ML20069K015

Request for Production of Documents

ML20069K015
Person / Time
Site:	North Anna
Issue date:	04/22/1983
From:	Coleman J BEVERIDGE, FAIRBANKS & DIAMOND, LOUISA COUNTY, VA
To:	VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
References
ISSUANCES-OLA-1, ISSUANCES-OLA-2, NUDOCS 8304260174
Download: ML20069K015 (6)

Text

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6I ' u UNITED STATES OF AMERICA c' g, NUCLEAR REGULATORY COMMISSIO ' c;dy j

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}: /Sgy 3 In the Matter of ) 'dkh

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VIRGINIA ELECTRIC AND POWER COMPANY ) ,

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(North Anna Power. Station, ) Docket Nos. 50-338/339 Units 1 and 2 ) OLA-1 and OLA-2

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(Proposed Amendments to Operating )

License to Allow Receipt and Storage )

of 500 Spent Fuel Assemblies from )

Surry Power Station, Units 1 and 2, )

and Expansion of Spent Fuel Pool )

Storage Capacity) )

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REOUEST TO APPLICANT FOR PRODUCTION OF DOCUMENTS Intervenors Louisa County and its Board of Supervisors request that Applicant Virginia Electric and Power Company

("Vepco") produce the documents herein set forth. Pursuant to the Order.of the Atomic Safety and Licensing Board said production shall be completed on or before May 16, 1983.

Each document requested herein pertains to documents in your possession or custody, or subject to your control, reflecting,

, referring or relating in any way to any allegation, fact, occur-rence, thing, or matter described.

To the extent that any documents called for herein are not produced on the groundo of privilege, list such documents by providing the following information with respect to each such document:

8304260174 830422 PDR ADOCK 05000338 0

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(1) A specification of the nature of the document (e.g.,

letter, memorandum, etc.);

e (2) The date appearing on the document, or if no date appears, the date on which such document was prepared; (3) A general description of the subject matter of the document; (4) An identification of each person who wrote, signed, dictated, or otherwise participated in the preparation of the document; i (5) The serial, reference or file number of the document, if any; (6) An identification of each person who received the docu- 4 ment or was an addressee thereof; (7) The location of the document, and the identification of each person having custedy of it;

(8) Whether the privilege being asserted is being asserted with respect to the entire document or with respect to a portion thereof; (9) With respect to each such document or, in,any case where only portions of a document are being withheld, each such portion, the~ precise nature of the privilege which you believe J-serves as the basis for refusing to produce the document.

DEFINITIONS j (A) As used herein, the words "you" or "your" or "vepco" '

l shall mean the Applicant Virginia Electric and Power Company; its subsidiaries, parents, and related, controlled, or affiliated i

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entities; their merged or acquired predecessors, .their _ successors and their possessed facilities, divisions, or subsidiaries; present and former members of their Boards of Directors, of fi-cers, agents, and employees; and all other persons acting or purporting to act on behalf of any of the foregoing entities or individuals.

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(B) The word "documeat(s)" shall mean any kind of written, printed, typed, recorded or graphic matter, however produced or reproduced, of any kind or description, whether sent, received or neither, including originals, all copies, and all drafts and both sides thereof, and including but not limited to: papers; books; handwritten notes; publications; book entries; letters; corre-spondence; telegrams; cables; telex messages; memoranda (whether formal, informal, to the file, or otherwise); notes, notations; interviews; notes of interviews; synopses of interviews; data; work papers; diaries; inter-office communications; inter-depart-mental communications; intra-office communications and intra-de-partmental communications (whether formal, informal, or other-wise); agenda; statements; summaries; opinions; indices; I analyses; questionnaires; answers to questionnaires; lists; minutes of meetings and other minutes; test reports, performance reports, and other reports; records; recording,soof telephone conversations, conferences, meetings, or other conversations; forms; studies; plans; specifications; evaluations; contracts; agreements; licenses; invoices; checks; drafts; vouchers; ledgers; journals; books or records of accounts; bills; receipts; I l

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calculations; charts; graphs; maps; surveys; drawings; sketches; diagrams; schematics; data sheets; photographs; microfilms; bids; bid materials; quotations; blueprints; statements of account; orders; purchase orders; brochures; pamphlets; manuals; warran-ties; literature; inspection reports; operation reports; main-tenance reports; schedules; computer tapes and discs; magnetic tapes; punch cards; computer printouts; data processing input and output; computer programs; computer program coding sheets; any retrievable data, whether in computer storage, carded, taped, coded, or stored electrostatically, electromagnetically or other-wise, and all transcripts thereof; all other records kept by electronic, photographic or mechanical means; all other writings; and all things similar to any of the foregoing, regardless of their author or origin, however denominated.

(C) The word "or" shall mean "and/or."

(D) Words such as " evaluation," " assessment," "considera-tion," " analysis," " review," " determination," " study," and similar words are meant to be used interchangeably and are to be l

construed broadly.

DOCUMENTS REOUESTED Rack Procurement

1. Provide copies of the Vepco procurement specifications and/or drawings for the new spent fuel storage racks.

2. Provide a copy of the Vepco purchase order and/or contract covering the design and manufacture of the new spent fuel storage racks.

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-3. Provide a copy of data, test reports, or other documents provided by the rack supplier to Vepco describing any cor-rosion . tests performed or expected to be performed for j qualification of the Boraflex for service in the proposed application.

4. Provide a copy of the rack designer and manufacturer's

quality assurance plan with respect to provisions for com-1 pliance with 10 CFR 50, Appendix B, Criteria III, VII, VIII, and XI.

5. Provide a listing of the locations and*date of manufacture and installation where Nuclear Energy Services, Inc. has furnished identical or similar racks to those being procured for the North Anna fuel storage pool.

Fuel Rack Installation

6. Provide a copy of the rack installation procedure.

If the racks are not to be installed by Vepco personnel, please provide copies of any installation contractor specification, contract, and/or procurement documents applicable to the installation.

7. Provide copies of Vepco and/or the installation contractor's quality assurance plans pertaining to the rack installation.-

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8. Provide copies of the Vepco and/or contractor as-low-as-rea-sonably achievable (ALAPA) review and planning documents covering the removal and installation of the racks.

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9. If the procedures for decontamination and disposal of the old racks are not included in the procedures identified in the documents identified above, provide copies of the decon-tamination and preparation for shipment procedures and ALARA review documents.

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J# Marshall Coleman Christopher H. Buckley, Jr.

Cynthia A. Lewis Robert Brager Virginia S. Albrecht Beveridge & Diamond, P.C.

1333 New Hampshire Avenue, N.W.

Washington, D.C. 20036 Attorneys for Intervenor April 22, 1983 Of Counsel:

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Richard W. Arnold, Jr.

County Attorney P.O. Box 276 Louisa, Virginia 23093 (703) 967-1650 1

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