ML20059A903
| ML20059A903 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 08/13/1990 |
| From: | Janson K VERMONT, STATE OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#390-10731 OLA-4, NUDOCS 9008240115 | |
| Download: ML20059A903 (14) | |
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RELATED CORRESPONDENCE 00cxCIED USNRC l
UNITED STATES OF AMERICA NUCLEAR PIGULATORY COMMISSION
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,5I U before the ATOMIC SAFETY AND LICENSING BOARD In the. Matter of
)
)
VERMONT YANKEE NUCLEAR
)
Docket No. 50-271-OLA-4 POWER CORPORATION
)
(Operating License
)
Extension)
(Vermont Yankee Nuclear
)
Power Station)
)
RESPONSES TO INTERROGATORIES BY STATE OF VERMONT TO THE VERMONT YANKEE NUCLEAR POWER CORPORATION (Set No. 5)
Q.1 Does SOV still intend to litigate the assertions contained in sub-part "b" of its Contention VII?
If your answer is anything other than an unqualified negative, then please:
(a) state which allegations (if any) within sub-part "b" SOV no longer intends to assert; 1
(b) update your Responses to the following interrogatories to reflect all new facts and documents now known to SOV, and to correct all statements by SOV which are now not 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; 1
The term " Responses", as used in this and all subsequent interrogatories, includes all supplements to the initial answers filed by SOV.
1 9008240115 900013 PDR ADOCK 05000271 0
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iii)
VYNPC Set No. 3, Interrogatory 4; and iv)
VYNPC Set No. 4, Interrogatory 3.
(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 "b" of SOV's contention VII, other than the allegations identified in response to (a) above.
A.1 (a)
At this time Vermont has not identified any allegation of this sub-part which it no longer intends to assert.
(b) & (c)
Vermont considers this a reiteration of the interrogatories identified in section (b), and as such Vermont objects to these requests as duplicative and resulting in undue burden to the 4
State.
The Board in its Memorandum and Order of July 20, 1990, has stated that it will establish a schedule for the submission of supplemented answers.
Vermont further objects to these requests as burdensome in that they attempt to force case preparation,in a manner, i.e., categorized acco. ding to the sub-parts of contention VII, which Vermont has made no decision to implement.
Vermont acknowledges its obligation to supplement this j
interrogatory in accordance with 10 C.F.R. S 2.740(e).
i i
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Q.2 Does Sov still intend to litigate the assertions contained in sub-part "c" of its Contention VII?
If your answer is anything other than an unqualified negative, then please:
(a) state which allegations (if any) within sub-part "c" SOV no longer intends to assert; (b) update your Responses to the following interrogatories to reflect all new facts and documents now known to SOV, and to correct all i
statements by SoV which are now not entirely true and complete:
i)
VYNPC Set No.
1, Interrogatories 7-10;
)
11)
VYNPC Set No.
2.
Interrogatories 33-40; iii)
VYNPC Set No.
3, Interrogatory 1 and 5-15; and iv)
VYNPC Set No.
4, Interrogatory 4, 23, and 24.
(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 "c" of SOV's contention VII, other than the allegations identified in respense to (a) above.
A.2 See the Response to Interrogatory No.
1.
i Q.3 Does SOV still intend to litigate the assertions contained in sub-part "d" of its Contention VII?
If your answer is anything other than an unqualified negative, then please:
(a) state which allegations (if any) within sub-part "d" SOV 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 SOV, and to correct all statements by SOV which are now not entirely true and complete.
3 i
i (c) describe in detail every fact and identify every document, other than the facts and documents described and identified in response to (b) abova and/or the previous interrogatories listed therein, which SOV contends support the allegations contained in sub-part "d" of SOV's Contention VII, other than the allegations identified in response to (a) above.
A.3 See the Response to Interrogatory No.
1.
Q.4 Does SOV still intend to litigate the assertions contained in sub-part "e" of its Contention VII?
If your answer is anything other than an unqualified negative, then please:
(a) state which allegations (if any) within sub-part "e" SOV no longer intends to assert; (b) update your Responses to VYNpC Set No.
2, Interrogatories 52-54, to reflect all new facts and documento now known to SOV, 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 e
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 "e" of SOV's Contention VII, other than the allegations identified in response to (a) above.
A.4 See the Response to Interrogatory No.
1.
Q.5 Does SOV still intend to litigate the assertions contained in sub-part "g" of its Contention VII?
If your answer is anything other than an unqualified negative, then please:
(a) state which allegations (if any) within sub-part "g" SOV no longer intends to assert; (b) update your Responses to the following interrogatories to reflect all new facts and 4
l
1 1
I documents now known to SOV, and to correct all statements by Sov which are now not entirely true 1
and complete:
i)
VYNPC Set No.
1, Interrogatory 11; 11)
VYNPC Set No.
2.
Interrogatory 55; iii)
VYNPC Set No.
3, Interrogatories 16-21 (1st)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 I
described and identified in response to (b) above and/or the previous interrogatories listed therein, which Sov contends support the a] legations contained in sub-part "g" of SOV's Contention VII, other than i
the allegations identified in response to (a) above.
j A.5 See the Response to Interrogatory No.
1.
Does SOV still intend to lit Q.6 containedinsub-part"h(1)"jgatetheassertions of its contention VII?
If your answer is anything other th an an unqualified negative, then please:
(a) state which allegations (ir any) within sub-part "h(1)" SOV 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 SOV, 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 Sov contends support the allegations contained in sub-part "h(1)" of Sov's contention VII, other 2
This refers to the first interrogatory designated as "21".
3 This refers to the first sub-part designated as "h".
5
than the allegations identified in response to (a) above.
l A.6 See the Response to Interrogatory No.
1.
Q.7 DoesSovstillintendtolit{gatetheassertions contained in sub-part "h(2)"
of its Contention VII?
If your answer is anything other than an unqualified negative, then please:
(a) state which allegations (if any) within sub-part t
"h(2)" SOV no longer intends to assert; (b) up'ute 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 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 SOV contends support the allegations contained in sub-part "h(2)" of Sov's Contention VII, other than the allegations identified in response to (a) above.
?
A.7 See the Response to Interrogatory No.
1.
Q.8 Does SOV still intend to litigate the assertions contained in sub-part "j" of its Contention VII?
If your answer is anything other than an unqualified negative, then please:
(a) state which allegations (if any) within sub-part "j" SOV no longer intends to assert; (b) update your Responses to the following interrogatories to reflect all new facts and documents now known to SOV, and to correct all This refers to the second sub-part designated as "h".
6
i l
i statements by Sov which are now not entirely true and completet i
i)
VYNPC Set No.
1, Interrogatory 12; j
i 11)
VYNPC Set No.
2.
Interrogatories 71-82; and iii)
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 identified in response to (b) above i
and/or the previous interrogatories listed therein, which Sov contends support the allegations contained in sub-part "j" of Sov's contention VII, other than the allegations identified in response to (a) above A.8 See the Response to Interrogatory No.
1.
Q.9 Does SOV still intend to litigate the assertions contained in sub-part "k" of its contenti.on VII?
If your answer is anything other than an unqualified negative, then please (a) state which allegations (if any) within sub-part "k"
SOV 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 SOV, and to correct all statements by SOV which are now not entirely true and complete.
t (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 "k" of SOV's contention VII, other than the allegations identified in' response to (a) above.
A.9 See the Response to Interrogatory No.
1.
7
Q.10 Does SOV still intend to litigate the assertions contained in sub-part "m" of its contention VII?
If your answer is anything other than an unqualified negative, then pleaser (a) state which allegations (if any) within sub-part "m" l
SOV no longer intends to assert:
(b) update your Responses to the following interrogatories to reflect all new facts and documents now known to SOV, and to correct all statements by SOV which are now not entirely true and complete:
1 i)
VYNPC Set No.
1, Interrogatories 13-15; l-11)
VYNPC Set No. 2, Interrogatories 102-129; 1
lii)
VYNPC Set No. 3, Interrogatory 21 (2nd)5; and i
I 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.
l A.10 See the Response to Interrogatory No.
1.
Q.11 Does SOV still intend to litigate the assertions contained in sub-part "n" of its Contention VII?
If your answer is anything other than an unqualified negative, then please:
l (a) state which allegations (if any) within cub-part "n" SOV 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 known to SOV, and to correct all 5
This refers to the second interrogatory designated as "21".
8 l
i 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 SOV contends support the allegations contained in sub-part "n" of Sov's Contention VII, other than the allegations identified in response to (a) above.
A.11 See the Response to Interrogatory No.
1.
Q.12 Does SOV still intend to litigate the assertions contained in sub-part "1" of its contention VIII?
If your answer is anything other than an unqualified negative, then please:
(a) state which allegations (if any) within sub-part "1"
Sov no longer intends to assert; (b) update your Responses to the following interrogatories to reflect all new facts and t
documents now known to SOV,'and to correct all statements by SOV which are ow not entirely true and complete 1)
VYNPC Set No.
2, Interrogatories 138-142; and 11)
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 to (b) above and/or the previous interrogatories listed therein, which SOV contends support the allegations contained in sub-part "1" of Sov's contention VIII, other than the allegations identified in response to (a) above.
A.12 See the Response to Interrogatory No.
1.
1 Q.13 Does SOV still intend to litigate the assertions contained in sub-part "n" of its Contention VIII?
If 9
I 1
your answer is anything other than an unqualified i
negative, then pleases (a) state which allegations (if any) within sub-part "n"
SOV no longer intends to assert; (b) update your Responses to the following
)
interrogatories to reflect all new facts and documents now known to SOV, and to correct all statements by SOV which are ow not entirely true and complete:
i)
VYNPC Set No.
1, Interrogatory 16; 11)
VYNPC Set No.
2, Interrogatories 143-149.
f lii)
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 SOV contends support the allegations contained in sub-part "n" of SOV's contention VIII, other than the allegations identified in response to (a) above.
1 A.13 See the Response to Interrogatory No.
1.
Q.14 Does SOV still intend to litigate the assertions contained in sub-part "o" of its Contention VIII?
If your answer is anything other than an unqualified negative, then pleaser (a) state which allegations (if any) within sub-part "o" SOV no longer intends to assert; (b) update your Responses to the following interrogatories to reflect all new facts and i
documents now known to SOV, and to correct all statements by SOV which are now not entirely true and complete:
i)
VYNPC Set No.
2, Interrogatories 150-152; and 11)
VYNPC Set No.
4, Interrogatory 22.
10
i (c) describe in detail every fact and identify every document, other than the facts and documents i
described and identified in response to (b) above i
and/or the previous interrogatories listed therein,
)
which SOV contends support the allegations contained in sub-part "o" of SOV's Contention VIII, other than the allegations identified in response to (a) above.
A.14 See the Response to Interrogatory No.
1.
Q.15 With respect to the initial paragraph of SOV's Contention VII, please:
(a) state which allegations (if any) within paragraph SOV no longer intends to as' sert; (b) update your Responses to the following interrogatories to reflect all new facts and documents now known to SOV, and to correct all statements by SOV which are not now entirely and complete:
i)
VYNPC Set No.
1, Interrogatories 1, 2,
5, 17, and 18; 11)
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 1, 2,
26-l 28, 30, and 31.
(c) describe in detail every fact and identify every document, other than the facts and documents described and identified in response to (b) of Interrogatories 1-15 above and/or the previous interrogatories listed therein, which SOV contends support the allegations contained in the first paragraph of its contention VII, other than the allegations identified in response to (a) above.
A.15 (a)
Vermont continues to assert all of Contention VII.
(b)
Vermont considers this a reiteration of the interrogatories identified in section (b), and as 11 L
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I such Vermont objects to these requests as duplicative and resulting in undue burden to the State.
The Board in its Memorandum and Order of July 20, 1990, has stated that it will establish a i
schedule for the submission of supplemented answers.
(c)
Vermont objects to this request as overbroad, asking without specificity for "every fact" and "every document" relating to Contention VII.
As to ob ections:
V Kurt Ja on Special Assistant Attorney General Department of Public Service 120 State Street Montpelier, Vermont 05602 (802) 828-2811 Dated:
August 13, 1990 t
12
y' do UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD i
J l
In the Matter of
)
)
VERMONT YANKEE NUCLEAR
) Docket No. 50-271-OLA-4 1
POWER CORPORATION
)
(Operating License j
)
Extension)
(Vermont Yankee Nuclear
)
l Power Station)
)
AFFIDAVIT OF WILLIAM K.
SHERMAN j
I, WILLIAM K. SHERMAN, being duly sworn, state i
that the answers provided on August 13, 1990,
" Responses to Interrogatories by State of Vermont to l
the Vermont Yankee Nuclear Power Corporation (Set No.
5)", are true and correct to the best of my knowledge.
i Dated at Montpelier, Vermont, this 13th day of August, 1990.
WILLIAM K. SHERMAN Subscribed and sworn to before me this 6th day of August, 1990.
Abb43
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( W otary Public My Commi%sion Expires:
2/10/91
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WTED CORRESPONDENCE i
( JL ri ;L(:
l UdN C UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
before the 10 Am 15 P5:58
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ATOMIC SAFETY AND LICENSING BOARD i
)
Ms gt W SECilf1An t In the Matter of
)
DOCKillNG & G[i'VlU j
VERMONT YANKEE NUCLEAR
)
Docket No. 50-271-O N [
j POWER CORPORATION
)
(Operating License
)
Extension)
(Vermont Yankee Nuclear
)
Power Station)
)
)
g CERTIFICATE OF SERVICE I_hereby certify that on August 13, 1990, I made service of
" Responses to Interrogatories by State of Vermont to the Vermont Yankee Nuclear Power Corporation (Set No. 5)",
in accordance with rules of the Commission by mailing a copy thereof postage prepaid to the following:
Administrative Judge Administrative Judge Robert M.
Lazo, Chairman Jerry R. Kline Atomic Safety and Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Administrative Judge Ann P. Hodgdon, Esq.
Frederick J.
Shon Patricia A. Jehle, Esq.
Atomic Safety and Licensing Board Office of the General Counsel U.S. Nuclear Regulatory Commission U.S.
Nuclear Regulatory Washington, DC 20555 Commission Washington, DC 21555 R. K. Gad, III, Esq.
Anthony Z. Roisman, Esq.
Ropes & Gray Cohen, Milstein, Hausfeld &
One International Place Toll Boston, MA 02110 Suite 600 1401 New York Avenue, N.W.
Adjudicatory File Washington, D.C.
20005 Atomic Safety and Licensing Board Panel U.S.N.R.C.
Washington, DC 20555
. :,w Kurt Jan@ @
Special fssistant l
Attorney General Dated: August 13, 1990 5sa