ML19270G949

Forwards Response to 790407 & 10 Interrogatories & Document Requests from Intervenor G Arnold.Objects to Some Questions & Requests That Are Irrelevant to Pumphouse Settlement.Certificate of Svc Encl

ML19270G949
Person / Time
Site:	North Anna
Issue date:	05/04/1979
From:	Christman J HUNTON & WILLIAMS
To:
Shared Package
ML19270G950	List: ML19270G949 ML19270G951
References
NUDOCS 7906220219
Download: ML19270G949 (5)

Text

May 4, 1979

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.YI' UNITED STATES OF AMERICA FUCLEAR REGULATORY COMMISSION f#

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BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD g',,!~

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In the Matter of

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VIRGINIA ELECTRIC AND POWER COMPANY

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Doc. Nos. 50-338 OL

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50-339 OL (North Anna Power Station,

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(Pump House Settlement Units 1 and 2)

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and Turbine Missiles)

VEPCO'S ANSWER TO INTERVENOR ARNOLD'S INTERROGATORIES ON PUMP HOUSE SETTLEMENT Counsel for intervenor Geraldine Arnold sent 17 inter-rogatories and requests for documents to Vepco on April 7, 1979, and one supplemental interrogatory on April 10, 1979.

Vepco arranged with Mrs. Arnold's counsel to respond by May 4, 1979.

Vepcs's responses are attached hereto.

Vepco's counsel and Mrs. Arnold's counsel have agreed that the responses need not be under oath.

Vepco asserts, however, that it believes the responses to be true and correct.

As noted in the responses, Vepco objects to Inter-rogatories 1 and 7 and Supplemental Interrogatory 1 on the ground that they are irrelevant to service water pump house settlement and therefore irrelevant to this proceeding.

For the same reason Vepco objects to Requests for Documents 13 and 14 insofar as the notes and memoranda requested discuss matters 2349 00l

'79 6220 %

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other than pump house settlement and the horizontal drain system.

Notes on those other matters have been deleted from the documents produced in response to Requests 13 and 14.

As for the continuing obligation of Vepco to update its responses, Vepco will comply with 10 CFR S 2.740(e):

(e)

Suoplementation of resconses.

A party who has responded to a request for discovery with a response that was complete when made is under no duty to supplement his response to include information there-after acquired, except as follows:

(1)

A party is under a duty seasonably to supple-ment his response with respect to any question directly addressed to (i) the identity and location of persons having knowledge of discoverable matters, and (ii) the identity of each person expected to be called as an expert witness at the hearing, the subject matter on which he is expected to testify, and the substance of his testimony.

(2)

A party is under a duty seasonably to amend a prior response if he obtains information upon the basis of which (i) he knows that the response was incorrect when made, or (ii) he knows that the response though correct when made is no longer true and the circum-stances are such that a failure to amend the response is in substance a knowing concealment.

(3)

A duty to supplement responses may be imposed by order of the presiding officer or agreement of the parties.

VIRGINIA ELECTRIC AND POWER COMPANY

/s/

James N.

Christman James N.

Christman 2349 002 -

1

J Of Counsel Michael W. Maupin James N.

Christman James M. Rinaca Hunton & Williams P.

O. Box 1535 Richmond, Virginia 23212 DATED:

May 4, 1979 2349 003

, - -..