ML20069F016
| ML20069F016 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/15/1983 |
| From: | Crawford V JOINT APPLICANTS - PALO VERDE, SNELL & WILMER |
| To: | WEST VALLEY AGRICULTURAL PROTECTION COUNCIL, INC. |
| References | |
| NUDOCS 8303220257 | |
| Download: ML20069F016 (124) | |
Text
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l NQED l
'83 pm 18
- Q.
1b Arthur C. Gehr Warren E. Platt 2 Charles A. Bischoff Vaughn A- Crawford 3 SNE 4 WILMER s 00 Valley Bank Center ii Phoenix, Arizona 85073 (602) 257-7211 5
Attorneys for JOINT APPLICANTS 6
7 UNITED STATES OF AMERICA 8 NUCLEAR REGULATORY COMMISSION 9 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 10 In the Matter of ) DOCKET NOS. STN 50-528 ARIZONA PUBLIC SERVICE ) STN 50-529
- .. 11 COMPANY, et al., ) STN 50-530
- !i:: 12 (Palo Verde Nuclear
) JOINT APPLICANTS' FIRST
!B Generating Station, Units 1, ) SET OF NON-UNIFORM
!*:!!: 13 2 and 3) , ) INTERROGATORIES TO WEST VALLEY AGRICULTURAL
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$. -l 14 i PROTECTION COUNCIL, INC.
l 15j TO: WEST VALLEY AGRICULTURAL PROTECTION COUNCIL, INC. and its attorneys.
16 17 , Under authority of 10 C.F.R. 52.740(b) you are -
18 hereby requested to answer in writing and under oath, within 19 thirty (30) days from the receipt hereof, the following 20 interrogatories: i
- i 21 ! !
i 22 ' INSTRUCTIONS FOR USE !
l A. All information is to be divulged which is in the pos- l l 23 l session of the individual or corporate party, his at- l 24 >
torneys, investigators, agents, employees, or other :
representatives of the named party and his attorney. l 25 ,!
, ll B. Where an individual interrogatory calls for an answer f l 26 which involves more than one part, each part of the
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answer should be clearly set out so that it is under-standable.
2 C. Where the term "you," or " defendant" is used, it is 3 meant to include every individual party and separate answers should be given for each person named as a 4 party, if requested.
5 D. A space has been provided on the Form of Interroga-tories for your answer. Two copies are served here-6 with. Complete all copies and serve a copy of each separate counsel representation, retaining a copy in 7 your file. Attach a verification and certificate of mailing.
8 E. In the event the space provided is not sufficient for 9 your answer to any of the questions, please attach a separate sheet of paper with the additional informa-10 tion.
a, 11 F. These interrogatories are intended as continuing inter-y si rogatories, requiring you to answer by supplemental
- e i: 12 l answer, setting forth any information within the scope of the interrogatories as may be acquired by you, your
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14 15 DEFINITIONS i
16 g The following definitions are applicable to all e
17 Interrogatories contained herein: ,
l 18 A. Any pronoun shall be deemed to designate the masculine, feminine or neuter gender, and singular or plural, as 19 in each case may be appropriate.
20 B. "Any," "each" and "all" shall be read to be all inclu- ;
sive, and to require the enumeration of each and every 21 item of information or document responsive to the i interrogatory in which such term appears. l l
22 C. "And" and "or" and any other conjunctions or disjunc- !
23 tions used herein shall be read both conjunctively and !
disjunctively so as to require the enumeration of all 24 information responsive to all or any part of each l interrogatory in which any conjunction or disjunction 25 i appears.
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1 D. " Person" means an individual, firm, corporation, as-sociation, organization or other entity.
2; E. "You" and "your" as used herein shall refer to the West 3 Valley Agricultural Protection Council, Inc., and to any and all of its members, agents, representatives, or 4 employees, and unless otherwise indicated, shall be read to include West Valley's attorneys.
F. " Document" as used herein means any physical thing 6 containing information, including without limitation of the generality of the foregoing any affidavit, agree-7 ment of any kind (or memorandum thereof), analysis, application, appointment calendar, appraisal, assign-8 ment, audit, bankbook, bank statement, bill, bill of
- lading, bill of sale, blueprint, book of account, 9 bulletin, cancelled check, card, certificate'(of any kind), chart, check, checkbook, check stub, compilation l 10 of data or, statistics, computer input or output ma-terial (including but not limited to any computer a . 11 program, printout or plotter output), computer storage y i. device (including but not limited to any magnetic tape,
!B f lll 12 paper tape, magnetic disk, magnetic card, punch card, mass storage device, diskette, floppy disk, core
! ! * :!l E 13 storage or other computer memory), contract, corre-3 $ !! spondence (sent or received), data sheet, diagram, 5
14 diary, diploma, drawing, evaluation, examination or examination results, film (whether or not developed),
i 15 financial statement, financing statement, forecast or projection, form (whether or not filled out), graph, 16 instructions, instrument (including but not limited to any negotiable or non-negotiable instrument), inven-
- 17 tory, invoice, ledger or ledger sheet, list, log or
! logbook, manuscript, map, memorandum, message (in-18 cluding but not limited to any report of any telephone
! conversation, conference or other conversation),
i 19 microfilm, notebook, note or notes or summarization of I
any communication (including but not limited to any 20 conversation, telephone conversation, personal inter-view or conference), notes or summarization of any 21 meeting (including but not limited to any negotiation, l' class, seminar, conference, rally, convention, lecture, l 22 session or formal or informal discussion), outline, painting, paper, patent or patent application, photo-
. 23 graph or photographic negative (including but not l limited to any x-ray, slide, movie or videotape),
24 plans, planning materials, preliminary drawing, prom-
[ issory note or other evidence of indebtedness, position l 25 ; paper, prospectus, publication (including but not l : limted to any book, booklet, circular, magazine, 26 newspaper, pamphlet or periodical), purchase order, e
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i 1l questionnaire, raw or uncompiled data or statistics, i receipt, recording of any kind (whether or not tran-2 scribed), register, report, schedule, schematic, scroll, specifications, statement, study, survey, 3 tablet, telegram (sent or received), telex, test or test results, ticket or ticket stub, voucher, warrant, 4 working paper, writing, or other data compilation from which information can be obtained or translated through 5 detection devices to reasonably usable form when trans- j lation is practicable or necessary, and includes any 6 original, draft (with or without notes or changes i thereon) or copy (with or without notes or changes 7 thereon) of any of the foregoing. Any such docum ent bearing on any portion thereof any mark (including but 8 not limited to initials, stamped indicia, comments or notations of any character) not a part of the original 9 text or photographic reproduction thereof, is to be considered as a separate document.
10 G. " Identify" as used herein with respect to a document a . 11 shall be read to require a statement of all of the fol-yij, lowing information relative to such document: (1)
- g i: 12 title; (2) nature and subject matter; (3) date; (4)
!t author; (5) addressee; (6) file number or other identi-a*{l: 13 fying mark or code; (7) location by room, building, 2 ;!
! address, city and state; (8) identification of custo-l 3l 14 dian; and (9) whether or not it is claimed that such document is privileged, and if so, the type of privi-15 lege claimed and a statement of all the circumstances which will be relied upon to support such claim of 16 privilege.
17 H. "Ident.ify" as used herein with respect to any indivi-l dual shall be read to require a statement of all of the l
18 following information pertaining to such individual:
(1) present home address; (2) present home telephone
! 19 number; (3) employer; (4) present or last known busi-ness address; (5) business telephone number; (6) job 20 description; (7) title; and (8) employment history (if any) with the party answering, including dates, job 21 descriptions and job titles.
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! 22 I. " Identify" as used herein with respect to any entity other than an individual shall be read to require a 23 statement of all of the following information relating to such entity: (1) full name or title; (2) principal 24 place of business; (3) nature or type of entity; and (4) its principal business.
25 e J. " Identify" as used herein with respect to any conversa-26 tion (including any telephone communication) or meeting l l s
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i 1 ll shall be read to require a statement of all of the fol-
, lowing information relating to such conversation or 2 meeting: (1) the date on which it occurred; (2) the identity of each and every person who was present or 3 who participated; (3) the place at which it occurred or, in the case of a telephone communication, the loca-4 tion of each party; and (4) a detailed statement of the substance of what was discussed or what actions were 5 taken.
6 K. " Petition" as used herein shall refer to the " Petition to Intervene and Request for Preparation of Supple-7 mental or Revised Environmental Impact Statement, Hearing and Other Relief" dated October 13, 1982.
8 L. " West Valley" as used herein shall refer to the West 9 Valley Agricultural Protection Council, Inc.
10 M. "PVNGS" as used herein shall refer to the Palo Verde Nuclear Generating Station.
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y si N. " Joint Applicants" as used herein shall refer to
!E Project Agricultural Improvement and Power District, El
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- la 5: 13 Paso Electric Company, Southern California Edison
' Company, Public Service Company of New Mexico, and 3di]i y
14 Southern California Public Power Authority.
INTERROGATORIES 15l 16 1. In your Petition, you allege that West Valley 17 is a non-profit corporation formed in 1982 by farmers in l
18 Maricopa County, Arizona. State the date upon which West 19 Valley was incorporated, and identify the officers and di-20 rectors of the corporation.
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1 2. In your Petition, you allege that West Valley 2 has 56 farmer members. Identify the 56 members who comprise 3 West Valley and state, for each, his or her address.
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9 3. For each member named in response to the pre-10 ceding interrogatory, state the precise legal description of a .. 11 the land owned and/or leased and/or operated by such member,
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- ! ne:!: 12 using the UTM or Arizona Coordinate System to describe such a e j!i 13 Property; also state the total number of acres owned and/or
- j si y h! 14 operated by each such member.
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l 21 4. For each parcel of property described in 22 answer to the preceding interrogatory, state whether you l
23 claim that such parcel, or any part thereof, will be af-I l 24 fected or may potentially be affected by salt drift deposi-25 ;. tion from the PVNGS. If you claim that only a portion of 9
l 26 j any parcel listed herein will or may be affected, describe l l ] !
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l 1 ll specifically the part thereof which you claim will or may be i
2 affected.
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7 8 5. For each parcel of property listed in answer 9 to the preceding interrogatory, state the amount of drift 10 per acre which you claim will be deposited thereon on a s.. 11 daily, monthly and annual basis.
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1 17 6. Describe the precise method by which the 18 deposition figures given in response to the preceding inter-19 rogatory were calculated. Include in your answer all facts, 20 assumptions, and calculations upon which such figures are 21 based. i 22 l i
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! 7. Identify each person having knowledge, or i
2l 1 claiming to have knowledge, of the facts set forth in your 3 answer to the preceding interrogatory. As to each such 4 person, state the specific facts concerning which they have 5 knowledge or claim to have knowledge.
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10 11 , 8. Identify each and every document which refers m..
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17 18 19 9. For each parcel of land described in answer to Interrogatory No. 3, state whether the farmer member of l l 20
, l 21 West Valley owns such land, leases it, or farms it under any !
22 other form of ownership or control. If the farmer member leases the land described, state the name of the owner / l 23
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24 lessor; if the farmer member does not own or lease such 25 property, describe the relationship pursuant to which the l i
1 farmer member operates the land in question.
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5 6 10. Identify each person having knowledge, or 7 claiming to have knowledge, of the facts set forth in your 8 answer to the preceding interrogatory. As to each such 9 person, state the specific facts concerning which they have 10 knowledge or claim to have knowledge.
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16 11. Identify each and every document which refers 17 or relates in any way to the facts set forth in your answer l 18 to Interrogatory No. 9.
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23 24 12. For each parcel of land described in response i
to Interrogatory No. 3, indicate for each of the last ten 25 l-i i 26 i years, the percentage of such acreage which was actually I
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II 1I planted in crops and further state for each of the last ten 2 years:
3 (a) The crop (s) which were planted on such 4 acreage, or any part thereof, and the number of acres which 5 were planted in each such crop.
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10 m., 11 (b) For each crop identified in response to
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! n l;e date upon which each crop was planted, the approximate leaf-
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i out date of such crop and the harvest date thereof.
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17l 18 19 20 (c) Define the yield (in pounds, bales, f 21 bushels, etc. per acre) of each crop planted on each of the 22 parcels of property described in respanse to Interrogatory ,
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ll 3 (d) As a continuation of the preceding sub-4 parts of this interrogatory, state the market price per 5 harvest unit of the crops identified in subpart (a) above, 6 for each parcel of land listed in response to Interrogatory 7 No. 3.
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- 2 3j 12 ER l a* gj::!? 13 (e) With respect to the information provided 14 in subpart (d) of this interrogatory, state the indiviudal 15 or entity to whom the crop (s) or any part thereof was sold, 1
the date upon which the crop was sold and the means by which 16 f I
17 the sale price was established.
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23 24 j 13. Identify each person having knowledge, or i
25 l claiming to have knowledge, of the facts set forth in your ,
26 answer to the preceding interrogatory. As to each such l
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1 person, state the specific facts concerning which they have 2, knowledge or claim to have knowledge.
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7 8 14. Identify each and every document which refers 9
I or relates in any way to the facts set forth in your answer 10 to Interrogatory No. 12.
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16 ! 15. For each parcel of property listed in re-17 SPonse to Interrogatory No. 3, and for each crop which you l
18 ' claim was grown thereon during the past ten years, identify 19 the irrigation method used for each such crop and the fre-20 quency with which such crop was irrigated. Your answer ,
21 should include, but not be limited to, the total quantity of l l
22 water applied per acre per day, per month, and per growing i 23 season, and the source of the irrigation water.
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3 16. Identify each
- person having knowledge, or 4 claiming to have knowledge, of the facts set forth in your 5 answer to the preceding interrogatory. As to each such 6 person, state the specific facts concerning which they have 7 knowledge or claim to have knowledge.
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!*:!?: 13 17. Identify each and every document which refers
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21 18. Describe the water quality (i.e., the content l l
22 in parts per million (ppm)), for the irrigation water refer-l red to in Interrogatory No.15, of any minerals, nutrients, 23 l i
24 or other solids, including -- but not limited to -- salt; 25 further state the source of your information regarding the i 26 ,
water quality described herein.
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r 5 19. Identify each person having knowledge, or 6 claiming to have knowledge, of the facts set forth in your 7 answer to the preceding interrogatory. As to each such 8 Person, state the specific facts concerning which they have
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.I 81 15 20. Identify each and every document which refers 16 or relates in any way to the facts set forth in your answer 17 to Interrogatory No. 18.
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l 20 21 22 23 21. For each crop planted on each parcel of prop- l l
24 erty described in response to Interrogatory No. 3, and for 25 , each of the last ten years, identify any and all crop and/or l i 26 j soil treatments applied to the crop at any time during its j I
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l 1l growing season. Your answer should include, but not be 2' limited to, a description of all herbicides, pesticides, 3 fertilizers, soil leaching practices, etc., administered to 4 the crop and/or to the soil, and a description of the phase 5 of the crop's life at which such practices were adminis-6 tered. Further include in your answer, the purpose of such 7 practice, the method of administration, the frequency 8 thereof, and the approximate cost of each administration.
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.j 14 22. Identify each person having knowledge, or 15 claiming to have knowledge, of the facts set forth in your 16 ,
answer to the preceding interrogatory. As to each such 17 person, state the specific facts concerning which they have 18 knowledge or claim to have knowledge.
19 20 21 22 23 24 23. Identify each and every document which refers 25 ; or relates in any way to the facts set forth in your answer 26 to Interrogatory No. 21.
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5 6 24. Your Petition alleges that West Valley mem-7 bers produce ninety six million dollar's ($96,000,000) worth 8 of agricultural products per year. Describe in precise 9 detail the method by which you arrived at the $96,000,000 10 figure and the year or growing season (s) to which such a . 11 figure applies. Also state the alleged value of crops grown 5 I.I g g: by each farmer member for each of the last ten years, or by 12 a a !!
l e Ei 13 his predecessor if the farmer member has not owned, leased 3j ii 14 or operated his land for the last ten years.
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e hl 15 16 17 18 19 20 25. Identify each person having knowledge, or 21 claiming to have knowledge, of the facts set forth in your 22 answer to the preceding interrogatory. As to each such 23 Pcrson, state the specific facts concerning which they have 24 knowledge or claim to have knowledge.
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4 26. Identify each and every document which refers 5 or relates in any way to the facts set forth in your answer 6 to Interrogatory No. 24.
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- 12 27. Your Petition (paragraph 1, pg. 2) alleges
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a e :: 13 that all West Valley members are located "within the area
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yg 14 likely to be affected" by salt deposition. Give the legal e -
15 description, the owner of each parcel thereof, and the total 16 acreage included, in your definition or calculation of the 17 area which you claim will be affected.
18 19 20 21 22 23 28. Contention I.A.(i) of the Petition alleges l 24 that a "recent study" has shown that the " sampling method" l 25 h utilized by the vendor in determining the drift ratio of the i
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recirculating water in the cooling towers "can easily be in l .
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1I error by greater than 100 percent." Identify the recent 2 study to which you are referring, the author thereof, the 3 date of its preparation and the precise conclusions set 4 forth therein which you claim support the above allegation.
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9 10 29. Define the sampling method which you claim a., 11 was utilized by the vendor and which you allege can result
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18 l 30. Identify each and every fact, premise, theory i
19 or conclusion upon which you rely to support the allegation 20 that the vendor's sampling method can result in a drift l
I 21 ratio which can be in error by greater than 100 percent.
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1l 31. Identify each person having knowledge, or 2 claiming to have knowledge, of the facts set forth in your 3 answer to the preceding interrogatory. As to each such 4 person, state the specific facts concerning which they have 5 knowledge or claim to have knowledge.
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10 m., 11 32. Identify each and every document which refers
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12 13 to Interrogatory No. 30.
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i 17 18 19 33. Describe in detail the sampling method which j 20 you allege should have been used in order to reduce or 21 eliminate the potential error which you allege in contention i
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1! i 2 34. Identify each person having knowledge, or i
3 claiming to have knowledge, of the facts set forth in your 4 answer to the preceding interrogatory. As to each such 5 person, state the specific facts concerning which they have l.
6 knowledge or claim to have knowledge.
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" is Identify each and every document which refers
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1 e :i 13 or relates in any way to the facts set forth in your answer l d !! to Interrogatory No. 33.
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15 16 17 18 19 20 36. Contention I.A.(ii) alleges that the sampling l
21 methods utilized in determining the drift ratio failed to 22 recognize wind effects within the fill and drift elimination 23 system. Describe precisely the wind effects which you claim 24 were not recognized and further describe the precise manner 25 l in which you claim such wind effects will impact upon the 26 drift ratio.
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5 6 37. Identify each person having knowledge, or 7 claiming to have knowledge, of the facts set forth in your 8 answer to the preceding interrogatory. As to each such 9 person, state the specific facts concerning which they have 10 knowledge or claim to have knowledge.
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16 38. Identify each and every document which refers 17 or relates in any way to the facts set forth in your answer 18 to Interrogatory No. 36.
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i 21 22 23 24 39. Contention 1.A.(iv) alleges that the ER, EIS i 25 and sampling methods utilized in determining the drift ratio 1 0)
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1 Describe in detail the drift losses which you claim will 2 arise from the water distribution canal and the precise 3
I manner in which such losses will contribute or otherwise 4 affect the drift ratio.
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10 40. Identify each person having knowledge, or
- a.. 11 claiming to have knowledge, of the facts set forth in your l w
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! ! n is l a . [g 13 person, state the specific facts concerning which they have i : i l
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18 19 20 41. Identify each and every document which refers ,
i 21 or relates in any way to the facts set forth in your answer 1
22 to Interrogatory No. 39. ;
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2 42. Contention I.B.(iii) alleges that studies at 3 the Chalk Point, Maryland power plant showed a " sizeable in-4 crease" in salt deposition occurring after the plant had 5 been in operation for six years. Identify each and every 6 fact, premise, theory or conclusion and describe all data 7 and information, which you allege supports that allegation.
8 Your answer should include, but not be limited to, a de-9 scription of the makeup water quality, tower operation, 10 meteorology (including temperature and icing conditions),
a.. 11 deposition pattern and all other pertinent data which you EII
- 2 3: 12 claim contributed to or otherwise affected the increase in
!8 l a* j'::!! 13 the salt deposition which you allege occurred after six e -ll 14 years of operation.
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20 43. Identify each person having knowledge, or i i
l 21 l claiming to have knowledge, of the facts set forth in your j 22 answer to the preceding interrogatory. As to each such I
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3 44. Identify each and every document which refers 4 or relates in any way to the facts set forth in your answer 5 to Interrogatory No. 42.
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10 11 45. Contention I.B.(iv) describes certain cooling m..
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12 tower deteriation problems which you claim will affect salt
} e Ei 13 emissions. Identify each and every " problem" which you
- dlsi 14 claim will affect such changes and describe the precise e - l 15 manner in which such problems will contribute to or other-16 , wise affect the salt emissions.
17 18 19 20 21 22 46. Identify each person having knowledge, or ,
i 23 claiming to have knowledge, of the facts set forth in your l 24 answer to the preceding interrogatory. As to each such 25 person, state the specific facts concerning which they have 26 knowledge or claim to have knowledge.
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5 6 47. Identify each and every document which refers 7 or relates in any way to the facts set forth in your answer 8 to Interrogatory No. 45.
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N I 14 48. Contention I.C. alleges that the cooling e -
15 tower drift model utilized at PVNGS underpredicts salt depo-4 16 sition to off-site properties by a factor of ten or more.
17 State each and every fact, theory, premises or conclusion '
18 upon which you rely to support that allegation.
19 20 21 22 23 4 24 49. Identify each person having knowledge, or 25 claiming to have knowledge, of the facts set forth in your 26 answer to the preceding interrogatory. As to each such i
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1l person, state the specific facts concerning which they have 2 knowledge or claim to have knowledge.
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8 50. Identify each and every document which refers 9 or relates in any way to the facts set forth in your answer 10 to Interrogatory No. 48.
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5 e ~Il 14 15 16 51. Contention I.C.(iii) alleges that the predic-17 tions for the PVNGS 'do not exhibit the " usual salt deposi- '
18 tion patterns" . Describe what you claim are " usual" salt i
to deposition patterns ar.d further describe the precise manner ,
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1 52. Identify each person having knowledge, or 2 claiming to have knowledge, of the facts set forth in your 3 answer to the preceding interrogatory. As to each such 4 person, state the specific facts concerning which they have 5 knowledge or claim to have knowledge. 6 7 8 9 10 a., 11 53. Identify each and every document which refers I II
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14 15 16 17 1 18 19 54. Describe all data, reports, statistics, or 20 other information upon which you rely to support your def-21 ir.ition of the " usual pattern" referred to in contention 22 I.C., including all meteorological data, predictive documen-i t 23 tation, tower operating characteristics and field verifica-24 tion which supports your contention. i 25 f 26 l' ila
I 1l 2 3 4 55. Contention I.C.(ii) alleges that the PVNGS 5 model cannot be applied to the Palo Verde region and be 6 expected to provide accurate results without some " verifying 7 experience". Describe precisely what you mean by the term 8 " verifying experience" and further describe the manner in 9 which you claim such verification would contribute to the 10 accuracy of the model. s . w : ., 11
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5 !! 14 15 16 56. Identify each person having knowledge, or 17 claiming to have knowledge, of the facts set forth in your 18 answer to the preceding interrogatory. As to each such . 19 Person, state the specific facts concerning which they have 20 knowledge or claim to have knowledge. l 21 22 ; i 23 l l l 24 l l 25 : ! I i 26 j j j tj
I l 1 57. Identify each and every document which refers 2 , or relates in any way to the facts set forth in your answer 1 3 to Interrogatory No. 55. 4 l 5 6 7 8 9 58. Contention I.C.(iv)(a) alleges that the PVNGS i ~ 10 model assumes that drift droplets are released "too high". s . 11 State each and every fact, theory, premise or conclusion 5 I.
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13 the elevation at which you claim such release would be more l l.-ll 14 l accurate. 15 16 l 17 ! I 18 19 , 20 59. Identify each person having knowledge, or 21 l claiming to have knowledge, of the facts set forth in your i i !' 22 answer to the preceding interrogatory. As to each such 23 person, state the specific facts concerning which they have i 24 knowledge or claim to have knowledge. ; 25 , 26 it 9 l r i . . l l
1 2 3 4 60. Identify each and every document which refers 5 or relates in any way to the facts set forth in your answer 6 to Interrogatory No. 58. 7 8 1 ! 9 l 10 l a ., 11
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) e Ei 13 model fails to consider " turbulent diffusion" of the drift
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14 15 conclusion upon which you base that allegation; include in 16 your answer a precise description of the turbulent diffusion 17 which you claim should have been included in the model, and l 18 the manner in which such diffusion affects the drift deposi-19 , tion which is the subject of this contention. 20 21 l 22 t ! 23 24 25 , 62. Identify each person having knowledge, or
! claiming to have knowledge, of the facts set forth in your 26 I
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i l 1l ! answer to the preceding interrogatory. As to each such 2 person, state the specific facts concerning which they have 3 knowledge or claim to have knowledge. 4 5 6 7 8 9 63. Identify each and every document which refers 10 or relates in any way to the facts set forth in your answer a .. 11 to Interrogatory No. 61. s =s
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15 16 17 ! 64. Contention I.C.(iv)(d) alleges that the PVNGS l 18 model fails to consider the "effect of plume trapping by 19 elevated temperature inversions". Describe precisely and in j i 20 detail the effect which the alleged plume trapping has on i I 21 the dispersion and deposition of the drift which is the l 22 subject of this contention. Include in your answer the l i 23 source, frequency, and other relevant characteristics of the 24 elevated temperature inversions which you allege cause or 25 contribute to plume trapping. l 26 lo
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F- i 1 2 3 4 5 65. Identify each person having knowledge, or l 6 claiming to have knowledge, of the facts set forth in your 7 answer to the preceding interrogatory. As to each such 8 Person, state the specific facts concerning which they have 9 knowledge or claim to have knowledge. 10 a . ,, 11 I!I
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14 15 66. Identify each and every document which refers 16 or relates in any way to the facts set forth in your answer 17 to Interrogatory No. 64. 18 19 20 i 21 ' l 22 23 67. Contention I.C.(v) alleges that salt drift 24 Predictions for the PVNGS are low compared to "another 25 study" of a "similar tower". Describe the study to which ! i l lll you are referring and state the precise factual conclusions l l 26 i l , i' l
I l 1 contained therein which you claim support your allegation 2 that the PVNGS predictions are low, including comparisons 3 of drift deposition as a funciton of distance from the 4 respective towers. , 5 l l 6 7 8 9 68. As a continuation of the preceding interroga-10 tory, describe the "similar tower" referred to and include i a.. 11 each and every similarity which you claim contributes to or u :- es
- e 3j 12 facilitates a valid comparison of the drift deposition pre-
?E l a* ll::$E 13 dictions for such tower to the drift deposition predictions
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e l 15 l 16 ,i i l 17 ' l 18 ! 19 . i t l l 20 69. Identify each person having knowledge, or ! I 21 claiming to have knowledge, of the facts set forth in your i i i answer to the preceding interrogatory. As to each such 22 l 23 person, state the specific facts concerning which they have 24 i knowledge or claim to have knowledge. 25 l l I 26 j l s i' l ! ! l 1- i
I 1 2 - 3 70. Identify each and every document which refers 4 or relates in any way to the facts set forth in your answer 5 to Interrogatory No. 68. I i 6 7 8 4
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{ 10 a . . 11 71. Contention I.C.(ii) uses the term " vastly
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' : 23: 12 different" in reference to the climatic conditions at Palo l a* ::l!l 13 Verde. Describe the specific climatic or meteorlogical 14 factors which you allege are significant to the ability of a 15 drift model to accurately predict salt drift deposition. 16 Include in your answer the magnitude or scope of the dif-17 ferences in these significant climatic parameters that you 18 claim would make a model with verifying experience in one 19 region unacceptable in terms of its predictive accuracy in , 20 another climatic region. l i i 21 i l 22 23 24 l 25 f, 26 1 l t l ;
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1 72. Identify each person having knowledge, or 2 claiming to have knowledge, of the facts set forth in your 3 answer to the preceding interrogatory. As to each such 4 person, state the specific facts concerning which they have 5 knowledge or claim to have knowledge. \ . 7 8 9 10 m.. 11 73. Identify each and every document which refers W=
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r i te 12 or relates in any way to the facts set forth in your answer { e :i 13 to Interrogatory No. 71. S U !! 8! 14 l l 16 17 18
- 74. Contention I.C.(vi) alleges that a " properly 19 l
20 conducted salt drift analysis" would show the PVNGS model to 21 be unreliable by a factor of from ten to seventy. Describe 22 in detail each and every step, facet, assumption and compo-23 nent of the properly conducted salt drift analysis which you 24 claim would show the PVNGS model to be unreliable. 25 26 I I 4
I 1 2 3 4 75. Identify each person having knowledge, or 5 claiming to have knowledge, of the facts set forth in your 6 answer to the preceding interrogatory. As to each such 7 person, state the specific facts concerning which they have 8 knowledge or claim to have knowledge. 9 10 l s.. 11 t
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15 or relates in any way to the facts set forth in your answer l I 16 to Interrogatory No. 74. 17 18 19 l 20 21 22 23 77. Contention I.D.(i) alleges that "at times" 24 the cooling tower salinity of the Palo Verde cooling towers 25 I will be " higher than assumed in the model." With reference 26 to that allegation, state: I l l : t I l
1 (a) The " times" at which, or during which, 2 you allege the cooling water salinity of the tower will be 3 higher. 4 5 6 7 8 9 (b) Each and every fact upon which you base 10 your determination or calculation of such " times". s.. 11
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.- l 15 l 16 (c) The salinity levels which you claim will 17 occur, and the magnitude by which they will exceed those 18 levels assumed in the model. State each and every fact upon 19 which you base this allegation.
20 21 22 23 24 25 (d) Describe what you claim to be the causes of the higher salinity concentrations referred to in sub-26 lt i l i l
1 Part (c) above, and the duration of the higher levels that 2 you allege will be experienced. 3 l 4 5 i 6 l 7 8 78. Identify each person having knowledge, or 9 claiming to have knowledge, of the facts set forth in your 10 answer to the preceding interrogatory. As to each such l 11 Person, state the specific facts concerning which they have s.. w :- 12 knowledge or claim to have knowledge. E a !!
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1 80. Contention I.D.(ii) alleges that records from 2 the Buckeye Irrigation Company show that some water samples 3 taken from the Phoenix sewage effluent which will be uti-4 lized at the PVNGS contain twice the salt content listed in 5 the ER and the EIS. Describe each and every " record" which 6 you are relying on to support that allegation and further 7 state: 8 (a) The date upon which each and every l 9 sample referenced in such records was collected. 10 s .. 11 E $I
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14 15 (b) The person or persons responsible for 16 ! the collection of the sample. 17 18 19 20 21 22 * (c) The collection methods utilized to 23 obtain the samples. 24 25 l !! ! 26 ! l c i 1 i,
I 1 2 3 (d) The tests, calculations, or other i 4 methods used to determine the salt content of such samples. 5 6 7 8 l 9 10 (e) The precise location at which such e .. 11 samples were drawn from the Phoenix Sewage effluent.
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a e I! 14 15 16 17 81. Identify each person having knowledge, or l l 18 claiming to have knowledge, of the facts set forth in your l i 19 answer to the preceding interrogatory. As to each such 20 Person, state the specific facts concerning which they have 21 knowledge or claim to have knowledge. 22 23 24 25 1 a 26 j l i i ! l
1 82. Identify each and every document which refers 2 or relates in any way to the facts set forth in your answer 3 to Interrogatory No. 80. 4 5 6 7 8 9 83. Contention I.D.(iii) alleges that the cooling 10 water source is likely to change over the life of the plant. a .. 11 State each and every fact, theory, premise or conclusion
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l 8] e - 14 15 16 17 18 84. Identify each person having knowledge, or 19 claiming to have knowledge, of the facts set forth in your l 20 answer to the preceding interrogatory. As to each such 21 person, state the specific facts concerning which they have 22 knowledge or claim to have knowledge. 23 24 25 26 j I i
1l 2 85. Identify each and every document which refers 3 or relates in any way to the facts set forth in your answer 4 to Interrogatory No. 83. 5 6 7 8 9 10 86. Contention I.D.(iii) alleges that the change a., 11 to which that contention refers will lead to "much higher w 1 :S E
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14 upon which you rely to support that allegation including 15 specifically the magnitude of the concentration which you 16 allege will result. 17 18 19 20 l 21 22 I 87. Identify each person having knowledge, or l ) 23 claiming to have knowledge, of the facts set forth in your 24 answer to the preceding interrogatory. As to each such 25 l Person, state the specific facts concerning which they have t 26 ! knowledge or claim to have knowledge. I l l
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t l l 1 2 3 4 5 6 88. Identify each and every doctcnent which refers 7 or relates in any way to the facts set forth in your answer 1 8 to Interrogatory No. 86. 9 10 m.. 11 EII 12
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- 89. Identify each and every fact, calculation,
%,n- h! 14 15 study, test, or other pertinent data upon which you rely to 16 support the allegation in contention I.E.(i) that blow off 17 from the evaporation ponds will average 23,000 pounds of 18 salt per day.
19 20 21 22 23 24 90. Identify each person having knowledge, or 25 claiming to have knowledge, of the facts set forth in your 26 answer to the preceding interrogatory. As to each such I
l I i l i 1j person, state the specific facts concerning which they have T l t 2l i knowledge or claim to have knowledge. 3 t 4 5 i 6 l 7
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9 91. Identify each and every document which refers 10 or relates in any way to the facts set forth in your answer l a .. 11 to Interrogatory No. 89. I II 12 l I
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l 5 e -!! 14 15 16 17 18 92. Identify each and every fact, study, test, 19 calculation, or other pertinent data upon which you rely to 20 support the allegation in contention F that the salt deposi-21 tion from spray ponds may exceed the deposition from the 22 cooling towers. ; i 23 I 24 25 ; 26 4 11 d
1 2 3 4 93. Identify each person having knowledge, or 5 claiming to have knowledge, of the facts set forth in your 6 answer to the preceding interrogatory. As to each such 7 person, state the specific facts concerning which they have 8 knowledge or claim to have knowledge. 9 10 m ., 11 w - I 82 12 I a 'j
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e 8! 14 15 94. Identify each and every document which refers 16 or relates in any way to the facts set forth in your answer 17 to Interrogatory No. 92. I 18 l 19 20 21 22 ; i 23 95. Contention I .F. (ii) alleges that the ER un- l 24 realistically expects refueling intervals for each tower to 25 , be one month per year when experience at most other similar i 26 ! stations has shown that a larger value would be more realis-i.
l 1i tic. Identify each and every station to which that allega-2 tion refers, the dates of refueling outages at each such 3 station and the " larger value" which you allege would be 4 more realistic for refueling intervals. 5 6 7 8 9 10 96. Identify each person having knowledge, or i a, 11 claiming to have knowledge, of the facts set forth in your l
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! a fl e 12 answer to the preceding interrogatory. As to each such ] e Ei 13 Person, state the specific facts concerning which they have i
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15 16 l 17 18 1 19 20 97. Identify each and every document which refers 21 or relates in any way to the facts set forth in your answer 22 to Interrogatory No. 95. 13 24 ; I 25 i , 26 l l
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2 98. Identify each and every fact upon which you 3 rely for your selection of the " larger value" referred to 4 in contention I.F.(ii). 5 6 7 8 9 10 99. Identify each person having knowledge, or a .. 11 claiming to have knowledge, of the facts set forth in your i:
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12 answer to the preceding interrogatory. As to each such 8* E! 13 person, state the specific facts concerning which they have
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i 15 16 17 18 19 20 100. Identify each and every document which refers , t 21 or relates in any way to the facts set forth in your answer l l 22 to Interrogatory No. 98. ! l, 23 24 1 25 .! i r 26 l l I i! il
I t 1 i 1l 2l 101. Identify each and every fact theory, premise 3 or conclusion upon which you rely to support the allegation 4 in contention I.F.(iii) that the drift distributions from 5 the spray ponds are unreliable and that the vendor's drift 6 source term and drift transport model can be expected to be 7 seriously in error by as much as a factor of ten. Include 8 in your answer each and every study, test, calculation, 9 report, or other source of pertinent data which supports 10 such allegation. e . 11
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14 15 16 102. Identify each person having knowledge, or 17 claiming to have knowledge, of the facts set forth in your l 18 answer to the preceding interrogatory. As to each such 19 person, state the specific facts concerning which they have 20 knowledge or claim to have knowledge. 21 . 22 23 14 25 t 26 i l i
E-I 1 103. Identify each and every document which refers 2 or relates in any way to the facts set forth in your answer 3 to Interrogatory No. 101, 4 5 6 7 8 9 104. Define the term " drift ratio" as used in con-10 tention I.G.(i). a.. 11
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14 15 16 , 105. Describe each and every item or component of 17 cooling tower deterioration to which you refer in contention 18 I.G.(ii) and which you claim will affect the drift ratio 19 utilized by the Applicant. Include specifically the date 20 upon which you claim each such component or item of deteri-21 oration can be expected to begin, the magnitude of such 22 deterioration, the precise aspect of the tower which you 23 claim wil] suffer such deterioration, and the precise manner 24 in which such deterioration will contribute to or otherwise 25 ;. affect the drift ratio. l 26 i l l
l 5 l 1l l 2 3 4 5 106. Identify each person having knowledge, or 6 claiming to have knowledge, of the facts set forth in your 7 answer to the preceding interrogatory. As to each such 8 person, state the specific facts concerning which they have 9 knowledge or claim to have knowledge. 10 m.. 11 W = 3 a$
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18 19 ! 20 21 22 23 108. Identify each and every fact, theory, premise l 24 or conclusion upon which you rely to support the allegation 25 i, in contention I.G.(i) that drift ratio measurements may be i 26 in error by a factor of more than 100 percent. h i
l 1 2 3 4 5 6 7 109. Identify each person having knowledge, or 8 claiming to have knowledge, of the facts set forth in your 9! answer to the preceding interrogatory. As to each such 10 person, state the specific facts concerning which they have s .. 11 knowledge or claim to have knowledge. 5 !i 12
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( 15 I i 16 l. 17 110. Identify each and every document which refers 18 or relates in any way to the facts set forth in your answer 19 to Interrogatory No. 108. I 20 l 21 i l 22 23 l 24 25 l 111. Identify each and every fact, theory, premise i 26 ', or conclusion upon which you rely to support the allegation ! l l l i,,
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i' i t in contention I.G.(iii') that the cooling tower drift model 1 lli 2 may be in error by a factor of ten to seventy or more. 3 4 5 6 7 I 8 112. Identify each person having knowledge, or l 9 claiming to have knowledge, of the facts set forth in your 10 answer to the preceding interrogatory. As to each such a .. 11 person, state the specific facts concerning which they have w :
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17 / i 18 l 113. Identify each and every document which refers 19 or relates in any way to the facts set forth in your answer 20 to Interrogatory No. 111. I 21 22 i 23 t 24 i , 25 ! i ! l
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I t 1! ! 114. Contention II.A. alleges that in other situa-2 tions where cooling tower emissions might have had the po-3 tential to adversely affect surrounding croplands, other 4 applicants have conducted " careful assessments" of the im-5 pact of the cooling towers on such crops. Identify each and 6 every report, test, measurement, calculation, prediction, or 7 other pertinent data which you allege is a component of such 8 a " careful assessment". 9 10 m .. 11
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!*:!?: 13 14 i 115. Identify each person having knowledge, or dl claiming to have knowledge, of the facts set forth in your 15l 16 answer to the preceding interrogatory. As to each such 17 person, state the specific facts concerning which they have 18 knowledge or claim to have knowledge.
19 20 21 22 23 l 24 116. Identify each and every document which refers 25 or relates in any way to the facts set forth in your answer n ll 26 ;, to Interrogatory No. 114. t i,
1l - 2 3 4 5 6 7 117. Contention II.A. alleges that there is a "far 8 greater risk" of crop damage in the instant situation. 9 Identify each and every fact, theory, premise or conclusion 10 upon which you rely to support that allegation.
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e - 14 15 16 118. Identify each person having knowledge, or claiming to have knowledge, of the facts set forth in your l 17 18 answer to the preceding interrogatory. As to each such 19 person, state the specific facts concerning which they have 20 knowledge or claim to have knowledge. 21 22 23 24 25 26 !i h ; 1 1 l, 119. Identify each and every document which refers 2 or relates in any way to the facts set forth in your answer 3 to Interrogatory No. 117. 4 5 6 7 8 9 120. Identify the data used to establish the his-10 tory of rain events in the PVNGS region to which you refer s . 11 in contention III.A.(i).
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13 3 $ !! y? 14 15 16 17 l 121. Define the term "PVNGS region" as used in 1 18 contention III.A.(i). 19 20 i i I l 21 j 22 23 24 122. Contention III.A.(i) alleges that it is "un-25 likely" that the rain events in the PVNGS region would re-l 26 move salts accumulated on crop leaves. Identify each and ( l l l
I l l every fact, theory, premise or conclusion upon which you rely to support that allegation. 2 3 4 5 6 7 123. Identify each person having knowledge, or g claiming to have knowledge, of the facts set forth in your answer to the preceding interrogatory. As to each such person, state the specific facts concerning which they have
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14 ! 15 16 1 17 l 124. Identify each and every document which refers or relates in any way to the facts set forth in your answer to Interrogatory No. 122. 21 ! 22 23 24 25 . l I 26 ! l i i
1 125. Your contention III.A.(ii) claims that %e 2 climatic conditions At the PVNGS will " wet the leaves of 3 crops in a manner" that will dissolve much of the salt de-4 posited on the leaves. Describe precisely the manner in 5 which you claim the climatic conditions vill effect such 6 dissolution, and further identify each and every fact, - 7 theory, premise or conclusion upon which you rely to support 8 that allegation. 9 10 e .. 11 a:
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m h! 14 15 126. Identify each person having knowledge, or 16 claiming to have knowledge, of the facts set forth in your 17 answer to the preceding interrogatory. As to each such 18 person, state the specific facts concerning which they have 19 knowledge or claim to have knowledge. l 20 i 21 l i 22 ; 23 i 24 25 26 l i
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I I 1l 127. Identify each and every document which refers i 2 or relates in any way to the facts set forth in your answer 3 to Interrogatory No. 125. 4 5 6 7 8 i 9 128. Contention III.A.(ii) uses the phrase "much 10 of the salt". Describe precisely what is meant by that 11 Phrase and further describe the precise manner in which you
"!.! arrived at the level or figure which you claim will be dis-
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14 - 15 - 16 l 17 . l 18 19 129. Identify each person having knowledge, or 20 claiming to have knowledge, of the facts set forth in your 21 i answer to the preceding interrogatory. As to each such j 22 Person, state the specific facts concerning which they have l \ 23 knowledge or claim to have knowledge. l I l 24 l l 25 - l 26 ! , il l r ' h
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1 2 3 130. Identify each and every document which refers 4 or relates in any way to the facts set forth in your answer 5 to Interrogatory No. 128. 6 7 8 9 10 m .. 11 131. Identify each and every fact, theory, premise
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!afa a ji 13 in contention III.A.(ii) that climatic conditions will 14 cause movement and concentration of salt along the leaf
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15 margins. Further, identify the characteristics and causes 16 l. of such movements and concentrations. I 17 18 19 , 20 l i 21 22 132. Identify each person having knowledge, or 23 claiming to have knowledge, of the facts set forth in your i 24 answer to the preceding interrogatory. As to each such 25 Person, state the specific facts concerning which they have 26 l knowledge or claim to have knowledge. I F i I i
4l l' 1 2 3 4 5 6 7 133. Identify each and every document which refers 8 or relates in any way to the facts set forth in your answer 9 to Interrogatory No. 131. i 10 a . . 11 W ga a ::
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e h! 14 15 134. Define the terms general " chlorosis" and l 16 " necrosis" as used in your contention III.A.(ii). 17 18 19 i I 20 21 22 135. Identify each and every fact, theory, premise 23 or conclusion upon which you rely to support the allegation 24 in. contention III.A.(i) that movement and concentrations of 25 salts along the leaf margins will cause chlorosis and 26 i necrosis. Include in your answer the precise manner in l 1 I
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1 which you claim such movements and concentrations will
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2 result in chlorosis and necrosis. 3 4 5 6 7 8 136. Identify each person having knowledge, or 9 claiming to have knowledge, of the facts set forth in your 10 answer to the preceding interrogatory. As to each such a.. 11 person, state the specific facts concerning which they have w :-
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e - 14 , 15 16 17 18 137. Identify each and every document which refers 19 or relates in any way to the facts set forth in your answer 20 to Interrogatory No. 135. l 21 i 22 23 24 25 i i l 26 l
1, 138. Describe the significance of " leaf margins" l 2' in connection with your assessment of potential salt damage 3 to crops. 4 ! 5 l l 6 7 8 9 139. In adbition to the leaf margins which you i 10 claim will be damaged by the potential salt drift deposi-l s .. 11 tion, are there any other portions of the plants (i.e., l w D
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! n le 12 leafs, stems, roots, etc.) that you allege are subject to j e Ei 13 Pl ant degeneracy or disease as the result of salt deposi-Sj !!
14 tion. If your answer to this interrogatory is in the 15 affirmative, please state: 16 , (a) Each and every part or portion of such 17 P l ants which you claim are subject to deterioration or 18 disease. l 19 20 l l 21 i l 22 23 24 (b) The precise disease or other deteriora-l 25 tion which you claim may or can be caused by salt deposi-i 26 ! tion. i il
i t i 1, le 2 !! . 3 4 5 6 140. Identify each person having knowledge, or 7 claiming to have knowledge, of the facts set forth in your 8 answer to the preceding interrogatory. As to each such ! 9 person, state the spe:cific facts concerning which they have
. 10 knowledge or claim to have knowledge.
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17 ! or relates in any way to the facts set forth in your answer l 18 to Interrogatory No. 129. 19 i 20 t 21 j i 22 i l 1 23 24 j 142. Contention III.A.(iii) alleges that studies l 25 i at Chalk Point, Maryland showed much higher injury to crops 26 during a drought year than had been observed during previous i II llI 1 1
i l 1i years. Identify the precise study, and each factual con-2 clusion contained therein, upon which you rely to support 3 the allegation of this contention. 4 5 6 7 8 9 143. Contention III.A.(iv) alleges that the salt 10 accumulation on leaves resulting from the operation of the e . 11 PVNGS would cause plants to exhibit symptoms of general
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- ! 35 12 drought stress. Identify each and every fact, theory,
! n 32 l e Ei 13 premise or conclusion upon which you rely to support that j !!
l l - 14 allegation. Include specifically the level of accumulation which you believe is necessary to cause plants to exhibit 15 16 symptoms of general drought stress; further describe pre-I 17 cisely what is meant by the term " general drought stress", 18 and the manner in which such stress affects or impacts upon i 19 the plant. 20 l l 21 22 23 24 25 ; 144. Identify each person having knowledge, or 26!!f claiming to have knowledge, of the facts set forth in your I li 1 0l
r l l _ I I i 1! answer to the preceding interrogatory. As to each such 2 person, state the specific facts concerning which they have 3 knowledge or claim to have knowledge. l 4 5 6 7 8 9 145. Identify each and every document which refers 10 or relates in any way to the facts set forth in your answer s .. 11 to Interrogatory No. 143. w :- s?
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5 e -Il 14 15 l 16 . 17 146. Describe the specific difference, if any, 18 between " general drought stress" and the condition which you 19 claim will result from salt deposition. 20 i 21 l 22 23 l 24 25 , 147. Can injury caused by " general drought stress" 26 be distinguished from injury caused by salt deposition? i l
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i . 1 . If your answer to this interrogatory is in the af-2 firmative, describe the specific differences in the injuries 3 or conditions, and further describe each and every test, 4 calculation, or measurement which is used to determine the 5 source of a particular plant's injury or disease. 6 7 8 9 10
- m. 11 148. Identify each person having knowledge, or w :
3 33 'ciaiming to have knowledge, of the facts set forth in your
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!nfe ! e Ei 13 answer to the preceding interrogatory. As to each such
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l.-h! 14 Person, state the specific facts concerning which they have 15 knowledge or claim to have knowledge. 16 17 l t 18 1 19 20 21 149. Identify each and every document which refers l 22 or relates in any way to the facts set forth in your answer 23 to Interrogatory No. 147. 24 25 i 26
-o6-II
i t l 1 2 3 150. Contention III.B.(i) states that "recent 4 studies" have established that aeresol deposition of salts 5 from cooling towers can harm agricultural crops. Identify 6 each and every "recent study" to which that contention 7 refers, including the authors, dates of preparation, and 8 each and every fact recited therein which you claim supports 9 the allegation of contention III.B.(i). 10 e . 11 w =3:.-
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14 15 151. Contention III.B.(i)(b) states that certain 16 studies have established that aerosol salt deposition can 17 harm a " variety of crops" at " comparatively low levels," and ; 18 that "high enough deposition levels" can harm virtually all l 1 19 crops. With reference to that allegation, state: 20 (a) The crops included in your definition of ; 21 the " variety of crops" which you claim can be damaged by 22 comparatively low levels of salt deposition. For each and l I , 23 every crop listed, identify the facts, theories, premises, l l 24 or contentions upon which you rely to support the allegation 25 that such crop can be so damaged, including each and every , 26 study, report measurement, or test upon which you rely. I [ . i
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4 1 2 3 4 5 (b) Define the phrase " comparatively low 6 levels" in the context of each specific crop alleged to be 7 harmed. 8 9 10 m ,, 11 w :-
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;* :: 13 (c) Define the phrase "high enough deposi-5 d !!
tion levels" which you allege can harm " virtually all
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14 15 crops." 16 17 l 18 19 20 ; 21 , 152. Identify each person having knowledge, or l' 22 claiming to have knowledge, of the facts set forth in your 23 answer to the preceding interrogatory. As to each such 24 Person, state the specific facts concerning which they have 25 , knowledge or claim to have knowledge. i 26 l 1 \ l s :
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2! l 3 4 5 153. Identify each and every document which refers 6 or relates in any way to the facts set forth in your answer l 7 to Interrogatory No. 151. 8 i 9 10
, s . ., 11
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- is l 3* Ei 13 154. Contention III.B.(i)(c) state that certain 5djli
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14 studies have established that a generating station much a l , 15 smaller and utilizing less saline water than PVNGS caused 16 extensive salt damage to native plants growing in similar 17 climactic and soil conditions. With reference to that , 18 allegation, state: 19 (a) The name and location of the generating 20 station to which the above allegation refers, including the , i 21 ' factual basis upon which you allege that such station was l l 22 "much smaller" than PVNGS. ; 23 l 24 i 25 g 1 26 l 8 l l l 1 , i, j 4 l
1 2 (b) Each and every fact, theory, premise or 3 conclusion upon which you rely to support the allegation 4 that such station utilized less saline water than PVNGS, 5 including the precise amount (in terms of both water volume 6 and salinity concensrations) of saline water that you claim 7 was utilized. 8 9 10 s.. 11 w :- x 13
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! s !! } e Ei 13 (c) The precise nature and extent of the
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14 " extensive salt damage" referred to in contention e 15 III.B.(i)(c). 16 17 18 19 20 i 21 (d) The native plants which you allege were i l 22 damaged. 23 24 25 26 i , I l j l : i ! i l
I . l l 1 l l l t l 1 (e) Each and every fact upon which you rely l 2 to support the allegation that the plants damaged by the 3 allegedly smaller station referred to in contention 4 III.B.(i)(c) were grown in similar climatic and soil con-5 ditions. Your answer should include, but not be limited to, , l 6 a description of the meteorological data upon which you rely 7 to support the claim that the climatic conditions were 1 8 similar, and a description of the soil types which you claim l I 9 were similar. 10 a . ., 11 5 Is
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14 15 16 I 155. Identify each person having knowledge, or 17 claiming to have knowledge, of the facts set forth in your 18 answer to the preceding interrogatory. As to each such 1 19 person, state the specific facts concerning which they have , I 20 knowledge or claim to have knowledge. I i 21 22 23 24 i 25 l l ! l ; 26 i , i l l h il
l l 1 1f l 156. Identify each and every document which refers 2 or relates in any way to the facts set forth in your answer 3 to Interrogatory No. 154. 4 5 6 7 8 9 157. Contention III(B)(ii) alleges that salt 10 injury to cotton could cause a reduction in the number of a .- 11 bolls per plant and thus a reduction in crop yields. Iden-w E 23
- e 3j 12 tify each and every fact, theory, premise or conclusion upon
!8 a . :!?: 13 which you rely to support that allegation, including spe-3 d !!
l 8j 14 cifically in your answer, the following: l 15 (a) The nature and level of salt injury 16 which you claim would be necessary to effect a reduction in 17 the number of bolls per plant. 18 19 , l , 20 I l 21 i ! I 22 23 (b) The precise reduction in the " number of 24 bolls" per plant that you claim would be caused by such 25 l injury. 0 26 1
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i I 1 2 3 4 (c) The precise reduction, by percentage or 5 by yield per acre, which you claim would be caused by such 6 salt injury. 7 8 9 10 e .. 11
$ II 158. Identify each person having knowledge, or g ij 12 !5 a . !?
- 13 claiming to have knowledge, of the facts set forth in your 3 d !!
l sj 14 answer to the preceding interrogatory. As to each such 15 person, state the specific facts concerning which they have 16 knowledge or claim to have knowledge. 17 18 19 , ! 20 1 21 22 159. Identify each and every document which refers 23 or relates in any way to the facts set forth in your answer 24 to Interrogatory No. 157. 25 26 i l i l ti
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1. 2 3 1 4 160. Contention III(B)(ii) further alleges that [ 5 salt injury would result in a reduction in leaf area caused 6 by necrosis induced salt injury, reducing the photosynthetic 7 capacity of the plant and reducting the plant's ability to 8 assimilate cellulose fibers. Identify each and every fact, 9 theory premise or conclusion upon which you rely to support l 10 that allegation, including specifically, any tests, studies, l l s . 11 or calculations upon which you rely to support said allega-w : 3 83
- d ij 12 tion. ,
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15 16 l 17 ; l 18 161. Identify each person having knowledge, or 1 19 claiming to have knowledge, of the facts set forth in your , 1 20 answer to the preceding interrogatory. As to each such ' 21 person, state the specific facts concerning which they have i 22 knowledge or claim to have knowledge. 23 l l l 24 1, I l 25 i. . 26 ! I ; l 1 l d
I i 1 2I 162. Identify each and every document which refers ; i 3 or relates in any w.ay to the facts set forth in your answer 4 to Interrogatory No, 160. i 5 6 7 8 9 10 163. Contention III(C) alleges that salt deposi-a=. 11 tion from the PVNGS will occur at levels sufficient to cause 5* . gj jj 12 harm to surrounding agricultural crops. State precisely the
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13 level of salt deposition which you allege is " sufficient to , { [:! 14 cause harm", and the precise nature of the harm which you 15 allege will be caused. Identify each and every fact, 16 theory, premise or conclusion upon which you rely to support ' l 17 this allegation. !' l 18 19 20 ! i 21 i , i 22 ; 23 i 24 164. Identify each person having knowledge, or 25 ' claiming to have knowledge, of the facts set forth in your , i 26 l' answer to the preceding interrogatory. As to each such i ll :I It
l 1 person, . state the specific facts concerning which they have 2 knowledge or claim to have knowledge. 3 4 5 6 7 8 165. Identify each and overy document which refers 9 or relates in any way to the facts set forth in your answer 10 to Interrogatory No. 163. s . 11
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13 U !! 5 e -!! 14 15 16 166. Identify the studies to which you refer in 17 contention III.C.(i). Include in your answer the identifi-18 cation of the "certain plants" which were the apparent sub-19 ject of such study; further identify the specific meteoro-20 logical data upon which you rely to support the allegation 21 that a heavy rainfall washed all salt from the crops on the i 22 average of once a week. 23 I l 24 , 25 i 26 ; 1 i l ! t i r t
i, 1l l 2 l 3 167. Identify each person having knowledge, or ; 4 claiming to have knowledge, of the facts set forth in your 1 5 answer to the preceding interrogatory. As to each such 6 person, state the specific facts concerning which they have 7 knowledge or claim to have knowledge. 8 9 10 11 sl.5 m 12
- d jj 13 a . ;?; 13 3 $ li 14 168. Identify each and every document which refers
{ !! l 15 or relates in any way to the facts set forth in your answer 16 ' to Interrogatory No. 166. 17 ; 18 19 20 i l l 21 j l 22 169. Contention III.C.(ii) alleges that in the ; 23 area surrounding the PVNGS, deposition levels of 2-4 lbs. 24 per acre per week will occur near the plant. Define pre-25 i cisely the area which you include in your definition of ; i 26 "near the plant." Identify each and every fact, theory, l l l l l
r . premise or conclusion upon which you rely to support the 1l 2 allegation that levels of 2-4 lbs. per acre per week will 3 occur in such area. 4 5 6 7 8 9 170. Identify each person having knowledge, or 10 ' claiming to have knowledge, of the facts set forth in your a .. 11 answer to the preceding interrogatory. As to each such I ii
- g3 12 person, state the specific facts concerning which they have a.:!j:
38 ? 13 knowledge or claim to have knowledge. 3 $ !! 5 e 14 15 16 l 17 r 18 19 171. Identify each and every document which refers , l 20 or relates in any way to the facts set forth in your answer - 21- to Interrogatory No. 169. 22 23 24 25 l,. l i 26 l l I ! I l
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F t 1 172. Contention III(C)(iii) uses the phrase "in 2I arer.s further from the plant. " Define precisely the area 3 included in your definition of such areas, and further i 4 define the level of deposition to which you believe such 5 area will be potentially subject. l l 6 7 8 9 10 a 3, 11 173. The memorandum report of Dr. Edward A. Davis, s i:
- g; 12 attached to your Petition as Exhibit "A", states on page 1, ,
!E l* $j gj 8
13 that "[t]here are several indications that the model used a := l 14 for the Palo Verde study underpredicts salt deposition." { !! i 15 Define each and every " indication" referred to in that 16 statement which leads you to the conclusion that the Palo 17 Verde model under predicts salt deposition. For each 18 " indication" listed, state the following: 19 (a) Each and every fact, theory, premise or i 1 20 conclusion upon which you rely to support the alleged indi- i 21 cation. i l 22 . 23 24 25 i 26 l
- i. -
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i 1! (b) The source of such indication. 2 3 4 l 5 6 7 (c) Each and every study, test, or other . 8 such report which supports, verifies, or lends credence to 9 the facts set forth in response to this interrogatory. 10 a.. 11 w :. I E *? ! : d3 12
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14 15' 174. Dr. Davis' report, at page 6, states that Dr. 16 Davis reviewed pertinent sections of NRC, APS and related 17 documents (references 1-4 of the report) in order to evalu-18 ate the modeling of the drift deposition. For each separate 19 document reviewed in connection with such evaluation, state 20 the specific " pertinent sections" of the document which were l 21 reviewed and relied upon by Dr. Davis in reaching his con- ! l 22 - clusions. l t - 23 24 25 l 26 1 1
l 1l , 2 'l 175. Dr. Davis' report at page 6, further indi-i 3 cates that "several persons connected with the project have 4 been contacted to discuss various details of the model." 5 With reference to that statement, identify the following: ! 6 (a) Each person contacted. - 7 1 8 9 3 10 m .. 11 w - 1
- g 3*2 12 (b) The individual who contacted each per-
!5 l ae: -j!! 13 son, if other than Dr. Davis.
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( ,) ! 18 . a i 19 (c) The manner in which and the p1' ace' at s t 20 which each person was contacted. m 21 i 22 x l 23 s
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1 I i 1h (d) The substance of each and every conver-l 2I sation held with each individual listed in response to sub-3 part (a) hereof. 4 5 6 7 $.s s 8 N s "l' 9 r- 10' (e) Whether or not any notes, memorandum or a.. 11 other written memorializations were made regarding the con-w : - , s er
= g jj 12 versatiidns referred to above. If your answer to sub-18 3%
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13 part (e) hereof is in the affirmative, identify the custo-14 dian of such reports, notes, or other memorializations. 5.I! - .s 15
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I J 16 17 18 19 , 20 176. Dr. Davis' report, at page 7, states that he 21 - was provided with certain information regarding modeling 22 ' Parameterr; from individuals connected with the Marley Com-23 Pany. Dr. Davis further states that "the values provided 24 are. considerably different than those used in the APS En-25 vironmental Report on Palo Verde. " With regard to that 26 l allegation, state: i f s l -s - - l s
I i 1j (a) A descriptio'n of the values provided by 2 Marley. i 3 t i 4 5 6 7 8 (b) The specific values in the APS Environ-9 mental Report to which the Marley data was compared. 10 m.. 11 5 II !
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!t !! l[a :n! 13 a 14 15 (c) The precise extent of the difference 16 referred to in Dr. Davis' report, at page 7. 17 l l 18 l 19 l 20 . 21 i 22 (d) The significance of the difference which , 23 Dr. Davis alleges exists between the Marley and the AFS l l 24 i data. i 25 ; i' 26 '
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1 1 2 3 4 177. Dr. Davis' report states at page 8, that 5 drift from the spray ponds is emitted from a much lower 6 height and could cause more off-site salt deposition than 7 the towers, depending on the cooling water salinity. Iden-8 tify each and every fact, theory, premise or conclusion upon 9 which West Valley relies to support that statement, includ-10 ing specifically, but not limited to, the level of cooling a .. 11 water salinity, the height of release, and the drift droplet 5 ii
- g 3" 12 size distribution upon which the truth of the statement is
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13 dependent. 14 I. I:! 15 16 17 18 19 178. Dr. Davis' report at page 8, further states 20 that in relation to potential dust blowoff from the evapora-l 21 tion ponds, " rough estimates based on information in ref- l 22 erences 7 and 8 indicate that this source could exceed the l 23 cooling tower as its salt source as the ponds grow in size." l 24 Appennix IIA of Dr. Davis' report purports to provide 25 j details of this estimate. With specific reference to ; , i! i 26 Appendix IIA, state the following: l I l ll I !i l t,
i . l l 1' (a) The identity of the individual who 1 2 developed, or the source of, the mathematical equation set 3 forth in Appendix IIA. 4 5 6 7 8 9 10 (b) The manner in which the " threshold value s ., 11 of 12 mph" for wind speed was determined, calculated or
$ si 12 otherwise arrived at.
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I 17 18 19 (c) The manner in which the " typical value 20 l of erodibility" 50 to 200 tons / acre-year was determined, i l i 21 calculated or otherwise determined. 22 e 23 24 i 25 ll l ! 26 l l i 6 l
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f 1, (d) The manner in which you arrived at the i 2 figure of 20% for the frequency of sufficiently high wind I i 3 speed. 4 5 6 7 8 9 179. List each and every communication relating in 10 any way to the matters or allegations referred to in Conten-e.. 11 tion I, between any West Valley member, agent, investigator, 5 II
- g 3j 12 or attorney and the Applicant or its agents or employees,
, ! a j; 3* :: 13 stating for each such communication: 1djli
!! 14 (a) The date it occurred.
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- 15 16 1
17 18 19 20 .(b) Whether it was verbal or written. 21 ! 22 23 24 l 25 i 1 26 i i i
1 (c) The name and last known address of the 2 person initiating the communication. 3 4 5 6 7 8 (d) The name and last known address of the 9 person receiving the communication. 10 a.. 11 I II 12
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13 5 f! e ~ 14 15 (e) The substance of the conversation and 16 the particular allegation (s) of Contention I to which it 17 related. 18 19 20 i ! -l l 21 i 22 !, 23 (f) If written, the name and address of the 24 present custodian of a copy of each such communication. i 25 l l l 26 i
t l 1 2
'l 4 (g) If verbal:
5 (1) Whether by personal conversation or 6 by telephone. - 7 8 9 10 m.. 11 5 is 12 (2) The names of any persons present
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8 d !! 14 15 16 17 18 19 (3) Whether any notice or memos were i 1 20 made of the communication and, if so, by whom and the name j l t l 21 and address of the present custodian of each such record. l i 22 l 23 ! i 24 , 25 a f ! l 26 i ! I ii !, [ i 1 I i
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l I l 1 180. List each and every communication relating in 2 any way to the matters or allegations referred to in Con-3 tention II, between any West Valley member, agent, investi-4 gator, or attorney and the Applicant or its agents or em-l' b ployees, stating for each such communication: 6 (a) The date it occurred. 7 8 9 10 a.. 11 w :-
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- t3 : 12 (b) Whether it was verbal or written.
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! * !! 13 djli $1 14 15 16 17 18 (c) The name and last known address of the 19 person initiating the communication.
20 i I 21 22 23 24 25 !!o (d) The name and last known address of the 26 ! Person receiving the communication. 1
i i 1! - 2 3 4 5 6 (e) The substance of the conversation and 7 the particular allegation (s) of Contention II to which it 8 related. 9 10 m.. 11 w :- a: *
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- 13
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"*-sj 14 (f) If written, the name and address of the 4
15 present custodian of a copy of each such communication. 16 17 18 19 20 21 (g) If verbal: 22 (1) Whether by personal conversation or 23 by telephone. i 24 25 I I l 26 h I' i i
i o r i l' 2 3 (2) The names of any persons present 4 during the communications. 5
. 6 7
8 9 10 (3) Whether any notice or memos were ag 11 made of the communication and, if so, by whom and the name x #s
- lj 12 and address of the present custodian of each such record.
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15 16 l 17 18 181. List each and every communication relating in 19 any way to the matters or allegations referred to in Conten- ! 20 tion III, between any West Valley member, agent, investi-l 21 gator, or attorney and the Applicant or its agents or em- i 22 ployees, stating for each such communication-l 23 (a) The date it occurred. j l 24 25 26 i
1 2 3 (b) Whether it was verbal or written. 4 5 6 7 8 9 (c) The name and last known address of the 10 person initiating the communication. s.. 11 w :- s as
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j e E! 13 14 15 16 i (d) The name and last known address of the i 17 person receiving the communication. l l 18 19 , l 20 l 21 i 22 ; I l 23 (e) The substance of the conversation and i l 24 the particular allegation (s) of Contention III to which it 25 j related. l I' 26 i, t
1! 2 3 4 5 6 (f) If written, the name and address of the 7 present custodian of a copy of each such communication. 8 9 10 m w 11 i 3 a$
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- j j 13 (g) If verbal:
a := { !! 14 (1) Whether by personal conversation or 15 by telephone. 16 j 17 : 18 19 l 20 l l 1 ! 21 (2) The names of any persons present 22 during the communications. ; i 23
- 24 l 25 ;
26
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i 1 2l (3) Whether any notice or memos were 3 made of the communication and, if so, by whom and the name 4 and address of the present custodian of each such record. 5; 6 7 8 9 10 '182. List each and every communication relating in a., 11 any way to the matters or allegations set forth in Conten-w :- I 82
- d sj 12 tion I, between any West Valley members and/or between any
!8 8 e :: !? 13 West Valley member and any agent of West Valley (excluding
- d is Ie h! 14 only its attorney), stating for each such communication:
15 (a) The date it occurred. 16 i 17 ( 1 18 l 19 , l 20 i 1 21 l (b) Whether it was verbal or written. i l 22 l 23 24 l I 25 ; i 26 l I j l' l l"!
1 (c) The name and last known address of the 2 person initiating the communication. 3 4 5 6 7 8 (d) The name and last known address of the 9 person receiving the communication. 10 a.. 11
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a e 14 15 (e) The substance of the conversation and 16 the particular allegation (s) of Contention I to which it 17 related. 18 19 20 21 22 23 (f) If written, the name and address of the 24 present custodian of a copy of each such communicatiion. 25 26 )
I 1 .. i 1 2 3 4 (g) If verbal: 5 (1) Whether by personal conversation or 6 by telephone. 7 8 9 10 m.., 11
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- g ij 12 (2) The names of any persons present I
?E $8 8 8 :: 13 during the communications.
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15 16 l i 17 l I 18 19 (3) Whether any notice or memos were 20 made of the communication and, if so, by whom and the name 21 and address of the present custodian of each such record. l 22
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24 25 .I i 26 i i t, ll
i l l 183. List each and every communication relating in 1 ll i 2 any way to the matters or allegations set forth in Conten-3 tion II, between any West Valley memberd and/or between any 4 West Valley member and any agent of West Valley (excluding 5 only its attorney), stating for each such communication: i 6 (a) The date it occurred. 7 8 9 10 s.. 11 w :-
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- ei!j 12 (b) Whether it was verbal or written. t 38 ?
a e: 13 3 d !! e I! 14 - 15 16 17 18 (c) The name and last known address of the 19 person initiating the communication. 20 i 21 22 , i 23 24 25 l (d) The name and last known address of the *
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26 ! person receiving the communication. l i j c
n 1 i 2! 3 4 5 6 (e) The substance of the conversation and 7 the particular allegation (s) of Contention II to which it 8 related. 9 10 11 m.: w : ' E $3
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Ii 14 (f) If written, the name and address of che e - present custodian of a copy of each such communication. 15 16 17 ! 18 19 20 , (g) If verbal: t l 22 (1) Whether by personal conversation or l by telephone. 23 24 25 j, i-26 { 1 ! l 1 i i :. l 'l l
i i l 1l i 21 3 (2) The names of any persons present 4 during the communications. 5 6 7 8 9 10 (3) Whether any notice or memos were a.. 11 made of the communication and, if so, by whom and the name
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- e 3: 12 and address of the present custodian of each such record.
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e ~ 14 15 16 , 17 , 18 184. List each and every communication relating in 19 any way to the matters or allegations set forth in Conten-20 tion III, between any West Valley menters and/or between any i i 21 West Valley member and any agent of West Valley (excluding l l , l 22 only its attorney), stating for each such communication: l l 23 (a) The date it occurred. 24 25 tl 26 !l i l il i l , - - -
d
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I 1 2 3 (b) Whether it was verbal or written. 4 5 6 i 7 ; 8 9 (c) The name and last known address of the 10 person initiating the communication. s .. 11 E II
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e - 14 15 16 (d) The name and last known address of the 17 Person receiving the communication. 18 19 . 1 i 20 i i 21 ! i 22 23 (e) The substance of the conversation and : l 24 the particular allegation (s) of Contention III to which it 25 related. l ? I 26 ; i i l l -100-i
1 2 3 4 5 (f) If written, the name and address of the 6 present custodian of a copy of each such communication. 7 8 9 10 m.. 11 w :- E "3
- e ij 12 (g) If verbal:
!8 !?
l8a :=jj 13 (1) Whether by personal conversation or
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14 by telephone. 15 16 , 17 18 19 20 (2) The names of any persons present 21 during the communications. 22 l j 23 l 24 25 i 26 :
-101-li
r l . 1 , (3) Whether any notice or memos were 2 made of the communication and, if so, by whom and the name 3 and address of the present custodian of each such record. 4 i t-5 l 6 7 8 9 185. List each and every communication relating in 10 any way to the matters or allegations referred to in Conten-e.. 11 tion I, between any West Valley member or agent of West w= 3 a$
- g i: 12 Valley, and any person not referred to in Interrogatories i
!8 a . ::
!! 13 Nos. 179 or 182, stating for each such communication:
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.-l ll 14 (a) The date it occurred.
15 16 l, j l l-17 ' 18 19 . I 20 (b) Whether it was verbal or written. l 21 i l 22 l i 23 24 l 25 !. ! !l 26 !i l
!! -102-l l
i
1l (c) The name and last known address of the 2 person initiating the communication. 3 4 5 6 7 8 (d) The name and last known address of the 9 person receiving the communication. 10
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s 12
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e 8l 14 15 (e) The substance of the conversation and 16 the particular allegation (s) of Centention I to which it 17 related. i l 18 19 20 i l 21 t l 22 ! i 23 (f) If written, the name and address of the 24 present custodian of a copy of each such communication. 25 26
-103-l'
1 2 3 4 (g) If verbal: 5 (1) Whether by personal conversation or 6 by telephone. 7 i 8 9 10 m.. 11
" i; e ! ij 12 (2) The names of a.ly persons present
!E la 8 8 :: 13 during the communications. 3 d !! 58! e - 14 15 16 i 17 18 19 (3) Whether any notice or memos were 20 made of the communication and, if so, by whom and the name 21 and address of the present custodian of each such record. 22 23 24 25 26
-104-i
. 1
. l 1 186. List each and every communication relating in l
2' any way to the matters or allegations referred to in conten-3 tion II, between any West Valley member or agent of West 4 Valley, and any person not referred to in Interrogatories 5 Nos. 180 or 183, stating for each such communication: 6 (a) The date it occurred. 7 8 9 10 m.. 11 553
- 12 (b) Whether it was verbal or written.
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- 13
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14 15 16 i I 17 l 18 (c) The name and last known address of the 19 person initiating the communication. 20 l i 21 i i ! 22 ; i 23 i l l 24 l 25 (d) The name and last known address of the 26 ' person receiving the communication. t I 1 l- l l -105-i
I' i .
'Ii 1
'l 2j 3
4 5 6 - (e) The substance of the conversation and i 7 the particular allegation (s) of Contention II to which it 8 related. 9 l 10 a., 11
$ Is ! t 3* 12 ! n [l I 3 8 :: 13 l d ji se tj 14 (f) If written, the name and address of the Present custodian of a copy of each such communication.
15 l 16 17 , I 18 19 20 21 (g) If verbal: i I ( 22 (1) Whether by personal conversation or l 23 by telephone. ! 24 l 25 l 26 l'
-106-
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d., ,
c 1 2 3 (2) The names of any persons present 4 during the communications. 5 6 7 8 9 10 (3) Whether any notice or memos were a.. 11 made of the communication and, if so, by whom and the name I II 12 and address of the present custodian of each such record. IBg3:!
!8 ::
13 3 d ji a e II 14 15 16 i 17 l l 18 187. List each and every communication relating in l 19 any way to the matters or allegations referred to in Con-l 20 tention III, between any West Valley member or agent of West i i 21 Valley, and any person not referred to in Interrogatories i I 22 Nos. 181 or 184, stating for each such communication: l l 23 (a) The date it occurred. l 24 l 25 26 ;
-107-ll
i 1 - 2 3 (b) Whether it was verbal or written. l 4 . 5 6 7 8 9 (c) The name and last known address of the 10 person initiating the communication. e.. 11 E NI
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- 13 i
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3 58-14 15 < 16 (d) The name and last known address of the I 17 Person receiving the communication. 18 19 20 l 21 22 23 (e) The substance of the conversation and 24 the particular allegation (s) of Contention III to which it 25 related. 26 ! l l l 1
-108-
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5 (f) If written, the name and address of the s 6 present custodian of a copy of each such communication. 7 N s 8 9 10 a .. 11 w :-
=s
- e 3: 12 (a) If verbal:
1 m !! l8 f{ 13 (1) Whether by personal conversation or Ie h! 14 by telephone. 15 - 16 17 _ , 18 19 i 20 (2) The names of any persons present s 21 during the communications. ) 22 , I 23 24 , 1 25 l l
'N -
26 ,
-109-i
.. .._.___._....__1
I 1 (3) Whether any notice or memos were t 2 made of the communication and, if so, by whom and the name 3 and address of the present custodian of each such record.
\ 4, 5
4
'6 7l 8
9 188. List the names, addresses, official titles
,10- (if any), and other identification of all witnesses, in-e ,
\'\1 11 i cluding expert witnesses, who, it is contemplated, will be
" i, N) s w
- e ij 12 called ~upon to testify in support of your contentions in
! * ! f; '
. 13 this action, indicating the nature and substance of the
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[ ] - 14, testimony which is expected to be given and the relationship
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N - 15' of each such witness, if any, to West Valley. x 16
, i 171 le's
_' s s 19
] 20 4. v . s. !
21 ., 189. Do you or your attorneys, have in your pos-I 'I 22 session, or know the existence of, any written or recorded i 23 statemencs from any of the persons identified in your answer 24 to Interrogatory No. 188, or from any other person or entity I 25 I who has any knowledge or the facts and events related to the ~
~
26 ! issues in this proceeding? c,\ ! Om ' I -110-i\ x
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n-e 1, 2 3 4 5 6 190. If your answer to the preceding interrogatory 7 is in the affirmative, please state the following: 8 (a) The name of the person who made the 9 statement or recording; 10 4 s .. 11 w : I 83
- g 3' 12 38
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e I! 14 15 (b) The date the statement or recording was 16 made; 17 18 19 20 21 22 (c) The name of the person who obtained the 23 statement or recording; i 24 25 . I l 26 ! i
-111-
1 2 3 4 (d) The name of the person or persons having 5 custody or possession of the original and all copies of the 6 statement or recording. 7 8 9 10 m.. 11 w :- z 58
- g ;j 12 33 a . !?
- 13 191. Describe and identify by title, author, date
- jlil-l y
e 14 of preparation, recipient and subject matter, each and every 15 document and or exhibit which you intend to use or which you 16 may use as evidence at the hearing in this proceeding. In-17 clude in your answer, the name of the person, firm or corpo-18 ration presently in possession of the original and of any 19 copy of each such document. 20 21 22 23 l t 24 l 25 i 192. Have you employed, or do you intend to employ : l l ! 26 j or use, any technician or expert witness for the purposes of I I i
-112-I l il ji
7 4 supportina your allegations and contentions in this pro-1 lh 2 ceeding and/or for the purposes of testifying on behalf of 3 West Valley at the hearing in this proceeding? . 4 l 5 6 . 7 8 9 193. If the answer to the preceding interrogatory 10 is in the affirmative, please state, for each such techni- , 11 cian or expert, the following: l s .. : I l
!8
- 3 d 12 (a) His name or other means of identifica- I l * !j ?
13 tion, last known address and telephone number; "a j!: 14
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15 16 17 18 19 (b) His profession, job title or occupation 20 and the field in which he is an expert; i 21 22 23 24 25 i, 26 i -113-l l ll l
l 1 (c) Whether you intend to call him as a wit-2 ness during the hearing in this pro.ceeding; 3 , 4 5 6 7 8 (d) A summary of his formal education in his 9 field; 10 4 .. 5 si 11 ll
- d 3j 12 !!
E8 !? l * :: 13 5 d !!
.-8!
14 15 (e) The name and address of each school 16 where he received any special education or training in his 17 fieli and a description of the training; 18 19 20 i l 21 j 22 23 (f) The name or description of each degree 24 he has received, including the date each was received, and 25 the name of the school from which he received each degree. 26 ! i
-114-h
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l l l l l l 1 - l 1 2 3 4 5 194. Do any of the persons listed in your answer 6 to Interrogatory No. 193 have any special expertise as a 7 result of any experience or emplo:/ ment? 8 9 10 t 11 i 5I.5 a
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l* jj 13 195. If your answer to the preceding interrogatory a :: e 8!
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14 is in the affirmative, please state the following as to each 15 such person: 16 I (a) The training, employment or experience 17 he has received; 18 19 l 20 l i i 21 - 22 i , 23 (b) The name and address of the school or i 24 place where he received his training, experience or was 25 employed; 26
-115-l i
l
r I 1l I 3 4 5 (c) The date he received his training, 6 experience or when employed; 7 8 9 10 l a .. 11 w =~ xj
- e3 12 (d) The name of each professional and or I 1 a la a . [i 13 trade association of which he is a member.
2 d !! 5.8! 14 15 16 17 l 18 19 196. Have any of the persons listed in your answer 20 to Interrogatory No. 193 written or co-authored any books, i l 21 Papers, treatises or articles on the subjects in their field { 22 of expertise? . 23 24 25 1 ! 26
-116-i i
r . 9 1 2 197. If your answer to the preceding interrogatory 3 is in the affirmative, for each person and each such book, 4 paper, treatise or article, please state: : 5 (a) The title and subject matter; 6 7 8 1 9 l 10 l l
=:. 11 (b) The name and address of the publisher; I z is
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15 16 17 (c) The date of publication; 18 19 ! l 20 1 21 ',I 22 . l l 23 198. For each person listed in your answer to l l 24 Interrogatory No. 193, please state whether each such l I l 25 [ person has practiced, worked or been involved in his par- , i ticular field of expertise during the past ten years. l 26 l
-117-l
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2 l 3 4 5 l 6 199. For each person identified in response to the 7 preceding interrogatory, please state: 8 (a) Whether he was self-employed, employed 9 by someone else, or associated wi.th any other pcInons in any ! 10 manner; I a.. 11 W ** a :S ,
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- 13
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15 16 (b) Each address where he has practiced or 17 been employed; 18 19 20 , I I 21 i 22 23 (c) The dates he was with such employer; 24 25 26
-118-I
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1l l 2l l 3 (d) The type of duties he performed with 4 each employer. 5 6 7 8 9 , 10 200. As to each person listed in your answer to l s 3 11 the pre' ceding interrogatory who has not practiced or worked ' is
- gij 12 in his field of expertise during the past ten years, list E8 !?
j* gj 13 and identify each person's employment or vocation during a :: l !! e - 14 that period of time. 15 16 17 l 18 19 20 201. What experience, other than that stated above i 21 has each person listed in your answer to Interrogatory No. 22 193 have to qualify him as an expert or technician in his i 23 field or which may give rise to his capacity as a witness at 24 the hearing in th'is proceeding? 25 26 I
-119-I
r i i i 1l 2 3 4 202. Has any expert or technician conducted any 5 tests examinations, or inspections in connection with this 6 proceeding? ,
. It your answer to this interroga-7 tory is in the affirmative, please identify each such 8 person. ,
9 !' 10 ; I I e.. w :- 11 l z 52
- g ;j 12
$5 IE:
13 d 14 203. If your answer to the preceding interrogatory
% 8!
e - 15 is in the affirmative, did such expert or technician make a 16 I record or report of his findings? . I 17 18 19 20 i 21 22 204. If your answer to the preceding interrogatory 23 is in the affirmative, please state: l 24 (a) The date each such report was submitted; 25 l 26 ! l , 1 l i -120-l,
I I e i 1 l i l 10 - i t 2 1 3 1 4 (b) The name or other identification, l 5 address and telephone number of the person to whom each such 6 report was submitted; . l 7
' I 8
l 9I 4 10 m.. 11 ! w :- 1 E *E j
- g 12 (c) The name, last known address and tele-
! * !?
l*a jj:= 13 phone number of each person who has present custody of each
$ !j 14 such report; e -
15 16 17
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1 l 18 19 20 (d) The subject: matter and finding of each 21 such report. 22 i 23 j i ( 24 25 l l 26
-121-
. i i
I 1 205. Is any expert or technician to be compensated 1 2 for his work and efforts in connection with this action? 3 . 4 5 6 7 8 9 206. If your answer to the preceding interrogatory 10 is in the affirmative, state as to each such expert or tech-
., 11 nician the amount he is to be paid and on what basis his w -
E 'S
- i*; 12 compensation is to be determined.
!B 's !
- Ei 13 S U !!
58! e - 14 15 16 17 18 207. For each expert you may call to testify at l 19 the hearing on this proceeding, specify and state with par-20 ticularity by expert, the subject matter on which he is ex-21 pected to testify. 22 , l 23 24 - 25 i 26
-122-
T n 1 208. State, by expert, the substance of the facts 2 and opinions to which each such expert is expected to tes-3 tify. 4 5 6 t 7 8 9 209. Set forth, by expert, a summary of the 10 grounds for each opinion which may be given by each such a.. 11 expert at the hearing on this proceeding. l II ! 13
}3 2 12 l
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13 3 $ !! 58! e - 14 15
. 16 17 210. List specifically and in detail each and 18 every exhibit you propose to utilize at the hearing in this 19 proceeding or which you may utilize at the hearing on this 20 proceeding.
21 i 22 23 24 25 26 l l
-123-l
I . . l r l l 1 211. With reference to the exhibits listed in 2l answer to the preceding interrogatory, state the source of 3 the exhibit, the nature of the exhibit, (i.e., whether said 4 exhibit is documentary, a picture or other); who prepared 5 each exhibit; and the date upon which each exhibit was prepared. 6 7 8 l 9! , 10 s ..- 11 LATED this lb day of March, 1983. ' w
.3 $! 12 SNELL 6 WILMER ii ?! !* *j 5I si 13 By /
5 a h! 14 Arthdr C. ehr
/)
15 Warren E. latt U Charles Bischoff 16 Vaughn Crawford 3100 Valley Center 17 Phoenix, Arizona 85073 Attorneys for Joint Applicants 18 19 20 21 22 23 24 -124-25 26 l
f s s UCf.MEIEI o 1 Arthur C. Gehr '83 MAR 18 A10 :43 Warren E. Platt 2 Charles A. Bischoff , Vaughn A. Crawford .
,d a SEl$ .L 3 SNELL & WILMER usWCH 3100 Valley Center 4 Phoenix, Arizona 85073 (602) 257-7211 5
Attorneys for JOINT APPLICANTS
, 6 7 UNITED STATES OF AMERICA 8 NUCLEAR REGULATORY COMMISSION l 9 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 10 In the Matter of ) Docket Hos. STN 50-528 11 ARIZONA PUBLIC SERVICE ) STN 50-529 a
yl,l COMPANY, et al., ) STN 50-530 12 )
- e."j
{sj 1 (Palo Verde Nuclear Generating ) a :: 13 Station, Units 1, 2 and 3) ) 5j !! ) m 8! 14 CERTIFICATE OF SERVICE I hereby certify that copies of Joint Applicants' 6 First Set of Non-Uniform Interrogatories to West Valley 7 Agricultural Protection Council, Inc. have been served upon 8 the following listed persons by deposit in the United States g ma , properly addressed and with postage prepaid, this 20 21
/ day of March, 1983.
1 I SNELL & WI - l 23 e By A(I , 24 ! %rthu' C. Gehr 9 Warr n E. Pla 25 :< Cha les A. B' choff Va ghn A. Cr ford 26 Attorneys for Joint Applicants l g
4 1 Docketing and Service Section U.S. Nuclear Regulatory Commission 2 Washington D.C. 20555 3 Chairman, Maricopa County Board of Supervisors 111 S. 3rd Avenue 4 Phoenix, Arizona 85004 5 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission 6 Washington, D.C. 20555 7 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission 8 Washington, D.C. 20555 9 Robert M. Lazo, Esq. i 1 Chairman, Atomic Safety and Licensing
,0 1 l Ecard U.S. Nuclear Regulatory Ccmmission
; Washington, D.C. 20555 11 a
w .: s Kenneth Berlin, Esq. I : Dr. Richard F. Cole 12 5 " {s; Atomic Safety and Licer. sing Board Suite 550 2550 M, Street, N.W. {5a[ ;;
!! 13 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20037 'a ::
[! 14 Dr. Dixon Callihan Union Carbide Corporation 15 P.O. Box Y Oak Ridge, TN 37830 Lee Scott Dewey, Esq. 17 Office of the Executive Legal Director U.S. Nuclear Regulatory Commission 18 Washington, D.C. 20555 19 Edwin J. Reis, Esq. Office of the Executive Legal Director 20 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Rand L. Greenfield, Esq. 22 Assistant Attorney General P.O. Drawer 1508 23 Santa Fe, NM 87504 24 Lynne Bernabei, Esq. l I Government Accountability Project 25 Institute for Policy Studies 1901 Q St., N.W. 26 Washington, D.C. 20009}}