ML20126E300

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Transcript of 850611 Hearing in Phoenix,Az Re OL Proceeding. Pp 2,894-3,090
ML20126E300
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 06/11/1985
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NRC COMMISSION (OCM)
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References
CON-#285-501 OL, NUDOCS 8506170040
Download: ML20126E300 (200)


Text

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UN11ED STATES NUCLEAR REGULATORY COMMISSION U,.

IN THE MATTER OF: DOCKET NO: STN-50-529-OL STN-50-530-OL -

OPERATING LICENSE PROCEEDING ARIZONA PUBLIC SERVICE COMPANY, et al.

PALO VERDE NUCLEAR GENERATING STATION, UNITS 2 & 3 O

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LOCATION: PHOENIX, ARIZONA PAGES: 2894 - 3090 DATE: TUESDAY, JUNE 11, 1985 TA. 0/ 'It - -

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ACE-FEDERAL REPORTERS, LNC.

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8506170040 850611 Washington, b.C. 20001 PDR ADOCK 05000529 T PDR (202)347-3700 NATIONWIDE COVERAGE

l CR23494.0 FIELD /cg 2894 1 UNITED STATES OF AMERICA 2 BEFORE THE l 3 NUCLEAR REGULATORY COMMISSION O 4 --------------------;

In the Matter of:  :

5  : Docket Numbers OPERATING LICENSING PROCEEDING  :

6 ARIZONA PUBLIC SERVICE COMPANY, et al.  : STN-50-529-OL (Palo Verde Nuclear Generating  : STN-50-530-OL Station, Units 2 and 3)  :

7

_____________________x 8

Courtroom Number 2 9 Seventh Floor Federal Building 10 230 North First Avenue Phoenix, Arizona 85025 11 Tuesday, June 11, 1985 12 The hearing in the above-entitled matter convened at t'y

(_j 13 9:30 a.m.

14 BEFORE:

15 JUDGE ROBERT M. LAZO, Chairman Atomic Safety and Licensing Board I6 JUDGE DIXON CALLIHAN, Member

! Atomic Safety and Licensing Board 17 I JUDGE JAMES H. CARPENTER, Member 18 Atomic Safety and Licensing Board l

l I 19 20 I '

21 f

Cl) 22 23 24 Am-Federal Reporters, Inc.

25 l

2895 1 PROCEEDINGS BEFORE THE UNITED STATES 2 NUCLEAR REGULATORY COMMISSION, JUNE 11, 1985, FEDERAL 3 COURTHOUSE, PHOENIX, ARIZONA, COMMENCING AT 9:30 A.M.

)

4 THE BOARD WAS COMPOSED OF ROBERT M. LAZO, 5 CHAIRMAN; DIXON CALLlHAN, MEMBER; RICHARD F. COLE, MEMBER; 6 AND JAMES H. CARPENTER, MEMBER.

7 THE JOINT APPLICANTS, ARIZONA PUBLIC SERVICE 8 COMPANY, ET AL., WERE REPRESENTED BY ARTHUR C. GEHR, VAUGHN 9 A. CRAWFORD, AND MARTHA E. GlBB3, ATTORNEYS AT LAW.

10 THE NECULEAR REGUL ATORY COMMISSION STAFF W AS 11 REPRESENTED BY LEE SCOTT DEWEY, ATTORNEY AT LAW.

12 THE INTERVENOR, WEST VALLEY AGRICULTURAL 13 PROTECTION COUNCIL, INCORPORATED, BY REPRESENTED BY RONALD 14 RAYNER AND WILLIAM T. GLADDEN. ,

15 16 17 18 19 20 21 22 23 24 25 I

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TELEPHONE 279-4711

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2896 1 JUDGE LAZO: WOULD THE PROCEEDING COME TO 2 ORDER, PLEASE?

() .3 GOOD' MORNING.

4 THIS IS AN ADMINISTRATIVE PROCEEDING BEFORE 4

5 THE ATOMIC SAFETY AND LICENSING BOARD OF THE UNITED STATES r

6 NUCLEAR REGULATORY COMMISSION IN THE MATTER OF ARlZONA 7 PUBLIC SERVICE COMPANY, SALT RIVER PROJECT AGRICULTURAL i

8 IMPROVEMENT AND POWER DISTRICT, SOUTHERN cal.lFORNIA EDISON 9 COMPANY, EL PASO ELECTRIC COMPANY, PUBLIC SERYlCE COMPANY 10 0F NEW MEXICO, AND SOUTHERN CALIFORNIA PUBLIC POWER 4

11 AUTHORITY. WE WILL REFER HEREINAFTER TO THESE UTILITIES 12 AS JOINT APPL ICANTS.

l I

l 13 THE PROCEEDING IS IDENTIFIED AS NUCLEAR O 14 REGULATORY COMMISSION DOCKET NUMBERS STN 50-529 AND STN 15 50-530.

I 16 THE PROPOSED ADMINISTRATIVE ACTION IS THE 17 ISSUANCE OF FACIL ITY OPERATING LICENSES WHICH WOULD 18 AUTHORIZE THE JOINT APPL ICANTS TO POSSESS, USE, AND 19 OPERATE PALO VERDE NUCLEAR GENERATING STATION UNITS 2 AND

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3, TWO PRESSURIZED W ATER NUCLEAR REACTORS LOCATED ON JOINT 20 21 APPL ICANT SITES IN MARICOPA COUNTY, ARIZONA, APPROXIMATELY 22 36 MILES WEST OF THE CITY OF PHOENIX.

l BY W AY OF BACKGROUND, ON JULY 25, 1980, THE i

23 24 U. S. NUCLEAR REGULATORY COMMISSION PUBLISHED IN THE 25 FEDERAL REGISTER A NOTICE OF RECElPT OF A APPLICATION FOR

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! TELEPHONC 2794711 I

r 2897 1 FACILITY OPERATING LICENSES FOR PALO VERDE NUCLEAR 2 GENERATING STATIONS, UNITS 1, 2, AND 3, AND A NOTICE OF

() 3 OPPORTUNITY FOR HEARING WAS PUBLISHED AT THE SAME TIME.

4 SUCH L ICENSES WOULD AUTHORIZE THE JOINT APPL ICANTS TO 4

5 POSSESS, USE, AND- OPERATE ALL THREE PALO VERDE NUCLEAR 6 GENERATING STATIONS OR UNITS, UNITS 1, 2, AND 3.

7 THIS OPERATING LICENSE PROCEEDING REMAINS 1

8 BEFORE THE LICENSING BOARD BY REASON OF THE GRANT OF A 9 LATE PETITION FOR LEAVE TO INTERVENE OF THE WEST VALLEY 10 AGRICULTURAL PROTECTION COUNCIL, INCORPORATED. WE WILL 11 REFER TO THE PETITIONERS AS WEST VALLEY.

12 ON THE STRENGTH OF THAT GRANT, THE BOARD 13 REOPENED THE EVIDENTIARY HEARING FOR THE PURPOSE OF pO CONSIDERING THE ENVIRONMENTAL ISSUE RAISED BY WEST' VALLEY, I 14 i- 15 SPECIFICALLY THE ASSERTED ADVERSE EFFECT THAT THE SALT 16 DEPOSITION ASSOCIATED WITH THE OPERATION OF THE PALO VERDE l

17 FACIL ITY WOULD HAVE UPON THE PRODUCTIV ITY OF NEARBY 18 AGRICULTURAL LANDS OWNED BY WEST VALLEY MEMBERS. FOR 19 REASONS STATED IN THAT OPINION, THE BOARD CONFINED THE 20 RECORD OPENING TO UNITS 2 AND 3 0F THE PALO VERDE 21 FACILITY. ,

22 IN A CONTEMPORANEOUSLY ISSUED DECISION, THE

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23 LICENSING BOARD RESOLVED IN THE JOINT APPL ICANTS' FAVOR 24 ALL ISSUES PREVIOUSLY RAISED BY ANOTHER INTERVENOR.

25 ACCORDINGLY, THE BOARD AT THAT TIME AUTHORIZED THE

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TELEPHONE 279-4711

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2898 l

1 ISSUANCE OF AN OPERATING LICENSE FOR UNIT 1 ALONE.

2' NOW BEFORE GOING ON WITH THE REASONS WHY WE 3 ARE G ATHERED HERE TODAY, i THINK WE SHOULD IDENTIFY THE 4 LICENSING BOARD, AND THEN I WILL CALL FOR APPEARANCES OF 5 THE PARTIES.

6 JUDGE DIXON CALLlHAN, WHO IS SEATED AT MY 7 RIGHT, YOUR LEFT, IS A PART-TIME MEMBER OF THE ATOMIC 8 SAFETY AND LICENSING BOARD PANEL, FROM WHICH INDIVIDUAL 9 LICENSING BOARDS ARE DESIGNATED. HE IS A PHYSICIST WHO 10 RECEIVED HIS PH.D. DEGREE FROM NEW YORK UNIVERSITY.

11 'BEFORE HIS RETIREMENT, DR. CALLlHAN WAS EMPLOYED FOR MANY 12 YEARS AS A PHYSICIST BY THE UNION CARBlDE CORPORATION OF

-13 OAK RIDGE, TENNESSEE. JUDGE CALLlHAN HAS BEEN A MEMBER OF 14 THE ATOMIC SAFETY AND LICENSING BOARD PANEL SINCE 1963.

15 JUDGE RICHARD F. COLE, WHO IS SEATED AT MY 16 LEFT, IMMEDIATE LEFT, RECEIVED HIS PH.D. IN ENVIRONMENTAL 17 SCIENCES AND ENGINEERING FROM THE UNIVERSITY OF NORTH 18 CAROLINA. HE HAS BEEN A PERMANENT MEMBER OF THE PANEL 19 SINCE 1973.

20 JUDGE J AMES H. CARPENTER, WHO IS SEATED AT 21 THE FAR LEFT NEXT TO JUDGE COLE, RECEIVED HIS PH.D. IN 22 OCEANOGRAPHY FROM THE JOHNS HOPKINS UNIVERSITY. PRIOR TO 23 JOINING THE PANEL, HE W AS CHAIRMAN OF THE DIVISION OF 24 MARINE AND ATMOSPHERIC CHEMISTRY AT THE UNIVERSITY OF 25 MIAMI. JUDGE CARPENTER HAS BEEN A PERMANENT MEMBER OF THE

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TELEPHONE 2794711 I

i 2899 1 PANEL SINCE 1981. HE WILL SERVE AS A TECHNICAL l 4  !

2 INTERROGATOR AND INFORMAL ASSISTANT TO THE BOARD.

() 3 MY NAME IS ROBERT M. LAZO. I AM THE LAWYER 4 MEMBER OF THIS LICENSING BOARD. I RECEIVED MY PH.D. IN 5 RADIATION CHEMISTRY FROM THE UNIVERSITY OF NOTRE DAME.

6 MAY WE HAVE APPEARANCES OF THE PARTIES, 7 PLEASE. AND l W ILL FIRST CALL UPON THE JOINT APPL ICANTS.

4 .

8 MR. GEHR: ARTHUR C. GEHR, G-E-H-R, VAUGHN 9 A. CRAWFORD, AND MARTHA E. GIBBS, G-l-B-B-S, APPEARING ON 10 BEHALF THE JOINT APPLICANTS.

t 11 MISS GIBBS HAS RECENTLY FILED HER FORMAL 12 APPEARANCE IN THIS PROCEEDING.

! 13 JUDGE LAZO: THANK YOU, MR. GEHR AND

)O 14 WELCOME, MR. CRAWFORD AND MISS GlBBS.

l 15 FOR THE NUCLEAR REGULATORY COMMISSION STAFF.

16 MR. DEWEY: 1 AM LEE DEWEY ATTORNEY FOR THE h.

l 17 NUCLEAR REGULATORY STAFF IN THIS PROCEEDING. WITH ME ON l

l 18 MY LEFT IS MR. EMANUEL LICITRA WHO IS THE PROJ ECT MANAGER 19 FOR THE PALO VERDE PROJECT.

20 JUDGE L AZO: THANK YOU, MR. DEWEY.

21 AND FOR THE INTERVENOR, WEST VALLEY l 22 AGRICULTURAL PROTECTION COUNSEL, INC.

23 MR. GLADDEN: MY NAME IS WILLIAM T. GLADDEN.

O 24 l AM A FARMER IN THE BUCKEYE AREA AND A MEMBER OF THE WEST i 25 VALLEY FARMING ASSOCIATION.

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TELEPHONE 279-4711 f

2900 1 JUDGE L AZO: THANK YOU, MR. GLADDEN.

L 5 MR. DEWEY: SIR, MR. RON RAYNER IS ALSO

() 3- EXPECTED TO COME THIS MORNING ON BEHALF OF THE WEST VALLEY 4 ASSOCIATION.

5 JUDGE LAZO: .YOU SAY HE IS PLANNING TO 6 ATTEND?

7 MR. DEWEY: HE IS PLANNING TO ATTEND.

.y 8 MR. GLADDEN: YES, HE WILL BE HERE SHORTLY.

9 JUDGE LAZO: ALL RIGHT. PERHAPS WE MIGHT 10 ASK: MR. GLADDEN, IS WEST VALLEY REPRESENTED BY COUNSEL 11 AT-THIS TIME 7 12 MR. GLADDEN: NO, SIR. WE INTEND TO 13 REPRESENT OURSELVES.

9O 14 JUDGE L AZO: WE NOTE FOR THE RECORD THAT 15 APPEARANCES OF COUNSEL REPRESENTING WEST VALLEY WERE 7' ENTERED BY KENNETH BERLIN, MR. EDWARD F. GRUEN AND MR.

y 17 J ACK L ASOTA ALL OF THE FIRM OF WINSTON & STRAWN, BOTH OF 18 0.C., WASHINGTON, D. C. AND PHOENIX. WE HAVE RECElVED NO 19 0FFICIAL NOTIFICATION OF A REQUEST FOR WITHDRAWAL OF ANY 9-20 0F THESE LAWYERS. PERHAPS, MR. GLADDEN, YOU MIGHT GIVE US 21 SOME OF THE INFORMATION. YOU DO NOT EXPECT ANY OF YOUR 22 PREVIOUS COUNSEL TO APPEAR, IS THAT CORRECT?

U 23 MR. GLADDEN: NO. NO, SIR, WE DON'T. WE

24 JUST SIMPLY COULDN'T AFFORD COUNSEL SO WE HAD TO TAKE THE 25 CASE ON OUR OWN.

i

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TELEPHONE 279-A711 h

1 I

i 2901 j 1 JUDGE L AZO: YOU HAVE DISMISSED YOUR 2 COUNSEL 7

() 3 MR. GLADDEN: YES.

4 MR. GEHR: IF THE BOARD PLEASE, I THOUGHT t

5 TWO OF THE COUNSEL, OTHER THAN MR. BERLIN, HAD W ITHDRAWN 6 SHORTLY AFTER THE INTERVENTION HAD BEEN FILED. I AM A 7 LITTLE SURPRISED THAT IT'S NOT lN THE RECORD.

l 8 JUDGE L AZO: MR. GEHR, YOU MAY BE CORRECT, 9 BUT I DID NOT MISSPEAK. OUR RECORDS DO NOT REFLECT THAT.

10 AND AGAIN, LET ME SAY I FEEL THAT COUNSEL WHO DO ENTER AN

?

11 APPEARANCE IN THESE PROCEEDINGS HAVE SOME RESPONSIBILITY 12 FOR ADVISING THE BOARD IF THEY DESIRE TO WITHDRAW. NONE 13 0F THESE GENTLEMEN ARE HERE TODAY, SO THERE IS NO POINT IN 1

O 14 DISCUSSING THAT MATTER FURTHER, 15 YOU ARE MOST WELCOME, MR. GLADDEN, AND WE 16 ARE PLEASED THAT WE DO HAVE A REPRESENTATIVE AND MAY HAVE

)

17 TWO OF YOUR ORGANIZATION.

18 ARE THERE ANY OTHER REPRESENTATIVES OF ANY 19 OTHER COUNTY OR STATE OR LOCAL ORGANIZATIONS WHO ARE 20 PRESENT AND WlSH TO ENTER AN APPEARANCE THIS MORNING?

21 WELL, IN HEARING NO RESPONSE -- OH.

22 PLEASE LET ME JUST PROCEED.

)

23 AT THE TIME WE PUBLISHED THE NOTICE ADVISING

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24 THAT THIS PROCEEDING WOULD CONVENE HERE TODAY, WE DID 25 OFFER TO RECEIVE LIMITED APPEARANCE STATEMENTS FROM

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2902 1 MEMBERS OF THE PUBLIC WHO WISH TO FILE A WRITTEN OR AN I

2 ORAL STATEMENT PERTAINING TO THE ISSUES TO BE ADJUDICATED 3- IN THIS PROCEEDING, AND l SEE A SHOW OF HANDS IN THE 4 HEARING ROOM.

5 MAY I ASK, DO ANY OF THESE MEMBERS OF THE 6 PUBLIC WISH TO ENTER A LIMITED APPEARANCE STATEMENT 7 7 YES. THERE ARE THREE OR FOUR WHO HAVE 8 INDICATED THAT THEY WOULD. PERHAPS THEN THE THING TO DO 9 AT THIS PolNT WOULD BE TO PROCEED WITH THOSE LIMITED 10 APPEARANCE STATEMENTS. AND I WOULD ASK EACH OF YOU IN 11 TURN WOULD COME FORW ARD.

12 AS WE STATED EARLlER, THE MATTERS WHICH 13 REMAIN IN ISSUE IN THIS PROCEEDING ARE THE ALLEGED ADVERSE 14 IMPACT FROM THE SALT DRIFT FROM THE PALO VERDE COOLING 15 TOWERS ON AGRICULTURAL CROPS. IF YOU WOULD RESTRICT YOUR

16 REMARKS TO THE ISSUES WHICH ARE TO BE ADJUDICATED, 17 WE WOULD APPRECI ATE THAT.

18 WHO WOULD LIKE TO START OFF7 IF YOU WOULD 19 COME FORWARD TO THE PODIUM, YOU CAN BE HEARD BY EVERYC.$1 20 IN THE ROOM. WHO SHALL BE FIRST?

21 GOOD MORNING AND WELCOME.

22 WE ARE MAKING A VERBATIM TRANSCRIPT 23 0F THESE PROCEEDINGS. AND FOR THE BENEFIT OF THE 24 LICENSING BOARD AND THE COURT REPORTER, I WONDER IF YOU 25 WOULD STATE YOUR NAME PLEASE AND PERHAPS SPELL IT FOR l "^*"!"u^a"at.afM'#" '"*- '*OS 5,?o*a *1" TELEPHONE 279-4711

2903 1 COURT REPORTER.

2 MS. HOFFMANN: BETH HOFFMANN,

() 3 H-0-F-F-M-A-N-N.

4 J UDG E. L AZO : THANK YOU.

5 MS. HOFFMANN: PUBLIC OPINION POLLS INDICATE 6 THAT MANY AMERICANS DISTRUST AND DISLIKE THEIR LOCAL 7 ELECTRIC UTILITY. THE REASONS FOR THIS HOSTILITY ARE NOT 8 DIFFICULT TO UNDERSTAND: DISASTROUS COST OVERRUNS, 9 NUCLEAR ACCIDENTS, AND ACID RAIN HAVE SENT SHOCK WAVES 10 ACROSS THE NATION. TEMPERS ARE RISING, ALONG WITH UTILITY.

11 BILLS.

r 12 TODAY WE ARE WITNESSING THE EARLIEST STAGES 13 0F SWEEPING REFORMS THAT APPEAR DESTINED TO TRANSFER 14 FORTUNES, SHIFT EMPLOYMENT PATTERNS, AND ALTER THE WAYS 15 AMERICANS PRODUCE AND USE ENERGY. TOMORROW'S UTIL ITY W ILL 16 LIKELY BEAR LITTLE RESEMBLANCE TO YESTERDAY'S. THE WHOLE 17 INDUSTRY lS BEING SHAKEN TO ITS CORE.

9 18 FOR THREE QUARTERS OF A CENTURY, UTILITIES 19 HAVE BEEN PRESUMED TO HOLD A NATURAL MONOPOLY ON POWER 20 GENERATIONS, AS WELL AS TRANSMISSION AND DISTRIBUTION.

21 BUT NOW SMALL POWER PRODUCERS, ABETTED BY THE PUBLIC 22 UTIL ITY REGUL ATORY POL ICI ES ACT, HAVE TRASHED THAT

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23 PRESUMPTION.

0 24 UTILITIES FIND THEMSELVES FACING HUNGRY 25 COMPETITORS -- SMALL POWER PRODUCERS USING COGENERATION

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TELEPHONE 279-4711

2904 1 EQUIPMENT, WIND TURBINES, HYDROPOWER FACILITIES, BIOMASS, s.

2 AND OTHER DECENTRALIZED POWER TECHNOLOGIES. UTILITIES

() 3 CONTROL THE L ARGEST POOL OF PRIV ATE CAPITAL IN THE WORLD.

4 MOST HAVE INVESTED YAST SUMS IN YESTERDAY'S TECHNOLOGIES --

4 5 ESPECIALLY NUCLEAR POWER -- WITH CONSEQUENCES THAT ARE 6 PERILOUS FOR SHAREHOLDERS AND RATE PAYERS AllKE.

7' SINCE 1973, ELECTRICITY PRICES HAVE TRIPLED.

)

8 AND UTILITIES HAVE CANCELED AT LEAST 180 PROPOSED POWER 9 PLANTS. PROBLEMS IN SOME REGIONS OF THE COUNTRY PROMISE 10 TO ACCELERATE. CONSUMERS FACE RATE SHOCKS EVERY TIME i

11 REGULATORS PASS ALONG THE COST OF A POWER PLANT THAT JOINS 12 THE UTIL ITY GRID. KANSAS GAS AND ELECTRIC CUSTOMERS WILL 13 CONFRONT AN 83 PERCENT INCREASE WHEN THE WOLF CREEK

) () 14 REACTOR'S BILL COMES DUE. ELECTRIC BILLS FOR THE AVERAGE 15 EL PASO INDUSTRI AL IST W ILL SKYROCKET ALMOST $900,000 16 DURING THE FIRST YEAR THE PALO VERDE PLANT IS IN 17 OPERATION. THE CALLAWAY ONE REACTOR WILL RAISE THE i 18 AVERAGE MISSOURI HOME0WNER'S ANNUAL BILL MORE THAN $300,

! 19 AND WILL RESULT IN THE LOSS OF 24,000 JOBS IN THE h

20 ST. LOUIS AREA ALONE. IF THE SEABROOK FACILITY IS 21 COMPL ETED, NEW HAMPSHIRE RATES WILL ALMOST TRIPLE.

22 AMERICA STILL REQUIRES RELIABLE, REASONABLY q 23 PRICED POWER FOR YOUNG, GROWING INDUSTRIES WHICH OFFER THE LJ TO SATISFY 24 BEST HOPE FOR U.S. ECONOMIC REVITALIZATION.

! 25 THIS DEMAND, ENTREPRENEURS ARE BRINGING INNOVATIVE I

O R RE R R O R O 1 TELEPHONE 2794 711 I

- . . - - -_.- . - __ _ . _ = - _ - .

U 2905 1 TECHNOLOGIES AND AGGRESSIVE BUSINESS SKILLS TO THE 2 ELECTRICITY MARKET. OFTEN IGNORED BY MONOPOLISTS, NEW

() 3 FlRMS ARE PROVIDING SOPHISTICATED COMPUTERS, EFFICIENT j

4 APPLI ANCES AND NEWLY DESIGNED GENERATORS WHICH CURTAll THE 5 NEED FOR CENTRALIZED POWER PLANTS. IN SOME SECTIONS OF 6 THE COUNTRY, INDEPENDENT ENTREPRENEURS WILL SOON SUPPLY A 7 THIRD OF THE ELECTRIC CAPACITY.

F 8 WHILE MANY OLD-LINE UTILITY ENGINEERS FAVOR 9 MORE CENTRAL POWER STATIONS, A NEW GENERATION OF 10 EXECUTIVES W ANTS TO AV0lD CONSTRUCTION BY EFFICIENTLY 11 MANAG ING THE DEMAND FOR POWER AND ADOPTING ALTERNATIVE 12 TECHNOLOGIES.

13 THE DEPARTMENT OF ENERGY CALCULATES THAT O 14 C0AL SUPPL IED 54 PERCENT OF U.S. ELECTRICITY IN 1984, 15 NUCLEAR SUPPLIED ONLY 14 PERCENT, WHILE RENEWABLE ENERGY

f. 16 SUPPL LED 15 PERCENT.

4 17 RENEW ABLES HAVE BEEN IN USE ONLY ElGHT TO 18 TEN YEARS WHILE NUCLEAR ENERGY HAS BEEN ON THE SCENE FOR 19 40 YEARS AND IT'S STILL NOT GOING ANYWHERE. RIGHT NOW 20 LOBBYlSTS FOR WEALTHY CONVENTIONAL ENERGY INTERESTS ARE 21 CIRCLING THE U.S. CAPITAL, TRYING TO INFLUENCE CONGRESS 22 WITH HUGE CONTRIBUTIONS TO PROTECT THEIR PERMANENT TAX

, - 23 SUBSIDIES -- AT A PUBLIC PRICE TAG OF $28 BILLION

-O 24 i ANNUALLY.

25 MEANWHILE, THE RENEWABLE ENERGY AND O E o o 1 TELEPHONE 279-4711 I

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2906 1 CONSERV ATION TAX CREDITS, WHICH COST LESS THAN SI .3 2 BILLION, ARE DUE TO EXPIRE' ON DECEMBER 31ST OF THIS YEAR.

() 3. BUT REGARDLESS OF MASSIVE SUBSIDIES TO OIL 4 COMPANIES AND THE NUCLEAR INDUSTRY, UTILITY MONOPOLlES 4.

5 ARE LOOSING POWER, BOTH LITERALLY AND FIGURATIVELY, TO A 6 NEW GENERATION OF ENTREPRENEURS.

7 WE HAVE FOUGHT OVER TEN YEARS TO KEEP PALO i

8 YERDE FROM HAPPENING. WE MAY NOT HAVE ACCOMPLISHED OUR 9 GOAL. WE MAY HAVE LOST THIS BATTLE, BUT WE WILL 10 ULTIMATELY W IN THE W AR.

1 11 THANK YOU.

12 JUDGE L AZO: THANK YOU, MISS HOFFMANN.

13 NOW, IN APRIL OF 1982, I THINK IT WAS ON THE

>0 14 17TH AND 18TH -- OR TWO DAYS DURING APRIL WHEN WE 15 CONDUCTED THE OPERATING LICENSE PROCEEDING ON ALL ASPECTS 16 0F THE CASE WHICH WERE IN CONTROVERSY AT THAT TIME, WE DID

)

17 HEAR LIMITED APPEARANCE STATEMENTS FROM MEMBERS OF THE 18 PUBLIC COVERING THOSE ASPECTS OF THE PROCEEDING. WE WOULD 19 ASK THAT THOSE WHO WISH TO ADDRESS THE BOARD TODAY CONFINE

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20 THEIR REMARKS TO THE ASSERTED ADVERSE EFFECTS THAT SALT 21 DEPOSITION FROM COOLING TOWERS WOULD HAVE ON THE CROPS OF 22 THESE WEST VALLEY ASSOCI ATION FARMERS. IF THERE ARE OTHER 1

23 MATTERS THAT ARE NEW OR DIFFERENT THAT HAVE ARISEN SINCE O 24 1982, WE WOULD OF COURSE PERMIT SOME BRIEF REMARKS IN THAT 25 REGARD. BUT IT WOULD BE MOST HELPFUL IF YOU WOULD

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TELEPHONE 279 4711 I'

2907 1 RESTRICT YOUR COMMENTS TO THE ISSUES WHICH WE ARE HERE TO 2 DECIDE, NAMELY THE SALT IMPACT.

() 3 YES, SIR 7 WOULD YOU CARE TO COME FORWARD 7 i

4 MR. HAGG ERTY: MY NAME IS HAROLD HAGGERTY,

)

5 AND I HAVE BEEN CONTESTING THE CONSTRUCTION OF .THE PALO 6 VERDE NUCLEAR GENERATING STATION SINCE 1976. I HAVE A 7 LETTER IN MY POSSESSION FROM THE NUCLEAR REGULATORY V

8 COMMISSION IN WASHINGTON, D.C. STATING THAT IT IS NOT 9 ALLOWABLE FOR THE PUBLIC SERVICE CORPORATION TO INCLUDE 10 THE CONSTRUCTION OF THE PALO VERDE NUCLEAR GENERATING L

11 STATION IN THEIR RATES FOR THE POWER WE ARE RECEIVING NOT l 12 CONNECTED W ITH THAT UNIT.

13 l ALSO HAVE MADE AN INVESTIGATION CONCERNING 14 THE BORON THAT W AS DISCOVERED AND STOPPED THE UNIT 15 NUMBER 1 FROM FUNCTIONING FOUR MINUTES AFTER IT WAS 16 STARTED' UP THE FIRST TIME AND THE BORON WAS IN THE WELL OF 17 WATER AT THE FOOT OF THE NUCLEAR FUELED RODS ON UNIT 18 NUMBER 1. WHERE THAT BORON CAME FROM, PUBLIC SERYlCE HAS 19 NOT TOLD THE ARIZONA CONSUMERS AND NEITHER HAS ANY OF THE ~

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20 TELEVISION STATIONS OR THE NEWSPAPER HERE IN ARIZONA.

21 1 MADE AN INVESTIG ATION AND I HAVE THE 22 OPINION OF THE MANAGER OF THE 19TH AVENUE AND GILA RIVER

) '

i 23 WATER TREATMENT PL ANT THAT THIS BORON COULD HAVE COME FROM O 24 PL ANTS SUCH AS MOTOROL A AND OTHER PL ANTS WHO ARE USING 25 S0-CALLED DOPE TO TREAT -- IN THE PROCESSING OF INTEGRATED

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TELEPHONE 279-4711

)

~ . _ - _ _ _ _ _ . _ _ _ _ _ . . _

i 2908 1 CIRCUlTS AND OTHER COMPONENTS THAT ARE USED IN COMPUTERS 2 AND COMPLICATED EQUIPMENT THAT THEY ARE BUILDING HERE IN

() 3 ARIZONA.

4 THAT BORON COULD HAVE COME DOWN FROM

)

5 UPSTREAM INTO THE EFFLUENT CLEANSING PLANTS ACCORDING.TO 6 THE MAN AGERS, ACCORDING TO A RESEARCH -- A CHEMICAL 7 RESEARCH PLANT-THAT l CONTACTED YESTERDAY. AND-IT COULD L

8 STILL REMAIN IN THE W ATER AFTER IT IS SENT TO PALO VERDE 9 NUCLEAR GENERATING STATION BECAUSE THEY USE ONLY TONS OF 10 CHLORIDE -- CHLORINE RATHER TO CLARIFY AND GET THE SOLID 1

11 -WASTES OUT OF THE EFFLUENT WATER BECAUSE THEY SEND IT TO 12 THE PALO VERDE NUCLEAR GENERATING STATION. THEY CLAIM

- 13 THEY USE NO OTHER CHEMICALS. BUT -- THE REASON THEY CL AIM

_b) 14 THEY USE NO OTHER CHEMICALS IS BECAUSE THE PUBLIC SERYlCE 15 USES -- AT THE PALO VERDE NUCLEAR GENERATING STATIONS USE 16 THEIR OWN CHEMICALS TO FURTHER RID THE EFFLUENT WATER OF

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17 IMPURITIES, INCLUDING VAST QUANTITIES OF LINE. SOME OF 18 THE BORON MAY HAVE COME FROM THAT LIME BUT SOME OF lT MAY 19 STILL BE INTO IT WHEN IT COMES TO THE EFFLUENT PLANTS.

)

20 AND SINCE IT DID ACCUMULATE TO A FOOT OF THE UNIT NUMBER 1 21 AND HAD TO BE REMOVED BEFORE FISHING COULD OCCUR, IT COULD 22 ALSO HAPPEN ON UNIT NUMBER 2 AND UNIT NUMBER 3.

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23 THERE IS ANOTHER SITUATION THAT THE PUBLIC O 24 HAS NOT BEEN INFORMED ABOUT. UNIT NUMBER 2 FROM THE 25 CONCEPTION OF ITS FINISHED CONSTRUCTION BEFORE IT WAS EVER --

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    • "!Eu^a7aUEEE'aY"""' 'l**o"dCEIi'o'n"fe'o TELEPHONE 279 4711

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2909 1 TESTING STARTED BEGAN TO BECOME EMERSED AT THE BASE OF IT r

2 BY SEEPAGE FROM UNDERGROUND W ATER. AND THE PUBLIC HAS NOT

() 3 BEEN TOLD ABOUT THAT. PUMPS HAVE BEEN IN OPERATION DAY 4 AND NIGHT. AROUND UNIT NUMBER 2 TO RID THAT, TO REMOVE THAT 5 WATER FROM THE BASE OF THE UNIT NUMBER 2. AND NOBODY HAS 6 BEEN TOLD ABOUT THAT. BUT-l HAVE THE INFORMATION FROM A 7 MAN WHO HAS WORKED OUT THERE AND IS WORKING OUT THERE 8 WHOSE NAME I CHOOSE NOT TO REVEAL BECAUSE IT WOULD 9 JEOPARDlZE HIS EMPLOYMENT. HE IS A TRUSTED INDIVIDUAL AND 10 AN I NTELL IG ENT PERSON.

11 NOW SALT IS NOT THE ONLY COMPONENT THAT WE 12 HAVE TO WORRY ABOUT TO -- BECAUSE THIS UNDERGROUND TABLE 13 IS SO CLOSE TO THE SURFACE THAT BORON OR S ALT THAT IS l0 14 DISPERSED ON THE GROUND AFTER BEING REMOVED FROM THE W ATER 15 AROUND THE BASE OF THESE UNITS CAN SEEP IMMEDI ATELY INTO 16 THE GROUND SURFACE WATER AND CONTAMINATE ANY WELLS OR ANY 17 OTHER WATER IN THE AREA THAT IS USED BY MA.5!UFACTURES OR 18 HOME0WNERS. AND i PETITIONED THE ARIZONA ASSOCIATION --

19 THE AMERICAN ASSOCIATION OF RETIRED CITIZENS IN 20 WASHINGTON, D.C. , TO USE 68 MEMBERS OF THEIR LEG AL STAFF 21 TO START A CLASS ACTION ON BEHALF OF THE PEOPLE OF ARlZONA 22 TO STOP THIS USE OF THIS NUCLEAR GENERATING STATION UNTIL 23 SUCH A TIME AS SAFETY REGULATIONS HAVE BEEN ESTABLISHED BY 24 THE NUCLEAR REGULATORY COMMISSION REGARDING THE USE OF 25 CONTAMINATED WATER WHICH COULD FOUL UP THE VALVES IN THE

~ *** u'a a "a ?M ': *

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  • MCllisisl1:*

TELEPHONE 2794711 i

l l

2910 a

1 COOL ING SYSTEM AND SHUT THEM OFF AG AIN ANY TIME IN THE 2 IMMEDIATE FUTURE AND CAUSE A MELTDOWN A HUNDRED TIMES

() 3 WORSE THAN ANYTHING THAT OCCURRED AT THE THREE MILE ISLAND 4 GENERATING STATION.

5 AND I -- THE TELEVISION STATIONS HERE IN 6 ARl20NA HAVE BEEN APPRISED OF WHAT l'VE BEEN TRYlNG TO DO 7 AND THEY SAY IT IS ONLY MY OPINION THAT I HAVE VOICED IN 1

8 OPPOSITION TO THE L ICENSING OF THIS -- 0F THESE UNITS. IT 9 IS NOT ONLY MY OPINION; IT IS THE WRITTEN FACTS RECEIVED 10 FROM THE NUCLEAR REGUL ATORY COMMISSION IN THE LETTER THAT 1

11 i H AV E W I TH ME. AND l WOULD LIKE TO PRESENT IT TO YOU AND 12 LET YOU OBSERVE THAT FACT, THAT WHEN THE PEOPLE VOTED TO 13 ALLOW THESE UNITS TO BE BUILT, THEY VOTED ON THE PREMISE 14 THAT THE ATOMIC ENERGY COMMISSION WOULD -- HAD LICENSED 15 THE BUILDING -- AUTHORIZED THE BUILDING AND CONSTRUCTION 16 0F THIS UNIT ON THE PREMISE THAT WE WOULD NOT BE BILLED t

17 FOR CONSTRUCTING IT.

18 i WOULD L IKE TO LEAVE THAT LETTER W ITH YOU 19 AND A LETTER FROM THE GOVERNOR STATING THAT THE USE OF t i

20 EFFLUENT W ATER IS SATISFACTORY. IN MY OPINION IT IS NOT 21 SATISFACTORY, AND EVENTUALLY THE -- BECAUSE THE 22 CONTAMINATION OF THE EFFLUENT WATER DRASTICALLY AFFECTS i

23 THE VALVES IN THE COOLING SYSTEMS OF THESE TOWERS, 24 EVENTUALLY THEY WILL HAVE TO USE THE WATER THAT WE 25 HOME0WNERS AND BUSINESS MEN USE FOR OUR HOMES AND FOR OUR v

"^"a^aaa"4='#" '"' '5 0 = #ro$r .

TELEPHONE 279-4711 1

2911 1 BUSINESSES. AND WE OF COURSE WILL HAVE TO BE CUT BACK SO 2 DRASTICALLY THAT EVENTUALLY PHOENIX COULD RETURN TO THE

() 3 DUST BOWL - THAT IT ONCE W AS.

4 THANK YOU.

5 JUDGE LAZO: THANK YOU, MR. HAGGERTY.

6 MR. HAGGERTY: MAY l LEAVE THIS LETTER WITH 7 YOU, PLEASE?

8 JUDGE LAZO: YES, YOU MAY.

9 MR. HAGGERTY: THE LETTER, INCIDENTALLY, 10 GENTLEMEN, IS FROM HUGH K. CL ARK, CHAIRMAN OF THE ATOMIC 11 SAFETY AND LICENSING BOARD. HOWEVER, THE HEAD OF THE 12 LETTER STATES UNITED STATES NUCLEAR REGULATORY COMMISSION 13 IN WASHINGTON, D.C. MR. CLARK WAS THE CHAIRMAN OF THE O 14 ATOMIC ENERGY COMMISSION. OF COURSE YOU KNOW THAT THE 15 AUTHORITY OF THE ATOMIC ENERGY COMMISSION WAS TRANSFERRED 16 TO THE NUCLEAR REGULATORY COMMISSION. AND BECAUSE OF THAT 17 TRANSFER, THE ARIZONA STATE LEG ISL ATURE W ITH THE CONSENT 18 AND APPROYAL OF THE CORPORATION COMMISSION PRESUMABLY 19 COERCED THE NUCLEAR REGUL ATORY COMMISSION TO REVERSE THEIR 20 STANDING ON THE CHARGES OF -- FOR CONSTRUCTING THE NUCLEAR 21 POWER -- THE PALO VERDE NUCLEAR REGULATORY SYSTEM AND 22 CHARGING US FOR THAT CONSTRUCTION.

23 JUDGE LAZO: MR. HAGGERTY, PARDON ME,

(

24 PLEASE. IS THE CLARK LETTER ADDRESSED TO YOU?

25 MR. HAGGERTY: YES, IT'S ADDRESSED TO ME.

'"*c"MA"r a"A;%'N '"c- **%'Cali-lEn' TELEPHONE 279-4711

-- . - _ . _ _ _ _ _ _ _ _ _ . _ _ _ , _ _ _ _ _ . _ . _ _ _ _ _ - . _ . - . - - - . _ . . , _ _ _ . - _ _ _ _ _ . , _ . - . . . _ _ _ . - . . . _ _ _ _ _ - - - ~ , _ _ _

1 2912 1 JUDGE L AZO: JUST FOR IDENTIFICATION, WOULD

')

2 YOU TELL US THE DATE OF THAT LETTER, PLEASE7

() 3 MR. HAGG ERTY : YES. IT'S MARCH 19TH, 1976.

4 WE ALL KNOW THAT THE ARIZONA STATE S

-5 LEGISLATURE REVERSED THAT DECISION BY THE ATOMIC ENERGY 6 COMMISSION AND THE PEOPLE THAT VOTED FOR IT ON THE PREMISE 7 THAT THAT WOULD REMAIN INTACT, THAT THAT PORTION OF THE

-)

8 LICENSING PERMIT THAT STATED WE WILL NOT BE CHARGED FOR 9 CONSTRUCTING IT WERE NOT ASKED TO VOTE ON THAT CHANGE.

10 THANK YOU.

Y 11 JUDGE L AZO: THANK YOU, SIR.

12 MR. H AGG ERTY, SINCE YOU DO NOT HAVE COPIES 13 0F THE LETTER SO THAT WE COULD HAVE IT INCLUDED INTO THE

) _..

14 TRANSCRIPT OF TODAY'S PROCEEDING, WE WILL SUBMIT IT TO OUR .

15 DOCKETING AND SERVICE SECTION OF THE OFFICE OF THE 16 SECRETARY OF THE COMMISSION IN WASHINGTON AND ASK THAT IT

-)

17 BE SERVED ON ALL OF THE PARTIES AND THE LICENSING BOARD 18 AND MADE A PART OF THE PUBLIC RECORD IN THE DOCUMENT ROOM 19 IN WASHINGTON.

')

20 ARE THERE ANY OTHERS WHO WOULD LIKE TO MAKE 21 A STATEMENT PLEASE7 22 YES.

)

23 MS. LAPL ACA: MY NAME IS NANCY LAPLACA, 24 L-A-P-L-A-C-A.

25 YOU MAY NOT REALIZE IT SITTING HERE IN THIS

""!!a"r*4"4=:'It" "*- ', N S E ir A 'f?

TELEPHONE 279-4711

)

. -. .. . - ... _= _ _ _ _ _ . . ..

2913 1 AIR-CONDITIONED COURTROOM, RIDING HERE IN AN 2 AIR-CONDITIONED CAR FROM YOUR AIR-CONDITIONED HOTEL ROOMS,

_O 3 Bur vou ^Re SITTING iN THe MiooLe oF ^ oESeRT-4 PALO VERDE IS BEING BUILT IN ONE OF THE 5 HOTTEST DESERTS ON THE NORTH AMERICAN CONTINENT.

6 AS EASTERNERS, YOU MAY NOT REALIZE WHAT 7 THOSE OF US WHO HAVE LIVED IN THE DESERT FOR YEARS HAVE 8 LEARNED: THE DESERT IS A PLACE OF LIMITS. THE MOST

, 9 OBVIOUS OF THESE LIMITS IS WATER; W ATER USED FOR ONE 10 PURPOSE MEANS THAT W ATER IS UNAVAILABLE FOR OTHER l 11 PURPOSES. ANOTHER L IMIT IS THE ABlL lTY OF PEOPLE AND 12 MACHINES TO FUNCTION IN HIGH HEAT. DESERT WEATHER IS 13 VIOLENT, CHANGING SUDDENLY AND UNPREDICTABLY. PALO VERDE 14 IGNORES ALL 0F THESE LIMITS AT TREMENDOUS COST AND RISK TO l

15 THOSE OF US WHO MUST LIVE IN THE SHADOW OF PALO VERDE.

16 PALO VERDE WILL BE THE LARGEST COMMERCIAL 17 NUCLEAR PL ANT IN THE WESTERN WORLD, YET IT IS THE FIRST 18 AND ONLY PL ANT IN THE FREE WORLD TO BE BUILT WITHOUT A i

19 NEARBY NATURAL SUPPLY OF WATER. EVERY DAY PALO VERDE WILL

! 20 GUZZLE MORE WATER THAN THE CITY OF TUCSON, THE SECOND 21 L ARGEST CITY IN ARIZONA. EACH PALO VERDE REACTOR WILL l

22 REQUIRE NEARLY 7 BILLION G ALLONS OF WATER FOR COOLING l 23 WATER, OR A TOTAL OF 140,000 ACRE FEET PER YEAR.

, O 24 PART OF THIS WATER WILL BE OBTAINED IN THE l

l 25 FORM OF EFFLUENT FROM SIX NElGHBORING CITIES. THE EFFLUENT 1

"*"L*a a"a%%?" '"' W ,* h C ! !s ? A R :

TELEPHONE 279-4711

i 2914 1 WILL BE PUMPED 36 AND A HALF MILES ACROSS THE DESERT

)

2 THROUGH A VULNERABLE PIPELINE TO THE PLANT SITE, WHERE IT

() 3 WILL BE RUN THROUGH AN EXPENSIVE MULTl-STAGE TREATMENT 4 PROCESS AND STORED IN AN 80-ACRE, 750 MILLION GALLON OPEN 1

5 RESERVOIR. SUCH OPEN AIR RESERV0lRS ARE A PRIME SITE FOR 6 THE DEVELOPMENT OF BACTERIAL CORROSION PROBLEMS SUCH AS 7 ALREADY HAVE OCCURRED IN ANOTHER W ATER SYSTEM AT THE 1

8 PLANT.

9 ONCE TREATED, THE EFFLUENT WILL BE MOVED 10 INTO THE PL ANT'S HUGE COOL ING TOWERS, NECESSITATED BY THE 11 HIGH DESERT HEAT, WHERE MUCH OF IT WILL EITHER BE RELEASED 12 INTO THE ENVIRONMENT IN THE FORM OF WATER VAPOR OR MOVED 13 TO EVAPORATION PONDS WHEN ITS MINERAL CONTENT BECOMES TOO

+

O 14 HIGH.

15 ENVIRONMENTAL PROBLEMS HAVE ALREADY RESULTED 16 FROM THESE PONDS, AND YOU HAVE NEVER SERIOUSLY EXAMINED 17 THE POTENTIAL FOR THIS EFFLUENT TO RELEASE DISEASE-CAUSING 18 BACTERIA INTO THE AIR, DESPITE THE CONCERNS OF LOCAL 19 MEDICAL PEOPLE.

h' l 20 EACH OF THESE EXTRA SYSTEMS, DUE TO PALO 21 VERDE'S DESERT LOCATION, WILL COST RATE PAYERS DEARLY.

22 YET EVEN AFTER ALL THE TREATMENT, PALO VERDE WILL OPERATE 23 ON A HIGHER CONCENTRATION OF TOTAL DISSOLVED SOLUTES THAN

'O 24 ANY OTHER PLANT IN THE NATION.

25 WHAT THIS WILL MEAN FOR THE LONG-TERM COST

) i COURT R R ERS O ARIZON 850 4 TELEPHONE 279-4711 h

2915 1 AND SAFETY OF THE PLANT DUE TO CORROSION PROBLEMS, NO 2 EXPERT CAN SAY. PALO VERDE IS A GREAT EXPERIEMENT. YET

(). 3 YOU HEARD CONTRADICTORY EVIDENCE ON THIS ISSUE TWO YE ARS 4 AGO AND DECIDED IT WAS A CHANCE WE COULD AFFORD TO TAKE, 5 AN _ EXPERIMENT WE WOULD COULD L IVE W ITH. YOU WILL EXCUSE 6 US IF MANY OF US DO NOT FEEL LIKE BEING GUINEA PlGS IN i

7 SUCH AN EXPERIMENT.

8- THE EFFLUENT COULD CERTAINLY BE PUT TO 9 BETTER USES. ACCORDING TO AGRICULTURAL SCIENTISTS AT THE 10 UNIVERSITY OF ARIZONA, MUNICIPAL WASTE WATER CAN BE USED 11 IN IRRIG ATING GRAIN AND HAY CROPS TO YlELD MORE GRAIN PER 12 ACRE THAN GROUNDW ATER ALONE. IN ADDITION, LARGE AMOUNTS l- 13 0F ENERGY CAN BE SAVED BY USING MUNICIPAL EFFLUENT FOR 14 IRRIGATION. A L ARGE AMOUNT OF ENERGY 15 NEEDED FOR -

15 MANUFACTURING FERTILIZER AND PUMPING WATER. ENERGY 16 REQUIRED TO MANUFACTURE FERTILIZERS EQUAL TO THE NUTRIENT

-17 CONTENT OF ONE ACRE-FOOT OF EFFLUENT AND TO PUMP WATER 18 FROM A 300-F00T DEPTH FOR lRRIG ATION EQUALS THE ENERGY 19 VALUE OF 33 GALLONS OF G ASOL INE, ACCORDING TO THE 20 UNIVERSITY OF ARIZONA STUDY. THUS, IN ADDITION TO THE 21 COST AND MONEY AND ENERGY TO TRANSPORT WASTE WATER TO PALO 22 VERDE AND FOR THE EXPENSIVE, MULTl-STAGE TREATMENT

)

23 PROCESS, PALO VERDE WILL COST THE ANNUAL EQUIVALENT OF

)

2

.4 APPROXIMATELY 3.5 MILLION GALLONS OF GASOLINE IN LOST 25 NETRIENTS.

4

"^*%^n*4"4 ";'#" '"*- T*obiO'7io*~T*

  • f TELEPHONE 279 4711 1:

2916 1 YET APS HAS HAD THE AUDACITY TO CLAIM THAT t

2 PALO VERDE WILL SAVE PETROLEUM. CLEARLY, APS DOES NOT

() 3 UNDERSTAND CONSERVATION, WHICH MEANS THE EFFICIENT USE OF 4 ALREADY AV AIL ABLE RESOURCES, DOING MORE W ITH LESS.

)

5 lNSTEAD, PALO VERDE WILL REQUIRE MORE OF EVERYTHING: MORE 6 GROUNDWATER AND MORE EFFLUENT TO BE DIVERTED AWAY FROM 7 INDIANS AND FARMERS AND CITIES TO THE PRODUCTION OF i

8 ELECTRICITY, MORE ELECTRICITY THAN ARIZONA CAN POSSIBLY 9 USE IN THE FORESEEABLE FUTURE, MORE COSTLY ELECTRICITY TO 10 THE FARMERS WHO W ILL HAVE TO PUMP GROUNDWATER TO REPL ACE 1

11 THE LOSS OF PALO VERDE'S EFFLUENT FOR l RR IG AT I ON, MORE USE 12 0F PETROLEUM AND OTHER RESOURCXES AND MORE ENERGY TO 13 PRODUCE THE FERTILIZER NECESSARY TO REPL ACE THE LOSS OF rO 14 NUTRIENTS IN THE EFFLUENT, MORE PETROLEUM USED TO 15 TRANSPORT MORE AGRICULTURAL PRODUCTS INTO ARIZONA AS ONE 16 AFTER ANOTHER MORE LOCAL FARMS GO OUT OF BUSINESS DUE TO

)

17 THE BAD ECONOMICS OF PALO VERDE, MORE ELECTRICITY TO PUMP 18 CENTRAL ARIZONA PROJECT WATER TO HELP REPLACE SOME OF THE 19 WATER LOST TO THE FARMERS AND CITIES FOR PALO VERDE, MORE 20 WATER TAKEN FROM THE ALREADY OVER-ALLOCATED COLORADO 21 RIVER, A RIVER NO MORE.

22 MANY OF US WHO LIVE HERE SEE THIS AS THE

)

23 SECOND L ARGEST B00NDOGGLE IN ARlZONA HISTORY BEING USED To O 24 SUBSIDlZE THE LARGEST B00NDOGGLE IN ARIZONA: .PALO VERDE.

25 THE PROCESS IS AS CIRCUL AR AS APS'S LOGIC

)

""*"E^="r"4"41M'?"d"*' '"'"dC#i*o*!!'5 ' f TELEPHONE 2794711

2917 1 WHEN IT STILL TRIES TO SAY PALO VERDE IS ECONOMICAL. IN A 2 DESERT, ECONOMY MUST BE BASED ON EFFICIENT USE OF THE

() 3 LEAST AMOUNT OF NONRENEWABLE RESOURCES POSSIBLE. THE ONLY 4 THING PALO VERDE 2 AND 3 WILL ECONOMlZE ON IS APS'S PROFIT 5 MARGIN, AND THAT IS ALREADY L ARGE ENOUGH.

6 PALO VERDE WILL CONSERVE NOTHING. IT WILL 7 REQUIRE EVER-INCREASING INPUTS OF SCARCE RESOURCES, 8 PARTICULARLY WATER. AND WHAT WILL YOU 00 IF ALL THREE 9 UNITS GO INTO OPERATION AS MORE GOLF COURSES AND 10 DEVELOPMENT PROJECTS BEGIN TREATING THElR OWN W ASTE WATER, 11 PULLING IT OUT OF THE SYSTEM 7 WHAT WILL YOU DO AS 12 HOME0WNERS CONSERVE MORE WATER, WATER THEIR LAWNS MORE 13 INTELLIGENTLY, FLUSH LESS OFTEN OR AT LOWER VOLUME AS THE 14 COST OF W ATER INCREASES? 'WHAT WILL YOU DO AS THE RATIO OF 15 WATER TO WASTE DROPS? HOW WILL YOU OPERATE PALO VERDE 16 SAFELY AS MORE OF US LEARN WHAT APS IS UNWlLLING TO LEARN:

17 HOW TO CONSERVE OUR SCAREST AND MOST PREC10US RESOURCE, 18 WATER.

19 THESE PROBLEMS, WHICH YOU Dl0 NOT RESOLVE 20 THE L AST TIME YOU HELD HEARINGS, HAVE NOT BEEN RESOLVED 21 SINCE. THE L AWSUITS BY NATIVE AMERICANS, SO OFTEN ROBBED 22 0F THEIR FAIR SHARE BY OUR SOCIETY, HAVE NOT DISAPPEARED.

fg 23 MORE LAWSUITS HAVE BEEN ADDED -- BY A LOCAL DEVELOPER --

V 24 lN AN ATTEMPT TO NEGOTI ATE A SETTLEMENT WITH THE CITIES --

25 AT A HIGHER COST OF W ATER -- FELL APART WHEN THE FARMERS

"*" " a*a"A%' " '"' *:%y""alio' ,1,*:

1.umo~. m m

2918 1 WERE EXCLUDED.

2 THE LEGAL PROBLEMS YOU REFUSED TO EXAMINE

() 3 LAST TIME HAVE NOT JUST GONE AWAY AND THEY WILL NOT GO 4 AWAY JUST BECAUSE YOU IGNORE THEM. THERE IS NO ASSURED 5 SUPPLY OF W ATER FOR PALO VERDE IN THE LONG TERM. WHAT 6 WILL YOU SAY WHEN THE W ATER RUNS OUT7 7 THANK YOU.

8 JUDGE L AZO: THANK YOU, MISS LAPLACA.

9 MS. BUSH: MY NAME IS BARBARA BUSH, B-U-S-H.

10 l'M PRESIDENT OF THE COAL ITION FOR RESPONSIBLE ENERGY 11 EDUCATION, ALSO KNOWN AS CREE.

12 i WOULD LIKE TO SHARE THE INCREASING CONCERN 13 THAT MANY OF US FEEL THAT THE NRC AND ARIZONA PUBLIC-14 SERVICE ARE FOSTERING DANGEROUS ATTITUDES OF 15 NONRESPONSIVENESS AND SECRECY.

16 BY ITS OWN ESTIMATE, THE NRC PHYSICALLY t

17 INSPECTS AND OVERSEES LESS THAN TWO PERCENT OF PLANT 18 SYSTEMS AND ACTIVITIES. IT NEEDS THE INPUT OF THE PUBLIC, 19 NOT ONLY TO ENSURE THAT THE PUBLIC'S HEALTH AND

)

20 ENYlRONMENTAL CONCERNS ARE BEING MET, BUT TO ENSURE THAT 21 IT 15 ABLE TO PERFORM ITS TECHNICAL JOB 0F GUARANTEEING 22 PLANT SAFETY. THE NRC ONLY LOOKS AT THE TIP OF THE

)

23 ICEBERG. FOR MOST OF iTS INFORMATION ON PLANT SAFETY, IT

(

24 RELIES ON THE UTILITIES, AND ARIZONANS HAVE VERY LITTLE 25 CONFIDENCE THAT APS CAN BE RELIED UPON.

)

  • ^"!"#r*a"4 M'.?" '"*- T'on'O!Tio'fi."

TELEPHONE 279 4711 f

f 2919 1 IT HAS COME TO OUR ATTENTION IN RECENT WEEKS 2 THAT APS HAS RETURNED TO THE POLICY IT FOLLOWED THROUGHOUT

() 3 MOST OF THE HISTORY OF PALO VERDE OF REFUSING TO DEBATE OR 4 MEET FACE-TO-FACE IN OPEN DISCUSSION WITH THE CRITICS OF t

5 ITS NUCLEAR POWER PROGRAM. THE EXTENT OF THIS POLICY IS 6 NOT CLEAR. CERTAINLY APS HAS REFUSED TO DEBATE ANY 7 REPRESENTATIVE OF CREE, AN OFFICIAL RATE CASE INTERYENOR.

)

8 APS ARROG ANTLY WRAPS ITSELF IN A CLOAK OF 9 TECHNICAL SUPERIORTY AND J ARGON AS IF IT WERE A NUCLEAR 10 PRIESTHOOD. IN FACT, APS IS ITSELF INEXPERIENCED IN

)

11 NUCLEAR POWER PLANT OPERATION. ITS TWO CHIEF EXECUTIVE 12 0FFICERS ARE NOT PHYSICISTS OR ENGINEERS OR EVEN 13 PROFESSIONAL FINANCIERS; THEY ARE PUBLIC RELATIONS O 14 SPECIALISTS. NO WONDER MOST ARl20NANS SHARE THE 15 PERCEPTION THAT APS ALWAYS HAS AND STILL DOES PUT P.R.

16 AHEAD OF PUBLIC SAFETY, ECONOMIC RESPONSIBILITY AND 17 DEMOCRATIC GlVE-AND-TAKE.

18 IN THE PAST APS REFUSED TO DEBATE ITS 19 CRITICS UNTIL 1984, WHEN, DESPERATELY IN NEED OF A 20 FINANCIAL BAILOUT BY RATE PAYERS FROM ITS PALO VERDE DEBT, 21 IT FOUND IT POLITICALLY EXPEDIENT TO DO S0. AFTER 22 RECElVING A RATE HlKE, APS HAS REVERTED TO TYPE. IT HAS 23 OECIDED IT NO LONGER NEEDS PUBLIC SUPPORT So IT lGNORES O 24 PUBLIC CONCERN. IF APS HAS DONE THIS ON THE ASSUMPTION 25 THAT THERE WILL BE NO PUBLIC CONTROVERSY OVER UNITS 2 AND

'"'c"

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    • %Cllic' .',',*:

TELEPHONE 279 4711 h

i 2920 1 3, THEY ARE IN GRIEVOUS ERROR. ARIZONANS UNDERSTAND THAT t

2 UNIT 1 IS MAINLY NEEDED BY APS STOCKHOLDERS, NOT APS

() 3 CUSTOMERS. AND WE FEEL THAT UNIT 1 IS A MISTAKE; UNIT 3 4 IS AN INSULT.

t 5 APS HAS CONTINUALLY DENIED THE MEDIA AND THE 6 PUBLIC lMPORTANT INFORMATION ON PROBLEMS AT THE PALO 7 VERDE PLANT. NO ONE CAN FORGET THE SUPPRES$10N OF t

8 lNFORMATION ON THE 1983 FAILURE OF THE REACTOR COOLANT 9 SYSTEM. MORE RECENTLY, APS FAILED TO REVEAL THE EXTENT OF 10 PROBLEMS WITH MICROORGANISMS IN THE SPRAY PONDS AT PALO 11 VERDE.

12 WITH SUCH NONRESPONSIVENESS TO PUBLIC 13 CONCERNS BY APS, THE ROLE OF THE NRC BECOMES EVEN MORE 70 14 CRITICAL.

15 BUT APS HAS NOT BEEN ALONE IN ITS 16 NONRESPONSIVE ATTITUDES. IN 1983 ON THE REACTOR COOLANT 17 SYSTEM FAILURE, AND AGAIN IN 1985 ON THE MICROORG ANISM

! 18 CORROSION, THE NRC ALLOWED ITSELF TO BE INSTRUCTED BY APS 4

19 NOT TO RELEASE PRELIMINARY SAFETY NOTIFICATION INFORMATION 20 TO THE PRESS. THE PUBLIC HAS A RIGHT TO KNOW ABOUT SUCH 21 PROBLEMS AS THEY ARISE, NOT ONLY WHEN AND IF lT IS I 22 POLITICALLY CONVENlENT FOR THE UTILITY TO INFORM THEM.

23 THE NRC HAS ALSO FAILED TO FULFILL ITS l0 24 RESPONSIBILITIES DURING THE LICENSING PROCESS. CREE HAS 25 FILED TWO PETITIONS TO SHOW CAUSE WITH THE NRC ON PALO

~:::==.* ~- ==~: =.u,':

TELEPHONE 279 4711

)

2921 1 VERDE UNIT 1. BOTH HAVE BEEN ACCEPTED BY THE NRC, YET IT 2 HAS FAILED TO ISSUE A TIMELY RESPONSE ON THOSE LEGALLY

() 3 VALID PETITIONS PRIOR TO UNIT 1 LICENSING AS REQUIRED BY 4 ITS RULES AND REGULATIONS. THE PROBLEMS ADDRESSED IN 5 THOSE PETITIONS, BACTERIA, CORROSION, AND FINANCIAL 6 QUALIFICATION, ARE RELEVANT TO UNITS 2 AND 3 AS WELL, BUT 7 WE FEEL LITTLE ASSURANCE THAT THEY WILL BE ADEQUATELY 8 ADDRESSED.

9 THE NRC HAS RECENTLY ADOPTED A CLOSED-DOOR 10 POLICY ON PRIV ATE MEETINGS WITH UTILITIES AT WHICH NO 11 MINUTES WILL BE TAKEN, CONSEQUENTLY DENYING POSSIBLE 12 FREEDOM OF INFORMATION ACCESS AND PUBLIC RIGHTS OF DUE 13 PROCESS. THE DECISION HAS APPROPRIATELY BEEN REFERRED TO 14 AS THE NRC ANTI-EMBARRASSMENT ACT OF 1985. CONGRESSMAN 15 MARKEY CORRECTLY STATED: "I CANNOT lMAGINE THAT IT IS IN 16 ANYONE'S BEST INTEREST TO DRAW DOWN A LED CURTAIN AROUND 17 NRC DELIBERATIONS."

18 THE EXTENT OF NRC NONRESPONSIVENESS APPEARS 19 TO HAVE GREATLY INCREASED IN THE PAST YEAR. IN MARCH 1984 1

20 NRC CHAIRMAN NUNZIO PALLADINO ISSUED AN INTERNAL MEMO 21 CALLING FOR EXPEDITED LICENSING OF A DOZEN TROUBLED y

22 NUCLEAR PROJECTS, INCLUDING THE THREE PALO VERDE REACTORS.

23 THE NRC W AS CRITIClZED BY CONGRESSMAN MARKEY FOR PUTTING p( /

24 UTIL ITY FINANCI AL NEEDS AHEAD OF PUBLIC SAFETY.

25 NONETHELESS, THE OFFICE OF NUCLEAR REACTOR REGULATION

)

"**:A"r*a"3%'#*** **" %2"!!i*o'Ch *1 TELEPHONE 2794711 I

I 2922 1 RUSHED TO SPEED UP AND SHORTCUT PL ANT L ICENSING AND F

2 INSPECTION PROGRAMS THROUGH THE INSTITUTION OF SPECI AL

() 3 TASK FORCES, EARLY READINESS REVIEWS, AND THE SETTING 0F 4 ARTIFICI AL LICENSING TARGET DATES -- WITH THE HAPPY 5 COOPERATION OF THE UTILITIES -- AT PALO VERDE AND 6 ELSEWHERE. QUALITY CONTROL FINES WERE REDUCED AT PALO 7 VERDE AND ELSEWHERE. ONE INTERVENOR WAS REPORTEDLY TOLD F

8 BY THE NRC THAT THERE WOULD NEVER BE AN INDEPENDENT 9 REINSPECTION OF A NUCLEAR PLANT IN THIS COUNTRY, DESPITE 10 CONCERNS THAT QUALITY CONTROL PROBLENS AT PALO VERDE AND 11 MANY OTHER PL ANTS COULD BE JUST THE TIP OF THE lCEBERG.

12 THE PUBLIC HAS BEEN LEFT WITH THE DISTURBING 13 FEELING THAT THE NRC IS AFRAID OF WHAT IT MIGHT FIND, 30

)

O 14 IT HAS JUST STOPPED LOOKING. SMALL WONDER THE NRC,HAS 15 INCREASED ITS ESTIMATE OF THE LIKELlHOOD OF A MELTDOWN 16 ACCIDENT AT A U.S. PLANT TO 50-50.

)

17 THE NRC HAS LICENSED DIABLO CANYON, 18 SHOREHAM, AND OTHER PL ANTS AGAINST THE ADVICE OF ITS OWN 19 TECHNICAL AND LEGAL STAFFS. IT HAS FORCED RECONSIDERING

)

20 0F THE REFUSAL 0F A LICENSE TO BYRON. IT HAS IGNORED THE 21 LONGER-TERM CORROSION PROBLEM AT PALO VERDE. IT IS 22 lMPOSSIBLE NOT TO CONCLUDE THAT THE GOOD FAITH EFFORTS OF

)

23 THE MAJORITY OF NRC STAFFERS, AS WELL AS INTERVENORS AND O 24 WHISTLEBLOWERS, HAVE BEEN SHORT-CIRCUlTED BY POLITICAL 25 CONCERN FOR UTILITY INVESTMENTS.

)

      • "!!v^n"rnI"4EE'nY"""** 'M'o$!CEIi'o*feUlf TELEPHONE 279 4711 3

2923 1 NOW THIS BOARD COMES TO CONSIDER TWO 2 REACTORS AT ONCE. PRESUMABLY THIS IS JUST ONE STEP AWAY 3 FROM THE ONE-STEP LICENSING THE ADMINISTRATION ADVOCATES.

4 BUT IT MAKES NO SENSE. IT IS PREMATURE. IT IS NOT 5 NECESSARY TO LICENSE UNIT 3 AT THIS TIME.

6 IT IS IMPOSSIBLE FOR US TO FEEL CONFIDENCE 7 THAT EITHER PLANT WILL BE SAFE.

8 WHAT IS ALL THE RUSH FOR7 CERTAINLY IT DOES 9 NOT SERVE THE PUBLIC HEALTH AND SAFETY OR ITS RIGHT TO 10 KNOW.

11 MS. HARWARD: 1 AM NAOMI HARWARD WITH THE 12 GRAY PANTHERS.

13 YOU HAVE HEARD EXCELLENT STATEMENTS AND 14 ARGUMENTS IN TERMS OF THE PROBLEM OF WATER WHICH IS S0 15 PRECl0US TO US IN THE VALLEY, MORE PRECl0US SOMETIMES THAN 16 THE CORPORATIONS REALIZE. WE PEOPLE HAVE TO HAVE WATER.

17 WE HAVE HEARD ABOUT THE FAILURE HERE OF THE 18 COMMISSION TO FOLLOW THROUGH AND CHECK ON THINGS THAT WE 19 HEAR ARE PROBLEMS THERE. THE WELD IN THE PlPES, THEY ARE I

20 STILL LEAKING, AND WE UNDERSTAND THERE'S B ACTERI A THERE.

21 AND NOTHING is BEING DONE ABOUT IT, AND IT IS BEING 22 IGNORED. AND IT IS GOING AT A GREAT RATE IN UNIT 2. NOW,

. 23 THERE'S N0 WORD ABOUT IT IN 3, BUT THAT PROBA8LY HASN'T 24 ADVANCED TO THAT STAGE. S0 THAT WE HAVE VERY LITTLE 25 FEELING THAT WE CAN DEPEND ON THIS BEING A REALLY SOUND I

"*"!!u^n"r"S"4EE n?"' '"*' 'E*o"dCEIi*o*u"fe*o'il TELEPHONE 279 4711 I

2924 1 PROGRAM. AND IT'S ONLY 50 MILES FROM US. WE ARE 2 TERRIFIED BY THIS. AND WE FEEL THAT THE WHOLE ISSUE OF 3 USE OF EFFLUENT AND THE POSSIBILITY OF VIRUS BEING SPREAD 4 THROUGHOUT THE VALLEY IS BEING IGNORED. THERE ARE TOO 5 MANY THINGS BEING lGNORED IN THIS.

6 AND THEN THE LAST PolNT THAT WAS MADE, WHY 7 lN THE WORLD 00 YOU CONSIDER THE LICENSING OF UNIT 3 WHEN 8 IT'S ONLY JUST BEGINNINGt THAT CERTAINLY DOESN'T GIVE US 9 ANY REASSURANCE THAT YOU ARE GOING TO WATCH THE PROCESS.

10 THAT'S WHAT WE THOUGHT A REGULATORY COMMISSION WAS FOR IS 11 TO WATCH THE PROCESS AND SEE FOR SURE IT'S SOUND.

12 WE CHALLENGE YOU. WE WANT YOUR HELP. WE 13 NEED YOUR HELP. THE PEOPLE ARE REALLY HAYlNG A TERRIBLE 14 TIME WITH THIS. THE COST IS AN UNBELIEVEABLE THING. AND 15 IN THESE TIMES WHEN THERE IS RUNOR THAT WE ARE ON THE 16 VERGE OF A DEPRESSION, WHAT WILL THAT MEAN TO US? IT CAN 17 REALLY BANKRUPT MANY OF THE SMALL INDUSTRIES IN THE f

18 VALLEY. AND WHAT WILL IT DO TO THE POOR PEOPLE? THESE 19 ARE THINGS THAT APPARENTLY JUST ARE FORGOTTEN. AND I URGE f

20 YOU AS THE COMMISSION, WE NEED YOUR HELP. WE NEED TO FEEL 21 THAT WE CAN DEPEND UPON YOU. LET'S HEAR FROM YOU.

22 THANK YOU.

23 JUDGE LAZ0: THANK YOU.

! O- 24 MS. HARRlNGTON: YOU HAVE TO EXCUSE NE IF MY l

25 V0lCE DOESN'T COME THROUGH. I HAVE STREP THROAT BUT I

      • "ESu^n" rya"SEEn's"" ***'o$!Ca*Iio*u"Es"so*1 Ttt.EPHONE 279-4711

I L

2925 1 FELT THAT l NEEDED TO BE HERE. IN THE PAST I HAVE BEEN 2 HERE, AND I HAVE DONE EVERYTHING I CAN IMAGINE TO TRY TO

() 3 STOP PALO VERDE, TO EDUCATE THE PUBLIC ABOUT PALO VERDE.

4 JUDGE L AZO: WOULD YOU PLEASE STATE YOUR 5 NAME7 6 MS. HARRINGTON: MY NAME IS SHARON 7 HARRINGTON, H-A-R-R-t-N-G-T-0-N.

8 JUDGE LAZO: THANK YOU, MRS. HARRlNGTON.

9 MS. HARRlNGTON: 1 FEEL TH AT WH AT I H AV E TO 10 SAY 15 NOT PERSONALLY DIRECTED AT ANY OF YOU BECAUSE 11 PERSONALLY l LOVE YOU. THE PRESS TOLD ME TO LOVE YOU. I 12 DON'T CONSIDER YOU PERSONALLY MY ENEMIES. BUT l REALLY 13 TRULY FEEL THAT THE MERE EXISTENCE OF THE NUCLEAR iO 14 REGULATORY COMMISSION IS A MORTAL SIN BECAUSE NUCLEAR 15 POWER CANNOT BE REGULATED. YOU SHOULD BE A SOLAR ENERGY 16 COMMISSION OR AN ALTERNATIVE FUTURE LIFE-GIVING 17 COMMISSION.

18 IN THE PAST l HAVE STAYED UP ALL NIGHT LONG 19 TRYING TO PREPARE A STATEMENT AND TRYlNG TO BE -- NOT 20 BEING EMOTIONAL. I DON'T FEEL WELL TODAY, BUT I AM HERE 21 TO SPEAK AS A MEMBER OF THE PUBLIC AND AS A MOTHER, WHO I 22 AM.

23 i FEEL WHAT HAS BEEN SAID HERE TODAY iS 24 REALLY IMPORTANT TO LISTEN TO.

25 WHEN YOU ASKED US DON'T TALK ABOUT ANYTHING

'"c-

~ ~ "is ta *a "a % ? " " % D D : n *,*:

TELEPHONE 2794711

2926 1 BUT THE SALT, THAT REALLY UPSET NE. I FELT THAT THAT'S A 4

2 TYPICAL ARROGANT STATEMENT OF THiS -- 0F THE ATOMIC

() '3 LICENSING BOARD, THE NRC, THE UTILITIES, ALL OF YOU, 4 BECAUSE I THINK YOU ARE AFRAID TO REALLY TRULY ADDRESS 9

5 WHAT IS HAPPENING =HERE.

6 THERE ARE FAR WORSE THINGS COMING OUT OF 7 THAT PLANT THAN SALT. THERE'S PLUTONIUM, THERE'S i

8 TECHNETlUM, STR0THlUM (SIC) IT GETS INTO THE L IFE CYCLE 9 AND THE FOOD CHAlN. THESE THINGS CAN'T BE IGNORED.

10 IN 1979 I TOOK PART IN A NONVIOLENT PROTEST 1

11 AGAINST THE PALO VERDE NUCLEAR PL ANT. I WAS ARRESTED. I 12 WAS ARRESTED L AST WEEK. I AM WILLING TO GO TO J AIL AND 13 STAY THERE FOREVER IF i COULD DO SOMETHING TO HELP BRING 14 ATTENTION TO WHAT IS HAPPENING WITH THE NUCLEAR FUEL 15 CHAIN. I DON'T THINK PEOPLE EVER CONSIDER THE EFFECTS OF 16 THE WHOLE NUCLEAR FUEL CHAlN.

17 MY HUSBAND DREW THIS LAST NIGHT, AND MY 18 DAUGHTER ASKED ME TO READ SOMETHING FROM THIS BOOK.

19 THIS IS A CHART CLEARLY SHOWING NO MATTER

.)

20 HOW MANY TIMES APS SAYS THERE ARE NO DANGERS IN PALO VERDE 21 OR THE NUCLEAR FUEL PROCESS, THE SIMIL ARITIES BETWEEN THE 22 BOND, THE NUCLEAR FUEL CHAlN TO MAKE ATOMIC WEAPONS, THE

)

23 NUCLEAR FUEL CHAlN TO ELECTRICITY THAT WOULD NOT BE NEEDED 24 IF WE PUT SOME ONE-TENTH OF THE MONEY INTO DEVELOPING 25 SOL AR ALTERNATIVES, EVEN PASSIVE SOL AR. IF PEOPLE USED

)

" *** au*a a *A W ;',? *"** ****tfCEliEFA'?!

o TELEMeONE 279-4711 I

l 2927 1 PASSIVE SOL AR ENERGY THERE WOULD BE NO NEED. IF WE HAD i

2 SIMPLE, ARCHITECTURALLY SOUND BUILDINGS, THERE WOULD BE NO

() 3 NEED FOR PALO VERDE.

4 THE WAY THINGS ARE DONE SEEM INTERCONNECTED i

5 FOR WASTE. AND THAT'S THE PROBLEM WITH AMERICA ON THE 6 WHOLE. BUT THIS FUEL CHAlN SHOWS DEATH AT THE VERY 7 BEGINNING IN URANIUM MINING. I HAVE SEEN PEOPLE IN TUBA

)

b CITY, LITTLE CHILDREN -- l HAVE SEEN THEM. I HAVE GONE UP 9 THERE. BECAUSE WHEN WE WERE ARRESTED AT PALO VERDE THE 10 NATIVE AMERICAN PEOPLE FROM BIG MOUNTAIN CAME DOWN TO 4-11 SUPPORT OUR ACTION AND THEY WANTED PEOPLE TO SEE WHERE 12 THEY ARE, TO SEE THAT THEY ARE FORCED INTO hELOCATION FROM 13 THElR ANCESTRAL HOMELAND AND TO SEE THAT THEIR CHILDREN 14 ARE DRINKING IT AND PLAYING IN IT AND TO SEE THAT THE 15 SPILLS THAT THE NUCLEAR REGULATORY COMMISSION -- YOU 16 YOURSELVES HAVE SAID THE TURCOTT (SIC) SPILLS IS WORSE f

17 THAN THREE MILE ISLAND. THOSE THINGS CAN'T BE IGNORED.

18 THAT'S JUST-THE BEGINNING. THERE IS DEATH IN THE.

19 BEG I NN I NG. -THERE IS DEATH IN THE MIDDLE, IN THE LOW LEVEL l 20 WASTE, WITH THE HIGH LEVEL WASTE. EVERY PHASE OF THIS, 21 THERE'S DEATH.

22 I DON'T WANT TO BE REDUCED TO TEARS SO I AM

)

23 GOING TO SUM THIS UP. I REALLY FEEL -- AS INDIVIDUALS I 24 DON'T THINK YOU WANT THE JOBS THAT YOU HAVE IF YOU FELT 25 THAT YOU HAVE A CHOICE ANY MORE.

"^**!!u^a"4"4*M'a?"""*- '"'"dCEIro%'"

o *12 TELEPHONE 279-4711 5

l

2928 1 WHEN I -- THE DAY -- LAST -- THE END OF MAY 4

2 WHEN WE WERE ARRESTED AT PALO VERDE WHEN WE STARTED THE

() 3 CHAIN REACTION OURSELVES S,YMBOLICALLY BECAUSE THAT WAS OUR 4 REACTION TO THEIR REACTION, WE FELT THAT -- 1 FELT THAT --

)

5 i KNOW IT W ASN'T GOING TO STOP THE PL ANT. BUT IF IT 6 HELPED EDUCATE SOMEBODY, IT WAS WORTH iT.

7 I REALLY FEEL THAT OUR CHILDREN'S FUTURES

)

8 ARE BEING DUMPED ON, IF THERE EVEN IS ONE. AND l KNOW 9 THAT YOU MEN MORALLY DON'T TAKE RESPONSIBILITY FOR THAT.

10 1 THINK IT'S JUST THAT THIS BALL HAS GOTTEN SO BIG AND SO

)

11 OUT OF CONTROL THAT INDIVIDUALS FEEL INTIMIDATED. THAT'S 12 WHY THERE AREN'T MORE PEOPLE HERE TODAY. I FEEL SHAKY 13 MYSELF AND I HAVE BEEN INYOLVED IN THIS SINCE 1979. THE

) O~ MORE I LEARN, THE MORE I KNOW THAT THIS IS WRONG, WITHOUT

. 14

! 15 MORALITY. IT'S TOTALLY EVIL. AND TH AT' S W HAT I S 16 HAPPENING. THERE IS NO SENSE OF MORAL ITY OR FORES IGHT OR 17 THOUGHT TO WHAT WE ARE D0 LNG. WHAT WE HAVE TO CONSIDER IS 18 FAR BEYOND US AS INDIVIDUALS. IT ISN'T REALLY. I MEAN l 19 INDIVIDUALLY IF EACH DECIDED TO DO SOMETHING HEALTHY, THIS V

20 WOULDN'T BE. BUT THAT'S WHY l AM PLEADING WITH YOU. I AM 21 NOT PLEADING WITH YOU AS THE NUCLEAR REGULATORY COMMISSION l

22 BECAUSE IN MY OPINION THAT COMMISSION HAS NO RIGHT TO i

23 EXIST. I AM PLEADING WITH YOU AS INDIVIDUALS TO PLEASE 24 DON'T RUSH THESE PLANTS. DON'T ALLOW THESE WELLS TO GO ON 25 LINE WITH THE CORROSION PROBLEMS AND THE BACTERI A

~ ~ : : : : " m ': e '"c- -

=W" li=3*:

i TELEPHONE 2794711

2929 1 PROBLEMS. DO ANYTHING YOU CAN TO STOP THIS AS 2 INDIVIDUALS.

() 3 NOW THE ONLY -- THE L AST THING l HAVE TO SAY  ;

4 IS FROM MY DAUGHTER. SHE WANTED TO BE HERE TODAY BUT I 5 THOUGHT SHE HAS ENOUGH TO DO IN HER YOUNG LIFE. SHE HAD A 6 BIRTHDAY YESTERDAY. SHE TURNED NINE YEARS OLD. AND I 7 WANTED HER JUST NOT TO HAVE TO CONSIDER THIS FOR TODAY.

t 8 BUT SHE DID ASK ME TO READ THIS L ITTLE STATEMENT HERE FROM 9 DR. SEUSS. I HAVE SUBSTITUTED A WORD, WICKERSHAM, FOR 10 BECHTEL. I FEEL LIKE HORTON STANDING HERE RIGHT NOW.

I 11 IT'S "HORTON HEARS A WHO," AND IT'S A LESSON IN CIVIL 12 DISOBEDIENCE.

13 "h0RTON FOUGHT BACK W ITH GREAT YlGOR AND V lM

)

() 14 BUT THE BECHTEL G ANG WAS TOO MANY FOR HIN. THEY BEAT HIM.

15 THEY MAULED HIN. THEY STARTED TO HAUL HIM INTO HIS CAGE.

16 BUT HE MANAGED TO CALL TO THE MAYOR, ' DON'T GIVE UP. I

)

17 BELIEVE IN YOU ALL. A PERSON'S A PERSON, NO MATTER HOW 18 SMALL. AND YOU VERY SMALL PERSONS DO NOT HAVE TO DIE IF 19 YOU MAKE YOURSELVES HEARD. SO COME ON.'"

l 20 PLEASE, ARIZONA, TRY.

21 JUDGE L AZO: THANK YOU, MRS. HARRINGTON.

22 GOOD MORNING.

23 MR. TEPP: GOOD MORNING.

( MY NAME IS MURRAY TEPP, T-E-P-P. I AM A 24 25 RESIDENT HERE IN PHOENIX. I AM NOT AN OFFICER OR MEMBER f

'"c-l "c" "a*a"AM;'#"

V ' #dCEli:Ch'1:*

TELEPHONE 279-4711

r 2930 1 0F ANY ORGANIZATION OR GROUP, BUT I HAVE TAKEN PART IN y.

2 SOME OF THE DEMONSTRATIONS OPPOSING NUCLEAR POWER PL ANTS HERE IN OUR VALLEY. I AM FAMILIAR WITH MANY OF THE

(]) 3 4 PROBLEMS THAT THERE ARE BECAUSE I HAVE STUDIED AND READ A 9

5 GREAT DEAL THAT CONCIRN THE BUILDING OF THE SECOND L ARGEST 6 NUCLEAR FACILITY HERE IN THE MIDST OF OUR DESERT. AND 7 FRANKLY MY WlFE AND I WHO HAVE A MONTH-OLD CHILD ARE VERY

)

8 WORRIED ABOUT WHAT COULD HAPPEN AT PALO VERDE. WE H AV E 9 SEEN THE RECORDS, WE HAVE READ -- WE HAVE SEEN ON TV 0F

~

10 THE MANY, MANY MISHAPS. WE RECENTLY VIEWED IN FACT L AST 9

11 WEEK ON CHANNEL 3 HERE, ABC, THE TV DOCUMENTARY THAT VERY 12 FRANKLY FRIGHTENED US VERY MUCH. I REALLY HOPE THAT THIS

! 13 COMMISS.10N SAW THAT SAME DOCUMENTARY BECAUSE IT HAD A

>O 14 GREAT DEAL TO DO AND SAY ABOUT THE ACTIVITIES OF THIS 15 COMMISSION IN THE PAST, ITS CURRENT POLICIES. AND I WOULD 16 LIKE TO ADDRESS MY REMARKS TO A FEW ITEMS THAT CAME UP IN 17 THAT DOCUMENTARY AND ALSO THAT ARE VERY APPROPRIATE FOR 18 OUR VALLEY.

l l 19 THE DOCUMENTARY WAS CALLED THE FIRE

)

20 UNLEASHED, AND THERE WAS A SEGMENT IN IT OF APPROXIMATELY 21 ,35 TO 40 MINUTES THAT ADDRESSED THE SAFETY RECORD AND THE l ~

l 22 RECORD OF THE NRC IN LICENSING A LOT OF NUCLEAR PLANTS IN l 23 THE UNITED STATES. IT ALSO ADDRESSED -- AND I THINK IF I lC 24 WERE TO SPEAK ABOUT ALL OF THOSE PROBLEMS i WOULD BE HERE 25 FOR HOURS. I DON'T INTEND TO. I WILL JUST BRING UP THE f.

l

"^**a^""4"4M?" '"*- '"'AS E !#"#! l TELEPHONE 279 4711

i 2931 1 ITEMS THAT I AM SURE THIS COMMISSION IS AWARE OF AND LET 2 YOU KNOW HOW I FEEL AS AN INDIVIDUAL AND TAXPAYER AND RATE

() 3 PAYER HERE IN PHOENIX ABOUT THOSE PROBLEMS.

4 THE PROBLEM BROUGHT UP WAS THE PROBLEM OF 5 NUCLEAR WASTE AND THE DISPOSAL OF THE WASTE THAT THE ,

6 NUCLEAR PL ANT GENERATES. NOW THAT WASTE IS GROWING EVERY 7 DAY. THE QUANTITIES OF W ASTE BECOME MONSTROUS. AT THE 8 PRESENT I DON'T BEL IEVE THERE IS AN ACCEPTABLE PL AN TO 9 STORE, ELIMINATE, DO ANYTH ING W ITH THAT WASTE.

10 1 DON'T BEL IEVE WE SHOULD HAVE ANY MORE 11 PLANTS UNTIL THIS COMMISSION COMES UP WITH AN ACCEPTABLE, 12 SAFE METHOD OF TAKING CARE OF THAT WASTE.

13 IN ADDITION, THIS COMMISSION IS AN OUTGROWTH 14 0F THE OLD ATOMIC ENERGY COMMISSION, WHOSE ORIG INAL 15 PURPOSE W AS TO ENCOURAGE AND PROMOTE ATOMIC ENERGY FOR 16 PEACEFUL USE. THAT HAS CHANGED NOW. NOW IT IS YOUR p

17 PURPOSE ONLY TO REGULATE AND CONTROL THE SAFETY OF NUCLEAR 18 PLANTS. I DON'T BELIEVE IT IS THIS COMMISSION'S JOB TO 19 PROMOTE PALO VERDE ANY MORE, WHICH IT SEEMS IT DOES TO ME, 9

20 BUT ONLY TO REGULATE THE SAFETY. AND THE RECORD OF SAFETY 21 HAS NOT BEEN SO GREAT IN THE LAST COUPLE OF YEARS. IT 22 SEEMS THAT THE PATTERNS HAVE PERSISTED AND THAT THIS k

i 23 COMMISSION IS TOO CLOSE TO THE INDUSTRY IT IS SUPPOSED TO 24 REGULATE RATHER THAN BE FORCED INTO REGULATIONS THAT 25 PROTECT MY SAFETY.

)

"**="r*4"4W:'#" '"*- 3 0 0 #! A 'fl TELEPHONE 279-4711

)

2932 1 IN ADDITION, 1 AL SO B EL I EV E TH AT TH I S AG ENCY 2 BELIEVES THAT I AS THE PUBLIC IS YOUR ENEMY, THAT l COME

() 3 HERE AS YOUR ENEMY. AND I DON'T BEL lEVE THAT' S S0. I 4 BELIEVE YOUR ENEMY IS THE DANGER OF NUCLEAR DISASTER.

5 FROM EVERYTHING l HAVE READ, THERE SEEMS TO BE -- YOU ARE 6 FIGHTING US RATHER THAN PROTECTING US.

7 i HESITATE TO EVEN BRING UP THE POSSIBIL ITY 8 0F WHAT WOULD HAPPEN IF THERE WERE A MELTDOWN AT PALO 9 VERDE. I HAVE READ ABOUT PALO VERDE. I HAVE READ A LOT 10 ABOUT THE EV ACU ATION PL AN. TO ME IT SEEMED TO BE A FARCE.

11 IT WAS SOMETHING THAT WAS SO L IGHTLY GLOSSED OVER. BUT IT 12 IS A POSSIBILITY.

13 CHILDREN WHO LIVE WITHIN MILES OF THE PLANT 3

eO 14 ARE SUPPOSEDLY PICKED UP BY BUS DRIVERS AND TAKEN AWAY. .

15 WHO IS GOING TO GET THE BUS DRIVERS? THEY ARE GOING TO BE 16 GONE BEFORE THE WORD I S OUT.

/

17 WE USE BALLOONS TO SEE WHICH WAY THE 18 PREVAILING WINDS BLOW, AND THOSE WINDS BLOW EAST. ANY 19 RADIATION RELEASED FROM PALO VERDE WILL DRIFT TO PHOENIX.

h 20 AND THE SCIENTISTS TODAY HAVE REVERSED THElR 21 ORIGINAL THOUGHT ABOUT ACCEPTABLE LEVELS OF RADI ATION. AT 22 THE TIME OF THREE MILE ISLAND AND SOME OF THE EARLIER

)

23 MISHAPS, THERE WERE LEVELS THAT THEY SAID WELL, THEY ARE O 24 ACCEPTABLE. EVEN WITH THOSE ACCEPTABLE LEVELS THERE HAVE 25 BEEN ALL KINDS OF ABERRATIONS OF ANIMALS. PEOPLE HAVE

)

"^"Eo"u^nY[EP"'EE n's' ' '"' $***o"d[c"n*Iio*uYs" i TELEPHONE 2794711

)

4 4

2933

]

1 CONTRACTED FATAL ILLNESSES. AND THEY ARE REVERSlNG THIS 2 DOWNWARD.

,() 3 IT SEEMS THAT ANY LEVEL OF RADIATION CAN BE 4 DISASTROUS TO PEOPLE. AND l CAN'T BELIEVE THAT THERE'S 5 ANY PL ANT DESIGNED OR BUILT THAT WILL OPERATE WITHOUT 6 RELEASE OF SOME LEVELS OF RADIATION.

7 BASED ON THAT, I WOULD ASK THIS COMMISSION 8 TO NOT ISSUE A L ICENSE TO COMPLETE 2 OR 3, 2 AND 3. I

, 9 FEEL THAT IT IS YOUR JOB TO PROTECT ME AND THE PEOPLE IN 10 THIS VALLEY. AND UNTil YOU CAN SLEEP AT NIGHT AND BE 100 11 PERCENT POSITIVE THAT I AM ABSOLUTELY SAFE, YOU HAVE NO

+

12 RIGHT TO ISSUE THAT LICENSE.

gs 13 THANK YOU.

, \-] 14 JUDGE L AZO: THANK YOU MR. TEPP.

15 MR. CHOLLTON: MY NAME IS DAVID CHOLLTON, 16 C-H-0-L-L-T-0-N. I LIVE IN CENTRAL PHOENIX. OUR 17 HOUSEHOLD IS AN APS CUSTOMER. I DON'T HAVE ANY TECHNICAL 18 EXPERTISE TO OFFER, ONLY A GOOD DEAL.0F SUSPICION. AND IN l 19 VIEW OF MANY OF THE THINGS THAT l HEAR FROM PEOPLE WHO 20 HAVE TAKEN THE TROUBLE TO INVESTIGATE WHAT HAPPENED IN THE 21 NUCLEAR POWER PLANTS, 1 FEEL THAT THAT IS JUSTIFIED.

22 1 ALSO HAVE SOME OBSERV ATIONS OF PEOPLE WHO, l 23 WHEN FACED WITH A VOL ATILE ISSUE WILL ALSO OPT FOR THE

($)

24 POPULAR YlEW. THE POPULAR VIEW IS VERY EASILY FOSTERED BY l 25 THE ADVERTISING, THE KIND OF ADVERTISING THAT L ARGE

^"="r"a"4W:'#" '"' =iCO#fA'&

TELEPHONE 279-4711

, , - - - , , - - - , , - - --,--.----n- ,n.-, - - . - - - ,

2934 1 UTILITY COMPANIES CAN AFFORD. IT PUTS THE PEOPLE WHO ASK 2 VERY RELEVANT QUESTIONS ON THE OUTSIDE, AND THOSE PEOPLE CAN EASILY BE DISCREDITED, AS HAS BEEN ATTEMPTED EVEN BY

(} 3 4 OUR LOCAL PRESS.

5 i THINK THAT WE ALSO KNOW THE PROBLEM IN 6 RAISING MONEY AND THE ENERGY TO TELL PEOPLE ALL SIDES OF 7 AN ARGUMENT. AND i PROPOSE WHAT WE ARE HEARING IS AN 8 OPINION THAT IS ONLY THE TIP OF A VERY VAST BODY OF 9 OPINION AND FEAR.

10 i LIVE IN A HOUSE THAT IS 67 YEARS OLD. I 11 AM AN IMMIGRANT HERE FROM EUROPE, AND I THINK OF THE TIME 12 THAT THE CATHEDRALS THAT WERE BUILT AND REBUILT AFTER THEY 13 HAD BEEN DESTROYED, AND I THINK OF THE INVESTMENT IN A O 14 NUCLEAR POWER PL ANT THAT HAS APPROXIMATELY HALF THE LIFE 15 0F OUR BRICK HOME. I WONDER ABOUT THE SENSE IN THAT.

16 OVERALL WE REFLECT VALUES. WHAT WERE THE 17 VALUES IN BUILDING THAT HOUSE? WHAT ARE THE VALUES 18 REFLECTED IN A GENERATOR FOR ENERGY? WHAT ARE WE DOING 19 WITH THAT ENERGY? ARE WE CREATING ANYTHING WITH IT THAT f 20 IS WORTHY OF KEEPING? FUTURE GENERATIONS WILL LOOK TO 21 THE DESERT MORE THAN THEY WILL LOOK TO THE CITY TO SEE 22 WHAT WE HAVE BEEN CAPABLE OF PRESERVING, AND THOSE 23 GENERATIONS WILL HOLD US RESPONSIBLE. AND WE CANNOT ACT T

  1. 24 AS IF WE WERE RESPONSIBILE AS A BODY OR AS A MASS OF 25 PEOPLE TRYING TO PRODUCE A LIY ABLE OPTION OR A COMPROMISE.

w. ==

TELEPHONE 279-4711

2935 1 1 THINK WE MUST ALL LIVE AS IF WE WERE PERSONALLY 4

2 RESPONSIBILE BECAUSE WE ARE.

() 3 THANK YOU.

4 JUDGE L AZO: THANK YOU, SIR.

5 MS. MCKAY: MY NAME IS LYNN MCKAY, 6 M-C-K-A-Y. I AM A MEMBER OF THE BOARD OF DIRECTORS OF THE 7 COAL ITION FOR RESPONSIBLE ENERGY EDUCATION.

8 MY COMMENTS DO NOT PERTAIN SPECIFICALLY TO 9 THE WEST V ALLEY W ATER ISSUE BUT THEY DO CONCERN MATTERS 10 NOT DEALT WITH AT THE 1982 HEARINGS.

i 11 THE NRC HAS NOT RESPONDED TO CONTENTIONS 12 REGARDING THE CORROSION PROBLEMS AT UNIT 1. AND WE FEEL

- 13 IT WOULD BE INAPPROPRI ATE TO GRANT LICENSES FOR UNITS 2 s\

14 AND 3 WlTHOUT THIS PROBLEM BEING DEFINITELY RESOLVED FOR 15 THE UNIT BEGINNING OPERATION.

16 THE DIVISION OF REACTOR SAFETY IS ONLY JUST 17 BEGINNING ITS EXAMINATION OF INTERNAL SYSTEMS AT UNIT 2.

18 AND EVEN IF THE CORROSION PROBLEMS ARE NOT BY TECHNICAL 19 DEFINITION CURRENT SAFETY PROBLEMS, THE RISK LONG TERM OF 20 PROBLEMS IN SAFETY RELATED SYSTEMS IS INCREASED BY NOT 21 DEALING WITH THE PROBLEM NOW. AND APS'S REPORT FROM

~

22 DECEMBER OF 1984 STATED THAT THE BACTERIA PROBABLY EXISTS 23 IN OTHER SAFETY RELATED SYSTEMS OTHER THAN SPRAY PONDS.

' O .

24 THE RESIDENT INSPECTOR, MR. ZIMMERMAN, IS 25 PURSUING AN INVESTIG ATION OF THE EXTENT OF CORROSION IN l

l "^**!!a"r a:53;'!.'" ""-  %'20!Tr#f* *1.

TELEPHONE 279-4711 i . . .- . __

t 2936 1 THE SYSTEMS NOW AND HE SAID AS RECENTLY AS MAY 6TH THAT 2 IT'S NOT KNOWN JUST HOW FAR THE GALL 10NELL A HAS SPREAD.

() 3 IT SEEMS TO SAY THE LEAST THAT IT WOULD BE PREMATURE TO 4 ISSUE LICENSES NOW FOR UNITS 2 AND 3 NOT KNOWING THE I

5 EXTENT OF THIS PROBLEM.

6 THERE ARE QUESTIONS ThAT REMAIN UNANWERED 7 CONCERNING APS'S PLANS FOR DEALING WITH THE CORROSION.

8 ONE VERY BASIC QUESTION IS WHETHER AERATION TREATMENT 9 WON'T ACTU ALLY ENCOURAGE THE AEROB IC GALL 10NELL A ORG ANISM.

10 l AM NOT A BIOLOGIST. I AM NOT A TECHNICAL EXPERT IN THAT 11 AREA, BUT THAT SEEMS PRETTY SIMPLE TO QUESTION.

12 APS CONTINUES AND HAS CONSISTENTLY 13 CHARACTERIZED THE CORROSION SITUATION AS A NONPROBLEM. WE

}

14 DISAGREE WITH THAT. ASSESSMENT AND WE URGE THE NRC NOT TO 15 ACCEPT THAT AS AN ANSWER TO THE VALID CONCERNS RAISED BY 16 CREE, AND AS YET UNANSWEREED BY APS.

17 THANK YOU.

18 JUDGE L AZO: THANK YOU, MRS. MCKAY.

I 19 MR. SCOTT: MY NAME IS MYRON SCOTT. I AM i 20 ALSO W ITil CREE. I AM EXECUTIVE DIRECTOR. I LIVE IN l 21 TEMPE, ARIZONA.

22 AND I HAD A NEW CONCERN THAT HAS ARISEN 1

SINCE- 1982 OR AT LEAST THAT APPEARS TO US TO HAVE BECOME

~

23 24 MORE ACUTE SINCE 1982. IT'S ALSO A CONCERN THAT THE NRC 25 IN THE PAST ROUTINELY UNDER THE ATOMIC ENERGY ACT DEALT

)

"a"!!a"r"a"4ll":'A'* '"' S%n!"E!~TE".

TELEPHONE 279-4711 1

2937 1 WITH THE QUESTION OF FINANCIAL QUALIFICATIONS OF A UTILITY 2 TO SAFELY OPERATE A NUCLEAR POWER PLANT. l THINK WE HAVE 3 A PROBLEM HERE TODAY WHICH IS OBVIOUS, THAT MOST OF THE

[ }-

4 PEOPLE WHO COME HERE HAVE CONCERNS THAT THESE SPECIFIC 5 PROCEEDINGS WERE NOT CALLED TO ADDRESS. AND 1 THINK YOU 6 HAVE ALL BEEN VERY PATIENT WITH HEARING THOSE CONCERNS 7 OUT, SO I AM NOT GOING TO BURDEN YOU WITH READING THE 8 RATHER SOMEWHAT LENGTHY STATEMENT ON THE FINANCI AL 9 QUALIFICATIONS CONCERNS THAT I DID PREPARE. AND I WILL 10 GIVE IT TO THE STENOGRAPHER SO THAT IT IS IN THE RECORD.

11 TO. SUMMARIZE BRIEFLY, I THINK WE HAVE SOME 12 SERIOUS QUESTIONS ABOUT WHETHER ARIZONA PUBLIC SERVICE AND 13 TWO OF THE OTHER UTIL ITIES INYOLVED IN PALO VERDE ARE O 14 GOING TO BE ABLE TO RAISE THE MONEY NECESSARY TO SAFELY 15 OPERATE. AS A MATTER OF FACT, THERE IS A STATE AUDIT 16 ONG0 LNG. THE CHIEF EXECUTIVE OF ONE OF THE PARTNERS CALLS 17 PALO VERDE AN ECONOMIC MISTAKE. AND WE ALSO SEE SOME 18 RATHER INTERESTING, IT SEEMS TO ME, CHANGES IN BEHAVIOR 19 SINCE A DELAY PENALTY HAS BEEN INSTITUTED AS A FORM OF 20 INCENTIVE REGULATION BY THE CORPORATION COMMISSION HERE IN 21 ARIZONA.

22 A YEAR AGO WHEN CORROSION PROBLEMS OCCURRED 23 ON AN AUXIL I ARY FEED W ATER PUMP, THE UTILITY REPLACED ALL 24 THE CORRODED METAL. SO WE WERE TOLD BY THE CORPORATION 25 COMMISSION A COUPLE OF MONTHS AGO IN THE L IGHT OF MUCH

)-

"^**EEu^"al"P ER5 O [ON 8 TELEPHONE 279-4711

-= . - _ _ . . . . . . _. . ..----.

2938 1 MORE EXTENSIVE CORROSION PROBLEMS THIS YEAR THAT YOU HAVE 2 ALREADY HEARD ABOUT THAT THE UTILITY HAS NOT TAKEN SUCH

() 3 ACTION PRESUMABLY BECAUSE THE DELAY OF A COUPLE OF MONTHS 4 WOULD.BE INVOLVED.

5 THAT'S B AS ICALLY THE CONCERNS THAT I W ISH TO 6 BRING TO YOUR ATTENTION.

7 i THINK IT'S IMPORTANT THAT YOU ADDRESS 8 THOSE PARTICULARLY IN L IGHT OF THE FACT THAT YOU ARE 9 SITTING HERE TODAY PREPARING TO RECOMMEND ON THE LICENSING 10 0F UNIT 3 WHICH WILL NOT BE OPERABLE FOR AT LEAST A COUPLE

, 11 0F YEARS, WHICH MAY NOT BE NEEDED FOR A DECADE OR LONGER 12 IN THIS STATE. BUT I AM NOT GOING TO SAY ANY MORE ABOUT

, 13 THAT.

14 i DID WANT TO COMMENT BRIEFLY ON THE PROBLEM 15- THAT I THINK WE DID HAVE HERE TODAY, THE FACT THAT SO MANY 16 PE0 LE CAME HERE TODAY WITH CONCERNS OTHER THAN THE SALT 17 DRIFT PROBLEM.

18 i THINK IT'S A REAL PROBLEM THAT WE ALL l

19 REALLY SHARE AND THAT ALL OUR MUTUAL ATTITUDES CAN MAKE 20 BETTER OR WORSE. THE LEAD TIMES INVOLVED IN NUCLEAR PLANT 21 CONSTRUCTION ARE SO LONG, THE PLANT OPERATIONS AND PLANT 22 SYSTEMS ARE SO COMPLEX THAT IT'S VERY DIFFICULT TO REMAIN 23 CURRENT ON EVOLVING ISSUES. IT'S VERY DIFFICULT FOR YOU

)

24 PEOPLE TO DETERMINE THOSE ISSUES IN W AYS THAT ARE BOTH 25 TECHNICALLY PROFICIENT AND TO ADDRESS I THINK THE

"^**EEu^nYnIP RS O RN'N O 8 01 TELEPHONE 279-4711

2939 1 EQUALLY VALID WAR ON DOLLARS AND CENTS AND CURRENCY 2 CONCERNS THAT AVERAGE CITIZENS HAVE. AND VERY OFTEN

() 3 THERE'S A PUBLIC MISPERCEPTION BETWEEN THE NRC AND THE 4 PUB L 'I C, A FAILURE TO COMMUNICATE ABOUT WHETHER THAT JOB IS 5 BEING DONE. AND I WOULD SAY WITHOUT REFLECTING IN ANY WAY 6 ON ANY OF YOU GENTLEMEN THAT ON THAT BASIS ALONE THERE IS 7 SOME VALIDITY IN SOME OF THE COMMENTS THAT WERE AIMED AT 8 NUCLEAR REGULATORY COMMISSION HERE TODAY.

9 STEPS TO SPEED UP LICENSING THAT HAS 10 OCCURRED IN THE PAST YEAR CANNOT IMPROVE PUBLIC CONFIDENCE 11 AND ACCEPTANCE OF NUCLEAR POWER. THERE ARE SIMPLY TOO 12 MANY UNANSWERED QUESTIONS IN THE GENERAL PUBLIC.

, 13 1 MAKE A PERSONAL NOTE THAT I HAVE BEEN VERY 14 IMPRESSED IN THE L AST SIX MONTHS WITH THE RESIDENT 15 INSPECTOR AT PALO VERDE NUCLEAR GENERATING STATION. I 16 THINK HE IS TRYING TO DO AN AN EXTRAORDINARY JOB THERE. I 17 ALSO THINK THAT THE SORT OF SPEEDED-UP L ICENSING PROGRAMS 18 AND SO FORTH THAT HAVE OCCURRED IN THE LAST YEAR REALLY 19 MAKE HIS JOB MORE DIFFICULT, BECAUSE I THINK PART OF HIS ,

20 JOB, AG A I N , IS NOT ONLY DEALING WITH THE TECHNICAL ISSUES 21 AS THEY ARISE BUT GlVING THE PUBLIC CONFIDENCE A SENSE OF 22 ASSURANCE THAT.THIS PLANT IS AS SAFE AS IT CAN BE. WE MAY 23~ NEVER AGREE ABOUT WHETHER THAT WILL EVER BE SAFE ENOUGH OR 24 WHETHER WE REALLY NEED NUCLEAR POWER, BUT WE WILL HAVE A 25 LOT LESS TO TALK AND ARGUE ABOUT IF WE HAVE THE SENSE THAT E

"**&^""afa%!ft" '"*- 'E'AC! Tis?f"#.

TELEPHONE 279-4711 l

2940 1 THE COMMISSION ITSELF, NOT ONLY THE UTIL ITIES, BUT THAT 2 THE COMMISSION ITSELF WAS NOT CUTTING CORNERS UNDER 1'

() 3 FINANCIAL PRESSURE ON THE UTILITIES, THAT THE COMMISSION 4 ITSELF IS NOT 000 SING THE DOOR ON PUBLIC DISCUSSION.

5 AND ON THAT BASIS, AGAIN, I WANT TO THANK 6 YOU FOR BEING SO PATIENT HERE TODAY. I WISH I COULD SAY 7 THE SAME TO ARIZONA PUBLIC SERVICE, BUT YOU HAVE HEARD 8 ABOUT THEIR STAND RECENTLY ON MEETING SOME OF THEIR 9 CRITICS IN PUBLIC. I HAVE JUST BEEN ASKED IN A GROUP 10 DECISION BY OUR ORGANIZATION TO ANNOUNCE THAT IN RESPONSE 11 TO THAT, AFTER WE ARE THROUGH HERE TODAY WE ARE GOING TO -

12 GO UP THE STREET AND HAND OUT SOME FLYERS TO APS CUSTOMERS 13 ASKING THEM WHY THEIR S0-CALLED PUBLIC SERV ICE COMPANY 14 WILL NOT TALK TO THE PUBLIC THEY ARE S0PPOSED TO SERVE.

15 AGAIN, I THANK YOU FOR YOUR FOREBEARANCE 16 TODAY, AND I HOPE YOU WILL TAKE A LOOK AT THE WRITTEN 17 MATERIAL.

18 JUDGE L AZO: MR. SCOTT --

19 MR. SCOTT: YES.

20 JUDGE L AZO: -- WE WERE AWARE OF THE 21 PETITION FILED BY CREE ON MAY 6TH THAT WAS REFERRED TO BY 22 LYNN MCKAY AND BARBARA BUSH, AND YOU HAVE REFERRED TO IT --

i 23 IT CAME TO OUR ATTENTION SHORTLY AFTER IT WAS FILED --

24 ALTHOUGH I DON'T THINK ANY OF US HAD NOTICE OR HAD BEEN 25 INFORMED OF THE SECOND P TITION WHICH HAS BEEN MENTIONED, t

"**!M"r"a"4='#" '"*- 2 0!7dr'&

TELEPHONE 279 4711 i

l 2941

- 1 NAMELY THE ONE RELATING TO FINANCIAL QUALIFICATIONS.

2 WOULD YOU TELL ME THE DATE OF THAT7

() 3 MR. SCOTT: THAT W AS FILED EARL IER. THAT 4 WAS FILED IN MIDDECEMBER. I CANNOT GIVE YOU THE PRECISE 5 DATE, BUT-IT WAS FILED JUST BEFORE THE COMMISSION ISSUED 6 THE FIVE PERCENT POWER LIMITED OPERATING LICENSE.

7 JUDGE L AZO: ALL RIGHT. AND BOTH OF THOSE 8 THEN ARE NOW BEFORE THE DIRECTOR OF NUCLEAR REACTOR 9 REGULATION?

10 MR. SCOTT: I BELIEVE, YES, THAT IS TRUE.

i 11 AND l ALSO BELIEF THE OFFICE OF REACTOR SAFETY IS LOOKING 12 AT SOME OF THE SYSTEMS AT PALO VERDE CURRENTLY ALONG WITH 13 THE RESIDENT INSPECTOR. SO AGAIN, I DON'T WANT TO SUGGEST -

14 THAT THE PROBLEMS AREN'T BEING ADDRESSED, BUT IT'S A l 15 QUESTION OF WHETHER THEY ARE BEING ADDRESSED IN A WAY TO 16 ALLOW THE PUBLIC TO KNOW WHAT IS GOING ON.

)

! 17 JUDGE CALLlHAN: EXCUSE ME. I THINK YOU 18 SAID MIDDECEMBER.

19 MR. SCOTT: YES.

?

l 20 JUDGE CALLlHAN: FOR THE RECORD, PUT A YEAR 21 ON IT.

22 MR. SCOTT: 1984.

)

JUDGE CALLlHAN: THANK YOU.

{} 23 24 MR. SCOTT: THANKS, GENTLEMAN.

l 25 JUDGE L AZO: THANK YOU, SIR.

)

^**!!#r"#4M'!!" '"*- '"*o %CEo'r' 'i.

TELEPHONE 279-4711

2942 1 NOW DO WE HAVE ANY OTHER MEMBERS OF THE 2 PUBLIC WHO WISH TO MAKE A L IMITED APPEARANCE STATEMENT

() 3 THIS MORNING?

4 THEN HEARING NO RESPONSE, JUST LET US SAY t

5 THAT WE APPRECIATE VERY MUCH ALL OF YOU COMING. WE ARE 6 PLEASED TO HAVE THE INFORMATION WHICH YOU HAVE PROYlDED.

7 i THINK IT MIGHT BE APPROPRIATE AT THIS TIME 8 TO TAKE A MIDMORNING RECESS. IT WOULD BE OUR INTENTION 9 WHEN WE COME BACK TO BRIEFLY MAKE A STATEMENT REGARDING 10 THE PREHEARING CONFERENCE BY TELEPHONE WHICH WE CONDUCTED 1

11 LAST WEEK WITH THE PARTIES AND THEN PROCEED PERHAPS WITH 12 SOME ORAL ARGUMENT REGARDING MATTERS WHICH WE BELIEVE ARE 13 STILL OUTSTANDING AND THEN GET ON TO SOME BOARD QUESTIONS

> (:)

l 14 BASED UPON THE WRITTEN TESTIMONY WHICH HAS BEEN PREFILED 15 lN THIS PROCEEDING. YOU MIGHT THINK ABOUT THAT. I WILL 16 ASK EACH OF THE PARTIES IF THEY WISH TO MAKE AN OPENING 17 STATEMENT.

18 WHY DON'T WE TAKE A 15-MINUTE RECESS NOW AND 19 RETURN AT 11:05.

9 20 THANK YOU.

21 (RECESS TAKEN AT 10:47 A.M.)

22 (PROCEEDINGS RESUMED AT 11:08 A.M.)

k 23

()

24 JUDGE L AZO: WOULD THE PROCEEDING COME TO 25 ORDER, PLEASE7

)

"^"!"u^a"r"4"45%'n's'"' '"*- %LIC!Tio'f'*if TELEPHONE 2794711 l

i 2943 1 YES, SIR. THE GENTLEMAN IN THE BACK.

4 2 MR. PENTOW SKY : YES, I WAS AT WORK THIS

() 3 MORNING. I JUST GOT HERE. I WOULD LIKE TO KNOW IF l 4 COULD STILL MAKE A GENERAL STATEMENT?

5 JUDGE L AZO: YES. HOW MUCH TIME WOULD YOU 6 REQUIRE 7 7 MR. PENTOW SKY : THREE MINUTES.

f 8 JUDGE L AZO: YES, CERTAINLY. PLEASE COME 9 FORWARD.

10 e

11 - MR. PENTOW SKY : THANK YOU.

12 JUDGE COLE: WITH ALL THOSE SHEETS OF PAPER, 13 THREE MINUTES?

L~O MR. PENTOW SKY : 1 TIMED IT THIS MORNING.

14 15 MY NAME IS GREG PENTOWSKY. I AM A NATIVE 16 ARIZONAN OF 31 YEARS. MY GRANDFATHER AND FATHER HAVE 17 LIVED HERE THE PAST 50 YEARS, AND MY SON IS A SECOND 18 GENERATION BORN IN THIS BEAUTIFUL STATE. MY ROOTS HERE 19 ARE DEEP, AND I LOVE ARIZONA AND THE PEOPLE VERY MUCH.

)

20 BECAUSE OF THIS HERITAGE, I WOULD LIKE TO PRESERVE ARIZONA 21 FOR MY SON'S FUTURE.

22 i SEE THE PALO VERDE NUCLEAR PL ANT AS BEING

~

l 23 DETRIMENTAL TO OUR FUTURE.

O 2 <4 WE HAVE HEARD MUCH OF THE S0-CALLED BENEFITS ,

25 THAT PALO VERDE CAN PROVIDE IN ADVERTISING BY OUR LOCAL

      • "E" ou 'E rn P S"5EEns ' ** '$$'"d$["EIi'Ef'$

o 4 o s 1 TELEPHONE 279-4711 e e - ,e , ,-.-ww,- -- e --- , , y ,,- c,- - r-----,-y,.-,--,---vm.g- -

! 2944 1 ELECTRIC UTILITIES. THESE BENEFITS HAVE ERODED AND BECOME

\ 2 OUTPACED BY THE NUMEROUS DETRIMENTAL FACTORS AT THE PLANT.

3 WE SEE REPORTS OF EMPLOYEE SABOTAGE AND DOPE PEDDLING AT 4 PALO VERDE, AND WE HEAR REPORTS OF BROKEN PIPES AND

.5 WELDING AND SAFETY SYSTEMS FROM THE MICROSCOPIC ORGANISMS 6 THAT EXPERTS SAY MAY HAVE AFFECTED THE ENTIRE PL ANT, WHICH 7 PROBLEMS COULD LEAD TO CATASTROPHIC EVENTS.

8 ARIZONA PUBLIC SERVICE HAS TOLD US THAT 9 NUCLEAR POWER IS SAFE. GO TELL THAT TO GOVERNOR RICHARD 10 THORNBURGH AND HIS CONSTITUENTS IN HARRISBURG, 11 PENNSYLVANIA, OR EXPLAIN THAT TO NUCLEAR WORKERS RECENTLY 12 EXPOSED TO RADIOACTIVE GASSES AT PL ANTS WHERE THEY WORK.

13 . FOR YEARS APS HAS BEEN TELLING US NUCLEAR POWER I' 14 IS ECONOMICAL. OUR ELECTRIC RATES HAVE DONE NOTHING BUT 15 SKYROCKET. THIS CHEAP FORM OF POWER IS COSTING US $10 16 MILLION AT THE PALO VERDE PLANT.

17 TWO DAYS AFTER UNIT 1 STARTED, APS HAD THE f

18 AUDACITY TO ASK FOR AN EIGHT PERCENT INCREASE. I 19 EXPERIENCED RATE SHOCK LONG BEFORE THIS HAPPENED.

20 THE RESPECTIVE PRESIDENTS OF ARIZONA PUBLIC f

21 SERVICE AND SALT RIVER PROJECT HAVE EVEN ADMITTED THAT IT 22 WAS A MISTAKE TO BUILD PALO VERDE. STATES LIKE TEXAS, NEW 23 MEXICO AND CALIFORNIA, WHO WILL CONSUME MORE THAN HALF THE 24 POWER GENERATED AND RECElVE NONE OF THE NUCLEAR WASTE 25 ARIZONA WILL INHERIT, CARE LESS ABOUT OUR UTILITIES IN

)

"^***!u^"ral"4EE'a?""*' '"* oS**!"EIi*olfd'a5 ' f TELEPHONE 2794711 h

t 2945 t

.1 THIS STATE. AFTER ALL, THEY LIKE THEIR CALVES FAT, THElR 2 BEER COLD, AND THE NUCLEAR POWER PL ANT AS FAR AS AW AY AS 3 ARIZONA.

)

4 SO WHY DOES THIS CONSTRUCTION OF PALO VERDE 5 CONTINUE 7 WHAT DOES FANATICAL PURSUIT TO EXTEND A PROJECT 6 THAT NEVER SHOULD HAVE BEEN BUILT B0ll DOWN TO? I BELIEVE 7 IT IS AGREED. TO ME THE ONLY DIFFERENCE BETWEEN A BANDIT 8 AND OUR ELECTRIC UTILITIES GETTING OUR MONEY IS THIS: THE 9 FIRST USES A LOADED GUN; THE OTHER USES A LOADED REACTOR.

10 SO FOR THE SAKE OF MY SON, MYSELF, FUTURE 11 GENERATIONS, I RESPECTFULLY REQUEST THAT YOU LOOK INTO THE 12 LICENSING OF UNITS 1 AND 2 -- 2 AND 3 RATHER. I BELIEVE 13 THAT UNIT 1 IS MORE THAN ENOUGH THAN THIS STATE NEEDS.

~

14 THANK YOU.

15 JUDGE L AZO: THANK YOU, M R .' PENTOW SKY.

16 ON JUNE 3RD OF THIS YEAR, WE -- OH, 1 NOTICE 17 ANOTHER GENTLEMAN HAS JOINED COUNSEL TABLE. MR. RAYNER?

18 MR. RAYNER: YES.

19 JUDGE L AZO: YES, THANK YOU, AND WE ARE 20 PLEASED THAT YOU ARE HERE.

21 ON JUNE THE 3RD WE CONVENED A CONFERENCE BY 22 TELEPHONE OF THE PARTIES. JUDGE COLE AND JUDGE CARPENTER 23 AND MYSELF WERE PRESENT DURING THAT CONVERSATION AND 24 CONFERENCE. JUDGE CALLlHAN, UNFORTUNATELY, WE WERE UNABLE 25 TO REACH. THE APPL ICANTS WERE -- THE JOINT APPL ICANTS

)

"^"Eu^"r"d",5EE a?"' '"*' 'E' "dC i'o*~To*1?

TELEPHONE 279 4711

)

l-2946 1- WERE REPRESENTED BY ARTHUR GEHR, THE NRC STAFF BY MR. LEE 2 SCOTT DEWEY, AND MR. RONALD RAYNER REPRESENTED THE WEST 3 VALLEY AGRICULTURAL PROTECTION COUNCIL, INCORPORATED.

4 WE STATED THAT BASED UPON A SETTLEMENT 5 AGREEMENT WHICH ARIZONA PUBLIC SERVICE COMPANY HAD ENTERED 6 INTO WITH WEST VALLEY, WE HAVE BEEN ASKED TO ENTER AN 7 ORDER DISMISSING THE PALO VERDE OPERATING LICENSE 8 PROCEEDING CONCERNING UNITS 2 AND 3 AND YACATING THE 9 HEARING NOW SCHEDULED TO COMMENCE ON JUNE 11, 1985.

10 IN A STATEMENT ENTITLED WITHDRAWAL OF 11 PETITION TO INTERVENE, THE INTERVENOR, WEST V ALLEY, HAS 12 STATED THAT IT DOES NOT INTEND TO PARTICIPATE FURTHER IN 13 THE PROCEEDING.

f 14 AFTER CAREFUL STUDY OF THE PLEADINGS AND THE 15 PREFILED TESTIMONY AS WELL AS OTHER DOCUMENTS IN THE CASE, 16 THE LICENSING BOARD STATED THAT IT HAD REACHED THE FOLLOWING 17 CONCLUSIONS: FIRSTLY, BASED UPON THE PRESENT RECORD, WE 18 CANNOT APPROVE THE SETTLEMENT AGREEMENT AT THIS TIME.

, 19 SECOND, ANSWERS TO A NUMBER OF QUESTIONS ARE 20 REQUIRED CONCERNING THE ENYlRONMENTAL PROTECTION PLAN THAT 21 IS APPENDIX "B" 0F-THE TECHNICAL SPECIFICATIONS OF THE 22 OPERATING LICENSE FOR UNIT 1 AND OTHER QUESTIONS REGARDING 23 , THE ADDITIONAL AGRICULTURAL MONITORING DESCRIBED IN THE

( -

24 SETTLEMENT AGREEMENT.

25 THIRDLY, WE STATED THAT WE BELIEVE INSTEAD h

"*"afe"4"4m'#" '"' ' " = S # r!~ T A 'f!

TELEPHONE 279-4711 h

2947 1 0F PROCEEDING AT THIS TIME WITH THE EVIDENTI ARY HEARING

\~

2 THAT WE SHOULD BEGIN ON TUESDAY, JUNE 11TH, AS SCHEDULED (f 3 WITH A PREHEARING CONFERENCE TO DISCUSS ALL OUTSTANDING ,

4 MATTERS. THAT CONFERENCE COULD BE FOLLOWED, WE SAID, BY A i

5 PRELIMINARY HEARING OF LIMITED SCOPE FOR THE PURPOSE OF 6 REV IEWING AND RECElV ING ANSWERS TO THE BOARD'S QUESTIONS 7 CONCERNING THE SETTLEMENT AGREEMENT AND THE PREFILED

)

8 TESTIMONY.

9 WE FURTHER STATED THAT WE DID INTEND TO 10 RECElVE L IMITED APPEARANCE STATEMENTS IF REQUESTS WERE 9

11 RECEIVED FROM MEMBERS OF THE PUBLIC AND STATED THAT WE 12 EXPECT THAT WE WILL THEN BE IN A POSITION TO RULE FROM THE

)() 13 14 BENCH ON THE REQUEST TO DISMISS THE PROCEEDING OR TO TAKE SUCH OTHER ACTION AS MAY BE REQUIRED.

15 WE REQUESTED THAT THE INTERVENOR, WEST 16 VALLEY, PARTICIPATE IN THE PREHEARING CONFERENCE AND NOTED

)

17 THAT THE BOARD PL ANNED TO QUESTION JOINT APPL ICANT L 18 WITNESSES DR. CURTIS, DR. MCCUNE, DR. GOLDMAN, MR. WILBER, 19 AND STAFF WITNESSES, DR. PENTECOST AND DR. SAMWORTH. WE 20 REQUESTED THAT MR. KENNETH E. FOSTER WHO HAD BEEN 21 IDENTIFIED AS ONE OF THE MEMBERS OF THE UNIVERSITY OF 22 ARIZONA PANEL WOULD ALSO BE PRESENT.

)

23 WE STATED THAT WE HAD NOTED THE LETTER OF O 24 MAY 13TH, 1985, FROM THE ADVISORY COMMITTEE OF REACTOR 25 SAFEGUARDS REGARDING UNRESOLVED SAFETY ISSUE A-45 WHICH IS k

a"r a==:'#= '"*- a="=='A "ff TELEPHONE 279-4711

)

2948

. 1 GENERALLY REFERRED TO AS SHUTDOWN DECAY HEAT REMOV AL 2 REQUIREMENTS AND NOTED THAT WE HAD SEEN A PETITION FILED

() 3 BY THE COALITION FOR RESPONSIBLE ENERGY EDUCATION RELATING 4 TO SPRAY POND WELL CORROSION. THAT IS THE 5 MICROBl0 LOGICALLY INDUCED CORROSION THAT WAS DISCUSSED p 6 THIS MORNING BY THREE OF THE MEMBERS OF CREE.

7 WE ALSO INDICATED THAT WE WOULD LIKE TO HAVE I

8 SOME DISCUSSION ON THE NEEDS OR POSSIBLE NEED FOR A 9 SUPPLEMENTAL ENYlRONMENTAL IMPACT STATEMENT TO BE PREPARED 10 BY THE STAFF AND WHETHER OR NOT THAT WOULD BE NECESSARY.

11 WE ALSO INDICATED TO THE PARTIES IN THAT 12 PREHEARING CONFERENCE BY TELEPHONE THAT THE FARMS OF THE 13 WEST VALLEY MEMBERS ACCOUNT FOR ONLY A PORTION OF THE 14 TOTAL AREA SURROUNDING THE PALO VERDE FACIL ITY THAT .MAY BE 15 ADVERSELY AFFECTED BY SALT DEPOSITION EMITTED FROM THE 16 FACILITY.

17 WE NOTED THAT OBVIOUSLY THE STATE HAS AN 18 INTEREST IN PROTECTING THE FRAGILE DESERT ECOLOGY AND 19 WONDERED IF PERHAPS THE STATE MAY HAVE EXERCISED ITS t

20 FOREBEARANCE BECAUSE THE MATTER WAS BEING ACTIVELY PURSUED 21 BY THE WEST V ALLEY INTERYENORS REPRESENTING A LARGE GROUP

\

22 0F LOCAL CITIZENS.

+

23 THEREFORE, IN OUR VIEW WE THOUGHT IT MIGHT 24 BE HELPFUL TO THE LICENSING BOARD IF WE WOULD HAVE THE 25 VIEWS OF THE STATE ON THE TERMS OF THE SETTLEMENT "c* %D D'o% ',*.

"sa*a*At%'A'* '"**

TELEPHONE 279 4711

i 2949 1 AGREEMENT WHICH-WE HAVE BEEN REQUESTED TO APPROVE. IN 2 THAT REGARD, WE SUGGESTED THAT PERHAPS THE PARTIES WOULD 2 BE ABLE TO DETERMINE WHETHER OR NOT ANYONE REPRESENTING 4 THE STATE OF ARIZONA WOULD HAVE ANY COMMENTS REGARDING THE 5 PROPOSED SETTLEMENT AGREEMENT.

6 WE ALSO NOTED THAT THE NOTICE OF WITHDRAWAL 7 0F THE PETITION TO INTERVENE REFERS TO OTHER COMMITMENTS 8 0F THE PARTIES AS PART OF THE BASIS FOR THE RESOLUTION OF 9 THE CONTENTIONS AND INDICATED THAT WE WOULD BE INTERESTED 10 IN KNOWING WHAT THOSE OTHER COMMITMENTS MIGHT BE.

11 NOW, EACH OF THE MEMBERS OF THE -- EACH OF 12 THE PARTIES' REPRESENTATIVES WHO WERE PARTICIPATING IN 13 THAT CONFERENCE CALL ARE ASKED TO STATE AT THIS TIME HAVE f 14 l ACCURATELY CONVEYED THE SUBSTANCE OF THAT CALL 7 ARE 15 THERE ANY OTHER MATTERS THAT WE SHOULD INCLUDE?

16 MR. GEHR, PERHAPS WE WOULD ADDRESS YOU FIRST 17 ON THAT QUESTION.

18 MR. GEHR: 1 THINK YOU HAVE ACCURATELY 19 STATED WHAT THE BOARD'S POSITION ON EACH OF THESE ITEMS 20 HAS BEEN THAT IS TO INQUIRE IN THESE AREAS. THE ONLY 21 THING 1 CAN THINK OF THAT MIGHT BE ADDED WOULD BE THAT l 22 COMMITTED TO SEND TO THE BOARD A COPY OF THE TRANSCRIPT OF 23 THE NRC COMMISSION MEETING HELD ON MAY 30TH IN WHICH l 24 SEVERAL OF THOSE ITEMS THE BOARD INQUIRED ABOUT WERE

i. 25 CONSIDERED BY THE FULL COMMISSION AND PASSED UPON IN
==e - ===:

TELEPHONE 279-4711

),

2950 1 CONNECTION WITH THE AUTHORIZATION TO ISSUE A FULL POWER 4

2 LICENSE FOR PALO VERDE UNIT 1.

() 3 i CARRIED THROUGH WITH THAT COMMITMENT AND 4 SUBMITTED A COPY OF THAT TRANSCRIPT TO THE BOARD AND TO 1

5 THE PARTIES.

6 JUDGE LAZO: THANK YOU, MR. GEHR. ,

7 WE NOTE THAT YOU DID INDEED COMMIT TO SEND

)

8 US A COPY OF THAT TRANSCRIPT AND WE EACH HAVE RECElVED IT 9 AND WE THANK YOU FOR IT.

10 MR. DEWEY, DO YOU HAVE ANYTHING TO ADD?

f 11 MR. DEWEY: YES, SIR. YOU HAVE STATED WHAT 12 THE BOARD WANTED WITH RESPECT TO THIS PREHEARING. ONE 13 OTHER THING WAS THAT THE STAFF COMMITTED TO SEND YOU A

{}

i 14 REVISION FOUR OF THE MONITORING PROGRAM, WHICH-l DID ON 15 JUNE 4TH, 1985.

16 JUDGE LAZO: AND WE ALSO THANK YOU, 17 COUNSELOR. WE DID RECElVE IT PROMPTLY.

18 NOW, IF WE CONSIDER THE NEXT PORTION OF 19 THIS PROCEEDING TO BE A PREHEARING CONFERENCE ON THE 20 QUESTION OF WHERE DO WE GO FROM HERE, LET ME FIRST ASK MR.

21 RAYNER, DO WEST VALLEY MEMBERS HAVE ANYTHING THEY WOULD 22 LIKE TO STATE ON THE RECORD?

)

23 MR. RAYNER: YES, i BEL IEVE WE D0.

[}

24 HONORABLE JUDGES, I HAVE NOT BEEN A PARTY TO 25 THESE HEARINGS PERSONALLY BEFORE, BUT I WOULD LIKE FOR YOU

)

""E"r"a",3 M'Is'"' '"*- ,"AC#7io*f" 'il TELEPHONE 2794711

2951 1 TO KNOW THAT THE WEST V ALLEY GROUP, SINCE OUR MEMBERSHIP 2 HAS HAD VERY LIMITED FUNDING IN THE PAST, WE DECIDED SOME

() 3 TIMT AG'$ THAT WE COULD NO LONGER AFFORD LEG AL 4 REPRESENTATION. THIS PERHAPS IS ONE OF THE THINGS THAT 5 BROUGHT US TO THE CONCLUSION THAT WE PERHAPS COULD BETTER 6 NEGOTI ATE THE SETTLEMENT W ITH THE NUCLEAR PL ANT PEOPLE AND 7 OBTAIN SOME OF THE THINGS THAT WE FELT THAT WERE MISSING

)

8 FROM THE STUDIES THAT HAD BEEN CONDUCTED OR MANDATED TO BE l 9 CONDUCTED IN THE FUTURE.

10 WE ARE MAINLY INTERESTED IN THE AGRICULTURAL 11 MONITORING.

12 THERE WAS A PUBLICATION THAT W AS PUT OUT BY 13 THE UNIVERSITY OF ARlZONA CALLED " COTTON: A COLLEGE OF 14 -

AGRICULTURE REPORT." IN IT WAS CONTAINED A

SUMMARY

OF -

15 SOME RESEARCH THAT WAS DONE BY THE UNIVERSITY AND l

16 ESSENTI ALLY THE WORK THAT WAS DONE IN PREPARATION FOR THE 17 COMMISSION HEARING.

18 PART OF THE RESULTS IN THAT, AND I WILL 19 QUOTE THE BOOKLET ON PAGE 46 -- THIS IS THE RESULTS OF THE l

l 20 STUDIES OF SALT DRIFT DEPOSITION -- THEY SAID, "THERE WERE 1

21 NO DIFFERENCES IN THE NUMBER OF FLOWERS PRODUCED IN ANY OF 22 THE TREATMENTS, HOWEVER, BOLL PRODUCTION WAS CONSISTENTLY l' 23 LOWER IN THE PLOTS TREATED WITH 7.4 POUNDS PER ACRE PER i 24 YEAR OR MORE OF SALT. ONLY THE 370 POUNDS PER ACRE PER 25 YEAR TREATED PLANTS HAD STATISTICALLY FEWER BOLLS PRODUCED

" ^* **"u^n"r co n E E n's * * '7o$$3n*'z"o'sYa'so*i4 p

TELEPHONE 279-4711

_ - - .- __ ,__ ,- _ _ .-. ..--. ,---_ _ --- - .._.-_. -___._ _ ~ ,. ,._ _ - _

2952 1 AS COMPARED TO THE CONTROLS. THIS INDICATES THAT THE 2 SALTS MAY BE AFFECTING FRUIT SET AFTER FLOWERING."

3 AS A RESULT OF THIS FINDING AND THIS

(])

4

SUMMARY

, THE WEST VALLEY GROUP THEN ASKED THE NUCLEAR 5 PLANT PARTNERS lF THEY WOULD CONDUCT ADDITIONAL MONITORING 6 THAT WOULD -- ON A WEEKLY BASIS DURING THE GROWING SEASON 7 0F COTTON BECAUSE IT'S PRIMARILY A COTTON-GROWING AREA, TO 8 MONITOR THE PRODUCTION OF SQUARE BLOOMS AND LOOSE BOLLS ON 9 EACH OF THE PLANTS IN A TEST PLOT AREA. AND ALL OF THESE l

10 DETAILS HAVE YET TO BE WORKED OUT. THAT ALSO INSECT 11 POPUL ATIONS WOULD BE MONITORED SO THAT THAT WOULD BE l 12 ELIMINATED AS A VARIABLE, AND THAT THERE WOULD BE 13 TEMPERATURE AND HUMIDITY SENSING AND MEASURING INSTRUMENTS

(

() 14 AT EACH OF THE SITES.

15 WE PICKED A NUMBER OF FIVE DIFFERENT SITES, 16 THREE WITHIN THE TEN- MILE RADIUS AND TWO OUTSIDE THE 17 TEN-MILE RADIUS, TO DO THESE MEASUREMENTS. WE WANT SOME l 18 AREAS THAT ARE NOT CLOSE TO THE AREAS THAT MIGHT BE 19 EXPECTED TO RECEIVE SALT DRIFT. HOPEFULLY WE WILL ACHIEVE l

20 A COMPARISON BETWEEN THOSE AREAS OF THE BOLL RETENTION 21 LEVELS OF THOSE COTTON PLANTS. THAT'S WHERE OUR PRIMARY 22 INTEREST LIES.

23 BASED ON THE PRELIMINARY RESEARCH THAT WAS O 24 DONE AND THE PHYSIOLOGICAL RESPONSE, WE HOPE THAT WILL 25 PROTECT OUR MEMBERS' INTEREST IN TERMS OF A SETTLEMENT, l

COURT RE RT RS P O Al2ON 85014 TELEPHONE 2794711

4 2953 1 ALLOW US I BELIEVE TO SEE WHETHER'THAT PHYSIOLOGICAL 2 RELATIONSHIP EXISTS AND OVER THE PERIOD OF TIME THAT WE l HAVE AGREED TO IN THE SETTLEMENT IF THIS RELATIONSHIP iS

(]) 3 4 SHOWN AND IT WOULD GIVE OUR MEMBERS A BASIS FOR DAMAGE 4

5 ACTIONS AGAINST THE NUCLEAR PLANT'S PARTNERS.

6 DO YOU HAVE ANY QUESTIONS OF ME AT THIS 7 TIME?

8 . JUDGE L AZO: MR. RAYNER, IN THE PLEADING 9 WHICH IS ENTITLED WITHDRAWAL OF PETITION TO INTERVENE 10 WHICH HAS BEEN EXECUTED BY YOU AND MR. GLADDEN AS 11 REPRESENTATIVES, PRESIDENT AND REPRESENTATIVE OF THE 12 INTERVENOR, YOU STATE THAT THE FOREGOING WITHDRAWAL AND 13 CONSENT IS MADE ON THE BASIS OF A SETTLEMENT AGREEMENT 1

() 14 ENTERED INTO BY WEST VALLEY WHICH PROVIDES FOR ADDITIONAL 15 AGRICULTURAL MONITORING AND OTHER COMMITMENTS OF THE 16 PARTIES THERETO. WOULD YOU TELL US THE NATURE OF THE 17 THOSE OTHER COMMITMENTS THAT YOU REFERRED TO IN THAT 18 PLEADING?

19 MR. RAYNER: NO, l'M NOT SURE SPECIFICALLY 20 WHAT MIGHT BE REFERRED TO IN THE AGREEMENT. LET ME SEE IF 21 l CAN --

22 ONLY THAT THE DATA COLLECTED AND REPORTS AND 23 EVALUATIONS MADE RESPECTING THE MONITORING WILL BE MADE O 24 AV AIL ABLE TO ALL OF OUR MEMBERS. AND BY THE SAME TOKEN, 25 WE ASK THAT ALL OF THE INFORMATION THAT WAS G ATHERED UNDER

"""EEu^"T REP E S O R [ON 8 014 TELEPHONE 279-4711

2954 1 THE N.U.S. MONITORING CONTRACT ALSO BE MADE AVAILABLE TO 2 OUR MEMBERS. THAT WOULD REPORT THE DUST FALL SAMPLES, DUST FALL COLLECTION SAMPLES HAV ING TO DO W ITH PART OF

(]} 3 4 THERE REQUIREMENT.

5 OTHER THAN THAT, 1 AM NOT -- YOU MIGHT ASK 6 THE SAME QUESTION AGAIN, BUT I AM NOT --

7 JUDGE L AZO: ALL RIGHT. SO THAT IT RELATES 8 TO THE DISTRIBUTION OF THE REPORTS REG ARDING ini DATA THAT L 9 ARE COLLECTED?

) 10 MR. RAYNER: THAT'S CORRECT.

11 JUDGE CARPENTER: MAY I ASK A QUESTION OUT 12 0F IGNORANCE 7 13 WHAT IS A COTTON SQUARE COUNT? THAT'S A O 14 TERM THAT I AM NOT FAMILIAR WITH.

  • l 15 MR. RAYNER: IN THE FRUITING PATTERN OF A IT'S A FLOWERED BUD, 16 PLANT, A SQUARE IS ACTUALLY A BUD.

17 SO THAT IT MOVES FROM SQUARE TO BLOOM TO BOLL, SO IT'S 18 REALLY BUD, FLOWER AND FRUIT.

19 JUDGE CARPENTER: SQUARE MEANS BUD?

20 MR. RAYNER: YES.

21 JUDGE CARPENTER: THANK YOU.

22 JUDGE COLE: YOU ARE SATISFIED THAT THE t-23 STUDIES THAT WILL BE DONE WILL PROVIDE WHATEVER YOU NEED O 24 TO MAKE YOUR DECISION 5 AS TO AN IMPACT 7 25 MR. RAYNER: WE SINCERELY HOPE S0. IN t

"^"

COURT R R ERS P O RIZON 85014 TELEPHONE 279-4711

)

2955 1 TRYlNG.TO THINK OF A NUMBER OF DIFFERENT WAYS TO APPROACH 2- THIS IN A WAY TO SCIENTIFICALLY MEASURE WHAT HAPPENS, THIS 3 IS BASICALLY ABOUT THE ONLY THING THAT WE CAN COME UP

(])

4 WITH, AND WE THOUGHT THESE MEASUREMENTS WERE BETTER THAN 5 THOSE PROPOSED BY OUR ATTORNEYS AND OTHERS INYOLVED. THESE 6 ARE VERY EFFECTIVE MEASUREMENTS.

7 THERE IS ONE KEY ITEM, TOO, THAT l DID MISS.

8 THERE WAS A FINAL YlELD DETERMINATION THAT HAD BEEN MADE 9 AT EACH OF THOSE SITES OF WHAT SHOULD BE HARVESTED AND 10 MEASURED AS A FINAL YlELD AT EACH OF THE SITES. SO THERE 11 IS NO RELATIONSHIP FOR INSTANCE BETWEEN THE ORIG INAL 12 SQUARE AND FLOWER PRODUCTION OF THE PLANTS AND HOW THAT 13 RELATES TO FINAL YlELD. WE WANT TO FIND OUT WHETHER IT'S O 14- SIGNIFICANTLY DIFFERENT IN THE AREA CLOSE TO THE PL ANT, 15 WHERE THERE IS SALT FALL OR FURTHER AWAY FROM THE PL ANT 16 WHERE IT'S NOT AFFECTED BY THAT.

17 JUDGE COLE: IS THE STATISTICAL DIFFERENCE 18 THAT YOU MIGHT GET FROM YEAR TO YEAR KNOWN TO YOU, SIR?

19 MR. RAYNER: NO, IT'S NOT, AND THAT'S A REAL 20 CONCERN. THAT'S WHY WE WANT THESE DIFFERENCES NEASURED 21 WITHIN THE PLOT BECAUSE WE KNOW THAT YlELDS V ARY 22 DRAMATICALLY. WE WOULD L IKE TO KNOW HOW THE PLANTS REACT 23 TO TEMPERATURE AND RELATIVE HUMIDITY MEASUREMENTS AT EACH 24 0F THE SITES, JUST DEPENDING ON THE TEMPERATURE, INSECT 25 COUNTS AND INSECT DAMAGE, YOU CAN HAVE QUITE A V ARI ATION

"^ ' " " '

"^"EOu[rR$"P R O R 50 8 01 TELEPHONE 279-4711

2956 s

1 WITH THE RATIO BETWEEN SQUARE TO BOLL SET ON THE PLANT.

t 2 JUDGE COLE: THE TERM YOU USED, THE RATIO OF 3- SQUARE TO BOLL, WHAT SIGNIFICANCE IS THAT, SIR?

(}

4 MR. RAYNER: WHAT THAT WILL TELL US IS THAT 5 ON THE BASIS OF THE RESEARCH THAT WAS DONE IN THE 6 PRELIMINARY STUDY THAT WAS ORDERED BY YOU FOR APS 7 CONDUCTED FOR THE ONE YEAR, THE RESULTS OF THAT WORK 4

8 POINTED OUT THAT THERE WAS A POSSIBLE PROBLEM ENEN AT VERY 9 LOW RATES OF SALT DEPOSITION, THAT FOR SOME REASON FLOWERS 10 DID NOT MATURE INTO BOLLS, THAT THERE WAS A GREATER 11 DISPARITY BETWEEN THAT BOLL SET FROM THE FLOWER AND WHERE 12 THE AREAS THAT WERE NOT TREATED BY SALT.

. 13 JUDGE COLE: IS THIS RATIO THEN A BETTER O 14 PARAMETER THAN YlELD?

15 MR. RAYNER: IT CERTAINLY IS, BUT THE YlELD 16 WILL NOT BE COMPARED, I WOULD SAY, FROM PLOT TO PLOT BUT 17 .ONLY TO TELL YOU WHAT THE FINAL YlELD WAS FROM THE 18 ORIGINAL SQUARE COUNTS WITHIN THE PLOT SO THAT THE YlELD 19 WAS NOT INTENDED TO MEASURE BETWEEN PLOTS, BECAUSE YOU l

20 HAVE TOO MUCH VARI AB IL ITY BETWEEN PLOTS. THAT'S OUTSIDE 21 THE CONTROL OF THE INDIVIDUAL FARMER.

22 JUDGE COLE: ALL RIGHTM SIR. THANK YOU.

23 JUDGE CARPENTER: ARE THESE ADDITIONAL PLOTS O 24 UNDER THE CONTROL OF MEMBERS OF YOUR ASSOCIATION?

25 MR. RAYNER: IT IS ANTICIPATED THAT THE l

l COURT RE R RS p O RIZON 85014 TELEPHONE 2794711

2957 1 INDIYlDUAL PLOTS WOULD BE ON FARMS THAT MORE THAN LIKELY 2 WOULD BE MEMBERS OF OUR GROUP. BUT WE ARE CERTAINLY NOT 3 REQUIRING THAT THEY BE SUCH. THEY CAN BE ON ANY FARMS.

(])

i 4 AND WE WOULD COLLABORATE WITH THE APS PEOPLE IN HELPING TO 5 SELECT THOSE SITES AND ACHIEVING THEM THE USE OF THOSE 6 SITES 'FROM THE FARMERS.

7 AND ALSO WE HAVE REQUESTED THAT THE 8 UNIVERSITY OF ARIZONA, THE AGRICULTURAL EXTENSION SERVICE, 9 BE THE THIRD PARTY THAT WOULD DO THE MONITORING FOR US 10 BECAUSE THEY HAVE SOME PEOPLE ON SITE IN THIS COUNTY THAT 11 ARE CAPABLE OF DOING THESE TYPES OF MEASUREMENTS, BECAUSE 12 THEY DO NOT REQUIRE LABORATORY WORK; THEY REQUIRE. PHYSICAL 13 COUNTING ESSENTIALLY IN THE FIELD.

O 14 JUDGE CARPENTER: DO I UNDERSTAND THE ACTUAL 15 SITES HAVE NOT BEEN SELECTED YET7 16 MR. RAYNER: THAT'S CORRECT.

17 JUDGE CARPENTER: YOU MENTIONED THE --

18 MAKING INSECT COUNTS SO THAT ONE COULD BE AWARE IF THERE 19 WERE ANY DIFFERENCES BETWEEN THE VARIOUS SITES WITH 20 RESPECT TO EFFECTS OF INSECTS. I WOULD LIKE TO ASK 21 WHETHER THESE SITES -- WOULD THERE BE ANY CONTROL OF THE 22 RATES OF FERTILIZATION AND THE RATES OF IRRIGATION OF THE 23 VARIOUS SITES? AS A L AYMAN, IT SEEMS TO ME THAT THIS

()

24 MIGHT BE A PROFOUNDLY -- HAVE A PROFOUND EFFECT ON THE 25 YlELDS AND THE GENERAL HEALTH OF THE PL ANT.

""**EEu^nYaIP5EEEs' "** 'M*o"d$"EIio's"Es*$[

TELEPHONE 279 4711

2958 1 MR. RAYNER: TH AT' S CORRECT, . AND THAT' S WHY

. 2 l THINK IT'S VERY IMPORTANT THAT WE MONITOR EACH LOCATION

() 3 ESSENTIALLY WITHIN ITSELF SO THAT THE ENTIRE FIELD GETS 4 TREATED THE SAME, THAT IT'S ALL IRRIG ATED THE SAME, THAT 5 IT'S ALL FERTILLIZED THE SAME EVEN THOUGH IT MAY BE 6 RADICALLY DIFFERENT FROM THE ONE FIVE MILES AWAY SO THAT J YOU ARE ONLY MEASURING THE DIFFERENCES THAT OCCUR WITHIN 8 THAT FIELD. IF INSECT POPULATION IS MUCH HIGHER, FOR 9 INSTANCE, YOU W ILL HAVE THAT AS A V ARI ABLE. YOU W ILL KNOW 10 WHAT THOSE COUNTS ARE BY THE WEEKLY INSECT COUNTS THAT ARE 11 CONDUCTED.

12 WHAT WE ARE INTERESTED IN IS THE RATIOS THAT 13 OCCUR IN THE PLOTS HOW MANY POUNDS OF L INT OR HOW NANY 14 BOLLS ARE- PRODUCED FROM THIS ORIGINAL PRODUCTION OF

\

15 SQUARES AND FLOWERS SO WE CAN SEE IF THERE'S A FLOWER LOSS --

16 BECAUSE WE WANT TO KNOW WHAT THE FLOWER LOSS IS WITHIN THE 17 PLOTS AND NOT NECESSARILY BETWEEN THE PLOTS.

18 JUDGE CARPENTER: DO YOU THINK IT WOULD BE 19 POSSIBLE TO HAVE THE SITES THAT ARE CLOSE TO THE PLANT AND 20 ALSO THE SITES THAT ARE FURTHER AWAY HAVE THE SAME AMOUNT i 21. OF IRRIG ATION AND HAVE THE SAME AMOUNT OF FERTILIZATION SO 22 THAT YOU COULD THEN COMPARE THEM WITHOUT HAVING TO WORRY 23 ABOUT THE EFFECTS OF DIFFERENCES IN IRRIGATION AND O 24 DlFFERENCES IN FERTILIZATION?

25 MR. RAYNER: WELL, PERHAPS YOU ARE NOT

^**L^e"4"4:!":'#" '"*- ' 5 N C #7i s t'A '11 TELEPHONE 279-4711

2959 1 UNDERSTANDING. THOSE FACTORS, THE W AY l V IEW THEM, ARE 2 NOT CRITICAL BECAUSE WE ARE NOT GOING TO BE MEASURING

() 3 THOSE DIFFERENCES BETWEEN PLOTS. THOSE DIFFERENCES CAN BE ,

4 RADICALLY DIFFERENT. AND IT'S ALMOST IMPOSSIBLE TO MAKE 5 THEM THE SAME BECAUSE OF SOIL TYPES AND ALL THESE OTHER 6 FACTORS, REAL VARIATIONS, EVEN BETWEEN FARMS. YOU ARE 7 GOING TO HAVE TEMPERATURE VARIATIONS. YOU ARE GOING TO 8 HAVE INSECT POPUL ATION V ARI ATIONS. WE NOT TRYING TO 9 MEASURE THOSE, AS I VIEW IT. WE WILL HAVE SOMEONE FROM 10 THE UNIVERSITY EXTENSION SERVICE TO HELP US DESIGN THOSE, 11 BUT WE ARE GOING TO BE MEASURING THE RATIOS WITHIN EACH 12 PLOT. WE WANT TO SAY HOW MANY BOLLS RESULT FROM A CERTAIN 13 NUMBER OF SQUARES THAT WERE PRODUCED ON A PARTICULAR

, -() 14 PLANT. IT'S VERY POSSIBLE -- JUST DATE OF PLANTING L

15 PRODUCES RADICAL DIFFERENCES IN A PLANT'S ABILITY TO 16 PRODUCE YlELD. SO IF IT ONLY PRODUCES 20 SQUARES, FOR 17 INSTANCE, AND FIVE OF THEM WIND UP BEING BOLLS AT THE END 18 0F THE YEAR AS OPPOSED TO ANOTHER PLANT THAT MIGHT PRODUCE 19 200 SQUARES AND A HUNDRED OF THEM BECOME BOLLS AT THE END 20 0F THE YEAR. IT'S THOSE RATIOS THAT WE ARE INTERESTED IN.

21 WHAT FACTORS AFFECTED THE DEVELOPMENT OF A BLOOM INTO A 22 BOLL. THAT'S WHERE THE DIFFERENCES, THE IMPORTANT 23 DlFFERENCES CAME OUT OF THE STUDY THAT WAS DONE BY THE O- 24 UNIVERSITY LAST YEAR.

25 JUDGE CARPENTER: I SEE. SO YOU ARE SAYING

"^"EEu^nYal"5EE'n's' "** ****o "dCdIio*NEs5o*1 l

TELEPHONE 2794711 i

2960 1 YOU WILL EMPHASIZE THOSE RATHER THAN THE YlELDS, IN MY 2 MIND WHICH WOULD BE RESPONSIVE TO IRRIGATION AND 3 FERTILIZATION. SIT BACK AND SAYING YOU'VE GOT PLOT "A"

(])

4 AND PLOT "B" AND "B" IS PRESUMED TO GET LESS SALT FROM THE 5 PLANT THAN PLOT "A." NOW I WAS JUST TRYlNG TO SEE WHETHER 6 IT WOULD BE POSSIBLE TO SAY THAT THE YlELD DIFFERENCE 7 BETWEEN THE TWO PLOTS WAS DUE TO THE SALT IF IRRIGATION 8 AND FERTIL IZATION WEREN'T CONTROLLED, AND YOU ARE SAYlNG 9 THAT IT'S NOT REALLY THE FOCUS BUT RATHER THE PERFORMANCE 10 0F INDIV IDU AL PL ANTS OR -- WITH IN EACH PLOT. IS THAT 11 RIGHT7 12 MR. RAYNER: THAT'S CORRECT.

13 JUDGE CARPENTER: RATHER THAN THE YlELD --

O 14 YOU FEEL THE YlELD IS NOT GOING TO BE AS DI AGNOSTIC AS THE 15 SQUARE TO BOLL RATIO?

16 MR. RAYNER: THAT'S TRUE. THE YlELD --

17 THERE'S STILL ANOTHER FACTOR THAT DETERMINES THE AMOUNT OF 18 YlELD AND THAT'S THE AMOUNT OF LINT THAT'S IN THE BOLL.

19 THE POLLINATION OF THE FLOWER -- EVEN THOUGH YOU MAY HAVE 20 A BOLL, YOU MAY NOT HAVE AS MUCH TOTAL LINT COTTON. SO 21 THAT'S ONE OF THE REASONS WE ASK FOR FINAL LINT YlELD 22 ALSO. AT LEAST THEN WE WILL HAVE A RATIO BETWEEN THE l 23 ORIGINAL SQUARE PRODUCTION, THE ORIGINAL BUD, AND THE

! ($) 24 FINAL YlELD IN L INT AND ALSO THE BOLL COUNT. SO WE WILL 25 HAVE A BOLL COUNT TO GIVE THE NUMBERS THAT WERE ACTUALLY i

THACKER ANO R IELD, INC. 42 2 2 H ST., SUITE 200 TELEPHONE 279-4711

k!

, l 2961 j/

4, 1 PRODUCED FROM THE ORIGINAL, AND THEN THE FINAL LINT YlELD I

2 WILL ALSO HOPEFULLY GIVE US THE INFORMATION THAT WILL

() 3 PROV IDE A CORREL ATION THAT WE CAN DRAW SOME CONOLUSIONS 4 FROM OVER THE YEARS.

j 5 AND 00 YOU UNDERSTAND THAT WE WOCLD BE

! 6 COMPARING THE RATIOS THAT OCCUR BETWEEN THE PLOTS CLOSE TO

7 THE PLANT AND THOSE FURTHER AWAY FROM THE PLANT. SO IF IT 8 TAKES TEN SQUARES TO MAKE FlVE BOLLS CLOSE TO THE PL ANT, 9 MAYBE IT ONLY TAKES ElGHT SQUARES TO PRODUCE FIVE BOLLS FURTHER AWAY FROM THE PLANT. SOMETHING ALONG THAT ORDER.

10 11 JUDGE COLE: MR. RAYNER, THIS -- IF YOU ARE j 12 GOING TO USE THIS RATIO, SQUARES TO BOLLS, IMPLICIT IN 13 THAT USE IS THE ASSUMPTION THAT THE IMPACT OF THE SALT 14 WOULD BE BETWEEN THOSE TWO STAGES, BETWEEN THE FORMATION l

15 0F THE SQUARE AND THE FORMATION OF THE BOLL. IS THAT 16 KNOWN?

! 17 MR. RAYNER: THAT'S ONE THING THAT WE WOULD l 18 ASSUME THAT WITH THE OTHER ADDITIONAL INFORMATION THAT WE 19 HAVE FROM THE -- THAT THE U.S. IS COLLECTING FOR THEM ON 20 SALT FALL DISTRIBUTION THAT WE CAN HOPEFULLY THEN SHOW A 21 CORREL ATION BETWEEN THOSE COUNTS, IF THERE IS SUCH. IF BY 22 GATHERING ALL THIS DATA WE CAN SHOW THAT THE CORRELATION 23 EXISTS, WE WOULD HOPE THAT WE COULD EITHER COME BACK TO O 24 YOU WITH THIS INFORMATION OR GO TO OUR OWN ATTORNEYS TO

'25 HELP PREPARE A CASE FOR DAMAGES, BUT BASED ON THE EVIDENCE

'"*c"::a"r*a"AM;'#" '"c-

'l,,' 3 C !!i @ 'n '?:

l TELEPHONE 279-4711

4 2962

'1 THAT WE CAN GATHER THAT SOME DAMAGE HAD OCCURRED. .

)

2 JUDGE COLE: I GOT THE IMPRESSION THAT YOU WOULD BE COMPARING THE SQUARE TO BOLL COUNTS FROM NEARBY

(]) 3 4 THE PLANT TO FAR AWAY. WOULD YOU HAVE ANY -- WOULD YOU BE

)

5 USING ANY BASELINE DATA TO COMPARE WITH ON THE INDIVIDUAL 6 PLOTS 7 7 MR. RAYNER: LET ME CORRECT YOU A LITTLE

)

8 BIT. I SAID THE RATIO. WE WILL NOT BE COMPARING THE 9 ACTUAL SQUARE BOLL PRODUCTION FROM THE UNITS CLOSE IN TO 10 FURTHER OUT BECAUSE THOSE V ARI ATIONS ARE SO GREAT. WE

')

11 WILL BE COMPARING THE RATIOS.

12 JUDGE COLE: ALL RIGHT, SIR. WOULD YOU BE 13 COMPARING THE RATIO OF A PARTICULAR LOT WITH THE RATIO OF

) )

14 THAT SAME LOT IN A PREVIOUS YEAR ALS07 15 MR. RAYNER: l'M SURE THAT AS THIS GOES ON 16 WE WILL GATHER THAT INFORMATION AND WE WOULD HOPE TO 17 PREV All ON THE UNIVERSITY EXTENSION PEOPLE THAT -- THEY 18 NORMALLY CONDUCT THESE TYPES OF MONITORING PROGRAMS ON 19 OTHER FARMS THROUGHOUT THE STATE. SO AS FAR AS THE

)

20 BASELINE DATA GOES, l'M SURE THAT THERE ARE THOSE TYPES OF 21 INFORMATION AVAILABLE.

22 JUDGE COLE: 1 AM JUST WONDERING WHAT YOU

.) -

23- WOULD HAVE AFTER A YEAR. INFORMATION FROM SAY FIVE OR SIX O 24 DlFFERENT LOTS, YOU HAVE DIFFERENT RATIOS. THERE MIGHT BE 25 A SMALL OR A L ARGE DIFFERENCE BETWEEN THESE RATIOS. WHO

)

"^* *Eu^##,'UE'n's'"' '"** '"'";

o SIMII'o'dil TELEPHONE 279-4711

)

1 i

I 2963 !

l l

1 IS TO SAY THAT THE DIFFERENCE ISN'T ATTRIBUTABLE TO THE l 9

2 LOT ITSELF IF YOU ARE NOT GOING TO COMPARE IT FOR A 1

() 3 BASELINE?

4 MR. RAYNER: I WOULD HOPE THAT AS WE BUILD 5 UP A RESERVOIR OF INFORMATION OVER THE YEARS THAT THIS 6 PROGRAM IS ANTICIPATED TO BE CONDUCTED THROUGH THE 7 VARI ABLES THAT HAVE BEEN KNOWN TO CAUSE -- THE OUTSIDE 8 FACTORS THAT ARE KNOWN TO CAUSE VARI ABLES. IF WE HAD A 9 HIGH TEMPERATURE, HIGH HUMIDITY -- FOR INSTANCE, WE KNOW 10 THAT IT CAUSES SOME SLOUGHING OF FRUIT FORMS ON THE 11 PLANTS, THAT WE COULD CORREL ATE THAT LOSS OF BOLLS W ITH 12 HIGH TEMPERATURES DURING THAT PERIOD OF TIME.

13 IF THE INSECT POPULATION WENT VERY HIGH, WE

)

() 14 COULD INDICATE THAT BOLL SHED OR SQUARE SHED WAS DUE TO 15 INSECT POPULATION PERHAPS.

16 SO HOPEFULLY W ITH THE FACTORS WE HAVE

-)

17 REQUESTED TO BE MEASURED, IT WILL GIVE US ENOUGH

( 18 INFSRMATION TO DRAW SOME CONCLUSION FROM.

i 19 JUDGE COLE: YOU ARE CONFIDENT YOU HAVE 20 ANTICIPATED THOSE KINDS OF PROBLEMS?

l 21 MR. RAYNER: YES.

22 JUDGE COLE: ALL RIGHT, SIR.

7-23 JUDGE CARPENTER: I AM STILL TRYING TO LEARN

~'

24 VERY QUICKLY.

25 YOU HAVE THE FEELING THAT EVEN THOUGH AN

==e ~ ===w:

TELEPHONE 279 4711 h

g 2964 1

1 INDIVIDUAL PLANT MAY BE HEALTHIER BECAUSE IT HAS MORE '

I 2 FERTILIZER OR HAS A BETTER WATER SUPPLY, THAT THE OVERALL  !

'( ) 3 HEALTH OF THE PLANT DUE TO THOSE TWO FACTORS WOULDN'T HAVE 4 MUCH EFFECT ON THE FREQUENCY OF SUCCESSFUL PASSAGE FROM i

5 SQUARE TO THE OTHER STAGES? I AM STILL HUNG UP WITH THIS 6 ONE FIELD GETTING MORE WATER AND GETTING MORE FERTILIZER 7 HAV ING HEALTHIER PL ANTS AND THEREFORE THE WHOLE CYCLE

)

8 BEING DIFFERENT. I ASK THAT OUT OF IGNORANCE. I AM NOT 9 BEING ASSERTIVE.

10 MR. RAYNER: THERE ARE PROBABLY A FEW 4

11 FACTORS THAT COULD HAPPEN. IF THE FARMER Dl0 NOT IRRIGATE 12 THE l'IELD, FOR INSTANCE, THAT IT COULD CAUSE FRUIT DROP IN i 13 THE PLANT, ALL THE FRUIT FORMS. THE SQUARES FALL OFF AS

) .O 14 WELL AS THE FLOWERS AND THE BOLLS. BUT THE RELATIONSHIP I 15 THINK SHOULD BE PolNTED OUT OR COULD BE P0lNTED OUT, AT 16 LEAST IN THE TRADITIONAL PATTERN, IF I UNDERSTAND THE WAY 17 A SCIENTIST GATHERS HIS DATA AND TRIES TO FIGURE WHAT IS 18 STATISTICALLY SIGNIFICANT, THAT IF SOMETHING REALLY WEIRD 19 HAPPENED THAT YOU COULD PROBABLY DROP OUT THAT 20 INFORMATION, SOMETHING THAT YOU HAD A VERY ADVERSE 21 CONDITION.

22 JUDGE CARPENTER: WELL, I WAS CONCERNED f 23 WHETHER ANY RECORDS WOULD BE KEPT OF THESE TWO VARI ABLES.

24 MR. RAYNER: NO, IT'SNOTANklCIPATEDTHAT 25 THEY WOULD BE REQUIRED. IF AFTER CONDUCTING OUR

      • "a"r*a"Al";'#* '"*- M C !!i': A '1:

TELEPHONE 279 4711 f

i 2965 1 INTERV IEWS W ITH THE UNIVERSITY PEOPLE -- AND BY THE W AY, I i

2 HAVE A MEETING TOMORROW WITH THEM TO HELP DESIGN THE

() 3 MONITORING PROGRAM, JUST A LOT OF DETAILS THAT STILL NEED 4 TO BE WORKED OUT IN THE DAY-TO-DAY OPERATION OF THE f

5 MONITORING PROGRAM ITSELF, AND THEY ESSENTIALLY WANT TO 6 TALK TO US TO SEE EXACTLY WHAT IT IS WE FEEL HAS TO BE 7 DONE.

t 8 JUDGE CARPENTER: I GUESS THIS BOARD WAS 9 HOPING THAT THAT HAD ALREADY BEEN DONE. WE COULD SEE 10 ANOTHER'S FINISHED PRODUCT.

t 11 MR. RAYNER: IN GENERAL THE CONCEPT HAS BEEN 12 TAKEN CARE OF, BUT THE REAL DAY-TO-DAY WORK IS GOING TO 13 TAKE A WHILE.

I-O 14 JUDGE CARPENTER: THANK YOU.

15 JUDGE CALLlHAN: MR. RAYNER, 1 TAKE IT FROM 16 WHAT YOU HAVE SAID THAT THERE ARE NO DATA YET ON SQUARE TO 17 BOLL RATIOS. I AM BOTHERED A LITTLE BIT BY THE STATEMENT 18 IN THE STlPULATION I GUESS THAT THE MONITORING COULD BE 19 BEGUN OR BEGUN AS SOON AS PRACTICABLE. WHEN IS THAT7 20 HAVE YOU STARTED YET OR --

21 MR. RAYNER: WE HOPE TO BEGIN IT JUST AS 22 SOON AS POSSIBLE. AND YOU MAY ASK THE SAME QUESTION OF

)

23 THE APS PEOPLE. BUT THEY ARE VERY ANXl0US TO GET IT C 24 STARTED. FLOWERING AND BOLL SETTING SEASON FOR COTTON 25 THIS YEAR HAS JUST STARTED THE FIRST WEEK IN JUNE. YOU i

  • ^**!"#r"a"41":r '"*- O t C O i r * *ff TELEPHONE 279-4711 I

2966 1 WILL SEE THE FIRST FLOWERS PRODUCED ON COTTON PLANTS. SO 4

2 THIS IS THE TIME IF YOU W ANT TO TRY TO GET THE INFORMATION 3 IN FOR THIS YEAR. THE PROGRAM SHOULD BE STARTED AS SOON

(])

4 AS POSSIBLE.

1 5 AS FAR AS BASELINE DATA, THE UNIVERSITY OF 6 ARIZONA HAS WORKED WITH COTTON FOR A NUMBER OF YEARS IN 7 THE COTTON INDUSTRY HERE IN PHOENIX, AND THEY HAVE DONE

)

8 THESE TYPE OF COUNTS FOR A LONG, LONG TIME. SO l'M SURE 9 IT'S JUST A MATTER OF FINDING THAT INFORMATION IF YOU WANT 10 TO KNOW WHAT TRADITIONAL RATIOS ARE. AND IT MAY DIFFER t

11 SOMEWHAT BETWEEN VARIETIES EVEN OF COTTON. SO WE HAVE ALL 12 0F THOSE FACTORS TO ADDRESS AS FAR AS THE VARIETIES 13 PLANTED AND HISTORICALLY.

f 14 JUDGE CALLlHAN: HOW MANY CROPS A YEAR 15 COTTON 00 YOU HARVEST?

16 MR. RAYNER: WELL, COTTON IS A YEAR-LONG 17 CROP HERE FOR US. IT'S GENERALLY PL ANTED IN MARCH, TO THE 18 15TH OF MARCH, AND THEN IT WOULD BE HARVESTED. THE CROP .

19 IS USUALLY TERMINATED. WE TERMINATE THE GROWTH OF THE 9

20 CROP SOMETIMES ABOUT THE FIRST OF OCTOBER AND IT'S 21 HARVESTED IN NOVEMBER AND DECEMBER. SO IT'S A YEAR-LONG

. 22 CROP. THAT'S ONE OF THE W AYS THAT WE ARE ABLE TO PRODUCE 23 THE HIGHEST YlELDS IN THE NATION IN THIS STATE, JUST

() 24 BECAUSE OF THE LENGTH OF THE GROWlNG SEASON.

25 JUDGE CALLlHAN: PICKING UP ON ANOTHER ITEM, I ~~c"::::::==="~c- =a::= =,c:

TELEPHONE 279-4711

2967 1 IS THE INTEREST IN INSECT POPULATION PRIMARlLY BASED ON i

2 POLLINATING AGENTS OR ARE THERE ADVERSE EFFECTS THAT ONE

() 3 MIGHT UNCOVER BY A POPULATION COUNT AS WELL?

4 MR. RAYNER: IT'S IMPORTANT TO MONITOR THE 5 INSECTS BECAUSE THERE ARE CERTAIN OF THEM THAT -- SUCKING 6 INSECTS ESPECI ALLY -- THAT WILL PENETRATE THE COVERING OF 7 THE SMALL -- THE IMMATURE BUD IN THE VERY EARLY STAGES,

'8 EVEN BEFORE PRACTICALLY VISIBLE, AND THEY DIE. IF THE 9 VERY SMALL INSECTS PENETRATE THAT, THEY CAN CAUSE THE 10 FRUIT FORM TO BE DROPPED BEFORE IT EVER HAD A CHANCE TO 11 BECOME A BUD. AT ALMOST EVERY STAGE OF GROWTH THERE'S AN 12 INSECT THAT CAN 00 DAMAGE TO IT AND CAUSE THAT FRUIT FORM 13 TO BE LOST, WHETHER IT'S A SQUARE OR FLOWER OR BOLL.

/( 14 THERE ARE CERTAIN INSECTS THAT CAN ATTACK IN EACH OF THOSE 15 STAGES.

. 16 AND IT'S PART OF THE MONITORING PROGRAM WITH 17 ANY GROWER. AS A FARMER, I HAVE ALL THE FIELDS CHECKED i 18 TW ICE A WEEK DURING THE GROW ING SEASON. ANYWAY, YOU HAVE

~

19 A CONSTANT BATTLE.

20 JUDGE CALLlHAN: SO THE POPULATION WILL NOT l

21 ONLY COUNT BODIES BUT ALSO IDENTIFY THEM l PRESUME 7 22 MR. RAYNER: YES.

23 JUDGE CALLlHAN: PART OF THE UNIVERSITY'S O 24 PROGRAM WAS CARRIED OUT DOWN IN THE CASA GRANDE W AY, 25 SOMEWHERE DOWN THERE, MIRAN A. DO YOU HAVE ANY CONCERN

==:e -

= a : = :::

i TELEPHONE 279-4711

- . _ . - - _ _ _ _ - . _ , _ _ _ _ _ _ . . , . - ~ , - _ . . _ , . . _ , _ _ . _ . _ _ _ _ _ _ _ _ _ _ . . . _ , _ _ _

4 2968 1 ABOUT THE APPLICATION OF THE INFORMATION GLEANED THERE TO s 5

2 YOUR WORK, TO YOUR LOCATION?

() 3 MR. RAYNER: WELL, THERE ARE PERHAPS SOME 4 CONDITIONS THAT EXISTED IN THE STUDY THAT REALLY DID NOT --

9 5 i HAD SOME PROBLEM W ITH. BUT I THINK THE MAIN FINDING OF 6 THE STUDY W AS THAT THIS REL ATIONSHIP, A PHYS IOLOG ICAL 7 RELATIONSHIP, EXISTED, THAT THE -- FOR INSTANCE, THE -- IN 9

8 THE REPORT ON THE STUDY THAT W AS DONE, THE APPL ICATION OF 9 SALTS ACTUALLY OCCURED FAIRLY LATE IN THE SEASON. WITHOUT 10 THAT IN FRONT OF ME -- I BELIEVE IT WAS IN MAY. THEN IT 4

11 CONTINUES CLEAR UP INTO THE FIRST OF DECEMBER, WHICH IS 12 ESSENTI ALLY LONG PAST THE TIME AT THE PLANT -- THAT WE 13 TRADITIONALLY GROW THE PLANT. SO WE STOPPED DEVELOPMENT -

  • ) O 14 0F THE PL ANT AFTER THE FIRST OF OCTOBER. JUST THE NATURAL -

15 PROCESSES OF THE PLANT USUALLY OCCURS TOWARD THE END OF 16 SEPTEMBER. SO THE PHOTOSYNTHESIS REALLY STOPS AT THAT y

17 TIME.

18 AND IN THAT STUDY WE CONTINUED TO APPLY THE 19 SALT TO 7.4 POUNDS PER ACRE AT THE LOWEST GRADE AND FOUND U

20 IT TO BE -- PART OF IT TO BE APPLIED DURING A PERIOD OF 21 TIME WHEN THE PL ANY DIDN'T REALLY GROW AND PRODUCE 22 ANYTHING FOR US. SO THAT WAS A CONCERN.

23 JUDGE CALL lHAN: 1 NOTICE YOUR REPORT MADE O 24 THE STATEMENT THAT BECAUSE OF HIGHER HUMIDITY A LITTLE 25 WAYS TO THE SOUTH, THE UNIVERSITY'S RESULTS WERE MAYBE A

"^**!"u^""a%5%M'a's'"""*- %"dC 'Ti' o*f * *1!

TELEPHONE 279-4711

Jc 2969 1 L ITTLE B IT ON THE CONSERV ATIVE S IDE. DO YOU TAKE CONFORT 4

2 IN THAT?

() 3 MR. RAYNER: THERE ARE PERHAPS THINGS THAT 4 HAVE CONCERN. IT IS'VERY DIFFICULT TO MEASURE IN THE TYPE 5 0F SYNTHETIC PROGRAM THAT THEY DEYlSED. AND THE WAY WE 6 VIEW THE OCCURRENCE IN THE FIELD WILL BE THAT SALT 7 DEPOSITION WILL OCCUR CONTINUOUSLY AS THE PLANT IS RUNNING 8 OVER A PERIOD OF TIME. WE HAVE A GROWING PLANT IN THE 9 FIELD THAT STARTS IN MARCH AND IT SITS THERE EXPOSED TO 10 THE ELEMENTS FOR SAY FOR THREE MONTHS. IT'S VERY COMMON 11 THIS TIME OF YEAR FOR NO RAIN TO OCCUR FOR THREE TO FOUR 12 MONTHS. THAT PLANT CAN SIT THERE AND ACCUMULATE SALT IN 13 THE FIELD. I DON'T HAVE ANY SCIENTIFIC EVIDENCE TO BACK

[() 14 THIS UP, BUT THOSE LEAVES GATHER A LITTLE SALT OVER A l

l 15 PERIOD OF TIME AND THEN YOU HAVE A VERY LIGHT RAIN AND 16 HUMIDITY WITH SALT ON THE LEAVES, WE HAD SOME FEARS OF l 17 SALT BURN. THAT WOULD BE A DIFFERENT TYPE THAN ANYTHING i 18 THAT WAS MEASURED IN THE EXPERIMENTS WHERE THEY WERE i 19 APPLYlNG A SOLUBLE SOLUTION TO THE PL ANTS EACH DAY. AND

)' 20 ALSO WITH WITH THE HIGHER HUMIDITY AND RAINFALL THAT 21 OCCURRED DURING THE YEAR WHEN THE STUDY WAS DONE, THE 22 CHANCE FOR A LOAD OF SALT TO ACCUMULATE ON THE LEAVES

)

23 REALLY NEVER OCCURRED.

()

r l

24 JUDGE CALLlHAN
I HAVE LOOKED, ALBEIT TO A

( 25 VERY L IMITED EXTENT, BUT I HAVE LOOKED AT SEVERAL FIELDS.

)

^"'"u^a"r"4"4 EE a?"' '"*' 'E*ohC# ICE *#

TELEPHONE 279-4711

2970 1 AND 00 l JUDGE THAT YOU DO SURFACE IRRIGATION -- AND 2 PARDON MY IGNORANCE IN TERMINOLOGY -- AS CONTRASTED TO

() 3 SPRAY IRRIGATION?

4 MR. RAYNER: THAT'S CORRECT. THE BULK OF 5 THE IRRIG ATION THIS AREA IS WHAT WE CALL FURROW. IT'S A 6 SURFACE I RR IG AT I ON.

7 JUDGE CALLlHAN: THERE WAS ALSO A REMARK 8 SOMEPLACE IN THIS MORASS OF PAPER THAT YOU DEFOLIATE WITH 9 SALT. WOULD YOU CARE TO COMMENT, PLEASE, A LITTLE BIT ON 10 WHY AND HOW AND WHAT HAPPENS TO THAT SALT AND DOES IT FIT 11 IN THIS PICTURE ANYWHERE7 12 ,

MR. RAYNER: WELL, THERE ARE SOME CHEMICALS 13 THAT ARE UTILIZED TO CAUSE THE LEAVES TO DROP FROM THE I

() 14 PLANTS AT THE END OF THE SEASON. SOME OF THE MATERIALS 15 ARE ORGANIC PHOSPHATES THAT SIMPLY CAUSE AN OBSCISSION OF 16 THE LEAVES, AND OTHERS ARE DESSICATING AGENTS THAT 17 ESSENTIALLY JUST DRY THE LEAVES AND CAUSE THEM TO FALL.

18 AND -- LET ME THINK OF ANOTHER NAME FOR IT. SODIUM 19 CHLORATE AND MAGNESlUM CHLORATE. SODIUM CHLORATE IS A

)

20 MATERI AL AND 'lT ALSO HAS OXIDlZING PROPERTIES THAT CAUSE 21 PHYSICAL BURN OF THE PL ANTS. AND THE COMMON RATE OF 22 APPLICATION WOULD BE AT THREE POUNDS PER ACRE TO EFFECT A 23 TOTAL DEFOLIATION IN THE MATURE PLANT.

O 24 JUDGE CALLlHAN: SO THAT'S LESS THAN THE 25 CONCENTRATION USED IN THE TEST IS, IF I BELIEVE MY MEMORY.

"^**EEu^n"r ni"p5EE'aY "** '***"d*["EIio*N[sa1 p o TELEPHONE 279 4711 l'

2971 1 MR. RAYNER: IN ALL FAIRNESS, THAT'S APPLIED 2 ONE TIME, NOT OVER A PERIOD OF TIME.

() 3 JUDGE CALLlHAN: THEN DO YOU -- DOES THAT 4 SALT JUST ACCUMUL ATE FROM YEAR TO YEAR?

5 MR. RAYNER: WHATEVER IS APPLIED TO THE 6 PLANT, IF IT FALLS OFF WITH THE LEAVES TO THE Soll WOULD 7 CERTAINLY BECOME A PART OF THE TOTAL SALTS WITHIN THE 8 SOIL.

9 THAT BRINGS UP A POINT THAT SOME OF THE i

, 10 MONITORING TH AT W AS DONE, THERE WAS SOME CONCERN OVER THE 11 TOTAL SALINITY IN THE SolL. AND OF COURSE IT'S A VERY BIG 12 CONCERN OF OURS. BUT ALSO, YOU KNOW, IN ALL FAIRNESS TO 13 THE WORK TH AT W AS DONE, Soll SAL INITY AND WATER SAL INITY 14 IS A PROBLEM THAT WE KNOW HOW TO WORK WITH AND THAT WE

. 15 HAVE WORKED WITH FOR A NUMBER OF YEARS. AND SALT LEVELS

16 IN THESE DESERT SolLS AND SOILS THEMSELVES AND IN THE 17 IRRIGATION WATER THAT WE USE ARE KNOWN TO BE QUITE HIGH IN 18 SOME AREAS. AND IT VARIES DRAMATICALLY FROM AREA ON AREA.

19 COTTON IS A FAIRLY TOLERANT PLANT TO THE

)

20 UPTAKE THROUGH THE ROOTS. THAT'S WHY WE WERE S0 CONCERNED 21 THAT SOME OF THOSE MEASUREMENTS WERE WHAT WERE BEING 22 RELIED UPON IN SOME OF THE N.U.S. TESTING OF THE SOIL

)

23 S AMPL ES. WE FELT LIKE THAT THIS MEASUREMENT .0F THE 24 SQUARE, BLOOM AND BOLL FACTORS REALLY NEEDED TO BE STUDIED 25 MORE SO THAN THOSE LEVELS OF THE SOIL BECAUSE WE KNOW THE

)

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. , _ . . _ _ _ . . . _ _ _ . _ . _ - - . _ _ _ . . . . _ _ , _ _ . . _ _ . .________.1___

1 l

l 2972 1 LEVELS GENERALLY UNDER THE Soll ARE MUCH HIGHER.

2 SO THAT AN APPLICATION RATE OF TWO TO THREE

() 3 POUNDS PER ACRE WOULD HAVE VERY INSIGNIFICANT IMPACT ON 4 THE TOTAL LEVELS IN THE S0ll AND EVEN OVER A PERIOD OF A 5 NUMBER OF YEARS, AND I THINK IT WAS BROUGHT UP IN SOME OF 6 THE STUDIES THAT WERE DONE, THAT IT'S NORMAL IN THE 7 APPLICATION OF IRRIGATION WATER THAT HAS EVEN VERY LOW

)

-8 SALINITY LEVELS THAT WE WOULD CATEGORIZE IT SEVEN TO 800 9 PARTS PER MILLION, WE WOULD APPLY A TOTAL OF ABOUT TWO 10 TONS OF SALT PER ACRE WITH THE APPLICATION OF THAT AMOUNT

).

11 0F W ATER. BUT THAT'S IN THE SOIL. AND WE KNOW THAT 12 PL ANTS ARE CAPABLE OF HANDL ING THAT BECAUSE WE HAVE BEEN 13 FARMING, AT THOSE LEVELS AND MUCH HIGHER THAN THOSE LEVELS

_f}

14 FOR YEARS AND YEAR. .

15 JUDGE CALLlHAN: IS YOUR SOURCE OF NORMAL 16 IRRIGATION WATER YOUR PRIMARILY WELLS 7

)

17 MR. RAYNER: IN THE AREA AROUND THE NUCLEAR 18 PLANT, THE BASIC SUPPLY IS FROM WELL W ATER.

19 JUDGE CALLlHAN: THANK YOU VERY.MUCH.

,)

20 JUDGE COLE: MR. RAYNER, YOU INDICATED THAT 21 YOU ARE FAMILIAR WITH AND HAVE BEEN WORKING WITH Soll 22 SALINITY PROBLEMS.

)

23 MR. RAYNER: YES.

{) 24 JUDGE COLE: IN ONE OF THE PIECES OF 25 TESTIMONY BEFORE US IT INDICATED PERIODIC LEACHING OF THE

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TELEPHONE 2794711

2973 1 Soll IS DONE. DO YOU DO ANY OF THAT?

2 MR. RAYNER: .YES, AS A MATTER OF COURSE, O 3 oePENoiNG ON THE SALINITY LEVEL OF THE WATER WE ARE 4 WORKING WITH. I HAD SOME FARMS WHERE THE TOTAL 3

5~ CONCENTRATION OF SALTS WERE AT 3500 PARTS PER MILLION, AND 6 IT REQUIRES THAT I APPLY ABOUT A 30 PERCENT ADDITIONAL 7 WATER FACTOR TO THE Soll TO MAINTAIN A LEACHING ELEMENT SO 8 THAT THE SALTS ARE CONTINUALLY REMOVED FROM THE ROOT ZONE.

9 JUDGE COLE: BY LEACHING, IS IT JUST LEACHED 10 THROUGH THE Soll DOWN THROUGH THE GROUNDW ATER TABLE OR IS 11 - IT RUN THROUGH AND PASSED THROUGH THE SYSTEM AND 12 DISCHARGED SOMEPLACE 7 13 MR. RAYNER: GENERALLY THE SALTS ARE PUSHED 14 FURTHER DOWN INTO THE S0ll. AND WHEN YOU SAY INTO THE 15 GROUNDWATER SYSTEM, GENERALLY THE AQUlFERS IN MOST AREAS 16 ARE SO DEEP -- NOT DEEP. ONLY IN VERY SHALLOW WATER 17 CONDITIONS. BUT WHEN YOU PUMP FROM SEVERAL HUNDRED FEET, l 18 YOU ARE ESSENTIALLY PUSHING THE SALINITY OUT OF THE AREA 19 0F THE RESERVOIR.

20 JUDGE COLE: SO YOUR SOURCE OF GROUNDWATER 21 IS A DIFFERENT AQUlFER THAN THE ONE THAT IS BEING

! 22 RECHARGED BY THIS LEACHING WATER?

)

23 MR. RAYNER: ESSENTIALLY, BECAUSE YOU REALLY 24 DON'T WIND UP WITH AN AQUlFR WHERE YOU ARE LEACHING TO.

25 BUT GENERALLY, THE MAIN AQUlFERS ARE QUITE DEEP. I DON'T l ==.- = = = =

! TELEPHONE 279-4711

t 2974 1 BELIEVE THERE ARE ANY STUDIES RECENTLY TO SHOW THAT ANY

)

2 ADDITION OF SALT TO THE UNDERGROUND TABLE ACTUALLY OCCURS O 3 FROM THAT LEACHING.

4 JUDGE COLE: WHICH AQUlFER 00 YOU USE FOR 5 YOUR GROUNDW ATER SOURCE, SHALLOW AQUlFERS OR DEEP j 6 AQUlFERS?

7 MR. RAYNER: GENERALLY DEEP AQUlFERS.

8 REALLY THERE ARE NO SHALLOW AQUlFERS IN THOSE AREAS.

l l 9 GENERALLY THF.RE'S NOT ENOUGH W ATER THERE TO BE CONSIDERED l

'. 10 A FREE W ATER SUPPLY. EVEN THOUGH YOU POSSIBLY PUSH THE

)

11 MOISTURE TO THOSE LEVELS, IT'S NOT A LEVEL THAT WOULD BE l 12 PUMPABLE TO BE CONSIDERED AN AQUlFER.

13 JUDGE COLE: THE SALTS CONCENTRATION IN 14 THESE AQUlFERS IS NOT INCREASING AT ANY APPRECIABLE RATE 7 15 MR. RAYNER: YOU KNOW, i REALLY HAVE NEVER

! 16 SEEN ESTIMATES OF MEASUREMENTS, BUT IT'S A PHENOMENA THAT

)

17 OCCURS IN DESERT S0lLS AND HAS OVER YEARS OF TIME, THAT --

18 THIS IS THE FOUNDATION OF WHAT WAS CALLED CALICHE LAYERS.

l 19 IT'S NOT CONSIDERED SODIUM SALTS BUT ACTUALLY SALTS AND

)

20 CARBONATES THAT LEACHED FROM THE SURFACE IN THE SURFACE 21 FROM LAYERS UNDERNEATH THE Soll SURFACE.

l 22 JUDGE COLE: ALL RIGHT, SIR. THANK YOU.

b THANK YOU, MR. RAYNER.

23 JUDGE L AZO:

l 24 i THINK AT THIS POINT WE SHOULD CONSIDER 1

25 GOING FORWARD WITH THE QUESTIONS BY THE BOARD OF THE l

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TELEPHONE 279-4711

2975 1 PREFILED TESTIMONY. IT WOULD BE OUR SUGGESTION THAT WE 2 MIGHT EXPEDITE MATTERS IF JOINT APPL ICANTS' WITNESSES AND

() 3 STAFF WITNESSES AND PERHAPS THE UNIVERSITY OF ARIZONA 4 PEOPLE, AT LEAST MR. FOSTER, WOULD ALL JOIN IN THE PANEL 5 AT THE SAME TIME. IT MIGHT EXPEDITE MATTERS SINCE WE 6 COULD QUESTION STAFF WITNESSES AND PANEL WITNESSES 7 CONSECUTIVELY RATHER THAN GOING BACK AND DOING PART OF IT 8 OVER AG AIN IF THEY APPEARED SEPARATELY.

9 WOULD ANYONE HAVE ANY OBJECTION TO HANDLING 10 IT THAT WAY?

11 MR. GEHR: 1 HAVE NO OBJECTION.

12 IS THERE A NEED FOR INTRODUCING THE 13 TESTIMONY OF WITNESSES AND EXHIBITS AT THE -- THE SEVERAL 14 WITNESSES THAT WERE PREPARED? .

15 JUDGE L AZO: WE MIGHT BE ABLE TO AWAIT A 16 DECISION ON THAT AND NOT DECIDE AT THIS TIME WHETHER WE 17 SHOULD GO THROUGH THAT FORMAL PROCEDURE. I JUST DON'T 18 KNOW. I THINK WE DO WANT TO BE SURE THAT THE PREFILED 19 TESTIMONY DOES IN FACT BECOME PART OF THIS RECORD, 20 ALTHOUGH IT MAY NOT BE SOMETHING THAT WE WILL HAVE TO RELY 21 ON IN REACHING A DECISION.

22 AS FAR AS MR. RAYNER AND MR. GLADDEN ARE r

23 CONCERNED, LET ME ASK, 00 ANY OF YOU FEEL A NEED TO ASK 24 THESE GENTLEMEN TO REMAIN DURING THE BOARD QUESTIONING?

25 THEY ARE OF COURSE WELCOME TO REMAIN IF THEY CHOOSE TO 00 l

COURT RE R RS P Q RIZON 85014 TELEPHONE 279 4711

2976 1 S0.

t 2 LET ME ASK THE BOARD MEMBERS FIRST. IT MAY 3 BE THAT SOME OF THE BOARD QUESTIONING MAY RAISE QUESTIONS

/])

(

4 IN YOUR MIND, MR. RAYNER, AND YOU OF COURSE WOULD BE

)

5 WELCOME TO ASK QUESTIONS OF THESE WITNESSES YOURSELF IF 6 THE NEED ARISES.

7 MR. DEWEY: MR. RAYNER DOES NEED TO LEAVE

)

8 ABOUT 2:00 0' CLOCK. YOU THINK THE BOARD WOULDN'T HAVE ANY 9 PROBLEM W ITH THAT, WOULD THEY?

10 JUDGE L AZO: WELL, WE ARE FAST APPROACHING 1

11 THE LUNCH HOUR.

l 12 MR. RAYNER, YOU HAVE OTHER OBLIGATIONS THIS I

13 AFTERNOON?

() 14 MR. RAYNER: YES, 1 D0.

15 JUDGE L AZO: MR. GLADDEN, ARE YOU IN A 16 POSITION TO STAY OR DO YOU DESIRE TO DO S0?

17 MR. GLADDEN: W EL L , 1 ALSO HAVE SOME OTHER 18 COMMITMENTS THIS AFTERNOON. WE DIDN'T THINK IT WOULD LAST 19 QUITE THIS LONG, PAST 2:00 0' CLOCK.

20 JUDGE L AZO: WELL, THAT'S THE REASON WHY WE i

21 WISH TO PROCEED WITH BOARD QUESTIONS. WE CERTAINLY MAY 22 ASK THE QUESTIONS THAT YOU WOULD IF YOU WERE HERE.

)

23 MR. RAYNER: 1 REVIEWED SOME OF THE O 24 TESTIMONY THAT'S BEEN SENT OUT AND l REALLY DON'T HAVE ANY 25 FURTHER QUESTIONS. I THINK WE FORMULATED IN OUR OWN MINDS

)

"^**!"u^."r"4"4M'a?"' '"*- '!%%iG#7io*NT'!:.

TELEPHONE 279 4711

2977 1 THE IMPORTANT THINGS, AND I DIDN'T SEE ANYTHING ELSE THAT 2 CAME OUT IN THE PREFILED STATEMENTS OR DOCUMENTS.

() 3 JUDGE LAZO: ALL RIGHT. WELL, THEN AS FAR 4 AS WE ARE CONCERNED, YOU ARE PERFECTLY AT LIBERTY TO 5 LEAVE. .

6 AGAIN, WE DO APPRECIATE YERY MUCH YOUR l 7 MAKING YOURSELF AV AIL ABLE THIS MORNING, BOTH OF YOU. IT'S 8 BEEN VERY HELPFUL 9 MR. GEHR: MR. CHAIRMAN, YOU HAD INQUIRED l

10 ABOUT OTHER COMMITMENTS, AND I WANTED TO MAKE IT CLEAR 11 SINCE MR. RAYNER AND MR. GLADDEN ARE HERE THAT THERE ARE 12 NO OTHER COMMITMENTS BETWEEN APS AND WEST VALLEY FARMERS i

13 OTHER THAN THOSE EXPRESSED IN THE SETTLEMENT AGREEMENT l

14 ITSELF. AND IN THE DRAFTING OF IT, 1 NOTICE THERE'S A 15 COMMA AFTER THE WORD " MONITORING." IF THAT HAD BEEN 16 DELETED, I THINK lT WOULD HAVE BEEN MORE CLEAR. THE OTHER 17 COMMITMENTS WERE THE AGREEMENTS TO COOPERATE IN FINDING

,. 18 SITES, GIVING US ACCESS TO SITES, CONDUCT THE ADDITIONAL 19 MONITORING, APS'S AGREEMENT TO COOPERATE AND USE ITS BEST 20 EFFORTS TO GET THE UNIVERSITY OF ARIZONA TO CONDUCT THE 21 STUDY, AND IF WE ARE UNABLE TO DO THAT TO FIND ANOTHER 22 ACCEPTABLE INDEPENDENT LABORATORY OR SOMEBODY. IT'S THAT 23 KIND OF COMMITMENT.

f 24 JUDGE LAZO: THANK YOU, MR. GEHR. I THINK 25 TilAT'I HELPFUL. MR. RAYNER HAD ALREADY SATISFIED US ON

'"c-

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i 2978 1 THAT SCORE. HE S AID TH AT THE OWN OTHER COMMITMENTS TH AT 4

2 HE WAS AWARE OF RELATED TO THE COMMITMENT TO PROVIDE DATA

() 3 TO THE FARMERS, AND WE WERE CERTAINLY SATISFIED WITH THAT, 4 ALTHOUGH WE D0. APPRECIATE YOUR ADDITIONAL CLARIFICATION.

5 THEN WHY DON'T WE TAKE OUR LUNCHEON RECESS 6 NOW AND PLAN TO COME BACK AT 1:30 AND PROCEED WITH THE 7 JOINT APPL ICANTS' PANEL OF W ITNESSES AND STAFF'S WITNESSES 8 AND WHOEYER WANTS TO JOIN THEM FROM THE UNIVERSITY OF 9 ARIZONA.

10 WE WILL RECESS UNTIL 1:30. THANK YOU.

I 11 (LUNCHEON RECESS TAKEN AT 12:05 P.M.)

12

> CE) - -

14-15 16

)

17 18 19 t

20 21 22

)

() 24 25

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' 2979 i

1 (THE AFTERNOON SESSION WAS COMMENCED 2 AT 1:32 P.M.)

() 3 JUDGE LAZO: NOW, MR. GEHR AND MR. DEWEY, I DO YOU 4 THINK PERHAPS THESE WITNESSES SHOULD BE SWORN.

5 AGREE WITH THAT?

6 MR. GEHR: YES, SIR.

7 MR. DEWEY: I HAVE NO PROBLEMS WITH THAT, YOUR 8 HONOR.

9 JUDGE LAZO: GENTLEMEN, WOULD YOU EACH STAND, 10 PLEASE, AND RAISE YOUR RIGHT HAND.

11 (THE WITNESSES WERE SEVERALLY SWORN.)

12 JUDGE LAZO: THANK YOU. PLEASE BE SEATED, 13 GENTLEMEN.

O 14 JUDGE COLE: GENTLEMEN, I HAVE A LOT OF SMALL 15 QUESTIONS WHICH I THINK COULD BE HANDLED EXPEDITIOUSLY.

16 I GUESS l'LL START WITH MR. WILBER.

17 MR. WILBER, ON PAGE NINE OF YOUR 18 TESTIMONY, YOU REFER TO THE EFFICIENCY OF A DRIFT 19 ELIMINATOR INDICATING THAT THE EFFICIENCY GOES UP WITH SEASONING AND WOULD BE LESSENED BY DEGRADATION. COULD 20 21 YOU TELL ME WHAT IS SEASONING? HOW DOES THAT EFFECT THE 22 EFFICIENCY OF A DRIFT ELlMINATOR?

23 MR. WILBER: DRIFT ELIMINATORS THAT ARE MADE O 24 0F PVC OR OTHER PLASTIC TYPE MATERIALS, WHEN THEY ARE 25 BRAND NEW OFTENTIMES HAVE A SMOOTH AND WAXY SURFACE

"^**ESu^n"r nSSoEEn's' ' '"*' $*oSICEIi*o'n"[s*o*1 TELEPHONE 2794711

)

2980 1 ASSOCIATED WITH THE MATERIAL ITSELF; AND AFTER SOME 2 EXPOSURE TO DROPLETS AND SUBSEQUENT DEPOSITION OF

() 3 MINERALS ON THAT SURFACE, THIS WAXY SURFACE THAT MIGHT 4 OTHERWISE CAUSE DROPLETS TO BEAD CAUSES DROPLETS TO 5 SPREAD OUT FURTHER AND, THEREFORE, ONCE THEY COLLECT ON 6 THE SURFACE, INSTEAD OF BEING REENTRAINED FOLLOWING THIS 7 BEADING PROCESS, HAVING BEEN SEASONED, THE WATER IS 8 COLLECTED AND RETAINED AND THEN DRAINED OFF.

9 JUDGE COLE: HOW LONG DOES IT TAKE FOR THIS I- 10 SEASONING ACTION TO TAKE PLACE 7 11 MR. WILBER: IT VARIES WITH THE WATER 12 CHEMISTRY AND SOMETIMES WITH THE MATERIAL AND WHAT TYPE l 13 0F WAXY SURFACE EXISTS ORIGINALLY. BUT TYPICALLY, TWO O 14 TO FOUR WEEKS WdULD INITIATE THAT PROCESS AND THEN 15 THERE'S PROBABLY -- AND I DON'T THINK THERE'S A LOT OF 16 GOOD DATA ON THIS PHENOMENA BY THE WAY -- THAT IT MAY 17 BECOME ASYMPTOTIC AFTER SOME SIX MONTHS OF OPERATION.

18 JUDGE COLE: ALL RIGHT, SIR. YOU MIGHT HAVE 19 ALREADY EXPLAINED IT, THEN. IN APPENDIX B 0F EXHIBIT

)

l 20 W-3 THERE'S A LETTER FROM THE MANUFACTURER OR 21 REPRESENTATIVE OF THE MANUFACTURER. DO YOU H AV E TH AT 22 LETTER, SIR 7 IT'S FROM MR. J.D. HOLMBERG, SCIENCES 23 DIRECTOR OF THE MARLEY COOLING TOWER COMPANY.

l t

O 24 MR. WILBER: I BELIEVE I D0. GIVE ME A SECOND 25 HERE. APPENDIX WHAT7

)

i j "**"L"Ja*a*M#*' "**  % ; M lli' ~lT * *1:

TELEPHONE 279-4711

l 298; 1 JUDGE COLE: IT'S APPENDIX B.

)

2 MR. WILBER: OKAY. YES, I 00.

3, JUDGE COLE: WHICH IS THE WATER FLOW RATE 4 DATA. THE FIRST PAGE OF THAT APPENDlX IS A LETTER TO

)

5 YOU FROM J.D. HOLMBERG. IN THAT LETTER HE REFERS TO THE 6 RETEST OF A REPEAT TEST ON THE ONE FAN CYLINDER, AND I 7 BELIEVE THAT WAS K, INDICATING THAT THAT IS SUPPOSEDLY A 8 VERY GOOD INDICATION OR MIGHT BE A GOOD INDICATION OF 9 THE SEASONING EFFECT. WHAT DID HE MEAN BY THAT?

10 MR. WILBER: WELL, I THINK HAD THE REPEAT 11 TESTS OCCURRED MANY WEEKS, NOT TWO OR THREE DAYS OR TWO 12 OR THREE HOURS AFTER THE INITIAL TEST, THEN THAT MIGHT 13 HAVE BEEN AN INDICATOR OF THE SEASONING AND HOW THAT 14 ' REDUCED THE DRIFT RATE; BUT IN OUR P5RTICULAR TESTS, THE 15 INITIAL TEST AND THE REPEAT TESTS WERE CLOSELY COUPLED 16 AS I REMEMBERED TIMEWISE.

?

17 JUDGE COLE: DO YOU THINK THAT HE WAS NOT 18 AWARE OF THAT, THE REASON FOR HIS COMMENT HERE?

19 MR. WlLBER: THAT COULD BE. I'M NOT SURE WHAT 20 HE WAS AWARE OF AT THAT TIME.

21 JUDGE COLE: ALL RIGHT, SIR. THEN THAT 22 COUPLED WITH THE LIQUID DRIFT EMISSIONS RESULTS ON THE 23 REPEAT OF K SEEMS TO BE CONTRARY TO ANY SEASONING EFFECT 24 IF THERE WAS ANY. DO YOU AGREE WITH THAT, SlR?

25 MR. WILBER: IT CERTAINLY WOULD BE IN THAT '

""**Eo"u^nYnEP5EEEs' "** 'E*o"d**EIio'uYa* o*1 TELEPHONE 279-4711

I 2982 y.

1 DIRECTION. .ONCE AGAIN, THOSE WERE FAIRLY CLOSE

~

2 TIMEWISE, WITHIN A DAY OF EACH OTHER, AND 1 DON'T -- 1

() 3 THINK WHAT YOU'RE SEEING THERE IS MORE A REPEATABILITY, 4 NOT ANY INDICATION AT ALL OF SEASONING AND THE EFFECT 5 THAT SEASONING MIGHT HAVE.

6 JUDGE COLE: ALL RIGHT, SIR. LOOKING 7 SPECIFICALLY AT THE LIQUID DRIFT EMISSION RESULTS FOR 8 THE'K CELL, IN THE INITIAL TEST IT WAS 1.82 GRAMS PER 9 SECOND; IS THAT CORRECT, SIR?

10 MR. WILBER: THAT'S CORRECT.

f 11 JUDGE COLE: AND ON THE REPEAT TEST, WHICH WAS 12 THE NEXT DAY I BELlEVE --

13 MR. WILBER: IT WAS WITHIN A, DAY AS I 14 REMEMBER.

15 JUDGE COLE: 2.28. ONE OF THE CRITICISMS OF 16 THE STUDY IS THAT CERTAIN OF THE STATISTICS MIGHT BE 4

17 DEFICIENT.IN THAT WE COULD NOT PUT A CONFIDENCE INTERVAL l 18 AROUND THE EMISSIONS RATE. DO YOU AGREE WITH THAT 19 CRITICISM, SIR?

20 MR. WILBER: l'M NOT SURE THAT BASED ON THIS 21 ONE CAN COME TO THAT CONCLUSION. I THINK IF YOU ARE l

22 FAMILIAR WITH AN EXIT PLANE OF A COOLING TOWER, WHICH IS 23 WHERE THESE MEASUREMENTS WERE MADE, AND THE VARIABILITY 24 THAT EXISTS AS WELL AS THE ACCURACY OF THE MEASUREMENTS, 25 l AM QUITE COMFORTABLE WITH TH AT K IND OF REPEATAB IL ITY,

""* *!!v^a"r"al"4EE a?"""*~ '"* o"dCEIi 'ni'.'s o *i!

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2983 1 AND THAT DOESN'T REDUCE MY CONFlDENCE IN THIS TYPE OF 2 MEASUREMENT. IF IT WERE A TEMPERATURE MEASUREMENT AND O 3 We SaiD THAT WE C0utD ME^SuRE ir WiTHiN 80 INT ONE DEGREE 4 F AND WE WERE FIVE DEGREES OFF, THEN I MIGHT BE A LITTLE 5 UNCOMFORTABLE WITH THAT. BUT l'M NOT BOTHERED BY THIS 6 AT ALL OR THE CONFIDENCE IN THE DATA.

7 JUDGE COLE: ALL RIGHT, SIR. WHAT SORT OF A

,)

8 BAND WOULD YOU PUT AROUND THE LIQUID DRIFT EMISSIONS 9 RESULTS THAT YOU RECEIVED?

10 MR. WILBER: I WOULD SAY THAT AS A TOTAL, A 11 NUMBER ROUGHLY OF PLUS OR MINUS SP PERCENT WOULD BE A 12 REASONABLE NUMBER.

13 JUDGE COLE: ALL RIGHT, SIR. THANK YOU, 14 THAT'S HELPFUL.

15 WITH RESPECT TO THE DIFFERENCE BETWEEN 16 THE ISOKINETIC SAMPLING AND THE SENSITIVE PAPER RESULTS, 17 DID YOUR 50 PERCENT ESTIMATE APPLY THERE ALSO, SIR, PLUS 18 OR MINUS 50 PERCENT?

19 MR. WILBER: l'M GLAD YOU BROUGHT THAT UP 20 BECAUSE I TH INK THERE WIRE SOME MIS INTERPRETATION IN THE

! il REYIEW OF OUR REPORT AND TESTIMONY IN THAT AREA. AS YOU 22 RECALL, I THINK IN BOTH THE REPORT AND TESTIMONY, THERE 23 WAS SIGNIFICANT TREATMENT OF THE FACT THAT THE AMBIENT 24 A I R, THAT IS THE AIR THAT ENTERS THE COOLING TOWER, AT 25 VERY HIGH LEVELS ARE THE SAME MINERALS THAT WE WERE

"" " a a"Am;' ,'" '"c-

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) 2984 1 TRYING TO USE AS TRACERS AT THE EXIT POINT. IN THAT IT 2 DID -- AND BY THE WAY, THOSE LEVELS WERE HIGHER, THE

() 3 CONCENTRATION LEVELS OF THE AMBIENT AIR WERE HIGHER THAN 4 THE EXIT PLANE CONCENTRATIONS SUGGESTING THAT IF BOTH 5 MEASUREMENTS WERE REASONABLY ACCURATE, THAT THE COOLING 6 TOWER ACTS AS A SCRUBBER WHICH l'M NOT SURPRISED THAT IT 7 MIGHT.

8 JUDGE COLE: SO RATHER THAN CREATING A DRIFT 9 PROBLEM, IT WAS REMOVING SOLIDS THAT MIGHT BE DEPOSITED 10 LATER SOMEWHERE?

11 MR. WILBER: WELL, i GUESS ONE COULD LOOK AT 12 IT THAT WAY, BUT CERTAINLY THE ENTRAINMENT OF THOSE 13 MINERALS IN THE INLET AIR AND OUR INABILITY TO ASSESS k

14 THE SCRUBBING EFFICIENCIES OF THE COOLING TOWER CAUSES 15 US CONCERN, GREAT CONCERN, FOR THE AMOUNT OF MINERALS 16 THAT WE'RE LEAVING AND THAT WE WERE PICKING UP WITH A 17 DEVICE THAT MEASURES MINERALS, NOT A DEVICE THAT L

18 MEASURES LIQUID WATER LIKE THE SENSITIVE PAPER DOES 19 DIRECTLY. SO IT MADE IT IMPOSSIBLE REALLY TO COMPARE 20 THOSE TWO SETS OF DATA.

21 JUDGE COLE: WAS THIS DETERMINED AFTER THE D 22 EXPERIMENT WAS COMPLETED AND THEN THE RESULTS WERE JUST h

l 23 NOT INTERPRETABLE OR USABLE; IS THIS WHAT HAPPENED?

24 MR. WILBER: THAT'S CORRECT. IN FACT, WE

! 25 LOOKED AT A NUMBER OF CHEMICALS TO TRY TO PICK SOMETHING h

l "^"!"#r"4"4 ML?" ""- 30 #7i o'r1.

TELEPHONE 279-4711

2985 1 THAT DIDN'T EXIST IN THE AMBIENT AIR THAT SOMEHOW 6

2 EXISTED IN ENOUGH CONCENTRATION IN THE CIRCULATING WATER

() 3 USED AS A TRACER. WE WERE UNABLE TO FIND ANYTHING THAT 4 WAS SUFFICIENT IN THE CONCENTRATION.

5 JUDGE COLE: THAT'S ONE OF THE PROBLEMS OF 6 D0 LNG RESEARCH.

7 DR. SAMWORTH OF THE N.R.C. STAFF

)

8 INDICATED IN HIS TESTIMONY THAT THESE METHODS WERE 9 GENERALLY CONSIDERED TO BE PLUS OR MINUS 15 PERCENT OF 10 TRUTH. MAYBE l'LL FIRST ASK DR. SAMWORTH WHAT HE 11 MEANT BY THAT AND THAN l'LL ASK YOU TO COMMENT ON 12 THAT, SIR. ,

13 WHAT DO YOU THINK OF THAT 15 PERCENT 7

'O 14 FIRST OF ALL, YOU MIGHT TELL US WHAT THE SOURCE OF 15 YOUR INFORMATION THERE IS, DR. SAMWORTH.

16 DR. SAMWORTH: 1 DON'T KNOW IF i CAN SAY THE 17 EXACT REFERENCE. l THINK THAT WAS A GENERAL -- THAT 18 ASSESSMENT OF THE CAPABILITY OF THOSE TWO METHODS, THAT 19 THEY WERE BOTH GOOD METHODS AND BOTH UNDER GOOD i

20 CONDITIONS, COULD MEASURE THE ACTUAL DRIFT TO WITHIN THE i

21 PLUS OR MINUS CONTAINMENT. CAPABLE -- BOTH ARE CAPABLE 22 0F MEASURING PHENOMENON.

-23 JUDGE COLE: IS THIS YOUR UNDERSTANDING ALSO, 24 MR. WILBER, OR IS YOUR UNDERSTANDING DIFFERENT?

25 MR. WILBER: LET ME PROVIDE A CLARIFICATION SO

==w~- ==:=u:

TELEPHONE 2794711 L

2986 1 WE'RE COMPARING APPLES AND APPLES. IF YOU SUBJECT 2 EITHER INSTRUMENT TO AN ENVIRONMENT WHERE YOU KNOW WHAT

() 3 EXISTS THERE AND CHARACTERIZE THAT ENYIRONMENT, SAY A 4 POINT MEASUREMENT THAT YOU'RE SUBJECTING THE IS0 KINETIC 5 SAMPLING.TO A KNOWN CONCENTRATION OF MINERAL, EXTRACTING 6 THAT MINERAL OUT AND MAKING AN ANALYSIS OF THAT, THEN I 7 .WOULD SAY THAT PLUS OR MINUS 15 PERCENT FOR A t

8 WELL-CONTROLLED ENVIRONMENT POINT MEASUREMENT IS 9 PROBABLY A GOOD NUMBER; HOWEVER, WE'RE LOOKING AT A 10 LARGE FAN STACK DIAMETER TAKING A NUMBER OF EQUAL AREA 11 POINTS AND I WAS HESITANT WHEN YOU ASKED ME THE NUMBER 12 ABOUT BAND WIDTH BEFORE OF ASSIGNING THE SAME TYPE OF 13 PLUS OR MINUS 15 PERCENT ACCURACY THAT YOU MIGHT ASSIGN

)

14 TO A POINT MEASUREMENT TO A LARGE VOLUME OF THAT TYPE; 15 THAT I S, THAT EXISTS AT THE EXIT POINT OF A FAN STACK OR

,. 16 CERTAINLY FOR A WHOLE COOLING TOWER AND I THINK YOUR 17 EARLIER QUESTION WAS MORE DIRECTED AT THE LATTER.

l L 18 JUDGE COLE: YES. ALL RIGHT, SIR. I i

19 UNDERSTAND YOUR POSITION ON THAT. ALSO IN YOUR 20 TESTIMONY YOU REFER TO INSPECTIONS TO RECOGNIZE THE 21 EFFECT OF DEGRADATION. WHAT IS THE STANDARD PRACTICE 22 WITH INSPECTIONS AND WHAT'DO YOU LOOK AT FOR THE -- l l_ 23 GUESS YOU WERE SPEAKING ABOUT THE DRIFT ELIMINATORS i

24 THEMSELVES.

25 MR. WILBER: STANDARD PRACTICE FOR A CROSSFLOW i

"^**!!a"r"a"4M'?"' '"*- 2 0 #io*~ T *'i.

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2987 1 COOLING TOWER THAT YOU CAN ACTUALLY GET INSIDE OF THE 2 COOLING TOWER WHEN ITS NOT IN OPERATION AND INSPECT THE (f 3 DRIFT EYE ELIMINATORS WOULD BE TO DO JUST THAT, TAKE A 4 WALK AROUND, LOOK FOR LARGE GAPS, LOOK FOR DETERIORATION 5 OR ANYTHING THAT MAY CAUSE EXCESS WATER TO BE CARRIED BY 6 THE AIR FROM THE FILL SECTION BEYOND THE DRIFT 7 ELIMINATOR PLANE TO THE EXIT PLANE OF THE COOLING TOWER.

)

8 IT'S A FAIRLY STRAIGHTFORWARD COMMON SENSE TYPE APPROACH 9 THAT YOU WOULD USE.

10 JUDGE COLE: AND HOW OFTEN IS THAT DONE?' HOW t

11 0FTEN SHOULD IT BE DONE?

12 MR. WILBER: l'M SURE THAT VARIES FROM UTILITY 13 TO UTILITY AND THOSE UTILITIES THAT HAVE HAVE LITTLE OR 14 NO ENVIRONMENTAL CONCERN ABOUT DRIFT, 1 DARESAY -- AND 15 THIS IS A GUESS -- THAT IT MAY BE DONE ONLY WHEN THE 16 TOWER IS INSPECTED FOR STRUCTURAL REASONS. MAYBE EVERY V

17 FOUR OR FIVE YEARS. IN OTHER CASES WHERE PEOPLE ARE 18 WORRIED ABOUT ENVIRONMENTAL CONCERNS, PERHAPS EVERY 19 PLANT OUTAGE, WHICH MAY BE ONCE A YEAR THEY GET IN THERE 20 OR MAYBE MORE OFTEN AND MAKE THAT INSPECTION AND THEN 21 PUT IN NEW DRIFT ELIMINATOR PANELS OR WHATEVER IS 22 REQUIRED, SEAL STRIPS, ET CETERA, TO RECTIFY THE L

23 SITUATION. THERE'S NO INDUSTRY STANDARD OR PRACTICE

[

24 THAT l'M AWARE OF.

25 JUDGE COLE: WELL, CONSIDERING THE FACT THAT

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1 l

1 2988 l l

1 WE MIGHT HAVE A SENSITIVE' SITUATION WITH RESPECT TO SALT 2 DRIFT, WHAT SORT OF INSPECTION PROGRAM MIGHT YOU

() 3 RECOMMEND BASED UPON YOUR EXPERIENCE WITH OTHER 4 UTILITIES AND THEN WHAT THEY FIND AFTER A PERIOD OF A 5 YEAR? IF THEY OBVIOUSLY HAD REPAIR WORK TO DO AFTER A '

6 YEAR, THE MAGNITUDE OF THAT REPAIR WORK IS SIGNIFICANT 7 BECAUSE YOU DON'T KNOW HOW LONG iT'S BEEN IN DISREPAlR 4

8 AND YOU DON'T KNOW HOW MUCH SALT HAS BEEN GETTING OUT 9 PAST THE DRIFT ELIMINATORS UP UNTIL THAT TIME.

10 MR. WILBER: I WOULD SAY FOR THIS PARTICULAR 9

11 DRIFT ELIMINATOR WHICH, BY THE WAY, HAVE YOU SEEN THE 12 DRIFT El.lMINATOR, PUT YOUR HANDS ON IT TO GET A FEELING c

{) 13 14 FOR THE RIGIDITY?

JUDGE COLE: I HAV'E NOT, S I R, BUT AS A CIVIL 15 ENGINEER, i ALWAYS LIKE TO DO THINGS LIKE THAT.

16 MR. WILBER: OKAY. I WAS IMPRESSED -- BECAUSE 17 i HAVEN'T SEEN THIS DRIFT ELIMINATOR AT THAT MANY SITES --

18 WITH THE STRUCTURAL RIGIDITY OF THE ELIMINATOR. IT'S 19 THE KIND OF THING THAT YOU COULD WALK ON IF YOU WANTED 20 TO AND PROBABLY NOT INCUR MUCH DAMAGE ON THE DRIFT 21 ELIMINATOR SURFACE ITSELF. I WOULD SAY IN THIS CASE 22 THAT PROBABLY AN ANNUAL INSPECTION WOULD BE SUFFICIENT.

23 OBVIOUSLY SOME EMPIRICAL DATA AT THIS SITE WHERE A 24 PERSON MIGHT GO ON A MORE FREQUENT BASIS FOR THE FIRST 25 YEAR OR TWO, AN EMPIRICAL APPROACH WOULD BE A WISE ONE l ~ :: = = e -

==

TELEPHONE 2794711 F

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I 2989 1 BUT I WOULD S AY ANNU ALLY WO!!LD BE SUFFICIENT.

2 JUDGE COLE: ALL RIGHT, SIR. THANK YOU.

O 3 Ta^T's HeLeFU'-

g 4 ANOTHER CRITICISM OF THE STUDY WAS THAT 5 IT WAS A LIMITED SET 0" TEST CONDITIONS, FOUR DAYS IN 6 MAY WITH A CERTAIN WIND CONDITION, A CERTAIN 7 TEMPERATURE, THE OPERATING TEMPERATURE OF THE TEST WAS 8 WASN'T UNDER A HOT, FUNCTIONING CONDITION. IT WAS 9 AMBIENT I GUESS IT WAS. THE CIRCULATING WATER QUALITY 10 WAS SIGNIFICANTLY DlFFERENT FROM THE CIRCULATING WATER 11 QUALITY THAT WE WOULD EXPECT DURING THE ACTUAL 12 OPERATION. HOW DOES THIS AFFECT THE RESULTS AND HOW WE 13 MIGHT APPLY THE RESULTS TO THE REAL WORLD?

9O 14 MR. WILBER: LET ME EXPLAIN FIRST THE 15 GENERATION, IF YOU WILL, OF DRIFT AND ENTRAINMENT OF 16 DRIFT INTO THE EXIT AIR AND THEN WE'LL TALK ABOUT EACH 17 0F-THESE PARAMETERS THAT YOU BROUGHT UP AND SEE WHAT 18 .EFFECT THEY MIGHT HAVE IN MY OPINION.

19 JUDGE COLE: FINE. I 20 MR. WILBER: WHEN THE WATER IS CIRCULATED IN 21 THE COOLING TOWER, IT'S PUMPED UP TO THE HOT WATER 22 DISTRIBUTION BASIS ON THIS CROSSFLOW COOLING TOWER, 23 CROSSFLOW MEANING THAT THE WATER DROPS VERTICALLY AND 1O 24 THE AIR COMES FROM THE SIDE. THEREFORE, THE AIR AND l

25 WATER PATH ARE PERPENDICULAR TO EACH OTHER, THAT THEREBY

= =:. -

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TELEPHONE 279 4711 h^

i 2990 1 THE CROSSFLOW TERMINOLOGY. IN THE PROCESS OF THE WATER 2 COMING FROM THE HOT WATER DISTRIBUTION BASIN TRICKLING

() 3 DOWN THROUGH THE FILL, THERE'S MECHANICAL BREAKUP OF THE 4 NATER, WHICH IS INTENTIONAL, THE OBJECT BEING TO SUSPEND 5 THOSE DROPLETS IN THE AIR AS LONG AS POSSIBLE. IN 6 EFFECT, HEAT AND MASS TRANSFER ON THOSE DROPLETS AND IN 7 THIS SAME PROCESS AIR IS ENTRAINED BY THE FANS, COMES 8 THROUGH THE FILL SECTION AND IT PICKS UP THESE DROPLETS 9 AND IT CARRIES SOME OF THE DROPLETS TOWARD THE DRIFT 10 ELIMINATORS.

9 11 NOW, THERE'S A SPACE BETWEEN THE FILL 12 SECTION AND.THE DRIFT ELIMINATORS THAT VARIES AS A 13 FUNCTION OF HEIGHT, SO SOME OF THESE DROPLETS MAY FALL

[

14 ,OUT GRAYlTATIONALLY BEFORE THEY REACH THE DRIFT 15 ELIMINATOR SURFACE. THOSE THAT CONTINUE ON IN THE AIR 16 PATH-lMPlNGE -- IN MANY CASES IMPINGE ON THE DRIFT 17 ELIMINATORS AND SOME OF THOSE DROPLETS MAY GET PAST THE 18 DRIFT ELIMINATOR SURFACE. THE PURPOSE OF THE DRIFT 19 ELIMINATORS IS TO REDUCE THAT DROPLET POPULATION AS IT'S 20 PRESENTED TO THE DRIFT ELIMINATORS TO REDUCE IT FROM THE 21 UPSTREAM TO THE DOWNSTREAM OBVIOUSLY OF THE DRIFT 22 ELIMINATORS.

23 JUDGE COLE: AND THE PRINCIPAL MECHANISM OF 24 REMOVAL IS?

25 MR. WILBER: INERTIAL IMPACTION. SO YOU

    • "EEu^nYnI"PSEEEs' "** o
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)

2991 1 CHANGE THE DIRECTION OF THE AIR AND YOU HOPE THAT THE I-2 INERTIA 0F THE DROPLETS CARRIES IT TOWARD THE SURFACE

() 3 AND IT IMPINTES AND IT'S DRAINED OFF AND ULTIMATELY GOES 4 BACK TO THE COLD WATER BASIN. SOME PORTION OF THOSE l

)

5 DROPLETS CONTINUE. THOSE DROPLETS THEN WOULD BE -- IN 6 SOME CASES IF THEY ARE LARGE ENOUGH WHEN THEY GET INTO 7 THE PLENUM, THAT IS THE CENTRAL AREA BELOW THE FANS, 1

8 SOME OF THEM MAY DROP GRAYITATIONALLY BACK INTO THE 9 6ASIN. OTHERS ARE CARRIED THROUGH THE FANS AND 10 EXHAUSTED AT THE FAN STACK EXIT POINT AS PART OF THE

)

11 PLUME.

12 NOW THAT l'VE EXPLAINED THOSE MECHANISMS, 13 LET'S LOOK AT SOME OF THE PARAMETERS THAT YOU ADDRESS

),

14' THERE AND SEE HOW THEY MIGHT AFFECT DRIFT. LET'S LOOK 15 AT THE FIRST AND EASY ONE FIRST, FROM SOME POINTS OF

, 16 VIEW EASY BECAUSE IT WAS BROUGHT UP IN DR..SAMWORTH'S

?

17 TESTIMONY, AND THAT IS THE EFFECT OF WIND SPEED. WE 18 TESTED -- WE ENJOYED QUITE A WIDE RANGE OF WIND SPEEDS 19' DURING OUR TESTS AND I DON'T THINK THAT WAS A 20 SHORTCOMING OF OUR STUDY. THE WINDS WERE FROM ALMOST 21 CALM CONDITIONS IN THE FIVE TO TEN MILES AN HOUR UP TO 22 THE PolNT-THAT OUR OWN METEOROLOGICAL TOWER WAS BLOWN 23 OVER AND I THINK THE WINDS EXCEEDED 45 MILES AN HOUR 24 DURING THAT TIME. THE CONCLUSION DRAWN BY DR. SAMWORTH 25 WAS THAT IF ANYTHING, THERE WAS A REDUCTION IN DRIFT

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l 2992

, -1 WITH INCREASING WIND SPEED.

2 JUDGE COLE: THE DATA SHOWED THAT. WHETHER 4

' () 3 THERE.WAS A RELATION IS SOMETHING ELSE.

4 MR. WILBER: THE DATA SHOWS THAT FOR A GOOD 5 REASON. I THINK THE CELL DURING THAT HIGH WIND SPEED 6 DAY THAT WE TESTED WAS CELL N, THE CENTER CELL. IF YOU 7 LOOK AT THE HORSEPOWER DATA ON CELL N AND THE HORSEPOWER 8 BEING AN INDICATION OF WHAT KIND OF AIR FLOW WAS GOING 9 THROUGH THAT, THE CENTER CELL WAS PURPOSELY SET BY THE 10 VENDOR -- THE FAN PITCH IS PURPOSELY SET LOWER FOR 11 AERODYNAMIC REASONS. IT PERFORMS MORE UNIFORMITY IN AIR 12 FLOW IN THE PLENUM AREA AND IT'S THEIR DES IGN TO H AVE A 13 LOWER VELOCITY IN THE CENTER CELL.

14 BEYOND IT BEING A LOWER VELOCITY, IT IS 15 THE FARTHEST ONE AWAY FROM THE DRIFT ELIMINATORS BECAUSE 16 IT'S IN THE CENTER. THEREFORE, DROPLETS THAT MAY SETTLE 17 OUT GRAYITATIONALLY OR IN A SITUATION WHERE THE FANS 18 COMPETE FOR AIR AND SOME OF THE FANS ON THE UPSTREAM AIR 19 PATH ENTRAIN THE DRIFT DROPLETS WHERE THEY GET TO THE 20 CENTER CELL, CELL N, I WOULD SUGGEST THAT FOR THOSE i

21 REASONS WHICH ARE GOOD ONES, THAT CELL N MAY NOT HAVE AS 22 MUCH DRIFT AND INDEED THAT'S WHAT WE SAW I THINK IT WAS gs 23 LESS THAN HALF OF THE DRIFT THAT WE SAW IN THE PEAK

[

24 MEASUREMENTS ON CELLS P OR K.

25 I WOULD THINK, IF ANYTHING, THAT IF THE 4

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4 2993 1 WINDS WERE EXTREMELY HIGH, THERE MIGHT BE A LITTLE 2 HIGHER DRIFT BECAUSE THE WINDS WOUL"D TEND TO BLOW AIR AT

. () 3 A HIGHER VELOCITY THROUGH THE DRIFT ELIMINATORS AND 4 _THEREBY MAYBE REENTRAINING SOME OF THOSE DROPLETS; BUT I

)

5 THINK IT'S IMPORTANT TO NOTE OVER THE RANGE OF WIND 6 SPEEDS THAT WE MEASURED IN THAT DRIFT SEEMED TO BE 7 FAIRLY CONSTANT AS DRIFT GOES.

8 JUDGE COLE: ALL RIGHT, SIR. WHAT'S THE RANGE 9 0F AVERAGE VELOCITY THROUGH EACH OF THESE CELLS? DO YOU 10 KNOW?

0 11 MR. WILBER: THE VELOCITY AT THE EXIT PLANE 12 WOULD BE AND I WOULD HAVE TO REFER TO THE DATA TO BE

-s 13 EXACT BUT IT MAY RANGE ON THE ORDER OF FlVE TO TEN 0:

14 METERS PER SECOND. OVER THE FAN HUB IT MAY ACTUALLY BE 15 ZERO OR NEGATIVE.

16 JUDGE COLE: AND THE DIFFERENCE BETWEEN, SAY, 17 ONE OF THE OUTER CELLS AND THE INNER CELL --

18 MR. WILBER: LET ME BACK UP. EXCUSE ME. WAS 19 YOUR QUESTION THE RANGE FROM CELL TO CELL OR WITHIN A 9

20 CELL WHAT KIND OF VELOCITIES CAN YOU GET?

21 JUDGE COLE: WELL, IT'S ACTUALLY BOTH. I 22 WANTED TO GET A BETTER FEEL FOR THE PHYSICAL RANGE OF 23 VELOCITY.

24 MR. WILBER: MOST OF THE CELLS WITH THE 25 EXCEPTION OF CELL N WOULD HAVE A SIMILAR VOLUMETRIC AIR p

    • "EEu^n"r n$"PSEEn's' " 'N#o$!CSIio*u"S a$o#14 TELEPHONE 279-4711

)

l l

2994 l l

l 1 FLOW GOING THROUGH THEM -- AND l'M SORRY IF I l 2 MISINTERPRETED YOUR QUESTION BEFORE. I THOUGHT YOUR l

() 3 QUESTION WAS WHAT KIND OF RANGE MAY YOU SEE AT THE EXIT 4- PLANE IN AIR FLOWS AND IT VARIES. THERE'S A BIMODAL 1 5 PROFILE OVER.THE FAN AS YOU WOULD EXPECT DOWNSTREAM OF 6 THE FAN AND THE FIVE TO TEN METERS PER SECOND THAT I 7 REFERRED TO WAS AN EXCURSION OF EXIT PLANE YELOCITIES 8 THAT YOU MIGHT SEE.

9 JUDGE COLE: I GUESS I DON'T UNDERSTAND YOUR 10 ANSWER, SIR. WE'VE GOT DIFFERENT CELLS. FOR EXAMPLE, 11 CELL I, IT'S A CERTAIN AREA AND THERE'S A HUB 0F A FAN 12 AND-THERE ARE SOME BLADES AND IT'S PUSHING AIR UP 13 THROUGH A CERTAIN SECTION, A CERTAIN CIRCULAR SECTION.

14 MR. WILBER: M' HUM.

15 JUDGE COLE: WHAT'S THE RANGE OF AIR VELOCITY 16 IN THAT SECTION? IS THAT THE FIVE TO TEN METERS PER 17 SECOND?

18 MR. WILBER: THAT'S RIGHT, THE SECTION BEING 19 THE FAN STACK IN WHICH THE FAN RESIDES WHERE WE MEASURED 20 AT THE FAN EXIT PLANE, THERE'S A BIMODAL PROFILE AND-21 THAT MAY BE ON THE ORDER OF FIVE TO TEN METERS PER 22 SECOND. FIVE AT THE LOWER POINTS AND THEN TEN AND THEN L

23 DOWN TO ZERO WHERE THE FAN HUB AND THEN THE SAME PATTERN O 24 EXISTS ON THE OTHER SIDE.

25 JUDGE COLE: NOW, IN N IT MIGHT BE HALF THAT?

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p o$!>*c*dIio*E2's$o*1 TELEPHONE 279 4711 i

i 2995 1 MR. WILBER: IN N BECAUSE AIR FLOW GOES AS THE 2 CUBE ROOT OF THE HORSEPOWER, IT WOULD BE LESS BUT IT

() 3 CERTAINLY WOULD BE AS LOW AS HALF.

4 JUDGE COLE: OKAY. THANK YOU.

i 5 DR. SAMWORTH:, IF YOU WOULD LIKE TO 6 COMMENT ON ANY OF THIS, THIS MIGHT BE AN APPROPRIATE 7 TIME IN THE RECORD IF YOU HAPPEN TO AGREE OR DISAGREE 8 WITH ANYTHING-THAT MR. WILBER SAYS. I THINK THAT'S ONE l

9 0F THE ADVANTAGES OF HAVING ALL OF THESE EXPERTS ON THE 10 STAND AT ONE TIME.

i 11 DR. SAMWORTH: LET ME JUST CLARIFY WHERE l'M 12 COMING FROM ALSO BECAUSE I DON'T REALLY THINK THAT WHAT 13 i HAVE OFFERED UP HAS BEEN IN THE SPIRIT OF CRITICISM.

),

14 I THINK WE LOOKED AT THE STU'DY WHEN IT CAME IN BACK IN 15 LATE '83 OR EARLY '84, i FORGET EXACTLY WHEN IT WAS, AND 16 LOOKED AT IT FIRST WITH THE YIEWPOINT OF HOW IT RELATED F

17 TO WHAT WE HAD DONE IN YOUR ENVIRONMENTAL REYIEW WITH 18 REGARD TO USING .0044 PERCENT AS THE FIGURE FOR 19 ESTIMATING WIDTH AND DEPOSITION.

). :

20 THE OTHER' QUESTION ALSO CAME UP, WELL, 21 CAN YOU SET A NEW DRIFT RATE BASED ON THESE STUDY 22 RESULTS? I ESSENTIALLY SAID, GEE, THERE ARE SEVERAL 23 THINGS THAT I WOULD LIKE TO KNOW BEFORE I ATTEMPT TO 00 0 24 COME UP WITH -- ESTABLISH A NEW RATE BASED ON THESE 25 RESULTS. SO WHAT l'M -- THE COMMENTS THAT I RAISED t

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TELEPHONE 279-4711 p..

2996 1 WEREN'T NECESSARILY INTENDED TO DESTROY THE VALUE OF THE 2 STUDY. I THINK IT WAS A WELL-DONE STUDY. THE PROBLEM

() 3 THAT I HAD WAS WITH MY INABILITY TO COME UP WITH A 4 NUMERICAL VALUE FOR THE DRIFT RATE FOR THOSE PARTICULAR 5 TOWERS BASED ON THESE FOUR DAYS IN MAY OF '83. SO WITH 6 THAT IN MIND, I THINK l'LL JUST MAKE ONE --

7 JUDGE COLE: HE'S SUGGESTING THAT I 8 MISCHARACTERIZED HIS --

9 DR. SAMWORTH: I DON'T REALLY THINK THAT 10 THERE'S ANYTHING TO BE GAINED FROM ME OR -- 1 JUST RAISE 11 ONE MORE POINT, HOWEVER, WITH REGARD TO WIND. I THINK 12 WE HAD TWO PROBLEMS THERE. ONE IS WHETHER WIND AFFECTS 13 THE AMOUNT OF DRIFT OR THE RATE AT WHICH DRIFT EMANATES 14 FROM THE TOWER, AND THE SECOND IS WHETHER THE WIND 15 AFFECTS THE MEASURING INSTRUMENTS. IT IS POSSIBLE EVEN 16 THOUGH THE WIND MAY OR MAY NOT HAVE AFFECTED THE AMOUNT 17 0F DRIFT COMING FROM THE TOWERS, DRIFT MAY HAVE l 18 INTERFERED WITH THE EFFORT TO MEASURE DRIFT 01 THAT l

t 19 PARTICULAR DAY IN MAY.

20 JUDGE COLE: I GUESS MY REACTION sq THE WIND, 21 l WOULD THINK A WIND OF 40 OR 45 MILES AN H0tiR MIGHT 22 HAVE SOME EFFECT ON WHAT THE PATTERN OF FLOW MIGHT BE AT 23 THE EXIT OF A COOLING TOWER, WHETHER IT BE A NATURAL

!-(Z) 24 DRAFT TOWER OR A MECHANICAL TOWER. I WAS LOOKING TOWARD l

! 25 THAT POSSIBLE EFFECT AS BEING THE ONE THAT WOULD MAKE l

l "S*!!a"r"4:: M'#" ""- '"O'C!Tita"!

l TELEPHONE 279-4711 1

b

L 2997 1 SOME DIFFERENCES AND I WOULD LIKE YOUR COMMENTS ON THAT.

2 MR. WILBER: IT DOES HAVE AN EFFECT ON THE AIR

() 3 FLOW PATTERN AND, THEREFORE, SOMEONE IN THE DROPLET SIZE 4 DISTRIBUTION AS THE FUNCTION OF DISTANCE ACROSS THE FAN 5 STACK. AT THE FAN STACK EXIT PLANE, IF YOU HAVE HIGH 6 WINDS YOU GET THIS DOWNWASH, AND ON THE LEADING EDGE 7 YOUR AIR FLOW PROFILE TENDS TO BE SKEWED. IT TENDS TO

)

8 BE SIMILAR IN FLOW RATE AND, IN FACT, OUR EXPERIENCE TO 9 THE EXTENT YOU CAN DRAW CONCLUSIONS ON DRIFT DATA TAKEN 10 AT THE EXIT PLANE AND THE EFFECT OF WINDS AT THE EXIT 4

11 PLANE IS THAT IT DOESN'T CHANGE A LOT. IT JUST SKEWS 12 THE DISTRIBUTION. IT PUSHES IT OVER, IF YOU WILL, FROM ex 13 THE UPWIND SIDE A LITTLE BIT TO THE DOWNWIND SIDE OF THE

) b) 14 CELL.

15 JUDGE COLE: BUT YOUR EXPERIENCE INDICATES 16 THAT THE MATERIAL BALANCE IS ABOUT THE SAME?

f 17 MR. WILBER: THAT'S RIGHT.

l 18 JUDGE COLE: OKAY. DO YOU WANT TO GO TO THE 19 NEXT PARAMETER?

20 MR. WILBER: ANOTHER PARAMETER I BELlEVE YOU l

21 BROUGHT UP WAS THE AMBIENT TEMPERATURES.

22 JUDGE COLE: YES.

23- MR. WILBER: WHAT CAN AMBIENT TEMPERATURES D07 24 THEY CAN AFFECT THE AIR DENSITY AND MAYBE A LITTLE BIT 25 AIR VISCOSITY. BUT TO THE EXTENT THOSE THINGS VARY, i

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' 2998 1 DON'T SEE LOOKING AT HOW DRIFT IS GENERATED. I DON'T

)

2 SEE HOW THOSE PARTICULAR PARAMETERS CAN AFFECT THE

() 3 GENERATION OF DRIFT OR THE COLLECTION OF DRIFT TO ANY 4 EXTENT.

5 JUDGE COLE: IS THERE ANY DIFFERENCE, ANY 6 SIGNIFICANT DIFFERENCE IN THE BEHAV10R OF DRIFT AND AIR 7 CURRENTS IN A NATURAL DRAFT COOLING TOWER AS COMPARED TO 8 A MECHANICAL DRAFT COOLING TOWER UNDER SIMILAR 9 OCCASIONS?

10 MR. WILBER: IN A NATURAL DRAFT TOWER, IF YOU 11 VARY THE AMBIENT. AIR TEMPERATURES OR THE HEAT LOAD ON 12 TH,E NATURAL DRAFT TOWER, THE DRAFT, THAT IS THE AIR FLOW 13 THROUGH A NATURAL DRAFT TOWER, IS EXTREMELY SENSITIVE TO 14 BOTH OF THOSE PARAMETERS. IN THE WINTERTIME A NATURAL 15 DRAFT TOWER CAN HAVE 50 PERCENT MORE AIR FLOW, THAT IS 16 50 PERCENT HIGHER VELOCITY THAN IN THE SUMMERTIME 17 BECAUSE OF THE CHANGE IN DENSITY AND, THEREFORE, DRAFT 18 ON THE TOWER.

19 SO, YES, THOSE THINGS CAN AFFECT A 20 NATURAL DRAFT TOWER AND ITS AIR FLOW AND, THEREFORE, 21 POTENTIALLY THE AMOUNT OF DRIFT THAT'S ENTRAINED IN THE 22 EXIT AIR. IN A MECHANICAL DRAFT TOWER, HOWEVER, THE 23 VOLUMETRIC AIR FLOW IS FAIRLY CONSTANT AS A FUNCTION OF

)

f 24 TIME OF YEAR. THE MASS AIR FLOW MAY CHANGE SLIGHTLY, 25 PLUS OR MINUS 10 PERCENT, BECAUSE THE AIR DENSITY

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2999 1 CHANGES. THE AIR DENSITY MAY CHANGE BECAUSE THE AMBIENT 2 AREA TEMPERATURES ARE CHANGING AND/OR BECAUSE THE HEAT

() 3 LOAD ON THE TOWER IS CHANGING BUT THE VOLUMETRIC AIR 4 FLOW IS YIRTUALLY CONSTANT DURING THE YEAR. YOU HAVE A 5 CONSTANT PITCH ON THE FAN, A CONSTANT R.P.M. AND THE l 6 YOLUMETRIC AIR FLOW IS CONSTANT.

7 JUDGE COLE: I GUESS MY INITIAL CONCERN THERE 8 WAS CONSIDERING THAT DIFFERENCES BETWEEN A NATURAL DRAFT 9 COOLING TOWER AND A MECHANICAL DRAFT COOLING TOWER WITH 10 RESPECT TO SOME OF THE THINGS YOU JUST MENTIONED, HOW

-11 VALID ARE SOME COMPARISONS BETWEEN NATURAL DRAFT DRIFT I 12 RESULTS AND MECHANICAL DRAFT COOLING TOWERS? ARE THEY 13 JUST NOT COMPARABLE?

14 MR. WILBER: WELL, I THINK THE AIR VELOCITY --

15 FIRST OF ALL, THE MECHANICAL BREAKUP OF THE WATER IS 16 SIMILAR. THE AIR VELOCITIES THAT THE DRIFT ELIMINATOR 17 FACE ARE NOT SIGNIFICANTLY DIFFERENT BUT THE AIR 18 VELOCITIES THE DRIFT ELIMINATOR FACE ARE GOING TO VARY 19 MORE ON A NATURAL DRAFT TOWER THAN ON A MECHANICAL DRAFT

)

20 TOWER. I THINK YOU CAN COMPARE A DRIFT ELIMINATOR 21 EFFECTIVENESS IN THIS TYPE OF THING BUT YOU MAY SEE A 22 LOT MORE VARIABILITY IN A NATURAL DRAFT TOWER THAN YOU

)

23 WILL IN A MECHANICAL DRAFT TOWER. THEREFORE, IF YOU 24 PICK ONE DAY SET MAY NOT COMPARE AS WELL AS ANOTHER. I 25 THINK YOU CAN SAY THAT IN THE ORDER OF MAGNITUDE BASIS,

)

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3000 1 YOU COULD COMPARE THOSE TWO DRIFT RATES, THAT'S A 2 MECHANICAL DRAFT AND A NATURAL DRAFT TOWER.

) 3 JUDGE COLE: AT WHAT POINT WOULD YOU COMPARE 4 THEM, THOUGH? AT THE EXIT?

5 MR. WILBER: WELL, THE EXIT PLANE IS OF COURSE 6 WHERE YOU ARE WORRYING ABOUT IT. THE POINT THAT I MIGHT 7 BE INTERESTED IN COMPARE ONE VERSUS THE OTHER IS IF ONE 8 IS USING A PARTICULAR TYPE OF DRIFT ELIMINATOR AND 9 THAT'S THE ONLY PLACE THAT DRIFT ELlMINATOR IS BEING

~10 USED, 1 MAY USE THAT AS A SOURCE OF GATHERING DATA ON 11 THE EFFECTIVENESS OF THE DRIFT ELIMINATOR AND I THINK 12 YOU COULD PROJECT THAT DRIFT ELIMINATOR, ASSUMING IT'S r 13 (N THE NATURAL DRAFT TOWER, AND SAY IT MIGHT BEHAVE 14 SIMILARLY lN A MECHANICAL DRAF.T TOWER.

15 JUDGE COLE: 1 ASSUME THERE ARE DIFFERENT 16 KINDS OF DRIFT ELIMINATORS. IS THAT TRUE, SIR?

17 MR. WILBER: THAT'S TRUE.

18 JUDGE COLE: ARE THESE DRIFT ELIMINATORS 19 DESIGNED TO REMOVE CERTAIN SIZE PARTICLES? IT SEEMS TO

?

20 ME IF YOU'VE GOT A DESIGN OF A SYSTEM WITH A UNIFORM 21 FLOW THROUGH IT AS IN A FORCED DRAFT COOLING TOWER, THAT 22 THE DESIGN OF THE SYSTEM WOULD BE FOR A CERTAIN SIZE 2:3 PARTICLE AND YOU WOULD REMOVE A GOOD PORTION OF THOSE

.( }

24 AND LARGER.

25 MR. WILBER: THEY MIGHT TYPICALLY HAVE A

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~ . - . _ - - . - _ - - - . . - _ - _ - - - . , _ - - _ . _ , , . , - - . _ , , , , - - . . - -

3001 1 CUTOFF DIAMETER FROM AN INERTIAL IMPACTION STANDPOINT.

2 YOU MAY NOT COLLECT MUCH BELOW THAT. I THINK THEY ARE

() 3 DESIGNED TO MINIMlZE PRESSURE DROP AND COLLECT AS MUCH 4 WATER, AS MUCH DROPLETS AS POSSIBLE. IT'S KIND OF A 5 LABORATORY NUMERICAL TYPE THING.

6 JUDGE COLE: OKAY, I WAS JUST GOING TO SAY IT 7 SOUNDS LIKE AN EMPIRICAL DESIGN RATHER THAN A t

8 THEORETICAL DESIGN.

9 i WAS SURPRISED AT THE DIFFERENCE IN THE 10 DIAMETER OF THE 50 PERCENT MASS PARTICLE S IZE BEING t

11 ALMOST A 500 MICRONS FOR THIS PARTICULAR COOLING TOWER.

12 THAT SEEMED TO ME TO BE A FAIRLY LARGE SIZE DROP. DO 13 YOU HAVE ANY REACTION TO THAT, SIR 7 14 MR. WILBER: MECHANICAL DRAFT TOWERS AND 15 NATURAL DR AFT TOWERS CAN H AV E -- ONCE W ATER IS F

16 COLLECTED, IT CAN GET REENTRAINED. THERE CAN BE SOME 17 PHENOMENA THAT OCCUR IN THERE THAT EVEN THOUGH SOME OF l 18 THESE DROPLETS ARE COLLECTED, THEY CAN GET REENTRAINED.

19 A LOT OF THE MECHANICAL DRAFT TOWERS THAT WE'VE STUDIED F

i 20 00 HAVE FAIRLY HIGH MASS MEDIA IN DIAMETERS.

21 JUDGE COLE: ALL RIGHT, SIR. LET'S SEE.

22 WHICH ONE ARE WE ON NOW7 g- 23 MR. WILBER: IT WAS PARAMETER?

24 JUDGE COLE: YES.

25 MR. WILBER: 1 THINK WE MIGHT HAVE GLOSSED

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i 3002 1 OVER HEIGHT LOAD. I THINK I COVERED THAT IN THE AMBIENT 2 AIR TEMPERATURE.

() 3 JUDGE COLE: NOW, WHAT ABOUT --

. 4 MR. WILBER: WATER CHEMISTRY?

?

5 JUDGE COLE: NO. THE WATER TEMPERATURE. WE 6 WERE TALKING ABOUT THE AIR TEMPERATURE BEFORE. DlD YOU 7 INCLUDE THE NON-DIFFERENCE IN THE WATER TEMPERATURE AS A 8 CONSIDERATION?

9 MR. WILBER: IN OUR STUDY?

10 JUDGE COLE: IN WHAT YOU JUST RESPONDED TO.

?

.11 MR. WILBER: NO, I DIDN'T. ONCE AGAIN, i 12 DON'T SEE ANY BIG EFFECT. I CAN'T CONJURE ONE UP. IT 13 WOULD INDICATE A SIGNIFICANT DIF.FERENCE AS EQUIPLIBRIUM

[}

14 GOES UP AND DOWN OF THE PLANT AND, THEREFORE, THE ,

15 COOLING TOWER.

16 JUDGE COLE: SO YOU WOULD EXPECT THE RESULTS 9

17 TO BE SIMILAR EVEN IF THEY WERE OPERATING AT A 30-DEGREE 18 TEMPERATURE DIFFERENTIAL ACROSS THE TOWER?

19 MR. WILBER: 1 THINK S0.

20 JUDGE COLE: DO YOU KNOW THAT, SIR, OR DO YOU 21 JUST --

22 MR. WILBER: THAT'S MY OPINION. WE'VE TAKEN

{} 23 DATA, WINTER AND SUMMER, A NUMBER OF DIFFERENT SITES. I 24 THINK WITH THE EXCEPTION OF THE CHALK POINT SITE.

25 JUDGE COLE: WHICH IS A NATURAL DRAFT TOWER?

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3003 0

1 MR. WILBER: I WAS GOING TO SAY WITH THE 2 EXCEPTION OF THAT, 1 DON'T KNOW ANY STUDIES WHERE PEOPLE

() 3 DID MEASUREMENTS FROM SUMMER TO WINTER FROM SUMMER TO 4 WINTER. THAT'S THE ONLY SOURCE OF THE DATA THAT l KNOW.

5 JUDGE COLE: THERE WOULD CERTAINLY BE A 6 DIFFERENCE WITH A NATURAL DRAFT COOLING TOWER.

7 MR. WILBER: I WOULD GUESS.

8 JUDGE COLE: SO HAVE YOU LOOKED AT THAT 9 PARAMETER IN A MECHANICAL DRAFT COOLING TOWER?

10 MR. WILBER: WE HAVE NOT MADE MEASUREMENTS ON 11 THAT. MY OPINION IS THAT l CAN'T SEE WHAT MECHANISMS, 12 WHAT PARAMETERS MIGHT CHANGE THAT WOULD ChdATE A 13 SIGNIFICANTLY DIFFERENT DRIFT IF THE WATER TEMPERATURE 14 WERE COOL YERSUS WARMER.

15 JUDGE COLE: AND YOU HAVE LOOKED AT IT OVER 16 SOME RANGE IN YOUR EXPERIENCE AND YOU'VE DISCERNED NO 17 EFFECT?

18 MR. WILBER: WE DON'T HAVE DATA THAT WOULD

. 19 CONCLUDE BEYOND A SHADOW OF A DOUBT IS THERE'S NO EFFECT

)

20 WHAT I WAS GOING TO GET TO IN THE CHALK POINT.

21 JUDGE COLE: 1 DON'T WANT YOU TO MISINTERPRET 22 MY QUESTIONS BECAUSE l'M NOT TRYING TO NIT-PICK 23 SOMETHING. l'M TRYING TO GET A FEEL FOR WHETHER THERE 24 IS ANY SIGNIFICANT EFFECT THERE. I THINK YOU'VE 25 PROVIDED THE ANSWER. IF THERE WAS A CONSIDERABLE 1

~~::==:e ~- ': = c :!a m :::

TELEPHONE 279-4711 I

3004 1 EFFECT, YOU MIGHT HAVE -- YOU SHOULD HAVE OBSERVED IT IN 2 YOUR WORK. j

() 3 MR. WILBER: THAT'S RIGHT.

4- JUDGE COLE: AND YOU DID NOT.

t 5 MR. WILBER: WE H AV E NOT, TH AT' S R IG HT.

6 JUDGE COLE: OKAY. HOW ABOUT WATER CHEMISTRY?

7 MR. WILBER: WATER CHEMISTRY, I GUESS I FEEL 1

8 THE SAME WAY ABOUT THAT AS I DO TEMPERATURE. WHERE 9 WATER CHEMISTRY AFFECTS US IS MORE IN HOW LONG DO WE 10 HAVE TO S AMPLE TO PICK UP A S IGNIFICANT AMOUNT OF 4

11 CHEMICAL CONSTITUENT SO THAT WE CAN TAKE IT BACK TO THE 12 LAB AND ANALYZE FOR IT7 I CAN'T SEE BEYOND'THE 13 SEASONING QUESTION THAT I MENTIONED THAT SEASONING MAY 14 BE ACCELERATED IF THERE'S MORE SALTS IN THE WATER. I 15 CAN'T SEE HOW A CHANGE IN THE SALT CONCENTRATION WOULD 16 MATERIALLY AFFECT THE DROPLET GENERATION AND THE l

17 DROPLETS PASSING BY THE DRIFT ELIMINATORS.

18 JUDGE COLE: ALL RIGHT, SlR. HOW ABOUT A 19 COMBINATION OF MAYBE TEMPERATURE AND WATER CHEMISTRY?

, 20 MR. WILBER: ONCE AGAIN, I CAN'T SEE ANY 21 SUBSTANTIAL CHANGE IN THE DRIFT RATE THAT MAY OCCUR. I 22 CAN'T IMAGINE IN ANY ANYWAY.

r- 23 JUDGE COLE: ALL RIGHT, SIR. DO YOU HAPPEN TO

\g/

24 KNOW HOW THE MARLEY COMPANY ARRIVED AT A DRIFT RATE OF 25 .0044?

""!aA"r*a"4='#" '"*- T'on = #32ffA'.

TELEPHONE 279-4711 1

.m . ,- e - , - - - - , , , , , , , . ~ ~ - . - . - , - - - , . . , . . , . - . . - . - . . .

3005 1 MR. WILBER: I CAN CONJECTURE AND THAT'S ALL I 2 CAN 00. THEY DO SOME LABORATORY STUDIES THEMSELVES.

() 3 THEY DO SOME FIELD TESTS. IN MY EXPERIENCE WITH THEM, 4 THEY TEND TO BE ULTRA-CONSERVATIVE ON SOMETHING LIKE 5 DRIFT. THERE'S NO REASON TO GO BELOW A GUARANTEE ON A 6 DRIFT RATE. YOU MIGHT AS'WELL THROW IN A FACTOR OF 7 CONSERVATISM, MAYBE A FACTOR OF FIVE JUST FOR SAFETY AND 8 MAKE SURE THAT YOU DON'T MISS THE DRIFT GUARANTEE. MY 9 EXPERIENCE WITH THEM, WHICH IS FAIRLY EXTENSIVE, IS THAT 10 THEY TEND TO BE CONSERVATIVE IN DRIFT SPECIFICATION.

)

11 JUDGE COLE: WHAT KlND OF A GUARANTEE IS THAT,

12 SIR?

l l 13 MR. WILBER: THE GUARANTEES THAT THEY GIVE ARE

) t 14 USUALLY EXPRESSED AS A PERCENTAGE OF THE CIRCULATING r 15 WATER FLOW POINT, THE .0044 PERCENT IS A PERCENTAGE OF 16 THE CIRCULATING WATER FLOW WHICH IS LIKE 195,000 G.P.M.,

17 SOMEWHERE IN THAT ORDER THAT WOULD LEAVE THE EXIT PLANE 18 AS LIQUID.

19 JUDGE COLE: ALL RIGHT, SIR. I'VE GOT A 20 NOTATION IN MY NOTES HERE FOR ANOTHER CROSSFLOW 21 MECHANICAL DRAFT TOWERS. ONE INDICATES A DRIFT RATE OF 22 0.12 AND ANOTHER INDICATES A DRIFT RATE OF 0.0006. l'M

)

(g 23 NOT SURE WHETHER THAT'S IN -- I'VE GOT W-8 MARKED HERE V

24 BUT l'M NOT SURE WHERE I SAW THAT.

25 MR. WILBER: 1 THINK THAT'S AN EXHIBIT TO MY

)

"" "A"r*a"At";'#"' '"*- *%C!!s??' *:

TELEPHONE 279-4711

)

4 3006 1 TESTIMONY.

-2 JUDGE COLE: ALL RIGHT, SIR. IT IS EXHIBIT I) 3 W-8 IN YOUR TESTIMONY, MR. WILBER. LOOKING AT THE TWO 4 CROSSFLOW MECHANICAL DRAFT COOLING TOWERS, ONE AT OAK 5 RIDGE AND THE OTHER AT PITTSBURG UNIT 7', PACIFIC GAS AND 6 ELECTRIC, WE'VE GOT DRIFT RATES AND ALSO DROPLET MASS 7 MEDIA DIAMETER. I ASSUME THAT'S THE 50 PERCENT MASS 8 SIZE. IS THAT STANDARD PRACTICE?

9 MR. WILBER: THAT'S CORRECT.

10 JUDGE COLE: ARE YOU FAMILlAR WITH THESE 11 COOLING TOWERS?

12 MR. WILBER: YES, 1 AM.

13 JUDGE COLE: HOW COME THERE'S SUCH A LARGE 14 DIFFERENCE BETWEEN THE CROSSFLOW MECHANICAL GRAFT TOWER 15 AT OAK RIDGE AND WHAT YOU'RE ESTIMATING AT THIS PLANT 16 AND AT WHAT YOU MEASURED AT PITTSBURG UNIT 77 17 MR. WILBER: THE OAK RIDGE GASEOUS DIFFUSION i

18 PLANT IT SAYS K-31, THAT'S THE NOTATION FOR THE COOLING

.19 TOWER, IT'S AT THE K-25 PLANT. l'M SURE YOU'VE HEARD OF 20 THAT.

21 JUDGE COLE: YES.

22 MR. WILBER: THAT TOWER WAS IN A STATE OF 23 DISREPAIR AND THE PURPOSE OF THE MEASUREMENTS THAT WE 24 MADE THERE WERE TO, AS I RECALL, ASSESS THE AMOUNT OF 25 CHROMATES WHICH WERE USED AS A WATER TREATING AGENT

""**EEu""rn*E555En*s"** ****on

" Ifc3dIio*u"2's5o*

TELEPHONE 279-4711

3007 1 LEAVING THE EXIT PLANE OF THE COOLING TOWER. IT WAS NOT 2 TO DETERMINE WHAT THE STATE OF THE ART WAS ON DRIFT.

() 3 ONCE AGAIN, THOSE WERE EXTREMELY OLD COOLING TOWERS. '

4 LARGE GAPS IN THE DRIFT ELIMINATORS AND THOSE TYPES OF 5 DRIFT RATES, .12 PERCENT, ARE CHARACTERISTIC OF A TOWER 6 THAT MAY NOT EVEN HAVE DRIFT ELIMINATORS. THAT'S HOW 7 BAD THE REPAlR WAS.

8 IN THE CASE OF PITTSBURG UNIT 7, THE DATA 9 WE ACQUIRED THERE-WERE PART OF A ELECTRIC POWER RESEARCH 10 INSTITUTE PROGRAM AND ONCE AGAIN, THE -- ANY OF THE

?

11 CELLS WAS NOT IN THAT GOOD OF A REPAIR EVEN THOUGH THE 12 TOWER WAS FAIRLY NEW. l THINK HAD THIS BEEN BETTER 13 MAINTAINED. IT MIGHT HAVE BEEN A SLIGHTLY LOWER DRIFT.

14 JUDGE COLE: ALL RIGHT, SIR. SO I UNDERSTAND 15 DIFFERENCE THERE --

16 MR. WILBER: l'M NOT SURE THAT THE PITTSBURG F

17 UNIT 7 HAD AN IDENTICAL DRIFT ELIMINATOR. IN FACT, l'M 18 PRETTY SURE IT WAS A DIFFERENT DRIFT ELIMINATOR AND YOU 19 MAY BE SEEING THE THE DIFFERENCE IN DRIFT ELIMINATOR 20 PERFORMANCE BETWEEN THE PITTSBURG UNIT 7 AND PALO VERDE 21 UNIT 1 COOLING TOWER.

22 JUDGE COLE: DID YOU ACTUALLY MEASURE THE

)

23 DRIFT RATE AT PITTSBURG UNIT 7 OR IS IT ESTIMATED?

)

24 MR. WILBER: NO. THAT'S A MEASURED VALUE.

25 JUDGE COLE: ALL OF THESE ARE MEASURED VALUES?

)

"^**aa"r"4"4 ";'#" '"*- 2!**0;?~T"'f?

TELEPHONE 2794711

)

3008 1 MR. WILBER: THESE ARE ALL MEASURED VALUES.

2 JUDGE COLE: WHAT SORT OF AN ERROR BAND WOULD

() 3 YOU PUT ON YOUR DRIFT RATE PERCENTAGE HERE?

4 MR. WILBER: PROBABLY IN THE SAME ORDER AS I

.)

5 GAYE YOU BEFORE, PLUS OR MINUS 50, THAT IS FlVE ZERO 6 PERCENT.

7 JUDGE COLE: DR. GOLDMAN, YOU MIGHT WANT TO 8 COMMENT ON THAT IF YOU SO DESIRE. IT'S GETTING PRETTY 9 CLOSE TO YOUR AREA.

10 DR. GOLDMAN: I HAVE NOTHING TO CONTRIBUTE.

4 11 JUDGE COLE: 1 BELlEVE YOU'VE ALREADY

-12 COMMENTED ON YOUR EFFORTS TO MAKE A CORRECTION FOR THE 13 SCRUBBING EFFECT OF THE AMBIENT AIR AND THE PROBLEMS

)O 14 WITH THE IS0 KINETIC SAMPLING. THE OBSERVED DIFFERENCE 15 BETWEEN THE IS0 KINETIC SAMPLING AND THE SENSITIVE PAPER 16 MEASUREMENTS WAS OF THE ORDER OF FIVE OR SIX TIMES. IS

)

17 THE ONLY EFFORT YOU MADE TO IDENTIFY THAT DISCREPANCY l

18 USING -- WAS USING MAGNESIUM AS A TRACER TO SEE IF YOU 19 COULD WASH OUT THE EFFECT7 l 20 MR. WILBER: WE LOOKED AT AT LEAST A HALF 21 DOZEN DIFFERENT ELEMENTS THAT WE WOULD -- WE HOPED WERE 22 IN THE CIRC WATER BUT NOT IN THE AMBIENT AIR. IN ALL l 23 CASES LOOKING AT THE HIGH VOLUME SAMPLE OF FILTER PAPERS 24 AND LOOKING AT THE WATER CHEMISTRY, THE ELEMENTS THAT WE 25 FOUND IN THE CIRC WATER WERE ALSO IN THE AMBIENT AIR

)

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TELEPHONE 2794711

3009 1 EXCEPT TO THE POINT WHERE WE GOT DOWN TO ELEMENTS THAT 2 WERE IN SUCH LOW CONCENTRATION OF CIRCULATING WATER THAT

) 3 WE REALLY DIDN'T PICK UP SUFFICIENT AMOUNT OF SAMPLE IN 4 THE IS0 KINETIC SAMPLIk6 TUBE TO DO AN ACCURATE CHEMICAL 5 ANALYSES.

6 SO WE EXHAUSTED THE CHEMICAL ANALYSIS 7 ASPECT TO THE POINT OF GIVING UP AND SAYING, BY GOLLY, 8 EVERYTHING IN THE AMBIENT AIR SEEMS TO BE IN THE 9 CIRCULATING WATER. IT'S NOT SURPRISING IF THE TOWER 10 DOES ACT AS A SCRUBBER TO FIND A LOT OF THINGS THAT ARE 11 IN THE AMBIENT AIR ALSO IN THE CIRCULATING WATER. IN 12 FACT, HEARING SOME OF THE COMMENTS HERE THIS MORNING 13 ABOUT THE PUTTING SODIUM AND ALL OF THESE OTHER 14 CHEMICALS ON THE PLANTS TO DEFOLIATE PLANTS, YOU'VE BEEN 15 0UT TO THE SITE l'M SURE AND KNOW ALL THE AMBIENT DUST 16 TH AT MAY BE GENERATED OUT THERE. I WOULDN'T BE 17 SURPRISED TO FIND A LOT OF THE AGRICULTURAL CHEMICALS 18 ALSO IN THE CIRCULATING WATER, TOO, IN SMALL 19 CONCENTRATIONS.

20 JUDGE COLE: YOU DID NOT MAKE ANY EFFORT TO 21 QUANTIFY THE REMOVAL OF AMBIENT AIR VIA A SCRUBBING 22 MECHANISM, DID YOU?

23 MR. WILBER: 1 DIDN'T TRY FOR VERY LONG TO 24 QUANTIFY THAT. THAT'S A ROUGH PROCESS. IF I HAD, 1 25 THINK IT WOULD BE A SUBJECT OF A LOT OF DEBATE AND

"^*"tu^a*a::='#" '"*- '!=T"E?TA!&

TELEPHONE 279-4711

) 3010

. ~1 CONFUSION AND CRITICISM. SO I TRIED TO STEER AWAY FROM 2 THAT.

() 3 JUDGE COLE: WELL, I THINK l ' LL AT L EAST 4 TEMPORARILY' LEAVE THE DRIFT SOURCE TERM AND I THINK DR.

5 CARPETNER HAS A QUESTION ON SOURCE TERM.

6 JUDGE CARPENTER: I WAS CURIOUS WITH RESPECT 7 TO THE POINT YOU WERE JUST SPEAKING TO. NORMALLLY WHEN

)

8 i THINK OF DOMESTIC WASTE WATER AS BEING DISTINCTIVE 9 FROM OTHER KIND OF WATER, ONE OF THE MOST OBY100S 10 THINGS, NOT NECESSARILY IN ARIZONA BUT ON THE EAST COAST 11 IS A REMARKABLE CONCENTRATION OF METALS LIKE ZINC AND 12 COPPER FROM PLUMBING. PARTICULARLY MANY PLACES WE HAVE 13 PLUMBERS WHO HOOK COPPER TUBES TO G ALV AN IZED PlPE. I 14 NOTICED IN YOUR REPORT, APPENDIX H, YOU blD DO SOME ZINC 15 ANALYSES AND THEY SHOW A ROUGHLY COMPARABLE 16 CONCENTRATION OF MAGNESIUM AND ZINC. I DON'T KNOW 17 ANYTH ING ABOUT AR IZON A GEOLOGY. I WOULD BE SURPRISED IF 18 THE DUST IN ARIZONA HAD EQUAL CONCENTRATIONS OF 19 MAGNESIUM AND ZINC. THAT MAY BE JUST MY IGNORANCE.

20 MR. WILBER: I BELIEVE WE FOUND CONCENTRATIONS 21 IN THE HIGH VOLUME FILTER PAPER OF ZlNC AND COPPER --

22 l'M SORRY, MAGNESIUM. IN FACT, AS I RECALL FROM OTHER 23 SITES, 1 DID FIND BACKGROUND AIR SAMPLING AT THE SUN 24 DESERT NUCLEAR PLANT WHICH THAT SITE NOT BEING THAT FAR 25 FROM PALO VERDE AND THERE WAS QUITE A BIT OF MAGNESIUM

"^"!"u^a"r"4"4WE n?"' '"*' '"'AIC#Iio*~"f.".* f TELEPHONE 279-4711 h

3011

, 1 IN THE BACKGROUND.

T 2 JUDGE CARPENTER: YES. l'M NOT SURPRISED AT

) 3 THE MAG NES IUM. l'M SURPRISED AT THE ZINC. I WAS 4 HOPEFUL THAT -- WELL, I WANT TO ASK THE QUESTION WHETHER 5 THE SAMPLE BOTTLES WERE MADE OF PLASTIC OR GLASS.

6 MR. WILBER: THE S AMPLE BOTTLES WERE MADE OF 7 PLASTIC. POLYETHYLENE OR POLYPROPYLENE, ONE OF THOSE.

8 JUDGE CARPENTER: I SEE. I WAS HOPEFUL MAYBE 9 THAT THERE HAD BEEN SOME CONTAMINATION AND ZINC WAS 10 RETRIEVABLE AS A TRACER.

11 MR. WILBER: BELIEVE ME WE LOOKED AT A LOT OF 12 THEM AND I WAS HOPEFUL THAT WE WOULD FIND ONE, TOO, BUT

. ("s 13 WE WEREN'T ABLE TO.

V '

. 14 JUDGE CARPETNER: 1 THINK YOU FORECLOSED A 15 LONG LINE OF QUESTIONING. THANK YOU.

16 i GUESS FOR THE. SAKE OF THE RECORD, IT 17 SEEMED TO ME ON READING YOUR REPORT THAT THE LOCAL 18 ENYlRONMENTS DIFFER FROM THE OTHER ENVIRONMENTS WHERE

'19 MEASUREMENTS HAVE BEEN MADE OF DRIFT FROM THE COOLING 20 TOWER IN THAT THE RELATIVE HUMIDITY IS QUITE LOW. DO 21 YOU THINK THAT THE POTENTIAL EVAPORATION OF DROPLETS 22 BETWEEN THE POINT WHERE THEY ARE GENERATED AND THE POINT

' = ~

23- WHERE THEY ARE S AMPL ED IN YOUR SAMPLING SCHEME COULD 24 HAVE PRODUCED A BlAS IN THE OBSERVED SIZE DISTRIBUTION?

25 COULD A 500 MICRON DROPL ET H AVE EV APORATED DOWN TO 200

~

~":"ar "An;':P'*-  % C ali M A '?:

TELEPHONE 279-4711

  • [

3012 1 MICRONS BY THE TIME IT WAS COLLECTED AT YOUR SAMPLE 2 STATION?

() 3' MR. WILBER: IF YOU LOOK AT OUR EXIT 4 PSYCHOMETRIC MEASUREMENTS, THE AIR IS NOT SATURATED BUT 5 IT'SLPRETTY CLOSE TO BEING SATURATED AND I DON'T THINK 6 YOU'RE GOING TO GET A SIGNIFICANT AMOUNT OF EVAPORATION 7 ON THE DOWNSTREAM SIDE OF THE DRIFT ELIMINATORS TO THE 8 EXIT PLANE. SO THOSE DROPLETS THAT PASS THE DRIFT 9 ELIMINATORS I DON'T THINK EXPERIENCE A SIGNIFICANT 10 AMOUNT OF EVAPORATION FROM THE DRIFT ELIMINATOR EXIT 11 PLANE, IF YOU WILL, TO THE EXIT PLANE OF THE COOLING 12 TOWER.

13 JUDGE CARPENTER: BUT HOW ABOUT FROM THE PLANE

{

14 0F GENERATION TO THE PLANE OF THE DRIFT ELIMINATOR?

15 MR. WILBER: THERE IS NO SINGLE PLANE OF 16 GENERATION BUT NO MATTER WHAT THE HUMIDITY IS IN -- THAT h 17 EXISTS IN THE ENVIRONMENT OF THE COOLING TOWER, THERE IS l

L 18 EVAPORATION OCCURRING. WHETHER IT'S 100 PERCENT 19 HUMIDITY BECAUSE THE HEAT IS GIVEN OFF AND IT DRIVES THE

)

i 20 HUMIDITY DOWN IN THE FILL TEMPORARILY AND THEN THERE'S l

21 MORE HEAT AND MASS TRANSFER THAT OCCURS, THERE HAS TO BE 22 SIGNIFICANT EVAPORATION NO MATTER WHAT THE AMBIENT 23 HUMIDITY.

24 ALSO LET ME PolNT OUT THAT A LOT OF OUR 25 OTHER MEASUREMENTS, EVEN THOSE AT PITTSBURG, CALIFORNIA,

""**EEu^"r n*EP5EEn's' ' '"*' 'N'o"S*$n*Iio*NYs'o*14 TELEPHONE 279-4711 Y=

3013 ,

l i

1 ALTHOUGH IT'S NOT THE DESERT SOUTHWEST, IT WAS A FAIRLY 2 DRY REGION, AL SO AT THE GE ISERS, WE GOT SOME FAIRLY DRY

. k 3 CONDITIONS FOR OUR DRIFT MEASUREMENTS AND i DIDN'T SEE 4 ANY SIGNIFICANT DIFFERENCE IN THE DROPLET POPULATION OR 5 NOTE ANY BIAS AS A RESULT OF A CHANGE IN HUMIDITY IN THE 6 AMBIENT AIR. IF YOU COULD EXPLAIN WHAT MECHANISMS YOU 7 THINK ARE GOING ON, OBVIOUSLY DROPLET EVAPORATION IS

{

8 OCCURRING NO MATTER WHAT THE HUMIDITY. IS THERE 9 SOMETHING, SOME SUBSET OF THAT OR SOMETHING THAT l'M 10 MISSING IN YOUR QUESTION?

11 JUDGE CARPENTER: WELL, LOOKING AT THE IT FROM 12 AN EMPIRlCAL P0 INT OF VIEW, HAVE YOU EVER SIMPLY

{) 13 14 COLLECTED THESE DROPLETS IN SOME SORT OF IMPACTOR AND MEASURED THE BULK SALT CONTENT OF THE DROPLETS THAT WAS-15 LEAVING THE TOWER VIS-A-VIS THE PARENT WATER'S SALT t

16 CONTENT 7 t

17 MR. WILBER: TO MY KNOWLEDGE, WE H AVE NOT DONE 18 MUCH ALONG THAT LINE. THE BULK WATER THAT YOU'RE 19 COLLECTlyGj IS PROBABLY GOING TO BE SLIGHTLY HIGHER THAN 20 THE ENTERING WATER CHEMICAL CONCENTRATION. OBVIOUSLY IN 21 A COOLING SYSTEM ON A GROSS SENSE AS YOU HAVE 22 EVAPORATION AND EVAPORATION MAY BE -- THE EVAPORATIVE

)-

{) 23 24 WATER LOSS MAY BE TWO OR TWO AND A HALF PERCENT OF THE CIRCULATING WATER FLOW. YOU'RE G0 LNG TO HAVE AN 25 ATTENDANT INCREASE IN CHEMICAL CONCENTRATION. IT'S HARD L

"^**EEu^" 4"p5EE'Es' ' '"*' ****o "d*!"!Iio*Efs*o*i!

TELEPHONE 279-4711

{ 3014 1 TO ISOLATE EACH LITTLE DROPLET AND, HEY, HERE'S WHAT'S 2 GOING ON.

() 3 ON A GROSS SENSE YOU WOULD HAVE PERHAPS 4 AN INCREASE OF TWO OR THREE PERCENT IN THE CHEMICAL 5 CENCENTRATION OF THE AVERAGE DROPLETS FROM THE TOP TO 6 THE BOTTOM BECAUSE TWO OR THREE PERCENT OF THE 7 CIRCULATING WATER IS LO3T AS VAPOR.

8 JUDGE CARPENTER: WE HOPE TO LOOK AT THESE 9 TOWERS TOMORROW. l'M STILL -- l'VE SPENT SOME TIME 10 INSIDE NATURAL DRAFT TOWERS BUT l'YE NEVER SEEN THESE 11 PARTICULAR CROSSFLOW TOWERS. I WAS YISUALIZING THE 12 DROPLETS PRIMARILY BEING GENERATED AS THE WATER TUMBLES 13 FROM DOWN THE FACE OF THE OUTER PERIMETER OF THE TOWER.

14 IS THAT CORRECT?

15 MR. WILBER: DROPLETS ARE GENERATED THROUGHOUT 16 THE FILL AND IF YOU REFER TO MY EXHIBIT -- I THINK IT'S 17 W-4 0R 5 -- W-4 WHICH, BY THE WAY, IS A MARLEY DRAWING 18 THAT WE MODIFIED AND SO IT IS A FAIRLY ACCURATE 19 DEPICTION OF THE COOLING TOWER CROSS-SECTION. IF YOU 20 START ON THE TOP LEFT THERE OF THE FILL SECTION AND IF 21 YOU DON'T MIND ME POINTING FROM HERE, I THINK YOU CAN 22 SEE THE WATER FLOW PATH. DROPLETS ARE GENERATED

- r's 23 ANYWHERE WITHIN THIS FILL SECTION AND WHETHER OR NOT

\_/

24 THEY MAKE IT DOWN TO THE BOTTOM, WHICH IS THE COLD WATER 25 BASIN, OR WHETHER OR NOT SOME ARE ENTRAINED IN THE AIR l

"*"EEu^n"r aS"EEE'n's' "' ** o"idC0Ii'o*u"5's5o't TELEPHONE 2794711

)

3015 )

I 1 THAT'S MOVING FROM LEFT TO RIGHT AS YOU LOOK AT THAT b

2 DRAWING, IT'S HARD TO TELL WHERE THE ORIG IN OF EACH

() 3 INDIVl DUAL DROPL ET IS AND, THEREFORE, WHAT ITS ULTIMATE 4 FATE IS.

f 5 JUDGE CARPENTER: LET ME ASK MY QUESTION IN 6 THE INVERSE. WHY DON'T YOU THINK THERE WOULD BE 7 EV APORATION OF THE DROPL ETS ONCE THEY LEAVE THE BULK OF i -

8 THE FLUID?

9 MR. WILBER: 1 NEVER SAID THERE WASN'T 10 EVAPORATION OF THE DROPLETS. WHEN YOU SAY THE BULK OF i

11 THE FLUID, ARE YOU REFERRlNG TO THE AIR --

12 JUDGE CARPENTER: 1 PRESUME THERE'S A FILM OF 13 WATER TUMBLIN,G DOWN THROUGH THE FILM.

14 MR WILBER: THIS IS A. SPLASH-TYP,E FILL AND NOT 15 A FILM PACK YOU MAY HAVE SEEN IN A NATURAL DRAFT 16 COUNTERFLOW TOWER. l'M SURE THERE ARE SOME FILMS OF

)

17 WATER ON SOME OF THE FILL SURFACES BUT PRIMARILY THERE'S 18 A MECHANICAL BREAKUP IN GENERATION OF DROPLETS THAT 19 CASCADE DOWN THROUGH THE FILL.

20 JUDGE CARPENTER: AND THEY KEEP IMPACTING THE 21 FILL AND REGENERATING DROPL ETS AND --

22 MR. WILBER: YES, SIR.

p

23 JUDGE CARPENTER
-- SOME OF THOSE DROPLETS

)

24 ARE ENTRAINED IN GAS FLOW AND THE MOVEMENT AND DIRECTION 25 0F THE DRIFT ELIMINATORS. l'M ASKING THE QUESTION WHY

"^**Eu^4"4"4EE'n's'"* '"*' -

'"*"d*

o EIio'u"f.'s'if TELEPHONE 279-4711

3016 1 .YOU DON'T TH INK THOSE DROPL ETS W ILL SUFFER EVAPORATION?

2 MR. WILBER: THEY D0.

() 3 JUDGE CARPENTER: THEN PERHAPS THE SALINITY OF

'4 THOSE DROPLETS IS DIFFERENT THAN THE SALINITY OF THE 5 PARENT WATER.

6 MR. WILBER: I WOULD SUGGEST THAT IT IS BUT I 7 WOULD SUGGEST ON A BULK SENSE, i THINK THE MEASUREMENT 8 YOU WERE TALKING ABOUT DOING IS COLLECTING SOME OF THAT; 9 THAT ON THE BULK SENSE FROM THE TOP TO THE BOTTOM IF YOU 10 COLLECTED THESE DROPL ETS AT THE BOTTOM OR COLLECTED THEM 11 AT THE DRIFT ELIMINATOR FACE, YOU WOULD SEE A FEW 12 PERCENT ON THE BULK SENSE INCREASE IN CHEMICAL

. 13 CONCENTRATION. l'M SURE THERE WOULD BE A GRADIENT IN

)

14 THOSE DROPL ETS. '

15 JUDGE CARPENTER: NO. I MEANT THE FAN EXIT.

16 THAT'S THE POINT l'M INTERESTED IN. AFTER THEY HAVE 17 GONE THROUGH THE ORIFT EL IMINATOR AND THEY ARE STILL i

18 PASSING THROUGH UNDERSATURATED -- l'M SORRY. THEY ARE 19 IN AN ENVIRONMENT OF UNDERSATURATED AIR, PERHAPS IT IS 20 SMALL. I JUST WAS CURIOUS AS TO HOW YOU KNEW IT WAS 21 SMALL.

l 22 MR. WILBER: 1 AGREE WITH YOU. THERE"IS STILL 23 EVAPORATION OCCURRING BUT YOU MENTIONED THE DRY

(

l 24 CONDITIONS OUT HERE AND I WANTED TO ALERT YOU TO THE 25 . FACT THAT THE EXIT AIR WAS FAIRLY MOIST DURING OUR TEST I

t COURT RE R R5 P O RIZON 85014 TELEPHONE 279-4711 i.

3017 1 .AND THERE WAS EVAPORATION NO DOUBT OCCURRING IN THE F

2 DROPLETS. TO WHAT DEGREE, I DON'T KNOW QUANTITATIVELY

() 3 THE ANSWER TO TH AT QUESTION. I AGREE W ITH YOU THERE IS 4 EVAPORATION OCCURRING.

+

5 JUDGE CARPENTER: I GUESS THE BOTTOM LINE THAT 6 i WAS COMING TO IS WHETHER YOU THOUGHT THE SENSITIVE 7 PAPER COLLECTION SYSTEM MIGHT UNDERESTIMATE THE DRIFT 8 BECAUSE IT ESSENTIALLY ASSUMES THAT THE SALINITY OF THE 9 WATER THAT'S IMPACTING THE PAPER IS THE SAME AS THE 10 SALINITY OF THE PARENT WATER FROM WHICH THE DROPLETS 11 CAME.

12 MR. WILBER: IT MAY TO THE EXTENT YOU WANT TO 13 MAKE THE CALCULATION UNDERESTIMATE THE MINERAL DRIFT BUT 14 THE PARAMETER IT'S MEASURING-lS LIQUID. A STAIN IS MADE 15 ON THE PAPER, SO --

16 JUDGE CARPENTER: THAT'S PRECISELY THE POINT.

17 IT MEASURES THE LIQUID DRIFT. WHAT'S OF INTEREST IS THE 18 MINERAL DRIFT. THE IS0 KINETIC SAMPLER MEASURES THE i 19 MINERAL DRIFT.

P 20 MR. WILBER: THAT'S CORRECT. IT MAY SLIGHTLY 21 UNDERESTlMATE THAT.

22 JUDGE 'NTER: BUT YOU NEVER LOOKED TO SEE h

l 23 WHAT THE BOLK SALs..iTY OF THE DROPLETS EMERGING AT THE

[}

24 EXIT --

I 25 MR. WILBER: WE MADE ONE ATTEMPT AT THAT AND h:

i

^" '

U URY REP R5 P O t Z"O N 85014 rem-O~e n uu t

4 3018 1 TAKE THE SENSITIVE PAPER AND SUBMITTED IT TO A FAIRLY Y

I 2 SOPHISTICATED ANALYSIS TECHNIQUE AND WE WERE

() 3 UNSUCCESSFUL IN COMING UP WITH A GOOD CORRELATION IN 4 THAT AREA. SO I DON'T HAVE DATA IN THAT REGARD.

5 JUDGE CARPENTER: I WAS JUST THINKING OF 6 SOMETHING. IMPI NGEMENT S AMPL ERS MIGHT COLLECT ENOUGH 7 YOLUME.

)

8 MR. WILBER: A LOT OF THE IMPINGEMENT SAMPLERS 9 CONCENTRATE ON THAT IS CASCADE IMPACTORS AND THAT TYPE 10 0F THING CONCENTRATE ON EXTREMELY SMALL DROPLETS.

4 11 NOTHING NEAR THE MASS MEDIA AND DIAMETER OF THESE DRIFT 12 DROPLETS. FOR INSTANCE, AMBIENT CASCADE IMPACTORS BREAK

{} 13 DOWN PARTICULATE SIZE INTO SEVEN OR EIGHT MICRONS AND

, 14 DOWN TO BELOW ONE MICRON.

15 JUDGE CARPENTER: IT WOULD SEEM TO ME IT'S 16 EVEN EAS IER TO COLLECT THE B IG DROPL ETS.

17 MR. WILBER: FROM AN INERTIAL STANDPOINT, i 18 GUESS THAT MAY BE. BUT, THEN, TO SEPARATE THEM INTO 19 SIZE DISTR IBUTIONS, WE DON'T H AV E ANYTH ING TH AT' S 20 COMMERCIALLY AVAILABLE THAT DOES THAT.

21 JUDGE CARPENTER: 1 TAKE IT THE ANSWER TO THE 22 QUESTION IS THAT THERE REALLY ISN'T ANY BASIS FOR

(} 23 ESTIMATING THE DEGREE TO WHICH THE DROPLETS WHICH EXIT 24 THE TOWER HAVE SUFFERED EVAPORATION IN THE COURSE OF 25 GETTING --

)

    • "EEu^a"r nEEn's*
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)

l 3019 1 MR. WILBER: 1 DON'T HAVE A NUMBER FOR THESE 2 MEASUREMENTS THAT l CAN CONFIDENTLY ASSIGN.

() 3 JUDGE CARPENTER: THANK YOU.

4 I DID WANT TO CLARIFY ON BACK TO 5 SOMETHING DR. COLE ASKED A QUESTION ABOUT. YOU FELT THE 6 TEMPERATURE OF THE WATER WOULDN'T HAVE ANY EFFECT ON THE 7 DRIFT GENERATION EVEN THOUGH THE VISCOSITY AND SURFACE 8 TENSION ARE GOING TO VARY SUBSTANTIALLY BETWEEN THE 9 UNHEATED WATER AND THE HEATED WATER. H AV E YOU REALLY 10 EVER RUN ANY OTHER CASE WHERE THERE WASN'T ANY HEAT? I 11 CAN'T IMAGINE WHY ONE WOULD.

12 MR. WILBER: WE HAVE DONE MEASUREMENTS WITH A 13 VERY L ITTLE LOAD ON THE EQUIPMENT, VISCOSITY AND SURFACE 14 TENSION. I THINK IF YOU LOOK AT SURFACE TENSION, IT MAY - -

15 AND I WOULD HAVE TO REFER BACK TO THE EXACT WATER 16 TEMPER ATURE WE' RE TALK ING ABOUT. LET'S SAY IT'S 60 OR 17 70 DEGREES, THE CIRCULAT!NG WATER TEMPERATURE DURING OUR 18 TEST THAT IS. DURING THE OPERATION OF THE PLANT, THE

-19 WATER COMES IN AT 115 OR 120 DEGREES, l'M SPEAKING

-20 ROUGHLY, AND THERE'S A DELTA "T" BETWEEN THE HOT AND 21 COLD WATER TEMPERATURE OF MAYBE 25 DEGREES SO IT BRINGS 22 IT DOWN FROM LET'S SAY 115 DOWN TO 90. THE NOMINAL 23 WATER TEMPERATURE IN THIS MIGHT BE INSTEAD OF 60 OR 70 24 DEGREES MIGHT BE ON THE ORDER OF 100 DEGREES FOR AN 25 OPERATING TOWER. . .

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3020 1 1 DON'T THINK YOU WOULD SEE SUBSTANTIAL 2 CHANGES IN SURFACE TENSION. YOU MAY SEE A LITTLE BIT

() 3 MORE CHANGE IN VISCOSITY. ONCE AGAIN, 1 DON'T THINK THE 4 ACCURACY OF OUR MEASUREMENTS THAT WE COULD DELINEATE THE f

5 EFFECT OF WATER TEMPERATURE ON DRIFT GENERATION. IT'S 6 JUST NOT WITHIN THE ACCURACY OF THE MEASUREMENT.

7 JUDGE CARPENTER: THANK YOU. THAT'S ALL i 8 HAVE.

9 JUDGE COLE: JUST A COUPLE OF QUESTIONS, DR.

10 PENTECOST. ON PAGE FOUR OF YOUR TESTIMONY IN RESPONSE 11 TO QUESTION SIX, THE LATTER PART OF YOUR ANSWER IS A 12 CONCLUSION CONCERNING THE -- YOUR ASSESSMENT OF THE

-13 IMPACT ON AGRICULTURAL CROPS. THAT CONCLUSION IS THAT

) )

14 THERE WOULD BE NEGLIGIBLE IMPACT TO CROPS FROM SALT 15 DRIET BEYOND A FIVE-MILE RADIUS. IS IT SAFE TO ASSUME 16 TH Ai' S B ASED UPON THE ACCEPTAB IL ITY OF THE S ALT DR IFT

)-

17 MODEL AND THE SALT DISTRIBUTIONS THAT WERE PROVIDED IN 18 THE TESTIMONY OF THE ARIZONA APS?

19 DR. PENTECOST: YES. IT WAS --

20 JUDGE COLE: WHAT WAS IT BASED ON?

21 DR. PENTECOST: FIGURE 5.1-4, AS I STATED, OF 22 THE ER-OL WHICH SHOWED THE DRIFT DEPOSITION CONTOURS n\J 23 FROM THE PLANT.

24 JUDGE COLE: DO YOU RECALL WHAT THE MAXIMUM 25 SALT DEPOSITION WAS ASSOCIATED WITH THAT FIGURE? I

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TELEPHONE 279-4711 I

3021 4

1 DON'T HAVE THAT FIGURE WITH ME.

2 DR. PENTECOST: THE MAXIMUM OFF-SITE WAS IN

() 3 THE RANGE OF 10 TO 12 POUNDS. I THINK 12 POUNDS WAS I 4 ~WHAT WE PREDICTED. THE MAXIMUM FOR ANY LAND THAT IS 5 CURRENTLY UNDER AGRICULTURAL USE WAS IN THE RANGE OF 6 FIVE TO TEN POUNDS TOTAL, SOLIDS PER ACRE PER YEAR.

7 JUDGE COLE: ALL RIGHT, SIR. THANK YOU.

8 IN THE ANSWER TO QUESTION ElGHT, 9 REFERRING TO THE ACREAGE WITHIN FIVE MILES OF THE POWER 4

10 PLANT, YOU INDICATE THAT THE LAND THAT EITHER IS OR 11 COULD BE USED FOR AGRICULTURAL PRODUCTION IN THE FUTURE 12 REPRESENTS APPROXIMATELY 12.9 PERCENT OF THE LAND WITHIN 13 THE FIVE-MIL E RADIUS OF THE PL ANT.

14 -

DR. PENTECOST: THAT'S CORRECT.

15 -JUDGE COLE: WHAT IS ALL OF THE REST OF THE 16 LAND USED FOR?

17 DR. PENTECOST: WELL, IT'S MY UNDERSTANDING 18 IT'S OPEN RANGE LAND RIGHT NOW, NON -- NATIVE 19 VEGETATION. IT'S NOT UNDER CULTIVATION. A VERY SMALL 20 PERCENTAGE OF COURSE WOULD BE ROADWAYS BUT HERE YOU'RE 21 TALKING A FRACTION OF A PERCENT OR JUST A FEW PERCENT.

4 22 IT'S OPEN LAND. IT'S NOT BEING USED FOR AGRICULTURAL 23 PURPOSES.

24 JUDGE COLE: IS IT OWNED BY ANYBODY?

i 25 DR. PENTECOST: I CAN'T SAY THE OWNERSHIP,

"*"!!a"r*a"4 ";'It" '"*- '"' o%T"!Ti a'A t ',".

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_ - . _ . _ . . . _ . _ . . . _ _ _ _ . _ . . _ _ _ . _ , ..__ _ . _ , _ _ . _ . .__.._._____.-., _ _ .. , ,___.-_ ~. _._ ,_-- _ .

I 3022 l

l 1 WHETHER THERE' S ANY STATE L ANDS W ITH IN TH AT FIV E MIL ES 2 OR NOT. I KNOW A FAIR AMOUNT OF ARIZONA IS STATE-0WNED

-() 3 LAND AND FEDERALLY OWNED BUT I DON'T BELlEVE THERE'S i

4 MUCH WITHIN THAT BUT l CAN'T SAY WITH CERTAINTY.

5 JUDGE COLE: AM I CORRECT IN MY IMPRESSION 6 THAT YOU ARE REASONABLY CONFIDENT THAT THAT ROUGHLY 87 7 PERCENT OF THAT LAND WILL NOT BE BE USED FOR AGRICULTURE 8 PRINCIPALLY BECAUSE THEY DON'T HAVE ANY RIGHTS FOR 9 IRRIGATION WATER IN THAT AREA? IS THAT YOUR PRINCIPAL 10 REASON FOR --

11 DR. PENTECOST: YES. ,

12 JUDGE COLE: -- FOR STATING THAT IT WOULD NOT 13 BE USED?

tO ~

14 DR. PENTECOST: YES.

15 JUDGE COLE: ONE OF THE CHANGES THAT HAS BEEN 16 MADE IN THE MONITORING PROGRAM IS THE MEASUREMENT OF A 1

17 FOLIAR SALT DEPOSITION. IN CERTAIN OF THE TESTIMONY 18 THAT I HAVE BEFORE ME OR CERTAIN OF THE EXHIBITS THAT I 19 H AV E BEFORE ME, THEY INDICATE WHY THAT IS NO LONGER 20 PLANNED OR BEING DONE. IN VIEW OF THE FACT THAT FOLIAR 21 SALT HAS BEEN ONE OF THE ISSUES IN THIS CASE, DEPOSITION 22 FROM THE PL ANT ON THE LEAVES OF AGRICULTURAL PL ANTS, AND 23 WE'RE CEASING THE MEASUREMENT OF THAT FOR VARIOUS 24 REASONS, NOT SAYING WHETHER THEY ARE GOOD OR BAD 25 REASONS, I WOULD LIKE YOUR COMMENTS ON THAT IN VIEW OF

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3023 1 THE FACT THAT l THOUGHT THIS WAS A MAJOR ISSUE IN THE 2 CASE.

() 3 DR. PENTECOST: 1 THINK IT IS A MAJOR ISSUE 4 BUT WE FEEL THAT THERE IS SOME REDUNDANCY THERE. THE 5 DUST FALL COLLECTORS, AS I UNDERSTAND IT, RUN 6 CONTINUOUSLY FOR 30 DAYS OF COLLECTION. THE WATER IS 7 THEN ANALYZED FOR DEPOSITION, YOU COULD GET AN AERIAL 8 DEPOSITION CALCULATION FROM THAT. IN THE CASE OF THE 9 FOLlAR DEPOSITION, AS I UNDERSTAND I T, THE MEASURES WERE 10 TO BE TAKEN TWICE DURING THE GROWING SEASON AND THE DUST 11 GENERATED BY CULTIVATION. SITES NEAR AGRICULTURAL ROADS 12 WOULD TEND TO GIVE YOU AN OVERESTIMATE IF THAT HAPPENED

, 13 TO OCCUR THE DAY BEFORE YOU TOOK YOUR SAMPLE OR YOU HAD i

14 A WINDSTORM OR RAIN TO CLEANSE THE LEAVE OF DEPOSITED 15 MATERIAL, YOU WOULD l THINK BE SUBJECT TO MORE 16 VARIABILITY WITH THAT KIND OF MONITORING AND WITH USING 17 DUST FALL COLLECTORS.

18 JUDGE COLE: AND IT WOULD BE UNREASON ABLE JUST 19- TO INCREASE THE SAMPLING TO ACCOUNT FOR THAT i

20 VARIABILITY; IS THAT YOUR OPINION?

21 DR. PENTECOST: THAT'S MY OPINION, YES.

22 JUDGE COLE: OKAY. HAD YOU FINISHED YOUR I'

23 ANSWER, SIR 7 24 DR. PENTECOST: YES.

25 JUDGE COLE: WOULD YOU LIKE TO COMMENT ON

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3024 1 THAT, DRS. McCUNE, CURTIS OR FOSTER? WOULD YOU LIKE TO 2 ADD ANYTHING TO WHAT MR. PENTECOST SAID? DO YOU AGREE

() 3 OR, DISAGREE?

~

4 DR. CURTIS: WELL, THE AMOUNT OF SAMPLING TIME 5 INVOLVED WAS SMALL AND YOU NEED TO MONITOR LEAF CHANGES 6 IN TIME AND JUST -- I AGREE THAT FOLlAR LEAF EXPERIMENT

-7 PROBABLY WOULD BE DROPPED AS IT WAS CURRENTLY PLANNED 8 BECAUSE l'M NOT SURE IT WOULD HAVE LED TO ANY NEW 9 INFORMATION. DUST IS CERTAINLY A PROBLEM OUT THERE AT 10 PALO VERDE.

l 11 JUDGE COLE: WHAT WE HAVE LEFT, THEN, ARE 12 THESE SEDIMENTATION MEASUREMENTS AND ARE THEY A 13 REASON ABLE SUBSTITUTE FOR THE L EAF MEASUREMENTS ? 00 14 THEY PROVIDE US WITH THE INFORMATION THAT WE MIGHT NEED 15 TO MAKE AN ASSESSMENT OF THE AMOUNT?

16 MR. GEHR: 1 DIDN'T QUITE FOLLOW YOUR 17 QUESTION. DID YOU SAY A SUBSTITUTION FOR LEAF 18 SPECIMENS?

19 JUDGE COLE: NO. FOR THE MEASUREMENTS ON THE t

20 LEAVES. WE ARE ABANDONING ONE SERIES OF TESTS FOR GOOD 21 REASON. WE HAVE SOMETHING LEFT THAT MIGHT TAKE ITS 22 PLACE. FIRST OF ALL, DO WE H AV E SOMETH ING TH AT' S GOING 23 TO TAKE ITS PLACE THAT WILL PROVIDE US WITH THE SAME 24 KIND OF INFORMATION? SINCE I THINK IT'S BEEN TESTlFIED 25 TO THAT THAT'S A VERY IMPORTANT ASPECT OF THIS CASE, THE

"*c"L'a*a?,a;;";'#" '"' %N'"!!iJ3'?.

TELEPHONE 2794711

3025 r

1 FOLIAR LEAF DEPOSITION IS SIGNIFICANT AND DO WE HAVE 2 SOME SUBSTITUTE FOR THAT THAT WOULD MAKE THAT ASSESSMENT

() 3 EITHER DIRECTLY OR INDIRECTLY? DR. GOLDMAN?

4 DR. GOLDMAN: IF l MIGHT ANSWER, THE BOTTOM 5 LINE, IF l MIGHT PUT IT THAT WAY, IS NOT NECESSARILY THE 6 FOLIAR DEPOSITION ITSELF BUT WHAT IMPACT THAT FOLIAR 7 DEPOSITION HAS ON THE V I AB IL ITY OF THE PL ANT. HOW MUCH 8 COTTON GROWS, HOW MANY SQUARES, FLOWERS OR BOLLS DROP OR 9 DON'T DROP? TO MAKE THAT DETERMINATION BY TRYING TO i

10 SAMPLE AND ANALYZE THE DEPOSITION ON THE SURFACE OF THE 11 LEAF IS A VERY TEDIOUS AND DIFFICULT PROCESS TO GO 12 THROUGH AND ONE, AS HAS BEEN DESCRIBED, IS TO BE DONE ON 13 A VERY FREQUENT BASIS IN ORDER TO SMOOTH OUT THE

)

14 VAR' ABILITIES THAT OCCUR IN THE FIELD.

15 TO DETERMINE THE WHAT l'LL CALL THE 16 BOTTOM L INE IMPACT INSOFAR AS THE UPTAKE OF MATERIAL IS 17 CONCERNED, LEAF TISSUE ANALYSES ARE BEING PERFORMED.

18 THOSE ACT AS INTEGRATERS AS SUCH. THEY WILL ACCUMULATE 19 WHATEVER SHOWS UP IN THE PLANT AND AFFECTS THE PLANT 20 WHETHER IT'S BY FOLIAR DEPOSITION OR BY ROOT UPTAKE.

21 AND OF COURSE THE STATE OF THE CROP ITSELF IN TERMS OF 22 LEAF BURN OR OTHER PHYSIOLOGICAL EVIDENCE WILL BE 23 OBSERVED -- IS OBSERVED AT THE SAME TIME. SO THE 24 COUPLING OF THE TISSUE ANALYSES OF THE PLANTS AND THE 25 SURVEILL ANCE PLOTS AND THE DUST FALL MEASUREMENTS

"""ESu^n"r nEEn*S*" P O RIZON 85014 TELEPHONE 2794711

~, ,. . . - - - . . . -- . . . - . - -. - - - . ~ . . - . - . . . - - . . . - - - - - - . - - - - - - - . _

3026 1 THEMSELVES WHICH GIVE A PER UNIT AREA DEPOSITION 2 DENSITY, IF YOU WILL, COMBINE TO GIVE US AN INDEX OF

() 3 WHAT THE LIKELY DEGREE OF INJURY IS AND THE SOURCE OF 4 THAT INJURY, AT LEAST INSOFAR AS FOLIAR DEPOSITION IS 5 CONCERNED.

6 JUDGE COLE: AND DO THE PLANT PATHOLOGISTS 7 AGREE WITH THAT7 8 DR. McCUNE: YES.

9 DR. CURTIS: YES.

10 JUDGE COLE: DR. FOSTER, DO YOU AGREE WITH 11 THAT7 12 DR. FOSTER: OUR STUDIES BOTH IN THE FIELD AND 13 IN THE GREENHOUSE INDICATED THAT WE WERE NOT ABLE TO 14 GLEAN MUCH INFORMATION FROM LEAF WASHES IN TERMS OF 15 TRYING TO CORRELATE THAT WITH YlELD OR OTHER VISUAL 16 PLANT RESPONSES. l THINK THE MORE CRITICAL QUESTION IS 17 WHAT AMOUNT OF THIS MATERIAL IS TAKEN UP WITHIN THE 18 PLANT ITSELF AND HOW THAT MIGHT IMPACT. THOSE TISSUE 19 ANALYSES WILL CONTINUE.

20 JUDGE COLE: ALL RIGHT, SIR. THANK YOU.

21 THAT'S VERY HELPFUL.

22 DR. GOLDMAN, WITH RESPECT TO THE 23 VALIDATION OF THE NUS/ FOG COMPUTER MODEL, i BELlEVE IN 24 YOUR TESTIMONY YOU INDICATED THAT YOU HAD AN OUTSIDE 25 EXPERT REVIEW THE FOG MODEL AND COMPARE IT WITH OTHER

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3027 1 MODELS THAT WERE DEVELOPED AND THAT THE RESULTS OF THAT 2 COMPARISON INDICATED THAT IT WAS A FAVORABLE COMPARISON

() 3 BEING IN THE -- AT LEAST IN THE TOP HALF OF THOSE THAT 4 WERE TESTED. I NOTICE THAT IN THAT REFERRAL IT WAS l 5 COMPARED WITH -- THE CHALK POINT STUDY WAS REFERENCED 6 WHICH IS OF COURSE A NATURAL DRAFT COOLING TOWER, AND 7 THE CONTEXT OF DR. DUNN'S RESPONSE WAS THAT WITH RESPECT t

8 TO A COMPARISON WITH HOW IT WOULD PREDICT CHALK PolNT 9 AND THAT BEING A NATURAL DRAFT COOLING TOWER, HOW MUCH 10' EFFECT DOES THAT HAVE ON ITS APPLICABILITY TO THIS A i

11 MECHANICAL DRAFT COOLING TOWER.

12 DR. GOLDMAN: 1 THINK THE QUESTION THAT DR.

13 DUNN LOOKED AT WAS HOW THE DIFFERENT MECHANISMS THAT 14 AFFECT THE TRANSPORTED DEPOS.il0N OF DROPLETS WERE 15 HANDLED BY THE CODE. SO THE' DROPLET SIZE SPECTRUM 16 APPROPRIATE TO CHALK PolNT WAS INSERTED IN THE CODE OR

)

17 IN THAT SECTION OF THE CODE DEALING WITH DROPLET 18 SPECTRUM. THE HEIGHT OF THE RELEASE FOR WHICH THE 19 CALCULATIONS WERE MADE FOR CHALK POINT CORRESPONDED TO 20 THE HEIGHT OF THE TOWER AT CHALK POINT AND NOT THE 21 HEIGHT OF THE MECHANICAL DRAFT TOWER. THE 22 METEOROLOGICAL CONDITIONS APPROPRIATE TO CHALK PolNT AT

)

23 'THE TIME OF THESE TESTS WERE THE PARAMETERS USED TO TEST 24 THOSE SECTIONS OF THE CODE AND THE AMOUNT OF' MATERIAL 25 DEPOSITED OR PREDICTED TO BE DEPOSITED, THEN, FROM CHALK

'"c-

'"~ :a"r* 37";'#"  % f C "i*:~2'.1 %*

TELEPHONE 2794711

1 3028 l

i 1 POINT USING THE CALCULATIONAL ROUTINES.FOR WIND 2 TRANSPORT, DROPLET EVAPORATION, ET CETERA, PROVIDED A I

() 3 GOOD' COMPARISON, A REASONABLY GOOD COMPARISON WITH THE 4 EXPERIMENTAL RESULTS.

5 SO THE TESTING OF THE CODE, IF YOU WILL, 4

6 HAD TO DO WITH TESTING THOSE ROUTINES IN THE CODE THAT i

7 DEAL WITH FUNDAMENTAL PHYSICAL PARAMETERS OF THE DROPLET

(

8 ' EVAPORATION, DROPL ET TRANSPORT, DROPLET SEDIMENTATION, 9 ET CETERA, RATHER THAN DEALING WITH THE SPECIFIC 10 MECHANICS OF ONE TYPE OF TOWER OR ANOTHER.

11 JUDGE COLE: ALL RIGHT, SIR. SO IN YOUR YlEW 12 IT'S APPLICABLE --

13 DR. GOLDMAN: IN DR. DUNN'S VIEW IT WAS O 14 APPLICABLE, IT WAS. IN MY YIEW AS WELL.

15 JUDGE COLE: ONE OF THE CRITICISMS OR COMMENTS

. 16 THAT I HAVE HEARD IN THIS CASE WITH RESPECT TO THE

)

17- CHARACTERlZATION OF THE EFFECT OF DRIFT IS THAT BECAUSE 18 0F THIS PARTICULAR ENVIRONMENT, IT BEING AN ARID 19 ENVIRONMENT OF EXTREMELY LOW HUMIDITY, AT LEAST COMPARED 20 TO THE CHALK POINT ENVIRONMENT, THAT THE DRIFT DOES IN 21 FACT BEH AV E DI FFERENTLY. DOES THE NUS/ FOG COMPUTER CODE 22 TAKE THAT INTO ACCOUNT 7

)

23 DR. GOLDMAN: OH, YES. THE AMBIENT CONDITIONS 24 ARE IN FACT PART OF THE INPUT TO THE MODEL. SO, FOR 25 EXAMPLE, AT CHALK P0lNT, DR. DUNN USED THE TEMPERATURE

"^**Mf."r"a"4ll%#" '"*- '"* %'C#7d~T'A 'i.

TELEPHONE 279 4711

)

{

3029 1 AND RELATIVE HUMIDITY THAT WERE APPROPRIATE AT THE TIME

'2 0F THOSE TESTS. WHEN WE RAN THE CODE FOR THE PALO VERDE

() 3 SITE, WE USED THE TEMPERATURE AND RELATIVE HUMIDITY 4 DISTRIBUTIONS THAT ARE APPROPRIATE TO THIS SITE. THE 5 ROUTINES OR SUB-ROUTINES IN THE CODE THAT DEAL WITH THE

EVAPORATION OF THE DROPLET, THEN, ARE BASED ON THE LOCAL 7 CONDITIONS OF LOW HUMIDITY, HIGH TEMPERATURE AND AS A 8 RESULT, WE DO SEE FOR THIS SITE A DIFFERENT PATTERN IN 9 THE RELATIVE' PROP 0RTION OF THE DRY PARTICLES DEPOSITED 10 VERSUS WET PARTICLES DEPOSITED THAT WE WOULD AT A SITE t

11 IN THE EAST, FOR EXAMPLE. WE SEE MUCH MORE WET 12 DEPOSITION IN THE EAST THAN WE DO HERE.

13 JUDGE COLE: AND CAN YOU DESCRIBE AT LEAST 1

O 14 QUALITATIVELY SOME OF THE DIFFERENCES FOR A GIVEN 15 EMISSION RATE? WHAT WILL BE THE EFFECT OF THE SPREAD OF 16 THE DISTRIBUTION AS COMPARED TO, SAY, COMPARE THE 17 MARYLAND AREA WITH THIS AREA. WHAT IS THE EFFECT OF 18 THAT?

19 DR. GOLDMAN: FOR THE SAME DROPLET SIZE

+

20 D ISTR IBUTION TO BEG IN WERE YOU W ITH, IN THE EAST AND 21 MARYLAND AREA, FOR EXAMPLE, ONE WOULD SEE A CONSIDERABLY 22 GREATER PORTION OF DROPLETS DEPOSITED CLOSE TO THE TOWER

)

23 AND IN A WET STATE BECAUSE THEY WOULD NOT H AVE 24 EVAPORATED COMPARED TO THIS AREA IN WHICH THE 25 OVERWHELMING BULK OF THE DROPL ETS EXCEPT THE VERY LARGE

)

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TELEPHONE 279-4711 I

i r

3030 1 ONE, THE ROCKS YOU MIGHT SAY, THAT FALL.0UT RIGHT 2 ADJACENT TO THE TOWER. THOSE WOULD STILL BE WET, BUT

() 3 ALMOST ALL THE OTHER DROPLETS WOULD EVAPORATE BEFORE 4 THEY HIT THE GROUND AND THEY WOULD BE CARRIED TO A MUCH

-5 GREATER DISTANCE AND SPREAD OUT OVER A MUCH GREATER AREA 6 THAN THEY WOULD FOR A SIMILAR TOWER IN A MORE HUMID l 7 CLIMATE IN THE EAST.

8 JUDGE COLE: ALL RIGHT, SIR. THANK YOU.

9 THAT'S VERY HELPFUL. l'M LOOKING AT EXHIBIT G-3B AND i 10 AND EXHIBIT G-3C AND EXHIBIT G-3E, TH AT' S PAG E 54, 55 11- AND 57 0F YOUR TESTIMONY. I MIGHT HAVE PAGE 56 LOST OR 12 SOMEPLACE ELSE'AROUND HERE. I THINK IF YOU'LL LOOK AT J

13 THOSE THREE PAGES, 54, 55~AND 57 0F YOI.IR TESTIMONY -- 58

)

r 14 IF YOU WlSH.

L 15 DR. GOLDMAN: l'M SORRY, PAGE 57 IS EXHIBIT 16 G-3E, EASY?

17 JUDGE COLE: YES.

I 18 DR. GOLDMAN: OKAY.

l 19 JUDGE COLE: AND I NOTE IN READING THE FIGURE 20 TITLE, ANNUAL S ALT DEPOS ITION RATES PREDICTIONS OF THE 21 EPRI COMPUTER MODEL FOR THE 5-BIN DROP SPECTRUM AND THEN

'. 22 THE NEXT FIGURE, FIGURE 15, IS THE NUX/ FOG COMPUTER

)

j 23 PREDICTION FOR THE 10-BIN DROP SPECTRUM AND THEN THE

)

24 EPRI COMPUTER MODEL FOR THE 10-B IN SPECTRUM. I GUESS 25 WHAT STRUCK ME IS COMPAR ING FIGURE 14 AND FIGURE 15. I

)

      • "A", a"A1M'N* '"c- -

" %'C:!k',T' *>*:

TELEPHONE 279-4711 I. ,

3031 1 ASSUME THEY ARE TO THE SAME SCALE. THEY APPEAR TO BE.

2 DR. GOLDMAN: YES.

() 3 JUDGE COLE: LOOKING AT TH E L I N ES OF EQUAL 4 DEPOSITION. I ASSUME TH AT' S WHAT THEY ARE.

5 DR. GOLDMAN: YES.

-6. JUDGE COLE: THERE SEEMS TO BE A LOT MORE 7 MATERIAL DEPOSITED ON FIGURE 15 TH AN IN FIGURE 14 AND i t

8 WONDER WHETHER THE INPUT WAS DIFFERENT.

9 DR. GOLDMAN: YES, VERY MUCH THE INPUT WAS 10 .DIFFERENT. THESE ARE NOT -- IF i CAN CLARIFY THIS TO 1.

11 MAKE SURE WE UNDERSTAND. THE 5-BIN DROP SPECTRUM IS NOT 12 THE S AME SPECTRUM AS THE 10-BIN DROP SPECTRUM. IT DOES 13 NOT DIFFER ONLY IN THE NUMBER OF BINS. IF i CAN REFER 14 YOU'TO EXHIBIT G-2.

15 JUDGE COLE: ALL RIGHT, SIR.

16 DR. GOLDMAN: THE 5-BIN DROP SPECTRUM REFERRED 17 TO ON EXHIBIT G-38 IS IN FACT ON THIS FIGURE CALLED FOG 18 73. IT'S THE SPECTRUM WHICH HAS VERY FEW IF ANY VERY 19 LARGE PARTICLES.

! 20 JUDGE COLE: ALL RIGHT, SlR. BUT MY PolNT WAS 21 THAT I ASSUME -- I MADE SOME ASSUMPTIONS AS TO HOW THIS

22. SPECTRUM WAS USED. SINCE THIS IS JUST THE DROPLET 23 DIAMETER VERSUS PERCENT IN A CERTAIN DIAMETER, 1 ASSUMED O 24 THAT WHEN YOU STARTED OUT, YOU HAD A CERTAIN TOTAL 25 AMOUNT OF MATERIAL THAT YOU WERE DEPOSITING.

?

"*"="r* ant":'#" '"- ',' 2 0!"!Tita f!

TELEPHONE 279-4711

)

i 3032 1 DR. GOLDMAN: MASS EMISSION RATE FROM THE t

2 TOWER IS THE SAME. THE MASS DEPOSITION TURNED OUT NOT

() 3 TO BE THE SAME. THE REASON FOR THAT IS REFERRING BACK 4 TO EXHIBIT G-2 ABOUT THE LARGEST DIAMETER DROPLET IN 5 THAT SPECTRUM IS ABOUT SOMEWHAT UNDER 200 MICRONS IN 6 DIAMETER.

7 JUDGE COLE: ALL RIGHT, SIR.

8 DR. GOLDMAN: THOSE DROPLETS NEVER CAME B ACK 9 TO THE GROUND W ITH IN THE AREA SHOWN ON THAT FIGURE. SO 10 THERE IS MUCH LESS MASS --

4 1 ". JUDGE COLE: SO THEY ARE PROB ABLY STILL 12 FLOATING AROUND UP.THERE?

13 DR. GOLDMAN: THEY ARE STILL FLOATING AROUND.

{)

Ik AS A CONSEQUENCE, THERE IS MUCH LESS MASS PER UNIT AREA 15 OR TOTAL IN THE -- IN THIS FIGURE AS A RESULT OF THE 16 PARTICULAR SIZE DISTRIBUTION IN THAT SPECTRUM. AS

-)

17 INDICATF0 IN MY TESTIMONY, THAT WAS A DROPLET SPECTRUM 18 TH AT WE WERE G IVEN BY ANOTHER VENDOR BEFORE THE TOWERS 19 WERE SELECTED AND IT WAS USED CONSISTENTLY BUT 20 INCORRECTLY THROUGHOUT ALL OF THE APPLICATION.

21 JUDGE COLE: ALL RIGHT, SIR. I UNDERSTAND.

22 THE DIFFERENCE WAS JUST SO GREAT THAT I JUST COULD NOT ,

23 ACCOUNT FOR -- THE TOTAL MATERIALS BALANCE JUST SEEMED

)

24 TO BE SO FAR OUT OF --

25 DR. GOLDMAN: THOSE DROPLETS ARE STILL FLOWING COURT REP R RS P Q Rf50N 85014 TELEPHONE 2794711

3033 I FLOATING SOMEWHERE.

2 JUDGE COLE: ALL RIGHT, SIR.

() 3 JUDGE CARPENTER: DR. GOLDMAN, WHAT WAS THE 4 DRIFT RATE 7 WHAT WAS THE EMISSION RATE FOR EXHIBIT 5 G-3A?

6 DR. GOLDMAN: THOSE ARE AT THE MANUFACTURER'S

. 7 GUARANTEE RATE.

)

8 JUDGE CARPENTER: SO FOR ALL OF YOUR EXHIBITS 9 WHERE IT'S NOT SPECIFICALLY IDENTIFIED IN THE LEGEND AS

- 10 BEING THE THREE ZEROS TWO IS THE MANUFACTURER'S RATE?

11 DR. GOLDMAN: TWO ZEROS FOUR FOUR.

12 JUDGE CARPENTER: YOU 00 HAVE EXHIBITS --

13 DR. GOLDMAN: WHERE IT IS IDENTIFIED AND ON 14 THOSE IT IS AS IDENTIFIED THREE ZEROS TWO.

15 JUDGE CARPENTER: IN EVERY --

16 DR. GOLDMAN: IN EVERY OTHER CASE IT'S TWO 17 ZEROS FOUR FOUP.

18 JUDGE CARPENTER: THANK YOU.

19- JUDGE COLE: ON PAGE 17, DR. GOLDMAN, YOU REFER

)

20 TO THE EVAPORATION PONDS AS NOT BEING A SOURCE OF 21 WINDBLOWN DUST AND YOU PUT FORTH A CONVINCING ARGUMENT 22 THERE BASED UPON THE INPUT OF LIQUID MATERIAL TO THAT.

23 I GUESS LOOKING AT THE EVAPORATION POND AS I VISUALIZE

)

24 IT, IS IT -- HAS IT GOT FAIRLY STEEP SIDES? ARE WE 25 GOING TO GET ANY SALT BLOWING AROUND FROM THE

)

"* * "A"r*a*a;";',?*' '"** '"2'C!!d:n',*:

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1-3034 1 EVAPORATION AT THE EDGES OF THIS POND OR IS THIS GOING 4-2 TO BE TOO SMALL AN AMOUNT TO WORRY ABOUT COMPARED TO THE

() 3 TOTAL AREA?

4 DR. GOLDMAN: I WOULD SUGGEST THERE WOULD 5 PROBABLY BE SOME SALT EVAPORATED AROUND THE EDGES AND 6 SOME FRACTION OF THAT MIGHT VERY WELL BE REENTRAINED BUT 7 i WOULD TH INK TH AT THE AMOUNT WOULD BE VERY, VERY SMALL.

)

8 JUDGE COLE: 00 WE H AVE ANY INFORMATION ON THE 9 SALT DRIFT FROM FACILITIES OF THIS TYPE 7 l'M SURE THE 10 THERE ARE EV APORATION PONDS ALL OVER THE COUNTRY, 11 PARTICULARLY IN THIS PART OF THE COUNTRY THEY HAVE THEM.

12 00 YOU HAVE ANY INFORMATION AS TO --

13 DR. GOLDMAN:,

1 DON'T H AV E ANY INFORMATION ON

(

14 THAT, NO.

15 JUDGE COLE: ON THOSE PROBLEMS? OKAY, TH ANK -

16 YOU.

17 THE FIGURES YOU IDENTIFY ON PAGE 18 18 MONITORING THE DEPOSITION IN THE VICINITY OF THE PALO 19 VERDE, WHAT'S THE SOURCE OF THAT INFORMATION, SIR?

, 20 DR. GOLDMAN: THAT IS THE ONGOING -- THE SALT I

21 DRIFT MONITORING PROGRAM THAT WE ARE CONDUCTING ON 22 BEHALF OF A.M.B.P. AROUND THE PLANT. THE SOURCE

- 23 SPECIFICALLY IS THE FIRST ANNUAL REPORT THAT WAS 24 PREPARED ON THAT SALT DEPOSITION MONITORING PROGRAM.

25 JUDGE COLE: I DIDN'T SEE THAT REFERENCE THE

"** e"r*a*A'%' ,'"' '"' ** % C !!in o **.

TELEPHONE 279 4711 h

- _ m -

3035 t

1 FIRST TIME I LOOKED AT THAT. ALL RIGHT. THANK YOU.

2 MR. GEHR: IF THE BOARD -- I HAVE COPIES OF

() 3 THAT' ANNUAL REPORT. I DON'T KNOW WHETHER YOU'VE 4 RECEIVED IT OR NOT.

i 5 JUDGE COLE: 1 THINK THAT WOULD BE 6 SATISFACTORY, MR. GEHR. I J UST D I DN'T RECOGN IZE THE i 7 SOURCE ~OF THAT BUT IT WAS BECAUSE I DID NOT SEE THE 8 REFERENCE NUMBER THERE.

i

! 9 JUDGE L AZO: BUT PERHAPS MR. GEHR MIGHT 10 IDENTIFY THAT REPORT BY DATE AND TITLE.

11 MR. GEHR: YES. IT IS THE ANNUAL REPORT 12 PREPARED BY N.U.S. CORPORATION. THE TITLE IS " ANNUAL 13 REPORT FOR THE P.V.N.G.S. SALT DEPOSITION MONITORING 14 PROGRAM MAY 1983/ JUNE 1984," D ATED APRIL 1985.

15 DR. GOLDMAN: 1 MIGHT SAY THAT IS REFERENCE 22 16 0F MY TESTIMONY.

17 MR. GEHR: 1 MAY WANT TO ASK A COUPLE OF 18 QUESTIONS ABOUT THAT.

19 JUDGE COLE: GO RIGHT AHEAD.

t 20 MR. GEHR: DO YOU HAVE A COPY OF THAT REPORT 21 WITH YOU MORT 7 22 DR. GOLDMAN: YES, 1 D0.

I q 23 MR. GEHR: THIS IS BASELINE DATA TAKEN BEFORE C/

24 THE OPERATION OF ANY COOLING TOWER; IS THAT CORRECT 7 25 DR. GOLDMAN: YES, IT IS.

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3036

)

1 MR. GEHR: WOULD YOU TURN TO PAGE 516 AND 2 DISCUSS WHAT YOU FOUND AS BASELINE DATA AS THE AMOUNT OF

() -3. DUST FALL AT VARIOUS LOCATIONS, AGRICULTURAL AND 4 NONAGRICULTURAL 7

5 DR. GOLDMAN
WELL, THE -- THERE ARE SEVERAL I 6 THINK INTERESTING PIECES OF DATA THAT WERE DETERMINED i

7 OVER THIS PRE-OPERATIONAL PERIOD. IN TERMS OF THE 8 BASELINE SODIUM DUST FALL FOR SITES THAT ARE IN THE 9 DESERT BASICALLY, NOT CULTIVATED, THE -- WE HAD AN i 10 AVERAGE OF OVER SIX POUNDS PER ACRE PER YEAR OF SODIUM 11 ALONE. AT THE AGRICULTURAL SITES, THE S AME V ALUE W AS 12 ABOUT 50 PERCENT HIGHER, IT RANGES FROM ElGHT TO NINE

_ 13 POUNDS PER ACRE PER YEAR OF SODIUM ALONE AT THOSE SITES.

14 WE WOULD BE ABLE B ASED ON THE BASEL INE DATA TH AT WE HAVE 15 BEEN ABLE TO DETEC,T DEPOSITION; IN THE UNCULTIVATED, THE 16 NATIVE VEGETATION AREAS OF LESS THAN TWO AND A HALF 17 POUNDS PER YEAR OF DEPOSITION.

18 IF THE DEPOSITION IS GREATER THAN TWO AND 19 A HALF POUNDS PER YEAR OF DEPOSITION, WE CAN IDENTIFY IT 20 IN THE DESERT AREA. FOR US TO IDENTIFY IT IN THE 21 AGRICULTURAL AREAS, WE WOULD H AVE TO GO TO SOMETH ING 22 BETWEEN THREE AND A HALF AND ElGHT POUNDS PER ACRE PER 23 YEAR BEFORE WE COULD IDENTIFY IT JUST BECAUSE THE 24 BACKGROUND --

25 JUDGE COLE: 0F SODIUM 7

""*"Eo"u^nYnEpS EEs' ' * $*o"dCa*Iio'sYe"o*i TELEPHONE 2794711 f

3037 1 DR. GOLDMAN: OF SODlUM ALONE.

2 JUDGE COLE: THIS 50 PERCENT INCREASE IS

-( 3 BECAUSE OF THE INCREASED HUMAN ACTIVITY? {

4 DR. GOLDMAN: THAT IS CORRECT.

5 JUDGE COLE: STIRRING UP THE EARTH?

6 DR. GOLDMAN: YES.

7 JUDGE COLE: THANK YOU.

8 ON PAGE 10 0F YOUR TESTIMONY, DR.

9 GOLDMAN, YOU REFER TO A DEFAULT SPECTRUM.

10 DR. GOLDMAN: YES.

)

11 JUDGE COLE: WHAT SPECTRUM DID YOU EVENTUALLY 12 USE? I AM NOT SURE READING THROUGH IT.

13 DR. GOLDMAN: AS I HAD HOPED I HAD INDICATED r

{}

14 . THROUGHOUT THE FORMAL SUBMISSIONS ON BEHALF OF PALO 15 VERDE, THAT IS THE ENVIRONMENTAL REPORTS THAT WERE 16 SUBMITTED, WE USED THE SPECTRUM THAT I HAD REFERRED TO t

17 EARLlER AS THE FOG 73 SPECTRUM. WE DID NOT USE ANY 18 SPECTRUM OTHER TH AN TH AT l':lTil THIS SUBMISSION NOW IN 19 WHICH THE DATA DETERMINED BY KARL WILBER AND HIS PEOPLE 3

20 WAS USED AS THE SPECTRUM APPLICABLE TO PALO VERDE. THE 21 NEW DEFAULT SPECTRUM, WHICH IS THE FOG 81 SPECTRUM IN 22 EXHIBIT G-2, IS THAT WHICH WE NOW USE FOR THOSE COOLING 23 TOWERS FOR WHICH WE H AVE NO DATA -- THOSE MECH AN ICAL v('s 24 DRAFT TOWERS l SHOULD S AY FOR WHICH WE H AVE NO 25 EXPERIMENTAL DATA.

)

"^**=A"r*a"4f"W '"*- 20 #7d~T* *,.

TELEPHONE 279-4711

t 3038 1 JUDGE COLE: ALL RIGHT, SIR. ON EXHIBIT G-2 2 YOU H AV E WH AT' S IDENTIFIED AS PALO 'IERDE 1983. IS THAT

() 3 Tile ONE TH AT YOU USED FOR YOUR ASSESSMENTS HERE?

4 DR. GOLDMAN: THAT IS THE ONE THAT l'VE USED 5 FOR THE MOST CURRENT ASSESSMENT, YES, THAT WHICH THE 6 RESULTS ARE PRESENTED IN EXHIBITS G-4 AND G-5 THAT WERE 7 RUN USING BOTH FOG MODEL PRESENTED IN EXHIBIT G-4 AND 8 THE EPRI MODEL IN G-5 THAT WAS DONE BY DR. DUNN.

, JUDGE COLE: THAT'S THE ONE IDENTIFIED IN THE 10 16-BIN REPRESENTATION?

11 DR. GOLDMAN: THAT'S CORRECT, THAT 16-BIN 12 REPRESENTATION IS EXPLAINED IN EXHIBIT G-2.

13 JUDGE COLE: ALL RIGHT, SIR, THANK YOU.

)

14 JUDGE LAZO: 1 THINK BEFORE SWITCHING TO 15 ANOTHER SUBJECT HERE IT MIGHT BE APPROPRI ATE TO TAKE A 16 MID-AFTERNOON RECESS SO CAN WE RECESS FOR 15 MINUTES, 17 PLEASE. ,

18 MR. DEWEY: l' VE GOT A DOCUMENT I WOULD LIKE 19 TO GIVE TO THE BOARD l BROUGHT WITH ME.

t 20 Jt!OGE LAZO: ARE WE ON THE RECORD?

21 MR. DEWEY: I GUESS WE COULD BE ON THE RECORD 22 HERE. THIS IS A LETTER THE APPL ICANT RECENTLY SENT TO

'23 US REGARDING THE MONITORING PROGRAM. IT WAS A LETTER 24 DATED MAY 16, 1985, AND IT UPDATES A LITTLE BIT OF OUR 25 TES'TIMONY AND GIVES SOME BASIS. l'LL GIVE THE BOARD

"*" :A"r a"M'#* '"'- ToND!!iluT' ll TELEPHONE 279-4711

1 l

3039 l I

l 1 COPIES AND ANYONE ELSE COPIES THAT DESIRES THEM. IT'S 2 JUST A SHORT LETTER.

() 3 (RECESS AT 3:09; RESUMED AT 3:35.)

4 JUDGE LAZO: WOULD THE HEARING COME TO ORDER 5 PLEASE.

6 JUDGE COLE: 1 J UST H AVE ONE OR TWO MORE 7 QUESTIONS, GENTLEMEN.

8 IS THIS LETTER THAT WAS JUST 9 GIVEN TO US BY THE STAFF ATTORNEY AT THE BREAK WHICH IS 10 A LETTER DIRECTED TO THE DIRECTOR OF NUCLEAR REGULATORY 11 COMMISSION FROM MR. VAN BRUNT CONTAINING A JUSTlFICATION 12 FOR LIMITATION OF CROP YlELD SAMPLING TO COTTON, IN THE 13 LATTER PART OF THAT TRANSMITTAL IN ITEM THREE, IT STATES 14 THAT THE INVESTIGATIONS OF THE UNIVERSITY OF ARlZONA, 15 FOSTER, ET AL., INDICATED CLEARLY THAT THE EFFECTS OF 16 ALFALFA, BARLEY, AND CANTALOUPE YlELDS OF FOLIAR SALT t

17 DEPOSITION WERE NONEXISTENT IN DOSAGES OF 370 POUNDS PER 18 ACRE YEAR OR LESS. AND IN THE CASE 0F FIELD-GROWN 19 ALFALFA, THE EFFECTS, IF ANY, ON YlELD WERE QUESTION ABLE 20 AT DOSAGES OF 740 POUNDS PER ACRE-YEAR. I GUESS LOOKING 21 AT THE REPORT OF THE UNIVERSITY OF ARl20NA IN SECTION 22 FOUR OF THE CONCLUSIONS OF THAT REPORT, MR. FOSTER, DO 23 YOU HAVE A COPY OF THAT, ITEM 1.3, CONCLUSIONS?

O 24 DR. FOSTER: WHAT PAGE WAS THAT AGAIN, SIR?

25 JUDGE COLE: THAT'S PAGE FOUR. I GUESS MY f

COURT R R5 0 ARIZON 85014 TELEPHONE 279-4711 f

3040 1 QUESTION IS A GENERAL QUESTION THAT IS ADDRESSED BOTH TO 2 YOU, DR. FOSTER, AND TO DRS. McCUNE AND CURTIS. IT

() 3 SEEMS TH AT TH E S AL T L O AD I NG S REFERRED TO IN THE 4 -CONCLUSIONS OF YOUR STUDIES ON PAGE FOUR OF THE 5 ASSESSMENT OF SALT DRIFT ON THE PRODUCTIVITY OF 6 AGRICULTURAL CROPS, YOUR CROPS, YOUR RESEARCH REPORT, 7 THE LOADINGS REFERENCE THERE ARE IN ORDER OF MAGNITUDE 8 DIFFERENT FROM THE SALT LOADINGS THAT ARE REFERRED TO BY - -

9 REFERRED TO IN THIS LETTER AND ARE ALSO IN ORDER OF 10 MAGNITUDE DIFFERENT FROM THE SALT LOADINGS REFERRED TO 11 AS'HAVING NO EFFECT AS STATED BY DRS. McCUNE AND CURTIS.

12 COULD YOU PLEASE COMMENT ON THAT, ALL THREE OF YOU? I 13 GUESS YOU FIRST DR. FOSTER.

.O 14 DR. FOSTER: WELL, THE 7.4 HERE IS REFERRING

  • 15 TO IN THE CONCLUSIONS RATE STATING THAT GIVEN THE 16 LIMITATIONS OF ONE-YEAR STUDY APPEARANCE THAT THE 17 SIMULATED SUN DRIFT RATE OF 7.4 ACRES, 7.4 POUNDS PER 18 ACRE PER YEAR, Dl0 NOT AFFECT THE PRODUCTIVITY OF THE 19 GREENHOUSE COTTON PLANTS TREATED WITH THIS SAME RATE BUT 1

20 SIGNIFICANTLY MORE COTTON. WHAT YOU'RE SIMPLY SAYING 21 HERE IS AT THAT RATE WE DID NOT SEE ANY STATISTICAL 22 DECLINES IN YlELDS. IF YOU LOOK AT -- IF YOU GET INTO 1

23 LOOKING AT ALL THE YlELDS OVER ALL THE CROPS, BACK IN 24 THE REPORT AND ON THE BACK PART OF THIS REPORT I BELlEVE 25 YOU COULD -- THERE MAY BE SOME DIFFERENCES FROM BETWEEN

?

^*"a^."r"a"4f";'A'" '"*- 2'C *Ti '~TJ o ' .*

TELEPHONE 279-4711 I

3041 1 7.4 TO 74. THE CONCLUSIONS OF 7.4 POUNDS PER ACRE PER 2 YEAR, THOUGH, IS TRUE AT THAT RATE. STATISTICALLY, WE

() 3. DID NOT SEE ANY SIGNIFICANT DECLINES IN PRODUCTlYITY 4 OVER ALL OF THESE CROPS.

5 JUDGE COLE: DID YOU FIND ANY STATISTICAL 6 DECLINE IN PRODUCTIVITY OVER ANY PORTIONS, OVER ANY OF 7 THE RANGES THAT YOU STUDIED?

I 8 DR. FOSTER: FOR PRIMARILY FOR ALFALFA AND 9 BARLEY AND CANTALOUPE WE DID NOT. WE DID SEE SOME 10 VARIATION IN COTTON YlELDS.

i 11 JUDGE COLE: WAS THIS A STATISTICALLY 12 DETERMINABLE VARIATION? DlD IT HAVE ANY STATISTICAL 13 RELlABILITY TO IT7 i

14 DR. FOSTER: WELL, THE FIELD COTTON. STATISTICS 15 IS REPORTED ON PAGE 139 0F THE REPORT AND TABLE 26, 16 WHICH IS ON PAGE 124.

17 JUDGE COLE: THIS IS A TABLE THAT'S ALSO 18 REFERRED TO IN THE TESTIMONY OF DRS. McCUNE AND CURTIS; I 19 IS THAT RIGHT?

20 DR. FOSTER: YES, THAT'S RIGHT.

21 JUDGE COLE: NOW, DR. FOSTER, THEY HAVE 22 INDICATED THAT THERE'S NO STATISTICAL RELIABILITY WITH 23 THAT. DO YOU AGREE WITH TH AT OR DO YOU DISAGREE WHILE O 24 WE HAVE ALL THREE OF YOU ON THE STAND 7 25 DR. FOSTER: WELL, I WOULD H AV E TO D IS AGREE

"*c" '"c-

"ar*a"A:\%%'t"  % % C ! d : M *:

TELEPHONE 279-4711

3042 1 WITH THE STATEMENT. l THINK THERE IS STATISTICAL 2 RELlABILITY IN WHAT HAS BEEN DONE. THERE MAY BE SOME --

() 3 i THINK THE QUESTION IS DERIVED OVER HOW ONE INTERPRETS 4 POSSIBLE INFORMATION ON NO TREATMrNT WHICH WAS NO SPREAD 5 AT ALL. WE HAD ESSENTIALLY TWO CONTROLS ON THE FIELD:

6 NO TREATMENT AND ONE THAT WE SPRAYED ONLY WITH THE 7 DISTILLED WATER OR DEMINERALlZED WATER. THAT CONFlRMS 8 TO THE ZERO POUNDS PER ACRE PER YEAR. ALL OF OUR 9 DISCUSSION CONCLUSIONS CENTER AROUND COMPARING 10 STATISTICALLY THE HAND-HARVESTED -- MACHINE-HARVESTED 11 PLOTS AT THE NOMINAL TREATMENT LEVELS OF THE NO 12 TREATMENT ZERO, 10 AND 100.

13 BUT FROM A STATISTICAL STANDPOINT, WE s/

14 FEEL THAT THE STUDY AND THE STRUCTURE OF IT IS 15 STATISTICALLY ACCURATE.

16 JUDGE COLE: 1 GUESS MAYBE I DIDN'T ASK THE

)

17 QUESTION RIGHT. DlD YOU COME TO ANY CONCLUSION THAT 18 THERE WAS AN EFFECT OF THE TREATMENT LEVEL ON THE 19 PRODUCTIVITY AND DID YOU DETERMINE ANY STATISTICAL 20 DIFFERENCES WITH PRODUCTIV ITY AT D I FFERENT L OADING 21 LEVELS? DID YOU CONDUCT ANY STATISTICAL TESTS TO ASSESS 22 THAT?

)

23 DR. FOSTER: WELL, IF YOU LOOK AT TABLE 26, 24 THIS SUMMARIZES OUR RESULTS AND ESSENTI ALLY WE LOOKED AT 25 HAND-HARVESTED PLOTS IN THE FIELD AS WELL AS

)

"**::e~ra?.8%'#"'"' ' " *o % f C alilE n '?:

TELEPHONE 279-4711 h

3043 1 MACHINE-HARVESTED. IN TERMS OF MACHINE-HARVESTED PLOTS, 2 WE SAW NO STATISTICAL SIGNIFICANCE BETWEEN TREATMENTS.

() 3 ONLY WHEN WE WENT TO THE HAND-HARVESTED PLOTS DID WE SEE 4 SOME STATISTICAL VARIATION THAT'S INDICATED IN COLUMN 5 TWO. THE REASON WE WENT TO TWO METHODS OF LOOKING AT 6 YlELDS IS, OF COURSE, WE WERE TRYING WITH THE 7 HAND-HARVESTED PLOTS TO INCREASE OUR PRECISION BECAUSE 8 WITH THE MACHINE-HARVEST WE, BY NATURE OF THE MACHINERY, 9 ARE NOT ABLE TO GET ALL OF THE YlELD, ALL OF THE LINT g 10 0FF 0F THE STALKS AT THE TWO PICKINGS. THERE IS 11 ALWAYS SOME WASTE. SO THE' REASON FOR THE HAND-HARVEST 12 WAS TO BE MORE PRECISE IN OUR YIELD ESTIMATIONS.

13 JUDGE COLE: DOES THAT MEAN, THEN, THAT THE

(-

14 DIFFERENCE THAT YOU DETERMINED MIGHT BE ACADEMIC BECAUSE 15 THEY DO NOT IN FACT HAND-HARVEST THEM?

16 DR. FOSTER: WELL, THAT'S TRUE, OPERATIONALLY 17 THEY DO NOT HAND-HARVEST COTTON. IT'S ALL 18 MACHINE-HARVESTED.

19 JUDGE COLE: GENTLEMEN, I RECALL IN YOUR 20 TESTIMONY WHERE YOU COMMENTED ON THE STATISTICAL 21 SIGNIFICANCE OF TH IS DIFFERENCE. YOU INDICATED -- 1 22 BEL lEVE YOU USED THE TERM THERE'S NO UNIFORM TREND WITH 23 RESPECT TO PRODUCTIVITY OR YlELD AND LOADING. DID YOU 24 USE THAT TERM " UNIFORM" IN A GENERAL SENSE OR IS IT 25 REALLY A STRONG PART OF YOUR EVALUATION? IF WE WERE TO

~~:==::= '~c- um:,8=.u,*:

TELEPHONEP 2794711 b

t 3044 1

1 TAKE OUT THE WORD " UNIFORM", WOULD IT STILL HAVE THE 2 SAME MEANING?

() 3 DR. McCUNE: WELL, l'LL ANSWER THAT QUESTION.

4 i THINK WE ORIGINALLY HELD THE STATISTICS WERE RELlABLE.

5 1 THINK THERE'S A QUESTION OF INTERPRETATION.

6 ESSENTIALLY, WHAT WE SAID IS BY THE STATISTICS, THE 7 HIGHEST LOADING USED INCREASED YlELD WHICH IS 370 POUNDS 1

8 PER ACRE YEAR. I THINK IT WAS A QUESTION OF WHAT 9 HAPPENS AT LOWER LEVELS AND WHY WE S AID UNIFORM IS --

10 THERE ARE SEVERAL POSSIBILITIES. ONE IS THAT THERE'S A 11 UNIFORM TREND. EVERY DECREASE -- EVERY INCREASE IN 12 LOADING RESULTS IN A DECREASE IN YlELD. WE DID NOT FEEL 13 THE EVIDENCE WAS STRONG ENOUGH TO SUPPORT THAT. IT 14 COULD BE THAT DECREASES IN YlELD ONLY OCCUR AFTER 15 LOADING OCCURS -- REACHES A CERTAIN POINT. IN OTHER 16 WORDS, THERE MAY WELL BE A THRESHOLD OF LOADING. BUT 17 WE FELT THAT THE DATA WAS INDETERMINATE AS TO WHERE THAT 18 MIGhT OCCUR.

19 JUDGE COLE: BUT LOOKING AT TABLE 26, COULD 20 YOU EXPLAIN TO ME HOW YOU CAME TO THAT CONCLUSION 21 BECAUSE THE DIFFERENCES BETWEEN THE POUNDS PER ACRE AND 22 DIFFERENT LOADINGS CERTAINLY AT L EAST ON THE SURFACE t- 23 APPEARS TO TREND RATHER WELL WITH DIFFERENCES IN

\T J 24

  • LOADING.

25 DR. CURTIS: THAT GOES BACK TO THE STATEMENT,

" ** &*a*a*A % ?*""' *"L'ClliEnlll o

TELEPHONE 2794711

)

3045 1 SIR, YOU MADE ORIG INALLY ABOUT WE NOT TH INKING THERE WAS 2 A STATISTICALLY CORRECT -- WE FEEL THAT -- WHAT IS THE

) 3 CONTROL GROUP THAT WAS USED? WE AGREE WITH DR. FOSTER, 4 HIS DATA IS CERTAINLY STATISTICALLY CORRECT. WE USED 5 THE NO TREATMENT AS A CONTROL. THE ONE MARKED ZERO IN 6 THE COLUMN WAS DEMINERALlZED WATER WHICH CONTAINED TRACE 4

7 AMOUNTS OF NUTRIENTS, VERY LOW LEVELS BUT NEVERTHELESS 8 THEY WERE THERE. WE USED ZERO AS THE CONTROL. WHERE IT 9 SAYS -- l'M SORRY. THE NO T.M.T. ME ANT TH ERE W AS 10 NOTHING DONE TO THOSE PLOTS. THERE WASN'T TAP WATER 11 SPRAYED ON THEM. NOTHING WAS DONE. TO US, THAT'S THE 12 SUITABLE CONTROL. WHEN YOU COMPARE THE DATA IN THAT

{} 13 14 FASH10N, YOU SEE THERE ARE NO SIGNIFICANT DIFFERENCES EXCEPT DOWN AT THE THREE SEVEN LEVEL.

15 JUDGE COLE: BUT DO YOU AGREE THAT THERE r

16 CERTAINLY IS A DECREASE OF HARVEST AS THE LOADING 17 INCREASES? ARE YOU SAYING THAT IT'S JUST NOT AS 18 STATISTICALLY LARGE ENOUGH TO BE SIGNIFICANT7 19 DR. CURTIS: WE COULD NOT DETECT A

)

20 STATISTICALLY SIGNIFICANT DIFFERENCE EXCEPT AT 370.

21 JUDGE COLE: I KEEP LOOKING AT THE CHART AND l 22 NOTICE AT T.M.T. IT GOES FROM 2527 TO 2355 AT 10 TO

( 23 2237 AT 100 AND TO 1905 AT 500. YOU'RE JUST S AYING TH AT (3>

24 EVEN THOUGH THAT'S CONSTANTLY DECREASING WITH INCREASED 25 LOADING, IT'S JUST NOT STATISTICALLY SIGNIFICANT7

)

0o"u^n"r n$NEns Po bn lN O 8S014 TELEPHONE 279 4711

)

3046 1 DR. CURTIS: THERE IS NO MATHEMATICAL SUPPORT 2 FOR THAT. IT REMINDS ME SIMILAR TO A STUDY l CONDUCTED

() 3 IN CHALK POINT WHERE WE HAD TREE SPECIES WHICH WERE 4 SPRAYED WITH TAP WATER AND WHEN YOU PUT TRACE AMOUNTS OF 5 ELEMENTS ON FOLlAGE, THEY ABSORB IT AND THEY ARE LOW 6 LEVELS AND THERE'S MAGNESIUM IN THERE, CALClUM, IRON, 7 COPPER. THOSE ARE ALL ESSENTIAL ELEMENTS FOR PLANT 8 GROWTH. WE HAD A SIMILAR -- ALTHOUGH THE TREE IS 9 CERTAINLY DIFFERENT THAN THE COTTON PLANT, YOUR CONCEPT 10 0F LOADING UP WITH SMALL AMOUNTS OF MICRO-NUTRIENTS. WE 11 FEEL THAT'S WHAT HAPPENED.

12 , JUDGE COLE: ALL RIGHT, SIR. I UNDERSTAND 13 YOUR POSITION. THANK YOU.

14 JUDGE CARPENTER: IF I MIGHT ASK A FOLLOW-UP 15 QUESTION OUT OF IGNORANCE. WHY DO YOU THINK THE 16 ADDITIONAL MOISTURE THAT'S BEING PRESENTED TO THE PLANT 17 IS INSIGNIFICANT 7 YOU POINT TO THE MINERAL CONTENT OF 18 THE DEMINERALIZED WATER AND SEEM TO DISCOUNT THE FACT 19 THAT THE PLANTS ARE RECElYING ADDITIONAL WATER.

20 DR. CURTIS
THE WATER PUT ON WAS IN A SPRAY 21 AND IT WAS AT 100 MICRON DIAMETER DROPLET AND IN THAT 22 PARTICULAR ENYIRONMENT, SOMEONE ON THE PANEL MENTIONED 23 THAT DRIFT APPARENTLY IS GOING TO BE DIFFERENT IN THIS 24 TYPE OF ENYlRONMENT AND WE WOULD CERTAINLY AGREE WITH 25 THAT. IN THE CHALK POINT EXPERIENCE YOU COULD ACTUALLY

"*" "Er*a"a";' '" '"*- *:MClli Ai,*.*

TELEPHONE 279 4711

3047 1 SEE THE WATER ON THE LEAVES. OUT HERE IN THE DESERT, WE 2 COULD NOT SEE THE WATER ON THE LEAVES. IT JUST i( ) 3 EVAPORATED QUICKLY. WHETHER THAT HAD AN EFFECT ON 4 PLANT, TO MY KNOWLEDGE NO ONE CAN SAY.

5 JUDGE CARPENTER: YOU DON'T THINK THE PLANT 6 GOT A SMALL DRINK IS WHAT l'M ASKING?

7 DR. CURTIS: SOMEBODY GOT IT. I DON'T KNOW 8 WHETHER THE PLANT DID. IT EVAPORATES VERY, VERY RAPIDLY 9 lN THE FIELD UNDER THESE CONDITIONS OUT HERE.

10 JUDGE CARPENTER: SINCE WE'VE GOTTEN INTO THE 11 UNIVERSITY ARIZONA REPORT, I THINK MAYBE IT WOULD HELP THE 12 RECORD IF i ASK MY QUESTIONS RELATIVE TO THAT REPORT RIGHT 13 AT THIS POINT IN THE RECORD SO THEY WILL BE TOGETHER. I 14 HAD A QUESTION. LOOKING AT EITHER THE TABLE IN THE 15 EXECUTIVE

SUMMARY

OR YOUR TABLE 26, IS IT TRUE THAT 16 HAND-HARVESTING IS INHERENTLY A MORE PRECISE TECHNIQUE 7 17 DR. FOSTER: WELL, WE FELT LIKE IT WAS BECAUSE 18 WE HAND-HARVESTED THE BOLLS AS THEY OPENED SO THAT WE 19 KNEW THAT WE WERE GETTING ALL OF THE LINT, ALL OF THE

20 SEED COTTON THAT WAS BEING PRODUCED AS THE BOLLS OPENED 21 SO THERE WERE ABSOLUTELY NO WASTE. ON MACHINE-PICK, THE 22 PRACTICE IS TO WAIT UNTil YOU HAVE A SUFFICIENT AMOUNT 1 23 0F COTTON OPEN THAT YOU CAN EXTRACT MOST OF THE COTTON O 24 WITH ONE PASS AND THEN NORMALLY YOU COME BACK WITH A 25 SECOND PASS TO GET THE REST. YOU WILL HAVE SOME WASTE.

" *c" M a r* a "a m ':.'" '"** MC'lio'En'h* -

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_ __ __ _ .-_ . _ _ _ _ . . . _ . _ . . . _ _ _ _ . . . _ _ _ _ _ . . . _ _ _ _ _ . , _ . . _ _ _ _ ~ _ _ _ _

! 3048 1 JUDGE CARPENTER: WHAT l'M REALLY INTERESTED 2 IN IS YOU SHOW A DIFFERENCE IN TERMS OF STANDARD

() 3 DEV I ATION FOR THE H AND-HARVESTED, THE STANDARD DEVIATION 4 IS 30 AND FOR THE MACHINE-HARVESTED, THE STANDARD 5 DEVIATION WAS 133. WHAT l'M REALLY ASKING 1S DO "OU 6 THINK THAT'S A VERY REAL DIFFERENCE IN THE PRECISION 7 ACH IEV ABLE WITH THE TWO DIFFERENT TECHNIQUES?

8 DR. FOSTER: MY OPINION ls YES.

9 JUDGE CARPENTER: DOES THE REVIEW BOARD HAVE 10 ANY OPINION ON THAT7 11 DR. CURTIS: WE THINK IT IS PROBABLY A MORE 12 PRECISE TECHNIQUE FOR GATHERING DATA BUT IT'S NOT USED 1

13 IN COMMERCIAL AGRICULTURE.

)

14 JUDGE CARPENTER: WELL, l'M NOT SUGGESTING 15 THAT THE FARMER WOULD CHOOSE THIS WAY OF HARVESTING BUT 16 i THINK SOMEONE TRYlNG TO MEASURE YlELD PERHAPS MIGHT

)

'17 CHOOSE THE MORE PRECISE TECHNIQUE IN ORDER TO BE ABLE TO 18 DISCERN EFFECTS IF THERE WERE ANY.

19 DR. McCUNE: 1 THINK ON THIS, l'M NOT SURE 20 WHETHER THIS IS -- AS YOU'RE AWARE, IN ANYTHING LIKE 21 TH IS WE H AVE MULTIPLE SOURCES OF ERROR. ONE IS MERELY 22 PLOT TO PLOT VARIATION. IN THE HAND-HARVESTED AND THE

)

23 MACHINE-HARVESTF.D WERE DIFFERENT ROWS ON THE S AME PLOT.

)

24 $0 IT COULD BE THAT THIS MEASURES THE PRECISION OF THE 25 METHOD LUT IT COULD ALSO MEASURE VARIABILITY AMONGST

"**"Cr'a'an;'h'**- ' 2iClli*'E.'!?.*

o TELEPHONE $19.711 h

3049 1 THOSE DIFFERENT SETS OF R0WS AND TL.0 DIFFERENT PLOTS.

2 JUDGE CARPENTER: WELL, i THINK DR. FOSTER

() 3 SAID HE ANTICIPATED THAT IT WAS GOING TO BE WORTH THE 4 EFFORT TO 00 THE HAND-HARVESTED PRIMARILY BECAUSE OF 5 IMPROVED PRECISION. ,

6 DR. McCUNE: MY P0lNT IS THAT IF PRECISION IS 7 IMPROVED TO A CERTAIN POINT, THEN PROBABLY CONTROLLING 8 YARIABILITY WILL BE THE PLOT-TO-PLOT VARIABILITY IN THE 9 WHOLE EXPERIMENT.

10 JUDGE CARPENTER: YES.

11 DR. FOSTER, G0 LNG ON, 1 NOTICE THIS ROW 12 LABLED CAPITAL L, CAPITAL S, CAPITAL D, THIS LEAST 13 SIGNIFICANCE DIFFERENCE TEST IN TABLE 26.

14 DR. FOSTER: YES.

15 JUDGE CARPENTER: COULD YOU TELL ME A LITTLE 16 BIT ABOUT THAT7 i HAVE A NUMBER OF BOOKS AND STATISTICS

)

17 BUT l LOOKED IN THE INDEXES FOR THEM AND COULDN'T FIND 18 LEAST SIGNIFICANCE DIFFERENCE TEST AS A HANDY-DANDY  ;

19 RECEIPE AND I COULDN'T FIND IN THE REPORT ANY DEFINITION

)

20 0F WHAT THIS MEANS. COULD YOU EDUCATE ME7 l 21 OR. FOSTER: I CANNOT ANSWER THAT QUESTION.  !

22 WE HAVE AN EXPERIMENT STATISTICIAN WHO WORKED ON THIS

?

23 PROJECT WITH US WHO DEVISED THESE TESTS. UNFORTUNATELY,

)

24 1 MAY HAVE SEEN THE STATISTICS. HE IS NOT HERE TODAY S0 l

25 l CAN'T REALLY ANSWER TH AT QUESTION FOR YOU.  ;

i  !

      • "!"#r*4"4M'.?"d" '!" L'O#i*o*f5 'i.

TELEPHONE 2794F11

)

3050 1 JUDGE CARPENTER: IS THE REVIEW BOARD FAMILlAR 2 WITH WHAT --

() 3 DR. McCUNE: ONLY TO THE EXTENT THAT IT'S ONE 4 WAY OF CONDUCTING THESE MULTIPLE COMPARISON TESTS AND 5 IT'S ONE STATISTIC THAT ONE CAN USE AND WHY IT WAS 6 CHOSEN l'M NOT SURE BUT IT'S ONE OF SEVERAL ALTERNATIVES - -

7 AS YOU CAN SEE BY THE L ETTERS -- AFTER IT IS DECIDING 8 WHICH TREATMENTS ARE DIFFERENT FROM THE OTHERS.

9 DR. CURTIS: IT'S A COMMON TEST IN AGRONOMIC 10 FIELD PLOT WORK. YOU'LL FIND LEAST S IGNIFICANT 11 DIFFERENCES VERY FREQUENTLY REPORTED IN THE AGRONOMY 12 JOURNALS. IT'S NOT AN UNUSUAL TEST.

13 JUDGE CARPENTER: I WAS SURPRISED IF THE 14 STANDARD DEVIATION IS 30 THAT THE LEAST SIGNIFICANT 15 DIFFERENCE WOULD BE MORE TH AN 10 TIMES L ARGER. NORMALLY 16 TWO STANDARD DEVIATIONS OR THREE STANDARD DEVlATIONS IS 17 BEGINNING TO BECOME A DIFFERENCE BIG ENOUGH TO BE 18 STATISTICALLY DIFFERENT.

19 DR. McCUNE: 1 THINK WE HAVE TO REFER TO THE

)

20 STATISTICIAN. l'M SURE IN THIS TEST THE NUMBER OF 21 REPLICATES WERE TREATMENT AND THE NUMBER OF TREATMENTS 22 AND HOW FAR APART THE TREATMENTS ARE IF WE RANK THEM 23 ENTERS INTO THE SIDE OF THE STATISTIC THAT HE LABELS

)

24 LSD. I THINK YOU WOULD REALLY NEED A STATISTICIAN TO 25 EXPLAIN HOW HE CALCULATED IT AND, NUMBER TWO, WHY HE

'"**" "A"r*a"An;'R* '"** *i " N C !r a l'A i,*:

TELEPHONE 879 4718

)

3051 1 USED THAT PARTICULAR TEST.

2 JUDGE CARPENTER: BUT I THINK AS SCIENTISTS WE

() 3 CAN ALSO MAKE MATHEMATICAL TESTS. WE USE 10 SIGMAS AS 4 VERY LARGE.

5 LEAVING THAT SINCE THERE DOESN'T SEEM TO 6 BE ANYONE WHO CAN ANSWER I T, WHY THE CAPITAL N, CAPITAL 7 S IN THE OTHER -- FOR THE MACHINE-HARVESTED PLOTS, WHAT 8 DOES NS MEAN?

9 DR. CURTIS: NON-SIGNIFICANT.

10 JUDGE CARPENTER: 1 THOUGHT PERHAPS THERE THE

)

11 NUMBER SHOWED HOW BIG IT HAD TO BE BEFORE IT WAS 12 SIGNIFICANT.

- 13 DR. CURTIS: l'M NOT SURE I KNOW WHAT NUMBER ,

14 YOU'RE REFERRING TO, SIR.

15 JUDGE CARPENTER: IF YOU LOOK AT THE LSD'S, 16 THE FIRST ENTRY IS TO FOUR SIGNIFICANT FIGURES 381.6 --

17 PERHAPS WE MIGHT MAKE IT JUST 380. I TOOK THAT TO MEAN 18 THE LEAST SIGNIFICANT DIFFERENCE WAS 380 POUNDS PER 19 ACRE.

)

20 DR. McCUNE: MY INTERPRETATION IS THAT THE 21 STATISTICIAN FELT IF NONE OF THESE MEANS WERE 22 SIGNIFICANTLY DIFFERENT BY THE LSD TEST, THEY DIDN'T PUT THE LSD IN THE TABLE.

') '

23 24 IS THAT WHAT --

25 DR. FOSTER: I WOULD GUESS THAT. AGAIN, DRS.

""*"E8v^n'r*nEEEE'n'sd"** '"$d'*n*Ii*o*uYe'o' I TELEPHONE $194711

)

3052 1 PALZKILL AND HOPF COULD ANSWER THAT.

2 JUDGE CARPENTER: WELL, l'VE BEEN TRYING TO

(') 3 ASK A SERIES OF FOUNDATION QUESTIONS L EADING UP TO THIS 4 QUESTION. FIRST OF ALL, WOULD YOU THINK THE RESULTS IN 5 TERMS OF THE VARIANCE THAT YOU OBSERVED IN SAMPLING THE 6 COTTON YlELDS IN YOUR STUDY AREA WOULD BE EXPECTED IN 7 THE PALO VERDE AREA? IS THERE ANY REASON TO THINK THE 8 YARIANCE MIGHT BE DIFFERENT IN THE PALO VERDE AREA?

9 DR. FOSTER: I THINK HISTORICALLY THE COTTON 10 YlELDS IN THE PALO VERDE AREA HAVE BEEN HIGHER THAN IN 11 THE AREA THAT WE CONDUCTED THE STUDY, PRIMARlLY A BASIS --

12 ON THE BASIS 0F A LITTLE LONGER GROWING SEASON, THESE 13 KINDS OF PARAMETERS. IN TERMS OF OVERALL VARIABILITY, I

? ['~)

14 DON'T THINK I WOULD EXPECT ANYTHING SIGNIFICANTLY 15 DIFFERENT THAN WE HAVE SEEN IN THE MARANA AREA.

16 JUDGE CARPENTER: WELL, IF THAT IS TRUE, THAT 1

17 THE H AND-HARVESTED TECHNIQUE WOULD BE EXPECTED TO GIVE A 18 STANDARD DEVIATION ON THE ORDER OF 30 POUNDS PER ACRE 19 AND THE MACH INE-H ARVESTED TECHNIQUE WOULD BE EXPECTED TO 20 GIVE STANDARD DEVIATION ON THE ORDER OF 130 OR ROUGHLY 21 FOUR TIMES LARGER, I WOULD LIKE TO ASK PERHAPS DR.

22 GOLDMAN, IN DESIGNING THE MONITORING PROGRAM, HAVE YOU 23 LOOKED AT HOW LARGE A DIFFERENCE HAS TO BE PRODUCED BY

() 24 THE SALT DRlFT BEFORE IT CAN BE RELlABLY OBSERVED IF THE 25 VARIANCE AS REPRESENTED BY THESE STANDARD DEYIATIONS IS

"*" Mar

  • a?"u?*"** "'.' " W ! : rl n '?:

TELEPHONE 2794711

)

i. ,

3053 ,

! i j 1 EITHER 30 OR 1307 00 YOU HAV E ANY NOTION WHETHER A 10 2 PERCENT REDUCTION IN YlELD CAN BE OBSERVED, A 20 PERCENT

.O > ae0uCTiON. A 50 PEacEaT as0ucTi0a2 i'M cuai0uS ^S TO 4 THE QUAL ITY OF THE MON ITORING PROGRAM. '  ;

5 DR. GOLDMAN: LET ME SEE IF I CAN GIVE YOU A i 6 RESPONSE THAT MAY BE HELPFUL BUT NOT DIRECTLY IN THE 7 CONTEXT OF THE QUESTION.

8 AS PART OF THE MONITORING PROGRAM WE D0 1

9 MEASURE THE YlELD OF COTTON GROWTH IN THE FARMS IN THE 10 VIClNITY OF'THE PLOTS THAT GROW COTTON. THESE VARY FROM  !

11 YEAR TO YEAR. NOT THOSE SAME FARMERS GROW COTTON IN THE 12 SAME PLOTS EVERY YEAR. IN THE PERIOD COVERED BY OUR  ;

i 13 F IRST ANNU AL REPORT, WHICH WAS REFERRED TO BEFORE THE j 14 RECESS, THERE IS A TABLE 6-13 WHICH INDICATES THE 15 RESULTS OF COTTON YlELDS AT SEVEN OF THE MONITORING  !

16 LOCATIONS THAT WERE GROW lNG COTTON IN 1983.

17 WE 00 HAND-HARVEST IN ESSENCE THE COTTON I 18 lN THOSE FIELDS, NOT ALL OF IT BUT IN STATISTICALLY 19 SELECTED SEGMENTS OF PLOTS OF THOSE FIELDS. THE RANGE 0F VALUES THAT WE G0T FOR SIX OF THE SEVEN FIELDS -- ONE 20 21 WAS HARVESTED BY MACHINE BEFORE WE G0T THERE -- EXTENDED 22 FROM A LOW 0F 750 P0UNDS PER ACRE TO A HIGH 0F 2520 l

) i 23 POUNDS PER ACRE. THERE ARE ALSO DATA THAT -- l

.24 JUDGE' CARPENTER: TELL ME AGAIN WHAT THE TWO 25 NUMBERS.ARE7 ,

> 1 I

"""cle'?"4: lit &** '"- %lC#7i o'a'40 r.u . m n l

\

i

3054 l 1 DR. GOLDMAN: THE LOW VALUE WAS 750 POUNDS.

2 JUDGE CARPENTER: THIS IS FROM THE SAME FIELD?

() 3 DR. GOLDMAN: ONE FIELD, ONE FARM, ONE PLOT 4 YlELDED 750 POUNDS PER ACRE.

5 JUDGE CARPENTER: ON THE SAME FARM, A 6 DIFFERENT PLOT?

7 DR. GOLDMAN: A DIFFERENT FARM, DIFFERENT 8 LOCATION, THE HIGHEST WAS A YlELD OF 2520 POUNDS PER 9 ACRE. THESE ARE PRACTICING ACTUAL FARMS, NOT 10 EXPERIMENTAL PLOTS. THE OTHER VALUES RANGED BETWEEN 11 1300 AND 2400 POUNDS PER ACRE FOR THOSE SAME FARMERS, 12 NOT NECESSARILY THE SAME INDIVIDUAL FIELDS SINCE ONE 13 FARMER MAY OPERATE SEVERAL FIELDS OF MAYBE SCATTERED 14 SEVERAL MILES FROM EACH OTHER. WE HAVE ALSO THE U.S.

15 DEPARTMENT OF AGRICULTURE YlELD DATA BASED ON THE 16 MATERIAL THAT FARMER BRINGS TO THE COTTON GIN AND THESE 17 REPRESENT MACHINE-PICKED OBVIOUSLY AND AN AVERAGE 18 OVERALL OF THAT FARMER'S PLOTS FOR THE FARM THAT HAD A 19 HAND-PICKED YlELD OF 749 OR 750 POUNDS PER ACRE, THE 20 U.S.D.A. NUMBER FOR THAT FARMER WAS 1120.

21 FOR THE HIGH YlELD, THE 2500 POUND PER 22 ACRE LOCATION, THAT FARMER'S YlELD WAS RECORDED BY THE g3 23 U.S.D.A. AS 1360 POUNDS PER ACRE. AGAIN, THE HIGHEST OF U 24 THE GROUP BUT NOT ANYWHERE NE AR AS L ARGE AS THE 25 HAND-PICKED STUDY. SO THERE IS NO CLEAR CORRELATION

"*:" a'a*an;':.'* '"*- %'Cali*o*~T.1 ',*.*

TELEPHONS $F9 4711

3055 1 BETWEEN THE VALUES DETERMINED BY HAND-PICKING ONE FIELD 2 AND THE TOTAL YlELD OF THAT FARMER AS DETERMINED BY

() 3 MACHINE-PICKING, AT LEAST B ASE0 ON THE DATA TH AT WE H AD 4 SO FAR.

5 i WOULD SUSPECT WE WOULD BE YERY H ARD PUT 6 TO DETERMINE A STATISTICAL DIFFERENCE IN COTTON YlELD 7 BASED ON THESE KINDS OF SAMPLING RESULTS AS AN OUTCOME 8 OR A CONSEQUENCE OF THE DRIFT FROM THE PL ANT. OUR 9 ABILITY TO DETECT THE DRIFT IS A LOT BETTER TH AN IT IS 10 TO DETECT THE EFFECTS ON COTTON OF THAT DRIFT.

11 JUDGE CARPENTER: l'M TRYING TO FIND OUT 12 WHETHER THE VARIABILITY WAS SO LARGE THAT OTHER THAN ALL 13 THE COTTON TURNING BROWN, ONE COULDN'T REALLY TELL 14 WHETHER THE DRIFT WAS THERE OR NOT.

15 DR. GOLDMAN: THAT WOULD BE MY JUDGMENT BUT 16 l'M NOT AN AGRONOMIST.

17 JUDGE CARPENTER: BUT THE STAFF IS APPROYING A 18 MONITORING PROGRAM WHICH THEY MUST THINK IS GOING TO BE 19 lN THE PUBLIC INTEREST AND THESE FARMERS' INTEREST AND 20 l'M RAIS ING THE QUESTION, WELL, IS THAT REALLY S07 IF 21 THE INHERENT VARIABILITY -- IT'S A VERY CHALLENGING 22 SAMPLING PROBLEM IT SEEMS TO ME.

23 DR. GOLDMAN: EXTRA 0RDINARY.

24 JUDGE CARPENTER: WHETHER IT'S POSSIBLE TO 25 GIVE SAMPLING EFFORT SUFFICIENT INTENSITY TO GIVE STABLE

"***::a*a*ata;%','"' '"**  %' A f C & # A :ll TELEPHONE $794711

3056 i

1 MEANS S0 TH AT 10 PERCENT DIFFERENCE COULD REALLY BE i 2 DISCERNED OR EVEN A 25 PERCENT DIFFERENCE, WHICH THE

() 3 UNIVERSITY OF ARIZON A STUDIES SUGGEST AT TIMES IT MIGHT 4 BE 25 PERCENT REDUCTION. TH AT' S THE B IGGEST EFFECT YOU i 5 SAW ON COTTON.

6 DR. GOLDMAN: I WOULD HAVE A GREAT DEAL OF i

7 DIFFICULTY IN SUGGESTING THAT I HAVE A HIGH DEGREE OF 8 CONFIDENCE BASED ON WHAT WE KNOW NOW ON THE ABILITY OF 9 THE MON ITOR ING PROGRAM TO REL I ABLY REL ATE A DECL INE IN 10 YlELD OF COTTON TO THE DEPOSITION. ITEM ONE IS THAT WE 11 DO NOT EXPECT TO BE WITHIN SEVERAL ORDERS OF MAGNITUDE 12 0F THE DOSAGES OF DEPOSITION THAT WOULD GIVE SUCH

) () 13 14 RESULTS. QUITE APART FROM THAT, THE VARIABILITY THAT WE HAVE SEEN BETWEEN FARMS -- AND WE DO NOT HAVE DATA YET 15 FROM YE AR TO YE AR FOR THE S AME FARMS OR WE CANNOT 16 QUANTIFY THAT BUT l WOULD NOT BE SURPRISED TO SEE 17 V AR I AB IL ITY OF 30 PERCENT OR MORE FROM YE AR TO YE AR AT l 18 THE SAME SITE.

19 JUDGE CARPENTER: BUT STILL IN ANY ONE YEAR

)

20 YOU MIGHT COMPARE GE0 GRAPH ICALLY, WOULDN'T YOU, WITH THE 21 SAME GE0 GRAPHICAL V ARI ATIONSf l 22 DR. GOLDMAN: GE0 GRAPH ICAL V AR I ATION IS A ,

23 FACTOR BETWEEN THREE AND FOUR. l

)

24 JUDGE CARPENTER: DOES THE STAFF HAVE ANY (

25 COMMENT ABOUT THl3 IMPEDIMENT TO THl3 MONITORING PROGRAM

-um =:.~~ w==:,: ll

. . m -.. . . . . , :

)

3057 1 THAT WE'RE SUPPOSED TO ACCEPT 7 2 DR. PENTECOST: 1 THINK THERE WILL BE SOME

() 3 DIFFICULTIES IN DETECTING DIFFERENCES. I DO BELlEVE THE 4 PLANT WILL SHOW ANY DRASTIC -- ASIDE FROM WHAT YOU SAID, 5 JUDGE CARPENTER, TURNING THE FIELD BROWN. I THINK IT 6 WILL SHOW -- WE COULD SEE SOMETHING LESS THAN THAT, SOME 7 GRAPHIC REDUCTION, MAYBE IN THE ORDER OF 40 TO 50 8 PERCENT PLUS THE INFRARED PHOTOGRAPHY PORTION OF THE 9 MONITOR PROGRAM WOULD ALSO ALERT THE APPLICANT AND THE 10 FARMERS OF SOMETHING GOING ON DOWN THERE. l THINK THE I

11 PROGRAM AS I SEE IT WOULD SHOW YOU FAIRLY SUBSTANTIAL 12 CHANGES IF THEY ARE G0 LNG TO OCCUR.

13 JUDGE CARPENTER: SORT OF IPSO FACTO OR MY

, 14 DEFINITION.

15 WELL, IN THE MONI TOR PROGRAM IT IS 16 FPLANNED TO USE THE HAND-HARVESTING; IS THAT MY 17 UNDERSTANDING 7 18 DR. GOLDMAN: YES. WE HAVE AND WILL CONTINUE 19 TO DETERMINE THE YlELD OF COTTON AT THOSE LOCATIONS 1

20 WHERE IT H AS GROWN BY ESSENTI ALLY H AND-HARVESTING. I 21 CANNOT TELL YOU WITH ANY GREAT PRECISION. MY 22 RECOLLECTION iS THAT THE FELLOW WHO DOES IT USES 10

)

23 ONE-METER SQUARES SELECTED ON A STATISTICAL BASIS USING

)

24 A RAND 0M NUMBER TABLE IN A GIVEN FIELD AND HARYESTS ALL 25 0F THE BOLLS ON ALL OF THE PLANTS THAT ARE IN THOSE h

"***:"sa*a"An;#*"** %fC!!ra'3'n',*:

TELEPHONE 879 4711

3058 1 METER SQUARES.

2 JUDGE CARPENTER: THANK YOU. THAT'S PROYIDED

( 3 ADDITIONAL INFORMATION THAT WASN'T PREVIOUSLY IN THE 4 RECORD. THANK YOU.

5 JUDGE CALLIHAN: MY ESTEEM COLL EAGUES H AVE 6 COVERED MANY TOPICS. I WILL TRY TO FILL IN A FEW PolNTS 7 FOR MY OWN INFORMATION AND MAY JUMP FROM HERE TO THERE.

8 SO BEAR WITH ME, PLEASE. I FIND MYSELF DISTURBED BY 9 THIS MOST RECENT CONVERSATION CONCERNING NOT ONLY 10 ACCURACY BUT I BELlEVE PRECISION OF MEASURING YlELD. I 11 FEEL MYSELF BELIEVING THAT WE'RE TALKING ABOUT CERTAINLY 12 NOT A SCIENCE AND MAYBE NOT EVEN AN ART. l' M BOTHERED

{) 13 14 THAT MR. RAYNER WAS UNABLE TO REMAIN HERE THIS AFTERNOON. I WONDER IF ANY EFFORT H AS BEEN MADE, 15 PARTICULARLY BY STAFF, BECAUSE THEY ARE THE OVERSEER AND 16 THE GODFATHER, TO INFORM THE INTERVENORS OR 17 EX-INTERVENORS THAT WE'RE TALKING ABOUT SUCH INEXACT 18 MEASURES AS I UNDERSTOOD YOU GENTLEMEN TO ALLUDE TO JUST 19 NOW.

t 20 THERE WAS A REMARK THIS MORNING THAT IT 21 MIGHT BE A BIT SOBERING TO SOME PEOPLE IN THIS ROOM THAT 22 THE INTERYENORS WOULD HOPE TO GET SOME HELP FROM THE

{) 23 24 UNIVERS ITY' S EXTENS ION SERY ICE TO PERH APS ESTABL ISH A BA$lS FOR A LAWSulT. THAT'S PRETTY SERIOUS IN YlEW 0F 25 WHAT l'YE JUST HEARD. I TRUST THAT THE APPROPRIATE 1

""*"!!u^n"r"n?4EEnY"""*' '"* oM C Ei'o*2f5$.

TELEPHONE 2794711

3059 1 PEOPLE -- AND l'LL START WITH THE STAFF -- WILL DISCUSS 2 JUST THIS NATTER WITH THE FARM COMMUNITY TO POINT OUT

() 3 THAT NOT ALL THE NUMBERS ARE L AW AND GOSPEL IN THIS 4 BUSINESS. I GUESS I KIND OF THROW THAT OUT AS A 5 CHALLENGE TO SOME OF YOU, WHOMEVER WISHES TO TAKE SOME 6 ACTION ON IT.

7 TO PICK UP A FEW SPECIFIC ITEMS, I WILL 8 BEGIN WITH MR. WILBER AND MR. GOLDMAN.

9 MR. DEWEY: YOUR HONOR, I THINK MAYBE STAFF 10 SHOULD MAKE A COMMENT AT THIS TIME. I DON'T KNOW IF THE 11 STAFF IS REALLY IN A POSITION TO GET INVOLVED IN A 12 PRIVATE LAWSUIT BETWEEN THE APPLICANT AND THE FARNERS.

f TELEPHONE 279-4711

)

3077 1 1 THINK, AS MR. GEHR AND OTHERS HAVE 2 MENTIONED, THERE ARE A L OT OF TH INGS TH AT CAN H APP N IN

() 3 A FARM FIELD THAT WILL AFFECT THE YlELD OF A CROP. THE 4 SALINITY OF THE lRRIGATION WATER, THE DIFFERENT 5 AGRICULTURAL PRACTICES AS FAR AS CONDITIONING OF THE 6 S0ll, FERTILIZATION, PESTICIDES AND EVERYTHING ELSE MOST 7 0F WHICH WILL HAVE A SIGNIFICANT REFLECTION IN THE SolL 8 AND ITS SALT -- ITS MINERAL CONTENT I SHOULD SAY.

9 ALTHOUGH OUR CONCERN IS FOCUSED ON SALT DRIFT AS SUCH, 10 WE FELT IT WAS APPROPRIATE TO BE AWARE OF HOW Soll 11 CONDITIONS MIGHT BE CH ANGED BY PR ACTICES OR EFFECTS OR 12 INFLUENCES OTHER THAN SALT DRIFT SUCH AS THE APPLICATION 13 0F A HIGHLY SALINE WATER WHICH WOULD BE REFLECTED IN THE

)

(2) 14 SOIL CONDITION IF NOT IN THE DUST FALL JARS. .

15 JUDGE CARPENTER: DOES THE STAFF HAVE ANY 16 COMMENT 7

)

17 DR. PENTECOST: 1 THINK I WOULD AGREE WITH 18 WHAT MR. GOLDMAN HAS TO SAY. IF IT WERE MY FIELD, i 19 WOULD WANT TO KNOW PRECISELY WHAT THESE OTHER FACTORS

?

20 WOULD D0. I THINK THE QUALITY OF THE IRRIGATION WATER, 21 AS YOU SAY, IS IMPORTANT. ARE YOU GETTING A LEACHED OUT

. 22 LAYER AT A CERTAIN DEPTH IN YOUR AGRICULTURAL FIELD

)

23 WHICH COULD AFFECT THE PLANT GROWTH, WATER? NO. WHAT O 24 TYPES OF DEFOLlANTS I WAS USING, ANY PESTICIDES THAT 25 WERE BEING USED. I THINK I WOULD WANT TO KNOW ALL OF

"^* *!"fa"r"al"4EE'!s'"' '"** **S"dCIIi*o'u"f*

  • l TELEPHONE 279-4711

)

3078 1 THAT, AND THE SOIL WOULD SHOW l THINK CHANGES IN THESE 2 S0ll SAMPLINGS WHICH WOULD SHOW CHANGES IN THESE INPUTS.

() 3 JUDGE CARPENTER: THANK YOU.

4 LET'S COME BACK JUST FOR A MOMENT TO THIS 5 IMPEDIMENT TO ANYONE'S BEING ABLE TO OBSERVE THE EFFECT 6 0F SALT DRIFT FROM A TOWER ON THE SURROUNDING VEGETATION 7 ASSOCIATED A LARGE VARIANCE IN THE VEGETATION, BOTH

)

8 SPACIALLY AND TEMPORALLY.

9 l'LL FINISH MY QUESTIONING WITH A L ITTLE 10 BIT OF A SEA STORY. I BELlEVE IT WAS DR. CURTlS

)

11 MENTIONED THAT THE UNIVERSITY OF ARlZONA STUDY USED THE 12 STATE OF THE ART METHODS BECAUSE MANY OTHER PEOPLE DO 13 THAT. SEVERAL YEARS AGO I WAS INVOLVED IN A STUDY WHEN 14 WE WERE CONCERNED ABOUT A POWER PLANT'S EFFECT ON THE 15 CHESAPEAKE BAY AND WE WERE CONCERNED ABOUT METALS. I 16 HAPPENED TO FIND A BIOLOGIST WHO WAS A FRIEND OF AN 17 OYSTER AND HE MANAGED TO GIVE ME AN OYSTER SPAWN.

18 INSTEAD OF HAYlNG A VARIATION OF'FOUR 19 VARIATION FROM OYSTER TO COPPER AND ZINC, HE H AD A 20 VARIATION OF FIVE PERCENT BECAUSE THEY ALL CAME FROM THE 21 SAME PARENT. I WOULD LIKE TO JUST PUT THAT ON THE TABLE 22 AS TO WHETHER USING SOME GENETICALLY UNIFORM GROUP OF 23 PLANTS AND ARRANGING THEM RADIANTLY OUT FROM THIS PLANT, O 24 WHETHER ONE COULDN'T ACTUALLY MEASURE WHETHER THERE WAS 25 AN EFFECT BECAUSE OF THE V ARI ANCE FROM PL ANT TO PL ANT

"^**Eu"O",fE4EE'n?"""** '"* oE**["n*Ii'o'f* *1f TELEPHONE 279-4711

)

1 3079 1 AMONG SOME TEST PLANTS MIGHT BE SMALL ENOUGH TO LET YOU 2 ACTU ALLY SEE WHETHER THERE WAS AN EFFECT.

() 3 DR. GOLDMAN: BEFORE THE AGRONOMIST DOES, AS A 4 CHESAPEAKE BAY SAILOR, I WOULD PolNT OUT THAT THE BAY, 5 AS INHOMOGENEOUS AS IT IS, IS A LOT MORE HOMOGENEOUS 6 THAN THE Soll GOING OUT IN ANY RADIAL DIRECTION FROM THE 7 PLANT.

8 JUDGE CARPENTER: PERHAPS THESE PLANTS MIGHT 9 BE IN POTS THAT ALL HAVE THE SAME KIND OF SOIL IN THEM, 10 ALL OF THE CANARIES MIGHT H AVE COME OUT OF THE S AME 11 BARN. HAS ONE LOOKED TO SEE WHICH CANARY DIED OR DIDN'T

~12 DlEt 13 DR. CURTIS: SIR, OUR JOB WAS TO FIND OUT IF 14 SALT DRIP HAD AN EFFECT ON t.GRICULTURAL CROPS AND WE 15 DETERMINED THAT IT DID NOT UP TO A CERTAIN P0lNT, THE 16 370 LEVEL. YOUR SUGGESTION TO DO A HOMCGENEOUS F

17 EXPERIMENT, THAT HAS BEEN DONE AT OTHER .'0WER PLANTS, 18 TURKEY P0lNT IN FLORIDA AND PROBABLY SOME UTHERS. THE 19 RELATIONSHIP 0F THOSE EXPERIMENTS TO YlELD, HOWEVER, IS 20 NOT A MEANINGFUL ONE TO USE BECAUSE OF THE -- YOU HAVE 21 TO HARVEST AND GET MORE ECONOMIC. THE EXPERIMENTS l'M 22 AW ARE OF WHERE THEY USED S INGLE S ALT-SENS ITIVE CULTIV ARS

)

23 WERE NOT RELATED TO ECONOMIC PRACTICES.

24 JUDGE CARPENTER: WELL, I WOULD BE HAPPY IF 25 YOU TOLD ME BY INSPECTION THAT IT MADE NO SENSE RATHER

"** ::a'a*Ai%'#*"** 'MNGUiC:n'n'*

TELEPHONE 2794711

)

)

3080 j

1 THAN SOMEBODY DIDN'T 00 IT.

2 DR. GOLDMAN: I WOULD BE HARD-PRESSED TO

() 3 RECOMMEND TO A.M.B.P. THAT THEY SET UP AN EXPERIMENT OF 4 THE KIND THAT YOU ARE DESCRIBING,. COTTON PLANTS GOING 5 OUT IN SEVERAL MILES IN SOME RADIUS. I WOULD POINT OUT 6 AMONG OTHER THINGS THAT QUITE APART FROM THE DIFFICULTY -

7 0F MAINTAINING THIS ARTIFICIAL FOREST OF COTTON PLANTS 8 IN ONE SECTOR, THAT THE MICROCLIMATE IN THE DESERT IS 9 VERY VARIABLE. YOU CAN HAVE SHOWERS, VERY INTENSE i 10 SHOWERS, THUNDERSTORMS LOCALLY AND HALF MIL E AW AY H AVE A 11 BONE-DRY DESERT.

12 l THINK STILL THE V ARI ABLES TH AT ONE 13 WOULD HAVE TO DEAL WITH AND CONSIDERING THE DEPOSITION, ,

14 THE VERY LOW DEPOSITION DENSITY THAT IS FORECAST FOR 15 THESE TOWERS, THAT THERE WOULD BE REALLY NOTHING TO SEE t

16 AND A GREAT DEAL OF MONEY TO SPEND FOR OBSERVING

)

17 NOTHING.

18 JUDGE CARPENTER: WELL, YOU'RE SAYING WE'RE 19 JUST GOING TO H AVE TO L IVE W ITH THIS B IG V AR I ANCE AND

)

20 THE EFFECT IS GOING TO BE SMALL AND YOU AREN'T GOING TO  ;

21 BE ABLE TO TO SEE IT. THE CONCLUSION IS FOREGONE. '

22 DR. GOLDMAN: l'M SUGGESTING THAT THE -- THAT 23 AS IN A NUMBER OF OTHER PHENOMENA THAT OCCURRED IN THE 24 RANGE OF THE STANDARD DEYIATION OF A NATURAL BACKGROUND ,

25 0F SOMETHING, IT'S DIFFICULT IF NOT IMPOSSIBLE TO

""*"EEu^n"S"EEEEs'"'* ****o"dCa*Iz"o's"Es5 o*:

4 TELEMMNE 2794711 I

3081 1 IDENTIFY CONTRIBUTION BY MAN TO VERY LARGE NATURAL 2 STANDARD DEVIATION.

() 3 JUDGE CARPENTER: THANK YOU VERY MUCH.

4 JUDGE LAZO: 1 JUST WANTED TO ADD ONE THING.

5 AGAIN, I THINK MOST OF THE QUESTIONS TH AT l H AV E H AD 6 HAVE BEEN ASKED AND ANSWERED BUT I DID WANT TO ASK DR.

7 GOLDMAN REGARDING l THINK YOU'VE STATED IN YOUR PREPARED 8 TESTIMONY THAT THE SALT DEPOSITION AND IMPACT MONITORING 9 PLAN REQ U I R ES ANNUAL REPORTS TO BE PREPARED.

10 DR. GOLDMAN: THAT'S CORRECT.

11 JUDGE LAZO: AND I DID WANT TO ASK OVER WHAT 12 PERIOD OF TIME WOULD SUCH REPORTS BE PREPARED 7 i THINK 13 THE APPLICANT'S ENVlRONMENTAL REPORT TALKED ABOUT

() 14 COLLECTING SEASONAL DATA UNTIL THE LEVELS OF IMPACT WERE 15 DETERMINED. I DON'T KNOW WHAT THAT MEANS. IS IT 16 FOREVER OR TWO YEARS OR --

17 DR. GOLDMAN: THE TECHNICAL SPECIFICATIONS 18 THAT ARE ATTACHED TO THE OPERATING LICENSE OF PALO VERDE 19 1 CALL FOR AN ANNU AL REPORT TO BE FIL ED W ITH THE N.R.C.

t 20 STAFF FOR A PERIOD OF SOME YEARS FOLLOWING THE OPERATION 21 0F ALL THREE UNITS AT FULL POWER. l THINK --

22 MR. DEWEY: TH AT' S THREE YE ARS AFTER THE L AST 23 UNIT, UNIT 3, COMES ON LINE.

O 24 JUDGE L AZ0: ALL RIGHT. NOW, THAT'S NOT IN 25 THE SALT MONITORING PLAN. THAT'S IN THE ENVIRONMENTAL t

"""!"#14"4

";'t.'" '"*- **20 *Tio'r.' *f.*

TELEPHONE 2794711

3082 1 PROTECTION PLAN.

I 2 MR. DEWEY: THE ENVIRONMENTAL PROTECTION PLAN.

() 3 JUDGE LAZO: WELL, THEN, MR. DEWEY ALSO SAID 4 SOMETH ING ABOUT -- WE ASKED WHAT WOULD THE J OINT 5 APPLICANTS BE REQUIRED TO DO AND MR. DEWEY REQUIRED THAT 6 THEY WOULD HAVE TO REPORT ANY HARMFUL EFFECTS AND l 7 THINK YOU SAID TAKE APPROPRIATE ACTION. IS THAT ALSO IN 8 THE ENV IRONMENTAL PROTECTION PL AN WHICH IS --

9 MR. DEWEY: YES, IT IS AND THEY H AV E TO FILE 10 THESE ANNUAL REPORTS. WHEN THE ANNUAL REPORTS ARE 11 FILED, WE WILL INSPECT THEM AND LOOK FOR VARIOUS THINGS 12 TO SATISFY OURSELF THAT THERE IS IN FACT NO CROP DAMAGE.

13 WE WILL ALSO BE REVIEWING THESE REPORTS TO MAKE SURE f() 14 THAT -- TO SATISFY OURSELVES THAT THERE'S NO CROP DAMAGE 15 AND THEN IF THERE IS CROP DAMAGE, THEN WE WILL ' COURSE 16 NOTIFY THE APPL l CANT AND THE APPLICANT IS OBLIGATED 17 UNDER THE ENVIRONMENTAL PROTECTION PLAN TO TAKE 18 APPROPRIATE MEASURES. l 19 JUDGE LAZO: WHATEVER THAT IS.

)

20 MR. DEWEY: THERE ARE A NUMBER OF DlFFERENT 21 THINGS THAT THEY CAN 00.

22 JUDGE LAZO: ONE OF THE -- TELL ME ONE OTHER 23 THING. TO WHOM WILL THESE REPORTS GO?

24 MR. DEWEY: THEY GO TO THE STAFF.

25 JUDGE LAZO: WILL THE PUBLIC OR THE FARMERS,

"^*"="r*4"4fM't.'" '"' "" L'C!,'io'a'.' ',"!  !

TELEPHONE 2794F11 l l l

3083 1

1 WEST V ALLEY PEOPLE GET COPIES OF REPORTSt -

2 MR. DEWEY: I BELlEVE YOU COMMITTED TO GIVE

() 3 THE FARMERS THE COPIES, TOO, DIDN'T YOU, OR DID YOUf 4 l'M NOT SURE.

5 MR. GEHR: N EG AT I V E. THEY HAVE N0 INTEREST --

6 i SAY THIS CANDIDLY. THEY HAVE NO INTEREST IN THE 7 MONITORING PLANT. THEY WANT TO KNOW THE WEEKLY COUNTS 1

8 0F SQUARES, BLOOMS, BOLLS, INSECTS, HUMIDITY, 9 TEMPERATURE AND YlELD.

10 JUDGE LAZO: ;10W , THAT'S ASTONISHING. YOU'RE 11 SAYING THE INTERVENORS IN THIS PROCEDURE HAVE N0 12 INTEREST IN THE RESULTS OF THE MONITORING PLANT. THE 13 ONLY INTEREST THEY HAVE IS IN TH l3 ADDITION AL MON ITORING 14 TH AT YOU'RE G0 LNG TO DO FOR $20,000 A YEAR. l 15 MR. GEHR: 1 REPEAT IT. WE HAD -- WE ARE 16 GOING INTO SOME ANCIENT H ISTORY. WE REACHED AN l

17 AGREEMENT TO EXTEND THAT PROGRAM TO WHATEVER LOCATIONS 18 THEY WANTED AND THEY TURNED THAT DOWN AND THEY FINALLY 19 CAME B ACK TO US AND S AID WE W ANT -- TH IS IS WHAT WE

)

20 WANT. WE WANT SQUARES, BLOOMS, 80LLS, MOSQUITOS --

t 21 INSECTS I SHOULD SAY, TEMPERATURES ON A WEEKLY -- THESE 22 COUNTS MADE ON A WEEKLY BASIS AND THAT'S IT.

23 JUDGE LAZO: l'LL HAVE TO READ THAT SETTLEMENT O 24 AGREEMENT AG AIN. THAT MAKES IT CLEAR THAT WHAT THEY'RE 25 INTERESTED IN IS THE ADDITIONAL --

[

5 I

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3084 1 MR. GEHR: THAT'S WHAT THEY REQUIRE. WE SAID 2 WE W ILL NOT UNDERTAKE TH AT UNL ESS WE CAN ALSO AT THE

() 3 SAME SITES DO OUR S0ll ANALYSIS, 00 OUR DUST COLLECTION 4 AND L EAF AN ALYSES.

5 JUDGE LAZO: OH, YES, ALL RIGHT. THEY WILL 6 HAVE TO ALLOW YOU ON THERE TO 00 THAT.

7 MR. GEHR: YES.

8 JUDGE LAZO: ALL RIGHT. AND THE REPORTS, 9 THEN, YOU'RE GOING TO SEND TO THE STAFF AND THE STAFF 10 ALONEY 11 MR. GEHR: WELL, THOSE STAFFS ARE PUBLIC 12 DOCUMENTS AND IF THEY WANT TO GIVE THEM TO THE FARMERS, 13 IF THEY WANT THEM, WE'LL GIVE THEM TO YOU. THEY HAVE

() 14 TOLD US UP TO NOW, WE DON'T CARE. IT'S NOT REALLY TOO 15 SURPRISING BECAUSE THEY HAVE -- YOU LOOK AT NULCHl'S 16 EXPERIMENTS UP THERE WHERE ONE AND A H ALF KILOMETERS 17 THEY COULDN'T DETECT ANY EFFECT ON SENSITIVE CORN.

18 WE'RE TALKING IN THE FARMS, THE DUST FALL A DAY 15 UP TO 19 EIGHT TO NINE POUNDS PER ACRE PER YEAR AND WE'RE TALKING 20 ABOUT ANYTHING AWAY FROM TWO MILES. WE'RE TALKING 21 THINGS THAT WE CAN'T DETECT.

22 JUDGE LAZO: IT WOULD BE OUR INTENTION TO r

23 THANK THESE WITNESSES AND RELFASE THEM THIS EVENING FROM O 24 ANY FURTHER QUESTIONING BUT BEFORE 00 LNG TH AT, I D0 WANT 25 TO ASK WHETHER EITHER OF THE PARTIES WHO ARE PRESENT

"""Eo"u# nYnI,5 EE n's'"' '"** 'N'o"dCa*Ii*o*u"Es$o's TELEh40NE 279-4711 l

J

3085 1 HAVE ANY QUESTIONS OF THESE WITNESSES IN THE FORM OF 2 FOLLOW-UP TO ANY RESPONSES THEY MAY HAVE GIVEN TO BOARD

() 3 QUESTIONS.

4 MR. GEHR: NOT OF THE BOARD BUT WHEN DR. COLE 5 STARTED QUESTIONING THIS AFTERNOON, HE STARTED WITH 6 ALFALFA REFERRING TO THE 7.4 POUNDS PER ACRE REFERENCE.

7 JUDGE COLE: YES, THE CONCLUSION ON PAGE FOUR.

8 MR. GEHR: I WANTED TO CALL YOUR ATTENTION TO 9 THE PAR AGRAPH ON PAGE 141.

10 JUDGE COLE: ONE FOUR ONE?

11 MR. GEHR: ONE FOUR ONE. THAT IS A -- l THINK 12 A MORE COMPL ETE STATEMENT OF THE EFFECT OF THE YlELD ,

13 MEASUREMENTS AS A FUNCTION OF DRlFT -- 0F THE SPRAY 14 DEPOSITIONS. THE LAST SENTENCE'0F THAT FIRST PARAGRAPH 4

15 SAYS THAT THE NOMINAL 500 POUNDS PER ACRE PER YEAR,

16 THAT'S THE 370 POUNDS EFFECTIVE, AT A YlELD NEARLY 17 IDENTICAL TO THAT OF THE CONTROLS. THAT'S THE BASIS FOR 6

18 THE STATEMENT IN THE JUSTlFICATION, FOR ELIMINATING ONE 19 0F THE JUSTlFICATIONS, FOR ELIMINATING ALFALFA YlELD 20 TERMINATIONS IS THAT WE'RE NOT ANTICIPATING ANYTHING OF 21 TH AT MAG NITUDE. WE'R2 NOT DOWN TO THE 7.4 POUNDS IN 22 OTHER WORDS.

23 JUDGE L AZO: MR. DEWEY, AGAIN, DOES STAFF H AV E l' 24 ANY QUESTIONS OF THESE WITNESSES WHICH MAY H AVE RESULTED l

25 FROM THE ANSWERS THEY GAVE TO BOARD QUESTIONSf

*** *!"u^a"r*4"4%%'n?"""** '*EI'?"Edu"l'***f TELEPHONE 2794711

3086 1 MR. DEWEY: NO, SIR, WE DON'T.

2 JUDGE LAZO: NOW, WE STILL HAVE A NUMBER OF

() 3 MATTERS WHICH WE DO HAVE TO DISCUSS. l THINK IT CAN BE 4 HANDLED THROUGH ORAL ARGUMENT BY COUNSEL IN THE MORNING.

5 THE ONLY THING l WOULD THINK ABOUT IS IF WE COME TO THE 6 QUESTION AS TO WHETHER OR NOT TH IS PRE-FILED TESTIMONY 7 SHOULD BE PUT INTO THE RECORD SOMEHOW AS AN EXHIBIT. WE 8 SHOULD HAVE AN AGREEMENT TONIGHT THAT THERE WOULD BE NO 9 OBJECTION TO THE RECElPT OF THAT EVIDENCE WITHOUT THESE 10 WITNESSES BEING PRESENT TO SPONSOR IT AT THAT TIME. IF t

11 THERE ARE NO OBJECTIONS IN THE EVENT THAT WE DO DECIDE 12 TO PUT IT INTO THE RECORD AS EXHIBITS, THEN WE CAN

{} 13 14 RELEASE THE WITNESSES. I DON'T TH INK WE SHOULD H AVE ANY '

PROBLEM, BUT THAT'S THE ONLY ONE THAT OCCURS TO ME.

15 MR. GEHR: l'VE PILED UP FOR THE REPORTER 16 THREE COPIES.

17 JUDGE LAZO: BUT WE'RE NOT G0 LNG TO NEED THE 18 WITNESSES IN THE MORNING TO MAKE CORRECTIONS TO THElR 19 TESTIMONY OR IDENTIFY THEIR QUALIFICATIONS.

20 MR. GEHR: OH, WAIT A MINUTE. YES, MR.

21 GOLDMAN REMINDS ME. HAS TWO CHARTS, MAPS SHOWING 22 LOCATIONS OF MONITORING STATIONS THAT HE WOULD LIKE TO

)

23 CORRECT.

24 JUDGE L AZO: WELL, TH AT' S WHY WE' RE ASK ING. I 25 DON'T WANT DR. GOLDMAN TO STAY OVERNIGHT TO JUST H AVE TO

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"EEvYr nI"EnEn's' '" '**'

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TELEPHONE 279 4711

i j 3087 1 COME BACK AND DO IT IN THE MORNING.

2 (DISCUSSION OFF THE RECORD.) i

'()

3 4

JUDGE LAZO:

MR. GEHR:

ARE THESE REPLACEMENTS 7 YES, THESE ARE REPLACEMENTS. IF I 5 THE BOARD PL EASE, I HAVE DISTRIBUTED REYISED COPIES OF 6 EXHlBIT G-7, G-6 AND G-7 ATTACHED FOR DR. GOLDMAN'S 4

7 TESTIMONY. THE DIFFERENCE BETWEEN THESE REYISED l 8 EXHlBITS, G-6 AND G-7, IS THE DEPICTION OF MONITORING 9 STATION NUMBER 44 WHICH HAS BEEN MOVED APPROXIMATELY 10 THREE MILES WEST OF ITS PREY 100S -- AT THE LOCATION i

11 SHOWN IN THE DOCUMENT ATTACHED TO HIS TESTIMONY.

12 DR. GOLDMAN: THE STATION HAS NOT BEEN MOVED.

i i

! 13 ITS LOCATION ON THE PRIOR DRAWING WAS ERR 0NE0US.

- () 14 MR. GEHR: YOU ASKED ABOUT ANY CHANGES IN THE i

i l 15 TESTIMONY. I WOULD LIKE TO ASK MR. WILBER ABOUT ONE l 16 ELEMENT OF DEGRADATION AND THE IMPACT OF THE MATERIALS

} 17 THAT ARE USED.. DOES THAT AFFECT THE DEGRADATIONT HE l I

i 18 WOULD H AVE ADDED THIS AT PAGE 10 0F HIS TESTIMONY. THE

{ 19 END OF ANSWER -- T0 QUESTION 18. l l \

! 20 MR. WILBER: THE QUESTION TH AT MR. GEHR l$

, 21 REFERRING TO HAS TO D0 WITH THE POTENTIAL FOR ACID TO j i i J

22 ATTACK THE PVC DRIFT ELIMINATOR. IN THE PVC IS USED To

I 23 CONVEY A NUMBER OF DIFFERENT ACIDS FOR VARIOUS  ;

' () 24 PROCESSES. I PROBABLY OVERESTIMATE THE POTENTIAL FOR l

j i

25 $UCH ACID CONCENTRATIONS THAT MAY EXIST IN THE C00 LING  !

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3088 1 TOWER HAVE ANY IMPACT AND I WOULD SUGGEST TH AT FOR ANY 2 0F THE REMOTE TEST -- ANY OF THE MOST REMOTE

() 3 CONCENTRATION -- CONCENTRATIONS OF ACIDS THAT MAY EXIST 4 IN THIS COOLING TOWER CIRCUlT, THAT IT WOULD HAVE NO 5 EFFECT ON THE PVC DRIFT ELIMINATORS.

6 MR. GEHR: THOSE ARE ALL THE CHANGES THAT WE 7 WANTED TO IDENTIFY.

8 JUDGE L AZO: FINE. THANK YOU. MR. DEWEY, DO 9 YOU HAVE ANY ADDITIONS OR CORRECTIONS TO YOUR WITNESS'S to TESTIMONY 7 i

11 MR. DEWEY: NO, SlR. OUR TESTIMONY REMAINS 12 INTACT AND AS IS.

13 JUDGE L AZO: THANK Yuu. WE'LL AGAIN -- WE'LL I

() 14 PLAN --

15 MR. GEHR: MAYBE THIS IS OFF THE RECORD.

16 WELL, OKAY.

17 JUDGE LAZ0: L ET' S PUT IT ON THE RECORD.

18 MR. GEHR: OKAY. WE HEARD SOME RUMORS --

19 JUDGE LAZO: I DON'T CARE.

20 MR. GEHR: WE HEARD SOME RUMORS THAT ALL OF 21 YOU OR SOME OF YOU MIGHT L IKE TO G0 OUT TO SEE THE PALO 22 VERDE SITE AND SEE THE C0OLING TOWERS OR SEE WHATEVER.

23 IF -- WE ARE UNDER -- AT LEAST A PORTION OF THE SITE IS O 24 UNDER VERY TIGHT SECURITY, UNIT 1 AREA IN PARTICULAR.

25 8UT IF YOU WANT TO GO QUT THERE, WE OUGHT TO START

      • "!Eu^nYa's"SIEn's '"** ***Ed*[4nIi*o*NT'e$o's TELEPHONE 37947:1

)

3089 1 MAKING ARRANGEMENTS.

2 JUDGE LAZO: WELL, I THINK YOU DID HEAR AT

() 3 LEAST ONE AND POSSIBLY TWO MEMBERS OF THIS LICENSING 4 BOARD INDICATE THAT ENGINEERS LIKE TO PUT THEIR HANDS ON 5 THINGS. l THINK THAT WAS -- THEY PROBABLY MEAN JUST 6 HAVE A LOOK.

7 MR. GEHR: YES. WE'RE INYITING YOU.

8 JUDGE LAZO: AND SINCE WE WOULD BE YOUR 9 GUESTS, WE WILL INYITE YOU TO INDICATE WHEN WOULD BE A 10 GOOD TIME. IT COULD BE TOMORROW AFTERNOON OR THURSDAY 11 MORNING, MAYBE IN THE C00L OF THE MORNING MIGHT BE 12 $ PREFERABLE. BUT, YES, i"THINK THERE IS A CONCENSUS ON 13 THIS LICENSING BOARD THAT WE WOULD LIKE TO SEE THE

)

14 C00' LING TOWERS, MECHANICAL COOLING TOWERS. I DON'T KNOW 15 !F YOU CAN SEE A GALL 10NELLA INFESTATION.

16 MR. GEHR: 1 HOPE NOT.

17 MR. GEHR: AS FAR AS COMFORT IS CONCERNED, i 18 CAN ASSURE YOU THAT THE MORE COMFORT -- THE EARLIER THE 19 BETTER. WHEN YOU GET INSIDE THE COOLING TOWER, IT 20 DOESN'T MAKE ANY DIFFERENCE. IT'S HUMID AND IT'S COOL.

21 JUDGE LAZO: WELL, I DON'T REALLY THINK WE'LL 22 REQUIRE ALL DAY TOMORROW TO H AVE OUR ORAL ARGUMENT AND 23 REACH SOME DECISIONS ON HOW WE'RE G0 LNG TO CONCLUDE THIS 24 PROCEEDING, BY WHAT MANNER IT SHOULD BE CONCLUDED; BUT 25 EARLY MORNING THURSDAY MIGHT BE A BETTER TIME TO SEE THE

  • ^**&^#4"40 't.'* *- 20 ',?o'r.* 'i.

TELEPHONE 2794711 l

f I 3090 1 COOLING TOWERS.

2 MR. GEHR: I SHOULD HAVE -- WHEN I MADE AN 3 APPEARANCE, 1 SHOULD HAVE MADE NOTE OF THE FACT THAT MR.

(])

4 ED V AN B RUNT, EXECUTIVE V ICE-PRES IDENT NOW OF APS, THE 5 ARIZONA NUCLEAR POWER PROJECT, HAS BEEN WITH US ALL DAY 6 TODAY.

7 JUDGE LAZO: MR. VAN BRUNT IS AN EXCELLENT 8 WITNESS AND WE ARE ALL AW ARE OF WHO HE IS.

9 REGARDING THE MORNING, THEN, I DO WANT TO 10 THANK ALL OF THESE GENTL EMEN. WE VERY MUCH APPRECIATE 11 YOUR COMING AND YOU ARE DISMISSED AS FAR AS WITNESSES 12 ARE CONCERNED. SHALL WE SAY 10:00 A.M. TOMORROW HERE7 13 MR. GEHR: THAT'S FINE.

)

14 JUDGE LAZO: YERY WELL, WE'RE ADJOURNED UNTIL 15 10:00 A.M. TOMORROW MORNING.

16 17 (ADJOURNED AT 5:13 P.M.)

18 19

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20 21

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23 24 25

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      • "Eo"u"Er nEEn"Itn's'""*' 'N'o"dCEIr"ON O O14 TELEPHONE 279-4711 I

I 1 CERTIFICATE OF OFFICIAL REPORTER 2

,m (j 3 THIS IS TO CERTIFY THAT THE ATTACHED PROCEEDINGS BEFORE 4 THE UNITED STATES NUCLEAR REGULATORY COMMISSION IN THE 5 MATTER OF:

6 7 NAME OF PROCEEDING: OPERATING LICENSE PROCEEDING 8 ARIZONA PUBLIC SERVICE COMPANY, ET AL 9 PALO VERDE NUCLEAR GENERATING STATION ,

10 UNITS 2 & 3 11 12 DOCKET NO.: STN-50-529-OL 7_s 13 STN-50-530-OL bc )

14 15 PLACE: PHOENIX, AR 16 17 DATE: TUESDAY, JUNE 11, 1985 18 19 WERE HELD AS HEREIN APPEARS, AND THAT THIS IS THE ORIGINAL 20 TRANSCRIPT THEREOF FOR THE F IL E OF THE UNITED STATES 21 NUCLEAR REGULATORY COMMISION.

23 ----. . N---- , M ._ #Alle i )

'J 24 KATHRYN h. HOWARD/ ELAINE M. SENICK 25 THACKER & GREENFIELD, INC.

n COU 47 REP R R5 P 40 Rlh0N 85014 TELEPHONE 279 4714 h

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