ML20043G060
| ML20043G060 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 06/11/1990 |
| From: | Gad R ROPES & GRAY, VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | VERMONT, STATE OF |
| References | |
| CON-#290-10467 OM, NUDOCS 9006190006 | |
| Download: ML20043G060 (47) | |
Text
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4 wuTro comesponoence
%P Filed: June !!,1990.
UNITED STATES OF AhtERICA 90 JN 13 P3:39 NUCLEAR REGULATORY COhthtISSION i
grnCE OF SECiiEitiW before the v0CKlllNG A Sit (VICI i E NCH 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)
)
)
RESPONSES OF VERhtONT YANKEE NUCLEAR POWER CORPORATION TO DOCUMENT REQUESTS PROPOUNDED BY TIIE STATE OF YERMONT Pursuant to 10 C.F.R. $ 2.741, Vermont Yankee Nuclear Power Corpora-tion hereby responds to the document requests propounded to it by the State of Vermont.
General Response Regarding Documents: In each case in which a document is identified hereinafter to be available, the documents will be produced for inspection and copying at either (i) the offices of Vermont Yankee Nuclear Power Corporation, in Brattleboro,(ii) the Vermont Yankee Nuclear Power Station in Vernon, or (iii) the Nuclear Services Division, Yankee Atomic Electric Company, Bolton, Massachusetts (depending on document location) on a date and time to be agreed upon by counsel.
j Request No.1.
Request:
Please identify all persons who participated in the preparation of answers to these document production requests. Identify the specific portions of each response to which each person contributed.
Response
l Licensee objects to this request, on the grounds that it does not call for the production of any existing document, but rather asks Licensee to compile 9006190006 900611 po3
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3
4 new information. While perhaps proper as an interrogatory, it is not an ap-propriate production request.
Without waiving this objection, but rather expressly relying upon the same, Licensee responds that the person who participated in preparation of these responses to production requests, exclusive of counsel, was Francis J.
Helin, Project Engineer.
Request No. 2.
Request:
For each and every supervisor who has been responsible for main-tenance and surveillance activities at the Vermont Yankee plant at any time since January 1,1988, as identified in response to Vermont Interrogatory (Set No.1) No. 2, please produce for inspection and copying all personnel files, including, but not limited to, performance evaluations, ratings by supervisors, qualification records, and training records and test scores.
Response
Licensee objects to this request on the grounds that it is overbroad and improperly invades the privacy of the individuals in question, and pursuant to 10 C.F.R. $ 2.740(c) requests a protective order that the same not be disclosed.
Without waiving these objections, but rather expressly relying upon the same, Licensee states that those documents identified in Licensee's answer to SOV's Interrogatory No. 2(g) will be produced.
Request No. 3.
Request:
For each and every Vermont Yankee employee who hts been responsible for or has performed maintenance or surveillance I
l activities at the Vermont Yankee plant at any time since January 1, 1988, as idetified in response to Vermont Interrogatory (Set No.1)
No. 3, please produce for inspection and copying all personnel files, including, but not limited to, performance evaluations, ratings by supervisors, qualification records, and training records and test scores.
Response
Licensee objects to this request on the grounds that it is overbroad and j
l i
improperly invades the privacy of the individuals in question, and pursuant l
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to 10 C.F.R. I 2.740(c) requests a protective order that the same not be i
disclosed.
Without waiving these objections, but rather expressly relying upon the same, Licensee states that such resumes and training records as are available will be produced.
Request No. 4.
Request:
For each and every contract employee who has been responsible for or has performed maintenance or surveillance activities at the Vermont Yankee plant at any time since January 1,1988, as identified in response to Vermont Interrogatory (Set No.1) No. 4, please produce for inspection and copying all personnel files, including, but not limited to, performance evaluations, ratings by Vermont Yankee personnel, qualification records, and training records and test scores.
Response
Licensee objects to this request on the grounds that it is overbroad and improperly invades the privacy of the individuals in question, and pursuant to 10 C.F.R. l 2.740(c) requests a protective order that the same not be disclosed.
Without waiving these objections, but rather expressly relying upon the same, Licensee states that those documents identified in Licensee's answer to SOV's Interrogatory No. 4(g) will be produced.
Request No. 5.
r Request:
l For each and every licensed control room operator, senior control t
operator, and shift supervisor who is currently employed at the I
Vermont Yankee plant, or has been in your employ at any time since January 1,1988, as identified in response to Vermont Interrogatory (Set No.1) No. 5, please produce for inspection and copying all personnel files, including, but not limited to, performance evalua-tions, ratings by supervisors, qualification records, and training records and test scores.
Response
Licensee objects to this request as irrelevant. Licensee further objects to this request on the grounds that it is overbroad and improperly invades the l
1 1
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privacy of the individuals in question, and pursuant to 10 C.F.R. ( 2.740(c) requests a protective order that the same not be disclosed.
Without waiving these objections, but rather expressly relying upon the same, Licensee states that those documents identified in Licensee's answer to SOV's Interrogatory No. 5(c) will be produced.
Request No. 6.
Request:
Please produce for inspection and copying all documents setting forth the current licensing basis for each structure, system and component of the Vermont Yankee plant, identified in response to Vermont Interrogatory (Set No.1) No. 6.
If in response to Vermont Inter-i rogatory (Set No.1) No. 6 Vermont Yankee has not identified any or all documents requested to be identified by that interrogatory, produce for inspection and copying all such documents.
Response
Licensee objects to this request, on the giound that the request is not relevant to the admitted contention. Without waiving this objection, but rather expressly relying upon the same, Licensee will produce the Engineer-ing Design Basis Manual identified in Interrogatory No. 6.
Request No. 7.
Request:
For structures, systems and components for which the current licensing basis is different from the licensing basis when the Vermont Yankee plant was originally granted its operating license, produce for inspection and copying each and every document, identified in response to Vermont Interrogatory (Set No.1) No. 7, which caused the licensing basis to change from its original basis, if in response to Vermont Interrogatory (Set No.1) No. 7 Vermont Yankee has not identified any or all documents requested to be identified by that interrogatory, produce for inspection and copying all such documents.
Response
All responsive documents presently known by Licensee to be within its possession or control will be produced. 4
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Request No. 8.
j Request:
For each and every person who has been responsible for reviewing maintenance requests or work orders with regard to the current i
licensing basis of structures, systems and components, or with regard to the regulatory or safety impact of the request, at the Vermont Yankee plant, at any time since January 1,1988, as identified in response to Vermont Interrogatory (Set No.1) No. 8, please produce for inspection and copying all personnel files, including, but not limited to, performance evaluations, ratings by supervisors, qualifica-tion records, and training records and test scores.
Response
Licensee objects to this request as irrelevant. Licensee further objects to this request on the grounds that it is overbroad and improperly invades the privacy of the individuals in question, and pursuant to 10 C.F.R,i 2.740(c) requests a protective order that the same not be disclosed.
Without waiving these objections, but rather expressly relying upon the same, Licensee states that those documents identified in Licensee's answer to SOV's Interrogatory No. 8(g) will be produced.
Request No. 9.
Request:
For the review of maintenance requests and work orders referenced in the foregoing document production request:
a.
If the current licensing basis maintained in a central location, accessible to personnel responsible for maintenance review, l
produce the documents from this location for inspection and l
- copying,
- b. If the current licensing basis is distributed by a controlled distribution, produce for inspection and copying the procedure by which these documents are controlled, and current and past copies of these current licensing basis documents, c,
if the current licensing basis is maintained in a format accessible by computer, please produce for inspection and copying the l
procedure by which this computer data base is controlled, and provide access to the data base for inspection and print out.
- d. If the current licensing basis is maintained for the maintenance reviewer by a method described in sub-part f of Vermont /
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Interrogatory (Set No.1) No. 9, please produce for inspection and copying all documents which the maintenance reviewer uses to perform the review with regard to the current licensing basis or the regulatory or safety impact of the maintenance request.
Response
- a. All responsive documents presentiy known by Licensee to be with!n its possession or control will be produced, t
- b. All responsive documents presently known by Licensee to be within its possession or control will be produced.
- c. All responsive documents presently known by Licensee to be within its possession or control will be produced, c.
Not applicable.
Request No.10.
Request:
Please produce for inspection and copying all the results of quality assurance audits since January 1,1988, identified in response to Vermont Interrogatory (Set No.1) No.10, which reviewed the adequacy of the process of reviewing maintenance requests or work orders with regard to the current licensing basis or regulatory or safety impact. These results include, but are not limited to, audit reports, reports to management, audit check lists, informal check lists and hand written notes, if in response to Vermont Interrogatory (Set No.1) No.10 Vermont Yankee ha not identified any or all docu-ments requested to be identified by that interrogatory, produce for inspection and copying all such documents.
Response
All responsive documents presently known by Licensee to be within its possession or control will be produced.
Request No.11.
Request:
Produce for inspection and copying all the results of quality assurance audits since January 1,1988, identified in response to Vermont Interrogatory (Set No.1) No.11, which reviewed the adequacy of the process of maintaining the current licensing basis in a current and correct condition. These results include, but are not limited to, audit l
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I reports, reports to management, audit check lists, informal check lists and hand written notes, if in response to Vermont Interrogatory (Set No.1) No.11 Vermont Yankee has not identified any or all docu-j
- ments requested to be identified by that interrogatory, produce for inspection and copying all such documents.
Response
I Licensee objects to this request on the grounds that the subject thereof is not within the scope of the admitted contention.
Without waiving this objection, but rather expressly relying upon the same, Licensee will produce all responsive documents presently known to be:
within its possession or control.
Request No.12.
Request:
Please provide a copy of the set of documents provided to NRC inspectors as requested by Appendix I of Inspection Report No.
50-271/89-80(also attached as Appendix 1 to Vermont interrogatories (Set No.1).
l
Response
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L License will produce the documents identified in the response to interrogatory No.12.
go.13.
Request:
Please produce for inspection and copying all documents which were requested by Appendix 1 of Inspection Report No. 50-271/89-80, but which were not copied for NRC, and all other documents which were reviewed by NRC maintenance team inspectors, identified in response i
to Vermont Interrogatory (Set No.1) No.12. (The intent of this request is to produce all documents provided to or reviewed by the maintenance team inspectors.) If in response to Vermont Inter-rogatory (Set No.1) No.12 Vermont Yankee has not identified any or all' documents requested to be identified by that interrogatory, produce for inspection and copying all such documents.
j
Response
Each of the documents identified in the response to Interrogatory No.12 will be produced.
m y
Request No.14.
Request:
Please produce for inspection and copying each document revised since the maintenance team inspection, identified in response to Vermont Interrogatory (Set No.1) No.13. If in response to Vermont 7
Interrogatory (Set No.1) No.13 Vermont Yankee has not identified e
any or all documents requested to be identified by that interrogatory, l
produce for inspection and copying all such documents.
l
Response
The current revision of each of the documents identified in the response to interrogatory No.12 will be produced.
Request No.15.
Request:
Please produce for inspection and cooying each and every document, in addition to those in document production request 12 above, which comprises the maintenance program upon which the licensee relies for the license extension, as identified in response to Vermont Inter-rogatory (Set No.1) No.14. If in response to Vermont Interrogatory (Set No.1) No.14 Vermont Yankee has not identified any or all documents requested to be identified by that interrogatory, produce for inspection and copying all such documents.
Response
Each of the procedures identified in the response to Interrogatory No.14,
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and any document referenced therein, will be produced.
Request No.16.
Request:
Please provide copies of the maintenance documents produced since or as a result of the maintenance team inspection, as identified in response to Vermont Interrogatory (Set No.1) No.15. If in response to Vermont Interrogatory (Set No.1) No.15 Vermont Yankee has not identified any or all documents requested to be identified by that interrogatory, produce for inspection and copying all such documents.
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Response
All responsive documents presently known by Licensee to be within its possession or control will be produced.
Request No.17.
Request:
Please produce for inspection and copying the following documents, generated or originated from January 1,1985 to the present:
a.
All maintenance requests
- b. All nonconformance Reports (NCRs).
c.
All Licensee Event Reports (LERs), and evaluation material-(PRO's, PORC minutes, etc.)
- d. All Engineering Design Change Requests (EDCRs) e.
All Plant Design Change Requests (PDCRs) f.- All Plant Alteration Requests (PARS) 8 All Temporary Modifications (TMs)
- h. All Temporary Mechanical Bypass Requests (MBRs) 1.
All Temporary Lifted Lead and Jumper Requests (LL/JRs)
- j. All Potential Reportable Occurrence Reports (PROS)
- k. ~ All Plant Information Reports (PIRs) 1.
All Plant Performance Monitoring Memoranda
Response
Licensee objects to this request as being overbroad and unduly burden-some and also on the ground that some of the items requested clearly lack relevance to the admitted contention.
L Without waiving these objections, but rather expressly relying upon the same, Licensee will produce the documents requested in items a., h., l., and I., and those of items b., c., J., and k. that arise out of a maintenance operation.
Request No.18.
Request:
Please provide a copy of the index to the maintenance and surveil-lance records ("The Visicard system") for each Vermont Yankee plant structure, system and cornponent, and produce for inspection and copying the surveillance and maintenance records system for each plant structure, system and component. Included in this request are the surveillance and maintenance records referred to in Section 3.2.2.3 of Attachment 2 of the application.,
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Response
Licensee objects to this request (except with respect to the index, which will be produced) as being overbroad and unduly burdensome.-
Without waiving these objections, but rather expressly relying upon the same, Licensee produce the documents requested.
Request No.19.
-i Request:
Please provide a copy of the index for vendor technical manuals, and produce the vendor technical manuals for inspection and copying.
Response
Licensee objects to this request (except with respect to the index, which j
will be produced) as being overbroad and unduly burdensome.
{
Without waiving these objections, but rather expressly relying upon the same, Licensee will make available any specific manuals which SOV requests.
Request No. 20.
1 Request:
i For the vendor manual update program at the Vermont Yankee plant:
J I
a.
Produce for inspection and copying the procedure which governs the Vendor Manual Update Program.
- b. Produce for inspection and copying the documentation of the l
results of the quality assurance audits relating to vendor manuals 1
or the vendor manual update program, including audit reports, 4
reports to management, audit check lists, handwritten check lists, i
and informal notes, as identified in response to Vermont Interrogatory (Set No.1) No.16, sub-part d. If in response to Vermont Interrogatory (Set No.1) No.16, sub-part d, Vermont Yankee has not identified any or all documents requested to be identified by that interrogatory, produce for inspection and copying all such documents.
e
Response
All responsive documents presently known by Licensee to be within its possession or control will be produced.
L Request No. 21.
Request:
Please produce for inspection and copying all documents related to the
" Computerized Maintenance Material Management System (CMMMS)"
referred to in BVY 89-75, including, but not limited to, the develop-ment plan referred to in BVY 89-75, all assessment documentation referred to in BVY 89-86, the system description, bid specification, purchase specification, and all internal and external correspondence, with all attachments.
Response
Licensee will produce the documents identified in the response to Interrogatory No.17, except those documents or portions thereof that contain l
budget or economic information, as to which Licensee will produce such portions to SOV if SOY undertakes, or the Board orders, that such informa-tion not be disclosed by SOY to any other person. Licensee objects to so much of this request as calls for the production of confidential and proprie-tary information submitted to Vermont Yankee by bidders. Licensee hereby requests, pursuant to 10 C.F.R. 6 2.740(c)(6), that the Board enter a protective order that such confidential and proprietary bidder information not be produced.
Request No. 22.
Request:
If bids have been received for the CMMMS identified in the foregoing document production request, but the supplier has not been ~
chosen, please produce for inspection and copying the technical description portions (exclusive of financial portions) of each bid.
Response
Licensee objects to this request to the extent that it could be construed to seek confidential and proprietary information submitted to Vermont Yankee by bidders. Licensee hereby requests, pursuant to 10 C.F.R. Q 2.740(c)(6),
that the Board enter a protective order that such confidential and proprietary -
bidder information not be produced. -
t I
Request No. 23.
Request:
Please produce for inspection and copying all documents related to containment integrity testing (i.e., testing in accordance with 10 CFR 50, Appendix J) during the life of the Vermont Yankee plant, including, but not limited to, all test reports, licensee event reports, test results, calibration records, internal memoranda, maintenance requests, correspondence, and contractor records.
Response
Licensee objects to this request on the grounds that the subject thereof is not within the scope of the admitted contention.
Without waiving this objection, but rather expressly relying upon the same, Licensee will produce all responsive documents presently known to be within its possession or control.
Request No. 24.
Request:
Please provide a copy of "the plant master equipment list for safety-related equipment" that is referenced in Enclosure i of BVY 89-75.
R:sponse:
The information requested is contained within a computer data base, which will be made available.
Request No. 25.
Request:
Please provide a copy of the current or most recent Master Equipment List for Environmentally Qualified (EQ) equipment that is referenced in Enclosure 1 of BVY 89-75.
Response
Licensee objects to this request of the grounds that the subject thereof is not within the scope of the admitted contention. i
3,
- Request No. 26.
Request:
Please provide a copy of the index for all environmental qualification -
documentation reports and qualification worksheets prepared in accordance with 10 CFR 50.49.
Response
b Licensee objects to this request of the grounds that the subject thereof is not within the scope of the admitted contention.
Request No. 27.
Request:
Please produce for inspection and copying the reports and qualifica-tion worksheets listed on the-index in the foregoing document production request, include the reports and worksheets referred to in Section 3.2.2.2 of Attachment 2 of the application.
Response
Licensee objects to this request of the grounds that the subject thereof is not within the scope of the admitted contention.
Request No. 28.
Request:
Please produce for inspection and copying all documents identified as references in the qualification documentation reports produced in response to the foregoing document production request.
Response
Licensee objects to this request of the grounds that the subject thereof is not within the scope of the admitted contention.
Request No. 29.
Request:
Please provide copies of all documents which identify the environ-mental conditions of each area of the Vermont Yankee plant evaluated -
as part of your 10 CFR 50.49 evaluation, including those areas considered to be mild environments.
Response
Licensee objects to this request of the grounds that the subject thereof is ~
not within the scope of the admitted contention.
Request No. 30.
Request:
Please provide copies of all documents not provided as part of the foregoing document production request which identify the environ-mental conditions of each area of the. Vermont Yankee plant which houses systems or components "whose failure can cause or adversely affect a transient or accident that significantly challenges structures, systems and components relied upon for the integrity of the reactor coolant pressure boundary, safe shutdown, or accident mitigation"-
(quoted from sub-part (b) of the definition of structures, systems and components).
Response
Licensee objects to this request of the grounds that the subject thereof is not within the scope of the admitted contention.
Request No. 31.
Request:
Please produce for inspection and copying:
- a. All documents identified in response to Vermont Interrogatory (Set No.1) No. 25, sub-part b, which indicate the bases for the qualified life, design life and installed life of the structures, systems and components,
- b. All documents identified in response to Vermont Interrogatory (Set No.1) No. 25, sub-part c, which describe the manner in which qualified life, design life or installed life is determined and demonstrated for each structure, system or component.
c.
All written procedures identified in response to Vermont Interrogatory (Set No.1) No. 25, sub-part d, which govern the determination of qualified life, design life and installed life of each category of equipment. -
.s.
3 m
u d.
All documents describing the results of quality assurance audits since January 1,1988, which reviewed the adequacy of the process '
of determining qualified life or design life of structures, systems and components including audit reports, audit check lists, informal check lists and handwritten notes.
4 i
If in response to Vermont interrogatory (Set No.1) No. 25 Vermont Yankee has not identified any or all documents requested to be identified by that interrogatory, produce for inspection and copying
- l all such documents.
Response
l Licensee objects to this request of the grounds that the subject thereof is not within the scope of the admitted contention.
Request No. 32.
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Request '
(
Please produce for inspection and copying all documents available to l
you providing failure rate information on the structures, systems and l
components of the plant, include documents which contain industry i-wide information, as well as documents which contain information specific to the Vermont Yankee plant, i
Response
Interpreting " failure rate information"in the same manner as in Licensee's answer to SOV's Interrogatory No. 26, Licensee will produce the documents identified in that response, other than the database. Licensee objects to the production of or access to the database referred to in the response to Inter-rogatory No. 26, on the ground that the database is the property of another (INPO).
l l:
Request No. 33.
7 I
Request:
Please produce for inspection and copying the failure rate data base-being used for the IPE evaluation referred to in BVY 89-100.
Response
Licensee objects to this request on the grounds that the subject thereof is not within the scope of the admitted contention. C
lc
- i 4
5 Request No. 34.
Request:
Please produce for inspection and copying all purchase specifications for Vermont Yankee plant structures, systems and components.
Provide a copy to [ sic) the index for these specifications, i
Response
Licensee objects to this request of the grounds that the subject thereof is~
not within the scope of the admitted contention.
Request No. 35.
Request:
Please produce for inspection and copying all documents as identified in response to Vermont Interrogatory (Set No.1) No. 28, establishing procurement quality control requirements for the structures, systems and components of the Vermont Yankee plant. If in response to Vermont Interrogatory (Set No.1) No. 28 Vermont Yankee has not i
identified any or all documents requested to be identified by that interrogatory, produce for inspection and copying all such documents.
Response
Licensee objects to this request of the grounds that the subject thereof is not within the scope of the admitted contention.
Request No. 36.
Request:
Please produce for inspection and copying all documents as identified in response to Vermont Interrogatory (Set No.1) No. 29, which demonstrate that the procurement quality control requirements were satisfactorily completed. If in response to Vermont Interrogatory (Set No.1) No. 29 Vermont Yankee has not identified any or all docu-ments requested to be identified by that interrogatory, produce for inspection and copying all such documents, i
Response
Licensee objects to this request of the grounds that the subject thereof is not within the scope of the admitted contention. - - - - - - - - - -
Request No. 37.
Request:
Please produce for inspecGn and copying all documents as identified in response to Vermon Interrogatory (Set No.1) No. 30, establishing construction quality control and quality assurance requirements for the structures, systems and components of the Vermont Yankee plant.
If in response to Vermont Interrogatory (Set No.1) No. 30 Vermont Yankee has nce identified any or all documents requested to be identified by 'nat interrogatory, produce for inspection and copying all such docu.nents.
Respense:
Licensee objects to this caquest of the grounds that the subject thereof is not within the scope of the admitted contention, t
Request No. 38.
Request:
Please produce for inspection and copying all documents as identified l
in response to Vermont Interrogatory (Set No.1) No. 31, which i
demonstrate that the construction quality control and quality as-l surance requirements were satisfied. If in response to Vermont Interrogatory (Set No.1) No. 31 Vermont Yankee has not identified any or all documents requested to be identified by that interrogatory, produce for inspection and copying all such documents.
Response
Licensee objects to this request of the grounds that the subject thereof is not within the scope of the admitted contention.
Request No. 39.
Request:
Please produce for inspection and copying all documents as identified in response to Vermont Interrogatory (Set No.1) No. 32, establishing inservice testing and inservice inspection = requirements for the structures, systems and components of the Vermont Yankee plant. If in re~sponse to Vermont Interrogatory (Set No.1) No. 32 Vermont Yankee has not identified any or all documents requested to be identified by that interrogatory, produce for inspection and copying all such documents..
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Response
All responsive documents presently known by Licensee to be within its possession or control will be produced.
Request No. 40.
Request:
Please produce for inspection and copying all documents as identified in response to Vermont Interrogatory (Set No.1) No. 33, which demonstrate that the inservice testing and inservice inspection requirements were satisfactorily completed. Specifically include the records of inspections completed under the ISI Program referred to in Section 3.2.2.1 of Attachment 2 of the application. If in response to Vermont Interrogatory (Set No.1) No. 33 Vermont Yankee has not identified any or all documents requested to be identified by that interrogatory, produce for inspection and copying all such documents.
Response
All responsive documents presently known by Licensee to be within its possession or control will be produced.
Request No. 41.
Request:
Please produce for inspection and copying all documents as identified in response to Vermont Interrogatory (Set No.1) No. 35, establishing the storage requirements for each structure, system and component, before installation, if in response to Vermont Interrogatory (Set No.
- 1) No. 35 Vermont Yankee has not identified any or all documents requested to be identified by that interrogatory, produce for inspec-tion and copying all such documents.
Response
Licensee objects to this request of the grounds that the subject thereof is not within the scope of the admitted contention.
Request No. 42.
Request:
Please produce for inspection and copying all documents as identified in response to Vermont Interrogatory (Set No.1) No. 36, establishing the procedures which established storage methods during the c
construction period. If in response to Vermont Interrogatory (Set No.
- 1) No. 36 Vermont Yankee has not identified any or all documents requested to be identified by that interrogatory, produce for inspec--
tion and copying all such documents.
Response
Licensee objects to this request of the grounds that the subject thereof is not within the scope of the admitted contention.
Request No. 43.
Request:
Please produce for inspection and copying all documents as identified in response to Vermont Interrogatory (Set No.1) No. 37, establishing the procedures which have established storage methods for structures, systems and components since initial operation, if in response to Vermont Interrogatory (Set No.1) No. 37 Vermont Yankee has not identified any or all documents requested to be identified by that interrogatory, produce for inspection and copying all such documents.
Response
Licensee objects to this request on the grounds that the subject thereof is not within the scope of the admitted contention.
Without waiving this objection, but rather expressly relying upon the same, Licensee will produce all responsive documents presently known to be within its possession or control.
Request No. 44.
Request:
Please produce for inspection and copying all documents as identified in response to Vermont Interrogatory (Set No.1) No. 38, which verify the manner in which structures, systems and components are stored prior to installation. If in response to Vermont Interrogatory (Set No.
- 1) No. 38 Vermont Yankee has not identified any or all documents requested to be identified by that interrogatory, produce for inspection and copying all such documents.
Response
Licensee objects to this request on the grounds that the subject thereof is not within the scope of the admitted contention....... _. _ _ _. _ _
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k Without waiving this objection, but rather expressly relying upon the same, Licensee will produce all responsive documents presently known to be within its possession or control.
Request No. 45.
Request:
Please produce for inspection and copying all documentation of quality assurance audits of the storage methods during the construc-tion period, as identified in response to Vermont Interrogatory (Set No.1) No. 40. If in response to Vermont Interrogatory (Set No.1)
No. 40 Vermont Yankee has not identified any or all documents requested to be identified by that interrogatory, produce for inspec-tion and copying all such documents.
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Response
Licensee objects to this request on the grounds that subject thereof is j
not within the scope of the admitted contention.
Request No. 46.
l l..
Request:
I l'
Please produce for inspection and copying all documents containing l
information regarding the environmental conditions which structures, systems and components of the Vermont Yankee plant experienced during the period between the construction period date and the operating license date. Include all available information on pres-sure-temperature histories for storage locations and for as-installed in-plant environmental conditions before operation.
Response
Licensee objects to this request of the grounds that the subject thereof is not within the scope of the admitted contention.
Request No. 47.
Request:
Please provide copies of all Quality Assurance Department Trend Reports identified in DVY 89-86.
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i
Response
Licensee objects to this request on the grounds that it is overbroad,'
Without waiving this objection, but rather expressly relying upon the.
same, Licensee will produce the relevant portions of the requested documents.
Request No. 48.
Request:
Please provide a copy of Vermont Yankee's " complete, independent reassessment of the subject [lNPO list of 125 Significant Operating Event Reports] SOER's as well as the governing review process" (quoted from BVY 89-86).
Response
p Licensee objects to this request on the grounds that it is overbroad.
i Without waiving this objection, but rather expressly relying upon the-same, Licensee will produce the relevant portions of the requested documents.
Request No. 49.
Request:
For the activity of reconstituting the design basis, as described by Mr.
Donald Reid at the meeting with NRC Region I in King of Prussia, PA, on January 26,1989:
l L
Please produce for inspection and copying the procedure by which a.
the design basis reconstitution activity is controlled.
l
- b. Please produce for inspection and copying all documents containing or describing the work product from the design basis l
l' reconstitution activity.
Response
Each of the procedures identified in the response to Interrogatory No. 42 will be produced.
21
rMt.
4 1
'1 Request No. 50. -
Request:
Please produce for inspection and copying all documents describing.
the external events and natural phenomena for which the Vermont Yankee plant is designed, for each of the design conditions and design -
basis events.
Response
Each of the procedures identified in the response to interrogatory No.' 43 will be produced.
Request No. 51.
Request:
I Please produce for inspection and copying all documents related to t
any safety system functional inspections (SSFis) performed for the I-Vermont Yankee plant. This request includes, but is not limited to, l
all internal correspondence and correspondence with Westec Incor-1 porated, or other contractors; all Westec Incorporated inspection results, records, data sheets, findings, internal memoranda; all documentation related to resolution of inspection findings; and the SSFI reports.
Response
All responsive documents presently known by Licensee to be within its possession or control will be produced.
l Request No. 52.
Request:
Please produce for inspection and copying INPO reports identifying or containing reliability information of Vermont Yankee plant-speci-fic equipment, including those documents identifying the Vermont Yankee Uninterruptible Power Supply (UPS) as a reliability outiier.
Response
The Component Failure Analysis Reports (CFARs) identified in the response to Interrogatory No. 45 will be produced provided that VY deter-mines that it is authorized by INPO, the owner of the information in the database, to do so.
s.
)
Request No. 53.
Request:
Please provide a copy of the Yankee Atomic Electric Company Operational Quality Assurance Manual (YOQAP-l-A) and a copy of the Vermont Yankee Safety Classification Manual, referred to in Section 3.2.2.1 of Attachment 2 of the application.
Response
7 Licensee objects to this request of the grounds that the subject thereof is not within the scope of the admitted contention.
Request No. 54.
Request:
Please produce for inspection and copying all procedures applicable to requalifying components to a longer service life, as stated in Sections 3.2.2.2 and 3.4.3 of Attachment 2 of the application.
Response
Licensee objects to this request of the grounds that the subject thereof is not within the scope of the admitted contention.
Request No. 55.
Request:
Produce for inspection and copying each document identified in response to Vermont Interrogatory (Set No.1) No. 50, identifying the location of each vendor recommendation for each structure, system and component, if in response to Vermont Interrogatory (Set No.1)
No. 50 Vermont Yankee has not identified any or all documents requested to be identified by that interrogatory, produce for inspec-tion and copying all such documents.
Response
Please see the response to Interrogatory No. 50, which stated that no document as such of the nature described exists. The Licensee will produce for inspection a copy of any vendor manual requested, and thereafter it will produce any documentation known to be in its possession and control evidencing the disposition of any " vendor recommendation" specifically identified by SOV.,
3 l
Request No. 56.
Request:
Produce for inspection and copying all documents identified in response to Vermont Interrogatory (Set No.1) No. 52, sub-part c, which are part of the evaluation or justification for not precisely following vendor recommendations, if in response to Vermont Interrogatory (Set No.1) No. 52, sub-part c, Vermont Yankee has not identified any or all documents requested to be identified by that interrogatory, produce for inspection and copying all such documents.
t
Response
The Licensee will produce the documents requested in accordance with its response to Request No. 55, above, which captures any document described in this request.
Request No. 57.
1-Request:
Produce for inspection and copying all procedures, policy statements and memoranda providing direction or instructions regarding following vendor recommendations for maintenance or vendor recommendations for maintaining qualified life or design life.
Response
l l'
All responsive documents presently known by Licensee to be within its possession or control will be produced.
l 1
j Request No. 58.
Request:
Please produce for inspection and copying all procedures guiding personnel in the determination of failure and root cause analysis.
Response
All responsive documents presently known by Licensee to be within its l
possession or control will be produced.
Li Request No. 59.
Request:
Please produce for inspection and copying all documents as identified in response to Vermont interrogatory (Set No.1) No. 57, explaining the method by which failure and root cause evaluations are performed and documenting these evaluations, if in response to Vermont Interrogatory (Set No.1) No. 57 Vermont Yankec has not identified any or all documents requested to be identified by that interrogatory, _
produce for inspection and copying all such documents.
Response
With the exception of 'PIRs and NCRs, Licensee will produce the documents identified in the response to interrogatory No. 57; with respect to PIRs and NCRs, Licensee will produce those PIRs and NCRs described in the response to Document Request 17, above. Licenree objects to the production of any other PIRs and NCRs on the ground that such documents are not-relevant to the admitted contention.
Request No. 60.
Request:
Please produce for inspection and copying all documents describing modules, courses, or training segments which train personnel to
- perform failure and root cause evaluations.
Response
All responsive documents presently known by Licensee to be within its possession or control will be produced.
Request No. 61.
Request:
Please produce for inspection and copying all instructions, policy guidances, and memoranda which have been operative since January 1,1988, to provide guidance or instructions to personnel performing root cause evaluations.
Response
All responsive documents presently known by Licensee to be within its possession or control will be produced.
4 -
Request No. 62.
Request:
Please produce for inspection and copying all procedures guiding personnel in the determination of the safety consequences and implications of the failure,inoperability or degradation of structures, systems and components, or of procedural inadequacies.
Response
All responsive documents presently known by Licensee to be within its possession or control will be produced.
Request No. 63.
Request:
Please produce for inspection and copying all documents as identified in response to Vermont Interrogatory (Set No.1) No. 62, explaining i
the method by which the safety consequences and implications of failure, inoperability or degradation of structures, systems and components are performed and documenting these enluations. If in response to Vermont interrogatory (Set No.1) No. 62 Vermont Yankee has not identified any or all documents requested to be identified by that interrogatory, produce for inspection and copying all such documents.
Response
The Licensee will produce the procedures identified in the response to Interrogatory No. 62. Neither did the question there call for nor did the response identify specific documents in which specific analyses are docu-l mented, but rather only the types of documents in which such analyses might be documented. If this request is for the production of the entirety of these types of documents, Licensee objects to the request on the grounds that it is l
grossly overbroad and unduly burdensome and that it is not relevant to the admitted contention, and the Licensee requests a protective order in respect of the same.
Request No. 64.
1 Request:
Please produce for inspection and copying all documents describing training modules, courses, or training segments which train personnel to perform the evaluation of safety consequences and implications of P
failures, inoperabilities and degradations of structures, systems and components.
Response
Licensee incorporates herein its answer to SOV's interrogatory No. 63.
Licensee will produce the relevant portions of its training program.
Request No. 65.
Request:
Please produce for inspection and copying all instructions, policy guidances, and memoranda which have been operative since January 1,1988, to provide guidance or instructions to personnel performing the evaluation of safety consequences and implications of-failures, inoperabilities and degradations of structures, systems and com-ponents.
Response
l All responsive documents presently known by Licensee to be within its 1-possession or control will be produced.
Request No. 66.
Request:
1 For each occurrence in which Vermont Yankee plant equipment has been modified because it has become obsolete, as referred to in Section 3.3.2 of Attachment 2 of the application, please produce for inspection and copying all documentation describing the method by 1
which the determination of obsolescence was made.
Response
Licensee objects to this request of the grounds that the subject thereof is not within the scope of the admitted contention.
Request No. 67.
Request:
For each occurrence in which Vermont Yankee plant equipment has been modified because it has reached its end-of-useful life, as referred to in Section 3.3.2 of Attachment 2 of the application, please produce for inspection and copying all documentation describing the method by which the determination of end-of-usefullife was made. -
(
Response
'i No such documents exist -- see Licensee's answer to SOV's Interrogatory No. 67. Documents relating to the replacements identified in that inter-rogatory will be produced.
Request No. 68.
Request:
Please provide copies of all trend analyses for safety-related electrical equipment not covered by the Equipment Qualification Program, referred to in Section 3.4.3 of Attachment 2 of the application.A
Response
All responsive documents presently known by Licensee to be within its l
possession or control will be produced.'
Request No. 69.
Request:
(
l Please produce for inspection and copying the strict construction procedures referred to in Section 3.4.4.1 of Attachment 2 of the L
application.
j
Response
Licensee objects to this request of the grounds that the subject thereof is not within the scope of the admitted contention.
Request No. 70.
Request:
Please produce for inspe.: tion and copying all documents describing.
the good maintenance pr.ictices for corrosion prevention, concrete surface repair and protective coating upkeep, referred to in Sections l
3.4.4.1 and 3.5 of Attachment 2 of the application.
Response
l Licensee incorporates herein its answer to SOV's Interrogatory No. 71.
, l
i:
..7
+
Request No. 71.
Request:
Please produce for inspection and copying the 18 references identified in Enclosure A,' Containment Paint Evaluation Basis," of BVY 89-69.
Response
Each of the documents identified in the response to Interrogatory No. 79 will be produced.
l Request No. 72.
Request:
Please provide a copy of Operations Department Primary Containment Surveillance procedure OP 4115, and produce for inspection and copying all documentation of surveillances, including, but not limited to, all generated documentation on VYOPF 4115.06, as referenced on page 2 of Enclosure A of BVY 89-69.
Response
All responsive documents presently known by Licensee to be within its possession or control will be produced.
Request No. 73.
Request:
Please produce for inspection and copying, all surveillances of containment performed under OP 4115, and all. surveillances performed or documented under earlier procedures or methods,
Response
All responsive documents presently known by Licensee to be within its possession or control will be produced.
Request No. 74.
Request:
Please provide copies of all results and documentation of the inspections of paint scraping activities for drywell and torus, referenced on page 5 of Enclosure A of BVY 89-69.
l
Response
All responsive documents presently known by Licensee to be within its possession or control will be produced.
Request No. 75. -
Requesd Please produce for inspection and copying all documents describing the design of the strainers for the core spray, RHR, HPCI and RCIC pump suctions.
Response
Licensee objects to this request on the grounds that the subject thereof is not within the scope of the admitted contention.
Without waiving this objection, but rather expressly relying upon the same, Licensee will produce all responsive documents presently known to be within its possession or control.
Request No. 76.
Request:
[
i Please produce for inspection and copying all procurement specifica-tions for the core spray, RHR, HPCI and RCIC pumps.
Response
1 l
Licensee objects to this request on the grounds that the subject thereof is not within the scope of the admitted contention.
Without waiving this objection, but rather expressly relying upon the-same, Licensee will produce all responsive documents presently known to be within its possession or control.
Request No. 77.
Request:
I-Please produce for inspection and copying all documents which document the minimum net positive suction head for the core spray, RHR, HPCI and RCIC pumps..
'e
Response
Licensee objects to this request on the grounds that the subject thereof is not within the scope of the admitted contention.
Without waiving this objection, but rather expressly relying upon the same, Licensee will produce all responsive documents presently known to be within its possession or control.
Request No. 78.
Request:
For any minimum net positive suction head acceptance tests which were required or performed for the core spray, RHR,liPCI and RCIC pumps, please produce for inspection and copying the following:
a.
All test reports i
b.
All test specifications and procedures by which tests were performed -
g L
e c.
All liccasee and licensee's agent documentation demonstrating approval of the test specification or test procedure.
1
Response
L Licensee objects to this request on the grounds that the subject thereof is L
not within the scope of the admitted contention, l
i Without waiving this objection, but rather expressly relying upon the L
same, Licensee will produce all responsive documents presently known to be within its possession or control.
I Request No. 79.
L l
Request:
l-Please produce for inspection and copying all documents which establish the quality assurance or quality control inspection require-ments for the tests identified in the preceding document production l
request.
Response
Licensee objects to this request on the grounds that the subject thereof is not within the scope of the admitted contention..
Without waiving this objection, but rather expressly relying upon the same, Licensee will produce all responsive documents presently known to be within its possession or control.
Request No. 80.
Request:
Please produce for inspection and copying all quality assurance or quality control inspection reports and documentation, and all reviews of test results for the tests identified in document production request 78.
Response
Licensee objects to this request on the grounds that the subject thereof is not within the scope of the admitted contention.
Without waiving this objection, but rather expressly relying upon the same. Licensee will produce all responsive documents presently known to be within its possession or control.-
Request No. 81.
Request:
Please produce for inspection and copying all calculations which identify the available net positive suction head for the core spray, RHR, HPCI and RCIC pumps.
Response
Licensee objects to this request on the grounds that the subject thereof is not within the scope of the admitted contention.
Without waiving this objection, but rather expressly relying upon the same. Licensee will produce all responsive documents presently known to be within its possession or control.
Request No. 82.
Request:
Please provide for inspection and copying all documents which identify the size of the largest particle or debris which the core spray, RHR, HPCI and RCIC pumps, respectively, can pass.
s
Response
t Licensee objects to this regrest 6 de mounds that the subject thereof is not within the scope of the admitted unf+1 tion.
Without waiving this objection, but r',+r axpressly relying upon the same. Licensee will produce all ree;onsht & coments presently known to be within its possession or control.
Request No. 83.
Request:
Please produce for inspection and copying all documents which establish the original and the current licensing basis for the coating system in the drywell and torus.
Response
Licensee objects to this request to the extent that it is duplicative of prior requests.
Each of the documents identified in the response to Interrogatory No. 94 -
will be produced.
Request No. 84.
Request:
Please produce for inspection and copying all codes which govern the coating requirements for the drywell and torus.
Response
Licensee incorporates herein its answer to SOV's Interrogatory No. 98.
The documents identified in that answer will be produced.
Request No. 85.
Request:
Please produce for inspection and copying all documentation of the review of maintenance requests which is identified on page 2 of 5 of LER 86-04..
.e W
Response
Al.' respontive documents presently known by Licensee to be within its possestion or control will be produced, Request No. 86.
Request:
Please produce for inspection and copying all documentation of the-departmental review of surveillance procedures which is identified on page 5 of 5 of LER 86-04,
Response
All responsive documents presently known by Licensee to be within its possession or control will be produced, Request No. 87.
Request:
Please produce for inspection and copying the procedure and documentation of the " closer look [at) drawings and procedures" identified on page 5 of 5 of LER 86-04,
Response
All responsive documents presently known by Licensee to be within its possession or control will be produced.
Request No. 88.
Request:
Please produce for inspection and copying all documents describing the Vermont Yankee program to determine any significant aging mechanisms for the structures, systems and components of the Vermont Yankee plant, other than harsh environment equipment covered by 10 CFR 50.49.
Response
{
Licensee incorporates herein its answer to SOV's Interrogatory No,105, The documents identified in that answer will be produced..
r l
Request No. 89.
Request:
For the Vermont Yankee program to determine any significant aging mechanisms for the structures, systems and comoonents of the Vermont Yankee plant, other than harsh environment equipment covered by 10 CFR 50.49, please prodJee for inspection and copying all documents which identify the criteria for determining if an aging criteria is significant and all documents which identify the bases for these criteria.
Response
Licensee incorporates herein its answer to SOV's Interrogatory No.106.
The documents identified in that answer will be produced.
Request No. 90.
Request:
Please produce for inspection and copying the Vermont Yankee program policy directive and implementing procedures for qualifying safety system equipment other than those equipment covered by 10 CFR 50.49.
Response
All responsive documents presently known by 1.icensee to be within its possession or control will be produced.
Request No. 91.
Request:
Please produce for inspection and copying all documents upon which you rely for claiming that there is reasonable assurance (within the mening of 10 CFR 50.57(a)(3)), if you so claim, that the paint undercoat (primer) of the drywell and torus will remain intact in the extended period, and that the metal surface will be protected.
Response
Licensee incorporates herein its answer to SOV's Interrogatory No.110.
The documents identified in that answer will be produced.
.3
s
-0 Request No. 92.
Request:
Please produce for inspection and copying all documents upon which you rely for claiming that there is reasonable assurance (within the meaning of 10 CFR 50.57(a)(3)), if you so claim, that peeling paint in containment will break into small pieces so smali they will pass through the pump suction screens and core spray nozzle without causing clogging.
1
Response
Licensee incorporates herein its answer to SOV's Interrogatory No.111.
The documents identified in that answer will be produced.
Request No. 93.
Request:
Please produce for inspection and copying all documents upon which you rely for claimh)g that there is reasonable assurance (within the meaning of 10 CFR 50,574X3)), if you so claim, that drywell paint failure in the extended period will be in the form of small chips which have a higher density than water.
Response
Licensee incorporates herein its answer to SOV's Interrogatory No,112.
The documents identified in that answer will be produced.
Request No. 94.
Rcquest:
Please produce for inspection and copying all documents upon which you rely for claiming that there is reasonable assurance (within the meaning of 10 CFR 50.57(a)(3)), if you so claim, that the comprehen-sive and formal maintenance program document identified in BVY 89-75 is effective for providing clearly documented objectives, j
policies, responsibilities, authorities, programmatic controls, and comprehensive and structured reviews of Vermont Yankee plant maintenance requirements, at present, and for the extended period.
l
Response
Not applicable -- see Licensee's answer to SOV's Interrogatory No,113, i
I i
l.
[
i O
O Request No. 95.
Request:
Please produce for inspection and copying all documents upon which you rely for claiming that there is reasonable assurance (within the meaning of 10 CFR 50.57(a)(3)), if you so claim, that the Com-puterized Maintenance Material Management System, identified in BYY 89-75, if implemented, will be effective for its intended use in the maintenance progra:n in the extended period.
Response
Not soplicable -- see Licensee's answer to SOV's Interrogatory No,114.
Request No. 96.
Request:
Please produce for inspection and copying all documents upon which you rely for claiming that there is reasonable assurance (within the meaning of 10 CFR 50.57(a)(3)),if you so claim, that a maintenance staff, with the requisite nuclear skills and knowledge, can be retained in the extended period.
Response
Licensee incorporates herein its answer to SOV's Interrogatory No.115.
The documents identified in that answer will be produced.
Request No. 97.
Request:
Please produce for inspection and copying all documents upon which you rely for claiming that there is reasonable assurance (within the meaning of 10 CFR 50.57(a)(3)), if you so claim, that trend analyses will determine decreased equipment reliability and expected life in the extended period.
Response
Not applicable -- see Licensee's answer to SOV's Interrogatory No,116.
(The documents referred to therein will be produced.) -
Request No. 98.
Request:
Pleate produce for inspection and copying all documents upon which you rely for claiming that there is reasonable assurance (within the meaning of 10 CFR 50.57(a)(3)). If you so claim, that all components with service lives less than Vermont Yankee plant service life will be determined and replaced, requalified or upgraded.
Response
Licensee incorporates herein its answer to SOV's Interrogatory No.117.
The documents identified in that answer will be produced.
Request No. 99.
Request:
Please produce for inspection and copying all documents upon which you rely for claiming that there is reasonable assurance (within the meaning of 10 CFR 50.57(a)(3)), if you so claim, that the maintenance and surveillance program in the extended period will be effective in limiting containment leakage to the leakage li' nits in the current licensing basis.
Response
l Licensee incorporates herein its answer to SOV's Interrogatory No,118.
The documents identified in that answer will be produced.
l Request No.100.
l l
Request:
Please produce for inspection and copying all documents upon which you rely for claiming that there is reasonable assurance (within the meaning of 10 CFR 50.57(a)(3)). if you so c! alm, that age-related degradation of active and par:ive mechanical components will be identified and corrected by the in service inspection / testing and maintenance program, and that component functional capability will l
be maintained, in the extended period, i
Response
Licensee incorporates herein its answer to SOV's Interrogatory No.119.
l The documents identified in that answer will be produced.
i..
c O
Request No.101.
Request:
Please produce for inspection and copying all documents upon which you rely for claiming that there is reasonable assurance (within the meaning of 10 CFR 50.57(a)(3)), if you so claim, that structural integrity of Vermont Yankee plant structures will be maintained in accordance with the current licensing basis in the extended period.
Response
Licensee incorporates herein its answer to SOV's Interrogatory No.120.
The documents identified in that answer will be produced.
Request No.102.
Request:
Please produce for inspection and copying all documents upon which you rely for claiming that there is reasonable assurance (within the meaning of 10 CFR 50.57(a)(3)), if you so claim, that any policy and implementing procedures for controlling and updating manufacturer technical manuals, contemplated in BVY 89-75, will be effective for these purposes in the extended period.
Response
Licensee incorporates herein its answer to SOV's interrogatory No.121.
The documents identified in that answer will be produced.
Request No.103.
Request:
Please produce for inspection and copying all documents upon which you rely for claiming that there is reasonable assurance (within the meaning of 10 CFR 50.57(a)(3)), if you so claim, that revisions to the Maintenance Request Procedure (AP 0021), contemplated in BVY l
89-75, will be effective to control post maintenance testing in the extended period.
Response
Licensee incorporates herein its answer to SOV's Interrogatory No.122.
l The documents identified in that answer will be produced.
l l.
Request No.104.
Request:
Please produce for inspection and copying all documents upon which you rely for claiming that there is reasonable assurance (within the meaning of 10 CFR 50.57(a)(3)), if you so claim, that Maintenance Requests for completed maintenance activities will be completed in a tiinely fashion in the extended period.
Response
Licensee incorporates herein its answer to SOV's Interrogatory No.123.
The documents identified in that answer will be produced.
Request No.105.
Request:
Please produce for inspection and copying all docur. tents presented to the NRC Maintenance Team to demonstrate the adequacy of Vermont Yankee Plant operability, equipment availability and plant material condition (as described in "overall plant performance" in NRC Temporary Instruction (TI) 2515/97 dated 11/03/81).
Response
All responsive documents presently kncwn by Licensee to be within its possession or control will be produced, j
Request No.106.
Request:
Please produce for inspection and copying all documents which l
provide information to show that paint failure in the drywell and torus will not fall in sheets rather than chips when exposed to j
t l
radiation, temperatures, steam, and chemical conditions postulated for design basis accidents.
Response
Without waiving this objection, but rather expressly relying upon the same, Licensee will produce all responsive documents presently known to be within its possession or control. !
i Request No.107.
Request:
Please produce for inspection and copying all documents which demonstrate that coating / paints will not experience sheet-mode failures similar to coating failures identified in NRC Information Notice 85-24 and INPO SER 68-83.
Response
Without waiving this objection, but rather expressly relying upon the same. Licensee will produce all responsive documents presently known to be within its possession or control.
Request No.10g.
Request:
Please produce for inspection and copying all documents which Vermont Yankee has reviewed or otherwise has relied on regarding coating and paint failures identified in NRC Information Notice 85-24 and INPO SER 68-83.
Response
Licensee objects to this request on the grounds that the subject thereof is not within the scope of the admitted contention.
Without waiving this objection, but rather expressly relying upon the same. Licensee will produce all responsive documents presently known to be within its possession or control.
Request No.109.
Request:
Please produce for inspection and copying all files documenting review of the industry safety issues identified in Section 2.3.6 of IR
[
89-80.
Response
Licensee objects to this request on the ground that it appears to be beyond the scope of ue admitted contention.
l 1
r i
D e
Without waiving the foregoing objection, but rather expressly relying upon the same, Licensee is unable to find a reference to any ' review of the industry safety issues" contained within Section 2.3.6 of IR 89-80.
Request No.110.
Request:
Please identify, and produce for inspection and copying, all docu-ments presented to the NRC Maintenance Team to demonstrate the adequacy of the following aspects of " Maintenance Implementation,"
stated in NRC Temporary instruction (TI) 2515/97 dated 11/03/88, and which were not described in IR 89-80:
a.
Work prioritir.ation l
- b. Backlog controls
- c. Maintenance procedures
Response
Licensee objects to this request to the extent that it is duplicative of prior requests.
Without waiving this objection, but ratN expressly relying upon the same, Licensee will produce all responsive documents known to be within i
L its possession or control.
Request No,111, l
Request:
Please identify, and produce for inspection and copying, all docu-1 ments relied upon during, and all documents created as a result of, the i
investigation of the scratches on machined surfaces inside the 'B" diesel generator engine, noted in paragraph 3.10 of IR 89-80.
Response
All responsive document' 7resently known by Licensee to be within its possession or control will be oduced.,,
i
I I
Request No.112.
Request:
Please identify, and produce for inspection and copying, all docu-ments presented to the NRC Maintenance Team to demonstrate that having no Master Equipment List caused no confusion, as concluded in paragraph 3.10 of IR 89 80.
Response
All responsive documents presently known by Licensee to be within its passession or control will be produced.
Request No.113.
Request:
Please identify, and produce for inspection and copying, all proce-dures which contain requirements for post maintenance testing.
Response
All responsive documents pretently known by Licensee to be within its possession or control will be produced.
Request No,114.
Request:
Please identify, and produce for inspection and copying, all docu-ments presented to the NRC Maintenance Team to demonstrate the adequacy of aspects of ' Plant Maintenance Organir.ation" and specifically the Corrective Action System (specified under deficiency Identification, Control and Corrective Action System and Support Interfaces specified by TI 2515/97).
Response
Licensee objects to this request to the extent that it is duplicative of prior requests.
Without waiving this objection, but rather expressly relying upon the same, Licensee will produce all responsive documents known to be within its possession or control. -
f, e
Request No.115.
Request:
Please identify, and provide copies of, all documents relating to failure data and trending for the 24 components mentioned in Paragraph 3.2 of IR 89-80.
Response
Licensee objects to this request to the extent that it is duplicative of prior requests.
Without waiving this objection, but rather expressly relying upon the same. Licensee will produce all responsive documents known to be within its possession or control.
Request No.116.
Request:
Please identify, and produce for inspection and copying, all docu-ments which describe Vermont Yankee's methods for upgrading material to a higher safety classification than originally specified in the purchase order, as noted in paragraph 3.3 of IR 89-80.
Response
Licensee objects to this request on the grounds that the subject thereof is not within the scope of the admitted contention.
Without waiving this objection, but rather expressly relying upon the same, Licensee will produce all responsive documents presently known to be within its possession or control.
I Request No,117.
Request:
Please identify, and produce for inspection and copying, all docu-ments, including but not limited to all written and verbal correspon.
dence with vendors, relating to the root cause analyses for Vermont Yankee's containment leak rate problems described in LER 89-07.
l l,
Ir
.o
Response
All responsive documents presently known by Licensee to be within its possession or control will be produced.
Request No.118.
Request:
Please identify, and produce for inspection and copying, all docu-ments prepared by or for Vermont Yankee containing its comments regarding, or positions on, the proposed NRC Maintenance Rule (53 FR 47822).
P
Response
Licensee is not aware of any such documents.
Request No.119.
Request:
Please identify, and provide copies of, all documents which develop, contain or comment on Vermont Yankee's position on Draft Pegula-tory Guide DG-1001.
Response
Licensee is not aware of any such documents.
Request No.120.
l Request:
Please identify, and produce for inspection and copying, all main-tenance requests, engineering change requests and all other documents approving and allowing installation of the gasket material involved in the failure of the Reactor Core Isolation Cooling (RCIC) valve operator identified in LER 89-14.
Response
All responsive documents presently known by Licensee to be within its possession or control will be produced.
i 1 -.
b'*
Request No.121.
Request:
Please identify, and produce for inspection and copying, all docu-ments which provide vendor recommendations for gasket material and thickness of the gaskets involved in the failure of the Reactor Core Isolation Cooling (RCIC) valve operator identified in LER 89-14.
Response
All responsive documents presently known by Licensee to be within its possession or control will be produced.
Request No.122.
Request:
Please identify, and produce for inspection and copying, all quality assurance and quality control documents which document the inspection,- verification, or approval of the gasket material and thickness of the gaskets involved in the failure of the Reactor Core isolation Cooling (RCIC) valve operator identified in LER 89-14.
Response
All responsive documents presently known by Licensee to be within its l
possession or control will be produced, i
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i R. K. Gad III Jeffrey P. Trout i
Ropes & Gray One International Place Boston, Massachusetts 02110 Telephone: 617-951-7520 Dated: June iI,1990.
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DOCKrilNG & SitiVICI Certificate of Ser9f'cgNCH I, R. K. Gad III, hereby certify that on June 11, 1990, I made service of the within responses to requests for production of documents by mailing copies thereof, first class mail, postage prepaid, as follows:
Robert M. Lazo, Esquire Jerry Harbour Chairman Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S.N.R.C.
U.S.N.R.C.
Washington, D.C. 20555 Washington, D.C. 20555 Frederick J. Shon Adjudicatory File Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board Panel U.S.N.R.C.
U.S.N.R.C.
Washington, D.C. 20555 Washington, D.C. 20555 Anthony Z. Roisman, Esquire Ann P. Ilodgdon, Esquire Cohen, Milstein & Hausfeld Patricia A. Jehle, Esquire Suite 600 U.S.N.R.C.
1401 New York Avenue, N.W.
Washington, D.C. 20555 Washington, D.C. 20005 i
Kurt Janson, Esquire Vermont Department of Public Service 120 State Street Montpelier, Vermont 05602 l
R. K. Gad III
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