UNITED STATES OF AMERICA 

NUCLEAR REGULATORY COMMISSION 

COMMISSIONERS: 

Stephen G. Burns, Chairman 

Kristine L. Svinicki 

William C. Ostendorff 

Jeff Baran 

Docket No. 50-391-OL 

CLI-15-19 

MEMORANDUM AND ORDER 

Southern Alliance for Clean Energy (SACE) has filed a petition for review of LBP-15-14, 

in which the Atomic Safety and Licensing Board denied SACE’s motion to reopen the record in 

this proceeding on the Tennessee Valley Authority’s (TVA’s) application for an operating license 

for Watts Bar Unit 2.1 For the reasons set forth below, we deny the petition for review. 

I. BACKGROUND

SACE’s motion to reopen the record cites the March 12, 2012, request for information to 

all power reactor licensees and holders of construction permits in active or deferred status, 

issued by the Staff pursuant to 10 C.F.R. § 50.54(f). The request for information was issued in 

response to the agency’s evaluation of events leading to the Fukushima Dai-ichi accident of 

 

1 Southern Alliance for Clean Energy’s Petition for Review of LBP-15-14 Denying Admission of a 

New Contention Concerning TVA’s Failure to Comply with 10 C.F.R. § 50.34(b)(4) (May 18, 

2015) (SACE Petition for Review); see LBP-15-14, 81 NRC __ (Apr. 22, 2015) (slip op.). 

In the Matter of 

TENNESSEE VALLEY AUTHORITY 

(Watts Bar Unit 2) 
- 2 - 

March 2011.2 Regarding seismic and flooding hazards,3 the request for information described a 

two-phased approach for hazard evaluation: the Staff first requested that licensees submit to the 

Staff reevaluations of seismic and flooding hazards at their sites. The letter then stated that the 

Staff would implement the second phase by determining the need for additional regulatory 

actions based on the information submitted.4

TVA submitted its seismic hazard reevaluation and screening for Watts Bar Nuclear 

Plant on March 31, 2014.5 Based on this submission, the Staff determined that Watts Bar Units 

1 and 2 would require additional seismic risk evaluation.6 In response, TVA submitted an 

Expedited Seismic Evaluation Process Report for Watts Bar on December 30, 2014, concluding 

that no modifications or additional regulatory commitments were necessary.7

 

2 Leeds, Eric J., Director, Office of Nuclear Reactor Regulation and Johnson, Michael R., 

Director, Office of New Reactors, letter to All Power Reactor Licensees and Holders of 

Construction Permits in Active or Deferred Status (Mar. 12, 2012) (ADAMS accession no. 

ML12053A340) (Request for Information). 

3 See “Proposed Orders and Requests for Information in Response to Lessons Learned from 

Japan’s March 11, 2011, Great Tohoku Earthquake and Tsunami,” Commission Paper 

SECY-12-0025 (Feb. 17, 2012) (ML12039A111); Staff Requirements—SECY-12-0025—

Proposed Orders and Requests for Information in Response to Lessons Learned from Japan’s 

March 11, 2011, Great Tohoku Earthquake and Tsunami (Mar. 9, 2012) (ML120690347); see 

also Staff Requirements—SECY-11-0137—Prioritization of Recommended Actions to be Taken 

in Response to Fukushima Lessons Learned (Dec. 15, 2011) (ML113490055) 

(SRM-SECY-11-0137). 

4 Request for Information at 4-5. 

5 Tennessee Valley Authority, “Tennessee Valley Authority’s Seismic Hazard and Screening 

Report (CEUS Site), Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) 

Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the 

Fukushima Dai-ichi Accident,” (Mar. 31, 2014) (ML14098A478) (TVA Seismic Hazard Report). 

6 Leeds, Eric J., Director, Office of Nuclear Reactor Regulation, letter to All Power Reactor 

Licensees and Holders of Construction Permits in Active or Deferred Status (May 9, 2014), at 5 

(ML14111A147) (Leeds Letter). Watts Bar and several other plants were “screened in” and 

directed to complete further seismic evaluations based on a higher re-evaluated seismic hazard. 

7 Tennessee Valley Authority, “Tennessee Valley Authority’s Watts Bar Nuclear Plant Expedited 

Seismic Evaluation Process Report (CEUS Sites) Response to NRC Request for Information 

Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force 
- 3 - 

The Board had terminated this adjudicatory proceeding on September 9, 2014, following 

resolution of the last contested issue.8 On February 5, 2015, SACE filed motions to reopen the 

record and for leave to file a new contention based on the information contained in TVA’s 

Expedited Seismic Report.9 TVA and the NRC Staff opposed both motions.10 In its proposed 

new contention, SACE asserted that “TVA’s Final Safety Analysis Report ... is deficient under 

10 C.F.R. § 50.34(b)(4) because it does not include the information provided in TVA’s 

[December] 30, 2014 Expedited Seismic Evaluation Process ... Report for Watts Bar Nuclear 

Plant.”11

 

Review of Insights from the Fukushima Dai-ichi Accident,” (Dec. 30, 2014) (ML14365A072) 

(Expedited Seismic Report). 

8 LBP-14-13, 80 NRC 142 (2014). We have authorized the Director of the Office of Nuclear 

Reactor Regulation (NRR) to issue the full-power operating license for Watts Bar 2 if the 

Director of NRR determines “that the applicable findings may be made and that the proceeding 

is uncontested.” Staff Requirements—SECY-15-0068—Watts Bar Nuclear Plant, Unit 2—

Review Status and Authority of the Director of the Office of Nuclear Reactor Regulation for 

Operating License Issuance (May 26, 2015) (ML15146A213). The Staff’s work regarding these 

findings is ongoing. 

9 Southern Alliance for Clean Energy’s Motion to Reopen the Record (Feb. 5, 2015; corrected 

Feb. 6, 2015) (Motion to Reopen); Southern Alliance for Clean Energy’s Motion for Leave to File 

a New Contention Concerning TVA’s Failure to Comply with 10 C.F.R. § 50.34(b)(4) (Feb. 5, 

2015; corrected Feb. 6, 2015) (Motion for Leave to File New Contention). 

10 NRC Staff’s Answer to Southern Alliance for Clean Energy’s Motion for Leave to File a New 

Contention (Mar. 3, 2015) (Staff’s Answer Opposing SACE’s Motion for New Contention); 

Tennessee Valley Authority’s Answer Opposing Southern Alliance for Clean Energy’s Motion for 

Leave to File a New Contention (Mar. 3, 2015) (TVA’s Answer Opposing SACE’s Motion for 

New Contention); NRC Staff’s Answer to Southern Alliance for Clean Energy’s Motion to 

Reopen the Record (Feb. 18, 2015) (Staff’s Answer Opposing SACE’s Motion to 

Reopen);Tennessee Valley Authority’s Answer Opposing Southern Alliance for Clean Energy’s 

Motion to Reopen the Record (Feb. 17, 2015) (TVA’s Answer Opposing SACE’s Motion to 

Reopen). 

11 Motion for Leave to File a New Contention at 1. 
- 4 - 

The Board denied SACE’s motion to reopen the record, finding that SACE did not satisfy 

the requirements for reopening set forth in our rules of practice.12 SACE has now petitioned for 

our review of the Board’s decision. The NRC Staff and TVA oppose SACE’s petition.13

II. DISCUSSION 

A. Standard of Review 

We will grant a petition for review at our discretion, giving due weight to the existence of 

a substantial question with respect to one or more of the following considerations: 

(i) A finding of material fact is clearly erroneous or in conflict with a finding 

as to the same fact in a different proceeding; 

(ii) A necessary legal conclusion is without governing precedent or is a 

departure from or contrary to established law; 

(iii) A substantial and important question of law, policy, or discretion has been 

raised; 

(iv) The conduct of the proceeding involved a prejudicial procedural error; or 

(v) Any other consideration which we may deem to be in the public interest.14

SACE argues that the Board’s decision raises “important issues of law and policy.”15 

As discussed below, we find that SACE has not raised a substantial question that merits 

review. SACE has not identified any error in the Board’s application of our reopening standards 

to its motion to reopen the record. 

 

 

12 LBP-15-14, 81 NRC at __ (slip op. at 7). In so holding, the Board declined to address the 

merits of SACE’s motion for leave to file a new contention. Id. 

13 NRC Staff Answer Opposing the Southern Alliance for Clean Energy Petition for Review of 

Board Decision LBP-15-14 (June 12, 2015) (Staff’s Opposition to SACE Petition); Tennessee 

Valley Authority’s Answer Opposing Southern Alliance for Clean Energy’s Petition for Review of 

LBP-15-14 (June 12, 2015) (TVA’s Opposition to SACE Petition). 

14 10 C.F.R. § 2.341(b)(4). 

15 SACE Petition for Review at 1. Although SACE does not specify the subsection on which it 

bases its request for review, we presume it intended to rely upon section 2.341(b)(4)(iii). 
- 5 - 

B. Reopening Standards 

Motions to reopen the record in our adjudicatory proceedings are governed by 10 C.F.R. 

§ 2.326, which states the following: 

(a) A motion to reopen a closed record to consider additional evidence will 

 not be granted unless the following criteria are satisfied: 

(1) The motion must be timely. However, an exceptionally grave 

 issue may be considered in the discretion of the presiding officer 

 even if untimely presented; 

(2) The motion must address a significant safety or environmental 

 issue; and 

(3) The motion must demonstrate that a materially different result 

 would be or would have been likely had the newly proffered 

 evidence been considered initially. 

(b) The motion must be accompanied by affidavits that set forth the factual 

 and/or technical bases for the movant’s claim that the criteria of 

 paragraph (a) of this section have been satisfied. Affidavits must be 

 given by competent individuals with knowledge of the facts alleged, or by 

 experts in the disciplines appropriate to the issues raised. Evidence 

 contained in affidavits must meet the admissibility standards of this 

 subpart. Each of the criteria must be separately addressed, with a 

 specific explanation of why it has been met. When multiple allegations 

 are involved, the movant must identify with particularity each issue it 

 seeks to litigate and specify the factual and/or technical bases which it 

 believes support the claim that this issue meets the criteria in paragraph 

 (a) of this section. 

Our case law interpreting section 2.326 makes clear that the regulations place an intentionally 

heavy burden on parties seeking to reopen the record.16 The rule reflects the importance of 

finality in adjudicatory proceedings.17 As we have noted, “the burden of satisfying the reopening 

 

16 Entergy Nuclear Generation Co. and Entergy Nuclear Operations, Inc. (Pilgrim Nuclear Power 

Station), CLI-12-15, 75 NRC 704, 714 (2012) (citing AmerGen Energy Co., LLC (Oyster Creek 

Nuclear Generating Station), CLI-09-7, 69 NRC 235, 287 (2009)). 

17 Private Fuel Storage, L.L.C. (Independent Spent Fuel Storage Installation), CLI-05-12, 61 

NRC 345, 350 n.18 (2005) (citing Vt. Yankee Nuclear Power Corp. v. Natural Res. Def. Council, 

Inc., 435 U.S. 519, 554-55 (1978)). 
- 6 - 

requirements is a heavy one,” and it rests with the party moving to reopen.18 To this end, “a 

motion to reopen will not be granted unless the movant satisfies all three of the criteria listed in 

10 C.F.R. § 2.326(a) and [the motion] is accompanied by an affidavit that satisfies 10 C.F.R. 

§ 2.326(b).”19 We have previously explained that “[w]e consider reopening the record for any 

reason to be ‘an ‘extraordinary’ action.’”20 Courts of appeal have consistently upheld our 

reopening standards, noting that “[a]gencies are permitted to impose requirements or thresholds 

for parties seeking to reopen a closed record”21 and acknowledging that these criteria may be 

“exacting.”22

C. Analysis 

In examining whether SACE’s motion to reopen the record satisfied the requirements of 

section 2.326, the Board found that SACE’s motion to reopen was timely filed.23 But the Board 

determined that SACE had not fulfilled the remaining requirements of section 2.326(a) because 

it neither addressed a significant safety or environmental issue nor demonstrated the likelihood 

 

18 Oyster Creek, CLI-09-7, 69 NRC at 287 (citing Public Service Co. of New Hampshire

(Seabrook Station, Units 1 and 2), CLI-90-10, 32 NRC 218, 221 (1990); Louisiana Power & 

Light Co. (Waterford Steam Electric Station, Unit 3), CLI-86-1, 23 NRC 1, 5 (1986)). 

19 Id.

20 Entergy Nuclear Vermont Yankee LLC and Entergy Nuclear Operations, Inc. (Vermont 

Yankee Nuclear Power Station), CLI-11-2, 73 NRC 333, 337-38 (2011) (citing Final Rule, 

Criteria for Reopening Records in Formal Licensing Proceedings, 51 Fed. Reg. 19,535, 19,538 

(May 30, 1986)). 

21 Mass. v. U.S. Nuclear Regulatory Comm’n, 708 F.3d 63, 75, n.18 (1st Cir. 2013) (citing Vt. 

Yankee, 435 U.S. at 554-55 (1978)); see also N.J. Envtl. Fed’n v. U.S. Nuclear Regulatory 

Comm’n, 645 F.3d 220, 233 (3d Cir. 2011) (“We have upheld the motion to reopen standard and 

deferred to the NRC’s application of its rules, so long as it is reasonable.”); Oystershell Alliance 

v. U.S. Nuclear Regulatory Comm’n, 800 F.2d 1201, 1207 (D.C. Cir. 1986) (“In examining 

petitioners’ plea to reopen the record, we rely on the same court-sanctioned test applied by the 

Commission ....”). 

22 N.J. Envtl. Fed’n, 645 F.3d at 234. 

23 LBP-15-14, 81 NRC at __ (slip op. at 6 n.30); see 10 C.F.R. § 2.326(a)(1). 
- 7 - 

of a materially different result upon consideration of its proposed new contention.24 Additionally, 

the Board found that the affidavit that SACE submitted with its motion to reopen the record did 

not meet the requirements set forth in section 2.326(b).25 As discussed below, SACE has not 

raised a substantial question with respect to the Board’s ruling.

SACE does not argue that the Board erroneously applied the reopening standards to its 

motion in its petition for review. Instead, SACE focuses its argument on the reopening 

standards themselves, asserting that “the Board imposed a burden that was greater than what 

the law required for the contention submitted by SACE.”26 SACE argues that the Board should 

have required it to demonstrate only that the information was pertinent, but it does not explain 

why it believes the reopening standards are inapplicable to its motion.27 SACE also argues that 

by requiring it to meet the reopening standards, the Board “erroneously shifted the burden of 

proof from TVA to SACE.”28 But the moving party properly bears the burden of meeting the 

reopening standards.29

In requiring SACE to meet the reopening standards set forth in section 2.326, the Board 

complied with our rules of practice and procedure. Section 2.335(a) of our regulations prohibits 

 

24 LBP-15-14, 81 NRC at __ (slip op. at 6). 

25 Id. at __ (slip op. at 7). SACE has not challenged the Board’s determination that its affidavit 

does not comply with section 2.326(b). Because a party must meet all of the section 2.326 

requirements to reopen the record, the motion to reopen could have been deemed insufficient 

for this reason alone. 

26 SACE Petition for Review at 6. 

27 Id. at 5. 

28 Id. at 7. 

29 TVA retains the burden of proof on the question whether the license should be issued, 

pursuant to 10 C.F.R. § 2.325. See Oyster Creek, CLI-09-7, 69 NRC at 269 (citing Louisiana 

Power and Light Co. (Waterford Steam Electric Station, Unit 3), ALAB-732, 17 NRC 1076, 1093 

(1983)). 
- 8 - 

challenges to our rules and regulations in the context of adjudicatory proceedings.30 By arguing 

that it should have been allowed to meet a lesser standard when moving to reopen the record, 

SACE impermissibly challenges the reopening standard. 

SACE also argues that the Board disregarded its concerns about the Staff’s review of 

TVA’s responses to the request for information regarding seismic hazards post-Fukushima. 

SACE expresses concern that the Staff, in reviewing these responses, will apply an “imminent 

risk standard,” which SACE believes will result in a less rigorous review of the information than 

would be performed if review of the report were conducted as part of the Staff’s review of the 

Watts Bar 2 operating license application.31 In support of this assertion, SACE cites a letter 

from William M. Dean, Director, Office of Nuclear Reactor Regulation, to SACE’s counsel.32 

SACE seems to infer from Mr. Dean’s letter that “imminent risk” is a standard against which the 

Staff evaluates updated seismic hazard information from licensees. But taken in context, the 

phrase “imminent risk” reflects the NRC’s determination that, post-Fukushima, continued 

operation of U.S. nuclear plants and continued licensing activities pose no imminent risk to 

public health and safety.33 The letter does not indicate that the Staff would apply an “imminent 

 

30 Section 2.335 permits parties to petition for a waiver or exception from this prohibition. But 

SACE has not petitioned for a waiver or exception. 

31 SACE Petition for Review at 7. 

32 Id. (citing Dean, William M., Director, Office of Nuclear Reactor Regulation, NRC, letter to Ms. 

Diane Curran, c/o Southern Alliance for Clean Energy (Nov. 21, 2014) (ML14267A466) (Dean 

Letter) (“However, the NRC also concluded that continued plant operation and licensing 

activities, including the review of the Watts Bar Unit 2 operating license application, can 

continue because these actions do not pose an imminent risk to public health and safety.”). The 

Dean Letter was prepared in response to concerns expressed by SACE (similar to those raised 

in its motion to reopen) to then-Chairman Allison Macfarlane. 

33 See Union Electric Co. (Callaway Plant, Unit 2), CLI-11-5, 74 NRC 141, 161 (2011) 

(“[N]othing we have learned to date [with respect to the Fukushima accident] puts the continued 

safety of our currently operating regulated facilities ... into question. Similarly, nothing learned 

to date requires immediate cessation of our review of license applications or proposed reactor 

designs.”). 
- 9 - 

risk standard” in assessing the seismic hazard information itself. Indeed, the Staff has stated 

that it will make a “final determination regarding the adequacy of any plant’s calculated hazard 

[,] will continue its review of the submitted seismic hazard reevaluations,”34 and “will determine if 

safe operation requires additional regulatory action.”35 

In its holding on this point, the Board focused on the fact that SACE does not 

demonstrate the likelihood of a materially different result if the Staff evaluates the Expedited 

Seismic Report in the context of post-Fukushima actions versus the licensing process.36 It 

concluded that the benefits of including information found in the Expedited Seismic Report in the 

Final Safety Analysis Report were speculative and lacked factual support.37 On appeal, SACE 

does not claim any error in the Board’s analysis of whether SACE had demonstrated that 

consideration of its proposed contention would likely lead to a materially different result. 

Therefore, we find that SACE does not raise a substantial question meriting review. 

Finally, SACE asserts that the Board’s decision raises the overarching legal and policy 

question of whether it is permissible for the Staff to issue the Watts Bar 2 operating license 

before completing its assessment of TVA’s Expedited Seismic Report.38 We have explicitly 

addressed this point and allow the Staff to issue operating licenses—provided all requisite 

findings are made—before it completes post-Fukushima regulatory activities.39 Further, we 

 

34 Leeds Letter at 6 (emphasis added). 

35 Dean Letter at 2. 

36 LBP-15-14, 81 NRC at __ (slip op. at 6). 

37 Id. at __ (slip op. at 6-7). 

38 SACE Petition for Review at 8. 

39 Callaway, CLI-11-5, 74 NRC at 166 (“Even for the licenses that the NRC issues before 

completing its review [of hazards like those that damaged the reactors at the Fukushima site], 

any new Fukushima-driven requirements can be imposed later, if necessary, to protect the 
- 10 - 

have noted that in general, “[w]e consider suspension of licensing proceedings a ‘drastic’ action 

that is not warranted absent ‘immediate threats to public health and safety,’ or other compelling 

reason.”40 Specifically in the context of the NRC’s post-Fukushima activities, we observed that 

“nothing learned to date requires immediate cessation of our review of license applications ....”41 

SACE has not articulated a reason to revisit these determinations. In sum, SACE does not 

articulate a substantial question for review. We therefore deny the petition for review.42

Our denial of SACE’s petition for review does not suggest that we take lightly the 

ongoing review of seismic issues at the Watts Bar site. The Staff is addressing post-Fukushima 

regulatory seismic activities for all reactor licensees and applicants, including TVA, through a 

process that we have approved.43 We are confident that the Staff will fully address seismic 

safety requirements for Watts Bar 2 as part of that review. SACE, and indeed any member of 

the public, will have the opportunity for additional participation if the Watts Bar 2 licensing basis 

is updated by amendment after the Staff issues the operating license.44 

 

public health and safety.”) (citing Private Fuel Storage, L.L.C. (Independent Spent Fuel Storage 

Installation), CLI-01-26, 54 NRC 376, 383-84 (2001)). 

40 Id. at 158 (quoting AmerGen Energy Co., LLC (Oyster Creek Nuclear Generating Station), 

CLI-08-23, 68 NRC 461, 484 (2008)). 

41 Id. at 161. 

42 SACE also requests that we reconsider our direction to the Staff to use the Watts Bar Unit 1 

design basis “as the reference basis for the review and licensing of [Watts Bar] Unit 2.” Staff 

Requirements—SECY-07-0096—Possible Reactivation of Construction and Licensing Activities 

for the Watts Bar Nuclear Plant Unit 2 (July 25, 2007) (ML072060688); see SACE Petition for 

Review at 9 n.5. We decline to take this action. “[E]xternal entities [are not] entitled to seek 

revisions to a Commission direction to the NRC Staff contained in an SRM.” U.S. Department 

of Energy (High-Level Waste Repository), CLI-14-1, 79 NRC 1, 3-4 (2014). 

43 See SRM-SECY-11-0137; Staff Requirements—SECY-11-0124—Recommended Actions to 

be Taken Without Delay from the Near-Term Task Force Report (Oct. 18, 2011) 

(ML112911571); Dean Letter at 1. 

44 See Dean Letter at 2 (“If the licensing basis is updated by amendment after the Watts Bar 2 

operating license is issued as a result of the NRC’s assessment of seismic ... hazard 

reevaluations, the public will have an opportunity to comment and request a hearing.”) 
- 11 - 

III. CONCLUSION 

For the foregoing reasons, we deny the petition for review. 

IT IS SO ORDERED. 

 For the Commission 

NRC SEAL 

 /RA/ . 

 Annette L. Vietti-Cook 

 Secretary of the Commission 

Dated at Rockville, Maryland, 

this 24th day of September, 2015. 
 

UNITED STATES OF AMERICA 

NUCLEAR REGULATORY COMMISSION 

In the Matter of ) 

 ) 

TENNESSEE VALLEY AUTHORITY ) Docket No. 50-391-OL 

 ) 

(Watts Bar Nuclear Plant, Unit 2) ) 

 ) 

 ) 

CERTIFICATE OF SERVICE 

I hereby certify that copies of the foregoing COMMISSION MEMORANDUM AND ORDER (CLI15-19) have been served upon the following persons by the Electronic Information Exchange. 

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Docket No. 50-391-OL 

COMMISSION MEMORANDUM AND ORDER (CLI-15-19)

2

Tennessee Valley Authority 

Office of the General Counsel 

400 W. Summit Hill Drive, WT 6A-K 

Knoxville, TN 37902 

Scott Vance, Esq. 

E-mail: savance@tva.gov 

Blake J. Nelson, Esq. 

E-mail: bjnelson@tva.gov

Christopher Chandler, Esq. 

E-mail: ccchandler@tva.gov

Diane Curran, Esq. 

Southern Alliance for Clean Energy (SACE) 

Harmon, Curran, Spielberg & Eisenberg, LLP 

1726 M Street N.W., Suite 600 

Washington, DC 20036 

E-mail: dcurran@harmoncurran.com

Morgan, Lewis & Bockius, LLP 

Counsel for Tennessee Valley Authority 

1111 Pennsylvania Ave., N.W. 

Washington, DC 20004 

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rkuyler@morganlewis.com

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martin.oneill@morganlewis.com

Anna Jones, Esq. 

anna.jones@morganlewis.com

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sburdick@morganlewis.com

Lesa G. Williams-Richardson, Legal Secretary 

E-mail: lrichardson@morganlewis.com 

Nuclear Energy Institute, Inc. 

1201 F Street NW, Suite 1100 

Washington, DC 20004 

Jonathan M. Rund, Esq. 

E-mail: jmr@nei.org 

 

[Original signed by Brian Newell ] 

Office of the Secretary of the Commission 

Dated at Rockville, Maryland 

this 24th day of September, 2015