STATE OF
PUBLIC
SERVICE BOARD
August 22, 2008 Docket No. 7440
Petition of Entergy
Nuclear
LLC, and Entergy Nuclear Operations, Inc.,
for
amendment of their Certificates of Public
Good
and other approvals required under 10 V.S.A.
§§ 6501-6504 and 30 V.S.A. §§ 231(a), 248
&
254, for authority to continue after March
21,
2012, operation of the Vermont Yankee Nuclear
Power Station, including the storage of spent
nuclear
Fuel
FIRST SET OF INFORMATION REQUESTS
SERVED UPON ENTERGY NUCLEAR:
New England
Coalition,Inc. (“NEC”) by Raymond Shadis, Pro Se Representative, hereby
serves the following First Set of Information Requests upon Entergy Nuclear
Vermont Yankee, LLC, Entergy Corporation, and Entergy Nuclear Operations, Inc.
(taken together "Entergy") in the above captioned docket in
accordance with Public Service Board Rule 2.214 and V.R.C.P.33 and 34, and
requests that Entergy answer the requests in accordance with V.R.C.P. 33 and 34
and cause to be delivered its answers and all requested documents and materials
to the New England Coalition, Inc. (“NEC”) offices in Edgecomb, Maine as soon
as practicable and in no case, per the Vermont Public Service Board’s Order of
July 22, 2008, 1ater than September 12, 2008.
Entergy is
requested to provide two complete copies of all answers; with a two
additional copies in standard electronic
format, that is, WordPerfect, Microsoft Word or electronically searchable,
extractable pdf format. Where Entergy has the requested information
in original electronic format, Entergy is requested to provide it in original
format.
INSTRUCTIONS
1. Reproduce the request being responded to
before the response per V.R.C.P.33.
2. Responses to any and all NEC requests that
are contained herein or that may be filed later should be supplied to NEC as
soon as they become available to Entergy. That is, Entergy should not hold
answers to any requests for which it does have responsive data, documents, etc, until responses to any or all other
requests are compiled.
3. V .R. C .P .33 requires the response to each
request to be made under oath by a person competent to testify concerning the
response and all documents and exhibits produced as part of the response.
With respect to each request, please state (1) the name(s) and title(s) of the
person or persons responsible for preparing the response; and (2) the
administrative unit which maintains the records being produced or maintains the
data from which the answer was prepared; and (3) the date on which each
question was answered.
4. Where information requested is not available
in the precise form described in the question or is not available for all years
(or other periods or classifications) indicated in a series of years (or other
periods or classifications), please provide all information with respect to the
subject matter of the question that can be identified in Entergy work papers
and files or that is otherwise available.
5. These requests shall be deemed continuing and
must be supplemented in accordance with V.R.C.P.26 (e). Entergy is directed to change, supplement and correct
its answers to conform to all information as it becomes available to Entergy,
including the substitution of actual data for estimated data. Responses to
requests for information covering a period not entirely in the past (or for
which complete actual data are not yet available) should include all actual
data available at that time and supplementary data as it becomes available.
6. Wherever responses include estimated
information, include an explanation (or reference to a previous explanation) of
the methods and calculations used to derive the estimates.
7. Some of NEC's requests may make particular
reference to a portion of Entergy's filing. Notwithstanding this specific
direction, these items should be understood to seek discovery of all
information available to Entergy that is responsive to the questions stated.
8. "Identify," when used in connection
with natural person(s) or legal entities, shall mean the full name and current
business address of the person or entity.
9. "Document," as used herein, shall
be construed as broadly as possible to include any and all means and media by
which information can be recorded, transmitted, stored, retrieved or
memorialized in any form, and shall also include all drafts, versions or copies
which differ in any respect from the original. All spreadsheets provided must
have all formulae intact and accessible.
10. "Petition,
" as used herein, means Entergy's petition filed with the Vermont Public
Service Board in this docket, unless the context indicates otherwise.
11. With respect to each document produced by
Entergy identify the person who prepared the document and the date on which the
document was prepared.
12. If any interrogatory or request requires a
response that Entergy believes to be privileged, please state the complete
legal and factual basis for the claim of privilege, and provide the information
required by the 5/16/95 order in Docket No.5771 and respond to the parts of the
interrogatory or request as to which privilege is asserted.
13. If any interrogatory or request is objected
to in whole or in part, please describe the complete legal and factual basis
for the objection, and respond to all parts of the interrogatory or request to
the extent it is not objected to. If an objection is interposed as to any
requested documents, please identify the document by author, title, date and
recipient(s), and generally describe the nature and subject matter of the
document as well as the complete legal and factual basis for the objection.
14. To expedite the discovery process and the
resolution of this docket, Entergy should contact NEC as soon as possible, and
prior to the above deadline for response, if it seeks clarification on any of
these information requests.
15. If Entergy believes that any of the
information requested has already been provided to New England Coalition please
identify the information that Entergy believes to be responsive by title,
location, author, date, and document and/or index number.
16. NEC reserves the right to submit additional
information requests to Entergy.
INTERROGATORIES AND REQUESTS TO PRODUCE
1. Please identify all executives,
managers, employees, contractors, contract employees and consultants who have
had any part in planning, evaluating, or analyzing the proposed extended period
of operation for Vermont Yankee Nuclear power Station that is the subject of
this docket. Please provide the titles, business or department affiliation and
business address contact information for each
a.
For each
of the above named individuals, please provide a job description and/or a
description of that individual or entity’s responsibility, or function with respect
to the proposed extended period of operation
b.
In the
case of contract employees, contractors, and/or consultants, please provide a
copy of the contract relevant to the proposed extended period of
operation; together with a description of the services provided or to be
provided.
c.
Please
provide a list of the individuals to whom the above named individuals or
entities report and/or from whom the above named individuals or entities take
orders or instructions. Please be certain to include, together with contact
information for the individuals listed in response to 1(b), that individual’s
title, department or section, and/or business affiliation.
d.
Please
provide an organizational chart showing how, with respect to the proposed
extended period of operation, tasks are assigned, work product is delivered,
and performance and/or work product is evaluated, resources allocated, and
decisions cast.
2. Please provide all relevant
meeting minutes, reports, work orders, quality control documents, inspection reports,
checklists, correspondence, notes and memoranda of Entergy employees, managers,
executives, working groups, departments, committees, task forces, and the like
that are or have been responsible for scheduling, engineering, designing,
interpreting, making determinations, casting decisions, and analyzing
activities related to the proposed extended period of operation.
a. Please be certain to include within the considered “working groups departments, committees, task forces, and the like,” all those entities that prepared or helped to prepare Entergy’s petition for a CPG for the proposed extended period of operation.
b. Please be certain to include within the considered “working groups, departments, committees, task forces, and the like”, boards of directors, oversight committees, and any other such entities responsible for informing, advising, or governing the activities of Entergy with respect to the proposed extended period of operation.
c. Please be certain to include documentation of the need or necessity for the proposed extended period of operation.
d. Please be certain to include within the considered “working groups, departments, committees, task forces, and the like,” all entities responsible for Entergy public and governmental outreach, information, lobbying, and public relations.
3. Please describe, and provide all
documentation for, Entergy’s consideration of all alternatives to the
proposed extended period of operation to date.
Please include a comparison of environmental impacts, costs, benefits,
and the potential for mitigation of impacts.
4. Please describe, and provide all
documentation for Entergy’s consideration of the replacement or modification of
major components or plant systems during the extended period of operation.
“Major components or plant systems” for purposes of this information request
means any component or system with a replacement cost in excess of $500,000.
a.
Please provide documentation (to date) of any surveys, examinations,
testing,
evaluations and/or analyses that Entergy has undertaken or caused to be undertaken with respect to aging, potential failure, potential necessity of
increased or modified inspection, surveillance, and maintenance of major
components and/or systems for the proposed
extended period of operation.
b. Please provide documentation for any considerations of the possible necessity of repairs or modifications of major components and/or systems during the proposed extended period of operation.
5. Please provide for the period 2006,
2007, and 2008 (to date) all condition reports, inservice inspection reports,
reports of inspections during outages, work orders, communications and/or
minutes and/or notes regarding meetings and/or teleconferences with NRC and/or
the Vermont State Nuclear Engineer; consultant reports, and corrective action
program (CAP) entries together with documents of resolutions of CAP entries
that relate to the following components and/or systems:
a. service water system
b. electrical systems (turbine hall, reactor
building, emergency or backup power supply, and switchyard.
c. condenser
d. reactor vessel
e. reactor internals
f. generator and turbines
g. steam system piping, valves, and
instrumentation
h. feedwater system piping, heaters, valves,
pumps, nozzles (reactor and heater)
i.
cooling
towers
j.
spent
fuel pool
k. fuel deck, cranes, fuel handling and/or
transfer components and structures within the reactor building.
l.
Drywell
shell and torus
m. Residual heat removal system
n. Passive fire protection (barriers, insulation,
fire wrap, etc.)
o. Drains (reactor building and turbine hall)
6. Please
provide a list of all outstanding maintenance items (maintenance items waiting
completion) on components and structures necessary to plant operation; together
with a description of each item and the function of the affected system or
structure. For each item, please state
the date that the item was first entered and the expected date of completion.
7. Please
provide any studies, evaluations, or analyses that Vermont Yankee Nuclear Power
Company or Entergy may have performed regarding the potential environmental
impact (exclusive of human health) and economic impact of a severe accident at
8. Please
provide plant steam, feed, and service water chemistry sampling and analysis
records for the period 2006, 2007, and 2008 (to date).
a. Please provide a complete and documented
characterization of dissolved or suspended chemicals, organic, and or mineral
matter in the water, including quantities, physical and chemical properties.
b. Please provide analyses, if any has been
performed, of deposition rates, corrosive, or scouring action of dissolved or
suspended chemicals, organic, and or mineral matter within the steam,
feedwater, and service water system (including torus and locations where leaks
or seepage may have occurred).
9. Please provide all
seismic analyses of systems, structures, and components that take into account
additions, modifications, changes in operating parameters, and any
unanticipated aging phenomena (including unanticipated rates of aging) that may
have taken place after original licensing.
10. From what agencies or
authorities, in addition to the NRC, VPSB, and the Vermont Legislature, must
Entergy gain approval for, or report,
a.
Please
provide copies of any applications or reports that may have been filed.
b.
Please
list anticipated dates of any filings that may be required.
c.
Please
provide copies of any such filings as they are filed if they are filed during
the course of this proceeding.
Dated this day August
22, 2008 at
New England Coalition, Inc.
Raymond Shadis
Pro Se Representative
New England Coalition, Inc. Post Office
207-882-7801