ML20012F679

Interrogatories Propounded by Vermont Yankee Nuclear Power Corp to State of VT (Set 2).* W/Certificate of Svc.Related Correspondence

ML20012F679
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	04/05/1990
From:	Gad R ROPES & GRAY, VERMONT YANKEE NUCLEAR POWER CORP.
To:	VERMONT, STATE OF
References
CON-#290-10211 OLA-4, NUDOCS 9004200081
Download: ML20012F679 (28)

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i- tOttlIED l-Rft.ATED CORRESP0tOENCE UWiG UNITED STATES OF AMERICA g 9 p)gg i

L NUCLEAR REGULATORY COMMISSION before the BriICr or $[CRIiMY h0Chih% A (CRVIU.

iikANCH ATOMIC SAFETY AND LICENS!NG BOARD i

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In the Matter of ) L'

) Docket No. 50 271 OLA-4 l

VERMONT YANKEE NUCLEAR ) (Construction Period '

POWER CORPORATION ) Recapture)

)  :

(Vermont Yankee Nuclear )  ;

Power Station) ) l l

INTERROGATORIES PROPOUNDED BY f VERMONT YANKEE NUCLEAR POWER CORPORATION  ;

TO THE ,

STATE OF YERMONT >

(Set No. 2)

Pursuant to 10 C.F.R. ) 2.740b, Vermont Yankee Nuclear Power Corpora- l tion hereby propounds the following interrogatories to the State of Vermont.

As used in these interrogatories, VYNPC mear.s Vermont Yankee Nuclear

• Power Corporation: YYNPS means Vermont Yankee Nuclear Power Station:  ;

SOY means the State of Vermont, including the agencies, officers, employees, i and agents thereof and further including contractors or consultants thereto, ,

As used in these interro latories, the term document has the same meaning l as it does in Fed. R. Civ. P. 34(a). l As used in these interrogatories, the term

• identify" with respect to a j person means to supply the name, current business or residential address and l telephone nurnber of the person, and to state the relationship, if any, of the  !

puson to SOV. l As used in these interrogatories, the term ' identify" with reference to a document means to provide such identifying information as the title or other  ;

name of the document, the author or authors of the document, the date of the

! document, and to state whether or not the document, or a copy thereof, is within the possession, custody or control of SOV.

9004200001 900405 PDR ADOCK 05000271 0 PDR  ;

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Your attention is called to the provisions of 10 C.F.R. i 2.740(e) regarding the duty of supplementation with respect to answers to interrogatories.

1. Please define what SOY contends is included within the scope of the term

• maintenance program" as used by it in its Contention 7,

2. Does SOY contend that NRC imposes any requirements upon the con-tent, substance or form of the YYNPS ' maintenance program" as that term is used by SOY in its Contention 77 If so, plente identify, by citation to or identification of a document, each and every such requirement.

3. Please define what SOY contends is included within the scope of the term ' surveillance program" as used by it in its Contention 7.

4 Does SOY contend that NRC imposes any requirements upon the con.

tent, substance or form of the VYNPS ' surveillance program" as that term is used by SOY in its Contention 77 If so, please identify, by citation to or identification of a document, each and every such requirement.

$. Does SOY contend that NRC imposes any requirements upon the con-tent, substance or form of the YYNPS ' program to maintain and/or determine and replace all components found to have aged to a point where they no longer rriet the anfety standards applicable to this plant" as that term is used by SOY in its Contention 77 If so, please identify, by citation to or identification of a document, each and every such requirement.

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6. Please list and describe in as much detail as is available to SOY cach of the changes to the YYNPC maintenance program, surveillance l program, or other program that, if made to the programs, would l render SOV's Contention 7 satisfied. i

7. Please define the failure mechanisms that SOY contends are within the  !

scope of the phrase 'found to have aged to a point where they no j longer meet the safety standards applicable to this plant" as this phrase j is used by it in its Contention 7.

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8. Please identify the components or classes of components that SOY l' contends are potentially subject to each of the failure mechanisms that SOY contends is within the scope of the phrase *found to have aged  !

to a point where they no longer meet the safety standards applienble  !

to this plant" as phrase is used by it in its Contention 7.  !

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9. Pleue define the measure of 'sufficiently effective" as the term is used by SOY in its Contention 7.

10. Please identify or describe all of the bases for the definition supplied in response to the foregoing interrogatory.

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11. Please define the measure of 'sufficiently . . . comprehensive" at the term is used by SOY in its Contention 7.

12. Please identify or describe all of the bases for the definition supplied in response to the foregoing interrogatory.

13. Does SOY contend that the VYNPS maintenance program is not in compliance with all applicable NRC requirement?

14. If your response to the foregoing interrogatory is anything other than an unqualified negative, please identify, by citation to or identifica.

tion of a document,each and every such requirement with which SOY contends th: VYNPS maintenance program is not in compliance, and, for each such requirement, each and every reason why SOY contends that the YYNPS maintensnee program is not in compliance with it.

15. Does SOY contend that the VYNPS surveillance program is not in compliance with eny applicable NRC requirement?

16. If your response to the foregoing interrogatory is anything other than an unqualified negative, please identify, by citation to or identifica.

tion of a document, each and every such requirement with which SOY contends the YYNPS surveillance program is not in compliance, and, fer each such requirement, each and every reason why SOV contends that the VYNPS surveillance program is not in compliance with it.

17. Please describe what SOY means by the phrase 'no closure showing improvement" as used by it in sub-paragraph *b." of its Contention 7.

18. Please describe the set of items, events or circumstances that would constitute ' closure showing improvement" within the meaning of sub-paragraph *b." of Contention 7 such thut, were any such item, event or circumstance to occur or exist, sub-paragraph *b.* would no longer be true.

19. If the NRC Staff were to publish a document or make a finding to the effect that any item described by it in an Inspection Report ('IR *)is 3

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l I now closed, would SOY acknowledge that such publication or finding constitutes ' closure' as that term is used by SOY in sub paragraph *b.*

r of its Contention 7 of the item in respect of which the publication or l finding were made?

20. If your response to the foregoing interrogatory is anything other than an unqualified affirmative, please describe all of the reasons why such ,

a publication or finding would not constitute ' closure.'

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21. Please identify each of the issues adverted to in Contention 7, inctudin g su b paragraphs 'b.', 'c.', 'd.', 'e.', 's.", 'h.(l)", 'h.(2)", 'j.', i

• k.', 'm.', and 'n.' thereof and sub paragraphs 't.*, 'n.' and 'o.' of Contention 8, that SOY acknowledges have been " closed" as of the date l on which your answers to these interrogatories are liled. <

22. Does SOY contend that all vendor-recommended preventative main-  :

tenance must be performed in order for the YYNPS maintenance f program to be adequate to prevent aging failures? Please give all the reasons for your answer and, if your answer is qualified, all of the qualificatiors applicable to YYNPS and the reasons for them. l

23. Please describe exactly how SOY contends that post maintenance I testing must be incorporated into the maintenance procedures in order for the procedures to be adequate.

24. If SOY contends that post maintenance testing must be proceduralized ,

in order for the maintenance program to be adequate, please describe the steps that SOY contends must be included in the procedures for  ;

insuring that post maintenance testing is comprehensive enough for a given maintenance task. ,

25. Please describe what SOY means by its assertion that 'PRA concept not incorporated into Vermont Yankee maintenance program" at page j 43 of its contentions.

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26. Please describe in detail exactly how SOY contends that 'PRA concept" should be ' incorporated

• into the VYNPS maintenance proEram.

27. Please state your basis for, and each authority on which you rely in I support of, your response to the foregoing interrogatory.

28. Please identify each and every benefit that SOY contends would result from the ' incorporation" of 'PRA concept" into the VYNPS main.

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tenance program, and pleue state each and every renon why SOY L

- contends that such benefit would result. l

29. Does SOY contend that its userted non incorporation of 'PRA  !

concept

• renders the VYNPS maintenance progrt,m, or the operation l of YYNPS, in any respect not in compliance with any regulatory (

requirement of the Commission? [

t i 30. If your answer to Interrogatory No. 29 is anything other than an '

unqualified negative, pleue state each and every regulatory require. [

ment of the Commission with which SOY contends VYNPS is not in  !

compliance on sceount of the non incorporation of 'PRA concept * [

into the YYNPS maintenance program.

31. What significance, if any, to the question of whether the 'incorpor. i ation* of'PRA concept"into a maintenance program is necessary to i the permissibility of plant operation does SOY attribute to the fact  ;

that the Commission has declined to impose such a requirement  ;

through the promulgation of a regulation? Please state in detail the l bases for your response. l

32. How, if at all, does SOY contend that the ' incorporation" of 'PRA [

concept" into the VYNPS maintenance program would modify the i safety margins established by the existing YYNPS Technical '

Specifications?

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33. Please define what is meant by SOY by the term ' qualified repince. .

ment personnel" as it is used by SOY in sub paragraph "c" of its  !

Contention 7.

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34. Please define what is meant by SOY by the term

• clearly established l management controls" as it is used by SOY in sub-paragraph *c" of its  !

Contention 7. i 3$. Please identify the author (or authors) of the work dated October 9, l 1989, to which SOY refers in sub paragraph "c." of its Contention 7. 1 i

36. Please describe the qualifications of the author (or authors) of the work dated October 9,1989, to which SOY refers in sub-paragraph -

'c

• of its Contention 7. 1

37. Please describe the data, investigations and analytical or investigative processes upon which the conclusions of the author (or authors) of the i

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i l work dated October 9,1989, to which SOY refers in sub paragraph

'c ' of its Contention 7 were based,

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38. Has SOY takrn any step to verify independently any of the opinions l

or conclusions of the author (or authors) of the work dated October 9.1989, to which SOY refers in sub paragraph 'c.' of its Contention 77

(. 39. Does SOY contend tht t a maintenance program

• based on the stability of maintenancs staff, their skill in their professions, and their knowledge of plant syttem characteristics that come with long term experience' wil always be incapable of achieving the purposes of a maintenance praram?

40. If your answer to the foregoing interrogatory is anything other than an unqualified affirmative, please state the conditions under which SOY acknowledges that a maintenance program ' based on the stability of maintenance staff, their skill in their professions, and their knowledge of plant system characteristics that come with long term experience"can be capable of achieving the purposes of a maintenance program?

41. Does SOY agree without qualification with the following statement:

'The standard for the quality of maintenance work at YYNPC is high and this standard is reflected in a relatively low rework rate for maintenance and repairs on plant systems.'

if your answer is anything other than an unqualified affirmative, then please:

a. State each and every qualification you have with respect to the quoted assertion.

b. State each and every fact on which your qualification is based,

c. Describe all of the evidence in SOV's possession or of which SOY has knowledge that SOY contends establishes each such fact.

d. For each qualification, either provide the technical qualifica-tions (education, employment history. licenses and certificates,

! experience, or other information which SOY contends est-6-

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o ablishes the qualifications of the person), of any person on i whose expertise SOY relies for the qualification or state that SOY does not rely upon the capertise of any person for the  ;

qualification. '

l if SOY agrees with the substance of the foregoing assessment, then u please:

e. State each and every reuon why SOY believes that the ,

situation described therein has come to exist. [

f. State each and every reason why, assuming the rejection of this contention, the SOY contends (if it does) that the same  ;

condition might not be expected to continue through the '

balance of the existing YYNPS license term.  ;

g. State each and every renon why, assuming the rejection of this contention, the SOY contends (if it does) that the same condition might not be expected to continue through the balance of the extended VYNPS license term,

42. Does SOY agree without qualification with the following statement:

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'The overall Vermont Yankee management i support at the corporate and plant levels for i maintertance is strong and effective?

If your answer is anything other than an unqualified affirmative, then please:

a. State each and every qualification you have with respect to the l quotec assertion.  :

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b. State each and every fact on which your qualificatio.:is based.

c. Describe all of the evidence in SOV's possession or of which SOY has knowledge that SOY contends establishes each such fact.

d. For each qualification, either provide the technical qualifica- i tions (education, employment history, licenses and certificates, i experience, or other information which SOV contends est- i ablishes the qualifications of the person), of any person on r whose expertise SOY relles for the qualification or state that

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SOY does not rely upon the expertise of any person for the '

i qualification.  !

If SOY agrees with the substance of the foregoing assessment, then i pleue:

e. State each and every repon why SOY believes that the i situation described thettin has come to esist, e

f. State each and every renon why, usuming the rejection of i this contention, the SOY contends (if it does) that the same i condition might not be expected to continue through the balance of the existing YYNPS license term.  ;

g. State each and every reason why, assuming the rejection of this contention, the SOY contends (if it does) that the same  ;

condition might not be expected to continue through the i balance of the extended YYNPS license term.

4. Does SOY agree without qualification with the following statement:

f

'VYNPS's informal management oversight and  !

feedback system works well to assure safe and  !

reliable plant operations.'

if your answer is anything other than an unqualified affirmative, then -

please:

a. State each and every qualification you have with respect to the  ;

quoted asscrtion.

b. State each and every fact on which your qualification is based.

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c. Describe all of the evidence in SOV's possession or of which SOY has knowledge that SOY contends establishes each such  !

fact.

d. For each qualification, either provide the technical qualifica- l tions (education, employment history, licenses and certificates, 4

experience, or other information which SOY contends est- l ablishes the qualifications of the person), of any person on ,

whose expertise SOY relles for the qualification or state that l SOY does not rely upon the expertise of any person for the qualification.

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if SOY agrees with the substance of the foregoing assessment, then pleue:

[ e. State each and every reuon why SOY believes that the situation described therein has come to exist, i f. State each and every renon why, usuming the rejection of l this contention, the SOY contends (if it does) that the same condition might not be expected to continue through the i balance of the existing YYNPS license term.

g. State each and every reason why, assuming the rejection of this contention, the SOY contends (if it does) that the same condition might not be expected to contiriue through the balance of the extended VYNPS license term.

44. Does SOY agree without qualification with the following statement:

'YYNPC has implemented a maintenance program adequate to provide resonable as-surance that YYNPC can and will be operated without endangering the health and safety of the public.'

If your answer is anything other than an ,inqualified affirmative, then plesse;

a. State each and every qualification you have with respect to the quoted assertion,

b. State each and every fact on which your qualification is based,

c. Describe all of the evidence in SOV's possession or of which SOY haa knowledge that SOY contends establishes each such fact.

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d. For each qualification, either provide the technical qualifica-tions (education, employment history, licenses and certificates, experience, or other information which SOY contends est-ablishes the qualifications of the person), of any person on j whose expertise SOY relies for the qualification or state that SOY does not rely upon the expertise of any person for the qualification.

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f If SOY agrees with the substance of the foregoing assessment, then please:

e. State each and every reason why SOY believes that the situation described therein has come to exist,

f. State each and every reason why, saauming the rejection of this contention, the SOY contends (if it d0es) that the same condition might not be expected to continue through the balance of the existing YYNPS license term,

g. State each and every reason why, assuming the rejection of this contention 2 the SOY contends (if it does) that the same condition might not be expected to continue through the balance of the extended YYNPS license term.

45. Please define the term ' age related problem" as it is used by SOY in sub paragraph 'd? of Contention 7.

! 46. Please define the term ' timely fashion" as it is used by SOY in sub-paragraph *d? of Contention 7.

47, Does SOY contend that there is an applicable NRC requirement specifying the maximum emount of time within which YYNPC must perform a ' review (of) the appropriateness and technical adequacy of completed maintenance activities?' If so, please identify, by citation to or identification of a document, each and every such requirement.

48. Does SOY contend that, without regard to any applicable NRC requirement, there is a maximum amount of time within which YYNPC must perform a

• review (of] the appropriateness and technical adequacy of completed maintenance activities?'

49. Unless your answer to the foregoing interrogatory is an unqualified negative, please identify what SOY contends is such maximum amount of time and provide each and every reason why SOY contends that its time is the maximum allowable.

50. Please identify each and every instance of which SOY is aware in which, after the maintenance or repair of a component, the lack or untimeliness of a ' review [of) the appropriateness and technical adequacy of completed maintenance activities" subsequently led to "a

! failure before correction."

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$1. For each instance identified in response to the foregoing inter.

rosatory, pleue provide each and every repon why SOY believes (if it does) that the event in Question was related to aging. l

$2. Pleue define the term ' timely updating' as it is used by SOY in sub-paragraph 't ' of Contention 7. ,

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$3. Pieue describe the types of circumstances under which SOY under-stand YYNPC vendor manuals to be updated. For each such type of circumstance, pleue explain the mechanisms by which, as SOY  !

contends is the case, *information on aging equipment from the  !

vendors will be critical to prevent failure of safety equipment.' i

$4. Please identify each and every instance of which SOY is aware in which an ' update" of a sendor manual contained information not i previously available that was ' critical to prevent failure of safety l equipment"in which the criticality was directly related to aging, j 55, Does SOY contend that there is an applicable NRC requirement l specifying the nature and content of trend analysis programs appli-  !

cable to the YYNPC maintenance program? If so, please identify, by  !

citation to or identification of a document, each and every such l requirement.  :

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56. Please define the term

• Reliability Centered Maintenance (RCM)  ;

program" as used by SOY in sub paragraph 'h.(l)"(hereinafter used j to refer to the first of the two sub paragraphs labelled by SOY 'h.*)  ;

of its Contention 7.  !

$7. Please define the term

• life extension

• as used by SOY in sub para- [

graph 'h.(l)* of its Contention 7.  !

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58. Would SOY acknowledge that, if what the authors of EPRI NP- I 6152, (January,1989) meant by the term ' life extension

• does not i include the authoritation sought by this operating license amendment. [

then sub-paragraph *h.(l)* of Contention 7 is without basis?  !

$9. If your response to the foregoing interrogatory is other than an i unqualified affirmative, please state each and every fact or cir.  ;

cumstance that SOY contends provides a basis for sub paragraph l

'h.(1)" of Contention 7.  !

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60. Pleue describe what SOY understands to be the special effectiveness of RCM for ' life extension.'

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61. Does SOY contend that there is an applicable NRC requirement YYNPS have in place, or have made a commitment to, an RCM  :

maintenance program? If so, pleue identify, by citation to or L loentification of a document, each and every such requirement.

62. Does SOY contend that, without regard to any NRC requirement,  !

RChi is the only way that a maintenance program can be effective to combat the effects of aging? l

63. If your response to the foregoing interrogatory is anything other than an unqualified negative, please state each and every reason why SOY  !

contends that RChi is the only way that a maintenance program can be effective to combat the effects of aging.

64. Pleue state each and every alternative method to RChi that SOY is  !

aware of and, for each such alternative, state whether SOY contends i that the alternative is superior to, equal to, or substantially inferior to RChi for correcting the deficiencies alleged by SOY in its Contention ,

7, and state each and every reason why SOY so contends. l l

65. Does SOY agree without qualification with the following statement:

4 Chi is primarily a means of decreasing maintenance costs and inerening plant econo- I mies, accomplished by eliminating unnecessary preventative maintenance and prioritizing the  ;

rest toward those systems and components with .

the greatest impact on megawatt-hours pro- I duced?"

If your answer is anything other than an unqualified affirmative, then please:

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a. State each and every qualification you have with respect to the [

quoted assertion, i

b. State cach and every fact on which your qualification is based, r

c. Describe all of the evidence in SOV's possession or of which SOY has knowledge that SOY contends establishes each such i fact.

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d. For each qualification, either provide the technical qualifica-tions (education, employment history, licenses and certificates, experience, or other information which SOY contends est-ablishes the qualifications of the person), of any person on whose expertise SOY relies for the qualification or state that SOY does not rely upon the empertise of any person for the qualification.

66. Please explain in detail what connection (if any) SOY contends emists

) between IR 89 80 and the NRC Draft Analysis for Proposed Rule-making on Maintenance of Nuclear Power Plants. November 1988.

67. Please define what is meant by .COV by the term

• weakness in the maintenance programs

• as it is used by SOY in sub paragraph 'h.(2)*

(hereafter used to refer to the second of the two sub paragraphs labelled by SOY 'h') of its Contention 7,

68. Please state each and every reason SOY contends that ' weakness in the maintenance programs" is 'of specific risk,' and, for each reason, please; j

n. State each and every fact on which your reason is based,

b. Describe all of the evidence in SOV's possession or of which i SOY has knowledge that SOY contends establishes each such fact, j

c. For each reason, either provide the technical qualification I (education, employment history, licenses and certificates,  ;

experience, or other information which SOY contends est-ablishes the qualifications of the person), of any person on whose expertise SOY relies for the reason or state that SOY l does not rely upon the expertise of any person for the reason.

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69. Please identify, including but not limited to a specific citation, all j

• aspects of maintenance problems relevant to the proposed action" for '

which SOY contends the

• Draft Regulatory Analysis" "provides a ,

summary and identification.' '

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70. For each and every ' aspect [] of maintenance problems" identified in response to the foregoing interrogatory, please state each and every j reason why SOY contends it !s " relevant to the proposed action."  ;

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[ 71. Does SOY contend that YYNPS ' plant management

• has not adequate.

ly ' review [ed) the industry practice in maintenance planning to

f. determine if the industry trend in estab!!shing formal maintenance j l planning groups would aid in increasing productivity in the main.

i tenance area.' If your answer is anything other than an unqualified i negative, then please:

a. State tach and every qualification you have with respect to the quoted assertion, i

b. State each and every fact on which your qualification is based,

c. Describe all of the evidence in SOV's possession or of which l SOY hu knowledge that SOY contends establishes each such I

fact.

d. For each qualification, either provide the technical qualifica-tions (education, employment history, licenses and certificates, experience, or other information which SOY contends estab-lishes the qualif. cations of the person), of any person on whose expertise SOY relies for the qualification or state that SOY does not rely upon the expertise of any person for the qualification.

72. Please state each and every reason SOY contends (if it does) that a

• review (of) the industry practice in maintenance planning to deter-mine if the industry trend in establishing formal maintenance planning groups would aid in increasing productivity in the main-tenance area" would materially impact safety through the balance of the extended VYNPS license term.

73. Please define what is meant by SOY by the term *better computeriza-tion of the MR system" as it is used by SOY in sub paragraph 'j' of its Contention 7.

74. Please state each and every reason SOY contends (if it does) that

'better computerization of the MR system" would materially impact safety through the balance of the extended VYNPS license term.

l 75. Please define what is meant by SOY by the term *better utilization of l the Assistant to the Operations Supervisor

• as it is used by SOY in sub paragraph 'j' of its Contention 7.

76. Piense state each and every renon SOY contends (if it does) that

'better utillution of the Assistant to the Operations Supervisor

• would materially impact safety through the balance of the entended YYNPS license term. ,

77 Pleue define what is rnennt by SOY by the term ' sufficient heed to their desires' as it is used by SOY in sub paragraph 'j' of its Conten.  !

tion 7.

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78. With respect to the matter referred to on page 47 of its

• Supplement l to Petition to Intervene' as the second excerpt from *LRS Report, w3-88, p. 7,' does SOY possess any information regarding the matter beyond that contained in the LRS Report? If so, pleue set forth all the information known or believed by SOY to be known by it relating ,

to that matter.

79. Please state each and every reason why SOY contends (if it does) that

• pay [ing) sufficient heed to [the operators] desires for hardware repair and replacement

• would materially impact safety through the balance of the extended YYNPS license term.

80. Please describe in detail exactly what 'more work' SOY contends (if  :

it does) needs to be done in 'the certification area,' as these terms are used in sub paragraph 'j' of its Contention 7 and state each and every reason SOY contends (if it does) that such work would materi.

ally impact safety for the balance of the extended VYNPS license term.

81. Please define the term

• formality" as it is used by SOY in sub- f paragraph 'j' of its Contention 7.

82. Please state each and every reason SOY contends (if it does) that  !

' formality" would materially impact safety for the balance of the extended VYNPS license term.  !

83. Please define what is meant by SOY by the term ' program infor- l mality" as it is used by SOY in sub+ paragraph 'k.' of its Contention 7, 1 i

84. Please define what is mesnt by SOY by the term

• vulnerable" as it is I used by SOY in sub paragraph 'k " of its Contention 7. I 1

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$$. Pleue define what is meant by SOY by the term ' attrition in the experienced maintenance organiution' as it is used by SOV in sub.

paragraph 'k.' of its Contention 7.

86. Pleue describe how SOY contends that ' program informality'(as SOY uses the term) leaves YYNPS ' vulnerable'(u SOY defines the term) to ' attrition in the experienced maintenance organiution' (as SOY <

uses the term).

87. Pleue describe each and every enhancement to ' program formality

• that SOY contends is required to obviate YYNPS's ' vulnerability' to

' attrition in the experienced maintenance organiution,' and, for each ,

such enhancement, set forth all of the repons why SOY contends that, if implemented, the enhancement would obviate the vul-nerability. ,

88. Please define what is meant by SOY by the term ' communications ,

problems' as it is used by SOY in sub paragraph 'k.' of its Contention l

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89. Please describe how SOY contends that ' program infortnality'(as SOY 1 uses the term) leaves VYNPS ' vulnerable'(as SOY defines the term) to ' communications problems"(as SOY uses the term).

90. Please describe ener and every enhancement to ' program formality

• that .*OV contends is required to obviate VYNPS's " vulnerability

• to

'coinmunications problems" and, for each such enhancement, set forth ,

all of the reasons why SOY contends that, if implemented, the  !

enhancement would obviate the vulnerability.  !

91. Please define what is meant by SOY by the term ' incidents involving l vendor data shortcomings" as it is used by SOY in sub-paragraph *k.' i of its Contention 7. ,

92. Please describe how SOY contends that ' program informality'(as SOY  !

uses the term) leaves YYNPS ' vulnerable * (as SOY defines the term) to ' incidents involving vendor data shortcomings" (as SOY uses the term).

93. Please describe each and every enhancement to ' program formality" '

that SOY contends is required to obviate VYNPS'sa vulnerability' to

• incidents involving vendor data shortcomings" and, for each such enhancement, set forth all of the reasons why SOY contends that, if implemented, the enhancement would obviate the vulnerability.

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94. Please define what is meant by SOV by the term " procedural inade-quacies" as it is used by SOY in sub-paragraph "k." of its Contention 7

95 . Please describe how SOY contends that " program informality"(as SOY uses the term) leaves VYNPS " vulnerable"(as SOY defines the term) to " procedural inadequacies" (as SOY uses the term).

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96. Please describe each and every enhanecment to " program formality" that SOY contends is required to obviate YYNPS's " vulnerability" to

" procedural inadequacies" and, for each such enhanecment, set forth all of the reasons why SOY contends that, if implemented, the enhancement would obviate the vulnerability.

97. Please define what is meant by SOY by the term " human error" as it is used by SOY in sub-paragraph "k." of its Contention 7

98. Please describe how SOY contends that " program informality"(as SOY uses the term) leaves VYNPS " vulnerable"(as SOY defines the term) to " human error"(as SOY uses the term).

99. Please describe each and every enhancement to " program formality" that SOY contends is required to obviate YYNPS's " vulnerability" to

" human error" and, for each such enhancement, set forth all of the reasons why SOV contends that, if implemented, the enhancement would obviate the vulnerability. j 100. Please define what is meant by SOY by the term " tested with satisfac-tory performance" as it is used by SOY in sub-paragraph "k" of its Contention 7, including the testing interval requirement and the acceptance criteria implied thereby.

101. Please state each and every reason why SOY contends that "the  !

proposed action cannot be considered" until "such maintensnee improvements are made and tested with satisfactory performance,"

and, for each such reason, please:

a. State each and every fact on which your reason is based. l q b. Describe all of the evidence in SOV's possession or of which SOY has knowledge that SOV contends establishes each such fact.

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L c. For each reason, either provide the technical qualification l (education, employment history, licenses and certificates, {

experience, or other information which SOY contends est-  :

i ablishes the qualifications of the person), of any person on . l t whose expertise SOV relies for the reason or state that SOY  !

d(m tot rely upon the expertise of any person for the reason.

< C 2. h.n describe in as much detail as is available to SOV what is

• a cred to by SOY in sub-paragraph "m." of its Contention 7 as "the Iailure to maintain the Uninterruptible Power Supply."

'I 103. Please set forth each and every reason why SOV contends that what ,

i is referred to by SOY in sub-paragraph "tr." of its Contention 7 as -

tu e "the failure to maintain the Uninterruptible Power Supply" demon-strates "a history of maintenance induced problems and incorrectly i executed maintenance and surveillance programs." )

104. Please set forth each and every reason why SOY contends that what is referred to by SOY in sub-paragraph "m." of its Contention 7 as "the failure to maintain . . . the toxic gas monitors" demonstrates "a history of maintenance induced problems and incorrectly executed ,

maintenance and surveillance programs." ,

105. Please define what is meant by SOV by the term " reliability standards" as it is used by SOY in sub-paragraph "m" of its Contention 7. -

106. Does SOV contend that NRC imposes any requirements as to "reliabil-ity standards" as that term is usea by SOY in sub-paragraph "m" of its Contention 7. If so, please identify, by citation to or identification of a specific provision of a document, each and every such requirement.

107. With respect to the matter referred to on page 49 of its " Supplement  !

to Petition to Intervene" as "LER-89-24," does SOY possess any information regarding the matter beyond that contained in the  ;

Licenree Event Report? If so, please set forth all of the information .

known or believed by SOV to be known by it relating to that matter. .

6 108. Please describe each and every change to the VYNPS maintenance program or surveillance program that SOV contends, had such change been implemented earlier, would have precluded the occurrence of the matters described in the Licensee Event Report described in the foregoing interrogatory.

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109. With respect to the matter referred to on page 49 of its ' Supplement to Petition to Intervene" as 'LER-89-23,* does SOY possess any  ;

info mation regarding the matter beyond that contained in the .

Licensee Event Report? If so, please set forth all of the information .

known or believed by SOY to be known by it relating to that matter.

110, Please describe each and every change to the VYNPS maintenance .t' program or surveillance program that SOV conter.ds, had such change been implemented earlier, would have precluded the occurrence of c

the matters described in the Licensee Event Report described in the i foregoing interrogatory.

111. With respect to the matter referred to on page 49 of its

• Supplement to Petition to intervene" as "LER-89-17,' does SOY possess any information regarding the matter beyond that contained in the Licensee Event Report? If so, please set forth all of the information known or believed by SOY to be known by it relating to that matter, Please describe each and every change to the VYNPS maintenance i 112.

program or surveillance program that SOY contends, had such change been implemented earlier, would have precluded the occurrence of the matters described in the Licensee Event Report described in the foregoing interrogatory, 113. With respect to the matter referred to on page 49 of its " Supplement to Petition to Intervene" as "LER-89-14,* does SOY possess any information regarding the matter beyond that contained in the Licensee Event Report? If so, please set forth all of the information known or believed by SOY to be known by it relating to that matter.

114. Please describe each and every change to the VYNPS maintenance program or surveillance program that SOY contends, had such change been implemented earlier, would have precluded the occurrence of the matters described in the Licensee Event Report described in the foregoing interrogatory, 115. With respect to the matter referred to on page 49 of its " Supplement to Petition to Intervene" as "LER-89-10," does SOY possess any information regarding the matter beyond that contained in the Licensee Event Report? If so, please set forth all of the information known or believed by SOY to be known by it relating to that matter.

116. Please describe each and every change to the VYNPS maintenance program or surveillance program that SOV contends, had such change 1:

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117. With respect to the matter referred to on page 49 of its " Supplement ,

to Petition to intervene" as "LER-88-14." does SOY possess any -

information regarding the matter beyond that contained in the ,

Licensee Event Report? If so, please set forth all of the information known or believed by SOY to be known by it relating to that matter, r

Please describe each and every change to the VYNPS maintenance 118.

program or surveillance program that SOY contends, had such change been implemented earlier, would have precluded the occurrence of the matters described in the Licensee Event Report described in the foregoing interrogatory. '

119. With respect to the matter referred to on page 49 of its " Supplement  ;

to Petition to Intervene" as "LER-88-13," does SOY possess any i information regarding the matter beyond that contained in the  ;

Licensee Event Report? If so, please set forth all of the information known or believed by SOY to be known by it relating to that matter.

120. Please describe each and every change to the VYNPS maintenance ,

program or surveillance program that SOY contends, had such change been implemented earlier, would have precluded the occurrence of the matters described in the Licensee Event Report described in the foregoing interrogatory.

121. With respect to the matter referred to on page 49 of its

• Supplement to Petition to Intervene" as "LER-88-09," does SOY possess any '

information regarding the matter beyond that contained in the Licensee Event Report? If so, please set forth all of the information known or believed by SOY to be known by it relating to that matter.

122. Please describe each and every change to the VYNPS maintenance program or surveillance program that SOV contends, had such change been implemented earlier, would have precluded the occurrence of the matters described in the Licensee Event Report described in the foregoing interrogatory.

123. With respect to the matter referred to on page 49 of its " Supplement to Petition to Intervene" as "LER-88-09," please:

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a. Esplain what is meant by the term "(inadequate non-safety related maintenance cuated reactor trip)".

b. Identify the author of the phrase quoted in sub-part a of this interrogatory.

c. Esplain all of the reasons why SOY so classifies the event in question.

124. With respect to the matter referred to on page 49 of la " Supplement to Petition to intervene" as "LER-88-05." does SOY possess any information regarding the matter beyond that contained in the Licensee Event Report? If so, please set forth all of the information known or believed by SOV to be known by it relating to that matter.

125. Please describe each and every change to the VYNPS maintenance program or surveillance program that SOY contends, had such change been implemented earlier, would have precluded the occurrence of the matters described in the Licensee Event Report described in the foregoing interrogatory.

126. With respect to the matter referred to on page 50 of its " Supplement to Petition to Intervene" as "LER-88-04 " does SOY possess any r information regarding the matter beyond that contained in the  ;

Licensee Event Report? If so, please set forth all of the information known or believed by SOY to be known by it relating to that matter.

127. Please describe each and every change to tha VYNPS maintenance program or surveillance program that SOV contends, had such change been implemented earlier, would have precluded the occurrence of ,

the matters described in the Licensee Event Report described in the l foregoing interrogatory. l l

128. With respect to the matter referred to on page 50 of its " Supplement to Petition to Intervene" as "LER-88-03," does SOY possess any information regarding the matter beyond that contained in the Licensee Event Report? If so, please set forth all of the information known or believed by SOV to be known by it relating to that matter.

129. Please describe each and every change to the VYNPS maintenance program or surveillance program that SOY contends, had such change been implemented earlier, would have precluded the occurrence of the matters described in the Licensee Event Report described in the foregoing interrogatory.

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i 130. With respect to the matter referred to on page 50 of its " Supplement  ;

to Petition to Intervene" as "LER-89-07,' does SOY possess any '

information regarding the matter beyond that contained in the  !

Licensee Event Report? If so, please set forth all of the information  !

known or believed by 00V to be known by it relating to that matter.

P 131. Please describe each and every change to the VYNPS maintenance program or surveillance program that SOY contends, had such change . I been implemented earlier, would have precluded the occurrence of  :

the matters described in the Licensee Event Report describG in the foregoing interrogatory. ,

132. With respect to the matter referred to on page 50 of its " Supplement to Petition to Intervene" as "LER-87-07," does SOY possess any information regarding the matter beyond that contained in the Licensee Event Report? If so, please set forth all of the information known or believed by SOY to be known by it relating to that matter.  !

133. Please describe each and every change to the VYNPS maintenance I program or surveillance program that SOV contends, had such change -

been implemented earlier, would have precluded the occurrence of the matters described in the Licensee Event Report described in the foregoing interrogatory.

134. With respect to the rnatter referred to on page 50 of its " Supplement to Petition to Intervene" as "LER-85-07," does SOY possess any information regarding the matter beyond that contained in the Licensee Event Report? If so, please set forth all of the information known or believed by SOV to be known by it relating to that matter.

135. Please describe each and every change to the VYNPS maintenance i program or surveillance program that SOY contends, had such change been implemented earlier, would have precluded the occurrence of the matters described in the Licenree Event Report described in the foregoing interrogatory. '

136. With respect to the matter referred to on page 50 of its " Supplement to Petition to Intervene" as "LER-84-il " does SOV possess any information regarding the matter beyond that contained in the Licensee Event Report? If so, please set forth all of the information known or believed by SOV to be known by it relating to that matter.

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137. Please describe each and every change to the YYNPS maintenance program or surveillance program that SOY contends, had such change been implemented earlier, would have precluded the occurrence of the matters described in the Licensee Event Report described in the foregoing interrogatory.

c 138. Please define " weakness" as that term is used by SOY 'in sub-para-graph "1" of its Contention 8.

n 139. Please define " future inadequacies in the maintenance program" as that term is used by SOY in sub-paragraph 't" of its Contention 8.

140. Please state each and every reason SOV contends that VYNPS will have " future inadequacies in [its] maintenance program", and, for each such reason, please:

a. State each and every fact on which your reason is based,

b. Describe all of the evidence in SOV's possession or of which SOY has knowledge that SOY contends e:tablishes each such fact.

c. For each reason, either provide the technical qualification (education, employment history, licenses and certificates, experience, or other information which SOY contends est-ablishes the qualifications of the person), of any person on whose expertise SOY relies for the reason or state that SOV does not rely upon the expertise of any person for the reason.

141. Please define " adequacy of the containment" as that term is used by SOV in sub-paragraph *l" of its Contention 8.

142. Please state each and every reason SOY contends that "past and future inadequacies of the maintenance program" "put in doubt" the "ade-quacy of the containment for the extended period," and, for each reason, please:

a. Please list each of the " inadequacies" that SOY contends put l the matter in doubt.  !

b. State each and every fact on which your reason is based.

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c. Describe all of the evidence in SOV's possession or of which SOY has knowledge that SOY contends establishes each such fact.

d. For each reason, either provide the technical qualification I (education, employment history, licenses' and certificates, 'I experience, or other information which SOY contends est-  !

ablishes the qualifications of tha person), of any person on i whose expertise SOY relies for the reason or state that SOY -

does not rely upon the expertise of any person for the reason. f 143. Please define what is meant by SOY by the term "the reliance claimed as it is used by SOY in sub paragraph "n" of its Contention ,

7, 144. Please define the term " gross age failure of the drywell paint system" as it is used by SOY in sub-paragraph "n" of its Contention 8.

145, With respect to the matter of " gross age failure of the drywell paint system" referred to by SOY in sub-paragraph "n" of its Contention 8 does SOY possess any information regarding the matter beyond that ,

contained in " letter, BVY 89-69, Pelletier to NRC"? If so, please set forth all of the information known or believed by SOY to be known vy it relating to that matter. ,

146. Please define the term " adequacy of the coating system in the ex-tended period" as it is used by SOY in sub-paragraph "n" of its Contention 8. t 147. Please state each and every reason SOV contends (if it does) that the I

" adequacy of the coating system" would differ for the extended period from its " adequacy" for the balance of the present VYNPS license term, and, for each reason, please:

a. State each and every fact on which your reason is based.

b. Describe all of the evidence in SOV's possession or of which SOV has knowledge that SOY contends establishes each such fact.

c. For each reason, either provide the technical qualification (education, employment history, licenses and certificates, experience, or other information which SOY contends est-ablishes the qualifications of the person), of any person on

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whose expertise SOY relles for the reason or state that SOY

doet. not rely upon the expertise of any person for the reason.

148. Please set forth all of the information known or believed by SOY to be known by it relating to ' torus wall thinning experienced at Nine  !

I Mile Point.'

i 149. Please set forth each and every respect, and reason therefor, why SOY ,

contends that the ' torus wall thinning experienced at Nine Mile Point' ,

applies to VYNPS, 150. Please define what is meant by SOY by the term 'ECCS criteria is not met" as it is used by SOY in sub-paragraph 'o' of its Contention 8.  ;

151. Please define what is meant by SOV by the term "misoperation of a proposed hardened containment vent" as it is used by SOY in sub- +

paragraph "o" of its Contention 8. Including for each mode of .

"misoperation" that SOY contends might occur, the resulting plant [

condition and safety impact. 1 152. Please state each and every reason SOY contends that "ECCS pump susction [ sic] must . . . be evaluated with regard to the effects of .

operation and misoperation of a proposed hardened containment vent," and, for each reason, please:

a. State each and every fact on whk.h your reason is based.

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b. Describe all of the evidence in SOV's possession or of which -

SOV has knowledge that SOV contends establishes each such fact. ,

c. For each reason, either provide the technical qualification (education, employment history, licenses and certificates, experience, or other information which SOV contends est-ablishes the qualifications of the person), of any person on whose expertise SOY relies for the reason or state that SOY ,

does not rely upon the expertise of any person for the reason.

153. Please identify each person assisting SOY in the preparation of its answers to these interrogatories.

154. For each person required to be identified in response to the foregoing interrogatory, please Iq y

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a. Identify the interrogatory answers prepared by that person or, l if such person prepared only a portion of an answer, the  ;

portions of the answer provided by such person, j

b. Provide the technical qualifications (education, employment history, licenses and certificates, experience, or other infor-  !

mation which SOV contends establishes the qualifications of '

the person), if any, of such person in each area in which SOY j contends such person to be technically qualified.  ;

c. Identify each and every report, paper or other document  !

prepared by such person (whether or not in conjunction with l other persons) and made available to SOV. ,

155. If, in response to any of the foregoing interrogatories, SOY has responded that it cannot answer or that it cannot answer completely  ;

without the acquisition by it of additionalinformation, for each such response:

a. Describe the additional information that SOY contends is I required in order for it to answer or to answer completely the .

interrogatory,

b. State each and every reason why SOY contends that the acquisition of such information is necessary in order for it to i answer or to answer completely the interrogatory, s c. State the steps that SOY is taking to acquire the information, f and, for each step, the anticipated date on which it will be  ;

completed,

d. State the intentions, if any, of SOY concerning supplementa-tion of its answer to the interrogatory, including (if supple-mentation is intended), the date on which it is anticipated that .

SOY will serve its supplemental response. ,

156. Does SOV intend to offer into evidence the testimony of any expert ,

witness or witnesses? If so, then for each such witness, provide: '

a. An identification of the witness.

b. The technical qualifications (education, employment history, licenses and certificates, experience, or other information t which SOY contends establishes the qualifications of the 4

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witness), if any, of the witness in each area in which SOY contends the witness to be technically qualified,

c. A summary of the facts and opinions to which SOV expects the witness to testify,

d. For each such opinion, a summary of the basis therefor.

p-By-its

( h R. K. Gad lit attorneys, kINA Jeffrey P. Trout 2 Ropes & Gray One International Place ,

Boston, Massachusetts 02110 Telephone: 617-951-7520 Dated: April 5,1990.

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LXhlli.D U$NhC YYN.14

'90 APR -9 P3 :29 Jg;l,g CertikhMg@(([

tlRAWi I, R. K. Gad til, hereby certify that on April 5,1990, I made service of the within interrogatories, by mailing copies thereof, first class mail, postage prepaid, as follows:

Robert M. Lazo, Esquire Jerry Hsrbour Chairman Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S.N.R.C. U.S.N.R.C.

Washington, D.C. 20555 Washington, D.C. 20555 Frederick J. Shon Adjudicatory File Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board Panel U.S.N.R.C. U.S.N.R.C.

Washington, D.C. 20555 Washington, D.C. 20555 Anthony Z. Roisman, Esquire Ann P. Hodadon, Esquire Cohen, Milstein & Hausfeld Patricia A. Jehle, Esquire Suite 600 -

U.S.N.R.C.

1401 New York Avenue, N.W. Washington, D.C. 20555 Washington, D.C. 20005 James Volz, Esquire Vermont Department of Public Service 120 State Street Montpeller, Vermont 05602 R. K. Gad III l

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