ML19347E421
| ML19347E421 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/22/1981 |
| From: | Swartz L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8104270306 | |
| Download: ML19347E421 (17) | |
Text
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Staff 4/22/81 e
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4 h ;g UNITED STATES OF AMERICA t
/l/,, 2 l /gg NUCLEAR REGULATORY COMMISSION
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Isl&r BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ff
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I In the Matter of
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METROPOLITA1 EDIS0N COMPANY,
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(Three Mile Island, Unit 1)
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NRC STAFF RESPONSE TO INTERVEN0R SH0LLY'S MOTION DATED APRIL 9, 1981 I.
INTRODUCTION Steven C. Snolly, an Intervenor in the TMI-1 Restart proceeding, filed a pleading on April 9,1981 entitled " Motion to the Atomic Safety and Licensing Board to Reject the NRC Staff Environmental Impact Appraisal on Tf11-1 Restart or in the Alternative to Seek Leave from the Board to Raise New Contentions" (Motion).
In his fiction, Mr. Sholly argues that the Staff's Environmental Impact Appraisal is defective because it does not address:
(1) the environmental consequences of Class 9 accidents, (2) the potential impact of the clean up of TMI-2 on T!!I-1, and (3) the socioeconomic impacts arising from the restart of Tl11-1. Should the Board deny this portion of his Motion, Mr. Sholly seeks leave from the Board to pose three new contentions related to the Environmental Impact Appraisal.
8104 2 70 3Olv S
The Staff opposes fir. Sholly's flotion in its entirety.1/ The basis for this position are set forth below.
II.
BACKGROUND Pursuant to the Board's Memorandum and Order of September 21, 1979, the Intervenors in this proceeding submitted the contentions they wished to have litigated in October,1979. The Staff discussed each of these proposed contentions in its October 31, 1979 "NRC Staff Brief in Response to Contentions" (Brief).
In this Brief, the Staff expressed its intention, as discretionary matter, to undertake an environmental impact appraisal of the proposed restart of TMI-1.
(Brief at 10,14 and 33.)
In addition, at the Special Prehearing Conference held in Harrisburg, Pennsylvania on November 8-10, 1979, Counsel for the NRC Staff restated the Staff's
" purely discretionary" decision "to conduct an environmental impact appraisal of this action as we understand it."
(Tr. 373.)
On March 27, 1981, the Staff issued its " Environmental Impact Appraisal Relating to the Proposed Restart of Three Mile Island, Unit 1" (EIA).
This document which evaluates the environmental effects of further operation of TMI-1 was served on the Board and all the parties on March 30, l
l 1981.
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On April 15, 1981, the Licensing Board asked that responses to Mr. Sholly's Motion be filed by April 22, 1981.
(Tr.
.)
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III.
DISCUSSION A.
The Staff's EIA Need Not Address the Environmental Consequences of Class 9 Accidents In his Motion, Mr. Sholly contends that the EIA is defective because of "its failure to discuss in a substantive manner the environmental impacts of so-called ' Class 9' accidents...."
(Motion at 3.) As a basis for this statement, Mr. Sholly argues that the Commission's June 13, 1980 Statement of Interim Policy (Statement) entitled " Nuclear Power Plant Accident Considerations Under the National Environmental Policy Act of 1969" (45 Fed. Re,c. 40101(1980)) provides " ample good cause for including c
such a discussion in the EIA on TMI-1 restart."
(Motion at 6.) Mr. Sholly, however, has misread the Commission's Statement.
In its Statement, the Commission instructed the Staff to prepare a discussion of Class 9 accidents "in its ongoing NEPA reviews, i.e., for any proceeding at a licensing stage where a Final Environmental Impact Statement has not yet been issued."
(45 Fed. R_eg. 40101,40103.) The Commission also indicated that "this change in policy is not to be construed as any lack of confidence in conclusions regarding the envi-l ronmental risks of accidents in any previously issued statements, nor, absent a showing of special similar circumstances, as a basis for opening, reopening, or expanding any previous or ongoing proceeding."
(_Id_. )E 2/
In his Motion, Mr. Sholly refers to the same quote from the 5
l Commission's Statement.
(Notionat4.) Mr. Sholly, however, deleted the word "similar" which precedes "special circumstances" in the original Statement. The phrase "similar special circumstances" is of particular importance in understanding the duties imposed on the Staff by the Commission in its Statement.
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This Statement of Interim Policy, by its terms, does not apply to the THI-1 Restart proceeding-and does not require the Staff to perform a Class 9 analysis in its EIA.
The Statement applies to "any proceeding at a licensing stage where a Final Environmental Impact Statement has not yet been issued."
(ld.)
The TMI-1 proceeding, however, is not a licensing proceeding. The licensee, Metropolitan Edison Company, is already in possession of an operating license for TMI-1. The only action pending before this Licensing Board and ultimately before the Commission is whether the suspension of that operating license ought to be lifted.2/ In addition, an environmental impact statement relating to the operation of TMI-1 was issued in December 1972 (reissued as HUREG-0552).
Inasmuch as this proceeding is not at the licensing stage and an FES has been issued, the directives in the Commission's Statement are not applicable in these circunstances.
Even though the TMI-I proceeding is not at the licensing stage and an FES has been issued on the operation of TMI-1, the Commision's State-nent would require the Staff to perform a Class 9 analysis upon a showing that the restart of TMI-1 involved "special circumstances" as defined in the Statement. As noted in the EIA, however, the proposed restart of THI-1 does not involve any such "special circumstances."
(EIA at 12-13.)
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On July 2, 1979, the Commission suspended the TMI-1 operating license and ordered that unit to remain in a shutdown condition until further order of the Commission itself.
(UnpublishedOrder.)
The "special circumstance 3 concept in connection with consideration of Class 9 accidents was first articulated in Offshore Power Systems (Floating Nuclear Power Plants), CLI-79-9,10 NRC 257 (1979).
In that case, the Staff argued that there was no need for a NEPA discussion of Class 9 accident risks unless special circumstances indicated that Class 9 accident risks night be unusually high or of a more different character than for a typical land based nuclear power reactor. The Staff stated that, to date, only three types of special circumstances had been identi-fied:
high population density for the proposed site, a novel reactor design, or combination of unique design and a unique siting mode.
(NRC Staff's Brief in Support of Affimative Finding on Certified Question, at 47, January 12,1979.) Although the Commission did not specifically address the standards developed by the Staff in its decision, it did hold that a Class 9 accident analysis was properly included in the environmental impact statement for the project.
This issue was raised again in the context of a request filed pursuant to 10 C.F.R. 62.206 for the revocation or suspension of the Seabrook construction pemits.
(Public Service Company of New Hampshire (Seabrook Station, iJnits 1 and 2), DD-80-6, 11 NRC 371 (1980)).
In denying the petition, the Director of the Office of Nuclear Reactor Regulation sNRR) stated that t, sass 9 accident analyses are appropriate only wnere one or more of three "special circumstances" is found to exist.
(H. at 377). These are: (1) high population density around the proposed site, (2) a novel reactor design (i.e., other than a light water reactor), or (3) a combination of a unique design and a unique siting mode.
(Id.).
In Public Service Co. of Oklahoma (Black Fox Station, Units 1 and 2),
CLI-80-8,11 NRC 433 (1980), the Concission again addressed the Class 9 issue. There, the Comission discussed "the type of exceptional case that night warrant additional consideration: higher population density, proximity to man-nade or natural hazard, unusual site configuration, unusual design features, etc.. i.e., circunstances where the environ-mental risk from such an accident, if one occurred, would be substantially greater than that for an average plant." (Id. at 434-5) (footnote deleted).
Thus the Coanission, in giving guidance to the Staff, adopted the three prong standard developed by the Staff and presented in Offshore Power Systems and Seabrook, suora.
Af ter these decisions involving "special circunstances" and the need for a Class 9 analysis, the Comission issued its State ent of Interim Policy which identified as "special circumstances" three cases which correspond to the three prongs of the standard: (1) the Clinch River Breeder Reactor ("a licuid retal cooled fast breeder reactor very different from the more conventional light water reactor plants"),
(2) the Perry =an Site (involving high population density), and (3) the floating nuclear power plants ("potentially serious consequences associated with water (liquid) pathways").
(45 Fed. R_eo. 40101). Since the publication of the Commission's Statenent, the Director of NRR has used the three-prong "special circumstances" standard to detennine whether to prepare supplemental Class 9 analyses.4/
e 4j See, e.g., Duke Power Co. (Catawba Nuclear Station, Units 1 and 2),
DD, 13 NRC (January 8, 1981).
In applying this standard to the instant proceeding, it is clear that the restart of THI-1 involves no "similar special circumstances" within the meaning of the Conaission's Statement. ' Absent a showing of special circumstances, an environmental assessner.t of the consequences of a Class 9 accident need not be included in the Staff's EIA relating to restart.
B.
The Impact of Cleanup of Ti1I-2 on the Operation of TMI-1 Should Not Be Included in the Staff's EIA.
Mr. Sholly also argues that the EIA is deficient because it does not " address the potential environmental impacts of the effects of cleanup of THI-'
r the lack thereof) on the operation of TMI-1...."
(Motion at 8).
itates that the " mere proximity of TMI-2 to T!!I-1 makes this a ur.
situation whose environmental risk must be fully i
disclosed by the scaff" and that there "is no other place where such issues are addressed."5/ (flotion at 8-9).
11r. Sholly is cistaken. The issue of the impact of the decontamina-tion of Unit 2 on the operation of Unit I has been raised and litigated in the restart proceeding. Both the Staff and the licensee filed testi-mony on this subject and the witnesses sponsoring the testimony were 5/
Mr. Sholly also states that the Final Progranatic Environmental Impact Statement related to the decontanination of TMI-2 (NUREG-0683) " expressly does not address such issues on the basis that such a discussion is to be found in a ' separate environmental revies'" (Motion at 9). The Staff believes !1r. Sholly is referring to a statement made in HUREG-0683, Section 13.1.1.7 which explains that issues relating to the restart of TMI-1 will be addressed "in a separate environmental review." This does not imply that the Staff intended to discuss Mr. Sholly's part1:ular concern.
' cross-examined by the Licensing Board and the Commonwealth of Pennsylvania on the conclusions reached.E That testimony revealed that the potential impact of Unit 2 on Unit 1 is not like that normally present when two nuclear units share a common site because Unit 2 is shutdown and will remain so for an extended period of time.
Further, the radiological impact outside the immediate area in which decontamination of buildings and equipment is taking place will be minimal because of controlled ventilation, special precautions to be taken which will minimize local airborne contamination, and automatic closure of the exhaust system should the effluent release monitors detect an excessive rate of release. Thus, the risks to the safe operation of TMI-1 from the decontamination activi-ties at TMI-2 are less than the risks from a normally operating reactor.
(Licensee testimony (follows Tr. 10020) at 41-43).
Inasmuch as this issue has been fully aired in the hearing, there is certainly no need for such a discussion to be included in the Staff's EIA.
The specific concern !1r. Sholly raises in his Motion, the use of.the spent fuel pool for both TMI-1 and TMI-2 (flotion at 10), has also been litigated in this proceeding.
Mr. Stoddart, witness for the NRC Staff (testimony follows Tr.10158) stated in direct testimony that the only common point where the atmosphere is in direct communication between Unit 1 and Unit 2 is on the shared fuel handling floor of the fuel handling building. The effect on TMI-1 of an accident occurring in the shared 6f The licensee's testimony was submitted by Edwin C. Fuhrer and Richard J. McGoey (testimony follows Tr.10020). The Staff's testimony was prepared by Phillip G. Stoddart (testimony follows T r. 10158).
area of the fuel handling building during decontamination of THI-2 is specifically addressed in Chapter C4 of the THI-1 Restart Evaluation Report (NUREG-0680). Because the fuel handling building contains an open bay area shared by both THI-l and THI-2, there is a potential that an accident could result in radioactive contamination of the shared area which could spread to the portion dedicated to Unit 1.
Powever, an engineered safety feature ventilation exhaust system which ventilates the TMI-1 portion of the fuel handling floor will be in operation whenever THI-2 fuel movements are in progress and suspension of work in the THI-1 portion of the fuel handling building during such movements will be a procedural requirement. Modifications of the interfaces between the unit-designated areas of the fuel handling floor area, the THI-1 and TMI-2 portions of the remainder of the fuel handling building, and the TMI-1 auxiliary building are being made to prevent an air flow between the buildings and to mitigate the consequences of an accident.
The shared fuel handling area is not required to be used during either normal or emergency conditions at TMI-1. Tnerefore, an accident at TMI-2 during decontamination will not affect TMI-1 through the common fuel handling building.
(Stoddart testimony at 19-23).
C.
The Staff's EIA is Not Rendered Defective Because It Does Not Discuss Possible Socioeconomic Impacts Mr. Sholly contends that the EIA is defective because it does not discuss "possible socioeconomic impacts arising from TMI-1 restart."
(Motion at 10). He argues that, although the Commission precluded the discussion of such issues in the hearing (Metropolitan Edison Co. (Three
Mile Island Nuclear Station, Unit 1), CLI-80-39,12 NRC 607 (1980)), it took no position on the considerat:9n of the issue in environnental inpact analysis.
(Motion at 11).
From this, Mr. Sholly assunes that consideration of socioeconomic impacts should be included in the Staff's EIA. The assumption,
~1e Staff's view, is erroneous.
In its Brief of NRC Staff on Psychological Stress Issues dated October 31, 1979, the Staff set forth its position on the question of whether psychological stress issues or socioeconomic impacts are cognizable under the Atomic Energy Act (42 U.S.C. 192011 ettseq.) or tne National Environmental Policy Act of 1969 (NEPA) (42 U.S.C. 954321 etiseo.). After a thorough analysis, the Staff concluded that neither the Atomic Energy Act nor NEPA require consideration of potential socio-economic impacts for the further operation of TMI-1. The Licensing Board itself, in certifying this question to the Commission, stated its own conclusion that the Staff is not required to consider such issues in an EIS but that the Commission should, -in its discretion, permit the Board to hear the concerns.
(Metropolitan Edison Co. (Three Mile Island Nuclear Station, Unit 1), LSP-80-8,11 NRC 297, 299 (1980)).
Thus, while Mr. Sholly may want the Staff to analyze the potential socioeconomic inpacts of restart, there is no legal requirecent for the Staff to do so. The absence of such analysis does not render the Staff's EIA deficient.
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D.
Mr. Sholly's Three Proposed Contentions Should Not Be Admitt9d As an alternative to declaring the Staff's EIA deficient, Mr. Sholly asks leave of the Board to file three new contentions related to the EIA.
(Motion at 12-13). These contentions assert that (1) the EIA fails to address the environmental impacts of accidents which are beyond the design basis of TMI-1, (2) the EIA fails to address the impact of the decontaM nation of TMI-2 on the operation of THI-1, and (3) the EIA fails to address possible socioeconomic impacts of the restart of TMI-1.
The contentions also assert that these concerns must be addressed prior to the restart of TMI-1.
The Staff would concede that the EIA does not discuss the conse-quences of Class 9 accidents, the impact of decontamination of Unit 2 on the operation of Unit 1, and the possible socioeconomic effects of the restart of TMI-1. These issues, however, have been raised elsewhere in the proceeding and either have been litigated before the Licensing Board or were dismissed prior to the start of the hearing.
Mr. Sholly makes no attempt to, and in fact cannot, demonstrate why these particular contentions should be admitted at this late date.
Mr. Sholly's contentions are late filed and as such must meet the appropriate regulatory standards if they are to be admitted. Section 2.714(a)(1) sets forth five factors to be balanced by the Licensing Board in detemining whether to accept late filed petitions. Late filed contentions are to be considered as late filings to which these standards must be applied.
(Memorandum and Order, January 8,1980, Slip Op. at 7).
The five factors are:
(i)
Good cause, if any, for failure to file on tice.
(ii) The availability of other means whereby the petitiorer's interest will be protected.
(iii) The extent to which the petitioner's participation cay reasonably be expected to assist in developing a sound record.
(iv) The extent to which the petitioner's interest will be represented by existing parties.
(v) The extent to which the petitioner's participation will broaden the issues or delay the proceeding.
Mr. Sholly cakes no attempt to justify his late filing or to caking a showing under $2.714(a)(1).
In any event, it is the Staffs view that the five factors, on balance, do not favor the acceptance of Mr. Sholly's late filed contentions.
It is evident that Mr. Sholly has not cet the first factor, the good cause requirenent.
k' nile Mr. Sholly could not know what would be contained in the Staff's EIA, such knowledge was not necessary to have submitted these particular contentions at a cuch earlier date.
- Indeed, other Intervenors did submit similar contentions in October,1979.
UCS Cortention 20, filed on October 22, 1979, asserted as does Mr. Sholly's Contention EIA-1 that the envirornental consequences of Class 9 accidents should be considered prior to restart. This conten-tion was not admitted to the proceeding.
(First Special Prehearing Conference Order, December 18, 1979, Slio Op. at 26). k'hile the Board did admit certain Class 9 contentions (Id. at 11-17), these contentions a
have already been litigated in this proceeding.E 7/
The licensee's testimony on this subject follows Tr.11047. The Staff's testimony follows Tr.11155.
s Many Intervenors (ECNP, CEA, TMIA, the Aamodts, and Mr. Sholly) raised contentions dealing with the separation of TMI-1 from THI-2.
Although all of the contentions raised were eventually withdrawn or disaissed, the Licensing Board posed Board Question 8 concerning whether decontamination activities at TMI-2 could affect the safe operation at THI-1. This issue is identical to tha one raised by Mr. Sholly in Contention EIA-2. Both the Staff and the licensee filed testimony in response to the Board QuestionN and the issue was litigated in January, 1981.
The Intervenors have also raised psychological stress contentiorcs similar to Mr. Sholly's Contention EIA-3. As Mr. Sholly notes, however (iiotion at 11), the Commission has already precluded the litigation of psychological stress issues.
(CL1-80-39, 12 NRC 607, 608). Therefore, under the Comission's ruling, Mr. Sholly's Contention EIA-3 is not litigable in this proceeding.
All of the contentions Mr. Sholly seeks to have admitted at this time have been raised by other Intervenors at a much earlier date.
Thus, Mr. Sholly cannot demonstrate good cause for his late filing.9/
While Mr. Sholly might be able to show that there are no "other means whereby the petitioner's interest will be protected," he cannot 8/
The licensee's testimony was submitted by Edwin C. Fuhrer and Richard J. McGoey (follows Tr. 10020). The Staff's testinony was prepared by Phillip G. Stoddart (follows Tr. 10158).
9/
Absent a showing of good cause, the burden of justifying the late filing based on the other 12.714(a)(1) factors is greater than where good cause has been shown. Nuclear Fuel Services (West Valley Reprocessing Plant), CLI-75-4, 1 NRC 273 (1975).
=ake the requisite showing under the remaining three factors of 12.714(a)(1). Mr. Sholly's participation on these issues would not assist in developing a sound record; testirony has already been filed on the litigable issues 6:d witnesses have been subjected to cross-examination by the Board and the parties.IEI Further, Mr. Sholly's interest in the contentions has been represented by other parties.
Finally, Mr. Sholly's participation will delay the proceeding. The time to prepare and re-litigate the issues he seeks to raise at this late date would prolong the hearing unnecessarily.
Mr. Sholly cannot demonstrate good cause 'or his late filing.
In addition, three of the remaining four factors under 52.714(a)(1) weigh against admitting the late filed contentions.
IV. Conclusion For the reasons stated above, the Staff opposes Mr. Sholly's Motion dated April 9, 1981. The Staff's EIA is not deficient because the Staff is not required to discuss the consequences of Class 9 accidents, the impact of decontanination of THI-2 on the operation of TMI-1, or the potential socioecono7ic impacts of the restart of TMI-1. Mr. Sholly should not be pernitted to raise contentions concerning those issues at this late date because such concerns have already been raised by other
~~~10/ Class 9 testimony by licensee follows Tr.11047.
Staff testimony on Class 9 accidents follows Tr.11155. Testinony on TMI-1 and TMI-2 separation by licensee follows Tr.10020; testinony on this subject by the Staff follows Tr.10158.
i I
{ t Intevenors and have been either dismissed or litigated in this proceeding.
Mr. Sholly's Motion should be denied in.its entirety.
Respectfully submitted, i
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Lucinda low Swartz IJ Counsel for NRC Staff Dated at Bethesda, Maryland this 22nd day of April,1981.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY C0fE4ISSION BEFORE THE AT011IC SAFETY AND LICENSING BOARD In the Matter of
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METROPOLITAii EDIS0N COMPANY,
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(Tnree 11ile Island, Unit 1)
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CERTIFICATE OF SERVICE I hereby certify that copies of "liRC STAFF RESPONSE TO INTERVEN0R SH0LLY'S MOTI0il DATED APRIL 9,1981" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail system, this 22nd day of April,1981:
- Ivan W. Smith, Esq., Administrative Ms. Marjorie M. Aamodt Judge R.D. #o Atomic Safety and Licensing Board Panel Coatesville, PA 19320 25 North Court Street Harrisburg, Pennsylvania 17106 Mr. Thomas Gerusky Bureau of Radiation Protection Dr. Walter H. Jordan, Aduinistrative Dept. of Environmental Resources Judge P.O. Box 2063 25 Horth Court Street Harrisburg, Pennsylvania 17123 Harrisburg, Pennsylvania 17105 Mr. !!arvin I. Lewis Dr. Linda W. Little, Administrative 6504 Bradford Terrace Judge Philadelphia, Pennsylvania 19149 25 Nortn Court Street Harrisburg, Pennsylvania 17105 Metropolitan Edison Company ATTN:
J.G. Herbein, Vice President George F. Trowbridge, Esq.
P.O. Box 542 Shaw, Pittman, Potts & Trowbridge Peading, Pennsylvania 19603 1800 H Street, N.W.
Washington, D.C.
20006 fis. Jane Lee R.D. 3; Box 3521 Karin W. Carter, Esq.
Etters, Pennsylvania 17319 505 Executive House P. O. Box 2357 Walter W. Cohen, Consumer Advocate Harrisburg, Pennsylvania 17120 Department of Justice Strawberry Square, 14th Floor Honorable Mark Cohen Harrisburg, Pennsylvania 17127 512 D-3 Main Capital Building Harrisburg, Pennsylvania 17120
Thomas J. Germine Deputy Attorney General Division of Law - Room 316 1100 Raymond Boulevard Newark, New Jersey 07102 Allen R. Carter, Chairman John Levin, Esq.
Joint Legislative Committee on Energy Pennsylvania Public Utilities Comm.
Post Office Box 142 Box 3265 Suite 513 Harrisburg, Pennsylvania 17120 Senate Gressette Building Columbia, South Carolina 29202 Jordan D. Cunningham, Esq.
Fox, Farr and Cunningham Robert Q. Pollard 2320 North 2nd Street 609 4tontpelier Street Harrisburg, Pennsylvania 17110 Baltimore, Maryland 21218 Louisa Bradford Chauncey Kepford 1011 Green Street Judith H. Johnsrud Harrisburg, Pennsylvania 17102 Environmental Coalition on Nuclear Power 433 Or1ando Avenue State College, Pennsylvania 16801 its. Ellyn R. Weiss Harmon & Weiss f!s.- Frieda Berryhill, Chairman 1725 I Street,ii.N.
Coalition for Nuclear Power Plant Suite 506 Postponement Washington, D.C.
20006 2610 Grendon Drive Wilmington, Delaware 19808 Mr. Steven C. Sholly Union of Concerned Scientists Gail P. Bradford 1725 I Street, N.W.
ANGRY Suite 601 245 W. Philadelphia St.
Washington, D.C.
20006 York, Pennsylvania 17401
- Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission t
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Washington, D.C.
20555 Lucinda Low Swartz
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Counsel for NRC Staff j
- Secretary U.S. Nuclear Regulatory Commission l
ATTN: Chief, Docketing & Service Br.
Washington, D.C.
20555 William S. Jordan, III, Esq.
Harmon & Weiss 1725 I Street, N.W.
Suite 506 Washington, D.C.
20006
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