ML20205E126

New England Coalition on Nuclear Pollution First Set of Interrogatories & Request for Production of Documents to NRC Staff on NRC Environ Assessment & Finding of No Significant Impact....* Certificate of Svc Encl.Related Correspondence

ML20205E126
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	10/21/1988
From:	Ferster A HARMON, CURRAN, SPIELBERG & EISENBERG, LLP., NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:	NRC OFFICE OF THE GENERAL COUNSEL (OGC)
References
CON-#488-7353 OLA, TAC-65253, NUDOCS 8810270309
Download: ML20205E126 (9)

Text

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October 21, gg{Sg g, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board

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In the Matter of ) s

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Vermont Yankee Nuclear )

Power Corporation ) Docket No. 50-271-OLA

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(Vermont Yankee Nuclear )

Power Station) )

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NECNP'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO NRC STAFF ON THE NRC ENVIRONMENTAL ASSESSMENT AND FINDING OF NO SIGNIFICANT IMPACT - SPENT FUEL POOL EXPANSION, (TAC NO. 65253)

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 cach 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, microfict c, analyses, intra-corporate or intra-office commual- ,iooks, diaries, sketches, diagrams, forms, 80102703o9 0 9

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- . .a 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 followings the document's title, its date, the author of the document, the person to whom the 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 conducts the person or persons proposing and taking such actions the date 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.

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4) "Identifv" with respect to an individual shall mean state the individual's name, address, employer, occupation, and

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title.

5) "Describe" with respect to any action or matter shall mean state the following regarding such action or matters the substance or nature of such action or matter; the persons partic-ipating in or having knowledge of such action or matters the cur-rent and past business positions and addresses of such persons; and the existenct and location of any and all documents relating to such action or matter.

6) "VY" or "Acolicant" shall refer to the Vermont Yankee

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Sn Nuclerr Power Corporation.

7) "Staff" shall refer to all persons employed by the NRC at headquarters or regional offices, including contractors hired by NRC.

8) "Environmental Assessment" or "EA" shall refer to the "Environmental Assessment and Finding of No Significant Impact -

Spent Fuel Pool Expansion, Vermont Yankee Nuclear Power Station (TAC No. 65253), issued by the NRC Office of Nuclear Reactor Regulation on July 25, 1988.

9) "Pronosed Action" shall refer to Vermont Yankee's request for an amendment to the Vermont Yankee Facility Operating License DPR-28 to allow the expansion of the increased storage capacity of spent fuel in the spent fuel pool to 2870 fuel assem-blies, as described in Section 1.1 of the Environmental Assess-ment.

INTERROGATORIES AND DOCUMENT REOUESTS

1) Picase 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) One of the alternatives to the proposed action evaluated by the Environmental Assessment, Section 1.3, is alternative five (5), Construction of a new independent spent fuel storage installation (7 AI), or dry cask storage installa-tion. The following questions relate theretor a) Provide all documents used in or generated during your evaluation of a dry cask storage installation. Identify by name, job title and address all persons (including con-tractors) who participated in or will participate in any

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such independent evaluation and describe their roles and tasks during that evaluation, b) Describe the process by which your eva)uation of a dry ,

cask storage installation was undertaken and the time period involved: e.g., has a committee been established, were con-tractors hired; were meetings or deliberations held?

c) Identify any and all requirements, criteria and/or guidance, whether or not formally promulgated, which the staff considers to apply to the consideration of a dry cask storage installation in the context of this proposed action pursuant to the National Environmental Policy Act ("NEPA").

d) Describe by date, substance of discussion and participants all meetings held between and among VY (and contractors), NRC Region 1 personnel and NRC Headquarters personnel related to the feasibility /ovaluation of a dry cask storage installation at VY, dating from January, 1985 and forward. Provide all documents relating to or used in these meetings or exchanged among participants thereto.

(Refer to definition of "documents").

e) Identify and produce all documents prepared or relied on by the NRC or its consultants to evaluate the technical feasibility of a dry cask storage installation at the VY site.

f) Identify and produce all documents prepared or relied on by the NRC or itu consultants that evaluate the cost of a dry cask storage installation at the VY site, g) Identify and produce all documents prepared or relied on by the NRC or its consultants tnat evaluate the safety or

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t ravironmental risks posed by a dry cask storage installa- i tion, and provide any supporting documentation.

h) Provide all documents in the staff's possession which compare the cost, technical feasibility and/or risks of VY's I

proposed action to the cost, technical feasibility and/or t

I risks of dry cask storage.

3) In its evaluation of alternative five (5) to the pro-posed action, construction of a new independent spent fuel  !

t storage installation (IsrSI), identifying a dry cask storage installation, the Environmental Assessment concludes that a dry I

cask storage installation is not feasible as an alternative to the proposed action because "this alternative could not be imple- l mented in time to meet the need for additional capacity for the  :

i Vermont Yankee Plant" (EA, page 4, 5). The following questions relate thereto a) Identify and provide all documents containing the time lines, time analyses, time estimates, or time comparisons on which you relied in reaching th.is conclusion.

b) State how much time (days, months and years) it would  ;

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take to design and construct a dry cask storage facility at t

VY.

c) Did NRC or its contractors prepare or use any analysis, study or other document that compares the time it would take [

to design and construct a dry cask storage facility at VY l with the time it would take to develop and install all f equipment necessary to implement the proposed action, l including the time necessary to design and install a spent fuel pool cooling system that meets current NRC regulatory l I

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1 tequirements? If yes, please provide a copy of any docu- l 1

i ments containing such analysis. If not, please explain the l 4

1 basis for the EA's conclusion that dry cask storage j l installation could not be designed and constructed in time f 1

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3 to meet VY's necid for additional capacity.

J d) State how much time (days, months and years) it would i i

I j take for an NRC review, evaluation, and licensing of a dry [

' I cask storage facility, j e) Did NRC or its contractors prepara or une any analysis, i j study, or other document that compares the time it would i

take for an NRC review, evaluation, and licensing of a dry l f

cask storage facility with the time it would take for an NRC review, evaluation, and licensing of the proposed action, [

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including the time necessary to review the enhanced spent f fuel pool cooling system described in the VY letter of June 7, 1988 to the NRC? If yes, please provide a copy of any  ;

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) documents containing such analysis. If not, please explain J

I the basis for the EA's conclusion that dry cask storage j J  !

installation enuld not be reviewed and licensed in time to meet VY's need for additional capacity.

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i 4) Provide all documents (including but not limited to 1 i

correspondence, memos, telephone logs, meeting minutes) among VY f (and contractors), NRC Region 1 personnel and NRC Headquarters t f

personnel related to expansion of spent-fuel storage capacity at f;

VY dating from January, 1985 and forward. (You need not provide I i material which has already been sent to the parties in this l

i case).

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5) Describe by date, substance of discussion and  !

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participants all mootings hold betwoon and among VY (and con-tractors), NRC Region 1 personnel and NRC Headquartors personnel related to expansion of spent fuel storago capacity at VY, dating from January, 1985 and forward. Provido all documents relating to or used in those mootings or exchanged among participants thoroto. (Yau nood not provido material which has already boon sont to the parties in this case)

6) Identify all applications by utilities for dry cask storage roccived by the NRC to dato and describe the status of each (e.g. status of staff review, licensing documents prepared, approved, in placo, etc.).

Respectfully submitted, Andrea Ferster h HARMON, CURRAN & TOUSLEY 2001 "S" Street N.W. Suito 430 Washington, D.C. 20009 (202) 328-3500

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CERTIFICATE OF SERVICE  :

I certify that on october 21, 1988, copies of the foregoing pleading were served by first-class mail, or as otherwise indi-cated, on all parties listed below. -

Charles Bechhoefer, Chairmaa .

Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Ej gj f' Washington, D.C. 20555 Sp ,

n, F3 .6 Glenn O. Bright i:~

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Atomic Safety and Licensing Board Panel v. ' r D4 j U.S. Nuclear Regulatory Commission -

, l Washington, D.C. 20555 ,

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Dr. James H. Car) enter Atomic Safety and Licensing Board Panel  ;

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ,

i secretary of the Commission t Attn Docketing and Service Section U.S. Nuclear Regulatory Commission l Washington, D.C. 20555 Christine N. Kohl, Chairman Atomic Safety and Licensing Appeal Board ,

U.S. Nuclear Regulatory Commission l

Washington, D.C. 20555 t

George Dean, Esq.

Assistant Attorney General l Commonwealth of Massachusetts r Department of the Attorney General One Ashburton Place Boston, MA 02108 {

David Mullet, Esq.

Vcrmont Department of Public Service .

120 State Street [

Montpelier, VT 05602 t

Ann Hodgdon, Esq.*  !

office of the General Counsel Be*.heada U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ,

Diana Sidebotham R.F.D. #2 Putney, Vermont 05346 l l

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R.K. Gad III _.

Ropes & Gray --

225 Franklin Street r Boston, MA 02110 Gary J. Edles Atomic Safety and Licensing Appeal Board -

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Howard A. Wilber Atomic Safety and Licensing Appeal Board U.S. Muclear Regulatory Commission Washington, D.C. 20555 Geoffrey M. Huntington, Esq. , _

r-office of the Attorney General Environmental Protection \gency 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

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