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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217D5211999-09-30030 September 1999 Informs That Remediating 3D Monicore Sys at Pbaps,Units 2 & 3 & 3D Monicore/Plant Monitoring Sys at Lgs,Unit 2 Has Been Completed Ahead of Schedule ML20216J3981999-09-29029 September 1999 Submits Comments for Lgs,Unit 1 & Pbaps,Units 2 & 3 Rvid,Rev 2,based on Review as Requested in GL 92-01,rev 1,suppl 1, Reactor Vessel Structural Integrity ML20212J6561999-09-29029 September 1999 Informs of Completion of mid-cycle PPR of Limerick Generating Station on 990913.Identified No Areas in Which Licensee Performance Warranted Addl Insp Beyond Core Insp Program.Historical Listing of Plant Issues Encl ML20212H6401999-09-24024 September 1999 Forwards Revised Epips,Including Rev 11 to ERP-101 & Rev 18 to ERP-800.Copy of Computer Generated Rept Index Identifying Latest Revs of LGS Erps,Encl ML20212E7941999-09-22022 September 1999 Requests Authorization for Listed Licensed Operators to Temporarily Suspend Participation in Licensed Operator Requalification Program at LGS ML20212E8081999-09-22022 September 1999 Provides Notification That Listed Operators Have Been Permanently Reassigned to Duties That Do Not Require Maintaining Licensed Operator Status,Per 10CFR50.74 ML20212F5481999-09-20020 September 1999 Forwards Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing, for Pbaps,Units 2 & 3 & Lgs,Units 1 & 2 ML20212F8991999-09-17017 September 1999 Provides Written Confirmation That Thermo-Lag 330-1 Fire Barrier Corrective Actions at Lgs,Units 1 & 2 Have Been Completed 05000353/LER-1999-010, Forwards LER 99-010-00,re Manual Actuation of Esf.Main CR Ventilation Sys Was Placed in Chlorine Isolation Mode Due to Rept of Faint Odor of Chlorine in Unit 2 Reactor Encl1999-09-16016 September 1999 Forwards LER 99-010-00,re Manual Actuation of Esf.Main CR Ventilation Sys Was Placed in Chlorine Isolation Mode Due to Rept of Faint Odor of Chlorine in Unit 2 Reactor Encl ML20216F7821999-09-16016 September 1999 Forwards Insp Repts 50-352/99-05 & 50-353/99-05 on 990713-0816.One Violation Noted & Being Treated as NCV, Consistent with App C of Enforcement Policy.Violation Re Inoperability of Automatic Depression Sys During Maint ML20212A8751999-09-13013 September 1999 Forwards Safety Evaluation of First & Second 10-year Interval Inservice Insp Plan Request for Relief ML20211N5061999-09-0909 September 1999 Forwards TSs Bases Pages B 3/4 10-2 & B 3/4 2-4 for LGS, Units 1 & 2,being Issued to Assure Distribution of Revised Bases Pages to All Holders of TSs ML20212A0091999-09-0909 September 1999 Provides Notification That Licenses SOP-11172 & SOP-11321, for SO Muntzenberger & Rh Wright,Respectively,Are No Longer Necessary as Result of Permanent Reassignment ML20211P8571999-09-0808 September 1999 Forwards Reactor Operator Retake Exams 50-352/99-303OL & 50-353/99-303OL Conducted on 990812 ML20211P3891999-09-0303 September 1999 Informs That During 990902 Telcon Between J Williams & B Tracy,Arrangements Were Made for NRC to Inspect Licensed Operator Requalification Program at Plant.Insp Planned for Wk of 991018 05000352/LER-1999-009, Forwards LER 99-009-00,providing 30-day Written follow-up Rept Re Performance of Maint That Affected Safeguard Sys for Which Compensatory Measures Had Not Been Employed1999-09-0101 September 1999 Forwards LER 99-009-00,providing 30-day Written follow-up Rept Re Performance of Maint That Affected Safeguard Sys for Which Compensatory Measures Had Not Been Employed ML20211H2571999-08-26026 August 1999 Informs of Individual Exam Result on Initial Retake Exam on 990812.One Individual Was Administered Exam & Passed ML20211E9191999-08-24024 August 1999 Forwards fitness-for-duty Program Performance Data for Jan-June 1999 for PBAPS & LGS IAW 10CFR26.71(d).Data Includes Listed Info ML20211E9731999-08-23023 August 1999 Forwards LGS Unit 2 Summary Rept for 970228 to 990525 Periodic ISI Rept Number 5, Per TS SRs 4.0.5 & 10CFR50.55a(g) ML20211D6761999-08-20020 August 1999 Forwards non-proprietary Revised Emergency Response Procedures (Erps),Including Rev 29 to ERP-110, Emergency Notification & Rev 17 to ERP-800, Maint Team & Proprietary App ERP-110-1.App Withheld Per 10CFR2.790(a)(6) ML20210T4271999-08-13013 August 1999 Informs That NRC Revised Info in Rvid & Releasing Rvid Version 2 as Result of Review of 980830 Responses to GL 92-01 Rev 1,GL 92-01 Rev 1 Suppl 1 & Suppl Rai.Tacs MA1197 & MA1198 Closed ML20210U2211999-08-10010 August 1999 Forwards Insp Repts 50-352/99-04 & 50-353/99-04 on 990525-0712.One Violation Occurred & Being Treated as NCV, Consistent with App C of Enforcement Policy.Violation Re Late Performance of off-gas Grab Sample Surveillance 05000353/LER-1999-005, Forwards LER 99-005-00,re Actuation of Primary Containment & Reactor Vessel Isolation Control Sys,Esf.Fuse Failed Due to Mechanical Failure of Cold Solder Joint1999-08-10010 August 1999 Forwards LER 99-005-00,re Actuation of Primary Containment & Reactor Vessel Isolation Control Sys,Esf.Fuse Failed Due to Mechanical Failure of Cold Solder Joint ML20211B7881999-08-10010 August 1999 Transmits Summary of Two Meetings with Risk-Informed TS Task Force in Rockville,Md on 990514 & 0714 ML20210M7571999-08-0404 August 1999 Forwards Response to Requesting Addl Info Re Status of Decommissioning Funding for Lgs,Pbaps & Sngs. Attachment Provides Restatement of Questions Followed by Response ML20210P4191999-08-0404 August 1999 Forwards Initial Exam Repts 50-352/99-302 & 50-353/99-302 on 990702-04 (Administration) & 990715-22 (Grading).Six of Limited SRO Applicants Passed All Portion of Exam NUREG-1092, Informs J Armstrong of Individual Exam Results for Applicants on Initial Exam Conducted on 990702 & 990712-14 at Facility.All Six Individuals Who Were Administered Exam, Passed Exam.Without Encls1999-08-0303 August 1999 Informs J Armstrong of Individual Exam Results for Applicants on Initial Exam Conducted on 990702 & 990712-14 at Facility.All Six Individuals Who Were Administered Exam, Passed Exam.Without Encls ML20210L2011999-07-28028 July 1999 Forwards Final Personal Qualification Statement (NRC Form 398) for Reactor Operator License Candidate LB Mchugh ML20211F2641999-07-27027 July 1999 Forwards Three Copies of Rev 12 to LGS Physical Security Plan, Rev 4 to LGS Training & Qualification Plan & Rev 2 to LGS Safeguards Contingency Plan. Without Encls 05000352/LER-1999-008, Forwards LER 99-008-00 Re 990623 Failure of Plant HPCI Sys to Start Due to Failure of HPCI Turbine,Hydraulic Actuator1999-07-23023 July 1999 Forwards LER 99-008-00 Re 990623 Failure of Plant HPCI Sys to Start Due to Failure of HPCI Turbine,Hydraulic Actuator 05000353/LER-1999-004, Forwards LER 99-004-00 Re 990701 Discovery of Pressure Setpoint Drift of Thirteen Mss SRV Due to Corrosion Induced Bonding within SRVs1999-07-23023 July 1999 Forwards LER 99-004-00 Re 990701 Discovery of Pressure Setpoint Drift of Thirteen Mss SRV Due to Corrosion Induced Bonding within SRVs ML20210E6211999-07-22022 July 1999 Submits Rev to non-limiting Licensing Basis LOCA Peak Clad Temps (Pcts) for Limerick Generating Station (Lgs),Units 1 & 2 & Pbaps,Units 2 & 3 ML20216D3081999-07-19019 July 1999 Requests Renewal of OLs for Listed Individuals,Iaw 10CFR55.57.NRC Forms 398 & 396,encl for Applicants.Without Encl ML20216D8041999-07-19019 July 1999 Submits Summary of Final PECO Nuclear Actions Taken to Resolve Scram Solenoid Pilot Valve Issues Identified in Info Notice 96-007 05000352/LER-1999-006, Forwards LER 99-006-00 Re 990614 Discovery That Grab Sample of Plant Offgas Sys Was Not Obtained within Time Limit Required by TS 3.3.7.12,Action 110 Due to Personnel Error1999-07-12012 July 1999 Forwards LER 99-006-00 Re 990614 Discovery That Grab Sample of Plant Offgas Sys Was Not Obtained within Time Limit Required by TS 3.3.7.12,Action 110 Due to Personnel Error ML20209F6341999-07-0909 July 1999 Submits Supplemental Response to GL 94-03, Intergranular Stress Corrosion Cracking of Core Shrouds in Bwrs, for Unit 2.Rev 0 to 1H61R & GE-NE-B13-02010-33NP Repts & Revised Pages to Summary Rept Previously Submitted,Encl ML20209G9121999-07-0909 July 1999 Informs That Ja Hutton Has Been Appointed Director,Licensing for PECO Nuclear,Effective 990715.Previous Correspondence Addressed to Gd Edwards Should Now Be Sent to Ja Hutton ML20209C9041999-07-0808 July 1999 Forwards Monthly Operating Repts for June 1999 for Limerick Generating Station,Units 1 & 2 & Revised Monthly Repts for May 1999 ML20210B4441999-07-0808 July 1999 Forwards Preliminary NRC Form 398 & NRC Form 396 for Reactor Operator for License Candidate LB Mchugh.Candidate Failed Category B Portion of Operating Exam Given at LGS During Week of 990315.Tentative re-exam Has Been Scheduled 990812 05000353/LER-1999-003, Forwards LER 99-003-00,re Bypass of RW Cleanup Leak Detection Sys Isolation Function on Three Separate Occasions.Bypass of Safety Function Was Caused by Inadequate Review & Approval of Change to Procedure1999-07-0707 July 1999 Forwards LER 99-003-00,re Bypass of RW Cleanup Leak Detection Sys Isolation Function on Three Separate Occasions.Bypass of Safety Function Was Caused by Inadequate Review & Approval of Change to Procedure ML20209D8821999-07-0707 July 1999 Submits Estimate of Number of Licensing Actions Expected to Be Submitted in Years 2000 & 2001,as Requested by Administrative Ltr 99-02.Renewal Applications for PBAPS, Units 2 & 3,will Be Submitted in Second Half of 2001 ML20209D2671999-07-0202 July 1999 Responds to NRC 990322 & 0420 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves ML20196J6301999-07-0101 July 1999 Requests Addl Info Re Status of Decommissioning Funding for Limerick Generating Station,Units 1 & 2,Peach Bottom Atomic Power Station,Units 1,2 & 3 & Salem Nuclear Generating Station,Units 1 & 2 05000352/LER-1999-004, Forwards LER 99-004-00,re Inoperability of Automatic Depressurization Sys Portion of Eccs.Condition Resulted from Incomplete Impact Review of Isolating Portion of ADS Nitrogen Backup Supply on Operability of ECCS Sys1999-07-0101 July 1999 Forwards LER 99-004-00,re Inoperability of Automatic Depressurization Sys Portion of Eccs.Condition Resulted from Incomplete Impact Review of Isolating Portion of ADS Nitrogen Backup Supply on Operability of ECCS Sys ML20209B7001999-06-30030 June 1999 Responds to GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants ML20212J5401999-06-28028 June 1999 Discusses Completion of Licensing Action for NRC Bulletin 96-003, Potential Plugging of ECC Suction Strainers by Debris in Bwrs. Bulletin Closed for Unit 2 by NRC ML20207H8271999-06-24024 June 1999 Informs NRC That Util Has Completed Core Shroud Insps for LGS Unit 2.Proprietary Rept GE-NE-B13-02010-33P & non-proprietary Rev 0 to 1H61R,encl.Proprietary Rept Withheld,Per 10CFR2.790(a)(4) ML20196G7041999-06-24024 June 1999 Forwards Insp Repts 50-352/99-03 & 50-353/99-03 on 990413- 0524.No Violations Noted.Nrc Concluded That Licensee Staff Continued to Operate Both Units Safely ML20196A5641999-06-15015 June 1999 Provides Info Re Util Use of Four Previously Irradiated LGS, Unit 1,GE11 Assemblies in Unit 2 Cycle 6.Encl 990518 GE Ltr Provides Objective of Lead Use Assemblies Program & Outlines Kinds of Measurements That Will Be Made on Assemblies ML20195J6831999-06-11011 June 1999 Provides Proprietary Objectives for Lgs,Units 1 & 2,1999 Emergency Preparedness Exercise Scheduled to Be Conducted on 990914.Licensee Identifies Which Individuals Should Receive Copies of Info.Proprietary Info Withheld 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217D5211999-09-30030 September 1999 Informs That Remediating 3D Monicore Sys at Pbaps,Units 2 & 3 & 3D Monicore/Plant Monitoring Sys at Lgs,Unit 2 Has Been Completed Ahead of Schedule ML20216J3981999-09-29029 September 1999 Submits Comments for Lgs,Unit 1 & Pbaps,Units 2 & 3 Rvid,Rev 2,based on Review as Requested in GL 92-01,rev 1,suppl 1, Reactor Vessel Structural Integrity ML20212H6401999-09-24024 September 1999 Forwards Revised Epips,Including Rev 11 to ERP-101 & Rev 18 to ERP-800.Copy of Computer Generated Rept Index Identifying Latest Revs of LGS Erps,Encl ML20212E7941999-09-22022 September 1999 Requests Authorization for Listed Licensed Operators to Temporarily Suspend Participation in Licensed Operator Requalification Program at LGS ML20212E8081999-09-22022 September 1999 Provides Notification That Listed Operators Have Been Permanently Reassigned to Duties That Do Not Require Maintaining Licensed Operator Status,Per 10CFR50.74 ML20212F5481999-09-20020 September 1999 Forwards Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing, for Pbaps,Units 2 & 3 & Lgs,Units 1 & 2 ML20212F8991999-09-17017 September 1999 Provides Written Confirmation That Thermo-Lag 330-1 Fire Barrier Corrective Actions at Lgs,Units 1 & 2 Have Been Completed 05000353/LER-1999-010, Forwards LER 99-010-00,re Manual Actuation of Esf.Main CR Ventilation Sys Was Placed in Chlorine Isolation Mode Due to Rept of Faint Odor of Chlorine in Unit 2 Reactor Encl1999-09-16016 September 1999 Forwards LER 99-010-00,re Manual Actuation of Esf.Main CR Ventilation Sys Was Placed in Chlorine Isolation Mode Due to Rept of Faint Odor of Chlorine in Unit 2 Reactor Encl ML20212A0091999-09-0909 September 1999 Provides Notification That Licenses SOP-11172 & SOP-11321, for SO Muntzenberger & Rh Wright,Respectively,Are No Longer Necessary as Result of Permanent Reassignment 05000352/LER-1999-009, Forwards LER 99-009-00,providing 30-day Written follow-up Rept Re Performance of Maint That Affected Safeguard Sys for Which Compensatory Measures Had Not Been Employed1999-09-0101 September 1999 Forwards LER 99-009-00,providing 30-day Written follow-up Rept Re Performance of Maint That Affected Safeguard Sys for Which Compensatory Measures Had Not Been Employed ML20211E9191999-08-24024 August 1999 Forwards fitness-for-duty Program Performance Data for Jan-June 1999 for PBAPS & LGS IAW 10CFR26.71(d).Data Includes Listed Info ML20211E9731999-08-23023 August 1999 Forwards LGS Unit 2 Summary Rept for 970228 to 990525 Periodic ISI Rept Number 5, Per TS SRs 4.0.5 & 10CFR50.55a(g) ML20211D6761999-08-20020 August 1999 Forwards non-proprietary Revised Emergency Response Procedures (Erps),Including Rev 29 to ERP-110, Emergency Notification & Rev 17 to ERP-800, Maint Team & Proprietary App ERP-110-1.App Withheld Per 10CFR2.790(a)(6) 05000353/LER-1999-005, Forwards LER 99-005-00,re Actuation of Primary Containment & Reactor Vessel Isolation Control Sys,Esf.Fuse Failed Due to Mechanical Failure of Cold Solder Joint1999-08-10010 August 1999 Forwards LER 99-005-00,re Actuation of Primary Containment & Reactor Vessel Isolation Control Sys,Esf.Fuse Failed Due to Mechanical Failure of Cold Solder Joint ML20210M7571999-08-0404 August 1999 Forwards Response to Requesting Addl Info Re Status of Decommissioning Funding for Lgs,Pbaps & Sngs. Attachment Provides Restatement of Questions Followed by Response ML20210L2011999-07-28028 July 1999 Forwards Final Personal Qualification Statement (NRC Form 398) for Reactor Operator License Candidate LB Mchugh ML20211F2641999-07-27027 July 1999 Forwards Three Copies of Rev 12 to LGS Physical Security Plan, Rev 4 to LGS Training & Qualification Plan & Rev 2 to LGS Safeguards Contingency Plan. Without Encls 05000352/LER-1999-008, Forwards LER 99-008-00 Re 990623 Failure of Plant HPCI Sys to Start Due to Failure of HPCI Turbine,Hydraulic Actuator1999-07-23023 July 1999 Forwards LER 99-008-00 Re 990623 Failure of Plant HPCI Sys to Start Due to Failure of HPCI Turbine,Hydraulic Actuator 05000353/LER-1999-004, Forwards LER 99-004-00 Re 990701 Discovery of Pressure Setpoint Drift of Thirteen Mss SRV Due to Corrosion Induced Bonding within SRVs1999-07-23023 July 1999 Forwards LER 99-004-00 Re 990701 Discovery of Pressure Setpoint Drift of Thirteen Mss SRV Due to Corrosion Induced Bonding within SRVs ML20210E6211999-07-22022 July 1999 Submits Rev to non-limiting Licensing Basis LOCA Peak Clad Temps (Pcts) for Limerick Generating Station (Lgs),Units 1 & 2 & Pbaps,Units 2 & 3 ML20216D3081999-07-19019 July 1999 Requests Renewal of OLs for Listed Individuals,Iaw 10CFR55.57.NRC Forms 398 & 396,encl for Applicants.Without Encl ML20216D8041999-07-19019 July 1999 Submits Summary of Final PECO Nuclear Actions Taken to Resolve Scram Solenoid Pilot Valve Issues Identified in Info Notice 96-007 05000352/LER-1999-006, Forwards LER 99-006-00 Re 990614 Discovery That Grab Sample of Plant Offgas Sys Was Not Obtained within Time Limit Required by TS 3.3.7.12,Action 110 Due to Personnel Error1999-07-12012 July 1999 Forwards LER 99-006-00 Re 990614 Discovery That Grab Sample of Plant Offgas Sys Was Not Obtained within Time Limit Required by TS 3.3.7.12,Action 110 Due to Personnel Error ML20209F6341999-07-0909 July 1999 Submits Supplemental Response to GL 94-03, Intergranular Stress Corrosion Cracking of Core Shrouds in Bwrs, for Unit 2.Rev 0 to 1H61R & GE-NE-B13-02010-33NP Repts & Revised Pages to Summary Rept Previously Submitted,Encl ML20209G9121999-07-0909 July 1999 Informs That Ja Hutton Has Been Appointed Director,Licensing for PECO Nuclear,Effective 990715.Previous Correspondence Addressed to Gd Edwards Should Now Be Sent to Ja Hutton ML20210B4441999-07-0808 July 1999 Forwards Preliminary NRC Form 398 & NRC Form 396 for Reactor Operator for License Candidate LB Mchugh.Candidate Failed Category B Portion of Operating Exam Given at LGS During Week of 990315.Tentative re-exam Has Been Scheduled 990812 ML20209C9041999-07-0808 July 1999 Forwards Monthly Operating Repts for June 1999 for Limerick Generating Station,Units 1 & 2 & Revised Monthly Repts for May 1999 05000353/LER-1999-003, Forwards LER 99-003-00,re Bypass of RW Cleanup Leak Detection Sys Isolation Function on Three Separate Occasions.Bypass of Safety Function Was Caused by Inadequate Review & Approval of Change to Procedure1999-07-0707 July 1999 Forwards LER 99-003-00,re Bypass of RW Cleanup Leak Detection Sys Isolation Function on Three Separate Occasions.Bypass of Safety Function Was Caused by Inadequate Review & Approval of Change to Procedure ML20209D8821999-07-0707 July 1999 Submits Estimate of Number of Licensing Actions Expected to Be Submitted in Years 2000 & 2001,as Requested by Administrative Ltr 99-02.Renewal Applications for PBAPS, Units 2 & 3,will Be Submitted in Second Half of 2001 ML20209D2671999-07-0202 July 1999 Responds to NRC 990322 & 0420 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves 05000352/LER-1999-004, Forwards LER 99-004-00,re Inoperability of Automatic Depressurization Sys Portion of Eccs.Condition Resulted from Incomplete Impact Review of Isolating Portion of ADS Nitrogen Backup Supply on Operability of ECCS Sys1999-07-0101 July 1999 Forwards LER 99-004-00,re Inoperability of Automatic Depressurization Sys Portion of Eccs.Condition Resulted from Incomplete Impact Review of Isolating Portion of ADS Nitrogen Backup Supply on Operability of ECCS Sys ML20209B7001999-06-30030 June 1999 Responds to GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants ML20207H8271999-06-24024 June 1999 Informs NRC That Util Has Completed Core Shroud Insps for LGS Unit 2.Proprietary Rept GE-NE-B13-02010-33P & non-proprietary Rev 0 to 1H61R,encl.Proprietary Rept Withheld,Per 10CFR2.790(a)(4) ML20196A5641999-06-15015 June 1999 Provides Info Re Util Use of Four Previously Irradiated LGS, Unit 1,GE11 Assemblies in Unit 2 Cycle 6.Encl 990518 GE Ltr Provides Objective of Lead Use Assemblies Program & Outlines Kinds of Measurements That Will Be Made on Assemblies ML20195J6831999-06-11011 June 1999 Provides Proprietary Objectives for Lgs,Units 1 & 2,1999 Emergency Preparedness Exercise Scheduled to Be Conducted on 990914.Licensee Identifies Which Individuals Should Receive Copies of Info.Proprietary Info Withheld ML20195G4591999-06-10010 June 1999 Forwards MORs for May 1999 & Revised Repts for Apr 1999 for LGS Units 1 & 2 ML20195H0531999-06-0909 June 1999 Forwards Revised Bases Pages B3/4 10-2 & B3/4 2-4 for LGS Units 1 & 2,in Order to Clarify That Requirements for Reactor Enclosure Secondary Containment Apply to Extended Area Encompassing Both Reactor Enclosure & Refueling Area ML20195E7701999-06-0707 June 1999 Provides Notification of Change to NPDES Permit PA0052221, for Bradshaw Reservoir Facility Which Supports Operation of Lgs,Units 1 & 2,per EPP Section 3.2 ML20195C7631999-06-0101 June 1999 Notifies NRC That PECO Energy Has Completed Installation of New Large Capacity,Passive Strainers on RHR & Core Spray Sys Pump Suction Lines at Lgs,Unit 2,in Response to Ieb 96-003 ML20195D5381999-05-26026 May 1999 Forwards 1998 Occupational Exposure Tabulation Rept for LGS Units 1 & 2. Encl Is Diskette & Instructions.Rept Is Being re-submitted to Reset 12 Month Time Period.Without Disk ML20195B2821999-05-24024 May 1999 Requests That NRC Distribution Lists for LGS Be Updated. Marked-up Distribution List Showing Changes Is Attached ML20196L2891999-05-20020 May 1999 Provides Status Update of Thermo-Lag 330-1 Fire Barrier Corrective Actions,Iaw Commitments Made in ML20195B2951999-05-20020 May 1999 Forwards Rev 0 to LGS Unit 2 Reload 5,Cycle 6 COLR, IAW TS Section 6.9.1.12.Values Listed Have Been Determined Using NRC-approved Methodology & Are Established Such That All Applicable Limits of Plants Safety Analysis Are Met 05000352/LER-1999-003, Forwards LER 99-003-00,re Rps,Pcrvics Actuations.Ler Contains Special Rept Info for HPCI & Reactor Core Isolation Cooling Sys Injections Into Rv1999-05-19019 May 1999 Forwards LER 99-003-00,re Rps,Pcrvics Actuations.Ler Contains Special Rept Info for HPCI & Reactor Core Isolation Cooling Sys Injections Into Rv 05000353/LER-1999-002, Forwards LER 99-002-00,automatic Actuations of Primary Containment & Reactor Vessel Isolation Control Sys & Other Common Plant ESF Due to Loss of Power to a Rps/Ups Power Distribution Panel on 9904191999-05-18018 May 1999 Forwards LER 99-002-00,automatic Actuations of Primary Containment & Reactor Vessel Isolation Control Sys & Other Common Plant ESF Due to Loss of Power to a Rps/Ups Power Distribution Panel on 990419 ML20206E2001999-04-28028 April 1999 Forwards 1998 Annual Environ Operating Rept (Non- Radiological) for Limerick Generating Station,Units 1 & 2. Rept Submitted IAW Section 5.4.1 of App B of Fols,Epp (Non- Radiological) & Describes Implementation of EPP for 1998 ML20206D8801999-04-27027 April 1999 Forwards Rev 2 to LGS Unit 1 Reload 7,Cycle 8 COLR, IAW TS Section 6.9.1.12.COLR Provides cycle-specific Parameter Limits for Noted Info ML20206A5461999-04-21021 April 1999 Responds to Conference Call Between Util & NRC on 990420,re TS Change Request 98-07-2,revising TS Section 2.0 to Incorporate Revised MCPR Safety Limits.Attached Ltr Contains Info Requested ML20205T0441999-04-17017 April 1999 Forwards 1998 Annual Radiological Environ Operating Rept 15, IAW TS Section 6.9.1.7.REMP for 1998,confirmed That LGS Environ Effects from Radioactive Release Were Well Below LGS TSs & Other Applicable Regulatory Limits ML20205Q7581999-04-15015 April 1999 Forwards Response to RAI Re ISI Program First & Second 10-Yr Interval Relief Requests.Revs to Identified by Vertical Bar in Right Margin 1999-09-09
[Table view] Category:LEGAL/LAW FIRM TO NRC
MONTHYEARML20235T8911989-01-18018 January 1989 Forwards Endorsements 130 & 131 to Nelia Policy NF-164, Endorsements 107 & 108 to Maelu Policy MF-44,Endorsements 94 & 95 to Nelia Policy NF-107,Endorsements 110 & 111 to Nelia Policy NF-220 & Endorsements 97 & 98 to Maelu Policy MF-73 ML20196L5401988-07-0505 July 1988 Confirms 880705 Telcon Re Updated Antitrust Review for Facility.Nrc Agrees That Company Has Until 880815 to Respond to Request ML20235B2741987-02-19019 February 1987 FOIA Request for Documents Indicated on Encl Docket Sheets. Request Does Not Encompass Matl Already Available in PDR or Lpdr Denoted by Three or Four Asterisks on List ML20209G1461986-09-0909 September 1986 Requests Issuance of Subpoena for Rt Brown to Testify at Hearing Re Adequacy of Communications Sys Used to Mobilize Manpower Necessary to Evacuate State Correctional Institute in Graterford,Pa ML20214M6501986-09-0909 September 1986 Advises That Licensee Will Not Respond to Air & Water Pollution Patrol 860826 Response to Testimony Re Remand Hearing on Bus Drivers for Oj Roberts & Spring-Ford School Districts,Per Clements .Related Correspondence ML20214M6961986-09-0808 September 1986 Recommends Denial of Rl Anthony 860821 & 25 Petitions for Relief Per 10CFR50.100 & for Ofc of General Counsel Review of NRC 10CFR2.206 Decisions ML20205C4711986-08-0808 August 1986 Forwards 860808 Testimony of Vs Boyer & R Bradshaw Re Remand Hearing on Availability of Bus Drivers for Oj Roberts & Spring-Ford School Districts.Related Correspondence ML20212A7241986-07-24024 July 1986 Notifies That Testimony Presented at 860818 Hearing Will Reflect Revised Number of Volunteer Bus Drivers in Event School Evacuation Necessary ML20211Q1601986-07-21021 July 1986 Advises of Attempts to Deliver Volunteer Sheets of 570 Util Employees Agreeing to Drive Buses in Event of School Evacuation to Limerick Ecology Action (Lea) Headquarters. Related Correspondence ML20206P7421986-06-27027 June 1986 Forwards & Revised Proposed Stipulation in Response to PEMA Request for Changes to Stipulation Re Remanded Issue.Certificate of Svc Encl.Related Correspondence ML20206P9031986-06-26026 June 1986 Corrects Proposing Resolution of Remanded Issue Re Availability of School Bus Drivers for Oj Roberts & Spring-Ford School Districts.Correct Date of Stipulation Re Medical Svcs Is 860616 Instead of 851115 ML20206P7801986-06-25025 June 1986 Responds to AR Love,Counsel for Graterford Inmates,860618 Ltr Accusing Author of Providing ASLB Chairman H Hoyt W/ Trade Publications Re Emergency Planning Requirements. Attempt to Influence Chairman Denied ML20199E5131986-06-19019 June 1986 Forwards Affidavits of AL Bigelow & Vs Boyer Re Availability of Volunteer School Bus Drivers for Oj Roberts & Spring-Ford School Districts in Event of Evacuation,Per ML20199E6881986-06-18018 June 1986 Responds to Re Ex Parte Filing of Offsite Emergency Planning for Nuclear Power Plants:Case of Govt Gridlock. Ex Parte Filings by Rader Seen as Contributing to Lack of Impartiality.Related Correspondence ML20206D7631986-06-16016 June 1986 Forwards Licensee Proposal for Resolution of Remanded Issue Re Availability of School Bus Drivers for Oj Roberts & Spring-Ford School Districts,Per ASLB 860522 Order, Supporting Affidavits & Proposed Stipulation ML20211E7421986-06-11011 June 1986 Forwards Graterford Inmates Response to Aslab 860603 Order. W/O Encl.Related Correspondence ML20198E3721986-05-19019 May 1986 Advises That Excess Flow Check Valves,Described in Dec 1985 License Amend Application Can Be Tested During Plant Operation Using Addl Personnel & Special Procedures.Need for Amend Unaffected.Certificate of Svc Encl ML20197G7961986-05-13013 May 1986 Forwards,For Info,Delaware River Basin in Commission 860427 Revs 5 & 6 to Docket D-69-210 CP Re Dissolved Oxygen Limitations for Temp Constraints & Consumptive Use Allocations.Related Correspondence ML20203P9401986-05-0505 May 1986 Informs That Unit 1 Shut Down on 860502 for Approx 6 Wks During Which All Tests on Excess Flow Check Valves & Other Containment Isolation Valves Will Be Performed.Related Correspondence ML20203E4851986-03-12012 March 1986 FOIA Request for Effluent Rept 3 Submitted Under Encl Ltr. W/O Ltr ML20154L1531986-03-0606 March 1986 Forwards Appeal Board 850805 & Board 831115 Orders & Util to Nrc,Cited in 860219 Answer to Anthony late-filed Petition for Leave to Intervene,Per 860305 Request ML20140D9111986-01-28028 January 1986 Requests Denial of Rl Anthony 860117 Request for Suspension of License & Finding That Util Violated Conditions of License NPF-39 Due to Pending Application for Supplemental Cooling Water Supply ML20154B9491986-01-24024 January 1986 Forwards 851216 Application for Approval of Temporary Substitution of in-stream Monitoring of Dissolved Oxygen Levels in Place of 59 F Constraint on Withdrawals,Filed W/ State of DE River Basin Commission.Related Correspondence ML20138R4571985-12-24024 December 1985 Forwards Procedure M1-18, Decontamination & Treatment of Radioactively Contaminated Patient at Montgomery Hosp. Related Correspondence ML20138R4701985-12-24024 December 1985 Forwards Procedure M1-18, Decontamination & Treatment of Radioactively Contaminated Patient at Montgomery Hosp. Related Correspondence ML20137T2381985-12-16016 December 1985 Advises That 851213 Encl Figures May Be Illegible.Figures Taken Directly from Fsar.W/O Encl.Related Correspondence ML20137U1981985-12-0505 December 1985 Submits Correction to Transcript of Author 851204 Oral Argument on Fourth Partial Initial Decision.Substantive Changes on Pages 47 to 70 Should Be Made ML20136J1971985-11-20020 November 1985 Notifies That Author Will Appear to Present Oral Argument on 851204 on Behalf of Util Re Appeals of Fourth Partial Initial Decision,In Response to 851024 & 1106 Orders.Related Correspondence ML20133L7261985-10-22022 October 1985 Forwards Commonwealth of PA Court Decision Finding Bucks County & Neshaminy Water Resources Authority Obligated to Complete Point Pleasant Project.Related Correspondence ML20133J0491985-10-16016 October 1985 Lists Misspellings & Errors in Transcript of Author 851011 Oral Argument Before Aslab Re Third Partial Initial Decision ML20136C8271985-10-0404 October 1985 Forwards Delaware River Basin Commission 851002 Emergency Certification Granting Application for Use of Schuylkill River Whenever Flow at Pottstown Gage Over 415 Cubic Ft/ Second.Related Correspondence ML20133B0821985-09-30030 September 1985 Informs of Appearance to Present Oral Argument on 851011 Re Appeals of Third Partial Initial Decision in Proceeding,Per 850829 Order.Related Correspondence ML20136A8171985-09-23023 September 1985 Forwards Util Application W/Delaware River Basin Commission for Approval of Withdrawal of Water from Schuylkill River for Consumptive Use & Revised Application Permitting Release from Beachwood Pit.Related Correspondence ML20137Q4971985-09-18018 September 1985 Responds to Mi Lewis Request to Lift or Retract Cp.Petition for Relief Under Section 2.206 Should Be Denied.Puc of PA Recommended Decision Only Basis for Petition ML20137P9411985-09-17017 September 1985 Comments on ALAB-813,including Issuance of Final Findings Not Prerequisite to Authorizing Full Power OL & Error in Curtailing cross-exam Insufficient to Warrant Appellate Relief.Related Correspondence ML20137L4591985-09-0909 September 1985 Advises That Author,Atty for Graterford Inmates,Will Be Unavailable Until 851001.Related Correspondence ML20136A9731985-09-0404 September 1985 Forwards 850813 Notice of Commission Action Approving Application to Delaware River Basin Commission for Approval of Use of Consumptive Water Saved by Curtailment of Listed Plants,Per .Related Correspondence ML20133L8931985-08-0808 August 1985 Forwards Notice of Appeal Re Denial of Stay & Accompanying Memorandum of Law.W/O Encl.Related Correspondence ML20132E3341985-07-30030 July 1985 Informs That Applicant Will Not Respond to Air & Water Pollution Patrol Brief Until 30 Days After Svc of Appeal Brief to Be Filed by Graterford Inmates,Per 850725 Notice of Appeal,Unless Otherwise Directed by Appeal Board ML20126K7831985-07-26026 July 1985 Forwards Comments of Intervenor Graterford Prisoners,Per 850723 Order.W/O Encl.Related Correspondence ML20126L0031985-07-25025 July 1985 Forwards Graterford Inmates Notice of Appeal.W/O Encl. Related Correspondence ML20129C3171985-07-25025 July 1985 Advises That Delaware River Basin Commission Withholding Action on Addl Supplemental Water for Unit 1 Until NRC Authorizes Issuance of Full Power Ol.Requests Action on Full Power License as Soon as Possible ML20137S4861985-07-17017 July 1985 Forwards Util 850603 Application Under Section 3.8 of Delaware River Basin Compact for Use of Water from Beechwood Pit.Related Correspondence ML20128H1591985-07-0303 July 1985 Forwards Testimony of Jd Case.Related Correspondence ML20128F4121985-07-0303 July 1985 Advises of Return of Subpoena to Rl Morris Signed by ASLB on 850628.Morris Gave Deposition Voluntarily at Ofc on 850703 as Result of Arrangements Among Counsel Rather than at Time & Place Listed in Subpoena.Related Correspondence ML20128A2831985-06-28028 June 1985 Requests That ASLB Issue Subpoena Directing Rl Morris to Appear on 850702 in Philadelphia,Pa for Deposition.Rl Morris,Principal Witness Identified by Love on Contention Re Evacuation Time for Graterford.Related Correspondence ML20127L8131985-06-20020 June 1985 Forwards Revised Page 11 to Correct Typo in Applicant Renewed Motion for Exemption from 10CFR50.47(a) Requirements Per Two Contentions Admitted on Behalf of Graterford Prisoners During Litigation Period ML20126J8711985-06-10010 June 1985 Forwards Notice of Delaware River Basin Commission Action Re Temporary Mod to Increase Frequency of Water Withdrawn from Schuylkill River.Some Copies May Have Been Incorrectly Reproduced.Related Correspondence ML20126J7801985-06-0606 June 1985 Forwards 850603 Notice of Commission Action Re Temporary Mod of Delaware River Basin Decision for Facility,As Followup to .Related Correspondence ML20129A6121985-06-0303 June 1985 Forwards,For Info,Application Filed W/Delaware River Basin Commission for Approval for Use During 1985 of Consumptive Use Water Allocations of Titus Units 1,2 & 3 & Cromby Unit 2.Related Correspondence 1989-01-18
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Text
. LAW OFFICES CONNER & WETTERII AIIN, P.C.
17 4 7 P EN N SYINAN I A AV EN U E. N. W.
. T'EY B. CO N N E R. J R. WASIt!NOTON D. C. 20000
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$Esw.^="CIOE=""" January 15, 1985 A'lC H A. M OO R R. J R.* fJO21833-3500 CABLE ADDRESS. ATOMLAW g ,
- mat anaesttso BW D. C Mr. Harold R. Denton Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washir.gton, D.C. 20555 In the Matter of Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2)
Docket Nos. 50-352 and 50-353 :
Dear Mr. Denton:
In response to the letter to you from Robert J.
Sugarman, Esq. on behalf of Del-Aware Unlimited, Inc., dated November 21, 1984, which requests relief pursuant to 10 C.F.R. 52.206 and " Request for Action Under 10 C.F.R. S2.206 Regarding Supplemental Cooling Water for the Limerick Facility," 50 Fed. Reg. , I am hereby submitting
" Comments of Philadelphia Electric Company on Del-Aware's Request Under 10 C.F.R. 52.206." For the reasons stated more fully therein, the matters raised by Del-Aware are merely repetitious of previous requests for relief denied by the Director and in any event inappropriate under Section 2.206. Further, the matters discussed by Del-Aware fail to raise any significant environmental concern which warrants relief. Accordingly, the relief requested by Del-Aware should be denied.
Sincerely, b
Troy B. Conner, Jr.
cc: Eugene J. Bradley, Esq.
Robert J. Sugarman, Esq.
kh0 p P ;
i~
P COMMENTS OF PHILADELPHIA ELECTRIC COMPANY ON -
DEL-AWARE'S REQUEST UNDER 10 C.F.R. Section 2.206 By letter dated November 21, 1984, Del-Aware Unlimited, Inc. (" Del-Aware") submitted "a renewed and amended and
- updated petition ~ under Section 2.206." The sole basis for the request is ' a - letter from J'.F. Paquette, Jr. , . Vice
' President Finance and Accounting, Philadelphia- Electric Company, to Jerry Rich, Secretary, Pennsylvania Public Utility Commission, dated October 30, 1984. That letter in pertinent part states:
Low Power Licensing of Unit #1 occasioned a new review of the remaining steps to achieve commercial operation.
As a . result we now estimate that the earliest date for commercial operation of Limerick Unit il will be during the Third Quarter of 1985, if an interim supply of supplemental cooling water _is available by May 1985. This represents a revision of two to five ' months from the previous . estimate - of the earliest commercial. operation date- and .will result in'an increase in the total cost- !
of Limerick Unit #1 of'approximatelyl$30 million per' month.
' Del-Aware ' interprets this as a decision by PECO to utilize an identified interim source of supplemental cooling water for the Limerick Generating Station. Petitioner requests the Commission Staff to " require.that PECO-provide to the Commission a full disclosure of'its intended sources,
~
and the' environmental consequences thereof, prior to issuing the full commercial . license." The- relief requested by Del-Aware is essentially the same.as previously requested by
-_.____--..n.
- - . - _ _ _ _ - _ . . _ . . - - _ _ .a
Del-Aware before the Director and before the adjudicatory boards of the Commission. Del-Aware presents absolutely nothing new which would require the institution of a pro-ceeding pursuant to 10 C.F.R. Section 2.206.
There is no need to redocument the history of the NRC's
-consideration of supplemental cooling water supplies for the Limerick . Generating Station. In both the Director's De-cisions and numerous decisions by the presiding Atomic Safety and Licensing Board and Appeal Board, the background and current status of this matter have been discussed.1! In particular, both the Director and the adjudicatory boards have. discussed the actions that PECO as the Applicant in the proceeding must take should it change its plans and modify its _ pending -proposal to rely on a source of supplementary cooling -water other than the Delaware River via the river follower method. There is absolutely no reason to institute a proceeding in order to inform the Company that it must inform the NRC that it has selected a source of supplemental water, interim or otherwise, other than described in the application.
" In accordance with the Commission's . regulations under 10 C.F.R. Section 1.101, 'it ' is the responsibility of the
~
1/ See [ Cite] ALAB-785, 20 NRC 848 (1984), aff'q in pertinent part, LBP-83-11, 17 NRC 413 (1983);
LBP-74-44, 7 AEC.1098 (1974) , . af f'd in pertinent part, ALAB-262, 1 NRC 163 (1975); DD-84-13, 19 NRC 1137
( 19 '3 4 ) .
applicant for a license to prepare and submit its applica-tion as prescribed by the applicable rules and regulations.
Nowhere in Section 2.201 or elsewhere in the regulations is the NRC authorized to require an applicant to utilize one particular source of supplemental cooling water as opposed to another.
The Director has previously addressed the possibility that an alternative to the Point Pleasant diversion might be required. In its April 25, 1984 Decision, the Director rejected Del-Aware's claim that actions by Bucks County seeking to terminate the project require immediate consid-eration of another alternative. The Director stated:
The information provided by Petitioners indicates no lessening of the resolve of PECO to go forward with the Point Pleasant Diversion Project.
Indeed, PECO has availed itself of its legal remedies to ensure that the PPD Project will go forward as currently configured. Should the Point Pleasant Diversion Project ultimately fail, and should PECO then identify an alternative proposal to supply supplemental cooling water to the Limerick Facility, action by the NRC would then be appropriate.
Such an alternative would have to be reviewed in the same fashion as the Point Pleasant Diversion Project was examined by this agency prior to issuance of a construction permit.
However, far from proposing an alternative to the Point Pleasant Diversion Project, PECO's current actions appear clearly directed at ensuring that the PPD Project goes forward. Concerns that the Point Pleasant Diversion Project may not be completed and, consequently, that alternative sources of cooling water may be required for the Limerick Facility are premature and speculative at this
time. I decline to commit this agency's resources to examine such questions, given their speculative nature, at this time.2_/
More recently, the Director restated the Staff's position in response to Del-Aware's letter of May 23, 1984.
b bte nOdiEcs "E to Ne Eoknt Plea" sank VNob NMbs problematical:
In my Decision, I determined that action on the part of NRC would be appropriate to review alternatives to the currently proposed supplemental cooling water system if the current proposal should for some reason fail and if PECO should then identify an alternative proposal to supply supplemental cooling water for the Limerick facility. I noted that any alternative would then have to be reviewed in the same fashion as the original proposal was examined by the agency prior to the issuance of a construction permit. In my Decision, I further noted that PECO's current actions appear clearly directed at insuring completion of the presently proposed supplemental cooling water system and that concerns that the project may not be complete and consequently that alternative sources of cooling water may be required for the Limerick facility are thus premature and speculative. On this basis, I declined to commit the agency's resources to examine such questions given their speculative nature. There is nothing in your letter which would cause me to reconsider this question.3/
2_/ DD-84-13, 19 NRC at 1141.
3/ Letter from Harold R. Centon, Director, Office of Nuclear Reactor Regulation to Robert J. Sugarman, Esq.
at 1-2 (June 29, 1984) (footnote omitted).
M
r
.4
- In its September 10, 1984 letter to Mr. Sugarman, counsel for Del-Aware, the Director again declined to institute a proceeding to consider alternatives to'the Point Pleasant project. In this regard, the Director stated:
The basic licensing function of the I commission is to review project pro-posals submitted by an applicant. I
-have noted this in earlier correspon-dence. 'In this matter, the Point Pleasant Diversion Project was submitted for review by PECo at both the con-struction permit and operating license stage of the proceeding. To the extent a submitted proposal is no longer viable, an applicant may submit an alternative for the Commission's consid-eration. In this context, the actions you request are inappropriate.
The Licensing Board has similarly rejected contentions relating to alternatives to Point Pleasant for the same reasons discussed by the Staff as quoted above. In the interest of brevity, we direct your attention to the dis-cussion of the Licensing Board's action in " Comments of Philadelphia Electric Company on Del-Aware's Request Under 10 C.F.R. 2.206," (page! transmitted by letter dated Decem-ber 29, 1983 at 9, and " Comments of Philadelphia Electric Company on Del-Aware's Request Under'2.206," transmitted by letter dated August 21, 1984 at 9.
In Philadelphia Electric Company (Limerick - Generating Station,. Units 1 and 2) , ALAB-785, 20 NRC 848, 884 (1984),
the Atomic Safety and Licensing Appeal Board rejected the same argument Del-Aware advances here, i.e., that 1
alternatives to the river follower method must be examined.
The Board held:
What Del-Aware is secking, in fact, is an ' order directing PECo to- abandon Unit 2 and to rely on a ' source of supplementary cooling water for the remaining Unit 1-other than the Delaware River via the river-follower method.
But we have no legal basis here for making such an order. There is no question that PECo has some formidable obstacles to surmount if it is to operate both Limerick Units 1 and 2 in the manner currently proposed. Whether PECo will change its plans to effect an easier resolution of the problems confronting it is a matter for PECo's management, and possibly its sharehold-ers, to decide. But the fact is we now have before us PECo's application for a license to operate two units, using the river-follower . method to supplement the plant's cooling water system. We have previously approved the river-follower method in ALAB-262, supra. The purpose of this proceeding, in that regard, is consideration of the impacts of any subsequent changes relating to that supplementary cooling system. Except the two matters that we have determined should have been, but were not, litigat-ed,* we agree'with the Licensing Board's conclusion that the impacts- of the subsequent _ changes are not significant.
In the absence of a finding to the-contrary, we. are without the. legal predicate to ' dictate to PECo that it must pursue other options.**
- Viz . , . Del-Aware's contentions- on salinity and the impacts on the Point . Pleasant Historic District.
See pp. 866-70, 874-76, supra.
- Of. course, if PECo does change'its-plans and modify its pending application accordingly,. _ it is obliged to- notify ns and the parties promptly. . Tennessee Valley
- Authority (Browns Ferry Nuclear Plant, Units 1, 2 and 3) , ALAB-677,
'~
15 NRC 1387, 1391-94 (1982). And, as the Licensing Board correctly.- 7 obcerved, in such circumstance the Commission "would have.to reconsid-er its. previous assessment of environmental impacts in light, of
-changes proposed by PECo." _Licens-
- ing Board Memorandum ;and Order of .
e June 1, 1983 (unpublished), at 9
, n.3. The parties would also have o to be afforded an opportunity to challenge any newly amended, .
significant portion of the applica- -
tion. See Philadelphia Electric Co. (Limerick - Generating Station,
. Units 1 and _ 2) , ALAB-778, 20 NRC 42, 48 (1984).
t it Thus, the Appeal Board placed the obligation upon PECO,
~
as the Applicant, to notify the Commission should its plans regarding the operation of- Limerick Generating Station change.- 'PECO certainly recognizes its_ obligation to' inform the . Commission and will do so . should the- circumstances -!
dictate. 'However,.-Philadelphia Electric Company remains 7-1 t . . .
~
~ . committed to the use of water - for :the Limerick Generating - - H Station as~ discussed in.the application.and asl. extensively-
- litigated over. the l a s t d e c a d e , a n d i.: M r . Paquette's . letter -
1 does ' not represent any - deviation.
The . letter : merely .re -
~
flects- a; change .in the' ' commercial- operation..date~;of Limerick. It also reflects the-: reality .that : sus _tained' .
- _ 1 power,operat, ion'duringlthe summer months-may not be~possible
7 swithoutia' supplemental source of water.
.PECO's: stated' intention to ~ pursue" .-completion - of : the gi ,
, Point. Pleasant: ? project..~as the -sourceof;' supplementary
, - r. ' cooling, water,for Limerick was the.'very; basis of'theirecent-N
.- "x.
4 decision by the Court of Common Pleas of Bucks County in 1- ~~
ruling that Neshaminy Water Resources Authority and Bucks County 'would . be required to take all necessary actions to completie the project.O 'In that decision, the Court granted PECO's~ request for specific ' performance of the contract
.between.PECO and NWRA to require it'"immediately.to recom-mence and complete construction of the Point Pleasant pumping station and the combined transmission main" and similarly ordered Bucks County "to do all things which are L 'necessary to implement and comply with its contractual 4
obligations so that the - construction and completion of the Point Pleasant pumping station and the combined transmission "5/
. main may be completed . . . .
In securing specific
~
performance of the contract, PECO successfully argued that 4
-any attempt to obtain other sources of supplemental cooling;
-water for Limerick .would be frought with . uncertainty and
~
would1 jeopardize the commercial operation of the : facility.
e '
(On this point, the . Court: emphatically - sustained ;PECO's position, stating:-
~
2' -As a prerequisite "to the : issuance of-
- an: -operating license by ? the .[ Nuclear]
' Regulatory Commission - (NRC) , .the succes .
sor to the~ Atomic Energy Commission
'(AEC),: the. licensing _ body- ' for - the '
w operation of Limerick, an . extensive; ienvironmental. impact study had been done J
- f ,
^ 4/.
iDaniel J. Sullivan,Tet al.'v. County of-~ Bucks,'et al'.,
No.- 84-8358 ,(Pa. Ct. ' Common Pleas) . (January 3, 1985).
5/:
-Id. tat 46.-
S' m-- a e4g = * + - + - t-M9"~ Met w i f
- v 5- *p v " ' re e .et- g v g 7v----wwt1*y e t
- m - " v7 ' v t w w- " - **g- +W't'i
with respect to the Point Pleasant project as a source of supplementary cooling water. If some alternative application were to be made by PECO for some other source, it is likely that a new environmental impact study would be required. An environmental study requires and consumes a great deal of time, effort and-money.
The regulatory permitting process is a long and tortuous one. This fact alone is probably the best argument for holding that neither PECO nor NP/NW are anyway remiss in their obligations for '
failure to seek and attempt to secure alternative scarces. They have been swimming in tnese turbulent waters for
^
so long that no one can blame them for refusing to take another plunge.6/
Accordingly, the very principle consistently espoused by the Director and the Adjudicatory Boards of the NRC in rejecting Del-Aware's argument has also been sustained by the Court of Common. Pleas of Bucks County in Pennsylvania.
Having raised identical matters before the Licensing Board and Appeal Board, Del-Aware cannot circumvent the
~ hearing and appeal processes.by allegations under 2.206. .As the Commission - held in Indian Point and Diablo ' Canyon,-
'6/
Id. at 19, 3 8_ . Additionally, the Court noted that Eere is "no assurance that PECO-will be'able to obtain' an alternative source of supplemental cooling water in the absence of the - Point Pleasant - project" :because-there'is "no evidence to indicate that either DER, DRBC oro the United . States Corps of- Engineers , will authori::e -
withdrawal of water'from Blue Marsh Reservoir in Berks County or:a relaxation of the regulatory restriction on
~ PECO's withdrawal of water from the, Schuylkill- River when' the . water temperature exceeds 59 degrees Fahrenheit." Id. at 20.
c.
parties must be prevented from using 10 C.F.R. 2.206 proce-dures as a vehicle for reconsideration of issues previously decided. Consolidated Edison of New York, Inc. (Indian Point, Unit Nos. 1, 2 and 3) , CLI-75-8, 2 NRC 1.73, 177 (1975); Pacific Gas and Electric Company -(Diablo Canyon Nuclear Power Plant, Units 1 and 2) , CLI-81-6, 13 NRC 443 (1981). See also Texas Utilities Generating Company
- (Comanche Peak Steam Electric Station, Unita 1 and 2) ,
DD-83-11, 18 NRC 293, 295 (1983).
Moreover, Del-Aware is collaterally estopped from attacking the previous rulings by the Director which, as explained, decided in Applicant's favor the issue which Del-Aware seeks- to raise here again. For the sake of brevity, Applicant incorporates its previous discussed in-Section III of its Comments on Del-Aware's Request Under 10 C.F.R. 52.206, transmitted by letters dated December 29, 1983 at 12-14 and August 21, 1984 at 10.
For these reasons, Del-Aware has failed to demonstrate that a proceeding should be instituted pursuant.to Sections
' 2.202 an'd 2.206 of the Commission's Rules of Practice.
w_C.___a____ _.i.____ _ _m. __m - _ _ _ _ . _ _ . m _____m _ _ .--a_-_-_____._____.m- . _ _ _ . _..________._-____-____-._.-_m.