ML20023D093

Response to Request for Production of Documents.Production Will Be Permitted Subj to Encl Stipulation of Confidentiality.Certificate of Svc Encl

ML20023D093
Person / Time
Site:	North Anna
Issue date:	05/16/1983
From:	Gelman M VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	LOUISA COUNTY, VA
References
ISSUANCES-OLA-2, NUDOCS 8305190219
Download: ML20023D093 (8)

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OJ UNITED STATES OF AMERICA 4f NUCLEAR REGULATORY COMMISSIg #7# -

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In the Matter of ) 24

) Docke A j Virginia Electric and Power Company ) 50-338,339 (North Anna Power Station, ) OLA-2 / .t;4f, I

f Units 1 and 2) )

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l Applicant's Response to Louisa l County's Request for Production of Documents l

l l Applicant, Virginia Electric and Power Company l

("Vepco"), files the following Response to the Request For Production Of Documents By Louisa County and the Board of Supervisors of Louisa County ("Louisa County").

! Production of all documents requested will be l i

l permitted subject to the stipulation of Confidentiality )

entered into by the parties and attached hereto as Exhibit A. This Stipulation of Confidentiality has been entered into because certain documents requested by Louisa County contain confidential and proprietary information of Applicant and of other persons or corporations not parties to this proceeding.

Respectfully submitted, VIRGINIA ELECTRIC AND POWER COMPANY (in L .

011 b, Marcia R. Gelmah, Counsel 8305190219 830516 PDR ADOCK 05000338 PDR G

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o Of Counsel

' Michael W. Maupin James N. Christman Patricia M. Schwarzschild Marcia R. Gelman HUNTON & WILLIAMS P.'O. Box 1535 Richmond, Virginia 23212 (804) 788-8672 .

Dated: May 16, 1983 I

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EXHIBIT A UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

) Docket Nos.

Virginia Electric and Power Company ) 50-338/339 (North Anna Power Station, . ) OLA-2 Units 1 and 2) )

Stipulation of Confidentiality Rela *.ive to Production of Certain Documents by Applicant WHEREAS, Louisa County has served upon Applicant a Request for Production of Documents relevant to the above-captioned proceeding; and WHEREAS, the Request of Louisa County calls for the production of certain documents identified in Appendix A hereto (" covered documents"); and WHEREAS, the covered documents contain confidential and proprietary information of Applicant and of other persons or corporations not parties to this proceeding; and WHEREAS, Applicant is willing to make available to Louisa County the covered documents for purposes of discovery, provided that their confidentiality is maintained; NOW, THEREFORE, it is hereby stipulated and agreed by the parties

1. That the covered documents shall be produced by Applicant marked with the word " CONFIDENTIAL."

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2. That.Louisa County, and its representatives, agents, employees and attorneys, will not use copies of the covered documents for any purpose other than in connection with the above-captioned litigation or related proceedings and agree that such documents or the contents.thereof shall not be made public during the course of any such litigation but shall be disclosed only to the parties and to the administrative officers involved and shall be filed under seal.

3. That no other dissemination of the covered documents will be made without the express written consent of Vepco.

4. That all discovery depositions involving the covered documents shall be taken in the presence of counsel for the parties and Applicant's corporate representative, and no other persons shall be permitted to attend.

Further, the original of all transcripts of such depositions shall be filed under seal.

5. That counsel for Louisa County may disclose the contents of covered documents and depositions described

'above to a designated expert witness. Such expert shall be j

identified to counsel for Applicant prior to disclosure.

Further, counsel for Louisa County shall be responsible for obtaining a prior written agreement prohibiting such expert witness from disclosure of such information, which agreement shall be obtained by securing the signature of such expert at the bottom of a copy of this Stipulation,

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e after having had such expert read the Stipulation and having explained the contents and requirements thereof.

6. Counsel for Louisa County and Louisa County's design'ated expert witness are prohibited from disclosing to any person the discovery subject to this Stipulation.

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/ Marcia R. Ge'iman Counsel for Vepco h)h \3. k '

\( W \6 Virginia S.~Albrecht 07 Date' I Counsel for Louisa County

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Appendix A Documents Covered by Stipulation of Confidentiality

1. Drawings for the new spent fuel storage racks.

(Request #1.)

2. Vepco's purchase order and/or contract covering the design and manufacture of the new spent fuel storage i

racks. (Request #2.)

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3. NES Proposal to Vepco for spent fuel storage racks. (Request #3.)

4. NES fabrication specifications. (Request #3.)

5. BISCO materials relating to boraflex.

(Request #3.)

6. NES Quality Assurance materials. (Request #4.)

7. NES installation procedure for spent fuel storage racks. (Request #6.)

8. ALARA materials contained in Vepco document transmittal dated 5-9-83. (Request #8.)

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- CERTIFICATE OF SERVICE I hereby certify'that I have this day served the foregoing

. Applicant's Response to Louisa County's Request For Production of Cocuments upon each of.the persons named below by depositing a copy in the United States mail, properly stamped and addressed to him at the address cet out with his name:

Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Chief Docketing and Service Section Sheldon J. Wolfe, Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Jerry Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. George A. Ferguson School of Engineering-Howard University 2300 5th Street Washington,.D.C. 20059 Henry J. McGurren, Esq.

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 t

J. Marshall Coleman, Esq.

Beveridge & Diamond P.C.

1333 New Hampshire Avenue, NW Washington, D.C. 20036 James B. Dougherty, Esq.

3045 Porter Street, NW Washington, D.C. 20008 1

Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i

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Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 By:

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/s/ Marcia R. Gelman Marcia R. Gelman, Counsel for Virginia Electric and Power Company Dated: May 16, 1983 .

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