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/c/K June 16, 1981 d2/ktcf2cd'4V) W G
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MEMORANDUM FOR:
W. E. Campbell, Jr.
Office of Nuclear Regulatory Research gg/, gg4 a[id rocedures Branch d'
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Division of Rules and Records g
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Office of Administration M
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SUBJECT:
DRR REVIEW 0F SECY-81-366, " AMENDMENTS TO 10 CFR PARTS
- <+d 2 AND 50 WITH RESPECT TO CRITERIA INVOLVING NO "SIGNIFICANT HAZARDS CONSIDERATION" g f/g,
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Attached is a marked copy of the Comission paper and Federal Register Notice portion of SECY-81-366, " AMENDMENTS TO 10 CFR PARTS 2 AND 50 WITH RESPECT T0 e
CRITERIA INVOLVING N0 "SIGNIFICANT HAZARDS CONSIDERATION."
In addition to the requested minor format changes, specific attention is called to the following:
1.
On page 5 of the Comission Paper, notation f will require you to contact Steve Scott, TIDC:DMB (extension 28585) to arrange for the rule to be distributed to licensees and other affected persons.
2.
When preparing the rule for publication after Commission action, please remove all arrows, " Enclosure C" notations, etc., and the footnote on page 7.
In addition, please leave blank the space to the right of " EFFECTIVE DATE" and include this information in the transmittal memorandum to J. M. Felton requesting publication in the Federal Register.
If you have any questions please call John Philips or me on extension 27086.
kW.br David L. Meyer Rules and Procedures Branch Division of Rules and Records Office of Administration
Attachment:
As stated 8604170568 860327 NSF 0491 PDR
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. m, 3q%CJ,l cs.~. j,p te RULEMAKING ISSUE (Affirmation)
For:
The Commissioners From:
William J. Dircks, Executive Director for Operations
Subject:
AMENDMENTS TO 10 CFR PARTS 2 AND 50 WITH RESPECT TO CRITERIA INVOLVING NO "SIGNIFICANT HAZARDS CONSIDERATION"
Purpose:
To obtain Commission approval for publication of the final amend-ments in the Federal Register.
Cateoory:
Tnis paper covers a minor policy question.
Issue; Should the Commission amend its regulations to incorporate criteria for determining when a proposed amendment to a license involves no "significant hazards consideration."
Discussion:
During the Affirmation Session on February 29, 1980, the Commis-sion approved for publication in the Federal Register a notice of proposed rulemaking (Enclosure A) concerning incorporation into Title 10 Part 50 criteria for determining when an amendment to a construction permit or an operating license involves "no significant hazards consideratien." The Commission action was
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in response to the staff recommendations contained in SECY 660 dated December 13, 1979.
The notice of proposed rulemaking inviting public comments was published in the Federal Register (45 FR 20491) on March 28, 1980, with the comment period sched-uled to expire on May 27, 1980.
The proposed rulemaking was in response to a petition for rulemaking filed May 7, 1976, by Mr. Robert Lowenstein on behalf of three petitioners (Boston Edison Company, Florida Power and Light Company, and Iowa Power Company) requesting that criteria be specified to determine when no significant hazard is involved in an amendment to an operat-ing license.
The petition (PRM 50-17) was published for comment in the Federal Register on June 14, 1976 (41 FR 24006), and is available through SECY Occketing and Service Branch from file "PRM 50-17."
If the staff recommendation is accepted, the peti-tion would be granted in part.
Contacts:
R. Bernero, RES 443-5903 W. E. Campbell, Jr., RES 443-5926 5 YY Q
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the Act or a testing facility licensed under section 104(c) + must + be based on the criteria set forth in 6 50.91(b) of this chapter; or*
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n (42 U.S.C. 2132-2135, 2233, 2239).
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PART 50 - DOMESTIC LICENSING OF DUCTION AND UTILIZATION FACILITI 6
2.
The authority citation for Part 50 is revised to read as followss t
AUTHORITY:
Secs. 103, 104, 161, 182, 183, 189, 68 Stat. 936, 937, 948, 953, 954, 955, 956, as amended (42 U.S.C. 2133, 2134, 2201, 2232, 2233, 2239); secs. 201, 202, 206, 88 Stat. 1243, 1244, 1246 (42 U.S.C., 5841, 5842,5846), unless otherwise noted.
Section 50.78 also issued under sec. 122, 68 Stat. 939 (42 U.S.C. 2152).
Sections 50.80-50.81 also issued under sec. 184, 68 Stat. 954, as amended; (42 U.S.C. 2234).
Sec-a tions 50.100-50.102 issued under sec. 186, 68 Stat. 955; (42 U.S.C. 2236).
For the purposes of sec. 223, 68 Stat. 958, as amended; (42 U.S.C. 2273),
650.54 (i) issued under sec.161i, 68 Stat. 949;,(42 U.S.C. 2201(i)),
S$50.70, 50.71 and 50.78 issued under sec.-1610, 68 Stat. 950, as amended; (42 U.S.C. 2201(o)) and the Laws referred to in Appendices.
Paragraph 50.58(b) of Part 50 is amended by revicing the final sentence to read:
"If the Commission finds that no significant N:$rds TW5 h-A
" Additions to the currently effective regulation are underscored and deletions are within brackets.
Changes to the proposed amendments that (0u' *4 A,
were published in the Federal Register on March 28, 1980, 45 FR 20491 l"
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are indicated with a line in the margin and the changes are between pp4,,;,m,
+ and
- Prior to publishing in the Federal Register the arrows, underscore, brackets, the material in the brackets and this footnote
.wo.wm ab.
will be deleted.
Also the text of 2.105(a) will be replaced by ***.
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y consideration is presented by an application for an amendment to a co'nsN, n
tion permit or operating license.,46Esttkring the criteria set forth in j;
9 50.91(b), it may dispense wi h ti:e and publication and may issue
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the amendment.
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Section 50.91 is arc tided by redesignating the present paragraph as paragraph afandadding newparagraph(b[toreadasfollows:
9 50.91 Issuance of amendment.
(b) hheCommissionwilldetermin that a proposec amendment to n
ooeratin[ license or construction permit involves [a[significant hazards consideration [f it finds thatdoceration of the facilit:r in accordance with the prooosed amendment would (1) involve a significant increase in the
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probability or consecuences of an accident previously evaluated, d d (2) crehtethepossibilityofda'newordifferentkindofaccidentfromany accident oreviously evaluated [ or (3) involve a sionificant reduction in a margin of safety.
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Dated at Washington, D.C. this day of 1981.
For the Nuclear Regulatory Commission.
Samuel J. Chilk Secretary of the Commission
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COMMENTS BY TWE NATURAL RZSOURCES DEFENSE COUNCIL AND THE UNION OF CONCERNED SCIENTISTS w-4 ON PROPOSED AMENDMENTS TO 10 CFR PARTS 2 AND 50:
NO SIGNIFICANT EA1ARDS CONSIDERATION These coussents on the NPC's proposed rulemaking to define "no -significant hasards consideration
- are offervd by the Natural Resources Defense Council, Inc. (NRIX.) and the Union of Concerned Scientists (UCS).
NKDC is a non-profit public interest organization, with a new.bership of over 45,000 persons.
NRDC is dedicated to the defense a.d preservation of the human environment and the wise use of i
natural resources.
The organisation has a strong interest I
in ensuring that the risks posed by nuclear energy are mini-nized and has actively participated in many procestings before L
the NRC.
UCS is a coalition of scientists, sngineers and other professional, supportedby the financial cor.t ributions of over 90,000 public sponsors.
CC5 has published a n unte r of independent tec'mical studies in t.he fiels of nuclear sa'ety and energy policy and, like NPN, has frequently par-t ici;;ated in proceedings te f ore the Nitf NPM aft X S 14 ; t e v e that the proposed rule is cor.t ary to law and to se";nd pel cy The Atonic Energy Rt, as eended, prev;.
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while P,L.87-615(1962) re:ooved the requirement of a hearirg j
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at the operating lic use stage, it balan cd this by providiry
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that amendments to the construction permit and operating liosase should tx issued only after notice and t.he opportunity l.
for hearing, asoopt in ossee invoIVing *no eignifieant hararda I
consideration."
Ttte statutory language is se follows:
In any proceedin under this chapter, for the greeting, r n g %, revoking, or amending of any lioesse or essetraction permit tae commissima shall grant a hearing upon the regneet of any peroom wheen interest may be afracted' hy the pesomeding... ftne Cossaission any dispense with such tL rty days' notice and pebliestime with remport to any application for an amendomet to e seestruction posait or an amend-ment to as operating liessee t:yes a determination i
by the cameissaan that the sammenant involves no l
significant hoseres semaideration.
42 Osc $2339(a)
Thee, the law grevides the opportunity for a hearing cm all hts, but permits the Commission to dispense witit the prior motion provisions only in cases involving no significant hasards eensideration.
The legislative history of the 1952 amendments shows that Congress was fully essere of the potential damage to the putite interest frosa removing the mandatory operatinal i teense hearing and Congress specifically viewed the strict provis4 ens for prior notice and opportunity for hearing e. a.t*endnents as a najor means to ensure that the pubiic 1nterest en,;d not be comprowtised by indiscriminate cham ee to t he p y2**1 aftet it had passed through the period or pun'.ic *crutt-Se r, e n a t.
h Report addresses this issoe as fc.' % s-k
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i nis amenA4ent alt hough relaxing the mandatory hearing requirassent, abould sot prejudice the public interest in reactor safety determinations.
A mandatory hearing will still be held at t.he critical point in reactor licensing - the con-struction permit stage - where the suitability of the site is to be jsoged.
Succeeding requia-tery actions will take piece chly upon publica-ties and certictent a4venet' MPtice to afford an laterested Derty the esportunity to intervene.
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Finally, it is espectee that the methority aivon l
to ee m with wtice end -dlicaties wooli!
he emereLees with erset eere and only in these l
taetanese eere the egqpH:: tat-preseeted 20 a1yn1-ficaet hasarde emesideratiae.
U.S. Ceen Ceng. 4 Ad. Waus, 87th Cong.,
2.d.,
Sees. 2207, 2214-2315 (1962),
amphasis edeed.
purther, the Senate Report book particular note that the 1
possibilities for mischief are increased proportionally to the aumeser of issues which remala unresolved at the time the t
construction permit is asseed.
- n seems Lavolvir,y important post-construction permit unresolved safety probleme, the legislators noted that the opportualty for a hearing on c.r,
amendment
- is not enoughs the Commission was dirocted to order hearings on itt, own motion ist these circuanetances.
The h ittee is cognisant of the provisional construction permit procedure which alleve the issuance of a permit, subject to further re-
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search and development work, before becoming j i final. lf when this resea r ch and deve logne-i y
Although the ffPC CS 10?. g e r ;4$ues
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tion permita, it continwee the pr*
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perv.its subject to t he later re ec ; u + wn M w. : co -.. <
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problens.
O lf Staten Utilit:as a r. v. tvass, t.c r4 Stat,
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work is directed toward the resolution of a dif ficult safety problem of uausual public importance it is espected t. hat the Coceissiuc.
on its own action, would order a hearing before significant ashnts or authorisation of tse final construction permit were issued.
I Id. at 2214.
J The plain words of the statute, combined with its legis-l 1etive history, envision en orderly, fair and open process t
ohich begime with public heariage on each construction permit t
applicaties, followed hF moties and the opportunity for hearins l
en all amendesste and en the operaties liennee and its 1stor mammesente.
The only narrow emosytten is that the prior notice provielen may be waived eer a certale elaas of amanesents, these involving as signifienst heaarde emoeideration.
Ia c w treet to this statetorily moedeted pseeems, the comunieston has developed a tem gn;:0 practies sedah operates to frustrate public participation and in Amesmeistemt with Coe*Trossional intest.
First, the staff has actively discouraged the holders of l
eenetreetles permits from filing for % ats whom changes are made to the plant durleg the process of construction. sLnce such ameneneste tend to cause administrative problems and require the enemitment of stof f resource s, it is well k.nown that the utilities are encorsaged to weit until the operatir; 11 cense review to seek po e t -ho< a pp etna l a f acx11f1 eat 1ons.
The NRC ha s no ragu l a t ion s d e s c r i b i n g i t.e situatie s which 1
require filing for an amendment.
Tr.e result ie it et n3 cor.
structLon permits have ever been as*mted for a design ehersse y
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, In a recent case, the Commaission requested the staff to describe in detail its practice in such cases m staff's response stressed the preliminary nature of the design information submitted at the essetruction permit stage, and the brevity and leek of specificity of the construction
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itself.
It meted that the Commaission's regula-i tiene spesifically oatheries the isomemoe of a cometreaties pesult even though not all technical s.a ma== bas been supplied.
The staff con-I treeted the poelaminary design laformation supplied et the seestanetten t stage with the f ar more detailed review of f I design information at the aparating 1Am==== review stage.
The ataff shapeved that es neither the Atomic anergy Act nor the wmatem's segulatione eye 11 out the comunit-ammt mees hy, or the oatherity granted to, holdere of sometweetion peemite, design F n:: proposed l
after isomenes of a sometrimetion posedt have long l
heen treated en en heels by 11esa**es and l
Feff.
The staff t it leerse of design ahangee desieg sometrisetton thrwegh formist or l
in h 1 estartesties by lisenesees throwsh the inspostiam med entereemmet effort and sometimes em1F them the facilitF is seedy for operating l
license review.
hapsoding en the esgree of signi-fiesmes, a pro detallet staff review, peeed ebenge may receive het enee soumealy, detailed review to deferred to the operating license review stage.
Although e auffielently mejor change oesid warrant a eenstreetian perait amendme:t, a reeiew of 88 estant emnetruction pesults indicated that some had been amended for a design skeppe, scoording to the staff's sehmission.
gehee as a whole, the bed.c of the staff's submission was that the definitive safety revies chich east take piecs hefers the plant ces he licensed to operate, one the eftertw-nity for a public hearing at that time, are tM principal mechae.ine for reeolving i se.e s, such as this one, shich arise in the course of constisetice..
Dorthern ladiana Pacifie Service Co. ftta11ty Generating Station, Wa41 ear-il, d.!-
Nc. 12 1979, 81.op. at 3-4.
It is self evident t1.a t the staff pra:tice descrita above is one of systematic abus-. of dLacretton aos cer t t v e -
tion of the statutory mandate vitr respect t o e,,. t t w ; %
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.s permit arandments.
Unless and antil t t; *- i m - a w s he 4 2dr c z n,
itself to the fundamental iss.,e of t erqui r a n g c. ;>
c e mh -
. ban significant changes or additions are maue tu e o n ' ;-
t during construction, " refining" the criteria goverr.ing the prior notice previsions for non-existent au ndants is a fraud on the public and patently meaningloss.
It is true that the proposed requintions would also govet r operating license amendments and it is at this point that the second prong of the staf f's traditionsi practice become significant.
The legislative histot y makes i t atr,md antly f
I clear that cases involving *no significant hazards c o r. 3 1 d e r e -
tice* were to be an exception frees the general rule that twt f ee i
f and the opportunity for hearing should precede the satAarisation i
of W.ts.
The Coussission was specifically directed to m I
the exception *with great care.*2/
I.atead, ' no s ipi f i can t hasards consideratice* has tween so broadly interpreted as te star.d this principle on its head.
In essents, the f r e w ar t 2 of the sta f f is tha t m>smiment s do no t involve a significart hazarcs consideration unless it t. an te eh e " < t '. e n. a s e.
Operating license sesendmen ts a r e grant ed wi t hoat pr i or re.; t t r e as a matter of routine.
l n.e pr e.ed r e at u. 1-maper.<a.e me.
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practice <
ney est4t,ist t'tse eriter.e ior : w *. g '. ~, v *a t u t i
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l (1) involve a significant increase in tt.e pro-bability or consequences of an accident previously evaluated, (2) create the possibility of an acci-dant of a type different from any evaluated previously, or (3) involve a significant reduction in a margin of safety.
The applicattom of these three c;iteria in many cases will noossearily require the resolution of substantial f actual gnostions.
Indeed, these qJnistions largely overlap the issues uttich bear on the g of the license amendment.
That is, if the amendment favolve - a sign'.facant increase in the probability or consegnances of an accident or significantly decreases a safety margin, presummbly it ought not to be per-l mitted-It is our view that the staff's confusion of the issues bearing on the metits with the issues bearing on whether prior notice is required accounts for its traditional misappii-cetion of the 'no significant hasards conalderation* enesytion.
l The staff is apparently reluctant to suggest the existance of any serious questions aber.at the propriety of an amendment and k
l may view the finding that moine signif icant ha s a rd e con s ide r a t ien I
is involved as carrying a negative coanotation on the merits, in any case, it in clear that *no significant hasarda consideration
- is only a threshold test governing e x c e ; tice s to the prior notics rule.
The une of criteria w r. i ch s varn the nerits of the amendaant in Sn wpropriate, as is tre rese.a tion of substantial factum
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The e,vr-aen tn
+'is threshold qa.4stion should L *>
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e'e' should be that prior r. a t t r e ;s t r5 : A r ed un l e g m _tf.e f3**'s*nr
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involves no_significant previously unrevised sate;y issue.
That is, the test should be completely neutral as to tr.e mer;t of the amendment and keyed instead to wnether or not it involves issues not previously reviewed in a g.roceeding subject to public participation.
This would be in ha ony with the le;in -
lative intent of 42 USC 52239(a) and with its clear langage.
Indeed, it is implicit la the use of the phrase 'no significant hasarde gensteetation* that the focus should be on whether a previously unreviewed issue esiste, est en its resolution.
Otherwise the phrase would have read *no significant hasards.*
Finally, the criteria proposed by the Cossainston twply a level of detailed review of applications far boycad what is, in reality, the case.
Specifically, eriteria el inquires l
whether the ammadmeet would
- involve a eifnificant increase in the probability or consequences of an accident previously
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evluated.*3/
As a practical matter, neither license applica-I tions nor staff reviews co44tain any useful information en the 4
probability of particuler accidents sequences.
Over th e ye ar o.
certain accidents have becon included in the design basis as an exercise of what can best be described as the ccilective subjective judgment of the st af f, utilities a r>d ve ndors.
To our knowledge, neither the Psn, rt An or SEM 's a s soci at a any 3/
neo note that into p r o c i sa n v.stierstion of the o f f e-t.
of an a:sondannt on t r. - p r o ta b : 1 *
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<r cunan; ences cfn>
-r reactor accidents whie, have ro t 14es
- prev:ausly av4: ust**.'
It is PfpDC's and !;c'3'
>;*v t hat tr, $ erela t x := cme 3 e law and has r.o rational t -n a t e or t e - :.n i c a ;
- s ti f i r =
- This view is well knewn
- o t'e NP? and wil. rat tw !:
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at length herein.
If penub,i y
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sidered, thef rust i n c l u '..e
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-3 particular quantitative probability to any accidents.
There-fore it is emoeedingly unlikely that, without a substantial teshaical offort, any meaningful answer can be given to the geesties of whether and to what degree an amendment increases l
hhe pechobility of an assident.
It should be remembered that even with the emessoas toehnical offeet lavolved in unse-1490, the Biak - Revise Group found that the margins of oneertalaty emessisted with the probability fi eres are very f
Tsuet.
Beem if the lageiry were sesseptible of yielding a reemenably sh$estive assuor, the queetles is far too complom to he easfally addreened as a threshend test for providing prior moties of esenheets.
In suo, this eriterien is inappro-priate basemos it osanot possibly he addressed well with limited time one senseroes and arTembly esmeet he addressed well even with great time and seeseroes, and beoemme, to the i
estemt it Le relevent and esadel, it goes to the merits of an a m and not to ehether prier moties ir required.
It een he resseeably prediated that, if adopted, the offeet of this eritmeten will he to generate hellerplate in oopport of a findies that me signifteest hasards seasideration esists.
Criteries 82 asks whether the amendomet would *erente the peesthility of an eeeldent of a type different from any evolmsted peevievely."
The meaning of this criterion is meeleer.
Ia particular, the rule does not refer to any grouping of aseidents by ' type
- that would be employed as the benchmark for applying this criterica.
It is f urther unclear whether the term " type
- et accident refers to very broad groupe (e.g.,
t/)CA,
loes of feedwater) or whe the r t he level of detail of analyses
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. b will be required to demonstrate that no new potential
- type
- of accident may be created by the asmendment?
The third criterion addresses whether the anendment would
- involve a significant reduction in a margin of safety."
with-out amplification, we find this, standard essentially unintelli-gible.
It lacks both quantitative and qualitative parameters.
In the vast majority of situations, no quantitative margin of safety has been associated with a component or design.
It is omtresnely difficult, therefore, to imagine how this criterion
' would be applied in most cases in any objective fashion and, similar to the other criteria, even in casew when it can be a useful tool for analysis, it is appropriata at the omrits stage, not the threshold.
CO#CWSIM In eenslusion, the proposed rule represents an attempt to codify historical staff practice which, while long-standing, is contrary to law and sound policy.
First, the staff has perverted the intent of the statute by simply refusing to consider construction permit amendments.
Licensees are routinely permit-ted to make changes and additions to the approved design wit.hout filing for construction permit amendments.
by the time of the operating license review, these are literally cast in mnerete.
It becomes exceedingly esponsive, if possible at all, to reverse the dec i s ion s nad e du r i ng con s t ruc t i on.
All of e S-fine words of the Comunission with rega r J t o Lts legal matherity at tu operating license stage, and even the existonee of a few
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,u' enceptions, do not alter that fact.
Isot only does this policy frustrate pelslic participation, it also fundamentally compro-mises the ability of the agency to do its job.
The pi q :: f rule would pesudt the practice to contisme.
seemed, the stetf hem treditiman11y eenfused the geesties of the ultimate peepriety of en W with the geneties of shether prior eeties een he waived.
ghe peepened rule would sodify that eenfestem.
The criteria peepened offeetively estehliek the solewful prosesytion that moties see he salved essert in eneseel seems.
The statutory langeenge med legisla-tive hish==y esapel the oppeette In eedities, ther 4
- 4 Eely feces se the serito ed the W.
The IIRC should peemelgate a rule holding that prior o
motion and opporteesty See hearing shouad he provided Ser enestreetten posset and operating iseenese %- in all
===== eesset these 1 evolving es mienirseest pewiseety-enseviseed andety isome.
In oomtreet to peseest praettee, seek e sole useld be folly ceasement with the Atende theryy Act and with the altjective of posedtting esealegful public est IIIIC seestley of eigelfisent enenaments witheet iskihittag the staff's eistlity to approve those amendments etah are warranted.
Seepectfully submitteet i
rm YM
- f, kf tllymia. isetas skrLDow. nAtmom 6 wt!58 1725 t St.reet, N.W.,
gutte get Washi ng ton, D.C.
20006 (207) 4 3 ).90 7C DATED:
May 23, 1980 counsel for Natural Resoure** :=fense Crunc n 1 and Un t er. of Coneernec sei.ne3 +
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