ML20073J884

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Affidavit of Rh Turner Re Use of Rept Analyzing Environ Effects of Seepage of Salt Water from Evaporation Ponds Into Aquifer Below Ponds.Rept Concluded Potential for Massive Environ Damage Existed.Certificate of Svc Encl
ML20073J884
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 04/11/1983
From: Turner R
HOURIHAN, P., NUS CORP.
To:
Shared Package
ML20073J870 List:
References
NUDOCS 8304190442
Download: ML20073J884 (25)


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EXHIBIT 1 UNITED STATES OF AMERICA NUCLEAR PEGULATORY CO N SION26 "

.g3 [f!!LO Before the Atomic Safety and Licensing Board 1

l In the Matter of- )

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ARIZONA PUBLIC SERVICE COMPANY, } Docket Nos. STN 50-528 et al.

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) STN 50-529 '

) STN 50-530 (Palo Verde Nuclear Generating )

Station, Units 1, 2 and 3) ) l

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AFFIDAVIT OF ROBERT H. TURNER I, Robert H.- Turner, being duly sworn, do depose and say:

1. For the period from January 1974 through May 1974, I was asked by Mohan Thadani and Larry Perez, both of the NUS Corporation, to manage the technical development of the project analyzing the environmental effects of the seepage of salt water from the evapo-ratien ponds into the aquifer below the ponds.

As technical project manager I coordinated field tests and

. mathematical analyses of the possible seepage from the evaporation ponds. I performed some of the mathematical analyses myself and coordinated the analyses of others.

! (In contrast, the " project manager" was the person responsible o@Ei for fulfilling the spirit and letter of the contract between the ant

.ff Ln NUS Corporation and NUS's client, the Arizona Public Service Company

'a u ("APS") to ensure that the work contracted for was completed in a er o8 satisfactory manner.)

SE Although the NUS Corporation organizational chart may not

'O list the position of " technical project manager," my line supervisor

a .

V assigned me to this ganctiot, apparently because he considercd me

eminently qualified to perform this work.
2. I never saw Dr. Goldman on the Palo Verde site. Nor did I at any time report directly to him. He may not have been aware of the extent of my responsibilities for this particular project.

-3. Paragraph 9 of Dr. Goldman's affidavit states that "Dr. Turner apparently misunderstood the objective of the studies and analyses he was directed to perform...."

I understood the objective of the project to be to : estimate and assess the environmental consequences of salt water infiltra g7-.

ans d any a s s oc iate s tion of the aquifer. AssuchthetechnicalanalysiswhichIfper-formed determined the design criteria for the evaporation ponds, and, additionally, the environmental harm which would occur if.the liner for the evaporation ponds failed.

After'we made the technical determination that there existed the potential for massive environmental damage, management made the ,

political decision not to publish the results of our analysis.

4. Dr. Goldman states in paragraph ll of his affidavit that "there was no purpose to be served by publication of [my] analyses since they were hypothetical in nature...."

If our analysis had indicated that there was no problem with seepage from the evaporation ponds into the aquifer, it is very likely that NUS would have published it.

V Further, our analysis assessed the environmental consequences of a failure of the lining. Since it is certainly possible for the liner to fail, APS should have considered these possible en-vironmental consequences in determining the environmental effects of the evaporation ponds.

o h 5. .The final summary of our analysis (see, Exhibit J to Turner Affidavit I) states that a soil lining is a_ viable option even though our analysis' determined that a soil lining was no better than no lining at all. Rt? lying on our analysis A?S could have informed the Nuclear Regulatory Commission as early as.1974 that a number of alternatives,were unacceptable because of the, serious environmental consequences which would occur if they were used.
6. In requesting that my name not be associated with this project, I spoke directly to Larry Perez, who was my supervisor and part of NUS Corporation management. Obviously I had no reason to speak to Dr. Goldman about the matter because as far as I knew

, he did not participate in this particular project in any way other than in top management overview.

7. According to Dr. Goldman, the Environmental Report-Construction Permit Stage, Section 3.6.3.2 states that the evapo-ration po'nd would be lined with a " suitable material to limit seepage to the groundwater." Goldman Affidavit, par. 10, at-4.

' This statement omits to mention the environmental con-sequences from a failure of the liner for the evaporation

. ponds.

It also does not state that both a soil liner and a concrete liner had been determined by our analysis to be insufficient to prevent contamination.

8. Neither Dr. Goldman nor the APS Environmental Report-OL addresses the question of whether salt will be removed from the evaporation ponds by dredging, or some other method. .If APS does f

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not remove the salt from the ponds, sooner or later the liners for the ponds will' fail and salt water from the ponds will-cause serious environmental damage. The only_ difference will be that this en-vironmental damage will occur at a time later than if no liner at all were used.

,~ ,~ ?fL ' XHI RO'BERT H. TURNER

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SUBSCRIEED AND SWORN TO before me this // day of A/A/L

, , 1983.

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Notary Public

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EXHIBIT 2 J' ' e,71

/l September 17, 1980 ANPP-16376-ACR/JSK Mr. Benson Scott h Chief Supervisor of Dam Safety Arizona Department of Water Res_ources 222 N. Central Avenue - 8th Floor R r r -- - --I Phoenix, AZ 55004 l 2 I N0

Subject:

Evaporation Pond f Palo Verde Nuclear Generating Sta1 iggCM . .g.,.w... ,,

CcmmlS3100 File: 80-003-028.6/CM-020

^

Reference:

ANPP-16339-ACR/JSK dated September 11, 1980

Dear Mr. Scott:

This letter transmits to you, the application for the approval of the plans and specifications for the construction of the evaporation pond at Palo Verde Nuclear Generating Station.

We have attached the following:

1) Application form with enclosed fee of $14,800
2) Drawings (2 copies) 13-C-ZVA-005,.,Rev. 1 ~

A0-C-ZVC-k53,"Rev. O A0-C-TBC-350, Rev. 1 AO-C-TBC-353, Rev. 0 *

. A0-C-TBC-355, Rev. 1

3) Construction Schedule (1 copy)
4) Engineers Report (2 copies)
5) Evaporation Pond Study (2 copies)
6) Specification 13-CM-020, Exhibit D, D-1 and D-2 (2 copies)

Additionally, please note that the evapor.. tion ponds do not chow a liner. The liner type has not been selected as of this date. We believe that this should not affect your review since the dikes are safe against piping and slope failure without considering the liner into the calculations. As an added feature of safety, we are pro-ceeding with the design of a toe drain to be placed on the higher slopes. We forecast submittal of the toe drain drawings during the weak of Sctober 6, 1980. Please inform us if the toe drain design will delay your review.

We are also now in the process of revising the reservoir drawings to show the existing elevation. We will enclose 1 copy of these drawings along witn the toe drain design.

e w o. Uctober 1/, Ag g J ~; '

'ANPP-16561-ACRrJSK Pcgo Two

~ Finally, we have enclosed our latest construction schedule. Please note we are now out f or bids and will mobilize by December 15, 1980.

J.

Should you have any additional' questions, please do not hesitate to call.

Very truly yourp ( - - '

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C - (_ . VCLLL O O_L rm' E. E. Van Brunt, Jr.

APS Vice President, Nuclear Projects ANPP Project Director

-.- EEVBJr/JSK/sb

Enclosures:

13-C-ZVC-069, Rev. 9 (3 copies)

A0-C-TBC-190, Rev. 5 (3 copies)

AO-C-TBC-191, Rev. 2 (3 copies)

A0-C-TBC-350, Rev. 2 (3 copies)

A0-C-TBC-353, Rev. 2 (3 copies) r,s A0-C-TBC-355, Rev. 2 (3 copies) 1 A0-C-ZVC-463, Rev. 1 (3 copies) g Specification 13-CM-020, Exhibit D, D-1 and D-2 (3 copies)

Construction Schedule (3 copies) cc: A. C. Rogers

.J. M. Allen D. B. Fasnacht W. L. Hurst J. R. Mann R. E. Kary W. H. Wilson W. G. Bingham D. B. Wood B. Ghadiali E. Euge.(Fugro)

L'. T. Klein (NUS) (w/ encl.-1 ccpy of dwg.)

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EXHIBIT 3

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, .' . ugh, Jerry Cox from Safety of I.f

..:. .;anders from APS.

.3-- ut for bids now. Bid award will be j w. ~ - nion should begin January 1, 1981.

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location map as part of the submittal, locating .:. derence to I-10. If one is available it

.will :20 pt .. . .

A :.; an da r d : . . : rent for new dam construction drawings is a

.s proille or ::w ntire dam, showing existing ground elevations, pro-

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' im::..; .): excavation and soil boring logs.

. APS has not prc*/:. ded . profile for Palo Verde Evaporation Pond. This is not

'[. . a " s t a n .: .i rd " dam, however. The dam is 2h miles long, encircling an offstream pond. Excavation for the foundation will be 5 feet

6.1 . into alluvial soils. Little variation is expected in foundation

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conditions along the entire length of the dam. Soil borings were ,

.9 made for the entire pond area and do not often coincide with the

dike alignment. APS feels that under these circumstances the
p b cross-sections provided give adequate information for construction

't and inspection of the dam.

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'I The inlet pipe will be constructed under specification 13-CM-335 ii '

which has not been submitted. APS will provide a copy of this specification and all other contract documents. It was noted that the energy dissipation structure is over-des'igned. APS was request-l ed to clarify whether the 954 gallons / minute / plant figure given in

( the Engineer's Report is a maximum discharcje from the outlet. The 3 answer, provided later by phone by Joe Kanovich, is that the maximum discharge will be 4500 GPM. APS will investigate the need for thrust blocks or other measures where the inlet pipe crosses the embankment. APS will also provide calculations showing that the inlet pipe is properly designed to handle patrol road traffic with less than one foot of cover.

It has been noted previously that agreement between the contours shown on the evaporation pond drawings and the USGS Quandrangle Map O

..; '(" Arlington", 15-minute series) is poor. APS has had the evaporc-tion' pond area surveyed, and in the surveyed area the USGS Map, the contours shown on the plans, and the new survey-match-reasonably

, well.-

As shown on the current drawings, there are gaps in the toe drains.

The toe drains should be provided along the entire length.of.the' downstream toe. Invert elevations should be given for the perforat-ed pipe used in the toe drains. Filter material in the toe drains should be compatible with the perforation size used in the drain

. pipe. Section 4.1 of the engineer's report says " cross-sections

, may be altered during construction to balance cut and fill." -This

.would refer to random fill only, the controlled embankment sections i will not be changed.

' Settlement markers along the dike. crest _ tied to a solid bench will h be' required. If evidence of seepage is discovered after impound-ment begins, installation of piezometers may be required in the embankment and at the toe.

Th'e drawings are contradictory c9ncerning the dimensions of founda-tion cuts. According to APS, the contract documents require a

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!' vertical cut from the toe of the dam to a minimum of 5 feet below

! existing. grade. Discussion: It will be difficult to get the g specified compaction along the vertical face. It is the contractor's

.- responsibility to provide the specified compaction. Do the specs call for special testing for the required compaction near the P embankment / foundation interface? APS will look into it.

, The shear parameters given on Page 8 of the Fugro Report are not substantiated by test data. Response: Fugro has provided a final i report with more,information. The data needed should be supplied by the new report.

k The Fugro Report recommends a maximum 6" to.8" compacted lift thick-it ness depending.on the equipment used.- The specifications require

!. a maximum uncompacted lift thickness. The specifications should-follow the. recommendations of the report, or else an explanation for not following the report should be given. APS will change the specifications.

/ Before construction begins, APS must supply Safety of Dams with

! additional information concerning the pond lining.- Question from APS: (Since the dam is designed to be safe even without the lining

. in pla'ce, why is Safety of Dams so interested in the lining?

L a I Response: The toe drain is one safety feature to guard against

piping,the lining is another s'.fety feature. Either might be L sufficient, but since both are being used, both should be properly

, constructed. ;,

Information required on the lining is:

1. Experience on the lining subcontractor.

p 2. Jointing pattern.

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Mothod of box dissipator lining termination at top of embankment ar..!

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4. Sequence or construction.
5. Method for holding the lining in place.

Drawings Numbered 00A-004 and 00A-005 should be included in the submittal.

Normally the owner's engineer is the owner's agent in contact w: .

Safety of Dams. For this project, the owner, APS , will be the : .i: r -

of Dams contact. Someone from Safety of Dams will attend the p:r-construction conference. APS was reminded that, according to t h.-

terms on the application, no foundation may be covered with mat. : : s.

for the dam until the Department of Water Resources has been c e. :.

the opportunity to inspect.

Additional Activity:

The site for the proposed Palo Verde Evaporation Pond was inspecir :.

APS transmitted a revised soils report and three copies of Drawi:::

No. FGD-1384C to be included with original submittal.

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MEMORANDUM TO: Files FROM: M.L. Arbaugh Mhb -

DATE: Decenter 1, 1980 EXHIBIT 4

SUBJECT:

Palo Verde Evaporation Pond (7-54)

General description and hazard classification.

Description. The proposed Palo Verde Evaporation Pond is an offstream lake formed partly by excavation and partly by con-struction of a perimeter embankment which entirely surrounds

- the excavation. The pond is rectangular in shape, approximately 3700 feet long by'3100 feet wide. Total length of the surround-ing embankment is approximately 2 miles. The height of the dam varies from 13 feet to 30 feet above existing ground. The crest has a constant elevation of 942 feet (datum mean sea level) . The reservoir has a surface area of approximately 250 acres, and a. storage capacity of approximately 5000 acre-feet at the maximum anticipated operating Javel, which is 3.5 feet below the top of the dam. Storage capacity is approximately 6000 acre-feet for water level at the top of the dam. Founda-tion for the embankment will be a minimum excavation of 5 feet into alluvial soils. Embankment material will come from the pond excavation. The upstream slope of the controlled embank-mont will be 3:1, downstream 2 :1. There will be an additional zone of random fn1 placed along the downstream face of the controlled fill,-and a toe drain installed at the toe of the controlled fill.

As implied by the name, the purpose of the pond is evaporation.

Highly saline wastewater from the power plant cooling towers, demineralizer, and domestic water system will be stored in the pond while evaporation takes place. Inlet flow will be entirely

, controlled. Water will enter the reservoir from a 12-inch re-inforced concrete pipe. The maximum anticipated inflow rate is 4540 gpm, or 10 cfs. This would give a maximum rise in reservoir water surface elevation of one inch per day. The pond will be provided with an impervious liner. There will be no outlet and no emergency spillway. Therefore all reductions in

water surface elevation will be due to evaporation.

In the case of the Palo Verde Evaporation Pond the lack of an outlet is justified by the following circumstances:

1. The impounded water will have an extremely high con-centration of dissolved solids (salts) . If problems I with the embankment do occur, lowering the reservoir water surface by drainage of the poor quality water l into a natural wash is not advisable.

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2. Wator flow into tho reservoir is entirely controlled and can be shut off at any time if necessary.
3. Maximum operating inlet flow is small, resulting in a very slow rise in reservoir level.

Hazard Classification. Although no design storm will be studied for this dam since it does not receive runoff, it is stall pru-dent to assign a hazard classification to the dam. Based on a height of 30 feet and a storage capacity of approximately 6000 acre-feet, this is a medium sized dam. (See Arizona Department of Water Resources Spillway Design Flood Criteria, Attachment 1) .

In the event of failure, drainage would be to the south along a local shallow wash, crossing a Southern Pacific Railroad track at about 3h miles, entering the Centennial Wash at about 4 miles, and then traveling the additional 4+ miles to the south-east along the Centennial Wash alignment to where the wash is apparently intercppted by the Arlington Canal. In the 1 miles through Arlington Valley from the Arlington Canal to the Gila River there are a number of buildings apparently residences.

These are located between 9 and 10 miles from the pond.

A breach would be expected to cause downstream damage to the railroad, roads and homes but loss of life is unlikely. Based on these observations the Palo Verde Evaporation Pond is given a moderate hazard rating.

Emergency Spillway. Because this is an offstream dam, an ;mer-gency spillway is not required. Only precipitation which falls directly on the pond will contribute to a rise in water level.

Since the surface area of the pond is nearly constant with depth, one inch of rainfall would result in a corresponding one-inch rise in' reservoir surface elevation. Probable maximum 72-hour precipitation in the area of the Palo Verde Evaporation

  • Pond is about 28 inches. Since the pond will be operated with a minimum 3.5 feet of freeboard, no overtopping would occur, even in the event of a PMP.
j rErosion Control. An energy dissipator box with surrounding gun-

! nite apron is more than adequate for the 10 cfs inlet flow. The i

pond floor and upstream face of the embankment will be protected

from seepage and wave action by the impervious liner. The soils i

report has identified a piping potential in the embankment material, so it is particularly important that the impervious liner function correctly. The toe drain should give some warn-

> ing if a leak does develop in the liner.

i Conclusions and Recommendations. If the operating procedures developed during the design stage are followed, the Palo Verde Evaporation Pond should be a safe structure without the usual safety features of an outlet at natural gound elevation and an l emergency spillway. To insure that operations are conducted in accordance with the original design assumptions it is recommended

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  • that a License of Approval to store water be issued subject

- to the following conditions: - .

1. . Maximum reservoir surface elevation shall be 3,5 feet below the top of dam.
2. The inflow rate shall not exceed 12 cfs.
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.'. , [t / SUPERVISION OF DAM SAFETY V INSPECTION OF DAM CONSTRUCTION EXHIBIT SA PROJECT P.V.N.G.S. Evaporation Pond (7-54) SHEET 1 of 1 CONTACTS Dick McGregor_ - APS Ken'Euge & Bill DuBois - Ertec Western IMPORTANT ACTIONS TAKEN:

Inspected the lining operation at pond bottom.

DESCRIPTION OF WORK:

The lining subcontractor ARC 0 has so far placed about 300 ft. of the asphalt rubberized lin-ing at the pond bottom at an average rate of 215 acres per day (about 3 lane x 10' = 30 ft.

width). Two trucks are being used now, another one may be brought soon.

COMMENTS:

It appears that with aging, the li'ning is 'already developing shrinkage cracks (alligator pattern). As can be seen in the photographs, these cracks start appearing 3 to 4 days after the placement. Probably because of the unusually hot weather, the lining is still too soft to walk on the surface. Hence it wouldn't be determined whether these cracks are rupturing the lining material or they are only surficial. I checked with Ken Euge and Bill DuBois on the finished thickness (after shrinkage) of the lining and was told the tests are indicat-ing the contractor is providing the specified thickness of 2/10". I believe that the contractor should be asked to recheck his mix design or make some more trial runs to accurately estimate the shrinkage factor and viscosity etc. It is important to correct the error at this stage since it will be difficult to run any equipment on the liner to make.

up for the deficiency. I have asked Dick McGregor of APS to discuss this matter with ARCO, Granite and Bechtel staff. -

Construction of the east. dike and the remaining halves of the north and south dikes is pro-

.gressing well.

Goodrich Co., the subconstractor for the upstream slope hypalon liner haven't showed up on the site as yet. They were supposed to have started on August 27, 1981. Their revised schedule is not known.

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.# U SUPERVISION OF DAM SAFETY t)

INSPECTION OF DAM CONSTRUCTION PROJECT P.V.N.G.S. Evaporation Pond (7-54) SHEET 1 of 1 CONTACTS Dick McGregor - APS IMPORTANT ACTIONS TAKEN:

Inspacted the plastic liner placement on the upstream face of the dikes.

DESCRIPTION 0_F WORK:

Placemcnt of the Hypalon plastic liner was started on Tuesday, September 15 and has been completed at the southwest corner so far. Approximately 3000 linear feet (along the crest)

. has been placed while 4 to 5 rolls (150'L x 76'W each) have been unrolled awaiting the loose ends to be anchored at the upstream toe and the crest. Because of the high wind v21ocity at the time of inspection, the contractor had suspended the placement for the rest of the afternoon. ,

Comments: ,

1. The liner ' appears to be sound and sturdy and quite satisfactory.
2. The jointing of the different sections and the 3 ft. overlap. is in accord-ance with tN specifications.
3. The rupture in the lining material noticed at few locations is patched up with sufficient overlap.
4. Termination of the liner at the downstream toe is not completed.
5. There are some questions about the contractor's methods of terminating the upper end of the liner on the upstream end of the crest. The construction drawings (which were reviewed and approved with the understanding that the liner will be placed according to the manufacturer's specifications) call for 12" deep trench, whereas the manufacturer's specifications require a minimum of 18" deep trench.

In my opinion, the trench depth giving a soil cover of 12" is not sufficient to prevent movement or the downward drag of the liner due to settlement, wave action and the hydro-static forces.

I discussed this with Dick McGregor at the site and Joe Kanovich (both of APS) after my return to the office and asked them to look into the matter before it is too late. To insure sufficient anchorage we would require that the manufacturer's specifications of the 18" minimum trench depth be followed. Further, the contractor is presently backfilling the trench without compaction. I suggested, 6" layers of uncompacted thickness should t;e hand tamped with proper care taken to protect the liner from damage. Joe Kanovich told me he will discuss these points with Goodrich and Bechtel staff and call me back.

I expect to visit the site again on Wednesday, September 23, 1981.

Wty_.

INSPECTED BY KM /GDC ON 9-18-81 PHOT 0S Yes

~

. P.V.H.G.S. Evap. Pond (7-54) .-

KMH & GDC/9-18-81

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s & 3R M Notice rupture,in the hypalon liner Similar rupture in the liner patched near the u/s toe. Location: South up. Location: Approx.150 feet west dike, near southwest corner, of Station 27+00, near southwest Station 27+00. ,

corner.

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l Hypalon liner placed on the upstream The hypalon liner being terminated slope of the south dike at the south- on the upstream side of the crest.

west corner. View from West Dike. Trench dimensions: 12" w x 12" d.

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~ ~ ~ ~ ' '

ENF SUPERVISION OF DAM SAFETY 45F J ,

l L INSPECTION OF DAM CONSTRUCTION EXHIBIT SC PROJECT P.V.N.G.S. - Evaporation Pond (7-54) SHEET 1 of 1 CONTACTS Dick McGregor - APS q Dick Anderson - Bechtel IMPORTANT ACT70NS TAKEN:

. Inspected the construction of the south and east dikes and also the lining operation at nor west portion of the dikes.

Discussed with Dick McGregor and Dick Anderson the discrepancy between the manufacturer's 1 specifications and the construction drawings on the required depth of trench to terminate t upper end of the hypalon liner near the upstream crest. It was finally agreed that Bechtel will issue the work stoppage notice (NCR) to the contractor and refer the problem to their design office in Downey, California to verify if the 12 inch depth of trench (as is being built according to the drawings) or the manufacturer's specifications requiring 18" depth

should be followed. The hypalon lining work was, as such, stopped from the afternoon of 9-23-81.

1 The lining of the pond bottom is continuing. With three trucks, the contractor is now 1 averaging about 7 acres (about 8 lane widths) .per day.

] The contract period ends tomorrow. Bechtel has recommended one month's extension to which APS has not agreed to date. There is no penalty clause in the agreement. ,

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INSPECTED BY . ' !H ON 9 81 PHOT 0S No

STATE OF ARILUNA P'-

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(_-) '

( ) SUPERVISION OF DAM SAFETY

. EDUfIBIT 5D ,

INSPECTION OF DAM CONSTRUCTION P.V.N.G.S. Evaporation Pond (7-54) SHEET.1 of 1

-PROJECT

- C0"-' CTS Dick McGregor - APS '
IMPORTANT ACTIONS TAXEN:

? . Discussed with Dick McGregor the controversy over the required depth of trench to bury the

-upper end of the hypalon liner on the crest. ,

l. DESCRIPTION OF._ WORK:

Inspected the dikes construction and excavation at the pond bottom. It appears 95% of the a: work- on these two items has been completed an,d the contractor is planning to wind up the cut and fill operations by next week (October 7th), however the lining work will continue

~

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- up to October 24, 1981. The APS has extended the contract by one month from Sept. 24th.

About one half of the pond bottom nas been laid with the rubberized asphalt liner and the work appeare.d satisfactory.

3

;. Hypalon liner has been placed on the entire west dike and a'pproximately one half each of the j- north and south dikes. There is still some confusion on the depth of trench required to 9  : terminate the upper end of the hypalon liner near the upstream crest. The manufacture's specifications require an 18" deep trench, whereas only 12" depth is shown.on the drawings.

l- Liner placement has been stopped until the Bechtel's Down,ey office completes the analysis

  • and investigation in view of the changed conditions of slope, friction value between the liner material and -the soil, etc.

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!J M 9-29-81 PHOT 0S No K.M. Hussain ON

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INSPECTED BY 1

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(

j, STATE OF ARIZONA j DEPARTMENT OF WATER RESOURCES

!.' DIVISION OF SAFETY OF DAMS l

EXHIBIT SE INSPECTION OF OPERATIONAL DAM NAME OF DAM P.V.N.G.S. Evaporation Dam DAM NO. 7-54 TYPE OF DAM Earth FREEBOARD ---

l Ft.

1 Varying from 1" to 3" STORAGE LEVEL at center of pondFt. ( ) Above bottom ( , ) Below SPILLWAY CREST CONTACTS Paul McNeere and Rich Badsgard - Nuclear Operations Support -

Arizona PuBlic Service Inspected the dikes and the inlet and outlet structures. There are no sign of cracks, settlement or holes at the crest. The upstream hypalon

, liner is in good shape. The asphalt liner at the pond's bottom was too cof t to walk at certain places probably due to heat and obsence of water.

Few small holes 1" to 2" in diameter were also observed in the bottom liner.

Gravel and cobbles rolling down the slopes penetrate through the soft sur-j face and are found to rip the liner. Suggested to the APS' staff that they thould put about 6" to 8" deep water to cool the surface and protect the j liner. The downstream slope was also inspected and found to be in good condition.

Comments:

lg 1. The dikes and the appurtenant works are in excellent condition.

No specific recommendations are made at this time.

t

2. All the required instruments (8 settlement markers and 10 neutron h moisture probes) have been installed at the crest.
3. I believe Bechtel hasn't yet officially transferred the pond to

} the Operations Support Group of the APS. As a result, the

$ staff is neither involved nor aware.if Bechtel is carrying periodic instrumentreadingsandthevisualinspectionasstatedin{pPS the 9 ,

  • APS' Operations Procedure Manual submitted for this project and D approved by the Department. We have been emphasizing in our j 'various meetings and letters to the APS that the settlement read-ings should be started immediately following the construction completion and the data sent to us on a regular basis. We haven't received any record of observation either from the APS or Bechtel

' so far. /

Inspected By: ~K.M. Hussain /'J //.

b Date of Inspection: 6-3-82

/,- W Ma*-

At his request a copy of this report was sent to Mr. Richard Badsgard of Date of Report: 6-4-82

. Nuclear Operations Support, APS on July 12, 1982. Photos: Yes XX No

o, d ack bNJS we

' 'Suggnat wa chould writo a letter cn nonittring of tha catt1cm::nt markers hasn' t started yct?

4. Discussed with thetheAPS to accurately measure inflowctnff into the thepond installation requireBecause d ofin the the flow mate of the space l ,

computation of the water budget. I told tion, it is difficult to put it inside the inlet box. j them that so long as it is properly protected, we don't have any ,

objection to installing it outside of the inlet box or wherever  :

convenient.

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  .       DEPARTMENT OF WATER RESOURCES                                                                   '
                                                                                                          ;YI /

99 E. Virginia Avinue, Phoxnix, Arizons 85004 i .. i - BRUCE BADBITT, Governor WESLEY E. STEINER, Director February 24, 1983

                                                                                                             . EXHIBIT 6 Arizona Public Service Company P.O. Box 12666                s Phoenix, Arizona 85036 Attention:       Mr. John Vorees, Manager Nuclear Operations Support Subj ect :        P.V.N.G.S.         Evaporation Pond Dam (07.54)

Dear Mr. Vorees:

Thank you for your letter of December 13, 1982 and the accompany-ing Affidavit of Total Construction Cost with the check in the amount of $7,135.00 to cover the balance of the application fee. We have reviewed our files and find that all the necessary documents have been submitted and are satisfactory to the Department. Enclosed is the License of Approval for the operation of the Palo Verde Nuclear Generating Station Evaporation Pond Dam and its appurten-ant works. 'The License is issued in accordance with the Arizona Revised Statutes, and the operation of the facility is subject to the conditions stated therein. Should any unusual or alarming circumstances develop that may adversely affect the safety of this dam or its appurtenant structures, please notify this office immediately. Sinodaly (

                                                                     ~$ $            ,  f DAN ROGER IA .R                 , M.E.

j Chief f Division of Safety of Dams 9

!         Enclosure 1

i Think Conservation! Of fice of Director 255-1554 l Admin.stration 255-1550, Water Resources and Flood Control Plonning 255 1566 Dom Safety 255 1541, Fivod worn.no Of f a.e 255 I">d8, Water Rights Adm n6t otum 2551581 H,drology 255 1586.

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ti Mty M M 3 M iMM M li imit im im M if WMW3 # 11 M"d im 11 C(Tit ti EEE iM LN ti MM 133 M Cli 74 h@'] 3 Q State of Ari:ona e Eg DEPARTNIENT OF WATER RESOURCES M Division of Safety of Dams h L- *

               ?

e LICENSE OF XPPROVAL A f R [~ Pursuant to Chapter 3. Title 45-Waters, cf the Ari:ona Revised Stattaes. the DIRECTOR. Department o' *i aver [T.3 P.V.N.G.S. EVAPORATION gj [d [ POND Dam and Reservoir. Application Number O.1.54 [ Resources authori:es the use of: Q c-Locatedin Sec. 3.. h.. 4. . Tp. - LS. .R. .6% . G. & S. R.B. & M. . Mar..t.copa .. County. Sta:e of'A r sto fn Y.D impound svater in accordance svish and subject to thefollmving terms and conditions: p [G 1. . The... permanent._ato. rage. shall not... exceed.. elevation.. 937. 50... feet. . . O ! r; ge b 2. Th e i n s trumen t s. proyided a.t. th is.. s.t rue.tur.e...shall...be...moni tored .. a t...the m d N [g - a, greed freguency., and. j;he..Aa.ta....b.e...Aent. to....the...Diyiaion...o.f... Safety...of. Dams . M r- 7) [ with the _ analyse.s. and. c.pn.glusions ,. .. r- This license of approval supersedes every previous ,onsent Jh' use V' y t- . l% h i issued by the State of Arizona relative to said dam and reserce tr Gk d

                                          ~,
           'hp k             -

k,k S.1 Witness my hand and seal of the Ari:ona Dep ~." nt [d

h. t 4rg.; ,

3 l 3} of it'ater Resources (( d

  • 3D 2.4th . day of _ February.. ,, , f p ,. e 1 h
                                                           *?                                                WESL            E. STEINER                                             N'
; \1
                $1                                       '

DIR ' OR R

      \           C

($ }E , J.' ' DAN ROGER L W A- $

         \       IC            hem.                                                                                                        N
                                                                                                                                        , ty of v_)ams. P.E No. .6.16 2..           p
         )       N               4f           *       '

By Chief. Divisto <(Se l'  : F !rDUUMR HlLRRH RW hi3UWJLiWJ11MMJULRERBMlJLH.HARJUL H.If 31RRRJLRRRBJll . 2

O

c. UNITED STATES OF AMERICA

, NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board i In the Matter of )

                                                      )

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

                                                      )                  STN 50-530 (Palo' Verde Nuclear Generating )

Station, Units 1, 2 and 3) )

                                                      )

l CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Supplanental Res ucidia of Intervenor Patricia Lee Hourihan to Joint Applicants' and NBC Staff's e tion to Strike Intervenor's E tion for Leave to File Response - have been served upon the following persons by deposit inithe United States mail, first class, postage prepaid, this 16th day < of April , 1983.

  • Docketing.and Service Section
  • Robert M. Lazo, Esq.

U.S. Nuclear Regulatory Chairman, Atomic Safety and Commission Licensing Board Washington, D.C. 20555 U.S. Nuclear Regulatory i Commission Chairman, Maricopa County Washington, D.C. 20555 Board of Supervisors 111 South Third Avenue Dr. Dixon Callahan i Phoenix, Arizona 85004 Union Carbide Corporation P.O. Box Y i *Dr. Richard F. Cole Oak Ridge, Tennessee 37830

,             Atomic Safety and Licensing Board                                                 .

U.S. Nuclear Regulatory

  • Atomic Safety and Licensing ,

' Commission Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory , Commission

  • Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board Panel U.S. Nuclear Regulatory Lee Scott Dewey, Esq.

Commission Office of the Executive Legal Director Charles A. Bischoff U.S. Nuclear Regulatory

3100 Valley Bank tenter Commission Phoenix, Arizona 84073 Washington, D.C. 20555

Rand L. Greenfield

                       ~

Kenneth Berlin Assistant Attorney General 2550 M Street, N.W. P.O. Drawer 1508 Suite 500 Santa Fe, New Mexico 87504-1508 Washington, D.C. 20037 Arthur C. Gehr, Esq. Snell & Wilmer 3100 Valley Bank Center Phoenix, Arizona 85073 S if ( i G~ A 2 -en- , LYNNE BERNABEI U

  • Served by deposit in the NRC Internal Mails.

O a l 4 I i

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