ML20236N814
| ML20236N814 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 07/28/1987 |
| From: | Dean G MASSACHUSETTS, COMMONWEALTH OF |
| To: | VERMONT YANKEE NUCLEAR POWER CORP. |
| References | |
| CON-#387-4155 OLA, NUDOCS 8708120118 | |
| Download: ML20236N814 (8) | |
Text
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-3 P3 :02 UNITED STATES OF AMERICA NUCLEAR REGULATORY' COMMISSION hh 9
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)
)
)
COMMONWEALTH OF MASSACHUSETTS' RESPONSES TO LICENSEE'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS GENERAL OBJECTION:
The Commonwealth objects to the Applicant's discovery.
on the basis that the rules of practice for the NRC do not provide for discovery on an Interested State.
Without waiving this objection, the Commonwealth is voluntarily providing the following responses.
INTERROGATORY NO. 1 Identify all evaluations, analyses or other documents that support or relate to the statement:
"the RHR system will have to be used to a greater extent than previously."
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7 RESPONSE:-
The following documents have'been identified to date:
- 1.. Vermont Yankee Spent Fuel ~ Storage Rack Replacement Report, April, 1986.
2.-
Vermont Yankee Response to Request for Additional Information - Proposed Change No. 133, Spent Fuel Pool Expansion, Nov. 21, 1986.
l 3.-
. Vermont Yankee. Response to Response for Additional Information Proposed Change No. 133, Spent Fuel Pool Expansion, March 19, 1987, and references therein.
4.
NRC Staff's Brief.in. Opposition to the Brief of Applicant (this docket), June 25, 1987 and attached Affidavit o'f. J o h n :1. Ridgeley.
5..
Safety Evaluation by the Office of Nuclear. Reactor Regulation Relating to a Modification to the Spent Fuel Pool for Facility Operating License No. DPR-28, Vermont Yankee Nuclear Power Corporation, Vermont Yankee Nuclear Power l
Station, Docket No. 50-271, June 10, 1977.
l 6.
Id.,
Supplement 1,-June 10, 1977.
7.
Letter from-D.E. Vandenburg, (Vice President, Vermont Yankee) to NRC, Nov.
5, 1976, cited at ALAB-869, Sl.Op. at 5.
8.
References given at ALAB-869, Sl.Op. at 5-8,' July 21, 1987.
INTERROGATORY NO.2 Identify all documents that support or relate to the assumption that the RHR system is required to augment the Spent,
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Fuel Pool' Cooling System or that the RdR system is necessary to cool both the core and the fuel pool during a refueling outage.
Response
The documents responsive to this request tnat have been identified to date are those numbered 1, 2,
3, 4,
8.
INT 8RROGATORY NO. 3 Identify all document that support or relate to the oasis for maintaining tne spent fuel pool water temperature of 140 F.
Response
The documents identified to date are the Standard Review Plan for the Review of Safety Analysis Reports, NUREG-75/087.,
S 9.13 and its later versions.
INTERROGATORY NO. 4 Identify all documents on which each contention you intend to litigate is cased.
Response
All documents thus far identified as responsive to tais request (as it relates to contention 1) have oeen identified in the above r(sponses.
INTERROGATORY NO. 5 Describe the complete accident scenario from anich you postulate hydrogen detonation and subsequent radioactive release.
Identify all technical information used which supports the possibility of a hydrogen leak.
Identify all sources of such information, ooth persons and documents.
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' Response:
The Commonwealth.of Massachusetts objects to Interrogatory No. 5 on the grounds that the.information sought'is not relevant to this proceeding in light of the Appeal Board's decision in Vermont Yankee-Nuclear Power Corporation-(Vermont l
Yankee Nuclear Power Station), ALAB-869, 26 NRC (July 21,
~1987)..
INTERROGATORY NO. 6 i
Identify.all documents that relate to any evaluation of.VY in connection with the hypothesized accident (hydrogen
- detonation in the Reactor Building).
Response
The Commonwealth of Massachusetts objects to Interrogatory No. 6 on the grounds.that the information sought is not relevant to this proceeding in light of the Appeal Board's decision.in Vermont Yankee Nuclear Power Corporation (Vermont Yankee Nuclear Power Station), ALAB-869, 26 NRC (July 21, 1987).
INTERROGATORY NO. 7
. Identify all documents which define and support the safety advantages of alternatives to increasing the storage capacity of the spent fuel pool.
Response
The' Commonwealth of Massachusetts oo]ects to Interrogatory No.-7 on the. grounds that the information sought is not relevant to this proceeding in lignt of the Appeal Board's j
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decision in Vermont Yankee Nuclear Power Corporation (Vermont Yankee Nuclear Power Station), ALAB-869, 26 NRC (July 21, 1987).
INTERROGATORY NO. 8 Identify all documents on which you rely or may rely or will rely to support your position on each of the admitted contentions.
Response
All documents thus far identified which are responsive to this request (as it relates to Contention 1) have been identified in the above responses.
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.
Response
The Commonwealth is not able to identify all persons on which it may or will rely.
The Commonwealth nas relied on Stephen Sholly.
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.
Descrioe tne suo]ect matter of tneir presentati~on and its substance and provide the documents or portions thereof upon which they rely or will rely.
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' Response:
bo The Commonwealth has not.yet determined.who it will use.as an expert witness;in this proceeding.
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' Document Response:
See' responses to Interrogatories set forth above.
' Respectfully submitted,
-(
JAMES M. SHANNON 1,1 L
Attorney General I
Commonweal _th M MA.ssaChusetts s,
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W By d.NhbgeWn V Lf a
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John Iraficonte Assistant Attorneys' General Nuclear' Safety Onit Department of.the Attorney One Ashburton Place, Room 1902 Boston, MA 02108-1698 (617) 727-1083 Dated:
July 28, 1987 e
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D OC YE Tll mn UNITED STATES OF AMERICA
'87 AUS -3 P3 :02 NUCLEAR'REGULATodY COMMISSION Ui! -
Defore the
[hk['iU ATOMIC SAFETY AND LICENSING BOARD
~/
)
In the Matter of
)
)
VERMONT YANKEE NUCLEAR
)
Docket No. 50-271-OLA POWER CORPORATION
)
)
(Vermont Yankee Nuclear
)
Power Station)
)
)
CERTIFICATE OF SERVICE I, George Dean, hereby certify that on July 28, 1987 I made service of the within document, by mailing copies thereof, postage prepaid, by first class mail to:
Charles Bechhoefer, Chairman Atomic Safet'y 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 Atomic Safety and Licensing Board Panel U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 l
s Secretary of the Commission Atta:
Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Christine N. Kohl, Chairman l
Atomic Safety and Licensing Appeal Bodrd U S. Nuclear Regulatory Commission Washington, D.C.
20555 Daniel J.
Mullett, Esq.
Vermont Department of Puolic Service 120 State Street Montpelier, VT 05602 Ann Hodgd9n, Esq.
Office of the General Counsel Bethesda U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Diana Sidebotham R.F.D.
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Putney, VT 05346 Thomas G. Dignan, Esq.
Ropes & Gray 225 Franklin Street Boston, MA 02110 Gary J.
Edles Atomic Safety and Licensing Appeal Board U.S.
Nuclear Regulatory Commission Washington, D.C.
20535 Geoffrey M.
Huntington, Esq.
Office of the Attorney General Environmental Protection Agency State House Annex 1
25 Capitol Street Concord, NH 03301-6397
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Assistant Attorney General duelear Safety Unit (617) 727-1083 Dated:
July 28, 1987.
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