ML20154S355
| ML20154S355 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 09/27/1988 |
| From: | Gad R ROPES & GRAY, VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | VERMONT, STATE OF |
| References | |
| CON-#488-7201 OLA-2, NUDOCS 8810050050 | |
| Download: ML20154S355 (10) | |
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QT.C0 *;c"umnDEnot; 000EEIEB Fil'e'l 9/27/88.
d UNITED STATES OF AMERICA NUCLEARREGUIATORYCOMMISSIOp
-3 N O before the r-ct;a a ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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Docket No. 5 0-2 71-OIA-2 VERMONT YANKEE NUCLEAR
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(Testing Requirements for POWER CORPORATION
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(Vermont Yankee Nuclear
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Power Station)
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VERMONT YANKEE'S FIP.ST SET OF INTERROGATORIES AND REQUP.STS FOR THE PRODUCTION OF DOCUMENTS TO THE STATE OF VERMONT Pursuant to 10 C.F.R. 55 2.740b and 2.741, Vermont Yankee Nuclear Power Corporation submits the following interrogatories to the State of Vermont (hereinafter, the "State").
1.
Please identify all persons wlo participated in the preparation of answers to these interrogatories and produc-tion requests, and identify each interrogatory or portions of each interrogatory to which each person contributed.
4 2.
Has the State prepared (or had prepared for it):
a.
Any failure mode analysis for any component affected by the proposed amendment?
If so, please provide the same, b.
Any analyses to quantify the impact of alternate testing on the availability of affected systems?
If so, please provide each such analysis, ea100%$
h PDR AOh G
3.
Identify all NRC Reg. Guides, Bulletins, Circulars, Information Notices, and Generic Letters that the State contends are applicable to components and devices affected by the proposed amendment.
For each such issuance identified, please specify the pages or sections that the State contends apply to components and devices affected by the proposed amendment and state the reasons why the State contends that each such page or section applies to such components and devices.
4.
Does the state possess any information on any occurrence that it contends is a failure or toportable event in any of the systems or subsystems affected by this proposed amendment?
If so, then for each such event please provide l
a.
The date of the Event, j
b.
The system affected.
c.
The Event Report Number (if any).
d.
Identification of the component responsible or affected by the event.
e.
A description of the Event.
f.
The source (s) of information upon which the State relies.
5.
Describe what the State contends are the bypassed and inoperable atatus indications required to be available to the control room operator for each system or subsystem affected by the proposed amendment.
For each such require-ment, identify the regulation or other item that the State
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contends imposes the requirement.
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6.
Identify any instance in the life of the plant in which the State contends that bypassed and inoperable status indication has not been set correctly.
7.
Does the State contend that, regardless of any legal impedient, Vermont Yankee should withdraw the pending amendment on account of the matters addressed NUREG-1251 or NUREG/CR-3621?
If so:
a.
State all of the reasons for your contention.
b.
Does your contention depend upon the conclusion that the proposed amendment either reduceu safety or fails to enhance safety?
8.
Does the State contend that there is ar.y legal requirement that, if the amendment is approved the Surveil-lance Sections of the Technical Specifications that are proposed to be deleted be replaced with statements in the Tect.nical Specifications requiring operators to verify immediately the operability status of the redundant system?
If so, please state each statute, regulation or other item that the State contends imposes such a requirement.
9.
Does the State contend that the document defined in its interrogatories as "The Report" is a document that is subject to the requirements of 10 C.F.R.,
Part 50, Appendix B?
If so, then:
a.
State each and every reason why the State contends that Appendix B applies to The Report.
b.
State each and overy obligation that the State contends is imposed upon Vermont Yankee or anyone else on account of Appendix B.
Identify each regulatory pronouncement upon which c.
the State relies for its contsntion.
d.
Identify each fact upon which the State relies for its contention.
10.
Does the State contend that the document defined in its interrogatories as "pLG-0500" is a document that is subject to the requirements of 10 C.F.R.,
Part 50, Appendix B?
If so, then:
a.
State each and every reason why the State contends that Appendix B applies to The Report.
1 b.
Identify each regulatory pronouncement upon which the State relies for its contention.
c.
Identify each fact upon which the State relies for its contention.
11.
Does the State concede that alternate resting is not part of the NRC's BWR Standard Technical Specification?
a.
If not, please identify each section of the Standard Technical Specification that the State contends imposes such an alternate testing require-ment.
4 b.
Does the State take lasue, in any respect, with the conclusion stated by Vernont Yankee in its submis-sion dated Dacember 7, 1987, that the proposed amendment "is consistant with the testing require-ments contained in the BWR Standard Technical l
Specifications"?
i c.
If so, then (i) state each respect in which the St:ta takes issue with that statement, (ii) for each such respect, identify the portion of the Standard Technical Specifications with which the State contends the proposed amendment is not consistent, and (iii) state every fact upon which the State relies to support its contention.
d.
Please identify each other Boiling Water Reactor i
(BWR) that the State contends is now operating under alternate testing requirements of the sort l
proposed to be deleted by the pending amendment.
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e.
For each such BWR, please identify (i) each specific testing requirement (by procedure or Technical Specification citation), and (ii) the source of information upon which the State relies for its contention.
12.
Does the State contend that, either on account of the deletion of the alternate testing requirements proposed by the pending amendment, or otherwise, any Vermont Yankee "LCo 'out of service time' before power reduction" (as the term is used in the State's interrogatories) should be dif-ferent from what it presently is?
If so, then please list each LCO that the State contends should be changed, and for each such LCO state (1) what the State contends it should be changed to; (ii) every regulation or other regulatory issuance upon which the State relies for its contention; and i
(iii) every fact on which the State relies for its conten-tion.
13.
Please describe in detail each and every "design change ()" that the State contends is "possible or desirable to allow the required testing to be accomplished safely" within the meaning of Interrogatory 24(b) of the State's l
interrogatories.
14.
Does the State contend that a requirement to "be at HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of an inoperable redundant component" should be required in respect of any of the t
systems affected by the proposed amendment?
If so, please identify each such system, and for each such system state (i) all of the reasons why the State contends the legal require-,
9 ment should be imposed, (ii) the alternatives, both in terms of risk and cost, that the State has assessed in reaching its conclusion, (iii) the steps that the State has tuken to have the legal requirements changed to conform to the State's contention as to what they should be.
15.
With respect to the assertion of the State in its interrogatories that:
"At page 6 of SThe Report,' it is indicated that the linoar approximation is valid only when the condition is met that the failure rate-time product is "much less" than 1.
At page 7, the same condi-tion applies, although it is not stated.
- However, for the failure rate data provided on pages 31 and 32, and the time periods graphed on pages 34 through 38, it appears this condition may not always be satisfied.",
please: (1) identify each respect in which the State contends j
that the referenced condition is not met; (ii) state a'.1 of the reasons why the State so contends, and (iii) state how the State contends the results of the analysis would change if "the failure rato-time product approaching 1 were taken into account."
16.
With respect to the following assertion by the Stat <. in its interrogatories:
"The anomaly presented in the graphs on pages 34, 43 and 45 of "The Report" is purely a function of the attempt to repair valle both redundant trains are inoperable instead of bringing the plant to an immediate safety shutdown condition.
This is con-firmed by statements in Sections 5.3.1 and 7.0 of "The Report."
This is an anomaly becaure it seems to indicate it is more desirable to n21 discover a failure by testing (if the failure is to occur on the next demand), but rather to discover it in an accident event if one were to occur.
The anomaly is removed from the results if it is assumed the
plant immediately proceeds to safe shutdown instead of repair."
please: (1) identify with precision the "anomaly" referred tot (ii) explain in detail why the State contends that the "anomaly" is "purely a function of the attempt to repair while both redendant trains are inoperable instead of bringing the plant to an immediato safety shutdown condi-tiont" (iii) identify the "statements in Sections 5.3.1 and 7,0 of 'The Report' to which the State refers; (iv) explain in detail why the State contends that the "anomaly" is "con-i firmed by statements ir sections 5.3.1 and 7.0 of "The Report;" (v) state all of the reasons why the State contends tl.at "it (presumably "The Report) seems to indicate that it is more desireable to not discover (sic) a failure by testing (if the failure is to occur on the next demand, but rather to
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discover it in an accident event if one were to occur" (emphasis in original); and (vi) state why the State contends that "the anomaly is removed from the results if it is assumed the plant immediately proceeds to safe shutdown instead of repair."
17.
Explain how the State contends that "the inoperable j
state of the standby Liquid contrF. System.
(should i
have been) taken into account in the analysis described in
'The Report.'"
r 18.
Does the State contend that it would be "more prudent to withdraw the present amendment at this time pending establishment by the Industry of ' generally accepted -.-
means (of directly associsting levels of risk and risk changes with the requirement of any technical specifica-tion),' endorsed by the NRC"?
If so:
a.
Please explain the comparative implicit in the phrasa "more prudent" -- more prudent than what?
b.
State what the State would consider the maximum expected "do nothing" interval that would be acceptable, and explain your reasons for the selection.
c.
How the State would justify potentially indefinite postponement of safety enhancements that might otherwise have been accomplished by license amendments and technical specification improve-ments?
d.
Does your contention depend upon the conclusion that the proposed amendment in this proceeding either reduces safety or fails to enhance safety?
If not, why not?
19.
Does the State contend chat "the 'out-of-service times,' during which it is proposed n21 to verify redundant subsystem availability by test
. cause unnecessary risk to public health and salety and the environment"?
a.
If so, please state each of the reasons uny the State so contends and each of the facts on which the State relies to support its contention, b.
Has the State quantified the "risk" to which reference is made in the quoted language?
c.
If so, please state the quantification, describo how it was derived, and provide any reports, calculations or other documents prepared during or i
as a result of, or that the State contends support, the quantification.
i 20.
Please identify (by providing the name, last known address, employer or business affiliation and occupation and business position held): _. _, -
a.
Each person upon whose factual knowledge the State of Vermont intends to rely in support of its contention, b.
For each such person identified, please state the facts to which such person might testify and the basis of such person's knowledge of such facts.
i c.
Each person upon whose opinion or expertise the State of Vermont intends to rely in support of its contention.
d.
For each such person, please state the substance of each opinion held by such person on which the State relies and summarize the basis for each such opinion.
atto
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K. Gad I Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 Telephone 617-423-6100 i
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- 4 VYN-13 5 ",l(dLA-2 )
ASLB - Reg. Mail RXGCOSRG.VY CERTIFICATE OF SERVICE
'88 OCT -3 P4 :43 i
Imadeserviceofthewithi(nNo;c.,,
I, R. K. Gad III hereby certify that on c
ument'in, September 27, 1988, accordance with the rules of the commission by mailing'a copy theraof postage prepaid to the following Charles Bechhoefer, Esquire, Samuel H. Press, 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 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 1
Mr. James H. Carpenter Ann P. Hodgdon, Esquire Administrative Judge Office of the General Counsel Atomic Safety and Licensing U.S. Nucler.r Regulatory r
Board Panel Commission U.S. Nuclear Regulatory Washington, DC 20555 Commission Washington, DC 20555 Adjudicatory File l
Atomic Safety and Licensing i
l Board Panel Docket (2 copies) l
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U.S. Nuclear Regulatory Commission l
J Washington, DC 20555 t
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K. Gad III //
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