ML20040A988
| ML20040A988 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/20/1982 |
| From: | Cutchin J, Goldberg J, Gray J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8201230038 | |
| Download: ML20040A988 (20) | |
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UNITED STATES OF AMERICA 7
NUCLEAR REGULATORY CGiMISSION 2
BEFORE THE COMMISSION In the Matter of
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METROPOLITAN EDISON COMPANY, ET AL.
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Docket No. 50-289
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(Restart)
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_3 NRC STAFF'S REPLY TO PARTIES' COMMENTS ONf i
1 WHETHER COMMISSION SHOULD DEFER RESTART DECISION L/
UNTIL ISSUANCE OF LICENSING BOARD'S OPIflION ON OPERATOR CHEATING INCIDENTS James M. Cutchin, IV Counsel for NRC Staff Jack R. Goldberg Counsel for NRC Staff Joseph R. Gray Counsel for NRC Staff Januah 20, 1982 i
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TABLE OF CONTENTS PAGE
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I.
INTRODUCTION.................................................
1 II. NRC STAFF'S REPLY C0MMENTS...................................
2 A.
Position of Intervenor Aamodt............................
3 B.
Position of Intervenor TMIA.............................
6 C.
Position of Intervenor UC5...............................
13 D.
Position of Licensee.....................................
14 i
III. C0NCLusION...................................................
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TABLE OF CITATIONS PAGE i
JUDICIAL PROCEEDINGS Friends of the Earth, Inc. v. U.S., 600 F. 2d 753 (9th Cir. 1979)...
8 People Against Nuclear Energy v. NRC; No. 81-1131, (D.C. Cir.
1982)....................................................
1 NUCLEAR REGULATORY COMMISSION PROCEEDINGS Metropolitan Edison Co., et al., Docket No. 50-289 (Three Mile Island, Unit 1)
CLI-79-8, 10 NRC 141 (1979) (August 9, 1979 Order).............
7, 8, 10, 13 CLI-80-5, 11 NRC 408 (1980) (March 6, 1980 Order)..............
13 CLI-81-9, 14 NRC (1981) (August 20, 1981 Order)............
1 (Commission's November 30, 1981 0rder).........................
1 CLI-81-34, 14 NRC (1981) (December 23, 1981 Order).........
1 (Commission's January 11, 1982 0rder)..........................
1, 2 LBP-81
, 14 NRC (August 27, 1981 Partial Initial Decision).............................)..(.......................
7, 10, 13, 14 LBP, 14 NRC (December 14, 1981 Partial Initial Decision)........................).(....................
1,2,4,5, 9, 10
i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of
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METROPOLITAN EDISON COMPANY, ET AL.)
Docket No. 50-289
)
(Restart)
(Three !!ile Island Nuclear Station,)
Unit 1)
)
NRC STAFF'S REPLY TO PARTIES' COMMENTS ON WHETHER COMMISSION SHOULD DEFER RESTART DECISION UNTIL ISSUANCE OF LICENSING BOARD'S OPINION ON OPERATOR CHEATING INCIDENTS I.
INTRODUCTION In its Order dated November 30, 1981, as modified by its Orders cated December 23, 1981 and January 11, 1982, the Commission invited comments, inter alia, on whether the Commission should defer its decision on restart of TMI-1 until the Licensing Board has issued its opinion on the implications of the operator cheating incidents.
Pursuant to those orders, comments on this question were filed by the NRC Staff,1/
-1/
The comments filed by the Staff on January 13, 1982 as well as these reply comments of the Staff are limited to the question posed by the Commission as to a deferral of any restart decision until issuance of the Licensing Board's opinion on operator cheating incidents.
The Staff has not addressed in its comments the separate matter of the imparL cn TMI-1 restart of the January 7, 1982 judgment of the Court of Appeals for the District of Columbia in People Against Nuclear Energy v. NRC, No. 81-1131.
1 Intervenors Aamodt, Three Mile Island Alert (THIA) and Union of Concerned Scientists (UCS), / the Commonwealth of Pennsylvania, and the Licensee.
Dr. der the Commission's Order of January 11, 1982, replies to the parties' comments on whether the Commission should defer its immediate effectiveness decision are to be filed on January 20, 1982.
In accordance with that Order, the NRC Staff's responses to those comments submitted by the Aamodts, THIA, UCS and the Licensee are set forth below.3_/
II.
NRC STAFF'S REPLY COMMENTS Intervenors Aamodt, THIA and UCS urae that the Commission defer its decision on THI restart until the Licensing Board issues its opinion on operator cheating, arguing, in essence, that the importance to safety of operator training, testing and licensing, and general policy considerations require such deferral and that, in any event, there is no practical need for a prompt Commission decision on immediate effectiveness.
In contrast, Licensee urges that the Commission not defer its immediate effectiveness 2/
Although the comments of the Aamodts, TMIA and UCS were apparently filed on January 13, 1982, the Staff had not received copies of those comments from the Intervenors as of Friday, January 15.
Copies of those parties' comments were requested fron, and provided by, the Licensee, however, late on the afternoon of January 15.
-3/
The Staff agrees with, and will submit no response to, " Commonwealth of Pennsylvania's Connents on the Effect of the Reopened Operator Ch: sting Hearing on the immediate Effectiveness of the ASLB Partial Initial Decision on Plant Design and Emergency Planning" (January 11,1982), in which the Commonwealth concurred in the Licensing Board's recommendation (Partial Initial Decision, December 14,1981,12021) that TMI-l be limited to operation at no greater than five percent of design power prior to the issuance of the Board's decision on the operator cheating incidents.
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decision and that the Commission consider now whether to permit operation at up to 100% of design power on the grounds that the Licensing Board's recommendation of a five percent power limitation is not,iustified by developments in the reopened hearing on cheating.
The positions of these parties are addressed seriatim.
A.
Position of Intervenor Aamodt Intervenor Aamodt's bases for urging that the Commission defer its decision on immediate effectiveness with regard to restart of TMI-1, are that:
1 (1) The Licensing Board considered the cheating incident to raise doubts about the evidence developed in the restart proceeding 4
on Licensee management integrity, the training and testing program and the numbers, competence and integrity of licensed operators and the Commission, therefore, should not rely upon the conclusions in the Licensing Board's August 27, 1981 partial initial decision on management issues until the Board has had the opportunity to modify those conclusions basegj on the facts developed in the reopened hearing on cheating;-
(?) the facts developed in the reopened hearing on cheating are contrary to the safe Licensee management;5pperation of TMI-1 by the present and (3) as a practical matter, postponement of the Commission's decision on immed e effectiveness will not result in substantial delay Intervenor Aamodt's first argument does not consider the fact that the Licensing Board itself recommends restart and operation of TMI-1 up to five percent of design power pending issuance of its decision on
-4/
"Aamodt Comments that Support Postponement of the Commission Decision on Restart to Receive the Opinions of the Board and Parties Concerning the Issues of the Reopened Hearing on Cheating,"
January 9,1982 (Aamodt Comments), p. 2.
Sj Id., pp. 3-4.
6/
Id., p. 4.
U i l cheating. The Licensing Board's recommendatien in this regard, made in recognition of the importance of the issues being examined in the reopened hearing, is based on the Board's finding that
[o]peration at no more than five percent of design power level would facilitate testing of many nuclear safety devices and systems but would essentially eliminate the possibility of an accident having serious consequences for the public health and safety (Partial Initial Decision, December 14,1981,12021) i and that such operation would be very short-term with the understanding that TMI-1 would be shut down if the result of the reopened proceeding does not favor operation (Partial Initial Decision, December 14, 1981,12022).
Thus, Intervenor Aamodt's concerns that the Licensing Board's previous conclusions may be invalid and may be affected by the evidence developed in the cheating proceeding have been fully considered and accounted for by the Licensing Board and have resulted in the Board's recommendation of significant limitations on any operation permitted prior to the issuance of the Board's decision on operator cheating.
Moreover, although Intervenor Aanodt alleges that evidence developed in the reopened hearing en cheating indicates that TMI-1 l
cannot be safely operated by the present Licensee management, such allegations are unsupported by citations to the reccrd of the reopened proceeding.
In the Staff's view, a Commission determination to defer a deckion on THI-1 restart cannot reasonably be based
.. on one party's conclusory and unsupported assertions as to what unidentified evidence in the reopened hearing establishes.E Finally, Intervenor Aamodt argues that the Licensing Board's decision in the reopened hearing should be issued in early February 1982 so that postponement of the Corrmission decision on immediate effectiveness until issuance of the Licensing Board's opinion should not result in substantial delay. Contrary to this assertion, the Licensing Board itself projects that its decisien in the reopened hearing will not issue until March or April of 1982.8/ Thus, a postponement of a Commission decision on immediate effectiveness, as proposed by Intervenor Aamodt, will result in a greater delay in the Commission decision than that intimated by Intervenor Aamodt.
Practical considerations to one side, however, there is, quite simply, no need for the Commission to delay its decision on immediate effectiveness. As indicated in the Staff's initial comments on the question as to whether the Commission should defer its immediate 1
-7/
Intervenor Aamodt states that Licensee admits that its management was " woefully inadequate and deliberately negligent in testing and certifying" operators to the NRC, citing Licensee's Proposed Findings of Fact and Conclusions of Law on Issues Raised in Reopened TMI-1 Restart Proceeding (January 5,1982), Paragraph 413.
(Aamodt Comments,p.3). This is a mischaracterization.
In fact, Licensee did not admit that its management was woefully inadequate or that it was deliberately negligent, although Licensee did candidly acknowledge that, in the past, its proctoring on internal examinations was not adequate, that it had not formalized its certification procedures for NRC operator license examination candidates, and that, in one instance, it had certified a candidate without simultaneously informing the NRC that such candidate had been involved in misconduct.
8_/
Partial Initial Decision, December 14, 1982, 12014.
_ effectiveness review, it is the Staff's view that the Licensee is entitled to a prompt decision on whether the Commission's shutdown order is to remain immediately effective once the concerns which prompted that immediately effective shutdown order have been resolved.9/ With regard to THI-1 management, those concerns have been resolved by the Licensing Board in a manner sufficient to permit at least limited operation without awaiting the Licensing Board's additional decision on the cheatingincidents.5/ The Commission, therefore, need not and should not postpone its decision on immediate effectiveness.
In summary, Intervenor Aamodt's arguments for postponement of the Commission's decision on immediate effectiveness are without merit and provide insufficient basis for the Commission to defer such decision until issuance of the Licensing Board's opinion on the cheating incidents.
.B.
Position of Intervenor THIA Intervenor TMIA bases its position that the Commission should defer its restart decision until after the Licensing Board issues its decision on the cheating issues on the following arguments.
(1) Permitting restart before resolution of the cheating issues would be arbitrary, capricious and an abuse of the Comission's discretion.
9/
See NRC Staff Coments on Whether Comission Should Defer Restart Teiision Until Issuance of Licensing Board's Opinion on Operator Cheating Incidents, January 13, 1982, pp. 5-6, 8-9.
10/ The question as to whether the Comission's concerns related to plant design and procedures, unit separation and emergency planning have been satisfactorily resolved will be addressed in the Staff's imediate effectiveness comments to be filed on January 28, 1982.
. (2) As a matter of " judicial policy," in order not to cause TMIA "to attempt to obtain court relief in order to preserve the status quo" (TMIA Comments at 7), the Commission's decision on restart should be deferred.
(3) The Licensing Board's decision recommending restart up to five percent of design power is seriously deficient and must nut be used as a basis for authorizing such restart.
(4) Neither the Licensee nor the ratepayers would suffer economic injuries if the Commission defers its decision on restart.
(5)
Evidence presented in the reopened proceeding on cheating indicates serious health and safety issues if restert is permitted.
For the reasons set forth below, the Staff submits that none of TF11A's arguments, individually or in combination, warrant the Commission's deferring its restart decision until after the issuance of the Licensing Board's decision on the cheating issues.
1.
Arbitrary, Capricious, and an Abuse of Discretion T!!IA argues that a Commission authorization of restart before the issuance of the Licensing Board's decision on the cheating issues would be inconsistent with the Commission's own Order of August 9,1981 (CLI-79-8,10 NRC 141) which required certain concerns to be adequately resolved before restart, and, therefore, that such Commission action would be arbitrary, capricious, and an abuse of discretion.
TMIA Comments at 1-4.
To the contrary, however, a Commission decision that restart can be authorized before resolution of the cheating issues, based on the Licensing Board's August 27th and Decembe-14th partial initial decisions (PID) is, in fact, a decision that those PIDs
4 sufficiently resolve the Commission's concerns expressed in its August 9thOrdertoallowrestartupto5%ofdesignpower.E As such, that decision on restart would be entirely consistent with, and indeed in accordance with, the Commission's August 9th Order.
Furthermore, as the Staff pointed out in its January 13th Comments, the pendency of the reopened hearing on cheating does not constitute a legal bar to the Commission's deciding now whether the immediately effective shutdown order for THI-l should be lifted. flRC Staff Comments at 9-10.
More specifically, as t:e noted, similar action by the Commission in permitting the Rancho Seco facility, shut down following the TMI-2 accident, to resume operation despite the pendancy of a hearing was found to not be "... arbitrary, capricious, an abuse of discretion, [or) otherwise not in accordance with law."
Friends of the Earth, Inc. v.
U.S., 600 F.2d 753, 754 (9th Cir. 1979).
2.
" Judicial Policy" Reasons TMIA argues that a restart order would affect its rights so significantly that it would be forced to attempt to obtain judicial relief.
TMIA Comments at 7.
TMIA states that "it seems more than likely" that a Commission decision authorizing restart prior to the resolution of the cheating issues would be considered by the courts to constitute final agency action and therefore be subject to judicial review M. at 6.
In essence, therefore, TMIA's argument is that if the Commission permits restart now, TMIA believes it would seek and obtain judicial review of that Commission action Tt11A does not argue that Commission action in authorizing restart would leave the litigant without
-11/ See the NRC Staff Comments of January 13,1982, at 6-9 for a more detailed discussion of this point.
an effective remedy but, instead, makes the novel argument that the Commission should not act now because, if it does, TMIA will have an effective judicial remedy.
There is no sound reason why the Commission should defer a restart decision simply because THIA believes it could seek and obtain judicial review of a Commission decision at this time.
The Staff submits that Ti11A has presented no policy reason why the Commission should defer a restart decision in light of a unanimous Licensing Board decision that the pendency of the unresolved operator testing and licensing issues shodd not be a bar to the restart of THI-1 and the short-term operation of that facility at up to five percent of design power.
PID, December 14, 1981, 12021.
3.
The Licensing Board's December 14, 1981 Decision THIA next argues that the Licensing Board's decision recommending restart up to five percent of design power is deficient because the Licensing Board ha: not sufficiently articulated its reasoning for that decision.
TMIA Coments at 7-8.
To the contrary, the Licensing Board explained that Dr. Jordan believes that restart at full power is permissible " based on the various short and long-term commitments and requirements as discussed throughout this decision." December 14, 1981 PID at 12020 (ec;hasis add'd).
Thus Dr. Jordan would permit restart and operation at full power based on the record supporting the December 14th PID.
Dr. Little would authorize restart but limited to no more than five percent of design power.
Id. at 12021. Both Dr. Jordan and Dr. Little " agree that operation at five percent of design power poses no threat to the public health and safety under the proposed conditions..."
M.at17023. The " proposed conditions" to which they refer are those of 1583 of the August 27th PID.
See PID of December 14, 1981 at l
M2020-2023. Those conditions, in turn, are based on the record supporting the August 27th PID.
Chairman Smith joined Dr. Little's position, resulting in a unanimous Board decision determining that restart at up to five percent of design power, subject to the conditions set forth in $583 of the August 27, 1981 PID, was not barred by the pendency of the reopened proceeding. PID, December 14, 1981, 12023.
TMIA's assertion that the Board's decision lacked sufficiently articulated reasons is simply incorrect and is not supported by a close reading of the Board's PIDs.
4.
The Absence of Economic In,iury TMIA argues that neither the Licensee nor its ratepayers will suffer economic injury from defferel of a Comission decision on restert. Whether or not they are right about that, the Staff submits that a prompt Commission decision on restart is in the public interest and that as soon as the Commission's concerns about restart are adequately resolved (see CLI-79-8, 10 NRC 141), a decision ought to be issued. As the Staff discussed in its January 13th Comments, the Commission management-related concerns have been sufficiently resolved to permit restart at up to five percent of.!esign power. NRC Staff Comments, at 6-10.
The Commission, therefore, need not and should not postpone its decision on restart.
5.
The Reopened Proceeding TMIA asserts that the "most compelling reason" why the Commission should defer its restart decision until after the resolution of the l
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, cheating-related issues raised in the reopened proceeding is that the evidence presented in that reopened proceeding " raises grave health and safety concerns..." TMIA Conments at 10. The Staff submits that TMIA is incorrect in this regard.
On the merits of TMIA's arguments concerning the evidence presented in the reopened proceeding, the re-opened record does not raise the
" grave health and safety concerns" which THIA asserts.
Rather, in the Staff's view, nothing in the reopened record justifies continued prohibition of restart and operation of TMI-1.El However, the reopened record is not yet before the Commission for review and the Staff will, therefore, limit its argument on the evidence in the reopened record to the specific conclusions TMIA draws from that evidence.
See TMIA Comments at 11-13. Those conclusions are, for the most part, improperly taken out of context arf unsupported by the evidence, including the testimony specifically cited by TMIA as supporting its conclusions (and which is attached to TMIA's Comments).
For example,El TMIA claims that the evidence indicates that cheating at THI is widespread and accepted.
TMIA Comments at 11. The overwhelming evidence, however, is that cheating was limited (Staff R/ The Staff position as to the reopened hearing has been presented to the Licensing Board in the "NRC Staff's Proposed Findings of Fact and Conclusions of Law on Issues Raised in the Reopened Restart Proceeding," filed January 15, 1982.
-13/ The Staff will discuss here only some of TMIA's erroneous conclusions.
Those not discussed are equally unsupported by the evidence.
_. Exs. 26, 27 and 28; Ward, ff. Tr. 25,274, at 2-3) and not accepted at TMI (see generally the testimony of Licensee witnesses Arnold (ff.
Tr. 23,590), Hukill (ff. Tr. 23,913), and Ross (ff. Tr. 24,127), and Staff ifitness Ward (ff. Tr. 25,274).
TMIA erroneously claims that Licensee's management may have believed it was constraining the NRC's investigation into cheating. TMIA Comments at 12.
To the contrary, the uncontradicted testimony of both Licensee and Staff witnesses was that Licensee's management did not intend to interfere with or constrain in any way the Staff's investigation into cheating. See generally the testimony of Licensee liitnesses Arnold (ff. Tr. 23,590) and Hukill (ff.
Tr. 23,913) and Staff Witness Ward (ff. Tr. 23,274).
TMIA also asserts that the record shows that the NRC has taken insufficient steps to detect cheating on future NRC examinations. TMIA Comments at 12.
In contrast, the evidence establishes that the Staff has developed a formal quality assurance procedure for grading examinations which specifically includes a review to detect cheating.
Staff Ex. 25 (Examiners Standard ES-109); Collins, ff. Tr. 25,109, at 2-4.
The Staff also has increased the spacing of examination candidates end now reovires 100% proctoring of examinations.
Tr. 25,124-27; 25,165-66 (Collins).
Taken toqcther, these improvements in examination administration give the Staff a high degree of confidence that it will detect blatant cheating. Tr. 25,127-28 (Collins).
The Staff submits that TMIA's " sampling of the evidence presented" in the reopened proceeding (TMIA Comments at 12) is so selective and taken out of context that it distorts the evic'ence as a whole. TMIA has presented no
.. reason, based on the record of the reopened proceeding, why the Commission should defer a restart decision until the Licensing Board decides the cheating issues.
C.
Position of Intervenor UCS UCS bases its arguments that the Commission's decision on restart of TMI-1 must await the Licensing Board's decision in the reopened proceeding solely on its erroneous apparent belief that issues related to the adecuacy of operator training were reopened by that Board. That error is fatal to the UCS position.
In its Partial Initial Decision (Procedural Background and Management Issues) dated August 27, 1981 the Licensing Board found that the Licensee's training of operators was adequate and that the Licensee has complied with the Commission's August 9,1979 and March 6,1980 Orders insofar as they relate to training. 1276. Only issues related to operator testing and licensing were left open.
1584, n. 63. Moreover, as the Chairman of the Licensing Board clearly stated in explaining the Board's rulings on issues to be considered in the reopened proceeding:
So although we will permit, under our tentative ruling, a limited inquiry into the substance of the flRC exams, it is only for the limited purpose of testing whether the purposes of the exam can be defeated.
We most particularly do not want a detailed inquiry into whether the exam content is correctly designed to test operators on their general competence, or relitigatjg of the overall issue of the adequacy of training.
Tr. 23,128.-
-14/ See also the Licensing Board's Memorandum and Order on October 2, 1981 Conference of the Parties Relative to Reopened Proceeding dated October 14, 1981.
, Thus, Intervenor UCS's arguments that the Commission's decision on restart must await a Licensing Board decision in the reopened proceeding are totally without merit.
D.
Position of Licensee The Staff agrees with the Licensee that the Commission's decision on restart should not await the Licensing Board's decision on the issues consideredinthereopenedproceeding.NI However, the Staff disagrees with the Licensee on whether the Commission should authorize operation of TMI-1 at power levels greater than 5% of its design power level before the Licensing Board issues its decision in the reopened proceeding.
As the Licensing Board noted in its Partial Initial Decision (Procedural Background and Management Issues) dated August 27, 1981, it omitted frem that decision any conclusions of law respecting operator testing and licensing pending inquiry into the matter of cheating on the NRC operatnr license examinations.
1584, n. 63.
Therefore, until the Licensing Board issues its decision in the reopened proceeding, the Commission does not know the Board's recommendations related to operator testing and licensing for operation of TMI-1 at power levels greater than 5% of design power. Although Licensee offers its opinions on the Board's reasons for reopening the hearing and on what the evidence in the reopened hearing did and did not establish, it provides no citations to 15/ See "NRC Staff Coments on Whether Comission Should Defer Restart Deitsion Until Issuance of Licensing Board's Opinion on Operator Cheating Inciderts," dated January 13, 1982.
the record to support its assertions.
In the Staff's view, a Commission determination to authorize operation of THI-I at power levels greater than 5% of design cannot reasonably be based on Licensee's conclusory and unsupported assertions.
III.
CONCLUSION In conclusion, it is the Staff's position that Intervenors Aamodt, TMIA and UCS have presented no justification for a deferral of the Commission's decision on restart until the Licensing Board issues its opinion on operator cheating.
The Staff agrees with the Licensee that the Commission need not and should not defer its decision, although, contrary to the positinn of the Licensee, it is the Staff's view that, pending the issuance of the Licensing Board's decision on the cheating incidents, any authorization for restart should be limited to operation at five percent of design power as found by the Licensing Board.
Respectfully submitted,
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w James M. Cutchin IV Counsel for NRC Staff
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ack R. Goldberg Counsel for NRC Staff
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) Co sel for N Sta f Dated at Bethesda, Maryle J this 20th day of January, 1982.
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LICENSING BOARD'S OPINION ON OPERATOR CHEATING INCIDENTS 1 in the above-'O N:
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as indicated by double asterisks, by delivery by messenger, this 20th day of January, 1982:
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Dr. Linda W. Little 6504 Bra ~dford Terrace J<
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Allen R.' Carter,' Chairman-Joint Legislative Sommittee on Energy Jordan D. Cunningham, Esq.
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Janes M. Cutchin, IV cWash,jngton,DC 20555 x-Counsel for NRC Staff
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