ML19225C837
| ML19225C837 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 06/20/1979 |
| From: | Rinaca J HUNTON & WILLIAMS |
| To: | |
| Shared Package | |
| ML19225C832 | List: |
| References | |
| NUDOCS 7908020570 | |
| Download: ML19225C837 (6) | |
Text
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June 20, 1979 UNITED STATES OF AMERICA (A
N HUCLEAR REGULATORY COE4ISSION EAQo 73 g:
JUygg 19733,~~
kn%
BEFORE THE ATOMIC SAFET' AND LICENSING 3]AR k
'""~
b os In the Matter of VIRGIhTA ELECTRIC AND POWER COMPANY) Doc. Nos.50-338SP
)50-339SP
)
(North Anna Power Station,
) (Proposed Amendment Units 1 and 2)
)
to Operating License NPF-4)
'IEPCO' S OBJECTIONS TO INTERROGATORIES POSED BY POTOMAC ALLIANCE AND CITIZENS' ENERGY FORUM. INC.
The intervenors in this proceeding, the Potomac Alliance and the Citizens ' Energy Forum, Inc. (CEF), have both posed interrogatorier to Vepco.
Bc.h intervenore served these interrogatories by placing them in the mail on June 1, 1979.
Vepco objects to certain of these interrogatcries, and the bases for those objections are stated belcw.
Vecco 's Obj ections to Potcmac Alliance Intarro2ateries Format for Answere Pages 1 and 2 cf the Potecac Alliance's 431 546 790802067'D
, interrogatories specify a format for Vepco's response.
Vepco obj ects to the request contained in part C of that format, which asks Vepco to "[i] der r.ify ali documents and studies, and the particular parts thereof, known to exist but not relied upon, which pertain to the subj ect matter of the question.
In lieu thereof, a copy of each document and study may be attached to the answer,"
Vepco objects to this request on the grounds that it is overly broad and calls for the identification or production of documents that are not relevar, t to the contested issues in this proceeding and that are not likely to lead to the discovery of admissible evidence.
Cc=pliance with this request would also i=-
pose an undue burden on Vepco.
If the Potomac Alliance wishes to narrow this request, Vepco will atte=pt to make specific documents or studies that are relevant to the issues of this proceeding available for inspection.
Questien 21 This question called for Vepco to describe all infernation in its possession, including personal kncwledge, concerning the adverse affects upon (1) fuel rod cladding, (2) other fuel asse='ly caterials, (3) fuel o
storage racks and (4) the pcol liner from exposure to an environment similar to that in the North Anna Units 1 and 2 f
3 f D)
. spent fuel pool.
This question included a request for Vepco to discuss the occurrence of such effects at all nuclear reactors.
Vepco objects to this question because is overly broad the preparation of a responsive
.c answer would place an undue burden upon Vepco.
This in-terrogatory is so broadly worded that the " effects" discussed therein are not necessarily limited to the contested issues in this proceeding and may therefore not be relevant.
To be responsive, Vepco,rcaid have to poll its employees to ascertain their personal knowledge and conduct a literature search of all of the journals and articles in its possession.
There are numerous j ournal articles that discuss the corrosion of circonium alloys and stainless steel and the experience the nuclear in-dustry has had with these metals.
It apre rs that the Potccac Alliance is asking Vepco to d<
cne research necessary to support the intervenor's own contentions.
This in-formation is j ust as readily available to the Potomac Alliance as it is to Vepco-Questien 45 The Potonac Alliance asked Vepco to identify all correspondence between Vepco and NRC concerning the pro-posec =cdifications to the spent fuel pool.
Vepcc objects
$]'l 34Q
. to this request on the grounds that it is overly broad and calls for the identification or production of dccuments that are not relevant to this proceeding and that are not likely to lead to the discovery of ad-missible evidence.
Identification of these documents would place an unnecessary burden on Vepco, particularly when all the documents covered by the interrogatory are in the NRC's Public Docenent Room and available for inspection by the intervenor.
Question 45 In'this question Potomac Alliance asked Vepco to "[i]dentify all memoranda and written senmaries or transcripts of other communications between Vepco em-playees concerning the proposed modification of the SFP."
Vepco obj ects to this question on the grounds that it is overly broad and calls for the identification or pro-duction of documents that are not relevant to the contested issues in this proceeding or likely to lead to the dis-covery of admissible evidence.
The request that Vepco identify all such documents also imposes an undue burden on Vepco.
Vepco is willing to make any documents that are responsive to this question and relevant to the con-tested issues available for inspecticn at Vepco's of ices.
43' 345?
.. Question 46 The Potomac Alliance also asked Vepco to "[i]-
dentify all recoranda and written summaries or transcripts of other communications between Vepco employees and others,
including legal cou;.sel, concerning the proposed modifi-cation of the SFP."
Again Vepco objects for the reasons stated in its objection to Question 45.
In addition, to the extent the intervecor seeks evidence of cocmunications between Vepco and its legal counse], these materials are protected frca discovery by the attorney-client privilege and by the " work product" doctrine.
Vepco objects on these grounds also.
Question 47 The Potomac Alliance asked Vepco to identify or produce "all correspondence between Vepco and the United States Department of Energy. "
Vepco objects to this question for the reasons stated in its obj ection to Questien 45.
Vecco's Cbjection to CEF Inter:cgatory Question 5-1 CEF asked Vepco co provide detailed drawings of
.ne new spent fuel pool racks.
The drawings requested by this interrogatory are considered proprietary to NUS
$]'1 39
- ~ Corporation, the rack supplier.
Vepco obj ects to their production on this basis.
Vepco will, however, make these drawings available for inspection by CEF if re-quested to do so.
Respectfully submitted, VIRGINIA ELECTRIC AND POWER COMPMTY is/ James M.
Rinaca James M.
Rinaca Counsel for Virginia Electric and Power Company Of Counsel:
Michael W.
Maupin, Esquire James N.
Ch.
- nan, Esquire James M.
Rin ca, Esqaire Hunton & Williams 707 E. Main Street P.
O.
3cx 15 35 Richmoud, Virginia 23212 DATED:
June 20, 1979 431 3]
tS