ML20023D808

Request for Production of Documents Identified in Response to First & Second Set of Interrogatories & Documents Requested in Interrogatories.Certificate of Svc Encl

ML20023D808
Person / Time
Site:	Palo Verde
Issue date:	06/01/1983
From:	Berlin K WEST VALLEY AGRICULTURAL PROTECTION COUNCIL, INC.
To:	ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
Shared Package
ML20023D807	List: ML20023D806 ML20023D808 ML20023D809
References
NUDOCS 8306030334
Download: ML20023D808 (6)

Text

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

)

ARIZONA PUBLIC SERVICE COMPANY, ) Docket Nos. STN 50-529 et al. ) STN 50-530

)

(Palo Verde Nuclear Generating )

Station, Units 2 and 3) )

)

INTERVENOR WEST VALLEY AGRICULTURAL PROTECTION COUNCIL ,INC.'S REQUEST FOR PRODUCTION OF DOCUMENTS Intervenor West Valley Agricultural Protection Council, Inc. (" West Valley") hereby requests, pursuant to 10 C.F.R. 5 2.741 and the Discovery Order governing this proceeding, that Arizona Public Service, et al. (" Joint Applicants") produce for the purpose of inspection and copying the documents and things described herein on or before July 15, 1983 at locations convenient to Joint Applicants to be agreed upon between the parties.

In accordance with the discovery order, West Valley requests that Joint Applicants respond to this Request for i

Production of Documents by July 1, 1983.

8306030334 830601 PDR ADOCK 05000529 O PDR

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T Definitions

1. As used herein, " document" shall mean any writing and shall include, without limitation, the original and each copy, regardless of origin, and all drafts of correspondence, memoranda, diaries, time records, reports, notes, letters, telegrams, messages (including reports, notes or memoranda of telephone conversations and conferences), books, magazines, newspapers, booklets, circulars, bulletins, notices, instructions, minutes (including those of corporate boards, executive and management committees and other internal bodies) and other communications, purchase orders, photographs, phonograph, tape or other records or recordings, and other compilations from which information can be obtained (translated, if necessary, by Joint Applicants through detection devices in'to us'able form), and labels.

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

3. As used herein, Joint Applicants refers.to the Arizona public Service Company and all other entities with an ownership interest in the palo Verde Nuclear Generating Station.

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

5. Bechtel as used herein refers to the Bechtel power Corporation of San-Francisco, California.

6. Marley as used herein refers to the Marley Cooling Tower Company of Mission, Kansas. - *-

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

8. As used herein, "you" or "your" refers to Joint Applicants and includes any person or entity associated with Joint Applicants, including, but not limited to, employees, agents, counsel, and anyone else acting on its behalf.

Instructions

9. This Request shall not be deemed to call for identical copies of documents. A document with handwritten notes, editing marks, etc. shall not be deemed identical to one without such modifications, additions or deletions.

10. If the attorney-client or any other privilege is claimed as to any document called for by this Request, the response hereto shall state the title of such document, the date of such document, the name(s) and address (es) of the person (s) who prepared it and the person (s) to whom it was directed or circulated.

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11. Each document produced or copied pursuant to this Request shall be identified in such production by the interroga-tory number (s) of West Valley's First and Second Set of Interroga-tories to which it pertains.

Documents to be Produced

1. All documents identified in response to West Valley's First and Second Sets of Interrogatories.

2. All documents,the identity of which was requested in West Valley's First and Second Sets of Interrogatories, but which were not indentified in Joint Applicants' Responses.

Dated: s ~ 3 , 7N - . . .s.M iS4 Lb ovS Kenneth Berlin Washington, D.C.

Attorney for Intervenor West Valley Agricultural Protection Council, Inc.

2550 M Street, N.W.

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

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

)

ARIZONA PUBLIC SERVICE COMPANY, ) Docket Nos. STN 60-529 et al. ) STN 50-530

)

(Palo Verde Nuclear Generating )

Station, Units 2 and 3) )

)

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Request For Production of Documents has been served upon the following noted 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

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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 Dated: h /4'/ ! 'Y 0 '/r /:45'

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'7'e Geri L. Kelly ,e Secretary to: '

Kenneth Berlin Attorney at Law Suite 500 2550 M Street, N.W.

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

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