ML20071M251
| ML20071M251 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 05/25/1983 |
| From: | Guild R PALMETTO ALLIANCE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8305310155 | |
| Download: ML20071M251 (21) | |
Text
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D 4
A UNITED STATES OF AMERICA g-8 TA NUCLEAR REGULATORY COMMISSION o a e
ATOMICSAFETYANDLICENSItJkdGARh 2
BEFORE THE 4Q
'S In the Matter of 4
Docket flos.90-413
/p DUKE POUER COMPANY, -et al.
O
)
(Catauba Nuclear Station,
)
May 25, 1983 Units 1 and 2)
)
PALMETTO ALLIAfjCE MOTION TO ESTABLISH DISCOVERY SCHEDULE ON ITS QUALITY ASSUR ANCE C0ffTEfjTION 6 Pursuant to 10CFR Section 2.740(b)(1) and the Board's direction of May 13, 1983, Palmetto Alliance hereby noves for an Order as hereafter set forth as establishing a Discovery Schedule,,
with respect to its Quality Assurance Contention 6.
This relief by uay of the extension of discovery on this contention is sought in order that Palmetto Alliance may have access to relevant, material evidence bearing on significant Quality Assurance prograr breakdowns at Catauba not yet available to it, in order that it may prepare for the fair and expeditious hearing of this matter and on the basis of good cause as is shown
- belou, Direct evidence from numerous Catauba Quality Control gn$
E'S inspectors of systematic quality assurance deficiencies including bLe falsification of documents, harrassment, intimidation and a n
my "uhitewash" investigation by Duke Pouer Company, all known to the Co
$Q Uuclear Regulatory Comnission Staff, has come to the attention of n
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Palmetto Alliance only in mid-April 1983.
See, NRC Staff Seccnd Supplemental Response to Palmetto Alliance First Interrogatories and Production Requests on Contentions 6 and 7 (re: General Interrogatory 4), April 8,
1983, transmitting the Memorandun of P.K. Van Doorn, Senior Resident Inspector, Catauba to Carl E.
Alderson, Director, Enforcement and Investigation Staff, dated 3/15/82, Attachment 3; "handuritten notes from QC and QA Inspectors which set forth their specific problems and concerns."
Item 10 of Attachment 1 to April 12, 1983, Duke Power Company letter; Attachment 4; and 26 April 1982 Management Analysis Company (MAC) Report 1 Attachment 6.
As late as May 19, 1983 (one day prior to the scheduled May 20, 1983, close of discovery on this contention and at the commencement of a Palmetto Alliance deposition of Inspector Van Doorn), the NRC Staff produced sone 97 " additional documents" comprising several hundred pages, identified in the course of a " partial response" to a Freedon of Information Act request regarding Catauba inspector allegations filed by the Government Accountability Project.
See, Ma y 19, 1983, letters of George Johnson, Esq., to counsel for Palmetto Alliance and of J. n. Felton, NRC to Billy P. Garde, Government Accountability Project, Attachment 11.
Included in these
" additional documents" uas a notice of significant licensee meeting betueen Duke and the Region II NRC Staff conducted Gay 2S, 1982, on the QC allegations significantly not circulated to this Board or the parties until now; and; an undated Memo from Inspector Van Doorn to Vorse of the Office of Investigation detailing Van Doorn's conclusions that falsification of 2
documents, harassment and intimidation of QC inspectors had occurred at Catauba.
Attachments 7 and 5 respectively.
Palmetto Alliance is informed that the NRC Office of Inspector and Auditor has initiated an investigation of the Staff handling of the Catauba inspector allegations.
'See, May 15, 1983, Charlotte Observer, "NRC Unit Examines Probe," Attachment 10.
In its February 2, 1983, Memorandum and Order establishing the present schedule in this proceeding, the Board observed:
" Generally speaking, Licensing Boards determine scheduling matters on the basis of representations of counsel about projected completion dates, availability of necessary information, and adequate opportunities for a fair and thorough hearing."
Order, at p.
6.
The Board also observed that additional discovery time "could be obtained upon a shouing of good cause." Order, at p.
10.
Rule 26(f), Federal Rules of Civil Procedure, provides guidance for the convening of a discovery conference in order to establish a discovery plan and schedule, upon motion of counsel setting forth:
(1)
A statement of the issues as they then appear; (2) A proposed plan and scehedule for discovery; (3) Any limitations proposed to be placed on discovery; (4) Any other proposed orders uith respect to discovery; and (5)
A statenent shouing that the attorney making the Motion has made a reasonable effort to reach agreement with opposing attorneys on the matters set forth in the Motion.
3
With the provisions of Rule 26(f) as a guide, Palmetto uill endeavor to organize its shouing in support of this Motion.
CONTENTION 6:
QUALITY ASSURANCE AT CATAUBA As originally plead in its December 1981 Supplement to its Petition to Intervene, Palmetto Alliance Contention 6 read as follous:
6.
Substandard uorkmanship and poor quality control strongly suggest that actual plant construction is substantially belou NRC standards in many safety related areas.
Applicants have failed to provide a Quality Assurance progran which meets the requirements of 10CFR Part 50, APP.
B.,
and no reasonable assurance exists that the plant can operate without endangering the health and safety of the public.
The Commission has noted that 'The regulated industry
. bears the primary responsibility for the proper construction and safe operation of licensed nuclear facilities.'
Federal Tort Claim of General Public Utilities Corp., et al, CLI 61T10, 13 NRC 773, 775-776 (1981).
The NRC's Systematic Assessment of Licensee Performance Revieu Group found the Catauba facility 'Belou Average' among power reactor facilities under construction particularly 'in the areas of Quality Assurance including management and training.' NUREG, 0834, NRC Licensee Assessments, August 1981, p.
B-1.
A number of former Duke l
l Pouer Company construction vorkers, including a i
certified Quality Control Inspector, have complained of systematic deficiencies in plant construction and company pressure to improve faulty j
workmanship.
l In its December 1 Remorandum and Order the Licensing Board i
recast and admitted Palmetto Contention 6, observing:
I l
Much of Palmetto 6, which is concerned uith l
substandard workmanship and poor quality control, 4
i
lacks sufficient specificity.
The last sentence, however, concerns alleged ' corner cutting' and does supply a sufficient basis for a contention.
We recast the contention that we now accept to read as follous:
"Because of systematic deficiencies in plant construction and company pressure to approve faulty workmanship, no reasonable assurance exists that the plant can operate without endangering the health and safety of the public."
"The thrust of this contention is primarily toward alleged company attitudes and practices; proof of this contention, presumably involving specific instances of misfeasance need not be adduced at this stage."
Id.,
at p.
5.
Board Chairman Kelley observed at the January 12, 1982, Pre-hearing Conference that in order to prove a case on Contention 6 Palmetto Alliance must "get more specific about quality assurance that is substandard
." TR, 119. As acknowledged in its Responses to Applicant's initial discovery and on the record at the first pre-hearing conference, the "former Duke Pouer Company employees" referred to in the body of the contention are Nolan R.
Hoopingarner, II, and Uillian R.
McAfee.
Mr.
Hoopingarner observed substandard work and poor quality control, and experienced retaliation for making complaints to the NRC and others.
Mr.
McAfee, the former certified electrical Quality Control Inspector, observed substandard work and poor quality control, and experienced pressure to approve faulty work.
As further basis for its original contention, Palmetto Alliance cited the SALp 1 Report, NUREG 0834 rating of Catauba anong sone of the most notorious "Belou Average" nuclear plants under 5
construction, most with widely knoun quality assurance breakdouns: Marble Hill, Midland, South Texas, Washington Nuclear Project 2, Uatts Bar, and Zimmer. Id.
App.
B.
The SALP Board criticized Catauba for "ueaknesses in the area of quality assurance" and " numerous items of non-compliance involving failure to follou procedures for activities involving uelding, concrete placement, design, quality control inspections, records control, and electrical equipment installation." NUREG 0834, Appendix B-1.
Only by use of the tools of discovery could Palmetto probe beyond the information directly knoun to it upon which its contention was based, investigate the breadth of these documented problems at Catauba, and seek to prove its case.
DISCOVERY ON PALMETTO'S QUALITY ASSURANCE CONTENTION 6 Palmetto Alliance served its "First Set of Interrogatories and Request to Produce" on Applicants April 20, 1982, seeking, inter alia, the basis for the "Belou Average" SALP 1 rating, Interrogatory 26; identificaticn of documents reflecting QC Inspector disputes uith supervision, Intcrrogatory 23; and worker complaints of substandard workmanship and pressure to perform or approve faulty workmanship, Interrogatory 25.
Upon the Motion of the applicants, the Board suspended discovery on Contention 6 by Order of May 25, 1982, pending appeal by Applicants and Staff of the March 5, 1982, Board Order admitting contentions.
On December 1, 1982, the Board admitted Contention 6, as recast, and 6
lifted the stay on discovery.
Applicants first discovery response, " Applicants Responses to Palmetto Alliance First Set of was not served until Interrogatories and Request to Produce,"
Decemb er 31, 1962.
This response contained virtually no substantive information, but did identify some documents, but with the following caveat: " Applicants do not nou represent that this list is complete." Applicants Response at page 41.
On May 7, 1982, the NRC Staff responded in opposition to Palmetto's Motion to Require Staff Answers and objected to Palmetto Alliance Discovery on Contention 6.
No answers whatsoever were provided by the NRC Staff at that time.
By Order of February 9, 1983, the Board granted Palmetto Alliance's Motion to Compel, in part, and Applicants filed their Supplemental Reponses on February 28, 1983, containing the first substantive description of Quality Control Inspector disputes and complaints, Id. at pages 29-43.
The first documents reflecting this information were made available at Palmetto Alliance's March 14, 1983, trip to Applicant's Charlotte, N.C.,
offices.
Meanwhile, on February 17, 1983, the NRC Staff filed its first substantive ansuers to Palmetto discovery on this contention in its "NRC Staff Supplemental Response to Palmetto Alliance Interrogatories and Production Requests on Contentions 6 and 7."
There at p.
2, the NRC Staff explains that it is voluntarily responding (or objecting) to only those interrogatories where, in its judgment, "had there been a proper showing under Section 2.720(h)(2)(ii), the Staff could have been required tu respond."
Regarding Contention 6 answers and objections to Interrogatories 7
3, 4,
8, 10, 11, 15, 26 and 27 are provided.
No answers or objections were provided to Interrogatories 23 and 25. While some documents are identified in response to specific interrogatories, the Staff's response remains incomplete: "The Staff is attempting to identify other responsive communications not identified in these earlier submittals, and intends to supplement this response," Id. at p.
5.
On March 25, 1983, Applicants filed their Responses to "Dalmetto Alliance Follou-up Interrogatories and Request to Produce" regarding Contention 6 which had been served on March 16, 1983.
In this Response, at p.
22, Applicants responded to Follow-Up Interrogatory 9 seeking identification of documents regarding the Catawba Welding Inspector Task Force:
Documents responsive to this interrogatory will be identified and rade available for inspection and copying by March 30, 1983.
Id.
By letter of April 7, 1983, Applicants transmitted the identified documents responsive to this interrogatory, hceever "the descriptive index for these documents has not been completed.
The Index will be sent to you when complete." Id.
On April 8, 1983, the NRC Staff served its "Second Supplemental Response to Palmetto Alliance First Interrogatories and Production Request on Contentions 6 and 7 (re: General Interrogatory 4)."
The Staff describes this response as identifying " communications, uhich relate to the Staff's investigation of allegations by certain Duke Pouer Company l
Quality Control Inspectors." However, the Staff withholds and deletes significant information which it characterizes as "directly identifying certain confidential informants to the Staff, or providing portions of communications which would identify such informants." The Staff asserts that "since all the relevant information, save the identity of the confidential informants is available (assertedly from Applicant's responses),
there is no need for Palmetto to obtain the information from the Staff." Id. at p.
3.
It is this April 8, 1963, Staff response which includes the March 15, 1982, Van Doorn memo reflecting direct Staff knowledge of allegations of harrassment, falsification, significant violations of the Q.A. Program, and inspector concerns that Duke would attempt to " whitewash" the velding inspector technical concerns.
See, Attachment 3.
But for the claim of privilege, to protect the identity of confidential infernants (to ubich counsel for Palmetto Alliance expressed no objection as a matter of principle, see Certification of Counsel attached to April 6, 1963, response, supra,), the NRC Staff expressed no reservation whatever regarding the completeness of its Second Supplemental Response.
By telephone conversation of March 9th or 10th with Applicant's counsel, counsel for Palmetto Alliance had questioned the completeness of Applicant's Supplemental Response of February 28, 1983, to the critical original interrogatories 23 and 2S.
That Supplemental Response contained apparently significant limiting l
l language:
9
r:
The 'following documents relate to 1) disagreements disputes, or differences of opinion between quality assurance inspectors and their supervisors or Duke Pouer management within the scope of interrogatory 23 which have not'been resolved as between the supervisor and'the inspector, Emphasis added.
Id. at p.
29.
By letter of April 12, 1983, counsel for Applicants responded:
"In an earlier conversation (on March 9 or 10).you had raised questions with regard to our response of February 28, 1983, to those interrogatories.
In accordance-with our' discussions, we agreed to broaden our search for documents responsive to_your request.
That was done, and the widened search has recently been completed.
It included, among other things, our meeting with QA employees at Catawba.
As we discussed, the documents were available for inspection March 30.
However, the identification of those documents has only recently been l
completed.
That. identification is Attachments 2, 3 and 4 to this letter."
Id. at p.
2.
Attachments 2, 3 and 4 represent 86 separately identified documents, comprising several hundred pages of material.
By letter of April 14, 1983, Applicant's counsel, Mr. Gibson, identifies further documents responsive to interrogatories on-Contention 6 regarding a May 25, 1982, meeting between_ Duke Pouer Company and the NRC Staff regarding the Cataubc Welding Inspector Investigation:
i l-1 The 'URC Staff Second Supplemental Response to Palmetto Allicance First Interrogatories and i
Production Request on Contention 6 and 7 (re:
General Interrogatory 4)' produces documents frcm a May 25, 1982, presentation by Duke to NRC concerning resolution of inspector concerns.
Upen
- eceipt of this Staff response, we requested all documents pertaining to the May 25 presentation.
10 i
lt
The documents are identified on Attachment A to this letter.
l$-
By oversight of counsel, this letter was sent only to Charleston, S.C.,
and not to the Palmetto Alliance's Columbia office where this counsel has been engaged in vork on this proceeding, and to which all correspondence has been customarily addressed.
It uas not until tuo weeks later, then, that Palmetto actually received Applicant's April 14, 1983, correspondence.
At counsel's request, on April 28, 1983, those identified documents were transmitted by Applicants under cover letter of April 29, 1983.
Among significant neu documents reflecting the Duke and NRC " resolution" of the welding inspector allegations was a December 20, 1982, file memo of Duke's corporate CA manager, G.
W.
Grier, reflecting his meeting of that date with NRC Resident Inspector, Kim Van Doorn, and attaching Inspector Van Doorn's "nctes of Van Doorn interviews with Catauba inspectors," See.
Upon inquiry by Palmetto Alliance, counsel for the NRC Staff explained the omission of these Van Doorn notes from the Staff's document identification as an " oversight." He asserted that he uas unauare of the existence of such notes, but that their transmittal to Duke Pouer Company in December 1982 uas not inconsistent with the NRC Staff's claim of confidential source privilege (as asserted in the April 8, 1983, Second Supplemental Response) natuithstanding the notes reflection of substantive concerns and identification of the number of persons expressing these concerns.
11
In mid-March 1983, it came to the attention of Palmetto Alliance that Applicant Duke Power Company had directed written communication to former Catauba workers, which, in our judgment sought to discourage and " chill" cooperation by these workers with Palmetto Alliance and the NRC in investigating potential quality assurance problems at the facility.
Former QC Inspector and Palmetto Alliance member, Uilliam R.
McAfee, informed counsel for Palmetto Alliance that he had received such communication.
At the Board's direction, in a May 18, 1983, conference call, Applicants provided, by letter of March 22, j
1983, a report descri'bing their communication with present and former Catauba workers.
The written communication warns the recipients that they may be contacted by Palmetto Alliance and explicitly identifir.s Mssrs.
Hoopingarner and McAfee as former Duke employees, Palmetto Alliance members, and potential uitnesses in the proceedine.
At about the same time Applicants sought Board limitations on Palmetto's ability to communicate eith present and former Catauba l
workers.
In order to respond to these Duke's effort to discourage worker cocperation and Palmetto access to potential uitnesses, Palmetto Alliance requested the advice and assistance l
of the Government Accountability Prcject of the Washington-based Institute for Policy Studies, a project which had established a favorable reputation for supporting " whistle blowers" at such nuclear construction projects as Zimmer and Midland.
Upon learning of the evidence of quality assurance breakdouns at Catauba, the Government Accountability Project agreed to assist 12 1
L
and Staff of Palmetto Alliance St investigation of Catauba worker concerns and adequacy of NRC efforts in response.
On April 20 and 21, 1983, Government Accountability Project (GAP) Citizens Clinic-Director, Billie Garde, and Staff Associate, Jennifer Phillips, met with Palmetto members in York and Charlotte-and announced the beginning of their investigative effort.
On May 4-6, Palmetto Alliance counsel met with GAP staff in Washington, D.C., to work on a review of Duke and NRC.Catauba construction documents.
On Friday May 6,.1983, GAP and Palmetto representatives met with Washington counsel for. Applicants and with counsel for NRC Staff to discuss the Catauba investigation and a negotiated extension of discovery on Palmetto Contention 6.
While these discussions uere fruitful, no agreement was reached.
In response to the Board direction and approval of Palmetto depositions to be recorded by non-stenographic means, Palmetto initiated discussions leading to agreement and stipulation with both Applicants and NRC Staff for the taking of depositions t
during the weeks of May 9 and 16--with discovery to close as previously scheduled, Friday, May 20, 1983.
Applicants and NRC l
Staffs agreement to make available individuals ic'entified by each i
i party as most knowledgeable with respect to the subject _of each l
Palmetto contention are reflected in letters of May 5 and flay 11, 1983, respectively, which have been circulated to the parties.
I Ultimately depositions were taken by Palmetto Alliance of eight (8) Duke Power witnesses and tuo (2) NRC Staff (Inspectors Bryant and Van Doorn) at Duke's Charlotte, N.C.,
Offices; and by
.13
Applicants and Staff of Palmetto Alliance members Hoopingarner and McAfee, in protracted sessions extending-past midnight on May j
19 and 20.
As Palmetto informed the Board in the conference call of May 13,1983, it recognized the inability to adequately 1 -
conclude review of the complex and rapidly developing evidence on its quality assurance contention 6; and,_therefore, elected to defer its earlier noted depositions of construction / quality assurance personnel and to seek this relief from the Board.
In sum, Palmetto Alliance believes that it has demonstrated due 4
diligence in pursuing, to the-best of its ability with limited time, resources, and expertise, this complex and fast unraveling issue of serious quality assurance deficiencies at-Catauba.
Full and complete development of these issues for efficient
{
consideration at hearing and fair appraisal by Palmetto of
~
evidence supporting its claims and its adversaries' defenses-requires the relief sought.
PALMETTO ALLIANCE PROPOSED PLAN AND SCHEDULE FOR DISCOVERY I
ON ITS QUALITY ASSURANCE CONTENTION 6 l
As reflected in the proposed schedule shown at Attachment 1, i
Palmetto Alliance proposes that its Quality Assurance Contention 6 be scheduled for hearing to commence December S, 1983.
Such hearing would follow hearings nou set to commence October 4, l
l 1963, on Contention 6, 7, 8, 16, 27 and 44, as well as CMEC Contentions 1 -4.
As anticipated by the Board, hearings on yet to 14
~ _ _. -. _.... _., -.
be filed emergency planning contentions could well be deferred for hearing " separately later on." Board Order of February 2, 1983, at p.
9.
It is Palmetto's belief that the present schedule can accommodate hearing on these Quality Assurance issues beginning December 5, 1983, as herein proposed.
To reach that December 5 date for commencement of hearings, Palmetto Alliance proposes that discovery on Contention 6 be scheduled for conclusion by October 14, 1983.
Notions for Summary Disposition, if appropriate and forthcoming, could be required by October 24, 1983.
Responses would follou by two weeks on November 7, 1983; rulings could be expected November 18; and prefiled testimony due November 25, 1983.
Palmetto Alliance submits that the absence of any contentions regarding the safety evaluation report (SER) and the nou limited environmental contentions provide significant additional flexibility to the February 2, 1983, schedule.
Palmetto submite that the nature of the quality assurance issue and the magnitut'e of the factual material to be digested and analyzed dictates l
l Board adoption of the discovery deadline proposed.
The Manual for Complex Litigation utilized in the Federal courts provides valuable guidance for coping uith the discovery task presented by this quality assurance contention.
There discovery is cast in a first and second "uave", uith the "second l
l uave" representing "discnvery on the merits:"
l The first uave of discovery should be designed to l
disclose as far as possible (a) the names and 15
locations of witnesses uhose written interrogatories or depositions upon oral interrogatories may be sought on the merits; (b) the existence, location, and custodian (s) of documents and other physical evidence, the production of which may be sought on the merits; and (c) information concerning the transactions upon which the claims for relief are based.
Section 1.50 Scheduling of Requests for First Uave of Discovery, Manual for Complex Litigation.
Palmetto submits that this guidance well reflects the posture of discovery nou faced by this intervenor with respect to its quality assurance contention.
We have indeed identified the uitnesses uhose depositions on the merits need be taken (a number probably in access of 60 individuals according to counsel for Applicants.
See,May 5, 1983, letter regarding depositions).
Uhile the completeness of Applicants' and Staff's document identification and production remains significantly in doubt in light of the most recent flood of releases, this "first uave" has clearly identified a vast range of documentary evidence yet to be thoroughly analyzed.
Finally, it is only nau that information regarding the " transactions" material to Palmetto's quality assurance claim has been adduced.
Pursuit of discovery on these transactions on the merits yet remains to be accomplished.
As the Affidavit of Billie Garde, Attachment 2, reflects, the discovery plan ahead includes significant documentary analysis as well as the critical field work uith present and former Catauba workers only nou beginning.
As indicated, the present extent of chill on worker cooperation produced by Duke Power Company's conduct is yet to be determined.
16
PALMETTO SETTLEMENT EFFORTS Counsel for Palmetto Alliance has sought through discussions with counsel for Applicants Duke Pouer Company and the NRC Staff to reach agreement on extending discovery on Palmetto Alliance Contention 6.
As described above, counsel for Palmetto Alliance and representatives of the Government Accountability Project met uith counsel for Applicants and NRC Staff in Washington, D.C.,
Friday, May 6, 1983.
Counsel for Applicants represented that they had anticipated Palmetto's request to extend discovery on this contention and that discussion among Applicants' counsel had taken place on the subject.
Applicants' counsel represented that a 60-day extension of the contention 6 discovery deadline appeared reasonable.
However, Applicants insisted that the agreement to such an extension must be founded upon agreement by Palmetto to uaive the pursuit of any claims arising after such date.
Applicants' counsel represented that its interest was in "getting all the cards on the table" on this issue such that all the facts could be presented at trial.
Counsel for the NRC Staff stated that Staff policy dictated agreement with Applicants' scheduling position, and that any extension acceptable to Applicants would be agreed to by NRC Staff.
Palmetto Alliance and GAP, of course, explained that they uould be obligated to respond to any evidence Uhich came to its attention even after the end of formal discovery.
At the conclusion of the last deposition at about 12:30 a.m.
17
Saturday, May 21, 1983, counsel for Applicants initiated a further discussion with counsel for Palmetto on the subject of an agreed extension of time for discovery on Contention 6.
Counsel for Applicants suggested an interest in pursuing settlement of the other Palmetto contentions in consideration of an agreement to extend discovery on Contention 6 as well to pursue anticipated emergency planning issues.
Palmetto Alliance suggested uillingness to pursue specific proposals for agreement on othcr Palmetto contentions, for example, a specific agreement as to placement of real-time monitors around the Catauba site.
Applicants' counsel, in subsequent conversation, has declined to further pursue such discussion.
Palmetto Alliance remains willing to further pursue agreement uith opposing counsel uith respect to a proposed plan and schedule for discovery on its quality assurance Contention 6.
C0f1CLUSION For the foregoint reasons; and on the basis of good cause I
shoun, Palmetto Alliance respectfully requests the Board enter an Order providing for adoption of the discovery schedule herein proposed for Palmetto A.lan e's Qua'ity Assurance Contention 6.
l
\\
f
\\
Ro(ert Guild,/'
P.O.
Box 12097 Charleston, S.C.
29412 Counsel for Palmetto Alliance l
18 l
1
ATTACHMENTS
- 1. Proposed schedule for Palmetto Alliance Contention 6,
- 2. Affidavit of Billie Pirner Garde--under separate cover.
- 3. 3/15/82 Memorandum, P.K. Van Doorn to Alderson.
4
" Hand written notes from QC and QA Inspectors which set forth their " specific problems and concerns." Item 10 of Attachment 1 to April 12, 1983, Duke Power Company letter.
- 5. May or June 1982 (undated)
P.K. Van Doorn Memorandum to Vorse.
- 6. 26 April 1982 Management Assistance Company (NAC)
Report.
7.
Notice of Significant Licensee Meeting.
- 8. Grier Memorandum to File with Van Doorn Notes from Interviews, dated 12/20/82.
- 9. 2/1/83 Van Doorn Remorandum, closing file,
- 10. 5/15/83 The Charlotte Observer.
- 11. 5/19/83 Letters, George Johnson, Esq. to R. Guild and Felton to B.
Garde, re: FOIA.
PROPOSED SCHEDULE FOR PALMETTO ALLIANCE CONTENTION 6 Discovery ends on Contention 6 October 14, 1983 Motions for Summary Disposition on October 24, 1983 Contention 6 Responses to Motions for Summary Disposition November 7,
1983 Board Ruling on Motions for Summary November 18, 1983 Dispositions Prefiled Testimony on Contention 6 November 25, 1983 Hearings Commence on Contention 6 December 5, 1983 1
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t I
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the matter of
)
Docket Nos. 50-413
)
50-414 DUKE POWER COMPANY, et al.
)
)
(Catawba Nuclear Station,
)
May 25 1983 Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of Palmetto Alliance Motion to Establish I)iscovery Schedule on Its Quality Assurance Contention 6 in the above captioned matters, have been served upon the follow-ing by depositing same in the United States mail, postage prepaid, on this 25th day of May 1983.
- James L. Kelley, Chairman Chairman Atcmic Safety and Licensing Board Panel Atanic Safety and Lic;nsing Appeal Board U.S. Nuclear Pagulatory Camlission U.S. Nuclear Reculaterf Ccmnission Washington, D.C.
20555 Washington, D.C.
20555
- Dr. A. Dixon Callihan Henry A. Presler Union Carbide Corporation Charlotte-Mecklenbura Environmental Coalitic p.O. Box Y 943 Henley Place Oak Ridge, Tennessee 37830 Charlotte, N.C.
28207
- Dr. Richard R. Foster
- *J. Michael McGarry, III, Esc.
P.O. Box 4263 Debevoise & Liberman Sunriver, Orecon 97701 1200 Seventeenth St., N.W.
Washington, D.C.
20036 Chairman Atanic Safety and Licensing Board Panel Jesse L. Riley U.S. Nuclear Regulatory Ccmnission 854 Henley Place Washington, D.C.
20555 Charlotte, N.C.
28207
- George E. Johnson, Esc.
- Soott Stucky Office of the Executive Lecal Director Docketing and Service Station U.S. Nuclear Regulatory Carlission U.S. Nuclear Regulatory Ccrmission Washington, D.C.
20555 Washington, D.C.
20555 William L. Porter, Esc.
Carole F. Kagan, Atty.
Albert V. Carr, Jr., Esq.
Atanic Safety and Licensing Board Panel Ellen T. Ruff, Esq.
U.S. Nuclear Regulatory Camdssion Duke Power Ca:pany Washington, D.C.
20555 P.O. Box 33189 Charlotte, N.C.
28242
- Richard P. Wilson, Esq.
\\
Assistant Attorney Cencral
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State of South Carolina nobektGuilb P.O. Box 11549 Coltrbia, S.C.
29211 Attorney for Palmetto Alliance, Inc.
0 Complete attachnents served; available to others upon request.
0* Federal Express