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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20195H1911999-06-15015 June 1999 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests.Requests That Commission Consent to Two Indirect Transfers of Control & Direct Transfer ML20204H9901999-03-24024 March 1999 Comment on Proposed Rule 10CFR50.54(a)(3) Re Changes to Quality Assurance Programs ML20206T9731998-05-27027 May 1998 Citizens Awareness Network'S Formal Request for Enforcement Action Against Vermont Yankee.* Requests That OL Be Suspended Until Facility Subjected to Independent Safety Analysis Review,Per 10CFR2.206 ML20247G8501998-04-0909 April 1998 Petition Demanding That Commission Issue Order Stating That Administrative Limits of TS 88 Re Torus Water Temp Shall Remain in Force Until Listed Conditions Met ML20217P5481998-04-0606 April 1998 Comment Supporting Proposed Rule 10CFR50 Re Proposed Changes to Industry Codes & Stds ML20199A3121998-01-20020 January 1998 Exemption from Requirements of 10CFR70.24 Re Criticality Monitors to Ensure That Personnel Would Be Alerted If Criticality Were to Occur During Handling of Snm.Exemption Granted ML20198L1791997-12-29029 December 1997 Final Director'S Decision DD-97-26 Pursuant to 10CFR2.206, Granting in Part Petitioners Request in That NRC Evaluated All of Issues Raised in Two Memoranda & Suppl Ltr Provided by Petitioner to See If Enforcement Action Warranted ML20217G7151997-10-0808 October 1997 Director'S Decision DD-97-25 Re J Block 961206 Petition Requesting Evaluation of 961205 Memo Re Info Presented by Licensee at 960723 Predecisional Enforcement Conference & 961206 Memo Re LERs Submitted at End of 1996.Grants Request ML20140C2511997-03-31031 March 1997 Comment Opposing Proposed Rule 10CFR170 & 171 Re Rev of Fee Schedules ML20134L5701996-12-0606 December 1996 Petition for Commission & EDO Evaluation of Encl Documents Pursuant to 10CFR2.206 to See If Enforcement Action Warranted Based Upon Info Contained Therein DD-93-23, Director'S Decision DD-93-23 Re M Daley & J M Block Requesting Per 10CFR2.206,that NRC Reconsider Civil Penalty Assessed Against Vynp for Operating Station Outside TS from 921015-930406.Request Denied1993-12-28028 December 1993 Director'S Decision DD-93-23 Re M Daley & J M Block Requesting Per 10CFR2.206,that NRC Reconsider Civil Penalty Assessed Against Vynp for Operating Station Outside TS from 921015-930406.Request Denied DD-93-19, Final Director'S Decision DD-93-19 Under 2.206.Denies Request That NRC Take Immediate EA to Require That Reactor at Plant Remain in Cold Shutdown Until Licensee Could Provide Proof That EDGs at Plant Meet Safety Function1993-12-14014 December 1993 Final Director'S Decision DD-93-19 Under 2.206.Denies Request That NRC Take Immediate EA to Require That Reactor at Plant Remain in Cold Shutdown Until Licensee Could Provide Proof That EDGs at Plant Meet Safety Function ML20057C1321993-09-16016 September 1993 Memorandum & Order (CLI-93-20).* Reverses Board Conclusion That NRC Staff Action Had Effect of Terminating Proceeding. W/Certificate of Svc.Served on 930916 ML20045H3741993-07-0909 July 1993 Comment Supporting Proposed Rule 10CFR55 Re Operators Licenses.Proposed Change Would Eliminate NRC Requirement to Conduct & Supervise Individual Operator Requalification Exams During Term of Opeerator 6-yr License ML20128P9821993-02-24024 February 1993 Affidavit of Rd Pollard Re New England Coalition on Nuclear Pollution Comments in Opposition to Proposed Finding of NSHC ML20128Q0101993-02-22022 February 1993 New England Coalition on Nuclear Pollution Request for Hearing on Proposed Amend to Vermont Yankee OL ML20128Q0041993-02-22022 February 1993 New England Coalition on Nuclear Pollution Comment in Opposition to Proposed Finding of NSHC BVY-91-106, Comments on NRC Proposed Amend to Policy Statement Re Cooperation W/States at Commercial Nuclear Power Plants. Consistent W/Mou,Util Established Position of State Liaison Engineer to Communicate W/State of VT1991-10-23023 October 1991 Comments on NRC Proposed Amend to Policy Statement Re Cooperation W/States at Commercial Nuclear Power Plants. Consistent W/Mou,Util Established Position of State Liaison Engineer to Communicate W/State of VT ML20085H8331991-10-23023 October 1991 Comment Supporting Proposed Rule 10CFR50 Re NRC Proposed Amend to Policy Statement Concerning Cooperation W/States at Commercial Nuclear Power Plants ML20082G8961991-08-0909 August 1991 Memorandum of State of Vermont Concerning Withdrawal of Contention.* Contentions Re Maint & Proferred late-filed Contention Re Qa.W/Certificate of Svc ML20082G9071991-07-30030 July 1991 Withdrawal of Contention & Intervention.* Withdraws Contention,Motion (Pending) for Admission of late-filed Contention & Intervention ML20066G9981991-02-0808 February 1991 Notice of Withdrawal of Appearance.* Requests Withdrawal of Jp Trout as Counsel for Applicant in Proceeding. W/Certificate of Svc ML20065U0421990-12-12012 December 1990 State of VT Reply to NRC Staff Response to Vermont Yankee Fifth Motion to Compel.* Motion Should Be Denied on Basis of NRC Misciting Cases.W/Certificate of Svc ML20062H6711990-11-0101 November 1990 NRC Staff Response to State of VT Motion to File Reply.* Staff Believes That Matter Should Be Resolved as Soon as Possible & Not Defer Resolution of Matter Until After Not Yet Scheduled Prehearing Conference.W/Certificate of Svc ML20065K4021990-10-29029 October 1990 Answer to State of VT Motion for Leave.* Unless State of VT Substantially Suppls,In Timely Manner,Prior Responses,Then Staff Citation to Stonewalling by Intervenors in Shoreham Proceeding Would Seem Well on Point.W/Certificate of Svc ML20065K3961990-10-29029 October 1990 Answer to State of VT Motion to Compel (Document Request Set 3).* Motion Should Be Denied.W/Certificate of Svc ML20062C2321990-10-22022 October 1990 Answer of Vermont Yankee Nuclear Power Corp to State of VT Motion to Compel (Interrogatories,Set 3).* Motion Should Be Denied.W/Supporting Info & Certificate of Svc ML20062C2371990-10-18018 October 1990 State of VT Motion for Leave to File Reply to NRC Staff Response to Vermont Yankee Motion to Compel.* Alternatively, State Requests That Licensee Motion Be Included for Oral Arqument in Prehearing Conference.W/Certificate of Svc ML20062C0221990-10-12012 October 1990 State of VT Motion to Compel Answers to Document Production Requests (Vermont Set 3).* W/Certificate of Svc ML20059N8671990-10-0404 October 1990 Motion to Compel Answers to Interrogatories (State of VT Set 3).* Requests That Board Enter Order Compelling Licensee to Give Proper Answers to Interrogatories.W/Certificate of Svc ML20059M6461990-10-0202 October 1990 NRC Staff Response to Licensee Motion to Compel Production of Documents.* Supports Licensee Motion Due to State of VT Objections Not Well Founded.Notices of Appearance & Withdrawals & Certificate of Svc Encl ML20059M5591990-09-27027 September 1990 State of VT Answer in Opposition to Vermont Yankee Nuclear Corp Fifth Motion to Compel & State of VT Application for Protective Order.* Protective Order Should Be Issued So State Need Not Suppl Responses.W/Certificate of Svc ML20059M5711990-09-26026 September 1990 Supplemental Response to Applicant Interrogatories by State of VT (Set 3).* W/Certificate of Svc.Related Correspondence ML20059M6301990-09-21021 September 1990 Transcript of 900921 Affirmation/Discussion & Vote Public Meeting Re Termination of Plant Proceedings & Motions on ALAB-919 & Amends to 10CFR40 in Rockville,Md.Pp 1-5 ML20059L8791990-09-21021 September 1990 Memorandum & Order.* Motion to Dismiss Proceeding Granted & Proceeding Terminated.W/Certificate of Svc.Served on 900921 ML20059M6221990-09-21021 September 1990 Notice.* Notifies That Encl Request for Clarification from Commission Will Be Reported in NRC Issuances. Certificate of Svc Encl.Served on 900924 ML20059L8721990-09-14014 September 1990 Responses of Vermont Yankee Nuclear Power Corp to Document Requests Propounded by State of VT (Set 3).* Util Objects to Request on Grounds That Request Not Relevant to Admitted Contention.W/Certificate of Svc.Related Correspondence ML20059L8241990-09-14014 September 1990 Answers of Vermont Yankee Nuclear Power Corp to Interrogatories Propounded by State of VT (Set 3).* Supporting Info Encl.Related Correspondence ML20059L7241990-09-12012 September 1990 Motion to Compel Production of Documents (Set 1).* State of VT Should Be Compelled to Produce,In Manner Requested,Documents Requested in Util Requests 1-15 ML20059L7431990-09-12012 September 1990 NRC Staff Response to State of VT Motion for Leave to File Reply.* Licensing Board Should Grant State Motion.W/ Certificate of Svc ML20059C4891990-08-28028 August 1990 Responses to Document Requests by State of VT to Vermont Yankee Nuclear Power Corp (Set 1).* Certificate of Svc Encl. Related Correspondence ML20059C5341990-08-27027 August 1990 Memorandum & Order (Motion to Compel Answers to Interrogatories,Set 3).* State of VT Need Not Answer Interrogatories 1,5,14 or 15 Presently But Obligated To,If Further Info Develops.Served on 900827.W/Certificate of Svc ML20059C5931990-08-23023 August 1990 State of VT Motion for Leave to File Reply to Vermont Yankee Nuclear Corp & NRC Staff Answers to State of VT late-filed Contention.* Requests Permission to File Written Reply to Filings of Util & Nrc.W/Certificate of Svc ML20059C5471990-08-22022 August 1990 Stipulation Enlarging Time.* Parties Stipulate That Time within Which Licensee May Respond to State of VT Third Interrogatories & Requests for Production of Documents Enlarged to 900910.W/Certificate of Svc ML20059A8641990-08-17017 August 1990 State of VT Answer in Opposition to Vermont Yankee Nuclear Power Corp Fourth Motion to Compel & State of VT Application for Protective Order.* Board Should Deny Util Motion to Compel & Issue Protective Order.W/Certificate of Svc ML20059A9151990-08-13013 August 1990 NRC Staff Response to Motion to Amend State of VT Suppl to Petition to Intervene & Accept & Admit Addl late-filed Contention.* Licensing Board Should Reject Proposed Contention X.W/Certificate of Svc ML20059A9491990-08-13013 August 1990 Notice of Postponement of Prehearing Conference.* Conference Scheduled for 900821 & 22 in Brattleboro,Vt Postponed to Date to Be Determined Later.Certificate of Svc Encl.Served on 900814 ML20059A9031990-08-13013 August 1990 Responses to Interrogatories by State of VT to Vermont Yankee Nuclear Power Corp (Set 5).* Related Correspondence. W/Certificate of Svc ML20056B2221990-08-0808 August 1990 Answer of Vermont Yankee to State of VT Motion for Leave to Submit late-filed Contention.* Motion of State of VT for late-filed Contention Should Be Denied.W/Certificate of Svc ML20056B2141990-08-0606 August 1990 Supplemental Responses to Applicant Interrogatories by State of VT (Set 2).* Clarification Re Scope of Term Surveillance Program as Used in Contention 7 Provided.W/Certificate of Svc.Related Correspondence 1999-06-15
[Table view] Category:PLEADINGS
MONTHYEARML20206T9731998-05-27027 May 1998 Citizens Awareness Network'S Formal Request for Enforcement Action Against Vermont Yankee.* Requests That OL Be Suspended Until Facility Subjected to Independent Safety Analysis Review,Per 10CFR2.206 ML20247G8501998-04-0909 April 1998 Petition Demanding That Commission Issue Order Stating That Administrative Limits of TS 88 Re Torus Water Temp Shall Remain in Force Until Listed Conditions Met ML20134L5701996-12-0606 December 1996 Petition for Commission & EDO Evaluation of Encl Documents Pursuant to 10CFR2.206 to See If Enforcement Action Warranted Based Upon Info Contained Therein ML20065U0421990-12-12012 December 1990 State of VT Reply to NRC Staff Response to Vermont Yankee Fifth Motion to Compel.* Motion Should Be Denied on Basis of NRC Misciting Cases.W/Certificate of Svc ML20062H6711990-11-0101 November 1990 NRC Staff Response to State of VT Motion to File Reply.* Staff Believes That Matter Should Be Resolved as Soon as Possible & Not Defer Resolution of Matter Until After Not Yet Scheduled Prehearing Conference.W/Certificate of Svc ML20065K3961990-10-29029 October 1990 Answer to State of VT Motion to Compel (Document Request Set 3).* Motion Should Be Denied.W/Certificate of Svc ML20065K4021990-10-29029 October 1990 Answer to State of VT Motion for Leave.* Unless State of VT Substantially Suppls,In Timely Manner,Prior Responses,Then Staff Citation to Stonewalling by Intervenors in Shoreham Proceeding Would Seem Well on Point.W/Certificate of Svc ML20062C2321990-10-22022 October 1990 Answer of Vermont Yankee Nuclear Power Corp to State of VT Motion to Compel (Interrogatories,Set 3).* Motion Should Be Denied.W/Supporting Info & Certificate of Svc ML20062C2371990-10-18018 October 1990 State of VT Motion for Leave to File Reply to NRC Staff Response to Vermont Yankee Motion to Compel.* Alternatively, State Requests That Licensee Motion Be Included for Oral Arqument in Prehearing Conference.W/Certificate of Svc ML20062C0221990-10-12012 October 1990 State of VT Motion to Compel Answers to Document Production Requests (Vermont Set 3).* W/Certificate of Svc ML20059N8671990-10-0404 October 1990 Motion to Compel Answers to Interrogatories (State of VT Set 3).* Requests That Board Enter Order Compelling Licensee to Give Proper Answers to Interrogatories.W/Certificate of Svc ML20059M6461990-10-0202 October 1990 NRC Staff Response to Licensee Motion to Compel Production of Documents.* Supports Licensee Motion Due to State of VT Objections Not Well Founded.Notices of Appearance & Withdrawals & Certificate of Svc Encl ML20059M5591990-09-27027 September 1990 State of VT Answer in Opposition to Vermont Yankee Nuclear Corp Fifth Motion to Compel & State of VT Application for Protective Order.* Protective Order Should Be Issued So State Need Not Suppl Responses.W/Certificate of Svc ML20059L7431990-09-12012 September 1990 NRC Staff Response to State of VT Motion for Leave to File Reply.* Licensing Board Should Grant State Motion.W/ Certificate of Svc ML20059C5931990-08-23023 August 1990 State of VT Motion for Leave to File Reply to Vermont Yankee Nuclear Corp & NRC Staff Answers to State of VT late-filed Contention.* Requests Permission to File Written Reply to Filings of Util & Nrc.W/Certificate of Svc ML20059A8641990-08-17017 August 1990 State of VT Answer in Opposition to Vermont Yankee Nuclear Power Corp Fourth Motion to Compel & State of VT Application for Protective Order.* Board Should Deny Util Motion to Compel & Issue Protective Order.W/Certificate of Svc ML20059A9151990-08-13013 August 1990 NRC Staff Response to Motion to Amend State of VT Suppl to Petition to Intervene & Accept & Admit Addl late-filed Contention.* Licensing Board Should Reject Proposed Contention X.W/Certificate of Svc ML20056B1741990-08-0202 August 1990 NRC Staff Motion to Enlarge Time within Which to Respond to State of VT Late Filed Contention.* Response Period Extended to 900813.W/Certificate of Svc ML20056B2101990-08-0202 August 1990 NRC Staff Motion to Enlarge Time within Which to Respond to State of VT Late Filed Contention.* Response Period Extended to 900813.Served on 900806.Granted for ASLB on 900803.W/ Certificate of Svc ML20056B1941990-08-0202 August 1990 Answer of Vermont Yankee Nuclear Power Corp to State of VT Motion to Compel (Interrogatories Set 2).* Motion Should Be Denied Based on Listed Reasons.Certificate of Svc Encl ML20056B1981990-08-0202 August 1990 Motion to Compel Answers to Interrogatories (Vermont Yankee Nuclear Power Corp Set 4).* Util Moves That Board Enter Order Compelling State of VT to Give Proper Answers to Interrogatories Propounded by Util.W/Certificate of Svc ML20056A3731990-07-24024 July 1990 Motion to Suppl Answer of Vermont Yankee Nuclear Power Corp to State of VT Motion to Compel (Document Requests,Set 1).* Util Moves That ASLB Grant Leave to Suppl Motion to Compel by Adding Encl as Howard Ltr.W/Certificate of Svc ML20058K7391990-06-26026 June 1990 Motion to Compel Answers to Document Production Requests (Vermont Set 1).* State Moves to Compel Licensee to Produce Documents Denied to State of VT Because of Licensee Limited & Improper Interpretation of Scope.W/Certificate of Svc ML20055D9211990-06-22022 June 1990 Response of Vermont Yankee Nuclear Power Corp to State of VT Motion to Enlarge Discovery Period.* Request for Indeterminate Enlargement of Discovery Period Fatally Premature & Should Be Dismissed.W/Certificate of Svc ML20043H2921990-06-18018 June 1990 State of VT Answer in Opposition to Vermont Yankee Nuclear Power Corp Third Motion to Compel & State of VT Application for Protective Order.* Board Should Deny Util Motion to Compel.W/Certificate of Svc ML20043H1931990-06-14014 June 1990 Motion to Compel Answers to Interrogatories (State of VT Set 1).* Licensee Should Be Ordered to Give Proper Answers to Encl Interrogatories.Supporting Documentation Encl ML20043C7211990-06-0101 June 1990 Motion to Compel Answers to Interrogatories,Vermont Yankee Nuclear Power Corp Set 3.* Certificate of Svc Encl ML20043C2881990-05-22022 May 1990 State of VT Answer in Opposition to Vermont Yankee Nuclear Power Corporation Second Motion to Compel & State of VT Application for Protective Order.* Board Should Deny Util Motion & Issue Protective Order.W/Certificate of Svc ML20043A6961990-05-16016 May 1990 Reply of Vermont Yankee to State of VT Answer in Opposition to Motion to Compel & Motion for Leave to File Same.* Std Lament Featured in State of VT Final Note Has Already Been Authoritatively Rejected. W/Certificate of Svc ML20042G8281990-05-0909 May 1990 State of VT Answer in Opposition to Vermont Yankee Nuclear Power Corp Motion to Compel & State of VT Application for Protective Order.* Motion Should Be Denied.W/Certificate of Svc & Notice of Appearance ML20012F7021990-04-13013 April 1990 Motion for Reconsideration (CLI-90-04).* Reconsideration of Remand to Obtain Factual Info Requested Due to Proposed Contention Lacking Sufficient Basis & Remand Found Unnecessary & Inappropriate.W/Certificate of Svc ML20247Q7081989-09-25025 September 1989 NRC Staff Response to Necnp Request to Set Briefing Schedule.* Request Opposed on Basis That Briefing Would Only Serve to Rehash Arguments Already Addressed at Length.W/ Certificate of Svc ML20247Q4501989-09-20020 September 1989 Response of Licensee,Vermont Yankee Nuclear Power Corp,To Necnp Ltr of 890828.* ALAB-919 Should Be Summarily Affirmed or Referral Declined,Unless Aslab Misperceived Commission Policies on NEPA Undertakings.W/Certificate of Svc ML20247B4771989-07-19019 July 1989 Necnp Motion for Leave to Amend Environ Contentions 1 & 3.* Amended Basis of Contentions Should Be Admitted & Held in Abeyance Until Aslab Ruling.Certificate of Svc Encl ML20245D6251989-06-19019 June 1989 Necnp Reply to Opponents Motions to Strike Vermont Yankee Motion to Dismiss Environ Contention 3.* Board Need Not Await Aslab Decision in Order to Find That NRC Erred in Recommending Spent Fuel Pool Expansion.W/Certificate of Svc ML20245A4641989-06-12012 June 1989 NRC Staff Response to Necnp Motion for Leave to File Memorandum Addressing Significance of Recent Supreme Court Decisions & NRC Staff Response to Necnp Memorandum Addressing Significance of Recent....* W/Certificate of Svc ML20244D3661989-06-0909 June 1989 New England Coalition on Nuclear Pollution Reply to NRC Staff,Vermont Yankee & Questions of Board on Environ Contention 3.* Alternative of Dry Cask Storage Must Be Considered Due to Unresolved Conflicts.W/Certificate of Svc ML20245A7771989-06-0909 June 1989 NRC Staff Motion to Strike Testimony of G Thompson.* Thompson Testimony Considered Irrelevant & Immaterial to Any Issue in Proceeding.Testimony Should Be Stricken & Environ Contention 3 Dismissed ML20245A7881989-06-0909 June 1989 NRC Staff Reply to Briefs of Necnp & Vermont Yankee on Environ Contention 3.* NRC Has Met Proof on Environ Contention 3 & Entitled to Decision in NRC Favor on Contention as Matter of Law ML20244D5231989-06-0909 June 1989 Memorandum of Vermont Yankee Nuclear Power Corp in Support of Motion to Strike & to Dismiss & in Response to Board Questions.* Facts Demonstrate That Environ Contention 3 Deemed Invalid & Should Be Dismissed ML20244D5401989-06-0909 June 1989 Motion to Strike Necnp Testimony Submitted on Environ Contention 3 & to Dismiss Environ Contention 3 for Lack of Contest.* ML20245A7981989-06-0909 June 1989 NRC Staff Response to Licensing Board Memoranudm (Issued for Consideration at 890621 Oral Argument), .* Discusses Environ Contention 3.W/Certificate of Svc ML20247K8171989-05-25025 May 1989 NRC Staff Response to Necnp Memorandum on NUREG-1353 & NRC Staff Response to Necnp Motion for Leave to File Memorandum on NUREG-1353.* LBP-89-06 Should Be Reversed Due to Necnp Argument Reiterating Other Arguments.W/Certificate of Svc ML20247L0561989-05-25025 May 1989 Necnp Motion for Leave to File Memorandum Addressing Significance of Recent Supreme Court Decisions.* Recent Cases Cited by Applicant Have No Bearing on Instant Proceeding.W/Certificate of Svc ML20247K9671989-05-25025 May 1989 Necnp Motion for Leave to File Memo Addressing Significance of Recent Supreme Court Decisions.* Requests Leave to File Memorandum Addressing Significance of Recent Supreme Court Decisions.W/Certificate of Svc ML20247F3871989-05-23023 May 1989 Advice to Board Re Commonwealth of Ma Position Re Dry Cask Storage.* Commonwealth of Ma Atty General Joins in Arguments in Necnp 890523 Summary of Facts & Arguments That Will Be Relied on Re Environ Contention 3.W/Certificate of Svc ML20247F4841989-05-23023 May 1989 NRC Staff Brief & Summary of Relevant Facts & Arguments on Which Staff Intends to Rely at Oral Argument on Necnp & Commonwealth of Ma Environ Contention 3.* No Issue of Matl Fact in Contention Exists.W/Certificate of Svc ML20247F6131989-05-23023 May 1989 Necnp Brief & Summary of Relevant Facts & Arguments on Which Necnp Intends to Rely at Oral Argument on Environ Contention 3.* ML20247L5151989-05-23023 May 1989 Memorandum of Vermont Yankee Nuclear Power Corp on Existence of Genuine & Substantial Question of Fact Re Environ Contention 3.* Contention Considered Invalid & Should Be Dismissed ML20246H4781989-05-10010 May 1989 Necnp Memorandum on NUREG-1353.* Addresses NUREG-1353 Applicability to Case in Response to Applicant & NRC Arguments.W/Certificate of Svc 1998-05-27
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UNITED STATES OF AMERICA 'g g 3 A939 NUCLEAR REGULATORY COM'MISSION iFT.y #
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vG.V 4ra n tr r ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of )
)
VERMONT YANKEE NUCLEAR ) Docket No. 50-271-OLA POWER CORPORATION )
) (Spent Fuel Pool (Vermont Yankee Nuclear ) Expansion)
- Power Station) )
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MEMORANDUM OF i VERMONT YANKEE NUCLEAR POWER CORPORATION {
ON THE EXISTENCE OF ANY GENUINE AND SUBSTANTIAL i QUESTION OF FACT REGARDING CONTENTION 1 I SWORN WRITTEN TESTIMONY OF DONALD A REID, JOHN T. HERRON, JAY K. THAYER, CHRISTOPHER H. HANSEN, AND PAUL A. BERGERON, SUBMITTED BY VERMONT YANKEE NUCLEAR POWER CORPORATION PURSUANT TO 10 C.F.R. g 2.1113(A) .
J John A. Ritsher R. K. Gad III Ropes & Gray One International Place Boston, Massachusetts 02110 Telephone: 617-951-7000 February 28,1989.
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8903100194 890228 m l PDR ADOCK 05000271 '/ l g PDR i
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UNITED STATES OF Ah1 ERICA NUCLEAR REGULATORY COSINilSSION before the ATOhlIC SAFETY AND LICENSING BOARD
)
In the Matter of )
)
VERMONT YANKEE NUCLEAR ) Docket No. 50-271-OLA POWER CORPORATION )
) (Spent Fuel Pool (Vermont Yankee Nuclear ) Expansion)
Power Station) )
)
51Eh10RANDU51 OF VERhf0NT YANKEE NUCLEAR POWER CORPORATION ON THE EXISTENCE OF ANY GENUINE AND SUBSTANTIAL QUESTION OF FACT REGARDING CONTENTION 1 Pursuant to 10 C.F.R. Q 2.lll3(a) and the Memorandum and Order of this Board dated January 10, 1989, the Licensee in this matter, Vermont Yankee Nuclear Power Corporation (" Vermont Yankee"), submits this memo-randum containing what it believes to be all the relevant facts, data and argument on the validity of Contention 1. Vermont Yankee contends that Contention I is incorrect and should be dismissed on the merits.
I. THE NATURE OF TIIE PROCEEDINGS, A. The Proposed Amendment.
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Vermont Yankee Nuclear Power Station ("VYNPS") is a boiling water I
{
reactor located in Vernon, Vermont. When originally licensed in 1972, the )
VYNPS spent fuel pool had a capacity of 600 spent futi assemblies. Li 1977, the capacity of the VYNPS spent fuel pool was expanded to 2,000 spent fuel assemblics. Verment Yankee Nuclear Pcwer Corporation (Vermont Yankee Nuclear Power Station, ALAB-455, 7 NRC 41 (1978), aff'd in relevant part sub nom. Minnesota v. NRC, 602 F.2d 412 (D.C. Cir.1979). In April of 1986, Vermont Yankee submitted to the NRC Staff an application for an operating
license amendment to increase the maximum authorized spent fuel storage capacity to 2,870 spent fuel assemblies. This proposed expansion, as the previous one, will be effected by the substitution of new racks that would permit the storage of a greater number of spent fuel assemblies in the same spent fuel pool. As originally proposed, only the design of the racks would have changed; in all other respects the VYNPS spent fuel pool and associated systems would have remained identical.
In May,1987, this Board admitted Contention 1, which challenges the adequacy of the heat removal capacity of the existing VYNPS spent fuel pool cooling system, given the supposedly higher heat loads to be imposed upon the pool by the expansion.1 In an effort to moot the contention, the Licensee committed to the NRC Staff that, prior to any reliance upon the authority to exceed the existing 2,000 spent fuel assembly limit, it would install an additional spent fuel pool cooling sub-system, which provides for two additional cooling trains of even larger capacity than is available given the existing system. It was, and remains, the position of Vermont Yankee that this spent fuel pool cooling system enhancement is not necessary to defeat Contention 1, that is to say, that the contention is invalid whether or not the enhancement is installed.
B. The Contention.
The admitted contention reads as follows:
"The spent fuel pool expansion amendment should be denied because, through the necessity to use one train of the reactor's residual heat removal system (RHR) in addition to the spent fuel cooling system in order to maintain the pool water within the
[ design] limits of [150*FJ, the Single-failure criterion as set forth in the General Design Criteria, and particularly Criterion 44, will be violated. The Applicant has not established that its proposed method of spent fuel pool cooling ensures that both the fuel pool cooling system and the reactor cooling system are single-failure proof."
i I i Siace the bulk of the peak heat load ever imposed upon a spent fuel pool comes from the recently discharged assemblies, and since the effect of a pool expansion is to increase the number of old assemblics in the pool, the supoosed increase in heat ioads is, in reality, quite small. See Licensee's Direct Testimony. Exhibit f. A 44% increase in spent f uel pool inventory l produces only a 12% increase in heat load.
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Vermont Yankee Nuclear Power Corporation (Vermont Yankee Nuclear Power Station), ALAB-869, 26 NRC 13, 20, 23 (1987). The " basis" for the conten-tion was succinctly stated thus:
"Should this amendment be approved, it would be necessary under certain conditions to use one train of the reactor's residual heat removal system (RHR) in addition to the spent fuel pool cooling system in order to maintain the pool water within the design limits of 150"F. . . . The heat load in the pool after a normal fuel discharge is roughly 50% greater than the design capacity of both trains of the spent fuel (r001] cooling system.
While Applicants assert that the two pumps in one RHR train are single active failure proof, they have not demonstrated that there is no single failure in the RHR system components and power supplies that would not disable the single train of RHR.
"Moreover, under conditions where one RHR train is needed for spent fuel pool cooling, there is only one train available for decay heat removal from the core. Applicants have not estab-lished that this leaves a single failure proof method of cooling the core.
"In summary, Applicants have not established that their proposed method of spent fuel pool cooling ensures that both the fuel pool cooling system and the reactor cooling system are single failure proof.as The contention was apparently borne of some (i) misunderstanding about the heat removal capacity of the existing VYNPS spent fuel pool cooling system and the loads imposed upon that system 8 and (ii) misunderstanding about a design feature that VYNPS has always had that permits one train of '
s"New England Coalition on Nuclear Pollution's Response to Board Order of February 27, 1987: Statement of Contentions and Standing" (March 30,1987) at 6-7.
8 Thus, for instance, the assertion that "[T]he heat load in the pool j after a normal fuel discharge is roughly 50% greater than the design capacity of both trcins of the spent fue! [ pool] cooling system," appears to have been {
based upon the pleader's use of FSAR figures for the heat removal capacity of the existing spent fuel pool cooling system without accounting for the difference between the reference inlet temperatures used in the FSAR and the temperatures at which the cooling system reaches its capacity. From the l
data contained in Licensee's Direct 7'estimony one can determine that the I correct values are 9.1 MBtu/hr. (at 10 days, using extremely conservative assumptions) for the beat load imposed upon the pool after the last norma' refueling that fills the pool to 2,870 spent fuel assemblies, while the cooling I capacity of the existing spent fuel pool cooling system (both trains operat-ing) is 15.5 MBtu/hr. This means that cooling capacity exceeds heat load (by about 2b%), not the revert,e.
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I
) the RHR system to be aligned to the spent fuel pool if desired. The
. proponents of the contention apparently believed that resort to the RHR to f- cure an inadequacy of spent fuel pool cooling was a regular event, and that the added heat loads of the increased spent fuel pool inventory would aggravate that situation.
As is demonstrated as a matter of technical as well as historical fact, however, that fear is not (and never has been) well taken. The VYNPS spent fuel pool cooling system, in its existing configura-
)
tion and even after degradation by the most critical single active failure, has adequate heat removal capacity to take the heat loads imposed by a normal f refueling discharge both with 2,000 spent fuel assemblies and with 2,870 spent fuel assemblies in the pool. Moreover, the proposed enhancement to the spent fuel pool cooling system adds even more cooling capacity.
Thus, in the words of the contention, there is not, never has been, and
, never will be, any " necessity to use one train of the reactor's residual heat removal system (RHR) in addition to the spent fuel cooling system in order 8
to maintain the pool water within the [ design] limits of (150*F]."
II. The Facts.
The facts upon which Vermont Yankee relies are set forth in the
" Sworn Written Testimony of Donald A. Reid, John T. Herron, Jay K. Thayer, Christopher Hansen and Paul A. Bergeron, Submitted by Vermont Yankee Nuclear Power Corporation Pursuant to 10 C.F.R. Q 2.1113(a)," submitted herewith.4 This testimony establishes the following propositions of fact, which the Board should find:
A. IIeat Loads. The most critical heat loads imposed upon the spent fuel pool cooling system are those that result from 1/3 core (normal) refueling. While the freshly discharged spent fue! assemblies have a high level of decay heat (compared to the balance of the pect inventory), the readiness of the reactor for restart requires thr.t the spent fuel pool be i
severed from the reactor fluid system, whose RHR has been cooling the l 1
combined fluid system during refueling. Licensee's Direct Testimony at 6. '
The magnitude of this heat load depends upon the interval between when the nuclear reaction was shut down and when the, reactor is ready for )
4 This document is hereinafter referred to as " Licensee's Direct Testimony."
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restart. Licensee's Direct Testimony at 14. The historical average refueling outage duration at VYNPS has been 44 days, and the most rapid normal refueling still took 25 days.3 Licensee's Direct Testimony at 14. As one element of conservatism,8 the heat loads are calculated as if all of this were performed in 10 days. Id. At the 10-day point, the heat load on the spent fuel pool is 8.12 million Btus per hour ("MDtu/hr.") given a pool containing 2,000 spent fuel assemblies, and 9.1 MBtu/hr. given a pool containing 2,870 spent fuel assemblies. Licensee's Direct Testimony at i1.
Any cooling system with a capacity equal to or greater than the heat load on the pool will cause the water in the spent fuel pool to maintain temperature or decline in temperature.7 While greater heat loads are imposed upon the pool by full-core discharges, the spent fuel pool cooling system need not be relied upon to provide spent fuel pool cooling in such a case. Licensee's Direct Testimony at 6.s 3
Outages that involved fuel movements of fewer than a normal refueling have taken, at the minimum,18-21 days. Of course, the heat loads imposed upon the spent fuel pool cooling system by restart following these " fuel movement" outages have been even less than those imposed by a normal I refueling.
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6 i As is set forth in the Licensee's Direct Testimony, a number of I conservative assumptions are made in order to exaggerate the heat load l
imposed on the cooling system. These include assuming an extremely rapid !
refueling (more than twice as quickly as has been historically achievable), a l conservatively long fuel cycle, a higher power level than the reactor is licensed for and an impossibly high cumulative capacity factor. Licensee's Direct Testimony at 9-10.
7 The temperature of the water in the pool is determined by the algebraic sum of the heat added to the water less the heat rejected from the water to some other medium. Although (for conservatism) no credit is taken for it, some heat is always rejected to the atmosphere through evaporation.
Therefore, if the heat load imposed by the spent fuel and the heat removal capacity of the spent fuel pool cooling system were exactly equal, the bulk l water temperature in the pool would decline.
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8 1n addition, as demonstrated by the words of the contention and the words of its associated basis, the contention is (properly) limited to the effect of normal,1/3 of tht core refueling, followed by restart.
h B. The Heat Removal Capacity Atallable. I
- 1. The Existing Cooling System. The existing VYNPS spent fuel pool cooling system consists of two pumps and two heat exchangers. Licen- l see's Direct Testimony at 7. The heat exchangers are configured such that l
J either can be aligned to either of the pumps, resulting in three possible 'l configurations of the system. Licensce's Direct Testimony at 7 As the heat I
I exchangers are passive components (while the pumps are active components),
the most critical single active failure results in a one pump - two heat exchangers configuration. Licensee's Direct Testimony at 7 In this !
configuration, the heat removal capacity of the existing spent fuel pool l cooling system is 9.1 MBtu/hr. Licensee's Direct Testimony at 8-9.8
- 2. The Enhanced Cooling Sub-System. The enhancement to the j
spent fuel pool cooling system proposed by Vermont Yankee adds to the existing system a two-loop standby sub-system. Licensee's Direct Testimony f
at 15-17 Each of these'two loops is entirely redundant and each has a heat i I
removal capacity of 11.0 MBru/hr.18 Licensee's Direct Testimony at 16.
j Thus, the heat removal capacity of the spent fuel pool cooling system, with the enhancement, is substantially increased.
C. Use of the RHR System for Spent Fuel Pool Cooling Enhancement. !
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As noted above, Contention I seems to have been borne of the misimpression f
that resort to the RHR for augmented spent fuel pool cooling on account of 8
While the spent fuel pool water temperature is normally held at a lower value, the licensing condition applicable to VYNPS specifies a limit of q 150*F. Licensee's Direct Testimony at 9. All other things equal, the heat removal capacity of a heat exchanger increases as the temperature of the water being cooled increases. Licensee's Direct Testimony at 8. Thus, as the temperature of the water in the pool increases, the heat removal capa-city of the existing spent fuel pool cooling system in any of its configura-tions increases. As the design capacity of the existing system as stated in !
the VYNPS FSAR is for references temperatures, the failure to account for the ternperatures at which the cooling system reaches its capacity will !
erroneously lead one to underestimate the capacity of the system. Licensee's l Direct Testimony at 8. j
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loLike the existing system, the enhanced sub-system is constructed so i 1
that it can operate in a one pump-two heat exchanger mode. While the cooling capacity of the system in this mode has not yet been determined with precision, it will be less than 22 MBtu/hr. but significantly more than I1 MBtu/hr. Licensee's Direct Testimony at 16.
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spent fuel pool cooling inadequacy is a common occurrence at VYNPS. The data set above demonstrates that there will not be any need for resort to
[ the RHR system to compensate for a spent fuel pool cooling system heat removal insufficiency -- with or without implementation of the emergency sub-system. In addition,16 years of operating history reveals that, in fact (and as would be expected), such resort has never been made. Licensee's j Direct Testimony at 6, l5.
I D. Compliance with the Single Fallure Criterion. As the foregoing i
Y data reflects, the existing spent fuel pool cooling system has the capacity to remove enough heat load to keep the pool water at or below 150'F after 10 days of decay following shutdown of the nuclear reaction. Licensee's Direct I
Testimony at 15,17. (In fact, during the time the proposed amendment is in force, the time required to reach the point at which the spent fuel pool load I
can be carried by the single-failure configuration of the existing spent fuel pool cooling system ranges from 6-7 days to 10 .!I days. Licensee's Direct Testimony at 15.) Since it is not necessary for the spent fuel pool cooling system to perform this task until the reactor is ready to restart," and since readiness to restart cannot occur until almost twice this 10 day period, it therefore follows that the situation of spent fuel pool cooling system I
inadequacy hypothesized in the contention cannot occur. Licensee's Direct Testimony at 17. From this it follows that the contention is without merit an'd must be dismissed.
The scenario on which the contention posits a violation of the single failure criterion cannot happen for another, independent reason. As stated !
in the Contention, the theory of the Contention is that, on account of a !
v heat removal capacity inadequacy, resort to the RHR to cool the independent spent fuel pool must be made. Either the necessity of such resort renders the spent fuel pool non-compliant with the single failure criterion (so the Contention goes) or the use of the RHR for this purpose (leaving only one train of RHR on the reactor) leaves the reactor non-compliant with tne single failure criterion. However, the VYNPS Technical Specifications "During refueling, both RHR system trains are availatle to cool the sper.t fuel pool and the reactor, as a single fluid system. Licensee's Direct f Testimony at 5. i l
1 require that both trains of the RHR be available for the reactor in' order to restart the reactor. Licensee's Direct Testimony at 6. Thus, even were the contended-for scenario to occur (which the data says won't happen and which history demonstrates has never happened), the reactor cannot be I
restartad.18 f ;
Conclusion I 1
For the foregoing reasons, the facts established beyond any genuine and l
substantial dispute demonstrate that Contention 1 is invalid and should be l, dismissed. i i
ully submitted,
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John A. Ritsher R. K. Gad III
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Ropes & Gray One International Place Boston, Massachusetts 02110 Telephone: 617-951-7000 February 28, 1989.
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12 Even more distended is the notion that the heat removal capacity Ij deficiency in the spent fuel pool first develops after the reactor has been started. This would appear to be impossible, since the only way to increase the heat load on the pool is to off-load teeut fuel assemblies into the pool.
Once the reactor h.is been started, the progression of spent fuel assembly-generated heat in the pool is alwayt decret. sing.
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