ML20137A786
| ML20137A786 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/10/1986 |
| From: | Roisman A Citizens Association for Sound Energy, TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#186-744 OL, NUDOCS 8601140543 | |
| Download: ML20137A786 (18) | |
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v 1 BEFORE THE UNITED STATES D3cg,dfD U$d NUCLEAR REGULATORY COMMISSION Before the Atoraic Safety and Licensing *[ Roar.d
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~ In the Matter of ) f r- ) TEXAS UTILITIES GENERATING COMPANY, ) Dkt. Nos. 50-445-OL _et _al. ) 50-446-OL (Comanche Peak Steam Electric ) Station, Units 1 and 2 ) MOTION TO COMPEL RESPONSES TO CASE's NOVEMBER 15, 1985, INTERROGATORIES The purpose of this motion is to compel responses to three 1 CASE interrogatories (November 15, 1985). BACKGROUND The issue of what protections, if any, are available to i Applicants that allow them to shield information from CASE in i dis'covery has already been settled. Applicants' refusal to cooperate with CASE on the interrogatories has no harbor in NRC precedent, federal law, or the law of this case. It was Applicants' position, first-articulated at the prehearing conference of Povember 12, 1985, that it could not and 1 By permission of the Board and consent of the Applicants, this motion is filed in response to Applicants' objections of December 9, 1985, and December 12, 1985, to CASE's September 4,
- 1985, Request for Document Production and the November 15, 1985, Interrogatories.
Although CASE has not yet received satisfactory l answers to all other requests and interrogatories, Applicants and CASE are currently engaged in a good-faith attempt to resolve those disputes, and we expect current discussions to produce.the responses and/or documents sought. Unless the Board directs us to file a motion to compel sooner, we will file only if efforts on the outstanding requests become-fruitless. 8601140543 860110 PDR ADOCK 05000445 3 S63 would not allow CASE to have in-process discovery of CPRT materials (Transcript of November 12, 1985, Prehearing Conference, pp. 24,232-24,260). The Board did not accept either the Applicants' argument against wholesale release or CASE's pleas for full disclosure. Instead the Board implemented a " middle-of-the-road" position by asking CASE to identify the information it really needed to begin its work (Tr. 24,244-24,230). CASE conceded, for the time being, to seek only the deficiency paper itself, who the persons were who might identify deficiencies, and what procedures, if any, governed reporting of deficiencies (Tr. 24,245-6). Since that time period, CASE and Applicant have begun, albeit slowly, to cooperate in discovery matters, including some identification of in-process deficiencies. Specifically, CASE has sought information which will enable it to determine the breadth and scope of further discovery regarding identification of deficiencies at the plant. The deficiency paper information was specifically permitted by this Board (Tr. 24,257-8). Howeve r,' in order to determine if we have properly sought all deficiency paper, CASE must know the universe of individuals or organizations which have been to the site, whether or not Applicants are using them now and, regardless of the description Applicants may give, their role at the site. CASE must know who has been excluded from discovery through the " expert immunity" advanced by Applicants in. order to challenge that claim or determine its validity. Such information is sought by Interrogatories 12, 13, and 14. i
... / s: CASE sought [information about how many of the CPRT and other Esimilar. personnel-the Applicants reta'ined for the purpose of trial preparation in this proceeding (Int. 12), how many of these personnel would have been hired regardless of the licensing hearing (Int. 13), and generally who these people or 2 . organizations are (Int. 14). Applicant objected to the questions-and provided no answers. They raise two objections,.first that CASE has no right to the information because of protections provided to Applicant by Federal Rule of Civil Procedure (FRCP) 26(b)(4), and second that any. discovery-which CASE conducts regarding.these experts must 3 comply with the requirements of FRCP 26(b)(4). Applicants base 2 The exact language of the interrogatories is as follows:
- 12. How many persons hired by Applicants since January 1,.1984, are experts hired by Applicants for the purpose of preparation for, or in anticipation of this licensing hearing?
This question does not seek a legal conclusion but a corporate answer using the corporation's opinion of the meaning of the question.
- 13. How many persons working'for consultants, contractors, and subcontractors since' January 1, 1984,.do Applicants claim are
- 1) experts hired by Applicants, 2)~for.the~
purpose of preparation for, 'cnr in anticipation of, this licensing hearing? Hcw many of these persons are included in the answer to question 127
- 14. How many of the persons identified in the. answer-to Question 12 and 13 would have been hired irrespective of the existence of
~ this licensing hearing? List those persons, or if.more than one person.is employed'by the same organization, list the organization -and the number of. persons employed by it. 3 Federal ^ Rule of Civil' Procedure 26(b)(4). states: [ footnote continued on next page)
-4 their objections on the premise that "all of the technical people engaged in the CPRT effort are experts retained by them in 4 preparation for and in anticipation of litigation." Applicants' objection is apparently that personnel hired in a dual capacity, as employees pursuing regulatory requirements l and who also may be either called as expert witnesses in the [ future or consulted in preparation for trial, are totally immune ,t I from discovery under applicable provisions of the federal Rules of Civil Procedure. [ i CASE at the outset disagrees that the controlling rule in this case is FRCP 26(b)(4), and argues that it is instead 10 CPR I 2.740. Second, even if the Board were to find that the federal rule provides the appropriate guidance for Board action, CASE disagrees with the premise that all CPRT personnel and other f consultants hired since January 1, 1984, even if deemed ? " experts," were hired in anticipation of litigation or for trial preparation within the meaning of FRCP 26(b)(4) or that their [ work during the period is immune from discovery. This Board has previously ruled on this issue in the context of a claimed trial preparation exemption for the "Lipinsky documents" and i i (4) Trial Preparation: Experts. Discovery of facts known and opinions held by experts, otherwise discoverable under the provisions of subdivision (b)(1) of this rule and acquired l or developed in anticipation of litigation or for trial, may be obtained only as follows: 4 December 12, 1985, Objections to CASE's Interrogatories, pp. 13-16. 4
5 -- l essentially rejected Applicants' claim. + Finally, because Applicants have-publicly indicated a-3 . present willingness to disclose the. names and total work product of all the persons-for whom~it now claims'a privilege, the real ' issue is tin.ing of discovery and not its availability (Tr. 24,228; 24,239). On this' point the Board has already ruled that i Applicants are not-entitled to delay in production of deficiency' paper.and Applicants apparently acquiesced in that rulitig, i although refusing to acquiesce in its implementation. I ARGUMENT f I. Discovery of " experts" is governed tyr 10 CFR $2.740 i and not FRCP 26(b)(4). Applicants base their entire objection on the applicability 4 ]. of FRCP 26(b)(4), which provides for limitations regarding, discovery of experts.under the federal rules. However, the [ operative rule before the NRC is 10 CFR 2.740. l 10 CFR 2.740 in pertinent past states (emphasis a'dded): j (b) Scope of discovery. Unless otherwise limited by order of the presiding officer in-accordance with this.section,-the scope of l discovery is as follows: .(1) In general.. Parties may obtain discovery regarding any matter, not previleged, which is relevantLto the subject matter involved in the proceeding, whetherJit relates to the claim'or defense of the party seeking discovery orito the. claim or defense l of any other party, including the existence, description, nature,. custody, condition, and location of any books, documents, or other. tangible things and-the identity and location .of persons having knowledge of ang-l . discoverable matter.. l A review of the Statement of Consideration makes it clear-i 1 l' t i J i c v m- .M_.'..~,#,.- m v s m ,,. _ +,,
that the Commission intended $i2.740, 2.740(a), and 2.740(b) to be the NRC's equivalent of FRCP 26 and that omissions of portions of the Federal Rules was deliberate and should be honored at least absent compelling argument to the contrary. The-pertinent part cf the Statement provides: A new 92.740 has been added to Part 2 containing general provisions relating to discovery - scope of discovery, protective orders, and motions to compel discovery. The Federal' rules [ pts Rules 26 and 37 of the new section ada sic 3 of Civil Procedure to Commission proceedings.. of particular interest are the provisions pertaining to~ discovery of trial preparation materials and ~ supplements to discovered material. [ Emphasis added.] Discovery (including depositions, production of documents, and interrogatories). The amendments expand the time available for legitimate discovery by the parties to the proceeding and are expected to obviate or lessen the delays which the current discovery process has caused.- Sections 2.740, 2.740a, 2.740b, and 2.741 follow the Federal rules [ sic 3 of Civil Procedure, as revised in 1970, by providing for production of. documents, serving of interrogatories and taking of depositions without the necessity of motions and orders by the presiding officer or the Commission. 37 Federal Register 15127 (published July 28, 1972, and effective Aug. 27, 1972), " Restructuring of Facility. License Application Review and Hearing Processes." Since the 1970 amendments to the Federal Rules specifically provided.for the provision on expert discovery, when the Commission wrote $2.740 it had before it the specific language of Rule 26(b)(4) on which Applicants rely.- As the above quotes indicate, the Commission focussed specifically on'the trial i r I l l-preparation provisions of Rule 26 and it is therefore extremely significant that the substance of Rule 26(b)(3) was added to the NRC. rules of practice but not the substance of Rule 26(b)(4). Consistent with the overall purpose of the amendments to the Rules of Practice, the Commission avoided adopting discovery provisions which, like Rule 26(b)(4) with its many tests and exceptions, would complicate and delay the licensing process. Moreover, preventing knowledge in the possession of an expert which is relevant to the safety of a nuclear facility from being a part of the record for deciding whether to license the plant would be completely inconsistent with the Commission's responsibilities to determine whether a nuclear plant is safe. In short, the provisions of Rule 26(b)(4) were deliberately not included by the Commission in its Rules of Practice and its use in this proceeding to avoid relevant discovery is improper. At least one Board that has faced the same issue now in front of this Board concluded that FACP 26(b)(4)) did not apply to a claim for the imm' unity from disclosure of the identity of experts relied upon by a party. In that case, General Electric Company (Vallecitos Nuclear Center, General Electric Test Reactor), LBP-78-33, 8 NRC 461 (1978), the Board foand the applicable provision to be 10 CFR 2.740. The Vallecitos board ruled that the identities of persons assisting the objecting party-(in that case, Intervenor Friends of the Earth) were " expressly discoverable under the Commission's rules" (Id. at 466), even though the intervenor had'not yet decided which experts it would call for the hearing. The Board concluded that intervenor's preparation for trial would not be hampered by the sought discovery. In several decisions other hearing boards have not followed the teaching of Vallecitos and, while not deciding the precise question here, have ruled that the absence of any explicit NRC rule of practice addressing a subject is an invitation to look to the federal rules for guidance. E.g., Public Service Company of New Hampshire (Seabrook), LBP-83-17, 17 NRC 490, 496-7 (1983); Carolina Power i Light (Shearon Harris), LBP-83-27A, 17 NRC 971-976-80; Boston Edison Company (Pilgrim), LBP-75-42, 2 NRC 159, 161 (1975); and Kerr-McGee Chemical Corp. (West Chicago), Slip Op. decided September 26, 1985. We respectfully submit that these boards erred because, at least insofar as Rule 26(b)(4) is t concerned, the Commission's silence appears to be deliberate, since the Commission had focussed on the very issue of trial preparation in promulgating $2.740 and chose not to add an [ equivalent of FRCP 26(b)(4) but did for FRCP 26(b)(3). In this case this Board should follow the guidance already provided by 52.740 and allow discovery of the names of all " experts" who have or may have information relevant to the safety of CPSES. It is noteworthy that here Applicants have only argued that the regular work of the CPRT personnel will be hampered by discovery, not that their trial preparation will be thwarted.(Tr. I ~ 24,239). In addition, what is sought by CASE is names, procedures for reporting deficiencies, and eventually deficiency paper. The production of the first two could not possibly affect either the work of the CPRT or-trial preparation and production of deficiency paper has been essentially approved by this Board
9-and accepted by Applicants. Thus, Applicants may not refuse to answer CASE interrogatories 12, 13, and 14 (November 15, 1985) unless the material sought is unavailable under $2.740. Generally, that rule authorizes discovery of all relevant and' admissible material and all relevant material that appears reasonably calculated to lead to discovery of admissible evidence. It specifically authorizes discovery of the " identity and location of persons having knowledge of any discoverable matter." The only exception to this broad discovery authorization is trial preparation i materials which are discoverable only under certain limitations. i 92.740(b)(2). However, by its terms that limitation applies only to the materials produced by experts and'not their identities. (We discuss in Argument II, infra, why none of the materials produced by these " experts" is trial preparation material.) Looking to the applicable rule, 2.740 of the NRC's Rules of i Practice requires an order compelling immediate responses to the requested discovery. II. Alternatively, pursuant to FRCP 26(b)(4), the material sought is discoverable. j Even if FRCP 26(b)(4) were applicable,.it could only be used i as guidance by this Board. Public Service Company oj[ Indiana i i (Marble Hill Nuclear Generating Station, Units _1 and 2), ALAB-374, 5 NRC 417, 421-(1977) (additional views of Mr. Farrar, joined by the entire Board). In the last analysis, this Board would still have to decide-in light of its discretionary ] authority whether Applicants ought to be allowed to avoid t. i i -w, r e 7 r m n v-e = y n p m--*- discovery. At the outset of an examination of FRCP 26(b)(4)(B), the first question, and the central question here, is whether the discovery relates to "an expert who has been retained or specially employed by another party in anticipation of litigation or preparation for trial." As the notes of the Advisory Committee on Rules explain: It should be noted that the subdivision does not address itself to the expert whose information was not acquired in preparation for trial but rather because he was an actor or viewer with respect to transactions or occurrences that are part of the subject matter of the lawsuit. Such an expert should be treated as an ordinary witness.5 The CPRT personnel and other "e'xperts" hired since January 1, 1984, are " actors and viewers" which are part of the subject matter of the lawsuit and do not qualify within the threshhold 6 test for FRCP 26(b)(4)(B). In Applicants Current Management 5 Federal Rules of Civil Procedure, 26(b)(4), Notes of Advisory Committee on Rules, Subdivision (b)(4) Trial Preparation: Experts; 1985 Edition, p. 81. 6 Authorities describe this ordinary witness classification as applying to "[e3xperts whose information was not acquired in preparation for trial. This class, includes both regular employees of a party not specially employed on the case and also experts who were actors or viewers. Wright & Miller, Federal Practice & Procedure $2029, p. 250; see also cases incorporated into the amended rule 25(b)(4) which held that experts regularly employed were not immune from discovery. Broadway & Ninety-Sixth St. Realty Corp. v. Loew's, Inc. (D.N.Y. 1958), 21 FRD 347, 359-360 (expert testimony from employee of defendant who in himself an expert in the field is proper discovery); Moran v. Pittsburg-Des Moines Steel Company (D.Pa. 1947), 6 FRD 594 (chief engineer of defendant required to answer questions as to why certain things were done or not done in the construction of tank, when he had final approval in the design and construction of the tank that exploded); but see Craig v. Eastern Air Lines, Inc. (D.N.Y. 1966), 40 FRD 508,.509.
.~.. -. Views and Management Plan for~ Resolution of All Issues, June 28, s 5;. 1985, p. 4, the CPRT is described las comprised of third-party experts with extensive experience in the design and'. construction of nuclear power plants, to. address the'TRT's findings and to probe well beyond those findings by developTng and implementing a program 1o identify and correct deficiencies in: safety-related. structures,. systems, and E mponents.. [ Emphasis added.]. ~ Applicants' description of the!CPRT' confirms that'these i ) individuals were retained to meet regulatory compliance i t j requirements and therefore represent properly discoverable' i-information. Even more to the point, Applicants concede that, 9 [t]o the. extent the effort of this highly qualified team bears on the contention before this Board, it should become a part of the hearing record before this Board. i Thus Applicants have confirmed.that the function of the CPRT is j l primarily for their regulatory work and secondarily for the i _. t hearing. CAS3 does not concede that these witnesses are experts. However, assuming arquendo that they would all be'later certified i i as experts within the meening of Rule 26(b)(4)(B), it still does not follow that information about these individuals (all that is i ~ now ' sought) and factual information developed by them is immune ] from discovery. i t l In applying a federal rule 'which has. no parallel in NRC f rules, the. Appeal Board has cautioned that "there must first be' i l inquiry into'whether situations are-truly similar." Consumers i Power Company (Midland Plant),. Units 1 and 2),'ALAB-379,-5 NRC I ) 565, 588 n.L13 (1977). ] An examination of;the history of-Rule 26(b)(4)' demonstrates-4 l 4 l I b + -w.anu -- - -, - + w >-.e-s m., .,,.,m. -,~,-,m-,v.., v.,.
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,+.~-,.v-~ ,,.-m.ve-.,n-,..,, that the situation it seeks to protect is not parallel to the situation now before this Board. One of the key purposes of the 1970 amendment was because it was considered unfair if one party t could learn through discovery what the other party has paid the 7 expert for. Since the CPRT has made all the information already available to the Staff for its work in evaluating the CPRT, the fear of disclosing the information for free is totally unfounded, particularly in light of the Applicants' current commitment to make all the information available to CASE in the future. See page 5, supra. Furthermore, the CPRT personnel would have been retained by the Applicants regardless of this licensing proceeding to resolve 8 identified deficiencies to the satisfaction of themselves, 7 Wright & Miller, 8 Federal Practice and Procedure $2029, n.44, pp. 243-44; J. Moore, 2 Moore's Federal Practice and Procedure, $15.02[53, pp. 15-40. 8 Statement of Michael D. Spence, President of TUGCo, on January 17, 1985, to NRC Staff: Let me say at the outset, as President of TUGCo I veiw [ sic] these matters, these issues, as matters are [ sic] of extreme concern to my company and to the Commanche [ sic] Peak project. I recognize the need for us to aggressively address these issues and resolve them to my satisfaction as well as to your satisfaction. I also recognize the need to recognize that our program plan and the actions that we take under that program plan would serve to. establish the regular conference [ sic] of the agency in our plan.
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and/or to the satisfaction of the Staff. The record of meeting transcripts and briefings between the Staff and the Applicants regarding the. findings of the TRT is 3 l replete with statements that make clear that the work of the CPRT was in response to findings by the NRC in order to achieve regulatory confidence in the adequacy of design and construction of the plant. The personnel whose identity. CASE seeks are ordinary witnesses for the purposes of discovery at this time. At some t point in the future when their factual inquiry into deficiencies at the plant, causes of sueh' deficiencies, and similar matters essential for licensing is completed, these' individuals may become solely the trial preparation assistants of Applicants counsel. However, their work on the CPRT and the factual 10 observations will remain legitimately discoverable. 9 See, generally, SSER #11, Appendix P, "TUEC ACTIONS," p. P-36, which sets forth the requirements of the Staff to TUEC, including the following: TUEC shall evaluate the TRT QA/QC findings and consider the implications of these findings on the quality of construction at Comanche Peak. TUEC shall then submit to the NRC a program plan and schedule for completing a detailed and thorough' assessment of the QA issues presented in the enclosure to thi's" supplement. The programmatic plan and the plans for its implementation will be reviewed and evaluated by the NRC staff. 10 This issue was already decided in this case when the' Docket 2 Board rejected Applicants' claim that1 data prepared by Mr.- Lipinsky before Applicants retained himofor the hearing but when he had been retained to provide advice on the : paint coatings programming for normal construction an'd regulatory needs was-barred from discovery. Memorandum (Lipinsky Erivi.lege),; November + 16, 1984, Slip Op., p. 17: [ footnote continued on next page], ,) ~ s f g t ,g, y m---
In a recent decision-a hearing board interpreted Rule' 26(b)(4)(B) to allow discovery from an expert of information developed by him during the period of his regular employment for regulatory compliance. Kerr-McGee, supra. The test applied by the Board there and applicable here is that, if the work ir. required in the normal course of Applicants' relationship with the NRC, it is discoverable. As already noted, Applicants concede as much in their much heralded public pronouncements about the CPRT and other ongoing plant reviews. CASE seeks only information which would fall under this category. If it is assumed, arguendo, that when all the CPRT personnel complete their work (i.e., reinspections, analysis, etc.) they are asked by Applicant to form opinions for the prupose of this litigation, at that point discovery of their opinions might be covered by FRCP 26(b)(4)(B). In sum, Applicants, having announced on several occasions ~ their intent to use the CPRT and other personnel hired, retained, consulted, etc., since January 1, 1984, to assure themselves and the NRC staff that all the problems have been found and corrected, cannot now convert these " experts" into persons hired merely to be used in litigation. Their names, procedures used by i Once Mr. Lipinsky's memo became known to Applicants and Intervenor, Mr. Lipinsky's testimony and his relevant documents could not be shielded from discovery by modifying Lipinsky's employment for the purpose of engaging him as an agent or representative within the meaning of 10 CFR 2.740(b)(2) or 26(B)(3) of the Federal Rules of Civil Procedure. e ..- -. m
' 't .y m them, 'and deficiencies seen-by them;are clearly discoverable. Applicants'Erefusal: to providef the data requested without endless -wrangling and th'e need.to-file this motion is' unconscionable, particularly since the'ir refusal.now is merely to preserve a ' 11- - point of -law they. have already lost-and since the data will eventually be disclosed by, Applicants anyway. CONCLUSION s, For the reasons stated, the Motion to Compel'should be i granted. Respectfully submitted, i j f 4 ANTHONY Z. R N BILLIE P. Gp DE 's Trial Lawyers for Public Justice 2000 P Street, NW,~#611 Washington, D.C. 20036 .(202) 463-8600. ' Counsel for, CASE 1 s Dated : : January 10, 1986 4 - t, 7 c 1' 11 l- .According to Applicants' counsel, the only, reason for the assertion ~of the 26(b)(4) objection'is :."in order'to avoid in-process discovery because of the calamitous'results that would' befall'.the whole effort.. We.'re willing to stand on those rights just'to put off'in-process discovery now."
- (Tr. 24,239.)-'-
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January 10, 1986 s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC-SAFETY AND LICENSING BOARD In the Matter of ) ) TEXAS UTILITIES GENERATING ) COMPANY, et al. ) Docket Nos. 50-445-OL ) and 50-446-OL (Comanche Peak Steam Electric ) Station, Units 1 and 2) ) CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE's Motion to Compel Responses to CASE's F November 15, 1985, Interrogatories have been sent to the names listed below this 10th day of January 1986 by: Express mail where indicated by *: Hand-delivery where~ indicated by **; and First Class Mail unless otherwise indicated. Administrative Judge Peter B. Bloch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Herbert Grossman Alternate Chairman .ASLB Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Kenneth A. McCollom, Dean Division of Engineering, Architecture and Technology Oklahoma State University Stillwater, Oklahoma 74074
r. Dr. Walter H. Jordan 881 W. Outer Drive Oak Ridge, Tennessee 37830 Ellen Ginsberg, Esq. U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Robert A. Wooldridge, Esquire Worsham: Forsythe, Sampels & Wooldridge 2001 Bryan Tower, Suite 2500 Dallas, Texas 75201 Nicholas Reynolds, Esquire ** Bishop, Liberman, Cook,. Purcell & Reynolds 1200 17th Street, N.W. Washington, D.C. 20036 Stuart Treby, Esquire Geary.S. Mizuno, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing & Service Section Office of the Secretary-U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Renea Hicks, Esquire Assistant Attorney General Environmental Protection Division Supreme Court Building Austin, Texas 78711 Mrs. Juanita Ellis President, CASE 1426 S. Polk Dallas, Texas 75224 Mr. W.G. Counsil Executive Vice President Texas Utilities. Generating Co. Skyway Tower, 25th-Floor 400 N. Olive' Street Dallas, Texas 75201
Mr. Roy Pf.-Lessy, Jr. Morgan,- Lewis & Dockius -1800 M Street, N.W. Washington, D.C. 20036 Mr. Thomas G. Dignan, Jr. Ropes & Gray 225 Franklin Street Boston,-Massachusetts 02110 g' g. V.:___ y ANTHO RdISMAN I l t 4 I f t k L i t i e l t I s e s. r..
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