ML20134P048

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Joint Applicant Exhibit A-2,consisting of Undated Testimony of Mi Goldman Re Effects of Foliar Depositions from Cooling Tower Drift.Supporting Documentation Encl
ML20134P048
Person / Time
Site: Palo Verde Arizona Public Service icon.png
Issue date: 06/12/1985
From: Goldman M
NUS CORP.
To:
References
OL-A-002, OL-A-2, NUDOCS 8509060120
Download: ML20134P048 (41)


Text

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$g . Jf 6 s>-  : w-fo 43D o L 0{t3ldT 00CMETED U3Nac UNITED STATES OF AMERICA - ~85 SEp -4 A8 US -

NUCLEAR REGULATORY COMMISSION CFFf..cE,cr IECD 9

...:9(g BEFORE THE ATOMIC SAFETY AND LICENSING BOARD'"C" In the Matter of: ) Docket Nos. STN 50-529

)

Arizona Public. Service ) STN 50-530 Company, et'al. )

)

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(Palo Verde Nuclear )

Generating Station, )

Units 2 and 3) )

)

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TESTIMONY OF DR. MORTON I. GOLDMAN IDENTIFICATION AND QUALIFICATIONS.

1. Q. Please state your name and address.

A. My name is Morton 1. Goldman and my address is 910 Clopper Road, Gaithersburg, Maryland,20878.

2. Q. By whom are you employed and in what_ capacity?'

A. I am employed by NUS Corporatiog in Gaithersburg, i s- <

Maryland in the position of ' Senior Vices President i lls '

? - -

and Technical Director. >

N^ y ,/,

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3. Q.

To what extent have you' been, involved'in the' Palo l 7 )

./

Verde project?  ! / , f, .@rr 1 , e . i i A. NUS was engaged in mid-1972?t,o. conduct g a si'te se-lection study for the Arizon/ ' c' .' /

acNuclearfPower Project

/{t 9-8509060120 850612

(ANPP) and I was the officer assigned by NUS to manage this work. I was intimately involved in all aspects of this study, including the formulation of site evaluation criteria, the selection of regions and sub-regions in Arizona to be evaluated, the data collection, including work required to obtain data, and the evaluation of more than 6 potential sites. The result of these efforts was the selec-tion of the site where the Palo Verde Nuclear Gen-erating Station (PVNGS) is now located.

Subsequently, NUS was given the responsibility for the development and preparation of the PVNGS Environmental Report -

Construction Permit Stage (ER-CP) and the PVNGS Environmental Report - Oper-ating License Stage (ER-OL), and I was the officer of NUS responsible for directing this work. In this connection I was one of applicant's witnesses on environmental matters, including questions re-lating to drift depositions, in the PVNGS construc-tion permit hearings conducted in February, 1976.

4. Q. To what extent have you been involved in the pro-ceedings now pending on
  • issues raised by the inter-venors on the effects of foliar depositions from i

drift from the PVNGS cooling towers?

A. I have served as a consultant on these matters. In that :onnection I have advised on the taska. which

)

should be undertaken to resnond to the concerns raised by the intervenors, the scope of such tasks and the selection of other consultants, including Environmental Systems Corporation (ESC), Dr. Wil-liam Dunn and the agronomists designated as the Review Board. Additionally, I participated in the review, and gave advice on the content and scope, of the proposal of the University of Arizona (UofA) to conduct greenhouse and field agricultural stud-les and attended most of the meetings of the Review Board. Also, NUS provided an expert in QA/QC mat-ters to assist, under my direction, the UofA in the preparation of procedures to assure the proper doc-umentation of the work undertaken in the UofA agri-cultural study.

I was also responsible for all of the work done in validating the NUS FOG, computer model and in developing the current predictions of drift dep-osition from the TVNGS cooling towers which is the main subject of this testimony.

5. Q. Please describe your educational and professional background and experience.

A. I have prepared Exhibit G-1 attached to this testi-mony which summarizes my educational and profes-sional background and experience and submit this exhibit in response to the question.

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P_URPOSE AND

SUMMARY

OF THE TESTIMONY

6. Q. Would you please describe the purpose and summarize the scope of your testimony.

A. The objectives of this testimony are (a) to present to the Board currently predicted drift deposition rates in the vicinity of PVNGS based on the most recent information about the nature and rate of emission of drift from the PVNGS cooling towers and other miscellaneous sources and (b) to describe the salt drift monitoring program. This information should be of assistance to the Board in judging the significance of the drift as a potential source of injury to crops grown in the vicinity of the plant.

The testimony reviews the drift projections made over the history of the project in the ER-CP and ER OL; nummarizes the independent review and validation of the NUS FOG computer model used to make the drift deposition estimates presented in those documents; describes the significance of the drift droplet size spectrum used in the modelling efforts and presents the spectrum resulting from '

the tests made in 1983 on one of the PVNGS towers as used in the current projections of drift deposi-tion; summarizes the drift rate determinations made on the PVNGS tower and compares them to the vendor guarantee; and provides the most current l

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, projections of drift deposition from PVNGS using the FOG model and one developed for the Electric Power Research Institute (EPRI).

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EARLIER DEPOSITION ESTIMATES

7. O, Please describe the basis and methodology used in developing the drift deposition rates reported in j the ER-CP.

A. The ER-CP presented estimates of cooling tower drift emissions and deposition patterns based on assumed cooling tower design characteristics. Since at the time the ER-CP was filed in 1974, the type of cooling towers to be used at PVNGS had not been 1

l established, the use of such assumptions was un-i' avoidable. Of the several alternative types of cooling towers discussed in the ER-CP, the alterna-tive selected and assumed for the purpose of drift analyses consisted of three rectangular mechanical draft towers per unit, each.containing 14 cells, with a drift loss rate of about 25C gallons per minute. With a circulating water flow rate of l

620,000 gpm, this represented a drift loss rate of 0.04% [1]. The concentration of dissolved solids in the circulating water system (and the drift) was estimated to be 14,600 ppm [2]. These assumed de-sign characteristics were selected because at the l

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, _ , -. . _ . _ . . - . . D

time we considered that they could be met or im-4 proved upon with any reasonable alternative ulti-mately selected.

Starting then with such assumed design charac-teristics the drift deposition estimates presented in the ER-CP for both onsite and offsite areas [3]

were developed using Gila Bend weather data and a droplet size spectrum provided by Research-Cottrell

[4). These estimates suggested that perhaps 130 acres of cultivated land might receive wet drift deposition at or above 50 pounds per acre-year and 3,850 acres would be subject to a total wet and dry drift particle deposition in excess of that value

[5].

8. Q. Were these estimates subsequently revised?

. A. Yes. During the ASLB hearing on the construction permit, evidence was introduced regarding the char-acteristics of and drift predictions for the round mechanical draft cooling tower design parameters selected for the plant [6). The contract to pur-chase such towers, including their specifications, was signed only the week before the hearing (7).

These towers were one of the alternatives evaluated in the ER-CP [8), although with somewhat different i

operating parameters. The drift evaluations pre-sented in the hearing were based on a drift rate per unit of about 26 gpm or 0.0044% of the circu-lating water flow as guaranteed by the cooling tow-er vendor and a circulating water dissolved solids t

concentration of 16,000 ppm. The drift deposition patterns resulting from the new designs indicated no depositions offsite in excess of about 12 pounds per acre-year. Again, offsite meteorological data and the Research-Cottrell droplet size spectrum was used in the modelling effort.

The ER-OL largely repeated the same analysis i as that performed for the CP hearing; a major dif-ference involved the use of 5 years of onsite (PVNGS) meteorological data supplemented by Phoenix upper air data from the National Weather Service.

In addition, a relatively slight change was made in the circulating water dissolved solids concentra-tion from 16,000 to 15,000 ppm, despite a somewhat lower estimate of 12,000 ppm in the ER-OL [9] . The drift rate remained at about 26 gpm per unit, or 0.0044% of the circulating water flow and the drop-let size spectrum was unchanged from that used ear-lier. The resulting deposition patterns were l presented in the ER-OL [10), and again indicated maximum total deposition at the northeast corner of the site to be about 12 pounds per acre-year.

COMPUTER MODEL VALIDATION

9. Q. Would you please describe the work which was under-taken by NUS to validate the NUS FOG computer model?

A. As a result of the allegations by West Valley of inadequacies in the computer code (FOG) used by NUS to predict the drift depotition at PVNGS, NUS re-

! tained an independent consultant to evaluate that I

code. The consultant selected was Dr. William Dunn, Champaign, Illinois, who was co-author of a report of an earlier study of matheraatical models for evaluating cooling tower salt drift deposition performed for the NRC [11), and was a principal contributor to the development of the most current computer models for prediction of cooling tower plume and drift behavior on behalf of EPRI [12].

The report on his evaluation of the FCG model [13) was provided to the parties on August 24, 1983 i

shortly after its receipt by the Applicant. I I

In summary, Dr. Dunn compared (a) the episodal predictions of FOG routines with the experimental field data collected during the Chalk Point Cooling Tower Project, as well as with the predictions of 11 other drift deposition models which had been evaluated in the earlier NRC-sponsored study; (b) the episodal predictions of FOG with field data i

from the Pittsburg (California) study, as well as with the predictions of the EPRI model for those conditions; and (c) the seasonal / annual predictions of the FOG model for PVNGS with those of the EPRI model. With respect to (a) and (b), Dr. Dunn wrote: "The results of the Chalk Point Study re-vealed that for these limited data, the FOG model fell into a category of six out of twelve models which could t!e classified as 'better performing'.

The results of the Pittsburg comparison were incon-clusive due to limitations inherent in the measured data, although both the FOG and EPRI models gave reasonable predictions, in a subjective sense."

The evaluation of the FOG model and its com-parison with the EPRI model for the PVNGS cooling towers included determining the effects on drift l deposition patterns of using three different speci-fications of the drift droplet size spectrum which were provided to Dr. Dunn. The first of these was the spectrum as provided by Research-Cottrell (re-ferred to as FOG 73), divided into five size class-es, or bins, and used in all of the ER evaluations for PVNGS beginning in 1973. The second and third specifications we3e both representative of one droplet size spectrum (referred to as FOG 81) but subdivided that spectrum in one instance into 10

_g.

bins and in the other, into 38 bins. The latter spectrum was the default spectrum (i.e., a droplet size distribution to be used in the absence of tower-specific data) adopted by NUS in 1981 based on an evaluation of the technical literature on cooling tower drift studien, although it was not used for t' us evaluations reported in the ER-OL which was filed in 1979. These droplet speqtra are presented in Exhibit G-2 attached to this testimony.

With respect to the comparison of theipredic-tions of the FOG and EPRI nodels for PVNGs, Dr. ,.

Dunn wrote: "The comparison of the seasonal / annual predictions using the Palo Verde site data indicat-ed that the FOG and EPRI models gave similar pre-dictions for two drop spectra with appreciable I i

fractions of large drops. For a third spectra de-void of larger drops, the predictions were qualita-tively different although of similar magnitude in the offsite areas. Overall, the comparisons were remarkably similar in light of the major difference between the methodologies of the two models. The sensitivity studies revealed that model performance is degraded as the detail of the input data is re-duced and that predictions are affected by the choice of user-selected model parameters."

s PVNGS DRIFT DROPLET SIZE SPECTRUM

10. Q. What other conclusions can be drawn from the Dunn study?

A. Findings of major significance in Dr. Dunn's evalu-ation, apart from the validation of drift deposi-tion segment of the FOG model, were the importance to the resulting patterns of drift deposition of both (a) the drift droplet size spectrum and (b) the number of bins into which that spectrum was divided. The significance of those effects are clearly represented in Figures 13 through 18 of the Dunn Report for both the EPRI and the FOG models which figures are attached to this testimony as Exhibits G-3a through G-3f. These figures show that there is a significant difference between the patterns predicted (by either model) based on the 5-bin FOG 73 droplet spectrum and those predicted with either the 10-bin or 38-bin FOG 81 spectrum.

i Further, although the patterns are similar (for I

either model) between the lO-bin and 38-bin spec-tra, the latter does provide a somewhat more uni-form distribution. I t. seems clear at this point that the S-bin spectrum did not produce deposition patterns which would represent those to be expected from the PVNGS towers.

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. i CURRENT PVNGS DRIFT DEPOSITION PREDICTIONS

11. Q. Since the ER-OL was prepared, have any more current evaluations been made of predicted drift deposi-tions, and if so, would you please describe them

! and provide the parameters.

A. Twe independent evaluations of drift deposition patterns were made within the past 2 years using the most directly applicable information currently available. One was performed by Dr. Dunn using the EPRI model, and the other by NUS using the FOG mod-el. In both instances the input parameters were identical: 5 years of PVNGS site meteorological data (a prior examination had indicated that using nine years of available meteorological data added nothing to the precision of the results while near-ly doubling the cost of the computer runs); the PVNGS tower performance characteristics, including the measured drift rate and a 16-bin droplet spec-trum discussed below; and, a circulating water con-centration of 12,000 ppm as presented in the ER-OL f9].

12. Q. You have explained why 5 years of meteorological data was selected. Would you also explain the bas-i es for the other two parameters that were used in
these current predictions?

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A. The earlier predictions reported in the i

construction permit hearings and subsequently in the ER-OL were both developed using the vendor's guaranteed drift rate of 0.0044% of the circulating water flow and the 5-bin droplet size spectrum.

Because the intervenors originally challenged the validity of basing predictions on the unveri-fled vendor's guarantee, APS engaged Environmental Systems Corporation (ESC) to make measurements of the actual drift emissions from the operation of one of the PVNGS cooling towers. This work was completed by ESC in 1983 and the report of the mea-

! surements has been given to the Board and the other 4

parties. Mr. Wilber's testimony fully describes the manner in which such measurements were made and the results. However, for purposes of my testimo-ny , ESC measurements show that the actual drift rate at PVNGS is substantially lower than the guar-anteed rate, measured by either of the two tech-niques used. The first technique employed direct liquid measurements using Sensitive Paper devices; the second involved mineral flux measurements using an isokinetic sampler from which drift rates were inferred. The direct measurement technique indi-cated a drift rate of 0.0002%, whereas the inferred technique indicated a drift rate of 0.0012%. In

view of the judgment by Mr. Wilber, [15] that the inferred drift rate based on the mineral flux mea-surement is conservative due to the occurrence in the ambient air during the test periods of the mag-nesium used as a tracer for the mineral flux, the drift rate based on direct liquid measurements, 0.0002%, was adopted as the most reasonable value for use in subsequent drift deposition predictions.

With respect to the use of the 16-bin spec-trum, the work performed by Dunn deme- trated the importance of both the spectrum of droplet sizes selected and the degree of subdivision of that spectrum used as input to the predictive model.

Consequently, in the recent deposition predictions, the droplet size spectrum determined in the studies of the PVNGS tower by ESC [14) was divided into 16 bins. This value represents a compromise between the slightly degraded precision of estimates ob-tained with 10 bins as compared to 38 bins, and the considerably longer computer running time (and cost) associated with the greater number of bins.

In my opinion the use of 38 bins would not have changed the predictions significantly. The PVNGS spectrum and its 16-bjn representation as used in subsequent drift deposition modelling are also shown in Exhibit G-2 attached to this testimony.

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13. Q. What are the current predictions of drif t deposi-tions from the operation of the Palo Verde cooling towers?

A. The results of these analyses are presented graphi-cally in the attached Exhibits G-4 and G-5 for the FOG and EPRI models, respectively. In each of these figures the contours represent annual average deposition rates in units of pounds per acre-year.

It can be noted that the patterns of deposition predicted by each of these models are quite simi-lar, and the magnitude of the deposition predic-tions agree within about a factor of two, with the FOG model being the more conservative, i.e., high-er, of the two.

The maximum deposition is predicted (by both models) to occur at the nearest site boundary to the west of Unit 2, and to approximate 60 pounds per acre-year. The maximum drift deposition pre-dicted at the nearest point of the cultivated land closest to the cooling towers, about 1.25 miles northwest of the Unit 2 towers, is predicted to range between 1.5 (EPRI) and 3 (FOG) pounds per acre per year.

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l OTHER POTENTIAL SOURCES OF DRIFT

14. Q. What is your evaluation of other potential sources of drift originally raised by the inte rvenors, specifically the spray ponds and evaporation ponds?

A. Drift from the spray ponds can occur only when they operate as heat sinks during periods when units are shut down and the cooling towers are not operating.

The liquid drift rate from the spray ponds is about 27 gpm, and the circulating water dissolved solids concentration is about 357 ppm [16). Since the guaranteed cooling tower liquid drift rate is about the same value (26 gpm) but the circulating water dissolved solids content is about 12,000 ppm, the emission rate of mineral salts in drift droplets during the infrequent periods of spray pond opera-tion is only about 3% of that for the towers. Fur-ther, the spray pond droplet size distribution is much more weighted toward large diameter droplets (98% of the spray volume is contained in droplets with diameters greater than 600 microns) than is the cooling tower drift, and the maximum height of the pond sprays is only about 12 feet above the nozzles [17); thus, there is little likelihood of any drift being carried offsite.

In any event, basing offsite drift deposition predictions on the operation of the units at full

power 100% of the time with cooling tower drift 30 4

times richer in salt content produces a more con-servative result than the alternative assumption of 11 months of cooling tower operation and 1 month of spray pond operation.

The evaporation ponds will not be a source of windborne dust since the sum of the liquid dis-charged to the (approximately) 250 acre first-phase i evaporation pond [18] from the plant systems at a 1

plant capacity of 60% or more (2870 acre-feet per year) [19] and the natural precipitation (125 v

acre-feet per 6 inches per year) [20] will be greater than the natural evaporation rate of 1600 acre-feet per year [21]. As this pond fills, addi-tional ponds will be placed in service, but except for the very beginning of pond service, there will not be a ' dry' bottom capable of being eroded by wind forces. Thus, the evaporation ponds are not capable of adding in any significant way to the drift released from the operation of the cooling towers and, hence, to the offsite deposition of such materials.

CONCLUSIONS RESPECTING PREDICTED DRIFT DEPOSITIONS

15. Q. Would you please summarize the conclusions you have reached?

A. In summary, the FOG computer model used by NUS to 4

predict the deposition pattern of drift emitted by the cooling towers at PVNGS has been validated by an independent evaluation of the code's ability to match experimental field data, and by comparison with the prediction of a current state-of-the-art (EPRI) computer code. Site specific data on mete-orology, tower drift rate and droplet size spectra have been used as input to the FOG code and the i EPRI code, and the predictions of these two codes agree well as to the shape and the magnitude of drift deposition patterns. There are no other sources of ' salt' drift on the PVNGS site which are i

expected to contribute to offsite drift deposition.

For perspective, it can be noted that monitor-ing of deposition in the vicinity of the PVNGS over the period May 1983 - June 1984 has indicated aver-age cumulative deposition values for sodium, potas-sium, calcium and magnesium at monitoring stations I

on cultivated lands of about 9, 10, 25 and 7 pounds per acre, respectively. [22] These can be com-pared to predicted deposition values from 3 unit tower operation at the nearest farm of 0.8, 0.05,

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O.1 and 0.04 pounds per acre-year, for the same ions, respectively, i

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4 SALT DRIFT MONITORING PROGRAM

16. Q. Would you please describe the plan which is cur-rently in effect for monitoring drift from the Palo Verde cooling towers?

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16. A. The program currently in effect for monitoring the deposition of drift from the PVNGS cooling towers is substantially the same as that described in the

" Salt Deposition and Impact Monitoring Plan" dated ,

February 1983 which was forwarded to the Board and the parties in March 1983. The program generally consists of seven elements:

a. Measurement of monthly deposition of ions and total suspended solids from wet and dry particulates at 44 sites using ASTM dustfall
jars;
b. Measurement of soil chemical parameters potentially affected by drift deposition at 44 sites twice per year (July-August and February-March) and, at 13 sites of the 44 which are located on cultivated lands, a third sampling after cotton defoliation;
c. Semi-annual sampling of indigenous vegeta-tion and analyses of species richness and rel-ative cover as well as measurements of tissue  ;

l loading of drift constituents at six locations; l t

d. sampling of crops grown at the 13 agricul-tural monitoring locations twice during the growing season for measurements of tissue loading and for cotton yield at the end of the growing season;
e. Infrared aerial photography of crops and native vegetation within a five mile radius of PVNGS during the peak vegetative growth season to detect and document vegetative stresses of any origin, then confirmed by field inspection; i
f. Airborne salt measurement by chemical ana-lyses of monthly composites of filters from six low-volume air particulate samplers used as part of the radiological monitoring pro-gram; and
g. Quarterly sampling and analyses of cooling tower basin water to confirm the chemical com-position of the drift emissions.

Samples collected in the field are for-warded to selected laboratories for analyses of constituents expected to be prominent in the drift from the PVNGS towers (see ER-OL Table 3.6-1) which include sodium, calcium, magnesium, potassium, chloride, sulfate and ,

nitrate.

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l In addition to these measurements for the salt drift monitoring program, meteorological data from the PVNGS meteorological tower are ana-lyzed specifically for this program to compare the deposition patterns expected to result from plant operations with those determined from field measurements.

Dustfall and soils are sampled at all loca-tions which are shown in the attached Exhibit G-6; the locations of the native vegetation and crop sampling sites are shown in the at-tached Exhibit G-7. Both Exhibits are taken I

from current version (Revision 4) of the " Salt Deposition and Impact Monitoring Plan," dated May, 1985.

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17. Q. How is the monitoring data reported?

A. Reports of data covering a calendar quarter are provided as soon as analytical results have been received from the laboratories, reviewed for con-sistency and converted to values related to the context of the samples represented (e.g., ion con-centrations in dustfall jar water samples must be converted to deposition rates per unit area) . An-nual reports are prepared which include evaluations of the data relative to plant operations and pre-dictions based on meteorological parameters during 1

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a the reporting period, as well as analyses of any changes from the baseline data collected during the preoperational period, or other prior operational periods.

18. Q. Is the program you have described any different from that which was distributed to the Board and the parties on March 28, 1983, and, if so, please explain the differences?

A. As stated earlier, the program is essentially the same as that described in the program plan referred to, although a number of relatively minor modifica-tions have been made over the past two years based on experiences in the field:

a. Site 5 was subject to a grass-fire that destroyed the native vegetation community be-ing monitored and was replaced by another of the same type of vegetative community as con-trol site at location 44;
b. Soil sampling protocol was modified to separate the 12 inch soil cores into upper and lower segments (equal segments in the case of i l

agricultural soils, and based on the depth to a textural change for uncultivated soils), to provide a greater sensitivity to surficial deposition and permit detection of any verti-cal migration of salts; l

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c. At each location, sampled soils were ini-tially characterized by textural analyses, and a third sampling period was added at cultivat-ed sites following the defoliation of cotton fields;
d. A f r.s locations were shifted due to changes in access or land uses which made maintenance of those sites either impossible or the results of dubious value to the pro-gram. For example, at one agricultural site, the monitoring site access was precluded by the addition of fencing to control cattle; at another, collectors were washed away by a flash flood; at others the sample sites were moved to escape contributions of traffic- and field-generated dustfall so great as to over-whelm any other source; l
e. Aerial infrared photography was performed i

twice in 1983 several months apart and was i returned to once per annum for 1984 and subse-quent years because of the lack of distinction between the results in 1983.

f. Foliar deposition monitoring (i.e., leaf rinsate and leaf area measurements) has been discontinued effective with the 1985 crop sam-pling season. These samples, taken twice l

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during the 200+ day growing season in both 1983 and 1984, are not representative, being

, affected both by the weather and by nearby agricultural machinery operations in the peri-od immediately prior to sampling.

All of these changes have been incorporated in Revision 4 of the Salt Deposition and Impact Monitoring Plan, dated May, 1985.

19. Q. When was this program placed into effect?

A. Sampling was begun in May of 1983.

20. Q. How is this program dealt with in the operating license for PVNGS Unit l?

A. The Facility Operating License (No. NPF-34) for PVNGS, Unit 1 includes an Environmental Protection Plan (Non-Radiological) as Appendix B which, in Section 4.2.2 Terrestrial Ecology Monitoring, re-quires that the monitoring program commence by the onset of commercial operation and that it continue for a minimum of three full years after the onset of operation of all three PVNGS Units, or until the licensees can demonstrate that program objectives have been fulfilled.

The Environmental Protection Plan also requires that procedures affecting program objectives re-quire prior NRC approval. Other changes require notification of the NRC within 30 days after their

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implementation. Annual monitoring reports are re-quired to be submitted to the NRC for review.

21. Q. In your opinion is this program adequate for de-tecting cooling tower drift in the environment and effects, if any, on agricultural crops?

i A. In my opinion this program will detect cooling tow-

er drift in the environment at levels below those

] currently measured from sources other than PVNGS J

operations, as well as effects, if any, attribut-i j able to that drift on agricultural crops.

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I REFERENCES

1. Environmental Report CP Stage, Table 3.4-1
2. Ibid, Table 3.6-1
3. Ibid, Figures 5.1-14 to 5.1-19
4. Lefevre, M.R., Hamon Cooling Tower Division, Research Cottrell to NUS Corp, July 1971
5. ER-CP, Table 5.4-1
6. CP Hearing Transcript pp. 788-789, 1047-1049
7. 428
8. ER-CP, Section 10.1
9. ER-OL, Table 3.6-1
10. Ibid, Figures 5.1-2 through 5.1-4 for dry particle, wet droplet and total drift deposition, respectively
11. A. J. Policastro, W. E. Dunn, M.L. Breig and J.P.

Ziebarth, " Evaluation of Mathematical Models for Charac-terizing Plume Behavior from Cooling Towers. Volume 2.

Salt Drift from Natural Draft Cooling Towers",

NUREG/CR-1581. Vol. 2, U.S. NRC, 1980

12. W. E. Dunn, et al, " Studies on Mathematical Models for Characterizing Plume and Drift Behavior from Cooling Towers", Report CS-1683, Electric Power Research Insti-tute 1981.

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13. W. E. Dunn, " Evaluation of NUS/ FOG Computer Model for Predicting Cooling Tower Drift Deposition Rates", l prepared for NUS Corporation, July 15, 1983
14. Environmental Systems Corporation, " Development of a Drift Source Term - Palo Verde Nuclear Power Plant Cir-cular Mechanical Draft Cooling Tower", Report No. TIN 83-1082, July 1983
15. Wilber, K. R., Vice President, ESC, letter of July 11, 1983 to Dr. Mort Goldman, NUS Corporation
16. ER-OL, Table 3.4-4 and Figure 3.3-1
17. Shah, Arvind M. , " Droplet Size Spectrum Tests Report For: SPRACO Type 1751, The Spray Pond Cooling Nozzle",

SPRACO Inc., New Hampshire, undated

18. ER-OL, Section 3.6.3.1
19. Ibid, Figure 3.3-1
20. Ibid, Table 2.3-19  ;
21. C. R. Smith, R. M. White, W. C. Jacobs,'" Weather Atlas of the United States," U.S. Dept. of Commerce, reprinted s 1975 by Gale Research Company, Book Tower, Detroit, Michigan
22. " Annual Report for'the'PVNGS Salt Deposition Monitoring Program, May 1983- June 1984", Table 52, NUS-4683, NUS Corporation, March, 1985

Exhibit G-1 MORTON I. GOLDMAN N SENIOR VICE PRESIDENT TECHNICAL DIRECTOR s

EDUCATION Massachusetts Institute of Technology, Sc.D., 1960 M.S., Nuclear Engineering, 1958 M.S., Sanitary Engineering, 1950 New York University, B.S., Civil Engineering, 1948 REGISTRATION Professional Engineer: South Carolina, 1982; California, 1977; Arizona, 1974; Maryland, 1972; District of Columbia, 1965; New York, 1955 EXPERIENCE Since 1961 with NUS Corporation in a series of positions from Technical Associate to Senior Vice President, Environmental Systems Group, involved with performing and managing work in safety and environw:ntal areas, including site selection and evaluation, safety analyses for commercial, military and aerospace nuclear applications, waste management systems evaluations, environmental assessments and impact analyses for nuclear and fossil-fueled power plants and industrial facilities. Currently Technical Director of NUS, responsible for auditing and guiding the Corporation's technical capabilities, serving as senior corporate spokesman on environmental and nuclear safety issues, and providing senior level consul +.ing and project direction for selected clients.

Earlier assignments, apart from management of a large number of site selection / environmental rer.>rt/ lice:nsing support activities, included, in 1968, serving as U.S. representative to, and chairman of an IAEA expert panel on Radioactive Waste Management at Nuclear Power Plants, resulting in IAEA Safety Series No. 28 of that title; from 1972 to 1975, serving at consultant to and witness for the Consolidated Utility Group in the W /NRC rulemaking hearing on "as low as practicable" radioactise waste disenarge stant.ards ; from 1975 to 1977 as consultant to and witness for ,

l the GESMO Utility Group party to those proceedings; from 1979 through l 1982, expert witness for Duke Power Co. on the Table S-3 radon issue in the Perkins proceeding ard subsequently for a consolidated utility group on its appeal. In adoition, has appeared as an expert witness on environmental issues in more than two dozen administrative proceediras for nuclear and non-nuclear power plants, including cooling tower impact issues for the Trojan, Davis Besse, Perry and Palo Verde Generating Stations. -

Current assignments include oversight of cooling tower impact predictions, crop studies and drift deposition monitoring programs for the PVNGS; cooling tower impact predictions for the Vogtle Electric Generating Plant; and NUS COAPCAATION

~

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l l '

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Norton I. Goldman Page Two direction of the NUS Savannah River Center programs in support of thc DOE-Savannah River Operations Office, including determining the feasibility and impacts of alternative cooling systems for production reactors and steam plants, review and evaluation of present ande proposed hazardous and radioactive waste management systems and techniques, and assistance in planning and conduct of emergency preparedness exercises.

Other activities include chairman, Atomic Industrial Forum Ad Hoc Committee on the Clean Air Act and member of Steering Group, AIF Committee on Environment; member Standards Committee ANS-2 " Site Evaluation"; and member and former chairman, Nuclear Effects Committee, Environment.al Engineering Division, ASCE.

Before joining NUS Corporation, served for 11 years with U.S. Public Health Service, Division of Radiological Health, in a variety of assignments, including serving as training instructors conducting research on disposal of radioactive wastes at ORNL and at MIT; participating in working group responsible for radioactivity standards in 19EO USPHS Drinking Water i Standards; and providing technical consultation and assistance to state and federal agencies on health and safety problems of nuclear facilities.

MEMBERSHIPS American Society of Civil Engineers American Nuclear Society American Academy of Environmental Engineering (Diplomate) l 2/85 l NUS COAPOPATION i

/

6 Exhibit G-2 MECHANICAL DRAFT TOWER DRIFT DROPLET SIZE SPECTRA I

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