ML20080A599

First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl

ML20080A599
Person / Time
Site:	Hope Creek
Issue date:	02/02/1984
From:	Jaime Rodriguez NEW JERSEY, STATE OF
To:	Public Service Enterprise Group
References
ISSUANCES-OL, NUDOCS 8402060148
Download: ML20080A599 (9)

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s RELATED CORRES, IDEOgjTE]

UNITED STATES OF AMERICA '84 FEB -2 Pi2:10 NUCLEAR REGULATORY COMMISSION

7 Before the Atomic Safety and Licensina Board-Q':.y CF;::S' In the Matter of  :

Public Service Electric and  : Docket No. 50-354 OL Gas Company  :

(Hope Creek Generating Station)  :

PUBLIC ADVOCATE'S FIRST SET OF INTERROGATORIES'AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE APPLICANTS Pursuant to the rules of practice of the Nuclear Regulatory Commission ( "NRC ") , 10 C.F.R. 52.740(b), and the Order of the Atomic Safety and Licensing Board of December 21, 1983 and the special prehearing conference of November 22, 1983, the Public Advocate of New Jersey, Joseph H. Rodriguez ("Public Advocate") hereby propounds the following interrogatories to the applicants, Public Service Electric and Gas Company, et al., (" Applicant" or "PSE&G") which are to be answered accurately and fully in writing and under octh in accordance with the definitions and instructions below.

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.v Additionally, pursuant to 10 C.F.R. 52.741, the Public Advocate requests that the applicant provide Q copies of all documents, reports, studies, or other written ma:erial referenced or utilized by the Applicant in responding to these Interrogatories.

Definitions and Instructions

1. For each question, please identify each person providing information or assistance for the answer, pro-viding the. full name, title or position, and business address.

2. Definition: The Public Advocate relies on the same definitions provided by the Applicants in their Interrogatories propounded.ppon the Public Advocate (dated January 20, 1984),along with the following:

a. " Applicants"means Public Service Electric and Gas Company and Atlantic Electric Company, or any of'ficial, employee, or con- ,

sultant currently or formerW employed by either of the two applicant companies or any subsidiary, related, or independent company contractually obligated to the applicant, currently or formerly.

3. The Public Advocate requests all knowledge

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5 and information in the 7pplicant's possession and/or knowledge i I

and information in the possession of the $pplicant's Q agents, representatives, consultants, and unless privileged, h n

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attorneys. (.

k Contention 1: Pipe }i]a Cracks E

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1. Specify each section of the Hope Creek Final _

Safety Analysis Report ("FSAR"), including 7pplicant's f.

response to staff questions, and any amendments or updates  ;

v thereof which 7ppl.icants assert are applicable to the consideration of the Public Advocate's Contention.  ;

2. Identify and specify all meetings, conferences, :p

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studies, reports, or other documentation relied upon

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by- 7pplicants in considering"the problem of " inter-granular stress corrosion cracking ("IGSCC"). Provide i

copies of all such materials together with transcripts,  ;

minutes or notes taken during any meeting, proceedings, -

or other discussions related to the Ipplicant's response g I -

to the phenomenon of IGSCC. }5 r

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- 3. Identify all persons, officials, or con- [

E l11 sultants now or formerly employed by PSE&G to advise i

the 7pplicants on the phenomenon of IusCC. Provide i

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. O copies of any reports, studies, or correspondence wherein these persons describe, analyze, or offer recommendations 4

upon IGSCC.

4. Specify and describe in detail any mitigation measures, plans, or programs developed or under con-sideration by the A pplicants for the prevention and/or mitigation of IGSCC.

5. Identify any experts, employees, or consultants ,

i of the A pplicants that have advised or in the future will advise i the company on IGSCC, and/or will testify for the A pplicants in hearings on this contention. Provide copies ,

I of their resumes and work product.

6. Identify and describe any and all "non-con-formance reports" ("NR"), surveillance reports ("SR"), or other reports provided by contractors, subcontractors, inspectors, or other personnel associated with the purchase, delivery, installation and welding of piping at Hope Creek.

l 7. Identify all inspectors currently or t

formerly employed by the Applicants to examine Type 304 i

stainless steel piping or any other form of piping which carries coolant water.

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8. Identify the locatien of all NR's, SR's, or other inspection reports specified in Interrogatory 6, 9 supra.

Contention 2: Management Qualification

1. Provide a table of organization, showing the chain of communication and command, which the Applicants

< employ to manage the operation of nuclear plants.

2. Identify all persons, employees, officials, or consultants currently or formerly employed by the Applicants who reviewed and/or participated in the Applicants' response to the ATWS incidents at the Salem Nuclear Generating Station in February, 1983. Provide copies of all reports, studie's, recommendations, corres-pondence or other material which sets forth eneir analysis and/or recommendations regarding the Salem ATWS.

3. Identify and describe the Applicant's program .

for management of the operation and maintenance of the Hope Creek Nuclear Generating Station. Include the names and qualifications of all personnel in a management capacity and with authority to operate or oversee the operation of the Hope Creek Generating Stetion.

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4. Describe any and all operational and/or management changes instituted by the Applicants at the 9

Salem Generating Station following the ATWS of February, 1983. Identify and describe any way in which these changes will be applied to Hope Creek.

Contention 3: Environmental Qualification

1. Specify all sections of the Applicant's FSAR and any response to staff requests for information which the Applicants assert provide adequate information for ,

e the NRC to determine that safety related electrical and g mechanical equipment are environmentally qualified at  ;

i the Hope Creek Station, i 5

2. Identify any and all persons, officials, d employees or consultants with responsibility, currently or formerly for the Applicant's program of environmentally -

qualifying safety related electrical and mechanical equipment. . E

3. Identify any and all reports, studies which .

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the Applicants assert show the environmental qualification --

s-of safety related electrical and mechanical equipment at Hope Creek. In particular, identify all reports, in- -

cluding NR's, SR's, and other documentation in the possession of the Applicants which relate to environmental qualification. -

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4. Identify and describe any studies, reports, or other documentation prepared by persons or agencies not under the control or direction of the Applicants, which the Applicants have used or relied upon in qualifying I safety related electrical and mechanical equipment.

l Request for Documents Production Please attach to your answers to the above interro- I gatories a copy of all reports or other documents applicable to your answers, or upon which you otherwise intend to 5 rely in the presentation of your direct-case or in the i

examination of witnesses. Thank you for your prompt [

attention to the Public Advocate's first interrogatories. 1 .

Should you have any difficultf in responding to the E above questions, please do not hesitate to call me.

I Respectfully submitted, 5 E

JOSEPH E. RODRIGUEZ Public Advocate of the State of New gqrsey g 0 1 f li' t , 3 ,\} (i,lii-- ~~ ;K ?Q~

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By: 0  ?

R. WILLIAM POTTER C Assistant Public Advocate of "

the State of New Jersey Dated: January 30, 1984 m9.

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i UNITES STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of  :

Docket No. 50-354 OL Public Service Electric and Gas Company  :

(Hope Creek Generating Station) [ .

CERTIFICATE OF SERVICE  ;

I hereby certify that copies of the Public Advocate's First Set of Interrogatories and Request for ,

Production of Documents to the Applicants, dated January l 30, 1984 in the captioned matter have been served upon  ;

the following by deposit in the United States mail f on this 30th day of January, 1984:  ;

The Hon. Marshall E. Miller

• Theodore Granger, Esq. '

Chairman Dept of the Public Advocate Atomic Safety and Licensing Division of Rate Counsel Board Panel 744 Broad Street -

Unites States Nuclear Regulatory 29th and 30th floors Commission Newark, NJ i East-West West Building .

4350 East-West Highway, Room 408 Atomic Safety and Licensing Bethesda, Maryland 20814

Board Panel (2 copies) United States Nuclear Regulatory Commission Dr. Peter A. Morris 1717 "H" Street, N.W.

Atomic Safety and Licensing Washington, DC 20555 l Board Panel United States Nuclear Atomic Safety and Licensing Regulatory Commission Apped Panel 1717 "H" Street, N.W. United States Nuclear Washington, DC 20555 Regulatory Commission 1717 "H" Street, N.W.

Dr. James H. Carpenter Washington, DC 20555 Atomic Safety and Licensing (5 copies)

Board Panel United States Nuclear Regulatory Commission 1717 "H" Street, N.W.

Washington, DC 20555

• Sent by Federal Express i

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• 3 Docketing and Service Station Troy B. Conner, Jr., Esq.

• L?: Office of the Secretary Conner and Wetterhahn SE United States Nuclear 1747 Pennsylvania Avenue, NW 5 Regulatory Commission Washington, DC 20006

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1717 "H" Street, N.W. . (2 copies)

. Washington, DC 20555

Hon. Irwin R. Kimmelman U Lee Scott Dewey, Esq.

• Attorney General Office of the Executive State of New Jersey 3 Legal. Director Justice Complex 2 25 Market Street U.S. Nuclear Regulatory ,

Commission Trenton, NJ 08623

$ Last-West West Building 4350 East-West Highway Carol Delaney, Esq.

Bethesda, Maryland 20814 Deputy Attorney General

( copies) Department of Justice State Office Building Richard Fryling, Jr., Esq. 8th floor Associate General Counsel 820 N. French Street PUblic Service Electric m ng n, Delaware 19801 and Gas Co.

PO BOX 570 (T5E)

Newark, NJ 07101 Director, Division of Environmental Control Tatnell Building ,

Dover, Delaware 19901 9

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