ML20076L196

Motion to Compel Responses to Second Set of Interrogatories 2-4,7 & 9.Legitimacy of Joint Applicant Objection May Be Resolved by Identifying Each Document Specifically

ML20076L196
Person / Time
Site:	Palo Verde
Issue date:	07/15/1983
From:	Berlin K BERLIN, ROISMAN, KESSLER & CASHDAN, WEST VALLEY AGRICULTURAL PROTECTION COUNCIL, INC.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20076L197	List: ML20076L196 ML20076L208
References
NUDOCS 8307190076
Download: ML20076L196 (2)

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l'm eeg Lac UNITED STATES OF AMERICA 18 Jg NUCLEAR REGULATORY COMMISSION \ NY arnese, (D./

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ,

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In.the Matter of )

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

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(Palo Verde Nuclear Generating )

Station, Units 2 and 3) )

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WEST VALLEY AGRICULTURAL PROTECTION COUNCIL, INC.'S MOTION TO COMPEL RESPONSES TO INTERROGATORIES West Valley Agricultural Protection Council, Inc. (West

. Valley) seeks an. order from the Board, pursuant to 10 C.F.R.

E'2.740(f), compelling Joint Applicants to answer certain inter-rogatories and to identify documents they are withholding on the grounds of privilege. Specifically, West Valley seeks an order requiring Joint Applicants to identify documents requested in West Valley's Second Set of Interrogatories Nos. 2, 3, 4, 7 and 9 and withheld on the grounds of privilege. In addition, West Valley seeks to compel Joint Applicants to respond to Interrogatory-No. 8, a critical interrogatory relating to the

" FOG" model which Joint Applicant utilized to describe salt drift deposition patterns. It is West Valley's positiog as set forth

, in;the. attached memorandum, that such discovery is warranted-

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1. Joint Applicants' privilege objection is overbroad.

To resolve the legitimacy of their objection, they must first identify each document by author and date and briefly outline itN subject matter.

2. Interrogatory No. 8 seeks clearly relevant documents and contrary to Joint Applicants' assertion it is narrowly drawn.

West Valley therefore respectfully requests that the Board order the relief described above.

Respectfully submitted,

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Dated: VA / b , / id Kenneth Berlin s -

Attorney for Intervenor West Valley Agricultural protection Council, Inc.

2550 M Street, N.W.

Suite 500-Washington, D.C. 20037 (202) 429-8502 l

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