ML20059C066
| ML20059C066 | |
| Person / Time | |
|---|---|
| Issue date: | 10/27/1993 |
| From: | Robert Davis NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | |
| Shared Package | |
| ML20059C064 | List: |
| References | |
| 93-01-PF, 93-1-PF, 93-673-01-PF, 93-673-1-PF, NUDOCS 9310290226 | |
| Download: ML20059C066 (22) | |
Text
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i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Law Judge Morton B. Margulies
)
In the Matter Of
)
Docket No. 93-01-PF
)
LLOYD P.
ZERR
)
ASLDP No. 93-673-01-PF
)
)
Motion for Admission of Statement of David P.
Loveless q
In Liqu of Live Testimony The Nuclear Regulatory Commission (NRC) hereby moves for the admission of the attached (original) declaration of David P.
Loveless (Enclosure 1) in lieu of live testimony at hearing.1 In the "NRC Witness and Exhibit List" served upon defendant's counsel on October 12, 1993, the NRC attached a copy, and proposed admission, of Mr. Loveless' written declaration at the hearing.
On October 19, 1993, the Defendant served an " Objection to NRC Pronosed Stipulation."
Pursuant to 10 C.F.R.
S 13.33(b),
the NRC now moves for an Order permitting the admission of said statement.
As an alternative resolution, the NRC would also be willing to arrange for a deposition by telephone for admission at the hearing.
The controlling procedure, as set forth in 10 C.F.R.
S
- 13. 33 (b), provides, in pertinent part, as follows:
At the discretion of the ALJ, testimony may be admitted in the form of a written statement or deposition.
Any 1
The attached " Affidavit of David ?, Loveless" was inadvertently styled as an affidavit but is actually a declaration under penalty of perjury, equivalent to an affidavit, in force and effect, pursuant to 28 U.S.C. S 1746.
9310290226 931027 D'
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2 such written statement must be provided to all other parties along with the last known address of such witness, in a manner which allows sufficient time for 1
other parties to subpoena such witness for cross-examination at the hearing.
As explained below, the NRC submits that acceptance of the written statement of Mr. Loveless is justified and should be admitted.
Mr. Loveless' statement would be used essentially as rebuttal to anticipated testimony of the Defendant.
During his deposition on August 10, 1993, the following exchange occurred.
during questioning of the Defendant by NRC counsel, Roger K.
Davis:
Q It didn't give ycu any pause?
Do you recall anyone 1
over telling you it was okay to claim lunch time while working at the Hatch plant as a resident inspector or elsewhere in an inspector's position?
A I recall that at least on one occasion while I was in the -- doing a region-based inspection that that type of discussion came up at Sequoyah at which point, based on the discussion, I would later -- which later came out that it was Dave Loveless that the conversation took place was -- or with; that there were times when he wouldn't -- would have to work through lunch and that type of thing.
Q How much time do you think you estimated for inclusion in your time and attendance hours for lunch when you q
discussed work?
A I have no idea.
I know that Ron Fields sat down and calculated this all out.
So maybe he'd be the better one.
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Q Would you have included 45 minutes?
A I would say yes; that the answer -- I would say probably without exception that the conversations that took place during lunch time focused around work.
(Transcript at 55-56; a copy of introductory pages, pp. 55-56 and the Reporter's Certificate are attached as Enclosure 2).
In his statement, Mr. Loveless has declared, under penalty of perjury, that, inter alia:
6.
I do not recall if I ever discussed with Mr. Zerr the payroll requirements associated with the 45-minute lunch period when required to work or when discussing work during the lunch period.
7.
I am certain that I never told Mr. Zerr that it was permissible to claim work hours for a meal period if work is discussed during the meal period.
8.
I am aware that there were times when resident inspectors at Sequoyah were required to work through their lunch period, for instance required to work in the control room, and the lunch period would not be deducted from the hours worked.
10.
Neither now, nor while working at Sequoyah, did I believe that it is permissible for an NRC employee to count as work hours the 45-minute period for a meal period if work is discussed on a voluntary basis during the meal period. at 2.
It is clear that the proposed testimony is extremely brief and limited in nature.
In addition, producing Mr. Loveless for presentation of such brief testimony at the hearing would involve the expense and burden of bringing Mr. Loveless from Bay City, Texas, to Bethesda, Maryland, and taking him away from his important work as Senior Resident Inspector at the South Texas Electric Generating Station during a restart operation at the plant.
Mr. Loveless has advised NRC counsel that travel to the I
4 hearing would involve essentially a full day of travel for a trip from his residence to Bethesda, Maryland, including a 2 and 1/2 hour drive to a Houston airport.
As a rebuttal witness, it would also be' difficult to determine on what day Mr. Loveless would be testifying.
Thus, Mr. Loveless' appearance would require a minimum of two days of travel away from his duties and most likely three or four days.
In the Defendant's statement of objection, he declares that
"[f]or the first time, the NRC proposes to have the testimony of a substantive witness by affidavit only."
The significance of this point is not obvious.
As a live rebuttal witness, there is no clear requirement to list Mr. Loveless even in the witness list.
However, submission of the proposed statement, in lieu of live testimony, at the time of the exchange of witness lists was required by, and a matter of compliance with, the provisions of 10 C.F.R. SS 13.33(b) and 13.22(a).
The Defendant's second point is that admission of Mr. Loveless' statement would fail to provide Mr. Zerr with an opportunity for cross examination.
However, this proposition is in error since provision of the j
)
statement with the witness list clearly affords other parties an j
opportunity to subpoena the witness for hearing as provided in 10 C.F.R. S 13.33(b).
Defendant also states an objection "to the receipt of any testimony which deprives him of his common law and constitutional rights."
The failure to specify any particular right makes it impossible to respond, other than to point to the preceding discussion regarding cross-examination.
- Finally,
5 Defendant states that he "does not object to the inclusion of witness, David P.
Loveless, on the witness list."
On October 26, 1993, the undersigned coutsel for the NRC proposed to counsel for the Defendant as a possible alternative to the admission of the written statement that the NRC arrange for a deposition by telephone, permitting cross-examination by counsel for Defendant, for use at the hearing.
Counsel for the Defendant declined to agree to this alternative proposal.
For the foregoing reasons, the NRC respectfully requests that the attached declaration of David P. Loveless, executed on October 12, 1993, be deemed admissible for the hearing in this case.
In the alternative, the NRC would be willing to arrange for a telephonic deposition for use at hearing, as indicated above.2 Respectfully submitted, Roger K. Davis Daryl M.
Shapiro U.S. Nuclear Regulatory Commission Mail Stop 15B18 Washington, D.C. 20555 (Tel. 301/504-1606)
Counsel for the NRC DATED:
October 27, 1993 2
Should neither resolution be afforded, the NRC will endeavor to present Mr. Loveless as a live witness at the hearing.
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4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD l
Before Administrative Law Judge Morton B. Margulies
)
In the Matter Of
)
Docket No. 93-01-PF
)
LLOYD P.
ZERR
)
ASLBP No. 93-673-01-PF
)
)
i 1
AFFIDAVIT OF DAVID P.
LOVELESS I,
David P. Loveless, declare as follows:
'I 1.
I am the Senior Resident Inspector, South Texas Project Electric Generating Station, Region IV, U.S.
Nuclear Regulatory Commission, and have been an NRC employee since 1984.
2.
My business address is:
I MAIL:
P.O.
Box 910, Bay City Texas, 77404.
PHYSICAL:
South Texas Project Electric Generating i
Station, 8 miles west of Wadsworth, Texas, 1
on Texas Farm Road 521.
3.
My home address is:
Mail:
P.O. Box 1352, Bay City, Texas, 77404, j
i Street: 25 Matagorda Dunes, Matagorda, Texas.
i 4.
I was stationed by the NRC at the Sequoyah Nuclear Power Plant from March, 1986 to September, 1990.
5.
While I was stationed there, Lloyd Zerr, another NRC j
employee was on site at least several times, and I. recall talking to him about various subjects.
6.
I do not recall if I ever discussed with Mr. Zerr the payroll requirements associated with the 45-minute lunch period when required to work or when discussing work during the lunch period.
7.
I am certain that I never told Mr. Zerr that it was permissible to claim work hours for a meal period if work is discussed during the meal period.
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8.
I am aware that there were times when resident inspectors at Sequoyah were required to work through their lunch period, for instance required to work in the control room, and the lunch period would not be deducted from the hours worked.
9.
It certainly was not the general policy at-Sequoyah to require work by resident inspectors during the lunch period.
10.
Neither now, nor while working at Sequoyah, did I believe that it is permissible for an NRC employee to count as work hours the 45-minute period for a meal period if work is discussed on a voluntary basis during the. meal period.
I declare under penalty of perjury that the foregoing declarations are true and correct.
l Executed this l) ' day of October, 1993.
./
DAVID P.
LOVELESS P
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Agency:
nuclear negulatory commission Tide:
oegosition or Lloyd P. zerr
, D M CC NO.
93-01-PF; ASLBP No. 93-673-01-PF C
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1612 K St. N.W, Suite 300
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UNITED STATES NUCLEAR REGULATOR COMMISSION ~
2 ATOMIC SAFETY LICENSING BOARD i
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............----X 1
e Docket Number b3-01-PF
,l In the matter of:
5 LLOYD P.
ZERR
- ASLBP Number 93-673-01-PF 6
x 7
7 8
U.S. Nuclear Regulatory Commission 9
One White Flint' North i!'
10 Rockville, Maryland 11 12 Tuesday, August 10, 1993-13 14 15 Deposition of:
y 16 LLOYD P.
ZERR l
17 called as a witness herein by Counsel for U.S. Nuclear 18 Regulatory Commission, pursuant to notice and c.areement of 19 Counsel, in the Offices of the Nuclear Regulatory Commission' f
20 in White Flint, Maryland, commencing at 2:00 p.m.,
before I
21 MARK MAHONEY, a Notary Public in and for the Commonwealth of-22 Virginia, when were present on behalf of the respective 23 parties:
24
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25
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Court Reporters 1612 K Street, N.W.,
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1 APPEARANCES OF COUNSEL:
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3 lOn Behalf of the U.S. Nuclear Regulatory Commission:
4
.5 ROGER K. DAVIS, Esquire 6
DARYL M. SRAPIRO, Esquire 7
Office of the General Counsel 8
United States Nuclear Regulatory Commission 9
Washington, D.C.
20555 10 4
11 On Behalf of the Deponent:
12 13 TIMOTHY E.
CLARKE, Esquire 14 5 North Adams Street 15 Rockville, Maryland 20850 l
16 2
17 5
18 19
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22 23 24 25 i
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'I N'D'E X
-2 WITNESS EXAMINATION BY 3-LLOYD P.
ZERR BY MR. DAVIS 4
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5 ZERR EXHIBIT-1 36 6
ZERR EXHIBIT 2 46 l
7 ZERR EXHIBIT-3 61 i
E 8-ZERR EXHIBIT 4 66 l
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9 ZERR EXHIBIT 5 71 10 ZERR EXHIBIT 6 74 l
11 ZERR EXHIBIT 7 94 l
12 ZERR EXHIBIT 8 101 3
13 ZERP. EXHIBIT 9
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l 14 ZERR-EXHIBIT 10 112 15 i
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19 20 21 22 1
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-3 ANN RILEY & ASSOCIATES, LTD.
= Court Reporters.
1612 K~ Street,LN.W.,' Suite 300 l
Washington, D.C.
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. Whereupon, 2
LLOYD P.
- ZERR, l
.I 3
a witness, was called for examination by counse1~for the j
4 U.S. Nuclear Regulatory Commission and, having been duly 5
sworn, was examined and testified as follows:
6 EXAMINATION BY COUNSEL FOR THE NRC:
7 BY MR. DAVIS:
8 Q
Good afternoon, Mr. Zerr.
I am Roger Davis, an 9
attorney for the NRC.
Beside me is Daryl Shapiro, he is 10 also an attorney for the NRC and co-counsel for the NRC in-11 this case.
12 Do you understand that we are here today pursuant 13 to a motion that the NRC brought in your case at the 14 Licensing Board of the NRC to take your deposition, which 15 motion was granted by the Judge on July 7th?
16 A
I do.
17 MR. DAVIS:
Mr. Clarke, did you have something you 18 wished to say?
19 MR. CLARKE:
Yes.
Before you begin any 20 questioning, I would like to note an objection, first, to 21 these proceedings, first of all, that they are unnecessary, t
22 they are unduly burdensome and inconsistent with the 23 previous discovery recognizing that we are here because of 24 an order only.
This is not a consensual proceeding.
I 25 We also preserve our constitutional objections, ANN RILEY & ASSOCIATES, LTD.
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the Federal. prosecutors'have given written statements 2
concerning the fact that they choose not to go forward on 3
certain matters that have been brought.to their attention.
4 However, that is not a blanket statement of no prosecution, 5
and that, therefore, any statements that are made here are 6
being coerced by order of the Administrative Law Judge, and 7
they are not done voluntarily.
S Alec. I would indicate to you that there is no 9
indication of any immunity or statement of intention by a 10 prosecutor in either a county in Georgia, a State Office of 11 Prosecution in Georgia, or in Montgomery County, Maryland, 12 which is the location where we currently are operating,.and 13 where the NRC has its headquarters, and an interpretation of 14 various provisions could be made that, if, in fact, any 15 activity took place, it may have taken place in Rockville, 16 Maryland,.and if, in fact, that took place in Rockville, 17 Maryland, the local prosecutor or the State's Attorney from 18 Montgomery County would be the appropriate prosecutorial 19 official, and there has been no contact ieom that person, 20 Additionally, we would preserve note our 21 constitutional objection to these proceedings on the basis 22 that these matters have been presented to grand juries and 23 other appropriate authorities of the United States 24 Government for the Department of Justice,'that throughout 25 the entire proceeding all of those matters.have now been ANN RILEY E ASSOCIATES, LTD.
Cour; Reporters 1612 K Street, N.W.,
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resolved, and that because of that resolution, there has 2
been a statement'that the matter has been closed.
3 Notwithstanding the fact that it has been closed, this 4
proceeding is still going forward, and we object to this 5
-deposition in that regard, and would indicate that this is 6
coerced testimony and is being forced upon Mr. Zerr.
7 Lastly, I would object to any alternating 8
interrogation and would object to any bouncing of one 9
interrogator to another, and would, in a court, raise'that 10 objection to the point where each witness, whatever witness, 11 would be subject to being questioned by one attorney, not by 12 a series of attorneys, or a pair of attorneys.
So we would 13 preserve that same position here today, and that is that any 14 questioning should be by one attorney and not by alternating 15 attorneys.
16 I am not sure there is any response that is 17 necessary.
18 MR. DAVIS:
I believe there is, and I would like 19 to correct and say that you claim that all questions today 20 are coerced by court order, and that all questions have a 21 constitutional objection and that all answers would be 22 coerced by the court?
23 MR. CLARKE:
All answers are provided because we 24 are here because of a court order, that's correct.
25 MR. DAVIS:
Well, we.could go through each 1
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.1 question.
I don't.think you can raise a blanket objection 2
to every question in the depositier.
I guess I want to know
~
3 if your intent is that you are raising.a constitutional L
4 objection, did I understand you-correctly,_to every question 5
today?
6 MR. CLARKE:
I am raising a constitutional 7
objection to being here and being present and doing this P
8 proceeding at all.
I wish to raise an objection which P
9 would, again, in a court, would be characterized as a.
10 standing objection.
That is, we object to each and every 11 question.
If there are specific objections to particular 12 questions, those'I will note per question.
I would 13 anticipate that there may be a question or two to which I i
14 may raise a particular objection, but other than that, I 15 would ask to have a standing objection, as would happen ~in 16 any courtroom where there would be a standing objection to a 17 line of questions.
That simply preserves that objection for 18 the purposes of appeal, but prevents the necessity of you t
19 having to simply stop every question while I argue the 20 question, and then, in the context of the deposition, have 21 to take the answer anyway.
So I am issuing a standing 22 objection now, and perhaps it won't ever be necessary to 23 deal with these issues.
24 MR. DAVIS:
What constitutional privileges are you 25 asserting?
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1 8
'l MR. CLARKE:
Fourth Amendment constitutional 2
privileges which he has, a constitutional privilege against 3
unreasonable' search and seizure.
A constitutional privilege
)
4 against-self-incrimination.
I do not practice law in the 5
State of Georgia.
I cannot suggest to him what provisions 6
there would be under the Georgia Constitution, but.certainly 7
in the State of Maryland, he would have a privilege under 8
various provisions of the Maryland Declaration of Rights as 9
well as the Fourteenth Amendment of the Constitution of the 10 United States.
11 The Maryland Declaration of Rights provision is, 12 for your information, interpreted to be essentially the same 13 as the privileges against self-incrimination, unreasonable 14 searches and seizures, and due process.
1 15 MR. DAVIS:
So I don't interpret this as a' blanket 16 refusal to answer the questions.
17 MR. CLARKE:
He hasn't refused to answer any 18 questions yet, and it is not a blanket refusal to answer 19 questions.
It is a blanket objection to the proceedings and 20 to going forward.
If we were going to blanketly refuse to 21 answer questions, we wouldn't have been here today.
22 MR. DAVIS:
Excuse me a second.
23 MR. SHAPIRO:
Let's go off the record, please.
24
[ Discussion off the record.]
25 MR. DAVIS:
Back on the record.
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'1.
Q.
'Now, am I correct that you included in your 2
estimates for time and attendance lunch time if you 3
discussed work?
4 A
That's correct, which would have been on most P
5 days.
6 0
When you were in Region 2 at headquarters, you had 7
to work eight hours or nine hours, whatever your1 regularly 8
scheduled hours were, in addition to a 45-minute lunch ~
9 break; is that correct?
10 A
That's correct.
11 Q
Why did you believe that it was all right to claim 12 lunch time when you were at Hatch?
13 A
Because it was an uninterruptable time.
I was 14 dealing with the plant.
There was calls coming in that we'd 15 have to take.
It wasn't like in the regional offices or up i
16 here where you can actually leave the building and go 17 somewhere.
You can either go-somewhere to eat or you can go-18 to a mall or something like that.
l 19 Q
Didn't you think it was advisable to check with 20 one of the other resident inspectors before you claimed it 21 since it was a departure from your past practice?
22 A
Never even occurred to me.
23 Q
It didn't give you any pause?
Do you recall 24 anyone ever telling you it was okay to claim lunch time q
25 while working at the Hatch plant as a resident inspector or ANN RILEY & ASSOCIATES, LTD.
Court. Reporters
-1612 K Street, N.W.,
Suite 300 Washington, D.C.
20006 (202) 293-3950
.. ~. _.
=
56-1 elsewhere in an inspector's position?
2 A
I recall that at least on one occasion while I was 3
in the -- doing a region-based inspection that that type of 4
discussion came up at Sequoyah at which point, based on the 5-discussion, I would later -- which later came out that it 6
was Dave Lovelace that the conversation took place was -- or 7
with; that there were times when he wouldn't -- would have 8
to work through lunch and that type of thing.
9 Q
How much time do you think you estimated for-i 10 inclusion in your time and attendance hours for lunch when 11 you discussed work?
.12 A
I have no idea.
I know that Ron Fields sat down 13 and calculated this all out.
So maybe he'd be.the'better 14 one.
15 0
Would you have included 45 minutes?
16 A
I would say yes; that the answer ~-- I would say I
17 probably without exception that the conversations that took l
18 place during lunch time focussed around work.
19 Q
Have you had occasion to review regulations on f
20 time and attendance, the NRC regulations on time and 21 attendance, since you started work at the NRC?
22 A
Not to my knowledge.
23 Q
Am I correct that some of the hours that you 24 submitted for work during the first few months at Hatch 25 could have been hours you worked at home?
. ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1612 K Street, N.W.,
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REPORTER'S CERTIFICATE This-is to certify that the attached proceedings before-the United States Nuclear Regulatory Commission in the matter of:
NAME OF PROCEEDING:
Deposition of Lloyd Zerr DOCKET NUMBER:
PLACE OF PROCEEDING:
Rockville, MD were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under tne direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.
4 Af&
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-4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD S
Before Administrative Law Judge Morton B. Margulies
)
In the Matter Of
)
Docket No. 93-01-PF
)
LLOYD P.
ZERR
)
ASLBP No. 93-673-01-PF
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing " Motion for Admission of Statement of David P.
"oveless in Lieu of Live Testimony" were served upon the fr i. iwing persons by U.S. mail, first class, except as indicated t 1 asterisk by hand delivery, this 27th day of October, 1993.
Morton B. Margulies*
Lloyd P.
Zerr Chief Administrative Law 718 13th Street, NE Judge Washington, DC 20002 Atomic Safety and Licensing Board, Mail Stop EW-439 Timothy E. Clarke, Esq.*
U.S. Nuclear Regulatory 5 North Adams Street Commission Rockville, MD 20850 Washington, DC 20555 (original plus two copies)
Office of Commission Appellate Adjudication
- U.S. Nuclear Regulatory Commission Washington, DC 20555 l%k %4 Roged K. Davis U.S.
Nuclear Regulatory Commission Office of the General Counsel Mail Stop 15 B18 Washington, DC 20555 Tel. 301/504-1606
-