ML20028G229
| ML20028G229 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 02/01/1983 |
| From: | Maupin M HUNTON & WILLIAMS, VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | |
| References | |
| ISSUANCES-OLA-1, NUDOCS 8302070540 | |
| Download: ML20028G229 (23) | |
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00CKETED US!IRC February 1, 1983
- 83 FEB -4 Aia:16 i
i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
) Docket Nos. 50-338/339-OLA-1 VIRGINIA ELECTRIC AND )
POWER COMPANY )
(North Anna Power Station, Units 1 and 2)
APPLICANT'S RESPONSE TO CONTENTIONS OF INTERVENORS COUNTY OF LOUISA, VIRGINIA AND THE BOARD OF SUPERVISORS OF LOUISA COUNTY I.
Introduction Virginia Electric and Power Company (the Applicant) files this Response to Contentions of Intervenors County of Louisa, Virginia and the Board of Supervisors of.Louisa County (Contentions). We will first emphasize precisely what the Applicant requests authorization to do, both in this proceeding and in proceeding OLA-2, because careful attention to the scope of each proposal is necessary in order to evaluate some of the contentions made by Louisa County and its Board of Supervisors (Louisa). We will then discuss briefly some of the guidelines customarily applied to determine whether particular contentions are admissible.
8302070540 830201 PDR ADOCK 05000338 C -X3
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2-A. The Application The Applicant has applied under 10 C.F.R. Part 50 for amendments to its North Anna Units 1 and 2 operating licenses that-would authorize the receipt and storage of 500 Surry Power Station spent fuel assemblies at North Anna. " Receipt and storage" is the description of Applicant's proposal that is used in the notice entitled North Anna Power Station, Units No. 1 and No. 2; Proposed Issuance of Amendments to Facility Operating Licenses, 47 Fed. Reg. 41892 (September 22, 1982), and that is the notice pursuant to which this Board was established, see Virginia Electric and Power Co.; Establishment of Atomic Bafety and Licensing Board, 47 Fed. Reg. 49763 (November 2, 1982). This is not a proceeding for cask licensing under j 10 C.F.R. Part 71, or for a route approval under 10 C.F.R. Part 73, or for any other approval of transportation of fuel from Surry to North Anna.
In a separate proceeding (OLA-2), the Applicant seeks amendments to its North Anna Units 1 and 2 operating licenses that would authorize the installation of neutron-
! absorbing racks in the spent fuel pool serving those Units.
1 B. Standards by which contentions should be judged.
Certain types of contentions are inadmissible on legal 1
grounds. Contentions raising questions that are the j-subject of generic proceedings come within this category, 9
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see, e.g., Consumers Power Co. (Big Rock Point. Nuclear Plant), LBP-80-4, 11 NRC 117, 124 (1980), as do contentions that are outside the scope of the proceeding or that seek
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to challenge a Commission rule, see Duke Power Co. (Catawba Nuclear Station, Units 1 and 2), LBP-82-16, 15 NRC 566, 570 (1982), Philadelphia Electric Co. (Peach Bottom Atomic Power Station, Units 2 and 3), ALAB-216, 8 AEC 13, 20 (1974).
Even if a contention is not inadmissible under one of these legal standards, its basis must be set forth with reasonable specificity. 10 C.F.R. S 2.714 (b) (1982) . In Duke Power Co. (Catawba Nuclear Station , Units 1 and 2) ,
supra at 570, the Board said that:
A contention must include a reasonably specific articulation of its rationale --
e.g., why the applicant's plans fall short of certain safety requirements, or will have a particular detrimental effect on the environment.
The Board in Commonwecith Edison Co. (Cuad Cities Station, Units 1 and 2), LBP-81-53, 14 NRC 912, 916 (1981), required "a clear articulation of the theory vE the contention, l sufficient that the Applicant can make an intelligent !
response."
Perhaps the most comprehensive statement of the 4 standards by which contentions must be judged was set out by the Board in Cleveland Electric Illuminating Co. (Perry l
Nuclear Powe.- Plant, Units 1 and 2), LBP-81-24, 14 NRC 175,
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184 (1981), an operating license proceeding:
(1) Have intervenors shown how the contention relates to specific sections of the FSAR or Environmental Report cited in the brief filed by Applicants or Staff?
(2) Is the contention sufficiently specific so that Applicant has .
general notice of the issues on which it may bear the burden of proof at a hearing?
(3) Is there either a reasonable explanation or plausible authority for factual assertions?
(4) If a contention has been thoroughly litigated in the construction permit proceeding and has been challenged on that ground, is intervenor's allegation significantlp diffdrent from the construction permit issue or has it shown sufficiently changed
! circumstances or policies to permit
. relitigation?
(5) If all the facts alleged in the contention were proved, would those l facts require imposition of a licensing condition or the denial of an operating license?
(6) lias intervenor indicated enough familiarity with the subject of its contention sc that its contribution to the proceeding may be expected to be helpful and so that minor short-comings should be overlocked?
In summary, it is not enough that a contention be specific. Some rational basis for it must be articulated by the intervenor. It must give the Applicant sufficient notice. It must not seek to relitigate settled matters.
4 It must be capable, if proved, of affecting the outcome. l We now turn to the contentions raised by Louisa.
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l II.
4 Discussion'of Contentions
,. A. -Contention I - Need for Proposed Action At the outset, the Board should distinguish between
'- the need for additional storage capacity an,d the acceptability of.the particular manner of providing it that the Applicant has selected. Louisa cannotLrationally contend that the Applicant does not need additional spent fuel storage capacity. Louisa acknowledges that the Applicant has "long-term interim storage problems,"
Contentions at 19, and that even if the OLA-1 and OLA-2 proposals are approved, "Vepco will run out of storage space for both Surry and North Anna in 1993," id. Louisa
- points out that under the Nuclear Waste Policy Act of 1982, i a permanent repository will not be available by 1993, id.;
in fact the Act's target date for completion of a repository is 1998. Indeed, Louisa describes the i exhaustion of Applicant's spent fuel storage capacity as
" inevitable." Contentions at 20. Thus, a Contention that the Applicant does not need more storage space is inadmissible simply because it is at odds with Louisa's own assertions.
Nor is a Contention that there is no need for receipt and storage of Surry fuel at North Anna admissible, because it does not raise a question that must be resolved in i
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order to grant or deny the Applicant's application. An example will make this point clear. When an Environmental Impact Statement is prepared in connection with a license
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for a nuclear power plant, the threshold question is not whether a nuclear station is needed; it is whether the applicant.needs additional generating capacity. So in this-case the need question is not whether receipt and storage is needed, it is whether more. storage capacity is needed.
If it is decided that new generating capacity, or new '
storage capacity, is needed, then the question is whether the proposed action is an acceptable way to provide it.
This analysis reveals Louisa's so-called need Contention for what it really is, not a "need" argument at all but an
" alternatives" argument. 'Louisa wants the Applicant to provide the needed capacity through use of an alternative
, that does not affect Louisa. In summary, whether Applicant i
needs to have more storage space available in 1984 or 1985
- or 1986, there can be no question that such capacity is needed. Louisa acknowledges as much, and the Contention should be denied.
To the extent this Contention is in fact an alternatives Contention, it seems to suggest the t
I alternative of postponing the provision of additional capacity. Viewing it in this sense, we believe that action on it should be deferred for the reasons set out in Section ,
D.1 of this Response in connection with other alternatives suggested by Louisa.
In any event, to the extent that this Contention questions the need for the Surry Power Station, and it does precisely that in arguing that "Surry need not be operated at maximum capacity," contentions at 3, it is inadmissible.
That issue was resolved in the early 1970's with the issuance of the Surry Units 1 and 2 operating licenses.
Prior to the issuance of those licenses NRC prepared an Environmental Impact Statement fully addressing the need for the Surry Station. See United States Atomic Energy Commission, Final Environmental Impact Statement, Surry Power Station Unit 2, 145-151 (June 1972). That determination is not to be reviewed in this proceeding.
Section 51.53 (c) of Part 10 says that:
Presiding officers shall not admit contentions proffered by any party concerning need for power or alternative energy sources for the proposed plant in operating license hearings.
If S 51.53(c) is applicable to proceedings for operating licenses, then a fortiori it should control the question in a proceeding for an operating license amendment. Cf.
Northern States Power Co. (Prairie Island Nuclear Generating Plant, Units 1 and 2), ALAB-455, 7 NRC 41, 46 n.4 (1978) and Consumers Power Co. (Big Rock Plant) ,
ALAB-636, 13 NRC 312, 333 (1981) (a reasonable application
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l of NEPA to spent fuel pool amendment does not require consideration of the continued operation of a plant whose operation has already been licensed).
B. Contention II - Consolidation This Contention involves two questions. The first is a procedural question, namely whether the OLA-1 and OLA-2 proceedings should be consolidated in order to achieve the
" proper dispatch of [the Commission's] business and . . . the ends of justice." See 10 C.F.R. S 2.716 (1982). The Board, in its Memorandum and Order of November i
22, 1982, deferred action on Louisa's earlier request for consolidation pending its decision on contentions and on whether to hold a hearing at all in either proceeding.
The second question is a substantive one. Louisa County says that three matters--receipt and storage of Surry fuel at North Anna, expansion of the North Anna pool and shipment of Surry fuel to North Anna--should be considered in a consolidated proceeding "to ensure that the cumulative environmental, health and safety, and common defense and security impacts are properly addressed."
Contentions at 5.
As support for'this Contention, Louisa says that a license to store Surry fuel at North Anna is " insignificant without an accompanying Commission approval to transship the spent fuel." Contentions at 5. This suggests that l
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l some sort of Commission approval to ship must be considered in this proceeding. In fact, however, the Applicant needs no further Commission approval for the act of transporting spent-fuel from Surry to North Anna. The Applicant obtained NRC's prior route approval for the proposed shipments under 10 C.F.R. S 73.37 (b) (7) (1982) on July 28, 1982. Moreover, the Applicant will have a general license under 10 C.F.R. S 71.12(b) to deliver the fuel to a carrier if it uses a licensed cask, and that is what it plans to do. Summary at 50. The truth is, the health, safety, defense and security aspects of shipment from Surry to N6rth Anna are beyond the scope of this proceeding. The scope of this proceeding is limited to " receipt and storage of Surry fuel at North Anna." The conclusion that this Board has no jurisdiction over the health and safety aspects of the Applicant's shipment plans is supported by the holding in a Memorandum and order issued in Duke Power Co. (Catawba Nuclear Station, Units 1 and 2), Docket Nos.
50-413, -414 (July 8, 1982). In its application for an
- operating license for the Catawba Nuclear Station, Duke requested permission to receive and store at Catawba spent ,
nuclear fuel from other reactors in its system. An intervenor sought to raise questions about the safety and environmental acceptability of transportation of spent fuel to Catawba. The Board concluded that, while it "must l
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consider the environmental impact associated with (spent fuel] transport-to, and storage at Catawba," it lacked
" jurisdiction over shipment of spent fuel.from other Duke facilities." Memorandum and Order at 6. Another Board reached the same conclusion in Carolina Power and Light Company (Shearon Harris Nuclear Power Plant, Units 1 and 2), Docket Nos. 50-400 OL, -401 OL, Memorandum and' Order at 57 (September 22, 1982).
Thus, to the extent Louisa contends that the health, safety, defense or security aspects of Applicant's proposed shipments should be dealt with in this proceeding, or that this Board must " approve" such shipments, the Contention is inadmissible. To the extent Louisa contends that the environmental effects of shipping must be considered in this proceeding, the Contention should be deferred for the reasons set out in connection with Subcontention III A.
Louisa also argues that storage of Surry fuel at North Anna, absent expansion of the North Anna pool, would merely shift the site of the storage capacity insufficiency to North Anna. Contentions at 5. And it contends that "NEPA mandates comprehensive censideration of the effects of all federal actions." Id. We believe these arguments should be treated as a Contention that the environmental effects of the proposals in OLA-1 and OLA-2 must be considered
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together. That contention should also be deferred for reasons set out in connection with Subcontention III A.
To the extent this Contention is merely a repetition i of the County's position on consolidation as a procedural matter, action on it should be deferred in accordance with the Board's Memorandum and Order.
C. Contention III - Scope of Environmental Inquiry Required 1, -Subcontention A - The proposed action is a major Federal action significantly affecting the quality of the human environment.
In the single case in which a similar proposal was made, namely Duke Power Company (Amendment to Materials License SNM-1773-Transportation of Spent-Fuel from Oconee Nuclear Station for Storage at McGuire Nuclear Station),
ALAB-651, 14 NRC 307 (1981), the Staff concluded, and the Appeal Board confirmed, that the proposed action would not significantly affect the quality of the human environment and that an " environmental assessment" was adequate. 14 NRC at 317. The Appeal Board also said, however, that whether a particular transshipment proposal will significantly affect the human environment must be decided on a case-by-case basis. 14 NRC at 315. Applicant believes, therefore, that the proper disposition for this Contention is the one followed in commonwealth Edison Co. ,
1 (Quad Cities Station, Units 1 and 2) , LBP-81-53, 14 NRC 912 l
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(1981). That case involved a spent fuel pool reracking.
The Board noted that in no such case, and there had been several, had an environmental impact statement been
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required. 14 NRC at 914. It also observed, however, that such-determinati^ons are to be made on a case-by-case basis.
Id. The Board noted that there was no " explicit allegation of significant impact on the environment" and that in ruling on contentions it did not yet have the results of the Staff's environmental review. Id. at 914-15. The Board, therefore, deferred ruling on the " major Federal action" contention until the Staff's review became available. Id. at 915.
The Quad Cities disposition is the appropriate one here. Louisa has merely made a bald allegation that the proposal, viewed either alone or in conjunction with transshipment and North Anna reracking, is a " major Federal action." Contentions at 6. We do not yet know whether the Staff will treat the OLA-1 proposal as such or will simply prepare an environmental assessment. Pending the completion of the Staff's review, therefore, this Board should defer action on Subcontention III A.
- 2. Subcontention B - The Application fails to consider the environmental impacts of the proposed shipments.
The National Environmental Policy Act, of course, imposes obligations on the NRC, not the Applicant. The
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important question is whether NRC's review of the environmental effects of a' proposal will prove to have been adequate. Again, Louisa does not describe any particular environmental impact that concerns it. In these circumstances, Applicant recommends that consideration of Subcontention III B be deferred until the Staff's environmental review has been completed and the results provided to the parties.
- 3. Subcontention C - Applicant fails to consider the environmental effects of transshipment security 3 measures. _ _ ,
This Subcontention could be treated in the same manner l as Subcontention III B. But the truth is, the Applicant simply has no idea what environmental effects concern Louisa. Mindful of the requirement in Commonwealth Edison Co. (Quad Cities Station, Units 1 and 2) , supra, 14 NRC at 916, that an intervenor should state "a clear articulation of the theory of the contention, sufficient that the Applicant'can make an intelligent response," the Applicant recommends that this Subcontention be dismissed.
- 4. Subcontention D1 - Applicant has not considered the environmental consequences for Louisa County of a North Anna shutdown.
This is a curious Subcontention. Louisa wants the Board to ignore the effects of a loss of full core reserve l at Surry on the Applicant--and on the county where the Surry Power Station is located--but to consider carefully
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the erfect on Louisa County of a loss of full core reserve at North Anna. Still, the Applicant believes that the thrust of this Subcontention is sufficiently clear and recommends that consideration of it be deferred until the Staff's environmental review is completed.
- 5. Subcontention D2 - Applicant has failed to consider the environmental consequences if spent fuel must remain at North Anna after the end of North Anna's operating life.
This Subcontention is inadmissible, because the availability of long-term high level waste disposal facilities is the subject of a current Commission rulemaking, see Public Service Electric and Gas Co. (Salem Nuclear Generating Station, Unit 1), ALAB-650, 14 NRC 43, 68-69 (1981) , Duke Power Co. (Catawba Nuclear Station, Units 1 and 2), LBP-82-16, 15 NRC 566, 579 (1982). Indeed, the Commission has instructed its Boards not to address such issues in individual proceedings, see 44 Fed. Reg. 61372, 61373 (October 25, 1979).
- 6. Subcontention E - Applicant's environmental analysis impermissibly segregates its total plan by separating its treatment of receipt and storage at North Anna, transshipment and reracking of North Anna.
Applicant's response to this Subcontention is the same l
l as its response to the environmental aspects of Contention II.
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J D. Contention IV - Alternatives
- 1. Background.
The law applicable in this area is clear. If the Staff should correctly conclude that Applicant's proposal is not a " major Federal action significantly affecting the quality of the human environment" and that only an environmental assessment is required, then it is
] unnecessary for the Staff or the Board to explore alternatives to'the proposed action. puke Power Co.,
(Amendment to Materials License SNM-1773-Transportation of Spent Fuel from Oconee Nuclear Station for Storage at McGuire Nuclear Station) , ALAB-651, 14 NRC 307, 321-22 (1981); Portland General Electric Co. (Trojan Nuclear Plant) , ALAB-531, 9 NRC 263, 266 (1979). Thus, if the Staff prepares an environmental assessment in this proceeding and this Board approves that course of action, none of the Subcontentions' set out under Contention IV has any place in this proceeding. We recognize that the Board cannot determine whether an environmental assessment is adequate until the Staff's environmental review is i complete. We believe, then, that it would be appropriate to defer consideration of some of the Subcontentions Louisa
- I has made on this subject. Some, however, merit denial now.
We shall deal briefly with each.
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- 2. Subcontention A - Aluminum or temporary racks.
Consideration of this Subcontention should be !
deferred.
- 3. Subcontention B - Constructing a new pool at Surry.
This Subcontention should be denied. The facts cited by Louisa as to the cost of a new pool and the long time i
required to bring it on line are consistent in every respect with the Applicant's conclusion that this is not a reasonable alternative. Put another way, even if Louisa can prove what it alleges, it would not affect the outcome of this proceeding. See Cleveland Electric Illuminating Co. (Perry Nuclear Power Plant, Units 1 and 2), supra, 14 NRC at 184.
- 4. Subcontention C - The dry cask option.
't Consideration of this subcontention should be deferred.
- 5. Subcontention D - Foreign reprocessing.
This Subcontention should be denied. The only basis for it cited by Louisa is a statement made by an employee of the United States office of Science and Technology Policy. The entire quotation is as follows: -
Marcum indicated that there were no .
impediments to U.S. utilities contracting l
, to have spent fuel reprocessed in foreign 1 I plants, but his understanding was that there was currently no surplus capacity available.
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" Bring back Buy back, " Nuclear News, 60-61 (October 1982).
(Emphasis added.) The very quotation relied on by Louisa
-as its sole basis for the Subcontention refutes its suggestion that foreign reprocessing is a reasonable alternative.
- 6. Subcontention E - Extended burn-up.
Consideration of this Subcontention should be deferred.
- 7. Subcontention F - Operation at reduced power.
This Subcontention should be denied, because it raises the question of the need for the power produced at the Surry Power Station.
- 8. Subcontention G - Shutdown of Surry.
This Subcontention should be denied for the reason set out above in connection with Subcontention F.
- 9. Subcontention H - Floating canisters.
Consideration of this Subcontention should be deferred.
- 10. Subcontention I " Buy-time alternatives."
There are four aspects to this Subcontention.
Consideration of thoce numbered 1, 2 and 3 should be deferred. Number 4, which is to operate Surry at a reduced capacity, should be denied for the reason set out in connection with Subcontention F.
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- 11. Subcontention J - Long-term alternatives.
The thrust of this Subcontention is that this proceeding cannot be disposed of unless the Applicant's plans for dealing with spent fuel during the period after the benefits of transshipment and reracking are exhausted have been comprehensively considered. That is precisely the argument made by the intervenors in the Duke Power Co.
transshipment proceeding. The answer, of course, is that the proposals in OLA-1 and OLA-2 have independent utility regardless of the Applicant's plans for producing more spent fuel storage capacity after 1990. That point is settled as a matter of law. Moreover, granting the amendments sought in OLA-1 and OLA-2 will not foreclose the agency's ability to reject plans for the post-1990 period.
Louisa's sole representation is that "Vepco must still develop additional interim storage capacity to bridge the gap between exhaustion of the North Anna pool's capacity t
and the availability of a federal repository to receive spent fuel." Contentions at 20. That is true. But it has nothing to do with this proceeding. Because of the clear guidance in Duke Power Co., the Board should deny this l Subcontention.
- 12. Subcontention K - Comprehensive alternatives. l This Subcontention has four aspects. Numbers 1, 2, I and 4 should he deferred. Number 3, which is to reduce 1 l
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temporarily Surry's capacity, should be denied for the reasons set out in connection with Subcontention F.
E. Contention V - Transportation Hazards
- 1. Subcontention A - Transshipment is inimical to the public health and safety.
Under this heading, Louisa County asserts four different Subcontentions, and one of those (number 4) has six subsidiary aspects. Each of these Subcontentions deals with health and safety aspects of transportation, and each is inadmissible in this proceeding for reasons set out in connection with Contention II and should be denied.
- 2. Subcontention B - The Application does not adequately address the: environmental effects of the proposed shipments.
This Contention is essentially the same as Subcontention III B, and its disposition should be the same, namely deferral until the Staff completes its
- environmental analysis.
- 3. Subcontention C - Independent quality assurance review.
This Subcontention goes to the health and safety i
considerations of transshipment. For reasons set out above i
i in connection with Contention II, it is beyond the scope of i
this proceeding and should be denied.
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1 F. Contention VI - Louisa County Spent Fuel Ordinance The Bottrd's jurisdiction extends to questions arising under the Atomic Energy Act of 1954 and the National Environmental Policy Act of 1969. Louisa does not say how the existence of the Ordirance should affect the Board's determinations under these laws, and we can think of none.
The Board should be advised that the Ordinance is the subject of a law suit brought by the Applicant against Louisa County in the United States District Court for the Eastern District of Virginia. The Applicant has filed a motion for summary judgment contending that the Ordinance violates the Supremacy and Commerce Clauses of the United States Constitution. Louisa's reply is due soon.
This Contention should be dismissed.
III.
Discovery In the foregoing responses, we have recommended that
, consideration of several Contentions be deferred until the Staff's environmental review is complete. We urge that discovery nonetheless~ proceed on these matters now so that l
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. o there will be no unnecessary delay if any of these Contentions is subsequently admitted.
Respectfully submitted, VIRGINIA ELECTRIC AND POWER COMPANY By /s/ Michael W. Maupin Michael W. Maupin, Counsel l
Of Counsel Michael W. Maupin James N. Christman Patricia M. Schwarzschild Marcia R. Gelman HUNTON & WILLIAMS P. O. Box 1535 Richmond, Virginia 23212 Dated: February 1, 1983 i-4
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l CERTIFICATE OF SERVICE I hereby certify that I have this day served Applicant's Response to Contentions of Intervenors County of Louisa, Virginia and the Board of Supervisors of Louisa County upon each of thI persons named below by depos,iting a copy in the United States mail, properly stamped and addressed to him at the address set out with his name:
Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Chief, Docketing and Service Section Sheldon J. Wolfe, Chairman Atomic Safety and Licensing Board Panel U ., S . Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Jerry Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. George A. Ferguson School of Engineering Howard University 2300 5th Street '
Washington, D.C. 20059 Daniel T. Swanson, Esq.
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 J. Marshall Coleman, Esq.
Beveridge & Diamond, P.C.
1333 New Hampshire Avenue, NW Washington, D.C. 20036 James B. Dougherty, Esq.
3045 Porter Street, NW Washington, D.C. 20008
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23-Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 .
Atomic Safety.and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555
, By: /s/ Michael W. Maupin Michael W. Maupin, Counsel for Virginia Electric and Power Company Dated: February 1, 1983 m e - -n--+c, , w -e,--