ML20073R263
| ML20073R263 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/27/1983 |
| From: | Crawford V JOINT APPLICANTS - PALO VERDE, SNELL & WILMER |
| To: | WEST VALLEY AGRICULTURAL PROTECTION COUNCIL, INC. |
| References | |
| NUDOCS 8305030594 | |
| Download: ML20073R263 (56) | |
Text
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'4 DELsq coru, NDc5 1 Arthur C. Gehr U[
Warren E. Platt 2 Charles A. Bischoff 3
Vaughn A. Crawford 33 yy 2 TU1:22 SNELL & WILMER 3100 Valley Bank Center 4 Phoenix, Arizona 85073 (602) 257-7211 u- g;Glj Attorneys for JOIliT APPLICANTS 7 UNITED STATES OF AMERICA 8 NUCLEAR REGULATORY COMMISSION 9 BEFORE THE ATOMIC SAFETY AND LICENSING EOARD 10 In the Matter of ) DOCKET NOS. STN 50-529 ARIZONA PUBLIC SERVICE ) STN 50-530 m .. 11 COMPANY, et al., )
I is )
- s 3j 12 (Palo Verde Nuclear ) JOINT APPLICANTS' SECOND EE !? Generating Station, Units 1, ) SET OF NON-UNIFORM j*
"s jj 13 2 and 3) ) INTERROGATORIES TO WEST VALLEY AGRICULTURAL
! )
$ PROTECTION COUNCIL, INC.
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14 )
15 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:
21 22 INSTRUCTIONS FOR USE j 23 A. All information is to be divulged which is in the pos-session of the individual or corporate party, his at-24 torneys, investigators, agents, employees, or other representatives of the named party and his attorney.
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25 B. Where an individual interrogatory calls for an answer 26 which involves more than one part, each part of the fr) 0305030594 830427 PDR ADOCK 05000529 O PDR L_
I 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
"" "9' 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.
11 F. These interrogatories are intended as continuing inter-la :!
- "j! 12 rogatories, requiring you to answer by supplemental answer, setting forth any information within the scope ilts ;;!jI 13 of the interrogar.ories as may be acquired by you, your agents, attorneys, or representatives following your
'" original answers.
1 8( 14 o -
15 DEFINITIONS 16 The following definitions are applicable to all 17 Interrogatories contained herein:
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 interrogatory in which such term appears.
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 interrogatory in which any conjunction or disjunction 25 appears.
26 , , , , ,
I 1
D. " Person" means an individual, firm, corporation, as-s iation, organization or other entity.
2 l 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.
5 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 10 of data or statistics, computer input or output ma-terial (including but not limited to any computer a
g 11 program, printout or plotter output), computer storage zg device (including but not limited to any magnetic tape, jdg5y; 8
12 paper tape, magnetic disk, magnetic card, punch card, mass storage device, diskette, floppy disk, core 13 g $ j!
3 . storage or other computer memory), contract, corre-spondence (sent or received), data sheet, diagram,
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= :! 14 diary, diploma, drawing, evaluation, examination or examination results, film (whether or not developed),
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),
19 microfilm, notebook, note or notes or summarization of 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, class, seminar, conference, rally, convention, lecture, 22 session or formal or informal discussion), outline, painting, paper, patent or patent application, photo-23 graph or photographic negative (including but not limited to any x-ray, slide, movie or videotape),
24 plans, planning materials, preliminary drawing, prom-issory note or other evidence of indebtedness, position 25 paper, prospectus, publication (including but not limted to any book, booklet, circular, magazine, 26 newspaper, pamphlet or periodical), purchase order, l
1 questionnaire, raw or uncompiled data or statistics, 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-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 nsidered as a separate document.
10 G. "Identi fy" as used herein with respect to a document
- - 11 shall be read to require a statement of all of the fol-a! lowing information relative to such document: (1)
{ 8d j!j 12 title; (2) nature and subject matter; (3) date; (4) i I author; (5) addressee; (6) file number or other identi-3 j j;" 13 fying mark or code; (7) location by room, building, address, city and state; (8) identification of custo-
' dl8:! 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 II . " Identify" as used herein with respect to any indivi-dual shall be read to require a statement of all of the 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.
22 I. " Identify" as used herein with respect to any entity other than an individual shall be read to ::equire 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.
J. " Identify" as used herein with respect to any conversa-26 tion (including any telephone communication) or meeting
4 1 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 5
substance of what was discussed or what actions were taken.
6 g, uPetition" 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.
1 10 M. "PVNGS" as used herein shall refer to the Palo Verde Nuclear Generating Station.
y d }!; 12 N. " Joint Applicants" as used herein shall refer to Arizona Public Service Company ("APS"), Salt River i
8: Project Agricultural Improvement and Power District, El g$jl' 13 l Paso Electric Company, Southern California Edison
' d Ij Company, Public Service Company of New Mexico, and g !! 14 Southern California Public Power Authority.
15 1. State whether each of the following indi-l i
16 viduals is a current director of West Valley:
i 17 (a) Dan Saylor 18 19 20 21 22 23 (b) Rick Ladra 24 25 26 li
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2 3
(c) Phil Ladra 4
5 6
7 8
9 (d) Paul Perry 10 m.. 11
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- a. Il 15 (e) Harry W. Porterfield 16 17 18 19 20 21 Gary Accomazzo (f) 22 23 24 25 26 l 1
1 (g) Bob Sheppard 2
3 4
5 6
7 8
(h) Jim Gladden 9
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14 15 l (i) Delbert Beyer 16 6
l 17 18 19 20 1
21 (j) Don Narramore 22 23 24 25 26 1
(k) Bill Odom 2
3 4
5 6
7 8
(1) F. Ronald Rayner 9
10 a .. 11
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14 15 (m) Stephen P. Pavich 16 'l l
17 18 19 20 21 (n) Jackie Meck l
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(o) W. T. Gladden 2
3 4
5 6
7 2. State the precise legal description of the 8 area which you believe will be affected by the Salt drift 9 which you claim will result from the Operation of PVNGS.
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15 3. In your Petition, you allege that West Valley 16 has 56 farmer members. Identify the 56 members who comprise 17 West Valley and state, for each, his or her address.
18 19 T
21 ,
22 For each member name'd in response to the pre-
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23 4.
24 ceding interrogatory, state the precise legal description of 25 the land owned and/or leased and/or operated by such member, i 26 using the UTM or Arizona Coordinate System to describe such l
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property; also state the total number of acres owned and/or 2
operated by each such member.
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4 1
1 5
6 I 7 I
8 9 5. For each parcel of property described in 10 answer to the preceding interrogatory, state whether you 8
11 claim that such parcel, or any part thereof, will be af-
, a it 12 l
- j jf 'fected or may potentia 11.y be affected by salt drift deposi-13 tion from the PVNGS.
!*ff. If you claim that only a portion of 14 any percel listed herein will or may be affected, describe 15 specifically the part thereof which you' claim will or may be 16 a f fected.
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19 3
20 l 21 i
22 23 6. For each parcel of property listed in answer 24 to the preceding interrogatory, state the amount of drift r .
25 per acre which you clain; will be deposited thereon on a 26 daily, monthly and annual basis.
I
. I 2
3 4
5 6
- 7. Describe the precise method by which the 7
deposition figures given in response to the preceding inter-8 Include in your answer all facts, rogatory were calculated.
9 assumptions, and calculations upon which such figures are 10 based.
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14 15 16 8. Your answer to Interrogatory No. 7, Joint 17 Applicants' First Set of Non-Uniform Interrogatories, states 18 that the " facts on which they [ Professors Davis and Golay) 19 will rely are set forth in the answers to these interroga-20 tories and in the Davis and Golay reports." Identify the 21 specific facts upon which Drs. Davis and Golay will rely, 22 or, alternatively, the precise answer (s) to Joint Appli-23 cants' First Set of Non-Uniform Interrogatories in which 24 such facts are contained. Also specify the exact pages of 25 the Davis and Golay reports which purportedly contain such 26 facts.
l
1 2
3 4
5 6 9. For each parcel of land described in answer 7 to Interrogatory No. 4, state whether the farmer member of 8 West Valley owns such land, leases it, or farms it under any 9 other form of ownership or control. If the farmer member 10 leases the land described, state the name of the owner /
a.. 11 lessor; if the farmer member does not own or lease such W
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- g !! 12 property, describe the relationship pursuant to which the EE !!
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's jj 13 farmer member operates the land in question.
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v 14 15 16 17 18 19 10. Identify each person having knowledge, or 20 claiming to have knowledge, of the facts set forth in your 21 answer to the preceding interrogatory. As to each such 22 person, state the specific facts concerning which they have 23 knowledge or claim to have knowledge.
24 25 26 i
i 1
2 3
- 11. 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. 9.
6 7
8 9
10 a
- 11 12. For each parcel of land described in response z a
- 12 to Interrogatory No. 4, indicate for each of the last ten j ja ((
13 years, the percentage of such acreage which was actually 14
{ [} planted in crops and further state for each of the last ten 15 years:
16 (a) The crop (s) which were planted on such 17 acreage, or any part thereof, and the number of acres which 18 were planted in each such crop.
19 20 21 22 23 24 25 (b) For each crop identified in response to 26 subpart (a) of this interrogatory, state the approximate I
date upon which each crop was planted, the approximate leaf-2 out date of such crop and the harvest date thereof.
3 4
5 6
7 8
(c) Define the yield (in pounds, bales, 9 bushels, etc. per acre) of each crop planted on each of the 10 parcels of property described in response to Interrogatory a ;. 11 No . 4.
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14
.I El 15 16 17 (d) As a continuation of the preceding sub-18 parts of this interrogatory, state the market price per 19 harvest unit of the crops identified in subpart (a) above, 20 for each parcel of land listed in response to Interrogatory 21 No . 4.
22 23 24 25 26
1 (e) With respect to the information provided 2
in subpart (d) of this interrogatory, state the indiviudal 3
or entity to whom the crop (s) or any part thereof was sold, 4
the date upon which the crop was sold and the means by which 5
the sale price was established.
6 7
8 9
10 a . 11 555 *
- s 12 l 13. Identify each person having knowledge, or l*,{ 13 claiming to have knowledge, of the facts set forth in your a ::
l !i 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 21 22 14. 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. 12.
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2 3
4 15. For each parcel of land described in response 5 to Interrogatory No. 4, indicate for each of the last three 6 years, the percentage of such acreage which was actually 7 planted in crops and further state for each of the last 8 three years:
9 (a) The crop (s) which were planted on such 10 acreage, or any part thereof, and the number of acres which a
p 11 were planted in each such crop.
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!! 14 15 16 17 (b) For each crop identified in response to 18 subpart (a) of this interrogatory, state the approximate 19 date upon which each crop was planted, the approximate leaf-20 out date of such crop and the harvest date thereof.
21 22 23 24 25 26
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. l 1
(c) Define the yield (in pounds, bales, 2
bushels, etc. per acre) of each crop planted on each of the 3 parcels of property described in response to Interrogatory 4
No. 4.
5 6
7 8
9 10 (d) As a continuation of the preceding sub-11 parts of this interrogatory, state the market price per s 's 12 harvest unit of the crops identified in subpart (a) above,
-td;*g lj 13 for each parcel of land listed in response to Interrogatory
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15 16 17 18 19 20 (e) With respect to the information provided 21 in subpart (d) of this interrogatory, state the indiviudal 22 or entity to whom the crop (s) or any part thereof was sold, 23 the date upon which the crop was sold and the means by which 24 the sale price was established.
25 26 1
2 3
4 2
5 16. 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.
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14 15 17. Identify each and every document which refers 16 I or relates in any way to the facts set forth in your answer 17 to Interrogatory No. 15.
18 19 20 21 22 23 18. For each parcel of property listed in re-24 sponse to Interrogatory No. 4, and for each crop which you 25 claim was grown thereon during the past ten years, identify 26 the irrigation method used for each such crop and the fre-l
I 1
quency with which such crop was irrigated. Your answer should include, but not be limited to, the total quantity of 3
water applied per acre per day, per month, and per growing 4
season, and the source of the irrigation water.
5 6
7 8
9 10 19. Identify each person having knowledge, or l
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11 claiming to have knowledge, of the facts set forth in your ij s ::
5 nd ij 12 answer to the preceding interrogatory. As to each such e
l[a ::{ 13 person, state the specific facts concerning which they have f !! 14 knowledge or claim to have knowledge.
15 16 ';
17 18 19 20 20. 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. 18.
23 24 25 26 i
1 2 21. For each parcel of property listed in response 3 to Interrogatory No. 4, and for each crop which you claim 4 was grown thereon during the past three years, identify the 5 irrigation method used for each such crop and the frequency 6 with which such crop was irrigated. Your answer should 7 include, but not be limited to, the total quantity of water 8 applied per acre per day, per month, and per growing season, 9 and the source of the irrigation water.
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15 22. 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.
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.
- 1 1
2 3
4 5
6
- 24. Describe the water quality (i.e., the content in parts per million (ppm)), fc the irrigation water refer-O red to in Interrogatory No. 18, of any minerals, nutrients, 9
or other solids, including -- but not limited to -- salt; 10 further state the source of your information regarding the
- ;: 11 water quality described herein.
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15 16 17 25. Identify each person having knowledge, or 18 claiming to have knowledge, of the facts set forth in your 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 26 1
- 26. 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. 24.
4 5
6 7
8 9 27. For each crop planted on each parcel of prop-10 erty described in response to Interrogatory No. 4, and for 8
g: 11 each of the last ten years, identify any and all crop and/or 1:*
- 12 soil treatments applied to the crop at any time during its l8s : !{
13 growing season. Your answer should include, but not be 14
{ !! limited to, a description of all herbicides, pesticides, 15 fertilizers, soil leaching practices, etc., administered to 16 the crop and/or to the soil, and a description of the phase 17 of the crop's life at which such practices were adminis-18 tered. Further include in your answer, the purpose of such 19 practice, the method of administration, the frequency 20 thereof, and the approximate cost of each administration.
21 22 23 24 25 26
1
- 28. 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 29. Identify each and every document which refers l ;:
11 or relates in any way to the facts set forth in your answer s:
g d gj 12 to Interrogatory No. 27.
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15 16 17 18 30. Your Petition alleges that West Valley mem-19 bers produce ninety six million dollar's ($96,000,000) worth 20 of agricultural products per year. Describe in precise 21 detail the method by which you arrived at the $96,000,000 22 figure and the year or growing season (s) to which such 23 figure applies. Also state the alleged value of crops grown 24 by each farmer member for each of the last ten years, or by 25 his predecessor if the farmer member has not owned, leased 26 or operated his land for the last ten years.
1 2
3 4
5 6 31. 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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14 15 16 32. 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. 30.
19 20 21 22 23 24 33. Your Petition (paragraph 1, pg. 2) alleges 25 that all West Valley members are located "within the area 26 likely to be affected" by salt deposition. Give the legal I
description, the owner of each parcel thereof, and the total 2
acreage included, in your definition or calculation of the 3
area which you claim will be affected.
4 5
6 7
8 9 34. In response to Interrogatory No. 30, Joint 10 Applicants' First Set of Non-Uniform Interrogatories, you 8 -
11 claim that the " statement which is made concerning a :**
-a 12 isokinetic sampling systems is based upon Professor Golay's
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13 experience in conducting a comparative assessment of drift
{ 8! 14 measurement methods in which various devices were tested in 15 a spectrum of simulated environments." With specific ref-16 erence to " Professor Golay's experience," state the follow-17 ing:
18 19 20 l
21 22 23 (a) Each and every test, examination, or 2
24 study which constitutes the " experience" in connection with 25 comparative assessments of drift measurement methods.
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- 26 i
1 2
3 4
(b) Each and every document relating to or 5
generated as a result of the Golay experience.
6 7
8 9
10
- ;: 11 35. With specific reference to the " simulated a .', 8
- 12
{j*g environments" mentioned in your answer to Interrogatory No.
lj 13 30, state the following:
-uf "8y 14 (a) The specific environemtal parameters 15 which were simulated.
16 17 18 19 20 21 (b) The data surveys upon which such simu-22 lated environments were based.
23 24 25 l 26 i
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1 2
(c) The person or persons responsible for 3 conducting or preparing the environmental simulations.
4 5
6 i
7 8
9 (d) The date upon which each such simulated 10 environmental drift measurement was conducted.
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, 15 16 (e) A description of the quality assurance 17 program under which each such measurement was conducted.
18 19 20 21 22 23 36. Contention I.A.(ii) alleges that the sampling 24 methods utilized in determining the drift ratio failed to 25 recognize wind effects within the fill and drift elimination 26 system. Describe precisely the wind effects which you claim
I were not recognized and further describe the precise manner 2
in which you claim such wind effects will impact upon the 3
r drift ratio.
4 I
l 5 6
7 8
.l 9 37. Identify each person having knowledge, or 10 claiming to have knowledge, of the facts set forth in your a ge 11 answer to the preceding interrogatory. As to each such 12 sl=s f
8 s person, state the specific facts concerning which they have
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i a :
a 8i 14 15 16 17 18
, 19 38. Identify each and every document which refers 20 or relates in any way to the facts set forth in your answer 21 to Interrogatory No. 36.
22 23 24 25 26 1
4
1
- 39. Interrogatory No. 39, Joint Applicants' First 2
Set of Non-Uniform Interrogatories, asked for a description 3
of the draft losses which you claim will arise from the 4
water distribution canal and the manner in which such losses 5
will contribute to or affect the drift rates. Your answer 6
to that interrogatory states that any losses would add to 7 State the precise amount of saft you claim will the total.
8 be added.
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14 l 8! 40. 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 41. 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. 39.
1 2
3 4
5 42. Contention I.D.(ii) alleges that records from 6 the Buckeye Irrigation Company show that some water samples 7 taken from the Fhoenix sewage effluent which will be uti-8 lized at the PVNGS contain twice the salt content listed in 9 the ER and the EIS. Describe each and every " record" which 10 you are relying on to support that allegation and further
- :: 11 state:
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12 (a) The date upon which each and every j d j'.n.j
, l' *' {.
{ 13 sample referenced in such records was collected.
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15 16 17 18 19 (b) The person or persons responsible for 20 the collection of the sample.
21 22 23 l 24 25 l
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(c) The collection methods utilized to 2
obtain the samples.
3 4
5 6
7 J
8 9
- 43. Identify each person having knowledge, or 10 claiming to have knowledge, of the facts set forth in your
- . 11 answer to the preceding interrogatory. As to each such a :s 12 person, state the specific facts concerning which they have
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'a f 13 knowledge or claim to have knowledge.
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17 18 19 20 44. 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. 42.
23 24 25 26 i
1 2 46. Contention I.F.(ii) alleges that the ER un-3 realistically expects refueling intervals for each tower to 4 be one month per year when experience at most other similar 5 stations has shown that a larger value would be more realis-6 tic. Identify each and every station to which that allega-7 tion refers, the dates of refueling outages at each such 8 station and the " larger value" which you allege would be 9 more realistic for refueling intervals.
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15 46. 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.
20 21 22 23 24 47. 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. 45. l j
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1 2
3 4
5 6
- 48. Identify each and every fact upon which you 7
rely for your selection of the " larger value" referred to 8
in contention I.F.(ii).
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" (( 14 49. 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 4
24 50. 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. 48.
1 l
1 2
3 4
5
- 51. Contention III.A.(i) alleges that it is "un-6 likely" that the rain events in the PVNGS region would re-7 move salts accumulated on crop leaves. Identify each and 8
every fact, theory, premise or conclusion upon which you 9
rely to support that allegation.
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14 15 52. 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, s ta.te the specific facta concerning which they have 19 knowledge or claim to have knowledge.
20 21 22 23 24 25 53. Identify each and every document, particu-26 larly those containing the meteorological data, if any,
W 1 which refers or relates in any way to the facts set forth in
^
2 your answer to Interrogatory No. 51.
3 4
5 6
7 8
9 10 54. Dr. Davis' report at page 6, further that a .. 11 "several persons connected with the project have been con-a 's
- g ;j 12 tacted to discuss various details of the model. " With
!5 l a* :-
gj!? 13 reference to that statement, identify the following:
{ 8! 14 (a) Each person contacted.
15 16 17 18 19 20 (b) The individual who contacted each per--
21 son, if other than Dr. Davis.
22 23 24 25 26 1
1 (c) The manner in which and the place at 2
which each person was contacted.
3 4
5 6
7 8
(d) The substance of each and every conver-9 sation held with each individual listed in response to sub-10 part (a) hereof.
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15 16 (e) Whether or not any notes, memorandum or 17 other written memorializations were made regarding the con-18 versations referred to above. If your answer to sub-19 part (e) hereof is in the affirmative, identify the custo-20 dian of such reports, notes, or other memorializations.
21 22 23 24 25 26
i N ] ,
1
- 55. Your answer to Interrogatory No. 175, Joint 2
Applicants' First Set of Non-Uniform Interu,gatories, fails
~
3 Please provide Mr.
to include an address of G. Fisher.
4 Fisher's address.
5 6
7 8 g 9 s 10 56. Do you or your attorneys, have in your pos-8
- - 11 session, or know the existence of, any written or recorded a
- *
12
- {j*g statements from any of the persons (excluding West Valley lj 13 member) identified in your answer to Interrogatory No. 188, a
{
{ [:[ 14 Joint Applicant's First Set of Non Uniform Interrogatories, 15 or from any other person or entity who has any knowledge or 16 the facts and events related to the issues in this pro- '
17 ceeding? '
18 19 20 .
l 21 22 23 57. In your Answer to Interrogatory No. 5, Joint 24 Applicants' First Set of Non-Uniform Interrogatories, you 25 state that Petitioner has turned over to the NUS' Corporation 26 a computer tape of the cooling tower drift model relied upon s.,
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1 in the Davis report. With specific reference to that 2 cooling tower drift model, state the following:
3 (a) The name, or other descriptive title, by 4 which such model is referred to or known.
5 6
7 8
9 10 % {b) Describe any and all validation efforts, i
11 including calculations, undertaken or performed in connec-a p:
- a e;:j 12 tion with, or as a result of, the above-referenced model.
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t 16 17 18 (c) Describe each and every equation and/or 19 algorithm upon which the model is based, or which is uti-20 lized in the model. .
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24
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1 (d) State whether any hard copies of such 2
drift model exist, and, if so, the present custodian of each 3
such copy.
4 5
6 7
8 9
(e) Describe the quality assurance program 10 !
in connection with the development, utilization and inter-l ;- 11 pretation of the model.
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(f) Identify the originators and developers 16 !'I 17 of the model.
18 19 20 21 22 23 (g) State the basis upon which the model re-24 ferred to above, in lieu of any others, was utilized by Dr.
25 Davis in connection with his work in this case.
26 1
2 3
4 5 (h) Describe specifically the output data 6 which the above referenced model is capable of generating.
7 I
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- 23: 12 58. In your answer to Interrogatory No. 5, Joint IE i
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14 state that " petitioner's preliminary calculations of these 15 and other relevant figures are contained in its experts' 16 reports." With reference to your phrase " preliminary cal-17 culations," state the following:
18 (a) Each and every fact, theory, or assump-19 tion upon which the preliminary calculations are based, in-20 cluding all data and other specific factual input upon which 21 such calculations are based.
22 23 24 25 26
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1 (b) Identify all documents, including spe-2 cifically, notes and/or records, upon which such preliminary 3
calcualtions are based, or which were generated as a result 4
of such preliminary calcualtions.
5 6
7 8
9 10 (c) Identify each and every person involved
- - 11 in the calculation or interpreation of the " preliminary cal-a
- s j { jj 12 culations" to which you refer in answer to Interrogatory 8 13 No. 5.
a
.-hI 14 15 16 17 18 19 (d) The date upon which said preliminary 20 calculations were developed.
21 22 23 24 4
25 26
1 (e) Describe the quality assurance program 2
utilized in connection with the development, calculation, I
3 and/or interpretation of your " preliminary calculations."
4 5
6 7
8 9
- 59. If you are claiming that the PVNGS operations 10 will result in decreased yields and/or decreased marketabil-
, " ;: 11 ity of agricultural products of the West Valley members, s as 12 provide the following:
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- 13 (a) The name of each and every agronomist,
! !! 14 plant pathologist, plant physiologist, county extension 15 agent, or other individual having any expertise, or claiming 16 to have any expertise relating to that specific subject, who 17 you have contacted or who has provided you with any informa-18 tion relative to that specific subject.
19 20 21 22 23 24 25 (b) Describe each and every document in your 26 custody or control relating to that specific subject.
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1 1
2 3
4 5
6
- 60. Your answer to Interrogatory No. 42, Joint 7
Applicants' first set of Non-Uniform Interrogatories, refers 8
to " subsequent verbal reports" to Proefessor Mulchi. With 9
specific reference to those " verbal reports," state the fol-10 lowing:
$ ;: 11 l (a) The name of the person making the z:
j" 12 report, and the entity on behalf of which the report was g
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a s. l mde.
I
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l 17 18 19 (b) The date upon which each such report was 20 purportedly made.
21 22 23 24 25 26 1
I (c) The subject matter of each such report.
2 3
4 5
6 7
(d) Whether there were any other witnesses, 8
other than Professor Golay and the reporter, to such reports.
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15 (e) The identification of each and every 16 document, notation, or other memorialization relating to any 17 such reports.
18 19 20 21 22 23 61. In response to Interrogatory No. 58, Joint 24 Applicants First Set of Non-Uniform Interrogatories, you I 25 state that the fifteen downwind distances utilized in con-26 nection with.the FOG model result in droplets being released l
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1 1 "too high" above the ground. With specific reference to the 2
phrase "too high, " please state the distance (in feet or 3
meters) at which you claim the droplets are released, and 4
further state the distance (in feet or meters) at which you
! 5 claim they should be released.
j 6 7
8 9
1 10 I
- 11 62. Your answer to Interrogatory No. 69, Joint s
- :
- 17 Applicants' First Set of Non-Uniform Interrogatories, which jj j' 13 asked for an identification of each person having knowledge
's :
{ [:! 14 of the facts set forth in your answer to Interrogatory No.
15 68, merely references your answer to No. 52, which in turn 16 identifies Professor Davis. State whether Professor Davis 17 is the only individual with knowledge of the facts upon 18 which your answer to Interrogatory No. 68 is based. If your 19 answer is in the negative, please state the name, address,
- 20 current employment, and telephone number of each and every 21 other individual who has knowledge of such facts. Also, 22 state the role or responsibility of each such individual 23 with respect to the preparation, conduct, or analysis of the 24 reference studies.
25 26
1 1
2 3
4
- 63. Your answer to Interrogatory No. 75, Joint 5
Applicants' First Set of Non-Uniform Interrogatories, uses 6
the term "all Petitioner's experts." If that phrase is in-7 tended to refer to Drs. Golay, Mulchi, and Davis only, 8
please so state. If there are experts in addition to Drs.
9 Davis, Golay and Mulchi, please identify such individuals, 10 and state the particular area of expertise for each.
s . 11
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15 64. In response to Interrogatory No. 77, Joint 16 Applicants' First set of Non-Uniform Interrogatories, you 17 state, at a(5): " Salt drift from the cooling towers into 18 the water storage area will increase the salinity of the 19 tower makeup water." Specify the exact amount of salinity 20 increase which you allege will result from salt drift into 21 the water storage area.
22 23 l 24 25 26 l
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1 (a) Identify each and every fact, theory, 2
premises, calculation or conclusion upon which your answer 3
to this interrogatory in based.
4 5
6 7
8 9
(b) Identify each and every document re-10 ferring or relating to the facts set forth in response to a
- e. 11 this interrogatories.
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!? 13 hf 14 15 16 17 65. In response to Interrogatory No. 77, Joint 18 Applicants' First Set of Non-Uniform Interrogatories, you 19 state at subpart (c): " Salinity records show variability in 20 the salinity of the waste treatment water from the City."
21 Specify each and every record to which your answer refers, 22 and include a description of the data or information con-23 tained therein. Also, describe each and every calculation, 24 or assumption upon which you rely to base your conclusion l
25 that there is a variability in the salinity of the waste l
l 26 water from the City.
l l
l 1
2 3
4 5 66. Your answer to Interrogatory No. 79, Joint 6 Applicants Eirst Set of Non-Uniform Interrogatories, refers 7 to " Buckeye Irrigation Co. records." Specify each and every 8 record upon which you rely, and include a description of the 9 data or information contained therein.
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15 67. Your answer to subpart (b) of Interrogatory 16 ,
No. 79, Joint Applicants' First Set of Non-Uniform Inter-l 17 rogatories, refers to " records at the Phoenix Waste Water 18 Treatment Plant." Specify each and every record upon which 19 you rely, and include a description of the data or informa-20 tion contained therein.
21 22 23 24 25 26 l
t 1
- 71. Your answer to Interrogatory No. 89, Joint 2 Applicants' First Set of Non-Uniform Interrogatories, ref-3 erences only "the Davis report." Specify the particular 4
j facts within that report upon which you rely for the infor-5 mation contained in answer to Interogatory No. 89, or, al-6 ternatively, state the specific page(s) of the report upon 7 which you rely.
8 9
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13 69. Interrogatories No. 121, Joint Applicants' a :.
i
{ !! 14 First Set of Non-Uniform Interrogatories, asks for a defini-15 tion of the term "PVNGS region" as used in your contention 16 III.A.(i). Your answer was "the area surrounding the 17 PVNGS." Specify the specific coordinates, or the precise 18 legal description, of the area to which you are referring.
19 I
20 21 22 23 24 70. Your answer to Interrogatory No. 122, Joint 25 Applicants' First Set of Non-Uniform Interrogatories, states 26 that the amount of water, "will be ample" to wash the salts i
l
t 4
1 from the crop foliage. Describe precisely your definition, 2 or calculation, of the amount of water which will "be ample" 4
3 to wash the salts from the crops.
4 4
5 6
7 8
9 (a) Identify each and every fact, theory, 10 premise, caculation or conclusion upon whatever answer to a
- . 11 this interrgatory is based.
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!
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i 17 (b) Identify each and every document re-18 ferring or relating to the facts set forth in reponse to the 19 interrogatories.
20 21 22 23 24 25 74. In answer to Interrogatory No. 122, Joint 26 Applicants' First Set of Non-Uniform Interrogatories, you
l 1
referenced certain "research studies simulating cooling 2
tower drift" which were apparently conducted during 1977.
3 For each such study, state the following:
4 (a) Each and every fact, theory or conclu-5 sion upon which the development of the simulation was prem-6 ised.
7 8
9 10 11 m.:
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- d ;j 12 (b) All documents pertaining to the develop-
!E l ae:!!?! 13 ment of the simulation.
$ 8!
14 15 16 17 18 19 72. Your answer to interrogatory No. 122, Joint 20 Applicants' First Set of Non-Uniform Interrogatories, refers 21 to " trace" precipitation. With specific reference .to that l 22 term, describe specifically the amount of precipitation to 23 which you refer.
24 25 l 26 l
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1 2
3
- 73. In answer to Interrogatory No. 138, Joint 4
j Applicants' First Set of Non-Uniform Interrogatories, you 5
! set forth two equations, one applicable to soy beans and one 6
applicable to corn. State the source of each of those equa-7 tions.
8 9
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! 8! 74. In response to Interrogatory No. 143, Joint 15 Applicants' First Set of Non-Uniform Interrogatories, you 16 state that " salt stress studies conducted during 1973 and 17 1978 identified numerous cases in which plant symptons re-18 sembled drought distress symptoms." State the precise 19 method by which salt stress was induced in the studies to 20 which you refer. Include also a description of the studies, 21 including the individual (s) responsible for the conduct of 22 the studies, and any and all documents generated as a result l
23 of, or which refer to, such studies.
24 25 26
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1 2
3
- 75. Interrogatory No. 169, Joint Applicants' 4 First Set of Non-Uniform Interrogatories, asked for a pre-5 cise definition of your term "near the plant" as utilized in 6 Your answer failed to define that contention III.C(ii).
7 term; please define that term as used in contention 8
III.C.(ii).
9 10 a . 11
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" [! 14 76. In answer to Interrogatory No. 177, Joint 15 Applicants First Set of Non-Uniform Interrogatories, you 16 state merely "see Davis report." Please specify the precise 17 page(s) of the Davis report upon which you rely to support 18 the facts referenced in Interrogatory No. 177.
19 20 21 22 23 24 25 26 VAC/21-A I
1 DATED this ) day of April, 1983.
SNELL&[ILMR ,
3 , ,
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4 By W /
5 Arthur ,/ Gehr iI Warren . Platt Charler A. Bischoff 6 Vaughn A. Crawford 3100 Valley Center 7 Phoenix, Arizona 85073 Attorneys for Joint Applicants 8
9 10 a . 11 u :. -
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$ 8!
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14 15 16 17 18 19 20 21 22 23 24 25 26
,1
.9 a f
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE Ti!E ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
ARIZONA PUBLIC SERVICE )
COMPANY, et al. ) Docket Nos. STN 50-529
) STN 50-530 (Palo Verde Nuclear )
Generating Station, )
Units 2 and 3) )
)
CERTIFICATE OF SERVICE I hereby certify that copics of " Joint Applicants' Second Set of Interrogatories to West Valley Agricultural Protection Council, Inc." have been served upon the following listed persons by deposit in the United States mail, properly addressed and with postage prepaid, this 27th day of April, 1983.
Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Chairman, Maricopa County Board of Supervisors 111 South Third Avenue Phoenix, AZ 05004 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Robert M. Lazo, Esq.
Chairman,. Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555
6 Dr. Richard F. Cole Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Dixon Callihan Union Carbide Corporation a
P.O. Box Y Oak Ridge, TN 37830 Lee Scott Dewey, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Edwin J. Reis, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Lynne Bernabei, Esq.
Government Accountability Project Institute for Policy Studies 1901 Q Street, N.W.
Washington, D.C. 20009 Kenneth. Berlin, Esq.
Suite 550 2550 M Street, N.W.
Washington, D.C. 20037
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