ML20205N298

State of VT Supplemental Response to Vermont Yankee First Set of Interrogatories & Requests for Production of Documents.* Certificate of Svc Encl.Related Correspondence

ML20205N298
Person / Time
Site:	Vermont Yankee
Issue date:	10/28/1988
From:	Press S, Sedano R VERMONT, STATE OF
To:	VERMONT YANKEE NUCLEAR POWER CORP.
Shared Package
ML20205N289	List: ML20205N286 ML20205N298
References
87-567-04-OLA, 87-567-4-OLA, OLA, NUDOCS 8811040044
Download: ML20205N298 (6)

Text

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t UNITED STATES OF AMERICA ,

NUCLEAR Ru.]ULATORY COMMISSION '88 NOV -1 All :10 i ATOMIC SAFETY AND LICENSING BOARD,n ,

Before Administrative Judges 00 4 .. .

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Charles Bechhoefer, Chairman  !

Glenn O. Bright  ;

Dr. James H. Carpenter '

I In the Matter of )

) i VERMONT YANKEE NUCLEAR POWJR ) Docket No. 50-271-OLA-2 POWER CORPORATION ) (Testing Requirements for

) ECCS and SLC Systems) ,

(Vermont Yankee Nuclear )  !

Power Station) ) (ASLBP No. 87-567-04-OLA) t

) I L

STATE OF VERMONT'S SUPPLEMENTAL RESPONSE TO VERMONT YANKEE'S FIRST SET OF INTERROGATORIES AND REQUESTS l FOR PRODUCTION OF DOCUMENTS  ;

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Pursuant to 10 C.F.R. 2.740(e) the State of Vermont submits [

tho following information to supplement its response to Vermont i Yankee's First Set of Interrogatories and Requests for Produciton l

(

of Documents. f

20. a. W. K. Sherman, Consultant i I

b. The State objects to this interrogatory to the extent that it l requests information of witnesses as other than expert witnesses on the grounds that it is beyond the scope of i discovery of expert witnesses authorized under 10 C.F.R. '

8811040044 881020 ~ <

gDR ADOCK 05000273 page 1 I PDR I 1

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2.740. Notwithstanding this objection, and without waiving it, the State of Vermont offers the following.

Mr. Sherman plans to testify to the following facts and opinions:

1) Without the necessary verification testing of the alternate system upon failure of the primary system, the probability, over a five year period, of both trains of the safety systems not being available on demand is 1.2 per year (6 events over a 5 year period). These facts and conclusions will be based upon information provided by the Applicant (see "Applicant's Answers to State of Vermont's First Set of Interrogatories and Requests for the Production of Documents to Vermont Yankee Nuclear Power Corporation," Interrogatory No. 14). The State is still reviewing Applicant's Answers to develop additional support fer these facts.

2) Mr. Sherman will testify that Applicar.t has not complied with 10 C.F.R. 50.92, which requires the Applicant to perform a public health risk assessment in conjunction with a request for licensing amendment. Applicant has failed to comply in thet it has not demonstrated that a plant performance design objective of likelihood of core melt less than one in 19,000 per year considering the the probability of both trains being unavailable (without testing the alternate system Page 2

to confirm availability) is 1.2 por year. The NRC-I has stated (NUREG-0880, Revision 1, "Scfety Goals for Nuclear Power Plant Oparation," p.14) its policy goal for plant performance design objective as "The likelihood of a nucicar reacter accident that respits in a large scale core melt should 1

normally bc less than ene in 10,000 per year of reactor operation."

The State is continuing to review Applicant's Answers to the State's Intorrogatories and other information to develop its planned factual and expert testimony. In addition, the State expects to generate additional information during the discovery of'NRC Staff once the Safety Evaluation is issued. If the State decides to call additional f actual or expert wit.nosses or have testimony on other matters, the State will supplement this response to the extent required by 10 C.F.R. 2.740(e)(1).

c. See response to subparagraph a. above.

d. See response to subparagraph b. above.

Richard P. Sedano, being first duly sworn, states that the foregoing answers are true, except insofar as they are based on information that is available to the State of Vermont but not within his personal knowledge, as to which he, based on such Page 3

information, believes them to be true, this ddayofOctober, 1988.

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/ v Richard P. Sedano Then personally apposrod Richard P. Sedaro, before and personally known to me, who being first duly sworn, made oath that the foregoing statement is true, this .? &rX> day of October, 1988.

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Notary Public g (/

My commissio expires: 8//0 /9/

1 STATE OF VE ONT . ,

Of1: (o DS' ?? \H',' # M2 Samuel Press Special Assistant Attorney General Director for Public Advocacy i Vermont Department of Public Service 120 State Street Stato Office Building Mcntpelier, Vermont 05602 (802) 828-2811 Page 4 l

UNITED STATES OF AMERICA ~A NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD '88 PG -1 All :10 Before Administrative Judges ,.; , ,

Charles Bechhoofer, Chairman [ ..

Glenn O. Bright Dr. Je.mos H. Carpenter In the Matter of )

)

VERMONT YANKEE NUCLEAR POWER ) Docket No. 50-271-OLA-2 "

POWER CORPORATION ) (Testing Requirements for

) ECCS and SLC Systems)

(Vermont Yankee Nuclear )

Power Station) )

)

CERTIFICATE OF SERVICC The undersigned certifies that on October 28, 1988, copies of the State of Vermont's Supplemental Response to Vermont Yankee's First Set of Interrogatories and Requests for the Production of f Documents were served on the following parties to this case by first class mails i

I

Charles Bechhoofer, Esq. Chairman l Atomic Safety and Licensing Board Panel -

U.S. Nuclear Regulatory Commission .

Washington, D.C. 20555 l Glenn O. Bright Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. James H. Carpenter Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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Adjudicatory File  ;

l Atomic Safety and Licensing i Board Panel Docket (2 copies) l U.S. Nuclear Regulatory Commission l Washington, D.C. 20555  :

R. K. Gad, III, Esq.

Kathryn A. Selleck, Esq.  !

Ropes & Gray 225 Franklin Street -

Boston, Mass. 02110 l George Dean, Esq.

Assistant Attorney General Commonwealth of Massachusetts  !

Department of the Attorney General f One Ashburnton Place Boston, MA 02108 Ann Hodgdon, Esq. ,

Office of the General Counsel Bethesda  !

U.S. Nuclear Regulatory Commission  :

Washington, D.C. 20555 l

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