ML20032D897
| ML20032D897 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 11/09/1981 |
| From: | Lanpher L CALIFORNIA, STATE OF, KIRKPATRICK & LOCKHART |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML20032D898 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8111180266 | |
| Download: ML20032D897 (3) | |
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j UNITED STATES OF AMERICA
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NOV 101981
- NUCLEAR REGULATORY COMMISSION Clue c' ?
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s E.ta BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BO j
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In the Matter of
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PACIFIC GAS AND ELECTRIC COMPANY
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Docket Nos. 50-275 0.L.
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50-323 O(LT'.&
(Diablo Canyon Nuclear Power Plant, )
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IO GOVERNOR BROWN'S SUPPORT FOR JOINT INTERVENORS H 0.s. %
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s In accordance with the Appeal Board's Order date October 29, 1981, the Governor submits this pleading in support of Joint Intervenors' Directed Certification Request, dated October 8, 1981.
The Governor will not repeat the arguments which have been made by Joint Intervenors and documented extensively in their October 8 pleading and attachments thereto.
Joint Inter-venors have presented detailed, specific contentions which bear directly on the safety of the Diablo Canyon facility.
- Further, Joint Intervenors have addressed and persuasively satisfied the criteria for reopening the record.
The Licensing Board, in its August 4, 1981 Memorandum and Order, largely ignored Joint Inter-venors' arguments and seriously misapplied the Commission's guidance.
The Licensing Board should be reversed and directed to admit Joint Intervenors' clarified contentions in the full power proceeding.
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The Governor offers specific comment on the substance of one of Joint Intervenors' contenuions -- that concerning the ad-verse impact on safety resulting from potential. interactions be-tween safety and nonsafety systems. /
-Joint Intervenors contend that there is no reasonable assurance of compliance with many General Design Criteria because PG&E has failed to analyze the potential adverse interactions between safety and nonsafety systems at Diablo Canyon.
The Governor agrees that this contention should be ad-mitted and attaches hereto the affidavit of Gregory C. Minor in support thereof.
Mr. Minor documents the need for a comprehen-sive systems interaction analysis of Diablo Canyon.
In particular, Mr. Minor demonstrates:
1.
Recent events, particularly at TMI, Crystal River and Rancho Seco, document the severe ad-verse interactions that can occur between safety and nonsafety systems.
2.
The limited systems interactions analyses conducted to date for Diablo Canyon identified more than 800 potential adverse interactions.
These analyses, however, only covered seismically induced inter-actions, leaving unanalyzed a wide spectrum of other potential interactions.
These other interactions must be analyzed and necessary modifications ef-fected before there can be reasonable assurance that Diablo Canyon can be operated in accordance with regulatory requirements.
- / 'See' Joint Intervenors' Statement of Clarified Contentions,
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The Governor acgordingly urges this Appeal Board to re-verse the Licensing Board and to direct admission of Joint Inter-venors' Clarified Contentions.
Respectfully submitted, Byron S. Georgiou Legal Affairs Secretary Governor's Office State Capitol Sacramento, California 95814 w
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Lawrence Coe Lanpher KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER AND-PHILLIPS 1900 M Street, N. W.
Washington, D.
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20036 Attorneys for Governor Brown of the State of California November 9, 1981 i
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