ML20031H524
| ML20031H524 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 10/20/1981 |
| From: | Baxter T SHAW, PITTMAN, POTTS & TROWBRIDGE, UNION ELECTRIC CO. |
| To: | Chackes K CHACKES & HOARE |
| References | |
| ISSUANCES-OL, NUDOCS 8110280058 | |
| Download: ML20031H524 (15) | |
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SHAw, PITTMAN, PoTTs & TROWBRIDGE' 1800 M STREET. N. W.
WASHINGTON, D. C. 20036 reAMSAY D. POTTS STEVEN M LUCAS 12O21 822 1000 STEUART L PtTTMAN DAvio M. RuaENS'EIN GEORGE F. TROweR10GE MATIAS F TRAviESO-DiA2 STEPMEN O POTTS VICTORI A J. PERMrwS.
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Dear Mr. Chackes:
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e Your letter of October 13, 1981, seeks a prompt reply to requests for the production of additional documents and inter-rogatory answers, and requests that we consider a revision of the schedule for the litigation of Joint Intervenors' Conten-tion No. 1.
I responded, in part, to your letter by telegram (attached) on October 19, 1981.
For the reasons stated below, Applicant will not agree to a revision in the schedule or to provide responses to additional discovery requests, with excep-tions I will identify.
I.
DISCOVERY The Special Prehearing Conference Order issued by the Atomic Safety and Licensing Board on April 21, 1981, established the following schedule for the conduct of discovery in this proceeding:
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8110280058 811020?
PDR ADOCK 05000483
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. SHAN, PITTMAN, POTTS & TROWBRIDGE Kenneth M. Chackes, Esquire October 20, 1981 Page Two 1.
Discovery commences.
Issuance of this Order.
2.
Last day for filing of first-round May 26, 1981.
discovery requests.
3.
Last day for filing responses to July 10, 1981.
first-round discovery requests.
4.
Last day for filing of second-August 10, 1981.
round discovery requests.
5.
Last day for filing responses to September 10, 1981.
second-round discovery requests.
Except for the filing of late interrogatory answers and the late production of documents by Joint Intervenors, the parties generally have adhered to this schedule.
The Licensing Board's Order further provided that:
Additional discovery requests to those per-mitted by the above schedule can only be filed with the Board's permission and must be based on information that could not, with diligence, be known at the time authorized for discovery.
Such requests must be filed within thirty (30) days after it became or should have become known.
Applicant believes that the opportunities for discovery provided by the Licensing Board's Order were reasonable and more than adequate to enable Joint Intervenors to prepare for trial (i.e.,
to cross-examine) on their own contentions.
The overall timc period (five months) was adequate, and an unlimited second round provided the opportunity not only for follow-up requests but for the initiation of inquiries which had been overlooked in the first round.
Applicant's Answer in Opposition to Joint Intervenors' Motion to Compel, dated October 13, 1981, outlines the scope of the discovery effort which has been required in order to meet Joint Intervenors' requests.
I am informed, for example, that 2,140 pages of Applicant documents have been reproduced for Joint Intervenors.
That figure does not begin to represent the volume of materials which have been produced for inspection and which Joint Intervenors have chosen not to copy.
In these circumstances, discovery requests filed outside the time period prescribed by the Licensing Board's Order must be regarded as prima facie unreasonable.
See Commonwealth Edison Company (Zion Station, Units 1 and 2), ALAB-196, 7 A.E.C.
- 457, 463 (1974).
. SHAN, PITTMAN, POTTS & TROWBRIDGE Kenneth1M. Chackes, Esquire October 20, 1981 Page Three I appreciate the fact you were attempting, by your letter, to solicit our voluntary agreement with these requests in the hope of avoiding the Licensing Board's involvement in a potentially uncontested matter.
In the past we have often been able to reach an accommodation.
The timing and scope of the additional discovery requests contained in your letter of October 13, however, convince me that Joint Intervenors are unwilling to conclude the discovery process voluntarily and now seek to disrupt the orderly progress of the proceeding.
You-provide no explanation of why Joint Intervenors have waited until so long after Applicant's second-round dis-covery responses were made available (September 10, 1981) to seek additional information.
Except for an introductory paragraph which purports to justify the first 11 of the 24 new document production requests, you provide no explanation as to why Joint Intervenors require such information in order to prepare for trial.
I will not ask my client -- in the absence of any effort on the part of Joint Intervenors to justify these extraordinary requests, and in view of the extensive discovery which already has taken place -- to undertake the additional burden and expense of responding to what appears to be an endless train of discovery requests.
Further, you must be aware that the burden involved is sub-stantially heightened ay the fact that Applicant and its counsel are busy with the effort to repare direct testimony, due to be filed on November 6, in response to Joint Intervenors' allegations.
While I am generally without the benefit of any explanation of the new discovery requests, I would like to provide you with some further information in connection with Applicant's position.
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A.
New Document Production Requests on Embedded Plates New document production requests 1 through 11 are said to relate to Joint Intervenors' Interrogatory No. 8(c)
(First Set), parts (i) and (iii) of which asked Applicant to enumerate the number of manually welded embeds repaired on site and the number of mechanically welded embeds repaired on site.
While Applicant initially objected to these parts of the interrogatory, I advised you by letter of August 26, 1981, that available documents do not provide the information requested, so that the answer to those parts of the interroga-tory is that Applicant does not know.
. SHAW, PITTMAN, POTTS & TROWBRIDGE Kenneth M.
Chackes, Esquire October 20, 1981 Page Four Your letter states that requests 1 to 11 represent "a continuing effort to obtain the answer to" this interrogatory.
Joint Intervenors ignore the fact that they have received an answer to the interrogatory which is both responsive and truthful -- Applicant does not know.
Consequently, there is no basis for the attempted justification of these eleven new document production requests, filed seven weeks after the interrogatory was answered.
I would also observe that Appli-cant does not consider the -number of embedded plates repaired on site to Le even remotely material.to the defense we intend to present in responsive testimony.
Further, it is apparent from even a casual reading of these requests that they will not reveal the number of plates repaired on site.
See, for example, request no.
9, which seeks a quality control procedure.
In addition, as explained below, our research shows that Joint Intervenors could have requested these documents much earlier.
No.
1.
Please note that SL:195 was produced for inspection by Joint Intervenors during the first round of discovery (i.e., shortly after July 10, 1981).
There is no excuse for seeking further discovery now with respect to a document which has been available to Joint Intervenors since well before the second round requests were filed.
Further, I should note that SL:128 (July 14, 1977), an_ attach-ment to BLSM-6708 (January 16, 1978), produced in response to Document Request No. 10 (First Set), provides details of the Cives inspection and includes data sheets on the numbers of stud defects and failures.
No.
2.
NCR-2-0831-C-B was produced in response to Document Request No. 8 (First Set).
Nos.
3, 4.
DLUC-2399 was produced in response to Document Request No. 5 (First Set).
The attachments to DLUC-2399, produced for inspection by Joint Intervenors shortly after July 10, 1981, included-610 pages of surveil-lance reports and supporting sketches from Daniel QA Record File N11.02.
That. file, which Joint Intervenors now request in toto, contains information on all vendors, and over 1200 pages with respect to Cives Steel Company alone.
This is a patently untimely and unreasonable request.
No. 5.
QM-48 was referenced in DLUC-5865 (October 16, 1980), which was produced in response to Document Request No. 10 (First Set).
. _ _ ~
- SHAW, PITTMAN, POTTS & TROWBRIDGE
.Kenneth M. Chackes, Esquire October 20, 1981 Page Five No.
7.
BLSM-3284 does not address Cives, and has nothing to do with embed repairs or rework.
No.
8.
SLBM:6-514 was produced in response to Document Request No. 10 (First Set).
No.
9.
Revision 6 of Quality Control Procedure 507 was produced in response to Document Request No.12 (First Set).
No. 10.
Because SLBM:6-514 apparently contained an incorrect NCR reference, I have asked Union Electric Company to search for an NCR dated October 25, 1976.
Enclosed is a copy of NCR-2-Oll7-C-A, which as you can see deals with Cives-manufactured connection bars for a door frame.
No. 11.
SLM 7-70 is updated by SLM 7-78, which has already been produced.
It is not specific to Cives and has no information on embed repairs.
B.
New Document Requests on Honeycombing in the Reactor Building Base Mat No general or specific justification or explanation is provided in your letter for the new and untimely document production requects on honeycombing in the reactor building j
base mat.
No. 12.
Joint Intervenors' Document Request No. 24 (Second Set) asked only for quality control surveillance reports, and not for the additional materials sought in this new request.
Joint Intervenors were made aware of concrete placing reports by Quality Control Procedure 109, produced i
in response to Document Request No. 20 (First Set), and by a blank report form which was produced in response to Document Request No. 19 (First Set).
No. 13.
NCR-2-0653-C-A was produced in response to Document Request No. 26 (First Set).
Please note, however, that Joint Intervenors' representatives did not request that the entire document be reproduced, and thereafter sought the remainder of the NCR in Document Request No. 47 (Second Set).
No. 14.
BLSE-4472 was produced in response to Document Request No. 26 (First Set), as an attachment to NCR-2-0653-C-A.
SHAN, PITTMAN, POTTS & TROWBRIDGE Kenneth M. Chackes, Esquire October 20, 1981 Page Six No. 15.
NCR-2-0856-C-A, with attached sketches of honeycomb areas and locations, has already been produced as a part of Attachment B to the September 27, 1977 Union Electric Company Final Report, Concrete Voids in Reactor Building Base Mat, in response to Document Request No. 32 (First Set).
Nos. 16, 17.
Applicant has no knowledge of the existence of any such maps.
C.
New Document Requests on Piping No general or specific justification or explanation is provided in your letter for the new and untimely document production requests on the piping allegations.
Nos. 19, 20.
AP-VI-02 rev. 8 (2/13/81) and interim change (6/18/81) were produced in response to Document Produc-tion Request No. 25 (First Set).
No. 22.
Please find enclosed an unmarked copy of the requested page.
The three words "The Originating personnel" had been highlighted on the original from which the copy produced was made.
I trust this delay has not unduly impeded Joint Inter-venors' preparation for cross-examination.
No. 24.
Joint Intervenors repeatedly cited IE Report 81-04 in their answers to the first round interroga-tories, and obviously were in possession of the report prior to July 10, 1981, and the filing of second round requests on August 10, 1981.
D.
Interrogatories 24 (b, c and d) (Second Set)
Applicant stands by its answers to the subject interrogatories as responsive and made in good faith to the interrogatories as written.
The question posed in your letter ("whether the persons conducting the test consider CLP evidence of defective material or weld") had not been asked in the interrogat ary.
Further, I should note that the time has long since expired for filing a motion to compel, pursuant to 10 C.F.R.
S 2.740(f), with respect to these answers.
. SHA% PITTMAN, POTTS & TROWDRIDGE Kenneth M.
Chackes, Esquire October 20, 1981 Page Seven II.
REVISION TO CURRENT SCHEDULE The Atomic Safety and Licensing Board's Special Prehearing Conference Order of April 21, 1981, established the following schedule with respect to a hearing on the so-called construction defects contentions (Joint Intervenors' Contention No. 1):
6.
Filing of direct, written October 1, 1981.
testimony on Joint Inter-venors' construction defects contentions.
7.
Prehearing Conference under October 15, 1981.
8.
Hearing commences on con-November 4, 1981.
struction defects contentions.
By letter to the Atomic Safety and Licensing Board dated September 11, 1981, Mr. Lessy, counsel for the NRC Staff, reported on the successful resolution of certain discovery-related disputes between Joint Intervenors and the Staff, and between Joint Intervenors and Applicant.
Mr. Lessy also reported that these parties had agreed to modify certain aspects of the above schedule in order to provide for motions for sum-mary disposition.
He reported, however, that Joint Intervenors had not agreed to the date of November 17, proposed by Applicant and the Staff, for the start of the hearing on Joint Intervenors' construction defects contentions.
By letter to the Licensing Board of September 17, 1981, you stated that "Mr.
Lessy's letter [of September 11, 1981] accurately reports the areas of agreement regarding the proceedings in this matter."
You further stated "I am also pleased to report that Joint Intervenors no longer dis-agree with the date proposed by the Applicant and Staff for commencement of the hearing; November 17, 1981."
Discovery had been concluded at the time you wrote this letter.
On September 24, 1981, the Licensing Board issued a Memorandum and Order (Modification of Hearing Schedule) establishing November 17 as the commencement date for the hearing.
Twenty-six days after your letter of agreement, on October 13, 1981, you wrote a letter to me proposing that the hearing commence the week of January 4, 1982 -- a seven-week delay.
You suggest a revision, as well, to the schedule for
SHAW, PITTMAN,' POTTS & TROWBRIDGE Kenneth M. Chackes, Esquire
-October 20, 1981 Page Eight (a) the filing of Joint Intervenors' answers to summary dis-position motions, even though no new information is sought as to concrete cracks or concrete? cover requirements (the subjects of_ motions).and much_of the information sought,in your letter is. irrelevant to the motions filed' (only the Staff moved on embedded plates; no motions have been filed withcrespect to honeycombing in the reactor building base mat; of the piping issues only SA-358 piping is the subject of motions); (b) the prehearing conference, which is scheauled
.for this Monday, October 26; and (c) the filing of testimony and exhibits.
j I am amazed at this proposal, which literally falls on the heels of Joint Intervenors' agreement to the current schedule.
Joint Intervenors have been aware of the general schedule for hearing their construction defects contentions i
_ since the special prehearing conference of March 24, 1981.
There has been ample time'to prepare cross-examination.
Delay in the hearing on the construction; defects contentions would also delay the litigation of Joint Inter-venors' environmental contentions on radiological effluents.
Now that the'NRC Staff's safety. evaluation report and draft environmental impact statement have been issued, there-is every reason to believe that those contentions could be. heard on schedule.
As noted in your letter, the plant will be completed-eight months later than previously had been estimated.
That development alone is no reason for disruptive, last-minute
. delays in this hearing.
The allegations to be heard' relate to events which are historical -- dating back to the-1976-78 time frame.
Furthermore, based upon your. agreement to the i
current' schedule, complicated arrangements have been made i
to schedule the appearance of witnesses'to testify in answer-to Joint Intervenors' contentions.
The only explanation provided,.in your letter, for
- a schedule ' change is that "[i] t is. highly unlikely, due in large part'to our need for the additional materials set out i
above, in my previous ~ correspondence and our motion to compel, l
that we will be able to comply'with the current schedule."
i With respect to the additional materials requested, I have explained that in some cases it has already been pro-vided, in most cases Joint Intervenors should have sought the i-1
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SHAW, PITTMAN, POTTS & TROWBRIDGE Kenneth M. Chackes, Esquire October 20, 1981 Page Nine material in the second round of discovery, and in all cases it cannot be viewed to be critical to'your preparation for cross-examination given the vast quantity of information already provided by Applicant.
With respect to information requested in your previous correspondence, please see Mr. Galen's response of October 14, 1981, providing a copy of the materials requested.
I feel you should know that while your letters of September 10 and 28, 1981, indicate that Applicant failed to provide relevant appendices and attachments to requested dccuments, in fact Applicant had produced these appendices and attachments for inspection and Joint Intervenors' representatives simply did not identify them for reproduction.
For all of the foregoing reasons, Applicant would oppose any suggested revision to the current schedule.
If you would like to discuss any of these matters prior to the prehearing conference on Monday, please feel free to telephone.
I will be in Union Electric offices all day on Friday, October 23.
Sunday evening, October 25, I will be staying at the Marriott (421-1776).
Sincerely, Thomas A. Baxter Counsel for Applicant TAB:jah Enclosures cc:
per Certificate of Service
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i
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Docket,No. STN 50-483 OL,
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(Callaway Plant, Unit 1)
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CERTIFICATE OF SERVICE
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I hereby certify that' copies of the foregoing letter
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SERVICE LIST 1
James P. Gleason, Escp. tire Kenneth M. Chackes, Esquire CM man Chackes and Ibare Atomic Safety and Licering Board 314 N. Broadway 513 Gilmoure Drive St. Icu s, Missouri 63102 i
i Silver Spring, Maryla'nd 20901 Mr. John G. Reed s Mr. Glenn O. Bright Poute 1 Atomic Safety and Licensing Kingdom City, Missouri 65262 Board Panel U.S. Nuclear Regulatory Comrission Mr. Howani Steffen Washa.ngton, D.C.
20555 Charcis, Missouri 65024 Dr. Jerry R. Kline Mr. Farold Iottrann Atomic Safety and Licensing Poute 1 Board Panel Owensv2.lle, Missouri 65066 U.S. Nuclear Regulatory Comnission Washington, D.C.
20555 Mr. Earl Brcwn P.O. Box 146 Roy P. Lessy, Jr., Esquire Auxvasse, Missouri 65231 Office of the Executive legal Director l
U.S. Nuclear Regulatory Ccrtrissian Mr. Fred Luekey Washington, D.C.
20555 Rural Route Rhineland, Missouri 65069 Docketi:1g and Service Section Office of the Secretary Mr. Samuel J. Birk,
U.S. Nuclear Regulatory Comrission P.O. Box 243 l
Washington, D.C.
20555 bbrrison, Missouri 65061
, Joseph E. Birk. Esquire Mr. Pcbert G. Wright Assistant to tne' General Counsel Poute 1 U0 ion Electric CC M r Fulton, Missouri 65251 p.O..Bex 149 l
St. Iouis, Missouri d3166 Eric A. Eisen, EsquJ.re I
Birch, Horton, Bittner & btnroe A. Scotthuger, Esquire 1140 Connecticut Avenue, N.W., #1100 Assistant General Counsel Washingtcn, D.C.
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DANIEL INTERNATIONAL CORPORATIO'N OUAUIY ASSURANCE PROGRAM '
12/15/ so ASME SECTION 111. DIVISION 1 ae NONCONFORMNICE A'ID gg m
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materials and Items in nonconformance with.applicabic Code This Section describes the controls used to assure that
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standards.' drawings, specifica tion, procedures or instructions
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are not inadvertantly used or installed. These controls include
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l' provisions for identification, documentation, segregation or
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correction and close-out of j<p
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This Section also des cribes the controls; used to assure that
!i-conditions adverse to fuillty ar'e promptly identified pud are f
reported to appropriate levels of clarygement.
These ron't rol s
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assure that the cause of the condition adverse to quality is
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identified, documented and corrected to preclude repetition.
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e.2 PROCEDUPE dh,.
.8.2.1 Materials and Itens which are found to be in nonconformance with 4
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project or Code requirements are identified, documented, scare-
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ga ted, or, cont.rcilcti, d.ixposi*in..ed, corrected and clGaed out in 3.; 4 i accordance wich Construction Procedure A M II-02, "Nonconform-
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~8.2.2 Uhen' a noccGaforman$e 5 ance Centrol and Reporting."
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' (f it identified, the Quality' Control L d s,,
Inspector initiates the appropriate control t.g (QC Hold Tag,
.. : q,3 Exhibit 20, or I!ald_ for h iber QC Inspection / Action Tag, y C 'l Exhibit 21) sad attaches the tai to the noncenter::ing material j f.
or item (s) to stop or to control further processing isntil the
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nonconformance is resolved.. Wen a QC Huid tag is not used, the it sj
.QC Inspector dociamantir Ethp.,:yethod used ta cantral the noncon-
'15 forming material #r 7tns(r) ori the Nonconformance Report ('iCR)
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,(Exhibit 48) or Deficiency Report (DR) (Exhibit I.82).
Noncon-
'. ! '*t formance Reports Repair dG. nsedjfsfYida.
Deficiency Reports are used s en.
for nonconfor.unces requiring a m ~
d ij USE-AS-IS or h
for nonconformances requiring a revolk or reject disposition.
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! h 8.2.3 The Originating per3cangE: downts the identification of the N N.
nonconfoming ma t erfiI.Ee 5 It'em(s ), ' The' ' de's e di p t ion WtIEnon'
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conforming material or item (s), the inspection method osed to
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