ML20151W580
| ML20151W580 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 08/16/1988 |
| From: | Gad R, Reid D ROPES & GRAY, VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| References | |
| CON-#388-6947 OLA, NUDOCS 8808250036 | |
| Download: ML20151W580 (15) | |
Text
.. _
(p0 e CLATto CopRf.St'p,WW Dated:
August 16, 198g UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
- 88 AUG 22 P5 :19 before the
( 1' t ATOMIC SAFETY AND LICENSING BOARD
'I 5
)
In the Matter of
)
)
Docket No. 50-271-OLA VERMONT YANKEE NUCLEAR
)
(Spent Fuel Pool POWER CORPORATION
)
Expansion)
)
(Vermont Yankee Nuclear
)
Power Station)
)
)
ANSWERS OF VERMONT YANKEE NUCLEAR POWER CORPORATION TO NECNP'S TIIIRD SET OF INTERROGATORIES AND REQUESTS FOR THC PRODUCTION OF DOCUMENTS Pursuant to 10 C.F.R.
S 2.740b, Vermont Yankee Nuclear Power Corporation ("Vermont Yankee") responds to the inter-rogatories propounded by NECNP, and served by express mail on August 4, 1988, as follows:
Interrocatory No. 1 Ouestion:
1.
Please identify all persons who participated in the preparation of answers to these interrogatories, and identify the portions of your response to which each person contributed.
Response
The persons who participated in the preparation of these responses, exclusive of counael, are as follows:
Donald A. Reid l
l John T. Herron l
L. A. Tremblay hG250036000816 G
ADDCK 05000271 l
ysOh t
l.
PDR.
t L.
e J.
K. Thayer J.
R. Hoffman C.
H. Hansen Interrocatory No. 2 Ouestion:
2.
Please identify all persons on whose factual knowledge, opinions, or technical expertise you rely or intend to rely for the design,, installation or testing of the "Vermont Yankee Proposed Techni-cal f pecification Change for New and Spent Fuel Stor..ge," or the systems described therein.
Resoonse (and cartial obiection):
At the present time, Velmont Yankee proposes to rely upon the same persons identified in response to Inter-roo'4 tories Nos. 21 & 22 of NECNP's first set (filed 7/1/87),
together with the porGons identified in response to the first interrogatory, to present its testimony in response to Contention 1.
Vermont Yankee notes, however, that it has not made any final selection as to witnesses a nd that it will not make any such final selection until such 1.ime as the pendency of the filing of testimony so requires.
To the extent that this interrogator:r calls for addi-tional information, Vermont Yankee objects to it on the ground that the request for additional material is beyond the scope of Contention 1.
Interroaat_grv No. 3 Ouestion:
3.
Please provide all documents which describe, comment upon or evaluate the Fuel Pool Cooling arid Demineralizer System, the Emergency Standly __
e Subsystem, or other systems described in "Vermont Yankee Proposed Technical Specification Change for New and Spent Fuel Storage," dated June 7,
- 1988, including but not limited to consultants' reports, and engineers' reports, safety evaluations, or design change packages.
Obiection (Partial):
Vermont Yankee objects to this interrogatory, insofar as it relates to any aspect of the materials submitted to the NRC Staff under date of June 7, 1988, other than the Emergen-cy Standby Subsystem of the Spent Fuel Pool Cooling System, for the following reasons:
(1)
Vermont Yankee's submission of June 7,
- 1988, proposed and described no change to the Spent Fuel Pool and associated cooling systems other than the addition of the Emergency Standby Subsystem of the Spent Fuel Pool Cooling System.
(2)
The Emergency Standby Subsystem of the Spent Fuel Pool Cooling System is relevant to Contention 1 in this proceeding only insofar as its cooling capacity responds to the contention that the cooling capacity of the existing system is inade-quate to carry the heat load of rejected loads of spent fuel assemblies under certain conditions.
(3)
Insofar as this interrogatory is addressed to any aspect of the June 7th submission other than the Emergency Standby Subsystem of the Spent Fuel Pool Cooling System, it addresses matters that are unchanged from Vermont Yankee's submission of April 25, 1986 (Proposed Change No. 133), which, in turn, was unchanged (except for the number of fuel assemblies and design of the racks) from the design and systems then and now existing in the Spent Fuel Pool.
(4)
Discovery on this matter closed, as to Contention 1, on August 3, 1987.
(5)
Additional discovery was allowed by this Board on account of the purportedly "new" material intro-duced by Vermont Yankee's June 7th submission, and such discovery should be limited to the matters added or altered by that submission.
Resnonse:
Vermont Yankee will make the requested documents, insofar as they relate to the Emergency Standby Subsystem of the Spent Fuel Pool Cooling System, available for inspection and copying at the offices of Vermont Yankee Nuclear Power Corporation in Brattleboro, Vermont, at a time mutually convenient to counsel for NECNP and Vermont Yankee.
Interrocatory No. 4 CuestiGD:
4.
Please provide all documents which describe or otherwise portray (as in the form of drawings, diagrams, schematics, engineering drawings, etc.)
the systems described in the "Vermont Yankee Proposed Technical Specification Change for New and Spent Fuel Storage," dated June 7, 1988.
Obiection (Partial):
Vermont Yankee objects to this interrogatory, insofar as it relates to any aspect of the materials submitted to the NRC Staff under date of June 7, 1988, other than the Emergen-cy Standby Subsystem of the Spent Fuel Pool Cooling System, for the following reasons:
(1)
Vermont Yankee's submission of June 7,
- 1988, proposed and described no change to the Spent Fuel Pool and associated cooling systems other than the addition of the Emergency Standby Subsystem of the Spent Fuel Pool Cooling System.
(2)
The Emergency Standby Subsystem of the Spent Fuel Pool Cooling System is relevant to Contention 1 in this proccading only insofar as its cooling capacity responds to the contention that the cooling capacity of the existing system is inade-quate to carry the heat load of rejected loads of spent fuel assemblies under certain conditions.
4
(3)
Insofar as this interrogatory is addressed to any aspect of the June 7th submission other than the Emergency Standby Subsystem of the Spent Fuel Pool Cooling System, it addresses matters that are unchanged from Vermont Yankee's submission of April 25, 1986 (Proposed Change No. 133), which, in turn, was unchanged (except for the number of fuel assemblies and design of the racks) from the design and systems then and now existing in the Spent Fuel Pool.
(4)
Discovery on this matter closed, as to contention 1,
on August 3, 1987.
(5)
Additional discovery was allowed by this Board on account of the purportedly "new" material intro-duced by Vermont Yankee's June 7th submission, and such discovery should be limited to the matters added or altered by that submission.
Resoonse:
Vermont Yankee will make the requested documents, insofar as they relate to the Emergency Standby Subsystem of the Spent Fuel Pool Cooling System, available for inspection and copying at the offices of Vermont Yankee Nuclear Power Corporation in Brattleboro, Vermont, at a time mutually convenient to counsel for NECNP and Vermont Yankee.
Interrocatory No. 5 Ouestion:
5.
Please describe in detail your schedule for completing the design, installation, and testing of the system described in the "Vermont Yankee Proposed Technical Specification Change for New and Spent Fuel Storage," including but not limited to the date this system is expected to be operational.
Resconse:
All of the "system described in the ' Vermont Yankee Proposed Technical Specification Change for New and Spent Fuel Storage 8" of June 7, 1988 is presently (and was on June.
7, 1988) designed, installed, tested and operational with the exception of the Emergency Standby subsystem of the Spent Fuel Pool Cooling System, which will be completely designed, installed and tested prior to the storage in the spent fuel pool of more than 2,000 spent fuel assemblies, but for which no more definite schedule now exists.
Interroaatorv No. 6 Ouestion:
6.
To the best of your knowledge, is the system described in the "Vermont Yankee Proposed Technical Specification Change for New and Spent Fuel Storage" similar to any used in other nuclear power plante?
If yes, please identify those plants, describe their systems, and describe any differen-ces in Vermont Yankee's proposal from those systems.
Qbjection (Partial):
Vermont Yankee objects to this interrogatory, insofar as it relates to any aspect of the materials submitted to the NRC Staff under date of June 7, 1988, other than the Emergen-cy Standby subsystem of the Spent Fuel Pool Cooling System, for the following reasons:
(1)
Vermont Yankee's submission of June 7,
- 1988, proposed and described no change to the Spent Fuel Pool and associated cooling systems other than the addition of the Emergency Standby Subsystem of the Spent Fuel Pool Cooling System.
(2)
The Emergency Standby Subsystem of the Spent Fuel Pool Cooling System is relevant to Contention 1 in this proceeding only insofar as its cooling capacity responds to the contention that the cooling capacity of the existing system is inade-quate to carry the heat load of rejected loads of spent fuel assemblies under certain conditions.
(3)
Insofar as this interrogatory in addressed to any aspect of the June 7th submission other than the Emergency Standby Subsystem of the Spent Fuel Pool Cooling System, it addresses matters that are unchanged from Vermont Yankee's submission of April 25, 1986 (Proposed Change No. 133), which, in turn, was unchanged (except for the number of fuel assemblies and design of the racks) from the design and systems then and now existing in the Spent Fuel Pool.
(4)
Discovery on this matter closed, as to contention 1,
on August 'J, 1987.
(5)
Additional discovery was allowed by this Board on account of the purportedly "new" maF, rial intro-duced by Vermont Yankee's June 7th submission, and such discovery should be limited to the matters added or altered by that submission.
Response
Interpreting "similar" to mean use of the same tech-nologies relating to fluid flow and heat transfer, the Emergency Standby Subsystem is believed to be similar to the spent fuel pool cooling subsystems used by all other commer-cial nuclear power plants in the United States.
Interrocatory No. 7 Ouestion:
7.
Please produce copies of the technical specifica-tions for the existing Vermont Yankee spent fuel pool cooling system.
ResDonse:
The VYNPS Technical Specifications are available for inspection and copying at the offices of Vermont Yankee Nuclear Power Corporation in Brattleboro, Ve rar.i t, at a time mutually convenient to counsel for NECNP and Vermont Yankee.
i l
l l
Interrocatory_No. 8 ouestion:
8.
Please identify and describe every change in the technical specifications for the Verment Yankee Nuclear Power Plant that will be required by the "Vermont Yankee Proposed Technical Specification Change for New and Spent Fuel Storage."
Rosconse:
The only change in the existing technical specifications for VYNPS that will be required is the amendment of the figure "2,000" to the figure "2,870" on page 189, item D of the VYNPS Technical Specifications.
Interroaatory No. 9 Question:
9.
Please identify the sources for the following design bases for the Fuel Pool Cooling and Deminer-alizer System described in the "Vermont Yankee Proposed Technical Specification Change for New and Spent Fuel Storage," (A-1, A-2), including but not limited to NRC regulations, regulatory guides, NRC Staff positions, or the Licensee's engineering judgment, and describe or explain in details what you plan to do in order to meet these regulatory requirements or standards:
A.3 Power Generation Desian Bases 1.
The Fuel Pool Cooling and Dcmineralizer System shall minimize corrosion product buildup within the spent fuel pool and shall maintain proper water clarity, so that the fuel assemblies can be efficiently handled underwater.
2.
The Fuel Pool Cooling and Demineralizer System shall minimize fission product concentration in the spent fuel pool water, thereby minimizing the radioactivity which could be released from the pool to the Reactor Building environment.
3.
The Fuel Pool Cooling and Demineralizer System shall monitor fuel pool water level and maintain a
?
)
water level above the fuel sufficient to provide shielding for normal building occupancy.
4.
The Fuel Pool Cooling System shall be capable of maintaining the spent fuel pool temperature below 150 F.
A.4 Safety Desian Basis 1
The Fuel Pool Cooling and Domineralizer System shall be designed to remove the decay heat from the fuel assemblies and maintain fuel pool water temperature at a level which will help maintain the Reactor Building environment within the bounding limits of the environmental qualification of electrical equipment, obiection:
Vermont Yankee objects to this interrogatory for the following reasons:
(1)
Vermont Yankee's submission of June 7,
- 1988, proposed and described no change to the Spent Fuel Pool and associated cooling systems other than the addition of the Emergency Standby Subsystem of the Spent Fuel Pool Cooling System.
(2)
The Emergency Standby Subsystem of the 3 pent Fuel Pool Cooling System is relevant to Contention 1 in this proceeding only insofar as its cooling capacity responds to the contention that the cooling capacity of the existing systam is inade-quate to carry the heat load of rejected loads of 2
spent fuel assemblies under certain conditionsi (3)
Each of the design bases referred to in this interrogatory is substantively unchanged by the June 7th submission.
(4)
Discovery on this matter closed, as to Contention 1, on August 3, 1987.
(5)
Additional discovery was allowed by this Board on account of the purportedly "new" material intro-duced by Vermont Yankee's June 7th submission, and such discovery should be limited to the matters added or altered by that submission.
Interrocatory No. 10 Ouestion:
10.
Please explain in detail how the Emergency Standby Subsystem satisfies each of the requirements of 10 C.F.R.
S 50.49 to ensure operability after exposure to a harsh environment.
Obiection:
Vermont Yankee objects to this interrogatory, on the ground that environmental qualification questions are not within the scope of contention 1 in this proceeding.
Interrocatory No. 11 Ouestion:
11.
Please identify and list all components of the Emergency Standby Subsystem.
For each of those electric components, please identify those that are environmentally qualified pursuant to 10 C.F.R. 5 50.49.
Obiection:
Vermont Yankee objects to this interrogatory, on the ground that environmental qualification questions are not within the scope of contention 1 in this proceeding.
Interroaatory No. 12 Question:
12.
For each of the qualified components listed above, provide the following information:
(a)
Identify and describe the performance specifications under conditions existing and following design basis accidents; (b)
Identify and describe the voltage, frequency, load, and other elactrical characteris-tics for which the performance spe.cifications identifieo in the preceding par >yraph can be mett (c)
Describo the environmental conditions, including temperature, pressure, humidity, radia-tion, chemicals, and submergence at the locations where the equipment must perform during an acci-dent; (d)
Produce the service environment charts or any other documentation showing the postulated accident conditions for which each component will be qualified.
If none is available, explain why this documentation is not available and state when it will be available.
(e)
Produce the equipment qualification file and any other documentation required by 10 C.F.R. 5 50.49(d) and 10 C.F.R.
S 50.49(j) for each component.
If none is available, explain why this documentation is not available and state when it will be available.
Qhioction:
Vermont Yankee objects to this interrogatory, on the ground that environmental qualification questions are not within the scope of contention 1 in this proceeding.
Interrocatory No. 13 Ouestion:
13.
Describe how the system described in the "Vermont Yankee Proposed Technical Specification Change for New and Spent Fuel Storage" is designed to survive a safe shut-down earthquake, and remain operational following the safe shut-down earthquake.
Identify all NRC regulations, regulatory guides, staff positions, or engineering judgments relied upon to conclude that the system is designed to survive a safe shut-down earthquake.
obiection:
Vermont Yankee objects to this interrogatory, on the ground that soismic qualification questions are not within the scope of contention 1 in this proceeding.
1 Interrocatory No.
1_4_
Ouestion:
14.
Identify and describu all changes in the technical specifications of the Emergency Standby Subsystem.
If there will be no changes, explain how you intend to justify your surveillance, inspection, and testing requirements.
Obiection:
Vermont Yankee objects to this interrogatory, on the ground that surveillance, inspection and testing questions are not within the scope of Contention 1 in this proceeding.
Interrocatory No. 15 Ouestion:
15.
Describe how the Emergency Standby Subsystem, including all cables and instrumentation used in the system, will be located or designed to prevent common mode failure from fire, flooding and missiles.
Provide any drawings, schematics, or other documentation that describes the fire, flooding, and missile protection designs.
Obiection:
Vermont Yankee objects to this interrogatory, on the ground that the questions subsumed by this interrogatory are not within the scope of contention 1 in this proceeding.
Interrocatory No. 16 QM9stion:
16.
Please identify all standards, including but not limited to NRC regulations, regulatory guides, NRC Staff positions, or the Licensee's engineering judgment, that you complied with in order to conclude that the Emergency Standby Subsystem is located or designed to prevent common mode failure from fire, flooding and missiles, and describe or explain in detail what you have done in order to meet these regulatory requirements or standards.
Obiection:
Vermont Yankee objects to this interrogatory, on the ground that the questions subsumed by this interrogatory are not within the scope of Contention 1 in this proceeding.
Interrocatory No. 17 i
Ouestion:
17.
The "Vermont Yankee Proposed Technical Specifica-tion Change for New and Spent Fuel Storage" states that the Fuel Pool Cooling and Demineralizar System (FPCDS), centrifugal pumps, related piping and valves, will be of corrosion resistant material.
a Describe the metallurgical composition of all component parts of the FPCDS, and describe your program for monitoring and controlling corrosion in all component parts of the FPCDS.
Obi ect f_Qn:
vermont Yankee objects to this interrogatory, on the ground that corrosion protection questions are not within the scope of Contention 1 in this proceeding.
13 -
44
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i Signattiras canald A. Reid, being first duly sworn, states that the j
scrogoing snavers are true, except insofar as they are based i
i on infor:ation that is available to Ver:nont Yan.kes but not within his personal knowledge, as to which he, based on su:h b
I information,believesthemtobetrue,this],,,(g,dayof August, 1986.
CA ~ S 0 }
Donald A. Reid '
Then personally appeared Donald A. Reid, before and personally kncvn to me, who, being first duly swornM:ay'of nades oath that the foregoing statorent is true, this 1 August, 1988.
e-bL Cl6/W
s' Notary Mblic 4
f My commission expftss
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in te chiantianm
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R.
K. Gad III
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Ropes & Gray /
225 Franklin Streat Boston, Massachusetts 02110 (617) 423-6100 l l
i fMYN-123 ASLB - Reg. Mail RKGCOSR3.VY CERTIFICATE OF SERVICE 18 ns 22 PS :20 i
I, R.
K. Gad III, hereby certify that on M' !' :
- 4' August 16, 1988, I made service of the within ddEEEe'p(than*
accordance with the rules of the commission by mailing 'a copy thereof postage prepaid to the following:
Charles Bechhoefer, Esquire, David J. Mullet, Esquire Chairman vermont Department of Administrative Judge Public Service Atomic Safety and Licensing 120 State Street Board Panel Montpelier, VT 05602 U.S. Nuclear Regulatory Commission
' Washington, DC 20555 Mr. Glenn O.
Bright Ellyn R.
deiss, Esquire Administrative Judge Harmon & Weiss Atomic Safety and Licensing Suite 430 Board Panel 2001 S Streat, N.W.
U.S. Nuclear Regulatory Washington, DC 20009 Commission Washington, DC 20555 Mr. Jamed H.
Carpenter George B.
Dean, Esquire Administrative Judge Assistant Attorney General Atomic Safety and Licensing Department of the Attorney Board Panel General U.S. Nuclear Regulatory one Ashburton Place Commission Boston, MA 02108 Washington, DC 20555 Adjudicatory File Ann P. Hodgdon, Esquire Atomic Safety and Licensing office of the General Counsel Board Panel Docket (2 copies)
U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 1
Atomic Safety and Licensing Geoffrey M. Huntington, Esquire Appeal Board Panel office of the Attorney General U.S. Nuclear Regulatory Environmental Protection Bureau Commission State House Annex Washington, DC 20555 25 Capitol Street Co NH 03301-6397
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i
/u-R. K. Gad III j/'