ML20056A363

Interrogatories Propounded by Vermont Yankee Nuclear Power Corp to State of VT (Set 5).* W/Certificate of Svc.Related Correspondence

ML20056A363
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	07/24/1990
From:	Trout J ROPES & GRAY, VERMONT YANKEE NUCLEAR POWER CORP.
To:	VERMONT, STATE OF
References
CON-#390-10669 OLA-4, NUDOCS 9008070124
Download: ML20056A363 (11)

Text

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• ATOMIC SAFETY AND LICENSINO BOARD

)

in the Matter of )

) Docket No. 50-271-OLA-4 VERMONT YANKEE NUCLEAR ) (Construction Period POWER CORPORATION ) Recapture)

)

(Vermont Yrnkee Nuclear )

Power Station) )

)

INTERROGATORIES PROPOUNDED BY YERMONT YANKEE NUCLEAR POWER CORPORATION TO THE STATE OF YERMONT (Set No. S)

Pursurint to 10 C.F.R. 6 2.740b, Vermont Yankee Nuclear Power Corpora-tion hereby propounds the following interrogatories to the State of Vermont.

As used in these interrogatories, VYF'PC 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 interrogatories, the term " identify" with respect to a person means to supply the name, current 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 informatiot, 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, custod) or control of SOV.

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i l Your attention is called to the provisions of 10 C.F.R. i 2.740(e) regarding

! the duty of supplementation with respect to answers to interrogatories.

I. Does SOY still intend to litigate the assertions contained in sub part "b"

• of its Contention Vil? If your answer is anything other than an unqualifica se2*tive, then please:  :

l (a) state which silegations (if any) within sub-part *b" SOY no longer '

I intends to assert;  ;

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update your Responses I to the following interrogatories to reflect (b) l all new facts and documents now known to SOY, and to correct '

all statements by SOY which are now r.ot entirely true and complete; i) VYNPC Set No.1. Interrogatories 3,4, and 6;

11) VYNPC Set No. 2, Interrogatories 17-21 and 23 32:

iii) VYNPC Set No. 3, Interrogatory 4; and iv) VYNPC Set No. 4, Interrogatory 3.

l (c) describe in detail every fact and identify every document, other than the facts and documents described and identified in response to (b) above and/or the previous interrogatories listed therein, which SOV contends support the allegations contained in sub-l part "b" of SOV's Contention Vil, other than the allegations l identified in response to (a) above.

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2. Does SOY stillintend to litigate the assertions contained in sub part "c" of its Contention Vil? If your answer is anything other than an unqualified negative, then please:

(a) state which allegations (if any) within sub-part 'c" SOY no longer intends to assert; I

l (b) update your Responses to tiie following interrogatories to reflect all new facts and documents now known to SOY, and to correct i

I The term " Responses", as used in this and all subsequent interrogatorit s, j includes all supplements to the initial answers filed by SOV.

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i all statements by SOY which are now not entirely true and complete:

1) VYNPc Set No.1, Interrogatories 7-10; li) 'YNPCL Ao. 2, Interrogatories 33-40; '

ill) V'. 4 Set No. 3. Interrogatories I and 5-15; and iv) VYNPC Set No. 4. Interrogatories 4,23, and 24.

(c) describe in detail every lact and identify every document, other than the facts and documents described and identified in responte to (b) above and/or the previous interrogatories listed therein, which SOY contends support the allegations contained in sub-part "c" of SOV's Contention VII, other than the allegations identified in response to (a) above.

3. Does SOY still intend to litigate the assertions contained in sub part "d" of its Contention Vil? If your answer is anything other than an unqualified negative, then please:

(a) state which allegations (if any) within sub-part "d' SOY no longer intends to assert; (b) update your Responses to VYNPC Set No. 2, Interrogatories 45-51, to reflect all new facts and documents now known to SOY, and to correct all statements by SOV which are now not entirely true and complete.

(c) describe in detail every fact and identify every document, other than the facts and documents described and identified in respcase to (b) above and/or the previous interrogatories listed therein, which SOY contends support the allegations contained in sub-part "d" of SOV's Contention Vil, other than the allegations identified in response to (a) above.

4. Dou SOY still intend to litigate the assertions contained io sub-part "c" of its Contention Vil? If your answer is anything other than an unqualified negative, then please:

(a) state which allegations (if any) within suetwt "e" SOY no longer intends to assert;

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(b) update your Responses to VYNPC Set No. 2, Interrogatories $2-54, to reflect all new facts and documents now known to SOY, and to correct all statements by SOY which are now not entirely true and complete.

(c) describe in detail every fact and identify every document, other than the facts and documents described and identified in response to (b) above and/or the previous interrogatories listed therein, which SOY contends support the allegations contained in sub-part 'e" of SOV's Contention Yll, other than the allegations identified in response to (a) above.

5. Does SOY still intend to litigate the assertions contained in sub-part 's" of its Contention Vil? If your answer is anything other than an unqualified negative, then please:

(a) state which allegations (if any) within sub-part *g* SOY no longer intends to assert; (b) update your Responses to the followink interrogatories to reflect t all new facts and documents now known to SOY, and to correct all statements by SOY which are now not entirely true and complete:

i) VYNPC Set No. I, Interrogatory 11;

11) VYNPC Set No. 2, Interrogatory 55; lii) VYNPC Set No. 3, Interrogatories 16-21(Ist)2; and -

iv) VYNPC Set No. 4, Interrogatory 25.

(c) describe in detail every fact and identify every document, other than the facts and documents describcd and identified in response to (b) above and/or the previous interrogatories listed therein, which SOY contends support the allegations contained in sub- j part "g' of SOV's Contention Vil, other than the allegations identified in response to (a) above.

2 This refers to the first interrogatory designated as "21".

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6. Does

• h(1)*ofGOV still intend les Contention Vil?to litigate If your theisassertions answer contained anything other than an in sub-part unqualified negative, then please:

(a) state which allegations (if any) within sub part 'h(1)* SOY no longer intends to assert:

(b) update your Responses to VYNPC Set No. 2, Interrogatories 56-65, to reflect all new facts and documents now known to SOY, and to correct all statements by SOY which are now not entirely true and complete.

(c) describe in detail every fact and identify every document, other than the facts and documents described and identified in response to (b) above and/or the previous interrogatories listed therein, which SOY contends support the allegations contained in sub-part 'h(1)" of SOV's Contention VII, other than the allegations identified in response to (a) above.

7. Does "h(2)" ofGOV still intend to litigate the assertions contained in sub-part its Contention Vil? If your answer is anything other than an unqualified negative, then please:

(a) state which allegations (if any) within sub-part "h(2)" SOY no longer intends to assert; (b) update your Responses to VYNPC Set No. 2, Interrogatories 66-70, to reflect all new facts and documents now known to SOV, and to correct all statements by SOY which are now not entirely true and complete.

(c) describe in detail every fact and identify every document, other 3

than the facts and documents described and identified in response to (b) above and/or the previous interrogatories listed therein, which SOY contends support the allegations contained in sub-part 'h(2)" of SOV's Contention Vil, other than the allegations identified in response to (a) above.

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This refers to the first sub-part designated as 'h".

4 This refers to the second sub-part designated as 'h".

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8. Does SOY still intend to litigate the assertions contained in sub-part "j" of its Contention Vil? If your answer is anything other than an unqualified negative, then please:

(a) state which allegations (if any) within sub-part "j" SOY no longer intends to assert; (b) update your Responses to the following interrogatories to reflect all new facts and documents now known to SOY, and to correct all statements by SOY which at9 now not entirely true and complete:

1) VYNPC Set No.1, Interrogatory 12;

11) VYNPC Set No. 2 Interrogatories 71-82; and lii) VYNPC Set No. 4. Interrogatories 5,6 and 32.

(c) describe in detail every fact and identify every document, other than the facts and documents described and identit'h.d in response to (b) above and/or the previous interrogatories listed therein, which SOY contends support the allegations contained in sub-part "j" of SOV's Contention Vil, other than the allegations identified in response to (a) above.

9. Does SOY still intend to litigate the assertions contained in sub-part "k" of its Contention Vil? If your answer is anything other than an unqualified negative, then please:

(a) state which allegations (if any) within sub-part "k" SOY no longer intends to assert; (b) update your Responses to VYNPC Set No. 2, Interrogatories83-101, to reflect all new facts and documents now known to SOY, and to correct all statements by SOV which are now not entirely true and complete.

(c) describe in detail every fact and identify every document, other than the facts and documents described and identified in response to (b) above and/or the previous interrogatories listed therein, which SOY contends support the allegations contained in sub-part "k" of SOV's Contention Vil, other than- the allegations identified in response to (a) above.

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10. Does SOY still intend to litigate the assertions contained in sub-part 'm' of its Contention Vil? If your answer is anything other than an unqualified negative, then please:

(a) state which allegations (if any) within sub-part 'm' SOY no longer intends to assert; (b) update your Responses to the following interrogatories to reflect all new facts and documents now known to SOY, and to correct all statements by SOY which are now not entirely true and complete:

1) VYNPC Set No. I, Interrogatories 13-15;

11) VYNPC Set No. 2, Interrogatories 102-129; lii) VYNPC Set No. 3, Interrogatory 21 (2nd)5; and iv) VYNPC Set No. 4, Interrogatories 7-10.

(c) describe in detail every fact and identify every document, other than the facts and documents described and identified in response to (b) above and/or the previous interrogatories listed therein, which SOV contends support the allegations contained in sub-part 'm' of SOV's Contention VII, other than the allegations identified in response to (a) above,

11. Does SOY still intend to litigate the assertions contained in sub-part "n" of its Contention Vil? If your answer is anything other then an  ;

unqualified negative, then please:

l (a) state which allegations (if any) within sub part "n" SOY no longer intends to assert; (b) update your Responses to VYNPC Set No. 2, Interrogatories 130-137, to reflect all new facts and documents now knoivn to SOY, and to correct all statements by SOY which are now not entirely true and complete.

(c) describe in detail every fact and identify every document, other than the facts and documents described and identified in response 5

This refers to the second interrogatory designated as "21".

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to (b) above and/cr the previous interrogatories listed therein, which SOY contends support the allegations contained in sub-part "n* of SOV's Contention VII, other than the allegations identified in response to (a) above.

12. Does SOY still intend to litigate the assertions contained in sub part 'l' of its Contention Vill? If your answer is anything other than an unqualified negative, then please:

(a) state which allegations (if any) within sub-part "I' SOY no longer intends to assert;

.(b) update your Responses to the following interrogatories to reflect all new facts and documents now known to SOY, and to correct all statements by SOY which are now not entirely true and complete:

1) VYNPC Set No. 2, Interrogatories 138-142; and li) VYNPC Set No. 4, Interrogatories 11-16.

(c) describe in detail every fact and identify every document, other than the facts and documents described and identified in response 4 to (b) above and/or the previous interrogatories listed therein, '

which SOY contends support the allegations contained in sub-part "1" of SOV's Contention VIII, other than the allegations identified in response to (a) above.

13. Does $0V still intend to litigate the assertions contained in sub-part "n" of its Contention Vill? If your answer is anything other than an unqualified negative, then please:

(a) state which allegations (if any) within sub-part "n" SOY no longer intends to assert; (b) update your Responses to the following interrogatories to reflect all new facts and documents now known to SOY, and to correct all statements by SOY which are now not entirely true and '

complete:

i) VYNPC Set No.1, Interrogatory 16; ii) YYNPC Set No. 2, Interrogatories 143-149; i

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iii) VYNPC Set No. 3, Interrogatory 22; and iv) VYNPC Set No. 4, interrogatories 17-21 and 29.

(c) describe in detail every fact and identify every document, other than the facts and documents described and identified in response to (b) above and/or the previous interrogatories listed therein, which SOY contends support the allegations contained in sub-part "n* of SOV's Contention VIII, other than the allegations identified in response to (a) above.

14. Does SOY still intend to litigate the assertions contained in sub-part "o" of its Contention Vill? If your answer is anything other than an unqualified negative, then please:

(a) state which allegations (if any) within sub-part 'o* SOY no longer intends to assert; (b) update your Responses to the following interrogatories to reflect all new facts and documents now known to SOY, and to correct all statements by SOY which are now not entirely true and i complete: ,

1) VYNPC Set No. 2, Interrogatories 150-152;and i

11) VYNPC Set No. 4, Interrogatory 22.

(c) describe in detail every fact and identify every document, other than the facts and documents described and identified in response to (b) above and/or the previous interrogatories listed therein, which SOV contends support the allegations contained in sub-I part "o" of SOV's Contention Vill, other than the allegations identified in response to (a) above. ,

j 15, With respect to the initial paragraph of SOV's Contention Vil, please:

(a) state which allegations (if any) within the paragraph SOV no longer intends to assert; (b) update your Responses to the following interrogatories to reflect all new facts and documents now known to SOY, and to correct all statements by SOV which are not now entirely and complete:

i) VYNPC Set No. I, Interrogatories 1,2,5,17, and 18; 9-1 a

ii) VYNPC Set No. 2, Interrogatories 1-16, 22, 41-44, 153-156; iii) VYNPC Set No. 3, Interrogatories 2 and 3; and iv) VYNPC Set No. 4. Interrogatories i,3,26-28,30, and 31.

(c) describe in detail every fact and identify every document, other than the facts and documents described and identified in responte to sub-part (b) of Interrogatories 1-15 above and/or the previous interrogatories listed therein, which SOY contends support the allegations contained in the first paragraph of its Contention Vil, other than the allegations identified in response to (a) above.

By its attorneys, J

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. . ad111 Jeffrey P. Trout Ropes & Gray One International Place Boston, Massachusetts 02110 Telephone: 617-951-7520 Dated: July 24,1990.

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m.uim UhNHC VYN-143 ASLAB - MA% JL 27 All :51 Certificate of Service f[fCNflNb VYf !

IlRANCH i 1,~Jeffrey P. Trout, hereby certify that on July 24,1990, I made service of the within interrogatories, by mailing copies thereof, first class mail, postage prepaid, as follows:

Robert M. Lazo, Esquire Jerry R. Kline Chairman Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S.N.R.C. U.S.N.R.C.

Washinston, 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 l

Anthony Z. Roisman, Esquire Ann P. Ilodsdon, 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 Kurt Janson, Esquire Vermont Department of Public Service 120 State Street Montpelier, Vermont 05602 '

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