ML20113H732
| ML20113H732 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 01/21/1985 |
| From: | Jaime Rodriguez NEW JERSEY, STATE OF |
| To: | Public Service Enterprise Group |
| References | |
| CON-#185-252 OL, NUDOCS 8501250286 | |
| Download: ML20113H732 (18) | |
Text
F F.E!.ATED CORRESo0ND:.V
... p jW UNITED STATES OF AMERICA
<]AAl.2f "*::p NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of Public Service Electric Docket No. 50-354-OL and Gas Company (Hope Creek Generating Station)
INTERVENOR'S SECOND SUPPLEMENTAL RESPONSE TO APPLICANTS' PRELIMINARY AND FIRST SETS OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS Pursuant to the rules of practice of the Nuclear Regulatory Commission
("NRC"),.10 C.F.R Sect on 2.740(b) and (e) and the Cirders of the Atomic Safety and Licensing Board of December 21, 1983 and December 24, 1984,
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l Intervenor, the Public Advocate of the State of New Jersey ("the Public Advocate"), hereby further supplements his responses to the Applicants' Preliminary Set of Initial Interrogatories and Applicants' First Set of Interrogatories.
l APPLICANTS PRELIMINARY SET OF INITIAL INTERROGATORIES I
1.
State whether you intend to present any ' expert witnesses on the subject matter at issue in Contentions 1 through 4. If so, identify each such expert witness and further state (a) his professional qualifications; (b)-the
. subject matter on which the expert is expected to testify; (c) the substance-i
.of the facts and opinions to which the expert is expected to testify; (d) the grounds for each opinion; (e) the expert's business and residential addresses.
l-Identify by court, agency, or other body, each proceeding in which such I
individual rendered testimony on this (these) subject (s).
l-l 8501250286 850121 PDR ADOCK 05000354 C
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Response
a.
The professional qualifications of the Public Advocate's expert
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witnesses -- Dale Bridenbaugh, Richard Hubbard and Gregory Minor of MHB Technical Associates -- have been previously made available to the Applicants.
b.
Dale Bridenbaugh is expected to testify regarding the issues raised by Contention I; Dale Bridenbaugh and Richard Hubbard are ex-pected to testify regarding the issues raised by Contention II; and Richard Hubbard and Gregory Minor are expected to testify regarding the issues raised by Contention III.
c. -d.
As to Contention I, the substance of and grounds 'for Dale Bridenbaugh's expert testimony is expected to include the following:
1) his professional qualifications; 2) the nature of Intergranular Stress Corrosion. Cracking (IGSCC);
P 3) the IGSCC-countermeasures that are necessary at BWRs such as Hope Creek, including replacement of all susceptible piping with IGSCC-resistant materials, where feasible, effec-tive stress reversal processes; and effective water chemistry controls (such as a substantial reduction in the levels of ionic species entering the primary coolant and a control of oxygen levels);
4) the IGSCC-countermeasures that have been taken by Applicauts at Hope Creek, including corrosion-resistant cladding of all field welds in contact with reactor coolant in type 304-S.S piping 4 inches or more in diameter. These welds were also reportedly solution annealed and rapidly cooled; use of welding and heat treatment controls and solution heat treatment; and the removal and capping of the recirculation piping system byp, ass line before furnace solution heat treatment of the recirculation pipe spools; 5) the additional IGSCC-countermeasures that mtist be taken by Applicants at Hope Creek to mitigate IGSCC in recirculation piping, including the replacement of all IGSCC-susceptible piping and the use of effective water chemistry controls (including hydrogen water chemistry). This will include the recent replacement experience or need to replace piping at the Limerick, 'Peachbottom, Ninemile Point, Monticello, Pilgrim and Hatch generating stations; 6) the leak detection techniques, devices and standards that are necessary at BWRs such as Hope Creek, including sump monitorthg, airborne particulate radioactivity monitoring, and condensate flow rate from air coolers or monitoring of airborne m
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gaseous activities; frequent and separate monitoring of flow rates from identified and unidentified leakage sources to an accuracy of I gpm in one hour; placement of indicators and alarms for leak detection in the main control room; use of acoustic leak detection and moistdre-sensitive tape leak detection; and a commitment to use'new or improved leak detection devices or procedures as they become available; 7) the leak detection techniques, devices and standards utilized by Applicants at Hope Creek, including sump monitoring, noble gas monitoring, and drywell cooler condensate flow monitoring system; 8) the additional leak detection techniques, devices and standards that must be utilized by Applicants at Hope Creek to detect leaks in recirculation piping, including. placement of both indicators and alarms for leak detection in the main control room, use of acoustic leak detection and moisture-sensitive tape detection systems for local leak detection, ensuring that the equilibrium radioactivity for noble gases and'the buildup of background radiation levels do not impair the noble gas monitor's ability to detect a 1-gpm leak within one hour, and a commitment to use new or improved leak detection devices or procedures as they become available;
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9) the PS and ISI piping inspection programs for IGSCC detection required at BWRs such as Hope Creek, including adherence to the NRC Piping Review Committee's recommended weld inspection schedule; use of automated UT data collection, data recording and data interpretation techniques; appropriate UT personnel and procedure qualification and performance demonstration; and a commitment to the use of new or improved IGSCC detection-
. techniques, procedures and devices as they become available; 10) the PSI and ISI piping inspection program for IGSCC detection utilized by Applicants at Hope Creek, including the weld in-spection schedule, UT operator training standards; the use of remote UT scanning equipment for examination of the nozzle-to-safe end and safe end-to-piping welds; the use of automated UT data collection during mechanized scanning; and UT equipment qualification program;
. 11).
_the~ inadequacies of Applicants' PSI and, ISI piping inspection program for IGSCC detection in recirculation piping at Hope Creek,' including the inadequacies of ASME Code, Article IWB-3000 to which Applicants committed in the FSAR; the need to perform additional volumetric preservice examination of a representative sample of welds in the RHR, ECCS and contain-ment cooling heat removal systems; the need to establish Applicants' ability to effectively perform UT examination on piping welds to which corrosion-resistant cladding has been applied; the need to adhere to the NRC Piping Review 3
1 Committee's recommended weld inspection schedule; the need to utilize automated UT data interpretation techniques; the need for preservice qualification of UT personnel and pro-cedures; and the need for a commitment to the use of new or improved IGSCC detection techniques, procedures and devices as they become available.
12) summary of testimony explaining that because of the inadequacies l
in IGSCC-countermeasures, leak detection techniques, devices and standards and PSI and ISI piping inspection program for IGSCC inspection, the Applicants have failed to demonstrate that they can prevent and mitigate IGSCC in a manner that does not represent an undue risk to the health and safety of the public.
As to' Contention II, the substance of and grounds for Dale Bridenbaugh and Richard Hubbard's expert testimony is expected to including the following:
I 1) their professional qualifications; 2) the nature of the Salem events of February 22 and 25,1983; 3) the NRC's findings with respect to the Salem events of February 22 and 25,1983; 4) the management implications of the Salem events of February 22 and 25,1983, for the design, construction and operation of Hope Creek, including but not limited to the following:
a) the need for an aggressive, 'prc-active' management with foresight, attentiveness and integrity l-a forthright recognition by management that there were l
l management related causes of the Salem events and that l
this requires diligence and vigilence in ensuring operational l
safety; encouragement of all employees--especially first line supervisors--to raise perceived problems outside their immediate jurisdiction; a problem-solving approach by management; a direct involvement in plant operations by managem.ent; clearly articulated standards for all employee performance; effective and critical assessment of employee performance, l
especially with respect to their adherence to safety pro-l cedures; l-l higher standards for training; 6
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a more effective management structure; willingness of management to assume responsibility, rather than to find excuses.for failures in operation of the plant; personal accountability for management performance; encouragement of a professional " inquisitiveness" in all employees; effective and timely preventative maintenance programs; concerted action to reduce personnel operating error; identify appropraite means and techniques for prevention of the repetition of problems; elimination of " tunnel vision" on the part of all personnel, especially the engineering staff; maintenance of close surveillance to ensure that remedial measures assertedly taken prove to be effective in 4
operation; direct access of operational staff to management; the development of effective information management tools, including periodic safety indicators; use of internal and external operating experience to improve plant safety and operations; timely staffing of open positions; need for timely and effective response to NRC concerns and requirements; increased efforts to internally identify and resolve problems before being pushed by the NRC
.b) the need for a clear safety orientation by management a clear commitment at all' levels'of management to safety; the articulation and enforcement of standards for plant shutdowns; the need for effective and independent quality assurance procedures and programs, including regular atidits and inspections of all systems, incentives for thoroughness and accuracy, and inspection / audit results provided directly to key raanagement officials; 5
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l the creation of a better organized safety review structure l
and an elimination of open safety items, the creation of an effective outside safety oversight committee at the Board of Directors level, which includes a
representatives of the public; the establishment and enforcement of clear plant safety l
standards and procedures; i
l implementation of a sound safety-oriented operating attitude.
c) improvement of communication between various PSE&G departments and divisions l
eliminate " parochialism" among " support groups" such as j-engineermg and maintenance; i
create means for systematic sharing of safety-related and other operating experience; improve communication between Corporate Headquarters i
j and Nuclear Department at Artificial Island.
i 5)
The steps taken by Applicants to attempt to resolve the manage-ment implications of the Salem events of February 22 and 25, 1983, including PSE&G's Plan for the Improvement of _ Nuclear Department Operations; its Corrective Action Program, and other l
actions taken by Applicants with respect to Hope Creek; 6) the further steps that must.be taken to fully resolve the manage-l-
ment implications of the Salem events of February 22 and 25,1983, and to ensure the Applicants have achieved and will maintain the -
i technical qualifications required for the safe operation of Hope Creek. With the exception of a few changes in formal management organization, Applicant have failed to demonstrate that they have taken the substantive steps necessary to address and resolve the management implications of the Saleih-events of February 22 and 25, 1983.
Responses to interrogatories have raised serious questions about whether Applicants have established systems i
that, in operation, effectively identify and correct safety defects in a regular and systematic fashion prior to NRL' action. The responses to interrogatories, including the ones t'or which Applicants !
unsuccessfully, sought a protective order witHn the last week, still must be reviewed to assess the Applicants' acW.1 conformance with asserted and purported goals.
The manner in which management has adopted and integrated the asserted goals and standards will be explored at the depo-sitions to be conducted of key management officials. Further, an independent Hope Creek-design review, independent Hope Creek construction assessment and independent review of the 9
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operational QA program at Hope Creek must be completed and all appropriate corrective actioh taken prior to the issuance of an operating license. Finally, Applicants have failed to.
take the appropriate measures to. ensure that. safety matters at. Hope-Creek are subject to appropriate independent public oversight rather than by individuals selected by the Board of Directors.
7)
NRC standards for evaluating management. capability are functional in nature and are largely dependent on an assess-l ment of past performance. In light of PSE&G's identifiable i
management failures and deficiencies related to the Salem ATWS, the NRC should impose substantial additional require-ments, including but not limited to training and operating experience standards, quality assurance, inspection require-i ments and public oversight; 4
i 8)
' A comparison of the technical qualification of PSE&G's manage-ment, including its actions with respect to each of the items identified in numbers (4), (5) and (6) above, with other l
plants reaching the operational license stage.
e)
The business addresses of the Public Advocate's expert witnesses have been previously provided, as has the information requested regarding their prior testimony.
2.
State whether you intend to present any fact witnesses on the subject matter at issue in Contentions 1 through 4. -If so, identify each such fact.
witness and further state (a) his business and residential addresses; (b) the
. subject matter on which the witnesses is expected to testify; (c) the substance of the factual testimony which a witness is expected to offer.
Response-L As indicated in Intervenor's Response to the Applicants' Preliminary Set of Initial Interrogatories, dated January 18, 1984, the Public Advocate does not presently intend to present any fact witnesses on the subject 3
matter at issue in Contentions 1, 2 or 3.
3.
Identify by title, author, publisher and date of issurance or publica-tion, all documents that you rely upon as'a basis for your contentions or that you intend to use (by way of reference or evidentiary proffer) in presenting your direct case on Contentions 1 through 4 and all, documents to which you intend to refer in conducting cross-examination of other witnesses who may testify in connection with any such contentions'.
Response
i In his Supplemental Respon'se, dated January 4,1985, 'the Public Advocate identified 32 additional documents (or categories of documents) upon which he presently intends to rely in presenting his direct case on Contentions 1, 2 and 3.
Any additional documents upon which the
. Public Advocate will rely in conducting cross-examination can only be 7.*
identified after receipt of Applicants' responses to interrogatories regarding the substance of their experts' testimony, and the documents these experts 1
will rely upon, which Applicants have indicated to Intervenor they wiu supply following receipt of these responses.
s I.
Contention 1 1.
Specify all applicable NRC regulations, general design criteria, guidelines or other regulatory requirements, or portions thereof, pertaming to the phenomenon of intergranular stress corrosion cracking ("IGSCC") which intervenor asserts are applicable to the recirculation piping installed at Hope Creek.
Response
Six additional regulatory requirements were identified by the Public Advocate in his Supplemental Response dated January 4,1985.
The Public Advocate asserts that following additional provisions are also applicable:
a)
G.D. C. 30-32 b)
R. G. 1. 50
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c)
A.S.M.E. Code Section XI, Subarticle IWA-1500 d) 10 C.F.R. 50.55(a) 2.
Specify each section of the Hope Creek Final Safety Analysis Report ("FSAR"), including Applicant's reponse to staff questions, which intervenor asserts is relevant to the consideration of the phenomenon <>f IGSCC in recirculation piping and specify, to the extent applicable, any failure to meet the regulatory, requirments set forth in response to Interrogatory 1 above.
Response
Six additional Hope Creek FSAR sections were identified by the Public Advocate in his Supplemental Response dated January 4,1985.
The Applicants' failure to meet applicable NRC regulatory requirements is addressed by Intervenor's Second Supplemental Response to Interrogatory 1(c) and (d) of Applicants' Preliminary Set of Initial Interrogatories.
3.
State ~ the basis upon which intervenor relies for its_ assertion 'that Type 304 austenitic stainless steel piping in the reactor coolant pressure boundary
-of boiling water reactors is " highly" susceptible to stress corrosion cracking.
Response
The Public Advocate fully responded to this interrogatory in his Supplemental Response dated January 4,1985. In particular, the 8
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Public Advocate relies upon the conclusions contained in NUREG-1061 and the studies referenced therein.
4.
Specify and describe in detail in what way the Applicants have failed to demonstrate that they can prevent and' mitigate IGSCC in accordance,.
with 10 C.F.R. Part 50, Appendix A, Criterion 40, in the recirculation piping installed at Hope Creek.
Response
The Applicants' failure to demonstrate that they can prevent and mitigate IGSCC in recirculation piping is specifically addressed in the Public Advocate's Second Supplemental Response to Interrogatory 1(c) and (d) of the Applicants' Preliminary Set of Initial Interrogatories.
5.
Define " critical" as it is used in Contention 1.
Response-As used in Contention 1, " critical" means "such structures, systems or components the failure of which could affect their important-to-safety and safety-related functions."
6.
Specify what recirculation piping intervenor considers to be
" critical."
R.esponse -
The recirculation piping that Intervenor considers to be " critical" was specified in the Public Adovcate's First Response to Interrogatory I. 6 of Applicants' First Set of Interrogatories.
7.
Spegify what critical recirculation piping has not been identified by
- Applicants as susceptible to IGSCC.
Response
i.
Applicants' have identified all recirculation piping at Hope Creek that is susceptible to IGSCC.
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-8.
Specify the basis upon which intervenor relies. for the assertion that connections to the decay heat removal system are critical piping.
Response
The Public Advocate specified the basis for his assert on that connections to-the ' decay heat removal system are critical piping in his j
First Response to Interrogatory I. 8 of Applicants' First Set of Interrogatories.
j 9.
Specify the regulatory requirement and/or any other basis for intervenor's assertion that all recirculation piping susceptible to IGSCC must be replaced.
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Response
The basis for the Public Advocate's assertion that all recirculation piping susceptible to IGSCC must be replaced was provided in his First Response and Supplemental Response to Interrogatory I. I of Applicants' First ' Set of Interrogatories.
- 10. Specify the conditions under which intervenor asserts replacement is feasible.
Response
Replacement of all susceptible recirculation piping is " feasible" within the meaning of Contention 1 at any time prior to start-up or at any time during a shut-down of the plant.
- 11. Specify all preventative measures intervenor asserts Applicants should take prior to start-up.
Response
In addition to replacement of all susceptible piping and the steps Applicants have already taken with respect to stress-reversal, Applicants must provide for effective water chemistry controls, including hydrogen water chemistry.
See Intervenor's Second Supplemental Response 'to Interrogatory 1(c) and (d) of Applicants' Preliminary Set of Initial Interrogatories.
l 12.
Specify the preventive measures intervenor asserts should be taken prior to start-up for each designated " critical" component of recirculation piping but which have not yet been taken.
Response
l See Response to Intbrrogatory I.11 (above).
- 13. Specify the deficiencies intervenor alleges exist in the Applicants' j
system for identification of cracks in recirculation piping after start-up.
Response
l The deficiencies that exist in Applicants' system for crack identi-fication in recirculation piping after start-up include:
failure to place both indicators and alarm for leak detection in the main control room; failure to use acoustic leak detection and moisture-sensitive tape 4
detection systems for local leak detection; O
e e
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f inability to ensure that the equilibrium radioactivity for noble gases and the buildup of background radiation levels do not impair the noble gas monitor's ability to detect a 1-gpm leak within one hour; the need for a commitment to use new or improved leak detection devices or procedures as they become available; i
i the need to perform additional volumetric preservice examination l ~
of a representative sample of welds in the RHR, ECCS and contamment cooling heat removal systems; the need to establish Applicants' ability to effectively perform l
UT examination on piping welds to which corrosion resistant cladding has been' applied; j
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the need to adhere to the NRC Piping Review Committee's recommended weld inspection schedule; the need to utilize automated UT data interpretation techniques; i
the need for preservice qualification of UT personnel and I,
procedures; and the need for, a commitment to the use of new or improved IGSCC detection techniques, procedures and devices as they become available.
[.
- 14. Specify those inspection techniques, other than manual ultrasonic testing, which intervenor asserts Applicants should use to identify recir-culation piping susceptible to IGSCC after start-up.
Response.
i Applicants should use automated UT data collection,-data recording and data interpretation techniques to inspect all recirculation piping for i'
j IGSCC.
Applicants should also commit to utilize all new or improved j
inspection techniques as they become available See Intervenor's Second i
Supplemental Response to Interrogatory 1(c) and (d) of Applicants' Pre-ll liminary Set of Initial Interrogatories. '
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II.
Contention 2 1.
Define " management implications" as used in this contention.
Response
t In addition to the definition provided in the Public Advocate's First Response to this interrogatory, " management implications" as used in Contention 2 means "the management lessons suggested as reasonably to be inferred, implied or understood."
2.
Specify each and every respect in which intervenor claims that PSE&G management in the administrative, procurement, maintenance and quality assurance programs for the Hope Creek Generating Station, as of this date, fails to meet all applicable regulatory require-i ments and license conditions imposed by the NRC.
Response
t The Public Advocate identified each respect in which PSE&G's management in the administrative, procurement, maintenance and quality assurance programs for the Hope Creek generating station fails to meet all regulatory requirements and license conditions as of this date in his Second supple-I mental Response to Interrogatory 1(c) and_(d) of Applicants' l
Preliminary Set of Initial Interrogatories.
3.
As to each alleged deficiency, specify the applicable NRC requirement and/or license condition and describe in detail:
I a)
The applicable NRC regulatory requirement or license condition; l
b)
The precise.; management function (s)calleged to be deficient; c)
The names and/or job titles of the particular PSE&G management officials with responsibilities for preventing or eliminating the deficiencies alleged; d)
The acts or omissions performed by such individuals',
identified by name or title, upon which intervenor relies in asserting that management deficiencies exist, including the. date (s) of occurrence; l
e)
The actions which should have been taken by such manage-i ment officials identified above in order to prevent or eliminate.the alleged management deficienciesp f)
All actions which intervenor contends must be taken with respect to.PSE&G management prior to the issuance of an operating license for the Hope Creek Generating Station.
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Response
a)
The applicable NRC regulatory requirements or license conditions relevant to Contention 2 were provided by the Public Advocate in his First Response and Supplemental Response to this interrogatory.
b)
The precise management functions alleged to be deficient were identifed by the Public Advocate in his Second Supplemental Response to Interrogatory 1(c) and (d) of Applicants' Preliminary Set of Initial Interrogatories.
c)
The following PSE&G management officials are responsible for preventing or eliminating the deficiencies identified above:
(1)
Management Aggressiveness.
Harold Sonn R.M. Eckert R.A. Uderitz J.T. Boettger R.A. Burricelli R. Salveson S. LaBruna M. Midura L.A. Reiter J. MacKinnon C. Johnson' G.C. Connnor H.D. Hanson (2)
Safety Orientation Harold Sonn R.M. Eckert R.AI. Uderitz J.T. Boettger R.A. Burricelli R. Salveson S. LaBruna M. Midura J. MacKinnon
'Cl. Johnson G.C. Connor H.D. Hanson (3)
Communication Harold Sonn-R.M. Eckert R.A. U6eritz J.T. Roettger R.A. Burricelli R. Salveson S. LaBruna M. Midura
- 13. -
C. Johnson i
G.C. Connor L.A. Reiter H.D. Hanson d)
The Public Advocate is completing his review of the thousands.of pages of documente received in the past few i
weeks to specifically identify any acts or omissions of the l
individuals identified above.
.Other information along these lines will be sought during the deposition of key i
management officials.
Intervenor reasserts that many of the identified management defects and deficiencies consti-tuting the management implications of the Salem events have not to.date been attributed to specific indivdual's by the NRC, Applicants' experts or by Intervenor, but represent fundamental flaws permeating the operation and attitude of PSE&G's management.
e) and f)
The actions that should have been taken by these management officials in order to prevent or eliminate the alleged management deficiencies and those that must be taken prior to the issuance of an operating license for the Hope Creek generating station have been identified _by the Public Advocate in his Second Supplemental Response to Interrogatory 1(c) and (d) of Applicants' Preliminary Set of. Initial Inter-
+
rogatories.
4.
If intervenor contends that PSE&G is not technically qualified to engage in the activities to be authorized by an operating license for the Hope Creek Generating Station within the meaning of 10 C.F.R. 550.57 (a) (4), specify and discuss'in detail:
a)
The particular aspect as to which PSE&G lacks technical qualifications; b)
The extent to w ich intervenor's claba is based upon any portion of the record of the application and, if so, identifying the particular portion (s).thereof; c)
All actions which must be.taken by PSEEG in order to '
eliminate any alleged deficiencies in its technical qualifi-cations asserted above.
Response
The failure by Applicants-to adequately address and resolve in a functionally effective manner the management implic'ations of the Salem e. vents of February 22 and 25, 1983 renders it.
technically unqualified to operate the Hope Creek generating station The particular respects in which it has failed.to act and the actions which must be taken to eliminate these deficiencies haVe been identified by the Public Advocate in his Second Supplemental Response to Interrogatory 1(c) and (d) of Applicants' Preliminary Set of Initial Interrogatories.
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The management implications of Salem require PSE&G to take actions that are not only formally appropriate but are
-functionally effective.
Recent discovery requests by the Intervenor to which the Applicant unsuccessfully sought a protective order have been directed at obtaining the docu-mentation and records that would reflect the actual operations of the asserted remedial organizational structures of PSE&G.
These responses and documents have not yet been received from the Applicants.
5.
To the extent that intervenor relies upon the reactor trip circuit breaker failure at the Salem Nuclear Generating Station, Unit 1, on February 22 and 25, 1983, including all investigative and enforcement actions undertaken by the NRC with respect to those events, specify and describe in detail:
a)
Each particular finding or statement by the NRC upon which intervenor relied to establish a " management implication" for Hope Creek; b)
The regulatory requirement or standard to which such statement or finding specified above applies; c)
All actions which intervenor contends PSE&G must take with respect to each such statement or finding specified above in o'rder to clbninate the alleged " management im-plication."
Response
The Public Advocate has fully responded to this inter-rogatory in his First Response and in his Second Supplemental Response, to Interrogatory 1(c) and (d) of Applicant's Pre-liminary. Set of Initial Interrogatories.
III.
Contention 3
~The Public Advocate will provide the information requested
'by the Applicants' five interrogatories on this. contention after receipt of certain outstanding information and discovery requests from Applicants.
See Order dated December 24, 1984, of the Atomic
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Safety and Licensing Board at 2 n. 1.
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9 STATE OF NEW JERSEY)) ss:
COUNTY OF MERCER
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JOSEPH H. RODRIGUEZ, being first sworn, deposes and states:
That he is the Public Advocate of the State of New Jersey, the Intervenor herein; that he has read the foregoing Intervenor's Second Supplemental Response to Applicants' Preliminary and First Set of Interrogatories and knowsMhe contents thereof; and.that the statements and matters set forth therein are true and correct to the best of his knowledge information and ief.
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/ OSE(H W. RODRIGUEZ
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UBLIC ADVOCATE OF THE I
IATE OF NEW JERSEY t.
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l Sworn to and Subscribed to before me this // /6 day of
, 1985.
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t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION y-Before the Atomic Safety and Ilcensing Board D ?if PUBLIC SERVICE ELECTRIC
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AND GAS COMPANY Docket No. 50-354-OL (Hope Creek Generating Station)
CERTIFICATE OF SERVICE I hereby certify that copies of Intervenor's Second Supplemental Response To Applicants' Preliminary And First Sets Of Interrogatories And Request For Production of Documents" and "Intervenor's Response To Applicants' Motion For Sactions" dated January 21, 1985, in the above-captioned matter have been served upon the following by deposit in the United States mail on this 21tst day of January,1985:
- Marshall E. Miller, Esq.
Atomic Safety and Licensing Chairman Appeal Panel.
Atomic Safety and Licensing U. S. Nuclear Regulatory Board Panel Commission.
U. S. Nuclear Regulatory Washington, DC 20555 Commission l
East-West West Building Docketing and Service West Tower, Room 408 Section 4350 East-West Highway Office of the Secretary Bethesda, Maryland 20814 U. S. Nuclear Regulatory Commission
. *Dr. Peter A. Morris Washington, DC 20555 i
l Atomic Safety and Licensing Board Panel
- Lee Scott Dewey, Esq.
U. S. Nuclear R'egulatory Office of the Executive Commission Legal Director East-West West Building U. S. Nuclear Regulatory West Tower, Room 408 Commission 4350 East-West Highway Washington, DC 20555 Bethesda, Maryland 20814
- Federal Express
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A Dr. David R. Schink Texa A & M University Oceanography & Meteorology Building Room 716 College Station, Texas 77840
- Richard Fryling, Jr., Esq.
Associate General Counsel Public Service Electric & Gas Company P. O. Box 570 (TSE)
Newark, NJ 07101
- Troy Conner, Jr., Esq.
Conner & Wetterhahn 1747 Pennsylvania Ave., N.W.
Suite 1050 Washington, DC 20006 Peter Hess, Esq.
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Dept. of National Resources and Environmental Control Legal Office 89 Kings Highway Dover, DE 19901 Mr. Een Koschek Planning Group Department of Environmental Protection State of New Jersey CN-402 Trenton, NJ 08625 A
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[ RICHARD E. SKAPIRO i
l January 21, 1984 I
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