IR 05000482/1983028
| ML20206H084 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek, 05000000 |
| Issue date: | 10/26/1983 |
| From: | Johnson W NRC |
| To: | Westerman T NRC |
| Shared Package | |
| ML20206G744 | List:
|
| References | |
| FOIA-85-594 NUDOCS 8606250515 | |
| Download: ML20206H084 (5) | |
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SERVED JAN 241984 In the Matter of
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) ASLBP Docket No. 81-453-03 OL KANSAS GAS & ELECTRIC CO., ET AL. )
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(Wolf Creek Generating Station, )
Unit No. 1) )
PETITION FOR LEAVE TO INTERVENE AND REQUEST FOR HEARING COMES NOW the petitioner, Nuclear Awareness Network, Inc.,
by and through its Director, Mary M. Stephens, and petitions for leave to intervene in the captioned matter pursuant to 10 CFR
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2.71 Petitioner's request, untimely made, is based on good cause and upon such circumstances as to justify the granting of
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said petition and for the setting of special evidentiary hearings herei In support of its request petitioner would show the following: Nuclear Awareness Network, Inc. is a duly authorized, :
not for profit, Kansas corporation established in 1983 for the
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express purpose of providing education, res'earch, lobbying, and testimony on issues relating to nuclear power, waste, and related 846I240067*B40119 PDR ADOCK 05000482
matter o PDR Tom and Joyce Young, Gridley, Kansas are members of Nuclear-Awareness Network and live within twenty miles of the Wolf Creek i
' Generating Station construction sit Other members of the B-OS Nuclear Awareness Network live, work, and recreate within _@h&R ,.Gu
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-2-the geographic areas surrounding Wolf Creek and have interests which may be affected by the outcome of the proceedin Mary M. Stephens, a member and director of the Nuclear Awareness Network, is authorized ,to represent its members in this proceedin .
The interests of petitioner and its members may be affected by the proposed operation and on-site storage of spent nuclear fuel at Wolf Cree The operation of a nuclear power .
plant at the site may endanger the health and safety of peti-
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tioner's members due to several factors includi'n'g both the ~
routine and accidental release of ionizing radiation from the plan Additionally, th'e safety and well be.ing o'f petitioner's members may be adversely affected by the possibility of a nuclear accident which.may damage or destroy their livelihood, homes, and propert Recreation may be jeopardized by the project's impact upon the water and aqu:.' ic life adjacent to the plant.- An order _. _
grant'ing applicants an operating' license may subject petitioner's
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members to unnecessary risks to health, life, and property in contravention of the protections provided by the Atomic Energy Act and the National Environmental Policy Ac Worth v. Seldin 422 US 490, (1975); Sierra Club v. Morton , 405 US 727,
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(1972).
Petitioner's members include doctors, physicists, public officials, a college dean, construction workers, a,ttorneys, and
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-3-farmer Petitioner's resources and the respective expertise of its individual members -insure that'its contribution to this proceeding will be significant and responsibl , Should the Board permit this intervention, the Nuclear Awareness Network will timely file contentions which, when viewed in the aggregate, create serious doubt as to the physi-
. cal integrity of the structure known as the Wolf Creek Generating Statio Statements made by former Wolf Creek construction workers to the undersigned in the'last thirty days
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strongly suggest that the contractor at Wolf Cr,eek has encouraged or permitted procedures and practices contrary to the conditions of the Safety Evaluation. Report (docket no. STN 50-482) and applicable federal regulation Statements made by construction workers to the undersigned evidence a systematic
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breakdown between construction site practices and quality
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assurance / quality contro . - . - -
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Based on the statements voluntarily made to petitioner's
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director in the last thirty days, Petitioner would file *conten-tions allegings a) That the deliberate policies practiced.and permitted by Daniels Construction Co. as general contractor at Wolf Creek are contrary to and make mockery of quality assurance / quality control requirements putatively imposed on this project;
. b) That construction workers were. directed by Daniels'
foremen to perform wotk in safety related areas at variance
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with established procedures creating doubt as to the physical soundness of the structure; c) That Daniels' foremen directed construction workers to ~ mislead quality control personnel and at least one Daniels'
foreman forged and falsified work documents for safety related matter .
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In support of its contentions relating to the breakdown
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testimony of the following individuals who worked at Wolf
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- (a) Sam Goucher was a journeyman sheet metal me.chanic who
, worked.at Wolf Creek till August of 198 Mr. Goucher was j involved in rework in the diesel generator building and frequently saw QC travelers altered and postdate Mr. Goucher discovered
- travelers and weld control documentation on safety related work s t .
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that had been falsifie Mr. Goucher would testify that he
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, discovered thirty to forty welds in the diesel generator building with no documentatio Ultimately, new documents were made and he witnessed a quality control official forced by supervisors to s'ign off on the paperwor (b) Mr. Kenny Rowell worked as a journeyman sheet metal welder at Wolf Creek through October of 198 Mr. Rowell has given statements to the undersigned indicating that he was constantly crdered by a foreman to do safety related welds
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"out of procedure". Mr. Rowell was instructed by his fore-man that he was never to question his instructions whether they were consistent with procedure or no Mr. Rowell was informed that.he would be fired if he failed to follow the instructions of
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his foreman rega'rdless of the prescribed procedur Mr. Rowell has stated that he witnessed welders ordered to make welds for
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which they were not certifie (c) Mr. Earnest Larrick wo'rked as a journeyman sheet metal
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mechanic at Wolf Creek until December of 198 Mr. Larrick heard a Daniels' Foreman tell a co-worker not to tell quality control
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about any mistakes he discovere Mr. Larrick stated to the undersigned that he worked on safety related jobs that involved tightening bolts with load indication washer Repeatedly the bolts broke before they were tightened down to the desired y strength and were subject to an engineering correctional report
! (ECR). Mr. Larrick stated the workers were told to continue , __
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using these bolts and to " solve" the problem, the bumps on the washers were flatened with a hamme M Larrick also stated it was common knowledge that supervisors at Wolf Creek painted
, regular bolts green so that they would pass as Q bolt (d) Mr. Neil Campbell worked at Wolf Creek through August of 1981 as a journeyman sheet metal worker in the auxiliary and control buildings. Mr. Campbell has stated to the undersigned that he was repeatedly ordered to stamp false D numbers on weld Mr.Campbellstatedthatheregularlysawhissupervisorfalsi[y and forge welders' names on auxiliary and control safety related travelers and weld document .
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-6-(e) Mr. Vince Ley worked as a sheet metal welder at Wolf Creek thrt h November of 198 Mr. Ley stated that for a year and a half that he kept a handwritten list of safety related QC
' problems regarding welds which did not have documentatio In September of 1982 his list was given to Daniels' supervisors at J
Wolf Cree The list was thrown in the tras Mr. Ley has o stated to the undersigned that the contractor constantly ordered *
its workers to do safety related, work out of procedur Mr. Ley stated that while he was employed at Wolf Creek the Nuclear Regulatory Commission distributed a letter to the workers encouraging them to speak up concerning any problems'they might have relating to work procedure Two of his co-workers reported
- specific concerns to the NR Subsequently one of the workers was threatened with great bodily harm by his foreman if he was to'
I report any other problems to the NR Mr. Ley also related inci-
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dents involving bolt holes in the wrong locatio According to
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M Ley's statement, the standard procedure was to weld over the
hole, grind it off, and cut a new hole without reporting to
. quality contro .
(f) Mr. Tony Shores worked at Wolf Creek as a sheet metal mechanic on two separate occasions through December of 198 Mr. Shores stated to the undersigned that he was repeatedly ordered to perform safety related work without quality con-
tol approva Mr.. Shores stated that he was told to
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-7-remove and replace concrete anchor bolts without quality control inspectio .Mr. Shores also stated that he handed Mr. Vince Ley's list of QC problems to his supervisors who threw the list
_in the tras Petitioner submits that the incidents stated by the named construction workers constitute evidence of a systematic disre-gard for procedures required by the Sa fety Evaluation Repor If the construction site experiences of the referenced workers is representative, the integrity of the physical structure at the Wolf Creek Generating Station must be seriously questioned as well as the ultimate question of whether the Plant may be safely operate Petitioner submits that only through .the use of Nuclear Regulatory Commission's adjudicatory processes can this ultimate issue be resolve .
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4. Pursuant to 10 CFR 2.714 (a) (1) (i) - (v) and 2.714
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(d) petitioner submits the following as good cause for its late -- ~
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filing and for the required balancing of factors necessary to permit its interventio a) Good cause, if any, for failure to file on tim Petitioner was unaware of the existence of the seriots allega-tions mad.e by the referenced construction workers till mid-December of 1983, when she was contacted by a represen-tative of the worker These allegations, made by construction workers in face-to-face interviews by the undersigned, clearly
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-8-constitute newly arising informatio Petitioner could not have obtained this information earlier than the moment these workers decided to make public their evidenc Having received the
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information, petitioner's director acted diligently to bring their serious allegations to the attention of the Boar On January 5, 1984, the undersigned wrote a letter to Hon. Sheldon Wo l fe , Chairman. of the Atomic Sa fety and Licensing Board Panel, informing him "Recent and significant evidence has increased our concern enough to * * * submit a late - filed peti-
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tion to intervene in the Operating License Hearing Procedure."
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(Letter dated January 5, 1984 from Mary M. Stephens, Director, Nuclear Awareness Network to Sheldon J. Wolfe, Chairman, Atomic Safety and Licensing Board Panel).
As this Board is aware " . . . newly arising information has long been recognized as providing " good cause" for,accep-
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tance of a later contentio In The Matter of Consumer's Power Company, docket no OM, and OL 50-330-OM, 16 NRC 571, 577, citing Indiana and Michigan Electric Co., 5 AEC 13,14(1972). The construction workers first approached peti-tioner's director in December of 198 Their allegations of safety-related violations were not available till these indivi-duals decided to come forward with their evidenc Petitioner cannot be charged with prior knowledge of their allegations and once the undersigned learned of them, she acted diligentl _____ _ _____
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-9-b) The availability of other means whereby the peti-tioner's interests will be protecte The availability of other means to protect petitioners' asserted interest is nonap-
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parent if not nonexisten Petitioner is not aware of any contention filed by parties to this proceeding which directly relates to the serious allegations referred to herein nor .
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is there reason to believe these matters will be dealt with sua spont Certainly petitioner's right to a limited
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appearance statement (whic,h'the undersigned has requested) are
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not comparable to the substantive rights provided by intervenor s
statu Only through prNsenting testimony, cross examining
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opposing witnesses, and through the full use of the Board's adjudicatoryprocessmay] petitioner's interests and rights be protecte If permitted to intervene, petitioner will request the setting of a bifurcated hearing schedule and call its wit-T ', -
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nesses to testify in support of'its allegation Obviously,
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the Board would permit staff and applicant adequate time to investigate these allegations and prepare testimony of its ow c) The extent to which petitioner's participation would
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reasonably be expected to ass'ist in developing a sound recor There is no other forum within which petitioner may present its contentions as exclusive jurisdiction of this matter is certainly with the Boar petitioner is represented by experienced counsel who has for the last five years been exten-
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. -10-sively engaged in state and federal regulatory practice involving public utilitie From 1979 through 1982 petitioner's counsel was employed as Deputy General Counsel to the Kansas
_ Corporation Commission and in that capacity was assigned to all matters relating to Wolf Creek, petitioner's members possess technical expertise in relevant areas which further insure its ability to contribute to the record ,in this proceedin *
d) The extent to which petitioner's interest will be
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represented by existing partie As indicated above, peti-tioner is aware of no other contention by anyone party to this proceeding which coincides with the allegations of the referenced construction workers. While concern about the safe operation of Wolf Creek is of central importance to the Board, no party to the proceeding has made these specific allegations raised herein by this petitione While the staff is charged with representing the public interest in this proceedi'ng, it . _ . . .
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cannot be presumed th'at the staff's view of the public interest in this case will coincide with petitioner's vie Absent the existence of coinciding contentions made by other parties to this proceeding, it would seem clear that only petitioner can be expected to advocate its point of view based on newly arisen
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evidence.
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-11-e) The extent to which the petitioner participation will broaden the issues or delay 'the proceeding Assuming, argutndo, that the Board accepts petitioner's specific conten-
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tions following the granting of intervenor status, the issues before the Board will necessarily be broadene Staff, appli-
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cant, and other parties to this proceeding will require time to prepare for hearing. The operating licensing hearing will likely be extended for a period of months. But, as this Board
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has noted in another proceeding, "If there are outstanding questions involving public health and safety relating to opera-tion of the Plant, the necessary action to resolve that _ should be taken rather than attempting to quiet the matter by invoking the doctrine of estoppel by laches." In the Matter of Washington Public Power Supply System, et al,_ docket n , ASLBP 83-486-01 OL (1983).
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Conclusion , , , _
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- The Nuclear Awareness Network has demonstrated that it has the legally required interest to establish standing and shown that a balancing of the factors required by 10 CFR 2.714 weigh in' favor od granting this petition. The Nuclear Awareness Network respectfully requests an Order granting its petition for leave to intervene and for hearing The Nuclear Awareness Network will, if permitted to intervene, submit proposed con- .
tentions which raise issues which are most serious. Any deci-sfon on its contentions adverse to applicants could dictate the
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-12-denial of an operating licens Petitioner believes this con-sideration overrides legal niceties pertaining to the timeli-ness of filing and the practical exigencies of extending this
- hearin Only through a full airing of this matter will public
confidence in the safety of Wolf Creek be insure Respectfully submitted, 6LLv w -
Mary M. pjephens, Dirdctor ,
Nuclear Kwareness Network, In hh Massachusettes, Lawrence, Kansas 66044 (913) 749-1640 A. Rodman Johnson 820 Quincy, Suite 418 Topeka, Kansas 66612 ,
(913) 232-6933 .
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Attorney for Petitioner
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AFFIDAVIT I, Mary M. Stephens, being first duly sworn, do depose the same as follows: That I am the Director of The Nuclear Awareness
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Network, Inc. and duly authorized representativer That the foregoing petition was prepared at my request and at my direction, that I have read the con-
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tents thereof, and that based upon my own persond@4kggwp3d%f1 :51
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believe that the facts averred therein are true and correc LFFw(O.:5EL,g
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CCCKf.uNG & SEF ,
BRANCH
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Mary M.-ptyphens, Director l' Nuclear M reness Network, In !
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j Subscribed and sworn to before me this 19th day of i
January, 198 . Carol Moe Shannon NOTARY P U P. L I C *
Ste:!e of Kr.w.as m, a to _e
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Notary Public T
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l CERTIFICATE OF SERVICE
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! - / I, Mary M. Stephens, do hereby certify that I caused a true and correct copy of the foregoing Petition for Leave to Intervene and Request for Hearing was placed in the U.S. Mail, postage prepaid on this 19th day of January, 1984,' addressed to:
The United States Nuclear Regulatory The Executive Legal Director Commission U.S. Nuclear Regulatory Commission l Washington, D.C., 20555 Washington, D.C. 20555
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Sheldon J. Wolfe, Chairman Atomic Safety and Licensin ,
Atomic Safety and Licensing . Appeal Board Board Panel U.S. Nuclear Regulatory Commission
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U.S. Nuclear Regulatory Commission Washington,* DC 20555 *
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Washington, DC 205555
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-14-Dr. George C. Anderson Docketing and Service Section Department of Oceanography Office of the Secretary University of Washington U.S. Nuclear Regulatory Commission Seattle,' Washington 98195 Washington, DC 20555 C. Edward Peterson, Esquire Kent M. Ragsdale g-As'sistant General Counsel General Counsel Kansas Corporation Commission Missouri Public Service Commission State Of fice Building - 4th Floor P . O '. Box 360 Topeka, Kansan 66612 Jefferson City, Missouri 65102 Dr e Hugh C. Paxton Atomic Safety and Licensing Board 1229 - 41st Street *
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U.S. Nuclear Regulatory Commission Los Alamos, Naw Mexico 87544 washington, DCs20555 Myron Karman, Esquira Scott Cauger,' Esquire Deputy Assistant Chie~f Assistant General l Counsel Hearing Counsel Missouri PUblic.S,rvicee Commission Office of the Executive P.O. Box 360 . l Legal Director Jefferson City,[ Missouri 65102 U.S. Nuclear Regulatory Commission .
Washington, DC 20555 {
t Eric A. Eisen, Esquire Jay E. Silberg ,
Birch, Horton, Bittner & Monroe Shaw, Pittmane Potts & Trowbridge 1140 Connecticut Avenue, M Street,f Washington, DC 20036 Washington, DC 20006
Alan S. Rosenthal, Esquire Dr. John H . Buc Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Appeal Board' l - - - - -
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 ,
Brian P. Cassidy, Esquire Thomas S. Moore, 1 squire Federal Emergency Management Agency Atomic Safety and Licensing Region I Appeal Board J.W. McCormack POCH U.S. Nuclear Regulatory Commission Boston, Massachusetts 02109 Washington, DC 20555
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