ML20062J540
| ML20062J540 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 10/22/1980 |
| From: | Ostrander F OREGON, STATE OF |
| To: | |
| References | |
| ISSUANCES-SP, TAC-13152, NUDOCS 8010300092 | |
| Download: ML20062J540 (19) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COM".ISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD I r. One Matt.er of Portland
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Docket No. 50-344 (Control General Electric Company,
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Building) et al.,
(Trojan Nuclear
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h I4:g\\n STATE OF OREGON'S BRIEF IN SUPPORT OF ITS EXCEPTIONS TO THE INITI AL DECISION AND ORDER REGARDING MOTION BY STATE OF OREGON FOP, RECONSIDERATION OF INITIAL DECISION F
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Table of Authorities Cases Page Portland General Electric v. Bechtel Corporation.
3 NRC Decisions Niagra Mohawk Power Corporation (Nine Mile 2
Northern States Power Company.
5 Maine Yankee Atomic Power Company.
13 NRC Regulations 10 CFR 50.59 2
10 CFR Part 50 5
10 CFR 50.59(a) 9 10 CFR 50.59 9
1 10 CFR 50.59(b) 10 10 CFR 50.59 10 10 CFR 50.59 11 10 CFR 50.59(b) 11 10 CFR 50.59(a) 11 10 CFR 50.59(b) 12 10 CFR 50.59(c) 12 10 CFR 27.63 13 NRC Statutes 42 USC 2133 5
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On completion of the evidentiary hearing, the licensee, the s aff, and Oregon submitted proposed findings of fact and conclu-
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si:ns of law.
Oregon's findings of fact and conclusions of law f ocused only on the issue of reporting requirements.
The licen-see and the 1;RC staf f responded in writing to Oregon's propcsed fi..fi..gs and conclusions of law.
On July 11, 1980, the initial decision was issued by the Licensing Board without the proposed fi..fi..gs and conclusions of law submitted by Oregon.
On July 23, 19 I 's, Oregon simultaneously.oved for reconsideration of the ini-ial decision and filed this appeal.
Pursuant to the July 28,
'4.s, 3rder of the Appeal Board, the Licensing Board on 3eptember 4, 1980, issued its " Order Regarding Motion by State of Oregon For Reconsideration of Initial Decision" again rejecting oregon's proposed findings and conclusions of law.
Due to a delay in serving the Licensing Board's Order on Oregon, the Appeal Board granted, in its September 15, 1980 Order, leave for Oregon to file Amended Exceptions To the Initial Decision until Se,:tember 29, 1980.
On September 23, 1980, Oregon filed its Amended Exceptions To the Initial Decision and 'the Licensing Board's September 4 order.
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SUMMARY
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The Licensing Board's decision to not require accelerated l
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- ing of design changes is contrary to the ::RC's obligation l
4 - 3R:EF/ STATE OF OREGO.C l
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prote:: -he public nealth and safety.
The need for acce-lara ed reporting is eviden f rom the unique nature of the engi-n3crin; fe:tzminations required during this proceeding.
Accelerated reporting should not be a burden on a licensee and is aa:hori:sf cy existing regulations.
3 The Adequacy and Accomplishment of the Modification of the Control Building Complex is an Issue Directly Affecting tne Puolic Heal n and Safety The funf amental purpose of NRC regulation of nuclear power is the pro:setion of public health and safety.
This is, of course,
- r e n 1; ensing amend:ent proceedings such as this case.
':e r;" a r-9:stes Power Corpany (Prairie Island Nuclear Generating Plant, Units 1 and 2), AL AB 4 55, 7 NRC 41 (1978).
42 'JSC 2133.
There is no question that seismic qualification of the Trojan Nuclear Control Building complex is of significance to the public health and safety.
cf. 10 CFR Part 50 Appendix A (General Design Criteria For Nuclear Power Plants).
The purpose of the Control Building complex modifications and the central issue in the Phase II proceeding is to restore desired margins of safety in the event of a " safe shutdown earthquake" (SSE).
Initial Decision p 13, TR 3348 (Herring).
- n accor$an:e with licensee's desire to continue operation of the plant drring the several months of modification work, ano ther i cortan: s;bject in the proceeding was the potential impacts of
- he.cf;fication work on the plan 's safety during Operation.
a.:L cle of :ne many sade:j aone:rns before c.e 11:ensing
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Board is the issue of the seismic capability of the plant during the phases of the construction work which will require removing some structural elements while the plant remains in operation.
Oregon, as did the staff and licensee, presented expert testimony on the necessity of maintaining careful cequencing of the construction so as not to unduly reduce the seismic capability of the existing structure.
State of Oregon Exhibits 2 and 2a, TR 4340, and TR 4463 - 4467.
The safety importance of the construc-tion sequence proposed by the licensee was recognized in the Licensing Board's opinion. and made a condition in its order.
Initial Decision p. 44, 45 and 63 - 65.
Other safety issues included such important r.atters as protection of cable trays, e
fire protection, control of dust, and seismic qualification of piping supports, as well as the fundamental issue of the adequacy of the design of the modifications.
knitial deicision p. 37 and 38 - 45.
In short, the record of the proceeding as reflected in the Licensing Board's initial decision shows that the modificat, ion "of the Trojan Control Building is direct 1y related 'to the public
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health and safety.
C The Engineering Design and Review of the Proposed Modification Required a Unicue, " State of tne Art" Effcgt BY NRC Staff Experts and Licensee'.s Experts As noted above, completion of the NRC staff review of the design of the proposed modifications took more than one year.
Highly qualified expert consultants were utilized by the staff 6 - 3RIEF/ STATE OF OE3GON 7
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l Table of Contents Pace I.
Introduction.
1 II.
Statement of the Case 2
III.
Oregon's Exceptions No. 1 - 5, 7, and 9 4
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4 A.
Summary 3.
The adequacy and accomplishment of the m'cd-5 ification of the Control Building complex is an issue directly affecting the public health and safety C.
The engineering design and review of the 6
proposed modification required a unique
" state of the art' effort by NRC staf f expers and licensee's experts D.
The initial decision fails to protect dhe 9
public health and safety by providing for timely staff review of dae, safety of changes in the modifications made by the licensee.
E.
The accelerated reporting under 10 CFR 11 50.59(b) proposed by Oregon would protect the public health and safety and would not be an undue burden on the licensee IV.
Oregon's Exceptions No. 6 and 8
- 12 V.
Conclusion 13 VI Request for Oral Argument 13 9
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL SOARD In :ne '4e.:ter of Portland
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Docke: No. 50-344 (Control General Electric Company,
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Building) et al.,
(Trojan Nuclear
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. e STATE OF OREGON'S BRIEF IN SUPPORT OF ITS.
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27 EXCEPTIONS TO THE INITIAL DECISION AND g the SMNI81 II ORDER REGARDING MOTION BY STATE OF OREGON
[h.dnt& IS'N I$' Y
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FOR RECONSIDERATION OF INITIAL DECISION M
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INTRODUCTION Oregon does not oppose the design of the modifications of the Trojan Control Building necessary to meet seismic safety require-ments or the schedule for accomplishing the modification work as approved by the Licensing Board.
Oregon's exceptions reflect its belief that t2chnically cualified Nuclear Regulatory Cc= mission staf f personnel should continue their immediate involvement in this matter.
As will be more fully set forth below, the design of the modifications in the Trojan Control Building complex reflects
--Ts of compisx and often controversial engineering effort by the licensee, certain NRC staff experts and others.
The design solutions that were approved by the Licensing Board are undoub-tedly a product of " state of the art" engineering applied in a c o n : 5..: : directly af f ecting the public health and saf ety, the 1 - 3RIEF/ STATE OF CREGON l
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seismic qualification of the Trojan Control Building.
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It is Oregon's position that the public health and safety requires accelerated reporting unfer 10 CFR 50.59(b) cf changes by the licensee in the Control Building modifications to the NRC staf f experts who participated in designing the modifications and who are technically qualified to conduct a meaningful review of the safety determinations of the licensee.
In contrast, the annual reporting of changes approved by the Board under 10 CFR 50.59 provides no mechanism for timely review of the licensee's decisions on a project that will be substantially completed by mid 1931.
By means of exceptions 1 - 9, Oregon is asking this panel to substitute its judgment for that of the Licensing Board to reach a result which Oregon sub,mits will better protect the public health and safety.
Niacra Mohawk Power Corporation (Nine-mile point nuclear station, Unit 2) ALA3 264,1 NRC 347, 357 (1975).
II STATEMENT OF THE CASE On May 26, 1978, the NRC staf f issued a modification order resulting from the discovery that due to several engineering design errors, the structural capacity of the Trojan Control 3;ilding in its "as built" condition did not meet the originally intended and licensed seismic capability and safety margins.
The NRC staff order provided an opportunity for a hearing which was requested by several persons.
Subsequently, an Ator.ic Safety and Licensing Board Panel was convened.
In Phase I
- - SRIEF/ STATE OF OREGCS O
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- i ::s proceeding the Licensing Board approved interim operation Of the plant with certain limiting conditions.
Partial Initial Os:isien, December 21, 197 8, 8 NRC 717.
From on or about May 26, 19'E, until the Phase I initial decision, the Trojan Plant remained shut down on the basis of a determination by the Nuclear Rs;clatory Commission that a significant ha:ards consideration was involved.
Commission Order, July 7, 1978.
The cost of the shutdown to the licensee was substantial and has led to litiga-t i.. between the licensee and the builder of the plant on the z.:fe:: of direct and consecuential damages.
See Portland 3e.aril Electric Ocmpany v.
Sechtsl.Corpcration, Civil No. 79-10 3
- ,Or June 4, 1980).
In March of 1979, a prehearing conference was held on Phase
- of the hearing which was to involve the structural adequacy of
.e modifications and the safety aspects of their implementation.
- ring a year of discovery between the parties and lengthy discussions between the NRC staff and the licensee, the hearing j
was repeatedly delayed.
See e.c.
Licensing Board's orders dated September 18, 1979 and November 30,-1979.
A second prehearing conference was held on March 11, 1980.
The Phase II evidentiary hearing was finally held on March 31 through April 3 and April 16 1.i 1, 1990.
As it did in Phase I of the proceeding, Oregon participated fully in the Phase II hearing by submitting interrogatories and
- ss:imony and cross-examination of the direct testimony of wit-
.e s e : 3 presented by the NRC and the licensee.
3 - 3RIEF/ STATE OF OREGON O
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and licensee on a variety of issues.
Intense eff orts by URC s:aff experts, particularly Mr. Herring, were necessary.
In a special hearing held during this period, the Licensing Board asked both the licensee and the staf f why the review was so dif-ficult and time consuming.
The licensee and the staf f agreed that the problems posed were unique and represented the "s ate of the art" in civil engineering.
TR 3274 (BROEHL).
The NRC staff expert, Mr. Herring, testified:
t "This is a little bit different than your nor-mal review.
As.eas all;ded :c, you don't have th e c ;de to rely ;pon and the margins intended in there.
And part of :he resolution of tne modifica-tion issue is to assess yourself that there are levels of margin that wculd meet the intented margins.
If you don't have a code and you're relying on 2
test data, you' re sta'rting to push the state of the art of civil engineering.
There are more uncer-tainties associated with going to higher levels in the determination of capacity and in the deter-mination of the required broadening of the response spectra peaks.
And the questions that I have been asking have been attempting to get a good handle on the error band associated with the numbers being reported.
But, again, when you're pushing the state of the art, the numbers being reported are not firm numbers.
There is an error band associated with those numbers, and it's important to be able to assess that that error band is adequately accounted for in peak broadening and in these capacities."
TR 3333.
During the evidentiary hearing, the licensee's experts
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review:
"The next item, perhaps, in our testimony goes to the matter that because of the complex nature of the buildings in this complex, and I mean the type of construction which utilizes a steel frame, in many cases a thick concrete core, faced on masonry exterior and interior, a very difficult sandwich to digest, that the exis ting codes, in fact, do not d=si with scch structaris.
Tt.e ex sting codes are usually developed either for reinforced concrete structures or prestressed concrete structures or steel structures.
But when the structure involves the various materials in one composit, one gets into problems of interpretation of codes that are just intractible and inapplicable."
TR 4420.
(3ressler)
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- n sis: 5:end it.sces;;ry :: : ire an expert consultant, Dr. Laursen, in order to fully participate in the review of the proposed modifications.1 Thus, the lack of building code or other accepted data which.are specifically and completely appli-cable to the construction of the Trojan complex made it necessary to rely on a testing program and to perform a detailed and complex analysis unique to the Trojan complex (Licensee Exh. 28 pp. 11, 2 3 a, 25, 33, 43, 59; Staff Exh. 17A pp. 42, 53; TR 3274, TR 3278, TR 3280, TR 3283, TR 333 (Herring), TR.3608, TR 4356; TR 4420 (Bressler)).
L Because of the complexity and unique nature of the engi-neering design safety questions that had to be resolved during the two-year course of this proceeding, dif ferences in engineering judgment necessarily arose between the staff
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and licensee (5taff Exh. 17a pp. 11-17, 20-22, 26, 28, 37-40, 54; Licensee Exh. 28 pp. 46, 66, 63, 73, 77; TR 3903, 8 - BRIEF/ STATE OF OREGON
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These engineering judgment differences oe veen the staff and the licensee were resolved at the eviden-tiary hearing.
F.owever, certain analyses, including review of the seismic qualification of safety related equipment due to the w;fened response spectra, certain details of construction plans and the modification design and other matters are not finalized and may be subject to changes.
(Licensee Exh. 28 pp. 64; Staff Exh. 15a pp. 25-27; TR 3727, TR 4373, TR 4647, TR 4622-4627, TR 47504753, TR 4789).
In sum, the record of the Phase II pro-
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- + ~;f_fications of the Trojan Control B.ilding involved complex, ", state of the art" civil engineering requiring utiliza-tion of highly qualified experts.
D The Initial Decision Fails to Protect The Public Health and Safety By Failing to Provide For Timely Staff Review of tne Safety of Changes in ene Modifications Made By tne Licensee Oregon's main concern is that the Initial Decision permits the licensee to change the design of the modifications or construction plans that were approved by the Licensing Board and which were subject to the scrutiny of the parties in this proceeding.
The licensee need only follow the requirements of 10 CFR 50.59 which permits the licensee :o unilaterally determine whether a change is significant or presents a safety hazard.1 '10 CFR 50.59(a).
Initial Decision pp. 57.
Reporting of the
- 1. ensee's determinations is required only on an annual basis to 9 - SRIEF/ STATE OF OREGON
the appropriate NRC regional office.
10 CFR 50.59(b).
In other words, the initial decision allows the licensee to make determina tions relating to the saf ety of the proposed modifica-tiens without timely review by the NRC staff.
Furthermore, as
,.5ee's reports of i:s de:erminations neef Only be filed annually with with the NRC regional office, it is likely tha t the licensee's determinations would not be seen by the NRC staff experts in the office of Nuclear Reactor Regulations who par-ticipated in the " state of the art" engineering review and design f e t.rri':s f above.
In any event, the nature of the..cd ifications
./.ccolve, for the most part, installation of Ocncrete and steel plates makes any "af ter the fact" review of a change of a licensee a review of a Fait Accompli, set in concrete.
Plainly put, after more than a year of highly sophisticated, often controversial "statt of the art" engineering involving all the parties to this proceeding, the Initial Decision leaves changes in what has been reviewed effectively solely up to the licensee's discretion.
It may be argued that eventually the requir'ed review of the licensee's determination will be completed by appropriate, qualified URC staff under 10 CFR 50.59.
An eventual review, l
however, is not sufificent to protect the public health and
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safety when, as here, safety issues such as reduction of seismic capability during construction are at issue.
Moreover, if the NRL, af ter the modification work is completed, does de: ermine that a change made by the licensee did remove a margin of safety, r.
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13 - 3RIEF/ STATE OF OREGON I
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. a new expensive and time consuming licensing proceeding may be required.
10 CFR 50.59(a)(2)(iii), 10 CFR 50.90.
J E
The Accelerated Reportinc Under 10 CFR 50.59 (b)
Trerosed 9v Orecen '.;;uld Pro:=ct ena Purlic F.ealth and Safe:v and Woulc Sc: Be an Undue surcen on :ne Licensee Oregon in 1:s proposed findings of f act and conclusions of law asked that the licensee be regnired to make accelerated reports of design changes as provided by 10 CFR 50.59(b) supra, which allows for shorter intervals of reporting.
Additionally, Oregon asks that a copy of any reports be sent directly by the l
11:ensee to the NRC's office of Nuclear Reac ce Regulation in which the NRC staf f experts who participated in this proceeding are located.
Oregon did not ask that the NRC staff actually approve in advance proposed changes in the belief that with i
timely receipt of the licensee's changes, the NRC staff could i
conduct a meaningful review and that adequate means of immediate i
enforcement would then exist.
The accelerated reporting proposed by Gregen would alleviate the risk to the public health and safety noted above.
The' appropriate NRC staf f experts would have the opportunity to i
. review the safety determinations made by the licensee before l
changes in _the modification were implemented, t
Finally, contrary to the Licensing Board's conclusion in its
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September 4 order, Oregon cannot understand how accelerated reporting could be a burden on the licensee.
The determinations required.by 10 CFR 50.59(a) must be made in advance of any 11 - SRIEF/ STATE OF OREGON l
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change.
The burden on the licensee is merely to transmit copies Of its already recaired reports and documentatien on an acce-1erated basis to the appropriate NRC staf f.
Construction would a interrupted unless the ':RC sta f f celieved th a t a change
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Moreover, the licensee 's risk of a determination.by the NRC staff after completion of construction that a safetv violation had occurred would be reduced.
Thus, accelerated reporting of licensee's design changes as 32 J.?rized under 10 CFR 50.59;o).ould increase the protec: ion of
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review by the appropriate NRC staff experts of the safety im act of the licensee's changes in the modifications approved bv the Licensing Board.
1 IV OREGON ' S EX CEPT *0'.;S UO. 6 AND 8
- n its September 4 Order the Licensing Board concludes that Gregon had never presented an issue or suggestion of a contention as to accelerated reporting and that there had been no showing of Oregon of any reason to submit evaluations of changes in the
=0difications to the NRC staf f.
September 4 Order pp. 3 and 4.
J 4
Although Oregon did not provide direct testimony on the issue or raise a contention, there is no recuirement th a't it should have done so.
10 CFR 2.715(c)
Oregon did repeatedly cross-examine on the sub"ect and J
c_early arought its concern to the Licensing Board's attention.
12 - 3RIEF/ STATE OF OREGON I
See eg. TR 4619-4623.
As noted ove, there is substantial evi-dance in the record showing the n'aed for accelera:ed reporting.
Or+70n also filed proposed findings of fact and conclusions of law supported by a memorandum of points and authorities.
Both the :RC staff and the licensee provided the Licensing Scard with written responses and argument on Oregon's proposals.
In any erint, that evidence may be adduced by cr0ss-examination is well e stsl* ished.
Maine Yankee Atomic Pc er Company (Maine Yankee) n
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Tr.i Ecarf's centlusior. is, thu. incc rre c t.
V CONCLUSION For all of the above reasons the initial decisien of the
~ icensing Board should be modified to include the accelerated reper:ing requirements proposed by the State of Oregon.
VI REQUEST FOR ORAL ARGUMENT Pursuant to 10 CFR 2.763, Oregon requests that the Appeal Board panel hold oral argument on its exceptions.
Respectfully submitted, t
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,s C, \\ s F RA'.!K i!. O:3T.ui;D ER, JR.
Assistant Aftornev. General of Counsel to the Oregen Energy Facility Siting Council and Oregon Department of Enerw.v l
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1 The qualifications of the staff, licensee and Oregon's experts are set forth in their direct testimony and are not in question.
2' Sec. 50.59 Changes, tests and experiments -
'1ll The holder of a li:ense authorizing cpera ion of a production or utilization facility may (1) make changes in the facility as descrioed in the safety analysis report, (ii) make enanges in the procedures as described in the safety analysis report, and (iii) conduct tests or experi-ments not described in the safety analysis report, without prior Commission approval, unless the proposed change, test er experiment involves a change in :ne tecnnical specifica-tions incorporated in ne license or an unreviewed safety question.
(2) A proposed change, test or experiment snall os deemed to involve an unreviewed safet.vthe probability of occurrer.ce or the consecuences of a c.uestion (i) accident or malfunction of eculpment important to safety previously evaluated in ene safety analysis reper: may oe increased; or (ii) if a possio,111:y for an accident or malfunction of a different type than any evaluated previously in the safety analysis report may be created; or (iii) if tue margin of safety as d.efined in the basis for any tech-nical specification is reduced.
(b)
The licensee shall maintain records of changes in the facility and of enanges in the procedures made pursuant
- :21 section, to tne extent that such enanges constitute cuanges in ene facility as described in the safety analysis report or constitute changes in procedures as described in tne I
safety analysis report.
The licensee shall also maintain
-:--"; of tests and e::periments carried out pursuant to paragraph (a) of this section.
These records shall inicude a written safety evaluation which provides the bases for the determination that the change, test, or experiment does not involve an unreviewed safety question.
The licensee shall furnish to the appropriate NRC Regional Office snown in Appendix D of Part 20 of this enapter with a copy to the
- .rtetor of Insep0 tion and Enforcenent, U.S.
Nuclear Regula:orv Commission, Washington, D.C.
20555, annually or a-shcrter intervals as may be specified in the license, a report containing a orief descrip:lon of such cnanges. tests, and experiments, including a summary of the safety svaluations of eaCn.
[ emphasis supplied]
t "2
3RIEF/ STATE OF CREGOM
Cr. Esed Johnson Of fice of the Executive Legal A:.i: Safety and Licensing Director L.;gesi Soarf U.S.
Nuclear Regulatory Corn'n
~~ ~. ':.::* ear Regulatory Cors'n h'as hing ton, DC 20555
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_e0.:.a-Docketing and Sertices Section J:seph R. Gray Of fice of the Secretary C.nle; for NRC Staff U.S.
Nuclear Regulatory Corm'n
.9. .:cle ar Rgula: cry Cor.m' n Mcshing:cn, DC 20555 Washington, DC 20555 Atomic Safety and Licensing Alan S. Rosenthal, Esq.
Appeal Board A:Omi: Safety and Licensing U.S. Nuclear Regulatory Corm'n Agpeal Soard Washington, DC 20555 4
U.S. Nuclear Rec.ulatorv. Corm'n Washington, DC 20555
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i FRANK W.
OSTRAND ER,'J R.
Assistant Attornev General e
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A s 4,y4 I Frank W.
Ostrander, Jr. he re b.v certifv. that on.
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22th day of October, 1980 I served the within "Brief IN' Support of Amended Exceptions To The Initial Decision and '
e r:er Regarding Motion By state of Oregon Fcr Reconsideration of Initial Decision" upon the following par-ties of record by then deposition in the United States Post Office at Portland, Oregon, full, true and correct copies thereof, addressed to the said parties of record at the following addresses listed below, and prepaying the postage thereon:
Marshall E. Miller, Esq., Chair.
Mr. David B.
McCoy Atomic Safety and'Licensi.ng Board 348 Hussey Lane
" S. Nuclear Regulatory Comm'n Grants Pass, OR 97256 Washington, DC 20555 Ms. C.
Gail Parson Or. Kenneth A. McCollom, Dean 800 S.W.
Green # 6 Di"ision of Engineering, Portland, OR 97205 Arthitecture & Technology Oklahoma State University Ronald W.
Johnson, Esq.
Stillwater, OK 74074 Corporate Attorney Portland General Electric Or. Hugh Paxton 121 S.W.
Salmon Street 1229-41st Street Portland., OR 97234 Los Alamos, New Mexico 97544 William W.
Kinsey Mr. John A. Kullberg 1002 N.E.
Holladay 15523 S.E.
River Forest Dr.
Portland, OR 97222
?: iland, OR 97222 Ms. Nina Bell
- lumbia Environnental Council 522 S.E.
18th 2G1 S.
First Street Portland, OR 97114 St. Helens, OR 97051 Mr. Stephen M. ~;illingham Maurice Axelrad, Esq.
555 N. Tomahawk Drive
(
ir enstein, Newman, Re i s,
Portland, OR 9 2;7 l
Axelrad & Toll 5 _te 1214 Mr. Eugene Rosolis 1025 Connecticut Avenue N.W.
Coalition for Safe Power
"'-hington, DC 20036 21?
3.E. 9th Aver,;e Portland, OR 97214 I
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