ML20034C251
| ML20034C251 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 04/26/1990 |
| From: | Gad R ROPES & GRAY, VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | VERMONT, STATE OF |
| References | |
| CON-#290-10299 OLA-4, NUDOCS 9005020227 | |
| Download: ML20034C251 (9) | |
Text
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goamouc DOCFETED USNRC UNITED STATES OF AMERICA
% APR 30 PS :06 NUCLEAR REGULATORY COMMISSION before the Or ict 0F SECR[1ARY imtathuG a 9Div n ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
.)
)
Docket No. 50-271-OLA-4 VERMONT YANKEE NUCLEAR )
(Construction Period POWER CORPORATION
)- Recapture)
)
(Vermont Yankee Nuclear
)
Power Station)
)
)
INTERROGATORIES PROPOUNDED BY VERMONT YANKEE NUCLEAR POWER CORPORATION TO THE ~
STATE OF VERMONT (Set No 3)
Pursuant to 10 C.F.R. i 2.740b, Vermont Yankee Nuclear Power Corpora-tion hereby propounds the following interrogatories to the State of Vermont.
As used in these interrogatories, VYNPC means Vermont Yankee Nuclear Power Corporation; VYNPS means Vermont Yankee Nuclear Power Station; SOY means the State of Vermont, including the agencies, officers, employees, and agents thereof and further including contractors or consultants thereto.
As used in these interrogatories, the term document has the same meaning as it does in Fed. R. Civ. P. 34(a).
As used in these interrogenries, the term *1dentify'.with respect to a person means to supply the nee..urrent business or residential address and telephone number of the person, and to state the relationship, if any, of the person to SOV.
As used in these interrogatories, the term " identify" with reference to a.
document means to provide such identifying information as the title or other name of the document, the author or authors of the document, the date of the document, and to state whether or not the document, or a copy thereof, is within the possession, custody or control of SOV.
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I Your attention is called to the provisions of 10 C.F.R. i 2.740(e) regarding.
j the duty of supplementation with respect to answers to interrogatories.
l 1.
Please identify each and every SALP report or 'other enforcement actions
- relating to VYNPS wherein SOY contends that NRC has placed 'importance* on " clearly established management controls
- for :
the purpose of alleviating any ' shortage of qualified replacement l
[ maintenance) personnel,' as asserted in the answer to Interrogatory No. 8, Set ! Responses at page 7.
l 1
2.
Does SOY adopt as true and correct, as of the date of its publication..
S the findings of SALP Report No. 50-271/88-89 (appended hereto as -
l Attachment B), that:
a)
"The Maintenance Program was considered a licensee strength b)
"The routine preventative and corrective maintenance programs continued to be effectively implemented, as evidenced by high -
equipment availability, reliability, and performance;"
c)
' Management - maintained a low tolerance for degraded l
equipment and typically pursued conservative resolution of
- l maintenance deficiencies;"
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d)
"By the end of the assessment' period, the licensee had j
developed and substantially documented a formal plan.'
if your answer is anything other than an unqualified. affirmative, please identify each finding that SOY contends is (or on the date of the publication thereof was) not correct, and for each such finding state all the reasons why SOV contends the filing is not correct.
3.
Please identify each and every item that SOY contends is part of the.
' current licensing basis" for YYNPS, as that term was used by SOY at page 3 of its Set 1 Responses, that have not been available to SOV -
either:
< i a) in the Public Document Room; b) by request through informal discovery from VYNPC; or
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c) through normal distribution to-SOY of Vermont Yankee communications with the NRC.
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4.
Please identify each and every type and item of *information reviewed by the Maintenance Team inspectors," as that term was used by SOV at page 4 of its Set i Responses, that SOV contends have not been available to SOY either:
a) in the Public Document Room; 5
b)~
by request through informal discovery from VYNPC; or c) through normal distribution to SOY.of. Vermont Yankee communications with the NRC.
5.
Please define what SOY contends is included within the scope of the term ' correct controls'. as used by SOY at page 7 of its Set 1 Re-sponses, and provide all the bases for your definition.
6.
Please state whether the ' period of time" that SOV contends, at page 7 of its Set i Responses, is necessary to show the effectiveness of management controls is the same as the five-year period advanced by l
SOY in its response to Interrogatory No.100 of Set 27 If not, please define the ' period of time' referred to. In either event, please state -
each and every reason for the time period specified, and, for each such reason, please:
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s.
State each and every fact on which your reason is based..
l b.
Describe all of the evidence in SOV's possession or of which-SOY has knowledge that SOY contends establishes each such
- fact, c.
For each reason, either provide the technical qualifiestions (education, employment history, licenses and certificates, experience, or other information that SOV contends establishes the qualifications of the person), of any person on whose -
expertise SOY relles for the reason or state that SOY does not '
rely upon the expertise of any person for the reason.
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7.
Please quantify the. expected " shortage" of qualified replacement (maintenance) personnel that SOY contends at pages 6-8 of its Set i Responses is to be expected, and-provide all the bases for your quantification.
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8.
With respect to the assertion at page 8 of its Set i Responses that the maintenance program will be ' inadequate," please identify each aspect of the program that SOY contends will be inadequate, the measure or standard by which SOY contends adequacy is determined, and for each aspect all of the reasons why SOY contends that it will be inadequate.
9.
Please identify each and every passage of each document that SOY contends supports its assertions, at page 8 of its Set I response, thst:
a)
- as the plant reaches the extended period, there will be a shortage of qualified maintenance workers;" and b)
'without established and implemented management controls -
the maintenance program will not only be less efficacious but will be inadequate."
10.
Does SOY contend that its asserted shortage of qualified replacement.
maintenance personnel cannot be completely alleviated by financial or other incentives offered to such personnel? If your response is anything other than an unqualified negative, please:
a.
State each and every fact on which your reason is based, b.
Describe all of the evidence'in SOV's possession or of which -
SOY has knowledge that SOY contends establishes each such
- fact, c.
For each reason, either provide the technical qualifications' (education, employment history, licenses and certificates, experience, or other information that SOY contends establishes the qualifications of the person), of any person on whose.
expertise SOY relies for the reason or state that SOY does not rely upon the expertise of any person for the reason, 11.
What does SOV contend will happen to the experienced maintenance workers at the "almost one-half of the nuclear generating capacity" whose ' current licenses
- SOY asserts, at page 9 of its Set i responds "will expire" *between 2010 and 20207" Please state each and every reason for your answer, and, for each such reason, please:
a.
State each and every fact on which your reason is based.
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i b.
Describe all of the evidence in SOV's possession or of which SOY has knowledge that SOY contends establishes each such j
fact.
c.
For each reason, either provide the technical qualifications (education, employment history, licenses and certificates.
experience, or other information that SOY contends establishes l
the qualifications of the person), of any person on whose expertise SOY relles for the reason or state that SOY does not.
rely upon the expertise of any person for the reason.
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12.
Please describe in detail each of the steps taken by SOY to verify.
independently any of the opinions or conclusions of the author (or =
authors) of the work dated October 9,1989, to which SOV refers in sub-paragraph "c." of its Contention 7, as asserted in its response to Interrogatory No. 38 of Set 2, including but not limited to: (1) the.;
identity and qualifications of the persons taking the steps, (ii) the'
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-identity of all persons interviewed or queried,(iii) the identity of all documents reviewed. (iv) a description of all data collected and analyzed and a description of the results of the analysis,'and (v) all other results of the steps.
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13.
For each and every assertion made by.SOV in hl Set i Responses at Interrogatory No.10 b. pases 10-12, please:
s.
State each and every fact on which your assertion is based.
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b.
Describe all of the evidence in SOV's possession or of which SOY has knowledge that SOY contends establishes each such
- fact, c.
For each assertion, either provide the technical qualifications (education, employment. history, licenses and certificates,-
experience, or other information that SOV contends establishes the qualifications of the person), of any person'on whose expertise SOY relies for the assertion or state that SOY does-not rely upon the experthe of any person for the assertion.'
14.
Please describe in detail what level of awareness SOY contends, at.
pages 10-11 of its-Set. l. Responses, that " nuclear maintenance personnel" must have of "the interrelationships between ECCS and '
other safety systems." Please also:
a.
State each and every f act on which your answer is based.
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Describe all of the evidence in SOV's possession or of which SOY has knowledge that SOY contends establishes each such fact.
c.
Provide either the technical qualifications (education, employment history, licenses and certificates, experience, or
- other information that SOY contends establishes the qualifica-j tions of the person), of any person on whose expertise SOV l
relies for the answer or state that SOY does not rely upon the expertise of any person for the answer, i
15.
Please describe in detail what level of awareness SOY contends, at 5
page 11 of its Set 1 Responses, that ' nuclear maintenance personnel" j
must have of ' requirements, commitments and regulations." Please also:
State each and every fact on which 'your answer is tiased.
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b.
Describe all of the evidence in SOV's possession or of which SOY has knowledge that SOY contends establishes each such fact.
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c.
Provide either the technical qualifications (education, employment history, licenses and certificates, experience, or -
J other information that SOY contends establishes the qualifica-j tions of the person), of any person on whose expertise SOY i
relies for the answer or state that SOY does not rely upon the -
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expertise of any person for the answer.
16.
Does SOY contend, in sub-paragraph 'g" of its Contention 7 or otherwise, that performance data is not tracked and analyzed? If your answer is anything other than an unqualified negative, please state all
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the reasons why SOY so contends, and identify every fact and document which SOY asserts supports that contention.
17.
Does SOY contend, in sub-paragraph 's" of its Contention-7 or.
i otherwise, that performance data is not reported to the Maintenance Supervisor? If your answer is anything other than an unqualified' negative, please state all the reasons why SOY so contends, and identify every fact and document which SOV_ asserts supports that
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1 contention.
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18.
Docs SOY contend, in sub-paragraph 'g* of its Contention 7 or otherwise, that trending analyt h is not reported to plant and corporate management? If your answer is anything other than an unqualified i'
negative, please state all the reasons why SOY so contends, and l.
identify every fact and document which SOY asserts _ supports that L
contention.
- i 19.
Does SOY contend, in sub-paragraph 's' of its Contention 7 or otherwise, that tracking and analysis of performance data has never led to equipment replacement? If your answer is anything other than--
i an unqualified negative, please state all the reasons why SOY so contends, and identify every fact ano document which SOV asserts.
supports that contention.
l 20.
Please describe in detail how high in the Vermont Yankee organization SOY contends that trending analysis should be reported, and a.
State each and every fact on which your answer is based.
b.
Describe all of the evidence in SOV's possession or of which SOY has knowledge that SOY contends establishes each such fact.
a c.
Provide either the technical qualifications '(education, employment history, licensos and certificates, experience, or other information that SOV contends establishes the qualifica-tions of the person), of any person on whose expertise SOY relles for the answer or state that SOY does not rely upon the expertise of any person for the answer.
21.
Please identify each and every type and item of " additional, related information" that SOV contends, at page 14 of its Set 1 Responses, it needs to complete its ' investigation," that have not been available to SOY either, i
a) in the Public Docenent Room; b) by request through informal discovery from YYNPC; or
. c)
. through normal distribution to SOV of Vermont Yankee '
communications with the NRC.
l 21.
Please identify every passage of every 'INPO report"(regardless of I
whether or not SOY had the report in its possession when it submitted l
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l its Contention 7) that SOY contends is meant to by referenced by the
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allegations contained in sub-paragraph *m' of SOV's Contention 7.
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22.
Please identify each and every type and item of
- additional evidence
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other than BVY 89-69,* as that term is used by SOY st page 17 of its Set 1 Responses, that have not been available to SOY either.
l a) in the Public Document Room:-
b) by request through informal discovery from VYNPC; or j
c) through normal distribution to SOY of Vermont Yankee.
communications with the NRC.
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R. K. Gad sti-Jeffrey P. Trout Ropes A Gray One laternational Place l
Boston, Massachusetts 02110
-j Telephone: 617-951-7520 Dated: April 26,1990.
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.tocntite UbHRC VYN 14s W APR 30 ' PS :06
- 1. R. K. Gad til, hereby certify that on April 26,1990, I made service of the.
within interrogatories, by mailing copies thereof, first class mail, postaC6 prepaid,
- as follows:
Robert M. Lazo, Esquire
' Jerry Harbour -
Chairman
~ Administrative Judge -
Atomic Safety and Licensing L9ard
- Atomic Safety and Licensing Board U.S.N.R.C.
U.S.N.R.C.
Washington, D.C. 20555 Washington, D.C. 20555 Frederici: :. Shon
. Adjudicatory File Administrative Judge Atomic Safety and Licensing Board.'
Atomic Safcty and Licensing Board Panel U.S.N.R.C.
U.S.N.R.C.
I!
Washington, D.C. 20555
. Washington, D.C. 20555 Anthony Z. Roisman, Esquire -
- Ann P. Hodadon,- Esquire Cohen, Milstein & Hausfeld -
. Patricia A. Jehle, Esquire'-
y Suite 600
. U.S.'N.R.C.
1 1401 New York Avenue, N.W'.
Washington, D.C.' 20555 '
Washington, D.C. 20005 i
James Volz, Esquare q
Vermont Department of Public Service -
120 State Street Montpelier, Vermont 05602 q
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R. K. Gad III
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