ML24250A100
| ML24250A100 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/05/2024 |
| From: | Lodge T, Taylor W Beyond Nuclear, Don't Waste Michigan, Law Office of Terry J. Lodge, Law Offices of Wallace L. Taylor, Michigan Safe Energy Future |
| To: | NRC/OCM |
| References | |
| Download: ML24250A100 (1) | |
Text
1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION IN THE MATTER OF
)
HOLTEC DECOMMISSIONING
)
INTERNATIONAL LLC
) Docket No. 50-255
)
PALISADES NUCLEAR PLANT
)
PETITION FOR DECLARATORY ORDER The Petitioners, Beyond Nuclear, Dont Waste Michigan, and Michigan Safe Energy Future (Petitioners), bring this Petition for Declaratory Order pursuant to the Administrative Procedure Act, 5 U.S.C. § 554(e), and in support thereof state as follows:
INTRODUCTION The Palisades Nuclear Plant (Palisades) is a nuclear power plant in Covert Township, Michigan. It was originally licensed for operation in 1971. The license was extended in 2007 for 20 years, to 2031. In 2017, Entergy Nuclear Operations, the licensee of Palisades, notified the Nuclear Regulatory Commission (NRC) that Entergy would permanently shut down Palisades no later than May 31, 2022. In fact, due to the performance of a control rod seal, Entergy closed the operation of the plant on May 20, 2022, 11 days early.
Entergys intent to shut down operation at Palisades placed the plant in decommissioning status. In connection with placing the plant in decommissioning status, Entergy certified, pursuant to 10 C.F.R. § 50.82(a)(1)(i), that power operations ceased at Palisades on May 20, 2022, and that pursuant to 10 C.F.R. § 50.82(1)(a)(ii), the fuel at Palisades was permanently removed from the Palisades reactor vessel and placed in the spent fuel pool on June 10, 2022 (ML22164A067). Those certifications in connection with
2 decommissioning prohibit operation of Palisades or replacement of the fuel into the Palisades reactor vessel.
On June 28, 2022, Entergy sold Palisades to Holtec Decommissioning International and Holtec Palisades (jointly Holtec). Holtec now proposes to restart Palisades and bring it out of decommissioning status and back to operational status. In order to accomplish this scheme, Holtec has submitted to the NRC a Request for Exemption From Certain Termination of License Requirements of 10 C.F.R. § 50.82 (ML23271A140). Without an exemption from the requirements of § 50.82, Holtecs plan to restart Palisades fails.
The exemption Holtec seeks, pursuant to 10 C.F.R. § 50.12, contains explicit requirements. And as the D.C. Circuit has said:
Section 50.12 provides a mechanism for obtaining an exemption from the procedures incorporated in section 50.10, but one that may be invoked only in extraordinary circumstances. The Commission has made clear that section 50.12 is available only in the presence of exigent circumstances, such as emergency situations in which time is of the essence and relief from the Licensing Board is impossible or highly unlikely. [citing Washington Public Power Supply System, 5 NRC 719, 723 (1977)].
NRDC v. NRC, 695 F.2d 623 (D.C. Cir. 1982). The Commission has also emphasized that
§ 50.12 exemptions are to be granted sparingly and only in cases of undue hardship. 39 Fed.
Reg. 14,506, 14,507 (1974). So Holtec bears an extremely heavy burden to justify its request for an exemption.
PARTIES AND STANDING
- 1. Beyond Nuclear Beyond Nuclear (BN) is a not-for-profit public policy, research, education organization based in Takoma Park, Maryland that advocates the immediate expansion of renewable energy sources to replace commercial nuclear power generation. Beyond
3 Nuclear has over 12,000 members of whom a number reside, work and recreate near the Palisades Nuclear Plant. Nuclears address is 7304 Carroll Ave., #182, Takoma Park, MD 20912, phone (301) 270-2209, www.beyondnuclear.org.
BN petitioned in 2021 to intervene in the on the application of Entergy Nuclear Operations, Inc., seeking approval of the transfer of control of Provisional Operating License No. DPR-6 and Renewed Facility Operating License No. DPR-20 for Big Rock Point Plant and Palisades Nuclear Plant, as well as the general license for the Big Rock Point Independent Spent Fuel Storage Installation and the Palisades ISFSI to Holtec Decommissioning International. Entergy Nuclear Operations, Inc., Entergy Nuclear Palisades, LLC, Holtec International, and Holtec Decommissioning International, LLC (Palisades Nuclear Plant) Docket Nos. 50-255-LT-2, 50-155-LT-2, 72-007-LT, 72-043-LT-
- 2.
BN additionally petitioned in 2015 to be an intervenor in a license amendment proceeding at Palisades wherein Entergy sought to amend its operating license by using an equivalent margin analysis to demonstrate that the steel plate and weld materials in the reactor pressure vessel would retain margins of safety against fracture from metallurgical embrittlement. Entergy Nuclear Operations, Inc. (Palisades Nuclear Plant), Docket No. 50-255-LA2.
BN also petitioned in 2014 to be made an intervenor in a license amendment proceeding at Palisades wherein Entergy desired to amend its operating license authorization to implement 10 CFR § 50.61a, Alternate fracture toughness requirements for protection against pressurized thermal shock events, in lieu of compliance with 10
4 CFR § 50.61. Entergy Nuclear Operations, Inc. (Palisades Nuclear Plant), Docket No. 50-255-LA.
- 2. Dont Waste Michigan Dont Waste Michigan (DWM) is a 30-year-old grassroots association with over 50 members in southern, western and central Michigan. DWM is located at 811 Harrison St.,
Monroe, MI 48161. DWM works to shut down aging, dangerous nuclear power plants in the Great Lakes Basin; to halt or block the construction of new nuclear power plants; to educate the public about the dangers of nuclear power and nuclear waste, its deadly by-product; and to block the practice of landfilling nuclear waste.
DWM petitioned in 2021 to intervene in the on the application of Entergy Nuclear Operations, Inc., seeking approval of the transfer of control of Provisional Operating License No. DPR-6 and Renewed Facility Operating License No. DPR-20 for Big Rock Point Plant and Palisades Nuclear Plant, as well as the general license for the Big Rock Point Independent Spent Fuel Storage Installation and the Palisades ISFSI to Holtec Decommissioning International. Entergy Nuclear Operations, Inc., Entergy Nuclear Palisades, LLC, Holtec International, and Holtec Decommissioning International, LLC (Palisades Nuclear Plant) Docket Nos. 50-255-LT-2, 50-155-LT-2, 72-007-LT, 72-043-LT-
- 2.
DWM additionally petitioned in 2015 to be an intervenor in a license amendment proceeding at Palisades wherein Entergy sought to amend its operating license by using an equivalent margin analysis to demonstrate that the steel plate and weld materials in the reactor pressure vessel would retain margins of safety against fracture from metallurgical
5 embrittlement. Entergy Nuclear Operations, Inc. (Palisades Nuclear Plant), Docket No. 50-255-LA2.
DWM also petitioned in 2014 to be made an intervenor in a license amendment proceeding at Palisades wherein Entergy desired to amend its operating license authorization to implement 10 CFR § 50.61a, Alternate fracture toughness requirements for protection against pressurized thermal shock events, in lieu of compliance with 10 CFR § 50.61. Entergy Nuclear Operations, Inc. (Palisades Nuclear Plant), Docket No.
50-255-LA.
- 3. Michigan Safe Energy Future Michigan Safe Energy Future (MSEF) is a grassroots association of people in western and southwestern Michigan which since 2013 has advocated for the permanent shutdown of Palisades Nuclear Plant and replacement of nuclear and natural gas power generation with safe and renewable nonnuclear energy technologies. MSEF has a dozen members and does not have a fixed office address.
- 4. Standing In determining whether a petitioner has sufficient interest in a proceeding, the Commission has traditionally applied judicial concepts of standing. See Metropolitan Edison Co. (Three Mile Island Nuclear Station, Unit 1), CLI-83-25, 18 NRC 327, 332 (1983)
(citing Portland General Electric Co. (Pebble Springs Nuclear Plant, Units 1 and 2), CLI-76-27, 4 NRC 610 (1976)). Contemporaneous judicial standards for standing require a petitioner to demonstrate that (1) she, he or it has suffered or will suffer a distinct and palpable harm that constitutes injury-in-fact within the zone of interests arguably protected by the governing statutes (e.g., the Atomic Energy Act of 1954 (AEA), the National
6 Environmental Policy Act of 1969 (NEPA)); (2) the injury can be fairly traced to the challenged action; and (3) the injury is likely to be redressed by a favorable decision. See Carolina Power & Light Co. (Shearon Harris Nuclear Power Plants), LBP-99-25, 50 NRC 25, 29 (1999).
An organization that wishes to intervene in a proceeding may do so either in its own right by demonstrating harm to its organizational interests, or in a representational capacity by demonstrating harm to its members. See Hydro Resources, Inc. (2929 Coors Road, Suite 101, Albuquerque, NM 87120), LBP-98-9, 47 NRC 261, 271 (1998). An organization seeking representational standing must demonstrate how at least one of its members may be affected by the licensing action (such as by activities on or near the site), must identify that member by name and address, and must show (preferably by affidavit) that the organization is authorized to request a hearing on behalf of that member. See, e.g., Georgia Institute of Technology (Georgia Tech Research Reactor, Atlanta, Georgia), CLI-95-12, 42 NRC 111, 115 (1995); Houston Lighting and Power Co. (South Texas Project, Units 1 and 2), ALAB-549, 9 NRC 644, 646-48-12 (1979); Houston Lighting and Power Co. (Allens Creek Nuclear Generating Station, Unit 1), ALAB-535, 9 NRC 377, 390-97 (1979).
Regarding the preference for an affidavit, see Shieldalloy Metallurgical Corp. (Cambridge, Ohio Facility), CLI-99-12, 49 NRC 347, 354 & n.4 (1999); Northeast Nuclear Energy Co.
(Millstone Nuclear Power Station, Unit 1), LBP-96-1, 43 NRC 19, 23 (1996).
In cases involving nuclear reactors, members of an organization who live within 50 miles of the reactor have presumptive standing. The presumption rests on the NRC finding, in construction permit and operating license cases, that persons living within the roughly 50-mile radius of the facility face a realistic threat of harm if a release from the facility
7 of radioactive material were to occur. Calvert Cliffs 3 Nuclear Project, LLC and Unistar Nuclear Operating Services, LLC (Combined License Application for Calvert Cliffs, Unit 3), 70 NRC 911 (2009).
- 5. Petitioners Have Demonstrated Standing Standing to participate in this proceeding is demonstrated by the proximity to Palisades stated in the declarations of the individuals annexed to this Petition. All individual Petitioners, in turn, have authorized the organizational Petitioners to represent their interests in this proceeding.
All but one of the individual members have provided evidence of living within 1 mile of Palisades. Alice Hirt lives 36.5 miles from Palisades. BN and DWM all are entitled to the presumption of injury-in-fact for persons residing within that zone. Houston Lighting
& Power Co. (South Texas Project, Units 1 & 2), LBP-79-10, 9 NRC 439, 443 (1979);
Detroit Edison Co. (Enrico Fermi Atomic Power Plant, Unit 2), LBP-79-1, 9 NRC 73, 78 (1979); and Entergy Nuclear Generation Co. & Entergy Nuclear Operations, Inc. (Pilgrim Nuclear Power Station), LBP-06-23, 64 NRC 257, 270 (2006)).
The exemption requested by Holtec is a prelude to a proposal to restart Palisades and that would inflict a safety and environmental risk on the Petitioners members for which the 50-mile presumption applies.
Even assuming, arguendo, there is no presumption of standing based upon mere close geographic proximity to Palisades, then standing should be accorded the individual citizens near Palisades based on the proximity-plus test, where a petitioner may show that the activity at issue involves geographical closeness to a significant source of radioactivity producing an obvious potential for offsite consequences. Sequoyah Fuels
8 Corp. and General Atomics (Gore, Oklahoma Site), CLI-94-12, 40 NRC 64, 75 n.22 (1994).
The case of Shaw Areva MOX Services, LBP-07-14 (2007) involved a license application for a mixed oxide fuel fabrication facility in South Carolina. The petitioners there submitted standing affidavits from members whose residences were within 20 to 32 miles from the facility site. The licensing board noted that the NRC Staff included residents as far away as 50 miles from the facility in its calculation of potential population doses. The Shaw decision suggests that a significant proximity radius is justified in cases involving large amounts of spent nuclear fuel, and cited Carolina Power & Light Co. (Shearon Harris Nuclear Power Plant), LBP-99-25, 50 NRC 25 (1999).
The notion of injury-in-fact encompasses all radiation impacts, including those that do not necessarily amount to a regulatory violation. See Duke Cogema Stone & Webster (Savannah River Mixed Oxide Fuel Fabrication Facility), LBP-01-35, 54 NRC 403, 417 (2001) (citing Yankee Atomic Electric Co. (Yankee Nuclear Power Station), CLI-96-7, 43 NRC 235, 247-48 (1996)). A minor exposure to radiation-even if it is within regulatory limits-will suffice to state an injury-in-fact. Id. And not only actual injury, but the threat of injury from radiation exposure, is sufficient to satisfy the injury-in-fact requirement of traditional standing. See Dominion Nuclear Connecticut, Inc. (Millstone Nuclear Power Station, Unit 2), CLI-03-14, 58 NRC 207, 216 (2003) (A threatened unwanted exposure to radiation, even a minor one, is sufficient to establish an injury.). See also, Duke Power Co. v. Carolina Environmental Study Group, Inc., 438 U.S. 59, 74 (1978). Here, the petitioning organizations members live, work and recreate near a site of a nuclear power reactor, and they express valid concerns that the reactor, although now involved in decommissioning, will be restarted and pose the risks of any operating nuclear plant.
9 Whether and at what distance from the radiation source a person can be presumed to be affected, and thus have legal standing, is judged on a case-by-case basis in NRC licensing cases, taking into account the nature of the proposed action and the significance of the radioactive source. While a petitioner must show that he or she lives, works or recreates proximate to the location of dangerously radioactive materials, importantly, the petitioner does not have the burden of articulating a plausible means through which those materials could cause harm. It is the inherent dangers of the radioactive materials that create the obvious potential for offsite consequences. U.S. Army Installation Command (Schofield Barracks, Oahu, Hawaii, and Pohakuloa Training Area, Island of Hawaii, Hawaii), CLI 20, 71 NRC 216, 218 (2010), citing USEC, Inc. (American Centrifuge Plant), CLI-05-11, 61 NRC 309, 311 (2005).
As noted, spent nuclear fuel is high-level nuclear waste and is inherently dangerous with obvious potential for offsite consequences. The reasonableness of a petitioners apprehension of injury must be left for consideration when the merits of the controversy are reached. Armed Forces Radiobiology Research Institute (Cobalt-60 Storage Facility),
ALAB-682, 16 NRC 150, 152, 154 (1982) (petitioners lived three to five miles from water-shielded irradiation facility at National Naval Medical Center holding 320,000 curies of radioactive cobalt-60 that allegedly Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel, (NUREG-2157) (2014) (Continued Storage GEIS or GEIS) at Executive Summary, p. lviii. were emitting gamma radiation; proximity to cobalt inventories sufficed to establish petitioner's interest). In Georgia Institute of Technology (Georgia Tech Research Reactor, Atlanta, Georgia), CLI-95-12, 42 NRC 111 (1995), the Commission left undisturbed the Atomic Safety and Licensing
10 Boards finding that it was neither extravagant nor a stretch of the imagination to presume that some injury, which wouldnt have to be very great, could occur within one half mile of the research reactor. Id. at 117. See also CFC Logistics, Inc., LBP-03-20, 58 NRC 311, 320 (2003) (petitioners residing from between one-third of a mile to three miles from a facility licensed to possess up to 1 million curies of cobalt-60 could rely on proximity presumption to establish their standing to intervene because of the quantity of radioactive material and its dangerousness). Also, see Louisiana Energy Services, L.P.
(National Enrichment Facility), CLI-04-15, 59 NRC 256, 257 (2004) (groups with members living at 2.5-and 4.9-mile distances, respectively, from the proposed facility live in [such] close proximity to the proposed LES facility that they would have an obvious potential to be affected by the facility). And in an earlier LES proceeding involving the proposed Claiborne Enrichment Center, the Licensing Board remarked that the petitioner (which had several members residing within 1 mile, in close proximity to the proposed facility) could rely on a presumption of injury from an accidental release of fission products. See Louisiana Energy Services, L.P. (Claiborne Enrichment Center), Memorandum and Order (July 16, 1991) (unpublished) at 6.
Prior agency rulings regarding spent fuel pool expansion proceedings also supply some guidance. Shearon Harris, LBP-99-25, 50 NRC at 29-31 (petitioner seventeen miles from the facility at issue accorded standing); Vermont Yankee Nuclear Power Corp.
(Vermont Yankee Nuclear Power Station), LBP-87-7, 25 NRC 116, 118-19 (1987); id.,
LBP-87-17, 25 NRC 838, 842, aff'd in part and reversed in part on other grounds, ALAB-869, 26 NRC 13 (1987) (residence within ten miles of ISFSI sufficient for standing);
Florida Power & Light Co. (St. Lucie Nuclear Power Plant, Unit 1), LBP-88-10A, 27 NRC
11 452, 454-55 (1988), aff'd, ALAB-893, 27 NRC 627 (1988) (standing of individual living within 10 miles of ISFSI conceded by parties); Northeast Nuclear Energy Co. (Millstone Nuclear Power Station, Unit 3), LBP-00-02, 51 NRC 25, 28 (2000) (standing granted individual with part-time residence located ten miles from ISFSI).
This petition relates to possible reactivation of the Palisades Nuclear Plant, implicating significant health, safety, environmental, and financial concerns for BN, DWM and their members. BN and DWM and their members will be at risk if there is a reactivation of the Palisades plant. The radiological risk to members health and safety is well documented in prior NRC reactor licensing cases.
In sum, Petitioner organizations have demonstrated, via declarations of their members, that the members face present or prospective injury, and that they reside close by inherently dangerous radioactive materials that could cause or contribute to extremely serious accidents and/or contamination accidents. Beyond Nuclear and Dont Waste Michigan all should be granted legal standing to pursue contentions denominated below on behalf of their members.
REQUEST FOR DECLARATORY ORDER On August 7, 2024, the NRC published notice in the Federal Register that Holtec has requested certain license amendments in order to restart Palisades. As explained above, however, Palisades cannot be restarted for power operations unless the NRC grants an exemption from decommissioning status pursuant to 10 C.F.R. § 50.12. On December 5, 2023, these Petitioners filed a petition to intervene and request for adjudicatory hearing.
One of the contentions presented in that petition was a challenge to the above-described
12 exemption being sought by Holtec. In its Order denying the petition to intervene, the NRC said that exemption requests do not form a basis for a hearing opportunity.
But the NRC did say that when an exemption request is inextricably intertwined with a licensing action triggering the opportunity to request a hearing, the hearing may encompass the exemption request as well, citing Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. (Vermont Yankee Nuclear Power Station), 83 NRC 542 (2016); Honeywell International, Inc. (Metropolis Works Uranium Conversion Facility), 77 NRC 1 (2013); Private Fuel Storage, LLC (Independent Spent Fuel Storage Installation), 53 NRC 459 (2001).
With respect to the Federal Register notice regarding Holtecs license amendment requests, the notice states, Consistent with the Atomic Energy Act of 1954, as amended, and NRC regulations, the NRC is not publishing a notice of opportunity for hearing on the exemption request. It is uncertain from this statement whether the NRC will allow the exemption request to be considered in a petition to intervene regarding the license amendment requests.
The Petitioners therefore request that a declaratory order be issued by the NRC stating whether the NRC will allow the exemption request to be considered in a petition to intervene regarding the license amendment requests.
APPROPRIATENESS OF A DECLARATORY ORDER 5 U.S.C. § 554(e) states, The agency, with like effect as in the case of other orders, and in its sound discretion, may issue a declaratory order to terminate a controversy or remove uncertainty. As explained above, there is uncertainty as to whether the NRC will allow the exemption request to be considered in a petition to intervene regarding the license
13 amendment requests. On the one hand, The response to Petitioners Petition to Intervene and Request for Hearing based on the exemption request stated that an exemption request does not give rise to a right to a hearing and the Federal Register Notice for the license amendment requests states that there would be no notice of opportunity for a hearing on the exemption request. On the other hand, the response to the previous request for a hearing stated that an exemption request could be the basis for a hearing request. These conflicting statements clearly create uncertainty. A declaratory order is therefore appropriate.
REQUEST FOR RELIEF Based on the foregoing and pursuant to 5 U.S.C. § 554(e), Petitioners request that the NRC issue a declaratory order declaring whether the NRC will allow the exemption request to be considered in a petition to intervene regarding the license amendment requests.
/ s/ Terry J. Lodge
/ s/ Wallace L. Taylor Terry J. Lodge Wallace L. Taylor 316 N. Michigan St, Suite 520 4403 1st Ave. N.E., Suite 402 Toledo, Ohio 43604 Cedar Rapids, Iowa 52402 419-205-7084 319-366-2428 (Fax) 419-932-6625 (Fax) 319-366-3886 e-mail: tjlodge50@yahoo.com e-mail: wtaylorlaw@aol.com CO-COUNSEL FOR PETITIONERS
14 CERTIFICATE OF SERVICE Pursuant to 10 CFR § 2.305, I hereby certify that copies of the foregoing Petition for Declaratory Order and Standing Declarations were served upon the Electronic Information Exchange (NRC Filing System) in the captioned proceeding this 5th day of September, 2024, and that according to the protocols of the EIE they were served upon all parties registered with the system..
Respectfully submitted,
/ s/ Wallace L. Taylor Wallace L. Taylor 4403 1st Ave. N.E., Suite 402 Cedar Rapids, Iowa 52402 319-366-2428 (Fax) 319-366-3886 e-mail: wtaylorlaw@aol.com
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Executed in Accord with 10 CFR 2.304(d)
Executed in Accord with 10 CFR 2.304(d)