ML20205N332
| ML20205N332 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 10/31/1988 |
| From: | Matt Young NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#488-7396 ALAB-902, OL-3, NUDOCS 8811040066 | |
| Download: ML20205N332 (16) | |
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CCCKEit0 n a, UNITED STATES OF AMERICA NUCLEAR REGl'LATORY COPftISSION
- ES K! 31 P4 :27 BEFORE THE COMMIS_SION In the Patter of Docket No. 50-302-OL-3 LONG ISLAND LIGHTING COMPANY (Entgency Planning)
(Shereham Nuclear Power Station.
Unit 1)
NFC STAFF ANSWER TO LILCO REQUEST FOR RESUMPTION OF IMMEDIATE EFFECTIVENESS REY!EW OR FOR STAY Mitzi A. Young Ceunsel for hRC Staff Octcber 31, 1988 esi1040066 081031 ptm ADUCK 0b0003??
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1 10/31/88 l
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UNITED STATES OF AMERICA
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NUCLEAR REGULATORY C0m!SSION i
l BEFORE THE COMMISSION
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l4 In the Matter of 1
1 Docket No. 50-322-OL-3 LONG ISLAND LIGHTING COMPANY (Emergency Planning) 1 *
(Shoreham Nuclear Power Station, Unit 1)
NRC SfAFF ANSWER TO LILC0 RE0 VEST i
i FOR RESUPPTION OF !*EDIATE
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EFFECTIVENESS REVIEV OR FOR STAY I.
INTRODUCTION i
On October 21, 1988. LILCO filed a request for the Comission to
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"irrediately resume its irwediate effectiveness review of LBP-88-24 1
pending any review of the Appeal Board's decision in ALAB-902."
LILCO l
Request to Resune ! mediate Effectiveness Review or, in the Alternative.
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for a Stay of ALAB-902 ("Request"), at 1.
Alternatively, if the i
i Comissien determines that a stay of ALAB-902 is "a prereouisite to i
j continuing its irrrediate effectiveness review." LILC0 reouests a stay of ALAB-907 for the reasons set forth in its stay request to the Appeal Board f
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(Request Attachrent A).
Id. at 2.
For the reasons stated below, the NRC t
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Staff supports the requests for a stay of ALAB-902 and the resurption of
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the Comission's imediate ef fectiveness review, M l
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Pursuant to 10 C.F.R. I 2.788(e), answers to applications for a stay i
may not exceed ten pages.
The Staff's discussion of LILCO's stay j
request complies with this limit.
The additional pages in this I
filing discuss LILCO's alternative (or separate) request for the resurption of the Comission's issnediate effectiveness review.
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2-o
!!. BACKGROUND In LBP-88-24, 28 NRC slip op, at 148-49 (September 23,1988),the OL-3 Licensing Board, inter alia, dismissed Suffo16 County, the State of New York and the Town of Southanpton ("Intervenors") from the Shoreham proceeding and authorized the issuance of a full power license for Shorehan.
The Appeal Board in ALAB-902, 28 NRC slip op, at 20 (October 7,1956), reversed LBP-88-24 insofar as it "purports to dismiss the Governments free the proceeding now before the OL-5 Licensing Board"
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and vaerted the full power license authorization.
On October 14, 1988 LILCO sought a stay of ALAB-902 (see Request at Attachment A), and the Appeal Brord sumarily rejected this request for a stay in a Memorandun ard Order, dated October 10, 1988 ("Octeber 18 Order").
The Appeal Board cercluded that LILCO did not reed a stay of ALAB-902 to achieve the resurption of the Cemission's irrediate effectiveress review ard stated that LILCO was free to pursue "its objective elsewhere without further delay."
October 18 Order at 2-3, 5.
The Appeal Board reasoned that whilt it appeared that the imediate effectiveness review based en the Comission's receipt of LBP-88-24 had apparently been suspended, the stay of the effectiverest of ALAB-SC: was not a cerdition precedent to the resurption of the Comission's review.
M. at 5-6.
Rather, the Comissicr could as a matter of discretion, proceed with its irrediate effectivertss review "in the unusual circumstances of this cast if (1) it is asked to do so by one of the parties, and (2) it agrees with that party that such a step is, in fact, recuired to avoid irreparable ham."
Id.
at 5.
The Appeti Board thus recomended that LitCO ask the Comission "to i
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i resure its innediate effectiveness review pending the outcome of any
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petition LILCO may file for review of ALAB-902." M.at6.
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l III. DISCUSSION i
A.
Recuest for Stay i.
Pursuant to 10 C.F.R. I 2.788(e), any htemination as to whether an application for a stay should be granted must be based upon a l
consideration of the following four factors:
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(1) Whether the moving party has mde a strong showing that it is likely to prevail on the merits; l
l (2) Whether the party will be irreparably injured unless a stay is i.
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(3) Whether the granting of a stay would harm other parties; and (4) Where the public interest lies.
j While no one of the four factors is necessarily dispositive, the t
weightiest consideration is "the need to preserve the status quo --
whether the party recuesting a stay has shown that it will be irreparably injured unless a stay is granted."
Westinghouse Electric Corp. (Exports 1
to the Phil11 pines). CLI-80-14 11 NRC 631, 662 (1980).
In detemining i
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whether the revant has satisfied the fcur factors set forth in 10 C.F.R.
I 2.7BS(e), it must be recognized that:
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The burden of persuasion of these factors rests on the moving i
party.... To meet the standard of making a strong shewing
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that it is likely to prevati on the merits of its appeal. the movant riust do more than merely establish possible grounds j
for appeal, in addition, an "overwhelming showing of likelihood of success on the merits" is necessary to obtain a l
i stay where the showing on the other three factors is weak, t
i Alabara Power Co. (Joseph M.
Farley huclear Plant. Units 1 and 2).
I CLI-81-27.14 NRC 795 (19E1) (footnotes omitted), citing. Florida Power &
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l Light Co. (St. Lucie Nuclear Power Plant, Unit 2), ALAB-404, 5 NRC 1185, 1186-89 and ALAB 415, 5 hRC
- 1435, 1437 (1977);
see also Public ferviceCo.ofIndiana,Inc.
(Marble Hill Nuclear Generating Station.
Units 1 and 2), ALAB 437, 6 NRC 630, 632 (1977).
The U.S. Court of f
t Appeals has also explained the significance of the first two factors by j
statirp:
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To justify the granting of a stay, a movant need not always
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establish a high prebability of success on tbc merits.
- .j Frnbability of success it irversely proportional to the
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degree of irreparable injury eviderced.
A stay may be l
1 ranted with either a high probability of success and some t
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hjury, or vice versa.
Cucco v. NRC, 772 F. 2d 972, 974 (D.C. Cir. 1985).
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While LILC0 has feiled to demcnstrate that it will be irreparably I
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injured, the Comission should stay ALAB 902 (1) because there is a high l
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pretability of success on the merits ard (2) in order to preserve the l
l public interest by not allowing parties found guilty of misconduct which f
I prejudiced the integrity of NRC proceedings (LBP 88<24, slip op. at 130)
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to centinue to participate further in proceedings (other than an appeal of
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1.
Likelihood of Prevailing on the Perits This fartnr weight in favor of a stay.
The Staff believes that ALAB oP 's reversal of the OL-3 Licensing Board's authoritation to issue a
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l license was in error and that there is a streno likelihood that LILC0 will prevail or the merits.
The creation of the OL 5 docket in the $horehan t
.i proceeding was a case Panagement tool to expedite decisierraking on the l
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the 1986 exercise and did ret leave the principal licensirg board, the OL-3 Board, powerless tn frpose a sanction which would dismiss Intervenors i
fron the entire proceeding.
The licensing beerd constituted in the CL-3
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phase of the Shoreham proceeding was "to preside over the proceeding on I
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all emergency planning issues."
EstablishMnt of Licensing Board to j
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Preside in Proceeding. 48 Fed. Reg. 22235 (May 17,1983).
In accordance with the Cnmmission's direction in CLI-86-11. 73 NRC 577 (1986), the OL-3 1.
Pnard was originally given the respensibility to preside ever litigation j
l cf the results of the February 1986 emergency exercise at Shoreham S/ and j
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that li'.igetion was assigned the OL-5 dncket rumber "[f. lor more e'fective I
decketmanagerent."2/ The parel was later reconstituted to rer,edy member
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schedularconfitets.S
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l The Comission's decision in CLI-EC-11 was in response to riotions filed by LILCC ard Intervernrs requesting Comission guidance specifically 1
J eencerning litigatten of the results of the 1986 exercise.
See Motion of a
Suffolk County, the State of New York, and the Town of Southampton for
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Puling Concerning Proceedings Related te the Shoreham Exercise. Parch 7
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l 190C. at 1 2: Long Island Lighting Cocpany's Metion for Establishment of Licensing teard and Institution of Expedited Frocedures for Litigation of I
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Shoreham Er.ergency Planning Exercise issues, and Response to intervenors'
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Pereb 7 19PC Totion Concerning Proceeding Rele.ted to the Shoreham l
Exercise." Harch 13, 1986, at 1, 10.
Thus, the establisbrent of the CL-5 Boerd did net remove the jurisdiction of the OL-3 Board to decide all exercise-related matters, but was merely to accoglish the expedited litigation of the results of the 19% exercise.
In addition. the OL-5 l
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Establishrent of Atomic Safety and Licensing Board, 51 Fed. Reg.
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21815 (Jere 16, 1986).
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Chtnge of Docket Nud er. 51 Fed. Reg 07296 (July 30 1986).
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Recerstitutien nf Beard, 51 Fed.. Reg. 3ffl9 (October it. 1986),
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_ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ Board itself concluded that it no longer had jurisdiction over any matter concerning Shoreham once it had rendered its decision on the 1986 4
exercise. LBP-88 7, ?7 NRC 289, 291-9? (1988).
Foreover, the result in ALAB-902 appears to be at odds with the philosophy behind the Comission's guidance concerning the imposition of sanctions for a party's miseenduct.
In its Statement of Policy on Con-duct of Licensing Proceedings, CLI 81 8, 13 NRC 452, 454 (1981), the Comission stated thtt boards may irpose a spectrum of sanctions against an offending party, including the dismissal of the party from a proceeding.
The holding in ALAB-902 renders a licensing board powerless to irpose this severe sanctier, against a party fourc* guilty of willful l
misconduct in a preceeding solely because of the fortuitous separation, for administrative convenierce, of issues in a single proceeding into proceedings before more than one board, tinder these circumstances, NRC adjudicatory boards could nSt swiftly and thoroughly punish egregious r.isconduct ecrely because a case manarement tool has been 9tilized for administrative convenience.
In order to acceeplish the sancti.mn of diseissal frce the entire proceeding, the ratter rust be repeatedly raised before each board separately and each board must cons 4er tne facts surrounding the risconduct and the propriety of the sancuon, The better view, consonant with CLI-81 8 and the broad authority of boards to regulatc t>
conduct of participants in NPC proceedings,10 C.F.R.
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e that each board has the authority to dismit s, froin the proceeding, party it detemines has deliberately defied board orders that are in accordance with substantive requirerents (in this case, the realism rule).
In shert, this factor favors the granting of a stay, I
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Irreparable Injury This factor should be accorded little weight in evaluating LTLCO's notion.
LILCO argues that it will be "irreparably and unnecessarily harmed to the tune of about $1 millier a day, for every day that Shoreham licensing is delayed."
Request at 6.
LILCO also argues that because there is no reason to postpone completior cf the Commission's imediate effectiveness review until any review of ALAB-90; is completed, any expenditures caused by the postponement of the Comission's review would be unjustified.
M.
The Staff agrees that nomally the econorric damages cited by LILCO under this factor are a relevant consideration for determining whether a stay is approprir.te.
See cases cited in Request, Attachment A at 6-7.
However, in the unusual circumstances of this case, it is not clear that LILC0 will suffer any ham as a result of the suspension of the Comission's irredi.?te effectiveness review.
LILCC has not recounted the fact that (1) there is a settlement agreement which, if approved by various New York State entities (ircludino the State Legirlature and the Governor), wculd result in the sale of the Shoreham facility to the Long
- sland Power Authority so that it mcy be decomissioned and (21 LILC0 hes comitted riot to operate the facility in excess of five percent power while the settlerent process continues. 5/
While the approval of that agreerent by all the cognicant parties is in no way certain, it is o
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See BN 88-04, Recent Correspondence Between NRC and FEMA and Long TiTand Lighting Co., dated June 3,1988, at atteched letter from W.
J. Catacosines LILCO, to V. Stello, NPC, dated June 1,1988; Letter from W. T. Revely. III, to lion. Lando W. Zech, Jr., dated August 9, 1988.
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difficult to estimate under these circumstances the harm LILCO my suffer, if any, as a result of any delay in the completion of the Comission's imediate effectiveness review.
LILCO's failure to addrers these unique circumstances undemines its argument that it will be hamed unless a stay is granted.
Thus, this factor should be accorded little weight in determining whether a stay should be granted.
3.
Harn to Other Parties The granting of a stay pending review of ALAB-902 will not result in subttantial harm t( either the Intervenors or the Staff.
A stay will not result in the isswoce of a full power license for Wreham, October 18 order at 6. and Intervenors have previously indicated an intention to file their own stay notion, ge Request at 5.
In addition, if the license authorintion is reinstated, the Commission would still have to complete its immediate effectiveness review and would be faced with Intervenors' 1
request for
- stay of ALAB-90? and their assertion that their dismissal was inproper in the corrents they provided to the Comission. 6_/
A stay of the effectiveness of ALAB-902, without a stay of LBP-88-P4, would result in the Intervencrs not being able to actively litigate, for exanple, their proffered exercise contentinns in the OL-S proceeding. See Emergency Planning Contentions Releting to the June 7-9, 1988 Shoreham Exercite. October 24, 1988.
If the dismissal sanction is upheld, i
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See Suffolk County, New York State, and Town of Southampton Coments Encerning Immediate Effectiveness Review, October 3, 1988.
The Comission also has before it the matters in the imediate effee-tiveness coments filed by LILCO as well as the jurisdiction issues raised in LILCO's petition for review.
See LILCO's Coments on tha Immediate Effectiveness of LBP-88-24, October 3, 1988; Long Island Lighting Company's Petition for Review of ALAB-902, Oc ober 21, 1988.
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___ __ Intervenors will not have been injured by the foreclosure of their right to participate in anything other than an appeal.
If the dismissal sanction is not upheld, however, Intervenors would only be temporarily prevented from pursuing their enntentions and admission of those contentions is not guaranteed given the favorable FEMA finding concerning the 1988 E m
- ee Letter from G. C. Peterson, FEMA, to V. Stello, Jr., dated Septenber 9, 1988).
Thus, no substantial or irreparable harm to the other pcrties is evident from the grant of a stay and this factor l
should be accorded little weight.
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The Public Interest This facter favors the granting a stay, but on grounds other than those which LILCO has asserted.
LILC0 argues that this factor favors the grar.t of a stay because the public interest dictates that a "safe plant should he allowed to operate without unrecessary delay."
Request at 7.
In addition, LILCO states that the integrity of the NRC regulatory process requires that licensing board finding! as to the safe operation of Shoreham being given legal effect.
M.
Ordinarily, LILCO would be cor-rect that there is a public interest in the operation of a power facility capchle of safe operation. Hewever, as roted above, there is an agreement not to operate Shorehen during the pendency of the settlement agreement i
trproval process and that Shorehan is to be decornissioned if the settlement is approved.
LILCO's failure to address the effect of its I
1 agreement not to operate Shorehar' (ebove five percent perer) undermines l
its argument that there is substantial public interest in the operation of i
the Shoreham facility which is adversely affected by the absence of a l
stay.
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.m On the other hand, there is an important public interest in the timely conduct of agency determinations on a license application and an equally important interest in the integrity of NRC adjudicatory proceedings.
If ALAB-902 is stayed, the integrity of the NRC's adjudicatory process will be preserved by prohibiting a party who has been found guilty of egregious misconduct from further participction in hearings (e.g., on the 1988 exercise before the OL-5 Board) while the appropriateness of the dismissal !s under review. U In sum, the first and fourth factors weigh in favor of the granting of a stev of ALAB-902.
There is a strong likelihood that LILCO will prevail on the merits and a strong public interest in pemitting the Commission to come to tirely determir;ations on license applications while preserving the integrity of NRC proceedings.
While LILC0 may not suffer foreseeable injury if a stay is not granted, the strong likelihood that it will prevail on the merits coupled with the NPC's interest in the integrity of its license determinations warrants the application of a stay of the effectiveness of ALAB-90.1.
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As a
result of ALAB-902, Intervenors are currently free to 7
participate in the ongoing proceedings before the OL-5 Licensing Beerd concerning the 1988 exercise despite the fact that Intervenors have been fcund by the OL-3 Licensing Board to have engaged in a "pattern of behavior designed to prevent the Comission from reaching an informed conclusion with respect to the adequacy of LILCO's emergency plan." LBP-88-24, slip op. at 108.
Although Intervenors have the right to aopeal the OL-3 Board's determination, and such appeal is presently pending, the Staff opposes pemitting Intervenors to participate further in any other aspect of this licensing proceeding pending disposition of the appeal because Interverors have been found guilty of "a sustained willful strategy of disobedience and disrepect for the Comission's adjudicatory processes" and actions which were
' willful, taken in bad faith and prejudicial to LILCO and the integrity of the Comission's ad,iudicatory process." LBP-08-24, slip op, at 129, 130.
i B.
Request for Resumption of Innediate Effectiveness Review As noted by the Appeal Board in denial of LILCO's request for a stay of ALAB-902, a stay is not a prerequisite for the continuation by the Commission of its "immediate effectiveness" review as a matter of Comission discretion.
ALAB-902, slip op. at S.
In addition, Commission oversight concerring this matter is not dependent on the receipt of a ber.rd decision authorizing the issuance of a license for operation at power levels in excess of five percent since 10 C. F. R.
I2.764(f)(2) expressly reserves the authority of the Connission to step in at en earliertime.El A fundamental issue pervades the entire Shoreham proceedino at this tir.c -- whether Intervenors were properly dismissed by the OL-3 Licensing Board from further participcticn as parties in the Shoreham operating license proceeding en the grounds of seriers misconduct.
See '.RP-88-24, slip cp. at 148.
In ALAB-902 the Appeal Board concluded the OL-3 Licensing Board did not have jurisdiction to dismiss Interverors from the i
entire proceeding.
ALAB-902, slip op. at ?0.
That matter is the subject of related petitions for Ccenission review filed by LILCO. El Although
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these procedural questions may be resolved as a result of LILCO petitions for Comnissier review, the case as a whole will remain in the shadow of i
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As there is no outstanding authorization to operate (above five percent), the nature of the review would be socewhat different from de tertnining "whetner to stay the effectiveness of the 4
decision," 10 C.F.R. 6 2.764(f)(2).
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Long Island Lighting Company's Petitien for Review of ALAB-901 and i
Follew-On Orders, October 5,1988; Long Island Company's Petition 'or Review of ALAB-9CP, October 21, 1988, i
further procedural complexity until the Appeal Board (and perhaps subsequsntly the Comission) resolves the question of the merits of the OL-3 Coard dismissal sanction.
If the dismissal sanction is determined to nave been improperly imposed. LBP-88-24 itself may require revision to address the contentire before the OL-3 Board on the merits rather than as dicta (see slip op. at 131-147), and it will be necessary to complete litigation of other aspects of the proceeding such as contentions relatino to the 1988
- exercise, regardless of t'ie procedural question of jurisdiction to iropose sanctions.
On the other hand, if the sanction of dismissal imposed by LBP-88-24 is sustained, subsequent dismissal from other parts of the proceeding is a likely result given the character of the misconduct found by the OL-3 Board even if the procedural questions are decided in terms of separate sanction jurisdiction consistent with ALAB-902.
These same questions are before the Comission in connectio1 with LILCO's petitions for review of ALAB-901 and ALAB-902 and because Intervenors a.ierted in their immediate effectiveness coments that the sanctions were improperly imposed.
See section I!!.A.3, supra.
A Commission decision on these questions or Comission guidance to the Appeal Board and the Shoreham licensing board 5 based on its review of LBP-88-24 would be of great value ia bringing the remaining aspects of the overall Shoreham operating license proceeding to a close.
Regardless of whether a stay is granted or denied, the Comission should exercise its discretion to proceed with its review of matters in this case, but for reasons of greater moment that those of fered by LILCO.
i IV. CONCLUSION For the reasons stated above, the Comission should grant LILC0's requests for a stay of ALAB-902 and for the resumption of the Comission's imediate effectiveness review.
Respectfully submitted.
.J d
Mitz' A. Young Counsel for NRC Staff Dated at Rockville, Marylard this 31st day of October 1988 4
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UNITED STATES OF AMERICA NUCLEAR REGULATORY C04tISS10H BEFORE TFE COMMISSION In the Matter of
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LONG ISLAND LIGHTING COMPANY Docket No. 50-322-OL-3 (Shoreham Nuclear Power Station, Unit 1)
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CERTIF,1CATE OF SERVICE I hereby certify that copies of "NRC STAFF ANSWER TO LILCO REQUEST FOR PESUMPTION OF lhMEDIATE EFFECTIVENESS REVIEW OR FOR STAY" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the fluclear Regulatory Comission's internal mail system, as indicated by double asterisks, by telecopy, and triple asterisks, will be hand carried this 31st day of October, 1988.
Sariuel J. Chilk (15)***
John Blau, Esq Office of the Secretary Director, Utility Intervention U.S. Nuclear Reculatory Comission Suite 1020 Washington, DC 20555 99 Washington Ave.
t Albany, NY 12210 Dr. Jerry R. Eline*
Administrative Judge Atomic Safety and Licensing Board Fabian G. Palomino, Esq.
U.S. Nuclear Regulatory Comission Richard J. Zahnleuter, Esq."
Weshington, DC 20555 Executive Chamber State Capitol James P. Cleason, Esq., Chairman
- Albany, NY 12224 Adrrinistrative Judge Atonic Safety and Licensing Board Jonathan D. Feinberg, Esq.
U.S. Nuclear Regulatory Cormission New York State Department of Washington, DC 20555 Public Service Three Empire State Plaza Frederick J. Shon*
Albany, NY 12223 Administrative Judge Atenic Safety and Licensing Board W. Taylor Reveley III, Esq.
U.S. Nuclear Regulatory Comission Donald P. Irwin, Esq.**
Weshington, DC 20555 Hunton & Williams 707 East Main Street 1
Philip McIntire P.O. Box 1535 i
Federal Energency fianagement Richmond, VA 2321?
t Agency 2C Federal Plaza l
Roor 1349 New York, !!Y 10?78 i
Stephen B. Lathan, Esq.
Herbert H. Brown, Esq.
Twomey, Latham & Shea Lawrence Coe Lanpher, Esq.**
Attorneys at Law Karla J. Letsche, Esq.
33 West Second Street Kirkpatrick & Lockhart Riverhead, NY 11901 South Lobby - 9th Floor 1800 M Street, NW Atonic Safety and Licensing Washington, DC 20036-5891 Board Panel (1)*
U.S. Nuclear Reg'ilatory Comission Jay Dunkleberger Washington, DC 205E5 New York State Energy Office Atonic Safety and Licensing Agency Building 2 Appeal Panel (5)*
Empire State Plaza ll.S. Nuclear Regulatory Commission Albany, NY 12223 Weshington, DC 20555 Spence W. Perry, Esq.
Pcrtin Bradley Ashare, Esq.
General Counsel Suffolk Ccunty Attorney Federal Emergency Management H. Lee Dennison Building Agency Veteran's Memorial Highway 500 C Street, SW Hauppauge, NY 11700 Washington, DC 20472 Anthony F. Earley, Jr.
Dr. Monroe Schneider General Ccunsel Ncrth Shore Comittee
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t Long Island Lighting Company P.O. Box 231 175 Fast Old Courty Road Wading River, NY 11792 Hicksville, NY 11801 Ms. Nora Bredes Dr. Rcbert Hoffrsn Shoreham Opponents Coalition Long Island Coalitien for Safe 195 East Main Street Livirg Smithtown, NY 11767 i
P.O. Box 1355 Massapequa, NY 11758 William R. Cuming, Esq.
Office of General Counsel Alfred L. Nardelli, Esq.
Federal Energency Management New York State Departnent of Law Agency 120 Broadway 500 C Street, SW Roor 3-118 Washington, DC 20472 Docketit>g and Service Section***
Barbara Newman Offict cf the Secrettry Director Envirorcental Health U.S. Nuclear Regulatory Comission Coalition for Safe Lv/ing 3'
Washington, DC 20555 Box 944 Huntington, New York 11743 t
RTT 'A./ Young gf-r Couns for NRC Staff i
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