ML20072A141
| ML20072A141 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/01/1994 |
| From: | Rinaldi F Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20072A142 | List: |
| References | |
| NUDOCS 9408120154 | |
| Download: ML20072A141 (14) | |
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7590-01 UNITED STATES NUCLEAR REGULATORY COMMISSION PHILADELPHIA ELECTRIC COMPANY DOCKET NOS. 50-352 AND 50-353 NOTICE OF CONSIDERATION OF ISSUANCE OF AMENDMENT TO FACILITY OPERATING LICENSE. PROPOSED NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION. AND OPPORTUNITY FOR A HEARING The U.S. Nuclear Regulatory Commission (the Commission) is considering issuance of an amendment to Facility Operating License Nos. NPF-39 and NPF-85 issued to the Philadelphia Electric Company (PECO or the licensee) for operation of the Limerick Generating Station, Units 1 and 2, located in Montgomery County, Pennsylvania.
The proposed amendment request of January 14, 1994, would increase the storage capacity in each spent fuel pool (SFP) from their current 2040 fuel assemblies to 4117 fuel assemblies.
In addition, the proposed amendment would extend the " full core reserve" capability from year 1998 to 2013.
On May 6, 1994, PECO submitted another application requesting an interim increase in the capacity of the Unit 1 SFP, from 2040 to 2500 fuel assemblies.
PEC0's submittal of June 3,1994 supplemented their submittal of May 6,1994.
The Commission granted approval of the May 6, 1994 application by Amendment i
No. 72 to Facility Operating License No. NPF-39 for the Limerick Generating j
Station, Unit 1, on June 30, 1994.
Before issuance of the proposed license amendment, the Commission will have made findings required by the Atomic Energy Act of 1954, as amended (the Act) and the Commission's regulations.
The Commission has made a proposed determination that the amendment request involves no significant hazards consideration. Under the Commission's regulations in 10 CFR 50.92,. this means that operation of the facility in 9408120154 940801 PDR ADOCK 05000352 P
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. accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety. As required by 10 CFR 50.91(a), the licensee has provided its analysis of the issue of no significant hazards consideration, which is presented below:
1.
The proposed Technical Specifications (TS) changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
Increasing the spent fuel storage capacity in each Spent Fuel Pool (SFP) to 4117 fuel assemblies does not increase the probability of occurrence of an accident. Since all fuel handling activities will be performed using approved procedures and compatible equipment, the probability of a fuel handling accident occurring is unchanged.
The intermediate configuration involving the installation of the new maximum density racks in the Unit 2 SFP and placement of additional existing racks in the Unit 1 SFP will not prevent the ability of the Fuel Pool Cooling and Cleanup (FPCC) systems from adequately cooling their respective SFP. The backup cooling and makeup systems (i.e.,
Residual Heat Removal (RHR), Emergency Service Water (ESW), and Residual Heat Removal Service Water (RHRSW) systems) will continue to function as designed to provide an alternate source of cooling and makeup water to ensure SFP cooling is maintained.
Increasing the spent fuel storage capacity in each SFP will result in a slight increase in the maximum normal decay heat load from 16.32 X 10' Btu /hr to 18.05 X 10 Btu /hr. This increase is due to 1) the heat load associated with a maximum storage capacity of 4117 fuel assemblies, 2) a 5% power rerate consideration (i.e., the effects of increasing the rated core thermal power from 3293 MWt to 3458 MWt),
- 3) a reduction in the minimum decay time until fuel movements begin, and 4) the effects of increasing our refueling cycles from 18-months to 24-months. Section 9.1.3, " Spent Fuel Pool Cooling and Cleanup,"
of NUREG-0800, " Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," recommends that the SFP
9 I temperature be maintained at or below 140'F. However, due to the increase in the maximum normal decay heat load, and with two (2) trains of fuel pool cooling operating, the temperature that the SFP can be maintained will increase from 140*F to 143'F. The time period that two (2) trains of fuel pool cooling can not maintain the pool temperature below 140*F is 2.5 days and the SFP temperature will exceed 140*F approximately 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> after plant shutdown. The slight increase in SFP temperature (i.e., 140*F to 143*F) is considered acceptable since the increase is small (i.e., 3*F), and the duration in which the temperature exceeds 140*F is short (i.e.,
2.5 days).
In addition, during this period the RHR system will be available for operation to maintain the desired SFP temperature. The maximumdecayheatload,assumingfullcorpdischargeandremaining 6
cells filled, will increase from 36.4 x 10 Btu /hr to 37.6 x 10 Btu /hr; however, the RHR system is still be [ sic] capable of maintaining SFP temperature less than 140*F as described in LGS Updated Final Safety Analysis Report (UFSAR) and supporting Safety Analysis Report provided in Attachment 2 (See application dated l
January 14, 1994 for Attachment 2]. This increase in tcmperature will not increase the probability of a loss of fuel pool cooling accident or adversely affect the Refuel Floor ventilation system.
j The proposed piping modifications to the RHR system piping inside the Unit 2 SFP will not interfere with the RHR system's ability to adequately cool the SFP or to prevent siphoning of the SFP water.
Movement of the Unit 2 SFP gates to the new storage location and-installation of the new fuel storage racks will be accomplished in accordance with the guidance specified in NUREG-0612, " Control of Heavy Loads at Nuclear Power Plants." Approved procedures, safe load paths, and single failure proof rigging will be used. Therefore, the probability of a heavy load drop is unchanged.
The consequences of a Fuel Handling Accident as described in the LGS UFSAR is not increased since the number of fuel assemblies stored in a SFP is not an input to the initial conditions of the accident i
evaluation. This accident evaluates the dropping of a spent fuel assembly and the fuel grapple assembly into the reactor core during refueling operations. A drop height of 32 feet for the spent fuel assembly and 47 feet for the fuel grapple assembly are assumed and will produce the largest number of failed fuel rods. The tops of the new spent fuel racks are at the same level as the existing spent fuel racks.
Since the maximum possible height a fuel assembly can be i
dropped over the SFP does not exceed 32 feet, the consequences of a Fuel Handling Accident will not be increased by increasing the number of fuel storage cells. The increase in dose estimates presented in
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k the Safety Analysis Report are within 10 CFR 100 limits and are the result of increased fuel enrichment for power rerate and 24-month refueling cycles, and not as a result of an increase in the number of' fuel storage cells. These other changes are the subject of separate i
TS Change Requests that have already been submitted to the NRC for approval.
h The consequence of a loss of fuel pool cooling as described in i
Section 9.1.3.6 of the LGS UFSAR will not be increased. The event described in the UFSAR assumes that the iodine in the fuel from past refuelings is negligible, due to long decay time.
Iodine is the t
major contributor to thyroid dose. Since the iodine in the fuel from i
past refuelings is negligible, due to the long decay time, increasing the number of fuel storage cells will not increase the dose due to the release of iodine in the SFP water resulting from boiling and therefore, the consequences are not increased. The time to boil of 13.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> currently spect fied in UFSAR bounds the time to boil of 9.15 hrs presented in the supporting Safety Analysis Report since the J
13.5 hrs is for 21 days after reactor shutdown and the 9.15 hrs is for 7.25 days after reactor shutdown, and the decay heat from the newly discharged fuel decreases exponentially with time after plant i
shutdown.
The new maximum density storage racks have been designed and. analyzed 1
to maintain K less than or equal to 0.95.
The supporting Safety n
Analysis Repo,rt includes the effects of various anomalies such as a 1
fuel assembly drop event, manufactaring tolerance variations, and 1
abnormal lec6 tion of a fuel assembly. Since a K of less than or
.i equal to 0.95 with a confidence factor of 95% is,nmaintained, the consequences of an event that would affect criticality control will not increase. The planned interim configuration of the Unit 1 pool is bounded by the current analyses in the UFSAR, since the rack design is unchanged.
The new maximum density storage racks have been designed and analyzed to seismic Category I criteria and are capable of remaining functional during the event of a fuel assembly and fuel grapple
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assembly impacting the rack from a height of 36 inches, as described in the attached Safety Analysis Report [See app 1h;ation dated January 14, 1994 for Attachment 2]. Since the %w maximum density storage racks are capable of withstanding an impact from e height of 36 inches, the consequences of the events described in thc LGS OFSAR which use a drop height of 16 inches, are not increased.
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Increasing the on-site storage capacity by installing additional
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storage cells will not increase the probability of a malfunction of the stored spent fuel based on the thermal-hydraulic analysis presented in the supporting Safety Analysis Report [See application dated January 14, 1994 for Attachment 2] which concludes that sufficient cooling exists with 4117 fuel assemblies in a SFP. As for fuel criticality, the determination is based on the criticality analysis documented in the supporting Safety Analysis Report which confirms that the stored fuel assemblies will remain sub-critical under normal and abnormal conditions.
j Increasing the on-site storage capacity by installing additional l
storage cells will not increase the probability of a malfunction of the SFP liner based upon the SFP structural analysis as documented in the supporting Safety Analysis Report which indicates that adequate 1
margin exists to prevent overstressing of the SFP liner.
Increasmg the on-site storage capacity by installing addition [al 1
storago cells will not increase the probability of a malfunction o]f the SFP structure.- This is based upon the SFP structural analysis as documented in the supporting Safety Analysis Report which confirms j
that the SFP structure still has adequate margin to prevent overstressing and meets the code requirements for the LGS.
1 Increasing the on-site capacity by installing additional storage cells will not increase the probability of a malfunction of the spent a
fuel storage racks based on the seismic / structural analysis
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documented in the supporting Safety Analysis Report which concludes 4
that in'.eraction of racks during a seismic event will not result in j
loSL of the spent fuel storage racks' ability to function. The planned relocating the storage location of the SFP gates will not increase the probability of a malfunction of the SFP gates since, while being stored, the SFP gates do not perform a safety function.
The hangers used to secure the SFP gates will be designed / installed to the same requirements as the existing hangers.
Increasing the on-site spent fu'il storage capacity will not increase the probability of a malfunction of the Fuel Pool Cooling and Cleanup (FPCC) system. The only impact on the FPCC system of increasing the spent fuel storage capacity will be a slight increase in fluid temperature (i.e., 140*F to 143*F) which is within the design temperature of the system (i.e., 150*F) as described in the LGS UFSAR.
Modifying the RHR piping in the Unit 2 SFP such that it will not interfere with increased fuel storage will not increase the probability of a malfunction of the RHR system since the RHR' system's i
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ability to cool the SFP and to prevent siphoning of the SFP water will remain unchanged. Only the RHR discharge piping inside the SFP will be modified. The proper flow pattern will be maintained and net-positive suction head requirements will be unaffected.
The probability of a malfunction of fuel handling equipment will not be increased since increasing the on-site storage capacity does not affect fuel handling equipment.
Increasing the on-site spent fuel storage capacity does not increase the consequences of a spent fuel assembly failure since the failure of one assembly will not result in additional spent fuel assembly failures.
Increasing the on-site spent fuel storage capacity does not increase the consequences of a loss of fuel pool cooling as described in Section 9.1.3.6 of the LGS UFSAR which evaluated the radiological affects due to thyroid dose.
Iodine is the major contributor to thyroid dose. The iodine in the fuel from past refuelings is negligible, due to the long decay time. Since the release of iodine resulting from the SFP water boiling is entirely due to the freshly discharged fuel, the consequences of reracking the SFPs are unchanged from that previously evaluated. The evaporation rate will increase due to higher decay heat load. However, since the time to boil is 9.15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />, as discussed previously, adequate time exists to align the alternate makeup water sources (e.g., RHR, Emergency Service Water (ESW), and Residual Heat Removal Service Water (RHRSW) systems) to maintain SFP water level and therefore, the consequences are not increased.
Increasing the on-site storage capacity will not increase the consequences of spent fuel storage rack failure, since both the new maximum density racks and the existing racks have been designed / qualified to limit the consequences of a failure. A failure of or damage to one (1) storage rack will not result in failure or damage to another storage rack.
Increasing the on-site storage capacity will not increase the consequences of a failure of the SFP gates or SFP liner since the design of the SFP to maintain adequate water. level and the available makeup capacity are unaffected.
Increasing the on-site storage capacity will not increase the consequences of the failure of fuel handling equipment since the maximum expected number of fuel rods damaged by a fuel handling equipment failure remains as evaluated in the LGS UFSAR.
Therefore, the proposed TS changes do not involve an increase in *.h>
probability or consequences of an accident previously evaluated.
< 2.
The proposed TS changes do not create the possibi1ity of a new or different kind of accident from any accident previously evaluated.
Increasing the spent fuel storage capacity in er.ch of the SFPs at LGS to a maximum of 4117 fuel assemblies as analyzed in the attached Safety Analysis Report (See application dated January 14, 1994 for ] will not create the possibility of an accident of a different type. The SFP configurations have been analyzed for reactivity / criticality effects, thermal / seismic-structural effects, radiological effects, and thermal-hydraulic effects. Since the increase in storage capacity is achieved by installation of additional storage racks which are passive components, the possibility of creating a new accident does not exist.
No new operating schemes or active equipment types will be required to store additional fuel bundles in the SFP. Therefore, the possibility of a different type of malfunction occurring is not created.
Therefore, the proposed TS changes do not create [the] possibility of a new or different kind of accident from any previously evaluated.
3.
The proposed TS changes do not involve a significant reduction in a margin of safety.
Since the existing TS limits for fuel handling interlocks, heavy loads restrictions, water coverage over irradiated fuel, and fuel sub-criticality will be maintained, the margin of safety will not be reduced.
Therefore, the proposed TS changes do not involve a reduction in a margin of safety.
The NRC staff has reviewed the licensee's analysis and, based on this review, it appears that the three standards of 10 CFR 50.92(c) are satisfied.
Therefore, Ine NRC staff proposes to determine that the amendment request involves no significant hazards consideration.
The Commission is seeking public comments on this proposed determination.
Any comments received within 30 days after the date of publication of this notice will be considered in making any final determination.
Normally, the Commission will not issue the amendment until the expiration of the 30-day notice period. However, should circumstances change
l during the notice period such that failure to act in a timely way would result, for example, in derating or shutdown of the facility, the Commission i
may issue the license amendment before the expiration of the 30-day notice period, provided that its final determination is that the amendment involves no significant hazards consideration. The final determination will consider all public and State comments received. Should the Commission take this actioh, it will publish in the FEDERAL REGISTER a notice of issuance and provide for opportunity for a hearing after issuance. The Commission expects that the need to take this action will occur very infrequently.
Written comments may be submitted by mail to the Rules Review and Directives Branch, Division of Freedom of Information and Publications Services, Office of Administration, U.S. Nuclear Regulatory Commission, Washington, DC 20555, and should cite the publication date and page number of this FEDERAL REGISTER notice. Written comments may also be delivered to Room P-223, Phillips Building, 7920 Norfolk Avenue, Bethesda, Maryland, from 7:30 a.m. to 4: 15 p.m. Federal workdays. Copies of written comments received may be examined at the NRC Public Document Room, the Gelman Building, 2120 L Street, NW., Washington, DC 20555.
The filing of requests for hearing and petitions for leave to intervene is discussed below.
By September 7,1994
, the licensee may file a request for a hearing with respect to issuance of the amendment to the subject facility operating license and any person whose interest may be affected by this proceeding and who wishes to participate as a pa-ty in the proceeding must file a written request for a hearing and a petition for leave to intervene. Requests for a
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hearing and a petition for leave to intervene shall be filed in accordance l
with the Commission's " Rules of Practice for Domestic Licensing Proceedings"
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in 10 CFR Part 2.
Interested persons should consult a current copy of 10 CFR l
2.714 which is available at the Commission's Public Document Room, the Gelman Building, 2120 L Street, NW., Washington, DC 20555 and at the local public document room located at Pottstown Public Library, 500 High Street, Pottstown, Pennsylvania 19464.
If a request for a hearing or petition for leave to intervene is filed by the above date, the Commission or an Atomic Safety and Licensing Board, designated by the Commission or by the Chairman of the Atomic Safety and Licensing Board Panel, will rule on the request and/or petition; and the Secretary or the designated Atomic Safety and Licensing Board will issue a notice of hearing or an appropriate order.
As required by 10 CFR 2.714, a petition for leave to intervene shall set forth with particularity the interest of the petitioner in the proceeding, and how that interest may be affected by the results of the proceeding. The petition should specifically explain the reascas why intervention should be permitted with particular reference to the following factors:
(1) the nature of the petitioner's right under the Act to be made party to the proceeding; (2) the nature and extent of the petitioner's property, financial, or other interest in the proceeding; and (3) the possible effect of any order which may j
1 be entered in the proceeding on the petitioner's. interest. The petition should also identify the specific aspect (s) of the subject matter of the proceeding as to which petitioner wishes to intervene. Any person who has filed a petition for leave to intervene or who has been admitted as a party may amend the petition without requesting leave of the Board up to 15 days
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prior to the first prehearing conference scheduled in the proceeding, but such an amended petition must satisfy the specificity requirements described above.
Not later than 15 days prior to the first prehearing conference scheduled in the proceeding, a petitioner shall file a supplement to the petition to intervene which must include a list of the contentions which are sought to be litigated in the matter. Each contention must consist of a specific statement of the issue of law or fact to be raised or controverted.
In addition, the petitioner shall provide a brief explanation of the bases of the contention and a concise statement of the alleged facts or expert opinion which support the contention and on which the petitioner intends to rely in proving the contention at the hearing. The petitioner must also provide references to those specific sources and documents of which the petitioner is aware and on which the petitioner intends to rely to establish those facts or expert opinion.
Petitioner must provide sufficient information to show that a
'l genuine dispate exists with the applicant on a material issue of law or fact.
Contentions shall be limited to matters within the scope of the amendment under consideration. The contention must be one which, if proven, would i
entitle the petitioner to relief. A petitioner who fails to file such a i
supplement which satisfies these requirements with respect to at least one contention will not be permitted to participate as a party.
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Those permitted to intervene become parties to the proceeding, subject to any limitations in the order granting leave to intervene, and have the opportunity to participate fully in the conduct of the hearing, including the l-opportunity to present evidence and cross-examine witnesses.
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j If a hearing is requested, the Commission will make a final determination on the issue of no significant hazards consideration. The final determination will serve to decide when the hearing is held.
If the final determination is that the amendment request involves no significant hazards consideration, the Commission may issue the amendment and i
make it immediately effective, notwithstanding the request for a hearing. Any hearing held would take place after issuance of the amendment.
If the final determination is that the amendment request involves a significant hazards consideration, any hearing held would take place before the issuance of any amendment.
A request for a hearing or a petition for leave to intervene must be filed with the Secretary of the Commission, U.S. Nuclear Regulatory Commission, Washington, DC 20555, Attention: Docketing and Services Branch, or may be delivered to the Commission's Public Document Room, the Gelman i
Building, 2120 L Street, NW., Washington, DC 20555, by the above date. Where petitions are filed during the last 10 days of the notice period, it is requested that the petitioner promptly so inform the Commission by a toll-free telephone call to Western Union at 1-(800) 248-5100 (in Missouri 1-(800) 342-6700). The Western Union operator should be given Datagram Identification Number N1023 and tha following message addressed to Charles L. Miller:
petitioner's name and telephone number, date petition was mailed, plant name, and publication date and page number of this FEDERAL REGISTER notice. A copy of the petition should also be sent to the Office of the General Counsel, U.S.
Nuclear Regulatory Commission, Washington, DC 20555, and to J. W. Durham,
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Sr. V.P. and General Counsel, Philadelphia Electric Company, 2301 Market Street, Philadelphia, Pennsylvania 19101, attorney for the licensee.
Nontimely filings of petitions for leave to intervene, amended petitions, supplemental petitions and/or requests for hearing will not be entertained absent a determination by the Commission, the presiding officer or the i
presiding Atomic Safety and Licensing Board that the petition and/or request should be granted based upon a balancing of the factors specified in 10 CFR 2.714(a)(1)(i)-(v) and 2.714(d),
i The Commission hereby provides notice that this is a proceeding on an i
application for a license amendment falling within the scope of Section 134'of 1
the Nuclear Waste Policy Act of 1982 (NWPA), 42 U.S.C. 10154. Under Section
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134 of the NWPA, the Commission, at the request of any party to the proceeding, must use hybrid hearing procedures with respect to "any matter which the Commission determines to be in controversy among the parties." The hybrid procedures in Section 134 provide for oral argument on matters in controversy, preceded by discovery under the Commission's rules, and the designation, following argument, of only those factual issues that involve a genuine and substantial dispute, together with any remaining questions of law, to be resolved in an adjudicatory hearing. Actual adjudicatory hearings are to be held on only those issues found to meet the criteria of Section 134 and i
set for hearing after oral argument.
The Commission's rules implementing section 134 of the NWPA are found in_
10 CFR Part 2, Subpart K, " Hybrid Hearing Procedures for Expansion of Spent Nucl(ar Fuel Storage Capacity at Civilian Nuclear Power Reactors" (published
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at 50 FR 41662, October 15, 1985) to 10 CFR 2.1101 gt igg. Under those rules, i
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, any party to the proceeding may invoke the hybrid hearing procedures by filing with the presiding officer a written request for oral argument under 10 CFR 2.1109. To be timely, the request must be filed within 10 days of an order granting a request for hearing or petition to intervene.
(As outlined above, the Commission's rules in 10 CFR Part 2, Subpart G, and 2.714 in particular, continue to govern the filing of requests for a hearing or petitions to intervene, as well as the admission of contentions.) The presiding officer shall grant a timely request for oral argument. The presiding officer shall grant an untimely request for oral argument only upon showing of good cause by the requesting part for the failure to file on time and after providing the other parties an opportunity to respond to the untimely request.
If the presiding officer grants a request for oral argument, any hearing held on the application shall be conducted in accordance with hybrid hearing procedures.
In essence, those procedures limit the time available for discovery and require that an oral argument be held to determine whether any contentions must be resolved in adjudicatory hearing.
If no party to the proceedings requests oral argument, or if all untimely requests for oral argument are denied, then the usual procedures in 10 CFR Part 2, Subpart G, apply.
For further details with respect to this action, see the application for amendment dated January 14, 1994, which is available for public inspection at
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..- i the Commission's Public Document Room, the Gelman Building, 2120 L Street, NW., Washington, DC 20555 and at the local public document room located at Pottstown Public Library, 500 High Street, Pottstown, Pennsylvania 19464.
Dated at Rockville, Maryland, this 1st day of August 1994.
i FOR THE NUCLEAR REGULATORY COMMISSION y axe K l
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Frank Rinaldi, Project Manager Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation r
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