ML20024A029

Request for Production of Documents.Certificate of Svc Encl

ML20024A029
Person / Time
Site:	Palo Verde
Issue date:	06/10/1983
From:	Crawford V JOINT APPLICANTS - PALO VERDE, SNELL & WILMER
To:	WEST VALLEY AGRICULTURAL PROTECTION COUNCIL, INC.
References
NUDOCS 8306150304
Download: ML20024A029 (10)

Text

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!. TRe UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 'd3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Jlpj 3 I!IO *12 In the Matter of )

)

ARIZONA PUBLIC SERVICE )

COMPANY, et al. ) Docket Nos. STN 50-529

) STN 50-530 (Palo Verde Nuclear )

Generating Station, )

Units 2 and 3) )

)

JOINT APPLICANTS' REQUEST FOR PRODUCTION OF DOCUMENTS TO WEST VALLEY AGRICULTURAL PROTECTION COUNCIL, INC.

Pursuant to 10 CFR 62.741, Joint Applicants Ari-zona Public Service Company, et al. (" Joint Applicants")

hereby request West Valley Agricultural Protection Council, Inc. (" West Valley") to produce for the purpose of inspec-tion and copying the documents identified herein, within forty-five (45) days of the date hereof, at a suitable loca-tion convenient to West Valley to be agreed upon between the parties. Joint Applicants further request that West Valley respond to this Request for Production of Documents within thirty (30) days of the date hereof.

DEFINITIONS The following definitions apply to this Request for Production of Documents:

A. Any pronoun shall be deemed to designate the masculine, feminine or neuter gender, and singular or plural, as in each case may be appropriate.

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B. "Any," "each" and "all" shall be read to be all inclu-sive, and to require the production of each and every document responsive to this Request for Production of Documents.

C. "And" and "or" or any other conjunctions or disjunc-tions used herein shall be read both conjunctively and disjunctively so as to require the production of all documents responsive to this Request for Production of Documents.

D. " Person" means an individual, firm, corporation, asso-ciation, organization or other entity.

E. "You" and "your" as used herein shall refer to the West Valley Agricultural Protection Council, Inc., and to any and all of its members, agents, representatives, or employees, and, unless otherwise indicated, shall be read to include West Valley's attorneys.

F. " Document" as used herein means any physical thing con-taining information, including without limitation of the generality of the foregoing, any affidavit, agree-ment of any kind (or memorandum thereof), analysis, application, appointment calendar, appraisal, assign-ment, audit, bankbook, bank statement, bill, bill of lading,' bill of sale, blueprint, book of account, bul-letin, cancelled check, card, certificate (of any kind), chart, check, checkbook, check stub, compilation of data or statistics, computer input or output mate-

l. rial (including but not limited to any computer pro-gram, printout or plotter output), computer storage I

device (including but not limited to any magnetic tape, paper tape, magnetic disk, magnetic card, punch card, mass storage device, diskette, floppy disk, core stor-age or other computer memory), contract, correspondence (sent or received), data sheet, diagram, diary, dip-loma, drawing, evaluation, examination or examination-results, film (whether or not developed), financial l

statement, financing statement, forecast or projection, form (whether or not filled out), graph, instructions, instrument (including but not limited to any negotiable or non-negotiable instrument), inventory, invoice, ledger or ledger sheet, list, log or logbook, manu-script, map, memorandum, message (including but not limited to any report of any telephone conversation, conference or other conversation), microfilm, notebook, note or notes or summarization of any communication i (including but not limited to any conversation, tele-i phone conversation, personal interview or conference),

! notes or summarization of any meeting (including but

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not limited to any negotiation, class, seminar, con-ference, rally, convention, lecture, session or formal or informal discussion), outline, painting, paper, patent or patent application, photograph or photo-graphic negative (including but not limited to any x-ray, slide, movie or videotape), plans, planning materials, preliminary drawing, promissory note or

other evidence of indebtedness, position paper, pro-spectus, publication (including but not limited to any book, booklet, circular, magazine, newspaper, pamphlet i or periodical), purchase order, questionnaire, raw or uncompiled data or statistics, receipt, recording of any kind (whether or not transcribed), register, re-port, schedule, schematic, scroll, specifications, statement, study, survey, tablet, telegram (sent or received), telex, test or test results, ticket or ticket stub, voucher, warrant, working paper, writing, or other data compilation from which information can be I

obtained or translated through detection devices to a reasonably usable form when translation is practicable or necessary, and includes any original, draft (with or

without notes or changes thereon) or copy (with or

. without notes or changes thereon) of any of the fore-going. Any such document bearing on any portion thereof any mark (including but not limited to ini-tials, stamped indicia, comments or notations of any i character) not a part of the original text or photo-graphic reproduction thereof, is to be considered as a separate document.

G. " Identify," " identity" or " identification" as used herein with respect to a document shall be read to require a statement of all of the following information

l. relative to such document: (1) title; (2) nature and i

subject matter; (3) date; (4) author; (5) addressee; (6) file number or other identifying mark or code; (7) location by room, building, addre.ss, city and state;

'and (8) identification of custodian.

H. " Identify," " identity" or " identification" as used herein with respect to any individual shall be read to require a statement of all of the following information pertaining to such individual: (1) present home ad-dress; (2) present home telephone number; (3) employer; (4) present or last known business address; (5) busi-ness telephone number; (6) job description; (7) title; and (8) employment history (if any) with the party answering, including dates, job descriptions and job titles.

I. " Identify," " identity" or " identification" as used herein with respect to any entity other than an indi-vidual shall be read to require a statement of all of the following information relating to such entity: (1) full name or title; (2) principal place of business; (3) nature or type of entity; and (4) its principal business.

J. " Identify," " identity" or " identification" as used herein with respect to any conversation (including any telephone communication) or meeting shall be read to require a statement of all of the following information relating to such conversation or meeting: (1) the date on which it occurred; (2) the identity of each and every person who was present or who participated; (3) the place at which it occurred or, in the case of a telephone communication, the location of each party; and (4) a detailed statement of the substance of what was discussed or what actions were taken.

K. " Petition" as used herein shall refer to the " Petition to Intervene and Request for Preparation of Supplemen-tal or Revised Environmental Impact Statement, Hearing and Other Relief," dated October 13, 1982.

L. " West Valley" as used herein shall refer to the West Valley Agricultural Protection Council, Inc.

M. "PVNGS" as used herein shall refer to the Palo Verde Nuclear Generating Station.

N. " Joint Applicants" as used herein shall refer to Ari-zona Public Service Company ("APS"), Salt River Project Agricultural Improvement and Power District, El Paso Electric Company, Southern California Edison Company, Public Service Company of New Mexico, and Southern California Public Power Authority.

INSTRUCTIONS The following instructions apply to all documents to be produced:

A. In producing documents, indicate the paragraph and sub-paragraph to which a produced document is responsive.

B. In producing documents, furnish all documents known or available to you.

C. If any requested documents cannot be produced in full, produce to the extent possible, specifying each reason

r for your inability to produce the remainder and stating whatever.information, knowledge, or belief you do have concerning the unproduced portion.

D. If_any documents requested were at one time in exis-tence, but are no longer in existence, then so state, specifying for each document:

(a) the type of document; (b) the type (s) of information contained thereon; (c) the date upon which it ceased to exist; (d) the circumstances under which it ceased to exist; (e) the identity of all persons having knowledge of the circumstances under which it ceased to exist; and (f) the identity of all persons having knowledge or who had knowledge of the contents thereof.

I E. Documents attached to each other or contained in a file, folder, or similar binder should not be sepa-rated.

F. In lieu of producing originals or copies thereof re-sponsive to this Request for Production of Documents, you may, at your option, submit legible photographic or other reproductions of such documents, provided that the originals or copies from which such reproductions were made are retained by you until the final disposi-tion of this litigation.

PROCEDURE FOR CLAIMING LIMITATION OF DISCOVERY In the event that you seek to withhold any docu-l ment on the basis that it is properly entitled to'some limi-tation of discovery, you are requested to provide a numeri-cal list of the documents for which limitation of discovery is claimed, indicating:

1. the name of each author, writer, sender, or initiator of such document; l  !

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2. the name of each recipient of such document; ,

3. the date of such document, if any, or an estimate thereof; the title of such document, if any, or the general subject matter as described on such document; and

4. the claimed grounds for limitation of discovery (e.g.,

" attorney-client privilege").

DOCUMENTS TO BE PRODUCED

1. All documents identified in response to Joint Applicants' First and Second Set of Interrogatories.

2. All documents concerning measurements of drift mass and droplet size distribution for operating cool-ing towers prepared in whole or in part by or under the direction or supervision of Dr. Charles Mulchi, Dr. Edward Davis and Dr. Michael Golay.

3. Any and all patents granted to Dr. Charles Mulchi, Dr. Edward Davis and Dr. Michael Golay concerning drift elimination or drift reduction for water cooling towers.

4. With reference to Contention I.B(iii) of the Petition, all documents concerning physical changes in the Chalk Point power plant cooling towers made or occuring during the initial six-year operation of the plant, in-cluding but not limited to replacement of the drift elimi-nators, and the changes in salt deposition resulting from each such physical change.

5. With reference to Contention VI.B of the Peti-tion, ~all documents concerning the possible modification of

t the salt drift eliminators at PVNGS which will increase the salt drift capture efficiency at relatively modest increases in fan power and fan energy costs.

6. With reference to Contention VI .C of the Petition, all documents concerning the potential for de-crease in salt drift emissions from the PVNGS cooling towers through implementation of one or more of the steps listed in paragraphs (i) through (iv) of Contention VI.C.

7. All documents concerning recommendations for reducing cooling tower drift at facilities other than PVNGS by Dr. Charles Mulchi, Dr. Edward Davis and Dr. Michael Golay.

8. All documents referred to in the following reports, including all documents listed as references or literature for such reports:

a. Memorandum Report, TO: Mr. Steven Pavicek, Committee Chairman, West Valley Agricultural Pro-tection Council, FROM- Dr. Edward A. Davis, Consultant,

SUBJECT:

Examination of Modeling of Salt Deposition to Off-Site Properties by the Palo Verde Nuclear Generating Sta-I tion, dated September 28, 1982.

l b. C. L. Mulchi, " Review of the Environmen-tal Impact of the Palo Verde Station on Agriculture" (un-dated).

c. fl. L. Golay, " Examination of Salt-Drift-and Water-Consumption-Related Aspects of the Palo Verde Nu-clear Generating Station," dated September 28, 1982.

DATED this 10th day of June, 1983.

SNEL W E Art 4/lfr G. C Ir~, K .,

Warren . Platt, T sq.

Charles A. Bischo f, Esq.

Vaughn . Crawford, Esq.

3100 V ley Bank Center Phoeni , Arizona 85073 Attorneys for Joint Applicants i

l

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

)

ARIZONA PUBLIC SERVICE )

COMPANY, et al. ) 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 " Joint Applicants' Request for Production of Documents to West Valley Agricultural Protection Council, Inc" have been served upon the following listed persons by deposit in the United States mail, properly addressed and with postage prepaid, this 10th day of June, 1983.

Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Chairman, Maricopa County Board of Supervisors 111 South Third Avenue Phoenix, Arizona 85004 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Robert M. Lazo, Esq.

Chairman, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555

'o Dr. Richard F. Cole Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Dixon Callihan Union Carbide Corporation P.O. Box Y Oak Ridge, TN 37830 Lee Scott Dewey, Esq.

Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Edwin J. Reis, Esq.

Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Lynne Bernabei, Esq.

Government Accountability Project Institute for Policy Studies 1901 0 Street, N.W.

Washington, D.C. 20009 Kenneth Berlin, Esq.

Suite 550 2550 M Street, N.W.

Washington, D.C. 20037 Charles A.disch

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