ML20054E046

Response to Pl Hourihan 820407 Motion for Order Requiring Admission of Genuineness of Nov 1977 Effluent Document.Ee Van Brunt Affidavit Answering Motions Encl

ML20054E046
Person / Time
Site:	Palo Verde
Issue date:	04/19/1982
From:	Bischoff C JOINT APPLICANTS - PALO VERDE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20054E047	List: ML20054E046 ML20054E048
References
NUDOCS 8204260064
Download: ML20054E046 (2)

Text

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c CD7 UNITED STATES OF AMERICA

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' 22 I'0 ' N NUCLEAR REGULATORY COMMISSION "

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

ARIZONA PUBLIC SERVICE ) Docket Nos. STN 50-528 COMPANY, et al. ) STN 50-529

) STN 50-530 (Palo Verde Nuclear ) c) gp Generating Sta tion, ) G Units 1, 2 and 3) ) t I # RECElVED 7 APR 231982> g JOINT APPLICANTS' RESPONSE TO INTERVENOR'S 9 g;ncas tsum teamer MOTION FOR ORDER REQUIRING ADMISSION AND PRODUCTION OF DOCUMENTS WITHIN TEN DAYS g 828 7 " /

03 On April 7, 1982, Joint Applicants received by han delivery Intervenor Patricia Lee Hourihan's ("Intervenor")

" Motion for Order Requiring Admission and Production of Documents Within Ten Days," dated April 7, 1982. Attached to Intervenor's motion is a document entitled " Arizona Nuclear Power Project, Palo Verde Nuclear Generating Station, Use of Effluent at Palo Verde," dated November 17, 1977 (hereinafter referred to as the " Effluent Document"). In her motion, Intervenor seeks an order requiring Joint Applicants to admit the genuineness of the Effluent Document, and to produce all engineering reports on which the following statement made at page 7 of the Effluent Document is based: "[I]n the average adverse summer months we expect our effluent requirements to peak at about 2600 A-F/ unit."

I 820426006Y

4 Rather than await any Board order on Intervenor's motion, Joint Applicants offer in response the attached affi-davit of E. E. Van Brunt, Jr. As set forth in Mr. Van Brunt's affidavit, the Effluent Document was prepared under his super-vision and control during or about November, 1977. Mr. Van Brunt also describes in his affidavit the derivation of the effluent requirement figure of 2600 acre-feet per unit and explains that this figure was used by him for purposes of determining con-servative contractual commitments. Finally, Mr. Van Brunt states that there are no " engineering reports" or other docu-monts which provide a basis for the statement made respecting the figure of 2600 acre-feet per unit.

RESPECTFULLY SUBMITTED, By 9 Arthur C. Gehr jf' O Charles A. Bischoff 3100 Valley Bank Center Phoenix, Arizona 85073 Attorneys for Joint Applicants Dated: April 19, 1982 i

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