ML20024D339
| ML20024D339 | |
| Person / Time | |
|---|---|
| Site: | 07002983 |
| Issue date: | 07/26/1983 |
| From: | Crow W, Ketzlach N NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20024D333 | List: |
| References | |
| NUDOCS 8308040557 | |
| Download: ML20024D339 (17) | |
Text
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JUL 2 61983 DOCKET NO.:
70-2983 APPLICANTS:
Pennsylvania Power & Light Company Allegheny Electric Cooperative, Inc.
FACILITY:
Susquehanna Steam Electric Station (SSES), Unit 2
SUBJECT:
SAFETY EVALUATION REPORT - REVIEW 0F LICENSE APPLICATION DATED APRIL 12, 1983 AND ITS REVISION DATED JUNE 20, 1983 FOR A MATERIALS LICENSE I.
INTRODUCTION
,e e
A.
General By application dated April 12, 1983 and its revision dated June 20, 1983, Pennsylvania Power & Light Company (PPL), on its behalf and as an agent for the Allegheny Electric Cooperative, Inc., requested authori-zation to receive, possess, inspect, and store fuel assemblies containing uranium enriched to 3.10 w/o U-235 at Unit 2 of the Susquehanna Steam Electric Station.
A 10 CFR Part 70 license for the possession and stor-age of similar fuel assemblies at Unit 1 was issued to PPL (SNM-1878) on September 10, 1981, The application requested authorization to store fuel assemblies in their metal shipping containers, in the New Fuel Storage Vault, and in the Spent Fuel Storage Pool.
The finished fuel assemblies will be sup-plied by the General Electric Company.
Each fuel assembly contains 62 fuel rods and two nonfueled (water) rods.
The rods are spaced on an 8 x 8 array.
Table 1 gives general fuel rod parameters that describe the fuel which will eventually be used in the Susquehanna Steam Electric Station, Unit 2.
The Materials License is being issued to allow early receipt of the fuel for the purpose of inspection and preparation of the fuel for reactor loading.
The license will automatically terminate upon issuance of the Part 50 operating license.
I B308040557 830726 PDR ADOCK 07002983 C
i JUL 2 6 E83 TABLE 1 Susquehanna Steam Electric Station, Unit 2 General Fuel Data Fuel Assembly Data in.
Overall Fuel Length 150.0 Fuel Rod Pitch 0.640 Fuel Rod Ar~ ray Size 8x8 Fuel Rods / Assembly 62 Fuel Rod Data Outside Diameter 0.483 Cladding Inside Diameter 0.419 Cladding Thickness 0.032 Cladding Material zircaloy Fuel Pellet Diameter 0.410 Fuel Pellet Material UO2 Fuel Pellet Density (% theoretical) 95.0 l
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JUL 2 61983 B.
Location Description The site for both the Susquehanna Steam Electric Station Units 1 and 2 is located on a 1,075 acre tract of land on the west bank of the Susquehanna River in Salem Township, Luzerne County, Pennsylvania.
The site is located in northeastern' Pennsylvania approximately 4 miles south of Shickskinny, 5 miles northeast of the Borough of Berwick, and about 20 miles southwest of the city of Wilkes-Barre.
It is currently under construction.
The construction permit, CPPR-102, was issued on November 2, 1973 (Docket No. 50-388).
Unit 1 has been operating under License No. NPF-14 since July 17, 1982.
II.
AUTHORIZED ACTIVITIES The applicant requests authorization to receive, possess, inspect, and store 764 finished fuel assemblies having a maximum enrichment of 3.10 w/o U-235 (including measurement and enrichment variations usually encountered).
The fuel will be stored in their metal shipping containers on the refueling floor, in the New Fuel Storage Vault, and in the Spent Fuel Storage Pool.
The applicant also requests the authority to repackage any assembly, if necessary, for delivery to a carrier.
It should be noted that the license
.will not authorize insertion of a fuel assembly into the reactor vessel.
The reactor in which the fuel assemblies will be used is a General Electric Boiling Water Reactor.
There are three types of fuel assemblies, each with a different distribution of enrichments.
The maximum total U-235 contained in all the fuel assemblies is 3,043 kg.
III. SCOPE OF REVIEW The safety review of the PPL request for a Materials License included an evaluation of the application dated April 12, 1983 and its revision dated June 20, 1983.
A detailed review was made of the PPL organization, adm.ini-
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stration, nuclear criticality safety, radiation protection, and fire protection programs.
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JUL 2 61983 Discussions were held with the NRR project manager, the resident inspector, staff members in NRC Region I, and with staff members of the applicant during the course of the reviews.
The evaluation of the physical security plan was made by.the Physical Security Licensing Branch, Division of Safeguards, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission.
IV.
POSSESSION LIMITS Since the applicant has already included measurement and enrichment variations, usually encountered, in the maximum U-235 enrichment requested, it is recommended Condition Nos. 6, 7, and 8 be added to the license to authorize the indicated special nuclear material, chemical and/or physical form, and maximum quantity the licensee may possess at any one time under this license, respectively.
6.
Material 7.
Form 8.
Quantity Uranium enriched In unirradiated 3,043 kg of U-235 ia the U-235 reactor fuel in uranium enriched isotope assemblies to no more than 3.10 w/o in U-235 V.
ORGANIZATION I
A.
Nuclear Criticality Safety and Radiation Protection Responsibilities l
All fuel receipt and inspection activities are controlled by applicable procedures which are reviewed and approved by the Plant Operations Review I
Committee (PORC), chaired by the Plant Superintendent.
The superintendent l
has the ultimate responsibility for administrative controls over fuel receipt and inspection activities.
The PORC has the responsibility for the review of procedures and changes thereto that affect nuclear safety.
t 4
JUL 2 61983 The applicant specified that the Reactor Engineering Supervisor is responsible for developing and implementing procedures involving control and handling of nuclear fuel and the Reactor Engineering staff personnel have the overall responsibility for nuclear criticality safety.
It is recommended Condition 11 be added to highlight the responsibility of the Reactor Engineering Supervisor f-or the control and handling of nuclear fuel.
Condition 11.
The Reactor Engineering Supervisor shall be responsible for developing and implementing procedures involving the control and handling of nuclear fuel.
The applicant also specified the responsibilities of the Health Physics Supervisor.
It is recommended the principal responsibilities be highlighted as Condition 12.
Condition 12.
The Health Physics Supervisor shall be responsible for administering the Radiation Protection Program.
The supervisor shall be responsible for providing the Plant Superintendent with information necessary to establish compliance with regulatic ns pertaining to i
radiation safety and for assuring that every reason-able effort is expended to maintain personnel exposure as low as reasonably achievable (ALARA).
The supervisor shall also be responsible for assuring that the staff who implements the Health Physics Program is trained and retrained in operational health physics principles applicable to this license.
B.
Minimum Qualifications The qualifications of the aforementioned safety related personnel were specified in the application.
It is recommended they be high Mghted as Conditions 13, 14, and 15.
Conditions 13 and 14 relating to the 5
JUL 2 61983 minimum qualifications of the Plant Superintendent and the Reactor Engineering Supervisor, respectively, are based on the minimum quali-fications for the Plant Manager and for Reactor Engineering, respectively, specified in ANSI /N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel"; that for the Health Physics Supervisor corresponds to the minimum qualifications for the Raaiation Protection Manager specified in Regulatory Guide 1.8, " Personnel Selection and Training" (Condition 15).
Condition 13.
The minimum technical qualifications for the Plant i
Superintendent, only as to activities that pertain to this license, shall be a B.S. degree in engineering or a scientific field and 10 years of power plant experience, of which 3 years shall be nuclear power plant experience.
Condition 14.
The minimum technical qualifications for the Reactor Engineering Supervisor, only as to activities that pertain to this license, shall be a B.S. degree in engineering or a physical science and 4 years work experience.
At least 2 of these years shall be nuclear power plant experience.
Condition 15.
The minimum technical qualifications for the Health Physics Supervisor shall be a B.S. degree in a science or engineering subject, including some formal training in radiation protection.
The Supervisor shall have at least 5 years of professional experience in applied radiation protection, at least 3 years of which should be in applied radiation protection work in a nuclear f acility dealing with radiological problems similar to those encountered in nuclear power stations.
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JUL 2 61983 i
C.
Training The applicant states that Plant Staff Radiation Engineering personnel, who have overall responsibility for nuclear criticality safety, will receive "all the classroom training given to fuel handling or inspection personnel." A commitment is also made that preoperational testing, to the extent necessary to prove that fuel handling equipment is functioning properly and is safe to handle the fuel, will be performed prior to using the equipment and that the necessary auxiliary support systems will be tested, to the extent necessary, to prove they are capable of performing their specific functicns for fuel receipt and inspection activities, prior to the receipt of fuel.
Although the applicant specified that before participating in any fuel receipt activities each individual will have completed all applicable training, the training neither identified the health and safety aspects of the training nor did it specify the i
training requirements for radiation safety personnel.
Therefore, it is recommended -Condition 16 be added to include additional training requirements.
1 1
Condition 16.
The following training shall be co:apleted by each r
individual prior to participation in the radiation safety and/or fuel handling programs:
P a.
All radiation safety personnel shall be trained l
in radiation safety and in SSES radiation protec-I tion procedures related to fuel assembly handling.
b.
All operations personnel involved in fuel handling shall receive training in proper fuel handling procedures, including the related health and safety aspects of the activities.
With the above conditions, the staff has concluded the applicant's i
i radiation safety and fuel handling training programs are adequate to allow them to reasonably carry out the activities for which a license is requested.
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JUL 2 61983 VI.
NUCLEAR CRITICALITY SAFETY 1
i A.
General The fuel assemblies will be stored in their shipping containers on the refuelino floor, in the New Fuel Storage Vault, and in the Spent Fuel j
Storage Pool.
Af ter the fuel assemblies are removed from the shipping containers, they may be stored dry in the New Fuel Storage Vault or either dry or under water in the Spent Fuel Storage Pool.
The New Fuel l
Storage Vault can accommodate 230 fuel assemblies.
The Spent Fuel Storage
]
Pool has a capacity for 2840 fuel assemblies.
In both the New Fuel Storage Vault and the' Spent Fuel Storage Pool, spaces between fuel storage positions are designed so that it is not possible to insert a fuel assembly l
in any position within the array not intended for fuel.
B.
Shipping Containers Although the applicant stated that when the fuel would be stored in their shipping containers, the fuel would only be stored in their inner
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metal containers, the truck unloading may be very time consuming.
The inner metal containers would have to be removed from their outer wooden containers as soon as each container was removed from the truck.
PPL requested authorization to store fuel assemblies in the metal containers in arrays stacked up to four high.
The staff has confirmed the nuclear criticality safety of the shipping container (inner metal and/or inner metal and outer wooden) storage arrays when it issued Amendment No. 5 l
to License No. SNM-1097 dated Jun.e 6, 1978, Docket No. 70-1113.
i Accordingly, the staff recommends the fcllowing license condition:
Condition 17.
Fuel assemblies, when stored in their shipping containers (inner metal and/or inner metal and outer wooden), shall be stacked no more than four high.
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JUL 2 61983 The applicant has stated the shipping containers containing fuel will be stored no closer than 5 feet from any other fuel.
In addition, the New Fuel Storage Vault is embedded in a concrete floor with a minimum of 1 foot of concrete between storage arrays.
The concrete barrier plus the a$itional 5 feet of space between the shipping j
container array and the New Fuel Storage Vault provides adequate spacing for interaction isolati:1 between fuel assembly arrays.
C.
Fuel Handlina The applicant has stated that upon removal of the assemblies from l
their shipping containers, the plastic bags will be removed prior to l
inserting the assembly in the storage rack.
The applicant has stated he plans to have no more than three fuel assemblies outside their shipping containers and storage racks at one time.
The NRC staff has shown that three fuel assemblies cannot be made critical independent of spacing between them and the degree of water moderation and/or reflection.
The staff has also determined that inter-action between this grouping of three assemblies and the other fuel arrays is negligible with either the 5 feet of air space or the 1 foot thickness of concrete between it and the fuel in the other arrays.
D.
New Fuel Storage Vault The New Fuel Storage Vault racks are designed so that the center-to center spacing between assemblies within a row is 6.535 inches and 11.875 inches between assemblies in adjacent rows.
There will be a maximum of 23 rows of assemblies with 10 assemblies per row.
In earlier studies, the staff had dh ermined that, if the entire vault t
could be flooded with water mist at optimum density the maximum k of gff the array would be greater than unity.
However, if flooded with full density water, an infinite array with water mist at the new fuel storage j
rack spacing would have a k, of less than 0.84.
The applicant has r e-cluded the possibility of flooding the entire array with water mist by placing 12 leak-tight metal covers over the fuel assembly vault.
No
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JUL 2 61983 i
more than two vault covers will be off (uncovering a maximum of five rows of fuel assemblies) at one time while fuel receipt and inspection activities are in progress.
At all other times, all 12 vault covers are locked in place.
Since it has been estimated by the staff that an array of as few as five rows of assemblies fully flooded with water mist at optimum density for maximum k may become critical, it is eff recommended that Conditions 18 and 19 be added to preclude the possibility of fully flooding the entire exposed section of the vault with water mist in the density range that may result in inadvertent criticality.
Condition 18.
Fuel assemblies, when stored in the New Fuel Storage Vault, shall be stored under the following conditions:
a.
No more than five rows of fuel assemblies shall remain uncovered during the ' loading or unloading of fuel assemblies.
b.
Leak-tight metal covers shall cover all other rows containing fuel assemblies during loading or unloading of fuel assemblies.
i c.
When loading or unloading of fuel is not in I
progress, leak-tight metal covers shall cover all rows of fuel assemblies.
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Condition 19.
All fire hoses on the refueling floor shall be equipped with straight stream nozzles.
Condition 19 precludes the possibility of moderating an entire open l
section of the fuel and from generating mist over the entire array to assure nuclear criticality safety.
The applicant had committed to the use of the leak-tight metal covers over the New Fuel Storage Vault when access is not required.
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yn. 2 61983 The applicant has indicated the assemblies will be stored bare (without plastic covers) in the fuel storage racks.
In storing the assemblies bare they cannot become internally moderated with water while the spaces between assemblies would be occupied with air.
This could only occur if the fuel assemblies were wrapped in plastic sheeting, closed at the bottoms. the storage area flooded, the area then drained, and the water retained in the plastic bags.
Large arrays under these conditions may become critical.
To allow the applicant the option of covering the fuel assemblies to protect them from the environment, it is recommended Condition 20 be added to ensure the fuel assemblies will be stored in such a manner that water would drain freely from the assemblies in the event of flooding and subsequent draining of the storage area.
Condition 20.
Fuel assemblies shall be stored in such a manner that water would drain freely from the assemblies in the event of flooding and subsequent draining of the fuel storage area.
It is the staff's opinion that with this condition, together with Conditions 18 and 19, the applicant has established reasonable and satisfactory precautions to avoid accidental criticality.
E.
Spent Fuel Storace Pool 9
The fuel assemblies in the racks in the Spent Fuel Storage Pool are spaced on 6.625-inch centers.
The racks are of anodized aluminum construction containing aluminum-clad Boral sheets positioned between each two adjacent assemblies.
The Boral plates are 0.100 inches thick 2
and contain 0.0233 g B-10/cm.
The applicant has stated the Boral slabs are c;anufactured by Erooks and Perk' ins.
The racks are manufactured by Programmed and Remote Systems Corporation (par) who provide assurance the correct Boral locations and quantities are present with design procurement documents through a quality assurance program evaluated, approved, and audited by Bechtel; PPL performed additional independent verificati5n of par's quality assurance program.
The staff has determined the maximum k, of the array of assemblies at optimum mist density (full density water) 11
jul 2 61983 to be 0.858+.005.
Therefore, any size array of fuel assemblies in the Spent Fuel Storage Pool is safe from inadvertent criticality.
F.
Criticality Alarm Exemption The applicant has requested, pursuant to 10 CFR 670.24(d), an exemption from the provisions of 10 CFR $70.24.
Because of the inherent features associated with storage and inspection of unirradiated fuel containino uranitm enriched to less than 5% in the U-235 isotope when no fuel processing activities are to be performed, the staff hereby determines that granting such an exemption will not endanger life, property, or the common defense and security, and is otherwise in the public interest and is authorized by law.
This exemption is authorized pursuant to 10 CFR g70.14.
The staff recommends that this exemption be identified as Condition 21.
1 Condition 21.
The licensee is hereby exempted from the provisions of 10 CFR @70.24 insofar as this exemption applies to materials held under this license.
VII. RADIATION SAFETY i
As mentioned in Section V. A. above, the Health Physics Supervisor is l
responsible for administering the Radiation Protection Program.
The main l
objective of the Health Physics Program is to provide administrative control of persons on the site to ensure that personnel radiation exposure is within j
the guidelines of 10 CFR Part 20 and that such exposure is kept as low as reasonably achievable (ALARA).
Personnel external exposures are evaluated and controlled on the basis of data from personnel dosimeters.
Each new fuel assembly is monitored for removable alpha and beta contamination and is surveyed for beta gamma dose l
rate.
Fuel assembly unpackaging and storage areas are routinely monitored for removable contamination and general radiation levels.
Area monitoring is l
performed daily when fuel assembly receipt and inspection work are in progress.
Otherwise, monitoring is performed weekly.
Since the radioactive materials 12 1
I l_______________.__..__._,_
2 6 1983 jul that are authorized by this license are fresh fuel assemblies (essentially sealed sources) for storage purposes only, it is unlikely that an individual would receive an internal exposure from materials possessed under this license.
Action levels have been established for new fuel assembly monitoring that are a small fraction of the surface contamination levels allowable on f acilities and equipment for release for unrestricted use (NRC " Guidelines for i
Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material," dated July 1982).
The applicant has specified the portable survey instrumentation used to support the receipt and inspection of new fuel assemblies will be calibrated on a quarterly basis. The frequency meets the frequency condition recommended in Regulatory Guide 8.24, " Health Physics Surveys During Enriched Uranium-235 Processing and Fuel Fabrication."
i Since this license authorizes possession only of fuel assemblies, very little radioactive waste, if any, will be generated under this license.
However, if there is any radioactive waste generated, the waste will be processed in accordance with the Solid Waste Management System referenced in the application (FSAR Section 11.4).
j VIII.
ENVIRONMENTAL PROTECTION The " Final Environmental Statement" related to the operation of the Susquehanna Steam Electric Station, Unit 2, dated June 1981, has been prepared and issued by the NRC as NUREG-0564.
Based on the environmental statement, l
implementation of the 10 CFR Part 70 license for the storage and handling of special nuclear materials will have an insignificant effect on the environment.
IX.
FIRE SAFETY The materials used in the fuel storage areas are steel and concrete! with the exception of the fuel storage racks which are of aluminum construction.
l The Reactor Building, in which the fuel assemblies are stored, are equipped 13
JUL 2 61983 with automatic dry sprinklers and manually operated fire fighting equipment consisting of fire hose stations and portable extinguishers.
The applicant is committed to equipping the fire hoses on the refueling floor with straight stream nozzles to provide added assurance for nuclear criticality safety of the array of fuel assemblies in the New Fuel Storage Vault (see Section VI.D.
above).
Under these conditions, the staff has determined the fire protection measures provided are adequate for the protection of the facility.
X.
The SSES physical security plan has been reviewed.
It is the staff's opinion that the program described is adequate and meets the requirements of i
10 CFR e73.67.
To ensure that the physical security plan shall be fully implemented and remain in effect whenever fresh fuel is stored onsite, the staff recommends the following license condition:
Condition 22.
The "Paysical Security Plan for the Protection of SNM of Lower Strategic Significance" shall be fully implemented by the date of fuel receipt and shall be in effect whenever fresh fuel is stored onsite.
XI.
CONCLUSIONS After reviewing the application and its revision, the NRC staff finds that:
i l
a.
The application meets the requirements of the Atomic Energy Act, as amended, and of the regulations of the Commission.
b.
Issuance of the license would not be inimical to the common defense and security.
i Issuance of the license would not constitute an unreasonable risk to c.
the health and safety of the public.
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JUL '2 61983 XII. RECOMMENDATIONS The staff recommends approval of the revised application subject to the following conditions which the staff finds are appropriate to protect health and to minimize danger to life or property:
3 11.
The Reactor Engineering Supervisor shall be responsible for developing and implementing procedures involving the control and handling of nuclear fuel.
12.
The Health Physics Supervisor shall be responsible for administering the Radiation Protection Program.
The supervisor shall be responsible for providing the Plant Superintendent with information necessary to establish compliance with regulations pertaining to radiation safety and for assuring that every reasonable effort is expended to maintain personnel exposure 1
as low as reasonably achievable (ALARA).
The supervisor shall also be responsible for assuring that the staff who implements the Health Physics ProgramistrainedandretrainedinoperationalhealthphysicsprincipIII"#
applicable to this license.
13.
The minimum technical qualifications for the Plant Superintendent, only as to activities that pertain to this license, shall be a B.S. degree in engineering or a scientific field and 10 years of power plant experience, r
of which 3 years shall be nuclear power plant experience.
l 14.
The minimum technical qualifications fo-the Reactor Engineering Supervisor, only as to activities that pertain to this license, shall be a B.S. degree i
in engineering or a physical science and 4 years work experience.
At i
j least 2 of these years shall be nuclear power plant experience.
i 15.
The minimum technical qualifications for the Health Physics Supervisor shall be a B.S. degree in a science or engineering subject, including some formal training in radiation protection.
The Supervisor shall have
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at least 5 years of professional experience in applied radiation protection, at least 3 years of which should be in applied radiation i
15 I
JUL 2 61983 protection work in a nuclear facility dealing with radiological problems similar to those encountered in nuclear power stations.
l 16.
The following training shall be completed by each individual prior to participation in the radiation safety and/or fuel handling programs:
All radiation safety personnel shall be trained in radiation safety a.
and in SSES radiation protection procedures related to fuel assembly handling.
b.
All operations personnel involved in fuel handling shall receive training in proper fuel handling procedures, including the related j
health and safety aspects of the activities.
17.
Fuel assemblies, when stored in their shipping containers (inner metal and/or inner metal and outer wooden), shall be stacked no more than four i
high.
18.
Fuel assemblies, when stored in the New Fuel Storage Vault, shall be stored under the following conditions:
a.
No more than five rows of fuel assemblies shall remain uncovered j
during the loading or unloading of fuel assemblies.
b.
Leak-tight metal covers shall cover all other rows.containing fuel assemblies during loading or unloading of fuel assemblies.
When loading or unloading of' fuel is not in progress, leak-tight c.
metal covers shall cover all rows of fuel assemblies.
19.
All fire hoses on the refueling floor shall be equipped with straight j
stream nozzles.
l 20.
Fuel assemblies shall be stored in such a manner that water would drain freely from the assemblies in the event of flooding and subsequent draining of the fuel storage area.
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JUL 2 61983 21.
The licensee is hereby exempted from the provisions of 10 CFR 570.24 insofar as this exemption applies to materials held under this license.
22.
The " Physical Security Plan for the Protection of SNM of Low Strategic Significance" shall be fully implemented by the date of fuel receipt and shall be in effect whenever fresh fuel is stored onsite.
Orir 7.91 SiFaed by 8
N. 7 :' "' eh Norman Ketzlach Uranium Process Licensing Branch Division of Fuel Cycle and Material Safety, NMSS UPI IDRI sf gned bit 8
Approved by:
W. T. Crow W. T. Crow, Section Leader FCUP %[
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FCUP ([
NKetzlach Vl/TMpe WTCrow 7//}lff)
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. UNITED STATES NUCLEAR REGULATORY COMMISSION h
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Docket No. 50-387 70-2983
. AMENDMENT T0.. INDEMNITY AGREEMENT.NO. B.
AMENDMENT NO. 2 E
Effective Indemnity Agreement No. B-90, between Pennsylvania Power and Light Company and Allegheny Electric Cooperative, Inc. and the Nuclear Regulatory Commission, dated September 10, 1981, is
...her,eby further amende.d.as f,ollows:
Item 3 of the Attachment to the indemnity agreement is deleted in its entirety and the following substituted therefor:
Item 3 - License number or numbers SNM-1878 (From 12:01 a.m., September 10, 1981 to 12 midnight, July 16, 1982, inclusive)
SNM-1919 (From 12:01 a.m.,
N
)
NPF-14 (From 12:01 a.m., July 17,1982)
FOR THE UNITED STATES NUCLEAR REGULATORY COMMISSION
/N
(
7M Jerome Saltzman, Asp stant Director State and Licensee / Relations Office of State Pfograms Accepted
, 1983 Accepted 1983 By By PENNSYLVANIA F0WER AND LIGHT CO.
ALLEGHENY ELECTRIC COOPERATIVE, INC.
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