analysis, design, and evaluation of 4 nuclear power plants; May 1978-December 1982, Nuclear and 5 Environmental' Engineer for PVNGS, responsible for prepara-6 tion of ER-OL and safety analysis; December 1982-May 1983, 7
Deputy Nuclear Group Supervisor for PVNGS, responsible for 8 PVNGS licensing.
9 8. Nora A. Blum 10 a.-c. B.S., Civil Engineer-11 ing, Worchester Polytechnic Institute, Worchester, Massa-12 chusetts, 1973; Civil and Environmental Studies, North-13 eastern University, Boston Massachusetts, 1975-1978.
14 d.(1) " Seawater Closed Cyc'e 15 Cooling Systems," Power Engineering, August 1979:
16 (2) "A Survey of Capital 17 Costs of Closed Cycle Cooling Systems for Steam-Electric I
18 Power Plants," American Power Conference, Chicago, Illi-19 nois, April, 1979.
20 (3) " Design and Model Tests 21 of Shorefront Revetment-Ditch System for a Nuclear Power 1
22 Plant," ASCE Hydraulic Division Specialty Conference, Col-23 lege Station, Texas, August, 1977.
24 e.(1) Stone and Webster Engi-25 neers, Inc.; May 1973-January 1981; Civil and Environmental 26 Engineer assessing environmental impacts.
1 (2) Bechtel Power Corpora-2 tion; February 1981-Present; Environmental Group leader 3 responsible for management of L. A. Power Division, Environ-4 mental Projects.
5 9. Peter Su 6 a.-c. B.S., Civil Engineer-7 ing, Cheng Kung University, Taiwan, 1963; M.S., Civil Engi-8 neering, Colorado State University, Fort Collins, Colorado, 9 1969; Ph.D., Civil Engineering, Colorado State University, 10 1972.
11 d. Unavailable.
12 e.(1) Bechtel, Inc., May 13 1973-December, 1981; Geotechnical Specialist engaged in 14 investigation and analysis of geological and civil aspects 15 of Bechtel projects.
16 (2) Bechtel Power Corp.,
17 January 1982-Present; Engineering Specialist engaged in 18 engineering and analysis of civil and mechanical aspects of 19 Bechtel Power Corp. projects.
l 20 10. Vasken Najarian 21 a.-c. B.M.E., American Uni-22 versity, Beirut, Lebanon, 1955; M.S.E., University of Cali-23 fornia at Los Angeles, 1958.
24 d. None.
25 - - - - -
26 - - -
1 e. Bechtel Power Corp.; May 2 1973-April 1979, Mechanical Group Supervisor; April 1979-3 Present, Assistant Project Engineer responsible for mechani-4 cal system design.
5 MARLEY 6 1. Ivan F. Kuharic 7 a.-c. Purdue University, West 8 Lafayette, Indiana, 1949, B.S.M.E., Mechanical Engineering.
9 d.(1) " Analyze Your Bids,"
10 Marley Technical Bulletin R-58-P-2 (coauthor).
11 (2) "Psychrometrics and the 12 Psychrometer," CTI Paper #TP-231A.
13 (3) Numerous in-house ar-14 ticles dealing with Sound Rating, Fan Selection, Basic 15 Theory and Thermal Performance of Cooling Towers.
16 e. Marley, 1969-Present; 17 Manager, Ratings and Performance Section; Duties include the 18 thermal and sound ratings of all evaporative cooling prod-19 ucts, field tests and investigations, operating characteris-20 tics of the products, placement and orientation studies, l
21 technical assistance to the Sales Division.
22 2. O. L. Kinney 23 a.-c. B.S., Mechanical Engi-24 neering, Finley Engineering College, 1964.
25 d. " Drift Technology for 26 Cooling Towers," (coauthor) The Marley Company, 1973.
1 e. Marley Cooling Tower Com-2 pany 1966-Present; Assistant Engineer (1966-68); Engineer 3 (1968-69); Project Engineer (1969-74); Project Engineer I 4 (1974-76); Senior Engineer (1976-77); Design Consultant 5 (1977-80); Senior Design Consultant (1980-Present).
6 3. Paul A. Lindahl 7 a.-c. B.S., Nuclear Engineer-8 ing, Kansas State University, Mannattan, Kansas, 1973.
9 d. "New Designs in Currently 10 Marketed Cooling Towers," 1977, Summer National Meeting, 11 American Nuclear Society.
12 e. Marley Cooling Tower Com-13 Pany 1968-Present; Summer engineering intern program of the l 14 Marley Cooling Tower Company (1968-73); Project Engineer in 1
15 Ratings & Performance Section for wet / dry and dry cooling 16 tower rating and product development (1973-75); Responsible 17 also for rating and optimization of mechanical draft con-18 crete towers (1975-82); Responsible for rating and product 19 development and testing of wet / dry and dry cooling towers 20 (1977-Present); Responsible for rating and optimization of 21 natural draft concrete cooling towers (1978-82); Senior 22 Engineer and Engineering Division Coordinator for Major 23 Project Proposals (1979-Present); Section Manager, Product 24 Evaluations Section; Responsible for all major project 25 OPtimizations, new product evaluations, rating and product 26 - - - -
1 development for wet / dry and dry cooling towers (1982-2 Present).
3 4. Joyce D. Holmberg 4 a.-c. B.S., Mechanical Engi-5 neering, University of Kansas, 1951.
6 d.(1) Discussion of the 7 paper, " Cooling Tower Fan Performance," by George W. Forman 8 and Neil W. Kelly, Journal of Engin.eering for Power, Trans-9 actions of the ASME, April, 1961.
10 (2) " Design and Development 11 of Large Cooling Tower Fan and Drive," ASME Paper No.
12 65-PET-11, September, 1965, by E. R. Allgeyer and J. D.
13 Holmberg.
14 (3) " Drift Technology for 15 Cooling Towers," (coauthor) The Marley Company, 1973.
16 (4) " Drift Management in i 17 the Chalk Point Cooling Tower," from Symposium on Cooling l
18 Tower Environment-1974, College Park, Maryland, March 4, i 19 1974.
l l 20 (5) " Debut of the Round 21 Mechanical Draft Tower, by J. B. Dickey, Jr., J. D. Holmberg,
- 22 R. E. Cates and T. W. Bugler III, for American Power Con-l l 23 ference, April 23, 1975.
l 24 e. Marley Cooling Tower Com-l 25 pany 1951-Present; Asst. Project Engineer -
fan design 26 (1951-54); Project Engineer - fan design and supervision of l
l 1 other mechanical component design (1954-57); Research Asso-2 ciate -
development of mechanical components (1957-59);
3 Manager, Research & Development - departmental supervision 4 for all product and component development (1959-69);
5 Sciences Director - supervision of the Computer, Analytical, 6 and Laboratory Services Section of the Engineering Division.
7 Also, supervision of work by external consultants and major 8 test projects in outside laboratories (1969-Present).
9 5. Joe Ben Dickey, Jr.
10 a.-c. B.S., Civil Engineer-11 ing, University of Colorado, 1946; 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> Business Ad-12 ministration, University of Kansas, 1947.
13 d.(1) " Evaporative Cooling 14 Towers for Chemical and General Industries," 1978.
15 (2) " Managing Waste Heat 16 with the Water Cooling Tower," 1970.
17 (3) " Debut of the Round 18 Mechanical Draft Tower," by J. B. Dickey, Jr., J. D. Holm-19 berg, R. E. Cates and T. W. Bugler, III, 1975.
20 e. Marley Company, 1947-21 1980; Project Engineer -
Engineering Div. (1947-49); Sr.
22 Application Engineer Sales Division (1949-53); Industrial 23 Sales Manager (1953-65); Asst. Division Manager, Research &
24 Engineering (1965-69); Vice President, Engineering (1969-77);
25 Vice President, Special Projects (1977-1980).
26 - -
1 6. William V. McCoy 2 a.-c. B.S., Mechanical Engi-3 neering, University of Kansas, Lawrence, Kansas, 1948; Uni-4 versity of Kansas, Lawrence, Kansas, 1968-51, completed work 5 toward M.S., except thesis.
6 d. None 7 e. Marley Company, 1963-8 Present; Regional Sales Manager - Washington, D.C. (1963);
9 District Sales Manager, L.A., CA (1963-77); Regional Vice 10 President - L.A. Sales (1977-Present).
11 7. James O. Kadel 12 a.-c. B.S., Mechanical Engi- i 13 neering, Texas A&M, College Station, Texas, 1951.
14 d. " Cooling Towers - A Tech-15 nological Tool to Increase Plant Site Potentials," 1970.
i 16 .
- e. Marley Company 1953-17 Present; Application Engineer - Dricooler Sales (1953-55);
18 Sr. Application Engineer - Industrial Tower Sales (1955-58);
19 Sr. Engineer - Industrial Tower Sales (1958-63); Sr. Project l
20 Manager - Industrial Tower Sales (1963-65); Manager, Indus-21 trial Tower Sales (1965-68); Asst. General Manager (1968-69);
22 V.P. Major Projects (1969-74); V.P. Sales Div. (1974-77);
i 23 V.P. Engineering Div. (1977-79); President - Marley Inter-24 national (1979-82); Executive Vice President (1982-Present).
25 - - - - -
l l 26 . . . . .
1 8. Richard D. Landon 2 a.-c. University of Missouri, 3 Columbia, B.S., Chemical Engineering, 1964; University of 4 Missouri, Columbia, M.S., Chemical Engineering, 1974; Stan-5 ford University, California, Certificate of Completion, 6 Stanford Executive Program, 1982.
7 d.(1) " Plume Abatement and 8 Water Conservation with the Wet / Dry Cooling Tower," American 9 Power Conference, 1973, by Richard D. Landon and James R.
10 Houx, Jr.
11 (2) " Reducing Environmental 12 Impact with Cooling Tower Innovations," Pacific Coast Elec-13 trical Association, 1975, by Richard D. Landon.
14 (3) " San Juan - Water Con-15 servation Reality," Cooling Tower Institute -
1982, by 16 Richard D. Landon.
17 e. Marley Cooling Tower Co.
18 (1973-Present); Sr. Vice President, Domestic Operations 19 (1982-Present); Vice President, Administration (1981-82);
20 Asst. Vice President, Major Projects (1974-81); Manager, 21 Power Projects (1973-74).
22 9. A. R. Thompson 23 a.-c. University of Kansas, 24 B.S.M.E., Mechanical Engineering, 1949; 25 - - - - -
26 - - - - -
l 1 d.(1) " Principles of Cooling 2 Tower Applications," Fourth Annual All-Industry Air Condi-3 tioning Conference, Chicago, Illinois, 1956.
4 (2) "A Water Pollution Con-5 trol Device - Cooling Towers," Chemical Engineering, Octo-6 ber 14, 1968.
7 (3) " Cooling Tower Seminar -
8 University of Wisconsin Extension School, October, 1973.
9 (4) " Cooling Towers - Energy 10 Considerations in Applications," presented April 22, 1976, 11 at the Energy-Industry Facilities Conference sponsored by 12 the Dept. of Engineering, University of Wisconsin Extension, 13 Madison, Wisconsin.
14 e. The Marley Company (1960-15 Present); Regional Manager (1960-76); Area Vice President, 16 Eastern Marketing Area (1976); Vice President and General 17 Sales Manager, Marley Cooling Tower Co., Mission, Kansas 18 (1976-83); Sr. Vice President - Marketing and Sales, The 19 Marley Cooling Tower Co. , Mission, Kansas (1983-Present).
I 20 APS 21 See attached resumes for following APS personnel:
22 1. W. L. Hurst.
l 23 2. J. M. Allen.
24 3. E. E. VanBrunt.
25 4. A. C. Rogers.
26 5. J. P. Mann.
l O
1 6. D. B. Karner.
2 7. W. F. Quinn.
3 4 1NTERROGATORY NO. 19. Has any expert or technician con-5 ducted, or will any expert or technician conduct, any tests, 6 examinations, or inspections in connection with this pro-7 ceeding? If so, please identify each such person.
8 ANSWER 9 19. The following persons or entities have con-10 ducted or will conduct tests, examinations or inspections in 11 connection with this proceeding:
12 1. CEP (Controls for Environmental Pollu-13 tion, Inc.) P.O. Box 5351, 1925 Rosina, Santa Fe, New Mexico 14 87502.
15 2. ESC (Environmental Systems Corp. ), 200 16 Tech Center Drive, Knoxville, Tennessee 37912.
17 3. William E. Dunn; 108 S. Prospect Ave.,
18 Champaign, Illinois 61820.
19 4. University of Arizona, as described in 20 proposal previously provided to Petitioner, including Dr.
21 Charles Curtis, Dr. Delbert McCune and Dr. Leon Bernstein.
22 5. CDM (Camp, Dresser & McKee), 11455 West 23 48th Avenue, Wheat Ridge, Colorado 80033.
24 6. NUS Corporation, 910 Clopper Road, 25 Gaithersburg, Maryland 20878.
26 . . . . .
L
T I
1 INTERROGATORY NO. 20. If your answer to the preceding in- l 2 terrogatory is yes, identify any record or report of his l 3 findings including:
4 a. the date of submission or expected sub-5 mission of each such report; i
6 b. the person to whom it was or is expected 7 to be submitted; 8 c. the person who has or is expected to 9 have custody of each such report; 10 d. the subject matter and finding of each 11 such report.
12 ANSWER 13 20.a.-d. The only reports prepared thus far are 14 those from CEP relating to the Low Volume Samplers and a 15 preliminary evaluation of the FOG model by Dr. Dunn. The 16 other individuals or entities identified in response to In-l 17 terrogatory No. 19 are expected to submit reports, but Joint 18 Applicants do not have precise dates on which such reports l 19 will be completed. It is anticipated, however, that ESC 20 will have completed its final report by June 30, 1983, and 21 that Dr. Dunn will have completed his report by June 30, !
22 1983. The expected date of the University of Arizona's 23 report on the effects of salt drift on crop productivity has I
24 been previously provided to Petitioner. CEP's and CDM's 25 reports are expected monthly. NUS' reports are expected l 26 - - - - -
j 1 annually. The University of Arizona will also be making 2 reports biannually.
3 All of the reports will be submitted to Snell &
4 Wilmer. The CEP reports will relate to the data collected 5 by the Low Volume Samplers; ESC's report will deal with the 6 quantity of salt drift emitted from and the salt drift drop-7 let size distribution associated with the PVNGS cooling 8 towers; Dr. Dunn's report will relate to validation of the 9 FOG Model and predictions of salt drift deposition; CDM 10 reports will analyze dustfall samples and cooling tower j 11 basin water; the University of Arizona report nn the effects 12 of salt drift on crop productivity will be as described in 13 the proposal previously provided to Petitioner; the Univer-14 sity of Arizona's other reports will relate to analyses of 15 soil and vegetation samples; and the NUS reports will relate 16 to the review of data collected as part of the Salt Deposi-17 tion and Impact Monitoring Plan.
18 19 INTERROGATORY NO. 21. State the amount each expert identi-20 fied in response to Petitioner's First Set of Interroga-21 tories, No. 56, is to be paid or has been paid and the basis 22 on which his compensation is to be determined.
23 ANSWER 24 21. The basis for the compensation of experts 25 identified in response to Petitioner's First Set of Inter-26 rogatories is an hourly rate. The amount of the compensa-l l
i L j
1 tion is irrelevant to the subject matter of these proceed-2 ings, and Joint Applicants therefore object to this inter-3 rogatory on that basis.
4 5 INTERROGATORY NO. 22. Identify each exhibit which you pro-6 pose to utilize at the hearing.
7 ANSWER 8 22. Joint Applicants have not yet identified the 9 exhibits it will utilize at the hearing.
10 11 INTERROGATORY NO. 23. Identify each person other tr.an Joint 12 Applicants' attorneys, who prepared answers to these and the 13 preceding set of interrogatories and the specific interroga-14 tories on which each such person worked.
15 ANSWER 16 Joint Applicants object to this interrogatory on 17 the grounds that it is burdensome and oppressive.
18 l t$-
19 RESPECTFULLY SUBMITTED this day of May, 20 1983.
21 SNELL &
22 23 By _ff " ,,"v Ar ur C. Geff /
24 Wa en E. Ph/:t l
C arles A. Bischoff '
25 aughn A. Crawford 3100 Valley Bank Center 26 - Phoenix, Arizona 85073 l l
VAC/21/F
. MORTON 1. GOLDMAN - PUBLICATIONS
" Nuclear Waste Management,"by Task Committee on Nuclear Effects, M. l. Goldman, Chairman; Journal of the Environments / Engineering Division, Proceedings of the American Society of Civil Engineers Vol.
108, No. EE1, February 1982.
" Regulatory issues in Uranium Supply," presented at Nuclear Engineering Seminar. University of Mary-land, College Park, Md., November 10,1981.
" Radon: The Ubiquitous Pollut' ant," presented at Atomic Industrial Forum Conference on Environmental Regulation of the Nuclear Industry: A New Decade, San Francisco, Calif., May 20,19An
" Management of Wastes From Energy Production: Nuclear and Coal," presentad to American Nuclear Society Student Chapter, University of Maryland, College Park, Md., April 22,1980.
" Energy: What About the Waste?" Chemica/ Engineering Progress, American Institute of Chemical
! Engineers, N.Y., Now.mber 1979.
" Nuclear Facilities Siting," by Task Committee on Nuclear Effects, M.1. Goldman, Vice Chairman; Journal of the (svironments/ Engineering Division, Proceedings of the American Society of Civil Engineers, Vol.
- 105, No. EE3, June 1979.
"The Nuclear Fuel Cycle An Overview and Outlook," Civil Engineering and Nuclear Power Conference.
American Society of Civil Engineers National Convention, Boston, Mass., April 2,1979.
" Radiological implications of Coal and Nuclear Fuels," presented at American Institute of Chemical Engineers Convention, Miami Beach, Fla., November 15,1978.
'The Low-Level Radiation issue-Radon from Uranium Production Facilities: Ststus Report," presented at Atomic industrial Forum Conference on Environmental Regulation: Looking Ahead, Monterey, Calif., June 11,1978.
"Our Energy Situation Today," Democratic Federation of Women's Clubs National Convention, Phoenix, Ariz., May 28,1977.
"The Environmentalimpact t,f a Nuclear Moratorium," presented at Environmental and Water Resources, Tenn., March 23,1976.
l "The Energy Environment," presented at Nuclear Engineering Seminar, University of Maryland, College Park, Md., March 16,1976.
" Environmental impact of Energy Sources"(coauthor), ChemicalEngineering, Vol. 81, No. 22 Deskbook issue, October 21,1974.
" Cost-Benefit Analyses of Environmentallmpact " Lecture, Continuing Education in Engineering, Univer-sity Extension, and the College of Engineering, University of California, Berkeley, Calif., Course: Environ-mental Analysis and Environmental Monitoring for Nuc; ear Power Generation, September 13,1974.
'The Environmental Impact of Nuclear Systems," Mechanical Engineering Colloquium, Worcester Poly-technic Institute, Worcester, Mass., November 6,1973.
" Benefits and Risks to Nuclear Power in the United States of the 'As Low As Practicable' Philosophy,"
Proceedings of the Third International Congress of the international Radiation Protection Association, Washington, D.C., September 11,1973.
" Environmental Effects of Electric Power Generation," National Science Teachers Association Annual Convention, Detroit, Michigan, April 2,1973 Reprint: A WARE Magazine, Community Performance Publi-cations, Inc., Madison, Wis., August 1973.
j j " Environmental Assessments for Nuclear Power Plants in the United States," The Sixth Conference on a
Nuclear Safety Research, Tokyo, Japan, May 10,1973. f "The Economic Consequences of Environmental Protection"(coauthor), presented at the international 1 1
Colloquium-Nuclear Energy and Environment, A.l.M., Liege, Belgium, January 22-25,1973.
NUS COAPORATION
MDRTON 1. COLDMAN - PUBLICATIONS Page Two
" Environmental Effects of Nuclear Power Generation," presented at the Workshop on *The Nuclear Controversy in the USA," April 30 to May 3,1972, Lucerne, Switzerland, sponsored by the Swiss Association for Atomic Energy in cooperation with the Atomic Industrial Forum, Inc.
)
" Radioactive Waste Management and Radiation Exposure,"Nuc/ ear Technology, Vol.14, pp.157-162.
May 1972.
"New Environmental Reportrl-A Growing Nuclear Headache"(coauthor), E/ectric Light andFower, March 1972.
"New Developments in Nuclear Power Plant Waste Treatment"(coauthor), ANS Transactions, Vol.14, No.1, p. 327, June 1971.
'The Role of Nuclear Power in a Protected Environm'ent," Proceedings of the Southern Conf. on Environ-mentalRadiation Protection from Nuclear Power Plants, St. Petersburg, Fla., April 22,1971.
"A Survey of Technological Responses by Electric Utilities to Environmental Problems," presented at the Atomic industrial Forum Ar, ual Conf., Washington, D.C., November 18,1970.
" Nuclear Facility Siting in the United States," Proceedings:Fifth AnnualHealth Physics Society Midyear TopicalSymposium, Idaho Falls, Idatap Vol.1, pp.10-16, November 4,1970.
"The Environment and Nuc! ear Power Generation," Proceedings: The Joint Power Generation Conf.,
Pittsburgh, Pa., September 30,1970.
" Nuclear Power and the Environment-Communications or Technical Problems," Transactions ofAmeri-can Nuclear Society 16th AnnualMrs., Los Angeles, Calif., June 29,1970.
" Environmental Considerations et Nuclear Power Plants," and " Management of Nuclear Fuel Reprocess-ing Wastes " Proceedings of a Student Conference on Nuclear Power and the Environment, Univ. of Wisconsin, Madison, Wis., April 3-4,1970.
I
" Waste Management at Nuclear Power Plants-A New Challenge," Proceedings ofJoint Power Confer-ence, Charlotte, N.C., September 24,1969.
" United States Practice in Management of Radioactive Wastes at Nuclear Power Plants," Appendix 4, international Atomic Energy Agency, Safety Series No. 28-Management of Radioactive Wastes at Nuclear Power Plants, Vienna, Austria, December 1969.
" Management of Gaseous Wastes from Nuclear Power Stations," Proceedings of a Symporium on Treatment of Airborne Radioactive Wastes, international Atomic Energy Agency, N.Y., August 26-30, 1968.
" Safety Aspects of Ground Testing for Large Nuclear Rockets," Nuclear Applications, Vol. 2. April 1966.
" Establishing Safety Design Critoria for Power Reactor Sites"(coauthor), Proceedings of ANS National TopicalMeeting, Los Angeles, Calif., February 1966.
- Treatment on Site-lon Exchange and Absorption," Chapter 11 of Low-Leve/ Radioactive Wastes, USAEC, 1964.
- Environmental Safety Aspects of Nuclear Rocket Flight Operations"(coauthor), Proceedings ofAerospace Nuc/eer Safety Conference October 1-4,1963 SC-DC-3553.
" Control of Airborne Radioactive Pollutants," presented at the Atlanta Environmental Engineering Confer-ence, American Society of Civil Engineers, February 27,1963.
" Environmental Monitoring at Nuclear Facilities"(coauthor), Nuclear Congress, Paper No. 73,1962.
"The Fixation in Vitreous Matrices of High-Activity Fission Products"(coauthor), Proceedings of the Second
/nternational Conference on Peaceful Uses of Atomic Energy, Vol.18 No. 27,1958.
" Studies on Radioisotope Removal by Water Treatment Processes"(coauthor),J. Am. Water Works Assn.
Vol. 43, No. 615,1951.
NUS COAPOAATION
PAUL V. MORGAN - PUBLICATIONS 4
PUBLICATIONS AND PRESENTATIONS Morgan, P. V., "A Survey of the Heterotrophic Bacteria in the Sanctuary Lake of the Pymatuning Reservoir," Master's Thesis, University of Pittsburgh, 1958.
. Shapiro, M. A., J. F. Ficke, P. V. Morgan, R. D. Spcar and C. C. Kisiel, "Some Factors of Importanco in Evaluating Sites for Nuclear Industry as Determined by a Limnological
' Study of the Upper Ohio River,", Verh. Int. Vor. Limnol.,
l Vol. 15, pp. 299-306, 19G2.
Morgan, P. V. and llonry C. Dramer, "Thormal Pollution as a Pactor in Power Plant Site Selection," American Power Conference, Vol. 31, pp. 724-732, 1969.
Morgan, P. V '. , "Dasic Data Requiremonts to Evaluate Water Quality Control Programs," National Symposium on Data and Instrumentation for Water Quality Management, Conference of Stato Sani.tary Engineers, the University of Wisconsin, Madison Wisconsin, 1970, Morgan, P. V., D. R. Johnson, !!. C. Dramer and W. L. Duncan,
" Design of Water Qualtiy Survei11ance Systems - Phase I -
Systems Analysis Framework," Publication 16090 DDJ 08/70, of the Federal Water Quality Administration, 1970.
. Morgan, P. V. and W. E. Dodnar, " Ecological Considerations for Deaver Valley Power Station," Ponnsylvania Electric As soci'a tion , 1971.
Mort]an, P. V.,
"llow Shall We Measure Waste Water Paiamatore." -
Panol - Automation of Waste Water Treatment Plants, American Institute 1971. ' of Chemical Engineers, San Francisco, California, 1 Morgan, P. V., D. R. Johnson, R.
P. Goldstein and L. J.
l t' Perez, " Data Acquisition Syntoms for the Design of Thormal Diccha rac .Teructure n , " Ua t."- ~'uality Ins trum. n t a tion, VM ~ ~ ~ -
1:r rumer
- c cier, n- ' ' -- -
]974. .
l Morgan, P. V., " Data Acquisition Systems for Remote Underwater Monitoring Platforms," International Exposition and Seminar on Water Resources Inntrumentation, Chicago, 1974.
Dahlberg, M. D. and P. V. Morgan, " Calculation of Impact of Zooplankton Entrainment by Power Plants," Amer. Fish. Soc.,
IInwaii, l'974.
t .
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- NUCLEAR PROJECTS PERSONNEL RESUME W. L. Hurst 1
hpeutso4. - Civil Nuclear Engineering'! '
Responsible for reviewing architectural, civil dnd structural engineering designs, specificatLons and construction contracts, along with coordinating geology, seismology and hydrology activities.
Educational Background Professional Leval Experience UNIVERSITY OF MISSOURI, Stone & Webster Engineering Corp.
BSCE (1967) Field Engineer (1967-1970)
Structural Field QC Engineer (1970-1972)
Gilbert Assoc., Inc.
Resident Civil QA Engineer (1972-1974)
Arizona Public Service Company O Civil Engineer, Nuclear Services (1974-1975)
Senior Civil Engineer, Nuclear Services (1975-1979)
Supervising Engineer, Nuclear Services (1979 .L %St. I h a.vmoo ,
u . a a. e n v e ee . m
( 198 L- yr eseo+ )
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STATION PERSONNEL RESUME J. M. Allen (Sheet 1 of 2) .
TECHNICAL SUPP0,RT MANAGER Responsible for Engineering Department, Radiation Protection _
and Chemistry Section, Licensing Department, Shift Technical Advisor / Independent Safety Engineering Group, and the Water Reclamation Facility.
Educational Background Professional Level Experience SOUTHERN OREGON COLLEGE Philco Ford Space Re-Entry B. S. Mathematics (1967) Systems, Palo Alto, California Systems Analyst for space UNIVERSITY OF SANTA CLARA systems
. Engineering (1968) (1967-1968)
. U. S. Atomic Energy Commission -
UNIVERSITY OF MARYLAND Division of Reactor Development Engineering (1969) and Technology I&C Engineer - assignments.
UNIVERSITY OF WASHINGTON included Power Burst Facility, '
M. S. Engineering (Nuclear) Loss of Fluid Test and EBR-II (1970) ,
(1968-1970)
Professional Engineer, Sacramento Municipal Utility Control Systems District, Sacramento, California (California) Assistant Plant I&C Engineer for the Rancho Seco Nuclear Generating Station (1970-1973) a Salt River Project . -
Senior I&C Engineer, Nuclear l Services (1973-1976) l , Lead I&C Engineer. Nuclear Services. (1976)
Nuclear Engineering Supervisor (1976-1978) -
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STATION PERSONNEL RESUME J. M. Allen (Sheet 2 of 2)
TECHNICAL SUPPORT MANAGER sy -
Educational Background Professional Level Experience Arizona Public Service Company Nuclear Engineering Supervisor, Nuclear Services (1978-1979)
Nuclear Engineering Manager, Nuclear Engineering (1979-1982)
Technical Support Manager PVNGS (1982-Present) 9 e
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C HEADQUARTERS PERSOUNEL RESUMES E. E. Van Brunt, Jr.
APS Vice President .
Responsible for engineering construction and quality assurance for PVNGS Educational Background Professional Level Experience Lehigh University Pratt & Whitney Aircraft B.S. in ME Company Nuclear engineer worked on Ransalaer Polytechnic aircraft-nuclear propulsion Institute project (1957-1961)
M.S. in Engineering Science - major in Ebasco Services, Inc.
Nuclear Engineering (1961-1972)
Project Manager - St. Lucie Project Engineer - Millstone Unit 1 Project Manager - Power '
Burst Facility Nuclear Engineer - Advance Test Reactor .
.- .s Arizona Public Service Company Manager Nuclear Services Project Director for ANPP (1972-1974)
APS Vice President Nucle'ar Services (Project Director)
(1974-1976)
APS Vice President Construc-tion Projects, also Project Director (1976-1978)
' Vice President, Nuclear Projects Management (1978-present) m I
NUCLEAR PROJECTS PERSONNEL RESUME A. Carter Rogers Nuclear Engineering Mandger Nuclear Engineering' Responsible for the c'ivil engineering, mechanical engineering, nuclear engineer-ing and fuel management sections in the
, Nuclear Services Department I -
Educational Background Professional Level Experience UNIVERSITY OF CONNECTICUT U. S. ARMY OFFICER (1961-1964)
M.S. in Chemical Engineering (1968) Pratt & Whitney Aircraf t Fuel Cell Development (1964-1966)
UNIVERSITY OF MISS0DRI B.S. in Chemical Combustion Engineering Engineering (1961) Nuclear Design Engineer (1966-1967)
Project Engineer for Plant Engincaring (1967-1970)
' Senior Project Engineer (1970-1972) Responsible for l
St. Lucie, and for floating nuclear power plant studies.
Supported NSSS turnkey pro-posals by directing nuclear island work in Switzerland, Mexico and Finland Arizona Public Service Company Senior Consulting Engineering, Nuclear Services (1972-1976) -
Nuclear Engineering Supervisor, Nuclear Services (1976-1979)
Nuclear Engineering Manager,-
Nuclear Services (1979-Present)
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4 9
NUCLEAR PROJECTS PERSONNEL RESU)E o
J. R. Mann Senior Health Physics Consultant Nuclear Engineering Responsible for Health Physics and Environ-montal Unit.
Educational Background Professional Level Experience THE COLORADO COLLEGE Dow Chemical Company - Rocky i B.S. Physics (1951)
- Flats Plant - Denver, Colorado Health Ph'ysics, Electronics VANDERBILT UNIVERSITY Engineer (1954-1959)
.M.S. Radiation Physics (USAEC Health Physics Fellow- Health Physics - Radiation ship Program) (1962) Engineer (1961-1965)
Certified Health Physicist Health Physics - Radiation (1975) Dosimetry Manager (1965-1973) l Certified Power Reactor U. S. Atomic Energy Commission i Health Physicist (1980) Regulatory Operations, Region I Radiation Specialist, i
l Operating Nuclear Power Plant Inspector (1973-1974)
Arizona Public Service Company
~
' Senior Health Physicist, _.
Nuclear Projects (1974-1980)
Senior Health Physics Consultant (1980-1981) i r
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PVNGS FSAR HEADQUARTERS PERSONNEL RESUMES D. B. Karnar
, Supervising Engineer - Licensing duelear Services Responsible for the direction of licensing activities for PVNGS Educational Background Professional Level Experience Arizona State University Arizona Public Service Company BSEE (1973) Instrumentation & Control Engineer, Nuclear Services University of Arizona (1974-1977)
MSNE (1974)
Senior Licensing Engineer, Nuclear Services (1977-1979)
!. Supervising Engineer, Nuclear Services (1979- / f#o )
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NUCLEAR PROJECTS PERSONNEL RESUME William F. Quinn
'Eutetusse4. - Nuclear Safety & Licensing Nuclear Engineering Responsible for licensing activities leading to obtaining'an Operating License for PVNGS and for the safety of PVNGS in regard to meeting regulatory agency requirements.
Educational Background Professional Level Experience Arizona State University U. S. Marine Corps - 1969-1971 i
BS in Engineering Science (1976)
(Structural Engineering) ~
Arizona Public Service Company Structural Engineer I (1976-1977)
^ . Responsible for structural design i -
- s. review of ancilliary and major PVNGS structures, review of civil /
structural specifications, and review of soils engineering
' activities for PVNGS.
St'ructural Engineer II (1977-1978)
~ i Responsible for structural and soils engineering design review
' for PVNGS 1-3 including providing consultant direction for soils /
geology studies required for CP licensing activities on proposed PVNGS Units 4 & 5.
Licensing Engineer II, III (1978- .
~
1980)
Responsible for PVNGS 1, 2 & 3 licensing activities, FSAR l . preparation,_THI requirements and i interfacing' with NRC and for CP l licensing activities for proposed 1 PVNGS Units 4-& 5, l Supervising Engineer, Licensing (1980-1981)
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Responsible for supervising Licensing group for PVNGS OL l activities _ including' review of regulatory requirements.
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NUCLEAR PROJECTS PERSONt.'EL RESUME William F. Quinn Suptvis en. - Nuclear Safety & Licensing Nuclear Engineering (Cont'd) f Educational Background ' Professional Level Experience
- Supervising Nuclear Safety and Licensing Engineer (1981 18682.)
Responsible for PVNGS 11:ensing and PVNGS safety in regard to meeting regulatory agency re-qui rements.
Chairman - PVNGS Safety Audit Committee (May 1982-Present)
Soyeawsea- Mo+ltu Safdy we Lemsy ( May 199L prewo+ )
Responsible for PVNGS licensing and PVNGS safety in regard to oeeting regulatory agency re-quirements.
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STATE OF ARIZONA )
) ss.
COUNTY OF MARICOPA )
VERIFICATION I, VAUGHN CRAWFORD, being duly sworn, depose and say that I am Counsel for Joint Applicants in the referenced action; l that I have read the foregoing answers to Interrogatories; that the information contained therein was gathered under my supervision; that said answers are based on information provided by Joint Applicants' experts; and that they are true to the best of my knowledge and to the best of the knowledge of the persons who helped in their compilation.
}
VA GHN CRAWFO.1D SUBSCRIBED AND SWORN to before me this 18th day of May, 1983.
NOTfRY PU %IC O, j My commission expires:
fly C:=.::.;;.. t ;:::: cQ : ,1:33 l
l l
a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
ARIZONA PUBLIC SERVICE ) Docket Nos. STN 50-529 COMPANY, et al. ) STN 50-530
)
(Palo Verde Nuclear )
Generating Station )
Units 2 and 3) )
)
- CERTIFICATE OF SERVICE I hereby certify that copies of " Joint Applicants' Response to West Valley Agricultural Protection Council, Inc.'s i
Sccond Set of Interrogatories Directed to Joint Applicants" have been served upon the following listed persons by deposit in the United States mail, properly addressed and with postage prepaid, I
this 18th day of May, 1983.
Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l Chairman, Maricopa County Board of Supervisors 111 South Third Avenue l
Phoenix, AZ 85004 l
l Atomic Safety and Licensing Appeal Board Panel O.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel i U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Robert M. Lazo, Esq.
Chairman, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555
1 Dr. Richard F. Cole Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Dixon Callihan Union Carbide Corporation P.O. Box Y Oak Ridge, TN 37830 Lee Scott Dewey, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Edwin J. Reis, Esq.
Office of the Executive Legal Director U.S. Nuclear Reguletory Commission Washingt.on, D.C. 20555 Lynne Bernabei, Esq.
Government Accountability Project Institute for Policy Studies 1901 Q Street, N.W.
Washington, D.C. 20009 Kenneth Berlin, Esq.
Suite 550 2550 M Street, N.W.
Washington, D.C. 20037