ML20074A747
| ML20074A747 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 05/13/1983 |
| From: | Berlin K WEST VALLEY AGRICULTURAL PROTECTION COUNCIL, INC. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8305160034 | |
| Download: ML20074A747 (5) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSI BEFORE THE ATOMIC SAFETY AND LICENSING BOARD \\'/s
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In the Matter of
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s ARIZONA PUBLIC SERVICE COMPANY )
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$Nos.'StN 50 529 (Palo Verde Nuclear Generating )
Wc 507 30 Station, Units 2 and 3)
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WEST VALLEY AGRICULTURAL PROTECTION COUNCIL, INC. ' S MOTION FOR MODIFICATION OF DISCOVERY SCHEDULE On March 23, 1983, the Licensing Board set a schedule for discovery in this proceeding in accordance with the Stipulation on discovery submitted on March 9,
- 1983, by the West Valley Agricultural Protection Council, Inc.
(" West Valley"), the Arizona Public Service Company, et al.
(" Joint Applicants"),
and the Nuclear Regulatory Conenission Staff.
As set out more tully in the attached Memorandum, the timing of discovery in this proceeding is keyed largely to the I
completion and distribution of the study recently begun by the j
University of Arizona on Joint Applicants' behalf to examine the effects of salt deposition on crops grown in the vicinity of the i
Palo Verde Nuclear Generating Station ("PVNGS").
Since the Crop j
Study proposal, which was not provided to West Valley until after entry of the Board's March 23, 1983 Memorandum and Order, states that the expected completion date (mid December 1983) is at least six weeks later than the date identified in the stipulation (on or about November 1, 1983), West Valley requests that the Board modify the discovery schedule to take the delay into account.*_/
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A copy of the relevant page of the Crop ' Study is attached as i
Exhibit 1.
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d 8305160034 830513 PDR ADDCK 05000529 0
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2 First, West Valley requests that depositions in this proceeding, now scheduled to begin on July 18, 1983, be rescheduled to begin six weeks later, on August 29, 1983.
The deposition l
l schedule would therefore provide as follows:
i a)
August 29 through September 2 l
Depositions noticed by West valley
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b)
September 5 through September 9 l
Depositions noticed by Joint Applicants l
4 l
1 c)
September 19 through September 23 j
Depositions noticed by West Valley l
1 4
i d)
September 26 through September 30 I
j Depositions noticed by Joint Applicants i
j e)
. October 10 through October 14 Depositions noticed by West Valley
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f)
October 17 through October 21 i
Depositions noticed by Joint Applicants g)
October 31 through November 4 i
j Depositions noticed by West Valley i
h)
November 7 through November 11 l
Depositions noticed by Joint Applicants i)
November 21 through November 25 Depositions noticed by West Valley l
j)
November 28 through December 2 l
Depositions noticed by Joint Applicants k)
December 12 through December 16 Depositions noticed by West Valley i
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3 Second, West Valley requests rescheduling of discovery concerning the crop Study, currently set to begin on November 7, l
1983, and to conclude on January 6, 1984, to begin on 'or about I
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December 20, 1983, or upon production of the Crop Study and related documants, whichever is later, and to conclude three months after j
that time.
In addition to the two months contemplated under the 1
l present Order for discovery relating to the Crop Study, West Valley i
i will require an additional month for its attorney and experts to I
l analyze the large quantities of data that the study is expected'to f
1 produce.
1 i
As contemplated under the present Order, filing of pre-t l
trial testimony and exhibits will occur nine days after completion 1
i of discovery and the evidentiary hearing will begin one month l
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i later.
f Respectfully submitted i
3 i
j Dated:
Kenneth Berlin Attorney for Intervenor West Valley Agricultural Protection i
Council, Inc.
2550 M Street, N.W.
Washington, D. C.
20037 t
(202) 429-8501 i
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EXHIBIT 1 l
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.able 2.
T1.~.e-Task-Report Schedule i
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Activny M
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l Group' Meeting with I egal l
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0 Staff and Consultants Task I - Determination of salt j
accumulation thresnolcs l
l on c cu production i
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Prepare peenhouse and i
field plots I
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1 Assemcle pets, mix, anc salt enameer 3
i Plant cotton, alfalf a
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l and carley l
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Salt treatment
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Plant evaluations l
f Analyze data I
Pr par report' g
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I Tasx II - Review of l
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Propam ?regam p
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O Meetings or Montnly Repor s Final Reoert i
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