ML19253D021
| ML19253D021 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/16/1979 |
| From: | Singer L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 7912120522 | |
| Download: ML19253D021 (14) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 11/16/79 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD f~~
g In the Matter of
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METROPOLITAN EDISON COMPANY,
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Docket No. 50-289 6j
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(Three Mile Island, Unit 1)
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NRC STAFF BRIEF ON THE EFFECT OF RULEMAKINGS UPON THE ISSUES OF THE TMI-1 SUSPENSION PROCEEDING I.
INTRODUCTION Several contentions submitted by petiticners in this proceeding relate in some way to issues that are or may become the subject of rulemak-ing by the Commission.
In that connection, the NRC Staff has attempted to identify issues raised by petitioners that are within the scope of this proceeding as we understand it and that are pending rulemakings.
In additicn, g
we identify certain areas proposed by the NRC Staff as appropriate for rulenaking.
These areas are specifically identified in NUREG-0578. We also attem;t to identify other related areas that have been the subject of formal Staff recom-mendations for rulemaking. While these latter issues are not, therefore, pend-ing rulemakings, their status as recommendations for rulemaking may be of interest to the Board. This Brief is submitted in response to the Board's re-quest that the NRC Staff report on the status and effect of proposed rulemakings upon the issues in this hearing. Accordingly, this brief will address the options and considerations of the Licensing Board when (1) the Commission 1540 297 522 7912120 G
. has published notice of a rulemaking in the Federal Register and (2) when a rulemakimj that has been proposed by the NRC Staff has not been commenced by the Commission. In so doing, we will discuss the subject matters identified above that are currently in rulemaking or that could become the subject of a rulemaking and the effect of their "rulemaking status" upon the TMI-1 suspension proceeding. For the reasons we develop below, we argue that neither the presently pending rulemakings nor the NRC Staff recommendations of subjects for rulemaking preclude the adjudication of otherwise appropriate contentions.
II. GENERAL DISCUSSION CONCERNING PENDING RULEMAKINGS Title 10, Part II, Subpart H, 662.800-2.807 of the Code of Federal Regulations governs the rulemaking procedures of the Nuclear Regulatory Commission. Rule-making proceedings may be initiated sua sconte by the Commission, upon the re-commendation of another United States agency or upon the petition of any other interested person. 10 C.F.R. 12.801.
In light of the provisions of the applicable NRC rulemaking regulations and absent a statutory prohibition to the contrary, the Commission falls within the general rule articulated by the Supreme Court of the United States in SEC v. Chenery Corporation, 332 U.S.
194 (1947), quoted in NLRB v. Bell Aerospace Co., 416 U.S. 267, 293 (1974).
In Chenery, the Court stated that "the choice made between proceeding by general rule or by individual, ad hoc litigation is one that lies primarily within the informed discretion of the administrative agency." SEC v. Chenery Coro., suora at 202-03. See In the Matter of Potomac Electric Power Company (Douglas Point Nuclear Generating Station, Units 1 and 2), ALAB-218, 8 AEC 79, 84 (1974).
If 1540 298
. the Commission wishes to adopt, amend or repeal a regulation, it publishes a notice of the proposed rulemaking in the Federal Register. 10 C.F.R. 52.804.
In the absence of such a directive, certain issues may be adjudicated in individual proceedings notwithstanding the fact that those issues may apply to all nuclear power plants.~1/ Douglas Point, suora, ALAB-218, 8 AEC 79 at
- 84. Once the Commission has decided upon a rulemaking to resolve a particular issue, however, the Atomic Safety and Licensing Appeal Board, focusing on the desire to achieve expediency and to eliminate unnecessary and duplicative pro-ceedings, has generally stated that licensing boards should refrain from allow-ing into individual licensing proceedings contentions that touch upon the sub-ject matter of that rulemaking. See Douglas Point, suora, ALAB-218, 8 AEC 79 at 85 ("... consideration in adjudicatory proceedings of issues presently to be taken up by the Comission in rulemaking would be, to say the least, a wasteful duplication of effort."); In the '>atter of Vermont Yankee Nuclear Power Corocration (Vermont Yankee Nuclear Power Station), ALAB-179, 7 AEC 159, 163 (1974) ("Once that [rulemaking] proceeding was initiated, it would have been singularly inappropriate to undertake to duplicate it in an individual reactor licensing proceeding."). See also In the Matter of Long Island Lighting Comoany (Shoreham Nuclear Power Station), ALAB-99, 6 AEC 53, 56-57 (1973). The Appeal Board has further particularized that " licensing boards should not accept in individual license proceedings contentions which are
-1/ See generally NRDC, Inc. v. NRC, 547 F.2d 633 (D.C. Cir. 1976), where the court neio tnat "aosent effective generic proceedings to consider Cissues of an ' irreversible and irretrievable' nature, these issues] must be dealt with in individual licensing proceedings."
Id_. at 641.
Nevertheless, licensing boards have been cautioned against attempting to resolve in individual proceecings generic issues that affect other licensees, especially where a future determination by the Commission could obliterate the result reached by the licensing board. See In the Matter of Vermont Yankee Nuclear Power Corcoration (Vermont Yankee Nuclear Power Station),
CLI-74-40, 8 AEC 509, 814-15 (1974).
0 299 (or are about to become) the subject of general rulemaking by the Commission."
See Doualas Point, suora, ALAB-218, 8 AEC 79 at 85 (empnasis supplied).
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lt should be noted that the cases discussed above deal with circumstances where a contention raised issues that did not involve an attack on a rule presently in place. Where a contention does launch an attack upon an exist-ing rule, however, licensing boards are generally proscribed from consider-ing the contention for that reason.
In addition, the pendency of a proposed amendment to a Commission regulation does not excuse licensing boards from the need to make a finding of whether there is confor-2/
mance with that regulation.-
2/ In this regard, the Board should note the recent statement by the Commission relating to modified adjudicatory procedures for licensing proceedings:
In reaching their decisions the Boards should interpret existing regulations and regulatory policies with due consideration to the implications for those regulations and policies of the Three Mile Island accident.
In this regard it should be understood that as a result of analyses still under way the Comission may change its present regulations and regulatory policies in important respects and thus compliance with existing regulations may turn out to no longer warrant approval of a license applica-tion. As provided in paragraph 3 below, in addition to taking generic rulemaking actions, the Comission will be providing case-by-case guidance on changes in regulatory policies in con-ducting its reviews in adjudicatory proceedings. The Boards shall, in turn, apply these revised regulations and policies in cases then pending before them to the extent that they are accli-cable. The Comission expects the Licensing Boards to pay parti-cular attention in their decisions to analyzing the evidence on those safety and environmental issues arising under applicable Commission regulations and policies which the Boards believe present serious, close questions and which the Boards believe may be crucial to whether a license should become effective before full appellate review is completed. Furthermore, the Boards should identify any aspects of the case which, in their judgment, present issues on which prompt Commission policy guidance is called for. The Boards may request the assistance of the parties in identifying such policy issues but, absent specific Commission directive, such policy issues shall not be the subject of discovery, examination, or cross-examination.
Nuclear Regulatory Commission, Suscension of 10 C.F.R. s2.764 and Statement of Policy en Conduct of Adiodicatorv Proceeoincs 4-5 povemoer o,19/9).
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Two specific issues that are currently in rulemaking have been raised in this proceeding and are discussed below.
A.
" Class 9" Accident Consecuences On December 1, 1971, the Commission published notice in the Federal Register of proposed amendments in the form of an Annex to Appendix 0 to 10 C.F.R. Part 50 (currently Part 51). 36 Fed. Reg. 22851-52 (December 1, 1971). The Annex contains assumptions proposed by the Atomic Energy Commission for use in environmental reports prepared by applicants. p. Specifically, because the AEC decided that it would be impracticable to consider all possible accidents, the AEC divided the spectrum of accidents into nine categories, which are listed in increasing order of severity. p.
The Annex concludes that neither Class 1 nor Class 9 accidents need to be considered. The consequences of Class 1 were deemed too trivial to warran:
discussion in environmental reports. The consequences of Class 9, although admittedly potentially severe, were censidered so improbable that the Annex provided that applicants need not discuss such events in their environmental reports. M.at22852. See also In the Matter of Offshore Power Systems (Floating Nuclear Power Plants), ALAB-489, 8 NRC 194, 209-10 (1978).
In the 1971 proposed rulemaking, the AEC stated that the proposed Annex "will be useful as interim guidance until such time as the Commission takes further 3/ The Staff would like to call the Licensing Board's attention to the Advance Notice of Proposed Rulemaking concerning the Acceptance Criteria for Emergency Core Ccoling Systems for Light-Water-Cooled Nuclear Power Plants, 10 C.F.R. Part 50, Dublished in 43 Fed. Reg. 57157 (December 6, 1978). We are unaware of any contention in this proceeding that raises the same subject matter as will be covered by that rulemaking.
1540 301 action on Cit]." 36 Fed. Reg. 22851 (December 1, 1971). See alsc Offshore Power Syst&ns (Floating Nuclear Power Plants), CLI, 10 NRC (September 14, 1979) (slip o_p. at 3). Recently, the Commission stated that it intends to complete the Class 9 rulemaking initiated by the Annex and to re-examine its own policy in this area. See id. at 9.
In this vein, the Comission also asked the Staff to provide recommendations on how the interim guidance of the Annex might be modified until completion of the Class 9 rule-making toreflect developments since 1971 and to accord more fully with current Staff policy. Until the Comission alters its interim policy or until the Class 9 rulemaking has been completed, however, the guidance provided by the proposed Annex remains controlling in all licensing proceedings where Class 9 issues arise. See Floating Nuclear Power Plants, supra, ALAB-489, 8 NRC 194 at 212.
Although this interim guidance generally precludes consideration of Class 9 acci-dents in environmental studies, it does not prevent parties from raising con-tentions that allege special circumstances that could result in specific Class 9 accidents at individual nuclear power reactors. See In the Matter of Duke Power Comcanv (Catawba Nuclear Station, Units 1 and 2) ALAB-355, 4 NRC 397, 415-16 (1976) (must show special circumstance rendering specific Class 9 acci-dent more likely in this particular reactor than in reactors in general), In the Matter of Lana Island Lighting Comoany (Shoreham Nuclear Power Station), ALAB-156, 6 AEC 831, 836 (1973) (must show reasonable possibility of the occurrence of a particular type of accident generically regarded as being in Class 9),
In the Matter of Wisconsin Electric Power Company (Point Beach Nuclear Plant, Unit 2), ALAB-137, 6 AEC 491, 502(1973) (must show assumptions in Annex are 1540 302 inapplicable to this reactor); Consumers Power Company (Midland Plant, Units 1 and 2), ALAB-123, 6 AEC 331, 346-47 (1973) ("where assumptions are not specified, or where those specified are deemed unsuitable, assumptions as realistic as the state of knowledge permits shall be used, taking into account the specific design and operational characteristics of the plant under con-sideration."), cuoting Proposed Annex in 36 Fed. Rec. 22852.
It appears to e
us, therefore, that the legal framework within which specific Class 9 accident contentions may be considered is not materially altered by the Com-mission's announcement in Offshore Power Systems, suora, that it intends to actively pursue the rulemaking in that area.-4/
S.
Emergency Preparedness The fact that the Commission may, within its informed discretion, choose between proceeding by a general rulemaking or by individual adjudications to resolve an issue, see SEC v. Chenery Corocration, 332 U.S. 194, 202-03 (1977),
ooes not preclude the Commission from requiring adjudication of an issue in individual licensing proceedings during the period of a rulemaking on that same issue.
In instances where the Comission has directed that an issue that is in rulemaking should also be adjudicated in an individual proceeding, the Staff is of the opinion that the licensing board is without discretion:
it must hear and resolve that issue.
In the TMI-l proceeding, the Comission has identified emergency preparedness as an issue to be resolved in the hearing, see In the Matter of Metrocolitan Edison Company (Three Mile Island Nuclear Station, Unit No. 1), CLI, 10 NRC (August 9, 1979) (slio 02
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at 6, 8), notwithstanding its earlier publication in the Federal Register of 4/ We continue to believe, of course, that the consideration of accidents in this proceeding must be limited to accidents that bear a close nexus to the March 28, 1979 accident and that, in order that the Board can determine whether such nexus exists, contentions must describe the scenario of events that might be involved in such accidents.
1540 303 a proposed amendment-5/
to Appendix E of 10 C.F.R. Part 50, see 43 Fed. Reg.
37473-75 (August 23,1978). The proposed amendment mandates that provisions for emergency protective measures to reduce exposures from an accidental release of, radioactive material be considered at least within the low population zone (LPZ). Moreover, pursuant to this amendment, emergency planning would also be extended to areas appropriate to each plant beyond the LPZ. The size of these areas depends upon the design of the facility and the physical characteristics of the area.-6/Accompanying the amendment is the announcement by the Comission of its intention that the proposed amendment be used as interim guidance in reviewing an applicant's emergency plan for a construction permit or at the operating license stage. M.at37475.
On July 17, 1979, the Commission published an Advance Notice of Proposed Rulemaking. See 44 Fed. Reg. 41483 (July 17, 1979). The Advance Notice seeks written comments suggesting items that should be included in the proposed regu-lations, "which will establish as conditions of power reactor operation increased
-5/ The proposed amendment to Appendix E, Emergency Plans For Production and Utilization Facilities, reads as follows:
For nuclear power reactors, provisions for emergency pro-tective measures to reduce exposures from an accidental release of radioactive material shall be considered, at a minimum, within the low population zone (LPZ) as specified in 10 C.F.R. Part 100. The extent to which emergency plan-ning,which may include planning for evacuation measures, should extend to areas beyond the LPZ shall be based on the design features of the facility and the physical characteristics of the environs in the vicinity of the site, taking into account the emergency protective action criteria developed by appropriate Federal authorities, and by appropriate State and local governmental authorities in cooperation with the Commission.
43 Fed. Reg. 37475 (Aug. 23, 1978).
6f The proposed amendment to Appendix E is a clarification by the Commission of its " intent that consideration of emergency planning beyond the LPZ is a factor in the licensing review and is not a factor in the site suitability review under 10 C.F.R. Part 100." This clarification was published in the wake of the Appeal Board decision that construed the Commission's regula-tions as disallowing consideration by licensing proceedings of evacuation plans that encompassed people beyond the LPZ. See 43 Fed. Reo. 37475 (August 23,1978), In the Matter of New England Power Company (NEP, Units 1 and 2); Public Service Comoany of New Hamoshire (Seabrook Station, Units 1 and 2), ALAB-390, 5 NRC 733 (1977).
1540 304
-g-emergency readiness for public protecLicn in the vicinity of nuclear power e
reactors on the part of both the licensee ano local and state authorities."
44 Fed. Reg.. 41483 (July 17, 1979).-7/
This notice does not alter, however, the Commission's earlier declaration that "the Connission is firmly of the opinion that continued implementation of its practice to review the possible need for emergency planning beyond the LPZ as necessitated by cir-cumstances in the vicinity of the site is required." See 43 Fed. Reg. 37475 (August 23, 1978). The Staff believes that the Licensing Board should therefore consider the issue of emergency preparedness in light of this express mandate and the statements in the August 9, 1979 Commission Order.
III. RULEMAKINGS PROPOSED TO THE COMMISSION BY NRC STAFF In TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommenda-tions, NUREG-0578, dated July 1979 (NUREG-0578), the Staff recommended a 7/ Later, the Commission published a Policy Statement entitled " Planning Basis for Emergency Responses to Nuclear Power Reactor Accidents." 44 Fed.
Rec. 61123 (Oct. 23, 1979).
In this statement the Commission concurred E and endorsed an EPA /NRC task force report entitled " Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants," NUREG-0396, EPA 520/1-78-016, dated December 1978 (NUREG-0396). NUREG-0396 recommends that two Emergency Planning Zones (EPZs) be established around light water nuclear power plants: (1) the EPZ for airborne exposure, which has a radius of approximately 10 miles and (2) the EPZ for contaminated food, which has a radius of approximately 50 miles. The report also calls for predetermined protective action plans for the EPZs.
In endorsing NUREG-0396, the Commission also directed the Staff to incorporate NUREG-0396's planning basis guidance into existing documents used in the evaluation of state and local emergency response plans to the extent practicable." 44 Fed. Reg. 61123 (Oct. 23, 1979).
The standard for measuring an EPZ, namely mileage, differs from that used to determine " low population zones." The definition of low population zone in 10 C.F.R.100.3(b), which refers to "the area irrnediately surrounding the exclusion area which contains residents, the total number and density of which are such that there is a reasonaole proba0111ty that appropriate pro-tective measures could be taken in their behalf in the event of a serious accident" (emphasis supplied), u+ili c: Dopulation density as a guide in
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emergency planning.
1540 505
. "rulemaking to require capaisility of installing" combustible gas control 8/
recombiners.'~ See NUREG-0578, suora at B-3, Table B-1, 2.1.5.c.
In its Final Report entitled TMI-2 Lessons Learned Task Force Final Report, NUREG-0585, dated October 1979 (NUREG-0585), the Staff similarly discussed hydrogen control as an issue in the context of the recommended rulemaking on the consideration of design features that would mitigate accidents result-ing in core melt and severe core damage without substantial melting. See NUREG-0585, suora at 3-6, A-14 to -15 and -15 (6).
In addition to Staff recomendations for rulemaking in NUREG-0578 and NUREG-0585, we have identified formal staff recommendations for or discussions of the options relating to rulemaking in certain other relevant areas.
In particular, the issues involved in operator licensing (SECY-79-330E and -330F) and occupational exposure / health physics (SECY-78-415) have been the subject of Staff pre-sentations to the Comission relating to potential rulemakings.
With respect to Staff proposals for rulemakings that have not been mide the subject of a proposed rulemaking, we regard the appropriate guidance to be In the Matter of Duke Power Comoany (Catawba Nuclear Station, Units 1 and 2),
ALAB-355, 4 NRC 397 (1976).
In that decision the Appeal Board held that a Staff " working paper" has no legal significance for any NRC regulatory pur-pose unless the suggestions in that paper have been adopted by the Commission.
M. at 416. Because the Commission has not adopted the suggestions 8/ The Staff also recommended revision of the limiting conditions for opera-tion based on safety system availability that are governed by 10 C.F.R. 550.36, NUREG-0573, supra at 5.
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. in NUREG-0578 and NUREG-0585-9/
and the SECY papers described above, and because no notice o'r advance notice of rulemaking in these areas have issued, those documents possess the status of " working papers." The observation of the Appeal Board in Douglas Point, suora, that " licensing boards should not accept in indivi-dual license proceedings contentions which are (or are about to become) the sub-ject of general rulemaking by the Comission" does not, therefore, apply to these areas. Where regulations presently govern these areas (e.g. 10 C.F.R. 550.44), the Board is bound by those regulations absent a Commission deter-mination pursuant to 10 C.F.R. 52.758 or special certification by this Board of the question of whether the purposes of the rule would be served by its application in this proceeding.
IV. CONCLUSION As we identify above, two issues raised in this proceeding are presently the subject of rulemakings by the Commission and several others have been recom-mended by the NRC Staff as subjects for rulemaking. For the reasons we out-line above, neither of the rulemakings, relating to " Class 9" accidents and emergency planning, precludes the Licensing Board frca considering otherwise 9/ In its Order of August 9,1979 the Commission suggested that the licensee
- be required to comply with the Category A and Category B recommendations as specified in Table B-1 of NUREG-0578. The recommendation of a " rule-making to require capability of installing recombiners" falls into neither Category A nor Category B.
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. appropriate contentions.
In addition, the recommendations by the NRC Staff of issues for rulemaking have no effect upon the propriety of board adjudi-cation of contested issues in this proceeding.
Respectfully submitted, ddO d l'
Mf Lisa N. Singer Counsel for NRC Staff Dated at Bethesda, Maryland this 16th day of November, 1979.
15LO 308
UNITED STATES OF AMERICA NUCLEAR REGULATf ' COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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METROPOLITAN EDISON COMPANY, Docket No. 50-289 ET AL.
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(Three Mile Island, Unit 1)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF BRIEF ON THE EFFECT OF RULEMAKINGS UPON THE ISSUES OF THE TMI-l SUSPENSION PROCEEDING," in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, express mail, or, as indicated by an asterisk, througn deposit in the Nuclear Regulatory Commission's internal mail system and by double asterisk hand delivered, this 16th day of November,1979:
- Ivan W. Smith, Esq.
- Ellyn Weiss, Esq.
Sheldon Harmon, Roisnan & Weiss Atomic Safety & Licensing Board Panel U.S. Nuclear RegulatorL ommission he l reet, N.W.
C Washington, D. C.
20oo3 Washington, D.C.
2CCC6 Dr. Walter H. Jordan Mr. Steven C. Sholly 881 W. Outer Drive 304 South Market Street Oak Ridge, Tennessee 37830 Mechanicsburg, Pennsylvania 17055 Dr. Linda W. Little 5000 Hermitage D-ive Mr. Thomas Gerusky Raleigh, North Carolina 27612 Bureau of Radiation Protection Department of Environmental Resources
- George F. Trowbridge, Esq.
P.O. Box 2063 Shaw, Pittman, Potts & Trowbridge Harrisburg, Pennsylvania 17120 1800 M Street, N.W.
Washington, D. C.
20005 Mr. Marvin I. Lewis 6504 Bradford Terrace Karin W. Carter, Esq.
Philadelphia, Pennsylvania 19149 505 Executive House P. O. Box 2357 Metropolitan Edison Company Harrisburg, Pennsylvar,ia 17120 Attn:
J. G. Herbein, Vice President P.O. Box 542 Reading, Pennsylvania 19603 Henorable Mark Cohen 512 E-3 Main Capital Building Ms. Jane Lee Harrisburg, Pennsylvania 17120 R.D. 3; Box 3521 Etters, Pennsylvania 17319 1540 309
Walter W. Cohen, Consumer Advocate Holly S. Keck Department of Justice Anti-Nuclear Group Representing Strawberry Square,14th Floor York Harrisburg, Pennsylvania 17127 245 W. Philadelphia Street York, Pennsylvania 17404 Robert L. Knupp Esq.
Assistant Solicitor John Levin, Esq.
Knupp and Andrews Pennsylvania Public Utilities Com.
P.O. Box P Box 3265 407 N. Front Street Harrisburg, Pennsylvania 17120 Harrisburg, Pennsylvania 17108 Jordan D. Cunningham, Esq.
John E. Minnich, Chairman Fox, Farr and Cunningham Dauphin Co. Board of Comissioners 2320 North 2nd Street Dauphin County Courthouse Harrisburg, Pennsylvania 17110 Front and Market Sts.
Harrisburg, Pennsylvania 17101 Theodore A. Adler, esq.
Atomic Safety and Licensing Appeal Board Widoff Reager Selkowitz & Adler Post Office Box 1547 U.S. Nuclear Regulatory Commission Harrisburg, Pennsylvania 17105 Washington, D. C.
20555 Atomic Safety and Licensing Board Panel 3
,a jorie M. Aamodt s M U.S. Nuclear Regulatory Commission Coatesville, Pennsylvania 19320 Washington, D. C.
20555 Docketing and Service Section U.S. Nuclear Regulatory Commission
- Ms. Karen Sheldon Washington, D. C.
20555 Sheldon, Harmon, Roisman & Weiss 1725 I Street, N. W.
Suite 506 Robert Q. Pollard Chesapeak Energy Alliance Washington, D. C.
20006 609 Montpelier Street Earl B. Hoffman Baltimore, Maryland 21218 Dauphin County-Cormissioner Chauncey Kepford Dauphin County Courthouse Front and Market Streets Judith H. Johnsrud Environmental Coalition on Nuclear Power Harrisburg, Pennsylvania 17101 433 Orlando Avenue State College, Pennsylvania 16801 Ms. Frieda Berryhill, Chairman 1
n (1n Coalition for Nuclear Power Plant i
U JlU Postponement 2610 Grendon Drive l{t'l}l.hyfG/]
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Wilmington, Delaware 19808
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Lisa N. Singer
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Counsel for NRC Staff