ML20196F726
| ML20196F726 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 11/28/1988 |
| From: | Gad R REID & PRIEST, VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| References | |
| CON-#488-7620 OLA, NUDOCS 8812140086 | |
| Download: ML20196F726 (9) | |
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a C LAlED CURRLS)?N,0.El(CR mrico Filed: Novembe608,1988, i
UNITED STATES OF ASIERICA SS DEC -5 IJ0:19 NUCLEAR REGULATORY COhlSilSSION t
before the ATOSilC SAFETY AND LICENSING BOARD I
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r in the hiatter of
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VERhtONT Y ANKEE NUCLEAR )
Docket No. 50-271-OLA 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 NEW ENGLAND COALITION ON NUCLEAR POLLUTION, INC.
(CONTENTIONS 2 AND 3)
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Pursuant to 10 C.F.R. { 2.740b and this Board's orders of hiay 26, 1987 and October 11, 1988, Vermont Yankee Nuclear Power Corporation (*Vermna*
Yankee") propounds the following interrogatories to New England Coalition l
on Nuclear Pollution, Inc. ("NECNP*).
1.
Please identify each person who participated or assisted in the l
preparation of NECNP's answers to these interrogatories, and identify the portions or your response to which each person contributed.
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i 2.
With respect to each verson identified in response to the forego-ing interrogatory, please state whether NECNP expects that such person will be presented as a witness in this proceeding. If so, please state:
l a.
The fvts to which each is expected to testify; l
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 NECNP in preparing its responses to these interrogatories, referred to by NECNP in preparing its responses to these interrogatories, or (whether or not referred to) upon which NECNP relies in support of any proposition set forth by NECNP in its responses to these interrogatories.
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i 4.
Please produce for inspection and copying, at the offices of Ropes
& Gray, 225 Franklin Street, Boston, Massachusetts 02110 on Thursday, December 29, 1938, each document identified or required to be identified in your responses to these interrogatories.
5.
Does NECNP admit that a worker exposure of 33 man-rem is sufficiently low that a conclusion that the proposed amendment does not constitute "a major federal action significantly affecting the environment" is correct?
6.
If your answer to the foregoing interrogatory is an> thing other than an unqualified affirmatise, please explain each and esery reason why NECNP contends that a worker exposure at a lesel of 33 man-rem renders the proposed amendment a "major federal action significantly affecting the ens ironme nt."
7.
There hase 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 signifie.intly affec;ing the ensironment," whether on account of worker exposure o' any other ground.
Does NECNP contend that, for any reason, the proposed re-racking at VYNPS is sufficiently different that a different result should obtain? If so, please explain all of the reasons why NECNP contends that VYNPS is different.
S.
Does NECNP 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 environ-ment?' If so, then please:
a.
State what NECNP contends is the worket esposure that ii.iplemen-tation cf the proposed amendment will entail, b.
Explain in detail how NECNP 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 NECNP beliese that, for purposes of assessing the reason-ableness 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-rsekings in the United States? If your answer to this interrogatory is in the affirmative, please a.
Describe the actions that NECNP took to inustigate such worker exposures at other facilities before submitting or supporting the admission of Contention 2.
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s b.
Describe the actions that NECNP took to insestigate such worker exposures at other facilities after submitting or supporting the acmission of Contention 2.
c.
De:cribe the results of the investigation (s) that NECNP performed, d.
Iden'ify and produce for inspection and copying all documents reflecting such ins estigation(s), the results thereof, the sig-nificance of the results, and the efforts undertaken by NECNP.
e.
Identity and state the qualifications of the person or persons who prepared this insestigationfs) for NECNP or estimate to make such an insestigation(s).
- 10. Does NECNP contend that the EA is deficient because "the EA fails to record indisidual worker exposures?" If so, please:
a.
Explain what NECNP means by the assertion that the *EA fails to record individual worker exposure.'
b.
Explain how NECNP contends *indisidual worker exposure" might be "recorded" prior to the events that produce the exposure.
II.
Does NECNP contend that, gisen that 33 man-rem is the correct estimate of aggregate worker exposure, the question of whether the proposed amendment should be approsed or not is affected by *the number of workers receiving additional exposures through this amendment, the maximum exposures to be receised by individual workers, or the number of workers who would likely receise various levels of exposures If so:
a.
Is NECNP aware of any case in which the question of worker exposure for an amendment of this type has been calculated or assessed on any basis other than in the aggregate?
b.
If so, please identify each such case, c.
Does NECNP admit that such exposures are usually calculated and assessed on an aggregate basis?
d.
If so, does NECNP contend that VYNPS is sufficiently different from other cases that worker exposure should be calculated or assessed differently?
e.
If so, please identify each and esery reason why NECNP contends VYNPS is different, and the significance that NECNP contends attaches to each such difference.
- 12. Does NECNP intend to introduce the testimony of any expert witness in support of its assertion that the EA is deficient because "the EA fails to r teord indisidual worker esposure?" If so:
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a.
Please identify, by prosiding the name, addi.ss.
affilia-u tion, and fields of expertise, each such expert.
b.
Please state the substance of the opinions which ea.: such expert is expected to gise and a summary of the grounds therefor.
13.
Does NECNP contend that the estimate of worker e xposure 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 tstimate to account for
- fuel handling accidents."
b.
Please describe in detail how NECNP calculated or estimated this nu mbe r.
c.
Identify and state the qualifications of the person or persons wtw prepared this calculation or estimate to make such a calculation or
- estimate, d.
Does NECNP contend that, as increased in the manner in which NECNP urges, the resultant worker exposure would render the proposed amendment a "major federal action significantly affecting the environment?'
If so, please explain in detail the standard that NECNP has used to determine whea worker exposure con-stitutes a proposed amendment a "major federal action significantly affecting the easironment."
14.
Does NECNP intend to introduce the testimony of any expert witness in support of its assertions regarding
- fuel handling accidents." If so a.
Please identify, by prosiding the name, address, business affilia-tion, and fields of expertise, each such expert, b.
Please state tne substance of the opinions which each such expert is espected to gise and a summary of the grounds therefor.
- 15. Does NECNP contend that the estimate of worker exposure prepared by Vermont Yankee should be increased to account for "crud release?" If so:
a.
Please state the amount of man-rem that should be added to the estimate to account for ' crud release."
b.
Please describe in detail how NECNP calculated or estimated this
- number, c.
Identify and statt the qualifications of the person or persons who prepared this calculation or estimate to make such a calculation or estimate.
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d.
Does NECNP contend that, as increased in the manner in which NECNP urges, the resultant worker exposure would render the proposed amendment a "major federal action significantly affecting the environment?'
If so, please explain in detail the standard that NECNP has used to determine when worker exposure con-stitutes a proposed amendment a "major federal action significantly affecting the environment."
16.
Does NECNP intend to introduce the testimony of any expert witness in support of its assertions regarding "crud release." If so:
3.
Please identify, by providing the name, address, business affilis-tion, and fields of expertise, each such expert, b.
Please state the substance of the opiaions which each such expert is expected to gise and a summary of the grounds therefot.
- 17. Does NECNP contend that the estimate of worker exposure prepared by Vermont Yankee should be increased to account for "inadsertent pool drainage accidents?" If so:
3.
Please state the amount of man-rem that should be added to the estimate to account for "inadsettent pool drainage accidents."
b.
Please describe in deta.:1 how NECNP calculated or estimated 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 NECNP contend that, as increased in the manner in which NECNP urges, the resultant worker exposure would render the proposed amendment a "major federal action significantly affecting the ensironment?"
If so, please explain in detail the standard that NECNP has used to determine when worker exposure con-stitutes a proposed amendment a "major federal action significantly affecting the environment."
- 18. Does NECNP intend to introduce the testimony of any expert witness in support of its assertions regarding "inadvertent pool drainage accidents." Ifso:
a.
Please identify, by providing the name, address, business affilia-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 therefer.
19.
Please describe the 'alternatise of dry cask storage" that NECNP contends should be further considered as an alternatise to allowance of the proposed amendment..
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- 20. Please state what NECNP contends is the capacity of a dry cask suitable for use as an alternative to storage of spent fuel assemblies in the spent fuel pool, or, if NECNP contends that more than one type of cask is asailable, the capacity of each type. Please identify each document or other source of information upon which NECNP relies for its information.
- 21. Please state what NECNP contends is the cost of a dry cask suitable for use as an alternalise to storage of spent fuel assemblies in the spent fuel pool, or, if NECNP contends that more than one type of cask is assilable, the cost of each t>pe.
Please identify each document or other source of information upon which NECNP relies for its information.
- 22. Please state what NECNP contends is the availability of a dry cask suitable for use as an alternatise to storage of spent fuel assemblies in the spent fuel pool, or, if NECNP contends that more than one type of cask is availab.e the asailability of each type. Please identify each document or other source of information upon which NECNP relies for its information.
- 23. Please state how quickly NECNP contends that a facility employing dry easks as an alternatise to storage of spent fuel assemblies in the spent fuel pool could be completed and ready for use. Please explain how NECNP reaches this conclusion, and include in your explanation the salues used by NECNP !ct:
a.
Conceptual design.
b.
Final engineering and design.
c.
Preparation of specifications for cask acquisition and cask acquisition, d.
Cask manufacture, e.
Site design and land acquisition.
f.
Obtaining of required licenses, permits and approsals from the United States Nuclear Regulatory Commission.
g.
Obtaining of required licenses, permits and approvals from any other federal agency.
h.
Obtaining of required licenses, permits and approsals from the State of Vermont.
i.
Obtaining of required licenses, permits and approsals from the Tow n of Vernon, Vermont.
j.
Obtaining of required licenses, permits and approsals from any other gosernmental agency not prosided for abose.
j k.
Construction.
,y Please explain the basis for each of your responses to the foregoing.
24.
flow much additionalland does NECNP contend would be required to be acquired and annexed to the existing VYNPS site in order to accom-modate the alternatise for which NECNP contends?
Please esplain how NECNP has determined the land requirement.
2$. If a dry cask alternatise were to be proposed or pursued by YYNPC, would NECNP sgree not to oppose the granting of all required licenses, permits and approsals in connection with such alternative?
- 06. If a dry cask alternstise were to be proposed or pursued by VYNPC, would NECNP agree to support the granting of all required licenses, permits and approsals in connection with such alternstise?
27, if a dry cask alternstise were to be proposed or pursued by VYNPC, would NECNP sgree not to oppose the recosery of the additional costs of such siternstise?
- 28. If a dry cask alternatise were to be proposed or pursued by VYNPC, would NECNP agree to support the recovery of the additional costs of such alternatise?
29.
Does NECNP contend that the proposed license amendment insolses unresolsed conflicts concerning the alternstise uses of asailable resources? If so, please:
a.
Identify each resource.
b.
Identify each alternstise use of each resource.
c.
Esplain why NECNP contends that there exists an unresolsed conflict concerning alternatise uses of each resource.
- 30. Does NECNP contend that the dry cask alternatise it espouses would be ensironmentally preferable to implementation of the spent fuel pool etransion as proposed in the pending license amendment? If so:
a.
Please identify each ensironmental criterion on which NECNP contends its alternatise would be preferable, b.
For each such criterion, state what NECNP contends would be the ensironmental effects of its dry cask alternatise?
c.
For each such criterion, state what NECNP contends would be the ensironmental effects of the proposed amendment?
d.
Identify each ensironmental criterion in addition to those iden-tified by NECNP in response to subpart (s) of this interrogatory of which NECNP is aware on the basis of which its dry cask alternstise and the proposed amendment might be compared.
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c.
For each such criterion, state what NECNP contends would be the environmental effects of its dry cask alternatise?
f.
For each such criterion, state what NECNP contends would be the ensironmental effects of the proposed amendment?
- 31. Is NECNP aware of any written environmental comparison of any dry cask alternatise to any form of spent fuel pool capacity npansion, whether heretofore published or not? If so, please:
a.
Identify each such comparison.
b.
State whether NECNP agrees with the conclusions stated in the comparison.
c.
Identify any conclusion stated in the comparison w ith which NECNP does not agree.
d.
Explain all of the reasons why NECNP does not agree with any such conclusion.
attorney s, I
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John A. Ritshet R. K. Gad 111 Kathryn A. Selleck Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 Telephone: 617-123 6100.
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VYN-123 ASLB - Reg. Mail DEC -5 *"DGffSR3.vY CERTIFICATE OF SERVIC
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Gad III, horoby cortify that on "di November 28, 1988, I made service of the within,' document in accordan:o with the rules of the Commission by mailing a copy thoroof postage propaid to the following:
Char 10s Bochhoofer, Esquire, Samuel H.
Press, Esquiro 0;iairman George E.
Young, Esquire Administrative Judge Vermont Dopartment of Atomic Safety and Licensing Public Servico Board Panel 120 Stato Street U.S.
Nuclear Regulatory Montpelier, VT 05602 Commission Washington, DC 20555 Mr. Glenn O.
Bright Ellyn R.
Weiss, Esquire Administrative Judge Harmon & Weiss Atomic Safety and Licensing Suite 430 Board Panel 2001 S Street, N.W.
U.S.
Nuclear Regulatory Washington, DC 20009 Commission Washington, DC 20555 Mr. James H.
Carpentor Georgo 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 Atomic Safety and Licensing Geoffrey M.
Huntington, Esquire Appeal Board Panel office of the Attorney General U.S.
Nuclear Regulatory Environmental Protection Bureau l
Commission State House Annex l
Washington, DC 20555 25 Capitol Street Concord, NH 03301-6397 l
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