ML20034H834
| ML20034H834 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/15/1993 |
| From: | Kohn M AFFILIATION NOT ASSIGNED, KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#193-13728 CPA, NUDOCS 9303220131 | |
| Download: ML20034H834 (15) | |
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UNITED STATES OF M ERICA A
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NUCLEAR REGULATORY C 'JM: '7 ION 2
E BEFORE THE COMMISm.
%$NCH SECT M p
)
I C
In the Matter of
)
)
TEXAS UTILITIES ELECTRIC CO.,
) Docket No. 50-446-CPA-et al.,
) (Construction Permit Amendment) i
)
(Comanche Peak Steam Electric
)
Station, Unit 2)
)
)
PETITIONERS 8 MOTION TO STAY ISSUANCE OF FULL POWER LICENSE I.
INTRODUCTION
+
Pursuant to 10 C.F.R. 5 2.788, Petitioners B. Irene.Orr and I Orr, hereby seek a stay in further construction,-testing and D.
the issuance of a full power license for Unit 2 of the-Comanche Peak Steam Electric Station ("CPSES").
II.
PETITIONERS MEET THE REO IREMENTS FOR A STAY 10 C.F.R. 92.788 requires Petitioners to set forth the grounds for the stay, which should address "(1) [w]hether the j
i moving party has made a strong showing that'it is likely to prevail on the merits; (2) [w]hether the party will be irreparably injured unless the. stay is granted; (3) [w]hether the.
granting of a stay would harm other parties; and (4). where t' he public interest lies."
10 C.F.R. 52.788 (e) (1)-(4 ).
A.
Grounds for requestina the stav.
P Petitioners seek a stay on the following grounds: 1) TUEC is not legally entitled, at this time, to operate the plant at low-i power not is TUEC' entitled to convert the Unit 2 construction i
permit to an operating license; 2) TUEC does noc currently-have 9303220131 930315
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l ry the necessary character and competence to operate Unit 2; 3)-
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TUEC's laps of character has resulted in unsafe operating
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conditions.
B.
Petitioners are likely to prevail on the merits.
i First, Petitioners are likely to obtain a hearing on whether TUEC has good cause for the delay in construction.- Until.such time as Petitioners exhaust their right to a hearing, TUEC mayf not legally continue to engage'in construction, testing and
?
operational activities with respect to Unit 2.
Petitioners ~
herein rely on, and incorporate by reference, the briefs Petitioners have filed with the Commission, including the March
-j 12, 1993 brief entitled " Petitioners' Response to the Commission's Order Dated March 5, 1993."
Based on Petitioners' legal challenge to the_ issuance of the full power license, the Commission mupt grant a stay unti1Lsuche time as~it determines whether Petitioners were improperly denied r
a right to a hearing on the issue of " good cause" for the delay-in construction.1 -
l The assertion that the issuance of'a-low power license 1
negates Petitioners' right to a hearing is completely misplaced.
As the. Commission pointed out'in CLI-93-02,="the risk ofLlow power operation.areLminimal." _CLI-93-02'at p. 5, Fn.-3.
as the: Court of Appeals-for.thel District of Columbia-
- Because, Circuit has-found, it "would ' serve' no practical purpose" f for-_a-petitioner to seek relief from the harm stemming ;from -the Commission's denial.of a right'to a hearing in matters concerning the issuance of aL" low power" license.
See San Louis'Obispot i
g Mothers for Peach v. NRC, 751 F.2d 1287, 1317 (D.C. Cir.' 1984)..
As;such, Petitioners' request for a stay.is ripe.
Moreover, '
_:J Petitioners relied:upon the fact taat the low power license was, at the insistence of-the Commission,' issued "without prejudice to:
future consideration by the Commission with respect:to operation.
1 (continued...)
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e' use it is
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beca stay
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a to i g on entitled to delay rul n are TUEC to ners Second, Petitio Commission uthorizing for the a
just aring while TUEC's_past inherently un a he 2
ers' right rate Unit that nd to Petition struct and ope demonstrates the health a con ce ve ue to tual e iden ation imperils titioners ha v
continThird, new fac inform the briefs Pe TUEC ted
~that of safety rela A review stant case s toJcon of allege ceal' -
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ver-up the public.
the in ctual agreementcerning the co in safety of Commission contra con
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the ce ation The_
filed with oney-for-silen inform Commission.
d information (an from the Specifically, m
into ntered nt TUEC)
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abl owledge; e
safety-significaand competen of is irrcL_ula_b_lg.
hand.kn ce f
first turn o' l
cter present TUEC had nding order, to_
chara ce Petitionerscumented TUI /
that:
the hands' of.
sta e iden of a v
ve do Petitioners ha required, by way e into licensing hear t' cam
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they were information_thaon-going oper ting IJ that ined all ne ly obta the then license Exhibits w
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d to which pertaine nd.2 operating ce ding.
Spe for CPSES Units endment pro dditionally, e
1a A
TUEC it am to Petition. ~ vidence that-stru tion permSupplement irrefutable ers Lj e
c wn c -o o
con 92 its a
October 5, 19 ve presented ments with Petitioners hasettlement agree deciding-nctit D
o restrictive 5_ percent" when-Commis effe into minimal,Ltogeth e
of the ued) excess that ir t
1(...continvels in The f a t st pursing;thelicense indic c
n in risk was ua -
the.iss qc - - 1 wer lePetitioners agaers that language in the CLI-93-02 the stemmingPetitionersre at po from
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appealseled of explicito prejudice"strates;that
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ion assuring Petit coun corporationwould.be n
demon
.i in e
low power licens,
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stay.1s; ripe.
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terms of which required-the'co-owners to turn over evidence
_+
t documenting a pattern and practice employed by TUEC to p
intentionally submit material false information to the A'SLB, as well as a pattern of threatening its former co-owners.2 To date the illegally secreted documentation has never-seen the light of day,3 and NRC Staff has yet to require TUEC=to release 1
this information.'
2 Indeed, Petitioners rely on a legal pleading filed by one of the co-owners before entering into an illegal money-for-silence restrictive settlement..Therein, it asserts, inter alia, that the minority' owner had amassed documentation demonstrating
.('
that: 1) TUEC failed to disclose material information about the' adequacy of the design of the CPSES to the'NRC; 2) TUEC misrepresented and failed to disclose information about.
inadequate construction practices employed during the.
~
construction _of the CPSES; 3) TUEC misrepresented and failed to disclosure violations of NRC requirements to_the NRC; 4) TUEC-failed to disclose information documenting incompetence on the part of TUEC management, TUEC's contractors, subcontractors and the architect / engineers responsible for.the design and construction of the CPSES; 5) TUEC failed to disclose material
[
t information necessary to correct inac' curate statements TUEC made to the NRC.
See Exhibit 1 to October 5, 1992 Supplement to Petition.
It appears that TUEC's counsel engaged in uneth'ical' 3
conduct through the intentional and blatant disregard of a standing ASLB order.
Secreting information from an ASLB knowing
.a that to do so would directly violate a standing judicial order.is outrageous conduct.
The Commission cannot ignore blatant _
.l unethical conduct on the part of TUEC's counsel.. Indeed, Petitioners note that the attorney responsible for the drafting of the minority owner agreements, Mr. Robert Wooldridge,~
continues to appear as counsel to TUEC in the instant proceeding.
and, upon;information and belief, is TUEC. chief counsel ~on' licensing matters.
6 In CLI-93-02, the Commission acknowledgedithat the settlement agreements could.have resulted in the secreting of-safety-related information from'NRC Staff, but asserted that "there.is no' showing that_any actions that'the NRC directed TU Electric to take [with respect to the release-of theLsecreted documentation) will have any impact on low power' operation."
l (continued...)
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In addition to the above, Petitioners counsel has uncovered information indicating that TUEC managed to secret material information from the ASLB through the practice of paying " hush; i
money" -- a practice which almost resulted in.a catastrophic t
accident at the CPSES in 1992.
In this respect, on the evening
]
of March 14, 1993, Petitioners' counsel spoke with a former inspector employed at the CPSES, Mr. Ronald J.-Jones.
During the course of this conversation, Mr. Jones recounted events in 1992 which almost resulted in a serious accident at the CPSES.~ He q
further asserted that the underlying deficiency.resulting in.the near accident had initially been identified in a non-conformance report he drafted while at the CPSES site.
According to Mr.
'(... continued)
Id.,
at p.
4.
The Commission has identified a major problem..
The fact that NRC Staff has not takenjany action that could impact on TUEC's ability'to operate Unit 2 is outrageous.
NRC
~
i
' Staff cannot take an ostrich approach to the licensing of a-nuclear power plant.
The Commission must grant Petitioners'1 3
i request for a stay until the illegally secreted documents are.
publicly released and reviewed.. To do otherwise ratifies illegal l
and unethical conduct taken by TUEC and its counsel.
Petitioners have presented sufficient evidence to shift the; burden to TUEC to demonstrate that it didLnot secret safety related information from the Commission.
As such', Petitioners I
are entitled to an adverse inference that the' documentation TUEC intentionally and illeaally secreted from.the:ASLB. includes information demonstrating that TUEC isLaware of the existence of' l
uncorrected safety. problems incorporated'into the design and i
construction of the CPSES, and an adverse.i'nference that~the withheld documentation constitutes sufficient support to admit.
the underlying contention Petitioners seek admission in the:
instant matter.
It is simply inconceivable to Petitioners thati the Commission would grant a full power license.without addressing and correcting blatant illegal and unethical conduct i
engaged in'by TUEC's counsel, particularly'in light of the fact that the secreted information reflects on the licensee's character and competence and may' pose a significant' threat to the health and safety of the public..
5' c
IL l
-W Jones, the non-conformance report was given to his then legal counsel, Billie P. Garde, who had assured Mr. Jones that this and some nearly 300 other such non-conformance reports _that were not reported to the NRC by TUEC would be released during the course of the ASLB proceedings.
Mr. Jones alleges that TUEC, through the payment of a large sum of money to other clients represented by Garde (including a former citizen intervenor group, Citizens Associated for Sound Energy, or " CASE") has resulted in.the.
secreting of this information from the Commission.
Late last evening, Mr. Jones agreed to transmit, via facsimile, a hand-written statement outlining how the secreting of safety information has and will continue to directly impact on the safe operation of the CPSES.
According to Mr. Jones's statement,s he was employed at the CPSES between 1983 and 1984 as a Nucl, ear Electrical Inspector.
Statement of Ronald J. Jones ("SRJ")'at 1 1.
As an inspector, Mr. Jones identified over 300 non-conforming conditions, id at 52, that were never corrected by TUEC and, to this day, present a significant risk to the public's health and safety.
Mr. Jones also states that one of the non-conforming conditions he identified concerned an electrical wiring defect associated with the coolant control valve to Unit 1, and that as a result.of the 4
defect, the' valve would not control the cooling of the reactor rods.
This defect, according to Mr. Jones, was never-corrected
=!
5 A copy of Mr. Jones' hand-written statement'is attached as Exhibit 1.
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which could have conditions gave rise to SRJ $ 3 Upon in 1992, t at the CPSES.
and eventually,a devastating accidenexperienced a uld have resulted in and belief, Unit 1 wo coolant control of the information due to the failureonly able to' avoid a significant accidentand that TUEC wascont uantity of operate valve to water (at the time an i
l catastrophe by pump ngwithin the CPSES Unit 2 source Id., at-1 3 d was.
boron from ted facility).that Ms. Billie P. Gar e a
unlicensed and uninspecspecifically alleges reports prepared by.
Mr. Jones other non-conformance t when-and numerous advised Mr. Jones tha given this and that she personally "TU would never
- SLB, Mr. Jones was presented to the A Nonetheless, SRJ at i 5.6 this informationoperating license."
to the.ASLB, TUEC's-receive their information was' presented negotiate Ms. Garde to before Mr. Jones' Wooldridge, met withing, oceeding counsel, Mr. Robertto disband the licens the ASLB.
- Notably, agreement could be presented towith TUEC's neg and-an information Jones' overlap in time ceived under the-these negotiations from the ASLB that TUEC re UEC forced secreting information settlement agreements T restrictive subject of dispute in 4
of the the terms co-owners and which are proceeding.
P intervention in the CPA its Petitioners' tend that aware, Petitioners.concitizens was As the Commission is 1988 settlement betweenEC was buying sile a
6 understanding that TU would not volunteer informsafety.of the the July 13, an based on such, Ms. Garde d to the and others that relate 1
as 7
i
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y with TUEC's' counsel to pa reements actively.
After Carde reaching ag clients, Ms. Garde their various lieve that her over $10,000,000 to whistleblowers to be be and other the licensing board to misled Mr. Jones would be "put beforewould be issued."
SRJ at safety concerns operating license pay some corrected before the nce TUEC had arranged to allegations, The fact remains that o of Mr. Jones' clients, none SRJ at 5-7 S 6.
to Garde's
$10,000,000 raised before the NRC.
managed.to Lthat TUEC has n
to this date, have beeallegations indicate ificant safetya i
Mr. Jones' ent of hush money s gn of Petitioners is secret through the paym underlying allegation d in; delays information.
and competence resulte The has not related haracter that TUEC's lack of c same lack of character this haracter has construction, and that Because this lack of ccann g
l; e in ffjygg corrected to date.
the Commissionoperating license.
been ce, direct safety significanconstruction permit l
to an iured will be irreparably in its convert will be to itioners Petitioners set forth above, Pet C.
convert its For the reasons allowed to l
if TUEC is matters In irreparably injured operating, license.
irreparabf -
construction permit to nuclear power plant, an
.i sing of a d safety of.
pertaining to the licen d risk to the health an tory of-injury includes increase In light of TUEC's his and the public.
nd NRC through Petitioners information from the ASLB a parties, andli?
secreting safety with witnesses.and other es that some 300 non.
contractual agreementsallegation from Mr. Jo light of the 8'
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l.
v-conformance reports were secreted from the ASLB and that the deficiencies identified therein have.never been corrected, Petitioners will suffer irreparable harm if an operating' license.
i is granted.
Petitioners will also be irreparably injured if an. operating license is issued before their petition to intervene in.the CPA.
proceeding is fully litigated and resolved by the Commission.
The issuance of a full power license prior to resolution of Petitioners' CPA appeal, which has been pending before the Commission since December of 1992, will deprive Petitioners of their right to due process and, by so doing, turning Petitioners'-
right to a hearing into a charade.
Such an undertaking by the.
Commission is not only blatantly illegal, but will irreparably' injure the Petitioners by granting a full power operating license-to a licensee which lacks the charactpr and competence to construct, let alone operate, Unit 2 at CPSES.
D.
The granting of a stay does not constitute a cognizable harm to TUEC Petitioners' request for a stay is based on their. legal right to a hearing.
Petitioners' due process.does not constitute a cognizable harm to TUEC.
Indeed, at the time TUEC sought a license to operate a nuclear power facility it fully realized that interested persons are entitled to hearings on matters pertaining to TUEC's seeking an amendment of its construction ~
permit.
TUEC cannot claim that Petitioners' right to a hearing constitutes a cognizable harm.
9 1
Moreover, the licensee presumably has an interest, if not a duty, to make sure that its nuclear facility is constructed in compliance with NRC regulations.
Rather than a_ cognizable harm ~,
the requested stay, if granted, would constitute a benefit to-TUEC by affording it an opportunity to assure the NRC and the public that it possesses the character and competence to construct and operate the CPSES.
E.
The public interest lies in the Grantinc of a Stav-r The public's interest is served by ensuring that the hearing rights of citizen intervenors are scrupulously maintained.
because the issues related to TUEC's character and
- Moreover, 9
competence include allegations that TUEC has intentionally.
constructed Unit 2 in violation of NRC requirements and continues l to engage in a pattern of covering up safety significant information which poses a serious ris) to the health'and safety i
of the public, it is in the public's interest to_ grant a' stay until such time as the hearing process is concluded.
TUEC will not be prejudiced by the delay which might result in permitting Petitioners to lltigate their contentions in the CPA proceeding (i.e., that the licensee lacks'the character and:
competence to construct CPSES Unit 2).
The public's interest in I
assuring that CPSES is safe outweighs TUEC's economic interest that would be derived from the licensing and operation of Unit 2.
The Public interest overwhelmingly weighs in favor of granting a'
.f stay to ensure that Petitioners are not deprived of their right l
to due process and that the public's health and safety is not-i 10
- l l
1
. ~.......-.-
~
.placed at ris.k by TUEC's insidious practice.of paying hush money l
- to suppress safet y concerns. at the CPSES.
- )
c y; t
Conclusion For the reasons set.forth.above, the. Commission should grant
?!
~ '
a stay of the Unit 2 full power license.
ll i
Respectfully submitted,-
l i
is Michael D.: Kohn David K. Colapinto
'KOHN,.KOHN AND COLAPINTO, P.C.
't 517' Florida Avenue,- N.W.-
'4ashington, D.C.
20001-(202).234-4663 3
I Attorneys for Petitioners
.f Dated:
. March 15,.1993
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5 s p IO s WL 3 D 000ftETED 51 UNITED STATES OF. AMERICA 'R 1 b 82 HUCLEAR REGULATORY COMMISSION ~~ DOOKETING & ATOMIC SAFETY AND LICENSING APPEAL BOARD SERVICE BRVIOH y SEGY44RC In the Matter of ) 1 ) Docket No. 50-44 ys C TEXAS UTILITIES ELECTRIC COMPANY, ) ASLBP HO. 92-668-01 ) ) (Construction Permit (Comanche Peak Steam Electric ) Amendment) r Station, Unit 2) ) CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of PETITIONERS' MOTION TO STAY ISSUANCE OF FULL POWER LICENSE was served upon the following persons, via. facsimile, on the date shown below: Office of Commission Appellate Adjudication-U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Office of the Secretary,
- (original and two copies)
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 George Edgar, Esq. Newman & Holtzinger, P.C. 1615 L Street, N.W., Suite 1000 Washington, D.C. 20036 Janice E. Moore, Esq. Nuclear Regulatory Commission Office of the General Counsel Washington, D.C. 20555 r
- R. Micky Dow 506 Mountainview Estates Grandberry, Tx '76048 i
Dated: March 15, 1993 By: Michael D. Kohn
- Also by deposit in the United States. mail
- Only by deposit in the United States mail 053\\ cert.nrc i
t E r 4 -r .L!-