ML20086L268
| ML20086L268 | |
| Person / Time | |
|---|---|
| Site: | Satsop |
| Issue date: | 02/06/1984 |
| From: | Reynolds N BISHOP, COOK, PURCELL & REYNOLDS, WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8402080057 | |
| Download: ML20086L268 (21) | |
Text
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A DOCKETED UNC
'84 EB -7 A9:16 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION --
BEFORE THE ATOMIC SAFETY -
AND LICENSING BOARD In the Matter of )
)
WASHINGTON PUBLIC POWER )
SUPPLY SYSTEM ) Docke t No. 50-508-OL
)
(WPPSS Nuclear Project No. 3) )
AP PL IC AN T ' S RESPONSE TO "INTERVENOR'S FURTHER SUPPLEMENT TO PETITION FOR LEAVE TO INTERVENE DATED JANUARY 10, 1984" I. Introduction On December 6, l.983, the Licensing Board in the captioned proceeding issued an Order requiring petition'r to make a further showing on the extent to which its participation may reasonably be expected to assist in developing a sound record.1 Petitioner filed a pleading l
l on January 10, 1984, in which it attempted to satisfy this obligation. The I?ashington Public Power Supply System
(" Applicant") hereby responds to pe titioner's January 10, 1984, pleading. For the reasons set forth below, petitioner has failed to establish that it is able to 1 Washington Public Power Supply System (WPPSS Nuclear Project No. 3), Docke t No. 50-508 OL, Order (Requiring Further Showing by Petitioner), December 6, 1983.
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assist in the development of a sound record. Accordingly, petitioner's request for untimely intervention should' be denied and this proceeding dismissed.
II. Legal Principles Based'on Washington Public Power Supply System (WPPSS Nuclear Project No. 3),2 there are three ways petitioner could demonstrate its ability to contribute to the development of a sound record in this proceeding. First, petitioner could identify at least one witness and provide the details of that witness' testimoriy regarding one or more of the contentions admitted to this proceeding. If petitioner decided to do so, it would be obliged to provide sufficient detail respecting such testiiaony to permit the Board to reach a reasoned conclusion as to the likely worth of the testimony.3 Second, petitioner could rely on its participation in other NRC proceedings. In such a case, petitioner would be required to establish a relationship between the issues petitioner litigated in other NRC proceedings and those it seeks to li tiga te here. Alternatively, petitioner could provide sufficient information to enable the Licensing Board to draw an informed inference that based on its 2 ALAB-747, 18 NRC , November 15, 1983, slip opinion ("WNP-3").
3 Id. at 26.
. participation in earlier NRC proceedings, petitioner can and will make a contribution to the record in this procecding.4 Third, petitioner could demonstrate that it has the ability to contribute to the record through the use of effective cross-examination. The majority opinion in l
WNP-3, ALAB-747, supra, did not articulate a standard to j be applied when evaluating such a demonstration.
Nevertheless, the law appeers to be that upon an adequate showing as to its ability to contribute to the record, petitioner could be admitted to this proceeding even if it endeavored to put on its case solely through cross-e xamina tion . 5 III. Analysis of Petitioner's Showing Petitioner attempted to demonstrate its ability to contribute to the record in this proceeding through all three means discussed above. First, it purported to
! identify at least one witness and provide the details of his or her testimony. As part of its showing in this i regard, petitioner identified "certain experts who would or might participate in evidentiary hearings . . . .
"6 l
inis representation on its face is insufficient to allow l
4 Id.
5 Id. at 28-29 (Edles, J., concurring).
6 Intervenor's Answer to Applicant's Appe.al October 1,7, 1983, at 7 (" Petitioner's Answer").
I
the Licensing Board to reach a reasoned conclusion as to the likely worth of their testimony. Petitioner did not state that it intended to call these individuals as witnesses. Nor did petitioner provide the Licensing Board with any details of.their proposed testimony.
Instead, petitioner stated only'that it
" consulted" with Karen Steingart, M.D., and Robert Pollard;7
" discussed" this proceeding with Erick Cheney who " expressed a desire to participate," but pe ti tione r
" refrained from retaining him[;]"8 has through its representatives
" personal and working" relationships with Drs. Rosalie Bertell and John Gofman and with Lon Topaz;9 and
" discussed involvement in this proceeding" with Dr. Ruth Weiner, Dr. E. J. Bell, Norm Buske, MHB Associates, and others.10 These representations, submitted to satisfy the standards set forth by the Appeal Board in WNP-3, ALAB-747, supra,11 fall short of the mark.
! '1 Id. at 7.
8
_I_d.
! 9 _I _d ,
l 10
_Id.
11 See Intervenor's Further Supplement to Petition for Leave to Intervene, Dated January 10, 1984, ("Further Supplement") at 2.
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However, petitioner did identify two individuals it intends to call as witnesses. The first of these individuals is Stuart Sandler. Petitioner states that "Mr. Sandler will review (for the purpose of assisting in the preparation of cross-examination as well as direct t es t'imo ny ) the procedures utilized at UNP-3 for welding and welding inspection and will testify on whether industry standards have been used."12 Petitioner adds that "Mr. Sandler will also review QA/QC and NRC inspection documents and testify on the quality of weldment at the project."13 These representations do not provide a level of detail sufficient to permit the Licensing Board to reach a reasoned decision as to the likely worth of Mr. Sandler's testimony. Petitioner does not state that Mr. Sandler will testify on welding or welding inspection procedures.
Instead, it represents only that in order to assist in the i
preparation of cross-examination as well as direct i testimony, Mr. Sandler will review certain procedures used l
! at WNP-3. It is unclear whether in fact Mr. Sandler will l
testify on welding or welding inspection procedures or whether he will only assist with the development of t
someone else's direct testimony in this rega rd .
{
12 Id,. , emphasis added.
13 Id.
t I _ - - -
Nor does petitioner provide any detail as to the areas 'on which it represents Mr. Sandler will testify.
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Petitioner states simply that Mr. Sandler ".will testify on whether industry standards [concerning welding and welding ,
inspection] have been used." However, petitioner does not identify the specific industry standards as to which Mr.
Sandler will testify. Nor does it provide any information as to the nature of Mr. Sandler's testimony regarding when and under what circumstances these industry standards were not followed, assuming that Mr. Sandler will testify along these lines.
Petitioner also asserts that Mr. Sandler will testify on the quality of weldments in WNP-3. Without more, this representation is meaningless. There are hundreds of thousands of weldments in WNP-3. To evaluate the worth of Mr. Sandler's testimony, petitioner was required to identify at least some of the weldments as to which Mr.
Sandler will testify or set forth at least in general terms the issues involving quality which Mr. Sandler will address. Indeed, a literal reading of petitioner's description of this testimony does not even indicate whether Mr. Sandler believes that the quality of weldments at WNP-3 is substandard.
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'At bottoia, pet'itioner has provided only conclusory statements,as tofth'e overall areas in which Mr. Sandler will testify.14 '6etitioner has not provided any details a s ' to ' ttle na tu r,e of Mr . Sandler's testimony, as required.
Thus, it is ibpossible to reach a reasoned conclusion as to the worth,'i,f any, of Mr. Sandler's testimony.
The other i;ndi~vidual petitioner identified who it intends to call as a witness is Dr. Jack Smith. Again, petitioner fails to provide sufficient information to allow the Licensing _ Board to make a reasoned decision as to the worth of Dr. Smith's testimony. This is because petitioner has not established that Dr. Smith is qualified to provide the expert testimony petitioner claims will be forthcoming. Pe titioner states that Dr. Smith is an "an aquatic toxicologist with graduate degrees from Harvard University."15 It does not state that Dr. Smith holds graduate degrees from Harvard University in aquatic toxicology. This is not a mere semantic issue.
14 Pe titioner stated that Mr. Sandler was unavailable to assist in-the development of proposed contentions in this proceeding (Intervenor's Answer at 7). As a result, it should not be assumed that the allegations in contention twelve are the same issues on which Mr. Sandler will testify. See NRC Staff Response to Intervenor's Further Supplement to Pe tition for Leave to Interve,ne, Dated January 10, 1984, ("NRC Staff Response") at 5. This is particularly the case in light of the recognition by the NRC Staff that petitioner could have described the nature of Mr. Sandler's proposed testimony with more particularity. Ids 15 Further Supplement at 2.
s
-S-Petitioner was required.to place in the record sufficient informa tion rega rding Dr. Smith's qualifications, including his past education, for the Licensing Board to make a reasoned decision as to the likely worth of his testimony.16 Petitioner's statements regarding Dr.
Smith's graduate education are not sufficiently specific for the Licensing Board to make such a decision.
Petitioner also states that "Dr. Smith has broad experience with analysis of discharges into waterways, the control of chemical pollutants and the ecological impacts."17 Yet, petitioner does net identify specifically any of this " broad experience."18 Therefore, in the absence of a clear statement of Dr. Smith's qualifications, it is impossible to assess the worth of l his testimony. The Board must exercise care in triggering l a full operating license hearing on the basis of such vague qualifications.19 Certainly, the petitioner should be held to a high degree of specificity in this instance, where it has been afforded this third opportunity to satisfy NRC requirements for intervention.
16 WNP-3, ALAB-747, supra, Nov. 15, 1983, slip op. at 26.
17 Further Supplement at 2.
18
_I_d.
19 WNP-3, ALAB-747, annra, Nov. 15, 1983, slip op. at 26.
With. regard to the substance of Dr. Smith's testimony, petitioner states that this witness will
" support" contention sixteen. Petitioner then provides a summa ry of- Dr.~ Smi th's " initial review" of the WNP-3 application and various Staff review documents.20-However, the critical representation petitioner was required to make concerned the likely content of Dr.
Smith's testimony. Yet, petitioner never linked Dr.
Smith's initial review to his proposcd testimony or represented that such testimony will be substantially the same as this " initial review."21 Therefore, petitioner failed to provide any meaningful information rega rdi ng the content of Dr. Smith's testimony. In sum, Applicant submits that petitioner has failed to satisfy the manda te of the Appeal Board in WNP-3, ALAB-747, supra, by providing the identity of at least one witness and l providing sufficient details of his or her testimony to allow a reasoned decision as to its worth.
i 20 Id. at 3.
21 Id. The Staf f Response concedes that petitioner did not state specifically that this summary will be Dr. Smith's testimony. Nevertheless, the Staff is willing to treat such summary as a representation of Dr. Smith's testimony. NRC Staf f Response at 8, n. 23. Applicant submits that the Staff's willingness to do so is inconsistent with UNP-3, ALAB-747, supra. It was up to petitioner to set forth details respecting Dr. Smith's testimony. Its failure to do so cannot be overlooked by the apparent willingness of the j NRC Staff to fill in these details.
l l
m
Nexth petitioner seeks to demonstrate.that it is capable of assisting in the development of a sound record in this-proceeding by relying on its participation in o ther NRC proceedings.. As discussed earlier, petitioner's decision to rely upon this participation carried with it the obligation to show either that the issues petitioner proposes to litigate here bear a relationship to those it litigated in other URC proceedings or that an informed inference can be drawn that based on its participation in earlier NRC proceedings, petitioner can and will make a contribution to the record in this proceeding.22 Pe titioner's Answer and Further Supplement both fail to discuss in any way the relationship between the issues it li tiga ted in other NRC proceedings and the issues it seeks to litigate here. In fact, petitioner all but concedes that this relationship does not exist when it states that "the issues which an intervenor is entitled to raise in the course of an operating license amendment or construction permit [ proceeding] (the types of proceedings in which the Coalition had previously been party to ) a re different from those in an application for an operating license."23 Therefore, if petitioner is to be admitted 22 UNP-3, ALAB-747, supra, Nov. 15, 1983, slip op. at 20.
23 Petitioner's Answer at 6. Compare Petitioner's Answer a t 8 and Further Supplement at 2 with WNP-3, ALAB-747, supra, Nov.
15, 1983, slip op. at 18-20.
based on its participation.in other proceedings, petitioner was required to show why a favorable inference could be drawn from its participation in' prior NRC hearings.
Although not specifically delineated in any of petitioner's pleadings, petitioner apparently would have the Licensing Board draw a favorable inference from its past participation in NRC proceedings because "its involvement since 1976 in NRC cases has resulted in an understanding of NRC regulations and nuclear power in general."24 Applicants submit that this statement does not provide any basis for the Licensing Board to draw a favorable inference from petitioner's past participation in NRC proceedings. As deraonstrated by the numerous factual errors identified in Petitioner's Supplemental Petition to Intervene filed on June 15, 1983, petitioner is far from expert in both NRC regulations and nuclear power in general.25 Nor has petitioner made specific 24 Petitioner's Answer at 8; Further Supplement at 2.
25 Applicant recognizes that the Licensing Board is not inclined to examine the merits of petitioner's Supplemental Petition to Intervene. See Applicant's Response In Opposition to Supplement to Request for Hearing and Petition for Leave to Intervene, July 6, 1983, at 11-13 and Washington Public Power Supply System (WPPSS, Nuclear Project No. 3), Docket No. 50-508, Memorandun and Order (Ruling on Proposed Contentions),
September 27, 1983, slip op. at 2. Nevertheless, petitioner has claimed that it has expertise in NRC regulations and nuclear power in general. Applicant believes that an examination of the accuracy and validity of petitioner's (footnote continued)
representations in support of the scope of ito alleged expertise. Lastly, if petitioner wanted to take credit for "research conducted into various aspects of nuclear powe r ope ra tion, "26 it should have identified those areas with specificity and summarized the product of its labor.
Finally, concluso ry sta tements regarding the individual knowledge of petitioner's director and staff intervenor do
'not entitle petitioner to a favorable inference that given its past participation in NRC proceedings it can contribute to the development of a sound record in this proceeding.27 Petitioner also would have the Licensing Board draw a favorable inference based on petitioner's previous participation in NRC and other state proceedings because such participation purportedly shows that petitioner is both willing and able to commit resources necessary to participate meaningfully in thic proceeding. The concurring opinion in WNP-3, ALAB-747, supra, suggests t ha t there may be cases where a petitioner properly asks a (footnote continued from previous page) pleadings will belie any claim that petitioner is entitled to a grant of la te intervention by virtue of its general expertise.
26 Petitioner's Answer at 8.
27 Compa re in this rega rd the record here with the record before the Appeal Board in Long Island Lighting Co. (Shoreham Nuclear Power Station, Unit 1), ALAB-743, 18 NRC ,
September 29, 1983, slip op. at 25. See also note 30, infra.
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licensing board "to consider its. participation on other issues ir. other cases as an illustration of its ability to ma rshal its resources, recruit any expertise it may need, and participate ef fectively on matters of interest to it."28 However, that opinion also suggests that a petitioner requesting a licensing board to consider past participation on this basis should " possess generalized knowledge on scientific and environmental issues."29 However, as noted above, there is nothing in the record here to support a finding that petitioner possesses such generalized knowledge.30 Additionally, petitioner's involvement in three ra te tariff proceedings and its status as a plaintiff in two lawsuits (the subjects of which were not disclosed) has 28 WNP-3, A!.AB-747, supra, Nov. 15, 1983, slip op. at 30 (Edles, J. concurring).
29
_I d_ .
30 In Shoreham, ALAB-743, supra, Judge Edles would have admitted an untimely petitioner in part because members of petitioner l enrked professionally in radiological emergency planning; l served as members of federal emergency response teams; were, as residents, familiar with the locality surrounding the l plant; and sought to litigate an issue (emergency planning) l where such expertise and experience would clearly be of j value. Id. at 33-38 (Edles, J. concurring). Accordingly,
[
Judge Edles apparently had in mind a petitioner-organization which could draw on its membership for the expertise needed to litigate issues of interest to it when in his concurring opinion in WNP-3, ALAB-747, supra, he referred to a
! petitioner " possessing generalized knowledge on scientific l and environmental issues." There is nothing in the record to l suggest that petitioner is an organization with such resources. See notes 24 through 27, supra, and accompanying text.
l l
little' relationship to the. ability of petitioner to participate meaningfully in an NRC licensing proceeding, where entirely different complex issues of a technical nature are, litigated. .Indeed, WNP-3, ALAB-747, supra, speaks in terms of past participation in NRC proceedings and not past participation in state rate proceedings or suits brought in state court.31 Thus, there is no basis for drawing an inference that as a result of petitioner's activities in other proceedings, it will be able to contribute meaningfully to the development of a sound record in this proceeding.
The last way petitioner sought to demonstrate that it could contribute to the development of a sound record in this proceeding was to show that through the use of cross-examination and other trial procedures it can make an effective case. The majority opinion in WNP-3, ALAB-l 747, supra, does not address this practice. However, the I
concurring opinion states, as follows:
i l Although I suspect it will be easier l
to satisfy a licensing board where a late intervenor plans to put forth an affirmative case (the Coalition, for example, has already indicated its
! intention to present at least one j witness), we do not rule out the possibility that some future late intervenor may be able to prevail on factor three by reliance on 1
31 990 1, ALAB-747, ="pra, Nf. 15, 1983, slip op. at 26.
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cross-examination, either alone or in combination with an affirmative presentation.32 By raising the prospect that petitioner -may " base its case in part on cross-examination and other trial procedures,"33 petitioner apparently is attempting to fall within the situation envisioned in the concurring opinion.
Petitioner has failed to make the showing contemplated in the concurring opinion. First of all, petitioner was req uired to identify the areas in which it intended to cross-examine witnesses and use other trial procedures with enough specificity to permit the Licensing Board to make a reasoned decision as to the worth of such participation. Petitioner should be required to do so because the showing a petitioner is obliged to make when it intends to develop its case through cross-examination shculd be just as detailed as the showing a petitioner is required to make when it intenos to put on an affirmative case. If such were not the case, a petitioner could circumvent its obligation to explain its intended participation in sufficient detail, such that licensing boards could make a reasoned decision as to its worth, by simply asserting that in lieu of an affirmative case it intended to put on a case through cross-examination.
32 Id. at 29 (Edles, J. concurring).
33 Further Supplement at 4.
Surely, the Appeal Board in WNP-3, ALAH-747, supra,_would not sanction such an illogical approach. Accordingly, because petitioner failed to provide any information as to the scope of its case to be based on cross-examination and other trial procedures, there is no basis to conclude that petitioner is able through such means to raise at least one substantial safety or environmental issue and to make a worthwhile contribution to the resolution of such issue.
In addition to providing at least some information about its case, petitioner was obliged to demons trate that it has both the knowledge and the skill to make a case through cross-examination 3 4 and other trial procedures.
Effective cross-examination is a skill'which is developed over a long period of time. It requires a working knowledge of both trial tactics and the substantive areas in dispute. Although petitioner is permitted to represent itself in this proceeding,35 no assumption can be drawn as to the effectiveness of petitioner's skills in the use of
, cross-examination or other trial procedures by virtue of i
such representation. In fact, there has been one recent I
l 34 Presumably this showing (which is not required when a
- petitioner will put on an affirmative case) is what Judge l Edles had in mind when he suggested that it would be harder to make a showing regarding ability to contribute to the record based on cross-examination above. UNP-3, ALAB-747, supra, Nov. 15, 1983, slip op. at 29 (Edles, J. concurring).
35 10 C.F.R. $ 2.713(b) l l
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case where a licensing board expreseed concern about the inability of in terve nors to use cross-examination effectively.36 At bottom, petitioner has not provided the Licensing Board with any basis to conclude that it is skilled in the art of cross-examination or that it is capable of using "other trial procedures"37 in lieu of or in addition to presenting an affirmative case. Therefore, the Licensing Board should find that petitioner has not demonstrated that it is capable of contributing to the development of a sound record in this proceeding through cross-examination or the use of other
- rial procedures.
III. Conclusion Applicant does not mean to suggest that petitioner was required to put on a detailed af firma tive case to demonstrate its ability to contribute to the development of the record in this proceeding. All petitioner was required to do was provide an adequate basis for the 36 Consumers Powe r Co. (Midland Plant, Units 1 and 2), LBP 28, 17 NRC 987, 990-91 (1983) ("But we can also agree with the Applicant and Staff that some of the cross-examination has been duplicative, or at least poorly focused. To some extent, this situa tion may reflect the realities of intervenors who are under funded"). See also SECY-82-447, Draf t Report of the Regulatory Reform Task Force, Nov. 3, 1982, at Chapter I, page 7 ("value of cross-examination is often diminished by unskilled questioning").
37 Further Supplement at 4.
D' Licensing. Board to reach a reasoned conclusion as to the worth of petitioner's contribution to the record in this -
proceeding.
One way petitioner could have done so was to identify at least one witness it intends to call, setting forth the qualifications'of that witness and providing enouch details of his or her testimony to permit an assessment of its worth. The closest petitioner came to satisfying this obligation was its inadequate offer of conclusory statements as to the testimony of two individuals it intends to call. Alternatively, petitioner could have shown that its past participation in NRC proceedings warrants intervention here. Again, petitioner provided no grounds to justify a grant of untimely Intervention on this basis. Finally, petitioner could have shown that through cross-examination or other trial procedures it is able to contribute to the record. That showing as well was not made . 38 In short, petitioner was given clear instructions as '
to the showing required to justify its late intervention.
Petitioner failed to comply with these instructions and as 38 The Licensing Board should not provide petitioner with yet another opportunity to demonstrate why its untimely petition to intervene should be granted. Petitioner has been given three opportunities to establish that it should be granted leave to intervene and in all three cases it has failed to i make an adequate showing. Applicant believes that it would be fundamentally inconsistent with the Rules of Practice to l give petitioner yet another opportunity to do so.
t
r-a result did not provide the Licensing Board with sufficient ba sis to conclude that it is able to contribute to the development of a record in this proceeding.
Accordingly, there is "no~ reason to allow [its]
inexcusably belated intervention petition to trigger a haaring"30 in this proceeding. Petitioner should be denied untimely intervention and this hearing dismissed.
Respec fu y submitted,
/
/
f Io Nicholgs S.}Reynolds Sanfor;d L. '
lartman BISHOE(,1 LTBjRMAN, COOK, PURCELL(W REYNOLDS 1200 Seventeenth Street, N.W.
Washington, D. C. 20036 Counsel for Applicant February 6, 1984 39 UNP-3, ALAB-747, suora, Nov. 15, 1983, slip op. at 25.
. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the_ Matter.of. )
)
WASHINGTON PUBLIC POWER ) Docket No. 50-508-OL SUPPLY SYSTEM )
)
(WPPSS Nuclear Project No. 3) )
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing " Applicant's Response to 'Intervenor's Further Supplement to Petition for Leave to Intervene Dated January 10, 1984'" in the captioned matter were served upon the following persons by deposit in the United States ma il , first class, postage prepaid this 6th day of February, 1984:
Morton Margulies, Esq. Chairman, Atomic Safety and Chairman, Atomic Sa fety and Licensing Board Panel Licensing Board U. S. Nuclear Regula tory U. S. Nuclea r Regulatory Commission Commission Washington, D. C. 20555 Washington, D. C. 20555 Adm. Judge Frederick J. Shon Chairman, Atomic Safety and Atomic Safety and Licensing Licensing Appeal Board Board U. S. Nuclear Regulatory U. S. Nuclear Regulatory Commission Commission Washington, D. C. 20555 Washington, D. C. 20555 Adm. Judge Richard F. Foster Stuart A. Treby, Esq.
Atomic Safety and Licensing Office of the Executive Board Legal Director P. O. Box 4264 U. S. Nuclear Regulatory
- Sunriver, Oregon 97702 Commission I
Washington, D. C. 20555 r
I L
e Mr. Scott W. Stucky Mr. Nicholas D. Lewis Docke ting & Service Branch EGSEC Chairman-U.S. Nuclear Regulatory Mail Stop: PY-ll Commission Olympia, Washington 98504 Washington, D.C. 20555 Mr. Gerald C. Sorensen Mr. Kevin M. Ryan Washington Public Power Attorney General's Office Supply System Mail Stop: AQ-04 3000 George Washington Way
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Temple of Justice Richland, Washington 99352 Olympia, Washington 98504 Mr. Douglas W. Coleman Mr. Eugene Rosolie Licencing Project Manager Joalition for Safe Power Hashington Public Power Suite 527 Supply System 408 South West 2nd P. O. Box 1223 Portland, Oregon 97204 Elma, Washington 98541 Ms. Nina Bell Nuclear Information and Resource Service 1346 Connecticut Avenue. N.W.
Washington, D. C. 20036
&%h* \
&5anford L. Hartman
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