ML20205N319
| ML20205N319 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 10/31/1988 |
| From: | Ferster A HARMON, CURRAN, SPIELBERG & EISENBERG, LLP., NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | VERMONT YANKEE NUCLEAR POWER CORP. |
| References | |
| CON-#488-7410 OLA, TAC-69179, NUDOCS 8811040054 | |
| Download: ML20205N319 (9) | |
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001.KETED itELATED CORRESPOrdDE/[?H g'fFC 4
UNITED STATES OF AMERICA
'88. my -2 All :54 NUCLEAR REGULATORY 70MMISSION Before the Atomic Safety and Licensing Board { {, }'
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In the Matter of
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Vermont Yankee Nuclear
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Power Corporation
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Docket No. 50-271-OLA
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(Vermont Yankee Nuclear
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Power Station)
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NECNP'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO NRC STAFF,ON THE NRC SPENT FUEL POOL EXPANSION SAFETY EVALUATION (TAC NO, 69179)
INSTRUCTIONS FOR USE The following interrogatories are to be answered in writing and under oath by an employee, representative or agent of the Applicant with personal knowledge of the facts or information requested in each interrogatory.
For each question, please identify by name, job title and address each person who prepared or assisted in preparation of the response.
The following definitions shall apply to these inter-rogatories and document requests:
1)
"Document" shall mean any written or graphic matter of communication, however produced or reproduced, and is intended to i
be comprehensive and include without limitation any and all cor-respondence, letters, telegrams, agreements, notes, contracts, instructions, reports, demands, memoranda, data, schedules, notices, work papers, recordings, whether electronic or by other means, computer data, computer printouts, photographs, microfilm, 8811040054 001031
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. microfiche, charts, analyses, intra-corporate or -intra-office-communications, notebooks, diaries, sketches, diagrams, forms, manuals, brochures, lists, publications, drafts, telephone minutes, minutes of meetings, statements, calendars, journals, orders, confirmations and all other written or graphic materials of any nature whatsoever.
2)
"Identifv" with respect to any document shall mean to state the following:
the document's title, its date, the author of the document, the person to whom to document was sent, all persons who received or reviewed the document, the substance and nature of the document, and the present custodian of the document and of any and all copies of the document.
3)
"Identifv" with respect to any action or conduct shall mean state the following regarding any such action or conduct:
the person or persons proposing and taking such action; the date l
such action was proposed and/or taken; all persons with knowledge or information about such action; the purpose or proposed effect of such action; and any document recording or documenting such action.
4)
"Identifv" with respect to an individual shall mean state the individual's name, address, employer, occupation, and title.
5)
"Describe" with respect to any action or matter shall mean state the following regarding such action or matter:
the substance or nature of such action or matter; the persons partic-ipating in or having knowledge of such action or matter; the cur-rent and past business positions and addresses of such persons;
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. and the existence and location of any and all documents relating to such action or matter.
6)
"VY" or "Acolicant" shall refer to the Vermont Yankee Nuclear Power Corporation.
7)
"Staff" shall refer to all persons employed by.the NRC at headquarters or regional offices, as well as contractors hired by NRC.
8)
"SER or Safety Evaluation" shall refer to the "Safety Evaluation by the Office of Nuclear Reactor Regulation Supporting the Spent Fuel Pool Expansion - Vermont Yankee Power Station (TAC i
No. 69179), issued on October 14, 1988.
INTERRCGATORIES AND DOCUMENT REQUESTS 1)
Please identify all persons who participated in the preparation of answers to these interrogatories, and identify the portions of your response to which each person contributed.
2)
Is it the Staff's position that a License Amendment will be required before Vermont Yankee may be permitted to install, test, or make operational the enhanced Spent Fuel Pool Cooling System proposed by Vermont Yankee in its letter dated June 7, 1988?
Explain why or why not, and cite the regulatory j
basis or authority for this position.
3)
Is it the Staff's position that a License Amendment will be required before Vermont Yankee may store more than 2,000 spent fuel assemblies in the Vermont spent fuel pool?
Explain uhy or why not, and cite the regulatory basis or authority for j
this position.
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. 4)
The SER (page 38), states that the number of. spent fuel assemblies may "not exceed 2000 until the enhanced system as described in the licensee's June 7, 1988 submittal has been installed and tested to demonstrate operability."
The following
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questions relate thereto:
a.
Describe what documents the Staff will review to determine that this enhanced system is operable,. including but not limited to piping and instrumentation diagrams, electrical drawings, line or isometric drawings, schematics, inspection reports, etc.
b.
Describe what Vermont Yankee must do to test this enhanced system to demonstrate operability,.and identify all general design critoria, design bases, regulatory guides, provisions of the currsnt standard review plan, or other NRC Staff positions, or engineering judgment will be applied in testing the enhanced system to demonstrate operability.
c.
Describe what general design criteria, design bases, regulatory guides, provisions of the current standard review plan, or other NRC Staff positions, or engineering judgment will be applied in datormining that the enhanced system has demonstrated operability, d.
State whether the Staff has required or will require the Licensco to submit any schedule, milestones, or other estimato for the longth of timo it will take to install and i
test this enhanced system.
If yes, identify and provido 4
copies of any documents describing such a schedule or time I
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5-estimate, or requesting that such a schedule or time estimate Le submitted.
e.
State whether the Staff has required or will require the Licensee to comply with any schedule, milestone, or time frame for installation and testing of this enhanced system.
If yes, identify and provido copies of any documents des-cribing such a schedule or time estimate, or requesting that such a schedule or time estimate be submitted.
5)
State whether the. current Stand.ard Review Plan (NUREG-0800) provisions regarding the' single failure criterion. apply to Vermont Yankee spent fuel pool cooling system.
If yes, answer the following questions.
a.
Does this constitute a current definition of what is required in order to satisfy the single failure criterion?
b.
Are those provisions currently being met by Vermont Yankee?
c.
If those provisions regarding single failure criterion are not being mot, explain why not.
d.
Describo what actions the NRC intends tc take or pro-coedings the NRC will initiate to ensure that Vermont Yankeo does not operato out of compliance with the single failuro critorion now and prior to the time when the enhanced spent fuel pool cooling system is installed and testod to demonstrato operability.
If none, explain why.
i 6)
The SER (page 18-20), states that "there has boon a concern expressed that a sovoro reactor accident could lead to loss of water from the spent fuel pool", and suggests that ado-I
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. quate cot'rective action could be taken in this event "to maintain individual occupational radiation exposures within the applicable limits..."
The following questions relate thereto:
a.
Please identify and describe in detail the equipment, safety systems, and procedures comprising Vermont Yankee's "defense in depth concept," for adequate early warning of any accident or abnormal occurrence, including a loss of cooling to the spent fuel pool.
Provide all documents, reports, studies on which you relied in reaching this con-clusion or which support this statement.
b.
Please identify and describe in detail the equipment, safety systems, and procedures comprising Vermont Yankee's "defense in depth concept" for taking adequate subsequent protective actions in response to any accident or abnormal occurrence, including a loss of cooling to the spent fuel pool.
Provido all documents, reports, studies on which you rolled in reaching this conclusion or which support this statement.
c.
Please identify and provido copies of all NRC documents describing the amorgency proceduros, regulatory guidance, Standard Review Plans, NRC Staff Positions, or other critoria for providing early warning of any accident or abnormal occurrenco, including a loss of cooling to the spent fuel pool.
d.
Please identify and provido copios of all NRC docur.onts describing the emergency procedures, regulatory guidance, Standard Review Plans, NRC Staff Positions, or other
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. criteria for taking adequate subsequent protective actions in response to any accident or abnormal occurrence, includ-ing a loss of cooling to the spent fuel pool.
e.
Please identify the persons or groups who raised this concern that "a severe reactor accident could lead to loss of water from the spent fuel pool", and identify and provide copies of all documents, studies, and reports raising and responding to this concern.
Respectfully submitted Andrea Ferster MARMON, CURRAN & TOUSLEY 2001 "S" Street N.W. Suite 430 Washington, D.C.
20009 (202) 328-3500
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CERTIFICATE OF SERVICE I certify that on October 31, 1988, copies of*8$htpfogeg$
pleading were served by first-class mail, or as otherwise 1851 cated, on all parties listed below.
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Charles Bechhoefer, Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Glenn O.
Bright Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. James H. Carpenter
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Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Socratary of the Commission Attn:
Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Christine N. Kohl, Chairman j
Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 j
George Dean, Esq.
Assistant Attorney General Commonwealth of Massachusetts l
Department of the Attorney General One Ashburton Placo I
I Boston, MA 02108 David Mullet, Esq.
Vormont Dopartment of Public Sorvico 120 State Street Montpelier, VT 05602 Ann Hodgdon, Esq.*
Offico of the Gonoral Counsel Bothesda U.S. Nuclear Regulatory Commiusion Washington, D.C.
20555 Diana Sidebotham R.F.D.
- 2 Putnoy, Vermont 05346 R.K. Gad III
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9-Ropes & Gray 225 Franklin Street Boston, MA 02110 Gary J.
Edles Atomic Safety and Licensing Appeal Board I
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Howard A. Wilber Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Geoffrey M. Huntington, Esq.
Office of the Attorney General Environmental Protection Agency State House Annex 25 Capitol Street Concord, NH 03301-6397 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Andrea Ferster By FAX I
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