ML17297A462

Intervenor First Set of Interrogatories Directed to Joint Applicants Re Contentions on Radiation Monitoring Devices & Topographical Features,Meteorological Data & Agricultural Products.W/Certificate of Svc.Related Correspondence

ML17297A462
Person / Time
Site:	Palo Verde
Issue date:	05/22/1981
From:	MEYERSON B CENTER FOR LAW IN THE PUBLIC INTEREST
To:	ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
References
NUDOCS 8106040423
Download: ML17297A462 (167)

Text

9l>po 0 ofg3 UNITED STATES OF AMERICA.NUCLEAR REGULATORY COMMISSION F il~p ARIZONA'UBLIC SERVICE COMPANY))(Palo Verde Nuclear Generating Station, Units l., 2, and 3)Docket Nos.STN 50-528 STN 50-529 STN 50-530 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of))SUPPLEMENTAL TESTIMONY OF NRC STAFF IN RESPONSE TO BOARD UESTION 6 by Ronald A.Zussman This testimony is being offered in response to the part of Atomic Safety and Licensing Board guestion 6 which relates to the airborne dispersal of pathogens.

guestion 6 reads as follows: Show each analytical step including assumptions and verification of claims utilized in staff's analysis to evaluate the public health and environmental impacts of the heat dissipation system relating to airborne dispersal of human pathogens, heavy metals, and pesticides.

In'view of the applicant's proposal to utilize City of Phoenix treated sewage effluent as the sole source of Palo Verde Nuclear Generating Station (PVNGS)cooling water, the'staff requested that additional information be supplied'y the applicant concerning the survivor ship of pathogens present in the water, so that any possible adverse impacts to the Public Health resulting from this use of the water could be evaluated.

The language of the request was specific and detailed, and designed to elicit a response containing information sufficient to serve as the basis of a staff evaluation and conclusion.

In addition to the written request, scientific and technical aspects were informally discussed on several occasions.

On December 20, 1975, a draft study prepared for the applicant by Dr.Nark D.Sobsey was submitted to the staff for informal review.>The reviewers concluded that while the study was appropriately responsive and contained most of the needed information, one area of consideration required additional analysis-that of the interface between possible pathogens and a potential human host.The technical aspects of this conclusion were informally discussed with Dr.Sobsey, and it was agreed that the additional analysis would be provided in the formal issue of the document.The additional analysis was accomplished and'the completed study was formally published in Supplement 3 to the ER.~Diffuculties were encountered in evaluating the possible impacts of the use of treated sewage in the PVNGS cooling system.Virtually no studies are available concerning the dispersal of pathogens by cooling towers.While'onsiderable work has undoubtedly been done by the military involving the aerosol delivery of pathogens ("germ warfare"), such information is classified.

Finally, since the PVNGS cooling system is not in existence, but is yet a proposal, it was not possible to directly verify the applicant's performance claims by the gathering and analysis of actual data..For these-reasons, the staff analysis and conclusions depended heavily on the scientific training, experience, and judgement of the staff.A number of technical assumptions were used in considering the applicant's analysis..

All assumptions were conservative';

where-'appl'doable.

The assumptions were:

1.Any viable pathogens contained in Phoenix waste water could cause disease if dispersed to the atmosphere prior to inactivation.

2.No credit was given for self-purification of the effluent during pipeline transit to the PVNGS.3.Fecal coliform microoirganisms are generally appropriate as indicator s of intestinal pathogens.

4.Fecal coliforms were considered to be at least as hearty as most pathogenic bacteria.5.Viruses were assumed in general to be more resistant to treat-ment than bacteria.6.The City of Phoenix sewage-treatment system was assumed to be an"average" system;that is to say: data obtained at other treatment plants could be validly applied to Phoenix.7.From the standpoint of infectivity, the.inactivation (destruction; killing)-of pathogens is, functionally equivalent to their removal from waste water.8.Serial treatment steps were assumed to result in serial inactivation of pathogens;

=-For.,-example:~~.if-waste water containing 100 organisms per milliliter would be treated first by one method, and then by another, each of which was known to cause a 905 reduction in infectivity, the remaining viable organisms would be 105 of 10K of 100,.or 1 organism.9.Where a number of values was available, only the most conservative value of the range of values was considered for the purpose of analysis.10.Combined chlorine was assumed to be generally less biocidal than free chlorine;however, it was also assumed to be more persistent, thus capable of acting upon pathogens for longer periods of time.ll.Viruses and protozoan cysts were considered more resistant to chlorine treatment than bacteria.12.Survivorship of residual microorganisms (after treatment) was considered to be inversely related to residence time prior to dispersal.

13.Survivorship was assumed to be inversely proportional to temp-eratur e and to roughly obey the 2g=10 relationship where for each increase in temperature of 10'C, there would be a reduction in survivorship of about 505.

14.It was assumed that only one inhaled pathogen would be necessary to initiate an.infection-for many cases, this assumption is considered to be very conservative, since it is known that more often than not, hundreds to tens of thousands of viable, individual pathogenic entities are necessary to initiate an infection in a single host.15.It was assumed that the most common route of inoculation of a hypothetical host in the.vicinity of a cooling tower would be by inhalation.

It was also assumed that in view of the tissue or organ specificity demonstrated by a number of enteropathogens, fewer infections could ever result than indicated by numbers of inhaled organisms, alone.Because of the dispersion characteristics of cooling towers, it was assumed the risk of exposure would be less at areas distal to the tower compared to areas more proximal.Working within the framework of the above assumptions, the staff s verification of the applicant's claims included the following activities:

1.'ey references used by the applicant were checked.2.Other references not cited in the applicant's study were consulted.

3.Calculations were checked.This activity resulted in the identification of an arithmetical error in Table 5 of the

applicant's study: in column"D" (drift conc., 1/ms), the value of 5.3 x 10 s is erroneously given.The correct value is 5.3 x 10".Since the correct value is actually smaller than the given value, the error was found to be in a conservative direction, and not damaging to the applicant's conclusions.*

4.Or.Paul Adams, Director of the Army Environmental Sciences Division, Dugway, Utah was consulted.

Dr.Adams, an acknowledged military expert in the field of biological war-fare, discussed certain nonclassified aspects of atmospheric disper sion of microogranisms, as well as certain effects of the atmosphere (sunlight, dessication, etc.)on dispersed pathogens.

Information gained through these discussions was applied to the staff analysis of the PYNGS cooling system.On the basis of the above, the staff concluded that there would be no potential for public health impact due to the operation of the PVNGS cooling system.*Subsequent to applicant and staff analysis, the applicant announced that the cooling tower drift rate would be reduced from 0.044 to 0.01/.Thus, values in Column"D" and those derived therefrom should be reduced by a factor of 4.

References 1.Letter and attachment from Lawrence T.Klein, NUS Corporation, to Ronald Zussman, ANL;dated Decmeber 20, 1974.

~~

s e PROFESSIONAL QUALIFICATIONS'onald A.Zussman Argonne National Laboratory My.name is Ronald A.Zussman-.I am on the staff of the Environmental Statement Project of Argonne National'Laboratory.

My principal responsibility is that of Project Leader in the preparation of Environmental Impact Statements.

My title-,is that of Staff Biologist.*

In this capacity I also participate in the evaluation of biological environmental impacts of proposed nuclear power generating.stations as assigned to me.Included in these responsibilities.are considerations of, disease and public health as related to nuclear power plant construction and operation.

I also contribute to other environment-associated prospects, both within my department and as a consultant.

I am a member of the Laboratory's Bioconversion Committee..I)oined the Environmental Statement Project'in September 1972.When schedules have allowed, I have also taught on a part-time basis at the.graduate level in the Department of"Biology, Roosevelt University, Chicago, Illinois.=-'.have a Bachelor of Science degree in Biology from Loyola University of Chicago,and'a Master of Science degree'nd; a Doctor of Philosophy degree in Microbiology from:.the University of Illinois at the Medical Center, Chicago.From 1964 until 1972 I was employed in the Biological Sciences Division/~of Abbott Laboratories, Inc., North Chicago tll'1'in'ois~.""During thi's period I worked in both the Microbiology and Molecular Biology Departments.

My prin<<cipal assignments were in basic.and applied research related to Biology, Invertebrate Pharmacology, Virology, Parasitology, Microbiology, and Immuno-chemistry.

My'ajor efforts in Invertebrate Pharmacology involved the study of the effects of biologically active agents upon~Da hnia,~gt latia, Antenna

~H dra ,Planaria, and various Protozoans.

My intere'sts in Virology were iooused principally upon Herpesvirus, Influenzavirus, and Bacteriophage.

My studies in Microbiology, Parasitology, and Immunochemistry have been mostly oriented toward the medical and public health aspects of organisms which cause human and animal diseases.From 1960 to.1963, while a graduate student, I also held the full-time-position of Optical Instructor/Optical Supervisor at the Adler Planetarium and Astronomical Museum, Chicago.From 1958 to 1963 I was a.Teaching Assistant and a Research Assistant in the Department of Microbiology, University of Illinois College of Medicine, Chicago.During my professional career, not including my Master's and Doctor'Theses, I have published approximately a dozen papers in learned Journals such as the Journal of Bacteriology, Mycopathologia, Journal of Parasitology, Journal of Cell Biology, and Applied Microbiology.

'have also published several articles on optical technology.

I have presented papers before the American Society for Microbiology, the Chicago Medical Mycological Society, the American Society of Parasitologists, the Society of Sigma Xi, the Illinois Society of Microbiologists, and others.In 1969, I invented a scientific device, assigned to Abbott Laboratories, Inc.I am a member of the International Association for Great Lakes Research, the American Society for Microbiology, the American Society of Parasitologists, the Chicago Medical Mycological Society, and the Society of the Sigma Xi.

'I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In'he Matter of ARIZONA PUBLIC SERVICE COMPANY (Palo Verde Nuclear Generating Station, Units 1, 2;and 3)Docket Nos.STN 50-528"STN 50-529 STN 50-530 SUPPLEMENTAL TESTIMONY OF NRC STAFF IN RESPONSE TO BOARD UESTION 6 by Fred Vaslow and Thomas V.Green This testimony is being offered in response to Atomic Safety and Licensing Board Question 6 which reads as follows: Show each analytical step including assumptions and verification of claims utilized in staff's analysis to evaluate the public health and environmental impacts of the heat dissipation system relating to airborne dispersal of human pathogens, heavy metals, and pesticides.

t In its evaluation of the'dispersal of toxic elements (e.g., heavy metals)and pesticides by the Palo Verde heat dissipation system, the staff has primarily used calculations which were reported in applicant documents such as the Environmental Report and its supplements, and in NUS Document No.1408.These 1 calculations evaluate both the amount of solids deposited on ground areas in a year's time from the cooling towers and the maximum and average concentrations ,I of solids per unit air volume for different locations relative to the cooling towers.These calculations use the NUS Corporation's"Fog" computer program, which the staff considers to be at a reasonable state-of-art level.I In evaluating the ground depositions and air concentrations of toxic elements and pesticides, each material is considered as forming a given fraction of the total emitted solids.These materials then represent the same fraction of total solids deposited in any area or concentration in any volume of air.For example, the total solids emitted per year are about 1.3 x 10 pounds (ER 7.Sec.3.6.2), including 197 pounds of arsenic.Consequently, the ground deposition of arsenic or air concentration is 197/1.3 x 107 times that of total solids deposited such as are given as isopleths in Figure 3.6 or as air concentrations in Table 3.1.Air concentrations calculated in this manner are given in Columns 2 and 3 of Table 1 of this testimony and ground depositions for the worst case of 125 pounds per acre per year are shown in Column 4.,, In Column 5 of Table 1 the staff has assumed conservatively that all substances deposited on the soil are not removed by organic decomposition, leaching, chemical inactivation etc., but rather are retained in the top 6 inches of the-soil during the lifetime of the plant.Even using these conservative assumptions, a total of less than 15 pounds of toxic elements and pesticides could be present on an acre at the end of plant lifetime.Many variables and processes such as chemical form of the.element, present concentration in the soil, equilibrium point, bulk density, soil pH, erosion, mfrieral uptake by vegetation, etc., are not known for the site.These processes singly or in combination will probably reduce the concentrations below those given in Column 5 of Table l.To the staffs'nowledge, there are no data concerning the existing levels of the substances-listed in Table 1 for the site area soils.It is therefore not possible to make a definite statement regarding the effects of adding the postulated concentrations (Table 1)to the existing background.

However, cultivated crops have been grown and"typical" native vegetation has existed in the site area'or many years.Thus, it can be assumed that the soils are not presently toxic to the species in question.The staff is of the opinion that the levels'f toxic elements in the soil are unlikely to be so high (or close to threshold level)that the addition of the small amounts of material in question would create a condition toxic to vegetation or food chains.To illustrate the above, fluoride comprises over half (by weight)of the toxic material listed in Table 1.The existing fluoride concentrations in the region, as inferred by the groundwater concentrations at the site (2.0-15.2 ppm), are relatively high (ER, Table 2.5-5).This may be due to usage in the site area"'"'f artifical superphosphate fertilizers wFiich may contain 10,000 or more ppm fluoride and/or natural mineral consitutuents of the soil.The maximum probable increase in fluoride concentration in the soil after 30 years of PVNGS operation, assuming no leaching, is less than 5 ppm.

Biocides The staff assumes that the maximum figure of 0.01 pounds of pesticides deposited-on an acre of land over the 40 year period of the plant license (assuming no decompo'sition, conversion etc.).is negligible compared to the 15 to 35 pounds per acre per year presently being applied to cotton crops in the Buckeye area (ER, SI, Sec.3.6).Reference 1.Predicted 24" hourly concentrations of airborne salt particles from drift for the Palo Verde East Site using onsite meteorological data.Prepared for APS and ANPP by G.Fisher and L.Breitstein, June 1975.NUS Corporation Document No.1408, Rockville, Maryland.

Table 1..Particulate Concentrations from PVNGS Mechanical Draft Cooling Towers~Substance 1 Hour Maximum 24 Hour Maximum'hximum Deposition Site Boundary Site Boundary Maximum Deposition Pound/acre Total pg/m~air pg/m3 air Pounds/acre/year for Plant Lifetime2 As Ba Cd Cr Cu F.F,e P,b Mn Hg Se lg A'g Zn Pesticides 0.Ol 0.03 0.18 0.008 0.002 0.03 0.76 0.08 0.008 0.008 3xlO 4 0.003 0.01 0.02 0.001 0.002 0.004 0.02 0.001 3xlO" 0.004 0.09 0.01 0.001 0.001 4xl0-5 Sx10"4 0.001 0.003 lx10-4 0.002 0.005 0.03 0.001 SxlO 4 0.005 0.2 0.02 0.001 0.001 5x10 5 SxlO 4 0.002 0.005 2.5x10"4 0.08 0.2 1.2 0.04 0.02 0.2 8.0 0.8 0.04 0.04 0.002 0.02 0.08 0.2 0.01 Adapted from Tables 3.5 and S.l of the FES.Based on a 40 year period for the plant license with no removal by natural forces (i.e., leaching, decomposition etc.)Pesticides consist of chlorinated hydrocarbons with approximately 3'o of organic phosphates.

Professional Qualifications Fred Vaslow Argonne National Laboratory I am an environmental scientist in the Argonne National Laboratory Environmental Statement Project.I am responsible for reviewing and eval-uating environmental reports submitted in application for the construction of nuclear electric power stations.My fields of review are in'thermal and chemical impacts and in general fields.I received my B.S.and Ph.D.degrees in 1940 and 1948 respectively from the University of Chicago.The fields were in Chemistry and Physical Chemistry with minors in Mathematics and Physics.Subsequently I have audited various courses in Mathematics and Chemical Physics.In 1972 and 1973 I attended a school at the Oak Ridge National Lab-oratory for the writing of environmental impact statements..

The courses were in Economics, Ecology, Meteorology, Hydrology and Environmental Heat Transfer, and a course in the Sources, Usages and Problems of Energy.From 1942 to 1945 I worked on various phases of the wartime Manhattan (Atomic Bomb)Project.Locations where I worked were the University of Chicago, Iowa State College and the Los Alamos Laboratory.

In 1945 I returned to the University of Chicago and then went to the , Oak Ridge National'Laboratory where I finished my Ph.D.thesis research in 1948.The work was on the Thermodynamics of Coprecipitation.

From 1948 to 1952 I was in the biology division of the Oak Ridge National Laboratory working on the Physic'al.

Chemistry of Enzyme Processes.

The work on cop-recipitation and enzymes involved extensive experience with nuclear reactors in the preparation of the radioisotopes used in both parts of the work.From 1952 to 1956 I continued the enzyme work at the Carlsberg Lab-oratory in Copenhagen, Denmark supported by an N.I.H.fellowship and a grant from the Danish Academy of Sciences.In 1956 to, 1957 I spent a year at the University of Minnesota on a post-doctoral fellowship studying the physical chemistry of proteins.From 1957 to 1973 I was at the Oak Ridge National Laboratory.

The work was on the thermodynamic properties of ion exchangers and polyelectrolytes and on water and solutions of electrolytes.

Extensive measurements of heat quantities and,heat transfer (i.e.calorimetry) were made in this work.In 1972 and 1973 as'a full-tine employee and as a consultant I was on the Oak Ridge National Laboratory Environmental Impact Project.My field of specialization was in thermal hydraulics where I evaluated thermal plume-and developed a model for drift deposition from cooling towers.

Professional Qualifications Fred Vaslow Page 2 I have 28 publications including a patent and a book chapter on the"Thermodynamics of Electrolyte Solutions." I am a member., of the American Chemical Society and the A.A.A.S.As a hobby I have walked extensively in environmentally sensitive areas such as mountain and low arctic areas of North America and Europe.

PROFESSIONAL QUALIFICATIONS Thomas M.Green Argonne National Laboratory I, Thomas W.Green, am an assistant ecologist in the Environmental Statement Project at Argonne National Laboratory.

My present duties include the analysis of Environmental Reports and the preparation of Environmental Impact Statements.

I have a Bachelor of Science degree in Hildlife Conservation (1968), a Bachelor of Arts degree in Zoology (1968)and a Master of Arts degree in B<<logy (1970)from California State University-Humboldt.

I also have a Doctor of Philosophy degree in Plant Ecology (1973)from Utah State University.

My career has been mainly as a student in various areas of Biology-Ecology.I have taught (singley or team)several courses in biology and ecology in addition to.a course in man and the environment.

In 1971 and 0 1972 I served', as Vice-President of the Cache Council for Environmental Quality and participated in the Speakers Bureau qf that organization.

From August 1973 to July 1974.I held a post-doctoral fellowship at the University of Houston where I was interim associate director of the Coastal Research Center.This position included part time work with local high schools and junior colleges on the impact of man on the gulf-coast environment.

My research has been in the areas of physiological reaction to stxess environments (1966-1968),'lant allelopathy (1968-1970), the effect of insect seed prec'ators on the evolution and dynamics of plant populations PROFESSIONAL QUALIFICATIONS Thomas W.Green Page 2 I~(1970-1974).

At the present time I have 2 publications in print, 1 in press and 2 in review, all of which deal with the plant-herbivore interface.

I have presented 4 papers at national meetings in the last 3 years.I am presently a member of the Ecological Society of America, American Botanical Society, American Association for the Advancement of Science, American Institute of Biological Sciences, Society for the Study of Evolution, Society of the Sigma Xi, American KLdland Haturalists.

Several of these memberships are held jointly with my wife.I have also held membership in The Wildlife Society, American Society of Mammalogists>

and the Scientists Institute for Public Information (Environment).

~~~~

UNITED STATES OF AMERICA NUCLEAR REGULATORY'OMMI'SSIQN BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of))ARIZONA PUBLIC SERVICE.COMPANY, et al.)~(Palo Verde Nuclear Generating Station, Units 1, 2 and 3)Docket Nos.STN 50-528 STN 50-529 STN 50-530 SUPPLEMENTAL TESTIMONY OF NRC STAFF IN"RESPONSE TO BOARD UESTIONS 9'AND'l l'y MICHAEL'A.PARSONT This testimony is offered in response to guestions 9 and 11 posed by the Atomic Safety and Licensing Board.These questions read as follows: 9.Predict the amounts of I-131 which are likely to be released from the heat dissipation system, using the most recent available data on the City of Phoenix sewage.11.Provide the projected radioactive effluent releases and calculated doses expected from PVNGS based on the model appropriate for new Appendix I of 10 CFR 50 as determined by the Staff.I will fir0t address guestion 11 (as it relates to doses, the testimony of Mr.Bellamy addresses the projected releases from the facility}.

guestion 11 is directed to the NRC Staff's assessment of individual doses from expected routine releases of radioactivity"dei ivina from'operation of the Palo Verde Nuclear Generating Station (PVNGS}.The Staff's assess-ment was performed to determine if the PVNGS met the design objective (1)doses contained in 10 CFR 50, Appendix I.(2)In a letter dated September 26, 1975, Arizona PuBlic Service Company (the Applicant) indicated that it wished to exercise the option provided by the Nuclear Regulatory Commission's SeptemBer 4, 1975 amendment (40 F.R.40918)to Section II.D of Appendix I'.The amendment provides=that an applicant need not comply with the radwaste system cost-Benefit analysis required by Section II.D of Appendix I if Ne proposed radwaste system satisfies the Guides on Design Objecttves contained in the Con-eluding Statement of Position of the Regulatory Staff in Docket No.RM-50-2, dated February 20, 1974 (the RM-50-2 destgn oBjectives}:

The Staff has, accordingly, undertaken to determinate compliance witK both the RM-50-2 and the Appendix I design objectives.

These deter-minations involved different considerati'ons, in tRat tKe RM-50-2 design objectives apply to'all light-water-cooled reactors at a stte, whereas the Appendix I design oBjectives apply to'each reactor at a site.The dose models used to perform both analyses are those set forth tn HE Draft Regulatory Guide 1.AA.TFiese models were revised (wi'th.respect to the models contained in reference 3}to Be responsive (5)to the mandate contained in the"Opinion of tBe Commission relati've to Appendix I,'which called for realism, wlierever possiBle, in tKe definition of input parameters for the dose models.

Included in this analysis are dose evaluations of two effluent categories:

1)noble gases released to the atmosphere and 2)path-ways associated with radioiodines, particulates, carbon-14 and tritium released to the atmosphere.

The dose evaluation of noble gases released to the atmosphere included a calculation of beta and gamma air doses at tBe site boundary and total body and skin doses at the residence having the higBest anti-cipated dose.The maximum site boundary air doses were at 1.2 miles E of the PVNGS.The maximum total body and skin doses were determined to.be at a residence at the same location.Individual doses resulting from pathways associated with radioiodine, parttculates, car'bon-14 and tritium released to the atmosphere were evaluated.

The maximum dose for this category was to the thyroid of a clitld P-ll years old]wIMse diet partially consisted of 530 kg/yr of food crops produced at a residence 1.2 mi.E of the site, and wBo leaved at tlu's same resi'dence for a full year.This dose was estimated to be 8.8 mrem/yr.8ecause of a lack of additional information, it has been assumed that the annual intake of 530 kg of crops was produced at this same residence.

This assumption will most likely cause an overestima'tion of the actual dose received by individuals living at this residence.

Dose estimates for the various pathways considered were made for adults (over 18 years of age), adolescents (12-18 years of age), children (1-ll years of age)and infants (less than 1 year old).Doses were calculated using parameters appropriate for each age group as dis-cussed in Regulatory Guide 1.AA.The doses from noBle gases released to the atmosphere constituted external exposure, and were, Nerefore, not age-dependent.

As described above for the pathways associated

'with radioiodine and the other radionuclides released to the atmosphere, a child located 1.2 miles E from the site recei"ved tfie liigfiest dose.All of the doses in this analysis were Based on the radionuclide releases presented in Mr.Bellamy.'s testimony.

Tfie dispersion of radionuclides in, and the deposition of radionuclides from, tlie atmosphere were based on an analysts performed By the NRC Staff., I As indicated earlier;a comparison with RM-50-2 design oBjecti'ves involves all reactors at a site.'ccordi'ngly, using the procedure described above, a calculation was made to determi'ne tlie doses associ",ated with PVNGS operation.

The results are shown tn TaBle 1 and are compared with the RM-50-2 design objectives.

In order to make a compartson with Appendix P design objectives, a calculation similar to the one mentioned'n the previous paragraph was performed.

This computation was, however, directed at dose values for each reactor unit on the site.The results of the calculation are presented in Table 2. Conclusion It is concluded, based on the values presented in Table 1, that the aggregate doses associated with PYNGS operation meet the RM-50-2 design objectives.

It is also concluded, based on the values presented in Table 2, that the doses per reactor unit associated with PYHGS operation meet the 10 CFR 50, Appendix I design objectives.

Table 1 Criterion Comparison of Calculated Doses from Palo Verde Nuclear Generating Station Operation with Guides on Design Objectives Proposed by the Staff on February 20, 1974 (Doses to Maximum Individual from all Units on Site)b RM-50-2'alculated

~oi DbDoses'oble Gas Effluents Gamma dose in air Beta dose in air Dose to total body of an individual Dose to skin of an individual c, Radioiodine and Particulates 10 mrad/yr 20 mrad/yr 5 mrem/yr 15 mrem/yr 2.2 mrad/yr 4.9 mrad/yr 1.4 mrem/yr 3.5 mrem/yr Dose to any, organ from all pathways I 15 mrem/yr 8.8 mrem/yr From"Concluding Statement of Position of the Regulatory Staff," Docket No.RM-50-2, Feb.20, 1974, pp.25-30, U.S.Atomic Energy Commission, Washington, D.C.b-PVNGS has no squid dose.-pathways'arbon-14 and tritium have been added to this category.

Table 2 Comparison of Calculated Doses from Palo Verde Nuclear Generating Station Operation with Sections II.A, II.B and EI.C of Appendix I, 10 CFR 50 (Doses to Maximum Individual per Reactor Unit)a Criterion Appendix I Desi n'Ob'ective Cal cul ated bDosesUriit 1'Unit'2'Unit 3 Noble Gas Effluents Gamma dose in air (mrad/yr).

Beta dose in air (mrad/yr)10 20 0.81 1.8 0.71 0.70 1.5 1.5 Dose to total body of an individual (mrem/yr)Dose to skin of-an indi vidual (mrem/yr)Radioiodines and Particulates 15 0.50 0.43 0.43 1.3 Dose to any organ from all pathways (mrem/yr).15 3.3 2.8 2.7 PYHGS has no.1>quand dose pathways.b The per reactor unit doses reflect the effect of different meteorological parameters for each unit at the specific receptor s.Carbon-14 and tritium have been added to this category.

Turning to guestion 9 (regarding the amounts of I-131 which are likely to be released from the heat dissipation system and the resulting doses to man), I have examined the Applicant's analysis of January 21, 1976 (see attachment 1)which predicts the amount of I-131 which may be released via the heat dissipation system.I find that the assumptions and calcula-tional method used by the Applicant are reasonable, and should not sub-stantially underestimate the amount of I-131 leaving the heat dissipation system of the plant.The dose calculations (given below)based upon these releases indicate that I-131 from the Phoenix sewage system would have to be increased many times in order to give any significant dose to any human'I in the vicinity of the Palo Verde site.As part of the customary Staff evaluation f'r nuclear power stations, radiological doses are evaluated for all potential exposure pathways to humans.Part of this evaluation considers the radiological dose from radioiodines derived from the gaseous radwaste system.This evaluation was made for the PVNGS and found to be only a small contributor to the potential radiological exposure to man, as is shown in the results of calculations presented below.In addition to radioiodines from the radwaste system, the PVNGS has a unique source of I-131, that being the use of cooling water derived from the Phoenix sewa'ge"system'whi'ch'contains some.I-131 effluent from hospitals.

The use of this source of water has the potential of introducing I-131 into the plant environs via the heat dissipation system.In order to give some perspective to the magnitude of the dose contribution of I-131 from the heat dissipation system, I have performed dose calculations to evaluate/this source of potential radiation exposure and compared it with the rad-iological dose calculated for the radwaste system derived I-131.Two exposure pathways were examined for each of the potential sources of radioiodines.

The first of these pathways was the radiological dose to the thyroid of an infant, from I-131 via the air-pasture-goat-milk pathway, and the second was the radiological dose to the thyroid of a child from'-131 via the air-vegetable pathway.These pathways were chosen for examina-tion because they contribute the largest source of potential dose from I-131.The dose models used to perform these calculations are contained in Draft Regulatory Guide lAA.The assumptions used in the calculations provide a range of potential dose values bounded on the high side by what I consider to be the maximum dose.Infant th roid dose via the air-asture-oat-milk athwa The maximum calculated realistic dose to'the thyroid of an infant:..(located 3.2 miles NW of Unit 1)via the air-pasture-goat-milk pathway was found to be 1.9 mrem/year.

This dose was calculated for the gaseous and parti-,,,,,culate releases from the radwaste system as part of the Staff's'customary

.evaluation of potential dose pathways.The contribution of radioiodines to

~~-10-..this dose was only about 105, the major contributors being C-14 and H-3.The radioactivity source terms used in these calculations were 1)radio-iodines and particulates derived from the radwaste system as provided by Mr.Bellamy and 2)I-131 (14mCi/year) derived from the heat dissipation system as provided by Applicant (as given in Attachment 1).Table 3 gives'the doses calculated for both radwaste system and heat dissipation system derived I-131, as well as radwaste system derived C-14 and H-3..Two estimates of dose are given for I-131, the first being for I-131 from the radwaste system and the second for I-131 from the heat dissipation system.Both elevated and ground level releases were con-sidered for the heat dissipation system derived I-131., Ground level releases lead to the maximum deposition of the radioiodines at'4ii receptor s of interest and therefore to the maximum dose, In addition, it ts.assuaged that none of the r~diotgdi,ne iq.lost close-jn: tg the.plant as a result of'epos'Mon with water droplets tn the.cooliiig tower drift.This also tends to maximiz~the dose.">('he lower doses are based on the assumption that all of the I-131 from the heat dissipation system is released from the same points as the radwaste system~gaseous releases.Again, the effect of cooling tower drift was ignored. Child th roid dose via the air-ve etable athwa As discussed in response to question ll, the maximum organ dose calculated in the Staff's pathway evaluation for gaseous radwaste system releases was 8.8 mrem/year.

This dose was to the thyroid of a child from radioiodines and particulates via the air-vegetable pathway.As was true for the pasture-milk pathway, the dose calculated from radioiodines via vegetables is only a small fraction of the doses calculated for C-14 and H-3.Since the dose derived from I-131 via this pathway is not at its maximum at this residence location (1.2 miles.E of Unit 1), an additional residence location (0.8 miles W of Unit 1), where the largest calculated I-131 dose could be received was selected for comparison purposes.Both ground level and elevated releases were considered for the heat dissipation system derived I-131, as was done in the calculations for the milk pathway.The results of these calculations are presented in Table 4.The assumptions and source terms used for these calculations are the same as were used for the milk pathway.Discussion The assumption that the ground level release in gaseous form.gives'a conservative dose--estimate.'N"Beaeid

'on-engin'eerinj3udgmehtand~'cansideration

'oi',the.possible fate of I-131 released in association with water droplets from the cooling towers. Any iodine associated with water droplets can follow one of several routes after discharge from the heat dissipation system.These routes are described as follows: 1)the, iodine released from the droplets by evaporation, 2)it can remain with these droplets and be deposited on the ground where it may react with soil and plants or evaporate and become available for transport to the receptors considered above, and 3)it may be transported to receptors in the water droplets themselves.

Since.the effluent from the cooling tower drift is injected into the atmosphere where it is subjected to evaporation and deposition, it is more likely that a combination of the routes considered above occurs.Droplets with their associated I-131 depositing on site (it is expected that most will fall within 500 meters of the towers)will be subjected to absorption, chemical reactions with the surfaces which they contact and additional radioactive decay during the time that they remain on the surface.Some of the I-131'ill thereby be removed from the exposure pathways considered.

For the above reasons, and in order,to derive the maximum doses, it was decided to use the conservative assumption that all the I-131 released at ground level were not influenced by being associated with water droplets.As is indicated in Tables 1 and 2, the dose contribution of I-131 to the thyroid, from the two pathways most likely to expose this organ, is less than 1 mrem/year.

This is true for the maximum dose calculation case as well.I consider these doses to be negligible. Table 3.Comparative Infant Thyroid Dose Via The Air-Pasture-Goat-Milk Pathway For Radwaste System Derived I-131, C-14 and H-3;and Heat Dissipation System Derived I-131 for Elevated and Ground Level Releases From the Heat Dissipation System (Location is 3.2 miles NM of Unit 1)Dose (mrem/year)

Radwaste S stem Heat Dissi ation S stem Elevated 0.2 0.1 I-131 Ground Level 0.2 C-14 Elevated 0.7.H-3 El evated 1.0 Table 4.Comparative Child Thyroid Doses Via The Air-Vegetable-Pathway at 2 Site Boundary Locations for Radwaste System Derived I-131, C-14 and H-3;and Heat Dissipation System Derived I-131 for.Elevated and Ground Level Rel.eases From the Heat Dissipation System Dose (mrem/year)

R~d<<t S t II Oi i ti S Location 1*Location 1 Location 2**I-131 Elevated Ground Level 0.06 0.03 0.08 0.05 0.42 C-14 Elevated 4.0 H-3 Elevated 4.7*Location 1: That location yielding the highest dose to the thyroid from all radionuclides (1.2 miles E of Unit 1}".*Location 2: That location yielding the highest dose to the thyroid of a child from I-131 (0.8 miles W of Unit 1) References l.10 CFR Part 50, Appendix I.40 FR 19442, May 5, 1975.2.'Letter from E.E.Van Brunt, Jr., Arizona PuBlic Service, to Daniel R.Muller, NRC.3.4.U.S.A'tomic Energy Commission, Concluding Statement of Positton of t'e Regulatory Staff (and its Attachment)

-PuBltc Rulemaking Hearing on: Numerical Guides for Design OB)ecttves and Limiting Conditions for Operation to Meet tlie,Criteria"As Low As PracticaBle" for Radioactive Material in Light-Mater-Cooled Nuclear Power Reactors, Docket No.RM-50-2, klashington, D.C., FeBr uary 26, 1974.Staff of the U.S.Nuclear Regulatory Commi'sston.

Draft Regulatory Guide 1.AA,,"Calculation of Annual Average Doses to Man from Routine Releases of Reactor Effluents for the Purpose of'Implementing Appendix I," September 23, 1975.5.Opinion of the Commission in the Matter of: Rulemaklng Kearing-Numerical Guides for'Design OBjecttves and L'imtttna Condtttons for Operation to Meet the Criterion"As Low As Practicable" for Radioactive Material in Light-~<later-Cooled Nuclear Power Reactor Effluents, Docket No.RM-50-2, CLI-75-5;NRCI-75/4R 277 (April 30, 1975).

'QRPORATION

~ENVIRONIVIENTAL SAI;EGUARDS DIVISION C RESEARCH PLACE RQCKVILLE.

MARYLAND EOBEQ 301 B~G-7010'TTACHMENT 1 January 21, 1976 ESD-76-49 (HQ)Dr.Mike Parsont Nuclear Regulatory Commission Site Safety and Environmental Analysis Division 7920 Norfolk Avenue.Bethesda, Maryland 20014

Dear Dr.Parsont:

In response to your verbal request for information regarding the calculational procedure and assumptions used to estimate the amount of radioiodine activity released in the cooling tower drift'f the Palo Verde Nuclear Generating Station, the attached explana-tion.is provided.Please feel free to call"us should you require further information on this matter.Sincerely, rid~~rs C.qual,!-s=-'-.'~-'oseph:J.

DiNunno Vice President and General Manager'H/jw Attachment cc: John Mann L.T.IQein RESPONSE A survey was done by NUS which identified nine hospitals upstream of the 91st Avenue Sev age Treatment Plant which had nuclear medicine facilities and could therefore discharge radioactive wastes into the sewage system.No radiopharmaceutical laboratories or other potential sources were identified.

Technical personnel from the nine hospitals were then interviewed to determine the amount of I-131 administered; per year, in both therapeutic and diagnostic

':ocedures.

It was repor:ed that approximately 1,389 mCi were administered

.'.ring 1973.The following assumptic were then applied: o 30%of the amount administered to the patient is lost by decay in the thyroid gland, therefore 70%of the administered amount reaches the (1)sewage system.-~10%of the radioiodine in the sewage influent is removed by primary and secondary treatment, therefore 90%of the influent amount leaves (2)the sewage plant.~83%is the maximum amount of the treated wastewater that will be diverted from the 91st Avenue Sewage Treatment Plant effluent stream to the PVNGS.water reclamation plant (in 1985).(3)~In.1985, the population is projected to have increased about 167%of the 1973 value.Radioiodine utilization per capita is assumed'o remain constant at the 1973 value.(4)

Application of the aforementioned assumptions to the source term administered to the patients yielded approximately 1210 mCi of I-131 available to reach the PVNGS water reclamation.

plant in 1985 (the maximum amount during the lifetime of the facility).

In order to predict the ul.imate fate and potential impact of the iodine of'edical.origin reaching PVNGS, the WRP,.reservoir, circulating water system, cooling tower blowdown complex was mathematically modeled and iodine concentrations in the reservoir and circulating water system were ca'lculat d.Iodine released.would be contained in the drift from the cooling towers, at the concentratio~

in the circulating wat~" system.It was conservat.'ely

\assumed that the moisture in drift evaporates before reaching the ground, freeing the iodine to be transported as a gas.The following equilibrium model was used: where: Fs Cs T ()Fb+Fc+A.Mt Fm C Fs=Cs=concentration of a cooling tower basin, mCi/lb flow into W'ater Reclamation Plant, lbs/day 131 concentration I in Fs, mCi/lb Fm=flow from r~servoir, Ebs/day Mr=Fb=Fc=Mt=mass of wat i in the reservoir, lb 131-1 decay constant of I, days flow from cooling tower to WRP, lbs/day drift loss from cooling tower, l&s/day mass of water in cooling tower basins/lbs Input data necessary to solve the equation was furnished by the PVNGS PSAR and Bechtel Engineering, San Francisco, California.

Using the models just described'together with the latest cooling tower specifications, it is estimated that, as a result of operation of the three units, about 1.2%of the 1-131 reaching PVNGS in sewage water, or about 14mCi, would be released to the atmosphere annually, the balance being decayed wh'ile in solution within the reservoir and circulating water system.l REFERENCES (1)ICRP Publication 2,"Report of Committee on Permissible Dose for Internal Radiation," Internal Commission on Radiological Protection, Pergamon Press, New York (1959).(2)Straub, Low-level Radioactive

'V'astes, Library of Congress, Catalog No.64-60034.(3)"PaloVerde Nuclear Generating Station-l, 2 and 3 Environmental

'Report," Table 5.7-3, p.5.7-8., (4)"PaloVerde Nuclear Generating Station-1, 2 and 3 Environmental Report," Section 2.2.

Statement of Professional qualifications of tiichael A.Parsont My name is Michael A.Parsont.I am an Environmental Scientist in the Radiological Impact Section of the Radiological Assessment Branch of the Office of Nuclear Reactor Regulation.

In this capacity I am responsible for writing Sections 5.4, Radiological Impact;6.1.4, Preoperational radiological monitoringg and 6.2.4 Radiological monitoring of Final Environmental Statements for various nuclear power stations.In addition, my responsibilities include the review of applicant Environmental Reports in the area of radiological effects on man and biota other than man, topical studies in r'adioecology and radiobiology and preparation of environmental monitoring technical speqification and safety guide preparation.

I.hold a Bachelor of Science Degree in Environmental Sanita'cion (University of'California at Los Angeles), aMaster'sDegree in Radiology and a Doctorate Degree in Radiation Biology (Colorado State University).

I have additional academic background in Environmental Health>Sahitation Engineering and Zoology (endocrinology and genetics).

I have more than eight years of experience working in areas related to th'e evaluation of the biological effects from dispersed radionuclides

'These include three years with the Aerospace Nuclear Safety Div9:sion at Sandia Laboratories, Albuquerque, New Mexico and two years at NUS I Corporation, Rockville, Maryland.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD'n the Matter of ARIZONA PUBLIC SERVICE COMPANY, et al.(Palo Verde Nuclear Generating Station, Units 1, 2 and 3)Docket Nos.STN 50-528 STN 50-529 STN 50-530 SUPPLEMENTAL TESTIMONY OF NRC STAFF IN RESPONSE TO BOARD UESTIONS 10 AND ll Ronald R.Bellatqy This testimony is offered in response to guestions 10 and 11 posed by the Atomic Safety and Licensing Board, which read as follows: 10.If I-131 levels are found to be excessive, what are the control technology options available to be employed to reduce doses to within acceptable limits7 ll.Provide the projected radioactive effluent rele'ases and calculated doses expected from PVNGS based on the model appropriate for new Appendix I of 10 CFR 50 as deter-mined by the Staff.I will address question 11 first.Introduction I.On December 3, 1970, the Atomic Energy Commission (now, the Nuclear Regulatory.

Coranission) published an amendment to its regulations that required releases of radioactive materials in effluents from nuclear power reactors to be kept"as low as practicable".

By amendment dated December 19, 1975 (40 FR 58847)the Conmission replaced the terminology"as low as practicable" with the terminology"as low as is reasonably achievable" (ALARA).This amendment was adopted to make the concept of radiation protection more understandable and to conform to the terminology used by the International Commission on Radiological Protection.

Ne shall hereafter in this testimony use the terminology"as low as is reasonably achievable".

The term"as low as is reasonably achievable" is defined'in the regulations (10 CFR 20.1(c)and 10 CFR 50.34a)to mean"as low as is reasonably achiev-able, taking into account the state of technology, and the economics of improvements in relation to benefits to the public health and safety, and other societal and socioeconomic considerations, and'in relation to the utilization of atomic energy in the public interest".'he Coamission recently published Appendix I to 10 CFR 50 (40 FR 19442, May 5, 1975), which set forth numerical guidelines for meeting"as low as is reasonably achievable" for light water reactors.On September 4, 1975 (40 FR 40816)the Corwoission amended Appendix I to 10 CFR Part 50 to provide persons who have filed applications for con-struction permits for light-water-cooled nuclear power reactors which were docketed on or after January 2, 1971, and prior to June 4, 1976, the option of dispensing with the cost-benefit analysis required by Paragraph II.D of Appendix I.This option permits an applicant to design his radwaste management systems to satisfy the Guides on Design Objectives for Light-Mater-Cooled Nuclear Power Reactors proposed in the Concluding Statement of Position of the Regulatory Staff in Docket RH-50-2, dated February 20, 1974.As indicated in the Statement of Considerations accompanying the amendment (copy attached), it is unlikely that further reductions to radioactive material releases would be warranted on a cost-benefit basis for light-water-.

cooleg nuclear power reactors having rad-waste'ystems and equipment determined to be acceptable under the proposed Staff design objectives set forth in RM-50-2.In a letter to the Commission dated September 26, 1975, Arizona Public Service Company (the Applicant) chose the option of dispensing with the cost-benefit analysis required by Paragraph II.D of Appendix I and chose to comply with'the September 4 amendment of Appendix I instead, The Applicant also provided information requested to permit determination by the NRC Staff of compliance with the design objectives of Paragraphs II.A, B, and C of Appendix I; Evaluation The Staff has evaluated the gaseous radwaste management systems proposed for Palo Verde Nuclear Generating Station, Units 1, 2 and 3 (PVNGS}, to reduce the quantities of radioactive materials released to the environment

.'in gaseous effluents.

The Staff has evaluated the liquid radwaste manage-ment system and.'found there will be no discharges of liquid effluents to the environment.

These systems have been previously described in Sections 11.2 and 11.3 of the Staff's Safety Evaluation Report, dated October 1975, and in Section 3.5 of the Final Environmental Statement, dated September 1975.In accordance with Appendix I, as amended, and based on information provided by the Applicant in the above referenced letter, on more recent operating data applicable to PVNGS, and'on changes in our calculational model, the Staff generated new gaseous source terms in order to calculate releases from the site by PVNGS.These values are different from and supersede those given in Tables 3.4 and 3.4A of the Final Environmental State-t ment.The new source terms, shown in Attachment 1;were, calculated using the models and methodology described in Draft Regulatory Guide 1.BB,"Calculation of Releases of Radioactive Materials in Liquid and Gaseous Effluents from Pressurized Water Reactors (PWRs)", September 9, 1975.These source terms were used by Dr.Parsont to calculate the doses presented in his testimony.

Based on the Staff's evaluation of the gaseous radwaste management systems and on the dose calculations presented by Dr.Parsont in his testimony, the calculated total quantity of radioactive material.s released in gaseous effluents from PVNGS, will result in a calculated annual gamma air dose of less than 10 mrads and a calculated annual beta air dose of less than 20 mrads at every location near ground level, at or beyond the site boundary, which could be occupied by individuals.

The calculated annual total quantity of iodine-131 released in gaseous effluents will not exceed 1 Ci/reactor and the calculated annual total quantity of radioiodine and radioactive particulates released in gaseous effluents from PVNGS, will not result in an annual dose or dose commitment to any organ of an in--dividual in an unrestricted area from a)l pathways of exposure in excess of 15 mrem.Conclusion Staff testimony demonstrates that the doses associated with the normal operation of the PVNGS, meet the design objectives of Sections II.A, II.B and II.C of Appendix I of 10 CFR Part 50, and that the expected quantity of radioactive materials released in gaseous effluents and the aggregate doses meet the design'objectives set forth in RM-50-2.

Staff's evaluation shows that the Applicant's proposed design of the PVNGS satisfies the criteria specified in the option provided by the Commission's September 4, 1975 amendment to Appendix I and;therefore, meets the requirements of Section II.D of Appendix-I of 10 CFR Part 50.Based on the Staff's evaluation, the proposed gaseous radwaste manage-ment system for PVNGS meets the criteria given in Appendix I and is, therefore, acceptable.

7 ATTAC ENT 1 CALCULATED RELEASES OF RADIOACTIVE MATERIALS IN GASEOUS EFFLUENTS FROM PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2 AND 3 (Ci/yr/uni t)'I Release Point Nucli des Turbine Vent Air Plant Fuel Ejector I~ttd.t I I I Kr-83m Kr-85m Kr-85 Kr-87.Kr-88 Kr-89 Xe-131m Xe-133m Xe-133 Xe-135m Xe-135 Xe-137 Xe-138 I-131 I-133 Co-60 Co-58 Fe-59 Mn-54 Cs-137 Cs-134 Sr-90 Sr-89 C-14 H-3 Ar-41 a a a a a 1 5 270 a a 270 1 a a 1 6, a 3 9 a a a a a a 9 a a 9 a, 21 a 1 22 a'900 a 63 2000 a 16 a 20 a 2.2(-4)3(-4)'-c c a 4.5(-3)6.4(-3)'.4(-4)b-7.6(-4)7.6(-5)2.3(-4)3.s(-4)2.3(-4)3.0(-6)1.6(-5)9 1125 25, 375 a 2.7(-3)3.9(-3)c c a, 7.4(-3}1.1(-2)3.4(4)7.6(-4)7.6(-5)2,3(-4)3.s(-4)2.3(-4)3.0(-6)1.6(-5}9 1500 25 a=less than 1.0 Ci/yr noble gases, less than 10" Ci'/yr for iodine.b=exponential notation: 7.0(-5)=7.0 x 10 5 c=less than 1$of total for nuclide.

I now turn to guestion 10, which concerns control technology options available if iodine-131 release levels resulting from the use of the sewage effluent are found to be excessive at the PVNGS.The testimony of Dr.Parsont indicates that the doses anticipated to result from the dispersion of the I-131 will be negligible.

Nevertheless, we offer the following comments in response to the Board's question.I The releases of concern result from the presence of iodine-131 in the plant cooling tower water prior to delivery to the onsite water reclama-tion plant.The source of plant cooling tower water is the waste water effluent from the City of Phoenix 91st Avenue Sewage Treatment Plant.This water is used-to remove waste heat resulting from normal operation of the PVNGS and reject it to the atmosphere vi'a the cooling towers in the system.Entrained water droplets (mist}are carried away in the cooling tower effluent air stream.?odtne-131 in the plant'cooling tower water entering the plant will be:released in this mist.Conventional treatment methods to remove iodine-131 in the plant cooling tower water would include demineralizers.(mixed bed, powdex, or anion), and charcoal adsorbers.

These systems, however, appear impractical to treat the large volume of water expected for Palo Verde (approximately 50,000 gallons per minute).

Once the iodine-131 becomes airborne at the cooling tower as a mist, it becomes entrained in the 6.3 x 10 cubic feet per minute per unit.air draft.Air draft is provided by a 28 ft.diameter electric fan on the top of each cooling cell (14 cells per tower, 3 towers per unit).If I this air draft were treated, it would require collection (confinement) and filtration through an adsorbent such as charcoal.The largest filter/adsorber systems yet designed have a capactty of the order of 105 cfm.Therefore, it would appear impractical to collect and filter the existing cooling tower air draft flow of 6.3 x 107 cfm with filter/adsorber systems.The primary option, therefore, to reduce iodine-131 releases from the cooling tower mist would be to reduce the iodine-131 contamtaation of the plant cooling tower water supply at Its soiree.

PART 50<STATEMENTS OF CONSIDERATION fiexlbiflty.

it cnn bc cnsurcd that the average population expo"uro wfll stIH be n small fraction of doses from natural background radiation.

Thc CommLssion notes, however, that.In using this opcr-atlonal flexibility under temporary or short-term unusual operating condi-tions, the Hcensee must continue to exert his best efforts to keep'lcvcls of radio-active material in cfllucnts within the numerical guides for design objectives.

In order to provide assurance that re-leases'f radioactive materials are known, the Commission hns expanded the survcfllance nnd monitoring program beyond current requirements for H-ccnsees to report on the quantities of thc principal rndionucHdcs released to un-rcstrlcted areas.It is expected that this expanded monitoring program wiO be used by Hccnsees as a basis for initiating prompt nnd effective corrective action towards ensuring that the actual offsite exposures per reactor aro compatible with the d""ign objectives ns adopted.,These guides will continue to provide operating flcxlbflity and at the same time ensure.a positive system of control by a graded scale of action firs by the Hcens-ee and second by the Commission, if the need arises, to reduce thc release of radioactive material should the rates of release actually experienced substantial-ly exceed the design objcctlvcs.

7.Implementation.

Thc proposed Ap-pendix I was sOent on the method for im-plementation of the numerical guides.The Commission bclfeves, however, that Appendix I should guide the Commission Staff.and other interested persons ln the use of appropriate calculntlonal proce-dures for applying the numcrlcal guides for design objectives.

Consequently, the provision adopted states that compH-ance with the guides on design objectives shall be demonstrated by calculational procedures based on models nnd data that wfll not substantially underestimate the actual exposure of an individual through appropriate pathways.all un-certainties being considered together.Quantitative measurement of radlo-'actlve materials released hl cfllucnts from Hcensed Hght-water-cooled nuclear power reactors 1s required by 10 CFR 50.36a.This requirement is made more speclflc by Appendix I and reflects the desirability of the use of the best avaO-able experimental data as well as calcu-latlonal models in order to achieve in-creased accuracy and renHsm.Strong incentives already exist for hnprovlng the calculatlonal models used in estab-lishing design objectives in view of the economic penalty associated with need-less overdcsign for conservatism.

Actual measurements and surveillance pro-grams can provide data tor improving these models.It Is recognized, however.that measurements of environmental exposures and quantities of radioactive materials in the environs arc compH-catcd by the very 10w concentrations that are encountered.

compared to back-ground, and by the fact that thero are n number of variables in both tlmc and space that ni?ect concentrnton.

Thus, the correlation of the best measurements with the best calculatfons is tedious and dificult.Qoprever, ej'flee calculational procedure's must be employed ln imple-menting the design-objective guides of Appendix I, thc Commission hns adopted an Implementation poHcy that encour-ages thc improvement of calculation.

modeLt nnd the use of the best datsI avaOablc.The forcttoing"Summary nnd State-ment of Cottsidcrntlons" has briefl sum-marized tho tcchnical context of thc Issues presented and outHned the changes made in Appendix I from the, form in which it wns originaHy proposed.The text of Appendix I as adopted foOows in Chapter II of this Opinion.The three foOowing chapters of text set forth the record bases for the changes in greatly expanded detaO.These supplemental ex-planatory chapters (III through V), be-cause of their length, will not be pub-Hshed in the Fxezaat.RzctsTzR with the text of Appendix I and the Summary and Statement of Considerations, but will be pubflshed in the April issue of Nuclear Regulatory Commission Issu-ances.'ingle copies of.this volume mny be purchased at a cost of$4.00 from the USERDA Tcchnical Information Center, P.O.Box 62, bak Ridge, Tennessee, 37830.Copies of the complete Opinion are also avaflable for inspection and copying ln the Commission's Public Doc-ument Room, 1V17 H Stree:, NW., Wash-ington, D.C.20555.Pursuant to the Atomic Energy Act ot 1954, as amended, nnd Sections 552 and 553 of Title 6 of the United States Code, the following amendments to Title 10, Chapter I.Code.ot Federal Regulations, Part, 60, are pubHshed as a document sub-ject to codiQcation to be eifective on June 4, 1976.40 FR 40816 Publ>shed 9/4/75 Effective 9/4/75 PART 50-LICENSING OF PRODUCTION

'ND UTILIZATION FACILITIES Application ot Cost Benefit Analysis Re-quirements of Appendix I to Certain Nu.clear Power Plants The Nuclear Regulatory Commission has adopted amendments to Appendix I of 10.CFR Part 50.Appendix I sets forth numerical guides for design objec-tives and limiting conditions for opera-tion to,mcet.the criterion"as low as practicable" for radioactive material in Hght-water-'cooled nuclear power actor eflluents.

The amendments provide persons who havo fOed appHcations for construction permits for Hght water-cooled nuclear'ower reactors which were docketed on or after.January 2, 1971, and prior to.June 4, 19M, ge option of dispensing with the cost-benefit analysts required by Paragraph II.D ot Appendix I if the proposed or installed radwaste systems and equipment satisfy~Copteo of the complete ttve-chapter Oplu-Ion of the Commtseton have been fuod with tho orlglaal document aubmttted for pub-ltcattou tn tho Pzorau.Rracorxa, and may ho examined by mombero of tho public at tho Otttcoo of tho Pectoral Rogtotor.thc Guides on Dcslgn Objectives for~ht-Water-Cooled Nuclear Power Re-actors proposed by thn regulatory stalf In the rulemaklng proceeding on Appen-dix I (Docket-RM-50-2)

.Pnrngraph 11$)requires each applicant for n permit to construct a Hght-wntcr-coolcd nuclear power reactor to submit n cost benefit analysis of additional rad-wastc systems and equipment that could reduce the radiation dose to the popula-tion reasonably expected to be wititln 50 mOos of the reactor.Xn this cost bene-fit analysis, the values 61000 pcr total body man-rem and$1000 pcr mllr thyroid-rem (or such lesser values n mny be demonstrated to bc suitable in a particular case)are required to be used.Thc requirements of Paragraph 1133 em-body an approach somewhat different from the proposed Appondlx I published for comment on Junc 9.19V1 (36~11113).~l After a lengthy Appendix I rulemnking proceeding Initiated In 1071 which v;as conducted by the former Atomic Energy Comlnission, the'uclear Regulatory Commission; which was assigned tho re-sponsibOity of carrying out the Hccnsing and related regulatory functions of the Atomic=Energy Commission by the Energy Reorganization Act of 19V4 (ef-fective January 19, 1975), adopted on"May 5, 1975, a new Appendix I to Part 60 (40 FR 19439).Appendix I provides numerical guides for design objectives and Hmlting condi-tions for operation for Hghi water~led nuclear power reactors to keep radio-activity in eifluents as low ns practicable.

AH Commission Hcensces nrc required by 10 CFR Part 20 to make every reasonable effort to maintain radiation cxposuros, nnd releases of radioactive materials'ln efliucnts to unrestricted areas.as far below Part 20 Omits as practicable.

The deflnition'f"as low as practicable" in both 10 CFR 4520.3(o)and 50.34a(a)includes consideration of the economics of improvements ln relation to the pubHc health and safety.Appendix I as adopted by the Commis-sion provides in Section II-ln addition to design objectives for annual doses for any Indlvldual In an unrestricted area from both Hquid nnd gaseous efltuents.

Includingradioactive iodine and radio-active material in particulate form-n further requirement that the appHcnnt include in the radwaste system aH items of reasonably demonstrated technology that, when added to the system scqucn-tlaHy and in order of diminishing cost-bencQt ratio, effect reductions in doso to thc population reasonably expected to be withlft 60 mfles of the reactor.As an interim measure nnd until establish-ment and adoption of better values (or other.appropriate criteria), the'values 31000 pcr total body man-rem and 31000 per man-thyroid-rem (or such lesser values as may be demonstrated to be suitable in n particular case)are to be used ln this cost-beneQt analysis.A rule-mnking hearing Is planned at tho earHest practicable date to estabflsh more ap-propriate monetary values for the worth of reduction ot radiation doses to the population.

'Ihe design objectives proposed.by the PART 60 o STATEMENTS OF CONSIDERATION s taN in thc rulemaklng proceeding on Appcndlx I Included spcclflcntions on the total radioactivity rclenscd (5 curie/per year reactor for liquid c(0uents, excluding trltiuin and dissolve(I gases: and 1 curie/pcr year pcr rector of radioiodine-131)(Lnd a 5 ndlllrcm Un)ltatlon on the annual whole body dose to lndlvlduals at or beyond thc site boundary from aU path-ways of exposure.Because the former crltcrlon used by the staff that each plant meet those design nbiectlves has led to the proposed or actual installa-tion of radwasto sysLems and equipmcnt Qlat 1'ccluco to low levels'Lhc toLal activ Ity ln cmuent releases or expected elliuent releases fro'n such plants, the appflcation of the$1000 per man-rcm criterion spe-cUied in Paragraph II.D of Appendix I to these or similarly dcslgncd plants is un-likely to result ln radsvastc equlpmcnt augmentation.

Cost-beneflt analyses by the NRC staiI,, of appUcatlons for construction permits for Ught-water-cooled nuclear power re-actors filed and reviewed sh)ce 1971 in accordance with those design ob]ectives show, that for bolflng water reactors, ad-ditional radwaste cqulpmcnt cannot be added for less than 61000/man-rcm.

Therefore, ln general, boiling water re-actors that have radwaste systems nnd equipmcnt that meet those proposed de-sign obicctivcs will meet the require-ments of Section II.D of Appendix L Simflar cost-benefi analyses have shown that pressurized water reactors whose~radwaste systems have been evaluated and found acceptable under those de-sign oblectlves also meet the require-ments of Section II.D of Appendix L Basic assumptions used ln these analyses were: (1)Iodine-131 ln gaseous releases was the only release considered, since thh Is the dominant factor in the costibencflt analyses;(2)boiUng water reactor condenser oNgas and pressurized water reacl,or waste gas treatment sys-tems were considered to be augmented In order to meet the Individual dose guide-lines proposed by thc staN ln the Appen-dix I rulemal'ing proceeding; (3)a re-leaso of 1 curie of Iodine-131 results In a population exposure of 100 man-thyrold-rem.The assumption that Iodine-131 In gaseous releases is the dominant factor h based on the results of ctaN evalua-tions, reported in draf t and final environ-mental impact statements, of proposed light-water-cooled nuclear power re-actors for which appflcatlons for'con-struction permits were docketed since 1971.The total body man-rem associated with noble gas and Uquld releases for radwaste systems and equlpmcnt found acceptable under the design obiectlves proposed by thc staN were small.I.e., Iem than 10 man-rem for the annual noble gas releases and less than 5 man-rem for the annual Uquld releases In almost, all cases.As a consequence, lt can reason-ably be concluded that reduction of pop-ulation dose by augmentation of the noble gas and Uquld radwaste treatment systems was not Ukcly to be achieved without exceeding the$1000/man-re!a criterion.

A.Boiling Water Reactor Cost-Bcne-flt Analyses.Sources of radioiodine re-lcascs in boillug water reactors aro: 1.Itoaotor banding vok, December 26, 1975 2.Auxiliary bundlng vont.2.Radwaato banding vont.4.Turblno building ront.6.Turb(no gland ooal condonsor exhaust.6.hfaln condonsor vacuum pump.'7 Condonsor a(c OJoctor oxhaust Tho last source wds assumed to be trcatcd such that the Iodine-131 relcnse Is ncgUglblo compared with tho other sources.Addltlonal radwaste equipment con-sidered included: charcoal adsorbers for building ventilation exhaust (Sources 1.2.3.6)and equlpmcnt for clean scaflng steam for the turbine gland seal exhaust and for scaling valve stems ln the steam system (Sources 4, 5).Thc charcoal ad-sorbers reduce the iodine-131 release to approximately 10%of thc cxpccted re-lease without the filters.The turbine gland seal condenser exhaust releases can be reduced to negUglble levels by tho usc of, clean steam.Releases from the turbine building vent can be reduced ap-proximately 80%by using clean steam on valves.2.5-ln.(Lnd larger, ln the tur-bine bufldlng.The cost of the additional equlpmcnt ls greater than the bencflt of reduced population exposure (at 81000/man-rcm) in nU cases.Accordingly, such addltlonal equipment for bolflng water reactors would not be Iustifled according to the criterion of Section II.D of Appendix L B.Pressurized Water Reactor Cost-Beneflt Anal)/ses.

Sources of iodine-131 releases in pressurized water considered were: 1.Contalnmont.

2.Auxiliary buudtng vont.S.Turbine building vont.h.Condenser air oleotor oxhauat, 6.1)lowdovfn nash Lank vent.Reduction In released activity can be achieved with charcoal adsorbers (Sources l.2, 4), with clean seaUng steam for valves (Source'3),'nd by installation of'a piped blowdown flash tank vent to the main condenser or feedwnter heater (Source 5).As with boUlng water reac-tors, charcoal adsorbers can reduce the nctlvity approxlmlttciy 90 per cent.Clean seaflng steam effects an 80%reduction in relcascs.Tho blowdown flash tank vent source can be eUminated by rout-ing the release to the main condenser or feedwater heater.WIth respect to the pressurized water reactor containment as a source of etgu-ent release, the estimated cost of char-coal adsorbers was based upon a plant having a low volume purse, system ln tho Initial design stage.Charcoal adsorbers cannot be lnstaUed ln plants which have a high volume purge system for less than$1000/man-rem.

Most pressurized water reactors for which Ucense appUcatlons have been docketed after January 2, 1971, Sall into thh latter category.Those which havo a low volume purse system are lo-cated on sites where the reduction ln population exposure Is less than 100 man-rem per curie of iodine-131, so that the cost of installation of charcoal adsorbcrs Is greater than 31000/man-rem.

Based on the foregoing, there h'no need, on a cost-bcnefl t basis, to apply the requirements of Paragraph II.D o!Ap-pendix I of Part 50 to those light-watcr-cooled nuclear power reactors having 50.SC42 radwaste systems and equipment deter-mined to be acceptable under the pro-posed staH design obiectives.

Accord-Ingly, Paragraph II.D of, Appendix I has beeu amended to specify that persons who'have Bled ap pflcatlons for construc-Lion permits for light water-cooled power reactors whhh werc docketed on or after January 2.19'7l, ana prior to June 4, 1976.need not comply with the cost-bencflt requirements of that paragrnph lf the radwaste systems and equipment described in the preliminary or flnal safety analysis report and amendments thereto satisfy the design ob)ectives p)s)-posed by thc staN in the Appendix I rule-n)aking proceeding.

Because the amendmeuts will result in no appreciable change in the population exposure from the affected plants than would result lf the amendments were not promulgated.

the Commission has found that note of proposed rulemaking and pubUc procedure thereon are unneces-sary.Since the amendments reUeve from restrlctlons imposed under regulations currently in eNect;they may, pursuant to 5 U.S.C.553, become effcctivc immedi-ately.Pursuant to the Atomic Energy Act of 1554, as amended, the Energy Reorgani-zation Act of 1974 and sections 552 and 553 of Title 5 of the United States Codes, the following amendments to Title 10, Chapter I, Code of Federal Regulations, Part 50, are pubUshed as a document sub-ject to codificatio.

0 FR 58847 Pubhshod 12/19/75 Effective 1/19/76 PART 20-STANDARDS FOR PROTECTION AGAINST RADIATION PART 50-.LICENSING OF PRODUCTION AND UTILIZATION FACILITIES Change of Terminology for"As Low As Practicable" Umits On May 5.1975, the Nuclear Regula-tory Commission publhhed in the Fzn-zzah Rzctsrza its decision Iu the rule making proceeding concerning numerical guides for design ob]ectives and limiting'conditions.for operation to meet the criterion"as Iow as practicable" for radioactive material In Ught-v;ater-cooled nuclear power reactor efQuents, including amendments of 10 CFR Part 50 which became effective June 4.1975.In lts decision, the Commission noted that during the pendency of the rule making, the International Commission on-Radiological Protection, in ICRP Publication No.22 has replaced the phrase"as low as practicable" with"as low as h reasonably achievable" ln its recommendation on dose Umltatlon.

The Commission, in its decision, endorsed the attempt to make this basic concept of radiation protection morc understand-able and dlrcctcd the staff to prepare and hsue for public comment a proposed rule that would substitute the currently ac-cepted phrasing"as low as ls reasonably achievable" for thc older, less precise terminology where lt appears in the 4 Dr.Ronald R.Bellamy Professional Qualifications Effluent Treatment Systems'Branch, NRR My name is Dr.Ronald R.Bellamy.I am a Nuclear Engineer in the'ffluent Treatment Systems Branch, in the Office of Nuclear Reactor Regulation.

I attended Lehigh University and received a Bachelor of Science Degree in Chemical Engineering in 1969.I attended Ohio State University and received a Master of Science Degree in Nuclear Engineering in 1970 and a Doctor of Philosophy Degree in Nuclear Engineering in 1973.The title of my dissertation was"The Adsorption of Elemental Iodine and Methyl Iodide on Activated Charcoal from Plowing Air Streams at Low~Inlet Concentration." While performing my graduate studies at Ohio State'University, I worked for CVI Corporation as a nuclear engineer in the engineering department.

In this position I assisted'n the design of BWR charcoa1 delay offgas treatment systems, including sizing, expected performance, seismic analysis, and preparation of operating procedures.

I also participated in the design of air filtration systems, and performed laboratory charcoal adsorption studies;In 1973 I joined the Nuclear Regulatory Commission (formerly AEC)as a'I nuclear engineer in the Effluent Treatment Systems Branch, Division of Site Safety and Environmental Analysis.In this position I am responsible for the review and evaluation of radwaste treatment systems and for the calculation of releases of radioactivity from nuclear power reactors.I have participated in generic studies of the relationship between'eactor operation and radwaste generation, in the preparation of staff papers and regulatory guides related to effluent control technology.

I am a member of t'e American Nuclear Society.I currently serve on the ANS 32.3 Vorking Group-Safety Related Ventilation Systems Outside Containment and the ANSI N45.8 Subcommittee

-Nuclear Power Plant Air and Gas Cleaning Systems.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

/7 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ARIZONA PUBLIC SERVICE COMPANY (Palo Verde Nuclear Generating Station, Units 1, 2, and 3))')))))Docket Nos.STN 50-528 STN 50-529 STN 50-530 SUPPLEMENTAL TESTIMONY OF NRC STAFF IN RESPONSE TO BOARD UESTION 12 by Thomas W.Green This testimony is being offered in response to Atomic Safety and Licensing Board Question 12, which reads as follows: Give the provisions that will be required of the applicant to provide grounding of'll structures likely to develop a shock hazard along transmission line rights-of-way and on space ad)scent to the right of way.

~'J The applicant will ground all transmission tower'tructures in a manner most appropriate to the tower type (e.g.wood tower will have 84 aluminum wire on the pole bonded to 84 copper wrapping around the portion of the post sunk in the ground).All fences,'metal gates and similar devices within the right-'f-way will be grounded by connecting all strands'of the fence and at least one gate hinge to a metal post which is driven into the ground.Fences which parallel the transmission line will be grounded as described above at.least once every 700 feet, or in other such manner as to prevent a section 1 from becoming insulated by cutting the fence in one place.These provisions are acceptable to the staff.Since the applicant's policy is to locate transmission lines more than 500 feet from inhabited dwellings, no specific provisions have been made for grounding various types of structures other than fences and their associated hardware.However, since final rights-of-way have not been selected, the staff is unable to verify whether such structures will be avoided.Therefore the staff will require the applicant to follow appropriate grounding precautions, 2 if necessary.

References l.Informal communication with officials of the Arizona Public Service Company and Southern California Edison Company, to be followed by formal submittal.

2.FES,-pp.5-19,20.

Y 1 PROFESSIONAL QUALIFICATIONS Thomas W.Green Argonne National Laboratory If Thomas W.Green, am an assistant ecologist in the Environmental Statement Pro)ect at Argonne National Laboratory.

My present duties include the analysis of Environmental Reports and the preparation of Environmental Impact Statements.

I have a Bachelor of Science degree in Wildlife Conservation (1968), a Bachelor of Arts degree in Zoology (1968)and a Master of Arts degree in B<<logy (1970)from California State University-Humboldt.

I also have a Doctor of Philosophy degree in Plant Ecology (1973)from Utah State University..My career has been mainly as a student in various areas of Biology-Ecology.'have taught (singley or team)several courses in biology and ecology in addition to a course in man and the environment.

'.In 1971 and 1972,I served as Vice-President of the Cache Council for Environmental Quality and participated in the Speakers Bureau qf that organization.

From August 1973 to,July 1974 I held a post.-doctoral fellowship at the University of Houston where I was interim associate director of the Coastal Research Center.This position included part time work with local high schools and]unior colleges on the impact of man on the gulf-coast environment.

My research has been in the areas of physiological reaction to stress environments (1966-1968), plant allelopathy (1968-1970), the effect of insect seed pre<'ators on the evolution and dynamics of plant populations I

PROFESSIONAL gUALIFXCATIOlhmmalogists, and the Scientists Institute for Public Information (Environment).

~~~~~~~~

v a lt 4 P UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ARIZONA PUBLIC SERVICE COMPANY (Palo Verde Nuclear, Generating Station, Units 1, 2, and 3)/Docket Nos.STN 50-528'TN 50-529 STN 50-530 SUPPLEMENTAL TESTIMONY OF NRC STAFF IN RESPONSE TO BOARD UESTION 7 by'ames'E.Carson and Ronald A.Zussman This, testimony is being offered in response to Atomic Safety and Licensing Board Question 7 which reads as follows: Evaluate the collective effect of all PVNGS cooling towers in dispersing pathogenic organisms with regard to the dust>>devil phenomenon.

Dust devils are small but vigorous whirlwinds of short duration, rendered visible by dust or sand picked up from the ground'.They should not be confused with tornadoes, however.Dust devils are formed by an entirely.mechanism than are tornadoes (which are formed in.clouds and the vortex moves downward),"~andx'are~bi ually"much.weaker.

They are best developed on clear, calm afternoons in dry areas when intense solar heating of the ground surface (surface temperatures of the order of 150 F)creates a very unstable stratification of air.This unstable condition (cooler, denser air overlying the very hot, less dense surface air)is frequently relieved by airflow into small areas where upward air motions are concentrated; angular momentum of the or'iginal air flow tends to be conserved and concentrated into the familiar rotating core of the dust device.,'ust devils come in a range of sizes.Diameters vary from 10 to more than 100 feet, and heights from a hundred to 3000 feet."" Most dust devils are of short duration (two to three 7 minutes)and cause no damage;a few may grow to very large size, last for long periods (hours)and may do significant damage to structures in their paths.Recent lidar observations of flow indicate horizontal speeds up to 49 mph.Airflows in dust devils tend to disperse particles lifted from the surface;after the vortex dissipates, the particles will fall to the ground over a larger area than the area scoured by the wind.Thus, dust devils are able to resuspend materials lying on the soil surface in the path of the vortex, and would likely be able to redisperse pathogens, if any, in the vicinity of the PVNGS cooling, towers.However, in view of the immeasurably small numbers of viable pathogens9 expected to be on the desert soil as a result of PVNGS operations, and the expected short lifetimes of most pathogens due to the sterilizing effects of intense 1 sunlight>>>>7>>(during the lifetime of the whirlwind, as well as before and after the event)*, photo-oxidation, and dessication," the staff expects no 6 impacts, whatsoever, due to the interaction of dust devils, cooling towers, and pathogens.

• Figure 1 shows the relative effectiveness of radiant energy from 2000 to 7000 nm(A).In the relatively pure air of the desert, the atmosphere is known to pass wavelengths above 2900 nm, relatively close to the germicidal peak of 2600 nm shown in the figure.Figure 2 shows typical exposures (intensity x time)for killing of a variety of microorganisms.

The intensity of radiation at approximately 2900-4000 nm is approximately 1000 to 2000 microwatts/cm (typical for the Arizona desert:).2 Although Figure 2 shows the killing effect of ultraviolet at lower radiation levels, extrapolation indicates that virtually all microorganisms would be killed within seconds in the radiation flux at the PVNGS.

Both figures are taken from Reference 7, below.1.0 0.6 0.4 k3 0.2 0.1 I~0.06 4'.04 0.02 P.O g o.or o.oo6 III.0.004 g'.002 0.001 0.0006 o 0.0002 0.0001 g 0.00006 Ia 0.00004~0.00002 0.00001'De termi ned b yL uckies h, Holladay, a nd Taylor 4ooo 5000 Navelength.

A Figure l.100 90 70 60 8 50 I o~40 30 20 C.,~I I g.I I.'~: I"." r I'.'.'*'.'I I+cp<.'q'.O N r$'I~r i~~Ir I r Ultraviolet microwatts per sq cm to kill in 1 minute.2.3.4.5.6.81.0 2 3 4 5 6 8 10 20 30 40 60 100 200 400 I I'iv<:j".'I.I 90 80 70 60 50 40 30 20 10 ,2,3.4.5.6.81.0 2 3 4 56 810 20 3040 60 Minutes to kill with an ultraviolet intensity of 1 microwatt per 10 I rr i)'~r r~~.r f 100 200 400'q cm Figure 2.

REFERENCES 1.R.E.Huschke,".Glossary of Meteorology", Amer.Meteor.Soc., Boston 638 pp.'~1959.2.S.B.Idso,"Tornado or Dust.Devil: The Enigma of Desert Whirlwinds," Amer.Scientist, 62, 530-541, 1974.3.S.B.Idso,"Whirlwinds, Density Currents, and Topographic Disturbances; A Meteorological Melange of Intriguing Interactions", Weatherwise, 28, 61-65, 1975.V 4.R.L.Schwiesow and R.E.Cupp,"Remote Doppler Velocity Measurements of Atmospheric

'Dust Devil'ortices," to be published in Applied Optics, 1976.5.B.D.Davis,"Principles of Sterilization

-Chapter 32," Bacterial and M cotic Infections of Man, 3rd Ed., R.J.Dubos, editor, J.B.Lippincott Co., Phila., Pa., 1958.N.Y., 1973.pp.216-218, 1958;Wiley, Inc., N.Y., Chapter 7, 1967.9.FES, 5.6.1.4

PROFESSIONAL QUALIFICATIONS James E.Carson Argonne National Laboratory I am a meteorologist in the Environmental Statement Project (ESP)of Argonne National Laboratory (ANL).My primary task is to write the meteorological sections (climatology and dispersion characteristics of the site, atmospheric effects of the cooling system, etc.)for the Environmental Statements for nuclear power plants and fuel facilities.

I)oined Argonne's Meteorology Group in May 1961.and transferred to ESP.in April,1972.

I have a Bachelor of Science degree in chemistry from Kent State University (1943).I did my graduate work in meteorology at The University of Chicago, receiving the Master of Science degree in 1948 and the Ph.D.degree in" 1960.I served as a weather officer and forecaster in the Air Force.While in graduate school, I served in various capacities, such as an instructor and.as a research assistant.

I was an Assistant Professor~V in the Meteorology Department at Rutgers Univepsity from 1951 to 1953, a meteorologist in the Army Quartermaster R&D Center in Natick, Massachusetts from 1953 to 1955 and an Assistant Professor of Physics at Iowa State.Universi'ty"~ii~Amds">'from'<<1955-'to 1961.0 While ab Argonne National Laboratory, I have been involved in a variety~f projects, including soil temperature and heat flux studies, I~JA Wr~~i~~I~~AWE Professional Qualifications-James E.Carson Page 2 smoke dispersion and plume rise measurements, urban dispersion models and the-atmospheric effects of thermal discharges from power plants.l have about 38 technical publications.

I am a member of the following professional societies:

American Meterological Society (Professional Member);Air Pollution Control Asso-ciation;and Sigma Xl.l am a member of APCA's TT-3 (Meterorology)

Technical Committee..

~~~~(~~~f~~0 PROFEGSXONAL QUALIFICATIONS Ronald A.Zussman hrgonne National Laboratory Hy name is Ronald A.Zussman.I am on the'staff of the Environmental Statement project of Argonne National Laboratory.

Hy principal responsibility is that of Project Leader in the preparation of Environmental Impact Statements.

My title is that of Staff Biologist.

Xn this capacity I also participate in the'valuation of biological; environmental'mpacts of proposed nuclear power generating, stations as assigned'to me.Included in these responsibilities are considerations of disease and public health as related to nuclear power plant construction and operation.

X also contribute to other environment-associated projects, both within my'department and'as a corisultant.

I sm a member of the Laboratory's Bioconversion Committee.

I joined the Environmental Statement Project in September 1972.Hhen schedules have allowed, I have also taught on a part-time basis't the graduate level in the Depaitment of Biology, Roosevelt University, Chicago, Il"inois.p I have'a Bachelor of Science degree in Biology from Loyola University of Chicago, and a Master of Science, degree and a Doctor of Philosophy degree in Mi'crobiology from the University of Illinois at the Medical Center, Chicago.From 1964 until 1972 I was employed in the Biological Sciences Division/of Abbott Laboratories, Inc., North worked in.both the Microbiology and cipal assignments were in basic and Chicago, Xllinois.During this period I Molecular Biology Departments.

Hy prin-aopl.ied res: arch r~'.la".ed to Biology, Invertebrate Pharmacology, Virology, Parasitology, Microbiology, and Immuno-chemistry.

Hy major efforts in Invertebrate Pharmacology involved the study of the effects of bfo]ogical]y active a~~;.nt." upon l)~.~hnia, St]aria Arte;gaia

~g dra, pianarie, and various Protosoans.

>ty interests in Virology were focused principally upon Herpesvirus, Xnfluenzavirus, and Bacteriophage.

My studies in Microbiology, Parasitology, and Immunochemistry have been mostly oriented I toward the medical and public health aspects of organisms which cause human and animal diseases.r Prom 1960 to 1963, while a graduate student, I also held the full-time.position of Optical Instructor/Optical Supervisor at the Adler Planetarium and Astronomical Museum, Chicago.From 1958 to 1963 I was a Teaching Assistant and a Research Assistant in.the Department of Microbiology; University of Illinois College of Medicin'e,Chicago.During my professional career, not including my Master's and Doctor'Theses, I have published approximately a dozen papers in learned journals such 1 as the Journal of Bacteriology, Mycopathologia, Journal of Parasitology, I" Journal of Cell Biology, and Applied Microbiology.

I have also published.several articles on optical technology.

I have presented papers before the American Society for Microbiology, the Chicago Hedical Hycological Society', the American Society of Parasitologists, the Society of Sigma Xi, the Illinois Society of Hicrobiologists, and others'.Xn 1969, X invented a scientific device, assigned to Abbbtt Laboratories, Inc.I am a member of.the International Association for Great Lakes Research, the American Society for Microbiology, the American Society.of Parasitologists,.the Chi'cago Medical Mycological Society, and the Society of the Sigma Xi.

..y)~~I)c.,z Rearm coaazSpommrcz JUN O g 1981 u,si wcw~~~NUCLEAR REGULATORY COMMISSION gogHilSSQ<

FORE THE ATOMIC SAFETY AND LICENSING BOARD"'J~e ,4'Aves 8 f98~>y>+thetec.~~or FizecÃ4 se,'n the Matter of:))ARIZONA PUBLIC SERVICE COMPANY, et al.))(Palo Verde Nuclear Generating Station,)Units 1, 2 and 3))))Docket Nos.STN 50-528 STN 50-529 STN 50-530 INTERVENOR'S FIRST SET OF INTERROGATORIES TO JOINT'APPLICANTS INSTRUCTIONS A.Unless otherwise indicated, information requested herein shall be for the time period beginning with the date of application for the construction permit through the expected life of the Plant.B.In responding to these interrogatories, you may refer to the Final Safety Analysis Report and Environmental Report-Operating License Stage Report and other documents required by 10 C.F.R.5 51.1 et seq., where appropriate.

However, these interrogatories seek information not included in such documents and it is expressly in-tended that the disclosure of such additional information be made.C.Any pronoun shall mean the masculine, feminine~or.neuter gender, and singular or plural, as in each case may be appropriate.

D.Where knowledge or information in your possession is requested, such request includes knowledge of your agents, represen-tatives, employees and, unless privileged, your attorneys; and 8106000)$3 1 1 W h further, in answering these interrogatories, you are to furnish such information as is available to you, not merely information which is of your own knowledge.

This means information known by or in the possession of your agents or employees, including your attorneys or any agents who have investigated such matter for you or your attorneys.

E.A space has been provided on the form of inter-rogatories for your answer.In the event that the space provided is not sufficient for your answer to any of the following questions, please attach a separate sheet of paper with the additional in-formation.

F.These interrogatories shall be deemed continuing, re-quiring you to serve upon intervenor further and supplemental written answers,.without notice or demand, promptly after aequi'ring further information with respect to the subject matter of any of these interrogatories.

DEFXNITZONS A."A.T.W.S." shall mean anticipated

'transient without scram.B."C.E." shall mean Combustion Engineeing, Inc., of Windsox, Connecticut.

C."Document" is used in its customary broad sense to include, without limitation, the following items, whether printed, recorded, filmed, reproduced by any process, written or produced by hand, and whether or not claimed to be privileged against discovery on any ground, and whether an original, master or copy: agreements, communications, including intracompany communications and correspondence; cablegrams, radiograms and telegrams; notes and memoranda; summaries, minutes and records of telephone conversations, meetings and conferences, including lists of persons attending meetings or conferences; summaries and records of personal conversations of interviews; books, manuals, publications and,diaries; charts;plans;sketches and drawings;photographs; reports and/or summaries of investigations and/or surveys;opinions and reports of consultants; opinions of counsel;reports and summaries of negotiations; brochures; pamphlets; catalog..and catalog sheets;drafts of original or pre-liminary notes on, and marginal comments appearing on, any docu-ments;other reports and records;and any other information-containing paper, writing or physical thing in the possession, custody or control of the Joint Applicants.

P D."E.R.-O.L." shall mean Environmental Report-Operating License Stage.E."F.S.A.R." shall mean the Final Safety Analyis Report (operating license).F."N.R.C" shall mean the Nuclear Regulatory Commission.

G."On site treatment facility" shall mean the sewage effluent treatment facility located at the Palo Verde Nuclear Generating Station.H."Person" or"persons" shall mean, without limitation, all entities including all predecessors in interest, individuals,'F associations, companies, partnerships, joint ventures, corporations, subsidiaries, trusts, estates, departments, bureaus, public agencies and boards.Z."Plant" shall mean the Palo Verde Nuclear Generating Station, Units 1, 2 and 3.J."You'or"your" means the Joint Applicants, Arizona Public Service Company, Salt River Project Agricultural Zmprovement and Power District, Southern California Edison Company, El Paso Electric Company and Public Service Company of New Mexico.K."23rd Avenue facility" shall mean the sewage treatment facility operated by the City of Phoenix at 23rd Avenue.L."91st Avenue facility" shall mean the sewage treatment facility operated by the City of Phoenix at 91st Avenue.

CONTENTION NO.1 l.Are radiati'on monitoring devices installed in the cooling towers?If so, please describe for each cooling tower where each device is located and describe each in detail.2.Identify every document that supports or tends to support your answer to No.1 above.3.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.'above.4.Do any schools within a 25-mile radius of the plant have radiation monitoring devices for gathering baseline data?If so, please identify the schools, give all data on frequency of reading each monitoring device and identify each person who does the reading and who has access to the devices.

5.Identify every document that supports or tends to support your answer to No.4 above.6.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.4 above.7.What is the background radiation level at the Plant?What contribution do natural radioactive gases have in this level?8.'Identify every document that supports or tends to support your answer to No.7 above.9.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.7 above.10.In Curies, what is the anticipated inventory of radioactive gases contained inside the reactor?This in-formation should be given for each reactor if differences in the inventories are anticipated.

ll.Identify every document that supports or tends to support your answer to No.10 above.12.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.10.above.13.In Curies, what is the anticipated inventory of radioactive gases contained in the r ad-waste building of each reactor?

14.Identify every document that supports or tends to support your answer to No.13 above.15.Identify each person who knows or.claims to have know-ledge or information establishing or tending to establish your answer to No.13 above.16.Describe the location and volume of release, in Curies, of all point sources of radiological gaseous effluents from all structures at each reactor.This'information should in-elude but not be limited to, a discussion of the height of any and all effluent stacks, their relative proximity to each other and a description of any mitigating.

filters.17.Identify every document that supports or tends to support your answer to No.16 above.

1 18.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.16 above.19.Provide the information requested in Nos.10, 13 and 16 above for each existing and operating C.E.reactor, including those reactors with less than one year operating experience.

20.Identify every document that supports or tends to support your answer to No.19 above.I 21.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.19 above.22.Have you identified any existing radiological point sources in a 50-mile radius of the Plant?These would include but not be limited to point sources of gaseous radioisotopes, aerosols, solids and liquids.23.Identify every document that supports or tends to support your answer to No.22 above.24.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer.to No.22 above.25.Identify all persons, to include their qualifications, who in any way authorized, devised, derived or formulated the recom-mendations and discussions contained in N.R.C.Regulatory Guide 1.109, Rev.1.26.Please identify all documents which were relied upon in developing N.R.C.Regulatory Guide 1.109, Rev.l.

27.Identify all persons, to include their qualifications, who in any way authorized, devised, derived or formulated the GASPAR computer model.28.Please identify all documents, to include mathematical working papers and computer programs (software) used in any way in connection with the GASPAR computer model.29.In a fashion Similar to that contained in Tables SB-l through 5B-7, Appendix 5B, E.R.-O.L., provide a detailed account of estimated individual doses (in millirems) from annual, historical, operating release of gaseous effluents from each existing and opera-ting C.E.reactor, including those C.E.reactors with less than one year operating experience.

30.Identify every document that supports or tends to support your answer to No.29 above.

31.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.29 above.32.Describe all calculations, including but not limited to all mathematical working papers, computer printouts and other data, used to arrive at the individual dose estimates contained in Tables 5B-1 through 5B-7 of Appendix 5B of Sec.5, Vol.IV.of your E.R.-O.L.33.Identify every document that.supports or tends to support, your answer to No.32 above.34.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.32 above.

35.What were the methods used to reach the calculations of individual dose estimates in the tables discussed in No.32 above?Include any information which specifically addresses the names of these methods, their authors and their qualifications, computer models used to employ them and any other data.36.Identify every document that supports or tends to support your answer to No.35 above.37.Identify each person who knows or claims to have know-J ledge or information establishing or tending to establish your'answer to No.35 above.38.What methods were used to verify compliance with Appendix I 10 C.F.R.g 50 and 40 C.F.R.5 190?Identify all persons, to include their qualifications, who in any way arrived at the claim of compliance.

39.Identify every document that supports or tends to support your answer to No.38 above.40.Identify all documents used for any calculations contained in Sec.5 and its Appendices of your E.R.-O.L.pertaining to health physics.41.Describe all topographical features, meteorological data, 50-mile radius population figures, local agricultural products includirg but not limited to all vegetables, citrus, dairy and meat operations, in a 50-mile radius for each operating C.E.reactor including those C.E.reactors with less than one year operating ex-perience.42.Identify every document that supports or tends to support your answer to No.41 above.43.Identify each person who knows.or claims to have know-ledge or information establishing or tending to establish your answer to No.41 above.10 44.List all possible radiation food chain pathways.45.Identify every document that supports or tends to support your answer to No..44 above.46.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.44 above.47.With respect to each pathway identified in No.44 above, please state the lengths in pathways in types of radioactive nuclides expected to enter such pathways.48.Identify every document which supports or tends to support your answer to No.47 above.

49.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.47 above.50.Have you done any study or investigation to determine whether low level radioactive emissions from the Plant will have any genetic effects on the population, including the unborn, within a 50-mile radius of the Plant?51.Identify every document that supports or tends to support your answer to No.50 above.52.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.50 above.12 53.Have you done any study or investigation to determine whether low level radioactive emissions from the Plant may result in increases in deaths from cancer?54.Identify every document that supports or tends to support your answer to No.53 above.55.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.53 above.56.Identify all studies which you have done or done by local, state or federal governmental and non-governmental entities, of the individual dose estimates from the consumption of all citrus grown within a 50-mile radius of the Plant during normal operation of each reactor block.This information should include estimates based on the release of routine reactor gaseous effluents from the operation of Unit 1 or.each reactor block hand from the cumulative operation of all three reactors.

57.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.56 above.58.What are the locations, production volumes, soil types, growing seasons and specific commodity(s) of all citrus operations within a 50-mile radius of the Plant?Identify these operations by the name or title of operating companies or indi-viduals, their addresses and telephone numbers.59.Identify every document that supports or tends to support your answer to No.58 above.60.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.58 above.14 61.Identify all vegetable growing operations within a 50-mile radius of the Plant.This information should include but not be limited to the locations of such operations, the names and addresses and telephone numbers of all owners and/or operators of such operations, and the general topographical and soil property features of lands on which these operations are based.62.Identify every document that supports or tends to support your answer to No.61 above.63.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.61 above.64.Identify all animal producing operations within a 50-mile ra iius cf the Plant.Animal producing operations is defined as any agricultural business which raises livestock for the purpose of sale to commodity markets for use as food for human consumption or any operation, however small, in which livestock is raised for eventual consumption by humans.This information should include the names, addresses and telephone numbers of all owners and operators of such animal producing operations; whether these feeds are grown 15 locally or processed elsewhere and imported;and all livestock operations to include beef, meat-packing, poultry, dairy, sheep, swine (pork)and any other designed for eventual human consumption.

65.Identify every document that supports or tends to support your answer to No.64 above.66.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.64 above.67.Describe in detail each peice of equipment listed in Tables 5B 8 through 5B ll, Appendix 5B, E.R.-O.L.The description should include the names, addresses and telephone numbers of manu-facturers of such equipment; how each piece of equipment operates;the manufacturer's sale price to the applicant; and any other in-formation pertinent to understanding why such equipment would be necessary and how it works.16

68.Please identify all documents which pertain to the requested information and which relate how such equipment has operated historically in other nuclear reactors.69.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.68 above.70..Explain all methods used in determining the cost benefit analysis in Sec.5B.4, Appendix SB, E.R.-O.L., including but not limited to, the historic evolution of cost benefit analysis whose goal is to"effect reduction in dose to the population reasonably expected to be within 50 miles of the reactor." 71.Please identify all documents pertaining to cost benefit analysis and any computer models and mathematical working papers used in arriving at the conclusion of Sec.5B.4.17 72 Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.71 above.73.What is the basis for the statement"the prevailing (wind)direction is from the east" contained in Sec.2.3.1.1.3.

of Vol.II of the F.S.A.R.?74.Identify every document that supports or tends to support your answer to No.73 above.75.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.73 above.76.What are the sources for Figs.2.3.2 through 2.3.14 in Sec.2.3 of Vol.II of the F.S.A.R.?18 77.Identify every document that supports or tends to support your answer to No.76 above.78.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.76 above.79.Provide a detailed description of all studies per-taining to wind directions at the Plant site and to a 50-mile radius outside it that was not included in Sec.2.3, Vol.II, F.S.A.R.80.Identify every document that supports or tends to support your answer to No.79 above.81.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.79 above.19 82.Describe in detail the names, types and specifications of all filters or any other mitigating equipment installed in gaseous release effluent stacks for each reactor block at the Plant.83.Identify all documents relevant to determining the adequacy of such filters, including, but not limited to, manufacturers'ames, addresses and telephone numbers;retail price of such equipment; and the historical use of such equipment in other operating reactors.84.Identify all meteorological data available to you not contained in any filings in this case to date.Such information should include, but not be limited to, annual precipitation by month;monthly wind roses;ambient site termperatures on a monthly basis;and any information pertinent to local meteorological conditions.

85.Identify all commodity related agricultural operations within a 50-mile radius of the Plant.'uch inventory should include, but, not be limited to, all cotton growing operations; cottonseed oil production facilities; alfalfa or legume growing operations; wheat, 20 corn, soybeans, oats, flax, barley operations including flour milling facilities; and any other agricultural operation in which commodities are grown for ultimate use of consumption by humans.The inventory also should include the names, addresses and tele-phone numbers of the owners and operators of such facilities.

86.Identify every document that supports or tends to support your answer to No.85 above.86'Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.85 above.21 87.Provide a detailed description of the seasonal water flows in all surface-water systems within a 50-mile radius of the Plant.This information should include, but not be limited to: A.The name and location of the water system;B.All pertinent hydrologic and geologic information about such system;C.The highest historical peak flow in each system;D.The average non-peak flow of each system;E.The average peak flow of each system;F.In-flow rates from each system to underlying aquifers.88.Identify every document that supports or tends to support your answer to No.87 above.89.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.87 above.22 90.What are the local and regional underground water systems within a 50-mile radius of the Plant?Give their location, geology and lithology, in-flow rates from adjacent aquifers and surface waterways, water quality and any other pertinent information.

91.Identify every document that supports or tends to support your answer to No.90 above.92.Identify each person who knows or,'laims to have know-ledge or information establishing or tending to establish your answer to No.90 above.93.What drinking water and livestock watering wells have been identified within a 50-mile radius'of the Plant'P Please state the following information for each well: A.Local geology including host aquifer;B.Quality of waters from each well (to include a 23 reasonable description of various radiological and chemical constituents, including but not limited to, gross alpha, total radium, sulfates, TDS, TSS, conductivity, pH, etc.);C.The names, addresses, telephone numbers of all persons who own or possess these wells or who receive waters from them.94.Identify every document that supports or tends to support your answer to No.93 above.95.Identify each person who knows ox'laims to have know-ledge or information establishing or tending to establish your answer to No.93 above.96.What transport factors were used for uptake of radioactive isotopes, namely cesium, cobalt, strontium and plutonium into agricultural products, milk and meat?24 97'dentify every document that supports or tends to support your answer to No..96 above.98.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.96 above.99.Have you considered the effect of local and regional atmos+ric temperature inversions in estimating the distribution of radioactive material emitted from the Plant?please explain.If so, 100.Identify every document that supports or tends to support your answer to No.99 above.101.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your 25 answer to No.99 above.CONTENTION NO.5 102.What agreements or contracts exist with respect to assuring a supply of treated effluent for the Plant?103.Identify every document that supports or tends to support your answer to No.102 above.104.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.102 above.105.Assuming treated effluent would not be available for cooling purposes, what agreements or contracts exist with respect to assuring an alternative supply of water for such purposes?26 106.Identify every document that supports or tends to support your answer to No.105 above.107.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.105 above.108.Why did you chose to use sewage effluent to cool the Plant?109.Identify every document that supports or tends to support your answer to No.108 above.27

'1~110.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.108 above.ill.Are there any other nuclear plants in the United States operating or under construction, that use or will use sewage effluent'or cooling purposes?state the name, location and M.W.rating.If so, please\112.Have there been any amendments or modifications to Agreement No.13904, Option and Purchase of Effluent executed April 23, 1973?ment or modification.

If so, please identify each amend-113.Have any rights, claims, complaints or demands been asserted challenging the agreement referred to in No.112 above, in whole or par0?If so, please state: A.The party asserting the claim;B.The nature of the claim;C.Your response to the claim.28 114.Identify every document which supports or tends to support your answer to No.113 above.115.Have you entered into any agreements or contracts relating to disposal of sewage effluent?describe all such agreements.

If so, please 116.Identify every document which supports or tends to support your answer to No.115 above.117.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.115 above.29 118.Have you applied for C.A.P.water?If so, please state: A.The quantity of water sought;B.Projected date of delivery;C.What impediments exist or might exist to prevent delivery;D.Whether the w'ater will require treatment of any kind;E.For what period would you intend to r eceive C.A.P.water.119.Identify every document which supports or tends to support your answer to No.118 above.120.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.118 above.30 121.Do you plan to obtain effluent by means of tradeoffs for C.A.P.water?If so, please explain.122.Identify every document which supports or tends to support your answer to No.121 above.123.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.121 above.124.Describe the basic design for the 91st Avenue facility and the on site treatment facility.125.Identify every document that supports or tends to support your answer to No.124 above.31 126.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.124 above.127.Describe all treatment processes at the 91st Avenue facility and the on site treatment facility.128.Identify every document that supports or tends to support your answer to No.127 above.129.Identify each person who knows or claims to have know-ledge or information establishing o'r tending to establish your answer to No.127 above.32 130.Please identify all blueprints of the on site treatment facility and the 91st Avenue facility to include connections between the 91st Avenue facility and the on site treatment facility and between the on site treatment.

facility and each unit.131.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.130 above.132.Has the 91st Avenue facility ever been the subject of any investigation, audit, complaint or lawsuit by any federal, state, county or other agency?If so, please state: A.The agency making the investigation, audit, complaint or lawsuit;B.The date;C.D.The nature of the investigation; The findings of the investigation; E.The disposition of the investigation.

33 133.Identify every document that supports or tends to support your answer to No.132 above.134.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.132 above.135.Describe the organization including functional organization of the on site treatment facility and the 91st Avenue facility.136.Identify every document that supports or tends to support your answer to No.135 above.34 137.Identify each person who knows or claims to have, know-ledge or information establishing or tending to establish your answer'to No.135 above.138.Please identify each person with supervisory re-sponsibility for the construction of the on site treatment facility.139.With respect to the on site treatment facility, please identify each job category, description and qualifications, and N.R.C.technical specifications and/or guidelines regarding water quality.140.With respect to the 91st Avenue facility identify each person who is an operator or technician.

35 141.How do you propose to transport the effluent from the 91st Avenue faci,lity and the 23rd Avenue facility to the on site treatment facility?142.Identify every document that supports or tends to support your answer to No.141 above.143.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.141 above.144.Please describe the current stage of construction with respect to your answer to No.141 above.36 145.Identify every document that supports or tends to support your answer to No.144 above.146.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.144 above.147.With respect to the 91st Avenue facility and the 23rd Avenue facility, for the past five years please state: A.Annual flow records;B.Each day's total minimum and maximum flow records.148.Identify every document that supports or tends to support your answer to No.147 above.149.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.147 above.37-150.Please provide projections of monthly peak flows from the 91st Avenue facility and the 23rd-Avenue facility to the Plant and daily minimum and maximum flows.Show all calculations and specify any standards referenced and assumptions made.151.Identify every document that supports or tends to support your answer to No.150 above.152.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.150 above.38 153.What will be the monthly peak demand of McDonald farms and Roosevelt Irrigation District from the 23rd Avenue facility?154.Identify every document, that supports or tends to support your answer to No.153 above.155.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.153 above.156.What will be the expected monthly peak demand of the Buckeye Irrigation District from the 91st Avenue facility?39 157.Identify every document that supports or tends to support your answer to No.156 above.158.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.156 above.159.If peak monthly demand will vary subsequent to the first full year of operation of all three units, please explain.160.Identify every document that supports or tends to support your answer to 159 above.40 161.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.159 above.162.What is the peak monthly demand of treated effluent for each month of the first full year of opera'tion af.all three units?163.Identify every document that supports or tends to support your answer to No.162 above.164.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.162 above.41 165.Will there be any loss in treated effluent be-tween the discharge from the treatment plants and delivery at the Plant?If so, what percentage of effluent available from the treatment plants will be lost'P 166.Identify every document that supports or tends to support your answer to No.165 above.167.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.165 above.168.What, is the minimum acceptable effluent flow to the Plant assuimg the following:

A.Unit 1 is in service and operating at: (1)25/capacity (2)50/capacity (3)75/capacity 42 (4)85/capacity B.Units 1 and 2 are in service and both are operating at: (1)25/capacity (2)50/capacity (3)75/capacity (4)85/capacity C.Units 1, 2 and 3 are in service and are operating at: (1)25/o capacity (2)50/o capacity (3)75/capacity (4)85/capacity 169.What will be the effect on delivery of effluent if the M.A.G.flow reduction programs in the Phoenix area are im-plemented to decrease sewer flow/water use?170.Identify every document that supports or tends to support your answer to No.169 above.43 171.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.169 above.172.What will be the effect on delivery of treated effluent if: A.The 91st Avenue facility is not expanded any futher?B.The 91st Avenue facility is not expanded on schedule?173.identify every document that supports or tends to support your answer to No.172 above.174.Xdentify each person whoknows

'or..cia'ims to have know-ledge or information establishing or tending to establish your answer to No.172 above.44 175.Is each unit connected to the on site treatment facility independently?

176.Identify every document that supports or tends to support your answer to No.175 above.177.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.175 above.178.Describe all of your requirements for effluent quality for the cooling of the Plant.179.Identify every document that supports or tends to support your answer to No.178 above.45

~~j~180.Identify each person who knows or claims to have know-I ledge or information establishing or tending to establish your answer to No.178 above.181.What testing, monitoring and analytical methods and procedures will be used to determine the quality of treated effluent?How often will such tests and monitoring be conducted?

182.identify every document that supports or tends to support your answer to No.181 above.183.Xdentify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.181 above.46

~~184.Identify the content of iodine and salts in the sewage effluent before and after the treatment process at the on site treatment facility.185.Identify every document that supports or tends to support'our answer to No.184 above.186.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.184 above.187.Also, what is the filter system for the on site treatment facility?188.Identify every document that supports or tends to support your answer to No.187 above.47 189.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.187 above.190.What amount of salts and iodine remains in the on site treatment facility after filtering?

191.Identify every document that supports or tends to support your answer to No.190 above.192.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.190 above.48 193.What system will be used to treat sewage effluent at the on site treatment facility?Specify treatment system and equipment, capacity, processes used, supplies needed, personnel, training and supervision.

194.Identify every document that supports or tends to support your answer to No.193 above.195.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.193 above.196.Please identify what water will be used for back-up in the event of system failures.49 197.Identify every document that supports or tends to support your answer to No.196 above.198.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.196 above.199.If the on site treatment plant cannot provide the quality of effluent required, what methods will mitigate the problem?200.Identify every document that supports or tends to support your answer to No.199 above.50 201.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.199 above 202.Describe any and all licensing conditions and technical specifications of any regulatory or governmental authority which are related to operation of the on site treatment facility.203.Identify every document that supports or tends to support your answer to No.202 above.204.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No;202 above.51 205.What amount of effluent from the 91st Avenue facility or the 23rd Avenue facility will be of unacceptable quality for cooling purposes?206.Identify every document that supports or tends to support your answer to No.205 above.207.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.205 above.208.Please describe what eff'ect prolonged dependence on groundwater would have on the following:

A.Adjacent groundwater levels;B.Adjacent groundwater quality;C.Seismic activity in a 10-mile radius.52 209.Identify every document that supports or tends to support your answer to No.208 above.210.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.208 above.211.Please.identify all documents determining projected seasonal variations with respect to sewage effluent quality.212.If groundwater is to be used for back-up cooling purposes, what would be the long-term effect on the Plant of its prolonged use?53 213.Identify every document that supports or tends to support your answer to No.212 above.214.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.212 above.215.If any testing procedures at the 91st Avenue facility, deviate from applicable federal, state or county water quality or pollution control standards or regulations, provide complete justification and documentation for each deviation from standard methods.54 216.Identify every document that supports or tends to support your answer to No.215 above.217.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.215 above.218.Describe all waste and by-products from the treat-ment process expected at the on site treatment facility.219.Identify every document that supports or tends to support your answer to No.218 above.55 220.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.218 above.221.If prolonged dependence on groundwater becomes necessary, what effects have you calculated for subsidence?

222.Identify every document that supports or tends to suport your answer to No.221 above.223.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.221 above.56 224.Describe the method and identify the location for disposal of each and every waste product from the on site facility.225.Identify each document that supports or tends to support your answer to No.224 above.226.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.224 above.CONTENTION NO.6B 227.Please identify all documents relating to your estimates and probabilities of A.T.W.S.accident occurrence in C.E.reactors and compare such to N.R.C.'s postulated probabilities for C.E.plants.57 228.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.227 above.229.Please identify all documents pertaining to the latest methods for mitigating A.T.W.S.problems, to include all of your correspondence with any federal agency or consultant.

230.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.229 above.231.Please identify all C.E.documents relating to A.T.W.S.testing and mitigation measures.58 232.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.231 above.233.For C.E.reactors in service, please identify each document pertaining in any manner to an analysis of A.T.W.S.accident probabilities.

234.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.233 above.235.Please identify all N.R.C.and C.E.documents relating to failure of control rods to insert upon: A.Manual command;B.Automatic command.59 236.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.235 above.237.Please identify all documents relating to the history of Syst: em 80 control rod drive mechanism performance in all operating reactors in the United.States.238.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.236 above.239.Please identify all documents relating to specifications of System 80 control rod drive mechanism design for all C.E.reactors.60 240.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.239 above.241.Please identify all documents relating to descriptions, and specifications, including cost data, on all pressurized water reactors which have installed new equipmen0 designed to mitigate A.T.W.S.after completion of reactor construction.

242.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.241 above.CONTENTION NO.7 243.What is your estimate of the cost, of decommissioning the Plant'61 244.Identify every document that supports or tends to support your answer to No.243 above.245.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.243 above.246.What method of decommissioning the Plant do you intend to use?247.Identify every document that supports or tends to support your answer to No.246 above.62 248.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.246 above.249.Why have you selected this method'250.Identify every document which supports or tends to support your answer to No.249.251.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.249 above.63 252.Provide the name, location and size in M.W.of any nuclear reactor ever decommissioned.

What was the cost of decom-missioning in each case?What was the initial estimated cost of decommissioning?

253.Identify every document that supports or tends to support your answer to No.252 above.\254.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.252 above.255.What is the N.R.C.'s estimate of decommissioning as a percentage of construction cost f'r a reactor of 1000 M.W.or more?64 256.Identify every document that supports or tends to support your answer to No.255 above.257.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.255 above.258.In what year, for each reactor do you anticipate decommissioning?

259.Identify every document that supports or tends to support your answer to No.258 above.260.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.258 above.65 4~~261.How do you plan to pay for the cost of de-commissioning?

262.1dentify every document that supports or tends to support your answer to No.26l above.263.1dentify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.258 above.'263.If the cost of decommissioning is to be passed on to the consumers receiving electricity from the Plant, how will you do this?264.Identify every document that supports or tends to support your answer to No.263 above.66 265.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.263 above.CONTENTION NO.8 266.Assuming the base mats for Units 1 and 2 were not properly poured, please describe the accident possibilities which would result.267.Identify every document that supports or tends to support your answer to No.266 above.268.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.266 above.67 269.Please describe how 0he reactor system rests on the base mats on Units 1 and 2.270.Identify every document that supports or tends to support your answer to No.269 above.271.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.269 above.272.Where is the reactor cavity located in comparison to Units 1 and 2?273.Identify every document that supports or tends to support your answer to No.272 above.68 274.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.272 above.275.How much weight must the base mats for Units l and 2 hold?276.Identify every document that supports or tends to support your answer to No.275 above.277.Identify every person who knows or claims to have knowledge or information establishing or tending to establish your answer to No.275 above.69 278.What is the foundation for Units 1 and 2?279.Identify every document that supports or tends to support your answer to No.278 above.280.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No'.278 above.281.Are there agreements or contracts between Bechtel Corp.and Engineering Testing Laboratory?

70 282.Identify every document that supports or tends to support your answer to No.281 above.283.Identify each person who knows of claims to have know-ledge or information establishing or tending to establish your answer to No.281 above.284.Describe all safety reports and testing results made by Engineering Testing Laboratory with respect to the Plant.1 285.Identify every document that supports or tends to support your answer to No.284 above.286.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.284 above.71 287.Describe all concrete pouring test results during the period December, 1977 through March, 1981 with respect to the base mats for Units 1 and 2.288.Identify every document that supports or tends to support your answer to No.287 above.289.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.287 above.290.Please identify all structural engineers, field engineers, and supervisors who have worked for Bechtel Corp.and E.T.L.for the period December, 1977 through March, 1981 at the Plant.72 291.Zdentify-every-support-yoar-answer-to-No-.-2953-~ve; 292.T.denti fy-each~rson-~Hmo~~~~~~~ve-~w-ledge-or-inf ormation-establishing

~~nding~~~1-.ash-~m-answer to No.290 above.293.Please-identify all persons who performed slump tests for the base mats for Units 1 and 2 during the period of December, 1977 through March, 1981.sappzrt-yoaz-ansmer-to-5o-.-203-Mme.

73 295.identify-each~~~~~~~l~ims-~~we-~w-Kedge-or-information-establishing

~ending-~mMol~~ur--

answer-to-No-.-295-above.

296.Please describe how a concrete slump test is performed.

297.Identify every document that suppcrts o'r tends to support your answer to No.296 above.298.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.296 above.74 299.What are the specifications for the concrete for the base mats for Units 1 and 2?300.Identify every document that supports or tends to support your.answer to No.299 above.301 Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.299 above.302.What specifications exist, if any, with'espect, to the cement which would be used in the base mats or with respect to the slump tests on the base mats either established by Bechtel, E.T.L.or the N.R.C.'P 75

'~303.Identify every document that supports or tends to support your answer to No.302 above.304.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.302 above.305.What are the stress requirements for the reinforced steel for the base mats for Units l and 2?306.Identify every document that supports or tends to support your answer to No.305 above.76 307.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.305 above.308.What specifications or regulations apply to the reinforced steel for the base mats for Units 1 and 2?309.Identify every document that supports or tends to support your answer to No.308 above.310.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.308 above.77 FURTHER QUESTIONS RELATING TO CONTENTION NO.1 311.How much tritium gas (H3)is released from each reactor block under normal operation for each year of operation?

312.Identify every document that supports or tends to support your answer to No.311 above.r 313.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.311 above..314.From what piece of equipment, plant stack, or other point source is H3 released.315.Identify every document that supports or tends to support your answer to No.314 above.78 316.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.314 above.317.What are the conditions under which H3 is released'18.

Identify every document that supports or tends to support your answer to No.317 above.319.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.317 above.79 320.Will routine releases of gaseous reactor effluents be regulated to achieve a'constant release', rate?is the rate?If so, what 321..Identify every document that supports or tends to support your answer to No.320 above.322.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.320 above.323.If the answer to No.320 above is no, are shorter releases of greater quantities of gaseous reactor effluents anticipated?

80 324.Identify every document that supports or tends to support your answer to No.323 above.325.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.323 above.326.If the answer to No.320 above is yes, are these short-term releases treated separately in dose calculations or included in averaged annual releases from which the dose calculations in Appendix 5B of E.R.-O.L.are derived?327.Identify every document that supports or tends to support your answer to No.326 above.81 328.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.326 above.329.What information has been gathered and what analyses have been made of exposure to short-term releases of gaseous radio-effluents in quantities greater than the annual average for the following:

A.Individuals (human);B.Citrus nearing budding periods;C.Food-animals during gestation periods;D.Other plants grown for human consumption.

330.Identify every document that supports or tends to support your answer to No.329 above.82 331.Identify each person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.330 above.332.Are any radionuclides released during normal operating conditions not subject to infiltration or other contaminant-removal systems'f the answer is no, please state from which piece of equipment such releases occur, when and under what conditions such releases occur, and in what volume (in Curies).333.Identify every document that supports or tends to support your answer to No.332 above.334.Identify each.person who knows or claims to have know-ledge or information establishing or tending to establish your answer to No.332 above.83 QUESTIONS RELATING TO ALL CONTENTIONS 335.Do you intend to call witnesses in this proceeding?

If so, with respect to each contention, identify each person you intend to call and for each state: A.The witness's professional and educational background; B.The nature of the witness's testimony, include a brief summary;C.Identify all documents upon which the witness intends to rely, to include any research or study conducted by the witness, whether or not such studies will be relied upon.336.With respect to.each contention, please identify.all documents which you have prepared in relation to or in connection with this proceeding.

337.To the extent: not mentioned in No.336 above, please identify all documents that you intend to rely upon in this proceeding.

84 338.Subsequent to the completion of the Draft Environ-mental Impact Statement, have you.been requested by an agency of federal, state or local government, to provide any documents or information relating to the Plant'P 339.If so, for each request, please state the following:

A.The name of the agency and person requesting the information; B.The date of'he request;C.A brief summary of the nature of the request;D.A brief summary of your response;E.The person submitting the response.340.Identify each document, that supports or tends to support your answer to No.339 above.341.Please identify all documents which you used to prepare the F.S.A.R.and the E.R.-O.L.-'85 DATED this ay of a , 1981.Bru Meyerson Arizona Center for Law in the Public Interest 112 North Fifth Avenue Phoenix, Arizona 85003 (602)252-4904 Attorney for Intervenor Copy th foregoing hand-delivered this y of May, 1981, to: Arthur C.Gehr, Esquire Snell 6 Wilmer 3100 Valley Bank Center Phoenix, Arizona 85073 and mailed to:.Robert M.Lazo, Chairman Atomic Safety and Licensing Board Panel United States Nuclear Regulatory Commission Washington, D.C.20555 Dr.Richard F.Cole Atomic Safety and Licensing Board United States Nuclear Regulatory Commission Washington, D.C.20555 Dr.Dixon Callihan Union Carbide Corpor'ation Post Office Box Y Oak Ridge, Indiana 37830 Docekting and Service Branch Secretary of the Commission United States Nuclear Regulaltory Commission Washington, D.C.20555 86 Henry J.McGurren, Esquire Office ofthe Executive Legal Director United States Nuclear Regulatory Commission Wa'ngton, D.C.20555 87