ML18192A685
| ML18192A685 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 06/07/1975 |
| From: | Fisher B Arizona Clean Energy Coalition (ACEC-PHX), Arizona Public Law Advocates |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| Download: ML18192A685 (27) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSXNG BOARD Xn the Matter of )
) Docket Nos. STN 50-528 ARIZONA PUBLIC SERVICE ) 50-529 COMPANY, et al. ) 50-530
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(Palo Verde Nuclear Generating ) INTERROGATORIES Station, Units 1, 2 and 3) ,)
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TO: Applicant, ARIZONA PUBLIC SERVICE COMPANY, and its attorneys, SNELL 5 WILMER, Arthur Gehr and Bruce Norton.
Under authority of 19 CFR 8 2.750, 10 CFR 2, App. A and the Federal Rules of Civil Procedure, Intervenors ARXZONA CLEAN ENERGY COALITION, hereby demand that Applicant Arizona Public Service Company (hereinafter APS) or their attorney answer .in writing and under oath and within thirty (30) days from receipt hereof, the following interrogatories:
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(l) List all officers and/or employees of all applicants who have dut1es concerning PVNGS along with a dis-of their PVNGS related duties, date first 'r1ption employed by applicant(s), date that they started PVNGS related duties, their professional and educational background, and any additional 1nformation showing their suitability for their PVNGS activities.
(2) a. List all members and/or ma)or employees of SNELL 5 WILMER, or other legal representative of applicant(s), having PVNGS related duties, legal or otherwise. Answer'as to interrogatory number one (l).
- b. L1st any and all attorneys and employees',.of SNELL 5 WILMER who have any financial interest in PVNGS through stock or otherwise and list the value of that interest.
(3) Provide to ACEC for all applicants annual reports from 1968 through the latest along with the latest propspectus for all applicants having offerings for which a propspectus may have been produced.
Also include for the same years a financ1al and statistical review.
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(4) State fully and in detail for all appl1cants
( a) The tot al generat ing capacity., load factor, and peak loads (b) Name', type, size .(design and rated capacity),
fuel source, and initial start-up date for each generating station (c) Capacity factor and availability factor on a yearly average for 1968 through 1974 and monthly average for Jan. 1974 through March 1975 for each generating station along with the net electrical power produced by each station for each period.
(d) All users us1ng more'han 1$ of the net generating capacity for the applicant serving that user along with the s1ze of the usage (in actual terms and percent of the service ut1lity's capacity),
l rate catagory and whether or not the service is interuptable.
(e) The reserve margin history from 1968 to present and the pro)ected reserve margins for each applicant thru 1985 if each user consuming more Chan (1) 1.0$ , and (11) 0.5$
of the net generating capacity of that ap-plicant were placed on interuptable load service and those users loads were used as part of the reserve margin in addition to
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the existing (or pro5ected) margins with and without PVNGS. State in detail how th1s in-format1on was determ1ned.
(5) State fully and in detail, any special qualifications required by the NRC, applicants or others for work on the 'onstruction of nuclear plants.
'I (6) State fully and 1n detail, the number of workers of each type of construction (eg. electricians, masons, welders), how many can be supplied by the state labor market and how many Will have to be imported from out of state.
(7) Discuss fully and in detail, any predicted problems that may be incountered in obtain1ng construction workers if all proposed nuclear plants around the country are built as planned.
(8) State fully and in detail, all plans contracts and assurances; with the basis and details of these plans, contracts and assurances; to provide (1) fuel, (ii) used fuel disposal and the transportation of each from the supplier to PVNGS for the site of the plant.
I (9) State fully and in detail the number, type, and duration of flight of all aircraft (military and private) in the geographic airspaces within (a) 5 miles, (b) l0 miles, and (c) 25 miles of the PVNOS site on a (1) per day and (11) per year basis and state in detail and fully how this in-formation was determined and the basis for this in format1on.
(10) State fully and in detail any- plans, progections, or considerations by any of the"applicants or by any group in con)unction with any of the applicants for the construction of any additional nuclear generating stations in Arizona.
(ll) Please state fully and in detail what power prospects the requested CAP water of 590,000 acre feet (the APS and SRP requests) will go to or are intended to go to and which prospects will use what amounts.
(12) State fully and in detail, the present and predicted groundwater recharge due to efft'uent discharges from the 91st AVE .and 23rd AVE plants. Include the re-charge in-river and canal chanels, and on farmland.
Also include the present and predicted amount of effluent for 1975, 1980 and 1985. List all sources of information used in answering th1s question.
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'.(13) D1scuss in detail, the possible 1mpact of the poss1ble lack of CAP water on the City of Phoenix, agricultural production on Maricopa County, and ANPP. Bear in mind the fact that ANPP would cause an additional load on an area with few or no additional water resources.
Discuss in detail the possible effects on =-the Applicant's ability to fund. the proposed prospect of the lack of CAP Bear in mind existing APS and SRP letters of intent 'ater.
for approximately 600,000 acre/ft/year and the intended re-liance on CAP water for proposed power prospects.
(15) State fully and in detail all facts and calculations used 'o conclude that there is only "an extremely remote pos-sib1lity" (PSAR 2;2.3.6) of an a1rcraft impact.
(16) State fully, and in deta11 with calculations the cost of PVNOS if the design criteria were to include aircraft impact.
(l7) State fully and in detail the site selection 'criteria used to select the. proposed plant site. List; all other areas having similar characteristics. Indicate for each criter1a the rating or score. achieved by the'roposed plant site.
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(18) State fully and in detail the reasons for preparing each site criteria as being reasonable and sufficient to )udge the site on. Give documentation in literature for each selection.
(19) As respects to the application and to your answers to In-terrogatories nos. 4 through 14, please state:
(a) The name, occupation, address, and telephone number of each person, who will be called as a witness to testify as to the facts set forth In the application and those answers, Identify-Ing which facts each person will be testifying to.
(b) The field or science In which each such person Is sufficiently schooled to enable them to ex-press opInion evidence in this matter, If any.
(c) whether such wItness will base his opinIon:
(1) In whole or in part upon facts acquired personally by that person in the course of an investigation or examination as to the facts; or
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(11) solely upon information provided that person by others.
(d) The quali fI cations of each such person Chat would render that person, if possible, as an expert witness.
(e) Xf any such witness has made a personal Investi-gation or examination relating to any of the facts or. cases set forth In the applIcation or Che answers to Interrogatories nos. 4 through 14, state the date(s) and nature of each such Investigation or examInation.
(f) Each and'very fact, and each and every document, photograph, report, item, or other tangible ob-Ject supplied or made available to each such person.
(g) Mhether each such person'as'rendered written reports, regarding facts, bases, or opinions as respects your contentions referred to In the application or interrogatories nos. 4 through l4. If so, state:
(I) the date(s) of each such report; (11) The name and address of the custodian of each such report.
(29) List each expert wItness you will call to testIfy in this matter.
C (a) Zf not previously given in answers to these Inter-rogatories, give the occupation, address, telephone number, educational background and experience (as it may relate to each person's field of expertise, if any) of each expert witness.
(b) State the subject matter on which each such expert is expected to testify.
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(c) State the facts'o which each such expert is expected to testify-(d) State each ~oinion, ii'ny, which each such expert is expected to express in testimony.
(e) G5.ve a detailed summary of the grounds for each opinion expressed by each such expert.
(21) Is any part of the application or any of the facts and/or opinions set forth 1n answers to the preceding interrogatories based solely or partially on secondary sources such as articles, books, pamphlets, publicat1ons, or the like' ~ - If so, please identify:
(a) which parts are based solely on such secondary sources; (1) The secondary sources each is based on;
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(11) if other than the entire secondary source.
is be1ng relied upon, 1dentify the part or are being relied upon.
parts'hich (b) Which parts are based partially on such secondary sources; (1) The seon'dary sources each is partially based upon; (11) if other than the entire secondary source is being relied upon, identify the part or parts which are being relied upon.
(c) Mhich facts are based solely on such secondary sources; (1) The seondary sources each such fact 1s based on;
~b (ii) if other than the entire secondary source is being relied upon, 1dentify the part or parts-which are being relied upon.
(d) Wh1ch facts are based partially on such secondary sources; (1) The seondary.sources each such fact is partially based on; (11) if other than the entire secondary source is being relied upon, identify the part or parts which are being rel1ed upon.
(e) Which opin1ons are based solely on such secondary sources;
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(f) Vhich opinions are based partially on such secon-dary sources; (1) The secondary sources each such op1nion is partially based upon; (11) if other than the ent1re secondary source is be1ng relied upon, identify the part or parts which are being relied upon.
(22) Identify, with specificity, each and every exhibit you intend to. use in this matter.
(a) As to each such exhibit, state which facts, op1nions, or contentions the exhibit supports, if any.
%1th reference to the exhibits 11sted 1n the preceding interrogatory, state the source and nature of the exhibit, i.e., whether said exhibit is documentary, a picture, or whatever; who prepared each exhibit; its date of preparation; and, who has custody of each exhibit..
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~Tg) j OJNESPONDMCE UNITED STATES OF AMERXCA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
) R ARIZONA PUBLXC SERVICE ) Docket Nos. STN 50-528 COMPANY, et al. ) 50-529
) 50-530 (Palo Verde Nuclear Generating )
Station, Units 1, 2 and 3)
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NOTICE OF SERVICE OF INTERROGATORIES Xntervenor hereby give notice that non-uniform interrogatories nos. 1-25 have been served on Applicant
,APS this'7th day of June, 1975.
ARIZONA PUBLIC LAW ADVOCATES BARBARA E. FISHER 201 North Stone Avenue, Suite 210 Tucson, Arizona 85701 Attorney for Intervenor COPY Of the foregoing mailed this 6th day 1975, to: of'une, I ~
Frederic S. Gray Bruce Norton, Esq.
Thomas M. Bruen Arthur Gehr, Esq.
U. S. Nuclear Regulatory Commission SNELL & WILMER Office of Staff Counsel 3100 Valley Center Washington, D. C. 20555 Phoenix, Arizona 85073 Andrew W. Bettwy Assistant Attorney General 1700 West Washington Phoenix, Arizona 85007 DOCKDED USNRC Carmine F. Cardamone, Jr.
1415 North Third Avenue 8 JUNll'1S75 > 2 Tucson, Arizona 85705 Docketing and Service Section Office of the Secretary U.S. Nuclear Re ulator
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