ML20056A368

Document Requests Propounded by Vermont Yankee Nuclear Power Corp to State of VT (Set 1).* W/Certificate of Svc. Related Correspondence

ML20056A368
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-#390-10668 OLA-4, NUDOCS 9008070141
Download: ML20056A368 (5)

Text

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i Filed: July 24,1990

% JLL 27 All:50 j UNITED STATES OF AMERICA >

gr;;:OF SLCiiflARY NUCLEAR REGULATORY COMMISSION 00CEF1ING A SiDVICl- l

% MICH j before the' i ATOMIC SAFETY AND LICENSING BOARD  :

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)

• In the Matter of )

) Docket No. 50-271-OLA-4 i

• /ERMONT YANKEE NUCLEAR ) (Construction Period POWER CORPORATION ) Recapture) ,

) 1' (Vermont Yankee Nuclear )

Power Station). ) 4

) ,

DOCUMENT REQUES'I3 PROPOUNDED BY  ;

VERMONT YANKEE NUCLEAR POWER CORPORATION  :

TO THE STATE OF VERMONT -

(Set No.1) j Pursuant to 10 C.F.R. I 2.741, Vermont Yankee Nuclear Power Corpora- .i tion hereby requests that the State of Vermont produce, for inspection and copying,Lat the offices of Ropes & Gray, One International Place, Boston, Massachusetts, at 10:00 am on August 24, 1990, or at such other time and  ;

place as counsel for the parties may agree, each of the following categories -  :

of documents. If a document called for in one of the following requests is  !

one that VYNPC previously produced to SOV, or is one that SOY obtained ,

from the Public Document Room, SOV may fully and specifically identify

• that document, in its response to the request, in lieu of' producing the document. ,

I As used in these requests, YYNPC means Vermont Yankee Nuclear Power l Corporation: VYNPS means Vermont Yankee Nuclear Power Station; SOV  !

means the State of Vermont, including the agencies, officers, employees, and ,

agents thereof and further including contractors or consultants thereto. l As used in these requests, the term document has the same meaning as it  ;

does in Fed. R. Civ. P. 34(a).

As used in these requests, 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.

I 9000070141 900724 PDR ADOCK 05000271 0 PDR p6

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. As used in these requests, the term "identily" with reference to a l i document means to provide such ideatifying information as the title or other -l name of the document, the author or authors of the document, the date of the q document, and to state whether or n3t the document, or a copy thereof, is I within the possession, custody or contal of SOV.'

Your attention is called to the provisioas of 10 C.F.R. I 2.740(e) regarding the duty of supplementation with respect w ':wers to discovery requests.  !

1. Please produce each' and every document that SOY contends supports the assertions made 1 y SOY in sub-part "b" of its Contention VII.

2. Please produce each and every document that SOV contends supports the assertions made by SOY in sub-part ."c" of its Contention Yll. ,

3. .Please produce each and every document that SOV contends supports the assertions made by SOV in sub-part "d" of its Contention VII.

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4. Please produce each and every document that SOV contends supports the assertions made by SOY in sub-par! "e" of its Contention VII,

5. Please produce each and every document that SOY contends supports '

the assertions made by SOV in sub-part "g" of its Contention Vll.

6. Pleast ;, oduce cach and every document that SOV contends supports the assertions made by SOY in sub-par:"h(I)".of its Contention Vll.

7. Please produce each and every document that SOV contends supports.

the assertions made by SOV in sub-part "h(2)" u."its Contention VII.

8. Please produce each and every document that SOV contends supports the assertions made by SOV in sub-part "j" of its Contention VII.

L 9. Please produce each and every document that SOV contends supports I

the assertions made by SOV in sub-part "k" of its Contention VII.

10. Please produce each and every document that SOY contends supports the assertions made by SOV in sub-part "m" of its Contention VII.

i Please produce each and every document that SOV contends supports

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the assertions made by SOY in sub-part "n" of its Contention Vll.

12. Please produce each and every document that SOV contends supports the assertions made by SOY in sub-pa. : ,,a its Contention . Vill.

13. Please produce each and every document that SOV contends supports the assertions made by SOY in sub-part "n" of its Contention Vill.  ;

14. Please produce each and every document that SOV contends supports the assertions made by SOV in sup-part "o" of its Contention VIII.

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15. Please produce each and every document, other than those produced (or identified) in response to the preceding requests, that SOY contends supports the assertions made by SOY in its Contention VII. .

I 16 - With respect to' every expert whom SOY has retained or otherwise' consulted for the purposes of these proceedings, please produce:

i (a) for each expert retained, all documents that reflect, refer, or relate -  !

l to any communications, direct or indirect, between SOY and the expert, or any person or entity affiliated with or acting on behalf of the expert,' prior to SOV's retention of the expert; (b) for each expert retained, all documents that reflect or refer to '

either or both the (i) date and (ii) terms of SOV's retention of the expert, including (but not limited to) any and all retention agreements; (c)~ for each expert consulted, all documents that re' lect or refer _ to either or both the (i) date(s) and (ii) terms of the consultation. 7 including (but not limited to) any and all consultation agreements; (d) for each expert, all documents that reflect, refer, or relate to any communications between SOV and any other individual, agencv, or other entity concerning the expert; -

7 (e) for each expert, all documents prepared (in whole or in patt) by i l

that expert which SOV intends to offer into evidence or otherwise rely upon at trial; and (f) for each expert retained to testify at trial, all documents upon which the expert's testimony will be based.

17. For every employee or official of SOV whom SOV intends to offer as 1 l

a witness, please produce:

(a) all documents which reflect or refer to the technical qualifications of the witness; l

(b) all documents which reflect or refer to the duties, respon-  ;

sibilities, and/or terms of employment of the witness.  ;

(c) all documents prepared (in whole or in part) by the w4 ness which ]

SOV intends to offer into evidence or otherwise rely .pon at trial; and l

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(d) all documents upon which the witness's testimony will be based.

18. Please produ:e:

(a) all documents, not produced in response to one of the foregoing requests, that reflect, refer, or: relate to any communications between SOY and any other individual, agency, or entity concerning these proceedings; -

(b) all documents, not produced in response to one of the foregoing requests, that reflect, refer, or relate. to any communications between SOY and any other individual, agency, or other entity-concerning the subject matter of these proceedings; and (c) : all documents, not produced in response to one of the foregoing requests, that refer or relate: to the subject matter of these proceedings.

By its' attorneys, y/ . - .

R. W. Gad III

- Jeffrey P. Trout Ropes & Gray-One International Place

! Boston, Massachusetts 02110 l

Telephone: 617-951-7520 Dated: July 24,1990.

. i M nlIED UdNitC .,

Certificate of service '90 JUL 27 A1 50.- ],

1, Jeffrey P. Trout, hereby certify that on July 24,1990, I made service Y 4

of the within requests for production of documents, by mailingst6 '

u ply 3fgy SECyll^[3 thereof, first class mail, postage prepaid, as follows: yzyCH '

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.

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. Hodadon, Esquire ,

1 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 Kart-Janson, Esquire . . ~.: - -- ..

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Vermont Department of Public Service - -<

120 State Street Montpelier, Vermont 05602 y &

Jeffrey P. Trout i

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