ML19345H106
| ML19345H106 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 04/22/1981 |
| From: | Adler R PENNSYLVANIA, COMMONWEALTH OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8104300505 | |
| Download: ML19345H106 (15) | |
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'c PA 4/22/81 UNIIED STATES OF MERICA NUCLEAR REGUUJORY CDMISSION BEFORE THE AT T IC SAFEIY AND LICENSING BOARD 4 O A
In tM Matter of ) cecmg
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FEIROPOLITAN EDISCN (n@ANY, )
) Ibcket No. 50-2 C APR24gggy :
(Three Mile Island Nuclear ) (Restart) Cma gg -S Station, thit No.1) ) b' 0x*eting &
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l N CDFDEEALTH OF PENNSYLVANIA'S RESPONSE TO 4 6 INIERVEDR STEVEN C. SHOLLY'S FDrION 10 REJECT THE NRC STAFF ENVIRONt4ENIAL APPRAISAL ON IMI-1 RESTART Introduction On March 30, 1981, Counsel for the NRC Staff served on the Board and the parties copias of the NRC Staff's Fnvircrmental Inpact Appraisal (EIA) relating to the proposed restart of Three Mile Island, thit 1.
The intent to prepare this document hc.d been announced by NRC Staff Counsel at the Novecher 9,1979 Special Prehearing Conference. Tr. 373.
On <'pril 9, 1981, intervenor Steven C. Shally n e d the Board to reject the Staff's EIA or to grant permission to raise new contentions.
The Coruonwealth herein responds to Mr. Sho11y's notion and addresses the adequacy of the EIA.
Jurisdiction The Board's first consideration should be whether it has juris-dicticn over NEPA questions in this proceeding. In its March 12, 1980
, "Memorandum on the Need for Preparing a Final Envirot-nen1 Statement of IMI-1" [ hereinafter " March 12, 1980 mecerandum) ,
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the Boa-d expressed streng doubt egarding its jurisA4rHm to consider the NEPA issue, noting that the Board's authority as lic:f.ted by the Comission's August 9,1979 Order and Notice of Hearing. If this Board finds that it has no jurisdiction over the NEPA question, the camm=al th presunes that the Comission will publish a notice of a negative declaration in the Federal Register in accordance with 10 C.F.R. 55 51.7, 51.50(d), and the intervenors will then be entitled to seek jndicini relief. For the reasons stated below, boever, the Or. ms.lth bslieves that this is not the 4pwpdate e course of action. .
In its July 31, 1980 Position Report, at 6, the CWth urged the Board "to decide the question of thether an EIS is required as early as possible in this proceeding to avoid potential further delay in final resolution of the restart petition." The Cammwealth still believes that an exercise of jurisdiction by this Board over NEPA questions, along with the subsequent mmmtic certification to l the Comission, muld ulti:nately produce the unst efficient and orderly i disposition of the issues.
The Board's decision on the question of NEPA jurisdiction should be governed by two general principles. First, it is well settled that 14cmaing boards have an " independent obligation to assure that the i:portant policias of [NEPA] have been protected by the agreed course of action." Consolidated Edison Cocpany of New York, Inc. (Indian Point Nuclear Generating Station, l'ait No. 3), 2 Nuc. Reg. Rep. (CCH) 130,027.03, (1976) (Cccr::ission Mecorandum and Order). See also,
Northern Indiana Public Service Co. , (Railly Generating Station, i
Nuclear 1) AIAB-303, 2 Nuc. Reg. Pep. (CCH) 130,031.06, (1975).
The restart of M-1, over which this Board has jurisdiction, is not exenpt from the Agecy's responsibilities under NEPA. This does not inply that the Board has un14drad jurisdiction over all possible NEPA issues involving M -1. Rather, an analogy should be drawn to the ,
Board's standard for exercising jurisdiction over safety-related issues in this procaading. 'Ihe Board accepted contentions on all safety issues having a ramamable nexus to the M-2 accident, regardless of whether the issue was set forth esplicitly in the Comission's Order and Notice of Hearing. First Special Prehearing Conferece Order, at 14. Similarly, ,
the Board should assune its responsibility to ensure coupliance with NEPA with respect to all envim-mmi issues that have a ramamable nexus to the M -2 accident. Thus, the Board has jurisdiction over all environmental issues that haw changed as a result of the M-2 accidet, or new environmental issues resulting from the M-2 accident.
%md, it is a general principle of NEPA law that, in making a negative declaration, federal aganciaa are obligated to produce an administrative record facilitating judic4al review. In Hanly v.
Mitchell, the Court ruled that NEPA requires " federal agencies to affirmatively develop a reviewable envirmmane=1 record . .. perfurstory and conclusory language simply does not suffice, eve for purposes of l
a threshold heim 102(2)(c) decarminaticn." 460 F.2d 640, 647 (2d Cir. 1972). Accord Hanly v. Kleindienst, 471 F.2d 823 i (2d Cir.1973); Arizona Public Service Co. v. Federzl Power Com. ,
l l 483 F.2d 1275 (D.C. Cir.1973). NRC case law also accepts this concept.
Northern Indiana Public Service Co. , suora, 130,031.06.
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@sent the preparation of an EIS, the parties uust be given some forum to develop an administrative record regarding potential deficienciaa in the NEPA process. This requirement is also expressly recognized in the l
NRC Rules of Practice:
l l In any proceeding in sich a hearing is held for the issuance of a permit, license, or order, or amand=mt thereto j or renewal thereof, where the Director of Nuclear Reactor l Regulation or Director of Nuclear Material Safety and Safe-l guards or their designee, as appropriate has determined that no envi.mtal inpact statement need be prepared
! for the particular action in question, any party to the l
proceeding uny take a position and offer evidence l on the aspects of the proposed action covered by NEPA and this part in accordance with the provisions of Subpart G of Part 2 of this chapter. In such pro-ceedings, the cresiding officer will decide any such matters in controversy acong the parties.
l 10 C.F.R. S 51.52(d) (enphasis added).1 This provision grants the Board jurisdiction over NEPA questions that are within the scope of this proceeding. It may be argued that the Staff's EIA constitutes an l
adequate aMnistrative record on which to base a jMicial appeal of coupliance with NEPA for this agency action. The EIA is limited, however, to the environmental issues defined by the Staff. Mr. Shelly's L
untion asserts that there are additimni areas, not considered by the Staff, that warrant evaluation. Agencies are required to take into l
account all relevant factors on detaMnat 4mn to issue negative declarations. Hanly v. Mitchell, 460 F.2d 640, 648 (2d. Cir.1972).
Thus, the agency "is called upon to review in a general fashion the same factors that would be studied in depth for preparation of a detailed environmental inpact statement." Hanly v. Kleindienst, 1 Proceedings in which ehen1 inpact statements are clearly required, such as construction permit or operating license proceedings, are covered by 10 C.F.R. 5 51.52(a)-(c). Proceedings in which a negative declaration is issued, such as this case, are encocpassed by 10 C.F.R. 5 51.52(d).
471 F.2d 823, 835 (2d. Cir.1972). Caly the ' depth of analysis differs between an EIA and an EIS; the scope of issues considered is the same.
Therefore, absent an order by the Board that the Staff consider these areas in a supplement to the EIA, or an epyvtunity to present evidence on these issues pursuant to 10 C.F.R. S 51.52(d), or an adjudicative ruling that the issues cited by Mr. Sholly are not cognizable in an NRC NEPA review, there will be a couplete void in the administrative record justifying the agency's da 4= inn not to consider these issues. Such a void is likely to produce a remand by a reviewing court, and consequently, additional delay in the final resolution of the 1MI-l restart issue.
Finally, the Cn=rmealth notes that both the Board and the Conmission have, by is lication, recognized the potential applicability of NEPA to this proceeding. In the Order and Notice of Hearingzthe Conmission wrote:
W ile real and substantial concern attaches to -
issues such as psychological distress and others l arising from the contiming inpact of aspects of the Three Mile Island accident unrelated directly to exposure to radiation on the part of citizens living near the plant, the Conmission has not decem4=d whether such issues can legally be relevant to this proceeding. Any party wishing to raise such subjects
! as contentions, or as aspects of separate contentions, should brief the Atomic Energy Act and Nationc1 Environmental Policy Act issues he believes ayytopriate to the Board as part of the contention acceptance process set out in the Conmission's regulations. The Board should then certify such issues to the Conmission for final decision prior to the issuance of its pre-hearing conference order pursuant to 10 C.F.R. 2.752(c),
either with or without its reconmendation on such issues, as it deems appive r late under the circtustances. At the time the Conmission reaches a decision on these issues, it will also consider whether it can and should grant financial assistance to parties seeking to raise these issues in this case.
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Slip op. at 13. (enphasis addad). A close reading of this language suggests cere4 ficae4m to the Cocmission as an alternative to hearing evidence on potential areas of deficiency in the Staff's NEPA analysis for envirnrmmeri issues not related to radiological hazards, such as socioeconand.c inpacts. Only the narrow issue of psychological stress has been certified to the Conmission pursuant to this 1ang" age. Although other contentions raised socioacnr=de i@ acts in general in tM NEPA context, e.g., 'DfIA 8, rulings on these contentions tere deferred by the Board pending staff preparation of the EIA. More inportantly, the Conmission expressed doubts only over the relevance of considering nonradiological mvironmental factors in this proceeding under NEPA.
'Ihis iglies that radiological environmental issues, such as Class 9 accidents and plant separation (both raised in Mr. Sholly's notion),
are clearly cognizable in this proceeding under NEPA. .
For the foregoing reasons, the Cocmonwealth urges the Board to pass on the merits of NEPA issues related to the restart of 'DfI-1.
Such jurisdiction could take a nunber of possible forms. First, tM Board could order the staff to supplement its EIA to consider the additional environmental issues posed by Mr. Sholly and other parties 2 The Cocmonwealth is somewhat puzzled over the status of existing NEPA contentions. Although some of these contentions have been withdrawn voluntarily, e. ., Sholly 12, others are apparently still open pending preparation ot new EIA. These, along with the three new contentions posed by Mr. Sholly based on new information contained in the EIA, are still before the Board for ruling.
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in the current round of filings, 3 as an exercise of its indva at obligation to ensure coupliance with NEPA and the familaHm of an adequate administrative record. Alternatively, the Board could admit contentions and hear evidence pursuant to 10 C.F.R. 551.52(d).
211rd, if the Board doubts hther some of the issues suggested by the parties are legally cognizable under NEPA, it should ask the l Ws to brief these issues. Although the Board can pass on the legality of considering radiological issues, nonradiological issues, such as socioeconomi.c factors, arguably should be certified to the Cocmission.
3 l The r W th suggests additional deficiencies in the Staff's l EIA in the substantive cc m ents that follow.
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. l Substantive Coments In general, the Cnnr==alth shares Mr. Sholly's concerns regarding the adeqta./ of the Staff's EIA, and consequently, the basis for rece-anding issuance of a negative declaration. Adequate coupliance I
with the Coundssion's NEPA regnlaHms (10 C.F.R. Part 51) is a necessary
, prerequisite to M-1 restart, as is coupliance with other NRC regnlaHms.
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l l NEPA case law varies on the substantive standard applicable to the I
issuance of a negative declaration. But it is clear that the Agency
( nest deconstrate that it took a " 'hard look' at the problem, identified t
j the relevant areas of environmental concern, and made a ' convincing case' that the inpact is insignh.ficant." Northern Indiana Public i
Service Co._, supra (quoting Maryland National Cap. Pk. & Pl. Com.
l v. U.S. Postal Service, 487 F.2d 1029, 1039-40 (D.C. Cir. (1973) ).
The Board should assure itself that these standards have been met before ruling that the EIA submitted by the Staff is adequate.
A brief examination of the approach taken to the preparation of l the EIA, as defined by the Staff, is indicative of the daf4ciancia*
in the Staff's analysis:
In detaMning the potential effects of the proposed restart, the Staff re+*ad the envirnrvneral inpact .of operocion of the M station as discussed in the FES for thits 1 and 2. This re-exdnation included an evaluation of whether reviously identified environmental inoacts would m changed in any way should restart be autherned.
The inpacts reported in the 1972 FES are restathlow I
and are followed by the present staff evaluation of the inpacts associated with the proposed restart.
l EIA, at 3. (enphasis added). Essentially, the staff sinply restates the environmental 1:rpacts ider4 f4ad in the sumary and conclusion
. section of the Decenber 1976 FES (NUREG-Oll2, at B-1), and deter =ines that operation of M-1 in itself after restart would not
have significantly different evirnnmmeal inpacts than did operaticn of M -1 prior to the accident. Since the safety-related physical nodi-fications to M-1 required after. the araidant are relatively minor and primarily interior, this point is alnost self-evident. The critical area of analysis overlooked in many cases by the staff was whether estimates of previously idanr4%d evironmmeal inpacts have changed as a result of the M-2 accident, or nore inportantly, whether there are potatial new environmental inoacts of M-1 operation as a result of the M-2 accident. 'Ibe three areas identified by Mr. Sholly, as well as the additional areas of concern noted below, fall into these categories.
Class 9 Accidents 'Ihe rem, wealth concurs in Mr. Sholly's inter-pretation of the Cocmission's statement of Interim Policy on Class 9 Accidents. 45 Fed. Reg. 40101 (1980). It is also notable that the two O
sentences relted upon by the Staff in excluding M-1 from the scope of this Policy Statement were objected to by tw of the four current NRC Cocmissioners. 45 Fed. Reg. 40103, fit. 5.
Plant Seoaration 'Ihe Cermnealth raised a nucher of issues during the litir-. ion of plant separation that deconstrate the need to evaluate the envirorm men 1 inpacts of concurrent thit 1 operation and Unit 2 deconenminntion.
- 1. No analysis has been performed of potential fuel drop accidents in the joint thit 1-thit 2 fuel handling building. Tr. 10,057-59; 10,205.
- 2. No analysis has been performed of the projected total radiation dose from Unit 2 cleanup and thit i restart.
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Counsel for the NRC Staff indicated that this analysis would be pufunad and provided to both the Coexualth and the Board. Tr. 10,185-191. No such report has bec di"aminated thus far.
- 3. Licensee's draft contingency plan provides for onsite storage of r=dinactive wastes from thit 1 and Unit 2 in the same facility. This storage is necessitated in part by limitations on storage in existing licensed burial facilities.
Tr. 10,025-031. The EIA included no analysis of the environmental effects of additional onsite interim waste storage, or of the adequacy of long-term offsite disposal fac414ti as for the conbined wastes from Unit 1 operation and thit 2 cleanup.
This is not intended to constitute a couprehensive list of plant -
separation-related environomtal inpacts. A cmplete analysis of this issue needs to be performed by the NRC Staff.
Socioeconomic Inmacts - As noted earlier, only the narrou consideration of psychological stress was certified to the Cocmission. There are, l
however, a wide range of other sociohc inpacts that resulted from the IMI-2 accident and that have a bearing on the proposed 3MI-l restart.
These include the costs to state and local gpvew-its for increased l
emergency preparedness, the envirnr= meal effects of licensee's alert-notification system, potential adverse effects of evacuation and other protective actions. (e.g. , business dislocation, depreciated property values, loss of pay, decreased tourism, commity disruption, etc.).
11 Again, this is not intended as a complete list. A thorough analysis should be performed by the Staff to 4danHfy all such impacts and to determine whether an EIS is warranted. Surely one of the lessons law frem the M-2 accident is that these inpacts are no longer too remote to consider as potential costs of nuclear power generation. .
Wreover, such soc 4Mc inpacts are clearly part of the " human envimmmm" anevsed by NEPA analysis. See, e.g., Maryland National Cap. Pk. & Pl. Conm. v. U.S. Postal Service, suora,
, 487 F.2d. at 1038-39. Hanly v. Mitchell, 460 F.2d 640, 647 (2d.
Cir.) cert. den. 409 U.S. 990 (1972); Kansas Gas and Electric Co.
(Wolf Creek Nuclear Generating Station, Unic No.1), AIAB 321, 2 Nuc. Reg. Rep. (CCH) 130,061. % (1976).
Construction and Site Develcoment - The Staff concludes sunmarily in this portion of its analysis that "All construction relating to Unit 1 which would cause disturbance of land onsite and of adjacent waters is couplete. No =AA4Hmni construcHm or site development relating to Unit i restart is occurring or will occur." EIA at 4.
This statement is blatantly incorrect on its face. For exanple, Licensee is constructing an interim staging faciHty for purposes of storage of wastes from both Unit 1 and Unit 2. Tr. 10,028-029. The Staff did not analyze the effects of this construction or other construction that may be required to achieve adequate plant separation.
4 i 4 Notably, the " Final Supplement to the Final Envircnmental Statement" for IMI-2 concluded that "there will be no significant ace wnic costs inposed on surrounding conmmities due to operaticn !
of 1MI-2." NUREG-Oll2, at 10-1. ;
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l 12-i Procedural Coments l In addition to the substantive coments listed above, the preparation of the Staff's EIA was notably deficient in terms of the lack of input from the public and other gpwm=it entities. 'Ihe council on F2tvb_- r.al Quality's NEPA inplementing regn1=Hms require the agency to " involve environmental agencies, applicants, 1
and the public, to the extent practicable, in preparing assessments . .. " '
40 C.F.R. 51501.4(b). Similar requirements have been imposed on agencies i
by the Courts in highly controversial cases. In Hanly v. Kleindienst, the Court required the agency, before issuing a negative decadaHm, to "give notice to the public and opportunity to submit relevant facts which might bear upon the agency's threshold decision." 471 F.2d.
823, 836 (2d. Cir. 1972). Of parHenlav interest to M-1 case, the Court comented that: .
parHenlarly where ecocions are likely to be aroused by fears, or rumrs of misinformation, a public. hearing serves the dual purpose of enabling the agency to obtain all relevant data and to satisfy the connunity that its views have been considered.
471 F. 2d at 835. No such effort was made by the Staff to solicit l the views either of the public or of other interested gowmmit l
entities.
Conclusion
'me Cacmonwalth is extremely concerned that deficiannias in the Staff's NEPA review of 'IMI-1 restart will result in additional delay of the final resolution of the restart question. 'Iberefore, the l
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,- Conm:mealth urges the Board to accept jMadiction over the open NEPA issues, in order to ensure NRC coupliance with the goals of NEPA within the context of the restart proceeding.
Re __th11y submitted, I
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lh, BOBERT W. ADLER Attorney for the C - alth e
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INITED SIAIES OF AMERICA NIXIIAR REGUIAIORY 00ttESSICH BEFORE TIE ATCMIC SAFEIT AND LICENSING BOARD In the Matter of )
)
MEm0POLITAN EDISON CDMPANY, )
) Docket No. 50-289
) (Restart)
(Three Mlle Island Nuclear Station, thit No.1) )
u2cinCATE OF SERVICE I hereby certify that ccpies of the attached Cermonwealth of Pennsylvania's Response to Intervenor Steven C. Sholly's & tion to Reject the NRC Staff Emnb - eral Appraisal on EfI-l Restart were served on the persons on the' attached service list this 22nd day of April, 1981. Parties denoted by an asterisk tare served by hand.
All other parties were served by deposit in the U.S. Mail, first class pcstage prepaid.
. G POBERT W. A)LER Attorney for the Cocronwealth l
i
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UtIIUD S2A23 CF AFSICA 20C. EAR RELLCOEU C3t'lSSIQI BEFORE ':HE AITIC SAFE"Y MD I.ICESI'E BCARD In the Patter of )
)
PracPcuTxt EDISat c2fx1Y, ) .
) Dockat :b. 50-289
(':hree Mile Islard !belear ) (Restart)
Station, thic Ilo.1) )
SERVICE IlST George F. tc4 ridge, Esedre Dr. Hrda W. Little Shaw, Pi: .an, Pot:s & t owbridge c Safety and Meansing 3 card Panel 1800 M Street, N.W. 5000 Famitage Drive Washington, D.C. 20006 Pala4 34 . Nord t'arolira 27612 Ms. Marjorie M. Aaced: Docketing and Seriice See"on 1.D. #5 office or cm Secrecan Coatesville, Pemsylvania 19320 U.S. Ibclear Fm?_= tory Ccrcission v.s. Houy S. Keck, tag. Chair =an Anti-tbclear Grous Papresentir.g Ellyn R. Weiss York (RGE) Sheldon, Parren. Roisman & Weiss 245 W. P'-4 M1+h Stree: 1725 I Street, N.W., Suite 506 York, Pecnsylvania 17404 Washi::gton, D.C. 20006 Ms. Frieda Berryhill, C mi"=n Karin P. Shaldon, Esquire (PKE)
'"Mid-* m for thclear Power Sbalrh . Harman. Roi.sman & Weiss Planc Postpor er 1725 I Street, N.W., Suite 506 2610 Grerden Drive Washing:en. D.C. 20006 Wi1=ington, Delaware 198C8 James A. Toirtellotte. Esqdre Mr. Rob e : Q. Pollard Office of the Executive IAgal Director 609 Itn:;:elier Street U.S. :Eclear Re6ul2Cor/t ', ,4 4sion Balti=cre, Mm:flard 21218 Washingt::n, D.C. 20555 Waltar W. C&mn, Esqdre John A. IAvin, Esquire C:nsumer Advocate Assiscan: Counsel Depar :cene of Justice Pennsylvania Public UH1' y Cocznission Strawber:y Sq,.:are,146 noor P.O. Box 3265 Harrisbi. -g, Perr.sylva=ia 17127 Harrisburg, Pemsylvania 17120 Cr. Chatre.sy Keoford Rober: I K % - p, Escuire Judid H. Jotr.srud Assistant Sclic1=r, Cou=c7 cf ::auphin E=vircrz: ental Coalition on Obclear P.r. Box P, 407 Porth Front Street Power Hr:risburg, Pemsylvania 17108 433 Criando Aver:ue State College, Pmfivania 16801 Jchn E. Mi:r.ich, Cm'-- =n Dauphin County Beard of tn-f <sioners j
Mr. Stenn C. Shally Dauphin Coun g Courthouse f.'nico of Concerned Scientists Front and Market Streets 1725 I Street, N.W., Suite 601 Harrisburg, Pemsylvania 17101 Washi=g:ca, D.C. 20006 Jordan D. Qr.dngham EsWe Ms. Louise Bradford Attor..ey for Newberry Township MI Alert T.M.I. Steering Coci::ir.cee 315 Peffer Street 2320 brd Second Street Harrisburg, ?arr.sylvania 17102 Har$ burg, Pecnsylvania 17110
. Ivan W. Sc::ith,' Esquire, C miman Pariin I. Lewis
( Accx::ic Safen and Mcensing Board Paral 6504 Bradford Terrace U.S. thclear Regulaterf t'n'-4 =sion Philadelphia, Perr.sylvania 19149 l Washing =n, D.C. 20555 Jara lee Dr. Walter H. Jordan R.D. 3, Sox 3521 Ar,-ir Safen and I.icensing Board Panel Etters, Demsylvania 17319 381 West Outer Drive Cak Ridge, Tennessee 37830 ':hczsas J. Ge=h.e. ~@e Depu n At:Orney General. Division of Iaw Rocri 316. H00 Rsy:end 3cidevard rewa:k. New Jersey 07102 l
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