ML20154D701
| ML20154D701 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/14/1988 |
| From: | Berry G NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#388-7066 ALAB-895, OL-1, NUDOCS 8809160067 | |
| Download: ML20154D701 (18) | |
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UNITED ST ATES OF AMERIC A NUCLE AR REGUL ATOR Y COMMISSION
'88 SEP 14 A9:29 BEFORE THE COMMISSION y,.
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In the Matter of
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Docket Nos. 50-443 OL-01 PUBLIC SERVICE COMPANY OF 50-444 O L-01 NEW HAMPSHIRE, g g.
On-site Emergency Planning and Safety Issues (Seabrook Station Units 1 and 2)
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J NFC ST AFF RESPONSE TO INTERVENORS' MOTION FOR AJCEPT ANCE OF ADDITION AL REPLY TO COMMISSION ORDER OF JULY 14, 1988 R EG A R DIN G AL A B-895 e
i Gregory Alan Berry Counsel for N R C Staff Septem ber 14, 1988
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t UNITED ST ATES OF AMERIC A NUCLE AR REGUL ATORY COMMIS!!ON BEFORE THE COMMISSION In the Matter of
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Docket Nos. 50-443 OL-01 PUBLIC SERVICE COMPANY OF 50-444 OL-01 N E W H A M P S HIR E, y a],.
On-site Emergency Planning and Safety Issues (Seabrook Station, Units 1 and 2)
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NRC ST AFF RESPONSE TO INTERVENORS' MOTION FOR ACCEPT ANCE OF ADDITION AL REPLY TO COMMISSION ORDER OF JULY 14, 1988 R E G A R DIN G A L A B-895 1
i Gregory Alan Berry Counsel for N R C Staff September 14, 1988
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of f
Docket Nos. 50-443 OL-01 PUBLIC SERVICE COMPANY Or 50-444 OL-01 l
NEW HAMPSHIRE, g al.
On-site Emergency Planning
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and Safety Issues (Seabrook Station, Units 1 and 2)
NRC STAFF RESPONSE TO INTERVENORS' tt0 TION FOR ACCEPTANCE OF ADDITIONAL REPLY TO COMMISSION i
ORDER OF JULY 14, 1988 REGARDING ALAB-89S j
INTR,0,00CTION l
l On August 26, 1988, the Seacoast Anti-Pollution League (SAPL), Town i
of Hampton, New England Coalition On Nuclear Pollution (NECNP), and the i
Massachusetts Attorney General (collectively "intervenors") filed a notion l
f in they request leave to bring to the Cemir,sion's attention a document
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entitled "Request For Financial Information" which was directed to Applicants by the NRC Staff on August 11, 1988. According.o intervenors, i
by requesting the informat on set forth in the attached document the Staff f
i has embraced "inconsistent puitions" with respect to the Massachusetts Attorney General's petition for waiver of the Comission's financial I
i qualification rules, and has "raise [d] evidence sufficient to make out a prima facie case" that application of those rules in this proceeding will not serve the purposes for which they were adopted.
See Motion at 1.
Although the instant rotio'1 filed by intervenors is not authorized by j
the Comission's Rules of Practice, the Staff does not oppose intervenors'
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request that the proffered document be included in the record.
As
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l explained below, however, nothing in the document suggests that the Staff
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4 2-2 has changed its position on the merits of intervenors' waiver petitions or l
constitutes information sufficient to warrant a waiver of the Comission's financial qualification rules.
j BACKGROUND
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l On July 5, 1988, the Appeal Board issued ALAB-895 1/ which affirmed f
the Licensing Board's dismissal of a petition for waiver of the
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Comission's financial qualification rules E/ filed by SAPL, NECNP, and I
the Town of Hampton, and which held that a separate waiver petition filed by. the Massachusetts Attorney General should be certified to the j
l Comission because it met the standards set forth in 10 C.F.R. I 2.758(b).
ALAB-895, slip op, at 39.
On July 12, 1988, SAPL, NECNP, and the Town of 4
2 Ha npton filed a petition for Comission review of ALAB-895.
In a response r
filed on July 22, 1988, the Staff opposed this petition for review and j
explained why the Appeal Board was correct in affirming the Licensing Board's denial of the waiver petition.
See NRC Staff Response To Joint
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Petitioners' Petition For Review Of ALAB-895, passim (July 22, 1988).
On July 14, 1988, the Commission issued an order soliciting the views of the $taff and Applicants as to whether it should exercise its l
discretion in favor of granting the Massachusetts Attorney General's petition.
See July 14, 1988 Order at 2.
Both the Staff and Applicants s
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Public Service Company of New Hampshire (Seabrook Station Units 1 f
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and 2), ALAB-895, 28 NRC (July 5, 1988) 2/
10 C.F.R. $l 2.104(c), 50.33(f), and 50.57(a)(4),
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- filed responses on July 22, 1988. 2/
In its order, the Comission stated that the Massachusetts Attorney General and any other party could file a reply to the responses of the Staff or Applicants. July 14, 1988 Order at
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2, The intervenors did so on August 2,1988.
See Intervenors Reply To f
The Responses Of The NRC Staff And Applicants To The Comission's Order Of July 14,1988 (August 2,198Ai; Response Of Massachusetts Attorney General James M. Shannon To Comission Order of July 14, 1988 (August 2, 1988).
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i In its response to the Comission's order, the Staff pointed out that t
the Appeal Board's finding that the Attorney General's petition met the i
i standards set forth in 10 C.F.R.
I 2.758(b) was based solely on I
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information presented by the Attorney General that one of the i
ra-applicants, MMWEC, had announced its intention to discontinue its share of the Seabrook maintenance costs. M The Staff also pointed cut that 4
subsequent to the issuance of ALAB-895, another of the Seabrook co-applicants. Northeast Utilities, announced its intention to fund r
HMWEC's share of the Seabrook maintenance costs through August 31, 1988.
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j Staff Response at 9-10.
The Staff also noted that the co-owners of the l
l Seabrook Station were working "to structure an arrangement to provide i
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See NRC Staff Response To Comission Order Of July 14, 1988 (July 22, j
TE8); Applicants' Response To The Comission's Order Of July 14, l
1988 (July 22, 1988).
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The Appeal Board stated
- J It is the financial inability or unwillingness of PSNH or some j
other joint owner to fund its share of the cost to operate i
Seabrook safely at low power that, if established, provides the I
i special circumstances warranting a rule waiver, j
ALAB-895, slip op, at 29.
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_ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. funding for the MWEC share for a period of at least a year." M.at10.
j In light of these developments, the Staff urged the Commission to deny the Attorney General's petition, arguing that "the circumstances underlying the Appeal Board's decision to certify the Attorney General's petition to the Commission no longer obtain."
j d,. at 10.
In other words, funds currently are available to Applicants to maintain and operate the Seabrook Statfor, safely, g, f
I In its response to the Commission's order, the Staff stated that even though the the Attorney General's waiver petition should be denied, the Staff would continue to monitor developments affecting the Seabrook t
Station:
r The Staff will continue to follow its usual practice of ronitoring developments bearing on Applicants' ability to maintain and operate the Seabrook Station safely and, pursuant to section 182 of the Atonic Energy Act, will require Applicants to demonstrate -- prior to the comencement of low power j
operations -- that there is reasonable assurance that they possess or can obtain the financial resources needed to conduct that activity in a manner that does not threaten the public I
health and ssfety.
M.at11,n.10. Consistent with this representation, on August 11, 1988, j
the Staff requested Applicants to provide certain information bearing on i
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their ability to fund the costs of maintenance, operation, and t
l decomissioning of the Seabronk Station after low power operations.
See i
t Attached Enclosure To Letter From Bruce Boger To Robert Harrison (August 11, 1988).
It is this request for information which intervenors argue P
represents a change in the Staff's position and which should irrpel the Commission to grant the Attorney General's waiver petition.
The t
intervenors are wrong.
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. _ - - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. l DISCUSSION No showing has been made to warrant a waiver of the Comission's financial qualification rules.
With respect to the waiver petition filed by SAPL, NECNP, and the Town of Hampton, the Staff argued -- and the Licensing and Appeal Boards agreed -- that neither the bankruptcy filing of the Public Service Company of New Hampshire nor New Hampshire's anti-CWIP law operate to deprive Applicants of the funds necessary to cperate the facility safely at low or full power.
See ALAB-895, slip op, at 18, 22.
Nothing in the motion filed by intervenors changes this salient fact.
Similarly, the Staff has urged the Cormiission to vacate the Appeal Board's finding that the A+,torney General's petition made out a prima facie case because, as discussed above, that finding has been superceded by intervening circumstances.
See Staff Response at 9-10.
I Nothing in the instant notion or the Staff's request for information from the Applicants to which intervenors allude suggests that these circumstances have changed materially. El The suggestion therefore that the infornation proffered by intervenors establishes a prima facie case warranting a waiver of the the Comission's financial qualification rules l
is baseless, 1
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Indeed and tn the contrary, the information sutcitted by Applicants I
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in response to the Stafs request indicates that Northeast Utilities has agreed to fund PFWEC's share of the project through November 20, i
1988, and that additional arrangements nay soon be completed which assure that MMWEC's share of the project will be paid at least through Decerrber 31, 1989. See Attached Enclosure to letter from Robert Harrison to NRC at 9 TAUgust 31,1988).
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6-In requesting Applicants to provide information bearing on their ability to maintain, operate, and decomission the Seabrook Station, the Staff simply was taking the type of action contemplated by the Comission when it relieved regulated utilities from showing their financial The Comission stated:
[T]he Comission does not intend to waive or relinquish its residual authority under Section 182a of the Atomic Energy Act of 1954, as amended, to require such additional information in individual cases as may be necessary for the Tommission to deternine whether an_ application should be granted or denied or whether a license should be modified or revoked.
"Elimination of Review of Financial Qualifications of Electric Utilities in Operating License Review and Hearings for Nuclear Power Plants",
49 Fed. Reg. 35747, 35751 (September 12,1984)(emphasisadded).
Essentially, intervenors argue that the Staff's request for financial information from the Applicants shows that the question of Applicant's financial qualifications to operate the Seabrook facility should be litigated. There is no merit to intervenors' position. The Staff, unlike an inte rver.o r, has the regulatory responsibility to protect the public health and safety.
To carry out this mission, the Atomic Energy Act provides, inter alia, that the "Comissier may at any tir.e... require further written statements in order to enable the Cemission to determine l
l whether the application should be granted or denied or whether a license l
should be modified or revoked."
42 U.S.C. I 2232.
This is why the Staff ray inquire into a regulated utility's financial qualification to operate a facility whenever it talieves it recessary to do so.
See 10 C.F.R.
Il2.102(a),50.71(b),50.73(c).
In order to warrant a waiver of the rules exempting a regulated utility frum having to demonstrate its financial qualification, a
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l petitioner must make a prima facie showing that application of the rule in question "would not serve the purpose for which the rule was adorted." 10 C.F.R. I 2.758(b).
This showing requires more than speculation about the financial condition of an applicant; a petitioner must make a showing thit is "legally sufficient to establish the fact or case unless disproved."
t Public Service Company of New Hampshire (Se6 brook Station, Units 1 and 2),
ALAB-653,16 NRC 55, 72 (19871 To warrant a waiver, intervenors were r* quired to demonstrate that the underlying premise of the financiai qualification rule --
i.e.,
that the rate process usures that funds needed for safe operation will be made available to regulated electric utilities, see 49 Fed. Reg. at 35750 -- is not applicable in this case.
For the reasons discussed in the Staff's response to the Comission's July a,1988, Order, intervenors have not made this showing.
That the Staff f
has requested financial infnrmation from Applicants does not constitute evidence undermining the premise of the rule; indeed, the Applicants response to the Staff's inquiry indicates.)at Applicants continue to have adequate funding through November 20, 1988 and continue to work on longer range funding. M n.5, supra.
i CONCLUSION The motion for leave to file an additional reply to the Comission's July 14, 1988 Order filed by 5APL, NECNP, Town of Harpston, and the l
Massachusetts Attorney General should be granted and the Massachusetts
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l 8-Attorney General's petition for waiver of the Comission's financial qualification rules should be denied.
Re e tfully submitted, 1
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I Gregory i an B ry Cot /nsel y fir Staff Dated at Rockville. Maryland this 14th day of September 1988 1
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UNITED STATES 6
I NUCLEAR REGULATORY COMMISSION e
W 45MINGToN, o. C. 20666 August 11. 1988 o
Docket No.: 50 443 Mr. Robert J. Harrison President & Chief Executive Officer Public Service Company of New Hampshire Post Office Box 330 Manchester New Hampshire 03105 j
Dear Mr. Herrison:
SUBJECT:
FINANCIAL COVERAGE FOR THE COST OF LOW POWER OPERATION REQUEST i
FOR ADDITIONAL INFORMATION As you are aware, the NRC is continuing to follow the financial aspects of i
Seabrook activities. The staff seeks clarification with tegards to the applicant's ability to provide financial coverage for the cnst of low power operation of Seabrook and the cost of any permanent shutdown of the facility and maintenance in a safe shutdown condition following low power operation.
It would be appreciated if you would provide the additional infonnation requested in the enclnsure by August 31. 19PP.
l Q [fruc Peger. Assistant irector Region I Reactors vision of Reactor Projects I/l!
Enclosure:
As stated See next page 1
@i(N/A5A7 I_
i ENCLOSURE REQUEST FOR FINANCIAL INFORMATION SEABROOK UNIT NO. 1 DOCKET NO. 50 443 1.
Pleaseprovidedetailedestimatesof(a.)thetotalcosttooperate Seabrook Unit No.1 at low power only (up to five percent power); and (b.)thetotalcosttopermanentlyshutdownthefacilityafterlowpower operation only and to maintain it in a safe condition, should that become necessary. Also provide an estimate of the cost to store and to dispose of the irradiated fuel assuming low power operation or.ly. Describe in i
i detail the assumptions underlying the estimates.
Include assumptions as j
to power leval, duration of operation, method of fuel storage and disposal l
and method of permanent shutdown and safe maintenance.
In response to l
l theabove,theapplicants(i.e.,thejointowners)shouldupdatetheir response to the NRC letter dated August 17, 1987. This request for information is iri addition-tt the reporting requirements of the tiRC's decomissioning rule published in the Federal Rgister on June 27, 1988, (53FR24018).
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2.
Please provide a detailed statement of the sources of funds for covering ll tctal costs of low power operation and total costs of percanent shutdown l
of ti:e facility and maintenance in a safe condition after a period of
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low power operation only.
Indicate the assumptions underlying the projection of each source of funds.
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Provide copies of the latest funding forecast approved by the joint l
j owners. Also provide copies of the funding performance for the most recent six months.
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4 Provide a detailed statement of the joint owners' plan for covering the 11.6 percent share of Seabrook costs that is no longer being paid by l
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Nassachusetts Municipal Wholesale Electric Company (WWEC).
Identify j
anyneworprospectiveowner(s)orotherparticipant(s)intheproject l
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covering the share of costs forrarly paid by WWEC. Describe how WWEC's
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share of costs will be covered by the time low power operation is authorized.
(For this purpose assume that low power authorization is received after September 1,1988.)
5.
Please identify any other joint owner (s) that is in default (or that is expected to be in default in the next twelve months) or in arrears t
or, its Seabrook payments. Describe the circumstances of the default (or potentialdefault)orthearrearageandindicatehowtheunpaidshareis l
being(orwillbe) covered. Describe the plan for coverage of the share through low power operation up until issuance of a full power license.
(For this purpose, assume a full power license is issued in the sumer 1989.)
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Describe the effect of bankruptcy on PSNH's ability to cover its share of Seabrook costs both currently and through a period of low power operation.
Please sumarize any pronouncements of the Bankruptcy Court that affect
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PSNH's ability to pay its total share of Seabrook costs both currently l
and through low power operation up until issuance of a full power license.
I Indicate if PSNH is up to-date on payment of its share of costs to the project end explain how PSNH expects to continue to be up-to date on its payments through low power operation up until issuance of a full power license.
(For these purposes, assume a full power license is issued in l
l thesurrer1989.)
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Describe the status of efforts to spin-off New Hampshire Yankee Electric Corporation as an independent company.
Explain any effects on responses l
l to tie above questions if the reorganization were to be accomplished.
8.
Provide the following for each joint owner a.
Copies of the most recent published, interim financial statements
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(andinterimreporttostockholdersfortheinvestorownedutilities).
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Copies of the 1987 SEC Form 10-K, the nost recent SEC Form 10-Q and the rest recent SEC Form 8 X, for the joint owners that file these reports.
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.h.0E p(T NRC Ouestion 4r Provide a detailad statement of the joint owners' plan for covering the 11.6 percent share of Seabrook costs that is no longer being paid by Massachusetts Municipal Wholesale Electric Corpany (MMWEC).
Identify any new or prospective owner (s) or other participant (s) in the project and describe in detail the arrangements for their participation and for covering the s' hare of costs forcerly paid by MMWEC.
Describe how MMWEC's share of costs vill be covered by the tino low power operation is authorized.
(For this purpose assume that low power authorization is received after September 1, 1988.)
Response _tp NRC Ouestion 4t On June 1, 1988 when MMWEC announced its intended "withdrawal from the Seabrook Station nuclear project", and that it would rake no further payments to the Seabrook Project and that it would seek an agreement "to take MMWEC out of the project in a financially responsible canner", the project account referred to above in Response to NRC Quest a
2 contained a posicive balance in MMWEC's favor sufficient cover MMWEC's share of the anticipated billings for the conth of Jur,e and part of July.
On July 13, 1988, Northeast Utilit'es ("UU"), the registered holding corpany parent of The connecticut Iight and Power Corpany, one of the Jcint owners, announces that it would advance sufficient funds in lieu of the MMWEC obligation to pernit the Project to reet its obligation through Augurt, 1988.
On July 20, 1988
$2,249,000 was advanced to the Project by NU, which will cover MMWEC's share to Septer.ber 9, 1988. -77/OlM&YT 2
b[h' cf;
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on August 3s, 1988 UU announced that it had concluded arrangements under which it will provide further funding "for the (MMWEC) portion of the Seabrook Nuclear Project that is subject to default" through November 30, 1988 (see Attachment 5).
This will pernit the Project to "cover" the MMWEC shcre through that period.
The status of MMWEC's participation in the Project has been the subject of active negotiation for some time.
MMWEC's unilateral announcement on June 1 that it was ceasing further payments corplicated these negotiations.
As indicated, the short-tern financial consequences of that announcerent are being covered by UU's payments through Nove-ber 30, 1988.
In addition, The United Illuminating Corpany has asser. bled investors who intend to cover the longer-tern consequences of the KMWEC def ault.
These investors will provide the Project up to $30 million of additienal funds as MMWEC's payrents fall due between Nover.ber 30, 1988 and December 31, 1989, which amount exceeds MMWEC's share of the presently estinated Project billings during that period.
The contracts to document this arrangement are in preparation and expected to be corpleted on or before Septenber 15, 1988.
A further response which provides the requested details of these arrangements will be filed at that time. [
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t 0N TE C' UNITED STATES OF AMERICA
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NUCLEAR REG"LATORY COMMISSION BEFORE THE COMMIS$!ON
'88 SEP 14 A9:29 l
In the Matter of i
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Docket Nos. 50-443 SL-01 %
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PUBLIC SERVICE COMPANY OF 50-444 OL-Ol '
l NEWHAMPSHIRE,tt,al.
On site Emergency Planning t
and Safety issues (Seabrook Station, Units 1 and 2) e CFRTIFICATEOFSERV!g I
I hereby certify that copies of "fiRC SW tl.SPONSE TO INTERVENOR$' MOTION FOR o
ACCEPTANCE OF ADDITIONAL REPLY TO COMM.
1 ORDER OF JULY 14, 1980 REGAR0!!iG l
ALAB-895" in the above-captioned procet n., have beca served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Comission's internal mail system, this 14th day of September 1988.
Samuel J. Chilk (15)*
H. J. Flynn, Esq.
Office of the Secretary Assistant General Counv i
U.S. Nuclear Regulatory Comission Federal Emergency Management i
Washington, DC 2055S Agency i
500 C Street, S.W.
Sheldon J. Wolfe, Esq. Chairman
- Washington, DC 20472 Administrative Judge l
Atomic Safety and Licensing Board Calvin A. Canney U.S. Nuclear Regulatory Comission City Hall Washington, DC 20555 126 Daniel Street Portsmouth, NH 03801 Or, Jerry Harbour *
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/,dministrative Judge Robert Carrigg, Chaittan Atomic Safety and Licensing B.urd Board of Selectmen l
U.S. Nuclear Regulatory Comiss" ',
Town Office Washington, DC 20555 Atlantic Avenue i
North Hampton, NH 03870 l
Dr. Erreth A. Lueble
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Adniriistrative Judge Judith H. Mizner, Esq.
l 4515 Willard Avenue.
Silverglate, Gertner, Baker.
l Chevy Chase, Maryland 20815 Fine, & Good 88 Board Street i
Philip Ahren Esq.
Boston, MA 02110 i
l Assistant Attorney General Office of the Attorney General J. P. Nadeau State House Station Board of Se!ectmen Augusta, ME 04333 10 Central Street i
Rye, NH 03870 Thocas G. Olgnan, Jr., Esq.
l Robert K. Gad, !!!, Esq.
l Ropes & Gray k
225 Franklin Stret L
Boston, MA 02110 r
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2-Carol S. Sneider, Esq.
Mr. Angie Machiros, Chairman Assistant Attorney General Board of Selectmen 4
Office of the Attorney General 25 High Road One Ashburton Place, 19th Floor Newbury, MA 09150 Boston, MA 02108 Allen Lampert George Dana Bisbee, Esq.
Civil Defense Director I
I Assistant Attorney General Town of Brentwood Office of the Attorney General 20 Franklin 25 Capitol Street Exeter, NH 03833 Concord, NH 03301 William Armstrong Ellyn R. Weiss. Esq.
Civil Defense Director l
Diane Curran, Esq.
Town of Exeter Harmon & Weiss 10 Front Street o
2001 S Street, NW Exeter, NH 03833 Suite 430 Washington, DC 20009 Gary W. Holmes, Esq.
Holmes & Ellis Robert A. Bacius, Esq.
47 Winnacunnet Road Backus, Meyer & Solomon Hampton, NH 83842 116 Lowell Street Manchester, NH 03106 Atomic Safety and Licensing Appeal Panel (8)*
Paul McEachern, Esq.
U.S. Nuclear Regulatory Commission Matthew T. Brock, Esq.
Washington, DC 20555 Shaines & McEachern 25 Maplewood Avenue Atomic Safety and Licensing P.O. Box 360 Board Panel (1)*
Portsnouth, NH 03801 U.S. Nuclear Regulatory Commission Washington, DC 20555 Charles P. Graham, Esq.
McKay, Murphy & Graham Docketing and Service Section*
100 Main Street Office of the Secretary Amesbury,itA 01913 U.S. Nuclear Regulatory Comnission Washington, DC 20555 Sandra Gavutis, Chairman Board of Selectmen Peter J. Matthews, Mayor RF0 #1, Box 1154 City Hall Kensington, NH 03827 Newburyport, MN 09150 l
William S. Lord Ashod N. Amirian, Esq.
l Board of Selectmen Town Counsel for Merrimac Town Hall - Friend Street 376 Main Street Amesbury, MA 01913 Haverhill, MA 08130 Sheldon J. Wolfe, Esq.
Administrative Judge 1110 Wimbledon Drive McLean, VA 22101 I....
2 Mrs. Anne E. Gocdman, Chairman Michael Santosuosso, Chairman Board of Selec'tmen Board of Selectmen 13-15 Newmarket Road South Hampton, NH 03827 Durham, NH 03824 lion. Golesn J. Humphrey United States Senate 531 Hart Senate Office Building Washington, DC 20510
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Grefory AJ in Bep 'y '
Counsel g NRCOitaff l
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