ML20023D806
| ML20023D806 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 06/01/1983 |
| From: | Berlin K WEST VALLEY AGRICULTURAL PROTECTION COUNCIL, INC. |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| Shared Package | |
| ML20023D807 | List: |
| References | |
| NUDOCS 8306030333 | |
| Download: ML20023D806 (10) | |
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'83 JDl-2 N0 :44 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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ARIZONA PUBLIC SERVICE
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Docket Nos. STN 50-529 COMPANY, et al.,
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STN 50-530
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(Palo Verde Nuclear
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Generating Station,
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Units 2 and 3
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PETITIONER WEST VALLEY AGRICULTURAL PROTECTION COUNCIL, INC.'S RESPONSE TO NRC STAFF'S SECOND SET OF INTERROGATORIES Petitioner West Valley Agricultural Protection Council,
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Inc. (Petitioner), hereby answers, to the extent not objected to, "NRC Staff's Second Set of Interrogatories to West Valley Agricul-tural Protection Council, Inc. " ( Interrogatories).
In so answering, Petitioner reserves all its objections, not set forth specifically in response to each interrogatory, as to the relevance or materiality of these interrogatories or any part thereof.
The answers to these Interrogatories are based on the best information presently available to Petitioner.
Petitioner reserves the right to supplement or amend these answers.
General Objections West Valley hereby incorporates, by reference, the General Objections set forth in its Response to Joint Applicants' Second Set of Interrogatories.
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INTE ROGATUR*E3 i
IN dOGATORY 1 In precosed Contantien IS.3 in Wes: 'lalley's Intarvention Petition, it is stated that the ex:ectad salt decosition levels in the areas of P'INGS are likely to cause inju.ry to creos.
With respect to all such fam areas where it is c:ntanded that creo injury is 11kaly:
(4)
Provide the name, location, and a descripticn of each fam to include:
(i) the name of the cwner (ii) the legal descriotion of the land utili:ad to descMbe dis precary
~ (iii) the numcer of acres of land devotad to agriculture en each fa m
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(iv) a designation as to wnether the fam is cwned by a Ast
'/ alley memcer I
(b)
- . Or each fam provide -he location (distanca in.niles and c:meass directien) of all creoland, hay and :asturt land fr:m the P'ING3 c:aling ::wers (c)
As to the creoland, hay and pasture land identified in (b),
list the ty;es of emos (e.;.:
cett:n, alfalfa, wheat) en each farn *nich were gr:wn for each of the years 1973 thr:ugn 1952, to include:
(i) the acreage devetad to each such em o (ii) the amcunt of eacn creo harvestad (in scunds, bales, bushels, at:. ;er acrt)
(iii) the sales volume (in dellars) for eacn crec (d)
As :: each crec grown on each f arn, sa: Out tne : refit or icss en the sale of each cree for each of the years 1973 thr:ugn 1982.
. 1.
Object on the basis of General Objection No. I to Joint Applicants' Second Set of Interrogatories.
Ihie.sROGATORY 2 In West Valley's Response to Staff's First Set of Intarrogatories (hereinaftar referred to as' Wost Valley's Response), it is statad in response to Intarrogatory 11 that:
.... the requestad information is available in public records and Petitioner currentiv does not have this infomation in its records.
Petitioner will make sumaries att this information available to the NRC Staff as soon as it is ' compiled.
For each public record tnat West Valley claims contains the recuested infornation:
(a)
Identify each such record by name and/or title and designata the relevant sections of each record where the relevant infomation can be found.
(b)
Describe in detail the-type of infonnation that is contained in each of these records as it apolies to Staff's interrogatorf.
(c)
Identify by name and address those locations where cocies of these records can be obtained.
(d)
Stata the approximate date that West Valley intends to make
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sumaries of these records available to Staff.
2.
West Valley is still in the process of inspecting and analyzing these records and therefore cannot respond at this time.
West Valley will provide the requested data as soon as its reviews are complete, which it estimates will occur early r
4 INTERROGATORY 3 In West Valley's Resconse ta Interrogatory 8 of Staff's First Set of Intarrogatories, West Valley failed to answer cortain portions on the grounds that it did not understand what was requestad.
By way of explanation, what Staff has asked for In this interregatory is West Valley's reasons why PVNGS and Chalk Point are analogous in view of the fact that even during a draught year at Chalk Point there are substantial differences between the two locations.
These differencas include the-fact that:
(i) crops near PVNGS are irrigated while those at Chalk Point are not.
(ii) the relative humidities are quita different between the two locations, even during drcught conditions in the Chalk Point vicini'ty.
It is reouested that West Valley explain ho~w these obvious dif-ferences regarding irrigation and relative humidity can be reconciled to enable West Valley to contand that Chalk Po' int and PVNGS are analogous.
3.
West Valley does not contend that conditions at Chalk Point and PVNGS are analogous on average.
Data from Chalk Point do provide a useful starting point for considering the potential impacts of salt drift on crops.
And, in some respects, Chalk Point and PVNGS may be more similar than would appear at first blush.
.5-First, the Chalk Point studies include data from a drought period, that of July - September 1977, similar to the limited rainfall conditions at PVNGS.
See Journal of Environmental Quality 10: 541-547, cited in West Valley's previous interrogatory.
responses.
Salt injury to crops was severe during that period, and supplemental irrigation became necessary to relieve drought stress symptoms.
Supplemental irrigation is used at the sites near Chalk Point when less than one inch of rain falls in a week.
Irrigation methods at Chalk Point and PVNGS do differ, with sprinkler irrigation commonly the practice at Chalk Point and furrow irrigation commonly the practice at PVNGS.
The latter method has the disadvantage of not removing salts.from leaves.
Sprinkler irrigation, like rain, will wash away accumulated salts.
PVNGS crops thus may be more prone to salt injury than Chalk Point crops grown under drought conditions.
Relative humidities at Chalk Point and PVNGS obviously differ.
Relative humidities within the plant canopy, however, may prove j
upon study to be quite similar.
Free water from furrow irrigation l
may increase relative humidities within the canopy considerably above ambient conditions, close to ambient levels typical of l
Chalk Point.
l Detailed study of PVNGS conditions is necessary to compare and contrast Chalk Point and PVNGS accurately.
. INTEROGATORY 4 In response to Intarrogatory 15 a-d of Staff's First Set of Intarrogatories, West Valley states that the infomation reoues*M is not presently available to it.
Staff is unable to datamine from this response whether:
(1) West Valley will later obtain infomation concarning time and frequency of dew femation and leaf damage and submit it in response to this interrogatory at a latar data or (2) no data exists on this subject and Dr..'dulchi's conclusions are speculative.
It is re-quested that West Valley:
(a) explain whether condition (1) or (2) above exists with resoect to each intarrogatory, 15.a-d.
If there is some other explanation, exclain fully; (b) provide the basis, to include a description of all data, ucon which Dr. Mulchi relies to assert leaf damage by dew formation and water droplets frem icw intansity rainfall events.
l 4.(a)
To West Valley's knowledge, no data have been compiled concerning time and frequency of dew formation and leaf damage in the pVNGS region.
Such data may subsequently become available
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through the Crop Study sponsored by Joint Applicants.
4.(b)
Dr. Mulchi's conclusions are based upon his field work on drought stressed crops, cited in response to the NRC Staff's First Set of Interrogr. tories.
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INTERROGATORY 5
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In Pesponse. to Intarrogatney 19 of Staff's first Set of' Intarrogatories, West Valley statas that Suckeye Irrigation Company records are not in its possession.
In lieu of making Buckeye records available, it is requestad that West Valley:
1 (a)
Fully identify tne Buckeye Irrigation Tecords which it examined as a basis for its statament that ".... some watar samoles...
c:ntain twica the salt contant...."
4 (b)
Fully describe which water samples West Valley refers to in its statement that "seme water samoles taken frem the Phcenix Sewage effluent
.... contain twice the salt contant...."
(c)
Identify any writtan summaries or any other documents made by West Valley rspresentati 2: as a result of examining Buckeye water quality data.
(d)
Exclain if, at the time West Valley insoected Buckeye Irr... tion recorcs, West Valley looked at and censidered average watar quality data.
5.(a)-(d) See Answers to Joint Applicants' Second Set of Interrogatories, Nos. 42-44, 67.
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Washington, D.C.):
I, KENNETH BERLIN, being duly sworn, depose and say that
-I am Counsel for Petitioner in the referenced action; that I have read the foregoing answers to Interrogatories; that the information contained therein was gathered under my supervision; that said answers are based on information provided by Petitioner's experts; and that they are true to the best of my knowledge and to the best of the knowledge of the persons who helped in their compila-tion.
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KENNETH BERLIN SUBSCRIBED AND SWORN to before me this 1st day of June, 1983.
1 NOTARY'PUBLIC My commission expires: My femmisdonNires kne 14,1986 I
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY'AND LICENSING BOARD In the Matter of
)
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ARIZONA PUBLIC SERVICE COMPANY
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Docket Nos. STN 50-529
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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 Response to NRC Staff's Second Set of Interrogatories, dated June 1, 1983, have been served upon the following listed persons by deposit in the United States mail, properly addressed and with postage prepaid.
Robert M. Lazo, Esq., Chairman Warren Platt, Esquire Administrative Judge Snell & Wilmer Atomic Safety & Licensing Board 3100 Valley Bank Center U.S. Nuclear Regulatory Comm.
Phoenix, Arizona 85073 Washington, D.C.
20555 Docketing and Service Section Dr. Richard F. Cole Office of the Secretary Administrative Judge U.S. Nuclear Regulatory Comm.
Atomic Safety & Licensing Board Washington, D.C.
20555 U.S. Nuclear Regulatory Comm.
Washington, D.C.
20555 Lynne Bernabei, Esquire The Institute for Policy Studies Dr. Dixon Callihan 1901 Q Street, N.W.
Administrative Judge Washington, D.C.
20009 Union Carbide Corporation P. O. Box Y Oak Ridge, Tennessee 37830
2-Rand L. Greenfield Edwin J. Reis, Esquire-Assistant Attorney General Office of the Exec. Legal Dir.
P. O. Drawer 1508 U.S. Nuclear Regulatory Comm.
Sante Fe, New Mexico 87504-1508 Washington, D.C.
20555-Arthur Gehr, Esquire Lee Scott Dewey, Esquire Snell & Wilmer Office of the Exec. Legal Dir.
3100 Valley Bank Center U.S. Nuclear Regulatory Comm.
Phoenix, Arizona 85073 Washington, D.C.
20555 f-
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Dated:_ Y /// '
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~ Geri L. Kelly p'/
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' Secretary to:
Kenneth Berlin 2550 M Street, N.W.
Suite 500 Washington, D.C.
20037 (202) 429-8501 Attorney for Petitioner West Valley Agricultural Protection Council, Inc.