ML20083N795

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Memorandum Supporting Licensee Motion for Expedited Order Compelling Production of Documents Relied on by C Perrow in Testimony.Licensees Entitled to Any Notes & Draft Manuscript Chapters.Certificate of Svc Encl
ML20083N795
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 02/01/1983
From: Brandenburg B, Colarulli P
CONSOLIDATED EDISON CO. OF NEW YORK, INC., MORGAN ASSOCIATES, POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20083N786 List:
References
ISSUANCES-SP, NUDOCS 8302030175
Download: ML20083N795 (19)
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Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

James P. Gleason, Chairman Frederick J. Shon Dr. Oscar H. Paris

)

In the Matter of )

)

CONSOLIDATED EDISON COMPANY OF ) Docket Nos.

NEW YORK , INC. ) 50-247 SP (Indian Point, Unit No. 2) ) 50-286 SP

)

POWER AUTHORITY OF THE STATE OF )

NEW YORK ) February 1, 1983 (Indian Point, Unit No. 3) )

)

MEMORANDUM IN SUPPORT OF LICENSEES' MOTION FOR EXPEDITED ORDER COMPELLING PRODUCTION OF DOCUMENTS Despite the Atomic Safety and Licensing Board's (Board's) requirement that all documents upon which witnesses are relying in their testimony be produced, see Transcript of Proceedings at 6462-63 (Jan. 20, 1983), FOE /

Audubon has refused to produce documents upon which Dr.

Charles Perrow, one of its witnesses on Commission Question 1, is relying.

On January 24, 1983, Consolidated Edison Company of New York, Inc. and the Power Authority of the State of New York, licensees of Indian Point Units 2 and 3, respectively, took the deposition of Dr. Perrow, who is scheduled to " testify on the difficulties in predicting accidents in complex systems such as nuclear reactors, and in perforring proba-8302030175 830201 PDR ADOCK 05000247 0 PDR m~ tw metxx' + w ~.:m m

bilistic risk assesments [ sic] on such systems."1 Supple- l mental Response of FOE /Audubon To Licensees' First Set of Interrogatories and Document Requests Under Commission Question 1 To Intervenors, Dated June 16, 1982, at 1 (Dec. 17, 1982). FOE /Audubon refused to produce two manuscript chapters that Dr. Perrow is preparing, one of which is titled "Why Have We Not Had More Three Mile Islands," although Dr. Perrow had brought it with him to the deposition, and stated that he will rely in his testimony upon material in those chapters not otherwise available in his writings. Transcript of Deposition of Dr. Charles Perrow at 28-29 (Jan. 24, 1983) (Perrow Deposition); see id.

at 32 ("This chapter I am using as notes.").2 As evidenced by his reading from his notes for the chapter, and by his responses to questions, Dr. Perrow is clearly relying upon material in his manuscript in his testimony.3 Thus, as the Board has recognized, the

1. The relevant pages of the deposition transcript are appended to this memorandum.
2. In addition to stating that he was relying upon portions of the manuscript, Dr. Perrow read, in response to a question from the Power Authority's counsel, from what he enaracterized as " notes . . . for a chapter that I am work-ing on." Perrow Deposition at 90-91. Dr. Perrow explained that this chapter was one of those referred to earlier. Id.

at 91.

3. The licensees are willing to stipulate that the use of Dr. Perrow's manuscript and notes will be limited to this proceeding.

OM%YWKMG RW&M

licensees are entitled to any notes and draft manuscript chapters for use in their preparation for the hearings on Commission Question 1. FOE /Audubon's refusal to produce ,

this material prevents the licensees' complete preparation for Dr. Perrow's testimony, and therefore denies them administrative procedural rights and due process of law.

Respectfully submitted, btoA1 k b nkoAhire ask k fok&Makb Brent L. Brandenburg Q g Charles Morgan, Jr. 4 Paul F. Colarulli CONSOLIDATED EDISON COMPANY Joseph J. Levin, Jr.

OF NEW YORK, INC.

Licensee of Indian Point MORGAN ASSOCIATES, CHARTERED Unit 2 1899 L Street, N.W.

4 Irving Place Washington, D.C. 20036 New York, New York 10003 (202) 466-7000 (212) 460-4600 Stephen L. Baum General Counsel Charles M. Pratt Assistant General Counsel POWER AUTHORITY OF THE STATE OF NEW YORK Licensee of Indian Point Unit 3 10 Columbus Circle New York, New York 10019 (212) 397-6200 Bernard D. Fischman Michael Curley Richard F. Czaja David H. Pikus SHEA & GOULD 330 Madison Avenue New York, New York 10017 (212) 370-8000 Dated: February 1, 1983

UNITED STATES OF AMERICA NUCLEAR REGULATORY CC"_MISSICN C ATCMIC SAFETY AND LICENSING SOARD

______________________x In the Matter of  :

CONSOLIDATED EDISON COMPANY 0" -

NEW YORK (Indian Point Unit 2) Docket Nos.

50-247-SP POWER AUTHORITY OF THE STATE 0" 50-226-SP NEW YORK (Indian Point Unit 3)  :

____________________________________________x Deposition of DR. CHARLES PERROW, an expert witness, taken by Licensees pursuant to notice, at the of fices of Consolidated Edison Company of New York, Inc., 4 Irving Place, New Yo rk , New Yo rk 10003, on January 24, 1983, at 10 :00 a.m. , before Samuei Singer, a Shorthand Reporter and Notary Public of the State of New York.

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1 Perrow 27 2 Q Now I unders;and from discussions with

( 3 your councel last week that you have an unpublished 4 =anuscript which will deal, at least in part, with 5 accidents at nuclear facilities; is tha: correct?

6 A Yes. And I should correct my last 7 statement to add another publication which is 8 substantially the same as publication number 33, but

'9 more extensive and longer, which appeared in -- I will 10 have to get you the ref erence, I don' t know it of fhand.

11 It is a longer version of item 33.

12 0 And that,just for the record, is :h.e article, 13 " Normal Accident at Three Mile Island," in Society (s 14 Journal?

15 A Yes. This one is in the International Year 16 Book of Organization Studies, I believe, but I am not 17 sure of the title.

18 In regard to the other question,. yes, I 19 am preparing a manuscript.

20 0 And what portion of that manuscript is devoted to nuclear reactors?

21 A Two of several chapters.

g 23 Q Do you have any portion of that manuscrip:

24 with you today?

25 A I have a rough draf t with me, yes .

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Perrow 23~

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<- Q A rough .draf t of the t<o chapters that "as .

f 3 to do with nuclear accidents?

4 A  !!o , just one of t. hem, one of the two.

5 Q What are the subjects of those two 6 chapeers?

7 A The first one, which I do not have with me, 8 is analyzing the accident at Three Mile Island.

9 And the second one is tentatively entitled I

10 "Why Have We !!ot Had More Three Mile Islands," and the 11 subject of that is the history of nucicar power plan 12 cperation in the U.S., and occasionally France, India 13 and other countries.

(s 14 Q And you have that with you?

15 A Yes.

16 , Q can I make a copy of that?

17 A I don't know about that. I would rather

}g not. It is in rough draft form.

19 MR. HART" MAN : Off the record.

20 (Discussion off the record.)

21 2iR . HARTZMAN: Being a work in g progress, it is subj ect to change and modifica-ti n, and there may be errors in it that ha 23 l

hasn't picked up.

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3 We do object to that.

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1 Perrow 29 2 :ta. soH:::K:: I anderstand.

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3 3Y MR. soHII:xt :

4 Q Let me ask you another questien.

5 will you be relying in any way on the 6 =a:crial in that manuser:.pt in your testimon/?

7 A Wall, f es, of course.  : cean, I wroce it 8 so it is part of my 1,ong term and short ter= --

9 Q Let me ask you this question:

10 Are you relying on material in that 11 =anuscript that is not otherwisa available in your 19 other writings?-

13 A Yes. If I understand your question.

/ 14 MR. HART MAN: objection.

\.

15 MR. soHINKI: We already have an 16 answer to the question.

le MR. KAPLAN: Can we have a moment, 18 please?

19 (A recess was taken.)

20 MR. HARTOMAN: In both -- you know, it is not clear what we mean by " reliance" here, 21 and I think we ought to be clear on it.

There are documents, you know, there is a draft on work on some testimony and he is also working on a manuscript covering similar 2s, eallmt&tg@ ell &MbV.

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p y Perrow '] 2 =aterial. And both these documenes I presume ( 3 are relying on the same factual background, and 4 that may be thoughts and ideas that he his 5 developed which will be appesting in doch the 6 testimony and the manuscript, but that doesn't 7 cean ha is relying on the manuscript for 8 developing the testimony, as I understand it. 9 THz WITuzss: That is correct. 10 MR. HART MAN: There shculd be a 11 clarification on what we mean by " reliance." 12 THz WITNZSS: I an relying upon 13 things that are not in the manuscript, also. 14 MR. HARTOIAN: Tha t ' s the basis for ( 15 my objection. 16 MR. COLARULLI: For the rerord, if 17 Dr. Perrow is relying upon the two chapters of 18 his unpublished manuscript, which he has 19 referenced, in any way, including any thoughts, 20 any facts, any conclusions, in any respect, if 21 he is relying upon those chapters for his y testimony, then we make a formal request of you 3 , to produce those chapters to us. I o4 And I would add that Judge Gleason 25 rec nely, I believe it was last Thursday, at the emimitm&g!11/g roll?p(UlY.lIlf-ieeam m rof97 ret ny 

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1 Perrow- 31 2 hearing made it very clear that documents that 3 are being relied upon by the witness must be 4 produced to the other side. 5 MR. KAPLAN: If I may, I think the 6 question evolves about the word " reliance." 7 I think maybe we can get the doctor 8 to clarify what he understood you to mean so he 9 can use the term. obviously, I -- it seems to 10 me the question whether or not both documents 11 stem from the factual basis and it is the factual 12 basis upon which he is relying, or whether or 13 not one precedes the other. (s 14 You simply cannot rely upon scmething 15 that is not extant. so I think we need a 16 clarification as to the definition, what he 17 means when he uses the word " reliance" to see if 18 it comports with your understanding. 19 obviously, I don' t think we can 20 object, assuming there is reliance in the sense 21 that we generally use the term, something exists 3 . and you are using it as a predicate for subsequene 

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  • 23 24 MR. COLARULLI: Ihe definition *.m rre 25 using is the one upon which we wculd request Dr.

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1 Perrow 32 2 Perrow to respond, that is, using " reliance" ( 3 in its broadest sense, if there are any, as I 4 stated before, any thoughts, any facts, any 5 conclusions, any impressions.-- 6 MR. KAPLAN: Used as a basis. 7 MR. coLARULLI: -- that are in the 8 manuscript whichare going to later appear in the 9 testimony, if the testi=ony in any way draws 10 upon anything in the manuscript we consider 11 that to be relying upon that manuscript for his 12 testimony. 13 And we would ask that question of ( 14 Dr. Perrow: Given that definition, is there 15 anything in the two chapters that you have 16 , referenced on which you are going to rely in 17 your tastimony? 18 THE witness: Let =e put it this way: 19 I brought the -- this chapter for 20 convenience in order to give you references in 21 case you wanted a reference. This chapter I am 22 using as notes. 23 In c.y testi=ony I would -- could 24 come and probably will ccme with notes rather , 25 than the chapter. I will rely upon those notes. t s conunmrRynogGonymhm N uhk $h?$ 

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1 10 Perrow gg 2 lines and come up with an analysis such that operate. s r 

'.      3 could be trained to respond tes such ---

4 A Yes, that's true, believe that. 5 o Earlier you were describing your concept 6 of tightly coupled, and I am not sure that you 7 completed the different factors. 8 As I recqll, you listed two factors . One 9 concerned the time consideration being very tight: 10 second concerned buf fers not being able to be 11 inserted, to intervene. 12 Were there other f actors that you would 13 describe in a tightly coupled system? t 14 A Yes. I would like to refresh myself by s 15 looking at some notes which I believe you have, Mr. 16 Ha rt: man . 17 THE WITNESS: Do you have them -- 18 let me see what you got of mine. 19 (The witness examined documents.) 20 MR. SOHINKI: Let the record reficct that by "you," Dr. Perrow is referring to Mr. 21 Hart: man. 22 

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i 11 Parrow 90 o And -let me pause for a acment and say I am ( 3 talking about not absolute values here, but relative 4 values, so that delays in processing in tightly 5 coupled systems are not nearly as possible as they 6 are in loosely coupled systems. okay, so it is 7 relative. It is not an absolute distinction. 8 There is.only one methed to achieve the 9 goal, the end result in a tightly coupled system, 10 whereas in a loosely coupled system there are 11 alternative methods available. There is littic J ad, 12 slack being excess resources, in supplies, equipment, 13 or personnel in tightly coupled systems. (, 14 The buffers and redundancies.that are used 15 in these systems are designed in and deliberate rather 16 than fortuitously available, as they a re in loosely 17 coupled systems. And substitutions of supplies, 18 . equipment and persca.nel is limited, and limited to 19 those substitutions that are designed in by the 20 designer. 21 And that's a summary statement of tight 22 e upling characteristics. 23 o can you tell us f rom what documents you 24 have been referring? 25 A These are notes I have for a chapter tha t w y;?ie&m m s t zlirk.> '. rom /pnt m, a~. - m ug [jfj.y .c-. ---a.-= l

9^1 S 1 12 ?er: w 1 2  : am working en. l t ( 3 o And th s is one of the chapters : hat yc u 4 referred to earlic ? 5 A Yes. 6 o can you go bac5: to one of the tens :chere 7 I believe you said that the process was not invar. ant? 8 A Y2s. , 9 o could you iust s briefly explain .ha: 2 ou 10 =can? 11 A Yes. 12 In a -- to make the comparison airplar, in 13 a smelting operation you may want to produce semething 14 cf a certain degree of acidity, or having cor: in 15 chemical ce=ponents, and if one -- if the nor=al 16 method fails, you can have other ways of doing this. 17 THE win:Ess : Excuse me. off the 18 record. 19 (Discussion off the record.) 20 3y :.ia. co'aaULLI: 21 o I believe we are discussing invariant 22 sequences. 23 A In assembly lines you can put the door en 24 the car later if the doors are defective or cut of 25 stock. The sequence is not invariant. mit}WWrlliC f9 'l:t47(cmimM7W&nig{Odo!itIpa s M.: J=Wxron7

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I 19 Perrow 98 2 quite a few. It is hard for me to think of them 211. k 3 0 Have you received any negative comments 4 back frcm any of these people to whom f ou have cent 5 the manuscript? 6 A yes. There has been a rather persistene 7 complaint that I should get a better word than 8 " complexity" for interaction, and I should call it 9 "interactiveness," because " complexity" means other 10 things. 11 0 Has anyone challenged your concept of 12 applying the system accident to a nuclear power plant 13 setting? - (s 14 A No. 15 0 And I believe you earlier stated,to your 16 knowledge, no one else has, in fact, done this kind 17 of application and published it; is that right? 18 A Yes. There are none that have been 19 published, and I am delighted to say so. 20 0 Have you reviewed any manuscripts that 31 are in progress that also address the same issues that y you have, other manuscripts? A No, I haver't. 2a, 24 MR. C O L A R U '.,L I :  :*.r . Har t: man, to the 25 record is clear, it is clear, at least in the Nit WurtillC camittW&trlig@freltuy1ra

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1 20 Perrow g9 2 Powar Authcrity 's view, that based u=en our r 1 k 3 definition of "reli.ance" and based upon Or. 4 Perrow 's responses in his testimony, that we are 5 entitled to receive ecpies of the manuscript, 6 the two chapters that he has referred to. 7 I think we have stated all our 8 reasons, and I won't repeat them all. As I 9 understand it, it is your position that we are 10 not entitled to those documents; is that 11 correct? 12 MR. HART::'A':: That is correct. 13 MR. scHI::xI: For the record, con ( 14 Edison joins in the view expressed by Mr. 15 colarulli. 16 MR. HART MA:I: You want to add 17 something to the previous answer? 18 THE WIT:iESS: Yes, about review by 19 others of this concept of system accidents. 20 could : add something there? 21 BY MR. COLARULLI: 22 0 sure. 23 A An early version, and much more imperfect 24 version of the idea of system accidents was reviewed 25 by approxima ely ten rev:. ewers in connection with a 0/mmimf&lr{ ct)mjkitrtllK. C})m' '/%: ,.T s dirt 

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges: James P. Gleason, Chairman Frederick J. Shon Dr. Oscar H. Paris 

                                                    )

In the Matter of ) 

                                                    )

CONSOLIDATED EDISON COMPANY OF ) Docket Nos. NEW YORK, INC. ) 50-247 SP (Indian Point, Unit No. 2) ) 50-286 SP 

                                                    )

POWER AUTHORITY OF THE STATE OF ) Feb. 1, 1983 NEW YORK ) (Indian Point, Unit No. 3) ) 

                                                    )

CERTIFICATE OF SERVICE I hereby certify that on the 1st day of February, 1983, I caused a copy of the Licensees Motion For Expedited Order Compelling Production Of Documents, and memorandum in support thereof, to be hand delivered to those parties marked with an asterisk, by Express Mail to counsel for FOE /Audubon, and by first class mail, postage prepaid to all others. w .

  • James P. Gleason, Chairman Charles M. Pratt, Esq.

Administrative Judge Stephen L. Baum, Esq. Atomic Safety and Licensing Board Power Authority of the 513 Gilmoure Drive State of New York Silver Spring, Maryland 20901 10 Columbus Circle New York, New York 10019 

     *Mr. Frederick J. Shon Administrative Judge               *Janice Moore, Esq.

Atomic Safety and Licensing Board Counsel for NRC Staff U.S. Nuclear Regulatory Office of the Executive Commission Legal Director Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 

     *Dr. Oscar H. Paris Administrative Judge                Brent L. Brandenburg, Esq.

Atomic Safety and Licensing Board Assistant General Counsel U.S. Nuclear Regulatory Consolidated Edison Company Commission of New York, Inc. Washington, D.C. 20555 4 Irving Place New York, New York 10003 Mr. Ernest E. Hill Administrative Judge Ellyn R. Weiss, Esq. Lawrence Livermore National William S. Jordan, III, Esq. Laboratory Harmon and Weiss University of California 1725 I Street, N.W., Suite 506 P. O. Box 808, L-123 Washington, D.C. 20006 Livermore, CA 94550 Charles A. Scheiner, Co-Chairperson Docketing and Service Branch Westchaster People's Action Office of the Secretary Coalition, Inc. U.S. Nuclear Regulatory Commission P.O. Box 488 Washington, D.C. 20555 White Plains, New York 10602 Joan Holt, Project Director Alan Latman, Esq. Indian Point Project 44 Sunset Drive New York Public Interest Research Croton-On-Hudson, New York 10520 Group 9 Murray Street Ezra I. Bialik, Esq. New York, New York 10007 Steve Leipzig, Esq. Environmental Protection Bureau Jeffrey M. Blum, Esq. New York State Attorney New York University Law School General's Office 423 Vanderbilt Hall Two World Trade Center 40 Washington Square South New York, New York 10047 New York, New York 10012 Alfred B. Del Bello Charles J. Maikish, Esq. Westchester County Executive Litigation Division Westchester County The Port Authority of New York 148 Martine Avenue and New Jersey White Plains, New York 10601 One World Trade Center New York, New York 10048 Andrew S. Roffe, Esq. New York State Assembly Albany, New York 12248

4 w a s Marc L. Parris, Esq. Atomic Safety and Licensing ] Eric Thorsen, Esq. Board Panel - County Attorney U.S. Nuclear Regulatory Commission _ County of Rockland Washington, D.C. 20555 , 11 New Hempstead Road liew City, New York 10956 Atomic Safety and Licensing - Appeal Board Panel Phyllis Rodriguez, Spokesperson U.S. Nuclear Regulatory Commission j Washington, D.C. 20555 ' Parents Concerned About Indian Point P.O. Box 125 Honorable Richard L. Brodsky . Croton-on-Hudson, New York 10520 Member of the County Legislature Westchester County Renee Schwartz, Esq. County Office Building = Paul Chessin, Esq. White Plains, New York 10601 Laurens R. Schwartz, Esq. 2 Margaret Oppel, Esq. Zipporah S. Fleisher

  • Botein, Hays, Sklar and Hertzberg West Branch Conservation i; 200 Park Avenue Association New York, New York 10166 443 Buena Vista Road _

New City, New York 10956 { l Honorable Ruth W. Messinger { l Member of the Council of the Mayor George V. Begany - Village of Buchanan City of New York District #4 236 Tate Avenue a City Hall Buchanan, New York 10511 - New York, New York 10007 d Judith Kessler, Coordinator Greater New York Council Rockland Citizens for Safe Energy on Energy 300 New Hemstead Road 5 c/o Dean R. Corren, Director New City, New York 10956 New York University 9 26 Stuyvesant Street David H. Pikus, Esq. - New York, New York 10003 Richard F. Czaja, Esq. ~2 Shea & Gould Joan Miles 330 Madison Avenue Indian Point Coordinator New York, New York 10017 ' New York City Audubon Society 71 West 23rd Street, Suite 1828 Amanda Potterfield, Esq. New York, New York 10010 Johnson & George 528 Iowa Avenue

  • Richard M. Hartzman, Esq. Iowa City, Iowa 52240 2 Lorna Salzman ,

Mid-Atlantic Representative *Ruthanne G. Miller, isq. . Friends of the Earth, Inc. Atomic Safety and

  • 208 West 13th Street Licensing Board Panel $

New York, New York 10011 U.S. Nuclear Regt11atory , Commission i - Stanley B. Klimberg, Esq. Washington, D.C. 20555 General Counsel - New York State Energy Office , 2 Rockefeller State Plaza - Albany, New York 12223 u 1 

              .                                                                       I

I l Mr. Donald Davidoff Director, Radiological Elriergency Preparedness Group Empire State Plaza Tower Building, Rm. 1750 Albany, New York 12237 Craig Kaplan, Esq. National Emergency Civil l Liberties Committee 175 Fifth Avenue, Suite 712 New York, New York 10010 Michael D. Diederich, Jr., Esq. Fitgerald, Lynch & Diederich 24 Central Drive Stony Point, New York 10960 Steven C. Sholly Union of Concerned Scientists 1346 Connecticut Avenue, N.W. Suite 1101 Washington, D.C. 20036 Spence W. Perry Office of General Counsel Federal Emergency Management Agency 500 C Street, S.W. Washington, D.C. 20472 Stewart M. Glass Regional Counsel Room 1349 Federal Emergency Management Agency 26 Federal Plaza New York, New York 10278 Melvin Goldberg Staff Attorney New York Public Interest Research Group 9 Murray Street New York, New York 10007 Jonathan L. Levine, Esq. P. O. Box 280 New City, New York 10958 m 31_h O h ) bb b S6 san B. Kaplan F}}

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