ML20151N581

Applicants First Set of Interrogatories & First Request for Production of Documents Re New England Coalition on Nuclear Pollution Contentions Concerning RG-58 Cable.* Certificate of Svc Encl.Related Correspondence

ML20151N581
Person / Time
Site:	Seabrook
Issue date:	08/01/1988
From:	James Smith PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	NEW ENGLAND COALITION ON NUCLEAR POLLUTION
References
CON-#388-6853 OL-1, NUDOCS 8808090041
Download: ML20151N581 (16)

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August 1, 19 88P 'gi pg iIS UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFF !O - ~ . ' . V ,'

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G' 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

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APPLICANTS' FIRST SET OF INTERROGATORIES AND FIRST REQUEST FOR PRODUCTION OF DOCUMENTS REGARDING NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S CONTENTIONS CONCERNINC RG-58 CABLE Pursuant to 10 C.F.R. 55 2.740b and 2.741, Applicants hereby request that New England Coalition on Nuclear Pollution ("NECNP") respond to the following interrogatories, and prcduce for inspection and copying the documents requested below. The production of the documents requested herein shall take place at the offices of Ropes & Gray, 225 Franklin Street, Boston, Massachusetts, at 10 A.M. on Monday, August 15, 1988.

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! Definitions and Guidelines to be Used I in Respondina to this Reauest

. 1. The word "document" as used herein shall mean any l

written matter, whether produced, reproduced or stored on paper, cards, tapes, disks, belts, charts, films, computer 8808090041 880B01 6Dh l PDR ADOCK 05000443

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I storage devices or any other medium and shall include, without limitation, matter in the form of books, reports, l l

studies, statements, speeches, notebooks, agreements, appointment calendars, working papers, manuals, memoranda, notes, records, correspondence, diaries, plans, diagrams, drawings, periodicals, lists, telephone logs, minutes, photographs, and any published materials and shall also include, without limitation, originals, copies (with or without notes or changes thereon) and drafts.

2. The word "communications" shall mean correspondence, contact, discussion, or any other kind of written or oral exchange between two or more persons or entities including, but not limited to, all telephone conversations, face-to-face meetings or conversations, visits, conferences, internal and external discussions, and exchange of a document or documents.

3. Applicants request that documents produced in compliance with this request be accompanied with an indication as to the particular paragraphs under which the documents are being produced.

4. In the event that it is claimed that any document responsive to any request is privileged, each privileged document should be fully identified in writing, signed by counsel, except that the substance thereof need not be described to the extent said substance itself is claimed to J

be privileged. To "identify" a document claimed to be privileged means to state:

(a) the date on which the document was prepared; (b) the author or authors of the document; (c) the addressee (s) and recipient (s) of the document, if any; (d) the title of the document; (e) the number of pages in the document; and (f) the substance of the document to the extent it is not privileged.

5. "Identify" with respect to an expert witness means to state:

(a) The name, mailing address, age and present professional or employment affiliation of the person; (b) The profession or occupation and field of claimed expertise of the person; (c) The history of formal education or training of the person, including but not limited to, (i) the name and address of each school where the person received special education or training, (ii) the date those schools were attended, and (iii) a description of each degree earned, including the date and granting institution; (d) The history of specialized training in the area of claimed expertise, including, but not limited to, (i) the type of training received, (11) the name and address J

of the institution providing this training, and (iii) the dates of such training; (e) A list of publications of any kind by the person in the area of claimed expertise, including, but not limited to, (i) the title and subject matter, (ii) the name and address of the publisher, and (iii) the date of publication; (f) A list of any and all licenses in the area of claimed expertise, including, but not limited to, (i) the designation of the authority by which the license was issued, (ii) the date(s) of the licensing, (iii) the requirements for obtaining each license, and (iv) the manner by which these requirements were met; (g) The amount of time the person has worked in the field of claimed expertir,e, stating periods where work was other than on a full-time basis; (h) The name and address of every person, or every corporation or other institution, that has employed the person within the last ten years of employment; (i) All periods of claimed self-employment, including a description of all duties and responsibilities thereof; (j) All previous experience in the field of claimed expertise which involved problems, analyses or studies similar to those concerning which the person is expected  !

to testify in this proceeding;

(k) All other litigation in which the person has been consulted, specifying those matters in which the person has testified, including the name of the case or matter and the court or other forum in which testimony was given; and (1) Any other experience in the field of claimed expertise.

6. Please include, with the answer to each of the interrogatories that follow, the name, institutional affiliation and professional qualifications, if any, of the person who is answering.

Interrocatories and Reauests for Production

1. With respect to NECNP's answers to each of the interrogatories 6 - 15 that follow, is that answer based upon reference to or knowledge of the exister.ca of ena or more documents? If so, plea'ae:

(a) Identify each such document on which the answer is based. -

(b) Identify the information in each document on which the answer is based.

(c) Identify all documents possessed by or known to exist by NECNP which deal with the same subject matter.

(d) Produce all identified documents.

2. With respect to NECNP's answers to each of the interrogatories 6 - 15 that follow, is that answer based upon

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any type of study, calculation, procedure, method, instruction, assumption, conclusion, recommendation or analysis? If so, please:

(a) Describe the nature of the study. calculation procedure, method, instruction, asst . ption, conclusion, recommendation or analysis.

(b) Identify and produce any documents that constitute, discuss or describe it.

(c) Identify the person (s) who performed it, including the institutional affiliation and professional qualifications, if any, of the person (s).

(d) State when and where it was prepared or performed.

(e) Describe in detail the information or data that was examined.

(f) Describe the results.

(g) Explain how it provides a basis for the answer.

3. With respect to NECNP's answers to each of the interrogatories 6 - 15 that follow, is that answer based upon conversations, consultations, correspondence or any other type of communication with one or more individuals or entities? If so, please:

(a) Identify each such individual or 7ntity.

(b) State the educational and professional background of each such individual, including occupation and institutional affiliates.

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(c) Describe the nature of each communication with each i

such individual or entity, whan it occurred, and identify all other individuals or entities involved.

(d) Describe in detail the information received from each such individual or entity, and explain how it provides a basis for the answer.

(e) Identify and produce each letter, memorandum, contract, tape, note or other document related to each conversation, correspondence, or other communication with such individual or entity.

4. Does NECNP intend to offer the testimony of any expert witness with respect to the issue remanded in ALAE-891? If so, please:

(a) Identify each expert witness whom NECNP intends to present with respect to this contention.

(b) State the substance of the facts to which each expert witness is expected to testify.

(c) State the substance of the opinion or opinions to which each expert witness is expected to testify.

(d) Previde a summary of the grounds for each opinion to which each expert witness is expected to testify.

(e) State whether the facts and opinions listed in response to the foregoing are contained in any written report, memoranda, calculation, analysis or other transcript, and, if so, whether NECNP is willing to

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D produce the same without the necessity of a notice to produce.

(f) State whether the opinion of any expert witness is based in whole or in part on any scientific rule or principle, and, if so, set forth such rule or principle.

(g) State whether the opinion of any expert witness is based in whole or in part on any code or regulation, governmental or otherwise, and, if so, identify each such code or regulation and the specific section or portion thereof relied upon.

(h) State whether the opinion of any expert witness is based in whole or in part upon any scient'ific or engineering book or other publication, and, if so, identify the book or publication.

5. Does NECNP intend to offer the testimony of any non-expert witness with respect to the issue remanded in ALAB-891? If so, please:

(a) Identify each non-expert witness whom NECN? intends to present with respect to this contention.

(b) State the substance of the facts to which each non-expert witness is expected to testify.

, (c) State the substance of the opinion or opinions to which each non-expert witness is expected to testify.

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(d) Provide a summary of the grounds for each opinion t which each non-expert witness is expected to testify.

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. l (e) State whether the facts and opinions listed in response to the foregoing are contained in any written report, memoranda, or other transcript, and, if so, whether NECNP is willing to produce the same without the necessity of a request to produce.

(f) State whether the opinion of any non-expert witness is based in whole or in part on any scientific rule or principle, and, if so, set forth such rule or principle.

(g) State whether the opinion of any non-expert witness is based in whole or in part on any code or regulation, governmental or otherwise, and, if so, identify each such code or regulation and the specific section or portion thereof relied upon.

(h) State whether the opinion of any non-expert witness is based in whole or in part upon any scientific or engineering book or other publication, and, if so, identify the book or publication.

6. Do you assert that RG-58 cable is not environmentally qualified? If so, plesse state in detail all the facts underlying this assertion and explain exactly how those facts support the assertion.

7. What are the performance specifications for environmentally qualified cable?

8. What is the electrical characteristic that demonstrates that a cable is environmentally qualified?

9. Do you assert that Applicants have not identified all RG-58 cable exposed to a harsh environment that need to be either qualified or replaced with a qualified cable? If se, please state (a) which cable (s) did Applicants fail to identify; (b) the function (s) performed by each cable; (c) the safety-related nature of the function (s) performed by each cable; and (d) all the facts underlying this assertion and explain exactly how those facts support the assertion.

10. Do you assert that Applicants did not replace all RG-58 cable exposed to a harsh environment that need to be either qualified or replaced with a qualified cable? If no, please state (a) which cable (s) did Applicants fail to replace; (b) the function (s) porformed by each cable; (c) the safety-related nature of the function (s) performed by each cable; and (d) all the facts underlying this assertion and explain exactly how those facts support the assertion.

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11. Do you assert that there are other RG-58 cables, in 10-i i

addition to the 12 RG-58 cables replaced, that must be environmentally qualified? If so, please state (a) which other cables need to be environmentally qualified; (b) the function (s) performed by each cable; (c) the safety-related nature of the function (s) performed by each cable; and (d) all the facts underlying this assertion and explain exactly how those facts support the assertion.

12. Do you assert that Applicants must replace any RG-58 cables other than the 12 RG-58 cables replaced with RG-59 cable? If so, please stata:

(a) which cable (s) need to be replaced; (b) the functions performed by each cable; (c) the safety-related nature of the functions performed by each cable; and (d) all the facts underlying this assertion and explain exactly how those facts support the assertion.

13. Do you assert that RG-59 cable is not technically qualified to perform the functions required by the 12 RG-58 cables that were replaced? If so, please state for each cable (a) the function (s) that cannot be performed;

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(b) the conditions under which the function (s) cannot be performed; (c) the safety-related nature of the Junction (s) ;

(d) the nature of the technical inadequacy; (e) the effect of this technical inadequacy on functional performance; and (f) all the facts underlying this assertion and explain exactly how those facts support the assertion.

14. Do you continue to assert the facts and opinions expressed in the affidavits you have filed before the Licensing Board and Appeal Board following the issuance of ALAB-891? If any of these facts or opinions have changed, please identify them and describe the reasons for the changes.

15. Identify all individuals on whose knowledge or opinions you relied in each of the filings before the Licensing Board and Appeal Board since the issuance of ALAB-891. For each of 1

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these individuals, describe that portion of the filing for which you relied on that individual.

By their attorneys,

.., & .s cl ,ln C' .

Thomas G. Dignan, Jr.

Deborah S. Steenland Jay Bradford Smith Ropes & Gray 225 Franklin Street '

Boston, MA 02110 (617) 423-6100

NLKEiED UWRC CERTIFICATE OF SERVICE I, Jay Bradford Smith, one of the attorneys for7he  % ME -3 A9 53 Applicants herein, hereby certify that on August 1, 1988, I made thereof service of the within with Federal Express, document by depositing prepaid, for deliverycopt 0 @ies/ (y L b W whereindicated,bydepositingintheUnitedStatesmail,Q['

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 Emmeth 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

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Philip Ahrens, Esquire Mr. J. P. Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 04333 Paul McEachern, Esquire Carol S. Sneider, Esquire Matthew T. Brock, Esquire Assistant Attorney General Shaines & McEachern Department of the Attorney General 25 Maplewood Avenue One Ashburton Placa, 19th Floor P.O. Box 360 Boston, MA 02108 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 -

Charles P. Graham, Esquire Office of General Counsel Murphy and Graham Federal Emergency Management 33 Low Street

, Agency Newburyport, MA 01950 500 C Straet, S.W.

Washington, DC 20472 Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Strcet Hampton, NH 03J41 Concord, NH 03301

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s Mr. Ed Thomas Judith H. Mizner, Esquire FEMA, Region'I 79 State Street 442 John W. McCormack Post Second Floor Office and Court House Newburyport, MA 01950 Post Office Square Boston, MA 02109

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Jay Bradford Smith

(*= Ordinary U.S. First Class Mail.)

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