ML20211H273
| ML20211H273 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 09/29/1997 |
| From: | Blake E, Silberg J AFFILIATION NOT ASSIGNED, SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#497-18532 97-732-02-ISFSI, 97-732-2-ISFSI, ISFSI, NUDOCS 9710060313 | |
| Download: ML20211H273 (16) | |
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o' UNITED STATES OF AMERICA 4.
NUCLEAR REGULATORY COMMISSION oce g g
.4 sK SEP 29 997 Before the Atomic Safety and Licensine Boardt n
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In the Matter of
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PRIVATE FUEL STORAGE L.L C.
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Docket No. 72 22 N'
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(Private Fuel Storage Facility)
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ASLBP No. 97 732 02 ISFSI APPLICANT'S ANSWER TO PETITION TO INTERVENE OF THE SKULL VALLEY BAND OF GOSilDTE INDIANS 1.
INTRODUCTION Applicant Private Fuel Storage L.L.C. ("PFS") submits this answer supporting the Petition to Intervene (" Skull Valley Band Pet.") filed on September 12,1997, by the Skull Valley Band of Goshute Indians ("the Band" or "the Petitioner"). The Petitioner requests to intervene in support of the license application filed by NS for the construction and operation of the Private Fuel Storage Facility ("the Facility"). sitich is to be located with the support and consent of the Petitioner on its reservation in Utah. PFS supports the Petitioner's participation in this proceeding.
The Petitioner has demonstrand standing pursuant to Ib C.F.R. Q 2.714. In addition, the Petitioner also quelifies to participate as an interested governmental entity pursuant to 10 C.F.R. Q 2.715(c). The Petitioner is a sovereign, Federally recognized tribal government having a government to government relationship with the executive departments and agencies of the United States Goversnent. As the host jurisdiction an(
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poperty owner of the site for the pro ed Facility, the Petitioner has a unique interest in.
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this proceeding.
lic RACKGROUND pOn lun 20,19s7. PFS submitted a license application to the NRC to construct s
aad dpcMyan indgendent Spent Fuel Storage Installation ("ISFSI") pursuant to 10 l
~p, C.F.R. Part 72. The Petitioner la the host jurisdiction and property owner for the site of
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l the proposed Facihty, Em Skull Valley Band Pet. at 2,3. The pr$ posed Facility will be
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located ent!nly within the property boundaries of the Petitioner's reaeivation: Sn PFS
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. Facility Safety Analysis Report at 1,ld,1.12, Figure L1-1 ("PFSF S AR").
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There is appropriate authoilzation to request partNiht. tion of the Band as an i_
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'[/a latervenor pursuant to 10 C.F.R. i 2.7[4. or alternatively, as an interested governmental
.L 3 j endty pursuant 10 C.F.R. G 2.715(c). The Petition to intervene is signed by Leon D.
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Beai g Mary i Allen,'and Rex A. Allen, ti e Executive Corrsnittee of the Skull Valley Band h,t.
g j)f Goshute Indians, which is the governing body rf theitli. ; Skull Valley Band Pet at 2,
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J4,JJart$ermore, Leon D. Bear, the Chairman of the Skull Wiley Band has been 9
, i.at.thorized by resolution of the General Council, which is comprised of the eligible voting -
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memtxirship of the Band, to take any actions iPxessary in connectioa with the p
e dMI$hnt of the independent spent fuel stortge i$ allation proposed by Private Fuel 4
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fb The Petitioner is a Federally recognized Indian Tribe that is sovereign under Federal Law. Skull Valley Band Pet. at 1; see Bureau ofIndian Affairs, " Indian Entities Recognized and litigible to Receive Services from the U.S. Bureau ofIndian Affairs",61 Fed. Reg 58,211, 58,212, 58,214 (1996). The Petitioner's reservation was established by Executive Orders in 1917 and 1918 (IV Kappler 1048, Sept. 7,1917 and Feb. 15,1918).
As a soverelgn, Federally recognized tribal government, the Petitioner operates on a government to government relationship with the United States Government and its executive departments and agencies pursuant to the Constitution of the United States, treaties, statutes, and couit decisions. Ses Executive hiemorandum of April 29,1994,59 Fed. Reg. 22,951 (1994) (hiemorandum from President Clinton to liends of Executive Departments and Agencies on " Government to Government Relations with Native American Tribal Governments") (" Executive hiemorandum") (copies of both the Federal Register notice and the original memorandum are included in Attachment A).
The Petitioner entered into an agreement with PFS to lease cenain lands within its reservation on which the Facility is to be sited. Skull Valley Band Pet. at 2, The lease between the Petitioner and PFS was approved by the Bureau ofindian Affairs on hiay 23, 1997.' The Pet ltioner "is an interested government with sovereignty over the lands on which the project is to be sited." Skull Valley Band Pet. at 3. The Petitioner's reservation has approximately 30 tribal members, most of whom reside in the reservation's tribal Buteau of Indian Affairs' approval is conditioned on completion of the NRC's National Etnisonmental Policy Act review and issuance of a license to operate the Facility.
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l village located about 3.5 miles east southeast of the proposed Facility. PFSF SAR at 1.1 l
2.
In addition to its obvious property and proximity interest, the Petitioner also stands to receive considerable benefits from the construction and operation of the Facility. The direct benefits are "a steady revenue stream for the Tribal Government and Band members, a diverse set of meaningfuljobs for tribal members and training / development opponunities for other Band members." PFS Facility Environmental Repon at 7.2 2
("PFSF ER").- The indirect benefits include " increased traffic and business at their convenience store during construction and operation, and an increased profile for the Band in the Utah business economy, po:entially bringing new economic development initiatives to the Band." PFSF ER at 7.2 3. Other indirect benefits include upgrades to transportation infrastmeture on the reservation hl 111.
THE PETITIONER HAS DEMONSTRATED STANDING
. UNDER NRC CASE LAW AND 10 C.F.R. 6 2.714(a)
. Under the Atomic Energy Act and NRC regulations, a petitioner to intervene must
- demonstrate a sufficient interest that might be affected by the outcome of the proceeding
. (i.e., demonstrate standing). San 42 U.S.C. Q 2239(a); 10 C.F.R. Q 2.714(a). The standing test seeks to ensure that permission to intervene is granted to participants who -
have a "real stake" in the outcome of the proceeding. Houston Lighting and Power Co.
(South Texas Project, Units I and 2), L8P-79 10,9 N.R.C. 439,447-48 (1979) ("'real stake'... must mean ' genuine,' actual' or ' direct stake'"), siting Sierra Club v. Morton. 405 4
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U.S. 727, 740 (1972) (standing test attempts to ensure review is sought by "those who l
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' have a direct stake in the outcome").
l NRC case law establishes that a petitioner supporting a license application can j<
demonstrate standing to intervene under 10 C.F.R. 6 2.714. Nuclear Ennineerinn Co..
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Int (Sheffield, Illinois Low Level Radioactive Waste Disposal Site), ALAB 473,7 N.R.C. 737, 743 (1978).' The Licensing Board and the Commission have cited the j
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Sheffield doctrine approvingly in a recent enforcement order proceeding. Seouovah FuelsL
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i Cofg (Gore, Oklahoma Site) LBP 94 5,39 N.R.C. 54,65 66, affirmed, CLI 94-12,40 N.R.C. 64, 68 (1994). The Petitioner supports granting of the PFS license application in 1
this proceeding. Skull Valley Band Pet. at 1,3J The Petitioner requests to intervene l
specifically "to protect the Band's legal interests by making the Band a full and equal party 1[to the NRC) proceedings." Skull Valley Band Pet. at 3. Standing to intervene does not
- hinge on the litigating posture the petitioner would assume if allowed to participate.
1 Sheffield, ALAB,473. auta,7 N.R.C. at 743, siting Association of Data Proceaging Service Ornanintions v. Camn,397 U.S.150,153 (1970). The Appeals Board in 1
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Sheffteld established that intervention did not depend on whether the petitioner supported or opposed the license application, but U
[r]ather, the test is whether a cognizable interest of the petitioner might be adversely affected if the proceeding has one outcome rather than another And, to repeat, no such :
interest is to be presumed. There must be a concrete
' demonstration that harm to the petitioner (or those it represents) will or could flow from a result unfavorable to it
- whatever that result might be.'
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' " The Commission has granted intervention to petitioners supporting a license application in several caws, Smut Lonn 1 8-81 lahtian Co. (Shoreham Nuclear Power Station) LBP.73 13,6 A.E.C,271,
- 1 274 (1973)(petitioner Suffolk Scientists for Cleaner Power and Safer Emironment granted intenention l
in support oflicense application); Consumers Power Co (Midland Plant. Units I and 2), LBP.72 34 ' $
3 J A E.C. 214. 215 (1972) (petitioners Dow Chemical Company and Midland Nuclear Power Committee 4
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' granted intervention in wpport of license application).
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1, Sheffield, ALAB-473, muna,7 N.R.C. at 743.
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As a petitioner supporting the license application, the Band's standing stems from -
the possibility for the Board to denp the license application or impose license conditions.
Ses 11 The Petitioner stands to suffer injury in fact that is concrete, actual, and imminent -
if the Facility is not approved. See Lubn v. Defenders of Wildlif, 504 U.S.' 555, 560
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(1992). The Petitioner would be substantially injured by an adverse decision in this I
proceeding which would deny it the considerable benefits and other interests that would flow to the Band from construction and operation of the proposed Facility. San PFSF ER i
at 7.2 2,7.2 3. ' As the host jurisdiction and property owner for the site of the prog Facility, the Petitioner has a unique Ir terest that will be directly affected by the outcome of '
the proceeding. As discussed above, the Petitioner owns the property the Facility will be ~
built on, has tribal members residing near the Facility, has its tribal village about 3.5 miles t'
east southeast of the Facility, and stands to receive considerable direct and indirect 3
benefits from the construction and operation of the Facility.
j The Petitioner's interest in receiving these benefits is directly linked to the outcome
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- of this proceeding. The Petitioner demonstrates the importance of the outcome of the 4-proceeding to its interest, in stating i
(gliven the nature of this facility and the materials which are proposed for storage, and the Band's property interests in p
the leased land and other reservation lands, the NRC.
determinations of whether to issue a license, and if so, on -
what terms, will have a substantial health, safety, cultural, and financial impact on the Skull Valley Goshute Reservation.
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' Skull Valley Band Pet. at 2.
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The Petitioner has complied with the requirement to provide a statement of aspects on which it wishes to intervene pursuant to 10 C.F.R.- Q 2,714.- The Petitioner has stated 4
that it wishes to intervene in "all aspects... affecting the health, safety, or cultural or i
financial resources of the Band, and any others which are material to the outcome or the -
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financial viability of the Applicant's proposal." Skull Valley Band Pet. at 3.
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IV.
ALTERNATIVELY, PETITIONER SHOULD BE GRANTED PARTICIPATION AS AN INTERESTED GOVERNMENTAL i
ENTITY Pl3RSUANT TO 10 C.F.R. 6 2.715 :
i Alternatively, as a sovereign, Federally recognized Indian Tribe that is the host -
jurisdiction of the proposed Facility, the Petitioner should be pemdtted to participate in any hearing on this proceeding as an interested governmental entity pursuant to' 10 C.F.R.
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12.715(c). The Board may grant an " interested" governmental entity such as a " State, 1
county, municipality, and/or agencies thereof," the opportunity to participate in a hearing.
10 C,F.R. l 2.715(c). When i 2.715(c) was amended to broaden its coverage from "an 3
interested State" to include " county, municipality and/or agencies thereof," the
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. Commission stated that its intent was to_ extend the cooperation provided in that regulation "to other units of government which also have an interest in the licensing
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proceeding." 43 Fed. Reg. 17,798, 17,800 (1978).
7 The Petitioner meets both the " governmental entity" and " interest" requirements to i
participate in a hearing pursuant to 10 C.F.R. i 2.715(c).' The Petitioner is a sovereign governmental entity recognized by the Federal govemment. Skull Valley Band Pet. at 1 -
r (stating that the Petitioner is "a federally recognized Indian Tribe and sovereign under 7
O Federal Law"). The Petitioner " fully supports this project and is interested in the success of the license application." Skull Valley Band Pet. at 3. As the host jurisdiction for the proposed Facility, the Petitioner has a demonstrated and unique interest in this proceeding i
(e g., the Petitioner owns the property the Facility will be built on, the Facility will be near Tribal members' residences, and the Petitioner will receive employment, revenue, and other direct or indirect benefits from PFS). The Petitioner "is an interested government with sovereienty over the lands on which the project will be sited," 11(emphasis added),
and should be granted the opportunity to participate in any hearing as an interested governmental entity pursuant to 10 C.F.R. Q 2.715(c).
In addition, the United States Government has directed executive departments and agencies to take aflirmative steps to assure that tribal governments are consulted on activities that afTect the trust property and/or governmental rights of the tribe. Sss 59 Fed. Reg. at 22,951 (Executive Memorandum, Subpart (c)). The government to-government relationship between the United States Government and Federally recognized Indian Tribes, recognized in the Executive Memorandum, means that the Skull Valley Band of Goshute Indians should be provided the same rights to participate in this proceeding as 10 C.F.R. Q 2.715(c) affords to "an interested State, county, municipality and/or agencies thereof." Because this proceeding is specifically about licensing a facility within the legal property boundaries of the Petitioner's reservation, this proceeding directly affects its " trust property and/or governmental rights." Sss 59 Fed. Reg. at 22,951 (Executive Memorandum, Subpart (d)). As the juiisdiction on whose lands the proposed 8
o Facility is to be built and operated, the Petitioner must be given the same right to panicipate in any hearing on this p.oceeding as a State, county, municipality or agency thereof.
V.
CONCLUSION For the reasons stated above, PFS supports the Skull Valley Band of Goshute Indian's participation in any hearings in this proceeding. The Petitioner has a unique role in this proceeding and has complied with the requirements to intervene pursuant to 10 C.F.R. Q 2.714. Alternatively, the Petitioner qualifies to panicipate in any hearings on this proceeding as an interested governmental entity pursuant to 10 C.F.R. 5 2.715(c).
Accordingly, the Petitioner's participation in any hearings on this proceeding should be granted.
Respectfully submitted, C6C. 6VJA Jay E. Siiberg F
Ernest L. Blake, Jr, SHAW, PITTMAN, POTTS &
TROWBRIDGE 2300 N Street, N.W.
Washington, D.C. 20037 (202) 663 8000 Counsel for Private Fuel Storage L.L.C.
Dated: September 29,1997 i
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a September 29,1997 5
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UNITED STATES OF AMERICA
- b NUCLEAR REGULATORY COMMISSION 2 DOCKETro 3
Before the Atomic Safety and Licensine Board J
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PRIVATE FUEL STORAGE L.L.C.
Docket No. 72-22 11 -
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(Private Fuel Storage Facility)
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ASLBP No.97-732 02 ISFSI CERTIFICATE OF SERVICE I hereby certify that copies of the " Applicant's Answer to the Petition to Intervene of the
_ Skull Valley Band of Goshute Indians," dated September 29,1997 were served on the persons listed below (unless c,thanvise noted) by facsimile with conforming copies by U.S. mail, first class, postage prepaid, this 29th day of September,1997.
G. Paul Bollwerk III, Esq., Chairman Dr. Jerry R. Kline Administrative Judge Administrative Judge Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001 Thomas D. Murphy
- Adjudicatory File Administrative Judge Atom.ic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001
l Catherine L. Marco, Esq.
- Charles J. liaughney Sherwin E. Turk, Esq, Acting Director, Spent Fuel Project Office Office of the General Counsel Office of Nuclear Material Safety and Mail Stop O.15 BI8 Safeguards U.S. Nuclear Regulaton Commission U.S. Nuclear Regulatory Conunission Washington, D.C. 20555 Washington, D.C. 20555 Danny Quintana, Esq.
Office of the Secretary Danny Quintana & Associates, P.C.
U.S. Nuclear Regulatory Commission 50 West Broadway, Fourth Floor Washington, D.C. 20555 0001 Salt Lake City, Utah 84101 Attention: Rulemakings and Adjudications Staff (Original and two copies)
' By U.S. mail only frust.dMA
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Ernest L. Blake, Jr.
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4 Attachment A l
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22951 reas*-
Presidenti:1 DocumCnts l
va. n s u Wedneedef. May 4. teed i
j Tide S Memorandum et Apse as, sees l
he Frasident Gevormansat Relations With Native Amnerican Goversuments l
i Mameernadens Ier the Heads of Enocudes r:;: ^ -te and Aguacies j
The United States Government has a unique legal relationship with Nettve Asnerican trhi gevaasseats et set forth hi b Constitullos of M United States, treetles, statutes, and cowt decisions. As enscuuve ts and agencies undertake ersivities afiseting Nettve American tribal ts or trust renowess, such ecovities should be tanplemented La a know le, wa.
Md of tribal esverstgaty. Today, as part an historic j
sluye naammer. lialag petaciples ht execuuve spi::ts and agencies.
essettag, I en out l
lacaudlag evey caempensat beseu and ethos, are to follow La htr inter.
essions with Nettve Aseerless tribal goverusents. The popose of these j
petaciples is to clarify our u;rNity to ensure that the Federal Govern.
Nedve Amartens tribes fa.-;" reletbaship with federally i
withis a goverm anet t naare a more ellective day 4oday working, thuly resecting respost Aer the rights of sel* r ~---" due the soverely tribal peerasments.
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la order to easme that the of esverenga tribal gevenumente am fuuy
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'shallg pided by the followies:
f (a)lIhe headof each annastive department and ogsary shallbe responsible >
ler easming that ths-er opentes withis a pvernment.
to govermosat saint with secogained tribalr : n"-
(b) Each sessutivet -
and shall eensult, to the smotest 4
"P and to5e essent leu,with tribal gevanawats extent p: king actness that. aged y recogalass tribal ats.
nad candid so that Itat==ted prior to ta All euch osasaltetness me is,ho l
pestles sney evaluate ter theemselves potential Lapact of relevant propes.
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(c) Each enscudge if ' and assacy shall ameses the tempact of Federal Goversmaat pleas, preyens, and medvlues on tribal trust resomcas and esame that pvernseest riqbts and concerns are consid.
l ered during the developement of such pleas, ' roorts, pragmas, ami activities.
p (d) Each easicutive department and agency shall take app.
ste to menove any procedural impediments to working directly offectiv with trhl pvernments on activities ht a5ect the trust property an l
or govwaansatal rights of b tribes.
(e) Each r scutive departement and esency shall work cooperetively with o h r Fedw.de to and assoc 6es to enlist their interest and support la coopes to e
, where oppropriate, to accomplish the goals of this mwnorandam.
(f) Each executive department and agency shall apply b requirements i
i of Executive Orders Nos.18476 (" Enhancing the latergovernmental Partner.
and 12864 (" Regulatory Planning and Review") to deelse solutions i
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ship") lor Federal programs, la appropriate circumstances, to address sp and tal or unique needs of tribal commualties.
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d Federal Raghest / Vol 59. MS 45 / Wednesday, May 4.1994 / Pr%tlal Documan3 22962 N bead of each execudge departeneet and agency shall ensure that the depanment or syncy's bureaus and components are fully aware of this memorandum, thmugh publication or other means, and that they are in compilance with its requirements.
This memorandum is intended only to improve the internal management of the exaciative branch and is not intended to, and does not, crate any right to administrative or judicial review, or an or trust responalbility, substantive or procedural,y other right or bene enforceable by a puty against the United Stater, its a employees,or any other person. gencies or instrumentalities, its omco N Director of the Offnce of Management and Budget is authorized and directed to pubitsh this memorandum in the rederal Reg 6 ster.
DIE WHITE HOUSE, j
Washirtgtort, Apr0 39, l>N.
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Fw 6 3-es. s se pad seine de stie.+i u Beis.rtel asem Per the Proe6deso rumean to Amartma ladlae and Nedre Alaska tibel needes, e A wevW, Casseeselse of munidssaint h (vol. so, > 1el I
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t THE WHITE HOUSE WASHINGTON h
April 29, 1994 l
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MEMORANDUM FOR THE HEADS OF EXECUTIVE DEPARTMDrTS AND AGENCIES i
SUBJECT:
Government to-Government Relations with j
Native American Tribal Governments i
j The United states Government has a unique legal relationship j
with Native American tribal governments as set forth in the Constitution of the United States, treaties, statutes, i
and court decisions.
As executive departments and agencies undertake activities affecting Native American tribal rights j
or trust resources, such activities should be implemented in a j
knowled l
Today, geable, sensitive manner respectful of tribal sovereignty.
as part of an historic meeting, I an outlining principles that executive departments and agencies, including every com-ponent bureau and office, are to follow in their interactions l
with Native American tribal governments.
The purpose of these principles is to clarify our respew ibility to ensure that the Federal Government operates within a governmaat-to-government 1
relationship with federally recognized Native American tribes.
I as strongly committed to building a more effective day-to day working relationship reflecting respect for the rights of ' elf-government due the sovereign tribal governments.
4 In order to ensure that the rights of sovereign tribal 1
governments are fully respected, executive branch activities shall be guided by the following:
4 (a)
The head of each executive department and agency shall be responsible for ensuring that the department or agency l
operates within a government-to-government relationship with j
federally recognized tribal governmants.
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(b)
Each axacutive department and agency shall consult, F
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- r=i t t a d by law, with tribal governments prior to taking actions that affect federally recognized tribal governments.
All such consultationa are to be open and candid so that all interested parties may evaluate for themselves the potential impact of relevant proposals.
(c)
Each executive department and agancy shall assess the impact of Federal Governacnt plans, projects, programs, and activities on tribal trust resources and assure that tribal government rights and concerns are considered during the development of such plans, projects, programs, and actiVI, ties.
(d)
Each executive department,and agency shall take appropriate steps to remove any procedural impediments to working directly and effectively with tribal governments on activities that affact tha trust property and/or governmental rights of the l
tribes.
(e)
Each executive department and agency shall work cooperatively with other Federal departments and agencies to enlist their interest and support in cooperative efforts, where appropriate, to accomplish the goals of this memorandum.
(f)
Each executive department and agency shall apply the requirements of Erecutive orders Nos. 12875
(" Enhancing the Intergovernmental Partnership") and 12866 (" Regulatory Plannin and Review") to design solutions and tailor Federal programs, gin appropriate circumstances, to address specific or unique needs of tribal communities.
The head of each executive department and agency shall ensure that the department or agency's bureaus and components are fully aware of this memorandum, through publication or other meaqs, and that they are in compliance with its requirements.
This memorandum is intended only to improve the.taternal management of the executive branch and is not intended to, and does not, create any right to administrative or judicial, review, or any other right or benefit or trust responsibility, substantive or procedural, enforceable by a party against the United States, its agencies or instrumentalities, its officers or empicyees, or any other person.
The Director of the office of Management and Budget is authorized and directed to publish this memorandum in the Federal Resister.
A ) u n m [a. t S w w Y
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