ML20056B480
| ML20056B480 | |
| Person / Time | |
|---|---|
| Issue date: | 06/08/1990 |
| From: | Cho J NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Meyer D NRC OFFICE OF ADMINISTRATION (ADM) |
| Shared Package | |
| ML19336C343 | List: |
| References | |
| FRN-55FR27645, RULE-PR-2 AD60-1-05, AD60-1-5, NUDOCS 9008280333 | |
| Download: ML20056B480 (12) | |
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June 8, 1990
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MEMORANDUM FOR:
David L. Meyer, Chief Regulatory Publications Branch Office of Administration FROM:
John Cho Special Counsel Office of the General-Counsel
SUBJECT:
SECY-90-074A
- REVISION TO RULES OF PRACTICE (10 C.F.R. PART 2, SUBPART B)
The rules attached hereto are forwarded to you for review and.
processing in accordance with the June 1, 1990 SRM on.this subject.
The attached rules incorporate the changes specified by the Commission.
They also incorporate some of the suggestions proposed by your May 17, 1990 memorandum to me.
However, these latter changes have been held to a minimum, to those considered necessary for accuracy or to meet publication requirements.
I will be out of the office the week of June-11. ^If you need to discuss the rules during that period, I suggest that you contact Lawrence J.-Chandler at extension 21580.
John Cho Special Counsel Office of the General Counsel cc:
L.J. Chandler l
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HUCLEAR REGULATORY COMMISSION 10 CFR Part 2 RIN 3150-AD60 Revisions to Procedures To issue Orders AGENCY:
Nuclear Regulatory Commtssion.
ACTION:
Proposed rule.
SUMMARY
- 'The Nuclear Regulatory Commission (NRCL proposes to revise its rule governing orders to provide for the expeditious consideration of challenges to orders that are made immediately effective.
The proposed amendments specifically allow challenges tc the imnediate effectiveness'of an order to be made at the outset of a proceeding and provide procedure for the expedited consideration and disposition of such challenges. The proposed amendn:ents also require that challengu to the merits of an irrmediately effective order be heard expeditiousiy, except wnere good cause exists for delay.
DATES:
The comment period expires on (60 days after publication in the t
FederalRegister). Comments received after this date will be considered if it is practical to do so, but assurance of consideration cannot be given
-except as to comn.ents received on or before th1s date.
AUDHESSES:
Send written comments to the Secretary of the Commission, U.S. Nuclear Regulatory Commission, Washington, DC 20555, Attention:
Docketing and Service Branch.
Comments may also be delivered to the Office of the Secretary, U.S. Nuclear Regulatory Commission, One White Flint North, 11555 Rockville P1ke, Rockville, Maryland, between 7:45 am and 4:15 pm Ft.deral Workdays Copies of any comments received may be examined and copied for a fee at the NRC Public Document Room, 2120 L Street, NW (Lower Level), Washington, DC between the hours of 7:45 am and 4: 15 pm Federal Workdays.
FOR FURTHER INFORMATION CONTACT: John Cho, Office of the General Counsel, U.S. Nuclear Reguletory Commission, Washington, DC, 20555. Telephone:-
301-492-1585.
SUPPLENENTARY INFORMATION:
Background
On April 3,1990, the Commission published in the Federa l Register, 55 FR 12370, proposed changes to 10 CFR Part 2, Subpart B.
The proposed changes, if adopted, would make clear that the provisions governing the issuance of orders include within thr'r scope all persons subject to the jurisdiction of the Commission, licensees as well as non-licensees. As it exists now, except for order.= imposing civil penalties, subpart B aadresses issuance of orders only to licensees.
Other changes were also proposed to
a-,_,,-,,,
clarity that hearing rights attach only to orders, in contrast to demands to show cause; e.g., demands for explan6 tion or other information.
Upon further consideration, the Comission has decided that additional changes should be made to subpart B.
These additional changes pertain to orcers that are made immediately ef fective.
Under current subpart B, as well as under the April 3 proposed changes, orders can be made immediately effective when required to protect the public health, safety, or interest or when there has been willful misconduct.
There 6re no provisions, however, under the existing rule or under the proposed changts, that specifically require that challenges to such orders, including challenges to the tarrediate effectiveness of such orders, be heerd expeditiously.
The revisions proposed herein address this and other related matters.
As the rule is structured, currently and under the April 3 proposal, the recipient of an order may answer it by consenting to the order or by challenging it by demanding a hearing. Where the hearing demand concerns an order that is inmediately eff ective, the person or persons to whom the order is issued are nevertheless required to comply with its provisions pending the completion of the hearing.
The imposition of this requirement is necessary to enable the Commission to carry out its responsibility for protecting the public health, safety, and interest.
The public health, safety, and interest must be held paramount over any conflicting private interests.
At the same time, fairness considerations dictate that the interests of the recipients be accommodated to the extent it can be done without impediment to the Com".ission's exercise of its resptnsibility. To this ene, the Consnission is proposing further changes to section 2.202, in addition to those published on April 3.
The Commission believes that a proper balance between the private and goverttental interests involved is achieved by a he : m conducted on an acreierated basis. The revisions proposed herein arr r. provision to the earlier proposed section 2.202 directing that any re ested hearing on an 5 mediately eff ective order will be conducted expeditiou,1y, giving due consideration to the rights of the parties. Another at:Le provision allows challenges to be made at the outset on the need f or invaediate effect1veness.
Such a challenge con be initiated by a motion by the recipient of the order to set aside the innediate effectiveness of the order.
A motion to set aside immediate eff ectiveness must be based on one or both of the folicwing grounds:
the willful misconduct charged is unfounded or the public health, safety or interest does not require the order to be made immediately effective. No other ground for chalgerge is permitted inasmuch as no other ground is relevant. The motion must set out specifically its supporting reasons and must be accompanied by any necessary affidavits providing the factual basis for the request.
The added provision also specifies that a motion to set aside the immediate eff ectiveness of an order will be decided proniptly by the prcsiding officer (an atomic safety and licensing board or an aaministrative law judge as designated by the Commission) betore the presiding officer Y
takes up any other matter not necessary to the resolution of that request.
To as;ure prompt decision, the provisicn establishes short time periods for action by the parties as well es by the presioing offi:er.
It is expectea that the presiding officer normally will decide the question of immediate effectiveness solely on the bcsis of the order and other filings in the record. The presidtr.g efficer may call for oral argument. However, an evidentiary hearing is to be held only if the presiding officer finds the record is inadequate to reach a proper decision on immediate effect;teness.
Such a situation is expected to occur only rarely.
In deciding the question of immediate effectiveness under section 2.202 as pronosed herein, the presiding of ficer Will apply an adequate evidence stancard. This standard is analogous to the evidence necessary to find probable cause to make an arrest, to obtain a search warrant, or to obtain a preliminary hearing on a criminal matter, in a criminal enforcement context,"lp]robablecauseisdeemedtoexistwherefactsandcircumstances within affiant's knowledge, and of which he has reawnably trustworthy information, are sufficient unto themselves to warrant a man of reasonable caution t. believe that an offense has been or is being committed."
United States v. Hill, 500 F.2d 315, 317 (5th Cir. 1974).
In the context of tTie prcposed rule, adequate evidence is c;eemed to exist when f acts and circumstences within the NRC staff's knowledge of which it has reasonably trustworthy information are suf ticient to warrant a person of reasonable caution to believe that the charges of willful enduct, if any, contained In the order are true and/o" that the action specified in the order is necessary to protect the public health, safety or interest.
The Comission believes that the " probable cause" standard, adapted as the acequate evidence standard for use in the Commission's proceedings involving challenges to the immediate ef tectiveness of orders, serves the public interest.
Commission orders often deal with willful misconduct or other circumstances that threaten harm to the public health, safety or interest.
In some instances, the threat may be imminent.
In other instances, while no violation may be involved, Information available to the Commission may indicate the nted for certain immediate action to provide reasonable assurance that the public health, setety, and interest will be prothet ed.
In all cases, 1t is imperative that the Commission be able to tal2 whatever r'easures that may be necessary to protect the public health, safety, and interest.
The adequate evidence standaro for deciding questions of irrmediate effectiveness enables the Commission to proceed with necessary protective action on the basis of reasonably trustworthy information without having to await the completion of a full hearing on the merits of the order.
At the same time, it provides the affected parties a measure of protection against_ forced com;,1cnce, before a hearing, with an order that is insubstentially f ourded. The adequate evidence standard has been applied to allow an agency to uspend persons from bidoing on government contracts (and l
thus allowing the s aspension to remain in effect for a reasonable period without a hearing), where sign 1ficant governmental interests are involved cnd the risk of erroneous deprivation of an indivicual's interest is slight.
see Tran co Security Inc. v. Freeman, 639 F.2d 318 (6th Cir.1981), cert.
denied, 44 U.S. 820 TIE l); Hori.e Erothers, Inc. v. Laird, 463 F.2d lR 8, 1
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(D.C.Cir.1972). Taose sarne considerations support adoption of the adequate evidence 'ule here.
The 1ollowing 3xample illustrates how the Comissicn intends that the actquete evidence stendard will be applied. A common type of order directs a licensee to take or irnst from taking certain action because of an asserted willful violation o' a license or regulation. An affidavit by a cognizant NRC of ticial that Uets forth facts setficient to lead a reasonably cautious person to believe that the asserted willful violation did occur is sufficient to sustain the imediate ef f ectiveness of the oroer. As another example, an order directs a licensee to take certain action because the Commission is in possession of information indicating that the ordered action is necessary to prottet the public health, saf ety or interest.
Similarly, an affidavit by a cognizant NRC official that sets forth sufficient information to lead a reasontbly cautious person to telieve that the ordered action is necessary to protect the public health, safety, or interest is sufficient to sustain the immediate effectiveness of the order.
This standard does not require evidence by persons with first hand knowledge of the tacts. Nor does it call for a balancing of evidence between that provided by the NRC staff and that provided by the person seeking to set aside inmediate effectiveness.
It is not a preponderence of the evidence test. Rather, if the staff's evidence is sufficient to cause a person of reasonable caution to believe that the order is properly founded, that is, tte conduct or activities of the person 1dentified in the order present a public health, safety, or interest th:.;.; 19t requires immeaicte remediel action, the presiding oft 1cer is required to upho'd the 1mmediate effectiveness of the order.
In this regard, the pri.3iding officer must view the evidence presented in a light mos N orable to the staff and resolve all inf erences in the staf f's f avor.
The burden of going f ormd on the immediate effectiveness issue is with the party who moves to et aside the immediate effectiveness provision.
The burden of pt:rsuasion on the appropriateness of imediate ef fectiveaess is on the NRC staff.
The Commission intends that a motion to set aside the immediate ef'ectiveness of an order will be the only mechanism for challenging immediate effectiveness, In the circumstance, a presiding officer will not entertain any motion to stay the immediate effectiveness of an order; nor will a presiding ofttcer issue sua sponte such a stay.
In general, the Comission expects that, through the licensing board's imposition of shortened response periods and expedited filing mechanisms, a motion to set oside immediate effectiveness will be decided within fifteen (15) days of the date the hearing request and accompanying niotion are referred to the presiding officer. See 10 CFR 2.772(j).
A presiding officer's order upholding the immediate effectivness of an order will constitute the final agency action on immediate effectiveness. A presiding officer's order setting aside inr:ediate effectivness will be ref erred promptly to the Commission for review and will not be effective pending further order of the Comission.
4
The Comission's authority under section 2.202 to issue immediately effective orders includes the authority to issue amendatory or supplemental orders that are immediately ef f ective. Section 2.202 will remain the same in this respect.
It such an order is issued by the staff after a hear 1ng has been ordered, the licensee or other person affected may move that the imediate effectiveness of the amendatory or supplemental order be set aside pending completion of the hearing on the merits.
Such a motion will be given expedited consideration by the presioing officer and decided on the basis described above.
Notwithstanding the factors that call for expedited resolution of disputes arising out of imediately ef fective orders, there may be instar.:es when overriding public interest considerations require delay in the proceeding on the merits. The revisions proposed herein to the earlier proposed section 2.202 include a provision allowing reasonable delays in the conduct of the proceedings on the merits where good cause exists. As_an 9xample of the kind of good cause warranting delay, there may be a need for further investigation by the Ccnmission or the U.S. Department ot Justice.
In such inst 6nces, to allow the Commtssion to investigate further into the matter or the Department of Justice to undertake criminal investigation wi+,hout prejudice to possible prosecution of any discovered crime, it may be necessary to hold the hearing on the immediately eff ective order in abeyance for a reasonable period of time. The proposed revision to section 2.202 allows the Commission, either on motion by the staff or any other party, to delay the hearing in such cases, for such periods as may be appropriate in the circumstancts.
The proposed revision, however, does not authorize delay in the proceeding on a motion to set aside immediate effectiveness. The length of a celay in the proceoding or the nerits should be based on a balance of the competing interests involved.
See Logan v. Zimmerman BrushCo.,455U.S.422,434(1962).
Such a motion will be expeditiously heard and decided.
Environmental Impact:
Categorical Exclusion The NRC has determined that this proposed rule is the type of action describedincategoricalexclusion10CFRi,1,22(c)(1).
Therefore neither an environmental impact statement nor an environmental assessment has been prepared for this proposed rule.
Paperwork Reduction Act Statement 1his proposed rule contains no information collection requirements and therefore is not subject to the requirements of the Paperwork Reduction Act i
of 1980 (4a U.S.C. 3501 et seq.).
higulatory Analysis The existing regulations in 10 CFH 2.202 authorize the NRC, through its designated officials, to institute a proceeding to modify, suspend, or revoke a license by service of an order to show cause on a licensee.
The regulations, as currently written, do not provide procedures for the NRC to take direct 6ction against unlicensed persons whom willful misconduct 5
causes a licensee to violate Commission requirements or places in question reasonable assurance of adequate protection of the public health and safety, although such action is authorized by the Atomic Energy Act of 1954, as a niended.
On April 3, 1900 (55 FR 12370), the Commission proposed amendments to make the Commission's Rules of Practice more consistent with the Commission's existing statutory authority and to provide the Commission with the appropriate procedural framework to t6ke action, in appropriate cases, in order to protect the public health and safety.
The proposed amendments also were to make clear the distinction between orders - e.g., directions to take or desist from taking certain actions - and demands for information.
Only orders were proposed to be made immediately eff ective and subject to hearing, consistent with existing regulations. Neither the existing regulations nor the proposed amendments, however, contained provisions requiring that any such hearing be conducted expeditiously.
The amendments proposed by this rulemaking supplement the earlier proposal by adding provisions directing the expeditious conduct of any hearing on an immeci6tely eff ective order but allowing delays in the conduct of such hearings in certain circumstances where good cause for delay is shown, and establishing a separate, informul procedure for dealing rapidly with challenges to the immediate effectiveness of such order.
The proposed rule constitutes the preferred course of action and the cost involved in its promulgation and application is necessary end appropriate.
The foregoing discussion constitutes the regulatory analysis for this proposed rule.
Regulatory Flexibility Certification As required by the Regulatory Flexibility Act of 1980 (5 U.S.C.
605(b)), the Commission certifies that this rule, if adopted, will not have a significant economic impact on a substantial number of small entities.
The proposed rule establishes the procedural mechanism for dealing with orders that are made immediately effective.
Tne proposed rule, by itself, i
does not impose any obligations in entities including any regulated entitles l
that may fall within the definition of "small entities" as set forth in section 601(3) of the Regulatory Flexibility Act, or within the definition of "small business" as found in section 3 of the Small Business Act,15 U.S.C. 632, or within the Small Business Size Standards found in 13 CFR Part l_
121.
Such obligations would not be created until an order is 1ssued, at which time the person subject to the order would h3ve a right to a hearing in accordance with the regulations.
Backfit Analysis This proposed rule does not involve any new impose backtits as defined in 10 CFR 50.109(a)(1) provisions which would Accordingly no backfit analysis pursuant to 10 CFR 50.109(c) is required for this proposed rule.
6 1
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J List of Subjects in 10 CFR Part 2 Aon,inistrative practice and procedure, Antitrust, Byproduct material, Classified internattor,, Environmental protection, Nuclear materials, Nuclear power plants and reactorr, Penalty, Sex discrimination, Source material, Special nuclear material, Wastu treatment and disposal.
For the reasons set out in the preamble and under the authority of the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, as amended, and 5 U.S.C. 553, the NRC is proposing to adopt the tollowing amendments to 10 CFR Part 2.
Part 2 -- Rules of Practice for Donestic Licens'ng Proceedings 1.
lhe authority citation for Part 2 is revised to read as follows:
Authority:
Secs. 161, 181, 68 Stat. 948, 953, asemended(42U.S.C.
2201, 2231); sec.191, as amended, PJb. L.87-61b, 76 Stat. 409 (42 U.S.C.
2241): sec. 201, 88 Stat. 1242, as amended (42 U.S.C. 5841); 5 U.S.C. 5b2.
Sec. 2.101 also issued under secs. 53, 62, 63, 81, 103, 104, 105, 68 Stat. 93C, 932, 933, 935, 936, 937, 938, as amended (42 U.S.C. 2073, 2092, 2U93, 2111,(2133, 2134, 2135);)sec.114(f), Pub. L.97-425, 96 Stat. 2213, as amended 42 U.S.C. 10134(f) ; sec. 102, Pub. L.91-190, 83 Stat. 853 as arnended (42 U.S.C. 4J32); sec. 301, 88 Stat. 1248 (42 U.S.C. 5871).
Sections 2.102, 2.103, 2.104, 2.105, 2.721 also issued under secs. 102, 103, 104, 105, 183, 189, 68 Stat. 936, 937, 938, 954, 955, as amended (42 'U.S.C.
2132,2133,2134,213b,??33,2239).
Section 2.105 also issued under Pub.
L.97-415, 96 Stat. 2073 (42 U.S.C. 2239). Sections 2.200-2.206 also issuto under secs. 161b, 1, o, 182, 186, 234, 68 Stat. 948-951, 955, 83 Stat. 444, as amendea (42 U.S.C. 2201(b)), (1), to), 2236, 2282); sec. 206, 88 Stat.
1246 (42 U.S.C. 5846). Sections 2.600-2.606 also issued under sec. 102, Pub. L.91-190, 83 Stat. 853, as amended (42 U.S.C. 4332). Sections 2.7006, 2.719 also issued under 5 U.S.C. 554.
Sections 2.754, 2./60, 2.770, 2.780 also issued under b U.S.C. 557. Section 2.764 and Table 1A of Appendix C also issued under secs. 135, 141, Pub. L.97-425, 96 Stat. 2232, 2241 (42 U.S.C. 10155, 10161). Section 2.790 also issued under sec. 103, 68 Stat.
936, as arended (42 U.S.C. 2133) and 5 U.S.C. 552.
Sections 2.800 and 2.808 also issued under 5 U.S.C. 553. Section 2.809 also issued unaer 5 U.S.C.
Sb3 end sec. 29, Pub. L. 85-2b6, 71 Stat. 579, as amended (42 U.S.C. 0039).
Subpert K also issued under sec.189, 68 Stat. 9bb (42 U.S.C. 2239); sec. 134. Pub. L. 97-4P5, 96 Stat. 2230 (42 U.S.C.10154). Subpart L also issued under sec. 189, 68 Stat. 95b (42 U.S.C. 2239). Appendix A also issued under s e. 6, Pub. L.91-560, 84 Stat. 1473 (42 U.S.C. 2135). Appendix B also 1ssued under sec.10, Pub. L.99-240, 99 Stat.1842 (42 U.S.C. 2021b et seq.).
2.
Section 2.202 is revised to read as follows:
6 2.202 Order.
(a) The Commission may inst 1tute a proceeding to modity, suspend, or revoke a license or to take such other act'.on as may be prcper by serving on the licensee or other person subject to the jurisdiction of the Connission an order that will:
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(1) Allege the violations with which the licensee or other person i
subject to the Comission's jurisdbtion is charged, or the potentially hazardous conditions or other facts deemed to be sufficient ground for the proposed action, and specify the ection proposed; (2) Provide that the licensee or other person must file a written answer to the order under oath or aftirmation within twenty (20) days of its date, or such other time as may be specified in the order; (3)
Inform the licensee or other person of his or her right, within twenty (20) days of the date of the order, or such other time as may be specified in the order, to demand a hearing on all or part of the order, except in 6 case where the licensee or othtr person has consented in writing to the order; (4) Specify the issues for hearing; (5) State the effective date of the order, and (6) Provide, for stated reasons, that the proposed action be immediately eff ective, pending further order, where the Commission finds that the public health, safety or interest 50 requires or that the violation or conouct causing the violation is willful.
1 (b) The licensee or other person to whom the Comission has issued an order under paragraph (a) must respond to the order by tiling a written answer under oath or affirmation. H Liswer shall specifically admit or deny each allegation or charoa ".ade in the order, and sha ll set forth the matters of fact and law on wt.ich tile licensee or other person relies, and, if the order is not consented to, the reasons as to why the order should not have been issued.
Except as provided in (c) below, the answer may include a demand for a hearing.
(c)(1)
If a hearing is demanded, the Commission will issue an order designating the time and place of hearing.
If a hearing is demanded with respect to an immediately effective order, the hearing will be conducted expedittously, giving due consideration to the rights of the parties.
(2) The licensee or other person to whom the Conmission has issued an order may, in addition to demanding a hearing, move to set aside the immeolate effectiveness of the order. The motion shall state with particularity the reasons why the immeciate effectiveness of the order should be set aside and shall be accompanied by aft 1 davits or other evidence relied on. The Commission statt shall respond within (b) days of the filing of the motion.
The motion shall be decided by the presiding officer expeditiously befoie any other matter unnecessary to the disposition of the motion.
The presiding officer shall exercise its powers to regulate the conduct of the proceeding, including reducing the times specified in subpart G for particular actions, to assure expeditious consideration and disposicion of the motion. During the pendency of the motion or at any other time, the presioing officer shall not stay the immediate effectiveness of the order, either on its own motion, or upon 8
motion of the licensee or other person. The presidir,g officer shall uphold the immediate effectiveness of the order it it finds that there is adequate evidence to support immediate effectiveness. An order upholding irned1 ate effectiveness will constitute the final agency 4.ction on ireediate effectiveness. An order setting aside immediate effectiveness will be referred promptly to the Commission itself and will not be ef fective pending further order of the Commission.
(3) Except as provided in paragraph (2) of this section the Commission may, on motion by the stuff or any other party to the proceeding, where good cause exists, delay the hearing on the immed10tely effective order at any time for such periods as are consistent with the due process rights of the licensee and other affected parties.
(d) An answer may consent to the entry of an order in substantially the form proposed in the order with respect to all or some of the actions proposed in the order. The consent of the licensee or other person to whom j
the order has been issued to the entry of a consent order shall constitute a waiver by the licensee or other person of a hearing, findings if fact and conclusions of law, and of all right to seek Commission and judicial review or to contest the validity of the order in any forum as to those matters which have been consented to or agreed to or on which a hearing has not been requested. The consent order shall have the same force and effect as an order made af ter hearing by a presiding officer or the Commission, and shall be effective as provided in the order.
(e)
It the order involves the modification of a Part 50 licensee and is a backfit, the requirements of b 50.109 of this chapter shall be t
followed, unless the licensee has consented to the action required, uated at Rockville, i:aryland, this day of 1990.
For the Nuclear Regulatory ComrM sion.
Samue l J. Cn11 k, Secretary of the Commission.
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UNITED STATES -
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j',g NUCLEAR REGULATORY COMMISSION
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wAsHWOTON, D. C. 206%
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June 8, 1990 g
MEMORANDUM FOR:
David L. Meyer, Chief Regulatory Publications Branch Office of Administration FROM:
John Cho special Counsel Office of the General Counsel
SUBJECT:
SECY-90-074A
- REVISION TO RULES OF PRACTICE (10 C.F.R. PART 2, SUBPART B)
The rules attached hereto are forwarded to you for review and processing in accordance with the June 1, 1990 SRM on this subject.
The attached rules incorporate the changes specified by the Commission.
They also incorporate some of the suggestions proposed by your May 17, 1990 memorandum to me.
However, these latter changes have been held to a min.' mum, to those considered necessary for accuracy or to meet publi ation requirements.
I will be out of the office the week of Cune 11.
If you need to discuss the rules during that period, I saggest that you contact Lawrence J. Chandler at extension 21580.
John Cho Special Counse; Office of the Gtneral Counsel cc: L.J. Chandler l
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