ML20151G613

New England Coalition on Nuclear Pollution (Necnp) Third Set of Interrogatories & Request for Production of Documents to Applicant on Necnp Contention I.B.2.* Svc List Encl.Related Correspondence

ML20151G613
Person / Time
Site:	Seabrook
Issue date:	07/21/1988
From:	Curran D PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
References
CON-#388-6797 OL-1, NUDOCS 8807290039
Download: ML20151G613 (13)

Text

(* ~

"y i;, <

) . qq

.' DOCKETED IJ5HRC.

July 21, 1988 UNITED STATES NUCLEAR REGULATORY CO8SIggyg A11 :40 t

BEFORETHEATOMICSAFETYANDLICENSIgBO_ARD . g, 3 . ,

h0C g rion'I' W,ta.

) 06?;t

• In the' Matter of )

)

Public Service Company of )

New Hampshire, et al. ) Docket No. 50-443 OL-1 V/-

e ) 46-/

,- (Seabrook Station, Units 1 & 2) ) ONSITE EMERGENCY

) PLANNING & TECHNICAL

) ISSUES

)

NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S THIRD SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO APPLICANTS ON NECNP CONTENTION I.B.2

. INSTRUCTIONS FOR USE The following interrogatories are to be answerad in writing and under oath by an employee, representative or agent of the Applicants with personal knowledge of the facts or information requested in each interrogatory. We remind you of your obliga-tion to ' supplement answers to interrogatories, under 10 C.F.R. 5 i

2.740(e).

The following definitions shall apply to these inter-d :s ,'ogatories:

t

1) "Document" shall mean any written or graphic matter or communication, however produced or reproduced, and is intended to be comprehensive and include without limitation any and all cor-respondence, letters, telegrams, agreements, notes, contracts, instructions, reports, demands, memoranda, data, schedules, notices, work papers, recordings, whether electronic or by other means, computer data, computer printouts, photographs, microfilm, n7 8807290039 880721 PDR ADOCK 05000443 n$w W

G PDR .

J

p

-- q r .

3 ,

't w

microfiche, charts, analyses, intra-corporate or intra-office communications, notebooks, diaries, sketches, diagrams, forms, manuals, brochures, lists, publications, drafts, telephone minutes, minutes of meetings, statements, calendars, journals, orders, confirmations and all other written or graphic materials .

of any nature whatsoever.

2) "Identifv" with respect to any document shall mean to state the following: the document,'s tit 1e, its date, the author of the document, the person to whom to document was sent, all

, persons who received or reviewed the document, the substance and natue r of the document, and the present custodian of the document' and of any and all copies of the document.

3) "Identifv" with respect to any action or conduct shall mean state the following regarding any such action or conduct:

the person or persons proposing and taking such action; the date such action was proposed and/or taken; all persons with knowledge or information about such action; the purpose or proposed effect

'> of such action;#and any document recording or documenting such action.

, 4) "Identifv" with respect to an individual shall mean state the individual's name, address, employer, occupation, and title.

L' 5) "NECNP's first set of interrogatories" refers to interrogatories posed in "New England Coalition on Nuclear Pollu-tion's First Set of Interrogatories and Request for the Produc-tion of Docunents," filed June 28, 1988.

I l

L

f INTERROGATORIES

1) For each of the four individual identified in response to interrogatory No. 1 of NECNP's first set of interrogatories, please describe the person's area of expertise and the particular substantive contribution that the person has made, both to the Applicants' review of the RG-58 coaxial cable issue,.and to the answering of NECNP's first, second, and third sets of inter-rogatories.

2) Please identify all witnesses and affiants you intend to use in hearings and summary disposition proceedings on RG-58 coaxial cable, and describe the substance of their affidavits and testimony.

3) On May 27, 1988, you filed a revised "Suggestion of Mootness" which cor' r ected your May 19, 1988, tabulation regarding the categorization of RG-58 cables in the Seabrook plant. How and when was this error discovered? To what do you attribute the error made in the May 19th filing? Was the review procedure described u. the May ic Bergeron affidavit inadequate to detect this error? If cc, how? Was the review procedure described in the Bergeron affidavit improperly carried out? If so, how?

4) Does the June 16 Bergeron affidavit describe any review procedures for the identification and location of RG-58 cable that are not already described in the May 19 Bergeron affidavit?

If so, please describe them, and explain why they were added.

5) In response to interrogatory 5 of NECNP's first set of interrogatories, you state that "subsequent review" has l

_4_ .l determined that cables.No.-FE2-FM4/2 and FE2-FM6/2 were spare cables. Please describe this "review" and state when it took place and by whom it was conducted. In what respects,'if any, does it differ from the review describt.d in the Bergeron affidavits of May 19 and June 16, 1983? Do you consider the procedures described in those affidavits to be inadequate in any way? If so, how? Please describe your reasons for conducting the "subsequent review."

6) Do the electrical schematic drawings that you reviewed according to the procedures described in the Bergeron affidavits show that cables No. FE2-FM4/2 and FE2-FM6/2 are spare cables?

If not, please describe the reason for the error and any efforts you have made to detect other errors in the electrical schematic drawings.

7) Does the CASP show that cables No. FE2-FM4/2 and FE2-FM6/2 are spare cables? If not, please describe the reason for the error and any efforts you have mado to detect other errors in the-CASP.

8) Given the fact that you previously erred in calculating that some cables were energized when they were actually spare cables, do you believe it is possible that some cables which you believe are spare are actually energized? If not, why not?

9) Have you physically inspected all spare RG-58 coaxial cables to determine whether they are indeed not connected to any circuits? If so, when was the inspection performed and what were the resuits? If not, why not?

]

- ~

, 10) Please describe the steps takenito account for the 502 i

~

feet of RG-58 cable that have not yet been accounted for. What are the results of)your review to date? To what do you attribute your previous inability to account for this cable? Are you confident that none of this cable must be environmentally -

qualified? If so, why? If not, why not?

11) In response to interrogatory No. 7. of NECNP's first set of interrogatories, you state that 4,000 of the 12,000 pages of electrical schematic drawings contain cable schematics and cable tables. Did'you review onl'1 those 4,000 pages, or did.you also review the other 8,000 pages? What information did the 8,000 pages contain? If you did not review them, why not?

12) In response to interrogatory No. 12 of NECNP's first set of interrog.ttories, you state that 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. Have Applicants physically traced the route of those cables over their entire lengths? If so, how and when was this done? Did the physical review confirm your review of CASp and the plant drawings? Please identify all cables for which your physical review did not confirm what was in CASP and the drawings, describe the discrepancy, and state why you believe the discrepancy exists.

13) Have Applicants physically verified the endpoints of any other of the 126 RG-58 coaxial cables? If so, which ones

, ,7 r_ , . .. - . - ,

a.

have.you verified? How and when was this done? Did the physical review confirm-your review of CASP and the plant drawings?

Please_ identify all cables for which your physical review'did not confirm what.was in CASP1and.the drawings, describe the' dis-

. crepancy, and state why you believe the discrepancy exists.

14) Have you physically traced the routes of any of the' remaining RG-58 coaxial cables over their entire lengths? If so, which ones were traced? Did the physical review confirm your review of CASP and the plant drawings?. Please identify all cables for which your physical review did not confirm what was in-CASP and the drawings, describe the discrepancy, and state why ,

you believe the discrepancy exists. *

15) Please explain how procedure FEP-504 provided physical verification of the location of each RG-58 coaxial cable. Would that procedure also verify whether cables were energized or not?

If so, why did it not show that some of the cables shown to be I

energized by CASP and/or plant drawings were not in fact energized?

16) What is the source of and basis for the acceptance criteria described in Section 5.2 of Procedure No. 2483-89N, Attachment 1 to NYN-8905? <

17) Your response to interrogatory 18 of NECNP's first set I

-of interrogatories appears to indicate that it is your position that the 12 circuits in which RG-59 coaxial cable is used will function properly regardless of how low the insulation resistance

RF 3 .

, . n 3 T:;

?

i s ,

s

% drops,as long as tbe cable does not short to ground. Is that

< correct? If so, please-explain your answer. If not, please explain why not. Is it_your position that the circuits would co'ntinue to function during a direct short? If so, please explain your answer. If not, please explain,why not. .

18) on what basis have you concluded that the functional performance of RG-59 coaxial cable in each of the 12 circuits makes it a technically acceptable substitute for RG-58 coaxial

~

cable?

19) Is it correct to stata that you do not know.the minimum insulation resistance necessary for the proper functioning of each circuit where RG-59 coaxial cable has been substituted for RG-58 coaxial cable? Please explain the reason for your answer.

20) In response to NECNP's interrogatory No. 19, you state that "cable manufacturer data was reviewed and determined to be acceptable" for each substiiate applicetion of RG-59 coaxial.

cable. Precisely what information in the RG-58aor RG-59 coaxial cable manufacturer data led you to believe that RG-59 cable was

'an acceptable substitute for RG-58 cable? Please explain why you considered the data to be sufficient.

21) Is it correct to state that there is De minimum insula-tion resistance required for the successful functioning of the circuits in which RG-59 coaxial cable have been substituted for RG-58 coaxial cable? Please explain your answer.

22) Do you agree that degradation of signal due to inser-tion loss (attenuation) and varintion in response time due to the 1

]

e. * /

(U 'j s.

~

t 1 rJ" C '

change in the velocity of propagation are pertinent parameters for proper function of the 12 substitute RG-59 coaxial cables?

q 23) Is it.your position that decreases in the insulation i resistance-of the 12 substitute RG-S9 coaxial cables would have e no-effect'on the degradation of signal due to insertion loss ,

-(attenuation) and variation in response time due to the change in the velocity of propagation?

24) Do you agree that the length of cable exposed to the accident environment is relevant to a determination _of its insulation resistance? If not, why not?

25) For each of the 12 cables exposed to a harsh environ-ment, is it'possible to measure the length of cable that is exposed to the harsh environment? If so, why have you not done so? If not, why not?  ?

REQUEST FOR THE IDENTIFICATION AND PRODUCTION OF DOCUMENTS

1) Please identify all documents relied on for purposes of anavering the foregoing interrogatories or identified in response to the foregoing interrogatories.

2) Within 14 days, please provide access to all documents 3dentified in response to the immediately proceding request, No.

1.

3) Please provide access to procedure FEP-504.

4) Please identify and provide access to all documentation of the manner in which procedure FEP-504 provided verification of j the location of RG-58 coaxial cable.

l

(M a

ro t ,.

':o

-9_-

5) Please provide access to the data sheets described in Attachment'2 to your answers to NECNP's first set of inter-rogatories, the July 5, 1988, letter from NTS to R. Bergeron/J.

Vargas.

6) Unless already provided in response to the preceeding document request, please provide access to all other results of equipment qualification testing of RG-58 coaxial cable, including insulation resistance measurements.

7) Please provide access to the cable manufacturing data referred to in your answer to interrogatory 19 of NECNP's first set of interrogatories.

Respectfully submitted,

. r7 k G= -

Diane Curran HARMON & WEISS 2001 "S" Street N.W. Suite 430 Washington, D.C. 20009 (202) 328-3500 July.21, 1988

s

, e .P .

July 21, 198800LKETED USNRC UNITED STATES NUCLEAR REGULATORY COMMISSION 3EFORE THE ATOMIC SAFETY AND LICENSING MAsAl. 25 51.41 In the Matter of f0 K i G ih}Ej'

) BRAN &

Public Service Company of i New Hampshire, et al. ) Docket Nos. 50-443 OL-1

) 50-444 OL-1 (Seabrook Station, Units 1 & 2) ) ONSITE EMERGENCY

) PLANNING & TECHNICAL

) ISSUES NOTICE OF DEPOSITIONS The New England Coalition on Nuclear Pollution hereby notifies Applicants that it intends to take the depositions upon oral examination of Joe M. Vargas, Richard Bergeron, Gerald A.

Kotkowski, Peter Tutinas, any other individual (s) whose affidavit (s) Applicants intend to file in summary disposition pleadings regarding RG-58 coaxial cable, and any other individ-ual(s) whose testimony Applicants intend to present in adjudicatory hearings regarding RG-58 coaxial cable. The deposi-tions will take place at the offices of Ropes & Gray, 225 Franklin Street, Boston, Marnachussetts, on August 12, 1988, at the following times, or at such other date and time as the parties may mutually agree:

Deconent Time Richard Bergeron 9:00 a.m.

Gerald A. Kotkowski 11:00 a.m.

Peter Tutinas 1:30 p.m.

Joe M. Vargas 3:30 p.m.

The deponents will be examined regarding the basis for Applicants' position on the need for and adequacy of environmen-tal qualification of RG-58 coaxial cable and substitute cable,

.w.

. s i' 1

2-and the adequacy of RG-59 cable as a substitute for RG-58 cable.

NECNP reserves the right, upon reasonable notice to Applicants, to amend this notice of deposition in order to add.or delete deponents and to request the production of documents.

Respectfully submitted, Diane Curran HARMON & WEISS 2001 "S" Street N.W. Suite 430 Washington, D.C. 20009 (202) 328-3500 July 21, 1988 D

--,.,,e-c, - w -.-n- ,-m, -,w, - - - -----,,-n-- -- , , - . , , - - , , - - - - - - , , , - , - - - - - - -.. ,c- .,

7

~ ..

EaMFABMMalMaik

%$yi ~

CERTIFICATE OF SERVICE.

,s M Ji 25 All:37 I certify that on July 21, 1988, copies of the following documents were served by overnight mail or first glass mail, on the individuals- listed on the attar.hed service liact;it iy,t, . ; y ., g

s t. A ..

NEW ENGLAND COALITION ON hUC"Z AR POLLUTION'S BRIEF IN OPPOSITION TO AUTEORI'4ATION OF LOW POWER OPERATION AT SEABROOK i!UCLEAR POWER PLANT NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S THIRD SET OF INTERRGGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO APPLICANTS ON NECNP CONTENTION I.B.2 NOTICE OF DEPOSITIONS .

NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S MOTION FOR EXTENSION OF DISCOVERY SCHEDULE f -

Diane Curran

. ~ . _ _ .

m

.m-4 . .

-. .x

,y -a. 4

~ ' '

SEABROOK SERVICE LIST

~ Onsite Licensing Board I

- .. , L r,,, ... i '.

ou :~

Georte Dana Disbee, Esq. Judith H. Mizner, Esq.

"Sheldoa J. Wolfe, Chairman - Geoffrey M. Huntington, Esq. 79 State St. 2nd Iloor i Atomic Safety and Ucensing Board Office of the AttornefGeneral ' Neeuryport,MA 01950 ,y

.1,l.S. Nuclear keplatory Commission Sute Hoese A .act "Thomas G. Dignan, Esq.

- % M. N 5;- Washington,D.C20555 Concard, N1103301 R.K. Gad II, Esq.

' ?Dr. Emmnh A. Luet ke Richard A. llampe, Esq. Ropes & Gray Ol* W. . * * '^h 00CMdC- 9 '-

Atomic Safety and Lkrasing Board . Hampe and McNicholas 225 Franklin Stact

$500 Priendship Bostevard 35 Pleasant Street . Bos6on,MA 02110

. Apartment 1923N 3' Concord,NH 03301 Otevy Chase,MD 20815 .

R. Scott IWi Whilton Gary W. Holmes, Esq. Lagoulis, Clark Hill-Whilton .

' "Dr. Jerry Hart >our llotmes & Eliis and McGuire 1'

Atomic Safety and ucensing Board 47 Winnacunnent Road TJ State Street U.S. Nuclear Replatory Commission ' Hampton, SH 038 82 Neeuryport,MA 01950 WashiIgton, D.C 20555 William Armstrong IAonard Koppelman, Esq.

CMI Defense Director Bast > ara J. St. Andre Esq.

T Atomic Safety'and Ucensing

' Board Panel 10 front Street Kopelman & Paige, PC 4 U1 Nuclear Regulatory Commus8 a Exeter,NH 03833 77 Franklin Srreet Boston, MA 02110 -

Washington, D.C 20555

- Calvin A. Canney Dockiting and Ser:iec Drant i City Manager -

, U1 Nuclear Regulatory 0 .nmission Cg Had Washington,D.C 20555 124 Daniel Stree: " Overnight Deliwry Portsmouth,NH 03801 JIs Doughty SAPL Charles P. Graham, Esq.

5 Mirket Street Murphy & Graham -

Portsmouth, N1103801 33 low Stree Nedutyport, MA 01950 Stantry W. Knowles Board of Selectmen Rep. Rcberta C Pevear P.O. Box 710 Drinkwater Road North Hampton,NH 03826 . Hampton Falls,NH 03848 J.P. Nadeau Philtip Ahrens, Esq.

, , Toms of Rye Assistant Attorney General 155 Washington Road kate llouse, Station #6 Rye,Newllampshire 03870 Auscsta,ME 04333 Senator Gordon J. Ilumphrey "Gyg>ry A. Berry, Esq.

. U.S. Senate Office of General Counsel WashiJgton,D.C 20510 U1 Nucicar Regulatory Commission (AttA Tom Burack) Washington, D.C 20535 C::rol S. Sneider, Eso ?> - Allen Lampert Assistatt Attorney General Civil Defense Director 1 Ashburton Place,19th floor Town of Brentomood Boston, MA 02108 . Exeter,NH 03833 Mrs. Anne E. Goodman Matthew T, Brock, Esq.

Board of Selectmen - Sbaines & McEachern 13-15 New Market Road P.O. Box 360 Durham, Nil 03842 Maplewood Awnue Portsmouth, Nil 03801 g

L William S. lord, Selectman

• Town llall- Friend Sareet Sandra Gavutis Amesbury,MA 01913 RIT)1 Box 1154 East Kensington, Nil 03827 Robert A. Backus, Esq.

Backus, Meyer & Solomon Senator Gordon J. Ilumphrey ill ionell Street 1 Eagle Square, Sie 507 M:nchester, Nil 03105 Concord, N1103301