ML20082N476

Statement of Concerns on Ohio Citizens for Responsible Energy & Environ Coalition on Nuclear Pollution Proposed Contentions Re Safety Issues.Certificate of Svc Encl

ML20082N476
Person / Time
Site:	Beaver Valley
Issue date:	11/30/1983
From:	Ferkin Z PENNSYLVANIA, COMMONWEALTH OF
To:
References
NUDOCS 8312070192
Download: ML20082N476 (6)

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DOCKETED USNRC UNITED STATES OF AMERICA 13 DEC -5 #0:32 NUCLEAR REGULATORY COMMISSION CFFIE or sg:gg.

CCCKETitiG & SERvir::

BRANCH BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

DUQUESNE LIGHT COMPANY, ET AL. ) Docket No. 50-412 (Beaver Valley Power Station, )

Unit 2) )

Statement of Concerns of the Commonwealth of Pennsylvania In anticipation of the Board's forthcoming ruling on proposed contentions filed by petitioners, ECNP and OCRE, the Commonwealth hereby advises the Board of the matters raised by the proposed contentions in which the Commonwealth has a particular interest.1 These contentions raise matters that are of particular concern to Pennsylvania because of the state's l

responsibility to protect the public health and safety. The NRC l

staff's safety and environmental evaluations are not expected to be completed until well into 1984. Because the analysis to be l

provided in these reports is not yet available, the Commonwealth ,

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1 In previous NRC proceedings in which the Commonwealth has participated, licensing boards have asked it to indicate particular matters on whichit desires to participate as permitted under 10 C.F.R. 5 2.715(c). See, e.g., Pennsylvania Power and Light Company ( Msquehanna Steam Electric Station, Units 1 and 2), Order of July 27, 1981 (unpublished).

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2 m believes it apprcpriate to inform the Board of its concerns at this time, while the Board considers whether to admit proposed contentions.

By enumerating certain contentions, the Commonwealth does not specifically adopt or endorse the language of the contentions. 'Further, in highlighting certain contentions, the Commonwealth does not intend to either restrict the scope of its participation in the proceeding, or imply a position regarding the merits of any of the proposed contentions.

10C.F.R}f 2 715(c) allows th'e representative of an interested state a reasonable opportunity to participate and to introduce evidence, interrogate witnesses, and advise the Commission without requiring the representative to take a position with respect to the issues.

The Commonwealth has a paticular interest in the matters raised by the following contentions:

(1) ECNP Contention 6 The Commonwealth is concerned that important safety issues be fully addressed prior to plant operation. With regard to safety issues the Commission has identified as unresolved generic issues, the Commonwealth's concern is that the plant may be operated safely notwithstanding the fact that such issues remain unresolved.

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(2) ECNP Contention 7 Issues with regard to auxiliary safety equipment have been raised and litigated in other pro'ceedi.ngs involving pressurized water reactors, including the TMI-1 restart proceeding. The Commonwealth is therefore concerned that safety issues I l

concerning such equipment be resolved satisfactorily prior to l l plant operation. -

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(3) ECNP Contention 8 As in the case of ECNP Contention 6 above, the Commonwealth is concerned that it be demonstrated that Beaver Valley 2 can ortrate safely, pending final resolution of the l generic issue of the safety consequences of pressurized thermal l

shock.

(4) ECNP Contention 10 The Commonwealth has a particular interest in evacuation planning and emergency response issues due to its responsibility for development and review of offsite emergency plans. In particular, the Commonwealth is interested in ensuring the l

I adequacy of radiological monitoring for offsite emergency workers, including sufficient dosimetry.

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The Commonwealth urges the Board to consider its concerns in its forthcoming ruling on proposed contentions.

Respectfully submitted, 4

Zori G. Ferkin Assistant Counsel Commonwealth of Pennsylvania Governor's Energy Council P. O. Box 8010

1625 North Front Street Harrisburg, PA 17105 i

j Date:

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! 1 UNITEo STATES Oe Am:aICA 09jffa!I l NUCLEAR REGUIA'ICIE CCIEISSION l 1

BEFORE THE A'IOMIC SAFETY AND LICENSING BOARD '83 DEC -5 A10 :33 i In the Matter of ) 0FFKE 0~ SiJGr 00CKElittG & SERVW

} BRANCH DUQUESNE LIGHT COMPANY, ET AL.

) .

Docket No. 50-412 OL

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(Beaver Valley Power Station, )

Unit 2) o) a:;KunCATE OF SERVICE I hereby certify that copies of " Statement of Concerns of the Ccmnonwealth of Pennsylvania" in the above - captioned prmaaling have been served in the following ,

by deposit in the United States mail, first class, or, as indicated by an asterisk (

through deposit in the C - wealth of Pennsylvania's internal mail system, this 30th day of Novent'wr,1983:'

l Morton B. Margulies, Chairman Docketing and Service Section Atomic Safety and Licensing Board Office of the Secretary U.S. Nuclear Regulatory Ocurmission U.S. Nuclear Regulatory Ccmnission ,

Washington, D.C. 20555 Washington, D.C. 20555 j Ernest E. Hill William A. Iochstet Administrative Judge 119 East Aaron Drive 210 Montego Drive State College, Pennsylvania 16802 I Danville, California 94526 l George S. White I Dr. Paul W. Purdam Box 58 Administrative Judge Shippensburg, Pennsylvania 15077 l 235 Colunbia Drive i Decatur, Georgia 30030 Ralph F. Walker l 1518 Fifth Street Jay E. Silberg, Esq. New Brighton, Pennsylvania 15066 Shaw, Pittman, Potts & Trowbridge Suite 900, South inhby Susan L. Hiatt 1800 M Street, N.W. 8275 Munson Road Washington, D.C. 20036 Mentor, Ohio 44060 Robert G. Perlis, Esq. Dr. Judith H. Johnsrud Office of the Executive legal Director 433 Orlando Avenue U.S. Nuclear Regulatory Comnission State College, Pennsylvania 16801 Washington, D.C. 20555 l

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• Atanic Safety and Licensing Board

• Director Panel Pennsylvania Emergency Management U.S. Nuclear Regulatory Coptission Agency Washington, D.C. 20555 Roan B-151 Transportation & Safety Building Atatic Safety and Licensing Appeal Harrisburg, Pennsylvania 17120 Panel U.S. Nuclear Regulatory rh=1ssion

• Thomas Genisky Washington, D.C. 20555 Bureau of Radiation Protection

.Pa. Department of Enviornmental Resources P. O. Box 2063 Harrisburg, Pennsylvannia 17120 1

4 'M Zori G. Ferkin Assistant Counsel Governor's Energy Council i

Date: November 30, 1983 l

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