ML20246B825
| ML20246B825 | |
| Person / Time | |
|---|---|
| Site: | 07000036 |
| Issue date: | 08/18/1989 |
| From: | Becchoefer C Atomic Safety and Licensing Board Panel |
| To: | ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY, AFFILIATION NOT ASSIGNED, COALITION FOR THE ENVIRONMENT, ST.LOUIS REGION, MISSOURI, STATE OF |
| References | |
| CON-#389-9066 89-593-01-MLA, 89-593-1-MLA, LBP-89-23, MLA, NUDOCS 8908240030 | |
| Download: ML20246B825 (20) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 19 Ara 18 P2 58 ATOMIC SAFETY AND LICENSYNG BOARD PANEL Before Administrative Judge: ((h ,,,,, , ' - (('.ka. -l g r. a k. "
Charles Bechhoefer SERVED AUG 1 8 1989 In the Matter of Docket No. 70-36-MLA COMBUSTION EIMINEERING, INC. ,
I (Hematite Fuel Fabrication ASLBP No. 89-593-01-MLA Facility, Special Nuclear ;
Materials License No. SNM-33) I August 18, 1989 i
l MEMORANDUM AND ORDER ;
(Recuests for a Hearinal l
By notice in the Federal Register of May 24, 1989 (54 Fed. Reg. 22510-11), the Nuclear Regulatory Commission provided an opportunity for a hearing on the proposed l amendment of the materials license of Combustion !
Engineering, Inc. (CE or Applicant) to authorize the installation and use of additional pellet production lines ,
j at its facility in Hematite, Missouri. CE currently carries on most of its pellet production activities at a facility in l
l Windsor, Connecticut, and it plans to transfer these operations to its Hematite facility (which aiready has the capability to perform this type of activity). To carry on the additional activities at Hematite, th,ree new buildings are to be constructed. Requests for a hearing and petitions
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for leave to intervene have been filed by four persons or organizations (three of them through a joint petition).
This proceeding is subject to theLinformal hearing procedures set forth in 10 C.F.R. Part 2, Subpart L
(" Informal Hearing Procedures for Adjudications in Materials Licensing Proceedings," 10 C.F.R. SS 1201-1263). On July' 24, 1989, the undersigned was designated as Presiding '
Officer, and I have appointed Administrative Judge Jerry R.
Kline, an environmental scientist, to assist me-in taking evidence and preparing a suitable record for review.- '54 Fed. Reg. 31749 (August 1, 1989).
For reasons set forth below, I am granting one of the petitions and seeking additional information concerning each of the petitions.
A. Backaround.
The requests for a hearing now pending before me consist of a petition, dated June 21, 1989, from State a Senator Jeremiah W. (Jay) Nixon (who represents the area in which the CE facility is located), and a joint petition, I
1 dated June 22, 1989, submitted by Ms. Martha Dodson (of Crystal City, MO), Ms. Karen Sisk (of Imperial, MO) and the Coalition for the Environment (of St. Louis, MO). These requests were each filed within the time limit specified in the Federal Register notice and hence were timely. By answers dated June 30, 1989 and July 7, 1989, respectively,
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the Applicant opposed each of the petitions. The NRC Staff, by letter dated August 3, 1989, exercised its option to decline to participate in the proceeding. See 10 C.F.R. S 2.1213.1 B. Apolicable Requirements.
The right to a hearing in materials license cases, as in other licensing proceedings, arises from S 189a. of the Atomic Energy Act, 42 U.S.C. S 2239(a). The Commission has implemented this statutory hearing right in materials license cases through its informal procedures at Subpart L of 10 C.F.R. Part 2. 54 Fed. Reg. 8269, 8270 (February 28, 1989). These informal procedures establish a significantly different and less structured methodology for providing a hearing than do the procedures for formal adjudications set forth at Subpart G of 10 C.F.R. Part 2. But, reflecting the common derivation of the hearing rights, a grant of intervention under the informal procedures is based on factors similar to those governing intervention in more formal adjudications: via, a requirement of appropriate standing or interest in the proceeding (which is " based upon the standards that are enunciated in S 2.714 for formal adjudications," see 54 Fed. Reg. at 8272), a statement of
'With respect to issues as to which I find that resolution would be aided materially by Staff participation, I retain the option of permitting or requesting the Staff to participate. 10 C.F.R. S 2.1213.
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i how a petitioner's interest may be affected'by the l proceeding, and identification of " areas of concern" to the i petitioner (comparable to the " aspects" requirement of 10 C.F.R. S 2.714 (a) (2)) . 10 C.F.R. S 2.1205(d). These " areas j of concern" must be germane to the licensing action under review--i.e., they must " fall generally within the range of .
matters that properly,are subject to challenge" in the
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proceeding. 54 Fed. Reg. at 8272.
l Procedurally, the Presiding Officer in an informal l
proceeding is afforded considerable discretion in developing information to determine whether a petitioner possesses the !
requisite standing. As indicated above, the standing requirement is similar to that in formal adjudications.
Consistent with the nature of the matters under i consideration in an informal proceeding, and the lower j i
potential radiation exposure attendant to materials license-l (as distinguished from reactor license) activities, the Commission has modified the method for demonstrating that a petitioner's interest may be affected by a licensing action; i it has indicated that the so-calledL" fifty-mile radius" rule l l which governs reactor licensing proceedings is not applicable in materials licensing cases. At the same time, the Commission rejected a presumption of a lack of standing i for persons residing or working more than five miles from a facility. 54 Fed. Reg. at 8272.
4 That does not mean, however, that proximity of a person's home or'workplace to a facility is not relevant to standing. All that is changed is the-applicable presumptions,,particularly as a result of'the wide variety.
of types of materials covered by materials license applications and the differing effects produced by each
- type. The standing of a petitioner in each case is thus:to be based upon the' circumstances of the case as they relate to the particular petitioner (and the particular material which is the subject of the application).
Reflecting the common statutory derivation of the formal and informal hearing procedures, the informal procedures, while differing in material respects-from the formal procedures, do not appear to have been intended to make it more difficult to attain intervention in an informal l
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proceeding than in a formal one. A meaningful-opportunity for a hearing must of course be offered.- City: of West i
. Chicaco. IL v. NRC, 701 F.2d 633, 645 (7th Cir. 1983)'.
. This !
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is particularly significant in view of the lack of' local- .
availability of material bearing upon a materials-license -l application. Unlike a reactor licensing proceeding,-'no l local public document room is available in an informal l proceeding.at the time a petition for. intervention:must be I filed. As a practical matter,,therefore, it is more difficult for a petitioner in an informa1' proceeding to I
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develop information in order to set forth exactly how an application might-affect its. interest and hence its standing to participate in a proceeding. That being so, a necessary concomitant of a meaningful right to a fair hearing is that a petition for. intervention need provide only.the minimal -
amount of detail essential to determ'ine that a petitioner has standing and seeks to: raise germane issues.
In its opposition to these petitions, the Applicant has advanced a variety of arguments, some of which I deem to.be hyper-technical in view of the informal nature of the hearing, to demonstrate that each of the petitioners lacks standing or for some other reason should not participate.2 However, CE has fairly pointed to deficiencies in the statements of standing of some of the petitioners.
For reasons spelled out below, I conclude-that the statement of standing of one of the petitioners (Ms. Dodson) 2 For example, with respect to'both petitions, the Applicant cites 10 C.F.R. S 2.1203(b) for the proposition that "a request for a hearing-must be filed with the Office of the Secretary" (Applicant's Answer to Sen. Nixon, dated June 30, 1989, at 3; Applicant's Answer to Joint Petition, dated July 7, 1989, at 4). Whatever may be the requirement with respect to pleadings generally, these petitions, which were addressed to the Executive Director for Operations, complied precisely with the terms set forth in the Federal Register notice with respect to the filing of-hearing requests (54 Fed. Reg. at 22511). This notice appears to have effectively modified the general pleading requirement j of 10 C.F.R. S 2.1203(b). See also 10 C.F.R. SS 2.1203(e),
2.1205(e) (regarding service of requests for a hearing).
The Applicant's position in this regard must therefore be l rejected; both petitions were properly filed.
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is marginally adequate (although susceptible to greater clarity with respect to the relationship of her intervention to that of other petitioners) and that the others include.
information which indicates that, except for technical omissions, the petitioners likely have standing to !
participate. For that reason, I am-granting leave for the various petitioners to supplement their petitions in certain l 1
respects, should they wish to do so.
C. Petition of Sen. Jeremiah W. (Jav) Nixon.
Turning to the specific petitions, State Senator Nixon !
specifically seeks a public hearing on the application 3. He i
states that he represents the area in which the facility.is I i
located in the state senate and also that he is a landowner, I
lifetime county resident and avid fisherman of Joachim Creek i (which is said to run "behind the facility"). Sen. Nixon then lists a number of his concerns, including increased j radiation, effect of approval of the application on water quality, changes in transportation patterns, volume of waste i produced at the plant, storage and disposal ofLthis waste, l potential accidents, and emergency procedures.
3 Sen. Nixon's petition, dated June 21, 19'8 9, was preceded by a telefaxed Memorandum dated June 19, 1989, also requesting a hearing. Both the Memorandum and the Petition were timely filed. I The Applicant comments that the petition it received-was unsigned. I have received copies of both a signed-petition and an unsigned copy, which must have been the one '
transmitted to the Applicant.
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-B-In opposition to.this petition, the Applicant correctly observes that a legislator cannot establish standing to intervene on behalf of unnamed constituents. He may, l however, intervene as a private citizen, assuming he otherwise has standing'to do so. See, e.a., General l
Electric Co. (GE Test Reactor, Vallecitos Nuclear Center),
LBP-79-28,,10.NRC 578,(1979). The petition does not state, however,.whether Sen. Nixon wishes-to participate individually or as a representative of his constituents.
To the extent Sen. Nixon wishes to participate as a-representative of his constituents, his petition would have to be denied for lack of. standing. However, if Sen. Nixon wishes to participate in this proceeding.in an individual capacity, he should so advise me, on the schedule set forth later in this opinion. He should also provide additional details concerning his standing--e.q,,'such matters as the proximity of the land he owns or of his residence to the' facility, and the frequency, extent and location of. his:
fishing activities viz-a-viz the facility. At this stage of the. proceeding, absent the local availability;of the case files, Sen. Nixon need only provide'a brief statement.of how-his interests may plausibly be affected byLthe concerns he has set forth.
- y As stated earlier, the concerns themselves need only be 1
a concise statement " sufficient to establish that'the issues 1 I
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the [ petitioner) desires to raise regarding the licensing action fall cenerally within the range of matters that properly are subject to challenge in such a proceeding." 54 Fed. Reg. at 8272 (emphasis supplied). I find that Sen.
Nixon's stated concerns with, inter alia, the proposal's increase in radiation discharges and in its effects on water quality parallel matters discussed in the Staff's recently issued Safety Evaluation Report and Environmental Assessment' and, hence, are sufficient at this stage of the proceeding to be deemed matters properly subject to challenge. l Pending my receipt of further advice from Sen. Nixon, I am deferring action on his proposed intervention.
D. Joint Petition.
l The joint petition includes hearing requests of two individuals (Ms. Dodson and Ms. Sisk) and an organization (the Coalition for the Environment). The request does not state whether the two individuals are members of the organization or whether each of the petitioners seeks to intervene personally or as a member of the group. The i petition notes that survice can be made on the representative of the Coalition, leading me to believe that i
' Safety Evaluation Report (SER) re: .Startup and Test of New Pellet Production Lines and Use of Additional Warehouse Space, dated July 28, 1989, at 1; Environmental Assessment (EA), dated May 17, 1989, at 3.
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the petition may be a joint one, with one intervention intended. Before I finally determine the nature of the
. requested intervention, however, I am affording each of the- 1 three petitioners the opportunity to supplement their petition. As of this time, I will treat the petitioners separately for determining standing. '
- 1. Ms. Dodson states that she lives approximately seven miles downwind from the plant, that the plant-is located on Joachim Creek approximately 15 miles from where it empties into the Mississippi River,-and that she obtains her drinking water from wells located on the Mississippi i River "just downstream." More importantly, Ms. Dodson.
states that she is an owner of undeveloped land.
approximately three miles downwind of the plant. 'She expresses concern about the increased'" potential for a criticality accident and for the release of greater amounts of radioactive and hazardous chemicals, particulate, and gases into the atmosphere, Joachim Creek (on which her property is situated), the groundwater, and onto land in all directions" (Petition, at 1).
Ms.'Dodson goes on to express concern about the lack of trained and equipped emergency responders and health care facilities in the county in the event of an accident at the i plant or "along the routes over which radioactive materials are delivered to and from the plant." She also. expresses 1
j concern about the potential for accidents resulting from the increased quantity of certain nuclear materials. allegedly to j result from tha proposed amendment, and'about the adequacy l of roads to handle an evacuation. Her final expression of concern relates to certain aspects of facility design, such'
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as' seismic capability of new structures and the ability of' the: site and its structures to' withstand flooding (Petition, l l
at 2, 4). (Except with respect to new structures,.the -
seismic and flood matters have been previously' reviewed and are thus not relevant to the. proposed amendment.)
The Applicant would have me reject the joint petition for a variety of reasons. Firat,-it states that the statements of concern are so broad and general that "no matters are placed in issue" (Applicant's Answer, at 3).
This objection, however, overstates the requirement for an L expression of concern at this early stage of:the proceeding.
It seeks a statement of issues comparable to that.which must be provided at a later date pursuant to 10 C.F.R.'S i
2.1233(c). The' Commission, however,'specifically rejected such a requirement. It stated: ,
This type of requireraent likely . is _ not practicable under-the present regulatory scheme. * *
- It would not-
- be equitable to require an intervenor to file its I written presentation setting forth all its concerns without access to the hearing file, 54 Fed. Reg. at 8272. The statement need only be sufficient 1
to establish that the issues. sought to be raised are germane
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to the proceeding--i.e. , that they fall. generally within the range- of matters that are subject to' challenge in the '
proceeding--so that the additional _ step of providing a presentation of issues under-10 C.F.R. $ 2-.1233 becomes3 warranted. Idx By expressing concerns comparable to -
certain of the matters dealt with by the Staff in its SER or EA (such as gaseous or effluent discharges. from the f acility) , Ms. Dodson has fulfilled the requirement for :s germaneness.
To demonstrate that her interests may'be affecta.d by the results of the proceeding, Ms. Dodson need only.show that her stated concerns could have an impact on her interests, which in this instance are property interests located - three and seven miles, respectively, _ from the plant, _
and a drinking water source located so;aewhat more' than.15 !
miles from the plant. Ms. Dodson asserts that the effluent discharges would have an adverse effect on her drinking water supply; perforce that would include an adverse effect on her riverfront property only three miles from the plant. {
A petitioner need not show that the effect on its interest )
l' is likely, only that it is plausible. Although' presumptions as to distance do not, in themselves, providrs a basis without more for determining that a petitioner has standing, Ms. Dodson's stated concerns go beyond that and provide a )
basis for determining that Ms. Dodson has set forth~an ]
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effect on her interests sufficient to confer standing.
Whether these concerns are justified, however, is a matter for consideration when the merits of issues in controversy are reached. Cf. Virainia Electric and Power Co. (North Anna Nuclear Power Station, Units 1 and 2), ALAB-522, 9 NRC 54, 56 (1979) (standing in formal proceeding involving expansion of spent fuel pool, where 50-mile presumption was questioned).
In short, Ms. Dodson has satisfied the requirements for intervention in this proceeding, and I am granting her petition insofar as it seeks intervention in her individual capacity. If Ms. Dodson rather seeks to participate only as a result of membership in Coalition for the Environment, she should so advise me, on the schedule set forth later in this opinion. In that circumstance, she should also authorize the Coalition to represent her--a step she may take only if she is a member of that organization. (Alternatively, should the Coalition be admitted as a party, she may agree that the Coalition is to be the lead intervenor on certain or all issues.)
- 2. Ms. Sisk's concerns parallel those of Ms.
Dodson. She additionally expresses concern.(as a registered f nurse) for the health of her minor children resulting from !
j emissions from the facility. Her interests, however, are i not as precisely set forth as those of Ms. Dodson. She
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14 - ,j provides her address and states that she is a resident of Jefferson' County but does not indicate the location of that address vis-a-vis the plant. She also does not provide any i additional explanation of a mechanism for plant discharges to affect either her property or her children. That being l so, I have no way of determining whether her concerns may plausibly affect her property.
l It appears, however, that with minor technical corrections, Ms. Sisk's petition.could be modified to reflect more clearly whether her interests may indeed be plausibly affected by the concerns sha has set forth. I am providing her an opportunity.to do so, on the schedule-set !
L forth later in this opinion. In the meantime, I am 1
deferring action on her petition.
In addition, as with Ms.-Dodson, Ms. Sisk has not indicated whether she wishes to intervonc eersonally or l
I through membership in the Coalition. When cLTrifying her petition, Ms. Sisk should indicate the manner in'which she wishes to intervene and, if a member of.the Coalition,
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d whether she wishes the Coalition to represent her interests. i
- 3. The Coalition for the Environment represents itself as a non-profit public interest organization
" serving" local organizations and citizens concerned with the environment. It states.that it has over 28,000 dues--
paying members in Missouri, Illinois and Kansas, many of 1
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c whom live within 50 miles of the plant and some of whom live in Jefferson County. No individual member is identified as authorizing intervention and as providing standing for the organization to intervene in a representative capacity. The-Coalition adopts the concerns as cet forth by the other two joint petitioners.
An organization may participate in an NRC proceeding either on its own behalf or as a representative of at least one member. Houston Lichtina and Power Co. (South Texas Project, Units 1 and 2), ALAB-549, 9 NRC 644, 646-47(1979);
Philadelphia Electric Co. (Limerick Generating Station, Units 1 and 2), LBP-82-43A, 15 NRC 1423, 1437 (1982);
Consumers Power Co. (Palisades Nuclear Plant) , LBP-79-20, 10 NRC 108 112-13 (1979). To participate on behalf of a member, the organization must identify the member and l demonstrate that the member has standing to participate on !
his or her own behalf and has authorized the organization to represent his or her interests. Houston Lichtina and Power Co. (Allens Creek Nuclear Generating Station, Unit 1), ALAB-535, 9 NRC 377, 390-96 (1976); Limerick, LBP-82-43A, suora, ;
15 NRC at 1437; Detroit Edison Co. (Enrico Fermi Atomic Power Plant, Unit 2), LBP-78-37, 8 NRC.575, 583 (1978).
The Coalition has not advanced any, organizational interest which would serve to establish standing to l
participate on its own behalf. It apparently seeks to
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1 participate as a representative of.certain members, but it
.has neither identified those members nor shown that any {
particular members have standing and have authorized such ;
representation. <
Therefore, the papers before me do not provide sufficient information for me to determine whether the -
Coalition has standing. Because the Coalition's petition i
indicates that the members it wishes to represent may well have standing, however, and taking into account the authorization of Ms. Dodson and Ms. Sisk to have papers !
served on the Coalition's representative, it appears that the Coalition may be able to establish that it has standing to intervene in a representative capacity. I am therefore 1 l deferring action on the Coalition's petition and will permit l
the Coalition to supplement its petition to provide the information outlined above. (The Coalition should also indicate whether a particular member who seeks coalition representation was a member at the time the Coalition filed its petition and, if not, when the member joined the organization.)
E. Other Matterst
- 1. As a result of my granting of one of-the petitions before me, the NRC Staff is required within 30 days to create a hearing file, containing documents relevant to this proceeding. 10 C.F.R. S 2.1231. The Staff may
t either provide this file to the parties or establish a local j public document room. In any event, the Staff should send me such documents (except for those which have already been l provided to me by it or the Secretary).
- 2. The supplements to the various requests for a hearing and petitions for leave to intervene which I have authorized to be filed should be filed (mailed) to me by Tuesday, September 5, 1989. (The information in these filings is of a type where a hearing file would'not normally-have been established.) The Applicant may' file a response by Monday, September 18, 1989. Thereafter, I will rule on whether any additional petitions should be' granted or I whether there should be a modification in the one petition 1 which I have thus far granted-(to reflect possible ;
representation of Ms. Dodson by the Coalition, or possible consolidation of Ms. Dodson with other' potential interveners '
whose petitions may be granted).
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- 3. I will issue a Notice of Hearing in the near future. That notice will, inter alia, provide an i
opportunity for limited appearance statements, as authorized by 10 C.F.R. S 2.1211.
- 4. In a letter to the Staff dated July-12, 1989, ;
l CE recognizes that the two petitions before me each appear l to solicit additional information about the proposed l amendment. CE suggests that the Staff sc'hedule an l
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information! public meeting to provide further explanations of the proposal.
I have been informally advised by the Staff that it intends to conduct such a meeting. This meeting, of course, is separate and-apart from the hearing sought by the
- petitioners in this proceeding. Attendance at-the informational meeting.would not affect a petitioner's opportunity to become a party in this proceeding. However, if a petitioner, through the informational meeting, determined that any or all of its concerns were not warranted, it should so advise me. "
F. Order.
For the reasons stated, it is, this 18th day of August, I
1989, l!
ORDERED:
- 1. The request for a hearing and petition for 1
) intervention of Ms. Martha Dodson is oranted.
- 2. Action is deferred on the petitions of Sen. l Jeremiah W. (Jay) Nixon, Ms. Karen Sisk,.and the Coalition I' for the Environment.
- 3. Supplements to the various intervention petitions, as described in this opinion, may be filed (mailed) by Tuesday, September 5, 1989., The Applicant may.
file a response by Monday, September 18, 1989.
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- 4. This Memorandum and Order, to the extent it grants an intervention petition, is subject to appeal to the Atomic Safety and Licensing Appeal Board pursuant to the l terms of 10 C.F.R. S 2.1205(n). Any appeal must be~ filed within ten-(10) days of service of this Memorandum and Order. The appeal may be supported or opposed by any party.
by filing a counter-statement within fifteen (15) days of service of the appeal brief.
M rs oe Dn)
. Charles Bechhoefer g Pren it'.ing Officer-ADMINISTRATIVE JUDGE Bethesda, Maryland August 18, 1989 W
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t.b R UN8TED STATES OF AMERICA NUCLEAR RESULATORY CCMMISSION ,
I in the Matter of 1
COMBUSTION ENGINEERING, INC. 1 Docket No.(s) 70-36-MLA i l )
(Hematite Fuel Fabrication Facility 1 License No. SNM-33) { i CERTIFICATE OF SERVICE-I hereby certify that copies of the foregoino LB MLO (LBP-89-23) DTD 8/18/89 have been served upon the following persons by U.S. mail, first class, except as otherwise noted and in accordance with the. requirements of 10 CFR Sec. 2.712.
Administrative Judge Administrative Judge !
Charles Bechhoefer Jerry R. Kline i
.Atomac Safety ano Licensing Board Atomic Safety and Licensino Board ;
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission ;
Washington, DC 20555 Washington, DC 20555 l I
a Michael A. Bauser,-Escuire Office of the General Counsel Newman & Holtzinger, P.C.
U.E. Nuclear Regulatory Commission 1615 L Street, NW Washington, DC 20555 Nashington, DC 20036 Missourt State Senator Jeremiah W. (Jay) Nixon 22nd District Martha Dodson Room 429 412 Mississippi State Capitol Crystal City, MD 63019 Jetferson City, MD 65101 Arlene Sandler President Karen Sisk Coalition for the Environment '
1123 Wolf Hollow Road St. Louis Chapter-l* Imperial, MO 63052 6267 Delmar Boulevard St. Louis, MO 63130 l
Dated at Rockville, Md. this # jI 10 day of August 1989 Office of the Secretary of the Commtssten
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