ML20065A999
| ML20065A999 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 02/15/1983 |
| From: | Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | |
| Shared Package | |
| ML20065A992 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8302220352 | |
| Download: ML20065A999 (10) | |
Text
'
~
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
-In the Matter of
)
WASHINGTON _PUBLIC POWER SUPPLY SYSTEM
)
Docket No. 50-460-OL
-(WPPSS Nuclear Project No. 1)
AFFIDAVIT OF GERALD C. SORENSEN REGARDING CONTACT WITH MEMBER OF PETITIONER ORGANIZATION My name is Gerald C. Sorensen.
I am employed by the Washington Public Power Supply System as the Manager of Reguletory Programs (former-ly Licensing Programs).
My business-address is Post Office Box 968, Richland, Washington 99352.
During the Prehearing Conference on January 26, 1983, concerning the Construction Permit extension requests for WNP-
'l and WNP-2, the representative for the Coalition for Safe Power (Petitioner) inferred that their member, Mr. Terry Dana, had been harassed by a representative of the Washington Public Power Supply System (TR at,41).
Again, in the document filed with the Licensing Board on February 7, 1983, Petitioner stated that "...the Applicant in this case has also.
subjected Petitione*'s members to harassment by exerting pressure upon him to withdraw his support from the petitions which were filed in early 1982" (CSP Position on Protective Order at 6).
These claims by the Petitioner concerning the contact between the Supply System and Mr. Dana do not correctly depict the nature of that i
contact and are therefore false and misleading. An accurate statement of the facts is as follows.
On March 25, 1982, I called Mr. Terry Dana at his home. When the phone was answered I asked to speak with Terry Dana. The answering party responded that he was Terry Dana.
I then introduced myself, noting that I-was the Manager of Licensing for the
(
8302220352 830217 gDRADOCK 05000460 l
Washington Public Power Supply' System and expressed interest in talking with him about the petitions filed by the Coalition for Safe Power.
~
After a rather lengthy pause, Mr. Dana replied that he would prefer not to' talk with me, that if_ I were attempting to alter his views it could be considered harassment, that he knew his rights, and since he was being represented by the Coalition I should contact them.
I assured Mr.
Dana that it was not 'my intent to harass him, that if he felt uncomfortable in speaking with me that was fine, and that it was not my intent to force a' conversation on him.
I explained-that the reason for my call was that since he is a party to the petition.and that the only interest the Coalition has is that represented by him, I would be interested in knowing of his concerns.
I noted that a hearing would be time consuming and costly, and questioned whether there are other ways to address his concerns.
I then stated that if he felt uncomfortable in speaking with me, I would have an opportunity to hear his concerns if a hearing were granted. Mr. Dana responded that he did not feel that we had anything to discuss as his views were not going to change.
I then gave him my telephone number and suggested that he call me if he had any interest in dis' cussing his concerns in the future, and terminated the conversation in a cordial manner. At no point in the conversation did I suggest that Mr. Dana withdraw his affidavit.
This entire conversation lasted less than three (3) minutes and to my knowledge constituted the only contact between the Supply System and Mr. Dana.
I have made no attempt to determine Mr. Dana's place of employment and to my knowledge there has been no contact bt ween the Supply System and Mr. Dana's employer regarding Mr. Dana.
a
9 STATE OF llASHINGTON)
)
SS COUi1TY OF BENT 0il
)
I, G. C. Sorensen, being duly sworn, subscribe to and say that I am the i-lanager, Regulatory Programs, for the ilASHINGTON PUBLIC P0ilER SUPPLY SYSTEM, and that the foregoing is a true and accurate account of my conversation with eir. Terry Dana.
Date /6~ M8
, 1933
- G. C. Socensen, Manager Regulatory Programs 2
On this day personally appeared before me G. C. Sorensen to me known to be the individual who executed the foregoing instrument and acknowledged that he sfgned the same as his free act and deed for the uses and purposes therein mentioned.
GIVEN under my hand and seal this 15.) day of Vhau,1983.
6' k
hd i otary'Public ihand for tne State of 11ashingt W Residing a M M k.
-GL N. No w.
Am.
- es <3 e
)
gg c[-*
- _...._ NUCLEAR REGUIATORY COMMISSION 3 ]'P r M q 9 ~
- +.y 1 11982 g
ii 1
'%ilUL'd l
^
.nn:t:In,!bwman, u
& Axelrad In the Mst:ar of:
p.. ;
)
1 PUGET SOUND POWER & LIGHT CO.,
) DOCKET WOS.
I
~
et al
) STN-50-522
..(Skagit/Eanford Nuclear Project 1 STN-50-523
).
Units J. & 2
.1 y.
PAGES:1 thru 77 I
DATE: May 5, 1982 yg ;-
Richland, Washington 4
g 1
.. j.:.=: :. :-
n.
r.
i:u,;..-
y-w,...
j _..
1...
@ C...
{-lC.
I. -
r,,.
g :. -
E0
&QQR Ac c virgisia Ave..,' S.N. Wa@ d v.=n, D. :C. ~20 0 2 4
'.~
~~
g,Qchc=a: '4202) 554-2345 IT -
h... y' !
t 36 lM.?i%
a.
if we could finance them without using this BPA financing, l,
i J
go forward, but in all likelihood we will want to try to i
2 F
I use the regional financing.
3 JUDGE LINENBERGER:
All right, thank you.
4 JUDGE WOLF:
Does anyone have any further statement 5
about the matter that they wish to make?
If not, we will 6
move on then to another matter, namely, the Notice of the 7
Taking of Deposition of M. Terry Dana.
8 MR. THOMSEN:
7 think I can dispose of that.
9 The Applicants had wanted to question Mr. Dana 10 about his affidavit, and about the 70-odd contentions that 33 have been filed on his behalf now by the Coalition.
of course, 12 the Coalition objected to that.
I thought that perhaps I 13 could resolve this informally by simply having a meeting with 14 Mr. Dana, and so I talked with him earlier this morning by
)
15 phone, and inquired whether -- I had talked to him Sunday 16 also about the possibility of meeting, and I asked him 37 whether he was willing to meet with me.
He had said he wanted
,g to talk to Ms. Bell, and I assume he has.
39 At any rate, this morning he said he was not willing 20 l
to meet with me, md.I asked him whether he was going to come 21 to this conference, and.he said he was not.
And I asked him 22 whether he would consider withdrawing from this proceeding, 23 and he said, "No."
And I asked whether he was familiar with 24 the 70 contentions filed on his behalf.
I wasn't sure about 25
"y%94
.'4.N
~~-
~
. -... =. _.. ~. - -
- - - - ~..
- : =_? = w
. -:.m -
37 I
T, g.
l And I asked him whether he y
n He said, "Yes," he was.
1 that.
f those ould be willing to consider withdrawing any o J
i h' That. had been one thing I wanted to discuss w t 2-w contentionk.
And I asked him whether he realized 3
l And he said, "No."
him.
in terms of this proceeding, the 4
i the consequences of that, way, of dealing I
5 expense and difficulty we all have, the job, any l
6 with those contentions, and he said he was.
it So in view of these responses, I concluded that 7
i o I withdraw 8
would not be productive to take his deposit on, s He satisified the points I had in mind g
'the request on-that.
to over the telephone.
Well, I don't think that I am satisfied.
33 JUDGE WOLF:
and I think 12 with his refusal to discuss the matter with you, I
is willing to 13 that under those circumstances, unless he ill not k 34 respond to discovery in this matter that he w 15 eligible to testify here.
Excuse me, he is not able to, or I am 16 MS. BELL:
17 not able to?
I say unless this person, Mr. Dana, 3g JUDGE WOLF:
h'is hearing, he is willing to comply with the procedures of t 19 intended to bring
,i
,g will n t be eligible to testify, if you f
i I don't know whether you did or not.
21 him as a witness.
Mr. Chairman, Mr. Dana is not a witness.l 22 MS. BELL:
and as for He is a member of the Coalition for Safe Power, 23 had with this member of l 24 the discussion that the Applicant has n
L
-s 38
]-
-.y,-
1
.r h t the Applicant n
ours, Mr. Dana, we were never informed t a m
l' ith him, or of 7
i was interested in an informal discussion w intending to bring him 2
these two phone calls, but we are not 3
He is simply our member.
/
Well, did I misunderstand Mr. Thomsen?
as a witness.
4 JUDGE WOLF:
king this person's 5
I thought that you had set up a date for ta 6
deposition, is that correct?Yes, I had in the Notice 7
MR. THOMSEN:
the Coalition objected' 8
that it be taken last evening, but then l
So I thought then maWe at g
to the taking of any deposition.
And they were least we could have an informal discussion.Mr. Dan to 9
n suggesting that I was trying to harrass Well, let us have a private 12 of -- and of course, I thought:
he wanted there, 13 meeting then, just Ms. Bell, and whoever
- Well, d Sunday he said:
34 off the record. sort of discussion, an d think it over, and he would talk to Ms. Bell about that, an 15 ot meet with me, even 16 this morning he said he would rather n d in 5
So I went on to ask him the questions, an 17 informally.
I decided to withdraw the request.
18 view of the answers I got, 4
! ;j Mr. Chairman, it seems that the 39 MS. BELL:
with Mr. Dana over i
Applicant has had an informal discuss on 20 f
i:
i hdrawn the request to l
ld 21 l the telephone, and since he has w t f
i is moot.
depose Mr. Dana, it seems the question 22 j
Well, I understand that, and r
23 CHAIRMAN WOLF:
/
dles it, but I am not q
of course it is up to him how he han 24
,5 4
I
~ ~ ~ ~ ~ ~
^%
f e
39 prepared to accept that conduct on the part of a person who l
is standing as the basis for your Intervention here.
I think 2
he has a duty to this Board to respond an be cooperative, and 3
I will take this under advisement, and we will discuss it at 4
5 a later time.
6 I don't believe that discovery is harassment.
That might have been so back around the period of the Civil War, 7
8 but the procedures in the courts have long passed that time, and I think that any time there is a request for discover:,
g 10 I think the parties have to respond.
If there is any 9;
harassment, you can bring it to me, and we will see that it is eliminated, but the mere fact that they are asked to appear 12 13 for discovery is not harassment, in my judgment.
14 We will take,up next, Ms. Bell, your motion for.
15 extension of time by the coalition for Safe Power, dated April 20th, 1982.
I 16 MS. BELL.
What do you request from me?
3 97 e
ig-CHAIRMAN WOLF:
Are you still standing by that I
motion?
Do you want to--
ig l
MS. BELL:
Yes, we are still standing by the motion, I
20
(
l and in fact since the motion was filed, we still received an gi additional amendment to the Preliminary Safety Analysis t
22 l
Report, and of course the Staff has also apparently filed 1
23 I
their DES, so--
24 caAIRnAn wom Wen, you may receive mendments l
l
f' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
WASHINGTON PUBLIC POWER
)
Docket No. 50-460-OL SUPPLY SYSTEM
)
)
(WPPSS Nuclear Project No. 1) )
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing "Appli-cant's Motion for Leave to Supplement Memorandum" in the captioned matter were served upon the following persons by deposit in the United States mail, first class, postage prepaid this 17th day of February, 1983:
Herbert Grossman, Esq.
Chairman, Atomic Safety and
. Chairman, Atomic Safety and Licensing Appeal Board Licensing Board U.S.
Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Mitzi A. Young, Esq..
Glenn O.
Bright Office of the Executive Atomic Safety and Licensing Legal Director Board U.S. Nuclear Regulatory
' U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Chairman, Atomic Safety and Dr. Jerry Harbour Licensing Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Commission U.S.
Nuclear Regulatory Washington, D.C.
20555 l
Commission l
Washington, D.C.
20555 l
l e
e
2-Mr. Eugene Rosolie
- Mr. Scott W.
Stucky Coalition for Safe Power Docketing & Service Branch Suite 527 U.S.
Nuclear Regulatory 408 South West 2nd Commission Portland, Oregon 97204 Washington, D.C.
20555 Gerald C.
Sorensen Manager of Licensing Washington Public Power Supply System 3000 George Washington Way Richland, Washington 99352 06lf
- San $rd L.
Hartman 4
4 4
.-w