ML20215J856
| ML20215J856 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 06/15/1987 |
| From: | Weiss E HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | VERMONT YANKEE NUCLEAR POWER CORP. |
| References | |
| CON-#287-3806 OLA, NUDOCS 8706250133 | |
| Download: ML20215J856 (8) | |
Text
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S hb FELATED CORRESf0ND3t.3 June 15,198700LKETED UbNik UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'g7 JJJj7 p4:42 Before the Atomic Safety and Licensing Board 0FR:..
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- 00CKEig, In the Matter of
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Vermont Yankee Nuclear
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Power Corporation
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Docket No. 5 0-271-O LA
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(Vermont Yankee Nuclear
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Power Station)
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NECNP'S FIRST SET OF IhTERROGATCRIES AND DOCUMENT REQUESTS TO VERMONT YANKEE NUCLEAR POWER CORPORATION 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 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, 8706250133 870615 j
PDR ADOCK 05000271
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PDR y
.. 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, j ournals, orders, confirmations and all other written or graphic materials of any nature whatsoever.
- 2) ~" Identify" with respect to any document shall mean to I
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).
" Identify" with respect to any action or conduct shall mean state the following regarding any such action or conouct:
the person or persons proposing and taking.such action; the date such action was proposed and/or taken; all persons with.knowl' edge or information about such action; the purpose or proposed effect of such action; and any document recording or documenting such action.
4)
" Identify" 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 l
i 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; and the existence and location' of any and all documents relating to such action or matter.
6)
"VY" or " Applicant" shall refer. to the. Vermont Yankee Nuclear Power Corporation.
INTERROGATORIES AND DOCUMENT REQUESTS 1)
VY states that the five (5) methods for increasing on-site storage listed on'page 3 of FVY 86-34 ( Apr. 2 5,1986) were
" considered.".The following questions relate thereto.
a.
Describe in detail the process by which this considera-tion took place.
Fo r instance, was a committee established, an analysis done, a contractor hired, etc.?
Were there meetings',' deliberations, etc.?
During what period of time?
-b.
Provide all documents used in or generated by the pro-j cess of this "consiceration" of alternatives.
c.
Name and identify by job title and address all persons (including contractors) involved in the consideration of' alternatives.
d.
Provide all evaluations, analyses or other documents in the possession of VY, whether or not they were used in VY's consideration of alternatives, relating to the cost, feasibility and/or risk of on-site alternatives to the requested re-racking.
e.
When did VY begin the process of considering how to store fuel assemblies in excess of the current license limit of 2000?
Who was put in charge of this task?
! 1 l
E 2)
Is it VY's position that dry cask storage is not a tech-nically~ feasible n.ethod for spent fuel storage at the VY-s ite?
Provide the reasons for. your answer and any documents or f acts in
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support thereof.
3)
'Is. it VY's position that dry cask storage is too costly a method for spent fuel storage at the VY site?
Provide the rea-sons for your answer and any documents or f acts in support thereof including but not limited to your estimate of the cost.
4)
Is it VY's position that dry cask storage poses safety risks greater than those associated.with VY's proposed action?
. Describe these risks in detail and provide any. supporting docu-i l"
mentation.
5)
Provide all documents in the possession of VY which com-pare'the cost, technical feasibility and/or risks of dry cask storage.to the cost, technical feasibility and/or risks of VY's proposed action.
6)
What is the cost of each of the proposed new racks and how many will be required to completely re-rack the pool to accommodate 2870 spent fuel assemblies?
7) hhat is the cost of removing the racks currently in place?
8)
What is the method and cost of disposal of the racks currently in place?
9)
What is the estimated total radiation dose for removing i
the current racks, installing the new racks and emplacing the spent fuel?
Provide the same information for the alternatives listed on page ;i of FVY 86-34.
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- 10) Is it VY's position that an independent wet storage pool is not a technically feasible method for spent fuel storage at the VY site?- Provide the reasons for your answer and any docu-i ments and facts in support thereof.
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- 11) Is it VY's position that an independent wet storage pool i
1 is too costly a method for spent fuel storage at the VY site?
1 Provide the reasons for your answer and any documents and facts in support thereof, including but not limited to your estimate of the cost.
- 12) Is it VY's position that an independent wet storage pool 1
poses risks greater than those associated with VY's proposed action?
If so, describe those risks in detail and provide any supporting documentation.
- 13) Provide all documents in the possession of VY which com-pare the cost, technical feasibility and/or risks of an inoepen-
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dent wet storage pool to the cost, technical feasibility and/or risks of VY's proposed action.
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- 14) Is it VY's position that independent air-cooled vault i
storage is not a technically feasible method for spent fuel storage at the VY site?
Provide the reasons for your answer and l
any f acts and documents in support thereof.
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- 15) Is it VY's position that independent air-cooled vault storage is too costly a method for spent fuel storage at the VY site?
Provide the reasons for your answer and any facts and doc-uments in support thereof, including but not limited to your estimate of the cost.
.. 16) Is it VY's position that independent air-cooled storage poses risks greater than those associated with VY's proposed
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action?
Describe those risks in detail ano provide any support-
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ing documentation.
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- 17) Provide all documents in the possession of VY. which com-
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pare the cost, technical feasibility and/or risks of independent air-cooled vault storage to the cost,-technical feasibility and/or risks of VY's proposed action.
- 18) Assuming that permission is granted to VY to store up to 2870 spent fuel assemblies-in the current pool:
a) what would l
be the total number of curies in the fuel stored in the pool af ter each refueling from 1987 forward?
b) what percentage of this total curie content after'each~ refueling is cesium?
c) what percentage is strontium?
d) what percentage is plutonium?
- 19) Provide all occuments in possession of VY and not already provided to the parties which contain any evaluation, analysis and/or description of the " safety hazards associated with spent fuel pool expansion" (FVY 86-34 p. 3), and in particu-lar, the VY proposal.
- 20) Provide all documents on which you rely or intend to rely during this proceeding which support VY's position on each of the admitted contentions.
This includes but is not limited to all documents relating to answers to interrogatories and prepara-tion of written presentations.
- 21) Identify by name, job title and address all persons an whose factual knowledge, opinions or expertise you rely or intend to rely for VY's position an each of the admitted contentions.
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. :2 2 ) Identify"by-nang,. job title and address all persons ~ who willfprepare or assist i1 the preparation of.VY's written presentation and oral argument under 10 CFR S 2.1113.
Describe thesubjectmatterof'trleirparticipationanditssubstanceand i
provide the documents;or-portions thereof upon.which they will rely for. factual matter or other support of their. presentations.
t
- 23) Assume.that VY,'ls shut down for refueling,.the spent fuel has been discharger'; and it is within the' period of time that t
one train of the RHR syr; tem is required to augment spent fuel
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pool cooling:
a.
How will VY ast'are adequate cooling of both the core, and the spent-fuel pooh in the event of failure of one RHR' i
s a
train?^ Explain yode answer in detail and provide any docu-6 ments'in support tr areof.
b.
Provide all plapt operating or emergency. procedures which would be used;by the operators should one train of RHR
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fail.
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Respectfully submitted, i
. [- hYA/$$/(C-
.f th l
Ellyn'lR.
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We iss HARMON & WEISS i
2001 "S" Street, N.W.
Suite 430 Kashington, D. C.
20009 f
(202) 328-3500 i
Counsel for NECNP 1
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UNITED STATES OF AMERICA; gggg g :
NUCLEAR REGULATORY COMMISSION Uysf
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'87 JJJ 17 P4 :43 In. the. Ma tter of
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" huh;,,0j[ht Vermont Yankee Nuclear
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. Power Corporation
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Docket No. Sh$7140LAi
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(Vermont Yankee Nuclear
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Power Station)
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CERTIFICATE OF SERVICE The undersigned certifies that on June 15, 1987, "NECNP' S First Set of ' Interrogatories and Document Requests to Vermont Yankee Nuclear Power Corporation" were served by overnight mail to Thomas G.
Dignan and by U.S. mail, first class to the other parties listed below.
Ch arles. Be chhoef e r, Ch airman George Dean, Esq.
Atomic Safety and Licensing Assistant Attorney General Board Panel U.S. Nuclear Commonwealth of Massachusetts hegulatory Commission Department of the Attorney General Washington, D.C.
20555 One Ashburton Place Boston, MA 02108 Glenn O.
Bright Daniel J.
Mullett, Es q.
. Atomic Safety and Licensing Vernont Department of Public Board Panel U.S. Nuclear Service 120 State Street Regulatory Commission Montpelier, VT 05602 Washington, D. C. 20555 Dr. James H. Carpenter Ann Hodgdon, Es q.
Atomic Safety and Licensing Of fice of the General Counsel Board Panel U.S. Nuclear Bethesda U.S. Nuclear Regulatory Regulatory Commission Commission Washington, D. C. 2 0555 Washington, D.C. 2 0555 Secretary of the Commission Diana Sidebotham Attn:
Docketing and Service R.F.D.
- 2 Section U.S. Nuclear Putney, Vermont 05346 Regulatory Commission
. Washington, D.C. 20555 Atomic Saf ety and Licensing Appeal Board Panel U.S. Nuclear Thomas G.
Dignan, Es q.
Regulatory Commission i
Kathryn A. Selleck, Esq.
Washington, D.C. 20555 W
b Frank Street Boston, MA 02110 Ellyn R. Weiss i
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