ML20126E023
| ML20126E023 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Shoreham |
| Issue date: | 08/23/1984 |
| From: | Cowan B ATOMIC INDUSTRIAL FORUM |
| To: | Palladino N NRC COMMISSION (OCM) |
| Shared Package | |
| ML20126D950 | List: |
| References | |
| FOIA-84-942, FOIA-85-A-5 NUDOCS 8506150272 | |
| Download: ML20126E023 (5) | |
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August 23, 1984
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, e m The Honorable Nunzio J. Palladino E Chairman e
,,. U.S. Nuclear Regulatory Commission a Washington, D.C. 20555 o
Dear Chairman Palladino:
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In SECY-84-290. dated July 17, 1984, the h7C staff posed several g questions with respect to the Commission's May 16, 1984, deci-
. sion in the Shoreham case relating to the standards for exemp- ~
l tions under 10 CFR 50.12(a). Long Island Lightine Co. (Shoreham c Nuclear Power Station, Unit 1), CLI-84-8, 19 NRC , slip op.
.S May 16, 1984). The Office of the General Counsel provided its y recommendations on this issue on July 24, 1984, in SECY-84-290A
< entitled " Exemptions. During a public meeting on July 25, i o 1984, the Commission met to consider SECY-84-290. The staff y observed in its paper that the Shoreham decision " establishes y practices and requirements for licensing which differ signifi- -
a cantly from prior regulatory interpreta. tion and practice" and 8 requested .further guidance from the Commission in implementing g the decision. SECY-84-290, p.1. ,
u The Atomic Industrial Forum's Lawyers Committee has reviewed d' the SECY documents and the transcript of the public meeting, j and offers the following comments on the Commission's guidance -
y to the staff. The Committee supports fully the Commission's _-
decision to clarify the limitations of the Shoreham case and to --
g proceed expeditiously with a study of the exemption process.
. We offer below some suggestions for consideration in this 2; l future study.
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The Commission Correctly Limited the Shoreham Case -
The issue of the procedures and standards for granting exemp- ]
tions.from the requirements of NRC regulations arises in the 4 context of Long Island Lighting Company's request for a low ?
power operating license pursuant to 10 CFR 50.57(c) and the -
applicability of General Design Criterion 17 (Electric Power )
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e Hon. Nunzio J. Palladino 2 August 25, 1984
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g Systems) to s6ch licenses. After briefing and oral arguments, the Commission ruled on May 16, 1984, that "10 CFR 50. 57(c) should not be read to make General Design Criterion 17 inap-plicable to low-power operation." Shoreham, CLI-84-8, slip op. =
at 1. In its decision, the Commission requested that the appli-cant address two " standards" in any request for an exemption i under 10 CFR 50.12(a). (The applicant had already stated its I intention to seek an exemption during the May 7, 1984, oral argument before the Commission). These standards were (Shoreham, CLI-84-8, slip op. at 2-3):
l 1. The " exigent circumstances" that favor-the
) granting of an exemption under 10 C.F.R. ;
50.12(a) should [the applicant] be able to (
demonstrate that, in spite of its non-compliance
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I with GDC 17, the health and safety of the [
l public would be protected. (footnote omitted). ?
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- 2. (The applicant's] basis for concluding that, at -
the power levels for which it seeks authoriza-l tion to operate, operation would be as safe under the conditions proposed by it, as opera- p tion would have been with a ful.ly qualified =
onsite A/C power __ source. -
Some of the difficulties with the Commission's Shoreham deci-sion have been described -by the staff in SECY-84-290 and by the =
l Office of General Counsel in SECY-84-290A. Briefly stated, the f l " exigent circumstances" and "as safe as" standards go far be- 1 yond the existing exemption standards found in 10 CFR 50.12(a) 4 and appear to constitute a new set of rules for granting exemp- 2 l tions.
1 In addition, it is possible to interpret Shoreham in a way I which upsets the licensing procedures which have been histor-ically followed by the staff, procedures which are clearly {'
S authorized under existing regulations. See for example,10 CFR 50.57(b), which provides that "[ejach operating license will e
include appropriate provisions with respect to any-uncompleted 'q items of construction and such limitations or conditions as are a required to assure that operation during the period of the -
completion of such items will not endanger public health and .
safety." A formal exemption under 10 CFR 50.12(a) need not be called into play where the subject of the request is a tempo- 1 rary non-compliance which the Applicant intends to cure at a ?
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later date respecting "any uncompleted items of construction." _;;
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A L Hon. Nunzio J. Palladino 3 August 25, 1984
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Such a temporary'non-compliance can and has been handled by the staff with appropriate license conditions and limitations which will not endanger public health and safety. See 10 CFR 50.36(c)(2). A different situation is presented where the applicant will never meet the General Design Criteria. There, a-formal exemption process may well be required.
Suggestions for Future Consideration In connection with the Commission's direction to its staff to
, study ,the exemption process, the Lawyers Committee suggests that the staff include four broad areas in its focus. First, the standards for granting exemptions should bd clear and
. capable of practical application such that.the staff can apply the standards to exemption requests with a reasonable degree of
' flexibility. . It is especially necessary to retain flexibility in' the : licensing process given that strict compliance with some regulations may have an adverse effect on the integrity of some components. See discussion'of Appendix J in the transcript of the; July- 25,.1984, public meeting, pages 32-36. At this-time, we see no need to change the criteria listed in 10 CFR 50.12 or
.the procedures long followed by the staff. , Years of staff experience have shown that the regulation and its implementa-tion have , worked well in a. substantial ' number of cases.
- The Commission may, however, in-its study of the exemption process- wish to make. it_ clear that 50.12 provides for two
'different kinds of exemptions, each with its own standards.- In contrast to'CLI-84-8, previous Commission decisions have not merged the standards 1in 50.12(a) and (b), a fact which was recognized by~ the staff in SECY-84-290 . It would be helpful
- for the : Commission to state clearly that 50.12(b) is limited to certain activities undertaken prior to the award of a construc-tion-permit. The standard-of 50.12(a) is to be used for all
~*"The' concept of ' exigent circumstance' had previously been considered a factor only in exemptions granted pursuant to .
10.CFR 50.12(b), limited work authorizations." SECY-84-290,
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Hon. Nunzio J. Palladino 4 August 23, 1984 i
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other exempt.io6' requests. Such a distinction is fully com-patible with the standards set forth in 10 CFR 50.57(b) on limitations and conditions and with the Commission's statutory mandate.
Secondly, the effect of revision of the exemption process on other areas of licensing must be carefully considered. As noted in the analysis of the Office of General Counsel, the Sholly regulatory process may be affected. SECY-84-290A, p.21.
The Sholly regulations are already a cumbersome process and must not be made more so by changes to the. general exemption regulations. The staff should also consider possible effects on the integrated scheduling plans which have-been adopted voluntarily by some operators.
Thirdly, the Lawyers Committee opposes the suggestion in the General Counsel's analysis that the Commission prohibit exemp-tions for operating reactors and treat non-compliance as a violation of Commission regulations. SECY-84-290A, p. 22-23.
Therein it is suggested that any noncompliance would be the subject of enforcement action appropriate to the severity of the safety issue posed, including the necessity for plant shutdown. To the extent that the General Counsel is talking about exemptions from regulations, the concerns expressed in SECY-84-290A are misplaced because there are no Sholly pro-blems. The staff can and should continue to process such ex-emptions under the exemptions procedures.
Inherent in the General Counsel's concept of "no exemptions" for operating reactors is the idea that the regulations of the Commission are so perfect and the vision in adopting such regulations so all encompassing that there can never be a circumstance not covered by the regulations. With more than eighty reactors currently licensed for operation in multiple locations and with a multiplicity of design features, it is difficult to accept such an underlying rationale. Clearly, the Commission must have the flexibility to consider and grant ex-emptions for operating reactors where circumstances warrant.
Otherwise the regulatory process becomes muscle-bound and self-defeating.
In those cases where an exemption would require alteration of a license condition (which we believe are few in number), the ,
Forum's Lawyers Committee is opposed to the General Counsel's l
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Hon. Nunzio J. Pall'adino 5 August 23, 1954 1
l suggestion for several reasons. The willingness of the Commission to entertain exemptions on an open public record for good reason and under appropriate circumstances is an invitation tc improve safety by technical innovation. Continuing efforts by the Commission and the private sector in safety research will quickly die if a message of absolutely "no exemptions" is adopted. The Commission should address directly the question of' revision of the exemption process rather than use an approach-which resembles back door regulation.
Finally, we believe that the Commission's action at its July 25 public meeting confirms that no new exemption policy was created by the Shoreham decision. While the Commission may have the authority to make new policy in the context of an adjudicatory proceeding, we urge the Coccission to proceed on a generic rather than plant specific basis.
Sincerely, M
Barton Z. Cowan Chairman, AIF Lawyers Committee BZC:hmg cc: Commissioner James K. Asselstine Commissioner Thomas M. Roberts Commissioner Frederick Bernthal Commissioner Lando Zech, Jr.
William Dircks, Executive Director for Operations Guy Cunningham, Executive Legal Director Hertzel Plaine, General Counsel
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\ 6 LAW OFFICES OF
.5ISHOP. LIB ERMAN. COOK, PURCELL & REYNOLDS 4200 SEVENTEENTM STR E CT. N. W. IN NEW YORK WASHINGTON, D. C. 20036 gissop LIBERMaN & COOK 3021 857-9800 26 aRomoway NEWvoRK NEwYoRni0004 TELEX 440574 eNTLAW Ut (2 2) 2+e-esco TELEX 222767 September 10, 1984 The' Honorable Nunzio J. Palladino Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555
-Dear Chairman Palladino On May 16, 1984 the Commission issued an order in the Shoreham proceeding which has subsequently created some confusion within-the NRC and the nuclear industry with respect to the NRC's 10 C.F.R. .$ 50.12 exemption process. See Long Island Lighting Co. (Shoreham Nuclear Power Station, Unit 1), CLI-84-8, 19 NRC-(slip op., May 16, 1984). On behalf of Duke Power Company,
.we respectfully submit our comments on the exemption process in light of the Shoreham decision and subsequent discussions.1/
TheLNRC' Staff,-as reflected in SECY-84-290, "Need and Standard for Exemptions" ' (July 17, 1984), initially interpreted CLI-84-8'to alter broadly the NRC's $-50.12 exemption process.
In our opinion, there is no reason the Staff's past exemption practice should be altered by either the Shoreham decision or through changes to the exemption. regulation. The Staff in the
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past has recognized the need for.. flexibility in the regulatory process. This flexibility would not be possible if the Commission were to adopt a rigid exemption approach such as is implied by Shoreham. We recognize that the Commission has already voted to limit CLI-84-8 to the Shoreham facts. However, as discussed below, it is not entirely clear that the Staff has done this. Moreover, we offer our comments in view of the Commission's announced intent to reevaluate the exemption regulation.
- 1. Background To . justify an exemption from GDC 17 for low power operation in Shoreham, the Commission stat'ed that the applicant should show (1) the " exigent circumstances" that favor the granting of an exemption under } 50.12(a), and (2) the basis for concluding that, at low power, operation would be "as safe" under the ;--
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conditions-proposed as it would be with full compliance with the !
GDC. Shoreham, CLI-84-8, slip op. at 2-3. This decision appeared to both raise the threshold for the grant of 4 50.12 exemptions and to increase the number of situations in which requests are necessary. In fact, the NRC Staff did so interpret Shoreham in a number'of cases. For example, prior to issuing a license for fuel load for Duke's Catawba plant, the Staff required Duke either to demonstrate compliance with each regulatory requirement for a full power operating license or to request a specific exemption from such requirement.
At the request of the NRC Staff, a public Commission meeting was held on July 25, 1984 at which the Staff sought clarification of the exemption requirements in view of the Shoreham order. See SECY-84-290. This meeting was a positive step toward eliminating the unnecessary confusion caused by Shoreham. By a four-to-one vote the Commission decided that the Staff should limit CLI-84-8 to the facts of that case and continue to follow its past practice with respect ~ to exemption requests. The effect of that direction to the Staff is to return the standard for the grant of an exemption to "no undue risk" and " good cause". Similarly, former Staff practice of utilizing license conditions rather than explicit _ exemption requests should be reinstated. It is not clear, however,.that the Staff has in fact returned to its prior practice in this latter regard.
In addition, the Commission at the July 25 meeting agreed to undertake a long term evaluation of the entire exemption process and directed that the Staff prepare a discussion paper within 30 days. The Commission also requested a short staff response in 7 days to proposals hy Commissioner Asselstine which in effect would apply and amplify the Shoreham tests for exemptions in all cases. Because we consider this to be a significant issue, we urge consideration of our comments. We have reviewed the Staff's 7-day response related to Commissioner Asselstine's proposals
-dated August 2, 1994. Our comments on the proposals and the Staf f's August 2 response are included herein.
- 2. The Standards to be Applied to Exemption Requests We begin by addressing the standards by which exemption requests will be evaluated, because it is in this context that the Shoreham dec t s ton has the greatest implications. In CLI-84-8 the Commission re7 aired that LILCO, in a request for an exemption from GDC 17 unlo- } 50.12(a), address (as LILCO proposed):
- 1. The " exigent circumstances" that favor the granting of an exemption under 10 C.F.R. 50.12(a) should it be able to lemonstrate that, in spite o f its non-compliance with GDC 17, the health and safety of the public aould be protected. [ Footnote omitted.]
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. 2. Its. basis for concluding that, at the power levels for which it' seeks authorization to operate, operation would be as_ safe.under the conditions proposed by it,
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-as operation would have been with a fully qualified
~on-site.A/C; power source.-
Shoreham, CLI-84-8,, slip op.-at 2-3. As pointed out by the Staf f in SECY-84-290i these_ standards exceed by a substantial margin
-prior requirements for exemption requests . We, however, perceive no reason for'an alteration of the prior Staff standards. The Commission was correct in its July 25th decision to limit applicability of .CLI-84-8 to Shoreham. In considering the future of the exemption process, however, we wish to emphasize several points.
- a. Exigent Circumstances First,." exigent circumstances" should not be a necessary component of the showing required for a { 50.12(a) exemption.
Exigent circumstances have been and should be required only for $
50.12(b) exemptions related to construction activities which
. precede ' issuance of a construction _ permit. Such an " exigency" test cannot by definition be met in many instances during the operating life of a plant where exemptions are sought on an interim schedular basis rather'than a permanent technical basis.
A request from-an applicant or a-_ licensee for. an interim
-(schedular):_ exemption can be premised only on economic or
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~1ogistical arguments and the lack of safety significance of compliance with the regulation for the particular short term situation. -Exigent circumstances, as understood for example in
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the context of the Sholly regulations, may not exist. The Commission must' recognize-this, and its system must be able to distinguish between_these matters. Application of the.Shoreham 6 50.12:" exigent circumstances" standard fails .to do so.
The-Commission, in Shoreham, did allude to an appropriate standard for { 50.12(a) exemptions:.
The' Commission regards the use of the exemption authority under 10 C.P.R.
50.~12 as extraordinary. This method of relief has previously been made available by the Commission only.in the presence of exceptional circumstances. See, United States Department of Energy, et al.
(Clinch River. Breeder Reactor Plant),
CLI-83-1, 17 NRC 1, 4-6 and cases cited therein (1983). A finding of exceptional circu.nstances is.a discretionary adminis-trative finding which governs the availa-lbility of ~ an exemption. A reasoned exercise of such discretion should take into account
-the equities of each situation. The
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- s equitiesLinclude the-stage of the facility's life, any-financial or economic hardships, any internal.-inconsistencies in the regulation, the . applicant's ' good-faith
- effort to comply with the regulation from which an' exemption is' sought, the public interest.in adherence to the Commission's regulations, and the safety significance of the issues involved.
Of course, these equitiesido not apply to the requisite findings on public health and safety and common defense and security.
- Shoreham, CLI-84-8, slip op..at 2-3, fn. 3. This Commission footnote. stresses that in-judging an exemption request, a balan'cing of all of the equities of each situation is Lappropriate. This standard allows the Commission necessary flexibility.in. applying.the exemption standard and is consistant
'with the wide discretion allowed the Commission by law in evaluating exemption requests as stressed by the Office of
-General Counsel in SECY-84-290A. Without adding excess language to.the. exemption regulation, this balancing concept can be established by use of a " good cause" test rather than an
" exigency" test.
The NRC hasl appropriately applied equitable standards in other-contexts. For example, 10 C.F.R. { 2.788 governing requests for -stays pending intra-agency - review, adopts the equitable balancing test of Virginia Petroleum Jobbers LAssociationiv. FPC, 259 P.2d 421, 925 (D.C. Cir. 1958). The
-presiding officer is granted the discretion to weigh the argumentsLon a case-by-case basis in order to; determine where the equities of the situation lie. See e.g., Portland General Electric Co'.: (Trojan Nuclear Plant), ALAB-524, 9 NRC 65, 69 (1979). Similarly, a flexible test for." good'cause"'is used in ruling on petitions for late intervention in licensing proceedings. 10 C.F.R. { 2.714(a)(1). What constitutes good cause in any given case will depend directly upon the ' facts and equities of that case. See e.g., Long Island Lighting Co.
(Shoreham Nuclear Power Station,~ Unit 1), ALAB-743, 18 NRC 387, 396-99 (1983). There is no reason a similar equitable test cannot be applie 1 by the -Staff in evaluating exemption requests un:ler 1 50.12 .(a) .
~ b . _. As Safe As Our second p>lnt related.to exemption standards is that the
- Staf f's' tradition s1 standard for exemptions, requiring a showing of "no undue risk", is appropriate and should be continued. It can-be applied without modification to both interim (schedular) and L li fe-of-plant (technical) exemption requests. It correctly allows : for an evaluation of overall plant conditions that will
' exist during the time the exemption will be in effect. This
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.4 evaluation includes a review of the purpose of the regulation,
-the extent-to which alternative measures or compensatory measures achieve that purpose, operating conditions (e.g., power level),
and the length of time for which the exemption will be needed.
Such a standard provides the Staff with necessary regulatory flexibility to effectively deal with the technical merits of each exemption request. Such a standard would also minimize Staff interpretive difficulties because the Staff has been applying the standard for a long time and can draw from its exemption experience.
The Commissioners discussed modifications to the Shoreham "as safe as" standard at the July 25th meeting. These modifications are apparently intended to eliminate the problems created by the Shoreham standard which never existed with the "no undue risk" standard. This strikes us as traveling a rather roundabout route only to return to the start. For example, the Commission considered recognizing a "de minimis" concept in the standard, or to make it a "substantially as safe as" test. The Commission therein correctly recognizes that the "as safe as" test was overly stringent and could not be met for many exemption requests (especially schedular but also full-term ones). Iloweve r , such a problem never existed under a "no undue risk" standard. We believe that the existing "no undue risk"
. standa'rd is appropriate and urge that it be continued.
- 3. The Situations in Which Exemptions are Required As an outgrowth of the Shoreham decision, the Commission also appeared to be reevaluating the types of situations in which the1 exemption. process would be invoked. The Staff originally interpreted CLI-84-8, as expressed in SECY-84-290' to require explicit exemptions in many cases where traditionally license conditions or technical specifications with limiting conditions on operation have sufficed. For example, the Sta f f's interpretation aould require an exemption request if spent fuel pool cooling will not be available until the first re fueling outage. The rigid interpretation ignores the technical reality that there is no need for the spent fuel pool cooling until after the first . cycle of operation. The Staff, in its more flexible prior practice, would have handled this situation with a license condition that pool. cooling be available by the first refueling outage. We believe the rigid Shoreham interpretation of the exemption process is improper, and that in considering the future of the exemption process the Commission should address the scope of that process as sell as the standards to be applied.
In this context we again do not see any compelling need to change the prior Staf f practice. The Commission appears to regard exemptions as extraordinary measures justified only in exceptional circdastances. United States Department of Energy, et al. (Clinch River Breeder Reactor Plant), CLI-83-1, 17 NRC 1, 4-6; Long Island Lighting Co. (Shoreham Nuclear Power Station, E
4 Unit 1),1CLI-84-8, 19 NRC , slip op. at 2-3,. fn . 3 (May 16, 1984). However, such will not be the case if the Shoreham
' approach as originally interpreted by the NRC Staff is followed.
Under that approach explicit exemptions are required to justify
, short-term (schedular) exemptions for both near term operating license'(NTOL) facilities and operating plants.
- a. NTOL Facilities Routinely, under prior practice, license conditions would be required instead.of exemptions to allow an NTOL to receive a low power license. The license conditions schedule full regulatory
' compliance at some later time consistent with public health and sa fe ty. Although not reviewed under the { 50.12 process, the Staff applies a standard equivalent to the "no undue risk" test discussed above. Therefore, this approach provides the same level of public protection as an exemption approach, is more flexible, and allows 'for full consideration of the technical realities of short term operation.
Many of the instances in which the NRC Staff has been requiring requests for exemptions since CLI-84-8 and since the July 25th meeting involve Staff interpretations of Appendices to
<Part 50 (often quite recently changed interpretations) . .Some o f the provisions in' Appendices to Part 50 were originally intended to serve as guidance documents rather than hard and . fast requirements, or to be interpreted in construction permits as design objectives and not as prerequisites to 10 C.F.R. $ 50.57 findings. Where compliance with a regulation or GDC for low power operation makes no technical sense, or presents no undue risk,.an exemption request should not be necessary. A license condition approach prevents unnecessary exemption paperwork and potential licensing delays, and appropriately reserves the exemption process for extraordinary cases.
- b. Operating Reactors Perhaps in recognition of the fac t that interim schedule exemptions for operating plants could not meet the Shoreham exemption standard, the Commission, at the July 25th meeting, discussed the idea of eliminating such schedular exemptions for operating reactors from the 50.12 process. The Office of General Counsel (OGC) proposed instead that violations of schedule requirements be treated as enforcement matters. Under this scheme, ,a notice of violation would issue for a failure to meet the schedule, and appropriate enforcement actions would
. follow depending upon the safety significance of the violation.
SECY-84-290A, at 20-23, 27. '
We.believe the OGC' approach is undesirable. For the reasons discussed above, we agree that interim schedular exemptions should_not be held to a standard higher than the present "no undue risk" standard. However, this reason alone does not
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. _ justify creating an awkward exception to the exemption process.
The OGC approach presents a rather peculiar, indirect means for licensees to obtain necessary and often relatively routine interim extensions of time for compliance with regulatory requirements. Consider, for example, a case in which a periodic offsite emergency' planning exercise must be held a month or two late because a state or local government cannot participate until that time. Initiation of enforcement action and a decision not to prosecute or to issue a pro forna notice of violation would be dn inefficient, a f te r-the- fac t , process for granting what is in effect an exemption.
Such notices of violation may also have financial and public relations implications for nuclear utilities. The violations may be subject to financial reporting obligations and may create an unwarranted perception of high investment risk in the financial community. In terms of the public perceptions, the OGC approach would have the further disadvantage of turning routine matters, where no undue safety risk is involved, into enforcement matters which by their very nature cast the licensee under the cloud of an appearance of guilt.
- 4. Conclusion In conclusion, we believe that the Commission should re-examine and clarify the complete exemption process in light of the Shoreham decision. The Commission should reaffirm the Staff's existing, clear standard for both short-term (schedular) and long-term (technical) exemption requests. Further, the Commission should not expand the process to include situations presently handlei by license conditions. Nevertheless, if the-exemption process is altered, it should include standards that are clear and consistently applied to all exemption requests, and a format that does not create unnecessary enforcement action.
Sincerely, ,
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! J. Michael McG rry, III cc: Commissioner James K. Asselstine Commissionec Thomas M. Roberts Commissioner Frederick Bernthal Commissioner Lando Zech, Jr.
Mr. William Dircks, Executive Director for Operations Mr. Guy Cuntingham, Executive Legal Director Mr. Hertzel Plaine, General Counsel