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| | issue date = 11/04/1980 | | | issue date = 11/04/1980 |
| | title = Affidavit in Support of Motion for Partial Disposition of Contention 2 Re Health Effects of Discharged Chlorine. Acid Drainage & Toxic Chemical Waste Spills Will Not Increase Amount of Chlorine.Prof Qualifications Encl | | | title = Affidavit in Support of Motion for Partial Disposition of Contention 2 Re Health Effects of Discharged Chlorine. Acid Drainage & Toxic Chemical Waste Spills Will Not Increase Amount of Chlorine.Prof Qualifications Encl |
| | author name = RIOS J | | | author name = Rios J |
| | author affiliation = BECHTEL GROUP, INC. | | | author affiliation = BECHTEL GROUP, INC. |
| | addressee name = | | | addressee name = |
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| | document type = AFFIDAVITS, LEGAL TRANSCRIPTS & ORDERS & PLEADINGS | | | document type = AFFIDAVITS, LEGAL TRANSCRIPTS & ORDERS & PLEADINGS |
| | page count = 3 | | | page count = 3 |
| | revision = 0
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| | =Text= |
| | {{#Wiki_filter:UNITED STATFD OF NIERICA NUCLEAR REKXJLÃlOHY CCNMESSICN BEFORE 'IHE ATCNIC SAFLTY AND LICENSING BOARD In the Matter of PENNSYLVANIA PCMER AND LIGHT CCMPANY Docket Nos. 50-387 and 50-388 ALLEGHENY ELECTRIC COOPERATIVE INC (Susquehanna Steam Electric Station Units 1 and 2) |
| | AFFIDAVIT OF JAMES RIOS IN SUPPORC OF SQKKK DISPOSITION OF CCNTE5TICN 2 (CHLORINE) |
| | Gounty of San Francisco )' |
| | ss State of California ) |
| | James Rios, being duly urn according to law, deposes and says as follows: |
| | : l. I am Supervising Engineering Specialist for the San Francisco Power Division of Bechtel Ebmr Corporation and give this affidavit in support of Applicants'otion for Sunxnary Disposition of Gontention 2 (Chlorine). I have personal knowledge of the matters set forth herein and believe them to be true and correct. A summary of my professional qualifications and experience is attached hereto as Exhibit "A". |
| | : 2. Contention 2 in this proceeding alleges in part that the health effects of chlorine discharged into the Susquehanna River have not been adequately assessed. In explanation of this claim, the sponsor W?'13/3-1 |
| | |
| | of this portion of Contention 2, Citizens Against Nuclear Danger, has asserted that the adverse health effects from the discharge of chlorine fran the Susquehanna facility have been underestimated because massive increases in the use of chlorine will be required due to major increases in mine acid drainage into the Susquehanna River and because of the spills of toxic chemical wastes illegally dumped into 'abandoned coal mines. This assertion is incorrect. |
| | : 3. The purpose for chlorinating the various water systems in the Susquehanna facility is to arrest the cumulative growth of slime-forming biolife on equipment surfaces and to disinfect the potable water supply and the sewage effluent. The presence of mine acid drainage and spills of toxic chemical wastes which may be in the Susquehanna River water does not result in any significant increase in the rate at which slime-forming biolife grows on equiprent surfaces. Nor do mine acid drainage and toxic chemical spills change the amounts of chlorine required to disinfect the potable water supply and the sewage effluent. Thus the presence of mine acid drainage and spills of toxic chemical wastes does not increase the aneunt of chlorine which will be used. |
| | S RI.OS Sworn to and subscribed before me this~@day o2 r 1980. |
| | BETTY t YASiL |
| | ) NOTARY PUBLIC<ALIFORNIA CITY ANO COUNTY OF WP13/3-2 SAN FRANUI8CO h1y Commfssion m~plres MaY 28, 1984 |
| | |
| | SUPERVISING ENGINEERING SPECIALIST KB SAN FRANCISCO HXKR DIVISION OF BECBZEL POWER CORPORATION. |
| | EDUCATION: ~ |
| | Associate in Chemical Technology, New York Institute of Applied Arts & Sc1ences 1951. |
| | Bachelor. of Chemical ~eering, 1955- |
| | |
| | ==SUMMARY== |
| | : Twenty five years experience in the conceptual and |
| | ~ detailed design of Water and Waste Water Treatment |
| | ~ |
| | Systans, including 16 years af direct involvement in the design af these systems for over 26 power stations. 'these power stations included Boiling Water Nuclear Reactors, Pressurized Water Nuclear Reactors, and FossQ. Fueled Plants. For the past 8 years Nr. Hios has been supervising engineering specialists who design the water and waste water treatment systems for Power Station Prospects Power Corporation San Francisco Power of'echtel Division. Nr. Rios has been directly involved 1n the conceptual and detailed design af chlorination and dechlorination systems for recirculating con<< |
| | denser cooling water systems incorporating cooling towers ard once-thro~ coo~ water systems, |
| | '.g. - |
| | Norm Creek, Unit.¹6, GordonEvans Unit ¹2, Michaud Unit ¹3, Lake Catherine Unit ¹3, J1m Bridger Unit ¹1-3,'Hush-Is. Units 1 & 2, Hope-Creek ¹1, etc. |
| | Mr. Hios has been involved with the Susquehanna SES Prospect since its inception, having been directly involved in the ordinal NPDKS permit application and design af sane of the water treataent systems, and. continuing his association through supervision af other engineering specialists assigned to carry on the work in the area af water and waste water treatment as well as chlorination and dechlorination of the circulating water. |
| | PROFESSIONAL ASSOCIATIONS: Ãr. Rios is a Diplomate of the American Academy Engineers, a member of the National of'wrLrormental Association of 'Corrosion Engineers and a Registered Professional Engineer in the State af California (COHR-327). |
| | F32/25-12}} |
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Category:AFFIDAVITS
MONTHYEARML20203G6131998-01-26026 January 1998 Affidavit of RG Byram Justifying That Redacted Portions of Pp&L,Inc Corporate Auditings Interim Rept 739459-97,dtd 971015 Be Withheld from Public Disclosure ML20203G6031997-12-0404 December 1997 Affidavit of RG Byram Justifying That Redacted Portions of Pp&L,Inc Corporate Auditings Rept 739459-1-97,dtd 971201 Be Withheld from Public Disclosure ML20027D4471982-11-0101 November 1982 Affidavit of Wj Rhoades Correcting Response to Hearing Question on Leak Rates.Leak Rate Sys Capable of Detecting 1 Gpm Per Hour.Tech Specs Will Require Shutdown for Unidentified Leakage of 5 Gpm.Certificate of Svc Encl ML20069D8321982-09-0909 September 1982 Original Signature Page to Sh Cantone Affidavit.Svc List Encl ML20065A9541982-09-0909 September 1982 Affidavit of Sh Cantone Re Dosimetry for Emergency Workers at Plant.Prof Qualifications Encl ML20027B2351982-09-0808 September 1982 Affidavit of AL Belser & Rj Hippert Responding to Questions in Aslab 820820 Order & Supporting Stipulation Withdrawing Exceptions.When Stipulated Number of Dosimeters Available, Emergency Workers Will Be Protected.W/Certificate of Svc ML20027B2331982-09-0808 September 1982 Affidavit of Ma Reilly Responding to Question in Aslab 820820 Order & Supporting 820909 Stipulation. TLD Necessary to Document Exposure of Officials Helping Contaminated Evacuees ML20011A2201981-09-29029 September 1981 Affidavit Opposing Applicants Motion for Summary Disposition of Contention 17.Contests Claim That People Will Not Experience Shocks from Transmission Lines ML20010J6251981-09-29029 September 1981 Affidavit Supporting NRC Motion for Summary Disposition of Portion of Contention 1 Re Radiological Health Effects of Isotopes Other than Rn-222 & Tc-99.Certificate of Svc Encl ML20140B2071981-09-0909 September 1981 Affidavit Supporting Applicants 810828 Motion for Summary Disposition of Contention 1 Re Fuel Cycle Doses.Prof Qualifications & Certificate of Svc Encl ML20140B1731981-08-31031 August 1981 Affidavit Re Reasonableness of Applicants Capacity Factor to Arrive at Projected Benefits in cost-benefit Analysis & Methodology Used for Calcaluating Benefits.W/Prof Qualifications & Certificate of Svc ML20010E0141981-08-28028 August 1981 Affidavit Supporting Applicant Motion for Summary Disposition of Contention 1 Re Fuel Cycle Doses.Radioactive Doses Are Released to Public by Release of Isotopes Other than Rn-222 & Tc-99.Related Correspondence ML20010F4461981-08-28028 August 1981 Affidavit Supporting Applicants Motion for Summary Disposition of Contention 7C.Cracking Has Not Been Reported in BWR Core Spray Nozzles.Prof Qualfications Encl.Related Correspondence ML20010F5301981-08-28028 August 1981 Affidavit Supporting Applicants Motion for Summary Disposition of Contention 7B.Prof Qualifications Encl ML20010F6221981-08-25025 August 1981 Affidavit Supporting Applicants Motion for Summary Disposition of Contention 7B.Applicants Mitigative Actions Should Eliminate Incidence of Stainless Steel Cracking.Prof Qualifications Encl ML20010C9211981-08-14014 August 1981 Affidavit Supporting Applicant Motion for Summary Disposition of Contention 17.Public Health Impact of Electric Fields Generated by Operating Lines at Design Voltage Will Be Insignificant.Prof Qualifications Encl ML20010B4161981-08-0707 August 1981 Affidavit in Support of Summary Disposition of Contention 1 Re Rn-222.Prof Qualifications & Certificate of Svc Encl ML20010C1451981-08-0404 August 1981 Affidavit Supporting Applicant Motion for Partial Summary Disposition of Contention 2.Radionuclide Release Estimates in Facility Environ Rept Represent Conservatively High Estimates of Actual Releases When Facility Operates ML20009H2151981-07-31031 July 1981 Affidavit in Support of Summary Disposition of Contention 7(a).Prof Qualifications & Diagrams Encl.Related Correspondence ML20009H0441981-07-28028 July 1981 Affidavit Supporting Applicant Motion for Summary Disposition of Contention 3.Adequate Supply of Domestic U Will Be Available at Moderate Prices to Provide Fuel for Facility Lifetime.W/Supporting Data & Proj Qualifications ML20009F8441981-07-17017 July 1981 Affidavit Supporting Applicant Motion for Partial Summary Disposition of Contention 11 Re Safe Onsite Storage of Spent Fuel.Facilities Can Safely Store Spent Fuel at Least as Long as Duration of Ol.Prof Qualifications Encl ML20009F8601981-07-17017 July 1981 Affidavit Supporting Applicant Motion for Partial Summary Disposition of Contention 11.Spent Fuel Can Be Safely Stored in water-filled Pools on Site Beyond 15 Yrs.Prof Qualifications Encl ML18030A1641980-11-0404 November 1980 Affidavit in Support of Motion for Partial Disposition of Contention 2 Re Health Effects of Discharged Chlorine. Acid Drainage & Toxic Chemical Waste Spills Will Not Increase Amount of Chlorine.Prof Qualifications Encl ML18026A3121980-10-24024 October 1980 Affidavit in Support of Summary Disposition of Contention 16 Re Cooling Tower Discharge.No Radioactive Water Will Be Vented from Facility Cooling Towers.Prof Qualifications Encl ML18026A3051980-08-14014 August 1980 Affidavit Supporting Applicant 800822 Motion for Partial Summary Disposition of Contention 17.Ozone Levels Emitted from 500 Kv Transmission Line Will Be Very Low.Calculations & Prof Qualifications Encl ML17138A8241979-07-20020 July 1979 Affidavit of C Marsh Re 790720 Response to NRC Interrogatories 1998-01-26
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20209H6691999-07-12012 July 1999 Comment Supporting Proposed Rule 10CFR50 Re Elimination of Requirement for Licensees to Update Inservice Insp & Inservice Testing Programs Beyond Baseline Adition & Addenda of ASME BPV Code ML20203G6131998-01-26026 January 1998 Affidavit of RG Byram Justifying That Redacted Portions of Pp&L,Inc Corporate Auditings Interim Rept 739459-97,dtd 971015 Be Withheld from Public Disclosure ML20203G6031997-12-0404 December 1997 Affidavit of RG Byram Justifying That Redacted Portions of Pp&L,Inc Corporate Auditings Rept 739459-1-97,dtd 971201 Be Withheld from Public Disclosure PLA-4330, Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control1995-06-0808 June 1995 Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control PLA-4193, Comment Opposing Petition for Rulemaking PRM-9-2 Submitted Ocre Requesting That NRC Revise Regulations to Provide Public Access to Info Held by Licensees But Not Submitted to Nrc.Urges NRC to Deny Ocre Petition in Entirety1994-08-31031 August 1994 Comment Opposing Petition for Rulemaking PRM-9-2 Submitted Ocre Requesting That NRC Revise Regulations to Provide Public Access to Info Held by Licensees But Not Submitted to Nrc.Urges NRC to Deny Ocre Petition in Entirety ML20046A9531993-07-20020 July 1993 Comment on Proposed Rules 10CFR170 & 171, FY91 & 92 Proposed Rule Implementing Us Court of Appeals Decision & Rev of Fee Schedules;100% Fee Recovery,FY93. Opposes Rule ML20045F7971993-06-21021 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Supports Rule in Part & Opposes Rule in Part ML20045D7461993-06-21021 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Disagrees W/Maintaining 100% Rate for Contractor & Vendor Employees ML20044F8361993-05-24024 May 1993 Comment on Proposed Rules 10CFR170 & 171, FY91 & 92 Proposed Rule Implementing Us Court of Appeals Decision & Rev of Fee Schedules;100% Fee Recovery,FY93. Opposes Rules ML20044F7511993-05-24024 May 1993 Comment on Proposed Rules 10CFR170 & 171, FY91 & 92 Proposed Rule Implementing Us Court of Appeals Decision & Rev of Fee Schedules;100% Fee Recovery,FY93. PLA-3744, Comment on Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant.Expresses Concerns of Potential for Inconsistent & Inappropriate Application by Individual NRC Inspectors & Examiners1992-03-0909 March 1992 Comment on Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant.Expresses Concerns of Potential for Inconsistent & Inappropriate Application by Individual NRC Inspectors & Examiners PLA-3568, Comments Supporting Proposed Rule 10CFR50 Incorporating 1986 -1988 Addenda & 1989 Editions of ASME Boiler & Pressure Vessel Code,Section Iii,Div 1 & Section Xi,Div 1,by Ref Into 10CFR50.55a1991-04-0808 April 1991 Comments Supporting Proposed Rule 10CFR50 Incorporating 1986 -1988 Addenda & 1989 Editions of ASME Boiler & Pressure Vessel Code,Section Iii,Div 1 & Section Xi,Div 1,by Ref Into 10CFR50.55a PLA-3462, Comment Supporting Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Proposed Rule,W/Enhancements Recommended by Numarc,Will Provide More Stable Basis for Util Planning & Development of Future Power Plants1990-10-15015 October 1990 Comment Supporting Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Proposed Rule,W/Enhancements Recommended by Numarc,Will Provide More Stable Basis for Util Planning & Development of Future Power Plants ML19332G5261989-12-0606 December 1989 Comments on Draft Reg Guide DG-1001, Maint Programs for Nuclear Power Plants. Industry Has Made Substantial Progress Re Maint Performance as Indicated by Respective Performance Indicators,Commission Insps & Plant Conditions PLA-3175, Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants1989-03-29029 March 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants ML20235V4001989-03-0202 March 1989 Comment on Proposed Rule 10CFR50 Re Maint Program at Nuclear Plants.Proposed Maint Rule Has Potential to Significantly Undermine Util Initiatives & Direct Limited Resources Away from Real Improvements in Maint PLA-3157, Comment Opposing Proposed Rule 10CFR50 Re Effectiveness of Maint Programs for Nuclear Power Plants.Proposed Rule Not Needed & Will Not Serve to Increase Commission Ability to Ensure Nuclear Plants Reliably Maintained1989-02-24024 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Effectiveness of Maint Programs for Nuclear Power Plants.Proposed Rule Not Needed & Will Not Serve to Increase Commission Ability to Ensure Nuclear Plants Reliably Maintained PLA-3118, Comment Endorsing NUMARC Comments on Proposed Rule 10CFR26 Re Fitness for Duty Rule1988-11-17017 November 1988 Comment Endorsing NUMARC Comments on Proposed Rule 10CFR26 Re Fitness for Duty Rule ML20247N7531988-07-28028 July 1988 Petition for Rulemaking PRM-50-53 Requesting NRC Action to Review Undue Risk Posed by BWR Thermal Hydraulic Instability.Nrr Should Issue Order Requiring All GE BWRs to Be Placed in Cold Shutdown for Stated Reasons PLA-3019, Comment Opposing Proposed Rule 10CFR50 Re Licensee Announcements of Inspectors.Nrc Does Not Fully Appreciate Impact of Rule as Written.Encourages Commission to Abandon Rulemaking1988-04-15015 April 1988 Comment Opposing Proposed Rule 10CFR50 Re Licensee Announcements of Inspectors.Nrc Does Not Fully Appreciate Impact of Rule as Written.Encourages Commission to Abandon Rulemaking PLA-2726, Comment Opposing Proposed Rules 10CFR50 & 55 Re Rulemaking to Enhance Levels of Engineering & Accident Mgt Expertise on Shift1986-09-25025 September 1986 Comment Opposing Proposed Rules 10CFR50 & 55 Re Rulemaking to Enhance Levels of Engineering & Accident Mgt Expertise on Shift ML20138A9521985-10-0909 October 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20027D4441982-11-0202 November 1982 Response to Aslab 821026 Order Requesting Info on RCS Leak Rate Detection.Util Preparing Tech Spec to Limit Increase in Unidentified RCS Leakage to 2 Gpm within 4-h Period ML20027D4471982-11-0101 November 1982 Affidavit of Wj Rhoades Correcting Response to Hearing Question on Leak Rates.Leak Rate Sys Capable of Detecting 1 Gpm Per Hour.Tech Specs Will Require Shutdown for Unidentified Leakage of 5 Gpm.Certificate of Svc Encl ML20069D8321982-09-0909 September 1982 Original Signature Page to Sh Cantone Affidavit.Svc List Encl ML20027B2291982-09-0909 September 1982 Stipulation of Withdrawal of Commonwealth of PA 820428 Exceptions Re Supply of TLD ML20065A9541982-09-0909 September 1982 Affidavit of Sh Cantone Re Dosimetry for Emergency Workers at Plant.Prof Qualifications Encl ML20027B2231982-09-0909 September 1982 Motion to Withdraw Commonwealth of PA 820428 Exceptions to Initial Decision,Contingent Upon Approval of Util & Commonwealth of PA 820909 Stipulation ML20027B2351982-09-0808 September 1982 Affidavit of AL Belser & Rj Hippert Responding to Questions in Aslab 820820 Order & Supporting Stipulation Withdrawing Exceptions.When Stipulated Number of Dosimeters Available, Emergency Workers Will Be Protected.W/Certificate of Svc ML20027B2331982-09-0808 September 1982 Affidavit of Ma Reilly Responding to Question in Aslab 820820 Order & Supporting 820909 Stipulation. TLD Necessary to Document Exposure of Officials Helping Contaminated Evacuees ML20063A4041982-08-18018 August 1982 Petition for Reconsideration of Commission 820809 Order Rendering ASLB Initial Decision Effective.Exceptions to Decision Require Resolution.Commission Order Premature. Certificate of Svc Encl ML20062J6391982-08-13013 August 1982 Order Directing Parties to Identify Person Presenting Arguments at 820908 Hearing in Bethesda,Md.Response Requested No Later than 820831 ML20058J6651982-08-0909 August 1982 Order Rendering ASLB 820412 Decision Authorizing OL Issuance Effective.Full Power OL Not Yet Authorized ML20054L5081982-07-0606 July 1982 Brief Opposing Commonwealth of PA 820428 & Citizens Against Nuclear Dangers 820421 Exceptions to ASLB 820412 Initial Decision.Pa Fails to Prove Dosimetry Issue Timely Raised. Citizens Failed to Comply W/Procedure.W/Certificate of Svc ML20054L2841982-07-0202 July 1982 Brief Opposing Commonwealth of PA 820428 Exceptions to ASLB 820412 Initial Decision Authorizing OL Issuance.Commonwealth Fails to Justify License Condition Imposition Re Availability of Dosimetry.Certificate of Svc Encl ML20054J5611982-06-25025 June 1982 Brief Opposing Citizens Against Nuclear Danger 820421 Exceptions to ASLB 820412 Initial Decision.Exceptions Fail to Comply W/Commission Regulations & Raise Issues Not Presented Before Aslb.Certificate of Svc Encl ML20053D0801982-05-28028 May 1982 Brief in Support of Exceptions to ASLB 820412 Initial Decision Authorizing Issuance of Ols.Shortage in Supply of Dosimeters for Emergency Workers Clear & Uncontroverted. Certificate of Svc Encl ML20053D2191982-05-28028 May 1982 Brief Supporting Commonwealth of PA Exceptions to ASLB 820412 Initial Decision.Certificate of Svc Encl ML20052B7461982-04-28028 April 1982 Exceptions to ASLB 820412 Initial Decision.Certificate of Svc Encl ML20052A2751982-04-21021 April 1982 Exceptions to ASLB Initial Decision.Certificate of Svc Encl ML20054C6551982-04-15015 April 1982 Response Opposing Citizens Against Nuclear Dangers 820402 Proposed Findings of Fact & Conclusions of Law.Requirements for Reopening Record Not Met.No Showing That Allegations Raise Significant Safety Issues.Certificate of Svc Encl ML20050D4191982-04-0202 April 1982 Proposed Findings of Fact & Conclusions of Law Based on Important New Info & Recommendations to NRC Commissioners & Congress.Certificate of Svc Encl ML20042C2781982-03-26026 March 1982 Motion for Order That Applicants Conduct Complete Retest of Emergency Plan W/All 20 Communities Participating.Testimony on Contentions 6 & 20 Should Be Reviewed to Identify Perjury by Fema,Applicants & State of Pa.Certificate of Svc Encl ML20042C2701982-03-26026 March 1982 Proposed Findings of Fact & Conclusions of Law Re Emergency Evacuation Plan ML20069B0301981-12-22022 December 1981 Reply to Parties' Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20039B0791981-12-16016 December 1981 Proposed Transcript Corrections.Certificate of Svc Encl ML20062M2141981-12-0909 December 1981 Proposed Transcript Corrections ML20039A1951981-12-0909 December 1981 Proposed Findings of Fact & Conclusions of Law ML20038C0131981-12-0303 December 1981 Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20038A8891981-11-17017 November 1981 Motion to Take Official Notice of Existence & Content of Listed Documents Relevant to Contention 21.Validity of Info in Documents Could Be Subj to Dispute.Certificate of Svc Encl.Related Correspondence 1999-07-12
[Table view] |
Text
UNITED STATFD OF NIERICA NUCLEAR REKXJLÃlOHY CCNMESSICN BEFORE 'IHE ATCNIC SAFLTY AND LICENSING BOARD In the Matter of PENNSYLVANIA PCMER AND LIGHT CCMPANY Docket Nos. 50-387 and 50-388 ALLEGHENY ELECTRIC COOPERATIVE INC (Susquehanna Steam Electric Station Units 1 and 2)
AFFIDAVIT OF JAMES RIOS IN SUPPORC OF SQKKK DISPOSITION OF CCNTE5TICN 2 (CHLORINE)
Gounty of San Francisco )'
ss State of California )
James Rios, being duly urn according to law, deposes and says as follows:
- l. I am Supervising Engineering Specialist for the San Francisco Power Division of Bechtel Ebmr Corporation and give this affidavit in support of Applicants'otion for Sunxnary Disposition of Gontention 2 (Chlorine). I have personal knowledge of the matters set forth herein and believe them to be true and correct. A summary of my professional qualifications and experience is attached hereto as Exhibit "A".
- 2. Contention 2 in this proceeding alleges in part that the health effects of chlorine discharged into the Susquehanna River have not been adequately assessed. In explanation of this claim, the sponsor W?'13/3-1
of this portion of Contention 2, Citizens Against Nuclear Danger, has asserted that the adverse health effects from the discharge of chlorine fran the Susquehanna facility have been underestimated because massive increases in the use of chlorine will be required due to major increases in mine acid drainage into the Susquehanna River and because of the spills of toxic chemical wastes illegally dumped into 'abandoned coal mines. This assertion is incorrect.
- 3. The purpose for chlorinating the various water systems in the Susquehanna facility is to arrest the cumulative growth of slime-forming biolife on equipment surfaces and to disinfect the potable water supply and the sewage effluent. The presence of mine acid drainage and spills of toxic chemical wastes which may be in the Susquehanna River water does not result in any significant increase in the rate at which slime-forming biolife grows on equiprent surfaces. Nor do mine acid drainage and toxic chemical spills change the amounts of chlorine required to disinfect the potable water supply and the sewage effluent. Thus the presence of mine acid drainage and spills of toxic chemical wastes does not increase the aneunt of chlorine which will be used.
S RI.OS Sworn to and subscribed before me this~@day o2 r 1980.
BETTY t YASiL
) NOTARY PUBLIC<ALIFORNIA CITY ANO COUNTY OF WP13/3-2 SAN FRANUI8CO h1y Commfssion m~plres MaY 28, 1984
SUPERVISING ENGINEERING SPECIALIST KB SAN FRANCISCO HXKR DIVISION OF BECBZEL POWER CORPORATION.
EDUCATION: ~
Associate in Chemical Technology, New York Institute of Applied Arts & Sc1ences 1951.
Bachelor. of Chemical ~eering, 1955-
SUMMARY
- Twenty five years experience in the conceptual and
~ detailed design of Water and Waste Water Treatment
~
Systans, including 16 years af direct involvement in the design af these systems for over 26 power stations. 'these power stations included Boiling Water Nuclear Reactors, Pressurized Water Nuclear Reactors, and FossQ. Fueled Plants. For the past 8 years Nr. Hios has been supervising engineering specialists who design the water and waste water treatment systems for Power Station Prospects Power Corporation San Francisco Power of'echtel Division. Nr. Rios has been directly involved 1n the conceptual and detailed design af chlorination and dechlorination systems for recirculating con<<
denser cooling water systems incorporating cooling towers ard once-thro~ coo~ water systems,
'.g. -
Norm Creek, Unit.¹6, GordonEvans Unit ¹2, Michaud Unit ¹3, Lake Catherine Unit ¹3, J1m Bridger Unit ¹1-3,'Hush-Is. Units 1 & 2, Hope-Creek ¹1, etc.
Mr. Hios has been involved with the Susquehanna SES Prospect since its inception, having been directly involved in the ordinal NPDKS permit application and design af sane of the water treataent systems, and. continuing his association through supervision af other engineering specialists assigned to carry on the work in the area af water and waste water treatment as well as chlorination and dechlorination of the circulating water.
PROFESSIONAL ASSOCIATIONS: Ãr. Rios is a Diplomate of the American Academy Engineers, a member of the National of'wrLrormental Association of 'Corrosion Engineers and a Registered Professional Engineer in the State af California (COHR-327).
F32/25-12