ML19273B991
| ML19273B991 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Hope Creek, 05000355  |
| Issue date: | 05/02/1979 |
| From: | Conner T CONNER, MOORE & CORBER |
| To: | |
| References | |
| NUDOCS 7906180656 | |
| Download: ML19273B991 (15) | |
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UNITED STATES OF AMERICA d F 1.- 7
$$, 1 b. '[ ,Es NUCLEAR REGULATORY CO!SiISSION .
. f.es : x~s In the Matter of ,
PHILADELPHIA ELECTRIC COMPANY ) Docket Nos. 50-277
) 50-278 (Peach Bottom Atomic Power )
Station, Units 2 and 3) )
)
PUBLIC SERVICE ELECTRIC & GAS ) Docket Nos. 50-354 .
COMPANY & ATLANTIC CITY ) j50- 355_
ELECTRIC COMPANY )
)
(Hope Creek Generating Station, )
Units 1 and 2) )
LICENSEE'S MOTION FOR RECONSIDERATION OF ALAB-540 AND SEVERENCE FROM THE CONSOLIDATION ESTABLISHED BY THAT DECISION In Philadelchia Electric Comoany (Peach Bottom Atomic Power Station, Units 2 and 3), e al., ALAB-480, 7 NRC 796 (1978), the Atomic Safety and Licensing Appeal Boards presiding over seventeen separate proceedings established a uniform procedure for reconsidering the environmental effects of radon-222 emanations occurring as a result of the mining and milling of uranium. Pursuant to the Commission's amendment of Table S-3 of 10 C.F.R. Part 51 (" Summary of Environmental Considerations for Uranium Fuel Cycle") to delete the value previously assigned to the emissions of radon-222 as incorrect, the combined Appeal Boards in ALAB-480 adopted a novel procedure 1/
proceeding was established as the " lead whereby the Perkins case" ,on the pending issue of radon releases. Accordingly, 1/ Duke Power'Co. (Perkins Nuclear Station, Units 1, 2 and:
3), LBP- 7 3- 2 5, 8 NRC 87 (1978).
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the evidentiary record on the radon issue in Perkirt was served upon every party to each of the sixteen proceedings. All parties were given an opportunity to file a memorandum addressing, first, the generic findings and conclusions of the Licensing Board in Perkins and, second,. the, application of these conclusions to NEPA.
After reviewing the papers submitted in response to the procedure established in ALAB-480, the combined Appeal Boards in ALAB-509-2/ determined that there were two areas calling for particular attention: (1) the extent to which parties were dissatisfied with Perkins " insofar as it deals with rates of ---
radon release or levels of radon concentration from either . _ . -
natural sources or nuclear fuel cycle activities . . . " and, assuming Perkins to be accurate on emission rates and concen-tration levels, "the Licensing Board's de minimus theory."-3/
The Appeal Board noted that only the intervenors in the 4/ 5/
Snerline and Tvrone proceedings contested the evidentiary 2/ Philadelphia Electric Co. (Peach Bottom Atomic Power Station, Onits 2 and 3), et al., ALA3-509, 8 NRC 679 (1978).
3/ Id. at 682.
4/ Rochester Gas and Electric Corp. (Sterling Power Project Nuclear Unit No. 1), Docket No. STN-50-485.
5/ Northern States Power Co. (Tyrone Energy Park, Unit No. 1),
Docket No. STN-50-484.
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record in Perkins to argue that more evidence should be adduced on the issue of emission rates and concentration levels.
The remaining parties in the sixteen pending proceedings were therefore given an opportunity to disagree with the Licensing Board's de minimus theory. In response to this invitation, the Sterling and Tyrone intervenors, Ecology Action of Oswego and Northern Thunder, respectively, challenged the Perkins evidentiary record on radon releases and concentrati n levels as well as the de minimus approach; the intervenors in the Peach Bottom, Hope Creek and Three Mile Island proceedings filed memoranda disagreeing with the de minimus approach. No other papers opposing the Licensing Board's evidentiary findings and conclusions in Perkins, or its de minimus approach, were filed.
As the matter now stands, therefore, only the Sterling and Tyrone intervenors have challenged the fact-finding by the Licensing Board on the radon-222 issue. Eleven of the sixteen proceedings are essentially uncontested. Thus, the Peach Bottom and Home Creek proceedings now merely involve an applica-tion of an uncontested evidentiary record to the cost-benefit analysis required by NEPA in light of the conclusion by the Licensing Board in Perkins that any increase in radon releases --- --- -
associated with the mining and milling of nuclear fue' over and above that associated with the natural background is so small in comparison as to be completely undetectable and therefore insignificant. This legal issue has been briefed by the 2353 166
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6/ 7/
Licensees and by the latervenors in the Peach Bottom and 8/ Inasmuch as the de minimus approach Hope Creek proceedings.
of the Licensing Board in Perkins presents an issue of law that may be dispositively resolved on the basis of the evidentiary 9/
record now constituted, the validity of the Licensing Board's . . . . ..
de minimus approach should and can be decided now.
On April 26, 1979, the combined Appeal Boards issued ALAB-540, which evaluated the current state of the radon con-tentions in the sixteen pendirg proceedings. The Appeal Boards concluded that they should consolidate and hear first those .
cases in which intervenors are actively participating and to hold the remainder in abeyance. The Appeal' Boards based their conclusion on the generic nature of the radon issue and con- _
siderations of manageability and efficiency. It was further suggested that, in view of the record respecting "not only the 10/'~
~-
level but also the consequences of the radon emissions,"
the outstanding contentions might be subject to a motion for summary disposition. Accordingly, the Appeal Boards directed that any motions by the Applicants for summary disposition be filed jointly.
6/ Licensees' Response to Briefs in Opposition to the Perkins Approach (April 4, 1979).
2/ In response to the de_ minimus theory and ALAB-509 (February 19, 1979).
8/ Brief of David Caccia on Boards de minimus conclusions on
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radon (January 3, 1979).
9/ In ALAB-509, the combined Appeal Boards noted that "(i]f we
- were to subscribe to (the de minimus] view, there would J appear to be no reason to -onsider the question o f health effects further." 8 NRC at 684.
10/ ALAB-540, slip op. at 10-11.
. 4 In our view, the consolidation and joint briefing required under ALAB-540 bhould be reconsidered for the following reasons.
It departs from,the philosophy of the " lead case" procedure pre-viously adopted by the combined Appeal Boards in ALAB-480 to resolve existing questions. Secondly, this procedure is unfair because it injacts new issues into the Peach Bottom and Hope Creek proceedidgs which have not been raised by any party thereto. Since a Board may properly rely upon uncontested 11/
Staff and licensee evidence,-- it follows that Licensees herein will be greatly prejudiced if forced to defend against the some twenty-three contentions pressed by the Sterlina and Tyrone intervenors, which are not contentions in Peach Bottom or Hope Creek. Consolidation should not require a licensee to 11/
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Consumers Power Co. (Midland Plant, Units 1 and 2),
ALAB-123, 6 AEC 331, 334-35 (1973) and Boston Edison Co.
(Pilgrim Nuclear Power Station) , ALAB-83, 5 AEC 354, 358 (1972). Inasmuch as a licensing board has no obligation to reword an invalid contention in order to make it accept-able, Commonwealth Edison Co. (Zion Station, Units 1 and 2), ALAB-226, 8 AEC 381, 406 (1974), it follows that con-tentions should not be altogether invented for intervenors
'and forced upon them. Thus, contentions which have not even been made .43 the Peach Bottom and Hope Creek proceed-ings should not ce attributed to intervenors in those proceedings and incidentally injected through the.consoli - - - - - -
dation procedure. Of course, after disposition of the intervenors' -:ententions in Sterline and Tvrone, the Appeal Boards in Peach Bottom and Hope Creek may raise similar con-tentions sua sponte, but that is altogether different'from requiring the Peach Bottom and Hope Creek Licensees to defend against all of the Sterling and Tyrone intervenors' contentions now.
12/
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In addition, it should be noted that the Peach Bottom and Hope Creek licensees never had an opportunity to oppose the twenty three contentions permitted by ALAB-509.
Fundamental fairness requires that the Licensees not be fballed upon to answer contentions which they never had an opportunity to oppose.
2353 168
~6-answer contentions permitted an intervenor in a different case, and certainly should not be the basis for decision on the present state of the record. Here, if the ALA3-540 is permitted to stand, the Peach Bottom and Hoce Creek Licensees would be re-quired to retain outside experts and expend additional time and money for the input of company personnel and legal counsel if they must, as presently contemplated by ALAB-540, respond to the Sterling and Tyrone contentions.
The " lead case" procedure utilized by the combined Appeal Boards has succeeded in its purpose. It has avoided a costly and timely repetition of evidentiary presentation in the different proceedings, but has not foreclosed any litigant from pursuing its factual or legal contentions. However, the__ __
original sixteen contested proceedings have now been whittled _
down to five, only two of which still challenge evidentiary _. _ . . _ _ .
findings and conclusions. In fairness to the Licensees in the Peach Bottom and Hope Creek procradings, neither of which in-volves any challenge to the eviCentiary record in Perkins on radon releases and concentration levels, those two cases should not be consolidated with the Sterline and Tyrone proceedings.
-Instead, they should be severed and decided by their Appeal Boards on the p yf3 mus i approach utilized by the Licensing ._
H/
Board in Pg3)30 en the basis of the existing record. In other worde, LyucQ Bottom and Hope Creek are in the same status 13/
In fact, there is no more evidence or argument of signifi-cance on this point.
2353 169 P. 1 ,i
on the evidence as the eleven cases which have not been con-solidated and should be decided on the same basis.
Just as the Appeal Boards in ALAB-540 implicitly recognized in not consolidating the eleven uncontested proceedings with Sterline and Tvrone, fundamental fairness requires that the Peach Bottom and Hope Creek proceedings not be affected by consideration of fact-finding challenges in the Sterling and Tyrone proceedings on the twenty-three contentions allowed by,.
the Appeal Boards in ALAB-540. The validity of the de minimus approach has been fully briefed by the Peach Bottom and Hoce Creek parties.
Respectfully submitted, CONNER, MOORE & CORBER
/2ffh Troy B. Conner, Jr.
~ -
Counsel for the Licensees May 2, 1979 2353 170 .. .- _
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of- 3 )
)
PUBLIC SEm/ ICE ELECTRIC & GAS ) Docket Nos. 50-354 COMPANY & ATLANTIC CITY ) 50-355 ELECTRIC COMPANY ) _ _ . . _
)
(Hope Creek Generating Station, ) . _._ _
Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Motic for Re-consideration of'ALAB-540 and severance from the Consolidation Established by that Decision," dated May 2, 1979, in the captioned
~ matter, have been served upon the following by deposit in the United States mail this 2nd day of May, 1979:
Jerome F. Sharfman, Esq. Dr. Oscar H. Paris Chairman, Atomic Safety and Atcmic Safety and Licensing Licensing Appeal Board Board Panel U.S. Nuclear Regulatory O'.S. Nuclear Regulatory Commission Commission Washington, D. C. 20555 Washington, D. C. 20555 Richard S. Sal:: man, Esq. Mr. Ernest E. Hill Atomic Safety and Licensing Lawrence Livermore Laboratory Appeal Board Panel University of California U.S. Nuclear Regulatory Post Office Box 808, L-122 Cnmmission , Livermore, California 94550 Washington, D. C. 20555 Chairman, Atomic Safety and Dr , W . Reed Johnson Licensing Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Appeal Board Panel Cnmmission U.S. Nuclear Regulatory Washington, D. C. 20555 Cnmmiasion Washington, D. C. 20555 Chairman, Atomic Safety and Licensing Appeal Board Panel Edward Luton, Esq. U.S. Nuclear Regulatory Chairman, Atomic Safety and Commission Licensing Board Washington, D. C. 20555 U.S. Nuclear Regulatory Commission Honorable F. Michael Parkowski Washington, D. C. 20555 Deputy Attorney General Department of Natural Resources and Environmental Control Tatnall Building Dover, Delaware 19901 2353 171
Richard L. Black, Esq. Dr. Paul Mecray, Jr.
Counsel for NRC Regulatory Suita 303 Staff Cooper River Parkway West Office of the Executive Legal North Park Drive Director Pennsauken, New Jersey 08109 U.S. Nuclear Regulatory Commission Dr. John R. Lamarsh Washington, D. C. 20555 68 North Chatsworth Avenue Larchmont, New York 10538 Richard.Fryling, Jr., Esq.
Assistant General Solicitor Mr. Chase R. Stephens Public Service Electric and Docketing and Service Section Gas Company Office of the Secretarf 80 Park Place, Room 7113 U.S. Nuclear Regulatory Newark, New Jersey 07101 Commission Washington, D. C. 20555 Mark L. First, Esq.
Deputy Attorney General State of New Jersey 36 West State Street -
Trenton, New Jersey 08625 _
Mr. David A. Caccia. .
R. D . #2 .
~ Box 70-A ._
Sewell, New Jersey 08080 Peter Buchsbaum, Esq.
Robert Westreich, Esq.
Department of the Public Advocate Division of Public Interest Advocacy 2353 172 520 East State-Street '
Trenton, New Jersey 08625
~
William Horner, Esq.
67 Market Street Salem, New Jersey 08079 .
)
Wam b0bu'a Troy B. Conner, Jr. U n
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE TM ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of )
)
PHILADELPHIA ELECTRIC ) Docket Nos. 50-277 COMPANY, ET AL. ) 50-278
)
(Peach' Bottom Atomic Pcwer )
Station, Units 2 and 3) )
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Motion for Re-consideration of ALAB-540 and Severance from the Consolidation Established by that Decision," dated May 2, 1979, in the captioned matter, have been served upon the following by deposit in the United States mail this 2nd day of May, 1979:
~
Michael C. Farrar, Esq. Dr. Kenneth'A. McCollum chai man , Atomic Safety- College of Engineering-and. Licensing Appeal. Board Oklahoma State University -
U.S. Nuclear Regulatory Stillwater, Oklahoma 74074 Commission Washington, D.C 20555 Ernest O. Salo Professor, Fisheries Research Dr. John H. Buck Institute, WH-10 Member, Atomic Safety University of Washington and Licensing Appeal Board Seattle, Washington 98195 U.S. Nuclear Regulatory Commission Chai' n, Atomic Safety Washington, D.C. 20555 and Licensing Appeal Board Panel U.S. Nuclear Regulatory Dr. W. Reed Johnson Commission Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board Panel U.S. Nuclear Regulatory Chairman, Atomic Safety Commission - and Licensing Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory C e i=sion Marshall E. Miller, Esq. Washington, D.C. 20555 Atemic Safety and Licensing -
Board Panel James M. Cutchin, Esq.
U.S. Nuclear Regulatory Counsel for NRC Regulatory Commission Staff Washington, D.C. 20555 ,'
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 23~53 173
Karin Carter, Esq. Eugene J. Bradley, Esq.
Department of Environmental Philadelphia Electric Company
- Resources 2301 Market Street Commonwealth of Pennsylvania Philadelphia, Pennsylvania 19101 505 Executive House Harrisburg, Pennsylvania 17120 Mr. Chase R. Stephens Docketing and Service Section John B. Griffith, Esq. Office of the Secretary Special Assistant Attorney U.S. Nuclear Regulatory
- General Commission
.. - State of Maryland Washington, D.C. 20555 Department of Natural Resources Tawes State Office Building Raymond L. Hovis, Esq.
Annapolis, Maryland 21401 Stock & Leader 35 South Duke Street Myron Blocm, Esq. York, Pennsylvania 17401 U.S. Environmental Protection Agency Mr. Chauncey R. Kepford Region III, Curtis Building 433 Orlando Avenue 6th and Walnut Streets State College, Pennsylvania 16801 Philadelphia, Pennsylvania 19106 e
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of -
)
)
METROPOLITAN EDISON COMPANY,_ et _al.
) DocRet No. 50-320 -
)
(Thiree dile Island Nuclear ) -
St.ation, Unit No. 2) )
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muanCATE OF sr.af.v1CE I hereby certify that copies of " Licensee's Motion for Re-consideration of ALAB--540 and. Severance frem the Consolidation Establi=hed by that Decision," dated May- 2, 1979, in the captioned matter, have been served upon the following by deposit in the United States mail this 2nd day of May, 1979:
Alan S. Rosenthal, Esq. , Chaiman George F. Trowbridge, Esq.
Atomic Safety and Licensing Shaw, Pittman, Potts & Trowbridge
. Appeal Board 1800 M Street, N.W.
U.S. Nuclear Regulatory Commission Washington, D.C. 20036 Washington, D.C. 20555 ,
Dr. Ernest O. Salo, Professor Fisheries Research Institute, WH i Dr. W. Reed Johnson, Member College of Fisheries Atomic Safety and Licensing University of Washington App,eal Panel Seattle, WA 98195 U.S. Nuclear Regulatory Comission Washington, D.C. 20555 .
Dr. Chauncey R. Kepford Citizens for a Safe Environ =ent Jgrome E~. Sharfman, Esq. , Member 433 Orlando Avenue Atomic Safety, and Licensing State College, PA 16801 Appeal Panel U.S. Nuclear Regulatory Commission Karin W. Carter Washington, D.C. 20555 Assistant Attorney General Office of Enforcemen:
Department of Environmental Edward Luton, Esq. , Chaiman Resources Atomic Safety and Licensing Board 709 Health and Welfire Bldg.
U.S. Nuclear Regulatory Commission Harrisburg, PA 17120 Washington, D.C. 20555
. Ms. Judith H. Johnsrud 433 Orlando Avenue .
Mr. Gustave A. Linenberger State College, PA 16801 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Ccmmission 2353 175 S Washington, D.C. 20555 /2 cv/ [. [ha j
. Troy B. Conner, Jr. [
UNITED STATES OF AMERICA -
NUCLEAR REGULATORY COF2iISSION BEFORE THE ATOMIC SAFETY AND LICENSING APFEAL BOARD n the Matter of TORT" M STATES POhrt CCMPANY, ) .
IT AL. ) Docket No. STN 50-484
) .
'Ty==ne Energy Park, Unit 1)
, )
CERTIFICATE OF SERVICE I hereby cer*4 'y that copies of "7 4 censee's Motion .for Re-consideration of ALAB-540 and. Severance from the Consolidation Es+ akl 4 ched by that Decision," dated May 2, 1979, in the captioned matter, have been served upon the following by deposit in the United States mail this 2nd day of May, 1979: .
=, Ja:nes P . A' *- =a , Esq
- e Rici:a:d S. Sa '-'=n, Esg d a, C2 =4- Assistant A wy Ge=eral At::=ic Safeef a=d M-a-si=g Ap a=' Eca:d Depa_ r ; cf Jus ice U.S. N ' ear .eg % '= f F 4 e-4 m State Capitol Aed ;-, D.C. 20555
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A1=mic Sadety a::d U ~~si=g A= peal Eca=d Po.::te 2, 3::c 64 U.S. N'e'ea: Regula- f F* e< d m TL:::le Lake, Wis---- e : 54889 Nashi=gt:::n, D.C. 20555 Jccalyn Ft: t,eangler Ols::r., Esq 4 e C=. W. Paed J N e Speial Assist === A. .ey General At=::ic Safeef a=d
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING AF'~a.AL BOARD -
In the' Matter of b ROCHESTER GAS AND ELECTRIC Docket No. STN 50-485 3 CORPORATION, ET AL.. .
(Sterling Pcwer Project
~
Nuclear Unit No.- 1). )
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Motion fo::- Re-consideration of ALAB-540 and Severance f=cm the Consolidation Established by that Decision," dated May- 2, 1979, in the captioned matter, have been served upon the following by deposit ir. the United States mail this 2nd day of May, 1979:
Alan S. Rosenthal, Esq. , Chairman
- Dr. George C. Anderson Atomic. Safety and Licensing Appeal Board Department of Oceanography U.S. Nuclear Regulatory Commission University of Washington Washington, DC 20555 Seattle, Washington 98195 Dr. John H. Buck
- Mr. Lester Kornblith, Jr.
- Atomic Safety and Licensing Appeal Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Ccmmission Washington, DC 20555 Washington, DC 20555 Richard S. Salzman, Esq.
- Lex K. Larson, Esq.
Atomic Safety and Licensing Appeal Board 1757 N Street, N.W.
U.S. Nuclear Regulatory Commission Washington,.DC 20036 Washington, DC 20555 Dirk S. Adams , Esq.
Edward Luton, Es q .
- Attorney for Movant Atomic Safety and Licensing Board Ecology Action of Oswego U.S. Nuclear Regulatory Ccmmission Office and P.O. Address Washington, DC 20555 1600 First Federal Plaza Rochester, NY 14614
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