ML20069D156

First Set of Interrogatories.Certificate of Svc Encl.Related Correspondence

ML20069D156
Person / Time
Site:	Palo Verde
Issue date:	03/15/1983
From:	Berlin K WEST VALLEY AGRICULTURAL PROTECTION COUNCIL, INC.
To:	JOINT APPLICANTS - PALO VERDE
References
NUDOCS 8303180289
Download: ML20069D156 (22)

Text

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- EELf.T:n r.--- m,7 C . "i ~ D UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ,, ,,,,,.

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

ARIZONA PUBLIC SERVICE COMPANY ) Docket Nos. STN 50-529

) 50-530 (Palo Verde Nuclear Generating )

Station, Units 2 and 3) )

PETITIONER WEST VALLEY AGRICULTURAL PROTECTION COUNCIL, INC. ' S FIRST SET OF INTERROGATORIES DIRECTED TO JOINT APPLICANTS Pursuant to 10 C.F.R. $2.740b, and pursuant to the Atomic Safety and Licensing Board Order governing discovery in this matter dated March , 1983, petitioner West Valley Agricultural Protection Council, Inc. (West . Valley) requests Joint Applicants to answer the following interrogatories, under oath and in writing, by April 15, 1983.

DEFINITIONS AND INSTRUCTIONS

1. As used herein " document" shall mean the original i

and any non-identical copies and drafts of any written, ree"ided or i

i graphic matter, however produced or reproduced.

2. As used herein " person" includes, without limitation, a natural person, partnership, corporation, association, joint venture, trust, estate, or any other form of organization or association.

3. " Identify" when used herein in reference to a natural person, shall mean to state his full name and present 8303180289 830315 PDR ADOCK 05000529 G PDR

2 address, his present or last known position and business affiliation, and his position at the time in question.

4. " Identify" when used herein in reference to any entity other than a natural person, shall mean to state its full name and the address of its principal place of business.

5.. " Identify" when used herein in reference to a document, shall mean to state the type of document, its date and author, any other characteristics necessary to identify the document, and its present location or custodian.

6. " Identify" when used herein in reference to an oral communication, shall mean to (i) identify the person making the oral communication; (ii) identify the recipient or intended recipient of the oral communication; (iii) state whether the communication was face-to-face or by telephone or other means; (iv) state the date and place of the communication, and if not face-to-face, also the place of its. receipt; (v) identify each person who was present and otherwise aware of the content of the oral communication; (vi) state its substance; and (vii) identify each document which in anyway refers to, reports, or summarizes the communication.

4 7. As used herein "and" means and/or and "or" means and/or.

8. As used herein, PVNGS refers to the Palo Verde Nuclear Generating Station.

l 9. As used herein, Joint Applicants refers to the Arizona Public Service Company and all other entities with .an I

ownership interest in the Palo Verde Nuclear Generating Station.

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10. ER as used herein refers collectively to the Environmental Report--Construction Permit and the Environmental Report--Operating License prepared for the PVNGS.

11. NUS as used herein refers to the NUS Corporation of Gaithersburg, Maryland.

12. Bechtel as used herein refers to the Bechtel Power Corporation of San Francisco, California.

13. Marley as used herein refers to the Marley Cooling Tower Company of Mission Kansas.

14. " Fog" model as used herein refers to a drift dispersion and deposition model, a proprietary computer program developed by NUS.

15. EIS as used herein refers collectively to the final Environmental Statement--Construction Permit and the final Environmental Statement--Operating License prepared for the PVNGS.

16. EIS-OS as used herein refers to the Final Environmental Statement--Operating License prepared for the PVNGS.

17. Use of the plural in these interrogatories shall be deemed to include the singular.

18. These interrogatories shall be deemed continuing so q as to require supplemental answers if defendants obtain information between the time the answer is served and the time of the hearing.

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l Such supplemental answers shall be served not later than thirty days after such information is received, or ten days prior to the hearing, whichever is earlier.

4 INTERROGATORIES

1. State the date on which Joint Applicants forecast they will begin fuel loading of Unit 2 of the PVNGS (hereinafter referred to as the "Date").

a) Identify the date on which it was determined that the Date described was the target date for the beginning of fuel loading for Unit 2 above.

b) Identify all documents which relate or refer to the setting of the Date.

c) Identify all documents which relate or refer to whether: (i) the Date will be delayed beyond the Date described above; and (ii) by how much the Date will be delayed.

d) Identify all oral communications since the Date was forecast relating or referring to whether or not fuel loading will begin on the Date.

2. Identify each, person who, prior to the completion of the EIS, worked on or reviewed any studies or analyses relating or l

referring to the amount of salt drift emitted from the PVNGS cooling towers (i.e., the quantity of salt emitted and the drift droplet distribution) (hereinafter referred to as cooling tower

!g salt emissions) , with:

i) NUS ii) Bechtel iii) Marley iv) Joint Applicants v) Any other entity l

5 a) State the role and responsibility of each person and organization identified above, b) Identify all documents prepared prior to the completion of the EIS-OS, including but not limited to all reports and correspondence, relating or referring to the cooling tower salt emissions.

3. Identify each person who, since the EIS-OS was completed, is reviewing or will review on behalf of Joint Applicants the ER and the EIS as they relate or refer to cooling tower salt emissions, with:

i) NUS ii) Bechtel iii) Joint Applicants iv) Marley v) Any other entity a) State the responsibility and role of each person identified in this interrogatory in reviewing the ER and EIS as they relate or refer to cooling tower salt emissions.

b) Identify all documents prepared since the completion of the EIS-OS, including but not limited to all reports

• j and correspondence, relating or referring to cooling tower salt j emissions.

4. Identify each person who, prior to the completion of the EIS, worked on or reviewed any studies or analyses relating or referring to the amount of salt drift emitted from the PVNGS spray ponds (i.e., the quantity of salt emitted and the drift droplet 6

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6 distribution) (hereinaf ter referred to as spray pond salt emissions), with:

i) NUS ii) Bechtel lii) Marley iv) Joint Applicants v) Any other entity a) State the role and responsibility of each person end organization identified above.

b) Identify all documents prepared prior to the completion of the EIS-OS, including but not limited to all reports and correspondence, relating or referring to spray pond salt emissions.

5. Identify each person who, since the EIS-OS was completed, is reviewing or will review on behalf of Joint Applicants the ER and the EIS as they relate or refer to spray pond salt emissions, with:

i) NUS l

ii) Bechtel iii) Joint Applicants Pg iv) Marley i

v) Any other entity a) State the responsibility and role of each person identified in this interrogatory in reviewing the ER and EIS as they relate or refer to spray pond salt emissions.

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l b) Identify all documents prepared since the j completion of the EIS-OS, including but- not limited to all correspondence, relating or referring to spray pond salt emissions.

6. Identify each person who, prior to the completion of the EIS, worked on or reviewed any studies or analyses relating or referring to the amount of salt drift or dust emitted from the PVNGS evaporation ponds (i.e., the quantity of salt emitted and the particulate size distribution) (hereinafter referred to as evaporation ponds salt emissions), with:

i) NUS ii) Bechtel iii) Marley iv) Joint Applicants v) Any other entity a) State the role and responsibility of each person and organization identified above.

b) Identify all documents prepared prior to the completion of the EIS-OS, including but not limited to all reports and correspondence, relating or referring to evaporation ponds salt emissions.

7. Identify each person who, since the EIS-OS was pg will review on behalf of Joint completed, is reviewing or Applicants the findings in the ER and the EIS relating or referring to evaporation ponds salt emissions, with:

i) NUS ii) Bechtel l iii) Joint Applicants

8 iv) Marley v) Any other entity a) State the responsibility and role of each person identified in this interrogatory in reviewing the ER and EIS as they relate or refer to evaporation ponds salt emissions.

b) Identify all documents prepared since the completion of the EIS-OS, inclu, ding but not limited to all correspondence, relating or referring to evaporation ponds salt emissions.

8. Identify all documents, including but not limited to studies, reports and correspondence, which relate or refer to alternative designs for the PVNGS (i) cooling towers, (ii) spray pond and (iii) evaporation ponds which would reduce salt emissions.

9. State:

a) the basis for the choice in the ER of the size distribution of salt drift d.roplets emitted from the PVNGS cooling towers; b) whether that choice is consistent with the salt

, ' drift droplet size distribution utilized by Marley; 1

l c) if there is a difference, the basis for the y size distribution used in the ER.

10. Identify:

a) all documents prepared prior to the completion of the EIS relating or referring to the size distribution of salt emitted from the PVNGS cooling towers; b) all such documents prepared after the t

completion of the EIS;

9 c) each person with knowledge of the choice of the salt drif t droplet size distribution emitted from the PVNGS cooling towers with (i) NUS, (ii) Bechtel, (iii) Marley, (iv) Joint Applicants, and (v) any other entity.

11. State the basis for statements by Joint Applicants in their response to West Valley's Petition to Intervene that the evaporation ponds will at all times be covered by water.

12. Identify each person who works for each of the following companies with knowledge of the subject matter referred to in Interrogatory 11:

i) NUS ii) Bechtel lii) Joint Applicants iv) Marley v) Any other entity I

13. State:

a) the basis for the decision that spray ponds would be used as the ultimate heat sinks for the PVNGS; 1

b) whether and what alternatives to spray ponds l

l were taken into account for this purpose.

1 h 14. Identify each person who works for each of the following companies with knowledge of the matters referred to in Interrogatory 13:

l i) NUS ii) Bechtel iii) Joint Applicants iv) Marley

10 v) Any other entity

15. State whether it is your position that the ER and EIS fully evaluated salt drift quantity and deposition patterns from the spray ponds.

16. If your answer to Interrogatory 15 is yes, state the basis for your contention and list each page in the ER, EIS and hearing record which you believe supports your position.

17. State:

a) the drift droplet size distribution expected from the PVNGS spray ponds; and b) the basis for this choice.

18. Identify:

a) all documents prepared prior to the completion of the EIS relating or referring to the droplet size distribution

' of salt emitted from the PVNGS spray ponds; b) all such documents prepared after the

! completion of the EIS; c) each person with knowledge of the choice of the droplet size distribution of salt emitted from the PVNGS spray ponds with (i) NUS, (ii) Bechtel, (iii) Marley, (iv) Joint Pg Applicants, and (v) any other entity.

19. Identify each person who, prior to the completion of i

! the EIS, worked on or reviewed any studies or analyses relating or referring to the quantity of salt drift deposition deposited per ,

acre as a function of distance from the cooling towers (including, i

but not limited to, all persons who worked on or reviewed the FOG or I

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11 other models of salt drift deposition patterns) (hereinafter referred to as salt drift deposition patterns), with:

i) NUS ii) Bechtel iii) Marley iv) Joint Applicants v) Any other entity a) State the role and responsibility of each person and organization identified above.

b) Identify all documents prepared prict to the completion of the EIS-OS, including but not limited to all reports and correspondence, relating or referring to the salt drift deposition patterns.

20. Identify each person who, since the EIS-OS was completed, is reviewing or will review on behalf of Joint Applicants the ER and EIS as they relate or refer to salt drift deposition patterns:

i) NUS ii) Bechtel iii) Joint Applicants fi iv) Marley v) Any other entity a) State the responsibility and role of each person identified in this interrogatory in reviewing the ER and EIS as they relate or refer to salt drift deposition patterns.

b) Identify all documents prepared since the completion of the EIS-OS, including but not limited to all reports t

12 and correspondence, relating or referring to salt drift deposition patterns.

21. State:

a) The basis for the choice in the ER of the " FOG" model to describe salt drift deposition patterns.

b) The basis for the choice of the " FOG" model over other models which describe salt drift deposition patterns.

22. Identify:

a) The person most familiar with the reasons why the FOG model was chosen over other models which describe salt drift deposition patterns.

b) All documents which relate or refer to why the FOG model was chosen over other models which describe salt drift deposition patterns.

23. Identify each person who, prior to the completion of the EIS, worked on or reviewed any studies or analyses relating or referring to the impact of salt drif t on agricultural crops grown ,

in the vicinity of PVNGS (hereinafter referred to as " effects on crops"), with:

i) NUS h ii) Bechtel lii) Marley iv) Joint Applicants v) Any other entity a) State the role and responsibility of each person and organization identified above.

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13 b) Identify all documents prepared prior to the completion of the EIS-OS, including but not limited to all reports and correspondence, relating or referring to effects on crops.

24. Identify each person who, since the EIS-OS was

" completed, is reviewing or will review on behalf of the Joint Applicants the findings in the ER and EIS relating or referring.to effects on crops, with:

1) NUS, ii) Bechtel iii) Joint Applicants iv) Marley v) Any other entity a) State the responsibility and role of each person identified in this interrogatory in reviewing the ER and EIS as they relate or refer to effects on,cpops.

b) Identify all documents prepared since the completion of the EIS-OS, including but not limited to all reports and correspondence, relating or referring to effects on crops.

25. State whether Joint Applicants have, since the completion of the EIS-OS, undertaken or plan to undertake any h studies of the effect of salt drift on agricultural crops.

26. If the answer to interrogatory 25 is yes, describe each such study, including but not limited to:

a) each plant which will be studied; b) how the study will be conducted; and c) the time period of each such study.

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27. Identify each person with Joint Applicants and each entity involved in each such study ident'ified in interrogatories 25 and 26.

28. If the answer to Interrogatory 25,is yes, identify:

a) all documents relating or referring to those studies; and b) all persons who have worked or will work on those studies.

28A. State .whether Joint Appl'icantsor any other entity has prepared or is planning to prepare a " worst case" analysis relating or referring to the effect of salt drift deposition from the PVNGS on agricultural crops.

29. Describe the program you have implemented to monitor salt drift from the PVNGS, including:

a) the date on which each monitor 4was installed; b) the loca. tion of each monitor;

, c) the type of monitor; and j d) the data ~ gathered by each monitor.

29A. Describe thd monitoring program you plan to l

l implement to determine the quantity of salt emitted from the PVNGS h and its impact on area agriculture, including, but'not limited to:

a) How you plan to monitor the salinity of the drif,t Smitted from the (i) cooling towers, (ii) spray ponds and (iii) evaporation ponds, b) How you plan to monitor the size and quantity of the salt particles emitted from the (i) cooling towers, (ii) spray ponds and (iii) evaporation ponds.

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15 c) How you plan to monitor the salt drif t per acre 4

as a function of the distance and direction from the plant.

l, d) How you plan to monitor the impact of salt drift from the plant on area agriculture.

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. e) What baseline monitoring studies, in addition l'

to those described in interrogatory 29, you plan to undertake prior to operation of PVNGS Unit 1 to determine current salt conditions.

f) How you plan to monitor each of the factors i described in a-e over the life of the plant.

I g) How you plan to verify the accuracy of the monitoring and associated analysis used in determining salt drift 4

- per acre as a function of the distance and direction from the plant.

30. Describe each monitoring device you are using or plan to use in monitoring the operation of PVNGS as described in interrogatories 29 and 29A, state why that device was chosen over other devices, and identify all documents that relate to the accuracy and reliability of each device.

31. Identify each person who works for:

a) NUS b b) Bechtel c) Joint Applicants d) Marley e) Any other entity with' knowledge of the monitoring programs or monitors referred to in interrogatories 29, 29A and 30.

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32. Identify each document which relates .or refers to the monitoring programs referred to in interrogatories 29, 29A and 30.

33. State whether water desalinization was considered as a salt drift mitigation strategy prior to the completion of the EIS-OS.

34. If the answer to interrogatory 33 is yes, identify:

a) all documents which relate or in any way refer to the use of salt desalinization as a salt drire mitigation strategy; b) all persons with knowledge of the use of salt desalinization as a salt drift mitigation strategy.

35 State whether you are now considering or have considered since the completion of the EIS-OS water desalinization as a salt drift mitigation strategy.

36. If the answer to interrogatory 35 is yes, identify:

a) all documents which relate or in any way refer j to the use of salt desalinization as a salt drift mitigation strategy; and

b) each person who is involved with the h consideration of this issue.

37. State whether blowdown treatment and water l rec,irculation were considered as salt drift mitigation strategies l

l prior to the completion of the EIS-OS.

38. If the answer to interrogatory 37 is yes, identify:

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17 a) all documents which relate or in any way refer to blowdown treatment and water recirculation as a salt drift mitigation strategy; and b) each person who was involved with consideration of this issue.

39. State whether you are now considering blowdown treatment and water recirculation as a salt drift mitigation strategy.

40. If the answer to interrogatory 39 is yes, identify:

a) all documents which relate or in any way refer to the use of blowdown treatment and water recirculation as a salt drift mitigation strategy; and b) each person who is involved with the consideration of this issue.

41. State whether prior to the completion of the EIS-OS any of f design operating conditions were taken into account in evaluating the salt drift and salt drift related environmental effects from the PVNGS cooling towers, spray ponds and evaporation ponds.

42. If the answer to interrogatory 41 is yes, describe b each such effect considered and describe whether and how each such effect influenced the evaluation in the ER. If some off design operating conditions were considered but not taken into account, explain the basis for that decision.

43. Identify all persons with knowledge of the subject matter contained in interrogatories 41 and 42.

44. State:

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a 18 a) the basis for the figures contained in the ER and EIS on the salinity of the effluent to be used for cooling at the PVNGS; b) whether you know if any water district statistics indicate that the effluent can reach a higher salinity than indicated in the ER and EIS.

45. If the answer to interrogatory 44 (b) is yes, state the basis for the decision to use the figures in the ER and EIS.

46. Identify all persons with knowledge of the subject matter referred to in interrogatories 44 and 45.

47. Describe the maintenance plans for the PVNGS dooling tower drift eliminators.

48. Identify:

a) all documents relating or referring to PVNGS cooling tower drift eliminators; and b) all persons with knowledge of this subject matter.

49. State whether the cooling tower vendor:

a) makes or has made cooling towers of the type being installed at PVNGS with a drift elimination system that b removes more salt from the drift than the system being insta.ed at PVNGS; and

. b) can make cooling towers of the type being installed at PVNGS with a drift elimination system that removes more salt from the drift than the system being installed at PVNGS.

49A. If your answer to interrogatory 49 is yes, describe 1

l the drift elimination systems referred to in interrogatory 49, and t

e 19 state the basis for choosing the drift elimination system used in the PVNGS cooling towers.

50. Identify all documents relating or referring to alternative cooling tower drift elimination system designs.

51. Identify each person who works for:

i) NUS .

) ii) Marley lii) Bechtel iv) Joint Applicants v) Any other entity with knowledge of consideration of alternative cooling tower drift elimination systems as well as the person at Marley most familiar with Marley's cooling tower drift elimination system.

i 52. State whether prior to the completion of the EIS-OS Joint Applicants conducted or had conducted for them any studies on the tolerance of crops grown within 10 miles of the PVNGS to i

aerosol salt deposition.

53. If your answer to interrogatory 52 is yes, identify:

a) each such study; b) each such crop studied; and b c) each person who worked on each such study.

54. State whether prior to the completion of the EIS-OS you had information in your possession relating or referring to the tolerance to aerosol salt deposition of crops grown within 10 miles I of the PVNGS.

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55. If your answer to interrogatory 54 is yes, describe that information for each of the crops grown in the vicinity of the PVNGS.

56. Identify each person whom the Joint Applicants expect to call as an expert witness at the hearing (including, without limitation, each such expert's full name, present address, present employment or other professional affiliation, and qualifications).

57. State the subject matter on which each expert identified in the answer to interrogatory 56 is expected to testify.

58. State the substance of the facts and opinions to which each expert identified in the answer to interrogatory 56 is expected to testify and summarize the grounds for each opinion.

59. With respect to each opinion set forth in the answer to interrogatory 58, identify each document which the expert rendering the opinion bases his opinion upon, or has relied upon in forming his opinion, or will rely upon during the hearing, testify to, or otherwise claim to support his opinion.

60. Identify each person who prepared answers to these b interrogatories and the interrogatories on which each such person worked.

Dated: M . /b Washington, D.C. Kenneth Berlin Attorney for Intervenor West Valley Agricultural Protection Council, Inc.

2550 M Street, N.W.

Washington, D.C. 20037 (202) 429-8501

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'03 7".o 16 pg,.; ,

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 13 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) '

)

ARIZONA PUBLIC SERVICE COMPANY ) Docket Nos. STN 50-529

) STN 50-530 (Palo Verde Nuclear Generating )

Station, Units 2 and 3) )

)

CERTIFICATE OF SERVICE I hereby certify that copies of the attached Petitioner West Valley Agricultural Protection Council, Inc.'s First Set Of Interrogatories Directed To Joint Applicants, dated March 15, 1983, have been served upon the following listed persons by deposit in the United States mail, properly addressed and with postage prepaid, this 16th day of March 1983.

Robert M. Lazo, Esq., Chairman Warren Platt, Esquire Administrative Judge Snell & Wilmer Atomic Safety & Licensing Board 3100 Valley Center U.S. Nuclear Regulatory Comm. Phoenix, Arizona 85073 t 3. Washington, D.C. 20555 1 Ms. Lee Hourihan Dr. Richard F. Cole 6413 S. 26th Street i Administrative Judge Phoenix, Arizona 85040 Atomic Safety & Licensing Board U.S. Nuclear Regulatory Comm. Docketing and Service Section Washington, D.C. 20555 Office of the Secretary U.S. Nuclear Regulatory Comm.

Dr. Dixon Callihan Washington, D.C. 20555 Administrative Judge Union Carbide Corporation P. O. Box Y Oak Ridge, Tennessee 37830 l

Lynne Bernabei, Esquire Edwin J. Reis, Esquire Harmon & Weiss Office of the Exec. Legal Dir.

1725 I Street, N.W. U.S. Nuclear Regulatory Comm.

Suite 506 Washington, D.C. 20555 Washington, D.C. 20006 Lee Scott Dewey, Esquire Rand L. Greenfield Office of the Exec. Legal Dir.

Assistant Attorney General U.S. Nuclear Regulatory Comm.

P. O. Drawer 1508 Washington, D.C. 20555 Sante Fe, New Mexico 87504-1508 Arthur Gehr, Esquire Snell & Wilmer 3100 Valley Center Phoenix, Arizona 85073 Dated: /mvd I b ,, ) $ N ,(L w ' M [%' U 'I\

/ Kenneth Berlin Attorney at Law

. Suite 500 2550 M Street, N.W.

Washington, D.C. 20037 (202) 429-8501 Attorney for Petitioner West Valley Agricultural Protection Council, Inc.

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