ML20151Y623
| ML20151Y623 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/02/1988 |
| From: | Reis E NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| CON-#288-6213 OL, NUDOCS 8805050053 | |
| Download: ML20151Y623 (16) | |
Text
62/3 00CKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'88 mY -3 P6 :29 BEFORE Ti1E ATOMIC SAFETY AND LICENSING APPEAL (BOARD.7U..A:
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in the Matter of
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Docket Nos. 50-443 OL PUBLIC SERVICE COMPANY OF
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50-444 OL NE% HAMPSHIRE, ej al,
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Off-site Emergency Planning
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(Seabrook Station, Units 1 and 2)
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NRC STAFF'S RESPONSE TO JOINT !NTERVENORS' MOTION FOR DIRECTED CERTIFICATION Edwin J. Reis Deputy Assistant General Counsel May 2,1900 6905050053 800502 PDR ADOCK 05000443 o
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9 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE Ti1E ATOMIC SAFETY AND LICENSING APFEAL B.O.AOD In the Matter of
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Docket Nos. 50-443 Oz.
f'UBLIC SERVICE COMPANY OF
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50-444 C4 NEW HAMPSHIRE, ej g.
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Off-site Emergene.y Planning
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(Seabrook Station, Units 1 and 2)
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NRC STAFF'S RESPONSE TC i
JOINT INTERVENORS' MOTION f
FOR DIRECTED CERTIFICATION i
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Edwin J. Reis I
Deputy Assistant General Counsel May 2,1980 1
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E UNITED STATES OF AMERICA NUCLEAR REGllt.ATORY COMMISSION BEFORE THE ATOMIC SAFETY _AND LICENSING APPEAL BOARD In the Matter of
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Docket Nos. 50-443 OL PUBLIC SERVICE COMPANY OF
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50-444 OL NEW HAMPSHIRE, et al.-
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Off-site Emergency Planning (Seabrook Station, Units 1 and 2)
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NRC STAFF'S RESPONSE TO JOINT INTERVENORS' MOTION FOR DIRECTED CERTIFICATION i
On April 22, 1988, the New England Coalition on Nuclear Pollution (NECNP),
Seacoast Anti-Pollution League (SAPL), the Mossachusetts I
Attorney General, and the Town of Hampton filed a motion for directed certification, M appealing from various cral rulings and statements made by the Licensing Board with respect to certain discovery disputes which have arisen between Intervenors and FEMA. EI For the reasons set forth 1/
"Joint Intervenors' Motion for Directed Certification" ("Motion"),
~
dated April 22, 1988.
1/
lt is unclear precisely which rulings or staterrents the intervenors t
seek to appeal, in general, however, their complaints seem to fall into two categories:
(a) the Licensing Board's allowance of FEMA's claim of the executive or deliberative process privilege, and (b) the Board's denial of their request that five additional FEMA officials I
eppear for depositions concerning the reasons behind FEMA's shift in position on the adequacy of protemve measures for New Hanipshire seasonal beach populations, as contained in the New Hampshire i
Radiological Emergency Response Plan (NHRERP).
These matters largely arose out of the Intervenors' deposition of Edward Thomas, the individual whom FEMA hao designated to appear as its sole witness on its initial (September 1987) prefiled testimony.
i (FOOTNOTE CONTINULD ON NEXT PACE) 8
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l below, the NRC Staff opposes the Motion and recommends that it be denied.
DISCUSSION 1.
Directed Certification is Not Warranted.
The standards governing motions for directed certification are well established and have previously been addressed on numerous occasions by the Appeal Board in this proceeding, b in ALAB-864, the Appeal Board summarized these standards as follows:
(FOOTNOTE CONTINUED FROM PREVIOUS PAGE)
Simultaneously with their filing of the instant Motion before the Appeal Board, the intervenors filed 13 requests for subpoenas of NRC and FEMA personnel to testify at the evidentiary hearings scheduled to commence on May 2, 1988.
The Licensing Doard has stayed its hand with respect to those subpoenas, in light of the Appeal Board's Orders of April 26 and 27, 1988 -- although it Indicated that it is inclined to grant a substantial portion of the relief requested by Intervenors (see Chairman Smith's concluding remarks in transcript of telephone conference call held on April 29, 1988, Tr.
).
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(1)
Public Service Co. of New Hampshire (Seabrook 3/
S ee,
e 5tation, Units 1 and 2), A LA B-889, 27 NRC (March 18,1988) l (directed certification of scheduling order denied, where movants failed to show a deprivation of due process);
(2) ALAB-884, 27 NRC (February 4,1988) (directed certification of rvidentiary e
ruling denied, for lack of promptness in filing); (3) ALAB-864, 25 NRC 417 (1987) (directed certification of scheduling order granted, where Intervenors were deprived of an adequate opportunity to prepare an affirmative case to rebut FEMA's still unknnwn position);
(4) ALAb-860, 25 NRC 63 (1987) (directed certification of scheduling orc ler denied, where movants' concerns were premature and might be mooted by the Licensing Board); (5) ALAB-858, 25 NRC 17 (1987)
(directed certification of scheduling order denied, where movants failed to show a deprivation of due process); (6) ALAB-639, 24 NRC 45 (1986)
(directed certification of motion to amend hearing transcript g ranted).
Cf.
Id.,
A LAG-838, 23 NRC 585 (1%6)
(interlocutory appeal from rejection of interested State's sole contention denled,
where State would nonetheless continue to participate in the proceeding);
ALAB-737, 18 NRC 168 (1983)
(same).
The Commission's Rules of Practice prohibit appeals from interlocutory licensing board rulings of the type involved here.
And, as we recently had occasion to observe anew in this proceeding, it is well settled that we will exercise our discretionary power to review an Interlocutory ruling by way of directed certification only if that ruling either (a) threatens the party adversely affected with immediate and serious irreparable harm that could not be remedied by a later
- appeal, cr (b) affects the basic structure of the proceeding in a pervasive or unusual manner, ld. at 420-21, citing A LA B-858, 25 NRC at 20-21 (footnotes omitted).
In particular, the Appeal Board has forcefully indicated that interlocutory review of discovery rulings is much disfavored:
We also have repeatedly pointed out that "discovery rulings of licensing boards are not promising candidates for the exercise of our discretionary authority to review interlocutory orders."
Texas Utilities Electric Co. (Comanche Peak Steam Electric Station, Units 1 and 2),
A LA B-870, 26 NRC 1 (1987) (footnote omitted), quoting Houston Lighting and Pov.er Co. (South Texas Project, Units 1 and 2),
ALAB-608,12 NRC 168,170 (1980). b Indeed, on a pre.vious occasion the Appeal Board declined to direct certification of an order quite similar to the ones at issue here, where an intervenor sought review of an order denying a motion to compel FEViA to produce certain documents.
There, the Appeal Board noted that,
-4/
- Accord, Consumers Power Co (Midland Plant.
Units 1 and 2),
ALAG-364, 13 NRC 96, 99 (1981) (declining to "second guess" a Licensing Board's ruling on a deposition
- request, absent an indication that the Board abused the broad discretion conferred upon it by the Commission in discovery matters; and observing that the Commission places "maximum reliance" on the presiding officer's l
determinations on discovery matters, given his "first-hand contact l
with and appreciction for all the circumstances" surrounding a particular case),
i l
I
"insofar as our research has disclosed, no prior endeavor to obtain directed certification of the denial of a discovery request has been successful. "
Long Island Lighting Co. (Shoreham Nuclear Power Station, Unit 1), ALAB-780, 20 NRC 378, 381 (1984) (emphasis in original).
The Appeal Board then ruled as follows (id., at 382):
We see no reason to reach a different result here.
Plainly, shou.'u it turn out that the discovery ruling in cuestion contributes materially to an unfavorable outcomo on the emergency planning
- issues,
[the intervenor) will be free to mount its challenge to the ruling or, an appeal from that outcome.
Equally plainly, there is no room for a serious claim that the ruling has affected the basic structure of the proceeding at all --
let alone in a pervasive or unusual manner.
To the contrary, the situation at bar cannot be differentiated from that in any other case in which a party endeavored unsuccessfully to acquire certain information to assist its preparation for trial.
Even if the party might have been entitled to obtain the sought Information by way of discovery, it scarcely follows that the proceeding was significantly altered in structure s'mply because the reouest was not enforced by the trial tribunal.
An application of these standards to the instant Motion demonstrates that it should be denied.
The Intervenors do not argue that the Licensing Board's rulings threaten them with "immediate and serious irreparable harm".
While they do not assert that the rulings "a f fect the basic structure of the proceeding in a pervasive or unusual manner",
they contend that the Board's rulings "have a pervasive effect on the conduct nf the litigation" (Motion at 1);
that they "surely had a pervasive and unusual impact in this critical litigation" (id, at 3); and that "[t]he rulings and their rationale have profoundly restricted and determined the 'very shape of the ongoing adjudication'" (ld.).
The meaning of these assertions is provided later, r
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where the Intervenors make it clear that their real concern is the effect these rulings might have on the outcome of the litigation:
[T]hese rulings have had the effect of absolutely barring intervenors from developing admissible evidence on at least three key claims which they would present, if permitted, to the Licensing Board:
- 1) that FEMA's dramatic reversal of position in the Seabrook case was substantially caused by pressure from NRC and others ouside FEMA;
- 2) that FEMA first committed to NRC that it would change its position and formulated the proferred bases for change af terward, and 3) that the key decision-makers at FEMA were heavily influenced by claims that Seabrook has a "special" containment, that life-threatening accidents are of such extremely low probability as to be negligible and that the releases would be essentially "benign" by the time they reached the beach.
These arguments are either factually inaccurate and/or in conflict with the governing precepts of emergency planning, if the Intervenors are effectively prevented from developing and presenting these arguments, the outcome of this litigation may well be predetermined.
(ld., at 31-32; emphasis added),
i These assertions cannot tt ansform a discovery ruling into an issue of such fundamental and irrevocable effect as to compel the reversal of this Board's long-standing reluctance to Interfere with a Licensing Board's discretionary authority to rule upon discovery matters.
Quite simply, even if the Intervenors are correct in their argument that further deposition discovery should have been permitted and that the outcome of the proceeding may otherwise be af fected, any harm that may be occasioned by the Licensing Board's rulings can casily and fully be remedied upon suosequent appellate review following the issuance of a decision on the merits.
Even if the Appeal Board should later determine that the Licensing Board erred in restricting further deposition discovery of FEMA, and that this error may have had a prejudicial effect on the outcome of the proceeding, a rerrand of the issue for further discovery
s and litigation at that time wl!I surely afford the intervenors the same relief they seek now.
No reason has been provided by the intervenors in their lcrigthy Motion which would warrant a contrary conclusion, ll.
The Licensing Board's Rulings Should Be Affirmed.
A.
The _Intervenors Failed to File A Recuest for Subpoena.
As a preliminary matter, it is important to note that FEMA is not a party in NRC adjudicatory proceedings, and therefore cannot be compelled to respond to a notice of deposition as was filed here, absent the filing of a request for subpoena -- which the Intervenors have failed to do.
In effect, FEMA appears in this proceeding as an advisor to the NRC, pursuant to a Memorandum cf Understanding between the two agencies.
I in this regard, the MOU states that "FEMA will provide support to the NRC for licensing reviews," inter alia, by providing its findings and determinations on offsite plans and preparedne::s, which FEMA is to support by makin0 expert witnesses available before the Licensing Boards and during any related discovery proceedings.
The MOU further provides that "FEMA will appear in NRC licensing proceedings as part of the presentation of the NRC Sta f f",
but that ',',F,EJjA is not a partv to NRC proceedings and, therefore, is not subject to formal discovery require-ments placed upon part.les to NRC proceed,inos."
(Id., emphasis added),
in the instant proceeding, the Staff requested that FEMA provide its Interim findings and determinations concerning the issues in controversy.
FEMA has responded to this request and, pursuant to the MOU, has 5/
"Memorandum of Understanding Between Federal Emergency Management Agency and Nuclear Regulatory Commission," 50 Fed.
Reg.15485 ( April 18,1985) ("MOU").
-7_
designated three witnesses to testify with respect to its current, favorable, prefiled testimony on beach population issues Dr. Joan Hock, Joseph Keller and William Cumming.
At the same time, FEMA voluntarily produced these individuals for deposition discovery, also making available the Individual who had been designated to sponsor PEMA's original, unfavorable, prefiled testimony (Edward Thomas).
Although the intervenors served notices of deposition requesting that five additional FEMA employees witnesses appear for depositions, they have never sought to compel such testimony with a request for subpoena.
Accordingly, under the procedures governing third-party practice, the additional deponents may not be compelled to appear.
See generally, Pacific Gas and Electric Co.
(Stanislaus Nuclear
- Project, Unit ~i),
ALAB-550, 9 NPC 683, 690 (1979); Fed R. Civ. P., Rules 26, 30 cnd il5.
B.
Executive Privliege May Properly B_e invoked _To Protect The Deilberative Precess, it is not subject to serious dispute that FEMA is entitled to assert the executive cr deliberative process privilege, to prevent disclosure of both intra-agency and inter-agency pre-decisional deliberations and thought processes.
The privilege has been recognized to exist in NRC adjudicatory proceedings, and has been upheld by the Appeal Board in 6/
As indicated at n. 2, supra, the Intervenors have now filed requests for trial subpoenas directed to four NRC employees and nine FEMA employees, including the five individuals at issue here.
The Licensing Board has not yet ruled on those requests, and has indicated that it will stay its hand pending the Appeal Board's resolution of the instant Motion.
A favorable ruling by the Licensing Board with respect to some or all of the subpoena requests could conceivably cure any harm which the Intervenors assert may be occasioned by the instant rulings -- further mandating that the instant Motion be denied.
appropriate circumstances.
- See, e
Long Island Lighting Co.
g, (Shoreham Nuclear Power Station, Unit 1), A LA B-773, 19 NRC 1333 (1984); Consumers Power Co. (Midland Plant, Units 1 and 2), ALAB-634, 13 NRC 96 (1981).
The Staff, however, expresses no position here with respect to whether FEMA properly asserted the privilege in this instance; whether its attorney may have waived the privilege, inadvertently or othe. wise; to what extent, if any, a waiver has occurred; or whether the Licensing Board correctly ruled upon FEMA's assertion of the privilege.
In our view, these matters are best addressed by FEMA.
C.
No Compelling Need For Further Depositions _ Has Been Shown.
The Intervenors' Motion complains that the Board erred in precludlng them from obtaining deposition discovery from Mr. Thomas and the five additional FEMA witnesses whom they sought to examine concerning the reasons behind FEMA's shift in position.
However, by t he.ir own admission, the Intervenors have been allowed almost unlimited opportunity to examine the four FEMA witnesses as to these matters, having examined FEMA's three principal witnesses over the course of six deposition days, and having conducted four days of examination of Mr. Thomas.
No showing has been trade that further depositions or examination of Mr.
Thomas might lead to the discovery of admissible evidence beyond that which the intervenors may have already obtained.
Further, the issue of why FEMA changed its position bears little, if I
any relevance to the central determination which must be made here, i.e.,
whether the NilRERP's provisions for protection of the New Hampshire seasonal beach populations are adequate.
In this regard, the Appeal Board has previously had occasion to observe as follows:
i
(
It is also important to place in perspective the significance of the FEMA findings:
First of all, it is the ultimate institutional findings and determinations by FEMA, lot the predecisonal opinions of various members of the P.AC, that are centrally important.
- Moreover, although these findings constitute a
rebuttable presumption under the Commission's regulations, the appilcant bears the ultimate burden of demonstrating
+
that the emergency plans are satisfactory and, on the basis of all the information submitted, the Licensing Board must be able to conclude that the state of emergency preparedness provides "reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency."
As we pointed out in our San On_ofre opinion,
[t]he fact that a final FEMA finding is entitled to a rebuttable presumption does not convert that agency into a decisionmaker in Commissicn licensing proceecings.
A failure by the four FEMA witnesses adequately to defend the FEMA findings and determinations deprives them of whatever reilability, and hence whatever presumptive effect, they might otherwise have.
Long Island Lichtir)g Co.
(Shoreham Nuclear Power Station, Unit 1),
A LA B-773, 19 NRC 1333, 1346 (1984) (footnotes omitted) (finding an inadequate showing of need sufficient to override FEMA's claim of the executive or deliberative process privilege).
- Thus, even if the Intervencrs could demonstrate, e t, they allege, that FEMA succumbed to outside pressures in deciding to adopt its current position, the merits of that position would still remain the central issue for resolution in this proceeding.
Similarly, even assuming that various NRC employees may have communicated their opinions to FEMA -- as was clearly contemplated and encouraged in the Memorandum of Understanding between FEMA and
o the NRC II -- and even if those views were communicated to FEMA in a particularly forceful manner (which the Staff does not concede has occurred), the Licensing Board's central task would still be to determine whether the N HRERP's provisions are adequate and, as a corollary, whether FEMA's substantive position is well supported.
Cf. Shoreham, ALAB-773, supra,19 NRC at 1344-47.
The intervenors premise their argument mainly on a claim that "the deposition of Mr. Thomas (which] elicited evidence of a meeting where NRC's Executive Director vowed war on FEMA unless that agency changed its position..." Motion at 17.
The transcript of Mr. Thomas' testimony as set out in the motion was that he had heard "that Stello had Indicated that the NRC wouldn't engage in total war with FEMA If we didn't change our testimony on the beach population. "
- g. at 7.
Interverors claim the transcribed word "wouldn't" was actually "would".
M.,
n.5.
Further, it is not shown where the "indications" of "war" comes from, whether it comes from Mr. Thomas, those who spoke to him concerning the meeting, those at the meeting, or Mr. Stello.
Certainly, there is no hint that the Exectutive Directer "vowed war," nor did anymore than express the NRC's staffs views on the Interpretation of NRC's regulatory requirements, in these circumstances, intervenors' argurrent might be more cogent if their motion was based on the deposition testimony of one of the FEMA designated witnesses, at least one of whom was at the NRC/ FEMA meeting 1/
See Memorandum of linderstanding Between Federal Management
~
Agency and Nuclear Regulatory Commission, 50 Fed. Reg. 15485
( April 19,10P,5).
m_
- 11
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where the alleged change in position was influenced.
No such effort was made.
No basis is shown for the claim of "extraneous, impermissible or political influences."
Motion at 19.
.No basis is shown for the need for 2
the deposition of the high FEMA officials which FEMA here seeks.
In these circumstances the Appeal Board should decline this effort to broaden and delay resolution of the issues in this proceeding.
CONCLUSION The Licensing Roard's rulings on these discovery matters neither threaten the Intervenors with immediate and serious irreparable harm, nor do they have a pervasive and unusual effect on the basic structure of the proceeding.
Further, no reason has been shown which would warrant a disregard for the deference that has traditionally been accorded to
!!censine boards to rule upon matters such as these.
For these reasons, as more fully set forth above, the Motion should be denied.
Respectfully submitted,
.ff Q/
Edwin J Reis Deputy / ssistant General Counsel A
Dated at Rockville, Maryland this 2na aay of May 1988 1
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00LKETED U94RC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 88 HAY -3 P6 :29 BEFORE THE ATOMIC SAFE'/Y AND LICENSING APPEAL ROARFICE Oi SUh't#.'
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QUCHEhG A SilW L SPANCH in the Matter of
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Docket Nos. 50-443 OL PUBLIC SERVICE COMPANY OF
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50-444 OL NEW HAMPSHIRE, g al.
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Off-site Emergency Planning
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(Seabrook Station, Units 1 and ?
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CERTIFICATE OF SERVICE i
hereby certify that copies of "NRC STAFF'S
RESPONSE
TO JOINT INTERVENORS' MOTION FOR DIRECTED CERTIFICATION" in the abcVe-captioned proceeding have been served on the following by deposit in the United States mall, first class or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Commission's internal mall system, this 2nd day of May 1988.
Ivan W. Smith, Chairman
- Atomic Safety and Licensing Administrative Judge Board
- Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Gustave A. Linenberger, Jr.*
Docketing and Service Section*
Administrative Judge Office of the Secretary Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Corr. mission Washington, DC 20555 Washington, DC 20555 Dr. Jerry liarbour*
Thomas G. Dignari, Jr., Esq.
Administrative Judge Robert K. Gad, lil, Esq.
Atomic Safety & Licensing Board Ropes & Gray U.S. Nuclear Regulatory Corr. mission 225 Franklin Street Washington, DC 20555 Boston, MA 02110 H.J. Flynn, Esq.
Atomic Safety and Licensing Assistant General Counsel Appeal Panel
- Federal Emergency Management Agency U.S. Nuclear Regulatory Commission 500 C Street, SW Washington, DC 20555 Washington, DC 20472
Philip Ahren, Esq.
Calvin A. Canney Assistant Attorney General City Hall Office of the Attorney General 126 Daniel Street State House Station Portsmouth, NH 03801 Augusta, ME 04333 Mr. Angle Machiros, Chairman Carol S. Sneider, Esq.
Board of Selectmen Assistant Attorney General 25 High Road Office of the Attorney General Newbury, MA 09150 One Ashburton Place,19th Floor Boston, MA 02108 George Dana Bisbee, Esq.
Allen Lampert Assistant Attorney General Civil Defense Director Office of the Attorney Ceneral Town of Brentwocd 25 Capitol Street 20 Franklin Concord, NH 03301 Exeter, NH 03833 Ellyn R. Weiss, Esci.
William Armstrong Diane Curran, Esq.
Civil Defense Director Harmon 6 Weiss Town oF Exeter 2001 S Street, NW 10 Front Street Suite 430 Exeter, NH 03033 Washington, DC 20009 Robert A. Backus, Esq.
Gary W. Holmes, Esq.
Backus, Meyer & Solomon Holmes & Ellis 116 Lowell Street 117 Winnacunnet Road Manchester, NH 03106 Hampton, NH 03842 Paul McEachern, Esq.
J. P. Nadeau Matthew T. Brock, Esq.
Board of Selectmen Shaines & McEachern to Central Street 25 Maplewood Avenue Rye, NH 03870 P.O. Boy. 360 Portsmouth, NH 03801 Judith H. Mizner, Esq.
Charles P. Graham, Esq.
Silverglate, Gertner, Baker, McKay, Murphy & Graham Fine & Good 100 Main Street 88 Board Street Amesbury, MA 01913 Besten, MA 02110 Sandra Gavutis, Chairman Robert Carrigg, Chairman Board of Selectmen Board of Selectmen RFD #1, Box 1154 Town Office Kensington, NH 03827 Atlantic Avenue North Hampton, NH 03870 William S. Lord Peter J. Matthews, Mayor Board of Selectmen City Hall Town Hall - Friend Street Newburyport, MN 09150 Amesbury, MA 01913
3 Mrs. Anne E. Goodman, Chairman Michael Santesuosso, Chairman Board of Selectmen Board of Selectmen 13-15 Newmarket Road South Hampton, NH 03827 Durham, NH 03824 Hon. Gordon J. Humphrey Ashod N. Amirlan, Esq.
United States Senate Town Counsel for Merrimac 531 Hart Senate Office Bullaing 376 Main Street Washington, DC 20510 Haverhill, MA 08130 Leonard Kopelman Barbara J. saint Andre Kopelman & Paige, P.C.
77 Franklin Street Boston, MA 02110
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Edwin J. Reis Deputydssistant General Counsci 1
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