ML20205K593
| ML20205K593 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 02/24/1986 |
| From: | Johari Moore NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| Shared Package | |
| ML20205K595 | List: |
| References | |
| CON-#186-224 OL, NUDOCS 8602270578 | |
| Download: ML20205K593 (20) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00ty)C us BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
. 16 FEB 26 #0:15 In the Matter of )
CAROLINA POWER AND LIGHT )
Oh I COMPANY AND NORTil CAROLINA ) Docket No. 50-400 OL EASTERN MUNICIPAL POWER )
AGENCY -)
)
(Shearon !!arris Nuclear Power Plant) )
NRC STAFF RESPONSE TO Tile APPEAL BOARD'S QUESTION CONCERNIl!G CCNC CONTENTIONS 16,17 AND 18 Janice E. Pfoore Counsel for NRC Staff February 24, 1986 8602270570 860224 PDR ADOCK 05000400 0 PDR i
r o .
4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00LKgiLD BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD 16 FER 26 NO:15 In the Matter of )
.. ) Offitt u * -e' CAROLINA POWER AND LIGHT ) 00CKlithu r. :L i.v:r.l.
COMPANY AND NORT!! CAROLINA ) Docket No. 50-400 OL BRM EASTERN MUNICIPAL POWER )
ACENCY )
)
(Shearen !!arris Nuclear Power Plant) )
NRC STAFF RESPONSE TO T}lE APPEAL BOARD'S OUESTION CONCERNIIIG CCNC CONTENTIONS 16,17 AND 18 Janice E. Moore Counsel for NRC Staff February 24, 1986
e 4
TABLE OF CONTENTS PAGE(S)
TABLE GF CITATIONS 11 I. INTRODUCTION 1 II. DACKGROUND 1 III. DISCliSSION - 4 A. Collateral Estoppel 4 D. The Doctrine of Collateral Estoppel is Applicable to the Instant Proceeding, and There are no Changed Circumstances or Special Public Interest Factors Which Would Preclude its Application 6 IV. CONCLUSION 14
. 1
I
. TABLE OF CITATIONS NRC CASES _ PAGE(S)
Alabama Power Company (Joseph M. Farley Fuclear Power Plant, Units I and 2)
ALAB-182, 7 AEC 210 (1974), remanded on other grounds, CLI-74-12, 7 AEC 203 (1974) 4,5,9 Carolina Power and Light Company and North Carolina Eastern Municipal Power Agency (Shearon Ilarris Muclear Power Plant, Units 1 and 2)
LBP-82-119A,16 NPC 2069, 2082 (1982) 3 Carolina Power and Light Company (Shearon Harris Muclear Power Plant, Units 1, 2, 3 and 4),
LPP-78-4, 7 NRC 92,122-124 (1978) 6, 7, 8, 13 Commonwealth Edison Company (Braidwood Nuclear Power Station, Units 1 and 2)
LBP-85-11, 21 NRC 609 (1985) 5,6,8
[.
-111-
[
l l NRC CASES PAGE(S) l i
Houston Lightinr and Power Company, et al.
(South Texas Project Units 1 and 2),
Texas Utilities Generating Company, et al.
(Comanche Peak Steam Electric Station. Units 1 and 2)
LDP-79-27,10 NRC 563 (1979) >
5 Philadelphia Electric Company (Limerich Cenerating Station, Units 1 and 2) '
LDP-82-43A,15 FRC 1423,1459 (1982) '5 Public Service Electric and Gas Company et al.
(Hope Creek Generating Station, Unit 1) l ALAB-759,19 NRC 13, 25 n.40 (1984) 5 Southern California Edison Company, et al.
(San Onofre Nuclear Generating Station, Units 2 and 3) s ALAB-673,15 NRC 688 (1982) ; \ 5 9
. 'g N
UNITED STATES OF AP! ERICA NUCLEAR REGULATORY COMMISSION BEFORE TI!E ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of )
)
CAROLINA POWER AND LIGIIT )
COMPANY AND NORTH CAROLINA ) Docket No. 50-400 OL EASTERN MUNICIPAL POWEP )
AGENCY )
)
(Shearon Ilarris Nuclear Power Plant) )
NRC STAFF RESPONSE TO THE APPEAL BOARD'S OUESTION CONCERNING CCNC CONTENTIONS 16,17 AND 18 I. INTRODUCTION During the oral argument on the intervenors' appeal of the Licensing Board's Partial Initial Decision on Management Capability and Certain Safety Contentions which took place on February 5, 1986, the Atomic Safety and Licensing Appeal Board (Appeal Board) designated to hear eppeals in the above-captioned proceeding asked the parties to address in supplemental briefs a question concerning Intervenor Conservation Council of North Carolina's (CCNC) Contentions 16, 17 and 18. Tr. 63. The response of the Staff of the Nuclear Regulatory Commission (Staff) to this question is set forth below.
II. BACKGROUND In its original supplement to its petition to intervene, Intervenor CCNC proposed three contentions concerning Applicants' environmental monitoring program. " Conservation Council of North Carolina Supplement
To Petition To Intervene" (May 14, 1982). These were Contentions 16,17 and 18. The contentions stated as follows:
- 16. A composite sample of water over a two-week
- - period at sample point 26 (the spillway) is not
. adequate to protect water quality of Buckthorn Creek and the Cape Fear river. A daily composite sample would better determine if radioactive water is entering off-site surface waters. Tests should include gross beta, gamma, isotropic tritium, as well as for I-131, so that corrective meesures can be z
taken as soon as radiation levels are greater than background. '
t
- 17. One deep well groundwater monitoring station (sample point 39) is not adequate to protect the wells in the area listed in table 2.4.3-3.
All of the listed wells are used for drinking purposes by schools, homes and communities and the people using the welh need to be adequately protected from ' radioactive materials causing health problem 1. A weekly composite sample should be made at each of the wells to determine if radioactive material is contaminating groundwater in the area.
Tests should include gross beta, gamma ,
/ isotropic tritium, as well as for I-131, so that corrective measures can be taken as soon as radiation levels are greater than background.'
- 18. The sampling at the Lillington Water Supply intake (sampling point 40) is not adequate to protect the people in Lillington who drink that water. A monthly composite sampling will not monitor immediate presence. of radioactive materials in drinking water. A daily composite sample with tests for gross beta, gamma isotropic tritium, as well as for I-131, would better protect the health of people in Lillincrton by allowing for corrective
- measures to be taken by the Applicant or at the Lillington Water Supply as soon as .
radiation levels are greater than background.
The Applicants and the Staff opposed the admission of these contentions. The Applicants opposed them on the grounds that the contentions misunderstood the function of the program in question, and
that the issues of sampling frequency and the number of sampling points had been litigated at the construction permit proceeding. " Applicants' Response to Supplement to Petition to Intervene by Conservation Council
. of North Carolina" at 6-8 (June 15, 1982) [ hereinafter Applicants' Response]. The Staff opposed the contentions on the ground that they lacked adequate basis. "NRC Staff Response to Supplemental Statements of Contention by Petitioners to Intervene at 87 (June 22, 1982).
In rejecting these contentions the Licensing Board did not rely on the doctrine of collateral estoppel. Rather , the Licensing Board rejected the contentions on the ground that the contentions did not accurately address Applicants' proposal. Carolina Power and Light Company and North Carolina Eastern Municipal Power Agency (Shearon !!arris Nuclear Power Plant, Units 1 and 2), LBP-82-119A,16 NRC 2069, 2082 (1982).
Intervenor CCNC appealed this ruling claiming that the Licensing Board went to the merits of the contentions in rejecting them. " Appeal From Partial Initial Decision on Environmental Contentions" at 21 ( April 9, 1985). Both the Staff and Applicants argued in support of the Licensing Board's decision that the Board did not look to the merits of the contentions , but rather determined if they related to the license application which is in issue in this proceeding. " Applicants' Brief in Reply to Intervenors' Appeal From the Partial Initial Decision on Environmental Contentions" at 33 (May 9, 1985). "NRC Staff Brief in Reply to the Appeal of Joint Intervenors and Wells Eddleman of the Licensing Board's Partial Initial Decision on Environmental Matters" at 30-32 (May 24, 1985) [IIereinafter Staff Reply]. As the Staff pointed out, the contentions alleged that more needed to be done with respect to
sampling at three specific sampling points. The Licensing Board did not determine whether Intervenor was correct in its allegations. Instead ,
the Licensing Board determined that the additional requirements proposed
. by Intervenor did not relate to the monitoring system for public health and safety as proposed by Applicants. Staff Reply at 30-31. In addition, the Staff argued that the contentions did not state any reasons why the sampling procedures in place to confirm the accuracy of Ap'plicants' dose prediction model are inadequate, and thus the contentions lack basis.
Id. et 31.
During the oral argument on February 5, 1986, the Appeal Board posed the following question to the parties chheerning these contentions:
Are CCNC'S Contentions 16,17 and 18 barred from litigation in the Operating License proceeding by the Doctrine of Collateral Estoppel, or in accordance with the Commission's decision in Alabama Power Company, CLI-74-12, 7 AEC 203 (1974), are there any changed circumstances or special public intercet factors that preclude the operation of that doctrine in this instance?
Tr. 63. The Appeal Board requested the parties to file supplemental briefs on this matter by February 19, 1986. That date was c:: tended at the request of the Staff until February :'4,1956. As the analysis below demonstrates, collateral estoppel provides another ground, in addition to those relied upon by the Licensing Board in its Partial Initial Decisfor, for the rejection of CCNC Contentions 16,17 and 18.
~
III. DISCUSSION A. Collateral Estoppel It is well established that both the doctrines of res judicata and collateral estoppel are appropriate for use in operating license proceedings to preclude the relitigation of issues already litigated in a Construction
j l
Permit proceeding. Alabama Power Company (Joseph M. Farley Nuclear Plant, Units 1 and 2) ALAB-182, 7 AEC 210 (1974), remanded on other grounds, CLI-74-12, 7 AEC 203 (1974). See also, Public Service Electric and Gas Company et al. (flope Creek Generating Station , Unit 1),
ALAD-759, 19 NRC 13, 25 n.40 (1984); Sodhern California Edison Company, et al. (San Onofre Nuclear Generating Station, Units 2 and 3),
ALAD-673,15 NRC 688 (1982); Commonwealth Edison Company (Braidwood Nuclear Power Station, Units 1 and 2), LBP-85-11, 21 NRC 609 (1985);
Philadelphic Electric Company (Limerick Generating Station , Units 1 and 2), L B P-82-43 A , 15 NRC 1423, 1459 (1982); Houston Lighting and Power Company, et al. (South Texas Project Units 1 and 2), Texas Utilities Generating Company, et al. (Comanche Peak Steam Electric .
Station, Units 1 and 2), LBP-79-27, 10 NRC 563 (1979). The Commission has - indicated, however, that these doctrines must be applied with a sensitivity to any supported assertions of changed circumstances, or the possible existence of some special public interest factors in a particular case. Farley, supra, 7 AEC at 203. The doctrine of collateral estoppel is a judicially formulated doctrine based on considerations of economy of judicial time and the public policy of favoring certainty in legal relations.
ALAB-182, supra, 7 AEC at 212. A party must put forth its entire case, rather than attempting to present it piecemeal in multiple proceedings.
Id. These concepts are as important in Commi.ision proceedings as in the courts. d. at 214. As the Appeal Board has noted, the Supreme Court has said that when an administrative agency acts in a judicial capacity and resolves disputed issues of fact which parties have had an opportunity to litigate, these doctrines have been imposed. Id.
In order to establish the applicability of collateral estoppel - to a given issue, certain elements must be present. First, the prior tribunal must have had jurisdiction to render the decision. Next, the decision must have included a valid prior judgment on the merits. Third , the issue which a party seeks to preclude must have actually been litigated.
and, the issue must have been necessary to the outcome of the prior decision.
Finally, the party against whom the doctrine is asserted must have been a party or privy to a party in the earlier proceeding. Braidwood , supra ,
21 NRC at 620. An examination of each of these elements indicates that the doctrine of collateral estoppel is applicable to the instant proceeding.
B. The Doctrine of Collateral Estoppel is Applicable to the Instant Proceeding, and There are no Changed Circumstances or Special Public Interest Factors Which would Preclude its Application As discussed above, first it must be determined whether the issue sought to be precluded was decided by a tribunal with the jurisdiction to do so. The issues of the number of monitoring stations and the frequency of sampling involved in the Applicants' environmental monitoring program were first discussed before a Licensing Board in the construction permit proceeding. Carolina Power and Light Company (Shearon liarris Nuclear Power Plant, Units 1, 2, 3 - and 4), LDP-78-4, 7 NRC 92,122-124 (1978) .
There is no doubt that the Licensing Board in the construction permit proceeding had the jurisdiction to hear such matters. The Licensing Board hearing lead to the issuance of an Initial Decision which resulted in a final agency action, and thus constitutes a valid final judgement. Since the subject of Applicants' environmental monitoring program was the subject of a contention, the resolution of the issue was necessary to the
outcome of the proceeding. Finally, the party against whom the doctrine of collateral estoppel would be applied -in this operating license proceeding, CCNC, was an intervenor in the construction permit
, proceeding and participated in cross-examination of witnesses testifying with respect to Applicants' environmental monitoring program. See, e.g.
Tr.1045-1076 (October 8,1978) .
One of the key elements. In determining whether collateral estoppel is applicable in this proceeding is whether the issue which would be foreclosed by the doctrine's application was actually litigated. In the construction permit proceeding the contention which was litigated stated as follows:
The monitoring and surveillance program proposed by the Applicant is not adequate to assess fully the radiological consequences of the proposed plant and to take proper remedial action .to protect the health and safety of the public. The surveillance program is deficient in that (1) there are too few <
monitoring - sites; (2) the frequency of monitoring at these sites. is too small; (3) the preoperational monitoring will not have been conducted for a sufficient period of time to establish and verify operational data; and (4) the monitoring proposed will not determine the concentrations and biological magnification -of radioactivity of all plant and animal life in the food chain in the vicinity of the proposed plant.
LDP-78-4, supra, 7 NRC at 122. This contention is very broad in nature covering the entire program . Therefore , the Licensing Board was required to make findings which related to the entire program.
The contentions proposed by Intervenor CCNC at the operating license stage relate to several specific sampling points rather than to the entire environmental monitoring program . Each of the contentions challenges the sampling frequency at each of these sampling points. In
addition , Contention 17 challenges the number of sampling points for ground water. Testimony was presented by both the Applicants and the Staff at the construction permit proceeding which showed both the number of sampling points in the program and the frequency with which different media would be sampled . Responses to Intervenor Contentions ff Tr. 1020 ; Testimony of David A. Baker concerning Contention C.1 ff.
Tr. 1140. Based on this testimony the Licensing Board specifically found that the entire environmental monitoring program was adequate from the standpoint of the number of sampling locations and the sampling frequency. LBP-78-4, supra, 7 NRC at 123. In ordar for the Licensing Doard to have made such a finding, the issues of the number of sempling locations and the frequency of sampling had to have been discussed. In fact, the record of the construction permit proceeding demonstrates that a number of questions were posed to Applicants' witnesses on the subject of sampling frequency by CCNC's representative at that time. See, e.g.
Tr. 1048-104 9, 1059, 1075-1076. In light of the broad nature of the contention and the testimony and cross-examination duringr the construction permit proceeding, the Staff concludes that the issues presented by CCNC Contentions 16,17 and 18 have actually been litigated at the construction permit starre, even though the Licensing Board in that proceeding did not make specific findings with respect to each of the sampling points mentioned in these contentions. Since all of the elements required for the preclusion of an issue by collateral estoppel are present with respect to these contentions , collateral estoppel is applicable to '
them.
m
It next remains to be determined whether there are changed circumstances or special public interest factors which would warrant relitigation of these issues despite the applicability of collateral estoppel.
The Staff does not believe that any such changed circumstances or special public interest fsetors exist with respect to CCNC Contentions 16,17 and 18.
It is for the party who wishes to litigate a given issue to make a particularized showing of the existence of changed circumstances or a special public interest concern which would warrant the relitigation of a previously litigated issue. CLI-74-12, supra, 7 AEC at 204. Intervenor never attempted to allege such changed circumstances or ,public interest concern at any time during this operating license proceeding. M For a change in circunstances to render the doctrine of collateral estoppel inapplicable, the change in facts would have to be significant.
Farley , supra , ALAB-182, 7 AEC at 213. The situation present at the
~1/ In CLI-74-12, the Commission noted that where res {udicat'a or collateral estoppel is claimed as a basis for denying the admission of a contention, the Licensing Board must solicit tha response of a party whose contention is attacked on these grounds prior to deciding the matter. 7 AEC at 204. In this proceeding. although the words collateral estoppel were not used, Applicants argued in their response to Intervenor's supplement to its petition to intervene that the issue had previously been litigated at the CP stage. The Staff believes that Intervenor had an adequate opportunity to address the need to re"tigate issues concerning the environmentel monitoring program had they chosen to do so. In any event, they are being given that opportunity now. Intervenor was given an opportunity to respond to the argument of the Applicants and Staff in opposition to its contentions during a prehearing conference which took place on July 13-14, 1982. Intervenor did not eddress Applicants' argument that the issues had been previously litigated.
time the issue was originally litigated would have to be vitally altered between the time of the first resolution of the issue, and that of the second attempt .to litigate it in order for collateral estoppel not to be
. applied . Id. In effect, the change must be one which creates a new issue. 1B. J Moore, D. J. Lucas & T. Carrier, Moore's Federal Practice 6 0.448 (2nd ed.1984).
As noted in the Staff's Final Environmental Statement - Operating License (FES-OL), the Applicant's environmental monitoring program has been updated and expanded. FES at p. 5-36. The Staff has compared the environmental monitorinsr program set forth in the Applicants' Environmental Report at the Construction Permit stage (ER-CP) with that set forth in the Environmental Report for the Operating License (ER-OL),
in order to determine the extent of changes affecting the three sampling points mentioned in CCNC Contentions 16,17 and 18. Affidavit of Robert W.
Fell In Support of NRC Staff's Response to The Appeal Board's Question Concerning CCNC Contentions 16, 17 and 18 [ hereinafter Fell Affidavit].
As Dr. Fell notes, differences in the two environmental monitoring programs are to be expected , since the program in the ER-OL was designed to comply with guidance issued by the Staff in 1979. Fell Affidavit at i 3.
Thc Staff comparison of the sampling frequencies for the three sampling points which are the subject of CCNC Contentions 16,17 and 18 shows that there have been some changes in sampling frequencies. Fell Affidavit at if 5-0. However, the comparison demonstrates that the program in the ER-OL is equal to or better than that contained in the
FR-CP and approved by the Licensing Board at the CP stage insofar as these sampling frecuencies are concerned. Fell Affidavit at i 10.
For example, the program proposed in the ER-OL specifies the use of a
. composite sampler to collect small aliquot size samples over a period of thirty-c,ne days. At the end of each period a monthly gross beta analysis is performed along with a gamma isotopic determination. By combining some of these monthly composite samples, a quarterly composite sample is prepared for tritium determination. The ER-CP specified that samples of rurface water such as those at sample point 26 should be taken as weekly grab samples. A portion of each weekly sample was utilized for gross beta anclysis each week. A portion of each weekly sample was saved for three menths to provide a composite for the quarterly gamma isotopic and tritium determinations. Fell Affidavit at f 5. Since samples are taken at more frequent intervals in the ER-OL program, they provide a more accurate representation of the average discharge from the reservoir. The monthly gamma isotopic analysis is conducted more frequently than specified in the ER-CP, and thus is more conservative. Id. at f 6.
As for the groundwater (sample point 39) while the samples are collected on a quarterly rather than a monthly basis , the analysis frcouency for gamma isotopic determinations and tritium determinations remain the same as in the ER-CP. Fell Affidavit at i 7. The program in the EF-OL no longer contemplates a gross beta analysis. M. at i 8. It is the Staff's position that since the soil filters out most, if not all, of the radioactive particuletes that would be detected by a gross beta analysis, the performance of such an analysis would not provide meaningful
information . Id. Therefore , these two programs are essentially equivalent.
Fin lly, as far as the monitoring of drinking water at Lillington
. (sample point 40) is concerned, the Staff's comparison demonstrates that the sampling scheme specified in the ER-OL is better than that set forth in the ER-CP. - Fell Affidavit at S 9. This scheme involves the use of a composite sampler to obtain a sampic that almost continuously represents the drinking water consumed over the sampling period and accordningly will provide a more representative analysis for gross beta determinations than fcur weekly analysis as specified in the ER-CP. The analyses for gamma isotopic determinations are performed more frequently than was spa'ifiert in the ER-CP. In summary then, since the two programs are either equivalent or the ER-OL is better to that at the CP stage, the changes do not rice to the level of creating a new issue.
In addition, Intervenor's contention is not that the frequencies are inadequate because they differ from those which were set forth at the CP stage. Rather, Intervencr advocates the imposition of sampling frequencies which would be more stringent than those found to be adequate at the CP stage. Therefore, though there have been changes in the environmental monitoring program, they are not changes which actually present a new issue. Intervenor is still claiming, in essence, that the sampling frequencien found to be adequate at the CP stage are inadequate. For example, at the CP stage surface water was sampled on
-2/ The location of sample point 40 was moved in 1984 to a location 1/3 mile downstream from its previous location . Ilowever, this chenge is irrelevant since Contention 18 does not challenge the adequacy of the location of sample point 40.
4 a weekly basis. In the operating license program surface water is to be sampled by a composite sample gathered on a monthly basis. Fell Affidavit at i S. Intervenor would require that a daily composite sample of surface water be taken. This daily sampling would be more frequent than that approved at the CP stage. In order to provide a new issue to be litigated, Intervenor's contentions would have to be modified to reflect the changes and to specify in detail why relitigation would be necessary.
As far as that portion of Intervenor's contentions alleging that sampling should be done for gross beta, gamma and isotopic tritium as well as I-131 is concerned, there was testimony presented at the construction permit stage as to what types of analyses were performed, and the Board found that the program was adequate to assess the radiological consequences of the plant. LBP-78-4, supra, 7 NRC at 124. Therefore ,
although the contention at the CP stage did not specifically discuss the particular types of analyses which should be performed , the issue war actually aired at the CP stage. There do not appear to be any changes to the proPram which would raise a new issue concerning the types of analyses being performed.
l The Staff is not aware of any special public interest factors which would wcrrant the relitigation of these issues. The Staff has found Applicants' preoperational monitoring program to be adequate. FES-Ol at
- p. 5-37. The operational monitoring program will in essence be a continuation of the preoperational monitoring program with periodic adjustments of sampling frequencies. The specifics of this program will i
be incorporated into the plant technical specifications. ,Id . These activities demonstrate that such programs are under ongoing Staff l
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scrutiny, and thus the public interest does not demand the relitigation of issues previously decided concerning the environmental monitoring program at the CP stage. Finally, as the Applicants' have previously
. pointed out, the thrust of the Intervenor's contentions appears to be that the program is inadequate to allow the institution of corrective measures if radiation levels rose above background. As Applicants have stated, this is not the function of the environmental monitoring program.
Applicants' Response at 6-8. That function is performed by another monitoring system described in the FSAR. d. Therefore, any changes to the Applicants' env'irobmental monitoring program would not raise new issues concerning the system designed to monitor plant radiation releases.
Therefore, there are no changed circumstances which would require the relitigation of issues already decided at the construction permit stage.
IV. CONCLUSIO!!
For the reasons set forth above, the Sta ff concludes that the doctrine of collateral estoppel would bar litigation of CCNC Conten-tions 16, 17 and 18 in this proceeding, and that there are no changed circumstances or special public interest factors which would necessitate l
the relitigation of issues already resolved at the construction permit stage. Therefore, collateral estoppel is another basis upon which these contentions could have been rejected.
Respectfully submitted Janice II. Moore '
Counsel for NRC Staff Dated at Bethesda, Maryland this 24th day of February,1986 i
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