ML20073J112
| ML20073J112 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/15/1983 |
| From: | Bischoff C JOINT APPLICANTS - PALO VERDE, SNELL & WILMER |
| To: | WEST VALLEY AGRICULTURAL PROTECTION COUNCIL, INC. |
| References | |
| NUDOCS 8304190188 | |
| Download: ML20073J112 (64) | |
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UNITED STATESlOFrAMERICA 2
NUCLEAR REGULATORY COMMISSION 3' '83 N IO 4
BEFORE THE ATOMIC SAFETY'AND LICENSING BOARD g;: ~
6
)
7 In'the Matter of )
8
) Docket Nos. STN 50-529 ARIZONA PUBLIC SERVICE ) 50-530 COMPANY )
9
)
(Palo Verde Nuclear )
10 Generating Station, )
Units, 2 and 3) ) l u . 11 W Z a. )
- )! 12 E8 IE JOINT APPLICANTS' RESPONSE TO j
- j' 13 WEST VALLEY'S FIRST SET OF INTERROGATORIES a u
.n -
14 15 PREFACE AND GENERAL OBJECTIONS 16 17 1. CFR S2.740(b)(2) provides that a party may 18 obtain discovery of documents and other tangible things 19 otherwise discoverable and prepared in anticipation of liti-t 20 gation or for the hearing by or for another party's repre- i 21 sentative only upon a showing that the party seeking dis- !
22 covery has substantial need of the materials and is unable 23 without undue hardship to obtain the substantial equivalent 24 of the mateials by other means. Joint Applicants therefore 25 object to those interrogatories which request an identifica-26 tion of documents to the extent that such an identification i
t 8304190188 830415 ,
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4 1 would require the disclosure of documents not discoverable 2 under 10 CFR 52.740(b)(2), or documents subject to the 3 attorney-client privilege and/or the attorney work product 4 privilege.
5 2. Joint Applicants also object to those inter-6 rogatories which purport to require the identification with-7 out limitation, of individuals who " worked on or reviewed" 8 studies or analyses, or of all persons with knowledge of a 9 particular subject, on the grounds that such an all-10 encompassing identification would be burdensome and oppres-11 sive. Joint Applicants have, in response to such interroga-12 tories, identified those persons with the most knowledge of 13 the particular subject area.
14 3. Joint Applicants object to West Valley's 15 Instruction No. 18 to the extent it purports to alter the 16 applicable rules and regulations relating to the duty of a 17 party to supplement its responses. See, 10 CFR 62.740(e).
18 19 INTERROGATORY NO. 1 20 1. State the date on which Joint Applicants 21 forecast they will begin fuel loading of Unit 2 of the PVNGS 22 (hereinafter referred to as the "Date").
23 a) Identify the date on which it was deter-24 mined that the Date described was the target date for the
., 25 beginning of fuel loading for Unit 2 above.
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4 1 b) Identify all documents which relate or 2 refer to the setting of the Date.
3 c) Identify all documents which relate or 4 refer to whether: (i) the Date will be delayed beyond the 5 Date described above; and (ii) by how much the Date will be 6 delayed.
7 d) Identify all oral communications since 8 the Date was forecast relating or referring to whether or 9 not fuel loading will begin on the Date.
10 ANSWER 11 a) The presently scheduled fuel loading 12 date for Unit 2 is August, 1984. That date was determined 13 in July, 1982.
14 b) 1) Letter from Olan Parr to E. E Van 15 Brunt, Jr., dated May 25, 1976.
16 2) Letter from E. E. Van Brunt to 17 Director of Nuclear Reactor Regulation, NRC, dated Octo-18 ber 12, 1982.
19 3) Joint Applicants' Answer to West 20 Valley's Motion for Ruling on Contentions, etc. , dated Feb-21 ruary 14, 1983.
22 4) Letter from E. E. Van Brunt, Jr. to 23 T H. Novak, NRC, dated August 11, 1982.
24 c) None.
25 d) Discovery is continuing; Joint Appli-26 cants will supplement.
__ __a
i-1 4
1 INTERROGATORY NO. 2 2 2. Identify each person who, prior to the com-3 pletion of the EIS, worked on or reviewed any studies or 4 analyses relating or referring to the amount of salt drift 5 emitted from the PVNGS cooling towers (i.e., the quantity of 6 salt emitted and the drift droplet distribution) (herein-7 after referred to as cooling tower salt emissions), with:
8 i) NUS 9 ii) Bechtel 10 iii) Marley 11 iv) Joint Applicants 12 v) Any other entity 13 a) State the role and responsibility of 14 each person and organization identified above.
15 b) Identify all documents prepared prior to 16 the completion of the EIS-OS, including but not limited to 17 all reports and correspondence, relating or referring to the 18 cooling tower salt emissions.
19 20 ANSWER .
21 Interrogatory No. 2 seeks information relative to ,
22 the amount of salt drift " emitted from the PVNGS cooling 23 towers." Assuming that this Interrogatory is directed to-24 wards predicted emission data from the PVNGS towers, the 25 answer is as follows:
26 (i) (a) NUS:
l
4 1 1) George E. Fisher; developed and 2 applied the FOG code, which includes both mass emission rate 3 and droplet size distribution.
4 2) Philip M. Altomare; up to Nov. 1976 5 reviewed Fisher's work.
6 3) Henry Firstenberg; from Nov. 1976 7 to Nov. 1979 reviewed Fisher's work.
8 4) John H. Taylor; from Nov. 1979 to 9 , Mar. 1981 reviewed Fisher's work.
10 5) Morton I. Goldman; overall respon-11 sibility for PVNGS work.
12 (ii) (a) BECHTEL:
13 1) W. G. Bingham; Reviewed analyses.
14 2) D. G. Keith; Reviewed analyses.
15 3) R. R. Steins; Reviewed analyses.
16 4) S. H. Shepherd; Reviewed analyses.
17 5) V. Najarian; Reviewed analyses.
18 6) W. W. Boles; Reviewed analyses.
19 (iii) (a) MARLEY:
20 l) Ohler L. Kinney, Jr.; Project 21 Engineer; drift measurement and eliminator development.
22 2) Ivan F. Kuharic; Supervising Senior 23 Engineer; supervision, technical services on drift rating.
24 3) Paul A. Lindahl, Jr.; Senior Engi-25 neer; technical service on drift rating.
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1 4) Joyce D. Holmberg; Sciences Direc-2 tor; management of various drift-related activities.
t 3 5) J. B. Dickey, Jr.; Engineering
- 4 V.P.; divsion management.
5 6) W. V. McCoy; Regional V.P.; liason 6 with Bechtel and APS.
7 7) J. O. Kadel; V.P. - Sales; division 8 management.
9 8) R. K. Landon; Manager - Major Proj-10 ects; project manager, cooling tower contract.
1 11 9) A. R. Thompson; V.P. - Sales; divi-12 sion management.
13 (iv) (a) APS:
a 14 1) E. E. Van Brunt, Jr.; corporate 15 officer responsible for engineering, design, construction 16 and licensing of PVNGS; review / submit the required licensing 17 documents to the NRC, such as the Environmental Report,
- 18 which include results of such analyses.
19 2) John M. Allen; Nuclear Engineering 20 Manager for Electrical, Instrumentation / Control, and Li-21 censing Engineering; manage submittal of required licensing 22 documents to the NRC.
23 3) Don Karner; Senior Licensing Engi-24 neer; review submit licensing documents to N.R.C.
25 4) John R. Mann; Senior Health Physi-26 cist; review / submit licensing documents to NRC.
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1 2. b) 1) ER-CP 2 2) ER-OL 3 3) CP Hearing Record, testimony of M.
4 I. Goldman 5 4) Letter from D. Robb to W. V. McCoy, 6 dated July 8, 1975. Custodian: Bechtel.
7 5) Memorandum from G. Fisher to C. G.
8 Mattsson, dated Nov. 13, 1975. Custodians: NUS, Bechtel.
9 6) Letter from R. D. Landon to D.
10 Robb, dated October 8, 1975. Custodian: Bechtel.
11 7) Memorandum from W. G. Bingham to V.
12 Najarian dated October 20, 1975. Custodian: Bechtel.
13 8) Letter from W. V. Coane to Lawrence.
14 T. Klein, dated October 22, 1975. Custodian: Bechtel.
15 9) Letter from C. G. Mattsson to E. E.
16 Van Brunt, Jr., dated October 29, 1975. Custodian: Bechtel.
17 10) Letter from C. G. Mattsson to W. V.
18 Coane, dated October 31, 1975. Custodian: Bechtel.
19 11) Letter from C. G. Mattsson to W. V.
20 Coane, dated November 6, 1975. Custodian: Bechtel.
21 12) Inter-office correspondence from G.
22 Fisher to C. G. Mattsson, dated October 31, 1975. Custo-23 dians: Bechtel, NUS.
24 13) Letter from W. V. McCoy to Duncan 25 Robb, dated November 19, 1975. Custodian: Bechtel.
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o 1 14) Letter from C. G. Mattsson to M. V.
2 Coane, dated November 18, 1975. Custodian: Bechtel.
3 15) Inter-office correspondence from G.
4 Fisher to C. G. Mattsson, dated November 13, 1975.
5 Custodian: Bechtel.
6 16) Letter from C. G. Mattsson to W. V.
7 Coane, dated December 11, 1975. Custodian: Bechtel.
8 17) Letter from W. H. Wilson to E. E.
9 Van Brunt, dated December 19, 1975. Custodian: APS.
10 18) Letter from J. J. DiNunno to E. E.
11 Van Brunt, dated March 10, 1976. Custodian: Bechtel.
12 19) Letter from T. A. Ritter to W. H.
13 Wilson, dated December 19, 1978. Custodian: Eechtel.
14 20) Letter from Lawrence T. Klein to E.
15 E. Van Brunt, dated May 29, 1979. Custodian: Bechtel.
16 21) ER-OL four-party reviews of Sec-17 tions 2.3, 3. 3.4, 5.1, 5.3, 6.2. Custodian: Bechtel.
18 22) ER-CP four-party reviews of Sec-19 tions 3.3, 3.4, 6.2.5, 10.1, and 10.3. Custodian: Bechtel.
20 23) Service Request dated July 3, 1973, 1
21 from Major Projects, Marley Sales distribution for a Class 22 600 rectangular tower for Arizona Nuclear. Includes re-23 sponse dated July 16, 1973, from I. F. Kuharic. Custodian:
24 Marley.
25 24) Letter from Richard D. Landon to 26 William V. McCoy, dated July 17, 1973. Custodian: Marley.
o o
1 25) Inter-Office letter from J. O.
2 Kadel to J. B. Dickey, dated May 2, 1974. Custodian:
3 Marley.
4 26) Letter from Mark Margetts to J. D.
5 Holmberg, dated June 11, 1974. Custodian: Marley.
6 27) Letter from Mark Margetts to Joyce 7 Holmberg, dated September 10, 1974. Custodian: Marley.
t 8 28) Curve dated July 19, 1974, and 9 accompanying data sheets from the Marley Development Center.
10 Custodian: Marley. (Proprietary) i 11 29) Report dated September, 1974, by 1
12 Ronald O. Webb of Environmental Systems Corporation, " Forked 13 River Pre-Bid Qualification Test Utilizing Sensitive Paper 14 Drift Measurement for The Marley Company." Custodian:
15 Marley. (Proprietary) 16 30) Marley Engineering Change Notice 17 No. 6257, dated January 23, 1975. Custodian: Marley.
18 31) Marley Engineering Specification 19 No. 26214, Revision 1, dated January 23, 1975. Custodian:
20 Marley. (Proprietary) 21 32) Service request dated June 25, 22 1975, from Major Projects to Ratings Section requesting 23 alternate tower selections for Palo Verde using SDNA100 24 eliminators. Custodian: Marley.
25 . . . . .
26 . . . . .
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l 1 33) Telex dated July 8, 1975, from 2 W. V. McCoy to David Rand, Major Projects. Custodian:
L 3 Marley.
4 34) Memorandum from Paul Lindahl to
! 5 Dick Landon, dated September 11, 1975. Custodian: Marley.
6 35) Service request IP-1110, dated i 7 November 5, 1975, from Major Projects to Rating Section and 8 attached response from Paul Lindahl to Dave Rand. Cus-9 todian: Marley.
10 36) Letter from W. V. McCoy to Mr.
11 Duncan Robb, dated November 19, 1975. Custodian: Bechtel.
12 37) Product Description, Page 1, of 13 Palo Verde Proposal by Marley (no da i.e ) . Custodian:
14 Marley.
15 38) Contract Work Order No. 12-345-76 16 for the 16-fan round towers for Palo Verde. Custodian:
17 Marley.
18 39) Marley Engineering Specification 19 26214, Revision 2, dated March 14, 1978. Custodian:
20 Marley. (Proprietary) 21 40) Marley Engineering Change Notice 22 6275, dated April 6, 1978. Custodian: Marley.
-23 41) Change order No. 39 to Contract 24 Work Order No. 12-341-76, dated April 11, 1978. Custodian:
25 Marley.
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1 42) Marley Engineering Specification 2 26214, Revision 3, dated June 6, 1978. Custodian: Marley.
3 (Proprietary) 4 43) Letter from A. R. Thompson to Joe 5 Gosmano dated August 16, 1978. Custodian: Marley.
6 44) Inter-office letters dated Au-7 gust 16, 1978, from Joe Gosmano to D. W. Meeker and Wayne 8 Struchtemeyer. Custodian: Marley.
9 45) Letter from W. V. McCoy to W. G.
10 Bingham, dated September 21, 1978. Custodian: Bechtel.
11 46) Change Order #61 to Contract Work 12 Order No. 12-341-76, dated December 8, 1978. Custodian:
13 Marley.
14 47) Purchase Order Number 10407 15 MM-015, dated February 10, 1976, including all revisions 16 thereto, from Arizona Public Service Company to Marley.
17 Custodian: Bechtel. (Proprietary) 18 48) The following Marley drawings:
19 Drawing No. Date Title 20 75-41531F 9-29-77 Schematic Views-Class 700 Round Mechanical Draft Tower 21 75-41532H 10-10-80 Cross Section-Class 700 Round 22 Mechanical Draft Tower 23 78-41406L 3-3-81 SDV-75 (Polyvinyl Chloride)
Eliminator Pack Assembly 24 78-41786E 12-16-80 SDV-75 Eliminator Pack Instal-25 lation Class 700 Round Tower 26 - - - - -
1 78-41778C 3-9-82 Fill Beam Installation Class 700 Round Tower 2
78-41802B 5-22-81 Firewall Installation 3
4 Custodian: Marley. (Proprietary) 5 49) U. S. Patent No. 4,040,824, issued 6 August 9, 1977, " Dual Path Eliminator Structure and Method 7 for Crossflow Cooling Tower." Custodian: Marley 8 INTERROGATORY NO. 3 9 3. Identify each person who, since the EIS-OS 10 was completed, is reviewing or will review on behalf of 11 Joint Applicants the ER and the EIS as they relate or refer 12 to cooling tower salt emissions, with:
13 i) NUS 14 ii) Bechtel 15 iii) Joint Applicants 16 iv) Marley 17 v) Any other entity 18 a) State the responsibility and role of 19 each person identified in this interrogatory in reviewing 20 the ER and EIS as they relate or refer to cooling tower salt 21 emissions.
22 b) Identify all documents prepared since 23 the completion of the EIS-OS, including but not limited to 24 all reports and correspondence, relating or referring to 25 cooling tower salt emissions.
26 i
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l 1 ANSWER 2 (i) (a) NUS:
3 1) T. F. Iaccarino; Project Manager, 4 March 1983 to present; Responsible for direction and manage-5 ment of all technical work associated with the PVNGS.
6 2) M. Septoff; Principal Environmental 7 Meteorologist and Project Manager (July, 1982 to March 8 1983); Responsible _ for assisting in technical work asso-9 ciated with the cooling tower salt emissions.
10 3) M. I. Goldman; Senior Vice-11 President and Technical Director; Responsible for technical 12 direction and approval of all work associated with the PVNGS.
13 (ii) (a) BECHTEL:
14 1) W. G. Bingham; Review.
15 2) D. G. Keith; Review.
16 3) R. R. Steins; Review.
17 4) S. H. Shepherd; Review.
18 5) W. W. Boles; Review.
19 6) N. A. Blum; Review.
20 (iii) (a) APS 21 1) E. E. Van Brunt, Jr.; corporate 22 officer responsible for engineering, design, construction 23 and Licensing of PVNGS; review / submit ER to NRC; review EIS 24 as a result of ER submittals to identify any unresolved con-25 _cerns.
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s 1 2) A. C. Rogers; Nuclear Engineering 2 Manager; direct engineering and licensing activities of 3 Nuclear Engineering Department.
4 3) W. F. Quinn; Licensing Supervisor; 5 day-to-day interface with NRC Licensing Project' Manager 6 for licensing of PVNGS.
7 (iv) (a) MARLEY:
8 1) Ivan F. Kuharic; Supervising Senior 9 Engineer.
10 2) Ohler L. Kinney, Jr.; Project 11 Engineer.
12 3) Joyce D. Holmberg; Sciences 13 Director.
14 3. b) See Preface and General Objections, 15 paragraph 1.
16 1) Marley Telcon Memo, dated Septem-17 ber 29, 1982.
18 INTERROGATORY NO. 4 19 4. Identify each person who, prior to the com-20 pletion of the EIS, worked on or reviewed any studies or 21 analyses relating or referring to the amount of salt drift 22 emitted from the PVNGS spray ponds (i.e., the. quantity of 23 salt emitted and the drift droplet distribution) (herein-24 after referred to as spray pond salt emissions), with:
25 i) NUS 26 ii) Bechtel 1 iii) Marley 2 iv) Joint Applicants 3 v) Any other entity 4 a) State the role and responsibility of 5 each person and organization identified above.
6 b) Identify all documents prepared prior to 7 the completion of the EIS-OS, including but not limited to 8 all reports and correspondence, relating or referring to 9 spray pond salt emissions.
10 11 ANSWER 12 Interrogatory No. 4 seeks information relative to 13 the amount of salt drift " emitted from the PVNGS spray 14 ponds." Assuming that this Interrogatory is directed to-15 wards predicted drift emission data from the PVNGS ponds, 16 the answer is as follows:
17 (i) (a) NUS: No one 18 (ii) (a) BECHTEL:
19 1) W. W. Bingham; Review.
20 2) D. G. Keith; Review.
21 3) P. A. Barbour; Perform analysis.
22 (iii) (a) MARLEY: Not applicable 23 (iv) (a) APS: No one 24 4. b) 1) PVNGS PSAR; PVNGS FSAR; 25 2) Bechtel Proprietary Calculation 26 13-NC-SP-200.
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1 INTERROGATORY NO. 5 2 5. Identify each person who, since the EIS-OS 3 was completed, is reviewing or will review on behalf of 4 Joint Applicants the ER and the EIS as they relate or refer 5 to spray pond salt emissions, with:
6 i) NUS 7 ii) Bechtel 8 iii) Joint Applicants 9 iv) Marley 10 v) Any other entity 11 a) State the responsibility and role of 12 each person identified in this interrogatory in reviewing 13 the ER and EIS as they relate or refer to spray pond salt 14 emissions.
15 b) Identify all documents prepared since 16 the completion of the EIS-OS, including but not limited to 17 all correspondence, relating or referring to spray pond salt 18 emissions.
19 20 ANSWER 21 (i) (a) NUS:
22 1) Morton I. Goldman; evaluated drift 23 transport.
(a) BECHTEL:
24 (ii) 25 1) W. W. Bingham; Review.
26 2) D. G. Keith; Review.
o 1 3) W. W. Boles; Review.
2 4) P.A. Barbour; Review.
3 5) S. H. Shepherd; Review.
4 (iii) (a) APS: See response to Inter-5 rogatory No. 3(iii) (a).
6 (iv) (a) MARLEY: Not Applicable.
7 5. b) Joint Applicants are unaware at this 8 time of the existence of any documents described in this 9 Interrogatory which are not subject to the attorney-client 10 privilege, the attorney work-product privilege, or which 11 were not prepared in anticipation of this litigation. See 12 Preface and General Objections, paragraph 1.
13 INTERROGATORY NO. 6 14 6. Identify each person who, prior to the com-15 pletion of the EIS, worked on or reviewed any studies or 16 analyses relating or referring to the amount of salt drift 17 or dust emitted from the PVNGS evaporation ponds (i.e. , the 18 quantity of salt emitted and the particulate size distribu-19 tion) (hereinafter referred to as evaporation ponds salt 20 emissions), with:
21 i) NUS 22 ii) Bechtel 23 ii#) Marley 24 iv) Joint Applicants 25 v) Any other entity 26 - - - -
9 1 a) State the role and responsibility of 2 each person and organization identified above.
3 b) Identify all documents prepared prior to 4 the comoletion of the EIS-OS, including but not limited to 5 all reports and correspondence, relating or referring to 6 evaporation ponds salt emissions.
7 8 ANSWER 9 Interrogatory No. 6 seeks information relative to 10 the amount of salt drift " emitted from the PVNGS evaporation 11 ponds." Assuming that this Interrogatory is directed towards 12 predicted emission data from the PVNGS evaporation ponds, 13 the answer is as follows:
14 (i) (a) NUS:
15 1) Morton I. Goldman; Review.
16 (ii) (a) BECHTEL:
17 (1) W. G. Bringham; Review.
18 (2) D. G. Keith; Review.
19 (iii) (a) MARLEY: Not applicable.
20 (iv) (a) APS: None 21 6. b) 1) ER-CP.
22 INTERROGATORY NO. 7 23 7. Identify each person who, since the EIS-OS 24 was completed, is reviewing or will review on behalf of 25 Joint Applicants the findings in the ER and the EIS relating 26 or referring to evaporation ponds salt emissions, with:
1 i) NUS 2 ii) Bechtel 3 iii) Joint Applicants
- 4. iv) Marley 5 v) Any other entity 6 a) State the responsibility and role of 7 each person identified in this interrogatory in reviewing 8 the ER and EIS as they relate or refer to evaporation ponds 9 salt emissions.
10 b) Identify all documents prepared since 11 'the completion of the EIS-OS, including but not limited to 12 all correspondence, relating or referring to evaporation 13 ponds salt emissions.
14-15 ANSWER 16 (i) (a) NUS:
17 1) T. F. Iaccarino, performed re-18 analysis.
19 2) M. I. Goldman, review Iaccarino re-20 analysis 21 (ii) (a) BECHTEL:
22
- 1) W. G. Bingham; Review.
23 2) W. W. Boles; Review.
24 3) S. H. Shepherd; Review.
25 4) D. G. Keith; Review.
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1 (iii) (a) APS: See response to Inter-2 rogatory 3(iii) (a).
3 (iv)-(a) MARLEY: Not applicable.
4 7. b) See response to Interrogatory No. 5(b).
5 INTERROGATORY NO. 8 6 8. Identify all documents, including but not 7 limited to studies, reports and correspondence, which relate 8 or refer to alternative designs for the PVNGS (i) cooling 9 towers, (ii) spray pond and (iii) evaporation ponds which 10 would reduce salt emissions.
11 12 ANSWER 13 (i) 1) CP hearing record; 14 2) Memo, W. McCoy to D. G. Keith dated 15 January 30, 1976. Custodian: Bechtel.
16 3) Draft response to ASLB (CP) Ques-17 tion 10, dated February 4, 1976. Custodian: Bechtel.
18 4) Memo from P. Lindahl to D. Rand, 19 dated January 28, 1976.
20 5) See also items 23, 24, 32, 35, 36 21 and 47 listed in responce to Interrogatory No. 2(b).
22 (ii) and (iii): Joint Applicants are 23 not aware of the existence of any documents described in 24 Interrogatory No. 8 (ii) and (iii).
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9 1 INTERROGATORY NO. 9 2 9. State:
3 a) the basis for the choice in the ER of 4 the size distribution of salt drift droplets emitted from 5 the PVNGS ccoling towers; 6 b) whether that choice is consistent with 7 the salt drift droplet size distribution utilized by Marley; 8 c) if there is a difference, the basis for 9 the size distribution used in the ER.
10 11 ANSWER 12 a) The size distribution of the salt drift 13 droplets used in the analysis of the PVNGS cooling towers 14 was based upon data from Research-Cottrell, Inc. in 1971.
15 b) That size distribution is not the same 16 droplet distribution utilized by Marley.
17 c) See response to subpart (a) herein.
18 INTERROGATORY NO. 10 19 10. Identify:
20 a) all documents prepared prior to the com-21 pletion of the EIS relating or referring to the size distri-22 bution of salt emitted from the PVNGS cooling towers; 23 b) all such documents prepared after the 24 ccmpletion of the EIS; 25 c) each person with knowledge of the choice 26 of the salt drift droplet size distribution emitted from the 1 PVNGS cooling towers with (i) NUS, (ii) Bechtel, (iii) 2 Marley, (iv) Joint Applicants, and (v) any other entity.
3 4 ANSWER 5 No data exists, to our knowledge, relative to the 6 size of salt particles emitted from cooling towers. Fur-7 ther, this Interrogatory seeks information relative to tne 8 size distribution of salt " emitted from the PVNGS cooling 9 towers." Assuming that this Interrogatory is directed to-10 wards the predicted droplet size distribution data from the 11 PVNGS towers, the answer is as follows:
12 a) 1) ER-CP; 2) Marley Engineering Specifi-13 cation 26214, Revision 5, dated March 31, 1980. (Proprietary) 14 b) See response to Interrogatory No. 5(b).
15 c) (i) NUS:
16 1) G. Fisher 17 2) M. I. Goldman 18 (ii) BECHTEL:
19 (1) W. G. Bingham 20 (2) D. G. Keith 21 (iii) MARLEY: K. Martens 22 -(iv) APS: None 23 INTERROGATORY NO. 11 24 11. State the basis for statements by Joint Appli-25 cants in their response to West Valley's Petition to Intervene 26 that the evaporation ponds will at all times be covered by water.
1 ANSWER 2 With all three units operating, the rate of blow-3 down discharged to the svaporation ponds exceeds the evapo-4 ration rate from the evaporation ponds.
5 INTERROGATORY NO. 12 6 12. Identify each person who works for each of 7- the following companies with knowledge of the subject matter 8 referred to in Interrogatory ll:
9 i) NUS 10 ii) Bechtel 11 iii) Joint Applicants 12 iv) Marley 13 v) Any other entity 14 15 ANSWER 16 (i) NUS:
17 1) T. F. Iaccarino; 18 2) M. I. Goldman 19 (ii) BECHTEL:
20 1) W. G. Bingham; 21 2) D. G. Keith; 22 3) W. W. Boles; 23 4) S. H. Shepherd; 24 5) P. Su.
25 (iii) APS:
26 1) E. E. Van Brunt, Jr.;
1 2 ) A. C. Rogers; 2 3) W. L. Hurst 3 (iv) MARLEY: None 4 INTERROGATORY NO. 13 5 13. State:
6 a) the basis for the decision that spray 7 ponds would be used as the ultimate heat sinks for the 8 PVNGS; 9 b) wheth- and what alternatives to spray 10 ponds were taken into account for this purpose.
11 12 ANSWER 13 a), b) PVNGS is a desert site which constrains 14 the design and selection of an ultimate heat sink. .Possible 15 designs considered to meet the desert design criteria in-16 cluded cooling towers, spray canals, and spray ponds.
17 Bechtel's recent favorable experience with the design and 18 licensing of spray ponds as an ultimate heat sink for the 19 Rancho Seco station provided the basis for the selection of 20 Spray pond for PVNGS.
21 INTERROGATORY NO. 14 22 14. Identify each person who works for each of 23 the following companies with knowledge of the matter re-24 ferred to in Interrogatory 13:
25 i) NUS 26 ii) Bechtel 1 iii) Joint Applicants 2 iv) Marley 3 v) Any other entity 4
5 ANSWER 6 (i) NUS: None 7 (ii) BECHTEL: W. G. Bingham 8 (iii) APS: E. E. Van Brunt, Jr.
9 (iv) MARLEY: None 10 INTERROGATORY NO. 15 11 15. State whether it is your position that the ER 12 and EIS . fully evaluated salt drift quantity and deposition 13 Patterns from the spray ponds.
14 15 ANSWER 16 APS prepared the PVNGS-ER following the guidance 17 Provided by NRC's Regulatory Guide 4.2. The EIS is an NRC 18 document and as such the EIS evaluations are not subject to 19 APS control.
20 INTERROGATORY NO. 16 21 16. If your answer to Interrogatory 15 is yes, 22 state the basis for your contention and list each page in 23 the ER, EIS and hearing record which you believe supports 24 your position.
25 26 - - -
1 ANSWER 2 1) ER-CP, figure 3.3-1.
3 2) ER-OL, figure 3.3-1.
4 INTERROGATORY NO. 17 5 17. State:
6 a) the drift droplet size distribution ex-7 pected from the PVNGS spray ponds; and 8 b) the basis for this choice.
9 10 ANSWER 11 a) See figure 13-10407-M185-26-1-017 at-12 tached hereto and incorporated herein by reference.
13 b) Manufacturer's testing results.
14 INTERROGATORY NO. 18 15 18. Identify:
16 a) all documents prepared prior to the 17 completion of the EIS relating or referring to the droplet 18 size distribution of salt emitted from the PVNGS spray 19 ponds; 20 b) all such documents prepared after the 21 completion of the EIS; 22 c) each person with knowledge of the choice 23 of the droplet size distribution of salt emitted from the 24 PVNGS spray ponds with (..) NUS, (ii) Bechtel, (iii) Marley, 25 (iv) Joint Applicants, and (v) any other entity.
26 . . . . .
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}llll ]jl g DIAMETER OF DROFLETS MICROES
1 ANSWER 2 . Interrogatory No. 18 seeks information relative to 3 the amount of salt drift " emitted from the PVNGS spray 4 ponds." Assuming that this Interrogatory is directed towards 5 predicted emission data from the PVNGS spray ponds, the 6 answer is as follows:
.7 a) " Droplet Size Spectrum Tests Report for 8 2 pray Pond Cooling Nozzle," SPRACO, Inc.
9 b) See the response to Interrogatory 5(b).
10 c) '(i) NUS: M. I. Goldman 11 (ii) BECHTEL:
12 1) W. G. Bingham; 13 2) S. H. Shepherd; 14 3) W. W. Boles; 15 4) P. A. Barbour; 16 5) D. G. Keith 17 (iii) MARLEY: None 18 (iv) APS: None 19 (v) OTHERS: Arvind M. Shah; Vice Presi-20 dont in Charge of Engineering, SPRACO, Inc., Two East Spit 21 Brook Road, Nashua, New Hampshire 03060.
22 INTERROGATORY NO. 19 23 19. Identify each person who, prior to the com-24 pletion of the EIS, worked on or reviewed any studies or 25 analyses relating or referring to the quantity of salt drift 26 deposition deposited per acre as a function of distance from 1 the cooling towers (including, but not limited to, all per-2 sons who worked on or reviewed the FOG or other models of 3 salt drift deposition patterns) (hereinafter referred to as 4 salt drift deposition patterns), with:
5 i) NUS 6 ii) Bechtel 7 iii) Marley 8 iv) Joint Applicants 9 v) Any other entity 10 a) State the role and responsibility of 11 each person and organization identified above.
12 b) Identify all documents prepared prior to 13 the completion of the EIS-OS, including but not limited to 14 all reports and correspondence, relating or referring to the 15 salt drift deposition patterns.
16 17 ANSWER 18 (i) (a) NUS:
19 1) G. E. Fisher; developed and applied 20 the FOG code.
- 2) P. M. Altomare; up to Nov. 1976 re-21 22 viewed Fisher's work
- 3) H. Firstenberg; from Nov. 1976 to 23 24 Nov. 1979 reviewed Fisher's work.
- 4) J. H. Taylor; from Nov. 1979 to 25 26 Mar. 1981 reviewed Fisher's work.
i Hun
i 1 5) M. I. Goldman; overall responsi-2 bility for PVNGS work.
3 (ii) (a) BECHTEL:
4 (1) W. G. Bingham; Review.
5 (2) D. G. Keith; Review.
6 (3) S. H. Shepherd; Review.
7 (iii) (a) APS: See response.to Inter-8 rogatory 2(iv)(a).
9 (iv) (a) MARLEY: None 10 19. b) 1) ER-CP.
11 2) Memorandum from G. Fisher to C. G.
12 Mattsson, Nov. 13, 1975.
13 3) CP Hearing Record, testimony of M.
14 I. Goldman.
15 4) ER-OL.
16 5) See also response to Interrogatory 17 No. 2(b).
18 INTERROGATORY NO. 20 19 20. Identify each person who, since the EIS-OS 20 was completed, is reviewing or will review on behalf of 21 Joint Applicants the ER and EIS as they relate or refer to 22 salt drift deposition patterns:
23 i) NUS 24 ii) Bechtel 25 iii) Joint Applicants 26 iv) Marley
1 v) Any other-entity 2 a) State the responsibility and role of 3 each person identified in this interrogatory in reviewing 4 the ER and EIS as they relate or refer to salt drift deposi-5 tion patterns.
6 b) Identify all documents prepared since 7 the completion of the EIS-OS, including but not limited to 8 all reports and correspondence, relating or referring to 9 salt drift deposition patterns.
10 11 ANSWER 12 (i) (a) NUS:
13 (1) T. F. Iaccarino; 14 (2) M. I. Goldman.
15 (ii) (a) BECHTEL:
16 (1) W. G. Bingham; Review.
17 (2) D. G. Keith; Review.
18 (3) W. W. Boles; Review.
19 (4) S. H. Shepherd; Review.
20 (5) N. A. Blum; Review.
21 (iii) (a) APS: See response to Inter-22 rogatory No. 3(iii)(a) above.
-23 20. b) See response to Interrogatory No. 3(b).
24 . . . . .
'25 . . . . .
26 . . . . .
1 INTERROGATORY NO. 21 2 21. State:
3 a) The basis for the choice in the ER of 4 the " FOG" model- to describe salt drift deposition patterns.
5 b) The basis for the choice of the " FOG" 6 model-over other models which descibed salt drift deposition 7 patterns.
8 9 ANSWER 10 a) NUS had the responsibility for prepara-11 tion of the ER-CP, including analyses of drift deposition in 12 ER-CP and ER-OL. Since NUS had a proprietary model of its 13 own (" FOG"), that model was used for the required analyses.
14 b) See a) above.
15 16 INTERROGATORY NO. 22 17 22. Identify:
18 a) The person most familiar with the rea-19 sons why the FOG model was chosen over other models which
.20 describe salt drift deposition. patterns.
21 b) All documents which relate or refer to 22 why the FOG model was chosen over other models which de- ,
23 scribe salt drift deposition patterns.
24 25 ANSWER 26 a) Morton I. Goldman. l l
l b) None 2 INTERROGATORY NO. 23 3 23. Identify each person who,. prior to the com .
4 pletion of the EIS, worked on or reviewed any studies or 5 analyses relating or referring to the impact of salt drift 6 on agricultural crops grown in the vicinity of PVNGS (here-7 inafter referred to as " effects on crops"), with:
8 (i). NUS 9 (ii) Bechtel 10 (iii) Marley 11 (iv) Joint Applicants 12 (v) Any other entity 13 (a) State the role and responsibility of 14 each person and organization identified above.
15 (b) Identify all documents prepared prior to 16 the completion of the EIS-OS, including but not limited to 17 'all reports and correspondence, relating or referring to 18 effects on crops.
19 20 ANSWER 21 (i) (a) NUS:
22 (1) M. K. Bland; 23 (2) M. I. Goldman; 24 (3) Paul B. Morgan.
25 (ii) (a) BECHTEL:
26 (1) W. G. Bingham; Review.
O 1 (2) D. G. Keith; Review.
2 (iii) -(a) APS: See response to Inter-3 rogatories Nos. 2(iv)(a) and 3(iii)(a) above.
4 23. b) ER-CP.
5 INTERROGATORY NO. 24 6 24. Identity each person who, since the EIS-OS 7 was completed, is reviewing or will review on behalf of the 8 Joint Applicants the findings in the ER and EIS relating or 9 referring to effects on crops, with: 1 10 i) NUS 11 ii) Bechtel 12 iii) Joint Applicants 13 iv) Marley 14 v) Any other entity 15 a) State the responsibility and role of 16 each person identified in this interrogatory in reviewing 17 the ER and EIS as they relate or refer to effects on crops.
18 b) Identify all documents prepared since 19 the completion of the EIS-OS, including but not limited to 20 all reoorts and correspondence, relating or referring to 21 effects on crops.
22 23 ANSWER 24 (i) (a) NUS: M. I. Goldman 25 (ii) (a) BECHTEL:
26 - - - -
1 (1) W. G. Bingham; Review.
2 Review.
(2) D. G. Keith; 3
(3) N. A. Blum; Review.
4 (4) S. H. Shepherd; Review.
5 (5) R. R. Steins; Review.
6 (iii) (a) APS: See answer to Interroga-7 tory No. 3(iii)(a) above.
8 24. b) See response to Interrogatory No. 5(b).
9 INTERROGATORY NO. 25 10 25. State whether Joint Applicants have, since 11 the completion of the EIS-OS, undertaken or plan to under-12 take any studies of the effect of salt drift on agricultural 13 crops.
14 ANSWER 15 Yes.
1.6 INTERROGATORY NO. 26 17 26. If the answer to Interrogatory 25 is yes, 18 describe each such study, including but not limited to:
19 a) each plant which will be studied; 20 b) how the study will be conducted; and 21 c) the time period of each such study.
22 23 ANSWER 24 See proposal from the University of Arizona to 25 Snell & Wilmer, previously provided to West Valley, de-26 scribing the scope of the study, including the plants which e
I will be studied, the manner in which the study will be con-2 ducted, and the time frame within which the study will be 3 completed.
4 INTERROGATORY NO. 27 5 27. Identify each person with Joint Applicants 6 and each entity involved in each such study identified in 7 Interrogatories 25 and 26.
8 9 ANSWER 10 Joint Applicants object to Interrogatory No. 27 on 11 the grounds that it is vague and ambiguous. Specifically, 12 the term " involved" is susceptible to varying interpreta-13 tions. Without waiving that objection, Joint Applicants 14 respond as follows.
15 The study referred to in Interrogatory 26 is being 16 conducted by the University of Arizona, in consultation with 17 Dr. Charles Curtis of the University of Delaware, Dr.
18 Delbert McCune of the Boyce-Thompson Institute, and Dr. Leon 19 Bernstein, formerly of the U. S. Salinity Labs in Riverside, 20 California. No individuals employed by Joint Applicants are 21 involved in the conduct of the study.
22 INTERROGATORY NO. 28 23 28. If the answer to Interrogatory 25 is yes, 24 identify:
25 a) all documents relating or referring to 26 those studies; and l
1 b) all persons who have worked or will work 2 on those studies.
3 4 ANSWER 5 a) See proposal from the University of 6 Arizona.
7 b) See proposal from the University of 8 Arizona.
9 INTERROGATORY NO. 28A 10 28A. State whether Joint Applicants or any other 11 entity has prepared or is planning to prepare a " worst case" 12 analysis relating or referring to the effect of salt drift 13 deposition from the PVNGS on agricultural crops.
14 15 ANSWER 16 Joint Applicants position on the necessity for a 17 " worst case" analysis is fully set forth in their prior 18 pleadings on this matter.
19 INTERROGATORY NO. 29 20 29. Describe the program you ha' 0 'mlemented to 21 monitor salt drift from the PVNGS, including:
22 a) the date on which each monitor was in-23 stalled; 24 b) the location of each monitor; 25 c) the type of monitor; and 26 d) the data gathered by each monitor.
I 1 ANSWER:
2 The Salt Deposition and Impact Monitoring Plan for 3 PVNGS Units 1, 2 and 3, February 1983, describes the use of 6 4 existing low volume samples used for the station preoperational 5 Phase Radiological Monitoring. The samplers are in current use .
6 a) The six samplers were installed for 7 radiological monitoring between June and August, 1981 and 8 were operational by the end of 1981. Salt data has been 9 collected since October, 1982.
10 b) (1) See the Salt Deposition and Impact 11 Monitoring Plan for PVNGS Units 1, 2 and 3, February 1983.
12 (2) See ER-OL, Section 6.1.
13 c) The existing monitors are: Schmidt 14 Model 2-AXP-0.
15 d) Salt leachates are reported as mg/ total 16 sample for Calcium, Chloride, Fluoride, Iron, Magnesium, 17 Nitrogen (Nitrate as N), Phosphate (Total as P), Potassium, 18 Sodium, and Sulphate.
19 INTERROGATORY NO. 29A 20 29A. Describe the monitoring program you plan to 21 implement to determine the quantity of salt emitted from the 22 PVNGS and its impact on area agriculture, including, but not 23 limited to:
24 a) How you plan to monitor the salinity of 25 the drift emitted from the (i) cooling towers, (ii) spray 26 ponds and (iii) evaporation ponds.
i
1 b) How you plan to monitor the size and 2 quantity of the salt particles emitted from the (i) cooling 3 towers, (ii) spray ponds and (iii) evaporation ponds.
4 c) How you plan to monitor the salt drift 5 per acre as a function of the distance and direction from 6 the plant.
7 d) How you plan to monitor the impact of 8 salt drift from the plant on area agriculture.
9 e) What baseline monitoring studies, in 10 addition to those described in Interrogatory 29, you plan to 11 undertake prior to operation of PVNGS Unit 1 to determine 12 current salt conditions.
13 f) How you plan to monitor each of the 14 factors described in a-e over the life of the plant.
15 g) How you plan to verify the accuracy of 16 the monitoring and associated analysis used in determining 17 salt drift per acre as a function of the distance and direc-18 tion from the plant.
19 20 ANSWER 21 a)(i) The salinity of the drift emitted from I
22 the cooling towers will be detrmined by periodically 23 sampling the circulating cooling water in the cooling tower 24 basin.
25 . . . . .
26 . . . . .
, q l1
I 1
(ii) and (iii) There are no plans to monitor 2
salinity of the spray ponds and evaporation ponds for the 3
purpose of determining drift salinity.
4 b)(i), (ii) and (iii) There are no plans to 5
implement a monitoring program to monitor drift mass or 6
drift droplet size distribution or the size and quantity of 7
salt particles emitted from the cooling towers, spray ponds 8
or evaporation ponds.
9 c) See the Salt Deposition and Impact 10 -
y Monitoring Plan for the PVNGS Units 1, 2 and 3, February 11l 1983.
l 12 d) See the Salt Deposition and Impact l 13 i Monitoring Plan for the PVNGS Units 1, 2 and 3, February i 1983.
15 I l e) See the Salt Deposition and Impact 16 Monitoring Plan for the PVNGS Units 1, 2 and 3, February 17 1983.
18 f) See the Salt Deposition and Impact 19 Monitoring Plan for the PVNGS Units 1, 2 and 3, February 20 1983. The monitoring program will be conducted until the 21 impacts of plant operations are determined.
22 g) See the Salt Deposition and Impact 23 Monitoring Plan for the PVNGS Units 1, 2 and 3, February 24 1983.
26 i l
1 INTERROGATORY NO. 30 2
- 30. Describe each monitoring device you are using 3
or plan to use in monitoring the operation of PVNGS as de-4 i scribed in Interrogatories 29 and 29A, state why that device 5
was chosen over other devices, and identify all documents 6
that relate to the accuracy and reliability or each device.
7 O '
ANSWER 9
The basic monitoring devices which are being used l
\
10 l i or planned to be used are as follows: i 11 j 1. Dustfall Jars, Model 190-18 from Anderson c ,
12 Samplers, Inc. The jars are planned to be used to monitor l 13 for drift deposition density. These jars conform to ANSI-14 ASTM D 1739-70, " Standard Method for Collection and Analysis 15 h; of Dustfall (settleable particulates). This jar was chosen !
16 because it meets the requirements of the cited standard and n
j 17 its physical dimensions (6 inch diameter x 18 inch depth) are 10 most suitable for sampling in desert environment.
19
- 2. Low-Volume Samplers, from Schmidt, Inc. The 20 samplers were selected because they are currently in opera-21 tion as part of the APS radiological monitoring program.
22 The filters from the samplers will be used to determine 23 airborne salt concentration.
24
- 3. Camera, using Kodak aerochrome IR 2443 color 25 l infrared film and a minus-blue filter (or equivalent). This 26 camera film type was chosen because it will allow an assess-0
P 1
ment through the use of aerial infrared photography of any 2
vegetative stress due to natural or artificially induced 3
conditons and provide a documented historical: record of 4
existing environmental conditions.
5 INTERROGATORY NO. 31 6
- 31. Identify each person who works for:
7 a) WS 8
b) Bechtel 9
c) Joint Applicants 10 d) Marley 11 e) Any other entity 12 with knowledge of the monitoring prograus or monitors re-13 ferred to in Interrogatories 29, 29A and 30.
14 15 ANSWER 16 a) 1) T. F. Iaccarino 17
- 2) M. Septoff 18
- 3) M. I. Goldman 19 b) 1) W. G. Bingham 20
- 2) S. H. Shepherd 21
- 3) N. A. Blum 22 c) 1) E. E. Van Brunt, Jr.
23
- 2) A. C. Rogers 24
- 3) W. F. Quinn 25
- 4) J. R. Mann 26 d) None 1
e) 1) Charles Curtis; University of Dela-2
, ware, Newark, Delaware, 19711.
3
- 2) Delbert McCune; Boyce-Thompson 4
Institute, Cornell University, Tower Road, Ithaca, New York 5
14853, 6
- 3) Leon Bernstein; 2412 Deventry Road, ,
7 Riverside, California 92506.
8
- 4) See University of Arizona proposal 9
for others.
10 INTERROGATORY NO. 32 11
- 32. Identify each document which relates or 12 refers to the monitoring programs referred to in Interroga-13 tories 29, 29A and 30.
14 15 ANSWER 16
- 1. Salt Deposition and Impact Monitoring Plan 17 for the PVNGS Units 1, 2 and 3, February 1983.
18
- 2. ER-CP. -
! 19
- 3. ER-OL.
20
- 4. CP Hearing Transcript.
21
- 5. Transcript from ASLB Pre-Hearing Conference 22 on Application for Operating Licenses for PVNGS Units 1, 2 23 and 3, February 24, 1983.
24
- 6. Letter from Warren E. Platt to Robert M.
25 Lazo, Esq. et al., dated March 28, 1983.
26 1
L
INTERROGATORY NO. 33 2
- 33. State whether water desalinization was con-3 sidered as a salt drift mitigation strategy prior to the 4
completion of the EIS-OS.
5 ANSWER Water desalinization was not considered as a salt 8
drift mitigation strategy prior to the completion of the 9
EIS-OS.
10 INTERROGATORY NO. 34 11
- 34. If the answer to Interrogatory 33 is yes, 12 identify:
13 a) all documents which relate or in any way 14 refer to the use of salt desalinization as a salt drift I
mitigation strategy; 16 b) all persons with knowledge of the use of 17 salt desalinization as a salt drift mitigation strategy.
18-19 ANSWER 20 Not applicable.
21 INTERROGATORY NO. 35 22
- 35. State whether you are now considering or h6ve 23 considered since the completion of the EIS-OS water desali-24 nization as a salt drift mitigation strategy.
25 26 1
ANSWER 2
Water desalinization has not been and is not being 3
considered as a salt drift mitigation strategy.
4 INTERROGATORY NO. 36 5
- 36. If the answer to Interrogatory 35 is yes, 6
identify:
7 a) all documents which relate or in any way refer to the use of salt desalinization as a salt drift 9
mitigation strategy; and 10 b) each person who is involved with the 11
- consideration of this issue.
12 13 ANSWER 14
, Not applicable.
15 INTERROGATORY NO. 37 16 t
- 37. State whether blowdown treatment and water 17 recirculation were considered as salt drift mitigation 18 strategies prior to the completion of the EIS-OS.
19 20 ANSWER 21 Blowdown treatment and water recirculation were 22 not considered as salt drift mitigation strategies prior to 23 the completion of the EIS-OS.
24 INTERROGATORY NO. 38 25
?S. If the answer to Interrogatory 37 is yes,
'26 identify:
- -- . - - -~ . _
1 a) all documents which relate or in any way 2
refer to blowdown - treatment and water recirculation as a 3
salt drift mitigation strategy; and 4
b) each person who was involved with con-5 l sideration of this issue.
6" ANSWER 8
Not applicable.
9 INTERROGATORY NO. 39 10
- 39. State whether you are now considering blow-11 a
4 down treatment and water recirculation as a salt drift miti-12
! gation strategy.
13 14 ANSWER 15 Blowdown treatment and water recirculation are not 16 r now being considered as a salt drift mitigation strategy.
17 INTERROGATORY NO. 40 18
- 40. If the answer to interrogatory 39 is yes, 19 identify:
20 (a) all documents which relate or in any way 21 refer to the use of blowdown treatment and water recircula-22 tion as a salt drift mitigation strategy; and 23 (b) each person who is involved with the 24 consideration of this issue.
25 26 I
1 ANSWER 2-Not applicable 3
INTERROGATORY NO. 41 4
- 41. State whether prior to the completion of the 5
EIS-OS any off design conditions were taken into account in 6
evaluating the salt drift and salt drift related environ-7 mental effects from the PVNGS cooling towers, spray ponds 8
and evaporation ponds.
l 10 ANSWER ll
- Some off design operating conditions were taken '
12 ! .
l Into account.
13 INTERROGATORY NO. 42 14
- 42. If the answer to interrogatory 41 is yes, 15 describe each such effect considered and describe whether 16 and how each such effect influenced the evaluation in the 17 ER. If some off design operating conditions were considered 18 but not taken into account, explain the basis for that deci-19 .
slon.
20 21 ANSWER 22 Cooling tower operation was assumed to be con-23 tinuous for 12 months every year. This assumption led to 24 overestimation of the amount of salt drift from the cooling 25 towers. Circulating water chemistry concentrations were 26 assumed to exceed those expected at 15 cycles of concen-
1 1
1 tration. This assumption led to overestimation of the 2
salinity ot the salt drift from the cooling towers.
3 INTERROGATORY NO. 43 4
- 43. Identify all persons with knowledge of the 5
subject matter contained in interrogatories 41 and 42.
6 7
ANSWER 8
- 1) D. G. Keith; 9
- 2) W. W. Boles; 10
- 3) S. H. Shepherd; 11
- 4) R. R. Steins; 12
- 5) W. G. Bingham.
13 !
j INTERROGATORY NO. 44 14 I
- 44. State:
15 (a) the basis for the figures contained in 16 the ER and EIS on the salinity of the effluent to be used 17 for cooling at the PVNGS; 18 (b) whether you know if any water district 19 statistics indicate that the effluent can reach a higher 20 salintiy than indicated in the ER and EIS.
21 22 ANSWER 23 (a) The basis for the salinity figures is 24 chemical analyses performed on City of Phoenix sewage efflu-25 ent and demonstration testing at the Circulating Water Test
'6 Facility.
V l
1 (b) Joint Applicants are not aware of any 2
such statistics 3
INTERROGATORY NO. 45 4
- 45. If the answer to interrogatory 44(b) is yes, 5
state the basis for the decision to use the figures in the 6
ER and EIS.
7 8
ANSWER 9
Not applicable 10 INTERROGATORY NO. 46 11
- 46. Identify all persons with knowledge of the 12 l subject matter referred to in interrogatories 44 and 45.
13 j 14 ANSWER 15
- 1) W. G. Bingham; 16-I
- 2) D. G. Keith; 17
- 3) R. R. Steins; 18
- 4) W. W. Boles; 19
- 5) J. W. Kluesener; 20
- 6) S. H. Shepher.
21 INTERROGATORY NO. 47 22
- 47. Describe the maintenance plans for the PVNGS 23 cooling tower drift eliminators.
24 25 26 1
ANSWER 2
The maintenance plans for the PVNGS cooling towers 3
have not yet been written. APS intends to use the Marley 4
Cooling Tower Company's Operation and Maintenance Instruc-5 tions Manual as guidance for developing future APS plans.
6 INTERROGATORY NO. 48 7
- 48. Identify:
8 (a) all documents relating or referring to 9
PVNGS cooling tower drift eliminators; and 10 (b) all persons with knowledge of this sub-11 l ject matter.
12 13 ANSWER 14 Joint Applicants object to Interrogatory No. 48 on 15 the ground that it is overbroad, ambiguous, oppressive and 16
! burdensome; Joint Applicants further object to this Inter-17 rogatory to the extent it would require identification of 18 documents subject to work product and/or attorney-client 19 privilege. See Preface and General Objections, paragraph 1.
20 Without waiving those objections, the answer is as follows:
21 (a) See documents listed in response to 22 Interrogatory 2(b).
23 (b) Those persons listed in response to 24 Interrogatory 3(a) have the most knowledge of the subject 25 matter.
26 i
1 INTERROGATORY NO. 49 2
- 49. State whether the cooling tower vendor:
3 (a) makes or has made cooling towers of the 4
type being installed at PVNGS with a drift elimination 5
system that removes more salt from the drift than the system 6
being installed at PVNGS; and 7
(b)- can make cooling towers of the type 8
being installed at PVNGS with a drift elimination system 9
that removes more salt from the drift than the system being 10 installed at PVNGS.
11 12 ANSWER 13 Joint Applicants object to Interrogatory No. 49 on 14 the grounds that it is unintelligible. Drift elimination 15 systems do not remove salt from drift.
16 INTERROGATORY NO. 49A 17 49A. If your answer to interrogatory 49 is yes, 18 describe the drift elimination systems referred to in inter-19 rogatory 49, and state the basis for choosing the drift 20 elimination system used in the PVNGS cooling towers.
21 22 ANSWER 23 Not applicable -
24 25 26 1
INTERROGATORY NO. 50 2
- 50. Identify all documents relating or referring 3
to alternative cooling tower drift elimination system 4
designs.
5 6
ANSWER 7
See documents listed in response to Interroga-8 tories Nos. 2(b) and 3(b).
9 INTERROGATORY NO. 51.
10 !
- 51. Identify each person who works for:
11
, i) NUS 12 ii) Marley 13 l iii) Bechtel 14 iv) Joint Applicants 15 v) Any other entity
- 16 with knowledge of consideration of alternative cooling tower 17 drift elimination systems as well as the person at Marley 18 most familiar with Marley's cooling tower drift elimination 19 system.
20 21 ANSWER 22 (i) NUS: No one 23 (ii) MARLEY: Those persons listed in 24 response to Interrogatory 3(i)(a); J. D. Holmberg has the 25 most knowledge about Marley's cooling tower drift elimina-26 tion system.
1 (iii) BECHTEL: No one 2
(iv) APS: No one 3
INTERROGATORY NO. 52 4
g 52. State whether prior to the completion of the 5
EIS-OS Joint Applicants conducted or had conducted for them 6
any studies on the tolerance of crops grown within 10 miles 7
of the PVNGS to aerosol salt deposition.
8 9
ANSWER 10 There were no such studies conducted.
11 INTERROGATORY NO. 53 12
- 53. If your answer to interrogatory 52 is yes, 13 identify:
14 a) each such study; 15 b) each such crop studied; and 16 c) each person who worked on each such
, study.
18 19 ANSWER 20 Not applicable INTERROGATORY NO. 54 22
- 54. State whether prior to the completion of the 23 EIS-OS you had information in your possession relating or 24 referring to the tolerance to aerosol salt deposition of 25 crops grown within 10 miles of the PVNGS.
26
w 1
ANSWER 2
Joint Applicants and their consultants possessed 3
such information.
4 INTERROGATORY NO. 55 5
- 55. If your answer to interrogatory 54 is yes, 6
describe that information for each of the crops grown in the 7
vicinity of the PVNGS.
8 9
ANSWER 10 The information is contained in the ER-CP, Section 11 5.4.2, and in reference No. 35 to that section.
12 INTERROGATORY NO. 56 13 Identify each person whom the Joint Applicants ex-14 pect to call as an expert witness at the hearing (including, 15 without limtation, each such expert's full name, present 16 address, present employment or other professional affilia-17 tion, and qualifications.
18 19 ANSWER 20
- 56. Joint Applicants have not yet determined who 21 will be called as expert witnesses at the hearing. Joint
-22 Applicants will supplement this Interrogatory in accordance 23 with the applicable Rules and Regulations when such informa-24 tion becomes available. However, it is anticipated at this 25 time that Joint-Applicants may call the following as expert 26 witnesses at the ic' iring:
--- c- _
1 1) M. I. Goldman 2 2) Charles Curtis 3 3) Delbert McCune 4 4) Leon Bernstein 5 5) Ken Foster 6 6) W. G. Bingham 7 INTERROGATORY NO. 57 8 State the subject matter on which each expert 9 identified in the answer to interrogatory 56 is expected to 10 testify.
11 l
12 ANSWER l
i 13 !
l
- 57. 1) M. I. Goldman may testify about the 14 modeling procedures and calculations utilized in predicting 15 the mass emission rate and the droplet size distribution of 16 the cooling tower emissions and also the predicted deposi-17 tion patterns of the drift.
18 2) - 5) Drs. Curtis, McCune, Bernstein and 19 Foster may testify abot't the study described in the Univer-20 sity of Arizona crop study proposal previously provided to 21 West Valley.
22 6) W. G. Bingham may testify about the 23 engineering and design of PVNGS, including but not limited 24 to, salt drift source terms.
25 . . . . .
26 . . . . .
l l
1 INTERROGATORY NO. 58 2 58. State the substance of the facts and opinions 3 to which each expert identified in the answer to interroga-4 tory 56 is expected to testify and summarize the grounds for 5 each opinion.
6 7 ANSWER 8 58. M. I. Goldman may testify regarding the 9 amount of salt which Joint Applicants predict will or may be 10 deposited per acre as a function of distance from the site.
11 The remaining individuals listed in respol:se to Interroga-12 tory No. 56 have not completed the study referred to and 13 Joint Applicants are therefore unable to provide the sub-14 stance of the facts and opinions to which they may testify.
15 INTERROGATORY NO. 59 16 59. With respect to each opinion set forth in the 17 answer to interrogatory 58, identify each document which the 18 expert rendering the opinion based his opinion upon, or has 19 relied upon in forming his opinion, or will rely upon during 20 the hearing, testify to, or otherwise claim to support his 21 Opinion.
22 23 ANSWER 24 59. Unknown at this time. Joint Applicants will 25 supplement the Interrogatory in accordance with the appli-26 - - - -
l
1 .
cable Rules and Regulations when such documents have been ,
2 identified.
3 INTERROGATORY NO. 60 4
- 60. Identify each person who prepared answers to 5
these interrogatories and the interogatories on which each 6
such person worked.
7 8
ANSWER 9
Joint-Applicants object to Interrogatory No. 60 on 10 the grounds that such information is irrelevant and non-11 l discoverable.
12 i 13 14 1
15
/f[r day of April, RESPECTFULLY SUBMITTED this 16 1983.
17 SNELL & WILMER 18 By d /
20 Arthur C. Ge fh' //1 21 Warren E. Platt Charles A. Bischoff
/ L' Vaughn A. Crawford 22 3100 Valley Bank Center Phoenix, Arizona 85073 23 Attorneys for Joint Applicants 24 25 26 VAC/20/B o
O IDENTIFICATION OF APS PERSONNEL (Current Titles)
Name/ Address Title E. E.' Van Brunt, Jr. APS Vice President, Arizona Public Service Company Nuclear. Projects Management P.O. Box 21666 Mail Station 3003 Phoenix, Arizona 85036 J. M. Allen PVNGS Technical Support Arizona Public Service Company Manager P.O. Box 21666 Mail Station 6130 Phoenix, Arizona 85036 Donald B. Karner Manager, Four Corners Arizona Public Service Company Fossil Generating Station P.O. Box 21666 Mail Station 4900 Phoenix, Arizona 85036 William F. Quinn Nuclear Safety and Arizona Public Service Company Licensing Supervisor P.O. Box 21666 Mail Station.3003 Phoenix, Arizona 85036 A. Carter Rogers Nuclear Engineering Manager Arizona Public Service Company P.O. Box 21666 Mail Station 3003 Phoenix, Arizona 85036 J. R. Mann Corporate Health Physicist Arizona Public Service Company and Emergency Planner P.O. Box 21666 Mail Station 1742 Phoenix, Arizona 85036 W. .L. Hurst Civil Engineering Supervisor Arizona Public Service Company
.P.O. Box 21666 Mail Station 3003 Phoenix, Arizona 85036
W i
IDENTIFICATION OF BECHTEL PERSONNEL Position at Time Name/ Address Current Position in Question William G. Bingham Project Engineering Project Engineer Bechtel Power Manager Corporation (BPC)
P.O. Box 60860 Terminal Annex Los Angeles, CA 90060 Dennis G. Keith Assistant Project Nuclear Group BPC Engineer Supervisor 4
Robert R. Stiens Project Engineer Assistant Project BPC Engineer Peter Su Engineering Geotechnical BPC Specialist Specialist Paul A. Barbour Nuclear Group Engineering BPC Supervisor Specialist William W. Boles Deputy Group Mechanical BPC Supervisor Engineer Stephen H. Shepherd Deputy Group Nuclear Engineer BPC Supervisor Nora A. Blum Group Leader '
BPC Vasken Najarian Assistant Project Mechanical Group BPC- Engineer Supervisor
{
John W. Kluesener Project Engineer Assistant Project l
Bechtel Civil and Engineer, Process Minerals, Inc. Engineer i
- 50 Beale Street San Francisco, CA 94105 y----.- -. .- u , .-- r -
,--e. -
,e
IDENTIFICATION OF NUS PERSONNEL Position at Time Name/ Address Present Position in Question Morton I. Goldman Senior Vice President, V.P., Environmen-NUS Corporation Technical Director tal Safeguards 910 Clopper Road Division; Senior Gaithersburg, MD 20878 V.P., Environmen-tal Systems Group
~
George E. Fisher Unknown Environmental 3175 Rt. 94 Meteorologist Woodbine, MD 21797 Marilyn K. Bland Unknown Staff Ecologist 378 Cambridge Ave.
Suite K Palo Alto, CA 94306 Ronald R. Stoner Manager, Atmospheric Same NUS Corporation Sciences Department, 910 Clopper Road Environmental Services Gaithersburg, MD 20878 Division Thomas F. Iaccarino NUS ANPP Project Air Quality Analyst i NUS Corporation Manager 910 Clopper Road Gaithersburg, MD 20878 Philip M. Altomare Nuclear Regulatory Manager, Air 4409 Cambria Ave.
Commission Quality Assess-Garrett Park, MD 20766 ments - through November 1976 John H. Taylor Retired Manager, Meteoro-Box 145 logical Programs Solomons, MD 20688 Department -
November 1979 -
March 1981 Henry Firstenberg Senior Executive Manager, Air NUS Corporation Analyst Quality Assessments, 910 Clopper Road November 1976 -
, Gaithersburg, MD 20878 November 1979 Michael Septoff Assistant Manager, Project Meteorolo-NUS Corporation Atmospheric Sciences gist, ANPP Project 910 Clopper Road Department Manager Gaithersburg, MD 20878
o Position at Time Name/ Address Present Position in Question Terry A. Ritter Deputy Regional NUS ANPP Project NUS Corporation. Project Manager, Manager, 1980-81 Raritan Plaza III, NUS Superfund King George Road Division Edison, NJ 08837 Lawrence T. Klein Manager, Southwest NUS ANPP Project NUS Corporation Regional Operations Management, 1972-14011 Ventura Blvd. 1980 Sherman Oaks, CA 91423 Joseph T. DiNunno Vice President, Major Vice President, NUS Corporation Projects Division Environmental 910 Clopper Road (retiring 4/15/83) Safeguards Gaithersburg, MD 20878 Carl G. Mattsson Unknown Coordinator Mobil Oil Corporation Environmental Mining and Coal Div. Studies, Western P.O. Box 17772 area, Environmental Denver, CO 80217 Systems Group Paul B. Morgan Unknown' Vice President, (unknown) Ecological Sciences Division P
O IDENTIFICATION OF MARLEY PERSONNEL Position at Time Name/ Address Present Position in Question Ohler L. Kinney, Jr. Senior Design Project Engineer 5800 Foxridge Dr. Consultant and Senior Mission, KS 66202 Engineer Ivan F. Kuharic Supervising Senior Same 5800 Foxridge Dr. Engineer Mission, KS 66202 Paul A. Lindahl, Jr. Project Engineer Senior Engineer 5800 Foxridge Dr.
Mission, KS 66202 Joyce D. Holmberg Sciences Director Supervisory Con--
5800 Foxridge Dr. sultant and ,
Mission, KS 66202 Sciences Director Joe Ben Dickey, Jr. hetired Engineering Vice 2900 W. 53rd President Fairway, KS William V. McCoy Regional Vice President, Same 217 West Las Tunas Western Marketing Area San Gabriel, CA 91778 J. O. Kadel Executive Vice Presi- Vice President, 5800 Foxridge Dr. dent, International Sales Division Mission, KS 66202 Operations Richard D. Landon Executive Vice Presi- Manager - Major 5800 Foxridge Dr. dent, Domestic Projects Mission, KS 66202 Operations' A. R. Thompson Senior Vice President, Vice President,
, 5800 Foxridge Dr. Sales Division Sales Division Mission, KS 66202
O 1
STATE OF ARIZONA )
) ss.
2 COUNTY OF MARICOPA) 3 CHARLES A. BISCHOFF, being first duly sworn upon 4
his oath, deposes and says:
5 That he is one of the attorneys for Arizona Public 6
Service Company in the foregoing entitled and numbered matter, 7
that he has read the above and foregoing Answers to West Valley's 0
First Set of Interrogatories and knows the contents thereof; 9
that all of the matters and things therein contained are true 10 to the best of his knowledge and belief, except those matters 11 alleged upon information and belief, and as to those, verily 12 believes them to be true.
13 14 g j(( [j, ((
,, Char 1es A. ey gj 16 g
SUBSCRIBED AND SWORN to before me this /I day of 18 ^E' '
- 20 C ttis 1. d y e,yy pu311c y 21 l My Commission expires:
2 23
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24 25 ,
l 26 l l
l
O f #$
00)(7.' ~ ,
UNITED STATES OF AMERICA "
NUCLEAR REGULATORY COMMISSION QW' gg16 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD , g,.q;':g i ,, +
In the Matter of )
)
ARIZONA PUBLIC SERVICE ) Docket Nos. STN 50-528 COMPANY, et al. ) STN 50-529
) STN 50-530 '
(Palo Verde Nuclear )
Generating Station, )
Units 1, 2 and 3) )
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Joint Applicants' Response to West Valley Agricultural Protection Council, Inc.'s First Set of Interrogatories" have been served upon the following listed persons by deposit in the United ' States mail, properly addressed and with postage prepaid, this 15th day of April, 1983.
Docketing and Service Section U.S. . Nuclear Regulatory Commission Washington, D.C. 20555 Chairman, Maricopa County Board of Supervisors 111 South Third Avenue Phoenix, AZ 85004 Atomic Safety and Licensing Appeal Board Panel
~
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel 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
e uf 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 Regulatory Commission Washington, 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 c/' + /&
Charles M sefloff