ML20196F741
| ML20196F741 | |
| 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: | MASSACHUSETTS, COMMONWEALTH OF |
| References | |
| CON-#488-7621 OLA, NUDOCS 8812140093 | |
| Download: ML20196F741 (9) | |
Text
e 74 a/
- ELATED CORRESfp,N,D,EJCg Filed: NovembOhh88.
UNITED STATES OF AhlERICA
'68 DEC -5 A10 :20 NUCLEAR REGULATORY COhlhilSSION before the ATOhllC SAFETY AND LICENSING BOARD
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In the hiatter of
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VERh10NT YANKEE NUCLEAR )
Docket No. 50-271-OLA POWER CORPORATION
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(Spent Fuel Pool (Vermont Yankee Nuclear
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Expansioa)
Power Station)
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INTERROGATORIES PROPOUNDED BY VER$10NT YANKEE NUCLEAR POWER CORPORATION TO Tile C05l.hlONWEALTII OF hlASSACIIUSETTS (CONTENTIONS 2 AND 3)
Pursuant to 10 C.F.R. I 2.740b and this Board's orders of hfay 26, 1987 and October 11,1988 Vermont Yankee Nuclear Power Corporation ("Vermont Yankee") propounds the following interrogatories to the Commonwealth of hf assachusetts ("Commonw ealth").
1.
Please identify each person who participated or assisted in the preparation of Commonwealth'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 Commonwealth 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 every document employed by Common-wealth in preparing its responses to these interrogatories, referred to by Commonwealth in preparing its responses to these interrogatories, or (whether or not referred to) upon which Commonwealth relies in support of 8812140093 001120 PDR ADOCK 05000;171 0
PDR D503
any proposition set forth by Commonwealth 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 Commonwealth 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 anything other than an unqualified affirmative, please explain each and every reason why Commonwealth contends that a worker 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 Stater 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 Commonwealth 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 Commonwealth contends that VYNPS is different.
8.
Does Commonwealth 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 Commonwealth contends is the worker exposure that implementation of the proposed amendment will entall.
b.
Explain in detail how Commonwealth 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 Commonwealth 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 investigate the level 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 affirmative, please:
2
s.
Describe the actions that Commonwealth took to investigate such worker exposures at other facilities before submitting or support-ing the admission of Contention 2.
b.
Describe the actions that Commonwealth took to investigate such worker exposures at other facilities after submitting or supporting I
the admission of Contention 2.
c.
Describe the results of the investigation (s) that Commonwealth perro med.~
.d.
Identify and produce for inspection and copying all documents l
reflecting such investigation (s), the results thereof, the sig-l nificance of the results, and the efforts undertaken by Common-i
- wealth, e.
Identify and state the qualifications of the person or persons who prepared this investigation (s) for Commonwealth or estimate to make such an investigation (s).
- 10. Does Commonwealth contend that the EA is deficient because "the EA fails to record individual worker exposures?" If so, please:
a.
Explain what Commonwealth means by the assertion that the "EA falls to record individual worker exposure."
b.
Explain how Commonwealth contends "individual worker exposure" might be "recorded
- prior to the events that produce the exposure.
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- 11. Does Commonwealth contend that, given that 33 man-rem is the I
correct estimate of aggregate worker exposure, the question of whether the proposed amendment should be approved or not is affected by 'the number of workers receiving additional exposures through this amendment, the i
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 Commonwealth aware of any case in which the question of
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worker exposure for an amendment of this type has been calcu-lated or assessed on any basis other than in the aggregate?
b.
If so, please identify each such case.
c.
Does Commonwealth admit that such exposures are usually l
calculated and assessed on an aggregate basis 7 d.
If so, does Commonwealth contend that VYNPS is sufficiently different from other cases that worker exposure should be I
calculated or assessed differently?
l e.
If so, please identify each and every reason why Commonwealth contends YYNPS is different, and the significance that Common-wealth contends attaches to each such difference.
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- 12. Does Commonwealth intend to introduce the testimony of any expert witness in support of its assertion that the EA is deficient because "the EA fails to record individual worker exposure?" If so:
a.
Please identify, by providing the name, address, business affilla-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.
- 13. Does Commonwealth 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 estimate to account for "fuel handling accidents."
b.
Please describe in detail how Commonwealth calculated or es-timated this rumber.
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 Commonwealth contend that, as increased in the manner in which Commonwealth urges, the resultant worker exposure would render the proposed amendment a "major federal action significant-ly affecting the environment?" If so, please explain in detail the standard that Commonwealth has used to determine when worker exposure constitutes a proposed amendment a "major federal action significantly affecting the environment."
- 14. Does Commonwealth intend to introduce the testimony of any expert witness in support of its assertions regarding "fuel handling acci-dents." 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.
- 15. Does Commonwealth 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 Commonwealth calculated or es-timated this number.
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i 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 Commonwealth contend that, as increased in the manner in which Commonwealth urges, the resultant worker exposure would render the proposed amendment a "major federal action significant-ly affecting the environment?" If so, please explain in detail the standard that Commonwealth has used to determine when worker exposure constitutes a proposed amendment a "major federal action significantly affecting the environment."
- 16. Does Commonwealth 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 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 therefor.
- 17. Does Commonwealth contend that the estimate of worker exposure prepared by Vermont Yankee should be increased to account for "inadvertent pool drainage accidents?" If so:
a.
Please state the amount of man-rem that should be added to the estimate to account for "inadvertent pool drainage accidents."
b.
Please describe in detail how Commonwealth calculated or es-timated this number, i
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 Commonwealth contend that, as increased in the manner in which Commonwealth urges, the resultant worker exposure would render the proposed amendment a "major federal action significant-ly affecting the environment?' If so, please explain in detail the standard that Commonwealth has used to determine when worker exposure constitutes a proposed amendment a "major federal action i
significantly affecting the environment."
- 18. Does Commonwealth intend to introduce the testimony of any expert witness in support of its assertions regarding "inadvertent pool drainage accidents." If so a.
Please identify, by providing the name, address, business affilis-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.
- 19. Please describe the "alternative of dry cask storage" that Com-monwealth contends should be further considered as an alternative to allowance of the proposed amendment.
- 20. Please state what Commonwealth contends is the capacity of a dry cask suitable for use as an alternative to storage of Spent fuel assemblies in i
the spent fuel pool, or, if Commonwealth 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 Commonwealth relles i
for its information.
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- 21. Please state what Commonwealth contends is the cost of a dry cask suitable for use as an alternative to storage of spent fuel assemblies in the spent fuel pool, or, if Commonwealth contends that more than one type l
of cask is available, the cost of each type. Please identify each document or other source of information upon which Commonwealth relies for its i
information.
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- 22. Please state what Commonwealth contends is the availability of a dry cask suitable for use as an alternative to storage of spent fuel as-semblies in the spent fuel pool, or, if Commonwealth contends that more than one type of cask is available, the availability of each type.
Please identify each document or other source of information upon which Common-wealth relies for its information.
- 23. Please state how quickly Commonwealth contends that a facility i
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
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how Commonwealth reaches this conclusion, and include in your explanation l
the values used by Commonwealth for:
a.
Conceptual design.
b.
Final engineering and design, c.
Preparation of specifications for cask acquisition and cask acquisition.
d.
Cask manufacture.
i e.
Site design and land acquisition, j
f.
Obtaining of required licenses, permits and approvals from the i
United States Nuclear Regulatory Commission, g.
Obtaining of required licentes, permits and approvals from any other federal agency.
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i h.
Obtaining of required licenses, permits and approvals from the
' State of Vermont.
i.
Obtaining of required licenses, permits and approvals from the Town of Vernon, Vermont.
J.
Obtaining of required licenses, permits and approvals from any other governmental agency not provided for above.
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k.
Construction.
t Please explain the basis for nch of your responses to the foregoing, j
- 24. How much additional land does Commonwealth contend would be required to be acquired and annexed to the existing YYNPS site in order to accommodate the alternative for which Commonwealth contends?
Please explain how Commonwealth has determined the land requiremer.t.
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- 25. If a dry cask alternative were to be proposed or pursued bv VYNPC, would Commonwealth 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 er parsued by
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VYNPC, would Commonwealth agree to support the granting of all required t
licenses, permits and approvals in connection with such alternative?
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- 27. If a dry cask alternative were to be proposed or pursued by VYNPC, would Commonwealth agree not to oppose the recovery of the l
additional costs of such alternative?
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- 28. If a dry casx alternative were to be proposed or pursued by l
VYNPC, would Commonwealth agree to support the recovery of the additional
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costs of sMn alternative?
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- 29. Does Commonwealth contend that the proposed license amendment involves unresolved conflicts concerning the alternative uses of available resources? If so, please:
f a.
Identify each resource, f
f b.
Identify each alternative use of each resource, c.
Explain why Commonwealth contends that there exists an un-resolved conflict concerning alternative uses of each resource.
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- 30. Doe: Commonwealth contend that the dry cask alternative it j
espouses would be environmentally preferable to implementation of the spent 7'
fuel pool expansion as proposed in the pending license amendment? If so:
a.
Please identify each environmental criterion on which Common-wealth contends its alternative would be preferable.
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b.
For each such criterion, stats what Commonwealth contends would be the environmental effects of its dry cask alternative?
c.
For each such criterion, state what Commonwetlth contends would be the environmental effects of the proposed amendment?
d.
Identify each environmental criterion in addition to those iden.
tified by Commonwealth in response to subpart (a) of this interrogatory of which Commonwealth is aware on the basis of which its dry cask alternative and the proposed amendment might be compared.
e.
For each such criterion, state what Commonwealth contends would be the environmental elfects of its dry cask alternative?
f.
For each such criterion, state what Commonwealth contends would be the envitcamental effects of the proposed amendr. tent?
- 31. Is Commonwealth aware of any written environmental comparison of any dry cask alternative to any form of spent fuel pool capacity expan-sion, whether heretofore published or not? If so, please:
a.
Identify each such comparison, b.
State whether Commonwealth agrecs with the conclusions stated in the comparison.
c.
Identify any conclusion stated in the comparison with which Commonwealth does not agree, d.
Explain all of the reasons why Commonwealth does not agree with ariy such conclusion.
attorneys,
.h ohn A. Ritsher R. K. Gad til Kathryn A. Selleck Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 Telephone: 617-423 6100.
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C at :f Esq VYN-123 ASLB ** Reg. Mail RKGCOSR3.VY CEBTIFICATE AF SERVrak DEC -5 A10:20 hereby certify thation:
?;/j Imadeserviceofthe'~withinidocu((mentin I, R.
K. Gad III, November 28, 1988, 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 Board Panel 120 State Street U.S. Nuclear Regulatory Montpelier, VT OC602 Commission Washington, DC 20555 Mr. Glenn O.
Bright Ellyn R. Weiss, E'Jguire 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. 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 Counsol Board Panel Docket (2 copios)
U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Atomic Safety and Licensing Geoffrey M. Huntington, Esquiro 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
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R. K. GadIIIp
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