ML20059L872
| ML20059L872 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 09/14/1990 |
| From: | Gad R ROPES & GRAY, VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | VERMONT, STATE OF |
| References | |
| CON-#490-10843 OLA-4, NUDOCS 9010020083 | |
| Download: ML20059L872 (85) | |
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RELATED CORRESPONDENCE
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FHed: Sep6 ember 14,1940. -
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-a UNITED STATES OF AMERICA 1 I
'90 SEP-20? P2:41 I
= NUCLEAR REGULATORY COMMISSION i 1
', klore the. ~ OFFICE OF SLCRLIMY- f DOCK [itNG A S[i4VIC[ l fiP ' MCH l g ATOMIC SAFETY AND LICENSING BOARD :
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In the Matter of
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) . Docket No. 50-271-OLA-4 '
VERMONT YANKEE NUCLEAR - ) (Construction Period
POWER CORPORATION ) Recapture) ,
K ) 0 (Vermont Yankee Nuclear: )
,. , Power Station) )
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RESPONSES OF -
jE ' VERMONT YANKEE NUCLEAR POWER C0W 4 TION 5 TO DOCUMENT REQUESTS PROPOUNDEL -
HE -a STATE OF YERMONT.
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(Set No. 3) {
- Pursuant to 10 C.F.R. $ 2.741. Vermont Yankee Nuclear Power Corpora-tion h~e reby responds to the document requests (third set) propounded to it by ii.
t the, State'of Vermont.
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i Request No.1.
a Re.luest:
Plerae Identify all persons who participated in the preparation of, answers to.cese document production requests:
- s. Describe in detail the specific portions of each docum'ent production request to which each person contributed.
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- b. Provideithe most current resume available for each identified iirdividual.
[ c. -Describe the qualifications of each identified individual, including ~
xw. training and papers published.
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' Objection:
Vermont Yankee objects to this " document request" on the ground that it :
is not'a request for the production of documents. <
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i Request No. 2.
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!' ' Please produce for inspection and copying a legible color copy of each j
,g and every photograph identified in Attachment A to item 13 of its fg response to Vermont Interrogatory (Set No.1) No. 79, if in response l N
'ic to Vermont Interrogatory (Set No.1) No. 79 Vermont Yankee has not
= identified all documents requested to be identified by that inter-p., I rogatory, plesse produce for inspection and copying all such docu-i3 ments. ,
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,cm Response:
C5 Vermont, Yankee will produce the requested photographs for inspection -
at the offices of Vermont Yankee Nuclear Power Corporation, Ferry Road, l{
y.I Brattleboro, on a date and at a time mutually' agreed upon by counsel for the . l Q parties. ,
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Request No. 3. y Request; Please produce for inspection and copying all documents identified in ,
response to Vermont Interrogatory (Set No. 2) No. 8.b If in response to Vermont Interrogatory (Set No 2) No. 8 Vermont Yankee has not Q- identified all documents requested to be identified by that inter .
t5"' rogatory, please produce for inspection and copying all such docu-ments.
Objection:
Vermont Yankee objects to this request on the ground that it is not relevant to the admitted contention.
Response
Without waiving the foregoing objection, but rather expressly re*ying- .
l- upon the same, Vermont Yankee will produce the documents identified in the response to Interrogatory (Set No. 2) No. 8(b) for inspection at the offices of
' l 5 Vermont Yankee Nuclear Power Cosporation, Ferry Road, Brattleboro, on a
.date and at a time mutually agreed upon by counsel for the parties. As for =
'I copying any document which is copyrighted by its author or publisher, SOY will have to make arrangements with the owner of the copyright.-
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i Request No. 4.
Request.6 Please produce for inspection and copying procedures AP 0206 and AP 4024 as identified in response to Vermont Interrogatory (Set No.'
1 2) No.10. If in response to Vermont laterrogatory (Set No. 2) No.10 -
Vermont Yankee has not identified all documents requested to be identified by that interrogatory, please produce for inspection and I,* copying all such documents.
Response
' AP 4024 does not currently exist, having Lann@ancelled. The request for -
AP 0206 duplicates Request No.15 of Set No.1, and a copy of the document was provided to SOY on June 6,: 1990.
Request No. 5. , F I Request:
1 Pleaseiproduce for inspection and copying the documentation of -
result of all vibration analyses in the last five years, as identified in
- response to Vermont interrogatory (Set No. 2) No.10. ,
Objection:
Vermont Yankee objects to this request on the ground that it is believed !
to be beyond the scope of the contention as ad 'ted by the Licensing Board. ) ;
In particular, Vermont Yankee-understand- e Licensing Board to have admitted a contention going (in the particular apects set forth in the " basis") '
to the programmatic adequcy of the maintenance program with respect to j I "
identifying and repairing or replacing components aged to the point of being unsafe during operation beyond the year 2007, not to the details of, or- ]j adequacy of performance of, each aspect of maintenance over the past 18 >]
years, i q
w Request No. 6. q f ' Request. ,
Please produce for inspection and copying procedurt AP 0200, as :
. identified in response to Vermont Interrogatory (Set N1. 2) No.16. ;
o If in response to Vermont Interrogatory (Set No. 2) No.16 Vermont Yankee has not identified all documents requested to be icentified by _!
that interrogatory, please produce for inspection and copying all such -l '
documents.
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1 Response:- 1
- The request for AP 0200 duplicates Request No 15 of Set No.1, and a copy of the document was provided to SOY on June 6,1990. <
- 8 Request No. 7. y Request: .t Please produce for inspection and copying each and every Visi-card
. PM that specifies requir vnts for lube oil analysis, as identified in-response to Vermont inton gatory (Set No. 2) No.16.- ..c-Objection: , ?
W . Vermont Yankee has previously made the entirety of theLVisi-card
- . records available to SOV. :It respectfully objects to the request that these ;
[i same records be made available a second time j
- Request No. 8.
Regaest:
c a Please produce for inspection and copying all Mobil Oil reports of ,
lube oil analysis in the past five years, as identified in response to- [
Vermont Interrogatory (Set No. 2) No.16.
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i Objection: *!
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u Vermont Yankee objects to this request, for the reasons set forth above i in its objeciion to Request No. 5. - 1 Request No. 9. +
Request:
L For each and every Mobil Oil Corporation employee who has been -
responsible for or has performed oil analysis testing and any correc- - ;
!I 1 tive recommendations at the Vermont Yankee plant at any time in the -
past five years, as identified in response to Vermont Interrogatory (Set No. 2) No.17, please produce for inspection and copying all personnel ,
j files, including, but not limited to, performance evaluations, ratings by Vermont Yankee personnel, qualification records, and training
,i records and test scores.
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. Objection:
,fh 3 IU Vermont Yankee objects to this request on the ground that it is not' l j c, . relevant to Contention VII, f '
Vermont Yankee further objects on the' grounds.that the request, even if
. it were relevant, is overboard and. improperly invades the privacy of. the l
$_ .y l , : individuals in question, and pursuant to 10 C.F.R. $ 2.740(c) requests a
, g protective order that the same not be disclosed.-
- Vermont Yankee further objects to this request to the extent that it seeks !
- documents possessed by Mobil Corporation rather than by Vermont Yankee.
l} Request No.10.
Request:
l Please produce for lnspection and copying all documentation of the- i Vermont Yankee Operations Department Performance Monitoring
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I Program, as identified in response to Vet mont Interrogatory (Set No. l
' 2) No. 22.
Objection: ,
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. Vermont . Yankee objects to this request on the ground that it is not Lg relevant to the admitted cor.tention.
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Response
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Without waiving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee will produce the Vermont Yankee Opera-
,I tions Department Performance Monitoring Program ' for. inspection and '
copying at the offices of Vermont Yankee Nuclear Power Corporation, Ferry Road, Brattleboro, on a date and at a time mutually agreed upon by counsel for the parties.
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, Request No.11. .
Request: ;
M Picase aroduce for inspection and copying all documentation of o 1, infrared thermography evaluations in the last five years, as identified in response' to Vermont Interrogatory (Set No. 2) No. 22. .If in 0 response to Vermont Interrogatory (Set No. 2) No. 22 Vermont Yankee i 4
has not identified all documents requested to be identified by that .,
interrogatory, please produce for inspection and copying all such i 14 n ,
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'q Objection: )
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Vermont Yank'ee objects to this request, for the reasons set forth above . j
'in its objection to Request No. .,. i B' Request No.12. j
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Request: .
Please produce for inspection and copying all docurrentation of the H 653 equipment faults detected by infrared thermography (in 1981,- I
';I during a review of 22 industrial facilities) prior to equipment failta as identified in response to Vermont Interrogatory (Set No. 2) No. 23.
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Objection:
Vermont Yanked objects to this request, for the reasons set forth abou j in its objection to Request No. 5. j
. Response:
! Without waiving the foregoing objection, but rather expressly relying i upon the same,, Vermont Yankee will produce for inspection at the offices of ~ , .,
fg Vermont Yankee Nuclear Power Corporation, Ferry Road, Brattleboro, on a d' *"d ' 'i=* ="'"'"x **'"d "a a by c "" ' ' 'h* **i 'h' *ic
- B identified in Vermont Yankee's response to SOY Interrogatory (Set No. 2) No.
l 23(b). To the extent that the document is copyrighted by its owner or ;
publisher, SOV will have to make arrangements for copying with the owner l
of the copyright, j Request No.13.
,, Request: >
1
. Please produce for inspection and copying the document identified by Vermont Yankee in response to Vermont Interrogatory (Set No. 2) No. . ,
23.b. If in response to Vermont Interrogatory (Set No. 2) No. 23 !
Vermont Yankee has not identified all documents requested to be .
-identified by that interrogatory, please produce for inspection and I- copying all such docements.
Response
I Vermont Yankee incorporates by reference its objection and response to -
Request No.12. .
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Request No.14.
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l, Request::
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f For each and every Yankee Atomic Electric Corporation employee-who has been responsible for or has performed infrared thermography.
, at the Vermont-Yankee plant at any time since January 1,1936, as identified in response to Vermont Interrogatory (Set No. 2) No.- 23.c .
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. please. produce. for inspection and copying ' all personnel files, including, but not limited to, performance evaluations, ratings by s supervisors, qualification records, and training records and test scores.
Objectlon: I Vermont Yankee objects to this request on the ground that it is not
. relevant to Contention VII.-
Vermont Yankee further objects on the grounds that the request, even if it were relevant, is overboard and improperly invades the privacy of the individuals in question, and pursuant to 10 C.F.R. I 2.740(c) requests a -
I j protective order that the same not be disclosed.
Request No.15.
Request:
Please produce for inspection and copying all documentation: of spectrography and atomic absorption spec *rophometry evaluations in the past five years, as identified by Vern ont Yankee in response to Vermont Interrogatory (Set No. 2) No. 25. If in response to Vermont Interrogatory (Set No. 2) No. 25 Vermont Yankee has not identified all documents requested to be identified by that interrogatory, please produce for inspection and copying all such documents, n Objection:
Vermont Yankee objects to this request, for the reasons set forth aNve lp,
- in its objection to Requer. No. 5.
Request No.16.
} For each and every Mobil Oil Corporation employee who has been I responsible for or has performed spectrography and atomic absorption spectrophometry evaluations for the Vermont Yankee plant at any time in the past fi se years, as identified in response to Vermont Inter-rogatory (Set No. .".) No. 26, please produce for inspection and copying all personnel f8 es, including, but not limited to, performance I
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L f ; evaluations,1 ratings by Ves;nont Yankee personnel, qualification:
records, and training records and test scores.
l Objection: l
- : Vermo'nt . Yankee object to this request'on the ground that it is not - ,
j - relevant to Contention VIL I
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Vermont Ybakee further objects on the grounds that the request, even if.
! * .it were relevant;is overboard e.nd 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. ,
Vermont Yankee further objects to this request to the extent that it seeks- j documents possessed by Mobil Corporation rather than by Vermont Yankee.
! Request No.17.
Request:
Please produce for inspection and copying procedure ' AP 0150i as '
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' identified in response to Vermont Interrogatory (Set No. 2) No. 31. ?
3 If in response to Vermont Interrogatory (Set No. 2) No. 31 Vermont- "l L Yankee has not identified all documents requested to be identified by : 1 ga that interrogatory, please produce for inspection and copying all such ,
documents. ;
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Response
The request for AP 0150 duplicates Request No.15 of Set No.1.
. Request No,'18.
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i . Request: -
Please produce- for inspection and copying all documentation of ' 1 h
. I' tearing temperature trending in accordance with the Plant Perfoc-mance Monitoring Program since October 1,1989, as identified by
' Vermont Yankee in response to Vermont Interrogatory (Set No. 2) No.
, I' , 4 31.
- n Objection
-Vermont Yankee objects to this request, for the reasons set forth above in its objection to Request No. 5.
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1 Request No.19.
Request:
Please produce for inspection and copying all documt nts identified in
- response to Vermont Interrogatory (Set No. 2) No. 32.b. If in response to Vermont Interrogatory (Set No. 2) No. 32 Vermont Yankee has not identified all documents requested to be identified by that
-- interrogatory, please produce for inspection and copying all such c'.ocuments.
Response
- Vermont Yankee will produce the documents identified in its response to Interrogatory (Set No. 2) No. 32(b) for inspection at the offices of Vermont Yankee Nuclear Power Corporation Ferry Road, Brattleboro, on a date and T at a time mutually agreed upon bi counsel for the parties. As for copying any document which is copyrighted by its author or publisher, SOY will have i to make arrangements with the owner of the copyright.
Request No. 20.
Request:
4, Please produce for inspection at noying all documentation of age q degradation mechanism detectio: waring temperature trending, as
- identified by Vermont Yankee in . . inse to Vermont Interrogatory
.- (Set No. 2) No. 32.
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Objection:
- Vermont Yankee objects to this request, for the reasons set forth soove
_j in its objection to Request No. 5.
Request No. 21.
Request:
-. Please produce for inspection and copying all documentation of each and every structure, system or component for which the predictive
- maintenance method of leakage detection was used during the past five years, as identified by Vermont Yankee in response to Vermont 1 Interrogatory (Set No. 2) No. 33. If in response to Vermont Inter-rogatory (Set No. 2) No. 33 Vermont Yankee has not identified all
_; documents requesred to , identified by that interrogatory, please produce for inspger ma copying all suc' documents.
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- Objections: ,
[' - ' l. The term "all' documentation of each and every structure, system or .
component" is not sufficiently specific to permit-Vermont Yankee toe
' . determine what documents are requested to be retrieved and produced.
' 2. If the intent was to request documentation of the results of the activity .
In question, Vermont Yankee objects to this request for the reasons set forth above in its objection to Request No. 5.
- 3. To the extent necessary, Vermont Yane incorporatss and restates its-objection to Interrogatory No. 33 of Set No. 2 Request No. 22.
Request:
Please produce for inspection and copyins prxedures DP 4153 and -
AP 4116, as identified in response to Vermont Interrogatory (Set No.
- 2) No. 34.a.
Response
The request for DP 4153 and AP 4116 duplicates Request No,' 15 of Set.-
8 No, l.. A copy of DP 4153 was requested by SOY and provided by VY on :
June 20,'1990, and no copy of AP 4116 was requested.
' Request No. 23.
Request:
ur Please produce for inspection and copying all documentation of main
" condenser and secondary containment leakage surveillances for the past five years, as identified in response to Vermont Interrogatory (Set No. 2) No. 34.c. If in response to Vermont Interrogatory (Set No. 2)
I+_. : No. 34 Vermont Yankee has not identified all documents requested to be identified by that interrogatory, please produce for inspection and
- copying all such documents.
e : Objection:
. Vermont Yankee objects to this request, for the reasons set forth above in its objection to Request No. 5.
Request No. 24.
Request:
For each and every Vermont Yankee and Yankee Atomic Electric Corporation employee who has been responsible for or has performed I. I
4 .jr-t leakage detection at the Vermont Yankee plant at any time in the past five years, as identified in response to Vermont Interrogatory (Set No. ,
- 2) No. 35.c, 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.'
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Objection:
LVermont YEnkee objects to this request on the ground that it is not
- relevant to Contention Vll.
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= Vermont Yankee further objects on the grounds that the request, even if it.wers relevant, is overboard and improperly. invades the privacy of the a
T individuals in question, and pursuant to -10 C.F.R. I 2.740(c) requests a .
< protective or.ier that the same not be disclosed.
Request No. 25.
N! Request:
~ Please produce for inspection and copying procedures OP 5220, OP
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- 5225 OP 5235, OP 5245 and Maintenance Department Guideline-480 VAC Switchgear and MCCs, as identified in response to Vermont Interrogatory (Set No. 2) No. 37. If in response to Vermont Inter-rogatory (Set No. 2) No. 37 Vermont Yankee has not identified all documents regmted to be identified by that interrogatory, please s produce for inspection and copying all such documents.
Response
s .
Copies of procedures OP 5220,- OP 5225, OP' 5235, OP 5245 have
- previously been offered to SOY for inspection and, if requested,' copying - s z
(only OP 5220 was requested to be copied and a copy of that' procedure was:
provided on June 22, 1990), and Vermont Yankee respectfully declines to- _
duplicate that process. Vermont Yankee will produce Maintenance Depart-7 ment Guideline-480 VAC Switchgear and MCC: for inspection and copying-at the offices of Vermont Yankee Nuclear Power Corporation, Ferry Road,
- Brattleboro, on a date and at a time mutually agreed upon by counsel for the parties.
Request No. 26.
Request:
n Please produce for inspection and copying all documentation of insulation resistance (meggering) evaluations in the past five years, as
- identified in response to Vermont Interrogatory (Set No. 2) No. 37.
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. Objection: -
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!' Vermont Yankee objects to this request, for the reasons set forth above -
'in its objection to Request No. 5.
- Request No. 27.
Request:
Please produce for inspection and copying all documentation of age b degradation mechanism detection by insulation resistance (meggering)
' evaluation, as identified in response to Vermont Interrogatory (Set No.-
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- 2) No. 38.b.
Objection:
. Vermont Yankee objects to this request, for the reasons set forth above in its objection to Request No. 5.
Request No. 28.
Request:
Please produce for inspection.and copying all documentation of all-
- polarization index evaluations in the past five years, as identified in -
response to Vermont Interrogatory (Set No. 2) No. 40. If in response :
to Vermont interrogatory (Set No. 2) No. 40 Vermont Yankee has not identified all documents requested to be identified by that inter-rogatory, please produce for inspection and copying all such docu---
ments.
Objection:
Vermont Yankee objects to this request, for the reasons set forth above in its objection to Request No. 5.
I Request No. 29.
Request:
Please produce for inspection and copying all documentation of the Heat Exchanger Preventive Maintenance Program, as identified in response to Vermont Interrogatory (Set No. 2) No ' 42. If in response to Vermont Interrogatory (Set No. 2) No. 42 Vermont Yankee has not 1 identified all documents requested to be identified by that inter-rogatory, please produce for inspection and copying all such docu-ments.
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Y Lif the intent was to request documentation of the results of the activity in' question, Vermont Yankee objects to this request, for the reasons set forth -
7 < above in its objection to Request No.- 5.
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G- : Response:
.Without walving the foregoing ~ objection, but ra+her expressly relying ,
upon the same, Vermont Yankee will produce the Heat Exchanger Preventive
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Maintenance Program for inspection and copying at the offices of Vermont
{f 4 Yankee Nuclear Power Corporation, Ferry Road, Brattleboro, on a date and 1 at a time mutually agreed upon by counsel for the parties, y Request No. 30.-
Request:
Please produce for inspection and copying all' documentation of the
- Heat - Exchanger : Preventive / Predictive Maintenance :- Program, as identified in response to Vermont laterrogatory (Set No. 2) No. 43.a.
If in response to Vermont Interrogatory (Set No. 2) No. 43 Vermont I .
. Yankee has not identified all documents requested to be identified by.-;
. that interrogatory; please produce for inspection and copying all such
. dosuments.
Response
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Vermont Yankee incorporates by reference its objection and response to
.. Request No. 29.-
. Request No. 31.
Request:
Please produce for inspection and copying all documentation of eddy
- current testing the [ sic) past five years, as identified in response to Vermont Interrogatory (Set No. 2) Nr. 43.c.
Objection:
Vermont Yankee objects to this request, for the reasons set forth above 1 .in its objection to Request No. 5.
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- Request No,' 32,
- Request
For each and every subcontract employee who has been responsible =
3 for or has performed eddy current testing at the Vermont . Yankee g plant in the past five years, as identified in response to Vermont.
- Interrogatory (Set No. 2) No. 43.c. please produce for inspection and copying all perscnnel files, including, but not limited to, performance I' : avaluations, ratings by Vermont Yankee personnel, qualification records, and training records and test scores.
Objection:
Vermont Yankee obje' to this request on the ground that it is not-as relevant to Contention VII.
E' ; Vermont Yankee further objects on the grounds that the request, even if
. it were relevant, is overboard 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 tame not be disclosed.
Request No. 33.
Request:
For each and every . Vermont Yankee employee who has beenc 8 responsible for or has performed eddy current testing at the Vermont Yankee plant in the past five years,' as identified in response to
~
Vermont Interrogatory (Set No. 2) No. 44, 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.
Objection:
I, Vermont Yankee objects to this request on the ground that it is not relevant to Contention VII.
Vermont Yankee further objects on the grounds that the request, even if I it were relevant, is overboard 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.
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Request No. 34.
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' Request:
e ; Pleast produce for inspection and copying all documentation for usage ,
of the INPO NPRDS data bass and its applicability to the Vermont
= Yankee plant. - Documentation should include, but not be limited to, preparation and evaluation of CFARs, as identified in' response to Vermont Interrogatory (Set No. 2) No. 49.
Objection:
Vermont Yankee objects to this request on the ground that the term "all:
, , documentation for usage on the INPO NPDRS data base and its applicability .
to the Vermont Yankee plant" is not sufficiently specific to permit Vermont
. Yankee to determine what documents are requested to be retrieved and produced. - Vermont Yankee further objects on the ground that the request does not appear to be relevant to Contention VII.
if the intent was, in whole or in part, to request documentation access to i which is limited by INPO, Vermont Yankee also objects on the grounds set-
. forth in its " Objection to Document Production and Request for Protective Order (INPO Documents)"(June 14,1990), and on the further ground that the request is duplicative of other requests by SOV.
Request No. 35.
Request:
Please produce for inspection and copying all CFARs, commencing May 1990, for the Vermont Yankee plant as identified in response to -
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- 4. ' Interrogatory (Set No. 2) No. 49 Vermont Yanhee has not identified; all documents requested to be identified by that interrogatory, please q . produce for inspection and copying all such documents.
x Objection:
Insofar as Vr mont Yankee understands this request, it calls.for the production of output products of the INPO NPRDS system to which Vermont Yankee objects for the reasons set forth in " Objection to Document 0> Production and Request for Protective Order (INFO Documents)," filed June 15,1990, and " Motion to Supplement Answer of Vermont Yankee Nuclear T- Power Corporation to State of Vermont Motion to Compel (Document Requests, Set No.1)," filed July 24,1990, and requests a protective order in respect of the same.
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I Request No. 36.
Request:
Please produce for inspection and copying all INPO NPRDS com .
- ponent specific failure rate reports since inception ('approaimately mid-1989") for the Vermont Yankee plant.' Documentation should.
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Include, but not be limited to, reports on uninterruptible power and -
- supply and MOVs, as identified in response to Vermont Interrogatory (Set No. 2) No. _49.
Objection:
Insofar as Vermont Yankee understands this request ' it calls for- the' production of output products of the INPO NPRDS system, to: which Vermont Yankee objects for the reasons set forth in
- Objection to Document -
Production and Request for Protective Order (INPO Documents),' filed June .
d! 15, 1990, and " Motion to Supplement Answer of Vermont Yankee Nuclear Power Corporation to State of Vermont Motion to Compel l Document Requests, Set No.1)," filed July 24,-1990, and requests a protecove order in i respect of the same.
Request No. 37.
Request:'
Please-produce for inspection and copying all details of Vermont -
Yankee plant component failures that have been reported to INPO for
. inclusion in the NPRDS data base, as identified in response to Vermont Interrogatory (Set No. 2) No. 50. If in response to Vermont i ' Interrogatory (Set No. 2) No. 50 Vermont Yankee has not identified
' - all~ documents requested to be identified by that interrogatory, please -
-produce for inspection and copying all such documents.
0bjection:-
, Vermont Yankee objects to this request on the ground that it is not-relevant to Contention VII.
Request No. 33.
3 Request:
Please produce for inspection and copying all INPO evaluations of maintenance activities at Vermont Yankee, as identified in response to Vermont Interrogatory (Set No. 2) No. 52. If in response to Vermont Interrogatory (Set No. 2) No. 52 Vermont Yankee has not identified all documents requested to be identified by that inter-o.
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$[ 9 t- rogatory, please produce for inspection and copying all such docu-ments.
- w ' Objection:
All such' documents are classified by INPO as ? Restricted Distribution."
- Vermont Yankee objects to this request for the reasons set forth in " Objection to Document Production and Request for Protective Order (INPO Docu-
_ ments),* filed June 15,1990, and " Motion to Supplement Answer of Vermont 1
- Yankee Nuclear Power Corporation to State of Vermont Motion to Compel =
(Document : Requests Set - No. 1)," filed July ' 24, ' 1990,1 and requests . a protective order in respect of the same.
< Request No. 39.
Please produce for' inspection and copying all Vermont , Yankee performance ir.dicators provided to INPO on a quarterly basis I beginning in 1985, as identified in response to Vermont Interrogatory (Set No. 2) No. 53. If in response to Vermont Interrogatory (Set No.
- 2) No. 53 Vermont Yankee has not identified all documents requested -
to be identified by that interrogatory, please produce for inspection and copying all such documents.
. Objection:
. Vermont Yankee objects to-this request on the ground that it is not relevant to the admitted contention.
Response
B Without waiving the foregoing objection, but rather expressly relying g
upon the same, Vermont Yankee will produce the-performance indicators provided to INPO on a quarterly basis beginnint ' 1985, as identified in the response to Interrogatory No. 53 of Set No,' 2. f inspection and copying at the offices of Vermont Yankee Nuclear F ew. Corporation, Ferry Road, Brattleboro, on a date and at a time mutually t ,, reed upon by counsel for the parties.
Request No. 40.
Request:
> Please prodce for inspection and copying all semi-annral and/or annual reports from INPO showing industry comparisons for
~
performance indicators beginning in 1985, as identified in response -
to Vermont Interrogatory (Set No. 2) No. 54. If in response to
- y. .
4
, . Vermont Interrogatory (Set No ' 2) No. 54. Vermont Yankee has not
-identified all documents' requested to be'idsntified by that inter- H rogatory, please produce for inspection aaJ copying all such docu . .j I
- ments. j i
. ' Objection:
P .
All such'dociments are classified by INFO as " Limited Distribution." j Vermont Yankee objects to this reqtast for the reasons set forth in " Objection i l g . ,
to Document Production'and Request for Protective Order (INPO Docu- ' -
l:. ments)," filed Jun '5,1990, and ' Motion to Supplement Answer of Vermont- > l Yankee Nuclear Power Corporation to State of. Vermont Motion to Compel +
31 .(Document Requests, Set No.1)," filed July 24 1990, and requests a I-protective order in respect of the same.
~ Request No.' 41.
l ; Request: ,
i
~
. Please produce for inspection and copying ' Assessment of Main-u tenance Practices at the Vermont Yankee Nuclear Power Station .l
.(Reference INPO 85-038); VY-88-1250-1," as identified in response - 1 to. Vermont' interrogatory (Set No 2) No. 55. If in response to "I , Vermont Interrogatory (Set No. 2) N9. 55 Vermont Yankee has not Identified all documents requested to be identified by that inter-
- f l
rogatory, please produce for inspection and copying all such docu ' y ments. -
-Response: :
Vermont Yankee will produce the "Assessmeat of Maintenance Practices 1 l
at the Vermont Yankee Nuclear Power Station (VY 1250-1)," as identified or in response to Vermont Interrogatory.(Set No. 2) No. 55, for inspection and I copying at the offices of Vermont Yankee Nuclear Power Corporation, Ferry :l l Road,'Brattleboro, on a date and at a time mutually agreed upon by counsel .'
for the parties.
~
l; , y Request No. 42. .
. Request:
O Please produce for inspection and copying all documentation of the implementation of the recommendations in the INPO report " Asses- !
I, ' ament of Maintenance Practices at the Vermont Yankee Nuclear !
L" ,
Power Station (Reference INPO 85-038); VY-88-1250-1," as iden- '
f tified in response to Vermont Interrogatory (Set No. 2) No. 55.
I. 1
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- Objectlon:;
i.
f Vermont Yankee objects to this request on the ground that the t*m."all .
documentation. of the implementation of-the recommendations" is not =
E - sufficiently specific to permit Vermont Yankee to determine what documents are requested to be retrieved and produced. Vermont Yankee further objects on the ground that the request does not appear to be relevant to Contention Vll. For the underlying document itself(which was prepared by VYNPC and '
not INPO), please see the response to Request No. 41.
14 Request No. 43.
Please produce for inspection and copying INPO Guideline 85.038,
" Guidelines for the Conduct of Maintenance at Nuclear Power-
' Stations", as identified in response to Vermont Interrogatory (Set No.
-2) No. 55.
Objection:
t Vermont Yankee objects to this request for the reasons set forth it.
lp ,
" Objection to Document Production and Request for Protective Order (INPO Documents)," filed June 15. 1990, and " Motion to Supplement Answer of.
Vermont Yankee Nuclear Power Corporation to State of Vermont Motion to I - Compel (Document Requests', Set No.1)," filed July 24,1990, and requests a
. protective order in respect of the same.
Request No. 44 Request:
Please produce for inspection and copying all INPO assessments of Vermont Yankee since 1980.
Objection:
All such documents are classified by INPO as " Restricted Distribution."
Vermont Yankee objects to this request for the reasons set forth in " Objection to Document Production and Request for Protective Order (INPO Docu .
ments)," filed June 15,1990, and
- Motion to Supplement Answer of Vermont Yankee Nuclear Power Corporation to State of Vermont Motion to Compel
'(Document Requests, Set No,1)," filed July 24, 1990, and requests a
~
--; protective order in respect of the same.
k
5 Request No. 45.
i y
Request: l w' I
}
since 1980, applicable to Vermont Yankee.-
21 ~ Objection.
All such documents are classified by INPO as ' Limited Distribution." j er Vermont Yankee objects to this request for the rersons set forth in " Objection ,
to Document Production and Request for Protective Order (INPO Docu- '
ments)," filed June 15,1990, and " Motion to Supplement Answer of Vermont .
~
.W ' Yankee Nuclear Power Corporation to State of Vermont Motion to Compel (Document Requests, Set No.- 1)," filed July 24, 1990,- and requestsLa I
_ protective order in respect of the same. .
A a
Vermont Yankee, noting that documentation of the disposition of all
' maintenance-related SOERs has previously _ been produced for SOV's inspection, further objects to this request on the ground that it is not relevant -l Y to the admitted contention.
Request No. 46.
Request: \
'E , Please produce for inspection and copying allINPO guidelines for 7
,o.
'~ 4 maintenance, applicable to Vermont Yankee, a
' Objection: ,
m
'g All such documents are classified by INPO as." Limited Distribution.">
g3 . Vermont Yankee objects to inis request for the reasons set forth in " Objection U to Document Production and Request for Protective' Order (INPO Docu-
.g, ments)," filed June 15,1990, and " Motion to Supplement Answer of Vermont-Yankee Nuclear Power Corporation to State of Vermont Motion to Compel L3 (Document Requests, Set No.1)," filed July 24, 1990, and requests a - i protective order in respect of the same. '
[i
.x Request No. 47.
l i
' Request:
J Please produce for inspection and copying all documentation of i D Vermont Yankee reviewing, commenting upon,- or using INPO i I Guideline 85-038, " Guidelines for the Conduct of Maintenance at
?, Nuclear Power Stations", as identified in response to Vermont
~
Interrogatory (Set No. 2) No. 79.' If Vecmont Vankee has not 1 -
BE identified all documents requested to be identified by that inter-rogatory, please produce for inspection and copying all such docu-1 8l ments.
Objection:
_ Vermont' Yankee objects to this request on the ground that the term *all documentation of Vermont Yankee reviewing, commenting upon,' or using" -
is not sufficiently specific to permit Vermont Yankee to determine what-8 documents are requested to be retrieved and produced.' Vermont Yankee further objects on the ground that the request does not appear to be relevant to Contention Vll.
To the extent that compliance with this request would necessarily disciose the contents of the referenced document, which is claulfied by INPO as I. ' Restricted Distribution,", Vermont Yankee further objects to this request for -
the reasons set forth in'its " Objection to Document Production and Request for Protective Order (INPO Documents)," filed June 15,1990, its " Motion to I . Supplement Answer of Vermont Yankee Nucle r Power Corporation to State of_ Vermont Motion to Compel (Document Requests, Set No.1)," filed July 24,.1990, and=lts request for a protective order concerning SOV's Inter .
5 rogatory (Set 2) No. 82.a, which request was filed on July 3,- 1990.
4
Response
Without waiving the foregoing objection, but rather expressly relying upon the same, please see the response to' Request No. 41, above.
Request No. 48.
, Request:
= For each and every Vermont Yankee employee (direct or contract) and Yankee Atomic Electric Corporation employee (direct or contract) who has been responsible for or has reviewed, commented upon, or I used INPO Guideline 85-038, " Guidelines for the Conduct. of-Maintenance at' Nuclear Power Stations" in the development' of 1 Vermont Yankee's maintenance program, as identified in response to Vermont- Interrogatory (Set No. 2) No. 79, 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.
Objection:
-Vermont Yankee objects to this request on the ground that it is not relevant to Contention VII.
I Ig : . - - - - _ . -- _ - _ _ _ - -
Q >
a .
J ,
\E - u Vermont Yankee further objects on the grounds that the request, even if t ' it were relevant, is overboard and improperly invades the privacy of the-Individuals in question, and pursuant to 10 C.F.R. $ 2.740(c) requests a protective order ' hat the same not be disclosed.
Request No. 49.
Request:
Please produce for inspection and copying all documeritation of Vermont Yankee reviewing, commenting upon, or using m.PO
- Guideline 83-024, ' Planned Valve Repacking as Preventive Main-
- tenance", as identified in response to Vermont laterrogatory (Set No.'
- 2) No. 82. If Vermont Yankee has not identified all documents requested to be identified by that interrogatory, please produce for 5 inspection and copying all such documents.
Objection:
Vermont Yankee objects to this request on the ground that the term "all documentation of Vermont Yankee reviewing, commenting upon, or using" is not sufficiently specific to permit Vermont Yankee to determine what-documents are requested to be retrieved and prduced. . Vermont Yatkee -
further objects on the tround that the request does .not appear to be relevant -
to Contention VII.
To the extent that compliance with this request would necessarily disclose the contents of the referenced document, which is classified by INPO as I ' Limited Distribution," Vermont Yankee further objects to this request for the reasons set forth in its
- Objection to Document Production and Request for Protective Order (INPO Documents)," filed June 15,1990, its "Motior. toi I Supplement Answer of Vermont Yar.kee Nuclear Power Corporation to State of Vermont Motion to Compel (Document Requests, Set No.1)," filed July -
24, 1990, and its request for a protective order concerning SOV's Inter-t rogatory (Set 2) No. 82.a, which request was filed on July 3,1990.
Response
,' Without walving the foregoing, but rather expressly relying upon the same, Vermont Yankee will produce for inspection and copying at the offices
, of Vermont Yankee Nuclear Power Corporation, Ferry Road, Brattleboro, on i' a date and at a time mutually agreed upon by counsel for the parties,' the documents constituting the preventative valve repacking program referen-I ced in Vermont Yankee's response to SOV's Interrogatory (Set No. 2) No.
82(a).
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Request No. 50.,
. Request:
c.
For each and every Vermont Yankee employee (direct or contract) ~
g _ and Yankee Atomic Electric Corporation employee (direct or contract) -
's-who has been responsible for or has reviewed, commented upon, or used INPO Guideline g3-024,* Planned Valve Repacking as Preventive -
Mainter.ance" in the development of Vermont Yankee's maintenance 1 program, as identified in response to Vermont Interrogatory (Set No.- ,
>! 2) No. 82, please produce for inspection and copying all personnel files,' including but not limited to, performance evaluations, ratings I, ' by supervisors, qualification records, and training records and test-scores.=
Objection: .
-Vermont Yankee objects to this request on the ground that it is not relevant to Contention Vll.
0 Vermont Yankee further objects on the grounds that the request, even if
- lt were relevant, is overboard and improperly invades the privacy of. the "
I."< ,
. individuals in question, and pursuant to 10 C.F.R. I 2.740(c) requests a 1 protective order that the same not be disclosed.
Repi.st No. 51.
Request:
l3 ~ Please produce for inspection and copying all documentation of the
, preventive valve repacking program, as identified in response to '
g Vermont Interrogatory (Set No. 2) No. 82. If in response to Vermont .
g : Interrogatory (Set No. 2) No. 82 Vermont Yankee has not identified
- all documents requested to be identified by that interrogatory, please
' produce for inspection and copying all such documents.
.c"
Response
4 Assuming this request to refer to the documents defining the program in y question, Vermont Yankee will produce the requestedf documents for inspection and copying at the offices of Vermont Yankee Nuclear Power Corporation,- Ferry Road, Brattleboro, on a date and at a time mutually F ' agreed upon by counsel for the parties.
- .1 m
i
r ,i ?
Request No. 52.
Q Request:
b Please produce for inspection and copying 01 documentation of -
Vermont' Yankee reviewing, commenting npon, or using- INPO Guideline 83-045, ' Plant Material: Deficiency identification", as identified in response to Vermont Interrogatory (Set No. 2) No. 83.
If Vermont Yankee has not identified all documents requested to be identified by that interrogatory, please produce for inspection and I x copying all such documents.-
Objection:
Vermont Yankee objects to this request on the ground that the term "all documentation of Vermont Yankee reviewing, commenting upon, or using" 1 is not sufficiently specific to permit Vermont' Yankee to determine what
- documents are requested to be retrieved and produced. Vermont Yankee.
further objects on the ground that the request does not appear to be relevant
- to Contention VII.-
I To the extent th'at compliance with this request would necessarily disclose the contents of the referenced document, which is classified by INPO as Limited Distribution," Vermont Yankee further objects to this' request for
~ the reasons set forth in its ' Objection to Document Production and Request for Protective Order (INPO Documents)," filed June 15,1990, its
- Motion to Supplement Answer of Vermont Yankee Nuclear Power Corporation to State
- of Vermont Motion to Compel (Document Requests, Set No.1)," filed July 24, 1990, and its request for a protective order concerning SOV's Inter-rogatory (Set 2) No. 32.a. which request was filed on' July 3,1990.
, Response:
Without waiving the foregoing objections, but rather expres sly relying upon the same, Vermont Yankee is unaware of the existence of any such
[ - documents, for the reasons set forth in the response to Interrogatory (Set No.
5
- 2) No. 33.
Request No. 53.
Request:
For each and every Vermont Yankee employee (direct or contract) and Yankee Atomic Electric Corporation employee (direct or contract) who reviewed, commented on, or used INPO Guideline 83-045,' Plant Material Deficiency Identification" in the development of Vermont Yankee's maintenance program,' as identified in response to Vermont 4
t
=
Interrogatory.(Set No. 2) No. 83, 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.
Objection:,
Vermont Yankee objects to this request on the ground that_ it is not
-- relevant to Contention VII.
=
Vermont Yankee further objects on the grounds tht: the request, even if j it.were relevant, is o'verboard and improperly invades the privacy of the s individuals in' question, and pursuant to 10 C.F.R. I 2.740(c) requests a protective order that the same not be disclosed.
Response
k Without waiving the foregoing objections, but rather expressly r-lying upon the same, Vermont Yankee states that it presently is not able to identify any such employees, for the reasons set forth in the response to Interrogatory -
- (Set No. 2) No,'83.
. Request No. 54.
y
=
-_ Request:
Please produce for inspection and copying INPO Guideline 83-047,
" Component Verification and System Validation Guidelines."
Objection:
All such documents are classified by INPO as " Limited Distribution."
Vermont Yankee objects to this request for the reasons set forth in " Objection -
to Document Production and Request for Protective Orde..(IMPO Docu-ments)," filed June 15,1990, and " Motion to Supplement Answer of Vermont J_ Yankee Nuclear Power Corporation to State of Vermont Motion to Compel' (Document Requests, Set No.1)," filed July 24, 1990, and requests ' a protective order in respect of the same.
Vermont Yankee further objects on the ground that this request is entirely duplicative of SOV's Request for the Production of Documents (Set No. 2) No. 6.
1 1
t' q ;; - g i
). Y
' ~~
Request No. 55.~
Reqwst: -
i Please produce for: inspection and copying all documentation Vermont Yankee reviewing, commenting upon, or using-inh >
Guideline 83-047, " Component Verification and System Validation
. Guidelines", as identified la response to Vermont laterrogatory (Set No. 2) No. 34; If Vermont Yankee has not identified all document: 1 requested to be identified by that interrogatory, please produce for I inspection and copying all such documents.
Objection:
Vermont Yankee objects to this ret;oest on the ground that the term "all documentation of Vermont Yankee reviewing, commenting upon, or using" 1, is not sufficiently specific to permit Vertront Yankee to determine what documents are requested to be retrieved and produced. Vermont Yankee
~
furtheribjects on the ground that the requN does not appear to be relevant I to Contention Vll. -
- To the extent that compliance with this request would necessarily disclose the contents of the referenced document, which is cicssified by INPO as
" Limited Distribution," Vermont Yankee objects 'to- this request for the reasons set forth in its " Objection to Document Production and Request for
' Protective Order (INPO Documents)," filed June 15,1990, and its " Motion to I Supplement Answer of Vermont Yankee Nuclear Power Corporation to State 4 ~ of Vermont Motion to Compel (Document Requests, Set No.1)," filed July 24,1990, and requests a protective order in respect of the same.
Response
LWithout waiving the foregoing objections, but rather expressly relying
' upon the same Vermont Yankee is unaware of the existence of any such documents, for the reasons set forth in the response to Interrogatory (Set No.
[
B., 2) No. 84.
m
, Request No. 56.
Request:
e For each and every Vermont Yankee employee (direct or contract)
' ' and Yankee Atomic Electric Corporation employee (direct or contract) who reviewed, commented on, or used INPO Guideline g3-047, Cv " Component Verification and System Validation Guidelines" in the development of Vermont Yankee's maintenance program, as identified in response to Vermont Interrogatory (Set No. 2) No. 84, please produce for inspectic a and copying all personnel files, including, but
\
1 5
not limited to, performance evaluations, ratings by supervisors, qualification records, and training records and test scores.
~' Objection:
Vermont Yankee objects to this request on the ground that it is not relevant to Contention VII.
Vermont Yankee further objects on the grounds that the request, even if I- it were relevant, is overboard and improperly invades the privacy of the ladividuals in question, and pursuant to 10 C.F.R. I 2.740(c) requests a protective order that the shte not be disclosed.
Response; Without walving the foregoing objections, but rather expressly relying upon the same, Vermont Yankee states that it presently is not able to identify any such employees, for the reasons set forth in the response to interrogatory I (Set No. 2) No. 84.
Request No. 57.
Request:
Please produce for inspection and copying procedures AP 0028 and AP 0312, .4 identified in response to Vermont Interrogatory (Set No.
B' 2) No. 85. If in response to Vermont Interrogatory (Set No. 2) No. 85 Vermont Yankee has not identified all documents requested to be identified by that interrogatory, please produce for inspection and copying all such documents.
Response
The request for AP 0028 and 0312 duplicates F.equest No.15 of Set No.1, and a copy of the documents was provided to ';OV on June 6,1990.
Request No. 53.
Request:
Please produce for inspection and copying all documentation of Vermont Yankee reviewing, commenting upon, or using- INPO Guideline 34-010.
- vendor Equipmi.nt Technical Information Program", as identified in response to Vermont Interrogatory (Set No.
- 2) No. 85. If Vermont Yankee has not identified 11 documents requested to be identified by that interrogatory, pleau produce for in.pection and copying all such documents.
a-yir ..
J q Objection:
Vermont Yankee objects to this request on the ground that the term *all documentetion of Vermont Yankee reviewing, commenting upon, or using*
( is not sufficiently specific to permit Vermont Yankee to determine what documents are requested to be retrieved and produced. Vert mt Yankee further objects on the ground that the request does not appear to tie relevant to Contention Vll.
To the exteat that c*>mpliance with this request would necessarily disclose
< the contents of the referenced document, which is classified by INPO as
- Limited Distribution,? Vermont Yankee objecu to this request for the reuons set forth in its
- Objection to Document Production and Request for Protective Order (INPO Documents),* filee sune 15, 1990, its ' Motion to a
j Supplement Answer of Vermont Yankee Nuclear Power Corporation to State
-of Vermont Motion to Compel (Document Requests Set No.1),* filed July 24, 1990, and its request for a protective order concerning SOV's Inter-rogatory (Set 2) No. 85.a., which request was filed on July 3,1990.
Response
Without waiving the foregoing objections, but rather cxpressly relying upon the same, Vermont Yankee refers SOY to Vermont Yankee's response to the immediately preceding regt st. n Request No. 59. G i
Request:
J I
For each and every Vermont Yankee employee (direct or contract)
R and Yankee Atomic Electric Corporation employee (direct or contract) who reviewed, commented on, or used INPO Guideline 84-010, l ' Vendor Equipment TechnicalInformation Program" in the develop-ment of Vermont Yankee's maintenance program, as identified in response to Vermont Interrogatory (Set No. 2) No. 85, please produce I- 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.
g p I Objection: ,
Vermont Yankee objects to this request on the ground that it is not
-relevant to Contention Vll.
Vermont Yankee further objects on the grounds that the request, even if it were relevant, is overboard and improperly invades the privacy of the j
Q 5
indi riduals 8n question, and pursuant to 10 C.F.R. I 2.740(c) requests a protective order that the same not be disclosed.
Request No. 60.
Request:
- Please produce for inspection and copying procedures AP 0150 and AP 4000, as identified in response to Vermont laterrogatory (Set No.
- 2) No. 86.
Response
The request for AP 0150 duplicates Request No.17 of Set No. 3 and both requests duplicate Request No. 1 of Set No.1. A copy of AP 4000 was I previously produced on June 6,1990, and insofar as we casi determine no copy of AP 0150 was requested.
Request No. 61.
I Please produce for inspection and copying all documentation of Vermont Yankee reviewing, commenting upon, or using INPO Guideline 84-025,' Operations Surveillance Program *, as identified in response to Vermont Interrogatory (Set No. 2) No. 86. If Vermo' .
I Yankee has not identified all documents requested to be idens'fi< by that interrogatory, please produce for intpection and copying al'.such documentt
.I Objection:
I Vermont Yankee objects to this request on the ground that the term "all documentation of Vermont Yankee reviewing, commenting upon, or using" is not sufficier tly specific tc permit Vermont Yankee to determine what documents are requested to be retrieved and produced. Vermont Yankee further objects on the ground that the request does not appear to be relevant to Contention Vll.
To the extent that compliance with this request would necessarily disclose the contents of the referenced document, which is classified by INPO as
' Limited Distribution,' Vermont Yankee objects to this request for the 1
reasons set forth in its
- Objection to Document Production and Request for Protective Order (INPO Documents),' filed June !!,1990, its ' Motion to Supplement Answer of Vermont Yankee Nuclear Power Corporation to State of Vermont Motion to Compel (Document Requests, Set No.1)," filed July 4
y y., +
w i
8 24, 1990, and its request for a protective order conceraing 50V's Inter-rogatory (Set 2) No. 36.s., which request was filed on July 3,1990.
Response
Without waiving the foregoing objections, but rather express'y relying upon the same, Vermont Yankee refers SOY to Vermont Yankee's response to the immediately preceding request.
Regnest No. 62.
Request:
For each and every Vermont Yankee employee (direct or contract) and Yankee Atomic Electric Corporation employee (direct or contract)
I - who reviewed, commented _ on, or used INPO Guideline 34-025,
' Operations Surveillance Program *,in the development of Vermont Yankee's maintenance program, as identified in response to Vermont -
I Interrogatory (Set No. 2) No. 36, please produce for inspectior, and copying all personnel files, including, but not limited to, performance evaluations, ratings by supervisors, qualification records, and training records and test scores.
objection:
Vermont Yankee objects to this request on the ground that it is not relevant to Contention Vll.
Vermont Yankee further objects on the grounds that the request, even if it were relevant, is overboard and improperly invades the privacy of the individuals in questivn, and pursuant to 10 C.F.R. I 2.740(c) requests a protective order that the same not be disclor,ed.
Request No. 63.
Request:
Please produce for inspection and copying all documentation of Vermont Yankee reviewing, commenting upon, or using INPO Guideline 34-026,'Setpoint Change Control Program", as identified in response to Vermont laterrogatory (Set No. 2) No. 37. If in response to Verniont Interrogatory (Set No. 2) No. 87 Vermont Yankee has not identified all documents reqaested to be identified by that interrogatory, please produce for inspection and copy)ng all such documents.
4
I -t Objection:
Vermont Yankee objects to this request on the ground that the term 'all r dxumentation of Vermont Yankee reviewing, commenting upon, or usin8' is not sufficiently specific to permit Vermont Yankee to determine what I documents are requested to be retrieved and produced. _ Vermont Yankee further objects on the ground that the request does not appear to be relevant to Contention VII.
To the extent that compliance with this request would necessarily disclose the contents of the referenced document, which is classified by INPO as I ' Limited Distribution,* Vermont Yankee objects to this request for the reasons set forth in its ' Objection to Document Production and Request for Protective Order (INPO Documents),' filed June 15,1990, and its " Motion to I Supplement Answer of Vermont Yankee Nuclear Power Corporation to State -
of Vermont Motion to Compel (Document Requests Set No.1),* filed July 24,1990, and requests a protective order in respect of the same.
I Response:
I Without waiving the foregoing objection, but rather expressly relying upon the same, please see the response to Interrogatory (Set No. 2) No. 87.
Request No. 64.
For each and every Vermont Yankee employx (direct or contract) and Yankee Atomic Electric Corporation employee (direct or contract) who reviewed, commented on, or used INPO Guideline 84-026, "Setpoint Change Control Program" in the development of Vermont I Yankee's maintenance program, as identified in response to Vermont Interrogator'c (Set No. 2) No. 87, please produce for inspection and copying ali exsonnel files, including, but not limited to, performance 1
I evaluatior , ratings by supervisors, qualification records, and training records and test scores.
Ob.lection:
Vermont Yankee objects to this re w sest on the ground that it is not relevant to Contention VII.
I Vermont Yankee further objects on the grounds that the request, even if it were relevant, is overboard and improperly invades the privacy of the I individuals in question, and pursuant to 10 C.F.R. I 2.740(c) requests a protective order that the same not be disclosed.
31 I
I
Ay i
- M-a Request No. 65.
~i Request:
Please produce for inspection and copying all dccumentation of 1 Vermont Yankee reviewing, commenting upon, or using INPO Guideline 87-009, as identified in response to Vermont laterrogatory (Set No. 2) No. 88. 'f in response to Vermont laterrogatory (Set No.
I 2) No. 88 Vermont Yankee has not identified all documents requested to be identified by that inter >ogatory, please produce for inspection and copying all such documentt Objection:
Vermont Yankee objects to this request on the ground that the term "all I documentation of Vermont Yankee reviewing, commenting upon, or using" is not sufficiently specific to permit Yermont Yankee to determine what documents are requested to be retrieved and produced. Vermont Yankee I further objects on the ground that the request does not appear to be relevant to Contention Vll.
To the extent that compliance with this request would necessarily disclose the contents of the referenced document, which is classified by INPO as
' Limited Distribution, Vermont Yankee objects to this request for the
- reasons set forth in its ' Objection to Document Production and Request for Protective Order (INPO Documents)," filed June 15, 1990, its ' Motion to Supplement Answer of Vermont Yankee Nuclear Power Corporation to State of Vermont Motion to Compel (Document Requests, Set No.1),' filed July I 24, 1990, and its request for a protective order concerning SOV's Inter-rogatory (Set 2) No. 99.a., which request was filed on July 3,1990.
Resconse:
Without walving the foregoing objections, but rather expressly relying I upon the same, Vermont Yankee refers SOY to Vermont Yankee's response to Request No. 88, below.
Request No. 66.
Request:
For each and every Vermont Yankee employee (direct or contract) and Yankee Atomic Electric Corporation employee (direct or contract) who reviewed, commented on, or used INPO Guideline 87-009 in the development of Vermont Yankee's maintenance program, as identified in response to Vermont Interrogatory (Set No. 2) No. 88, please
produce for inspection and cory.;ng all personnel files, .8ncluding, but not limited to, perform *..ee evanustions, ratings by supervisors, qualification records, and training record and test scores.
Objection:
Vermont Yankee objects to this request on the ground that it is not relevant to Contention VII.
Vermont Yankee further objects on the grounds that the request, even if it were relevant, is overboard aci improperly invades the privacy of the individucts !n question, and pursuant to 10 C.F.R. $ 2.740(c) requests a protective order that the same not be disc'osed.
=
Request No. 67.
,' Request:
Please produce for inspection and copying INPO Guideline 85-001,
'Perforniance Objectives and Criteria for Operating and Near-term Op rating Licer:se Plants.'
Objection:
Vermont Yankee objects to this request on the grounds that, not only is this request wholly duplicative of SOV's Document Request (Set 2) No.11
- but, indeed, Vermont Yankee has already made the requested document available to SOV. See ' Responses of Vermont Yankee Nuclear Power Corporation to Document Requests Propounded by the State of Vermont (Set No. 2)" at 2 and 5 (June 15,1990).
Request No. 68.
Please produce for inspection and copying all documentation of Vermont Yankee reviewing, commenting upon, or using INPO Guideline 85-001,' Performance Objectives and Criteria for Operating and Near-term Operating License Plants", as identified in response to Vermont interrogatory (Set No. 2) No. 89. If in response to Vermont interrogatory (Fat No. 2) Nc. 89 Vermont Yankee has not identified all documents reycasted to be identified by that interrogatory, please produce for inspection and copying all such documents.
j Objection:
Vermont Yankee objects to this request on the ground that the term "all documentation of Vermont Yankee reviewing, commenting upon, or using' 33 -
l
=
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is not sufficiently specific to permit Vermont Yankee to determine what documents are requested to be retrieved and produced. Vermont Yankee
$j] further objects on the ground that the request does not appear to be relevant L_ to Contention Vll.
To the extent that compliance with this request would necessarily disclose tne contents of the referenced document, which is classified by INPO as
' Limited Distribution,' Vermont Yankee objects to this request for the I reasons set forth in its
- Objection to Document Production and Request for Protective Order (INPO Documents),' filed June 15,1990, and its ' Motion to Supplement Answer of Vermont Yankee Nuclear Power Corporation to State I of Vermont Motion to Compel (Document Requests, Set No.1),' filed July 24,1990, and requests a protective order in respect of the same.
Respcae:
Without waiving the foregoing objections, but rather expressly relying upon the same, Vermont Yankee is_ untware of the existence of any such documents, for the reasons set forth in the response to Interrogatory (Set No.
- 2) No. 89.
Reqvest No. 69.
Request:
For each and every Vermont Yankee ec ployee (direct or contract)
I and Yankee Atomic Electric Corporation employee (direct or contract) who reviewed, commented on, or used INPO Guideline 85-001,- -
" Perform <.,nce Objectives and Criteria for Operating and Near-term Operr. ting License Plants" in the development of Verm( Ai Yankee's I maintenance program, as identified in response to Versomt Inter-roa,atory (Set No. 2) No. 89, please produce for inspection and copying all personnel files, including, t'ut not limited to, performance evaluations, ratings by superviv s, qualification records, and training I records and test scores.
Objection:
I Vermont Yankee objects to this request on the ground that it is not relevant to Contention Vll.
Vermont Yankee further objects on the grounds that the request, even if it were relevant, is overboard 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 ths same not be disclosed.
I I
____7.__.._..
I !
Response: ,
1 Without waiving the foregoing objections, but rather expressly relying j I upon the same, Vermont Yankee states that it presently is not able to identify ,
any such employees, for the reasons set forth in the response to Interrogatory l (Set No. 2) No. 89. ,
Roguest No. 70.
Request:
Please produce for inspection and copying all documentation of Vermont Yankee reviewing, commenting upon, or using INPO l Guideline 85-010. ' Surveillance end Periodic Task Scheduling ;
I Program", as identified in response to Vermont Interrogatory (Set No. l
- 2) No. 90. . If in response to Vermont Interrogatory (Set No. 2) No. ?
90 Vermont Yankee has not identified all documents requested to be i identified by that interrogatory, please produce for inspection and I copying all such documents.
Objection:
Vermont Yankee objects to this request on the ground that the term "all ,
documentation of Vermont Yankee reviewing, commenting upon, or using' i
I is not sufficiently specific to permit Vermont Yankee to determine what documents are requested to be retrieved and produced. Vermont Yankee !
further objects on the ground that the request does not appear to be relevant ,
to Contention VII.
To the extent that compliance with this request would necessarily disclose the contents of the referenced document, which is classified by INPO as I
" Limited Distribution,' Vermont Yankee further objects to this request for _1 the reasons set forth in its "Ob.iection to Document Prodnetion and Request !
for Protective Order (INPO Documents)," filed June 15,1990, its ' Motion to I __ Supplement Answer of Vermont Yankee Nuclear Power Corporation to State of Vermont Motion to Compel (Document Requests Set No; !)," filed July 24, 1990, and its request for a protective order concerning SOV's Inter-I ~
rogatory (Set 2) No. a2.a. which request was filed on July 3,1990.
Response: ;
Without walving the foregoing objections, but rather expressly relying ,
upon the same, Vermont Yankee is unaware of the existence of any such documents, for the reasons set forth in the response to Interrogatory (Set No.
- 2) No. 90.
l l
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1, i
j; g Request No. 71.
Request:
I For each and evcry Vermont Yankee employee (direct or contract) and Yankee AO & Elent'c Corporation employee (direct or contract) i l
who reviewed, com.riented on, or used INPO_ Guideline 45-010, I
" Surveillance and Periodic Task Scheduling Program' in the develop- 2 mr at of Vermont Yankee's maintenance- program, as identified in j
' response to Vermont Interrogatory (Set No. 2) No. 90, please produce '
I 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.
?
Objection:
Yermont Yankee objects to this request on the ground that it is not !
relevant to Contention VII.
Vermont Yankee further objects on the grounds that.the request, even if I it were relevant, is overboard 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.
t Response: ;
i I Without walving the foregoing objections, but rather expressly relying upon the same, Vermont Yankee states that it presently is not able to ideatify any such employees, for the reasons set forth in the response to Interrogatory 1
(Set No. 2) No. 90. !
Request No. 72. .,
Request:
Please produce for inspection and copying DWO 85-016," Temporary i Modification Control,' identified in Vermont Interrogatory (Set No.
I .
- 2) No. 92.
Objection:
i Vermont Yankee objects to this request for the reasons set forth in its objection to Interrogatory (Set No. 2) No. 92 and Document Request (Set No.
- 2) No.14, of the latter of which this request appears to be a perfect duplication.
I '
I <
LI lI Regmest No. 73.
Request:
Please produce for inspection and copying procedure AP 0831, as identified in response to Vermont Interrogatory (Set No. 2) No. 93.
Response
The request for AP 0831 duplicates Request No.15 of Set No.1, and a copy of the document was produced for inspection and inspected by SOV's representative.
Request No. 74.
Request:
Please produce for inspection and copying all documentation of Vermont Yankee reviewing, commenting upon, or using INPO -
I Guideline 85-026 " Writing Guideline for Maintenance. Test and Calibration Procedures', as identified in response to Vermont Interrogatory (Set No o No. 93. If in response to Vermont Inter-rogatory (Set No. 2) No. 93 Vermont Yankee has not identified all I documents requested to be identified by that interrogatory, please produce for inspection and copying all such documents.
Objection:
Vermort Yankee objects to this request on the ground that the term "all I documentHlon of Vermont Yankee reviewing, commenting upon, or using" is not svificiently specific to permit Vermont Yankee to determine what docununts are requested to be retrieved and produced. Vermont Yankee I
further objects on the ground that the request does not appear to be relevant te Contention Vll.
To the extent that complishee with this request would necessarily disclose I the conter.ts of the referenced document, which is classified by INPO as
" Limited Distribe*lon," Vermont Yankee objects to this request for the reasons set forth in its ' Objection to Document Production and Request for
- I Protective Order (INPO Documents)," filed June 15, 1990, its ' Motion to
_ Supplement Answer of Vermont Yankee Nuclear Power Corporation to State of Vermont Motion to Compel (Document Requests Set No.1),* filed July I
24, 1990, and its request for a protective order concerning SOV's Inter-rogatory (Set 2) No. 93.a., which request was filed on July 3,1990.
I I I I
LI-I Response:
Without waiving the foregoing objections, but rather expressly relying upon the same, Vermont Yankee refers SOY to Vermont Yankee's response to the immediately preceding request.
Request No. 75.
Request:
For each and every Vermont Yankee employee (direct or contract)
I and Yankee Atomic Electric Corporation employee (direct or cotitract) who reviewed, commented on, or used INPO Guideline 85-026,
' Writing Guideline for Maintenance, Test and Calibration Procedures" in the development of Vermont Yankee's maintenance program, as identified in response to Vermont Interrogatory (Set No. 2) No. 93,
+ 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.
I Objection:
I Vermont Yankee objects to this request on the ground that it is not relevant to Contention VII.
I Vermont Yankee further objects on the grounds that the request, even if it were relevant, is ovirboard 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.
Request No. 76.
Request:
Please produce for inspection and ceryir.g all documentr.tlen of
$ Vermont Yankee reviewing, commenting upon, or using INPO Guideline 85-0311,' Guidelines for the Conduct of Technical Support 5 Activities at Nuclear Power Stations", as identified in response to 4 Vermont Interrogatory (Set No. 2) No. 94. If in response to Vermont El Interrogatory (Set No. 2) No. 94 Vermont Yankee has not identified all documents requested to identified by that interrogator /, please produce for inspection and copying all such documents.
Objection:
Vermont Yankee objects to this request on the ground that the term "al documentation of Vermont Yankee reviewing, commenting upon, or using' is not sufficiently specific to permit Vermont Yankee to determine what I 1 I
I documents are requested to be retrieved and produced. Vermont Yankee further objects on the ground that the request does not appear to be relevant
'I to Contention Vll.
To the extent that compliance with this request 'vould necessarily disclose '
the zontents of the referenced document, which is classified by INPO as
\I ' Limited Distribution,' Vermont Yankee further objects to this request for the reasons set forth in its ' Objection to Document Production and Request I for Protective Order (INPO Documents)," filed June 15,1990, its " Motion to Supplement Answer of Vermont Yankee Nuclear Power Corporation to State of Vermont Motion to Compel (Document Requests Set No.1)," filed July I 24, 1990, and its request for a protective order concerning SOV's later-rogatory (Set 2) No. 82.a. which request was filed on July 3,1990.
Response
Without waiving the foregoing objections, but rather expressly rei ins upon the same, Vermont Yankee is unaware of the existence of any such IF documents, for the reasons set forth in the response to Interrogatory (Set No.
. 2) No. 94.
Request No. 77.
Request:
For each and every Vermont Yankee employee (direct or contract)
I and Yankee Atomic Electric Corporation employee (direct or contract) who reviewed, commented on, or used INPO Guideline 35-031,
" Guidelines for the Conduct of Technical Support Activities at Nuclear Power Stations" in the development of Vermont Yankee's maintenance program, as identified in response to Vermont Inter-i.
rogatory (Set No. %. No. 94, please produce for inspection and copying all personnel file , including, but- not limited to, performance i evaluations, ratings by supervisors, qualification records, and training records and test scores.
Objection:
Vermont Yankee objects to this request on the ground that it is not relevant to Contention Vll.
Vermont Yankee further ob*ects on the grounds that the request, even if it were relevant, is overboard and improperly invades the privacy of the l Individuals in question, and pursuant to 10 C.F.R. I 2.740(c) requests a lI1 protective order that the same nc't be disclosed.
8 I I
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' Response:
Without walving the foregoing objections, but rather expressly relying 4
g upon the same, Vermont Yankee states that it presently is not able to identify W any such employees, for the reasons set forth in the response to Interrogatory )
(Set No. 2) No. 94. )
Request No. 78.
Request: .
Please produce for inspection and copying procedure AP 0021, as ,
identified in response to Vermont Interrogatory (Set No. 2) No. 95.-
Response
The request for AP 0021 duplicates Request No.15 of Set No.1, and a ;
copy of the document was provided to SOY on June 6,1990.
Request No. 79.
Request:
Please produce for inspection and copying all documentation of :
^
Vermont Yankee neviewing, commenting upon, or using INPO L
I' Guideline 85-032,' Preventive Maintenance", as identified in response to Vermont Interrogatory (Set No. 2) No. 95, if in response to Vermont Interrogatory (Set No. 2) No. 95 Vermont Yankee has not ;
I identified all documents requested to be identified by that inter-rogatory, please produce for inspection and copying all such docu-ments. '
Objection' Vermont Yankee objects to this request on the ground that the ter:n 'all iE documentation of Vermont Yankee reviewing, commenting upon, or using" 3
is not sufficiently specific to permit Vermont Yankee to determine what documents are requested to be retrieved and produced. ' Vermont Yankee I further objects on the ground that the request does not appear to be relevant to Contention Vll.
To the extent that compliance with this request would necessarily disclose the contents of the referenced document, which is classified by INPO as
" Limited Distribution," Vermont Yankee further objects to this request Nr the reasons set forth in its " Objection to Document Production and Requot for Protective Order (INPO Documents)," filed June 15,1990, its " Motion to 3 L
- 40 I ^
-G , ,
6 bpplement Answer of Vermont Yankee Nuclear Power Corporation to State
- of Vermont Motion to Compel (Document Requests, Set No.1)," filed July 24, 1990, and its request for a protective order concerning SOV's Inter-rogatory (Set 2) No. 95.a. which request was filed on July 3,1990.
Response
Without waiving the foregoing objections, but rather expressly relying upon the same, Vermont Yankee refen SOY to Vermont Yankee's response
- to the immediately preceding request.
Regmest No. 80.
Request:
For each and every Vermont Yankee employee (direct or contract) _
and Yankee Atomic Electric Corporation employee (direct or contract) who reviewed, commented on, or used INPO Guideline 85-032,
' Preventive Maintenance" in the development of Vermont Yankee's maintenance program, as identified in response to Yermont Intcr-rogatory (Set No. 2) F1. 95, please produce for ' inspection and copying all personnel file' includir1, but not !!mited to, performance evaluations, ratings by super ers, qualification records, and training records and test scores.
Objection:
Vermont Yankee objet.s to this request on the ground that it is not relevant to Contention Vll.
Vermont Yankee further objects on the grounds that the request, even if it were relevant, is overboard 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.
Request No. 81.
Request:
Please produce for inspection and copying all documentation of Vermont Yankee reviewing, commenting upon, or using INPO Guideline 86-002, " Maintenance History Program", as identified in response to Vermont Interrogatory (Set No. 2) No. 96, if in response to Vermont Intbrrogatory (Set No. 2) No. 96 Vermont Yankee has not identified all documents requested to be identified by that inter-rogatory, please produce for inspectior and copying all such docu-
. ments.
R- .
.c i
a Objection:
Vermont Yankee objects to this request on the ground that the term 'all documentation of Vermont Yankee reviewing, commenting upon, or using" g is siot sufficiently specific to permit Vermont Yankee tc determine.what y documents are requested to be retrieved and prodes# Vermont Yankee further objects on the ground that the request does t e Sw to be relevant to Contention Vll.
To the extent that compliance with this request would necessarily disclose the conzents of the referenced document, which is classified by INPO as I ' Limited Distribution,' Yermont Yankee further objects to this request for the reasons set forth in its ' Objection to Document Production and Request for Protective Order (INPO Documents),' filed June 15,1990, i:s ' Motion to I Supplement Answer of Vermont Yankee Nuclear Powei Corporation to State of Vermont Motion to Compel (Document Requests. Set No.1),' filed July 24, 1990, and its request for a protective order concerning MV's Inter-rogatory (Set 2) No. 82.n, which request was filed on July 3,1990.
Response
- l Without waiving the foregoing objections, but rather expressly relying upon the same, Vermont Yankee is unaware of the existence of any such documents, for the reasons set forth in the response to Interrogatory (Set No.
i 2) No. 96.
Request No. 32.
I For each and every Vermont Yankee employee (direct or contract) and Yankee Atomic Electric Corporation (direct or contract) .vho reviewed, commented on, or used INPO Guideline 86-002, "Mai-ntenance History Program
- In the development of Vermont Yankee's
,I maintenance program, as identified in response to Vermont Inter-rogatory (Set No. 2) No. 96, please produce for inspection and copying all personnel files, including, but not limited to, performance evaluations, ratings by supervisors, qualifiestion records, and training records and test scores.
Objection:
Vermont Yankee objects to th' request on the ground that it is not relevant to Contention Vll.
I Vermont Yankee further objects on the grounds that the sequest, even if it were relevant, is overboard and improperly invades the privacy of the I individuals in question, and pursuant to 10 C.F.R. l 2.740(c) requests a protective order that the same not be disclosed.
Response
Without walving the foregoing objections, but rather expressly relying i
upon the same, Vermont Yankee states that it presently is not able to identify
=~ any such employees, for the reasons set forth in the response to Interrogatory (Set No. 2) No. M.
5 Request No. 33.
Request:
Please produce for inspection and copying all documents identified in response to Vermont Interrogatoiy (Set No. 2) No. 97. Documents should include, but not be limited to, documentation of the following:
- b. Procedure OP 5203; and
- c. Each and every documentation of snubber vendor information.
I Objection:
Vermt.it Yankee objects to this request, for the reasons set forth above in its objection to Request No. 5.
Response
Without waiving the foregoing objections, but rather expressly relying on the same, Vermont Yankee will produce the Snubber Maintenance Program and OP 5203 for inspection and copying at the offices of Vermont Yankee I Nuclear Power Corporation. Ferry Road, Brattleboro, on a date and at a time mutually agreed upon by counsel for the parties, !
Request No. 34.
Request:
Please prodtce for inspection and copying all documentation of Vermont Yankee reviewing, commenting upon, or using INPO I Guideline g6-014," Snubber Maintenance Program", as identified ic response to Vermont Interrogatory (Set No. 2) No. 97. If in response to Vermont Interrogatory (Sct No. 2) No. 97 Vermont Yankee has not 8 1 i
1
)
identified all documents requetted to be identified by that inter-rogatory, please produce for inspection and copying all such docu-ments.
1 Objection:
Vermont Yankee objects to this request on the ground that the t. m "all documentation of Vermont Yankee reviewing, commenting upon, or using*
k8 is not sufficiently specific to permit Vermont Yankee to determin what documents are requested to be retrieved and produced. Vermont Yankee further objects on the ground that the request does not appear to be relevant to Contention Vll.
To the extent that cortpliance with this request would necessarily disclose the contents of the referenced document, which is classified by INPO as I " Limited Distribution," Vermont Yankee further ot+ cts to this request for the reasons set forth in its " Objection to Document iioduction and Request lB for Protective Order (INPO Documents)," filed June 15,1990, its " Motion to Supplement Answer of Vermont Yankee Nuclear Power Corporation to State of Vermont Motion to Compel (Document Requests, Set No.1)," filed July 24, 1990, and its request for a protective order concerning SOV's Inter-rogatory (Set 2) No. 97.a. which request was filed on July 3,1990.
Response
Without waiving the foregoing objections, but rather expressly relying upon the same, Vermont Yankee refers SOY to Vermont Yankee's response to the immediately preceding : :uest.
Request No. 85.
I Request:
For each and every Vermont Yankee employee (direct or contract) and Yankee Atomic Electric Corporation employee (direct or contract) who reviewed, commented on, or used INPO Guideline 86-014,
" Snubber Maintenance Program
- in the development of Vermont Yankee's maintenance program, as identified in respons . to Vermont interrogatory (Set No. 2) No. o7, please produce for it.spection and copying all personnel files, including, but not limited to . performance evaluations, ratings by supervisors, qualification record, and training records and test scores.
Objection:
Vermont Yankee objects to this request on the ground that it is not relevant to Contention Vll.
L i .
Vermont Yankee further objects on the grounds that the request, even if 8 it were relevant, is overboard 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.
Request No. 86.
Request:
Please produce for inspection and copying all documentation of Vermont Yankee's performance based training program, as identified in response to Vermont interrogatory (Set No. 2) No. 93, if in 8 response to Vermont interrogatory (Set No. 2) No. 93 Vermont Yankse 4= has not identified r4l documents requested to be identified by that interrogatory, plea'e produce for inspection and copying all such documents.
Objection:
Vermont Yankee objects to this request on the ground that it is not relevant to Contention VII Vermont Yankee further objects on the grounds I that, even if the request were relevant, it is overbroad.
Request No,37.
Request:
For Jach and every Vermont Yankee employee (direct or contract) and Yankee Atomic Electric Corporation employee (direct or contract) who reviewed, commented on, or used INPO Guideline 36-018,
' Guidelines for Training and Qualification of Maintenance Personnel" in the development of Vermont Yankee's maintenance program, as I, identified in response to Vermont Interrogatory (Set No. 2) No. 98, please produce for inspection and copying all personnel files, includin8, but not limited to, performance evaluations, ratings by supervisors, qualification records, and training records and test scores.
i Objection:
Vermont Yankee objects to this request on the ground that it is not relevant to Contention VII.
Vermont Yankee further objects on the grounds that the request, even if it were relevant, is overboard and improperly invades the privacy of the individuals in question, and pursuant to 10 C.F.R. $ 2.740(c) requests a I protective order that the same not be disclosed.
5 I I i
I I Request No. 88.
Request:
Please produce for inspection and copying plant procedure 0312, an identified in response to Vermont Interrogatory (Set No. 2) No. 99.
Response
The request for AP 0312 duplicates both Request No. 57, above, and Document Requests (Set No.1) No.15. In all events, a copy of the document was provided to SOY on June 6,1990.
Regnest No. 89.
Request:
Please produce for inspection and copying all documentation of Vermont Yankee reviewing, commenting upon, or using INPO I Guideline 87-009, ' Control of Vendor Manuals", as identified in response to Vermont interrogatory (Set No. 2) No. 99 If in response to Vermont laterrogatory (Set No. 2) No. 99 Vermont Yankee has not I identified all documents requested to be identified by that inter-togatory, please produce for inspection and copying all such docu-ments.
Objection:
Vermont Yankee respectfully objects to the necessity of responding to the identical request for a second time; please see the response to Request No. 65, 8 above.
Request No. 90.
For each and every Vermont Yankee employee (direct or contract) and Yankee Atomic Electric Corporation employee (direct or contract) who reviewed, commented on, or used INPO Guideline 87-009,
' Control of Vendor Manuals
- in the development of Vermont Yankee's maintenance program, as identified in response to Vermont Inter-rogatory (Set No. 2) No. 99, 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.
46 -
I ;
L Ob)trilon:
Vermont Yankee respectfully objects to the necessity of responding to the identical request for a second time; please see the response to Request No. 66, above.
Request No. 91.
Request:
For each and every Vermont Yankee employee (direct or contract) and Yankee Atomic Electric Corporation employee (direct or contract)
LI who reviewed, commented on, or used INPO Guideline 87-028,
- Post-Maintenance Testing"in the development of Vermont Yankee's main-L tenance program, as identified in response to Vermont Interrogatory
'I (Set No. 2) No.100, please produce for inspection and copying all-a personnel files, including but not ilmited to, performance evaluations, ratings by supervisors, qualification records, and training records and test scores.
Objection:
Vermont Yankee objects to this request on the ground that it is not relevant to Contention Yll.
Vermont Yankee further objects on the grounds that the request, even if -
it were relevant, is overboard 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.
Request No. 92.
Request:
Please produce for inspection and copying all documentation of Vermont Yankee reviewing, commenting upon, or using INPO
+ Guidelir.e 88-022,
- Vendor Manual Specification and Procurement",
I as identified in response to Vermont Interrogatory (Set No. 2) No.
101. If in resronse to Vermont interrogatory (Set No. 2) No.101 I Vermont Yankee has not identified all documents requested to be identified by that interrogatory, please produce for inspection and copying all such documents.
Objection:
Vermont Yankee objects to this request on the ground that the term *all documentation of Vermont Yankee reviewing, commenting upon, or using*
ls not sufficiently specific to permit Vermont Yankee to determine what 5 .
I
I documents are requested to be retrieved and produced. Vermont Yankee i further objects on the ground that the request does not appear to be relevant to Contention Vll.
I To the extent that compliance with this request would necessarily disclose the contents of the eferenced document, which is classified by INPO as
" Limited Distribution,' Vermont Yankee further objects to this request for the reasons set forth in its
- Objection to Document Production and Request I for Protective Order (INPO Documents)," filed June 15,1990, its ' Motion to Supplement Answer of Vermont Yankee Nuclear Power Corporation to State of Vermont Motion to Compel (Document Requests, Set No.1)," filed July I 24, 1990, and its request for a protective order concerning SOV's inter-rogatory (Set 2) No. 82.a. which request was filed on July 3,1990.
Response
Without waiving the foregoing objections, but rather expressly relying I upon the same, Vermont Yankee is unaware of the existence of any such documents, for the reasons set forth in the response to Interrogatory (Set No.
Request No. 93.
Request:
For each and every Vermont Yankee employee (direct or contract) and Yankee Atomic Electric Corporation employee (direct or contract) who reviewed, commented on, or used INPO Guideline 88 022,
' Vendor Manual Specification and Procurement" in the development of Vermont Yankee's maintenance program, as identified in response to Vermont Interrogatory (Set No. 2) No.101, 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.
Objection:
Vermont Yankee objects to this request on the ground 2 hat it is not rele* ant to Contention VII.
Vermont Yankee further objects on the grounds that the request, even if it were relf vant, is overboard and improperly invades the privacy of the individuals :n question, and pursuant to 10 C.F.R. I 2.740(c) requests a protective order that the same not be disclosed.
4 8
Response
Without waiving the foregoing objections, but rather expressly relying upon time same, Vermont Yankee states that it presently is not able to identify any such employees, for the reasons set forth in the response to laterrogatory 8 (Set No. 2) No.101.
Regeest No. 94.
8 Request:
Please produce for inspection and copying all documentation of 8 Vermont Yankee reviewing, commenting upon, or using INPO Guideline 39-009,' Plant Predictive Maintenance
- in the development of Vermont Yankee's maintenance program, as identified in response I to Vermont Interrogatory (Set No. 2) No.102. If in response to Vermont interrogatory (Set No. 2) No.102 Vermont Yankee has not identified all documents requested to be identified by that inter-I rogatory, please produce for inspection and copying all such docu-ments.
Objection:
Vermont Yankee objects to this request on the ground that the term 'all documentation of Vermont Yankee reviewing, commenting upon, or using" I is not sufficiently specific to permit Vermont Yankee to determine what documents are requested to be retrieved and produced. Vermont Yankee further objects on the ground that the reque' does not appear to be relevant to Contention Vll.
To the extent that compliance with this request would necessarily disclose the contents of the referenced document, which is classified by INPO as I ' Limited Distribution,' Vermont Yankee further objects to this request for the reasons set forth in its " Objection to Document Production and Request for Protective Order (INPO Documents)," filed June 15,1990, its ' Motion to I Supplement Answer of Vermont Yankee Nuclear Power Corporation to State of Vermont Motion to Compel (Document Requests, Set No.'l),' filed July 24, 1990, and its request for a protective order concerning SOV's inter-rogatory (Set 2) No. 32.a. which request was filed on July 3,1990.
Response
Without waiving the foregoing objections, but rather expressly relying upon the same, Vermont Yankee is unaware of the existence of any such documents, for the reasons set forth in the response to Interrogatory (Set No.
- 2) No.102.
I 5
J Request No. 95.
Request:
J For each and every Vermont Yankee employee (direct or contract) and Yankee Atomic Electric Corporation employee (direct or contract) lg who reviewed, commented on, or used INPO Guideline 89-009,' Plant Predictive Maintenance' in the development of Vermont Yankee's g maintenance program, as identified in response to Vermont Inter-l rogatory (Set No. 2) No.102, please produce for inspection and copying all personnel files, including but not limited to, performance I. evaluations, ratings by supervisors, qualification records, and training records and test scores.
Objection:
Vermont Yankee objects to this request on the ground that it is not relevant to Contention VII.
Vermont Yankee further objects on the grounds that the request, even if it were relevant, is overboard and improperly invades the privacy of the I individuals in question, and pursuant to 10 C.F.R. I 2.740(c) requests a protective order that the same not be disclosed.
Response
Without waiving the foregoing objections, but rather expressly relying I upon the same, Vermont Yankee states that it presently is not able to identify any such employees, for the reasons set forth in the response to Interrogatory (Set No. 2) No.102.
Request No. 96.
Request:
Please produce for inspection and copying INPO Operation and Main-tenance Reminder O&MR-308, identified in Vermont Interrogatory I (Set No. 2) No.103, if in response to Vermont Interrogatory (Set No.
- 2) No.103 Vermont Yankee has not identified all documents requested to be identified by that interrogatory, please produce for inspection and copying all such documents.
Objection:
All such documents are classified by INPO as ' Limited Distribution."
Vermont Yankee objects to this request for the reasons set forth in ' Objection
f, to Document Production and Request for Protective Order (INPO Docu-ments),' filed June 15,1990, and ' Motion to Supplement Answer of Vermont 8 Yankee Nuclear Power Corporation to State of Vermont Motion to Compel (Dxument Requests, Set No.1),* filed July 24, 1990, and requests a protective order in respect of the same.
Vermont Yankee further objects on the grounds that, not only is this request wholly duplicative of SOV's Document Request (Set 2) No. 26, but I also that,in response to that request, Vermont Yankee has already staied that it does not possess a copy of the document requested. See ' Responses of Yemont Yankee Nuclear Power Corporation to Document Request I Pts, sounded by the State of Vermont (Set No. 2)* at 4 (June 15,1990).
Request No. 97.
Please produce for inspection and copying INPO Guideline 87-030,
' Performance Objectives and Criteria for Corporate Evaluations '
Objection:
Vermont Yankee objects to this request on the ground that the subject document is not releva.nt to Contention Vll.
All such documents are classified by INPO as ' Limited Distribution.'
Vermont Yankee further objects to this request for the reasons set forth in
' Objection to Document Production and Request for Protective Order (INPO I Documents),' filed June 15, 1990, and ' Motion to Supplement Answer of Vermont Yankee Nuclear Power Corporation to State of Vermont Motion to Compel (Document Requests, Set No.1)," filed July 24,1990, and requests a protective order in respect of the same.
Request No. 98.
I Request:
Please produce for inspection and copying all documentation of Vermont Yankee- reviewing, commenting upon, or using INPO B Guideline 87-030,* Performance Objectives and Criteria for Corporate Evaluations', as identified in response to Vermont Interrogatory (Set I No. 2) No.104. If in response to Vermont Interrogatory (Set No. 2)
No.104 Vermont Yankee his hot identified all documents reque led to be identified by that interrogatory, please produce for inspect;on and copying all such documents.
I-I !
I
'I Objection:
Vermont Yankee objects to this request on the ground that the term "all documentation of Vermont Yankee reviewing, commenting upon, or using" is not sufficiently specific to permit Vermont Yankee to determine what 8 documents are requested to be retrieved and produced. Vermont Yankee further objects on the ground that the request does not appear to be relevant to Contention VII.
To the extent that compliance with this request would necessarily disclose the contents of the referenced document, which is classified by INPO as
" Limited Distribution,' Vermont Yankee further objects to this request for I the reasons set forth in its ' Objection to Document Production and Request for Prctective Order (INPO Documents),' filed June 15,1990, its ' Motion to
)ylx Supplement Answer of Vermont Yankee Nuclear Power Corporation to State of Vermont Motion to Compel (Document Requests, Set No.1)," filed July 24, 1990, and its request for a protective order concerning SOV's Inter-
- rogatory (Set 2) No. 82.e. which request was filed on July 3,1990.
k-
Response
Without waiving the foregoing objections, but rather expressly relying upon the same, Vermont Yankee is unaware of the existence of any such I documents, for the reasons set forth in the response to Interrogatory (Set No.
- 2) No.104.
Ltquest No. 99.
For each and every Vermont Yankee employee (direct or contract)
I and Yankee Atomic Electric Corporation employee (direct or contract) who reviewed, commented on, or used INPO Guideline 87-030,
' Performance Objectives and Criteria for Corporate Evaluations" in the development of Vermont Yankee's maintenance program, as I identified in response to Vermont Interrogatory (Set No. 2) No.104, 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.
I Objection:
I Vermont Yankee objects to this request on the ground that it is not relevant to Contention Vll.
8 8 8
J Yermont Yankee further objects on the grounds that the request, even if it were relevant, is overboard and improperly invades the privacy of the
) individuals in question, and pursuant to 10 C.F.R. I 2.740(c) requests a J
I protective order that the same not be disclosed.
Response
Without waiving the foregoing objections, but rather expressly relying upon the same, Vermont Yankee is unaware of the existence of any such documents, for the reasons set forth in the response to Interrogatory (Set No.
- 2) No.104.
"tequest No.100.
Request:
Please produce for inspection and copying INPO Guid6ine 65-002, "The Accreditation of Training in the Nuclear Power Industry.'
Objectror :
Vermont Yankee objects to this requst on the ground that it is not I relevant to the admitted contention.
All such documents are classified by INPO as ' Limited Distribution."
I Vermont Yankee further objects to this req'aest for the reasons set forth in
" Objection to Document Production and Request fer Protective Order (INPO Documents)," filed June 15, 1990, and ' Motion to Supplement Answer of
-l Vermont Yankee Nuclear Power Corporation to State of Vermont Motion to 5
Ccmpel(Document Requests, Set No.1)," filed July 24,1990, and requests a protective order in respect of the same.
Request No.101.
Request:
Please produce for inspection and copying all documentation of Vermont Yankee reviewing, commenting upon, or using INPO Gcideline 85-002, "The Accreditation of Training in the Nuciear Power Industry", as identified in response to Vermont Interrogatory (Set No. 2) No.105. If in response to Vermont Interrogatory (Set No.
- 2) No.105 Vermont Yankee has not identified all documents requested to be identified by that interrogatory, please produce for inspection and copying all such documents.
Objection:
Vermont Yan' tee objc:ts to this request on the ground that the term "all documentation of Vermont Yankee reviewing, commenting upon, or using*
is not sufficiently specific to permit Vermont Yankee to determine what I documents are requested to be retrieved and produced. Vermont Yankee further objects on the ground that the request does not appear to be relevant to Contention Vll.
To the extent that compliance with this request would ntcesarily disclose the contents of the referenced document, which is classified by INPO as
' Limited Distribution,' Vermont Yankee further objects to this request for B the reasons set forth in its
- Objection to Document Production and Request for Protective Order (INPO Documents)," filed June 15,1990, its ' Motion to Supplement Answer of Vermont Yankee Nuclear Power Corporation to State I of Vermont Motion to Compel (Document Requests, Set No.1),* filed July 24, 1990, and its request for a protective order concerning SOV's inter-I rogatory (Set 2) No. 82.a, which request was filed on July 3,1990.
Response
Without waiving the foregoing objections, but rather expressly relying upon the same, Vermont Yankee is unaware of the existence of any such I documents, for the reasons set forth in the responsa to Interrogatory (Set No.
- 2) No.105.
Request No.102.
Request:
For enci and every Vermont Yankee employee (direct or contract) and Yankee Atomic Electric Corporation employee (direct or contract) who reviewed, commented on, or ised INPO Guideline 8.i-002,"The Accreditation of Training in the Nuclear Power Industry" in the development of Vermont Yankee's maintenance program, as identified in response to Vermont Interrogatory (Set No. 2) No.105, 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.
Objection:
Vermont Yankee objects to this request on the ground that it is not relevant to Contention VII.
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Vermont Yankee further objects on the grounds thu the request, even if--
7 _
L it were relevant, '- bard and improperly invader the privacy.of the-
- individuals in quen and pursuant to 10 C.F.R. $ 2.740(c) requests a protective order that the same not be disclosed.
? Response:
- Without waiving the foregoing objections, but rathe expressly relying l upon the same, Vermont Yankee states that it presently is t..n able to identify -
~
any such employees, for the reasons set forth in the response to In'errogatory:
(Set No. 2) No.105.
- . Request No.103.
] - Request: ,
mis
< ' For each and every Vermont' Yankee employee (direct or contract) -
- and Y1nkee Atomic Electric Corporation employee (direct or contract) o identified in response to Varmont inteirogatory (Set No. 3) No. 9.d.
- please produce for ' inspection and ~ copying, all personnel files, -
including, but not limited to, performance evaluations, ratings by -
- a.pervisors, qualification records, and training records and test scores. -
-~
- Objection
0 Vermont _ Yankee ob.iects to this request on the ground that it is not-relevant to Contention VII.
Vermont'Yankt.; further objects on the stounds that the request, even it it were relevant, is overboard 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.
Response
I' '
Without waiving the foregoing objections, but rather expressly relying upon the same, Vermont Yankee notes that.the resum6s, qualifications,
,and/or training ~ records of the referenced individuals have already been J_, ) produced to SOY in response to Document Request (Set No.1) No. I and Interrogatory (Set No. 2) No. 61.
Request No.104.
Request:
y@ y
[' Please produce for inspection and copying all documents identified in rrtoonse to Vermont Interrogatory (Set No. 3) No. 9.e. If in response
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. to Vermont Interrogatory (Set No. 3) No. 9 Vermont Yankee br~ not
- e identified all documents requested to be identified by that it.svr-5$
.V rogatory, please produce for inspection and copying all such docu-ments.
}tesponse:-
Vermont Yankee will produce the requested document (letter USNRC to -
n VY NYY 83-192,' dated 8/19/83, and LER 39-07) for inspection and copying-at the offices of Vermont Yankee Nuclear Power Corporatiota, Ferry Road,-
af
- J Brattleboro, on a date and at a time mutually agreed upon by counsel for the parties.
Request No.10$.
Request:
5 "
- Please produce for inspection and copying all documents identified in 3 response to Veimont Interrogatory (Set No. 3) No.12.b. If in response to Vermont interrogatory (Set No. 3) No.12 Vermont Yankee 2
]
- has not identified all documents requested to be identified by that intertogatory, please produce for inspection and copying all such L
' documents, a .
Objection:
Vermont Yankee objects.to this request on the grount . at it is not
'~
cj relevant to the admitted contention.
Response;. ,
--Without waiving the foregoing obketion, but rather expressly relying
. 4 upon the same, Vermont. Yankee observes that the referenced response i.-dicates that the referenced set of documents is null.
Requeu No.106.
]' : Req. test:
Please prostuce for inspection and copying all documents identified in response to Vermont Interrogatory (Set No. 3) No.12.b.
Objection:
- ~
Vermont Ya'n kee cbjects to this request on the ground that it is not
' relevant to the adinitted contention.
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- Vermont Yankee further objects to this request oh the ground that it is- -;
wholly duplicative of the immediately preceding request.
Vermont Yankee also incorporates by reference its objectior, to Request : ,
I No. 90, above, substituting "105" for '66.' '
I '!
Request No.107.
s c Request:
. Please produce for inspection and copying all documents identified in - --
response to Vermont Interrogatory (Set No. 3) No.16.b. -
Objection:
~
Vermont Yankee objects to als request on the grcund that it is not
. relevant to the admitted contention. l Request No.108. ;,
h '
Request:
Please produce for inspection and copying all documents identified in - <
response to Vermont Interrogatory (Set No. 3) No; 16.d.
.Objectioni
~
Vermont Yankee objects to this request on the ground that it is not :
c relevant to the admitted contention, b ,
Request No.1109. t i ' Request:- )
If in response to Vermont Interrogatory (Set No. 3) No.16 = Vermont [
'3 . Yankee has not identified all documents requested to be identified by i g that interrogatory, please produce for inspection and copying all such i documents.
Objection:
u Vermont Yankee objects to this request on the ground that:it is not j relevant to the admitted contention.
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Request'No.110. j o Request:i
'1 1' Please produce for inspection and copying all documents Mentified in 'i
~l b-I' u-response to Vermont Interrogatory (Set No. 3) No. 26.a. If in response to Vermont Interrogatory (Set No. 3) No. 26 Vermont Yankee has not ?
identified all documents-requested to be identified by that inter-h rogatory, please produce for inspection and copying all such docu-g mentsi -
Objection: ,
i
. Vermont Yankee obje .us request on the ground that it is not elevant to the admitted conten. ion.
Response: A i;
h3 Without waiving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee will produce MR 89-1333 identified in the l
I response to Interrogatory No. 26 of Set No. 3 for inspection at the offices of . 1 Vermont Yankee -Nuclear Power Corporation, Ferry Road. .Brattleboro,-. t I Vermont, on n'date and at a time mutually' convenient to counsel for the parties. MRs 89-0992, 8o-!!02, 89-1103, 69-1104, 89-1195 and 39-1320 M
{
g were previously produced, ard copier were provided to SOY in June,1990. -
l Requ 4t No.111.
i.
L . Request: .
Please producc for inst.ection and copying all documents identified in
. response to Vt rmont Interrogatory (Set No. 3) No. 32. If in response .
to Vermont Imerrogatory (Set No. 3) No. 32 Vermor* Yankee has not l f
identified all chcuments requested to oe identifico by-that inter- '
.rogatory, please p cduce for inspection and copying all such docu- ;
m e es. -i
. 0bjection:- a
- m
- Vermont Yankee objects to this. request on the ground that it is not
? . relevint to the admitted contention.
le l Response:
3
- Without walving the foregoing objection, but rather expressly relying I,, upon the same, Vermont Yankee will produce the MRs 89-1009 identified in the response to Interrogatory No. 32 of Set No. 3 for inspeedon at the offices -
4 I
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's '
of Vermont Yankee Nuclear Power Corporation. Ferry Road, Brattleboro, .
,I Vermont, on a date and at a time mutually convenient to counsel for the parties. 'MR 87-1954 was produced and a copy provided to SOY on June 13, C, ' 1990.-
Request No.112.
' Request:
' Please produce for inspection and copying all documents identified in response to Vermont Interrogatory (Set No. 3) No. 37.a. If in response
- to Vermont laterrogatory (Set No. 3) No. 37 Vermont Yankee has not jI identified all documents requested to be identified by that inter-rogatery, please produce for inspection and copying all such docu-
- ments.'
- Objection:
Vermont Yankee objects to this request on the ground that it is not I ,s 1 relevant to the admitted contention.
. Response:
E Without waiving the foregoing objection, but rather expressly relying upon the same, please see the response to Request No.110, above.
Request No.113.
Request:
Please produce for inspection and copying all documents identified in response to Vermont Interrogatory (Set No. 3) No. 38. If in response to Vermont Interrogatory (Set No. 3) No. 38 Vermont Yankee has not identified ali documents requested to be identified by that inter--
rogatory, please produce for inspection and copying all such docu-ments.
Response
By the terms of the interrogatory to wlOh reference is made, no.
documents were requested to be identified, and ey the terms of the response thereto, no documents were identified.
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J Request No.114; .
iRequest:-
Please produce for inspection and copying all documents identifisd in
. response to Vermont Interrogatory (Set No. 3) No. 39.- If in response '
to Vermont Interrogatory (Set No. 3) No. 39 Vermont Yankee has not ident?fied all documents requested to be identified by that= inter-
__=. rogatory, please produce for inspection and copying all such docu-
,3 ments.
L
. Response:
- By the- terms of _ the interrogatory. to 'which reference is made,' no
- ' documents were requested to be identified, and by the terms of the response c thereto, no documents were identified.
Request No.115.
' Request:
Please produce for inspection and copying all documents identified'in
> response to Vermont interrogatory (Set No. 3) No. 43, if in response to
' Vermont Interrogatory (Set No. 3) No. 43 Vermont Yankee has not
-- identified all documents requested to be identified by that interrogatory, please produce for inspection and copying all such documents.
1 Response:
-.}
Vermont Yankee' will produce 'Section VI of the .VYNPC . planning -
document " Strategies for the Future" for inspection and copying at the offices of Vermont Yankee Nuclear Power Corporation, Ferry Road, Brattleboro, on
?!! a' date and.at a time mutually agreed upon by counsel for the parties.- ,
Request No.116.
Request:
Please produce for inspection and copying all documents identified in response to Vermont Interrogatory (Set No. 3) No. 45. If in response -
to Vermont Interrogatory (Set No. 3) No. 45 Vermont Yankee has not 1 --
identified all documents requested to be identified by that inter-rogatory, please produce for inspection and copying all such docui ments.
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- p.'vn p i i N-w Response:'
Vermont . Yankee has produced and provided copies of the.~ General
- Electric Specifications 21 A5837 and 22All83 identified in the respense to Interrogatory No. 45 of Set No. 3 on June 20,1990.
,, Lysest No.117.
- Request:
. . Please produce for inspection and copying all documents identified in
'e ' response to Vermont Interrogatory (Set No. 3) No. 46. If in response g- - to Vermont Interrogatory (Set No. 3) No. 46 Vermont Yankee has not identified all documents requested to be identified by that inter-
~. rogatory, please produce for inspection and copying all such docu-ments.
Objection:
To the extent that this request calls for the production of documents concerned with the plant life extension (PLEX) process, Vermont Yankee ob,lects on the ground that the request is not relevant to the admitted.
II Request No.113.
Request:
' Please produce for inspection and copying all documents identified in response to Vermont Interrogatory (Set No. 3) No. 47. If in response to Vermont Interrogatory (Set No. 3) No. 47 Vermont Yankee has not f
' identified all docurpents requested to be identified by that inter-rogatory, please produce for inspection and copying all such docu-ments.
Response
. Vermont Yankee has already produced for inspection the MRs identified in its response to Interrogatory (Set No. 3) No. 47-indeed, to the entirety of .
the MR files. SOV was provided a copy of AP 0200 on June 6,1990.-
Request No.119.
Request:
Please produce for inspection and copying all documents identified in 3
response to Vermont Interrogatory (Set No. 3) No. 48. If in response E. . to Vermont Interrogatory (Set No. 3) No. 48 Vermont Yankee has not
. E; jdentified all documents requested to be identified by that inter-w I
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rogatory, please produce for inspection and copying'all such docu-I ments. t
Response
Vermont Yankee is aware of no documents that meet this reonest as ~
framed.
' Request No.120. d
. Request: ;
Please p oduce for inspection and copying all documents identified in . i 1 response to Vermont Interrogatory (Set No.~ 3) No. 49. If in response
- to Vermont Interrogatory (Set No. 3) No. 49 Vermont Yankee has not :
I identified all documents requested to be identified by that inter-
. rogatory, please produce for inspection and copying all such docu-ments.-
l
.a 0bjection:
a E ,
-Vermont Yankee objects' to this request on the ground that it is' not i relevant to the admitted contention. .;.
Response
Vermont Yankee has already produced for inspection the MRs identified ,
in its response to Interrogatory (Set No. 3) No. 47-indeed, to the entirety of ,
the MR files. SOY was provided a copy of AP 0200 on June 6,1990.
m Request No.121.
- Request:
Please produce for inspection and copying all docu.ments identified in 33 response to Vermont Interrogatory (Set No. 3) No; 51. If in response to Vermont Interrogatory (Set No. 3) No. 51 Vermont Yankee has not
{~ , : identified all documera requested to be identified by that inter-rogatory, please produce for inspettion and copying all such docu-i ments.
< Objection:
Vermont Yankee objects to thi Fest on the ground that-it is not relevant to the admitted contention.
62 - .
. . .1
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g Response: 3
( ..
Without' waiving the foregoing objection, but rather expressly relying L upon the same, Vermont Yankee incorporates herein:by refe ence its response j
.to Request No. I16 above, g Request No.122. q Request:.
L i For each and every Vermont Yankee employee (direct or contract) j; lg - and Yankee Atomic Electric Corporation employee (direct or contract) s
,g identified in response to Vermont Interrogatory (Set No. 3) No. 52.b.
please produce for inspection and copying all personnel files.
l including, but not limited to, performance evaluations,' ratings by.
supervisors, qualification records, and training records and test scores,
- k. Objection: .;
~
. Vermont Yankee objects to this request on' the ground that it is not L . relevant to Contention VII.
Vermont Yankee further objects on the grounds that the request, even if 3 L 'it were relevant, is overboard and improperly invades the privacy of the J lr -
individualiin question, and pursuant to 10 C.F.R. I 2.740(c) requests a -
protective order that the same not be disclosed, t I
. Response .
1Without waiving the foregoing objections, but rather expressly relying' T upon the same, Vermont Yankee 1 notes that.the resumes, qu'alifications,
. 'and/or. training records of the referenced individuals ~ have already been provided to SOY in response to Document Request (Set No.1) No.1, and Interrogatories (Set No.1) Nos. 75 and 77, except for Messrs. Miller, Thayer and McElwee, whose resum6s Vermont Yankee will produce for inspection
~
and copying at the offices of Vermont Yankee Nuclear Power Corporation, '
Ferry Road, Brattleboro, on a date and at a time mutually agreed upon by counsel for' t ie parties.
Request No.123. t f Request: l
> Picase produce for inspection and copying all documents identified in ;
response to Vermont Interrogatory (Set No. 3) No. 52.c. If in response 4('
to Vermont Interrogatory (Set No. 3) No. 52 Vermont Yankee has not c
identified all documents requested to be identified by that inter-l
. 63 -
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~
rogatory, p; ease produce for inspection and copying all such docu -
V ments.
% . Response:
. Vermont Yankee will produce the documents identified in its response to Interrogatory No 52(c) for inspection and copying at the offices of Vermont Yankee Nuclear Power Corporation, Ferry Road, Brattleboro, on a date and at a time mutually agreed upon by counsel for the parties.
}tonest No.124.
- Request:
- Please prod. ace for inspection and copying all documents identified in I
respooe to Vermont Interrogatory (Set No. 3) No. 55. If in response to Vermont Interrogatory (Set No. 3) No. 55 Vermont Yankee has not identified all documents requested to be identified by that inter-rogatory, please produce for inspection and copying all such docu- -. .
ments.
1 Objection:
Vermont Yankee objects to this request for the reasons set forth above in its objection to Request No. 5.
Request No.125.
Request:
l Please produce for inspection and copying ail documents identified in response to Vermont interrogatory (Set No,'3) No. 56. 'If in response. =
to Vermont Interrogatory (Set No. 3) No. 56 Vermont Yankee has not
-identified all documents iequested to be. Identified by. that-inter-1< rogatory, please produce for inspection and copying all such docu-ments.
I m i.
~ Objection:
Vermont Yankee objects to this request, which by definition calls for the I, . production of publicly available documents, as improper. Vermont Yankee l further objects on the ground that the documents requested have already been .
provided to SOV-in most cases, provided long ago.
64 -
~I
_.--- __i_m_ .-_.m__.___m.m_._._.m .___._m_ __m_._,_____._ _ _. .._._._.,______.__._._,..__,_m.________m________ ___ _ _ _ _ , . _____.__ ___, ____
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- i Request No.126.
Request:
- g
- t. Please produce for inspection ud copying all documents identified in
~
response to Vermont Interrogatory (Set No. 3) No. 58. If in response to Vermont Interrogatory (Set No. 3) No. 58 Vermont Yankee has not identified all documents requested to be identified by that inter-rogatory, please produce for inspection and copying all such docu-ments.
Objection:
Vermont Yankee objects to this request for the reasons set forth in its
" Objection to Document Production and Request for Protective Order (INPO.
Documents)," filed June _15,= 1990, and _' Motion to Supplement Answer of -
I _ Vermont Yankee Nuclear Power Corporation to State of Vermont Motion to Compel (Document Requests, Set No.1)," filed July 24,1990, and requests a protective order in respect of the same.
Request No.127.-
. Request:
Please produce for inspection and copying all documents identified in
- -' response to Vermont Interrogatory (Set No. 3) No. 60. If in response -
to Vermont Interrogatory (Set No. 3) No. 60 Vermont Yankee has not :
i . identified all documents requested to be identified by that inter-rogatory, please produce for inspection and copying all such docu-
- . ments.
l . Response:
Vermont Yankee incorporates by reference its response to Interrogatory (Set No. 3) No. 60.~
Request No.'128.
Request:
I Please produce for inspection and copying all documents identified in
. response to Vermont Interrogatory (Set No. 3) No. 62. If in response to Vermont Interrogatory (Se'. No. 3) No. 62 Vermont Yankee has not M , identified all documents requested to be identified by that inter-l : _
rogatory, please produce for inspection and copying all such docv-ments.
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I - Response:
z Vermont Yankee incorporates by reference its response to Interrogatory; (Set No. 3) No. 62l Request No.129.
Request:
Please produce for inspection and copying all documents identified in response to Vermont Interrogatory (Set No. 3) No. 64. If in response s
to Vermont Interrogatory (Set No. 3) No. 64 Vermont Yankee has not Hentified all documents requested to be identified by that inter-rogatory, please produce for inspection and copying all such docu-ments. ,
- Objection
. Vermont Yankee objects to this request on the ground that it is not I relevant to Contention Vll Vermont Yankee further objects on the grounds
- that the request, even if it were in pot relevant, is overbroad and unduly burdensome.
I Request No.130. .
-Request:
Please produce for inspection and copying all documents identified in response to Vermont Interrogatory (Set No. 3) No. 66, if in response to Vermont Interrogatory (Set No. 3) No. 66 Vermont Yankee has not I. identified all documents requested to be identified by that inter-rogatory, please produce for inspection and copying all such docu-ments,
Response
Vermont Yankee incorporates by reference its objection and response to SOV's Interrogatory (Set No. 3) No. 66.
Reqkest No.131.
Request:
[I' Please produce for inspection and copying all documents identified in
~
response to Vermont Interrogatory (Set No. 3) No. 74. If in response to Vermont Interrogatory (Set No. 3) No. 74 Vermont Yankee has not.
I identified all documents requested to be identified by.that inter-rogatory, please produce for inspection and copying all such docu-
- ments..
I 66 -
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y 3bjection:
A 1 Vermont Yankerobjects to'this request ou the ground th't 'it is ne' relevant to Contention Vll. Vermont Yankee further objects on the ground
,I . that the request, even if it were in part relevant, is overbroad and undt burdensome, a
[ Request No.132.
" Request:
' Please produce for inspection and copying all documents identified in response to Vermont Interrogatory (Set No. 3) No. 75. If in response -
c : to Vermont interrogatory.(Set No. 3) No. 75 Vermont Yankee has not
.' - ~ identified all documents requested to be identified by that inter-c ? rogatory, please produce for inspection and copying all such docu-ments.
Objection:
. The' Vermont Yankee Maintenance program has already been produced .
.to SOY, and Vermont Yankee respectfully objects to producing it n'second :
time.
Regost No.133.
, Request:
- Please produce for inspection and copying all documents identified in-
= response to Vermont Interrogatory (Set No. 3) No. 76.a.
1 -
Response
Vermont Yankee incorporates by reference its objection to Request No.
- 117, above.
Request No.134.
Request:
"i. Please produce for inspection and copying all documents identifib in
~) response to Vermont Interrogatory (Set No. 3) No. 76.b. a
'; Response:
I Vermont Yankee incorporates by reference its objection to Request No.
117,above.
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. I,1 ' i Request No.135.
Request:
If in response to Vermont Interrogatory (Set No. 3) No. 76 Vermont -
Yankee has not identified all documents requested to be identified by that interrogatory, please produce for inspection and copying all such
, documents.-
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.)
Response:: ,
No response is required by the terms of the request.-'
Request No.136. ;
- ' Rcquest:-
Please produce for inspection and copying all documents identified int ;
l}
response to Vermont Interrogatory (Set No. 3) No. 77.a.
s i, l Objection: . >
I. : . :i' "
E . Vermont Yankee incorporates by reference its objection to Request No.-
L' 129, above.
l' ,
Request No.137.
e Reauest:
Please produce for inspection and copying all documents idsntified in response to Vermont Interrogatory (Set No. 3) No. 77.b. i a
l Objection:
I Vermont Yankee incorporates by reference its objection to Request No.'
129, above.
i Request No.138.
Request: i I
' .~
if in response to Vermont Interrogatory (Set No. 3) No. 77 Vermont
- Yankee has not identified all documents requested to be identified by that interrogatory, please produce for inspection and copying all such i
documents. ;
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. Response:
_ Vermont Yankee incorporates by reference its object".on to Request No.
129,above.
[I Request No.139.
n v.
Request:
Please produce for inspection' and copying all documents identified in response to Vermont Interrogatory (Set No. 3) No. 80. If in response
,. - to Vermont Interrogatory (Set No. 3) No. 80 Vermont Yankee has not
"- identified all documents requested to be identified by that inter
- rogatory, please produce for inspection and copying all such docu-
- ments.
Response
7g' Vermont Yankee will produce the MRs 89-1004 identified in the response :
g to Interrogatory No. 80 of Set No. 3 for inspection at the offices of Vermont Yankee Nuclear Power Corporation, Ferry Road, Brattleboro, Vermont, on
- a date and at a time mutually convenient to counsel for the partiesh MR 89-1089 was provided to SOY on June 22,1990.
Request No.140.
'E , Request:
For eacl; and every Vermont Yankee employee (direct 'or contract)
I and Yankee Atom e Electric Corporation employee (direct or contract) 8
~ identified ir. response to Vermont Interrogatory (Set No.- 3) No. 81, 1 please prod ace for inspection and copying all personnel files, includ-
.ing-but not limited to, performance evaluations, ratings by super-
' visors, quaii*ication records, and training records and test scores, Objection:
I, Vermont Yatkee objects to this request on the ground that it is not relevant to Contention VII.
I Vermont Yank 9e further objects on the grounds that the request, even if it were relevant, is overboard 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.
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Po:onse; Without waiving the foregoing objections, but rather expressly relying iupon the. same, Vermont Yankee notes that- the resumes,. qualifications, and/or training records of the referenced Vermont Y;mkee personne'. nave .
' I, already been proffered to SOY in response to Document Request (Set No.1) .
No. 2.
Request No.141.
Request:
' For each and every Vermont Yankee employee (direct or contract, and Yankee Atomic Electric Corporation employee (direct or contract) r y" identified in response to Vermont Interrogatory (Set No. 3) No. 82, please produce for inspection and copying all personnel files, includ-ing but not limited to, performance evaluations, ratings by super-visors, qualification records, and training records and test scorer
, Objection:
Vermont Yankee objects .to this request on the gwnd that it is not I . relevant to Contention Vll.
Vermont Yankee further objects on the ground that the request, even if-
. it were relevant, is overboard and improperly invades the privacy of the individuals' in question,-and pursuant to 10 C.F.R. $ 2.740(c) req'iests.a protective order that the same not be disclosed.
' ~ *
,y.g . Vermont Yankte further objeeb to this request to the extent that it seeks -
~* - documents possessed by the Mercury Company rather than by Vermont' Yankee.
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, Request No.142.
L For each and every Vermont Yankee employee (direct or contract) and Yankee Atomic Electric Corporation employee (direct or contract) a identified in response to Vermont Interrogatory (Set No.' 3) No. 83, please produce for inspection and cpying all personnel files,includ-ing but not limited to, performance evaluations, ratings by super- -
I, visors, qualification records, and trainin;; mcords and test scores.
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- ' Objection:
Vermont Yankee objects to this request on the ground that it is not '
relevant to Contention VII.
! Vermont Yankee further objects on the grounds that the request, even if '
it were relevant, is overboard and improperly invades the privacy of- the y individuals in question,land pursuant to 10 C.F.R. $ 2.740(c) requests a protective order that the same not be disclosed.
Response; I
. Without waiving the foregoing objections, but rather expressly relying' apon the same, Vermont- Yankee notes that the resumes, qualifications,-
. and/or training records of the referenced Vermont Yankee personnel have already been proffered to SOV in response to Document Request (Set No.1)
No. 2.
Request No.143.,
Request:
For each and every Vermont Yankee employee (direct or contract)
I- and Yankee Atomic Electric Corporation employee (direct or contract) identified in response to Vermont Interrogatory (Set No. 3) No 84,
- g. please produce for inspection and copying all personnel files, includ-g' ing but not limited to, performance evaluations, ratings by super--
visors, qualification records, and training records and test scores.
Objection:.
Vermont Yankee. objects to this request on the ground that it is not -
relevant to Contention VII.
Vershont Yankee further objects on the grounds that the requast, even if I . it were relevant,,is overboard 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.
Vermont Yankee further objects to this request to the extent that it seeks documents possemd by the Mercury Company rather than by Vermont
. Yankee.
Request No.144.
Request:
Please produce for inspection and copying all documents identified in C , response to Vermont Interrogatory (Set No. 3) No. 85.a.
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- Response:
Vermont Yankee has already produced YNEC 16% on June 13,1990, and -
it has already produced four revisions of procedure OP 4115, the most recent' L of which was produced on June 6,1990.
Request No.145.
Request:
Please produce for inspection and copying all documents identified in response to Vermont Interrogatory (Set No. 3) No. 85.b.
Response
There are no such documents.
Request No.146.
k Request:
Please produce for inspection and copying all documents identified in response to Vermont Interrogatory (Set No. 3) No.' 85.c.
Response
.5 Please see the response to Request No.144.
Request No.147.
I Please produce for inspection and copying all documents identified in
. response to Vermont Interrogatory (Set No. 3) No. 85.d.
. Response:
[ .
( ,' Please see the response to Request No.144.
Request No.148.-
Request:
Please produce for inspection and copying all documents identified in response to Vermont Interrogatory (Set No. 3) No. 85.e.
- i Response:
': t y Please see the response to Request No.144, i
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s Request No.149. h Request: .
I If in response to Vermont Interrogatory (Set No. 3) No. 85 Vermont ;
Yankee has not identified all documents requested to be identified by- i that interrogatory, please produce for inspection and copying all such P: i documents. ;
- Response: i
_No response is required by the terms of the request.-
+
Kequest No.150. j Reque.st:
- Please produce for inspection and copying all documents identified in
response to Vermont Interrogatory (Set No. 3) No. 88.' If in response ' i to Vermont Interrogatory (Set No. 3) No. 88 Vermont Yankee has not q
- identified all documents requested to be identified by._ that inter-
- ; rogatory, please produce for inspection and copying all such docu- l L- ments.
t: .
Response
-Vermont Yankee has already produced YAEC 1696,- the document - f identified in its response to Interrogatory (Set No. 3) No. 88.
Request No.151.-
Request:. :
. Please produce for inspection and copying all documents identified in-response to Vermont Interrogatory (Set No. 3) No. 98. - If in response to Vermont Interrogatory (Set No. 3) No. 98 Vermont Yankee has not-
<I,< identified all documents requested to be identified.by that inter-rogatory, please produce for inspection and copying all such docu ~
,i ments. .
Hji , ,
Rl Objection:
I Vermont Yankee objects to this regt.est on the ground that it is not .'
L g;l l3 relevant to the admitted contention.
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Response
Without waiving the foregoing objection, but rather expressly relying f
. upon the same, Vermont Yankee will produce MRs 86-1332 and 86-1213 for !
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II inspection ~at the ~ offices of Vermont Yankee Nuclear Power Corporation,.
'EB Ferry Road;- Brattleboro, Vermont, on a date and at a time mutually coavenient to counsel for the parties. MR 89-1089 was provided to SOV on -
1 .
--June 22,1990.
Request No.152. x Reqwst:
Please produce for inspection and copying all documents identified in response to Vermont Interrogatory (Set No. 3) No.104.c.
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- s. .
- . There are no such documents.
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. Request No.153.
Please produce for inspection and copying all documents identified in
. response to Vermont interrogatory (Set No. 3) No.104.e.
Response
i There are no such documents.
. Request No.154. -
Request:
W If in response to Vermont Interrogatory (Set No. 3) No.104 Vermont Yankee has not identified all documents requested to be identified by.
that interrogatory, please produce for inspection and copying all such I documents.
Response
~
5 ', - No response is required by the terms of the request.
Request No.155.
- Request
Please produce for inspection and copying all documents id,:ntified in
! response to Vermont interrogatory (Set No.'3) No.111. If in response to Vermont Interrogatory (Set No. 3) No.111 Vermont Yankee has not identified an documents requested to be identified by that inter-r .
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rogatory, please produce for inspection and copying all such docu-
' 1 ments.
~
~ Objection:
1
~
Vermont Yai.kee objects to this request as duplicative, since the ;
. referenced documents have already been requested by and produced to SOV. ;
See Vermont Yankee's response to SOV's laterrogatory (Set 3) No.111. -i f Request No.156.
i Request: U Please produce for inspection and copying all documents identified in l
~ response to Vermont Interrogatory (Set No. 3) No. I12. If in response f
' IL to Vermont Interrogatory (Set No. 3) No.112 Vermont Yankee h as not 3
< identified all documents requested to be identifieri by that s ster-rogatory, please produce for inspection and copying all such Gocu- ..
nients. 4 j
Response
Vermont Yankee incorporates by reference its response to Request No. .;
i 144 above, d """"'***'
i i
1 Please produce fu inspection and copying all documents identified in iEe response to Vermo.n Interrogatory (Set No. 3) No,113. If in response to Vermont Interrogatory (Set No. 3) No.113 Vermont Yankee has not-g
' identified all documents requested to be idcntified by that inter-
" ' rogatory, please produce for inspection and copying all such docu-l:
!- ments.
Response. .
MR 89-1089 was provided to SOY on June 22,1990.
Request No.158.
Request: ?
H Please produce for inspection and copying all documents identified in response to Vermont Interrogatory (Set No. 3) No.114.: If in response h! - to Vermont Interrogatory (Set No. 3) No.114 Vermont Yankee has not u- t identified all documents requested.to be identified by that. inter--
P,M 4 rogatory, please produce for inspection and copying all such docu-H ments.
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Response
Vermont Yankee has already produced YAEC 16%, the document identified in its response to Interrogatory (Set No. 3) No.114.
Request No.159.
Request:
Please produce for inspection and copying all documents identified in response to Vermont Interrogatory (Set No. 3) No.115. If in response I to Vermont Interrogatory (Set No. 3) No. I 15 Vermont Yankee has not identified all documents requested to be identified by that inter-rogatory, please produce fr inspection and copying all such docu-ments.
Respons.':
Vermont Yankee has already produced YAEC 1696, the document identified in its response to Interrogatory (Set No. 3) No.115.
Request No.160.
Request:
Please produce for inspection and copying all documents identified in response to Vermont Interrogatory (Set No. 3) No.116. If in response to Verraont Interrogatory (Set No. 3) No. I 16 Vermont Yankee has not I identified all documents requested to be identified by that inter-rogatory, please produce for inspection and copying all such docu-ments.
Response
Vermont Yankee has already prods. 3 YAEC 1696, the document I identified in its response to Interrogatory (Set No. 3) No.116.
Request No.161.
Please produce for inspection and copying all documents identified in I response to Vermont Interrogatory (Set No. 3) No. I17. If in response to Vermont Interrogatory (Set No. 3) No.117 Vermont Yankee has not identified all documents requested to be identified by that inter-rogatory, please produce for inspection and copying all such docu-ments.
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Response
Vermont - Yankee has already produced YAEC 1696, the' document -
identified in its response to Interrogatory (Set No. 3) No.117.
Request No.162. .
Request:
alease produce for inspection and copying all documents identified in -
respcase to Vermont interrogatory (Set No. 3) No.118. If in response to Vermont Interrogatory (Set No. 3) No,118 Vermont Yankee has not I identified all documents requested to be identified by that inter-rogatory, please produce for inspection and copying all such docu -
ments.-
Response
- g
- Vermont Yankee has already produced YAEC 1696, the -document identified in its response to Interrogatory _(Set N. . 3) No.118.
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- - _ Request No.163.
Request:
Please produce for inspection and copying all documents identified in fI '
response to Vermont Interrogatory (Set No. 3) No.119. If in response to Vermont Interrogatory (Set No. 3) No.119 Vermont Yankee has not
- identified all docum(nts requested to be identified by that inter-rogatory, please produce for inspection and copying all such docu-
- I. -
ments.
Response
' Vermont Yankee has f aiready-produced , EC 16%, the document'
. identified in its response to Interrogatory (Set No. 3) No.119.
I Request No.164.,
, Request:
Please produce for inspection and copying all documents identified in l response to Vermont Interrogatory (Set No. 3) No.120. If in response
' to Vermont Interrogatory (Set No. 3) No.120 Vermont Yankee has not :'
identified all documents requested to be identified by that inter-rogatory,' please produce for inspection and copying all such docu-ments.
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Response
E9 - Vermont Yankee has already produced YAEC'16%, the document
- identified in its response to Interrogatory (Set No. 3) No.120.
/
7 Request No.165.
Request:
Please produce for inspection and copying all docuu, & s identified in response to Vermont Interrogatory (Set No. 3) No.122.' If in response to Vermont Interrogatory (Set No. 3) No.122 Vermont Yankee has not I identified all documents requested to be identified by that inter-rogatory, please produce for inspection and copying all such docu-ments.
Response
Vermont Yankee will produce VYOPF 4115.04, dated 3/19/89, which is I the documentation of the verbal inspection- results from Underwater Constr uction of Essex, Connecticut, identified in its response to Interrogatory (Set No. 3) No.122.
Request No.166.
Req test:
Please produce for inspection and copying all documents identified in response to Vermont Interrogatory (Set No. 3) No.123.J1f in response I to Vermont Interrogatory (Set No. 3) No.123 Vermont Yankee has not identified all documents requested to be identified by that inter-rogatory, please produce for inspection and copying all such docu-ments.
Response
Vermont Yankee has already produced MDE-184-0885, the document -
identified in its response to Interrogatory (Set No. 3) No.'123.
Request No.167.
Request:
Please produce for inspection and copying all documents identified in
> response to Vermont Interrogatory (Set No. 3) No.133. If in response to Vermont interrogatory (Set No. 3) No.133 Vermont Yankee has not
,I' identified all documents requested to be identified by that inter-
- rogatory, please produce for inspection and copying all such docu-ments.
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iResponse: ,
~
d Vermont Yankee incorporates its response to Request No. 3, above.' I
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Request No.168. ~'
1 Request:
g 5
Please produce for inspection and copying all documents identified in I<' ,
response to Vermont Interrogatory (Set No. 3) No.137. If in response -
-identified all documents requested to be identified by that inter - .
@ rogatory, please produce far inspection and copying all sucl. docu- .
ments.
I
Response
No such documents are or are required to be identified in Vermont
~
E. 3 Yankee's response to Interrogatory (Set No. 3) No.137. f.
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Request No.169.-
7 ,
? Request:
1 Please produce for inspection and copying all documents identified in' O response to Vermont Interrogatory (Set No. 3) No.138. If in response J
. to, Vermont Interrogatory (Set No. 3) No.138 Vermont Yankee has not .;
'I identified all documents requested to be identified by that inter- 1 rogatory, please produce for inspection and copying all such docu-a ments. .]
'Objectlon:
Vermont Yankee objects to this req' vest on= the ground that it is not
~ relevant to the admitted contention. .
- Response;,
Without waiving the' foregoing objection, but rather expressly relying '(
~ upon the same, Vermont Yankee will produce for inspection and copying the ' ~
~
documents identified ir its response to Interrogatory (Set No. 3) No.138.a at the offices of _ Vermont Yankee Nuclear Power Corporation, Ferry' Road, ,
Brattleboro, on a date and at a time mutually agreed upon by counsel for the J
, parties.
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v Request No.170.
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Request: , }i
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4U, Please produce for inspection and copying all documents identified in i
N response to Vermont Interrrgatory (Set No. 3) No.140. If in response -
?g to Vermont Interrogatory (Set No. 3) No.140 Vermont Yankee has not -
identified all documents reonested to be identified 5y that inter- J rogatory, please produce for inspection and copying all such docu- '
, . m e nts.
N Objection:
Vermont Yankee obLets to this request on the ground that it is 'not '
relevant to the admitted contention.
I5 l_ y Response:
I:.'
-7
'- l Without waiving the foregoing objection, but rather expressly relying -
l
.[ upon the same, Vermont Yankee will produce the procedures identified in its response to Interrogatory (Set No. 3) No.140 (other than AP 0200, AP 0021 -
i
'! and DP 4153, all of which have already been produced) at the offices of }
Vermont Yankee Nuclear Power Corporation, Ferry Road, Brattleboro,~ on a ;
,v a date and at a time mutually agreed upon by counsel for the parties. I a
me Request No.171.
$ Request:
a l! Please produce for inspection and copying all documents identified in l' response to Vermont Interrogatory (Set No. 3) No.141. If in response 4 I to Vermont Interrogatory (Set No. 3) No.141 Vermont Yankee has not identified all documents requested to be identified by that inter-rogatory, please produce for inspection and copying all such docu-ments.
Objection:
).
'I Vermont Yankee objects to this request on the ground that it is not relevant to Contention VII. _ Vermont Yankee fudaer objects on the grounds that the request, even if it were in part relevant, is overbroad sad unduly 3 burdensome. j
Response
Without waiving the foregoing objections, but rather expressly relying upon the same, Vermont Yankee will produce the procedures identified in its I l . !
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' response to Interrogatory (Set No. 3) No.141.b (other than AP 0310 and AP, .i 0200, which have already been produced) at the offices of Vermont Yankee 5 Nuclear Power Corporation Ferry Road, Brattleboro, on a date and at a time mutually agreed upon by counsel for the parties, j
)
Request No.172.
Request: .
Please produce for inspection and copying all documents identified in response to Vermont Interrogatory (Set No. 3) No.147. If in response s to Vermont Interrogatory (Set No. 3) No.147 Vermont Yankee has not I
-t identified all documents requested to be identified by that inter- : };
rogatory, please produce for inspection and copying all such docu-ments.
Objection: -
~
L u Vermont Yankee incorporates by reference its objection to Interrogatory ,
No.147.
.- Request No.173.
E Request: ;l Please produce foiJ inspection and copying all documents identified in- 1
=~. -
response to Vermont Interrogatory-(Set No. 3) No.149.c. If in response to-Vermont Interrogatory (Set No. 3) No.149 Vermont
. Yankee has not identified all documents requested to beidentified by ,
that interrogatory, please produce for inspection and copying all such E documents, lI .
e c, Response.'
Vermont Yankee has iready produced to SOY the document in question.
I Request No.174.
Request:
Please produce for inspection and copying all documents identified in response to Vermont Interrogatory (Set No. 3) No.155. If in response
- to Vermont Interrogatory (Set No. 3) No.155 Vermont Yankee has not l' identified all documents requested to be identified by that inter-
,I'
!~
togatory, please produce for inspection and copying all such docu-ments,
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^ Objection:
I, ~
Vermont Yankee objects to this request on the ground that it is;not relevant to the admitted contention.
Regnest No.175. -
Request: -
Please produce for inspection and copying all documents identified in . -i '
response to Vermont Interrogatory (Set No. 3) No.' 156.b. - If in response to Vermont Interrogatory (Set No.- 3) No.156 Vermont
I Yankee has not identified all documents requested to be identified by that interrogatory, please produce for inspection and copying all such documents,
' j i .
Response
There are no such documents. 1 Request No.176.
l Request:
Please produce for inspection and copying all documents identified in:
response to Vermont interrogatory (Set No. 3) No.162.. If in restwnse -
L I to Vermont Interrogatory (Set No. 3) No.162 Vermont Yankee has not-identified all documents requested to be identified by that inter-rogatory,~ please produce for inspection and copying all such dreu-ments.
[ Objection:
Vermont Yankee objects to this request on the ground that it is not-relevant to the admitted contention.
Request No.177.
Request:
Please produce for inspection and copying all documents identified in response to Vermont Interrogatory (Set No. 3) No.187. If in response to Vermont Interrogatory (Set No. 3) No.187 Vermont Yankee has not identified all documents requested tv be identified by that inter--
- rogatory, please produce for inspection and copying all such docu-ments.
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'I Objection:
- I Vermont Yat.kee objects to this request on the ground that it is not -
1 relevant to the admitted contention.
4
. Request No.178. I g;
Request:
E' For each and every Vermont Yankee employee (direct or contract) and Yankee Atomic Electric Corporation employee (direct or contract) - l
- identified in response to Vermont Interrogatory (Set No. 3) No.139,
'I
- 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.
Objection:
Vermont Yankee objects to this request on the ground that it is not I
relevant to Contention Vll. i 1
g- Vermont Yankee further objects on the grounds that the request, even if-g it were relevant, is overboard and improperly invades the privacy of.the individuals in question, and pursuant to 10 C.F.R. I 2.740(c) requests a l
protective order that the same not be disclosed. !
l-I Request No.179.
1 1
i
(
0 : Request:
Please produce for inspectioil and copying all documents identified in response to Vermont Interrogatory (Set No. 3) No.190 if in response to Vermont Interrogatory (Set No. 3) No.190 Vermont Yankee has not
..- identified'all documents requested to be identified by that inter-rogatory, please produce for inspection and Upying all such docu-ments.
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- f Objection
' Vermont Yankee objects to this' request on' the ground that it is not
. relevant to the admi tted content ion.
Byh rneys.
I R. K. Gad at i b Jeffrey P. Tro Ropes & Gray B One International Place
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Boston, Massachusetts 02110 Telephone: 617-951-7520 mted: se,, ems, i 1,,0.
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gy t Certificate of:SerWet
, I, R' K. Gad III, hereby certify that on September- 14,1990, l made =
service of the within response to document production request, by mailing-copies thereof, first class mall, 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.
! Washington, D.C. 20555 Washington, D.C. 20555 I-.i Frederick J. Shon
- Administrative Judge Atomic Safety and Licensing Board -
Adjudicatory File Atomic Safety and Licensing Board Panel
!gi U.S.N.R.C. U.S.N.R.C.
'I W .- Washington, D.C. 20555 Washington, D.C. 20555 I Anthony Z. Roisman, Esquire Cohen, Milstein & Hausfeld Suite 600 ;
Ann P. Hodadon, Esquire Patricia A. Jehle, Escuire
. Eugene Holler, Esquire
- g 1401 New York Avenue, N.W. U.S.N.R.C.
g Washington, D.C.' 20005 Washington, D.C. 20555 -
James Volz, Esquire Vermont Department of Public Service B > 120 State Street Montpelier, Vermont 05602 i
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