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Applicant Response to New England Coalition on Nuclear Pollution (Necnp) First Set of Interrogatories & Request for Production of Documents to Applicant on Necnp Contention I.B.2.* Supporting Documentation & Certificate of Svc Encl
	ML20151A597
Person / Time
Site:	Seabrook
Issue date:	07/13/1988
From:	Trout J, Vargas J; NEW HAMPSHIRE, STATE OF, PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	; NEW ENGLAND COALITION ON NUCLEAR POLLUTION
References
	CON-#388-6729 OL-1, NUDOCS 8807200055
	Download: ML20151A597 (45)
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July 13, 1988 0FFQ. U Sc a ' i A .l 00CeliM ' 'Y i .

r UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

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PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL-1 NEW HAMPSHIRE, et al. ) 50-444-OL-1

) On-site Emergency (Seabrook Station, Units 1 and 2) ) Planning Issues

)

APPLICANTS' RESPONSE TO "NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO APPLICANTS ON NECNP CONTENTION I.B.2" Pursuant to 10 C.F.R 52.741, Applicants herein respond to "New England Coalition on Nuclear Pollution's First Set of Interrogatories and Request for the Production of Documents to Applicants on NECNP Contention I.B.2".>

GENERAL OBJECTIONS Applicant's object to the proposed definitions provided in paragraphs 2-4 of the instructions on the grounds that such definitions are overbroad and burdensome. Applicant's will "identify" drawings by number, and other documents by category or by title and date. Applicants will identify an 8807200055 880713 PDR ADOCK 05000443 0 PDR:

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1 individual by providing the individual's name, title, and l 1

business address. )

l INTERROGATORY NO. 1 For each separate interrogatory below, identify each person who participated'in any way in the development or preparation of answers thereto, and describe the information or ideas contributed by that person.

RESPONSE

Applicants object to the interrogatory to the extent that it asks for a description of "the information or ideas contributed" by each person, on the ground that such a request is burdensome and seeks privileged information.

Applicants further object to the interrogatory on the grounds that it is burdensome, as well as irrelevant, to identify every person who participated "in any way" in the development or preparation of answers.

Without waiving the foregoing objections, Applicants state that the following persons materially participated in answering the interrogatories:

Joe M. Vargas - Manager of Engineering Richard Bergeron - Instrumentation and Controls Engineering Supervisor; Gerald A. Kotkowski - Electrical Engineering Supervisor; Peter Tutinas - Project Engineer, Instrumentation and Controls The business address of each of these individuals is Seabrook Station, Seabrook NH 03874.

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i e9 INTERROGATORY NO. 2 What is your position with respect to NECNP Contention I.B.2?

REEPONSE Appli,.re*J object to this interrogatory on the ground that NECNP Contention I.B.2 is no longer the issue in litigation in these proceedings.

Without waiving the foregoing objection Applicants state their position to be that NECNP Contention I.B.2 is now moot.

INTERROGATORY NO. 3 Please identify all individuals whom you intend to call as witnesses to support your position during the proceedings regarding Contention I.B.2, and describe the substance of their testimony.

RESPONSE

Applicants object to this interrogatory on the ground that NECNP Contention I.B.2 is no longer the issue in litigation in these proceedings.

Without waiving the foregoing objection, Applicants 1

state that witnesses have not yet been selected.

INTERROGATORY NO. 4 Please identify all individuals whose affidavits you intend to submit in summary disposition proceedings regarding Contention I.B.2, and describe the substance of their affidavits.

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RESPONSE

Applicants object to this interrogatory on the ground l that NECNP Contention I.B.2 is no longer the issue in litigation in these proceedings.

Without waiving the foregoing objection, Applicants state that affiants have not yat been selected.

INTERROGATORY NO. 5 Do you continue to assert the facts and opinions expressed in the affidavits you have filed before the Licensing and Appeal Board Board (sic) following the issuance of AIAB-891? If any of these facts and opinions have changed, please identify them and describe the reasons for the changes.

RESPONSE

Subsequent review has determined that two cables (Cable No. FE2-FM4/2 and FE2-FM6/2) previously indicated as being in a mild environment and energized are in fact located in a mild environment but are spare. Therefore, there are 74 RG-58 cables located in mild environments and 21 cables designated as spares. It should be noted that this change does not alter the total number of RG-58 cables indicated (i.e., 126).

l Also, the replacement of the 12 RG-58 cables has been completed. No other facts or opinions have changed.

i l INTERROGATORY NO. 6 l

Identify all individuals on whose knowledge or opinions you relied in each of the filings before the Licensing Board l

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et and Appeal Board since the issuance of ALAB-891. For each of thosc individuals, describe that portion of the filing for which you relied on that individual.

RESPONSE

Applicants object to this interrogatory on the ground that it seeks privileged information.

Without waiving the foregoing objection, Applicants state that each affidavit was based upon the knowledge of the person making the affidavit, and that each pleading was based l

upon the opinions of law of the attorneys signing the pleading.

INTERROGATORY NO. 7 Please describe how the "electrical schematic drawing package review" described in paragraphs 6 through 8 of the Bergeron Affidavit was conducted. Did this review include examination of all 124 packages of 12,000 drawings? If so, please identify the individuals who participated in the review of the drawings, describe how long the review took, and on what dates it took place. If not, please describe the procedure by which you determined which of the 12,000 .,

drawings should be reviewed, and identify the drawings that were reviewed, j RESPONSE l

The electrical schematic drawing packages were reviewed by identifying those pages which contained the cable schematics and cable tables (approximately 4,000 of the total 1

12,000 pages). The cable schematics and cable tables were then examined to identify each application where cable code TA6Y or coaxial cable was specified. The review did include examination of all 124 packages of 12,000 drawings.

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The individuals who participated in the revier : vere:

Nirmal K. Bhowmik - Electrical Engineer; Neil F. Flanagan - Senior Electrical Designer; Edward J. Kotkowski - Instrumentation and Controls Engineer; Jane L. McCullough - Senior Electrical Designer; Thomas P. Nagle - Lead Electrical Designer; Trevor J. Pannell - Senior Electrical Designer; Vasant C. Patel - Electrical Engineer.

The business address of Thomas Nagle is Seabrook Station, Seabrook NH 03874. The business address of each of the other six is United Engineers & Constructors, Inc.,

30 South 17th Street, P.O. Box 8223, Philadelphia, PA 19101.

The review took place during the last week of Aprjl, 1988. The total time for the collection of each drawing and the associated review process was not recorded.

INTERROGATORY NO. 8 i

How many cable raceway drawings exist for the Seabrook plant?

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RESPONSE

Four hundred and forty.

INTERROGATORY NO. 9 In determining the route of each RG-58 cable, did you

( review all cable raceway drawings? If not, how many and I which drawings did you review? By what criteria did you select those drawings?

RESPONSE

I No. Because CASP had identified all of the raceway

! locations through which the 126 RG-58 cable runs were routed, it was only necessary to review 45 of the 180 cable raceway l

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drawings. Those 45 drawings contained all the information necessary to trace the cable routes. The 45 drawings reviewed are listed below.

301254 310476 301257 310478 301286 310479 301287 310496 301288 310497 301289 310498 301290 310499 301291 310500 301292 310501 301293 310688 309859 310691 310296 310694 310329 310744 310335 310746 310366 310796 310367 310797 310368 310798 310369 310799 310370 310800 310371 310801 310442 310802 310444 310803 310450 INTERROGATORY NO. 10 l Are you able to account for all 60,000 feet of RG-58 l

cable purchased under P.O. 9763-006-113-19-01? If so, how is l this accounting done, and what is the source of the data?

I RESPONSE Applicants object to this interrogatory on the ground l that it is irrelevant to the issues properly in litigation in these proceedings.

Without waiving the foregoing objection, Applicants l

state that 67,506 feet out of the 68,008 feet delivered are presently accounted for. The amount of cable delivered was 1

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verified through receipt documents and/or field inspections.

Cable footage markers on the cable itself were used to track the amount of cable cut for use in the plant. Actual usage of the amount of cable cut from the cable reels was then verified by a combination of cable pull slips, construction records and field verifications. A review to account for the final 502 feet is still in process.

INTERROGATORY NO. 11 If your answer to the preceeding (sic) interrogatory is yes, please describe the length of each used, unused, and spare cable.

RESPONSE

Applicants object to this interrogatory on the grounds that it is irrelevant to the issues properly in litigation in these proceedings. Without waiving the foregoing objection, Applicants state that the lengths are provided in Attachment 1.

INTERROGATORY NO. 12 Have Applicants performed any physical inspection of the Seabrook plant to determine the actual location of each RG-58 cable? If so, when was this done? What were the results?

RESPONSE

Yes. Applicants physically verified the locations of the end points of each of the 12 replaced RG-58 cable, as part of the process of disconnecting and replacing those cables. That physical inspection confirmed that each of these cable ends was precisely where CASP indicated it should

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be.

INTERROGATORY NO. 13 Have Applicants performed any physical inspection of the Seabro >k plant in order to verify the information yielded by the CASP data base regarding the location of each RG-58 cable? If so, whf .: was this done? What were the results?

RESPONSE

Yes. See the response to Interrogatory No. 12. In addition, the procedure (FEP-504) used for the installation-of cables during the construction phase of the project provided physical verification for the CASP Data Base regarding the location of each RG-58 cable. This procedure applied to the installation of safety, nonsafety and associated cables as specified on the CASP System. The purpose of this procedure was to define and provide the requirements and instructions for the installation and inspection of cable.

INTERROGATORY No. 14 Is the CASP data based (sic) derived from electrical schematic drawings? If so, please describe the manner in which it is derived.

RESPONSE

l The portions of CASP regarding cable code, circuit code, system, schematic drawing number, origin and destination were derived from drawings and tables in the electrical schematic j drawing packages. The CASP designer then used all this information to generate a cable number and raceway routing.

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1 INTERROGATORY NO. 15 Is there a common source of input to the electrical schematic drawings and the CASP data base? If so, what is i I

it?

RESPONSE

Those portions of the CASP data base that were derived from the electrical schematic drawing packages have the same source as the electrical schematic drawings. The principal documents which are a source of input to the electrical schematic drawing packages are the logic diagrams, P & ID's, design base calculations, vendor requirements, loop diagrams, one-line diagrams, NRC regulatory guides, Westinghouse functional diagrams, and the FSAR.

INTERROGATORY NO. 16 To your knowledge, has RG-58 coaxial cable ever been submitted to environmental qualification or other performance testing? If so, please describe the date, parameters, and results of each such test.

RESPONSE

l Applicants object to this interrogatory on the grounds l

that it is irrelevant to the issues properly in litigation in j

these proceedings.

1 Without waiving the foregoing objection, Applicants 1

state that, to their knowledge, other than the standard factory tests for compliance with specification performed by I the manufacturer prior to shipment, the only environmental qualification testing performed on RG-58 cable was conducted l

i by National Technical Systems at P.he request of the_New l Hampshire Yankee Division of Public Service Company of New Hampshire. National Technical Systems performed IEEE 383-1974 environmental qualification tests, which testing began on May 6, 1988 and was completed on June 30, 1988.

Attachment 2 hereto is National Technical Systems' letter of July 5, 1988 documenting the preliminary test results.

Attachment 3 hereto is PSNH letter (NYN-88095), dated July 12, 1988, "Environmental Qualification of RG-58 Coaxial Cable," Ted C. Feigenbaum to the United States Nuclear Regulatory Commission, containing test parameters.

INTERROGATORY NO. 17 In deciding whether a cable is environmentally qualified, do you agree that you must take into consideration i the functional performance requirements of that cable in its particular functional application? For example, do you agree that the magnitude of leakage current permissible for a cable used in a power circuit could be significantly larger than the leakage current permissible for a cable used in an instrumentation circuit?

RESPONSE

Applicants object to this interrogatory on the grounds that it is irrelevant to the issues properly in litigation in 1

these proceedings.

Without waiving the foregoing objection, Applicants state that the functional performance of a cable is only considered in determining the acceptability of that cable for a particular functional application. Differing applications i

may require different cable performance. Therefore, a cable functional performance is not a criteria in determining whether a cable is environmentally qualified, but is only used to determine the acceptability of that cable for a specific application.

The leakage current for an instrumentation circuit is more significant than for power cable applications. This is due tc the fact that the circuit current for instrumentation applications are generally 4-20 milliamps.

INTERROGATORY NO. 18 Did you evaluate the functional performance of RG-59 cable when exposed to the harsh environment in the twelve circuits where it will be used to replace the RG-58 cable?

If so, what were the results of your evaluation? If not, why not?

RES PONSE Applicant's object to this interrogatory on the ground that it is irrelevant to the issues properly in litigation in these proceedings. Without waiving the foregoing objection, Applicant's state that the functional performance results of the RG-59 cable were reviewed and found acceptable for the twelve instrument circuits exposed to a harsh environment (i.e., the results demonstrated that the cable would not short to ground). The functional performance results are documented in NECNP Exhibit 4, Reference 2.

INTERROGATORY NO. 19 What are the lengths of the twelve cables that you

J PTARINT. NH intend to replace w/ RG-59? How much of each cable length could be exposed to the harsh environment? What are the specifications for the minimum insulation resistance necessary for proper functioning of each circuit?

RESPONSE

The lengths of the twelve cables that have been replaced by RG-59 are tabulated below. The length of cable exposed to the harsh environment is unavailable. However, the length in the harsh environment is irrelevant because the entire cable length was replaced.

Approximate Cable No. Cable Lenath FM3-JW5 502 ft.

FM3-JW5/1 502 ft.

FM6-JW5 492 ft.

FM6-JW5/1 489 ft.

FM4-JX1 424 ft.

FM4-JX1/1 422 ft.

FM7-JX1 448 ft.

, FM7-JX1/1 446 ft.

l GU4-Y59/2 232 ft.

I GU4-Y59/3 232 ft.

GU4-Y59/4 238 ft.

GU4-YS9/5 232 ft.

The minimum insulation resistance necessary for the proper functioning of each circuit during normal plant operation was not specified. However, cable manufacturer data was reviewed and determined to be acceptable for each of these applications. See Affidavit of Gerald A. Kotkowski, I

served May 19, 1988, regarding the pertinent paramaters for l

l proper functioning of these circuits.

I INTERROGATORY NO. 20 For each of the 126 RG-58 cables that you have identified, you have provided broad information regarding the function of that cable. See Attachment D to the Bergeron Affidavit. However, these functions are not described in sufficient detail to allow an independent judgment as to whether they are safety or non-safety related. Please provide all additional information that is necessary for the evaluation of the specific functions served by the RG-58 cable, including what specific information is carried by each circuit. For example, please describe whether the cable carries instructions to a printer, instrument readings (including the specific instrument whose measurements are being conveyed, and the parameters that are reported), or other signals, and the significance of those signals. Please describe the source and the destination of the signals.

RESPONSE

Applicants object to this interrogatory to the extent it suggests that the Bergeron Affidavit is in any way insufficient. Applicants further object to this interrogatory on the ground that the term "all additional information that is necessary for the evaluation of the specific functions served" is too vague.

Without waiving the foregoing objections, in regards to the significance of the signals transmitted, Applicants state that each signal provides information that is helpful to plant operation but not essential for safe shutdown or accident mitigation. See Attachment 4.

1 INTERROGATORY NO. 21 For each RG-58 cable, what was the source material for the determination that functions were non-safety related?

l Please provide access to that material.

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RESPONSE

The "source material" for identifying which RG-58 cables are non-eafety related is described in Richard Bergeron's Affidavit of June 16, 1988 and the Attachments thereto, a copy of which has been served on NECNP.

Applicant's object to the request for "access to that material", on the ground that the request is inappropriate in an interrogatory. Without waiving the foregoing objection, Applicant'c will produce the material requestad.

INTERROGATORY NO. 2R Was any attempt made to determine whether P.O. 9763-006-113-19-01 is the only purchase order that included RG-58 coaxial cable? If so, please describe what was done.

RESPONSE

Applicants object to this interrogatory on the grounds that it is irrelevant to the issues properly in litigation in these proceedings.

Without waiving the foregoing objection, Applicants state that a review of Seabrook Station cable specifications verified that RG-58 coaxial cable was only received pursuant to P.O. 9763-006-113-19. Another purchase order had l

specified RG-58 coaxial cable but was subseque'tly canceled.

No RG-58 cable is on site from that purchase order.

INTERROGATORY NO. 23 l

What measures, if any, do you intend to implement to ensure that at no time during plant life will the spare RG-58 cables inadvertently become energized, for example, by l

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technician error or equipment malfunction? Please provide documentation of any measures you describe.

RESPONSE

The ends of the spare cables are physically i 1

disconnected. Reconnection of any of these cables would require the issuance of a work request in accordance with applicable Seabrook Station procedures. Thus the Seabrook Station Work Control and Design Control Programs serve to prevent the cables from inadvertently becoming energized.

Applicants object to the interrogatory to the extent

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that it asks Applicants to "prov,ide documentation", on the ground that such a request is inappropriate in an interrogatory. Without waiving the foregoing objection, Applicants will produce the material requested.

INTERROGATORY NO. 24 What is your basis for claiming that the ten cables outside the nuclear island are routed only with non-safety cables?

RESPONSE

In conjunction with tracing the route of an identified RG-58 cable, a review was performed to identify the cable (s) routed with RG-58 cable (s). This was done by means of using CASP to identify other cables sharing the raceway with the RG-58 cable (s). CASP was also used to determine whether the other cable was safety-related (i.e., Class lE) or nonsafety-l related (i.e., Non-Class lE). A review of this information verified that only non-safety cables shared these raceways.

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INTERROGATORY NO. 25 What, if any, review was done of the plant emergency procedures to determine whether all the emergency procedures can be carried out as instructed, assuming the failure of all RG-58 cables and the failure of all unqualified cables routed with RG-58 cables. Describe any such review (s). If no such review was carried out, explain the basis for deciding no such review was necessary.

RESPONSE

Applicants object to this interrogatory on the grcunds that it is irrelevant to the issues properly in litigation in l these proceedings.

1 Without waiving the foregoing objection, Applicants state that, as to that portion of the interrogatory inquiring into an emergency procedure review "assuming . . . the failure of all unqualified cables routed with RG-58 cables",

l no review was performed because there are no unqualified cables routed with RG-58 cables. As to that portion of the i

( interrogatory inquiring into an emergency procedure review

"assuming the failure of all RG-58 cables", no such review was performed or required because

. all ITT Suprenaut RG-58 coaxial cable applications

( are nonsafety-related (i.e., they do not perform an j

accident-mitigating function);

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. failure of spare RG-58 coaxial cable need not be postulated;

. failure of RG-58 coaxial cables located in a mild environment need not be postulated; 1

. for RG-58 cables located outside the nuclear island see response to Interrogatory No. 26;

. failure of the twelve coaxial cables located in harsh invironments within the nuclear island need not be postulated since the RG-59 cable is environmentally qualified.

INTERROGATORY NO. 26 In deciding that RG-58 cable exposed to a harsh environment did not need to be either qualified or replaced with a qualified cable, did you assume that all these RG-58 cables plus all cables routed w/ RG-58 cable will fail during an accident?

RESPONS,E No. Applicants' position is and always has been that all RG-58 cable is qualified. However, RG-58 cables outside the nuclear island were not replaced because no applications were identified where a safety-related cable was being routed along with the RG-58 coai:ial cable outside the nuclear island. Thus, the postulated failure of an ITT Suprenant RG-58 coaxial cable cannot prevent satisfactory accomplishment of safety functions by safety-related equipment since none of the cables it comes in contact with outside the nuclear island are safety-related (i.e., the failure could only affect another nonsafety-related cable). Therefore, the RG-58 coaxial cable outside the nuclear island is not "important to safety", the qualification requirements of 10 C.F.R. S 50.49 are not applicable and further inquiry is not required.

b INTERROGATORY NO. 27 Did you review the emergency procedures to verify that none of the functions served by the RG-58 cables are relied on in those procedures? If so, how was that review conducted and what were the results? If not, why not?

RESPONSE

See Response to Interrogatory No. 25.

REOUEST NO. 1 Please identify all documents on which you rely to support your position with respect to contention I.B2 [ sic).

RESPONSE

Applicants object to this interrogatory on the ground that NECNP Contention I.B.2 is no longer the issue in litigation in these proceedings. Without waiving the foregoing objection, Applicants state that they rely upon the pleadings that they have filed in connection with this matter, the affidavits and other materials filed with those pleadings, and all documents referenced in those pleadings, affidavits and materials.

REOUEST NO. 2 Please identify all documents which discuss or refer to whether environmental qualification is required for RG-58 cable; why it is or is not environmentally qualified; why it does or does not need to be environmentally qualified; what environmental qualification specifications, if any, have been required or considered for RG-58 cable; whether RG-59 cable meets qualification specifications or other specifications for RG-58 cable; the location of RG-58 cable in the Seabrook plant; the functions served by RG-58 cable; and whether or not those functions are considered important to safety.

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RESPONSE

Applicants object to this interrogatory on the grounds that it is irrelevant to the issues properly in litigation in these proceedings. Without waiving the foregoing objection, Applicants state that these questions are discussed or referred to in the pleadings, affidavits and rulings filed in these proceedings. In addition, see documents identified in Attachment 5.

REOUEST NO. 3 Please identify all documents relied on for purposes of answering the foregoing interrogatories.

RESPONSE

See responses to Requests No. I and No. 2, and the documents referenced in the responses to the interrogatories.

RESPONSE

Applicants object to this request on the ground that exceeds the scope of the issues properly in litigation in these proceedings. Applicants also object to the production of, and will not producc, any and all documents previously served on NECNP, and any and all documents that otherwise are publicly available.

Without waiving the foregoing objections, and with the exception noted above, Applicants will produce all requested documents which are in their possession or control.

Documents will be produced at the Seabrook Station and will be made available to HECNP or its representatives for inspection and copying at a time between 8:00 a.m. and 4:00 p.m., Monday through Friday. Please contact Mr. William J. Daley at (603) 474-9521 Extension 2057 to arrange for document inspection.

REOUEST FOR ENTRY ON LAND Please provide access to the Seabrook plant for the purpose of examinir.g all cable raceways.

REEP9EER Applicants object, on relevance grounds, to affording NECNP unrestricted access to the more than 16 miles of cable raceways and 6 million feet of cable in the Seabrook Station. ,

l If NECNP identifies specific parts of specific accessible raceways, Applicants will allow a properly qualified representative of NECNP to view such areas, under the supervision of New Hampshire Yankee employees and at NECNP's expense. No NECNP representative will be allowed to handle or otherwise interfere with the raceways or the cables contained therein, but may request that New Hampshire Yankee employees take reasonable steps to afford the representative a view of the location or material specified by NECNP.

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As to Answers:

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J e M. Vargas f anager of Engineering ew Hampshire Yankee Division of Public Service Company of New Hampshire July 13, 1988 l

l State of New Hampshire Rockingham County, ss.

Then appeared before me the above subscribed Joo M.'Vargas and made oath that he. is the Manager of Engineering of New

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Hampshire Yankee Division, authorized to execute the foregoing responses to interrogatories on behalf of the Applicants, that he made inquiry and believes that the foregoing answers accurately set forth information as is available to the Applicants.

Before me, f

l Ou%D b N(w l My Commisdion Expires > 3 46 l

, As '.o objections:

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[, j n, SQhad- .

Tholias G. Dignan, Jr.

Deborah S. Steenland Jeffrey P. Trout Ropes & Gray 225 Franklin Etreet Boston, MA 02110 t

(617)423-6100 Counsel for Acolicants

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Pcge 1'of 6

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ATTACHMENT 1 .

e SPARE CUT NO. CABLE NO. LENGTH FOOTAGE (4)

l. FM4-JX1/2 462 1

2. FM7-JX1/2 522

- '3. ~ FM3-JW5/2 532

4. FM6-JW5/2 544

5. FM6-JX5/2 496

6. FM4-JX5/2 486

7. FM7-GY4/2 274

8. FM4-GY4/2 286

9. FE7-FM6/2 140

10. 'FM6-GY6/2 296

11. FM4-GY6/2 300

12. FM3-FP1/2 78

13. FM7-FP1/2 100

14. FE7-FM4/2 144

15. FM3-GYO/2 550

16. FM7-GYo/2 570

17. F86-G13 462

18. FM3-GY9/2 596

19. FM6-GY9/2 552

20. FE2-FM4/2 128

21. FE2-FM6/2 134 TOTAL SPAPE FOOTAGE 7,652 1

.m.&

~' Fegs.2 cf 6.

ACTIVE- CUT NO. CABLE NO. LENGTH FOOTAGC~(4).

1. FM4-JX1 462

2. FM7-JX1 520

3. FM4-J X1/1 462

4. FM7-JX1/1 518

5. GU4-YS9/2 306

6. GU4-YS9/4 318

.7. GU4-Y59/3 314

8. GU4-YS9/5 308

9. FM3-JWS 532

10. FM3-JW5/1 530

11. FM6-JW5/1 524 4 ..

12. FM6-JW5

13. FM4-JX5 400

14. FM6-JX5/1 500

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15. FM6-JXS 482

16. FM4-JX5/1 484

17. FE2-FM4/1 132

18. FS2-FN1/3 212

19. F52-FN5/3 256

20. F72-FN5/2 270

21. FM6-GY6/1 294

22. F52-FN1/4 212

23. F52-FN5/4 274

24. FM6-GY6 318 i

25. F52-FN1/5 212

26. F52-FN5/5 260

,,.= Faga 3 cf 6= ~~ '!

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ACTIVE CUT NO. _

CABLE NO. LENGTH FOOTAGE (4) 2 7. - FMO-FT5 220

28. FM4-GY6/1 298

29. FMO-FTS/1 220

30. F5?,-FN1/6 248 '

31. W4H-W4J (55) Note 1

32. F52-FN5/6 266

33. F52-FN1/7 218

'4. F52-FN5/7 264

35. FN4-W4H/3 140 l

36. F81-FN4 276

37. FM3-FP1 100

38. FN4-W4H/2 140 f

39. FM7-FP1 100

40. FM3-FFl/l 100

41. FH7-FP1/1 100

42. F90-FN4/2 312

43. F10-F.v0 340

44. F90-FN4/1 314

45. F52-FN5 276 i

46. F72-FN5 268

47. F52-FN1 220

48. F31-FN1 344

49. F31-FN5 294

50. FE7-FM6 122 1

51. FM4-GY4 296

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$2. FE2-FM6 138

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ACTIVE CUT NO. CABLE WO. LENGTH FOOTAGE (4)

53. FM7-GY4 272

54. FE7-FM6/1 122

55. FE2-FM6/1 1241

56. F61-FN1/1 278

57. FM7-GY4/1 274 5 8. - F61-FN1/3 278

59. F61-FN1/2 ..)

60. F40-FN5/1 312

61. FN4-W4H 150

62. F40-FN5/2 314-

63. FM4-GY4/1 288

64. FN4-W4H/1 150 -

65. FM0-FT5/2 220

66. W4H-W4J/2 (55) Note 1

67. FH0-FT5/3 222

68. W4H-W4J/1 (55) Note 1

69. F10-FN4 310

70. W4H-W4J/3 (55) Note 1

71. F10-FM0/1 342

72. F40-FN5 310

73. F10-FM0/2 342

74. F52-FN1/1 220

75. F52-FN5/1 274

76. F31-FN1/1 346

77. F61-FN1 250

78. FM4-GY6 296 t

x - .: - Pega 5 of 6;

=* .

ACTIVE CUT ~

NO. ' CABLE NO. LENGTH FOOTACE (4)

~

79. F10-FM0/3. 342-

80. Fit FM4 144

'81. F52-FN1/2 212;

82. F52-FN5/2 276

83. FE2-FM4 136

84. F72-FN5/1 270

85. F31-FN1/2 348 8 6. - FE7-FM4/1 128 1

87. G7S-R3J/1 115

88. G7S-R3G 115

89. G7S-R3J 115

90. 07S-R3L/1 75 (5)

91. G67-Z!!3/ 2 192

92. G67-ZM3/3 192

93. G67-2M3/4 192 9 4. - G67-ZM3/5 192

95. G75-R3G/1 115

96. G7S-R3L 115

97. FM3-GY9 606

98. FM3-GY9/1 598 l 99. FM6-GY9/1 552 100. FM6-GY9 554 101. FM3-GYO 548 102. FM7-GYO 574 103. FM3-GYO/1 552 h

l 3.ww-- -+T-- g--- , --yy - -

--ery g-e-

P gs 6 cf 6 I'

1 ACTIVE. CUT

3. NO. CABLE NO. LENGTH FOOTAGE (4) 104. FM7-GYO/1 570 _

105. F86-S3W 486 TOTAL ACTIVE FOOTAGE 29,614

SUMMARY

TOTAL SPARE FOOTAGE 7,652 TOTAL ACTIVE FOOTAGE 29,614 TOTAL UNUSED F00TAGF. 30,240 Note 2 TOTAL FOOTAGE UNACCOUNTED FOR 502 Note 3 TOTAL FOOTAGE DELIVERED 68,008 NOTES:

1. Lengths provided for cables W4H-W4J, W4H-W4J/1, W4H-W4J/2 d W4H-W4J/3 are computed by DCR-87-229 which has not been imple-mented. Lengths are not included in totals.

2. Total unused footage includes cable returned to vendor, unused reels in stock, cut allowances, cuts scrapped during construction, cable used as test samples, etc.

3e Unaccounted footage represents one 238' length and one 264' length.

An ongoing search of construction recards may account for these lengths.

4. Cut length footage represents the amount of cabla cut from the cable reels and includes the excess footage on the cable ends which ic re-moved at the time of termination.

5. Actual cable length f om field verification.

1

. ATTACHMENT 2 National Acton Omsson Technical 533 Main Street Systems Acton, MA 01720 617/263 2933 July 5, 1988 ilew Hamsphire Yankee A Division of Public Service of New Hampshire Route 1, Lafayette Road General Office Building Seabrook Station Seabrook, NH 03874 Attention: Richard Bergeron Joseph Vargas

Reference:

Environmental Qualification Testing of RG56 Coaxial Instrument Cables, NTS/Acton Job No.

24843-89'N .

Gentlemen:

The purpose of this letter is to provide a summary of the Qualification Test Program for RG58 Cable samples for tiew Hampshire Yankee. A comprehensive report shall be submitted in addition to this letter. The agreed submittal due date is July 8, 1988.

Ten cable samples were submitted to NTS/Acton for qualification testina in accordance with IEEE 383-1974, and a previously conducted test progrcm documented in Franklin Research Test Report No. F-A5550-8. The ten samples were designated as follows:

Group One: Two aged samples and two unaged samples Group Two: Two aged samples and two unaged samples Group Thrers: Two aged spares

! One grot'.g of two aged and two unaged samples was subjected to the following tests:

Receiving Inspection & Baseline Functional Test Therma 1 Acing Post-thermal Functional Test irradiation Post-Irradiation Functionel Test 15-Day LOCA Test Post-LOCA Functional Test -

t I

/ I/ b5' l

l 1

l l

New !!ampshire Yankee July 5, 1988 R. Bergeron/J. Vargas Page 2 of 3 The other group of two aged and two unaged samples was subjected to a 30-day LOCA test instead of the 15-Day LOCA test. Testing on this group is not discussed in this letter as testing is still in progress.

Receivino/ Inspection and Baseline Functional Test:

Each cable sample was logged in and labeled with a unique identification number. The identification numbers for this sample group are:

1, 2 Aged Samples ,

7, 8 Unaged Samples The samples were then subjected to continuity checks and insulation resistance measurements. The results are un the attached data sheets.

Thermal Aoino:

Two of the samples (1, 2) were placed in a temperature chamber at 3020F for 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br />, simulating a 40-year service life.

Eost-Thermal Aoinu Functional Test The samples were again subjected to continuity checks and insulation resistance measurements.

I Irradiation l

Two of the smaples ( 1, 2) were subjected to gamma radiation exposure at Isomedix, New Jersey. The radiation dose was specitled as 220 megarads at a rate not to 3xceed one magarad per l hour.

l Post-Irradiation Functional Test:

The samples were subjected to continuity checks and insulation resistance measurements.

\

W New Hampshire Yankee July 5, 1988 R. Bergeron/J. Vargas Page 3 of 3

\

15-Day LOCA Test:

The samples were placed in the NTS/Acton System One LOCA chamber and subjected to a margin transient (with chemical spray) followed by a 15-day LOCA exposure as required by NTS/Acton Test Procedure No. 24843-89N and the Franklin Reasearch Report previously noted. During LOCA testing, daily insulation resistanco measurements were recorded. The sample carried one amp continuously throughout the LOCA test, post-LOCA Functional Test:

Following the 15-day LOCJ exposure, each sample was subjected t'o insulation resistance measurements and a voltage withstand test at 3200 VAC.

Results:

All results were acceptable. Some embrittlement of the outer jacket material was observed during the test program, however, the cable samples carried a continuous one amp load during LOCA and withstood the 3200 VAC Hipot Test. All results are included in the attached data sheets.

Conclusions:

The RG58 cable is acceptable for use under environmental and accident conditions specified in NTS/Acton Test Procedure No.

24843-89N.

If you should have any questions concerning the test program, please do not hesitate to contact me.

Sincerely, g.dd NTS/Acton! #$a6 Keith G. Whittles Engineering Manager

ATTACHMENT 3 l

e d f Ted C. Feigenbaum Vice President b .i !

Public Service of New Hampshire NYN-88095 New HampsNre Yankee Division United States Nuclear Regulatory Commission Washington, DC 20555

. Attention: Document Control Desk

Reference:

(a) Facility Operating License NPF-56, Docket No.

50-443

Subject:

Environmental Qualification of RG-58 Coaxial Cable Gentleme n:

The issue of environmental qualification of RG-58 coaxial cable at Seabrook Station has been in litigation for an extended period of time. In attempting to resolve this issue, several solutions have been pursued in parallel. In May 1988, New Hampshire Yankee management de-cided to replace the RG-58 cable in controversy to avoid further un-necessary litigation and licensing delays. This was followed up with a motion to the Licensing Board to moot the issue, which was subsequently denied by the Board. In parallel, NHY has proceeded with a test program to demonstrate that the subject cable is fully qualified for use at l Seabrook Station. The results of this test program were received in early July 1988.

Attached please find the test plan (Attachment 1) and results of the environmental qualification testing (Attachment 2) recently completed by National Technical Systems / Acton Division on RG-58 coaxial cable manufac-tured by ITT Surprenant. The test profile envelopes Seabrook Station's i

inside containment conditions (even though no RG-58 cables are installed inside the containment).

The data of the testing fully support the conclusion that RG-58 cable meets all 10CFR50.49 requirements and is environmentally qualified for Seabrook Station applications.

This data is being submitted for your information and use. Since provides inf ormation that is relevant to an issue under litigation, we are providing same to the interested parties, the Licensing Board and the Appeals Bcard . A copy of the detailed test report and supporting documentation will be placed in our environmental qualification files.

P.O. Box 300.Seabrook, NH 03874 . Telephone (603) 474 9574

-ot United States Nuclear Regulatory Commission NYN-88095 Attention: Document Control Desk Page 2 We hope that the test res,'ts and conclusions provided herein will facilitate resolution of this iss,a.

Very truly yours, fdb {

Ted C. Feigenbaum At ta chme nt cc: Atomic Safety and Licensing Board Service List Mr. Victor Nerses, Project Manager Project Directorate I-3 Division of Reactor Projects United States Nuclear Regulatory Commission Washington, DC 20555 Mr. William T. Russell Regional Administrator United States Nuclear Regulatory Commission <

Region 1 425 Allendale Road King of Prussia, PA 19406 Mr. Antone C. Cerne NRC Senior Resident Inspector Seabrook Station Seabrook, NH 03874

(

I I

~*

.e.

ATOMIC SAFETY LICENSING BOARD SERVICE LIST-Lando W. Zech, Jr. Chairman' Gustave A. Linenberger U. S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Washington, LC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Kenneth Rogers, Commissioner U. S. Nuclear Regulatory Commission Dr. Jerry Harbour Atomic Satety and Licensing Board Panel Washington, DC 20555 U.S. Nuclear Regulatory Commission Kenneth M. Carr, Co=missioner Washington, DC 20$55 U. S. Nuclear Regulatory Commission Washington, DC 20555 Adjudicatory File

Atomic Safety and Licensing Board Thomas M. Roberts, Commissioner Panel Docket U. S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Frederick M. Bernthal, Commissioner Atomic Safety and Licensing Appeal U.S. Nuclear Regulatory Commission Panel Vashington, DC 20555 U.S. Nuclear Regulator; Commission Washington, DC 20555 Alan S. Rosenthal, Chairman Atomic Safety and Licensing Appeal Panel Atomic Safety and Licensing Board Fanel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Co= mission Washington, DC 20535 Washington, DC 20555 Howard A. Wilber William C. Parler, Esq. General Counsel Atomic Safety and Licensing Appeal Panel Office of the General Counsel U.S. Nuclear Regulatory Co= mission U.S. Nuclear Regulatory Co= mission Washington, DC 20555 Washington, DC 20555 Sherwin E. Turk Esquire Thomas S. Moore Atomic Safety and Licensing Appeal Panel Office of General Counsel U.S. Nuclear Regulatory Co= mission U.S. Nuclear Regulatory Co= mission 7

! Washington, DC 20555 Washington, DC 20555 Ivan W. Smith, Chairman H. Joseph Flynn, Esq.

Atomic Safety and Licensing Board Panel Office of General Counsel l Federal Emergency Management Agency U. S. Nuclear Regulatory Commission 500 C Street, SW Washington, DC 20555 Washington, DC 20472 l

Administrative Judge Sheldon J. Wolfe Esq., Chairman Senator Gordon J. Humphrey**

l Atomic Safety and Licensing Board Panel U. S. Senate l Washington, DC 20510 j

U.S. Nuclear Regulatory Co= mission Washington, DC 20555 (ATTN: Tom Burack)

Samuel J. Chilk, Secretary Senator Gordon J. Humphrey**

U.S. Nuclear Regulatory Co==ission 1 Pillsbury Street Washington, DC 20555 Concord, NH 03301 (ATTN: Herb Boynton)

Administra?ive Judge Emmeth A. Luebke Atomic Safety and Licensing Board Panel Mr. Ed Thomas 5500 Friendship Boulevard FEMA Region I Apartment 1923N 442 John W. McCormack PO & Courthouse Boston, MA 02109 Chevy Chase, MD 20S15 1

L

e, ATOMIC SAFETY LICENSING BOARD SERVICE LIST (continued)

Diane Curran, Esq. Mr. George Olson Andrea C. Perster, Esq. Town Manager Harmon & Weiss Town of Exeter Suite 430 10 Front Street 2001 S. Street, NW Exeter, NH 03833 Vashington, DC 20009 Mr. William S. Lord Carol S. Sneider, Esq. Board of Selectmen Assistant Attorney General Town Hall - Friend Street Department of the Attorney General Amesbury, MA 01913 One Ashburton Place, 19th Floor Boston, MA 02108 Calvin A. Canney City Manager Paul McEachern, Esq. Cicy Hall Matthew T. Brock, Esq. 126 Daniel Street Shaines & McEachern Portsmouth, NH 03801 25 Maplewood Avenue P. O. Box 360 Leonard Kopelman, Esquire Portsmouth, NH 03801 Kopelman and Paige, P.C.

77 Franklin Street Brentwood Board of Selectmen Boston, MA 02110 RFD Dalton Road Brentwood, NH 03833 Mrs. Sandra Gavutis Chairman, Board of Selectmen Richard A. Hampe, Esq. RFD 1 - Box 1154 Hampe and McNicholas Kensington, NH 03827 35 Pleasant Street Concord, NH 03301 Charles P. Graham, Esquire Murphy and Graham Robert A. Backus Esq. 33 Low Street 116 Lowell Street Newburyport, MA 01950 P. O. Box 516 Manchester, NH 03105 Ashed N. Amirian, Esquire Assistant City Solicitor Philip Ahrens Esq. City of Haverhill Assistant Attorney General Haverhill, KA 01830 Department of the Attorney General Statehouse Station #6 Mr. J. P. Nadeau Augusta, ME 04333 Selectmen's Office 10 Central Road Judith H. Hizner Rye, NH 03870 Silvergate, Gertner, Baker, Fine.

Good & Mitner Gary W. Holmes. Esq.

88 Broad Street Holmes & Ells B'ston, MA 02110 47 Winnacunnet Road Hampton, NH 03842 Stephen E. Herrill, Esq.

Attorney General Robert Carrigg George Dana Bisbee, Esq. Town Office Assistant Attorney General Atlantic Avenue 25 Capitol Street North Hampton, NH 03862 Concord, NH 03301-6397 R. Scott Hill-Whilton Legoulis, Clark, Hill-khilton & McGuire

Two copies 79 State Street

- Letter of Transmittal Only Newburyport, MA 01950

ATTACHMENT 4 The station computer application for the following cables is a data link-between the Intelligent Remote Terminal Unit (IRTU) and the computer mainframe.

FM4-JX1 FM6-JX5 FM4-GY4/1 FM3-GYO/1 FM7-JX1 FM4-JX5/1 FM4-GY6 FE7-FM4 FM4-JX1/: FE2-FM4/1 FE2-FM4 FM3-FP1/1 FM7-JX1/1 FM6-GY6/1 FE7-FM4/1 FM7-FP1/1 FM3-JW5 FM6-GY6 FM3-GY9 FE7-FM6 FM3-JW5/1 FM4-GY6/1 FM3-GY9/1 FM4-GY4 FM6-JW5/1 FM3-FP1 FM6-GY9/1 FE2-FM6 FM6-JW5 FM7-FP1 FM6-GY9 FM7-GY4 FM4-JX5 FE7-FM6/1 FM3-GYO FM7-GY4/1 FM6-JX5/1 FE2-FM6/1 FM7-GYO FM7-GYO/1 The station computer application for the following cables is a data link between the CRT and the computer mainframe.

F52-FN1/3 F90-FN4/2 FN4-W4H/1 F52-FN1/1 F52-FN5/3 F10-FMO FMO-FT5/2 F52-FN5/1 F72-FN5/2 F90-FN4/1 W4H-W4J/2 F31-FN1/1 F52-FN1/4 F52-FN5 FMO-FTS/3 F61-FN1 F52-FN5/4 F72-FN5 W4H-W4J/1 F52-FN1/2 F52-FN1/5 F52-FN1 F90-FN4 F52-FN5/2 F52-FN5/5 F31-FN1 W4H-W4J/3 F72-FN5/1 FMO-FT5/1 F61-FN1/1 F10-FMO/1 F31-FN1/2 FN4-W4H/3 F61-FN1/2 F40-FN5 F40-FN5/1 FN4-W4H/2 F40-FN5/2 F10-FMO/2 The station computer application for the following cables is a data link between the keyboard logic and the computer mainframe.

FMO-FT5 F81-FN4 F61-FN1/3 F10-FMO/3 l W4H-W4J F31-FN5 FN4-W4H F52-FN5/7 F52-FN1/6 F52-FN5/6 F52-FN1/7 The following cables provide the data link between the Letdown Degasifier level element CS-LE-1-1 and the Letdown Degasifier Panel CS-CP-126 for local level indication.

GU4-Y59/2 GU4-Y59/3 GU4-Y59/4 GU4-Y59/5 l

l

~^ ^

T The following cables provide the data link between the Waste Feed Tanks (WS-TK-198A & B) and Concentrate Bottoms Tank WS-TK-200 to instrument rack WS-IR-95 for local level indication on waste management control panel MM-CP-464A.

G67-ZM3/2 G67-ZM3/3 G67-ZM3/4 G67-ZM3/5 The following cable provides the data link between the turbine generator and the main control board for temperature indication.

F86-S3W The remaining cables are spare and therefore do not perform a function.

m ATTACHMENT 5

1. Specification for Specialty Cable, No. 9763-006-113-19.

2. Purchase order No. 9763-006-113-19 with ITT Surprenant and all change orders thereto.

3. EQ File 113-19-01.

4. EQ File 113-20-01.

5. Computerized Conduit & Cable Schedule Program (CASP) .

6. CASP Design Guide.

7. (FSAR)' Final Safety Analysis Report.

8. 300000 Series Raceway Drawings.

9. Service Environment Chart Calculations - Design Basis -

6.01.00.00.

10. Service Environment Chart 300219.

11. Electrical Schematics.

12. Class 1E Equipment List 505300.

13. Harsh Environment Equipment List 300218.

14. Design Coordination Reports DCR-88-079 and DCR-87-229.

I 15. Engineering Evaluation Number 87-018, Environmental Qualification of ITT Surprenant RG-58 and RG-59 Coaxial Cables.

16. Engineering Evaluation Number 87-028, Review of ITT l

Surprenant RG-58 Coaxial Cable Applications.

17. Engineering Evaluation Number 88-014, Replacement of Coaxial Cable Type RG-58 by RG-59.

l l

18. Engineering Evaluation Number 88-017, Failuru Modes and Effects Analysis for RG-58 Coaxial Cable.

19. Memorandum, dated May 25, 1988, T. P. Nagle to J. M.

Vargas.

20. Franklin Institute Research Laboratory Final Report F-A5550-11, "Qualification Tests of Electrical Cables in

s. .t a Simulated Steam-Line Break and Loss of Coolant Accident Environment: 100-Day Duration 1/C and 2/C #20 AWG Thermocouple Cable."

21. PSNH Letter (NYN-88095), dated July 12, 1988, "Environmental Qualification of RG-58 Coaxial Cable,"

Ted C. Feigenbaum to the USNRC.

l l

I

. .: . ' 2 ATTACHMENT 6

1. Site Data. Packages. *

2. Cable Purchase Orders and Change orders.

Construction Phase Change Documents (e.a., ECAs, NCRs).

3.

4. Work Requests. *

5. Material Receiving Report. *

6. Document Distribution System.

72 Foreign Prints. *

8. Electrical Status Program.

9. Cable Specifications.

All items identified were specifically related to.the RG-58 coaxial cable supplied by ITT Surprenant under Purchase

. order No. 9763-006-113-19. .

I l

l l

i i

i

'\ =

s DOCKriED USNPr CERTIFICATE OF SERVICE I, Jeffrey P. Trout, one of the attorneys for the'E6 J114 P5 39 Applicants herein, hereby certify that on July 13, 1988, I made service of the within document by depositing copies.cr. c; n j7 g,. ,

thereof with Federal Express, prepaid, for delivery tdO(of M s R viu where indicated, by depositing in the United States mail, ' R3 ANM first class postage paid, addressed to) the individuals listed below.

Administrative Judge Sheldon J. Robert Carrigg, Chairman Wolfe, Esq., Chairman, Atomic Board of Selectmen Safety and Licensing Board Panel Town Office U.S. Nuclear Regulatory Atlantic Avenue Commission North Hampton, NH 03862 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Administrative Judge Emmoth A. Diane Curran, Esquire Luebke Andrea C. Ferster, Esquire 4515 Willard Avenue Harmon & Weiss Chevy Chase, MD 20815 Suite 430 2001 S Street, N.W.

Washington, DC 20009 Dr. Jerry Harbour Stephen E. Merrill Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee U.S. Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General East West Towers Building 25 Capitol Street 4350 East West Highway Concord, NH 03301-6397 Bethesda, MD 20814 Adjudicatory File Sherwin E. Turk, Esquire Atomic Safety and Licensing Office of General Counsel Board Panel Docket (2 copies) U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission One White Flint North, 15th Fl.

East West Towers Building 11555 Rockville Pike 4350 East West Highway Rockville, MD 20852 Bethesda, MD 20814

Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board Panel Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission P.O. Box 516 Washington, DC 20555 Manchester, NH 03105

I o

+ ..

~

o Philip Ahrens, Esquire Mr. J. P. Nadeau a Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augucta, ME 04333 Faul McEachern, Esquire Carol S. Sneider, Esquir-Matthew T. Brock, Esquire Assistant Attorney Gent.-al Shaines & McEachern Department of the Attorney General 25 Maplewood Avenue One Ashburton Pit;e, 19th Floor P.O. Box 360 Boston, MA v2108 Portsmouth, NH 03801 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Route 107 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801

Senator Gordon J. Humphrey R. Scott Hill-Whilton, Esquire U.S. Senate Lagoulis, Clark, Hill-Whilton &

Washington, DC 20510 McQuire (Attn: Tom Burack) 79 State Street Newburyport, MA 01950

Senator Gordon J. Humphrey Mr. Peter J. Matthews One Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall (Attn: Herb Boynton) Newburyport, MA 01950 Mr. Thomas F. Powers, III Mr. William S. Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Brentwood Board of Selectmen Office of General Counsel RFD Dalton Road Federal Emergency Management Brentwood, NH 03833 Agency l

500 C Street, S.W.

Washington, DC 20472 Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301 l l l

l

~

i Mr. Ed Thomas Judith H. Mizner, Esquire FEMA, Region I 79 State Street, 2nd Floor 442 John W. McCormack Post Newburyport, MA 01950 Office and court House Post Office Square Boston, MA 02109 Charles P. Graham, Esquire Murphy and Graham 33 Low Street Newburyport, MA 01950

> W Kf)ffe p . Trout 1

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