ML20082N936

Licensee Response to Petitioner First Set of Interrogatories.* Licensee Will Respond to Petitioner Request for Production of Documents Separately Per 10CFR2.741(d).Related Correspondence

ML20082N936
Person / Time
Site:	Palo Verde
Issue date:	08/28/1991
From:	Gutterman A ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR, NEWMAN & HOLTZINGER
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20082N939	List: ML20082N936 ML20082P027
References
CON-#391-12170 91-633-05-OLA-2, 91-633-5-OLA-2, OLA-2, NUDOCS 9109100121
Download: ML20082N936 (28)

Text

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/ 2/ 9'd

, DBATEOCOnnESPONDENCE Jet j UNITED STATES OF AMERICA '

NUCLEAR REGULATORY COMMISSION '91 TE 3() Pi;:15 BEPORE Tile ATOMIC SAFETY AND LICENSING BOARD -

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)

In the Matter of )

) Nos. 50-528-OLA-2, 50-529-OLA-2 ARIZONA PUBLIC SERVICE ) and 50-530-OLA-2 COMPANY, et al. )

) (Allowable Setpoint Tolerance)

(Palo Verde Huclear Generating )

Station, Units 1, 2 and 3) ) ASLDP No. 91-633-05-OLA-2 i

)

LICENSEES' RESP'ONSE TO PETITIONERS' FIRST SET OP INTERROGATORIES  ;

Arizona Public Service Company, et al. (Licensees) serve this, " Licensees' Response to Petitioners' First Set of Interregatories," in accordance with 10 CPR 2.740b(b). Licensees will respond to Petitioners' Requests for Production of Documents separately, in accordance with 10 CPR 2.741(d). While developing this response, Licensees have preliminarily noted that some of the requested documents are proprietary to Combustion -

i Engineering. Accordingly, Licensees will be in touch with counsel for Intervenors to discuss execution of an appropriate protective order.

I Petitioners' " general instructions" state that their discovery request is " deemed to be continuing" and demand that Licensees supplement their answers if they obtain new information. Licensees recognize their obligation to supplement in accordance with the requirements of 10 CPR 2.740(e), but 9109100121 910020 COL PDR ADDCK 05000520 .'/ v 9 PDR  ;

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, object to this instruction to the extent it seeks to create any  ;

additional duty.

Interrogatory 1:

i Identify each person Licensees intend to call as a witness in this proceeding. For each auch person, state the person's  :

name, address, telephone number, and professional qualifications; state whether the witness will be designated as an expert witness; and provide a summary of the witness's  ;

anticipated testimony in this proceeding.  ;

i Licensees' Response  !

Based on their current understanding of the issues, l Licensees have tentatively identified two potential witnesses, I i

both of whom are experts: l (1). Mr. Larry Chockie, 221 Condon Lane, Port Ludlow, WA 98365, telephone (206) 437-9529. Mr. Chockie has a degree in j Metallurgical Engineering and a Master of Science from the ,

Colorado School of Mines, and a degree in Electrical Engineering i

and Electronics from Texas A&M College. He is a member of the  ;

American bociety of Mechanical Engineers (ASME) and has served [

ASME in various capacities during his lengthy career in the j nuclear industry. It is expected that Mr. Chockie's testimony will describe the ASME Code-Inservice test requirements for 1 safety valves in nuclear power plants and the rationale for the test requirements. [

(2). Mr. Stephen J. Troisi, Supervisor, Safety Analysis, j Nuclear Fuel Management, APS, P.O. Box 52034, Sta. 1605, Phoenix, j AZ 85072-2034, telephone (602) 340-4079. Mr. Troisi has a degree f

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in Mechanical Engineering from Arizona State University and has j ten years professional experience in engineering. Mr. Troisi will testify that he supervised the conduct of the safety i evaluation described in the amendment application. It is

, f expected that Mr. Troisi will describe the analysis of the l effects of the proposed license amendment on the consequences of a loss of condenser vacuum event, and show that the analysis  !

i demonstrates that the amendment meets the NRC requirements applicable-to a loss of condenser vacuum and is in accord with nuclear industry practice for safety analyses. j l

l Interrogatory 2:  ;

l Identify all books, reports, papers, studies, analyses, i calculations and other documents that Licensees intend to  !

rely upon in this proceeding, whether for purposes of  ;

exhibits, direct examination, cross-examination, or for any  ;

other purpose. For each such document, identify the specific portions relied upon, summarize the purposes for which the >

document is relied upon, and produce the documents for i copying.  ;

Licensees' Response  ;

Based on their current understanding of the issues in f this proceeding Licensees expect to rely on the results of a  !

calculation performed by Arizona Public Service and reviewed by Combustion Engineering (APS calculation SA-PVl-CO3-89-26-00, <

"PVIC3 LOCV analysis for +3%/-3% tolerance change of MSSVs & ,

t PSVs" (October 24, 1989) (Proprietary)). The calculation may be j relied upon to demonstrate that the proposed license amendment, [

and particularly the proposed changes to setpoint tolerances for

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4 the Main Steam Safety Valves and Pressurizer Safety Valves meet the NRC acceptance criteria for a loss of condenser vacuum event.

The entire calculation-may be relied upon for this purpose. In addition,-Licensees may rely upon the NRC Standard Review Plan (NUREG 75/087) $5_15.2.1-5 and various ASME Code provisions and f most particularly Subarticle IWV 3500 and ASME Code OM-1.

Licensees also expect to rely on Letter No. 161-03907-WFC/MEP, from William F. Conway to NRC, " Supplemental Information to l!

Support proposed Technical Specification Amendment" (April 29, 1991). Documents identified in Licensees' responses to  ;

Interrogatories 3 and 9-may also be referenced in the testimony of one or more witnesses, or used in cross-examination to some f i

undetermined extent, depending upon Intervenors' basis for the j l

contention.

Licensees will respond to Petitioners' requests for ,

t production of documents separately, in accordance with 10 CFR 2.741(d).

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Interrogatory 3: t Regarding Licensee's November 13, 1990-Application for amendment of the Technical Specifications ("The Application"), the Palo Verde Updated Final Safety Analysis Report, or any of the references cited therein; identify all documents, books, reports, studies, analyses, calculations, ,

experts or other basis relied upon by Licensees in--support i of their_ position. )

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Licensees' Response:

The following were relied upon in support of Licensees'  !

position regarding the LOCV analysis reflected in the application for amendment, the PVNGS Updated PSAR, and the references cited [

thereint  ;

(1) Letter No. 161-03587-WFC/JST, from William P. Conway to NRC, f

" Proposed Technical Specification Amendment" (Nov. 13, 1990) f

(" Amendment Application").  !

(2) Combustion Engineering Standard Safety Analysis Report  :

(CESSAR), Okt. No. STN 50-470, through amendment 10. l.

(3) PVNGS Updated FSAR (UFSAR), Dkt. Nos. 50-528/529/530,  !

i through Revision 2.  !

(4) CEN-227, CC Owners Group, Nuclear Power Systems Division, j

" Summary Report on Operability of Pressurizer Safety Valves in C-E Designed Plants," at C C-12 (December 1982).

(5) Diablo Canyon Units l_t. 2, Dkt. Nos. 50-275/323, Licensee j Amendment Request No. 89-11, Attachment A, " Revision of Technical Specification 3.4.2.1, 3.4.2.2, Table 3.7-2 and j t

Associated Bases to Increase Setpoint Tolerances for Safety l

Valves" (September 6, 1989).

(6) CE Letter, No. REL-89-V-524, frtm Nils J. Breckenridge to Paul F. Crawley, "C-E Review of APS LOCV and PWB Analysis Calculation Packages" (October 18, 1989)(technical review conducted by Donald E. Uhl of CE and supervised by Nils J. (

i Breckenridge).  ;

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(7) Letter No. 226-00521-GWS, from Gerald W. Sowers to Paul F. }

Crawley, " Proposed Change in the High Pressurizer Pressure I Trip Response Time Value" (August 1, 1989) (analysis also [

reviewed by Allen W. Hartwig of APS). f (8) Letter No. 161-01969-ACR, from A. Carter Rogers to Paul F. '

Crawley, " Proposed Technical Specification Amendment on Main Steam Safety Valves and Pressurizer safety Valves Setpoint [

i Tolerance" (May 26, 1989) (John S. Taggart assisted in the [

preparation of this letter). l (9) DVNGS, LER 528-88-014-01 (April 25, 1989).

f (10) PVNGS, LER 529-89-002-00 (July 10, 1989). l (11) PVNGS, LER S29-89-007-00 (November 1, 1989). [

t (12) ABB/CE Proprietary Calculation No. 14273-TS-096, Rev. 00,  !

Asemios Malliakos & Wai Law, " Impact of the 'as-found' j Pressurizer and Steam Generator Valves Setpoints in the LOCV [

I analysis for PVNGS-1 Cycle 3" (May 23, 1989)

-i (proprietary)(reviewed by Suk K. Sim and supervised by Earl i J. Schulz).

t (13) ABB/CE Proprietary Calculation No. 14473-TS-044, Rev. 00, j Wai Law, "PVNGS-3 Cycle 2 Loss of Condenser Vacuum Analysis" }

j (May 2, 1989)(proprietary)(reviewed by Donald E. Uhl and .

i supervised Earl J. Schulz). j (14) ABB/CE Proprietary Calculation No. 14273-TS-083, Rev. 01, }

Wai Law, "Palo Verde-Unit 1 Cycle 3 CESSEC III Base Deck" ]  !

(April 23,-1989)(proprietary)(reviewed by Keane Hu and }

supervised by Earl J. Schulz). f

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i (15) James F. Church, REL-88-V-176, " Final PVNGS UIC3 Groundrules" (March 25, 1988).

(16) APS calculation SA-PV1-CO3-89-26-00, "

PV1C3 LOCV analysis l for'+3t/-31 tolerance change of MSSVs & PSVs" (October 24, 1989) (Proprietary)(calculation performed by Peri Shankar, j l

reviewed by Donald E. Uh1 (CE) and Kathleen C. Parrish, '

supervised by Stephen J. Troisi).

Interrocatory 4: )

i Identify the basis for I.,icensees' assumption of 0.5 seconds i for the high pressurizer pressure trip (HPPT) response time  !

in the Application. Include specific references to any i studies, reports, data, other documents, statements or l witnesses or expert opinion that support Licensees' i assumption.

Licensees' Response Licensees object to this interrogatory on the grounds that the information requested is not material to any issue in j t

this proceeding and therefore will be inadmissible, f

Additionally, none of the information requested is reasonably  !

calculated to lead to the discovery of admissible evidence. . ,

i Without waiving the foregoing objection, Licensees  !

voluntarily provide the following information in response to this request. The basis for the assumption was that the. proposed

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amendment to the Technical Specifications would require that the [

Licensees HPPT response time be no greater than 0.5 seconds.

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determined that it i s appropriate to base the safety analysis on f I

the. assumption that this parameter would be at the outer boundary ,

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of the proposed Technical Specification limit in the direction that is most conservative for the LOCV analysis. Since the pressures calculated in the analysis of a LOCV increase with inctemaing HPPT response time, Licensees determined that it would be acceptab3e and conservative to assume, for purposes of analyzing the postulated LOCV event, that the HPPT response time is 0.5 seconds, rather than the shorter respense time demonstrated in surveillance testing of the instruments. The Amendment request supports Licer sees' assumption.

Inter roca t" _., 5:

Statt 'w licensees will be able to comply with the proposed HPPT .sponse time of less than or equal to 0.5 seconds? If so, laentify all documents, books, reports, papers, studies, analyses, calculations, or expert opinions relied upon by Licensees in support of their position.

Licensees' Response:

Licensees object to this interrogatory on the grounds that the information requested is not material to any issue in this proceeding and therefore will be inadmissible.

Additionally, none of the information requested is reasonably calculated to lead to the discovery of admissibla evidence.

Without waiving the foregoing objection, Licensees voluntarily provide the following information: 1) in response to the first sentence of this interrogatory, curveillance ' asts for all three units have shown that this trip response time is consistently less than 0.5 seconds; and 2) in response to the second sentence, Licensees do not intend to rely on any documents

. or other information in support of this position because the assumption fo- the HPPT response time is not in icsue in this proceeding.

Interrogatory 6:

For each study, calculation, and analysis mentioned in response to these. Interrogatories, identify and produce for copying all documents that describe the assumptions, methodologies or results of such studies, calculations or analysis.

(1) .. Identify all persons who were-involved in conducting such studies, calculations or analysis and describe each such person's contribution thereto.

Licensees' Response:

Many of the studies, calculations, and analyscs identified in response to Interrogatories 3 & 9 include descriptions of their assumptions, methodologies or results.

Some of these documents also describe other studies, calculations, and analyses identified in response to Interrogatories 3.& 9. Additionally, Licensees have identified the following documents which directly describe the assumptions, methodologies or results of the studies, calculations and

. analyses identified in response to Interrogatories _3 & 9:

(1) . Letter No. 162-04141-PFC-PS, from Stephen J. Troisi to Thomas R. Bradish, " Pressurizer Safet) '

lves 'As-Found' Impact on Safety Analysis" (August 23, 1990).

I' (2)' Letter No. 162-04662-PFC/PS, from Peri'Shankar to Thomas R.

Bradish, " Impact of 'As-Found' Pressurizer Safety and Main

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Steam Safety Valve Set Point Openings for Unit 3, Cycle 2 on i Safety Analysis" (May 22, 1991).

(3) Letter No. 162-03236-PFC/PS, from Stephen J. Troisi to Timothy D. Shriver, " Pressurizer Safety Relief Valve Set ,

Points Out of Tolerance" (May 25, 1989). .

(4) CE Letter, No. REL-89-V-308, from James F. Church to Paul F.  ;

Crawley, " Impact of As-Found Safety Valve Setpoints" (May 23, 1989).  !

(5) Letter No. 162-03559-PFC/PS, from Paul F. Crawley to A. f Carter Ro[ers, " Proposed Technical Specification Amendment on Main Steam Safety Valve (MSSV) and Pressurizer Safety  ;

i Valve (PSV) Setpoint Tolerances" (October 30, 1989). [

(6) Letter No. 162-03474-PFC/PS, from Paul F. Crawley to James I F. Church (CE), "CE Review of APS' LOCV and FWLB P

Calculations" (September 25, 1989).  ;

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-(7) Letter No. 162-03768-PFC/PS, from Paul F. Crawley to A.

Carter Rogers, " Proposed Technical Specification Changes for HPPT Response Time, AFW Flow Rate, PSV and MSSV Tolerances" l (March 2, 1990).  ;

(8) 10.CFR 50.59 Review and Evaluation, initiate'? r- 'eri ,

Shankar (February 28 1991), reviewed by APL anto- Engineer Mathew J. Reid (March 2, 1991).

(9) Draft from files of Joseph R. Provasoli (Attachment 1)  ;

Safety Evaluation, For Purposes of Discovery, " Draft A", i (10) Draft from files of Joseph R. Provasoli (Attachment 2) i Safety Evaluation, For Purposes of Discovery, " Draft B".

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(11) Draft from files of Joseph R. Provasoli (Attachment *)

Safety Evaluation, For Purposes of Discovery, " Draft C".

(12) Letter No. 162-03967-PFC/PS, from Stephen J. Troisi to Thomas R. Bradish, " Impact of 'As-Found' Pressurizer Safety  ;

Valve Setpoint-Openings for Unit 2, Cycle 2 on Safety Analysis" (May 21, 1990).  !

(13) Letter No. 162-03236-PFC/PS, from Stephen J. Troisi to -

i Timothy D. Shriver, " Pressurizer Safety Relief Valve Set .

Points Out of Tolerance" (May 25, 1989). ,

(14) Letter No. 162-03559-PFC/PS, from Paul F. Crawley to A. P Carter Rogers, " Proposed Technical Specification Amendment ,

on Main Steam Safety Valve (MSSV) and Pressurizer Safety [

Valve (PSV)~Setpoint Tolerances" (October 30, 1989). i Licensees will respond to Petitioners' requests for prod 7ation of documents separately, in accordance with 10 CPR f

2.741(d). 7

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6(1). Persons involved in the referenced studies whose .

I involvement in those studies relates to the issues in this  ;

proceeding are-identified in the response that identifies the particular study, to the extent that the identity of such persons  !

is reasonably ascertainable. Unless otherwise noted, the persons- l identified are APS employees and their address and telephone number are: APS, P.O. Box 52034, Phoenix, AZ 85072-2034,  ;

telephone (602) 250-1000. The addree.s and telephone number for j i

E those persons identified as being employed by Combustion t

Engineering ~are: CE, 1000 Prospect Hill Road, P.O. Box 500, I W' -idsor , CT 06095-0500, telephone (203) 688-1911. The job titles of identified persons who are currently or formerly employed by i APS or CE are given in response to Interrogatory 8.

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Interrogatory 7:  ;

i For all data mentioned in response to Interrogatory 6, [

identify the source of such data and identify and produce for copying all documents that describe tbd time, place and '

method of collection of such data. ,

r Licensees' Response: l i

No data is requested by Interrogatory 6 and Licensees have not identified any data in response to Interrogatory 6. To the extent that data is included in the documents identified in Licensees' response to Interrogatory 6, 'e documente describe r

the source of such data and the time, place and method of l>

collection of such data, y r

Interrogatory 8: f

' Identify all persons who have personal knowledge of the basis for the Application.

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Licensees' Response:  !

Any persons who have reviewed the application, l i

including at least some members of NRC Staff, would have {

knowledge of the basis for the application. Licensees construe f l

the interrogatory as seeking the names of individuals with some j

. E additional source of knowledge beyond the application.  ;

The following individuals who have personal knowledge l of the basis for the application are currently employed by APS:  ;

NAME JOB TITLE  !

t Robert J. Adney Plant Manager, Unit 3 ,

Jack A. Bailey Director, Nuclear Engineering Jack N. Bailey Vice President, Nuclear Safety and ,

Licensing i i'

Richard A. Bernier Supervisor, Nuclear Licensing i

Engineering [

Thomas R. Bradish Manager,-Compliance )

William F. Conway Executive Vice President Nuclear ll Paul F. Crawley Manager, Nuclear Fuel Management l Ronald K. Flood Plant Manager, Unit 2 .f, I

Michael A. Friedlander Manager, Operations Engineering Allan W. Hartwig Senior Systems Engineer, Instrumentation {

and Control Systems l

William E. Ide Plant Manager, Unit 1 C i

James M. Levine Vice President, Nuclear Production I i

Gregg R. Overbeck Director, Site Technical Support j Kathleen C. Parrish Nuclear Safety Analysis Engineer III .

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f Michael E. Powell Manager, Nuclear Licensing ,

A. Carter Rogers Senior Technical Management Assistant  !

John A. Scott General Manager, Chemistry [

t Richard F. Shaller Assistant Plant Manager, Unit 1 l Peri Shankar Senior Nuclear Safety Analysis Engineer l l

Elbert C. Simpson Vice President, Nuclear Engineering  ;

Gerald W. Sowers Senior Technical Management Assistant t

Douglas N. Stover Manager, Business Planning I

John S. Taggart Senior Technical Management Assistant Stephen J. Troisi Supervisor, Nuclear Safety Analysis  ;

The following individuals who have personal knowledge of the basis for the application were formerly employed by APS:

f NAME- FORMER JOB TITLE  ;

s Robert A. Joyce Manager, Site Maintenance .;

Licensees believe that Mr. Joyce is currently employed at j San Onofre Nuclear Generating Station, San Clemente, CA.

His telephone number is (714) 368-9823.

William F. Quinn Director Nuclear Licensing Address: 16240 N. 62nd Place  ;

E Phoenix, AZ 85254 5 (602) 991-0713 l

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George T. Shell Manager, Quality Systems Licensees believe that Mr.-Shell is currently employed by Bechtel Power Corporation in the Peoples Republic of China.

His address and telephone number are unknown.

The following individuals have personal knowledge of studies, analyses, or calculations which formed the basis of the application and in this way may have personal knowledge of the basis for the application:

NAME JOB TITLE Nils J. Breckenridge Nuclear Fuels Project Manager, CE James F. Church Reload Project Manager, CE Keane Hu Principal Nuclear Engineer, CE Wai Law Formerly Senior Nuclear Engineer, CE Asemios Malliakos Formerly Consulting Engineer, CE Earl J..Schulz Senior Consulting Engineer, CE s

Philip A. Secker Formerly Nuclear Safety Analysis Engineer III,-APS APS believes that Philip-A. Secker's current job title, address and telephone number are Professor, Department of Nuclear and Energy Engineering, University of Arizona, Tucson, Arizona, tel: (602) 621-8794.

Suk K. Sim Consulting Engineer, CE Donald E. Uhl Principal Nuclear Engineer, CE

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Finally, the expert witnesses identified in response to ,

Interrogatory 2 also have personal knowledge of the basis _for the application.

Interrocatory 9:

Identify any studies, calculations, analyses or data, other than those referenced which show the effects of PSV setpoint drift on pressures resulting from a LOCV.

Licensees' Response:

Licensees have identified the following such information:

(1) APS calculation, SA-PVl-C03-89-19-00, " Impact of 'as-found' steam generator safety valve set points in the LOCV analysis for Unit 1 Cycle 3" (July 19, 1989) (Proprietary)(performed by Peri Shankar, reviewed by Philip A. Secker and supervised by Stephen J. Troisi).

- (2). APS calculation, SA-PV2-CO2-90-19-00, " Impact of 'as-found' Pressurizer Safety Valve Set Point Openings for the Unit 2 Cycle 1 and Cycle 2 in the LOCV Analysis," (August 23, 1990)

(Proprietary)(performed by Peri Shankar, reviewed by Kathleen C. Parrish,-and supervised by Stephen J. Troisi).

(3) APS calculation, SA-PV3-C02-91-014-00, " Impact of 'as-found' PSV and MSSV Openings for Unit 3 Cycle 2 LOCV Analysis"_(May 22, 1991) (Proprietary)(performed by Peri Shankar, reviewed by Kathleen C. Parrish, and supervised by Stephen J.

Troisi).

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Interrogatory 10: j For each study, calculation, and analysis mentioned in response to Interrogatory 9, identify and produce for  :

copying all documents that describe the assumptions, [

methodologies or results of such studies, calculations or -!

t analysis, (1). Identify all persons who were involved in conducting such studies, calculations or analysis and describe  :

each such person's contribution thereto.

Lic.?nsees' Response:  ;

Documents that describe the assumptions, methodologies i or results of the items identified in response to Interrogatory

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9, are identified in Licensees' response _to Interrogatory 6.

Licensees will respond to Petitioners' requests for production of i documents separately, in accordance with 10 CFR 2.741(d).

i 10(i). As stated in response to Interrogatory 6, j persons involved in the referenced studies whose involvement in those studies relates to the issues in this proceeding are identified in the response that identifies the particular study, i

to.the extent-that the identity of such persons is reasonably l, ascertainable. These-individuals are further identified in  ;

Licensees' response to Interrogatory 8. j r

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-Interrogatory ll:

I For all data mentionrd in response to Interrogatory 9, identify the source af such data, explain how the data shows -

the effects of PSV setpoint drift and identify and produce -

for copying all documents that describe the data and the time, place and method of collection of such data.

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Licensees' Response:

The response to Interrogatory 9 does not mention any data. To the extent that data is contained or referenctd in the calculations, the source, time, place and method of collection of such data are also indicated therein.

Interrogatory 12:

Have Licensees reviewed any LERs filed by Licensees regarding PSV or MSSV setpoints? If so, answer the following:

(A) Identify all such LERs reviewed by Licensees.

(B) Do any of those LERs show that a safety limit would have been exceeded in the event of a LOCV? If so, identify the specific LERs and the statements in such LERs that form the basis for such conclusion. 1 (C) Prodace for copying all LERs reviewed and/or identified.

Licensees' Response:

Yes. Every LER filed by Licensees is reviewed by Licensees, including the lei Licensees' Response:  !

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i Licensees will respond to Petitioners' requests for production of documents separately, in accordance with 10 CFR }

2.741(d).

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Interrocatory 24:

Separately for each response given to every one of these interrogatories, identify the person, other than counsel, responsible for providing the information for, or formulating such response and identify each document relied on in formulating such response.

Licensees' Response:

To the extent that documents were relied upon in formulating each response to these interrogatories those documents are identified in the respective response, except that with regard to Interrogatory 8, Licensees additionally relied upoti an internal Routing Slip attached to a file copy of the

-Amendment Application and--the Plant-Review Board's " Minutes of Meeting 90-45" (August 22, 1990).

The persons, other than counsel, responsible for providing the information for, or formulating responses to Interrogatories 3, 4, 6, 8, 9, 12, 16, 17, 18 are Richard A.

Bernier, Stephen J. Troisi and Peri Shankar. The persons, other than counsel, responsible for providing the information for, or formulating responses to Interrogatory 5 are Richard A. Bernier and Allan W. Hartwig. The persons, other than counsel, responsible for providing the information for, or formulating responses to Interrogatories 12, 13 and 14 are Richard A. Bernier and-Thomas R. Bradish. The persons, other than counsel, responsible for providing the information for, or formulating responses to Interrogatories 13 (2nd) and 15 are Richard A.

Bernier and William E. Webster. The person, other than counsel,

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t responsible for provjding the information for, or formulating responses to this Interrogatory is Richard A. Bernier.

Respectfully cubmitted l 4~---

Alvin 11. Gutterman Newman & Holtzinger, P.C.

1615 L Street, N.W.,  :

Suite 1000  !

Washington, D.C. 20036 .

(202) 955-6600 .

I Counsel for:

Arizona Public Service Company  ;

E Date: August 28, 1991 t

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