ML20004E303
| ML20004E303 | |
| Person / Time | |
|---|---|
| Issue date: | 05/19/1981 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML20004E300 | List: |
| References | |
| REF-10CFR9.7, RULE-PR-51, TASK-RICM, TASK-SE SECY-81-317, NUDOCS 8106110523 | |
| Download: ML20004E303 (15) | |
Text
. _ _.
O f I IYi Nffi May 19,1981 SECY-81-317 RULEMAKING ISSUE (Commission Meeting)
For:
The Commissioners From:
William J. Dircks Executive Director for Operations
Subject:
PROPOSED RULEMAXING TO ELIMINATE NEED FOR POWER AND ALTERNATIVE ENERGY SOURCES ISSUES IN OPERATING LICENSE PROCEEDINGS IN THE ABSENCE OF SPECIAL CIRCUMSTANCES
Purpose:
To obtain approval for the publication for public comment in the Federal Register of c notice of proposed rulemaking to amend 10 CPR Part al to provide that, for NEPA purposes, need for power and alternative energy source issues will not be considered in operating license proceedings for nuclear power plants and need not be addressed by oper-ating license applicants in environmental reports submitted to the NRC at the operating license stage, in the absence of a showing of special circumstances under 10 CFR 2.758.
Discussion:
On April 20, 1981 the Secretary transmitted to EDO, through S81-69, (Enclosure B) a request that (1) the staff develop procedures to solicit state and FERC input for the licensing EIS and for testimony before licensing boards with regard to need for power, energy conservation, and alternative energy sources and (2) that staff initiate rulemaking to preclude, in the absence of very significant new infannation, the reconsideration at the OL stage of need for power and energy alternatives. This paper is in itsponse to the second request.
Development of pro-cedures for working with States and FERC will be forth-coming. This paper also relates to the first paragraph of S81-208, Generic Rulemaking (April li,1981) which requested the staff to prepare a paper analyzing the
Contact:
Darrel Nash, OSP Ext. 492-9882 8106110 %
1 I desirability of rulemaking to move consideration of alternative energy sources at ae operating license review.
(Enclosure C) if the rule proposed in this paper is adopted, that part of S81-208 would become moot.
As explained more fully in the proposed Federal Register notice (Enclosure A), the proposed rule is grounded on the premise that in an OL proceeding it is extremely unlikely that an alleged reduction in the need for power or new developments concerning alternative energy sources, in and of themselves, could result in the dental of an operating license.
Rather, denial of the operating license would be warranted only in the rare or unusual case in which there has been some significant change in (or newly discovered) information concerning the public health and safety or environmental impacts associated with operation of the facility of such magnitude that mitigation measures would not be possible. The notice also points out that need for power and alternative energy sources are considered and resolved at the con-struction pennit proceeding and that experience demon-strates that constructed nuclear power plants are needed and do generate electricity - licensees do not abandon constructed facilities in favor of other alternatives.
Hence, it is very unlikely that the prior conclusions reached on these issues at the construction pennit stage l
will be upset at the operating license stage.
Accordingly, rules are proposed which would preclude consideration of need for power and alternative energy r
source issues in operating license proceedings and which provide that operating license applicants r 'd not address these issues in environmental reporu submitted to the NRC at the operating license stage. However, an exception to, or waiver of the rule would be pemitted in particular cases if special circumstances were shown in accordance with 10 CFR 2.758 of the Commission's regula-tions.
Recomendation:
That the Commission:
1.
Approve the enclosed notict of proposed rulemaking (Enclosure A) for publication in the Federal Register.
l i
i 2.
Acorove the staff's conclusions set forth in l
Enclosure D, which provides the analysis called for l
by the Periodic and Systematic Review ~ of the I
l
. Regulations. The criteria used were derived from Executive Order 12044 which was rescinded on February 17, 1981 by Executive Order 12291 (see memorandum from Bickwit to the Commission, February 27,1981). This approach is proposed as an interim procedure until the staff can make recommendations and the Commission decides what to do in response to Executive Order 12291.
3.
In order to satisfy re.quirements of the Regulatory Flexibility Act 5 U.S.C. 605(b) certify that this rule, if promulgated, will not have a significant economic impact on a. substantial number of small entities.
4.
Note:
a.
That the enclosed notice states that the Com-mission intends to apply the final rule, when effective, to ongoing license proceedings then pending and to issues or contentions therein.
b.
That pursuant to 951.5(d)(2) of the Commission's regulations, an environmental impact statement, negative declaration, or environmental impact assessment need not be prepared in connection with emendments to Part 51 of the regulations.
c.
That the appropriate Congressional committees will be notified of the proposed rule.
(Enclosure E) d.
That this proposed rule contains no new requirements for recordkeeping, reporting, l
plans or procedures, cpplications, or any other type of information collection, but will nonetheless be submitted to OMB for its I
consideration pursuant to the Paperwork Reduction Act.
e.
That the proposed rule contains a statement that the Commission certifies that the rule j
will not, if promulgated, have a significant economic impact on a s'.ibstantial number of small entities, pursuant to the Regulatory Flexibility Act of 1980, 5 U.S.C. 9 605(b).
l t
. f.
That the Staff will directly actify affected licensees and other persons of this proposed rule.
g.
That a Preliminary Value/ Impact Analysis is provided as Enclosure F.
William J. Dircks Executive Director for Operations
Enclosures:
A.
Notice of Proposed Rulemaking R.
S81-69 C.
S81-208 l
D.
Analysis With Respect to the Periodic and Systematic Review of Regulations E.
Draft Congressional Letter F.
Preliminary Value/ Impact Analysis l
DISTRIBUTION Commissioners Commission Staff Offices Exec Dir for Operations ACRS ASLBP ASLAP Secretariat l
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NUCLEAR REGULATORY COMMISSION (10 CFR Part 51)
NEED FOR POWER AND ALTERNATIVE ENERGY ISSUES IN OPERATING LICENSE PROCEEDINGS AGENCY:
Nuclear Regulatory Commission, ACT10N:
Proposed Rule.
SUMMARY
- The Nuclear Regulatory Commission (NRC), proposes to amend its regulations in 10 CFR Part 51, " Licensing and Regulctory Policy and Pro-cedures for Environmental Protection," to provide that, for NEPA purposes, need for power and alternative energy source issues will not be considered in operating license proceedings for nuclear power plants and need not be addressed by operating licence applicants in environmental reports sub-mitted to the NRC at the operating license stage. The NRC proposes to take this action to avoid potentially duplicative and unnecessary litiga-tion of issues previously resolved at the construction permit stage.
DATES:
Comment period expires 60 days after publicatici, in the Federal Register.
Comments recei' fed after (insert 60 days after publication in the Federal Register) will be considered if it is practical to do so, but assurance of consideration cannot be given except as to comments received on or before this date.
Enclosure A
, ADDRESSES:
Interested persons are invited to submit written comments and suggestions on the proposal and/or the supporting value/ impact analysis to the Secretary of the Commission, U.S. Nuclear Regulatory Commission, Washington, D.C.
20555, Attention: Docketing and Service Branch.
Single copies of the value/ impact analysis may be obtained -
request from Darrel A. Nash, Office of State Programs, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555 (Telephone: 301-492-9882). Copies of the value/ impact analysis and of comments received by the Commission may be examined and copied for a fee in the Commission's Public Document Room at 1717 H Street, N.W., Washington, D.C.
FOR FURTHER INFORttATION CONTACT: Darrel A. Nash, Office of State Programs, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555 (Telephone:
301-492-9882).
SUPPLEMENTARY INFORMATION:
In accordance with the Commission's NEPA respon-l sibilities, the need for the power to ba generated by a proposed nuclear l
power plant and alternative energy sources for the generation of the power, including no additional generating capacity at all, are considered and resolved in the construction pennit proceeding associated with the proposed l
l facility. The construction permit proceeding is the appropriate forum in l
the Commission's two step licensing process for resolution of these issues.
As the Commission's Appeal Board has recognized, " absent some 'need for l
power,' justification for building a facility is problematical" (emphasis g
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. added).1/ Alternative energy source issues are also highly relevant at the construction permit stage.
Prior to the start of construction there has been essentially no environmental disruption at the proposed site and only a relatively small capital 'avestment has oeen made by the license applf; ant.
l l
Hence, as a practical matter, at tne construction permit stage, real alter-natives to the construction and operation of the proposea facility exist, including no additional generating capacity at all if no "need" exists or generation of the needed electricity by some non-nuclear energy source.
Accordingly, need for power and alternative energy sources are often liti-gated by interested parties in contruction permit proceedings.2/
The situation is significantly different at the operating license stage, however. This stage of the licensing process is reached only after a prior finding by the Commissior. or its adjudicatory tribunals at the construction pennit stage that there existed a need for the power the proposed facility
(
would generate and that, on balance, no superior alternative energy sources existed. At the time of the operating license decision, construction f
related environmental impacts have already occurred at the site and the I
l J_/
Public Service Comoany of New Hampshire, (Seabrook Station, Units 1 &
l 2), ALAB-422, 6 NRC 33,90 (197/).
I
-2/
It should be noted that as a matter of policy the Commission endorses placing substantial reliance on State assessments of need for power, energy conservation, and alternative energy source analyses to fulfill NRC's NEPA responsibilities at the CP stage and has requested its staff to develop procedures to solicit input from the states and the Federal Energy Regulatory Commission for use in the environmental impact state-ment and for testimony before licensing boards in construction pennit proceedings.
. construction costs have been incurred by the licensee. The facility is essentially completely constructed and ready to operate when the Commission's Atomic Safety and Licensing Board renders its decision an the operating license application.
Given this factual background, the Commission cannot readily conceive of a situation where an alleged reductico in the need for power or new develop-ments concerning alternative energy sources, in and of themselves, could result in the denial of an operating license.
Simply put, in the Commis-sion's judgment, such a result would be unreasonable.
Rather, it is the Commission's view that dental of the operating license would be reasonable and justified only in the rare or unusual case in which there has been some significant change in (or newly discovered) information concerning the public health and safety or environmental impacts associated with operation of the facility of such magnitude that mitigation measures would not be possible.E
/
Furthermore, past experience amply supports the proposition that completed nuclear power plants are needed - licensees authorized to operate such plants do in fact operate them to the maximum extent of their availability to produce electricity and do not abandon th'em in favor of some other means i
l
'-3/
NEPA requires agency decisionmakers to only consider reasonable alternatives.
Friends of the Earth v. Coleman, 513 F.2d 295 (9th Cir.
1975); Natural Resources Defense Council v. Morton, 458 F.2d 827 (D.C.
l Ci r. 1972). The Commission recognizes this " rule of rearon." See Public Service Company of New Hampshire (Seabrook Station, Units 1 l
and 2), CLI-77-8, 5 NRC 503, 540 (19/7).
I l
of generating electricity.
Indeed, the costs of operating nuclear power plants are invariably below the operating costs of other methods of base-load generation except for hydroelectric plants which in some areas are used as baseload.
See Steam-Electric Plant Construction Cast and Annual Production Expenses, 1978 Annual Report, U.S. Department of Energy, Energy Infonnation Administration, Washington, D.C. 20641.
Based on all of the above, the Commission finds that new information con-cerning the need for power or alternative energy sources at the operating license stage, in and of themselves,1) would not warrant the denial of an operating license and 2) are very unlikely to upset the prior conclusions reached on these issues at the construction permit stage. Accordingly, the Commission propossis to amend its regulations in 10 CFR Part 51 to provide that need for power and altornative energy source issues will not be con-sidered in operating license prcceedings for nuclear power plants and need not be addressed by operating li ense applicants in environmental reports submitted to the NRC at the operating license stage.4I An exception to or waiver of the rule, if adopted, would be pennitted in particular cases
~
l 4_/
Promulgation of' these proposed rules in final fonn is not inconsistent with the Commission's earlier denial ct a petition for rulemaking,492 PRM-51-4, submitted by Boston Edison Company, et al. See 45 FR 10 (February 15,1980). That petition would have excludeo consideration of such matters as need for power, alternative sites, and alternative l
energy sources at the operating. license stage. The denial of the l
petition was grounded largely on the petitioners' erroneous and overly l
narrow assumption concerning the scope of an operating license safety l
review. However, the Commission specifically noted in the denial that it might be possible to limit the NEPA review at the OL stage to new infonnation of significance to the ultimate decision on the proposed action.
l
~-
if special circumstances are shown in accordance with 10 CFR 2.758 of the Commission's regulations, " Consideration of Commission rules and regula-tions in adjudicatory proceedings." The rules, if adopted in final fom, will apply to ongoing licensing proceedings then pending and to issues or contentions therein.
Regulatory Flexibility Certification In accordance with the Regulatory Flexibility Act of 1980, 5. U.S.C.
5605(b), the Commission hereby certifies that this proposed rule will not, if adopted, have a significant economic impact on a substantial number of small entities. The proposed rule eliminates certain reporting requirements for owners of nuclear power plants licensed pursuant to Sections 103 and 104b of the Atomir
.. Act, as amended, 42 U.S.C. 2133, 2134b. Owners of nuclear power plants are not within the definition of small business found in Section 3 of the Small Business Act,15 U.S.C. 5632, or within the Small l
Business Size Standards set forth in 13 CFR Part 121.
Paperwork Reduction Act Statement Pursuant to the provisions of the Paperwork Reduction Act of 1980 (Pub. t..
l l'96-511), the NRC has made a preliminary detemination that this proposed 1
rule does not impose new reporting or recordkeeping requirements.
This proposed rule has nevertheless been submitted to the Office of Management i
i l
. and Budget for its consideration of any potential or new morting or i
i recordkeeping requirements, pursuant to Pub. L.96-511.
Pursuant to the Atomic Energy Act of 1954, as amended, the National Environ-mental Policy Act, of 1969, as amended, the Energy Reorganization Act of 1974, as amended, and Section 553 of Title S of the United St5tes Code, notice is hereby given that adoption of the followiag amendments to 10 CFR Part 51 are contemplated:
1 It is proposed that 10 CFR '
t 51 be amended as follows:
The authority citation for Part 51 be revised to read is follows:
1.
Authority:
Sec. 161h., i., o., Pub. L.83-703, 68 Stat. 948 (42 U.S.C. 2201 (h), (i), and (o)); Sec. 102, Pub.
L.91-190, 83 Stat. 353 (42 U.S.C. 4332); Sec. 201, as amended, Pub. L 93-438, 88 Stat.1242; Pub. L.
94-79, 89 Stat. 413 (42 U.S.C. 5841) 2.
10 CFR 51.21 be revised to read as follows:
i 51.21 Applicant's Enviromental Report - Operating License Stage.
Each applicant for a license to operate a production or utilization facility covered by 5 51.5(a) shall submit-with its application the
i i
. number of copies, as specified in i 51.40, of a separate document, to be entitled " Applicant's Environmental Report-Operating License Stage."
which discusses the same matters described in 151.20 but only to the extent that they differ from those discussed or reflect new informatiori in addition to that discussed in the final environmental impact state-ment prepared by the Commission in connection with the construction permi t.
The "Applic?nt's Environmental Report-Operating License Stage" may incorporate by reference any information contained in the Appli-cant's Environmental Report or final environmental impact statement previously prepared in connection with the construction permit. Wi th respect to the operation of nuclear reactors, the applicant, unless otherwise required by the Commission, shall submit the " Applicant's Environmental Report-Operating License Stage" only in connection with the first licensing action that would authorize full power operation of the facility. No discussion of need for power or alternative enerqy l
sources for the proposed plant is required in the report.*
1 3.
Present i 51.53 be retained and designated paragraph (a) and a new paragraph (b) be added to read as follows:
151.53 Hearings - Operating Licenses.
(b) Presiding officers may not admit contentions proffered by any party concerning need for power or alternative i
l l
- The underscored words are proposed to be added. The underscoring will be removed prior to transmittal to the Federal Register.
=.
.g-energy sources for the proposed plant in operating license hearings and may not raise such issues sua sponte.
Dated at Washington, D.C. this day of
, 1981.
4 FOR THE NUCLEAR REGULSTORY COMMISSION Samuel J. Chilk Secretary of the Commission i
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