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Docket No. 8880 NEC Reply To: Joint Petitioners' First Set of Discovery

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Docket No. 8880 NEC Reply To: Joint Petitioners' First Set of Discovery Docket No. 8880 NEC Reply to: Joint Petitioners’ First Set of Discovery Requests to the New England Coalition Relating to Testimony of Arnold Gundersen September 7, 2017 REQUESTS FOR NEC Q.JP:NEC. 1-1: With respect to the witnesses for whom prefiled testimony was submitted on behalf of the NEC and who were identified as experts in this proceeding, to the extent not already produced: a. Produce a curriculum vitae or resume; b. Identify and produce all publications prepared, written, authored, co-authored, peer-reviewed, and/or contributed to by the witness within the preceding ten years, whether or not included in his or her respective curriculum vitae; and c. Identify all matters in the last five years in which the witness has been designated and/or has testified as an expert at hearing or trial, or by deposition, and identify and produce any transcripts, affidavits, testimony or other written statements by the witness in connection with the matters. Objection by counsel. VRCP 26(b)(1) states: (1) Scope in General. -- Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties' relative access to relevant information, the parties' resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit. Mr. Gundersen’s CV is attached to the original filing. Mr. Gundersen has already identified all publications written, authored, co-authored, peer-reviewed, and/or contributed to by the witness within the preceding 10-years in his CV. Documents older than 10 years old would require an effort disproportionate to the value of the importance of the documents to identify or to locate. All items requested for production exist in the public domain. If there are specific articles in his CV which Joint Petitioners lack that have not been provided, however, please inform counsel and we will attempt to provide those. Depending on the burden, Mr. Gundersen may seek compensation for his time under V.R.C.P. 26(c). See also the documents produced in response to JP:NEC.1-3. Docket No. 8880 NEC Reply to: Joint Petitioners’ First Set of Discovery Requests to the New England Coalition Relating to Testimony of Arnold Gundersen October 6, 2017 Requests For Arnold Gundersen Q.JP:NEC.1-2: Identify, list and produce all exhibits to be introduced or used at hearing in support of the prefiled testimony of Mr. Gundersen in this proceeding. Answer: NEC has provided this information in Mr. Gundersen’s pre-filed testimony, which may also be introduced at hearing. As these proceedings continue, new and additional information may supplement Mr. Gundersen’s pre-filed testimony. 2 Docket No. 8880 NEC Reply to: Joint Petitioners’ First Set of Discovery Requests to the New England Coalition Relating to Testimony of Arnold Gundersen October 6, 2017 Q.JP:NEC.1-3: Identify, list and produce all documents, data compilations, electronically stored information, photographs, workpapers or other tangible things provided to, exchanged with, prepared by, reviewed by, relied upon or used by Mr. Gundersen in developing his prefiled testimony and the opinion(s) underlying his prefiled testimony, including, but not limited to, all exhibits to his prefiled testimony. Answer: Mr. Gundersen has relied on the following document: Decommissioning Cost Analysis for the Vermont Yankee Nuclear Power Station, Document E11-1643-001, Rev. 1. Prepared for Entergy by TLG Services, Inc, (Feb. 2012). It is believed that Joint Petitioners have this document in their possession. Otherwise, documents responsive to this request and relied upon in developing Mr. Gundersen’s pre-filed testimony are identified within said testimony. If there are specific articles in the testimony which Joint Petitioners lack, however, please inform counsel and we will provide those. 3 Docket No. 8880 NEC Reply to: Joint Petitioners’ First Set of Discovery Requests to the New England Coalition Relating to Testimony of Arnold Gundersen October 6, 2017 Q.JP:NEC.1-4: Identify all assumptions, materials, inputs, data or information provided to Mr. Gundersen in connection with his preparation of prefiled testimony. Answer: Assumptions, materials, inputs, data and information relied upon in developing Mr. Gundersen’s pre-filed testimony is identified within said testimony. As such, Mr. Gundersen relies on those identifications contained within the testimony for this Answer. 4 Docket No. 8880 NEC Reply to: Joint Petitioners’ First Set of Discovery Requests to the New England Coalition Relating to Testimony of Arnold Gundersen October 6, 2017 Q.JP:NEC.1-5: Identify and describe all previous work (include cost estimation and funding analysis) Mr. Gundersen has undertaken with regard to nuclear decommissioning, spent nuclear fuel management, or site restoration, and produce all documents relating to all previous work Mr. Gundersen has undertaken with regard to nuclear decommissioning, spent nuclear fuel management, and/or site restoration projects. a. Identify all regulatory proceedings by jurisdiction, date, docket number and name in which Mr. Gundersen has testified or provided consulting or expert support for witnesses testifying on nuclear decommissioning, spent nuclear fuel management and/or site restoration projects. Objection by counsel. VRCP 26(b)(1) states: (1) Scope in General. -- Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties' relative access to relevant information, the parties' resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit. Given that Joint Petitioners already possess Mr. Gundersen’s very detailed CV, the request to identify all work and provide all documents violates this standard. Responding to this would be a huge, very time-consuming task and expensive undertaking, not proportional to the needs of the case. Therefore, counsel objects and has limited the response as follows. Answer: See the 1096 pages of decommissioning documents provided in response to JP:NEC.1-32. In addition: As identified in his CV, Mr. Gundersen is a chapter author of the first Department of Energy (DOE) Decommissioning Handbook in 1980 while employed at Nuclear Energy Services (NES) in Danbury, CT as the Director of General Engineering. During his employment with NES, Mr. Gundersen progressed from the Director of General Engineering, to the Vice President of Engineering, to Senior Vice President of Engineering, and then promoted to Senior Vice President of In-Service Inspection Services at Nuclear Energy Services (NES). Mr. Gundersen had more than 400 employees reporting to him in his role as the only Senior Vice President with Nuclear Energy Services, at that time a division of PCC (Penn Central Corporation) a fortune 500 Corporation. 5 Docket No. 8880 NEC Reply to: Joint Petitioners’ First Set of Discovery Requests to the New England Coalition Relating to Testimony of Arnold Gundersen October 6, 2017 NES was licensed by the Nuclear Regulatory Commission (NRC) to perform decommissioning services on radiologically contaminated facilities throughout the United States. As part of its NRC license, NES was required to create a Radiation Safety Committee. Mr. Gundersen was a founding member of that Radiation Safety Committee. In all of his capacities within NES, Mr. Gundersen and NES personnel performed numerous decommissioning cost analyses, testimony in regulatory proceedings, actual decommissionings of contaminated facilities, and site restorations. Additionally, the organizations reporting to Mr. Gundersen were responsible for designing, manufacturing and installing numerous spent fuel racks nationwide, including those provided to Vermont Yankee. Detailing the extensive nature of Mr. Gundersen’s expertise in each of these projects would be very time-consuming; Mr. Gundersen is no longer in possession of any of these specific records. 6 Docket No. 8880 NEC Reply to: Joint Petitioners’ First Set of Discovery Requests to the New England Coalition Relating to Testimony of Arnold Gundersen October 6, 2017 Q.JP:NEC. 1-6: Identify any instance in which a tribunal determined that Mr. Gundersen did not possess the necessary expertise to render an expert opinion. As part of Mr. Gundersen’s answer, identify and produce any decision rendered by such a tribunal. Answer: The only responsive incident was in Finestone, et al. v. Florida Power & Light, 2:03-cv-14040-JIC, (S.D. Fla Jan 1. 2006). The relevant document is enclosed. 7 Docket No. 8880 NEC Reply to: Joint Petitioners’ First Set of Discovery Requests to the New England Coalition Relating to Testimony of Arnold Gundersen October 6, 2017 Q.JP:NEC.1-7: Identify and describe all previous work Mr. Gundersen has undertaken relating to any of the Joint Petitioner parties, or affiliated entities. Answer: Beginning in 2003, Mr. Gundersen was retained by NEC as an expert in the Entergy Vermont Yankee (ENVY) Power Uprate proceeding. o Mr. Gundersen submitted all of his testimony in the case before the Vermont Public Service Board (VT PSB) now the Vermont Public Utilities Commission (VT PUC). o In his capacity as the nuclear engineering expert for New England Coalition, the attorneys representing ENVY (Gary Franklin and Victoria Brown of Eggleston and Cramer) attempted to impeach Mr. Gundersen while he was testifying before the VT PSB by presenting him with material Entergy did not provide during discovery. o When that incident occurred, the VT PSB shut down the hearings until the issue could be resolved. o The VT PSB then levied a $51,000 fine against ENVY and its attorneys for this nefarious act.
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