ML20196F709
| ML20196F709 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 11/28/1988 |
| From: | Gad R ROPES & GRAY, VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | VERMONT, STATE OF |
| References | |
| CON-#488-7622 OLA, NUDOCS 8812140075 | |
| Download: ML20196F709 (9) | |
Text
7.: pv ttLAkkQ W N L?[ $ ? M y c7g9 Filed: November 28Fl988.
UNITED STATES OF AN! ERICA
'E8 DEC -5 NO :19 NUCLEAR REGULATORY COSIN11SSIONc before the ATO5 tlc SAFETY AND LICENSING BOARD
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In the hiatter of
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VERhtONT YANKEE NUCLEAR )
Docket No. 50-271-OL A POWER CORPORATION
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(Spent Fuel Pool (Vermont Yankee Nuclear
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Expansion)
Power Station)
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INTERROGATORIES PROPOUNDED BY VERSIONT YANKEE NUCLEAR POWER CORPORATION TO Tile STATE OF VERhlONT (CONTENTIONS 2 AND 3)
Pursuant to 10 C.F.R. } 2.740b and this Board's orders of htay 26, 1987 and October 11, 1988, Vermont Yankee Nuclear Power Corporation ("Vermont Yankee") propounds the following interrogatories to the State of Vermont
(' State of Vermont").
1.
Please identify each person who participated or assisted in the preparation of State of Vermont's answers to these interrogatories, and identify the portions or your response to which each person contributed.
2.
With respect to each person identified in response to the forego-ing interrogatory, please state whether State of Vermont expects that such person will be presented as a witness in this proceeding. If so, please state:
a.
The facts to which each is expected to testify; b.
The basis of each's knowledge of the facts to which he is expected to testify; c.
The opinions to which each is expected to testify; and d.
A summary of the basis for each such opinion.
3.
Please identify each and esery document employed by State of Vermont in preparing its responses to these interrogatories, referred to by State of Vermont in preparing its responses to these intu 'ogatories, or (whether or not referred to) upon which State of Vermont relies in support 8812140075 001120 PDR ADOCK 0b000271 0
PDH b563
4 of any proposition set forth by State of Vermont in its responses to these interrogatories.
4.
Please produce for inspection and copying, at the offices of Ropes
& Gray, 225 Franklin Street, Boston, Massachusetts 02110 on Thursday, December 29, 1988, each document identified or required to be identified in your responses to these interrogatories.
5.
Does State of Vermont admit that a worker exposure of 33 men-rem is sufficiently low that a conclusion that the proposed amendment dou not constitute "a major federal action significantly affecting the environ-ment" is correct?
6.
If your answer to the foregoing interrogatory is anything other than an unqualified affirmative, please explain each and every reason why State of Vermont contends that a worxer exposure at a level of 33 man-rem renders the proposed amendment a "major federal action significantly affecting the environment."
7.
There have been approximately 100 spent fuel pool expansions performed in the United States by re-racking. Not one of those expansions has been determined to be a "major federal action significantly affecting the environment," whether on account of worker exposure or any other ground.
Does State of Vermont contend that, for any reason, the proposed re-racking at YYNPS is sufficiently different that a different result should obtain? If so, please explain all of the reasons why State of Vermont contends that VYNPS is different.
8.
Does State of Vermont contend that the NRC Staff is required to prepare an EIS in respect of the proposed spent fuel pool amendment because the worker exposure that implementation of the amendment will entail renders the amendment a "major federal action significantly affecting the environment?" If so, then please:
a.
State what State of Vermont contends is the worker exposure that implementation of the proposed amendment will entail, b.
Explain in detail how State of Vermont calculated or estimated this worker exposure, c.
Identify and state the qualifications of the person or persons who prepared this calculation or estimate to make such a calculation or estimate.
9.
Does State of Vermont believe that, for purposes of assessing the reasonableness of Vermont Yankee's estimate of 33 man. rem of worker exposure for implementation of the proposed amendment, it is relevant to insestigate the lesel of worker exposure estimated or incurred at other spent fuel pool re-rackings in the United States? If your answer to this inter-rogatory is in the affirmatise, please:
a.
Describe the actions that State of Vermont took to investigate such worker exposures at other facilities before submitting or supporting the admission of Contention 2.
b.
Describe the actions that State of Vermont took to investigate such worker exposures at other facilities after submitting or supporting the admission of Contention 2.
c.
Describe the results of the investigation (s) that State of Vermont performed.
d.
Identify and produce for inspection and copying all documents reflecting such insestigation(s), the results thereof, the sig-nificance of the results, and the efforts undertaken by State of Vermont.
e.
Identify an '. tate the qualifications of the person or persons who prepared th', investigation (s) for State of Vermont or estimate to make such an insestigation(s).
- 10. Does State of Vermont contend that the EA is deficient because "the E A fails to record individual worker exposures?" If so, please:
a.
Explain what State of Verrnent means by the assertion that the "EA fails to record individual worker exposure.'
b.
Explain how State of Vermont contends "individual worker exposure
- might be "recorded
- prior to the events that produce the exposure,
- 11. Does State of Vermont contend that, given that 33 man-rem is the correct estimate of aggregate worker exposure, the question of whethf.r the proposed amendment should be approved or not is affected by "the number of workers receiving additional exposures through this amendment, the maximum exposures to be received by individual workers, or the number of workers who would likely receive various levels of exposures?' If so:
a.
is State of Vermont aware of any case in which the question of worker exposure for an amendment of this type has been calcu-lated or assessed on any basis othen than in the aggregate?
b.
If so, please identify each such case.
c.
Does State of Vermont admit that such exposures are usually calculated and usessed on an aggregate basis?
d.
If so, does State of Vermont contend that VYNPS is sufficiently different from other cases ti.
worker exposure shonid be calculated or assessed differently?
e.
If so, please identify each and esery reason why State of Vermont 3
4 contends VYNPS is different, and the significance that State of Vermont contends attaches to each such difference.
- 12. Does State of Vermont intend to introduce the testimony of any expert witness in support of its assert'on that the EA is deficient because "the EA fails to record individua' worker exposure?' If so:
a.
Please identify, by prosiding the name, address, business affilia-tion, and fields of expertise, each cuch expert.
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b.
Please state the substance of the opinions which each such expert
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is expected to give and a summary of the grounds therefor, i
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- 13. Does State of Vermont contend that the estimate of worker exposure prepared by Vermont Yankee should be increased to account for "fuel handling accidents?' If so:
a.
Please state the amount of man rem that should be added to the I
estimate to account for "fuel handling accidents."
b.
Please describe in detail how State of Vermont calculated or es-timated this number.
c.
Identify and state the qualifications of the person or persons who prepared this calculation or estimate to make such a calculation or estimate.
d.
Does State of Vermont contend that, as increased in the manner in which State of Vermont urges, the resultant worker exposure would render the proposed amendment a "major federal action sig-nificantly affecting the environment?"
If so, please explain in detail the standard th:t State of Vermont has used to determine when worker exposure constitutes a proposed amendment a "major federal action significantly affecting the environment."
14 Does State of Vermont intend to introduce the testimony of any expert witness in support of its assertions regarding "fuel hand!!ng acci-dents." If so:
a.
Please identify, by providing the n.me, address, business affilia.
tion, and fields of expertise, each such expert.
i b.
Please state the substance of the opinions which each such expert is expected to give and a summary of the grounds therefor.
j
- 15. Does State of Vermont contend that the estimate of worker
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esposure prepared by Vermont Yankee should be increased to account for i
"crud release?' If so:
a.
Please state the amount of man rem that should be added to the estimate to account for "crud release.'
t 4
t
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't.
b.
Please describe in detail how State of Vermont calculated or es-timated this number, c.
Identify and state the qualifications of the person or persons who prepared this calculation or estimate to make such a calculation or
- estimate, d.
Does State of Vermont contend that, as increased in the manner in which State of Vermont urges, the resultant worker exposure would render the proposed amendment a "major federal action sig-nificantly affecting the environment?'
If so, please explain in detail the standard that State of Vermont has used to determine when worker exposure constitutes L proposed amendment a "major federal action significantly affecting the environment."
- 16. Does State of Vermont intend to introduce the testimony of any expert witness in support of its assertions regarding "crud release." If so:
a.
Please identify, by providing the name, address, business affilis-tion, and fields of expertise, each such expert.
b.
Please state the substance of the opinions which each such expert is expected to give and a summary of the grounds therefor.
17.
Does State of Vermont contend that the estimate of worker exposure prepared by Vermont Yankee should be increased to account for "inadvertent pool drainage accidents?" If so:
3.
Please state the amount of man-rem that should be added to the estimate to account for "inadsertent pool drainage accidents."
b.
Please describe in detail how State of Vermont calculated or es-I timated this number.
c.
Identify and state the qualifications of the person or persons who prepared this calculation or estimate to make such a calculation or estimate.
I d.
Does State of Vermont contend that, as increased in the manner in which State of Vermont urges, the resultant worker exposure would render the proposed amendment a "major federal action sig-nificantly affecting the environment?'
If so, please explain in 1
detail the standard that State of Vermont has used to determine when worker exposure constitutes a proposed amendment a "major federal action significantly affecting the environment.'
- 18. Does State of Vermont intend to introduce the testimony of any l
expert witness in support of its assertions regarding "inadvertent pcol 4
drainage accidents." If so:
3.
Please Mentify, by providing the name, address, business cffilis-i tion, and fields of expertise, each such expert.
5-
r e
b.
Please state the stetwee of the opinions which each such expert is expected to gi,e " 1 summary of the grounds therefor.
19 Please describe the "alternative.of dry cask storage" that State of Vermont contends should be further considered as an alternative to al-lowan of the proposed amendment.
Ou, P! esse state what State of Vermont contends is the capacity of a dry cask suitable for use as an alternative to storage of spent fuel as-semblies in the spent fuel pool, or, if State of Vermont contends that more than one type of cask is available, the capacity of each type.
Please identify each document or other source of information upon which State of Vermont relies for its information.
2:. Please state what State of Vermont contends is the cost of a dry cask suitable for use as an alternatise to storage of spent fuel assemblies in the spent fuel pont, or, if State of Vermont contends that more than one type of cask is available, the cost of each type.
P' e idenx each document or other source of information.apon which Str'e of % munt reliet for its information.
- 22. Please state what State of Vermont cont =nds is the avai' ability of a dry cask suitable for use as an alternatise to norage of spent fuel as-semblies in the spent fuel pool, or, if State of Vermont contends that more than one type of cask is assilable. the availability of each tepe.
Please identify each document or other source of information upon wl.ich State of Vermotit relie: for its information.
- 23. Please state how quickly State of Vermor' contends that a iaeility employing dry casks as an alternative to storage of spent fuel assemblies in the spent fuel pool could be completed and ready for use. Please explain how State of Vermont reaches this conclusion, and include in your explans-tion the salues used by State of Vermont for:
I a.
Conceptual design.
b.
Final engineering and aesign, c.
Preparati;n of specifications for cask acquisition and cask acquisition.
d.
Cask inanufacture, e.
Site design and land acquisition.
i l
f.
Obtaining of required licenses, pern.t$ and approsals from t'ie
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United States Nuclear Regulatory Ccmmusion.
g.
Obtaining of required licenses, permi.ts and apprt 11s from any other federal agency.
i
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d h.
Obtaining of required licenses, permits and approvals from the State of Vermont.
i.
Obtaining of required licenses, permits and '.pprovals from the Town of Vernon, Vermont.
J Obtaining of required licenses, permits and approvais from any other governmental agency not provided for above.
k.
Construction.
I Please explain the basis for each of your responses to the foregoing.
21 Ilow much additionalland does State of Vermont contend would be required to be acquired. and annexed to the existias VYNPS site in order to accommodate the alternative for which State of Vermont contends? Please explain how State of Vermont hat determined the land requirement.
- 25. If a dry cask alternative were to be proposed or pursued by VYNPC, would State of Vermont agree not to oppose the granting of all required licenses, permits and approvals in connection with such alternative?
- 26. If a dry cask alternative were to be proposed or pursued by YYNFC, would State of Vermont agree to support the granting of all l
required licenses, permits and approvals in connection with such alternative?
- 27. If a dry cask alternatise were to be proposed or pursued by VYNPC, would State of Vermont agree not to oppose the recovery of the i
additional costs of such alternatise?
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- 28. If a dry cask alternatise were to be propord or pursued by VYNPC, would State of Vermont agree to support th recovery of the I
additional costs of such alternative?
- 29. Does State of Vermont contend that the proposed license amend-ment invols es unresolved conflicts concerning the alternative uses of I
available resources? If so, please:
i 3.
Identify each resource, b.
Identif, each alternatise use of each resource.
i c.
Explain why State of Vermont contends that there exists an un-s resolsed conflict concerning alternative uses of each resource.
I
- 30. Does State of Vermont contend that the dry cask alternative it espouses would be environmentally preferable to implementation of the spent fuel pool expansion as proposed in the pending license amendment? If so:
[
a.
Please identify each ensironmental triterion on which ftate of l
Vermont contends its alternatise would be preferable l
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b.
For each such criterion, state what State of Vermont contends would be the environmental effects of its dry cask alternative?
c.
For each such criterion, state what State of Vermont contends would be the environmental effects of the proposed amendment?
d.
Identify each environmental criterion in addition to those iden-tified by State of Vermont in response to subpart (a) of this interrogatory of which State of Vermont is aware on the basis of which its dry cask af ernathe and the proposed amendment might t
be compared.
e.
For each such criterion, state what State of Vermont contends would be the ensironmental effeets of its dry cask alternatise?
f.
For each sucn criterion, state what State of Vermoni cantends would be the environmental effects of the proposed amendment?
- 31. Is State of Vermont aware of any written environmental com-parison of any dry cask alternatise to kny form of spent fuel pool capacity expansion, whether heretofore published or not? If so, please:
a.
Identify each such co.nparison.
b.
State whether State of Vermont agrees with the conclusions stated in the comparison, c.
Identify any conclusion stated in the comparison with which State of Vermont does not agree, d.
Explain all of the reasons why State of Vermont does not agree with any such conclusion.
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John A. Ritsher /
R. K. Gad III / '
Kathryn A. Selleck Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 Telephone: 617-423-6100, i
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yqq.
M VYN-123 ASLB - Reg. Mail CERTIFICATE OF SERVICE b0 IC ~
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R.
K. Gad III, hereby certify that on>fht. 9 VICf.
Novenber 28, 1988, I made service of the within' document in accordance with the rules of the Commission by mailing a copy thereof postage prepaid to the following:
Charles Bechhoefer, Esquire, Samuel H. Press, Esquire Chairman George E.
Young, Esquire Administrative Judge Vermont Department of Atomic Safety and Licensing Public Service a
Board Panel 120 State Street U.S. Nuclear Regulatory Montpelier, VT 05602 Commission l
Washington, DC 20555 Mr. Glenn o. Bright Ellyn R. Weiss, Esquire Administrative Judge Harmon & Weiss 3
Atomic Safety and Licensing Suite 430 Board Panel 2001 S Street, N.W.
j U.S. Nuclear Regulatory Washington, DC 20009
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Commission j
Washington, DC 20555
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Mr. James H. Carpenter George B.
Dean, Esquire j
Administrative Judge Assistant Attorney General Atomic Safety and Licensing Department of the Attorney Board Panel General J
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 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 Concord, NH 03301-6397 O
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