ML20043A666

Document Production Request Propounded by State of VT to Vermont Yankee Nuclear Power Corp (Set 2).* Listed INPO Documents Requested.W/Certificate of Svc.Related Correspondence

ML20043A666
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	05/14/1990
From:	Janson K VERMONT, STATE OF
To:	VERMONT YANKEE NUCLEAR POWER CORP.
References
CON-#290-10367 OLA-4, NUDOCS 9005220377
Download: ML20043A666 (6)

Text

._ . -_

ret.ATED CORRESPONDENCE g tf5NRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '90 MY 17 P4 :03  :

before the '

ATOMIC SAFETY AND LICENSING BOARD g y ggf,

\ HICK (? M A'M Vlff

';R ANC H I

In the Matter of )

)

VERMONT YANKEE NUCLEAR ) Docket No. 50 271-OLA-4 1 POWER CORPORATION ) (Operating License

) Extension) i (Vermont Yankee Nuclear )

Power Station) )

DOCUMENT PRODUCTION REQUEST PROPOUNDED BY THE STATE OF VERMONT TO THE VERMONT YANKEE NUCLEAR POWER CORPORATION (Set No. 2)

Pursuant to 10 C.F.R. 5 2.741, the State of Vermont hereby propounds the

- following document production request to the Vermont Yankee Nuclear Power Corporation.

DEFINITIONS

1. " Document" as used herein is used in its broadest sense as expressed.

in Rule 34(a) of the Federal Rules of Civil Procedure, and specifically includes copies of every instrument or device by which, through which, or on which information has been recorded, including those reflecting meetings, discussions or conversations: notes; letters; memoranda (including internal Vermont Yankee Nuclear Power Corporation memoranda); manifests; tables; drawings; files; graphs; charts; maps; photographs; deeds; studies; data sheets; notebooks; books; appointment calendars; telephone bills; telephone messages; receipts; vouchers; minutes of meetings; pamphlets; computations; calculations; accounting statements; financial statements; voice recordings; computer printouts  ;

and disks; or any other device or media on which or through which information of any type is transmitted, recorded, or preserved. The term " document" also means every copy of a document when such copy is not an identical duplicate of the original.

1 i

l 9005220377 900514 PDR 0 ADOCK 05000271 PDR' 0

L 3)5'9

g

[ i

/ l q

2. " Vermont Yankee" and " licensee" each refer to Vermont Yanke.  ;

Nuclear Power Corporation, its predecessors, successors, parents, subsidiaries, i affiliates, segments or divisions, including all past and present officers, directors, i employees, agents or members of the Board of Directors of Vermont Yankee.

INSTRUCTIONS

1. The response to each sub part of the Document Request is to be numbered in a manner consistent with the Document Request.

2. In responding to this Document Request, furnish all responsive information that is available to Vermont Yankee, including information that is in the possession of any of Vermont Yankee's officers, employees, agents, contractors, consultants, assigns and attorneys or otherwise subject to Vermont Yankee's custody or control.

3. If any requested document was but is no longer in your possession or '

subject to your control, state what disposition was made of it.

4. If any Document Request cannot be provided in full, it shall be provided to the extent possible, and an explanation shall be given as to why a full provision is not possible.

5. If only part of a document is responsive to a Document Request and the entire document is produced, the responsive section of the document shall be indicated.

6. If anything is deleted from a document produced in response to a '

Document Request, Vermont Yankee shall state the reason for the deletion l and the subject matter of the deleted material.

L

7. If any requested document or information is withheld pursuant to an

!~ objection or claim of privilege, Vermont Yankee shall identify the specific j Document Request (including subparagraph) requesting the withheld document l or information, state the nature of the objection or privilege and the precise L grounds upon which the objection is made or the privilege is claimed.

l

8. If an objection is made or a privilege is claimed as to any requested information, identify each person who has knowledge of such information.

l

i, i V .. . .. -

9. If any document is not produced because Vermont Yankee has not retained it or because it is being withheld pursuant to an objection or claim of privilege, Vermont Yankee shall identify the document by stating:

(a) the name(s) and affiliation (s) of the document's author (s) or

- originator (s);

(b) the name(s) and affiliation (s) of the document's addressee (s); ,

(c) the document's date; ,

(d) the document's title or heading; -

(e) the document's type (ca, letter, contract);.

(f) the docume.nt's subject matter; (g) the name(s) and affiliation (s) of the present or last knowm custodian (s) of the original document or copies thereof;

(h) the current or last known business and residential addresses of such custodian (s); and (i) the name(s) and affiliation (s) of all recipients of copies of the document.

10. If any Document Request is objected to in part, for any reason, the ,

remainder of the Document Request is to be provided in full.

11. All responses must be supplemented as provided for in 10 C.F.R. !

2.740(e).

12. Documents are requested for production for inspection and copying in accordance with 10 C.F.R. f 2.741.

DOCUhiENT PRODUCTION REQUEST Please produce for inspection and copying all of the Institute of Nuclear Power Operations (INPO) documents identified below:

Document Tule 1

1. INPO 82-001 Reduction of PWR Radiation Level Buildup by Maintenance of High Reactor Coolant PH L 2. INPO 82-002 Maintenance History Program (hiA 310)

3. INPO 82-002 Snubber Maintenance Program (MA 313) 3 l

1 l

A Document Igig

4. INPO 83-024 Planned Valve Repacking as Preventive Maintenance

5. INPO 83-045 Plant Material Deficiency Identification

6. INPO 83-04 Component Verification and System Validation Guidelines

7. INPO 84-010 Vendor Equipment Technical Information i Program

. 8. INPO 84-025 Operation Surveillance Program

9. INPO 84-026 Setpoint Change Control Program

10. INPO 84-028 Control of Vendor Manuals i

11. INPO 85 001 Performance Objectives and Criteria for Operating and Near-term Operating License .

Plants I

12. INPO 85-010 Surveillance and Periodic Task Scheduling Program

13. INPO 85 013 Plant Modification Control Program

14. INPO 85-016 Temporary Modification Control l

L 15. INPO 85 026 Writing Guideline for Maintenance, Test and l Calibration Procedures l

16. INPO 85-031 Guidelines for the Conduct of Technical Support Activities at Nuclear Power Stations

17. INPO 85-032 Preventive Maintenance

18. INPO 85-038 Guidelines for the Conduct of Maintenance at Nuclear Power Stations

19. INPO 86-002 Maintenance History Program l

4

r Docurnent Etic

20. INPO 86-014 Snubber Maintenance Program

21. INPO 86-018 Guidelines for Training and Qualification of Maintenance Personnel

22. INPO 87 009 Control of Vendor Manuals

23. INPO 87 028 Post Maintenance Testing

24. INPO 88-022 Vendor Manual Specification and Procurement

25. INPO 89-009 Plant Predictive Maintenance

26. INPO Operations and Maintenance Reminder O & MR 308 By its Attorney,

~ *' ~n Kurt Janso Special Assistant Attorney General Department of Public Service 120 State Street Montpelier, Vermont 05602 (802) 828 2811 Date: May 14,1990 i

5 i

r j

/0367 ....

00(,KETED UNITED STATES OF AMERICA USNRC NUCLEAR RE1ULATORY COMMISSION before the 90 my 17 P4 :03 ATOMIC SAFETY AND LICENSING BOARD

) Orrett or StCRETAR" In the Matter of ) 00Cht1*G A S H M VERMONT YANKEE NUCLEAR ) Docket No. 50-2iISbSk-4 ,

POWER CORPORATION ) (Operating License ,

) Extension)

(Vermont Yankee Nuclear )

Power Station) -)

)

CERTIFICATE OF SERVICE j 6

I hereby certify that on May 14, 1990, I made service of

" State of Vermont Answer in Opposition to Vermont Yankee Nuclear Power Corporation Motion to Compel and State of Vermont -

Application for Protective Order," and " Notice Of Appearance" in accordance with rules of the Commission by mailing a copy thereof postage prepaid to the following: i Administrative Judge Administrative Judge Robert M. Lazo, Chairman Jerry Harbour Atomic Safety and Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Washington, DC 20555 U.S. Nuclear Regulatory Commission ^

Washington, DC 20555 Administrative 7udge Ann P. Hodgdon, Esq.

Frederick J. Shon Patricia A. Jehle, Esq.

Atomic Safety and Licensing Board Office of the General Counsel  ;

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory -

Washington, DC 20555 Commission Washington, DC 20555 R. K. Gad, III, Esq.

• Anthony Z. Roisman, Esq.

Ropes & Gray Cohen, Milstein, Hausfeld-&

One International Place Toll -

Boston, MA 02110 Suite 600 1401 New York Avenue, N.W.

• Adjudicatory File Washington, D.C. 20005 Atomic Safety and Licensing Board Panel U.S.N.R.C. /

Washington, DC 20555 4 ' c.m" KuttJansop/stant Special As,si ,

Dated:

r Y / f fO Federal Express Overnight Delivery '

- . . _ - _ - _ - - _ _ _ _ _ - _ - _ _