ML20006B525

Responds to 891212 Request for Status Rept on NRC Licensing Activities at Plant,Response to Comments by Two Constituents Re Facility & NRC Response to Several Senate Colleagues on Procedures Used by Commission in Licensing Proceeding

ML20006B525
Person / Time
Site:	Seabrook
Issue date:	01/04/1990
From:	Parler W NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	Cohen W SENATE
Shared Package
ML20006B526	List: ML20006B525 ML20006B529
References
CON-#190-9653 CCS, OL, NUDOCS 9002050027
Download: ML20006B525 (7)

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.= %k. UNITED STATES.- NUCLEAR REGULATORY COMMISSION n ~' 5 [ WASHINGTON, D. C. 20N4 January 4,1990 3 3 i i \\ i The Honorable William S. Cohen United States Senate i Washington, D.C. 20510 q

Dear Senator Cohen:

4 f p I have been asked to respond'to-your December 12, 1989 letter j in which'you request the following: (1) a status reporteon i . a1 response l NRC licensing activities regarding-Seabrook; (2) to comments by.two of your,constituentsoregarding:Seabrook; and (3) a. copy of'the.NRC's response;to;several of"your-d Senate colleagues.concerning the procedures usedeby~the l Commission in:the Seabrook licensing proceeding. I.am pleased,to-provide you with the, requested information. [ First, regarding'yourirequest for a status report on the' Seabrook Licensing procee 1: on-November 9, 1989, an. Atomic Safety andrLicent doard issued a lengthy opinion: =i which resolved, in favo. the licensee,. emergency: planning: 1 l issues relatingsto the'> tchusetts; portion of the emergency planning zone. 'In ear; 1 pinions the Licensing Board had-e c determined that:all ot. .ssues. relati;.g to the facility 1had - L been satisfactorily ad.. Therefore,:in itsLNovember;9 j opinion the Licensin, ard authorizedithe: issuance'of a' , full-power operating' license for the Seabrook facility. Prior to the issuance of this~decisionithe Atomic Safetyiand: Licensing Appeal. Board;hadcremanded severallissues-back:to i: the Licensing' Board for'further. hearing.- The, Licensing-Board- ~

concluded thatuthese1remandsEdid not bar issu'ance'of the

_j i: full-power, operating: license. !In a follow-up order issued on ? November 20, 1989,1the Licensing Board providedia detailed-l L explanation ofcitstreasoning of whyJoperationishould be: permitted.during:the pendency of the: remands.. 1 r-l: ~UnderENRCiregulations,La1 Licensing Board: decision authorizing. full-power operation does notibecome effective,upon11ssuance. E The commission conductscan'"immediate' effectiveness"' review 1 l of the* LicensinglBoard's? decision: to' determine' whether1the y ' plant 1should be permitted:to operate during-the pendency.of ,i t L administrative appeals of'the1 Licensing Board's decision.1 a The: Commission: has received thel views ofothej partiesl to the - i Seabrook; proceeding on~whetherothe. Licensing Soard's.decisioni. 5 L should be made'immediately: effective.. The Commission ~has; .i [' announced thatJit will not make a decision 1on.the.Lmatter-until January 18, 1990 at;the earliest.- In the meantime, i x bfh[M O ., J t

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1 - Hon. William S. Cohen 2 l 1 E lawsuits have been. filed-in the United States Courtiof l. Appeals for the District of Columbia circuit challenging' l various-rulings in the Seabrook proceeding and requesting that the Court bar the NRC_from making its immediate i effectiveness decision at this time.' l With respect to the concerns expressed by.your~ constituents -in.the two letters, the issues they: raise relate;to matters ' being adjudicated._in'the.Seabrook' proceeding. As such,1they constitute ex parte matters as defined in the Commission's_ 1 L regulations 7 See 10 CFR S 2.780. _Accordingly, Lit 1s not appropriate for the_ Commission ~to. comment on.these issues at'- l this time. With respect to the issues raised by your_ Senate colleagues, _ they also raised issues'directly related to the ongoing'. Seabrook proceeding. Accordingly,. their letters were also ~ viewed as ex parte communications-under the Commission's . regulations 7 Therefore, the. Commission concluded it was-inappropriate to address their concerns. t As required by our regulations, yourlletter and-the l'etters- . of your constituents are being served on the parties to the, Seabrook proceeding and;will be-placed;in'.the.public-record l_ offthe proceeding:in the Nuclear Regulatory Commission'st Public Document Room. Sincerely,' < William,C. Parler Genera 1ECounsel.

Enclosures:

As stated cc: Seabrook Service List [ i t f .[

. --~_. -~. j Ja w ary 4, 1990 i i o The Honorable William S. Cohen l United States Senate Washington, D.C. 20510

Dear Senator Cohen:

l I have been asked to respond to your December'12,'1989 letter in which you request the following:-(1) a status report on NRC licensing activities regarding.Seabrook; (2)-a response to comments by.two.of your constituents regarding Seabrook; and (3) a copy of the NRC's response.to several of- .your-Senate colleagues concerning the. procedures used by-the Commission in the Seabrook licensing proceeding. -I am pleased to provide you with the requested information.

t First, regarding your' request for a status' report on the.

Seabrook Licensing proceeding on. November 9, 1989, an-Atomic Safety and Licensing Board-issued a lengthy opinion which resolved, in favor of the licensee, emergency. planning issues relating to-the Massachusetts. portion of~the emergency planning zone. In' earlier opinions-the Licensing Board had. determined that all other' issues relating to.the l facility-had been satisfactorily resolved. Therefore,.in 4 L its November 9 opinion the Licensing Bo!ird authorized.the, issuance of a-full-power operating license for the Seabrook-facility. Prior to-the issuance.of this decision-the: Atomic j 1: -5520: Cohen 2.txt 3 W# T l FC l % 1, i%4 if b \\ / W _ o M _ !: L NAME TRotbschikd JFitzge$ald [ DATE ' 01/3 M $01/3/lh 01/k /IS7 [3Y $- I f 'm m up ' Mw & l 4 D l b ~

_ _ _ _ ~ _ _ - - - - l [, starg% i UNITED STATES 4 .p ' ' 't - NUCLEAR REGULATORY COMMISSION ~* 3 W ASHINGTON, D. C. 20605 k...... 1 November 22, 1989 i CHAIRMAN j Senator Edward'M. Kennedy United States Senate ( Washington, D. C.- 21510 j

Dear Senator Kennedy:

I i I have. received your letter'of Noven'ber 3, 1989, co-signed by-Senator Kerry and Representatives Mavroules and Markey, in l which you request the Commission's views on a number of issues concerning the Nuclear: Regulatory-Commission's regulations governing emergency planning for nuclear power plants.. These-- issues-are addressed in a'.recent' decision of the Atomic Safety and Licensing Appeal Board in the ongoing'Seabrook' adjudicatory-- proceeding. Public Service Com an Station, Units 1 and 2), AC H -927,.y of New Hampshire:-(Seabrook J NRC ( H U ).- The ? Commission is presently reviewing ACU-922,..and11s considering' the questien certified to the-Commission in that' decision, 'Because the questions.you raise' concern: issues.in the Seabrook [ I l adjudicatory proceeding, the Commission cannot comment on: ~ -these issues at this time..See 10 C.F.R. Sec. 2.780.--When the Commission has decided the issues-beforeiit, weLWill-i promptly provide you with a copy.of the< Commission's decision. Commissioner Curtiss. did not. participate lin' th'e preparation of-this letter. i LSincerely, 4 'k g. Kenneth

arr, cc:

Seabrook Service List r [. p(Et,t 2,. =

a g .J i, , JOHN KERRY %1Ritts $tatts,$tDatt @c g l WASHINGTON DC 20510 -i November 3, 1989 l The Honorable 3enneth L Carr Chairman U.S. Nuclear Regulatory Commission Washington DC-20555

Dear Mr. Chairman:

T Wearewritingtoexpress-severalconcernsregardingNRb-: regulations-on emergency response plans ~for nuclear power' plants. As you know, recently the Atomic =S'afety and. Licensing; k 0 Appeal Board acknowledged to'the Commission-its-inability to-interpret NRC regulations-k what " reasonable _ assurance (of ade10 CFR 50,47 (a)-(1):-) governing. -l 4 -means:as it relates-to emergency quate protective measures" q planning.. In doingEso, it: H y is obvious to us that the Appeal Board has shown its ' inability to comprehend what standard governs emergency: a -{ = planning review. 'i This statement troubles us;for several reasons'..First, it demonstrates that ten-. years.after Congress; clearly R mandated the;NRC to adopt. emergency planning: standards,.the Commission hastbeen approving. plans and nuclear operating-licenses without' remotely understanding-the-fundamental standard by which-it:is-to judge-such plans.- To that end, we strongly-request an immediate explanation from you on:why L this-uncertainty regarding an issue so important.as emergency planning is: surfacing at this late date. 'Second,,in raising this question,-the1 Appeal 1 Board. O concluded that. emergency planning hasia:1 esser rolesin= l ) prctecting public safety:than siting and engineering design features. The Board characterized. emergency planning:as a' "second tier" safety provision not tied to the requirement of. " adequate protection" (section--182 of the Atomic = Energy Act of the'1980 NRCtAuthorization Act.)- We strongly: disagree l with this: interpretation ty the Board.. Furthermore, asJyou a know, over the years the Commission has repeatedly'and explicitly assured us in Congress that' emergency planning is i a-primary component to ensuring the health and safety of,the-public in the event of a nuclear mishap. i For example, in-1983 the Commissioners expressed their. view on~the;importance-of emergency planning before the: 7Wij ((u= W PD

1 ii 7 i ,o N i '2 l L L 1 p Senate Subcommittee on Nuclear Regulations of the Environment [ and Public Works Committee. Senator Simpson the. Chairman of f (_ the Committee at the time asked the NRC the following ~ . questions ? l To:what extent are the NRC's current emergency t planning requirements directly related to protection of the public~ health from radiological risk, and therefore deemed preemptive of local. l requirements on'those areas? .He received the following response from the NRC l I The fundamental objective of ' the NRC's emergency ~ planning. regulations is.to enhance protection lof. l L' public health andLaafety in the event of-a radiological ~ emergency. This; objective was: explained by the. Commission ~at the time of;the proposed emergency planning rule: "The proposed i rule is predicated on the Commission's considered' L judgement in~the7 aftermath of1the accident at Three I Mile Island that safe siting and. design-engineered features:alone do_not: optimise. protection of the public-health and' safety...The' accident showed clearly that the: protection provided by: siting and engineered safety _ features must be boletered by'the ability'to take'protectivalmeasures during the ' course of an~ accident"; L Additional statements issued over the-years /by the NRC' I have echoed _similar sentiments onotheLimportance of emergency planning. .Mr. Chairman, given the uncertainty' create'Lby the-d Appeal. Board's recent. decision and~given'what we have. . understood up until~now to to:a clear Commission view, we -would like to receive.your' assurance that.theLNRC_still views emergency planning as;a1"first tier" requirement of the. Atomic Energy Act. We are'further concerned thatithe NRC~may contemplate, or even' rule (as -thel Atomic Safety and Licensing Board 1has in the Seabrook case-ALAB-922 n.37)'.thatiemergency.plansi for a i site are adequate as long as,they' represent the "best i efforts" of the utility or sponsoring' state under the circumstances of the'particular site. fit seems. frightfully clear.to usithat under thiairule,' review of emergency ij response plans would be offlittle benefit. In fact, based on that~ scenario, utilities would be guaranteed an operating license regardless of how serious thecrisk:could-belto:the surrounding' populations. Surely this is-not the intent of the Commission.

+ x_ 4 3 We recognize that this issue, is at the core of the Appeal Board's uncertcir.ty stated above.- To.that end, we { await with great interer,t your development of;the precise standard-governing emergency planning review. In that regard, we would appreciate your assurance that "best efforts" in no way governs that standard.. Lastly, there'is-one final issue that-relates to emergency planning standards that needs clarification. It is our view that the purpose of an effective emergency. plan is to enhance the safety of the public; in_othercwords, to reduceithe dose of radiation that they may be exposed to in the event of a nuclear accident. We are-confused, however, by contradicting statements'made by the Commission on this issue. In~a 1987 rulemaking. governing utility sponsored-emergency plans.the Commission stated: emergency plans are-n~ valuated for adequacy without reference to numerical dose reductions which might be_. accomplished,...every emergency plan.is to be. evaluated for adequacy on its own merits, without reference to the specific dose reductions which might be accomplished < q under the plan or to the capabilities of any other plan. q y On the other hand,T the Commission has said in'the Shoreham decision, 24 NRC 22, 30, that emergency: plans must ] 11 provide " reasonable and feasible dose: reductions under-the-circumstances." We strongly believeLthat dose: reductions must.be taken into consideration when-evaluating the effectiveness of an emergency plan. Your clarification on 1 this issue would be' helpful -i 3 The health, safety;and welfare of citizens.. surrounding nuclear power plants-in the United States?and of course-the citizens near the Seabrook Nuclear. Power Plant are,.as you', .know, our utmost. concern. . Your ability-to fully' address and' clarify cur concerns will'be;very helpful in our. complete understanding of the Commission's view on emergency _

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planning.= We look' forward to your prompt response to all'.of-R our concerns, q Sincerely, ' gtd f N cholas M vro gohn F. Kerry FM k QEdwardJ.'Mtrkey Edward M.. Kennedy h I

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o,,. UNITED STATES E c, ; NUCLEAR REGULATORY COMMISSION - '{ WASHINGTON, D. C. 20066 - %,,,,,+ NOV 2 8.1989 CHAIRMAN The Honorable Gordon J. Humphrey United States-Senate Washington, D.C. 20510

Dear Senator Humphrey:

'I have. received your letters of November.14 and 19, 1989, in which you expressed concerns about the Atomic' Safety'and Licensing. Board's recent . decision regarding~ emergency-planning,iPublic Service Company of New- - Hampshire. (Seabrook-Station,< Units' I and 2). LBP-89-32, .NRC - ,1989).- and the Commission's decision that-it, rather: than the Appeal BoaFd.(will consider all applications for stay of;the Licensing Board's. authorization of a full power operating license for Seabrook.. Unit 1. Because the questions you raise concern issues-in the Seabrook ~ adjudicatory proceeding :it is not appropriate for the' Commission.to coment on -these ' issues.at this time. See 10 C.F.R.,i 2.780. However, after the Commission-

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has. decided the11ssues M fore it;-we will~ provide-you'with a copy:of the Comission's decision.. l Cosnissioner.Curtiss did not participate 1n the preparation of this' response. ~ Sincerely.c 3 .Kenneth C~. Rogers Acting Chairman cc: Seabrook. Service List ~ \\ q q l .#~ y i. ot D y J

_ ~ - - - 0 4_ O. Q 1 poness manom l . niimgg massa m m,r o r 23:=. EINUd hlEEI%CIIElf = '* " J"' J *a"" WASHINGTON, DC 20510 ' f November.14, 1989-The Honorable Kenneth M. Carr Chairman U. S. Nuclear Regulatory Commission Washington, DC 20555

Dear Mr. Chairman:

I was astonisheduto find on page 569:of the Atomic Safety and Licensing Board's (ASLB) Partial Initial Decision on Seabrook that the ASLB was, in effect, ignoring.four contentions with regard-to the.New Hampshire. Radiological Emergency Response Plan which were remanded by the2 Atomic Licensing Appeal Board last week. The ASLB' saids "The Board has carefully read-ALAB-924' [the Appeal Board's decision]',' evaluated the' remanded issues, 4 and studied the Appeal'Doard's directions-to this Board. We concluded that those. issues.and directions do'.not preclude the-immediate issuance -of an operating license for the-s Seabrook Station." 1 l I cannot recall a more disturbingsdisregard for the protection of public health and safety'in'the Seabrook a proceedings. ALAB-924 was. issued on-November-7.~ It'is a-71 page document. The-contentions which were remanded--- A sheltering the beach popul'ation,. evacuation of handicapped people and otherstwith "specialuneeds",fand:the safety of school children--are complex and important. It seems inconceivable-that, in less than.'two days, the ASLB was able to'" carefully read"=the' order, " evaluate _";the remanded issues, " study" the Appeal' Board's directions'and 4 come to the conclusion.that the. contentions should not l preclude an operating license. Inasmuch as the adequate resolution of:these: contentions will directlytaffeet the(safety ot' New Hampshire residents, I-i insist that the Commissioniupholdedue process.in,its. administrative 1 proceedings.. In my view,..the issues raisediby -Appeal Board last week must be: resolved:to assure the. safety _ of the public. I ask that the Commission: ensure: that:the contentions remanded last week are resolved,after: thorough' and deliberate review before an operating license Jis : issued. 4 Sincerely yours, h t h h0) b h.}p h Gordon . Humphrey, US L OEG,E -Q om.. . in w,:=

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7. .i. i d N'[. GORDoN J. HUM *HREY ' _m Juneww a il. pensen memons ' ') 58' "amg,g ""*"* um ao rusuc -- j a.= BuitedJtates,5cnate-i ' '** "a=","4?JT =" WASHINGTON, DC 20610 J November _19,-1989: The Honorable Kenneth M. Carr i -Chairman Li U. S. Nuclear Regulatory Coma.'.asion Washington', DC-20555

Dear Mr. Chairman:

j 1 Sixty-seven years Ago,.with, Rome.in a.' state of-sio r,.

t Benito Mussolini ~was called upon to head a:new-government.

j BoardingJa train in Milan on:his way to the, capital', j Mussolini said to the Station Master,.-"I~want to depart exactly on time;.from now on everything must. function? Et perfectly." ^ j The Commission's November;16th order which< effectively-vacated the Atomic Safety and' Licensing, Appeal Board from- ^ further consideration.of. issues relating to the authorization of a full power license for~the-Seabrook: Nuclear; Power ' Station is morellike'a diktat from Il Duce than a ') deliberative decision from;a regulatory body _ charged-with'. protecting.the health and safetynof the.Americanopeople.' _ It. i was especially-disturbing-to read that-the Commission made. 1 L this decision "in-the interests of efficiency-and' i' i. effectiveness..." MussoliniEwould have'liked"theJ Commission's attitude. q I would remind the Commission that that there areEmany.. d interests involved in the Seabrook-proceedings and youtare. 1 l obliged to r_espect them all. " Efficiency a'nd effectiveness" l should-not-be the-standards.against which crucial': decisions affecting the: health andfsafety of thousands.of people.are 't judged., Regulatory proceedings--are generally:not. efficient,. j ~ nor should they be, especially;when protection of:"the public 4 is in the balance.- ~ ~ a ] - U l The Commission's amputation of.'the-Appeal Board is ] L especially significant'in light'of the. Board's recent, O l remanding of four serious and important contentions' lodged: i l against the New: Hampshire evacuation plan. 'I will"be pushing for a full-blown Congressional. investigation.into,this, matter-q .in the next session. A Sincerely, j p l} TT.) $JlGT M El ordon-J Humphrey,'USS oi= sama i., m 36 04 73 3 E m..

1 t Ncaer c. 'o,,- UNITED STATES o NUCLEAR REGULATORY COMMISSION \\ *..*,o#} [ wAswiwarow, o, c. nossa - NOV i 8 -1989 CHAIRMAN s I The Honorable John F. Kerry United States Senate -i Washington, D.C. 20510 3

Dear Senator Kerry:

-I have received your letter of. November 15, 1989i in'which you expressed-concerns about the Atomic Safety and Licensing Board's:(ASLB), handling of-an Atomic Safety and Licensing Appeal Board remand and the ASLB's subsequent-authorization of-a full-power operating; license for Seabrook., 7; ' Because the questions you raise concern issues in the'Seabrook ' adjudicatory. proceeding, it is not appropriate for:the Commission:to comment ~on these: issues at this time. See 10 C.F.R. 9 2.780. ' However,iafter the Cosmiission-' has decided the issues 3 fore it, we willr providenyou with a. copy. of the.; ~ Commission's decision.: Cosuiissioner Curtiss did not-participate ini the preparation.off.this-response. a f . Sincerely.. j dALAS Kenneth C. Rogers- [ Acting. Chairman ] ~ f cc: Seabrook Service List l t b' ?

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0:05. :" 2022242417-50 W*'18513A l NICA0LAs Mavt0VLt8 93 3,,,,,e. i em ocac, es.aeaanweem ans,. as, ; pea te : 1 01."l0. Congress of tfje Miteb4tates A*a.. sm. ......,p. Douse of Representatibes ~~= . /. C.. m.e Easb(ngton. BC 20515 Y'O weeman tem essutt-thagens - 3 32 have neve 4 p 311. (303)338 4080 'I November 15, 1989 1 1 The Honorable-Kenneth M.'Carr .i Chairman U.S. Nuclear Regulatory Commission ,l washington, D.C. 20555: 'j

Dear Mr. Chairman:

We'are extremely: dismayed over'the recent decision of the Atomic-Safety and. Licensing Board ( ASLB) : authorizing. a; full-powet -license for-the. Seabrook Nuclear Power P1 ant. This decision wil: not only have f ar-reachingf mpacts on then people ~ of! Massachusetti: i .and New Hampshire, but-it calls:into question'the NRC's-- interpretation of.due process and its commitment toJfaithfully q l. execute:its regulatory responsibilities. Indeed, today's decision has-broad implications for'all-future licensing. decisions nationwide. On ~ November ' 7th, the Atomic Safsty and, Licensing. Appeal Boart 4 remanded.certain' issues concerning emergency planning:to the Commission for'further action.L : The Appeal Board' told: the ASLB tc reconsider the adequacy of plans for evacuating; people:with special needs, ~ sheltering the beachgoing population, and ensurinc,* the= safety of schoolchildren.. Nevertheless, within a two-day? period of the Appeal Board's remandJ the ASLB authorized the-issuance of a full-power 1icense for the plant, leaving these L ' critical ~ issues of emergency preparednesc unanswered. This hast-and ill-advised: action did.notJeven provide the parties involved in the. appeals process with anoopportunity to' comment upon'the s concerns identifled.by:the. Appeal-Board.- o l -- In our November 3rd letter to you1(copy attached)', we requested clarification of:an-issue raised by-the Appeal Board, regarding the-standards governing emergency planning.for..the New Hampshire and the' Massachusetts communities within the 10-mile y^ 3y a j ? ..-------.....-~--L--------

Y h f To date, the Commission hss.not-offered to us or to the EP2. Appeal Board any explanation or elaboration on these emergency ?reparedness standards. 'One can only assume that the ASLB. believes emergency preparedness standards to ha unimportant er- . Nothing could be-further-unrelated to:the licensing process.We cannot comprehend how the Commission could from the truth.. consider affirming the ASLR ruling authorizing the issuance of a r license to-a nuclear power plant without a full resolution' of all. emergency preparedness issues., I The people living near the Seabrook facility. deserve the Forging ahead with a full power l maximum protection possible. license at this = time is a disservice to these-residents, :and it l raises serious doubts concerning.the NRCfs ability to protect the. L public in the' event of a. radiological emergency. We are deeply disturbed with the ASLB's attempt to circumvent the administrative-sppeal mechanism that-was established'to into the licensing process. We believe.that l onsure public input this action represents-a flagrant disregard for proper procedure-and for statutory!1ntent.. Consequently, we have. asked the-congressional committees with oversight. cf.the Commission's activities to initiate an-immediate review of recent decisions. relating-to the Seabrook plant. I We urge the Commission to postpone any further. consideration of. licensing the Seabrook Nuclear: Power Plant-untillall questions raised by the Appeal Board have been fully addressed, and:until 1 the Agency's appellate process on all emergency-planning issues o has been completed. Ne lookiforward'to your prompt response. Sincerely,- 4 Nicholas Mavroules - House of; Representat iv s Y_ Edward M. Kenn y John F._. Kerry. /. U.S. Senate .S. Senate h j ) h I 4 Patrick J. Leahy Howard M. lStfenbaum U.S. Senat< wg-g.--ow +.~.n. .fw, ,w-e----we,,,.v_ ,.,,,-,--..e- ,#w. e,-w.m.,,--w, -.e-,--,e,-,-

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Don Edwards Barrisy Frank; House of Representatives House ofLRepresentatives YEnnd5y / o /tieorggHoch5rueckner se of Representatives House of Representatives ) All ht b - W W Mel Leivine Edward J. Darkey ( House of Representatives-House of-Representatives-tM p. g,g j 63 m. = L_cTosb 1 I .Fanc op Pa ta Mode ' Repbese tatives Hou o' epresentatives. k ( h P m ie4 et retc.or - Gerry pludds House of Relresentatives Housef R Representatives = L WW u l Ron Wyden. House of Representatives i i .l* _ _ _j}}