ML20235J027

Licensee First Set of Interrogatories & Request for Production of Documents to State of Vt.* Info Re RHR Sys, Spent Fuel Pool & Accident Scenario Requested.W/Certificate of Svc.Related Correspondence

ML20235J027
Person / Time
Site:	Vermont Yankee
Issue date:	07/09/1987
From:	Selleck K ROPES & GRAY, VERMONT YANKEE NUCLEAR POWER CORP.
To:	Atomic Safety and Licensing Board Panel
References
CON-#387-4017 OLA, NUDOCS 8707150368
Download: ML20235J027 (6)

Text

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uG, lYi:iin USN!< c Dated: July 9, 1987 87 JM.13 R2:14 UNITED STATES OF AMERICA hf im 1, ;

NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

)

VERMONT YANKEE NUCLEAR ) Docket No. 50-271-OLA

. POWER CORPORATION ) (Spent Fuel Pool

) Amendment)

(Vermont Yankee Nuclear )

Power Station) )

_ )

LICENSEE'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO STATE OF VERMONT Pursuant to 10 C.F.R. 69 2.715(c), 2.740(b) and 2.741, Licensee requests that the attached Interrogatories be answered fully in writing and under oath by an agent or official of State of Vermont (Vermont) who has personal knowledge thereof. The answer to each Interrogatory should contain the name and identification of the person supplying the answer and whether or not he or she has verified the answer.

As used herein, the term " document" or " documents" means all tangible things, whether handwritten, typed, printed, or otherwise produced and all non-identical copies thereof in the poasession, custody, or control of Vermont including, but not limited to, communications, correspondence, notes, field notes, work sheets, survey instruments, models, disks, tapes, s tudie s ,' reports, summaries, instructions, charts, schedules, photos,. sketches and drawings, maps, records, accounts and accounting records, opinions, machine readible records and computer translations, and reports of consultants.

8707250368 G70709

{DR ADOCK 05000272 PDR 60

4 As used herein, the term " identify" means:

1. In the case of a natural person:

(a) name; ,

(b) last known address; J (c) employer or business affiliation; and (d) occupation and business position held.

2. In the case of a document: 4 (a) identity of the person or persons preparing it; (b) its title or a description of the general nature of the subject matter; (c) the identity of the addressee; (d) date of preparation; (e) identity of persons who can identify it; and (f) all of the aforementioned information should be supplied with such reasonable particularity sufficient to permit a specific demand for its production. In lieu of the foregoing, a copy of the document may be supplied.

3. In the case of oral statements and communications:

(a) when and where they were made; (b) identity of each of the makers and recipients thereof; (c) the medium of communication; and (d) substance of the statement and/or communication.

Pursuant to 10 C.F.R. 6 2.740(e), responses should be supplemented under circumstances when new or different information becomes available. If Vermont cannot answer the Interrogatories in full, it shall so state and indicate when it expects to be able to answer in full to the Interrogatory.

If a privilege or work product immunity is asserted as a ground for not producing any document, state for each such document its preparation date, author (s), addressee (s),

title (s), pages, recipient (s), custodian, and subject matter to the extent not privileged, as well as the basis for withholding it.

l INTERROGATORY NO. 1 )

Identify all evaluations, analyses or other documents that support or relate the statement: "the RHR system will have to be used to a greater extent than previously."

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-INTERROGATORY No. 2 Identify all documents that support or' relate to the assumption that the RER system is required to augment the

' Spent Fuel. Pool Cooling System or that the RHR system is necessary to cool both the core and the. fuel pool during a refueling outage.

INTERROGATORY NO. 3 Identify all documents that support or relate to the basis for maintaining the spent fuel pool water temperature of 140'F.

INTERROGATORY NO. 4  !

Identify all documents on which each contention you intend to litigate is based.

INTERROGATORY NO. 5 Describe the complete accident scenario from which you postulate hydrogen detonation and subsequent radioactive rele-ase. Identify all technical information used which supports.the possibility of a hydrogen leak. . Identify all sources of such information, both persons and documents.

INTERROGATORY NO. 6 Identify all documents that relate to any evaluation of VY in connection with the hypothesized accident (hydrogen detonation in the Reactor Building).

INTERROGATORY NO. 7 s Identify all documents which define and support the safety advantages of alternatives to increasing the storage capacity of the spent fuel pool.

INTERROGATORY NO. 8 Identify all documents on which you rely or may rely or will rely to support your position on cach of the admitted contentions.

INTERROGATORY NO. 9 ,

Identify all persons on whose factual knowledge, opinion or expertise you rely or may or will rely for your position on each of the admitted contentions.

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o INTERROGATORY NO. 10 Identify persons who will prepare or assist in the preparation of your written presentation and oral argument under.10 CFR 2.1113.. Describe the subject matter _of their presentation and its substance and provide the documents or portions thereof upon which they rely or will rely.

DOCUMENT REQUEST Licensee' requests that Vermont, pursuant to 10 C.F.R.

$ 2.741, provide copies of or make available for inspection and copying at a designated time and place the documents identified by Vermont in response to the. foregoing Interrogatories.

By its attorneys,

. IML thopa#'C. Dignan, Jr.

Ka Gryn A. Selleck Ropes & Gray

• 225 Franklin Street Boston, MA 02110 (617) 423-6100 1

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1 bO[Silf I uWr' 87 JJL 13- Pl2:14 CERTIFICATE OF SERVICE I, Kathryn A. Selleck, hereby certify that on $y p.6 y$9M '

1987, I made service of the within document in accordan'ce. 'j WI wi'th the rules of the Commission by mailing a copy thereof postage prepaid;to the following:

Charles Bechhoefer, Esquire, David J.. Mullet,-Ecquire Chairman Vermont Department of Administrative Judge .Public Service Atomic Safety and Licensing 120 State 'treet S

Board Panel Montpelier, VT 05602 U.S. Nuclear Regulatory 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 Straet, N.W.

U.S. Nuclear Regulatory Washington, IX3 20009 Commission Washington, DC 20555 Mr. James H. Carpenter George B. Dean, Esguire Administrative Judge Assistant Attorney General Atomic' Safety and Licensing . Department of the Attorney General Board Panel One Ashburton Place U.S.-Nuclear Regulatory Boston, MA 02108 Commission Washington, DC 20055 Atomic' Safety and Licensing Ann P. Hodgdon, Esquire Board Panel Office of the General Counsel U.S. Nuclear Regulatory U.S. Nuclear Regulatory

. Commission Commission Washington, DC 20555 Washington, DC 20555 Atomic Safety and Licensing Appeal Board Panel U.G. Nuclear Regulatory Commission Washington, DC 20555

f.

Geoffrey M. Huntington, Esquire office of the Attorney General Environmental Protection Bureau State House Annex 25 Capitol Street Concord, NH 033014 6397

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