ML20214N225

Licensee Answer in Opposition to Request for Hearing & Leave to Intervene by Air & Water Pollution Patrol.* Supporting Info Encl.Certificate of Svc & Notices of Appearance Encl

ML20214N225
Person / Time
Site:	Limerick
Issue date:	05/20/1987
From:	Conner T CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Atomic Safety and Licensing Board Panel
References
CON-#287-3582 OLA, NUDOCS 8706020104
Download: ML20214N225 (37)

Text

i 00LKETED USHRC g my 22 - P5 :10 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION q ,.

L f0CEIIbUE,,

1MilC-Before the Atomic Safety and Licensing Board In the Matter of )

)

Philadelphia Electric Company ) Docket No. 50-352-OLA

) (Iodine Spikes)

(Limerick Generating Station, )

Unit 1) )

LICENSEE'S ANSWER IN OPPOSITION TO REQUEST FOR HEARING AND LEAVE'TO INTERVENE BY AIR AND WATER POLLUTION PATROL Preliminary Statement on August 19, 1986, Philadelphia Electric Company

(" Licensee") filed an application with the Nuclear Regulato-ry Commission (" Commission" or "NRC") requesting changes to the Technical Specifications contained in Appendix A of Facility Operating License NPF-39 for Limerick Generating Station, Unit 1. The requested amendment, which the NRC Staff had requested Licensee to file, would incorporate the NRC model Technical Specifications provided with Generic Letter 85-19 regarding the requirements for reporting iodine spikes during normal plant operation.

As required under 10 C.F.R. SS50.91 and 50.92, the Commission made and published its "no significant hazards 870520 Nh0kDOfj05000352 0

PDR.,

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consideration" -finding concerning the proposed amendment.1/

The Commission determined that the application for the requested amendment involves no significant hazards consid-eration.2 The effect of that finding is to permit issuance of the requested amendment despite any request for hearing in response to published notice of proposed issuance of the requested amendment.1 Notice of the proposed issuance of the requested amendment and opportunity for hearing was published with the Commission's finding of no significant hazards consid-eration.A The published notice afforded interested parties an opportunity to participate in the proceeding under the terms for requesting a hearing and intervention provided in 10 C.F.R. Part 2.5I Specifically, the notice provided that any request for hearing must be received by April 13, 1987.

1/ Under 10 C.F.R. S50.92(c), a proposed amendment to an operating license for a facility involves no significant hazards consideration "if operation of the facility in 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."

2/ 52 Fed. Reg. 7675, 7693 (March 12, 1987).

3/ See 10 C.F.R. 550.91(a) (4) .

4/ 52 Fed. Reg. 7675 (March 12, 1987).

5/ Id.

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No request for hearing was received by the NRC or Licensee's counsel following publication of the notice of opportunity for hearing in the Federal Register. However, a petition dated September 4, 1986 had previously been submit-ted by Air and Water Pollution Patrol ("AWPP") in response to the application for the requested amendment. Thus, it predated the notice by five months. AWPP's petition was forwarded by the Secretary of the Commission to the Chief Administrative Judge of the Atomic Safety and Licensing Board Panel by memorandum dated April 29, 1987.

In his forwarding memorandum, the Secretary stated that Mr. Romano, AWPP's representative, was advised at the time the petition was submitted that it was premature, "but would be held" until the Staff had completed its review of the amendment application and published an appropriate notice in the Federal Register.- Apparently, the Office of the 6/ By letter dated September 10, 1986, Mr. Clements, then Chief of the Docketing and Service Branch, had advised Mr. Romano in relevant part:

When the NRC Staff has reached a decision on PECO's application of August 19, 1986, a notice will be published in the Federal Register informing interested persons of their hearing rights, and indicating the procedures for filing petitions. The Commission will not act on your request until that time.

The Office of the Secretary will hold your filing until the Staff has issued (Footnote Continued)

A

_4, Secretary took the position that it could retain Mr.

Romano's admittedly premature petition and reactivate it after notice of the Staff's proposed action had been pub-lished.

For the reasons discussed below, Licensee submits that AWPP's petition of September 4, 1986 was not a valid request for a hearing because the regulations do not authorize' a request for hearing prior to formal published notice under 10 C.F.R. S2.105 of an opportunity to file such a request.

Mr. Romano's premature request, therefore, cannot constitute a legal basis for the appointment of the presiding Atomic Safety and Licensing Board (" Licensing Board" or " Board").

Further, even if the petition were not deemed invalid for this reason, AWPP has failed to meet the pleading require-ments for intervention because it has not demonstrated the requisite interest in the proceeding. Accordingly, its petition should be dismissed.

Nature Of The Recuested Amendment The requested amendment resulted from the Staff's position in a two-page document circulated as Generic Letter (Footnote Continued) its Federal Register notice. At that time we will formally forward the petition to the Chairman, Atomic Safety and Licensing Board Panel for appropriate action. However, in the interim, I will send a copy of your filing to the Office of Nuclear Reactor Regulation and to the ASLBP for their information.

't 85-19 (September 27, 1985) (copy attached). The Staff stated that it had " reviewed the reporting requirements related to primary coolant specific activity levels, specif-ically primary coolant iodine spikes" and " determined that the reporting requirements for iodine spiking can be reduced from a short-term report (Special Report or Licensee Event Report) to an item which is to be included in the Annual Report."

The Staff also stated that "to eliminate unnecessary Technical Specification requirements," it had determined that "the existing requirements to shut down a plant if coolant iodine activity limits are exceeded for 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a 12-month period can be eliminated." As the basis for this conclusion, the NRC stated that the " quality of nuclear fuel has been greatly improved over the past decade with the result that normal coolant iodine activity (i.e. in the absence of iodine spiking) is well below the limit."

In the past, iodine spiking had been considered an important indicator of significant fuel cladding degrada-tion. In Generic Letter No. 85-19, the Staff stated that this concern is adequately addressed by 10 C.F.R.

S50. 72 (b) (1) (ii) , which " requires the NRC to be immediately notified of fuel cladding failures that exceed expected 1

values or that are caused by unexpected factors." The Staff f

therefore concluded that the short-term reporting require-ment for iodine spiking in plant Technical Specifications "is no longer considered necessary on the basis that proper l.

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1 fuel management by licensees and existing reporting require-ments should preclude ever approaching the limit." The Staff invited licensees to seek an amendment based upon the model Technical Specifications provided.

In its application dated August 19, 1986, Licensee ;

proposed to incorporate the model Technical Specifications regarding the requirements for reporting iodine spikes. The application discussed the safety significance and environ-mental considerations of the change as well as the NRC's "significant hazards consideration" determination under the three criteria set forth in 10 C.F.R. 550.92(c).

On March 12, 1987, the NRC published in the Federal Register its intent to issue the requested amendment. It discussed the background analysis which lead to the issuance of Generic Letter No. 85-19 and then evaluated the three criteria under Section 50.92(c). The Staff's analysis of the three criteria under Section 50.92(c) and its determina-tion of "no significant hazards consideration" are indepen-dent of the issuance of the amendment itself.2I Nonethe-less, the analysis is important in explaining the nature of the amendment and its lack of impact upon existing plant op-erations.

7/ As stated above, the "no significant hazards consideration" finding merely permits the NRC under Section 50.91(a) (4) to issue the amendment prior to the conclusion of any hearing, if requested.

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4-Under the first criterion of Section 50.92(c), (involve a significant increase in the probability or consequences of an accident previously evaluated), the NRC stated:

The change in the reporting require-ments is administrative in nature.

Although the reporting requirement for iodine spiking events is being reduced from a short term report to an item which is to be included in the Annual Report, the immediate notification and reporting requirements of 10 CFR 50.72 and 10 CFR 50.73 will provide adequate information on an increase in coolant activity which may be indicative of significant fuel degradation. The change in reporting requirements does

! not affect any p:. ant equipment, or operational procedures or conditions for operation which could impact the probability or consequences of an accident.

. . . This change does not increase

the current (coolant iodine] limits on specific activity and, therefore, does not increase the radiological conse-quences of any accident in which reactor coolant is postulated to be released to the environment.

. . . Further, the [ amendment] does not involve any change in the design of plant equipment or reactor operator practices that could impact the probability or consequences of an accident and does not involve degrada-

, tion of any of the conservative as-sumptions used in staff's previously performed dose assessment analysis.8_/

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i 8_/ 52 Fed. Reg. at 7693 (emphasis added).

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With respect to the second criterion (create the possibility of a new or different kind of accident from any accident previously evaluated), the NRC stated:

The administrative changes in report-ing requirements do not vary or affect any plant operating condition or parame-ter. . . . [T]he design of the plant is unchanged, the inputs, assumptions and results for the previously performed safety analyses are unchanged, and no new paths are introduced that could lead to a new or different kind of acci-dent.9_/

On the third criterion (involve a significant reduction in a margin of safety) , the NRC similarly stated:

The administrative changes in report-ing requirements do not vary or affect any plant operating condition or parame-ter, do not change any of the design bases of the plant and thus do not involve a significant reduction in the margin of safety of any plant parameter.

. . . There is no change in the design of the plant and the inputs, assumptions and results for previously performed and accepted safety analyses are un-changed.M/

In essence, the minor change in reporting requirements is an administrative measure which will have no perceptible impact upon plant operations. A proper understanding of the nature of the amendment is essential in applying the NRC's requirements for intervention to AWPP's request to 9/ Id. (emphasis added).

10/ Id. (emphasis added).

4 intervene, chiefly with respect to AWPP's allegations of an interest in the outcome of the proceeding.

Argument I. AWPP's Petition Is Not A Valid Request For A Hearing In Response To The Notice Published In The Federal Register Before addressing AWPP's alleged interest in the outcome of this proceeding, the Board must decide prelimi-narily whether AWPP's petition is even a valid request for a hearing under the NRC's regulations governing such requests and the notice of opportunity for hearing and for requests to intervene published in the Federal Register. For the reasons discussed below, Licensee submits that no valid request exists.

The requested amendment for Limerick is covered by the provisions of 10 C.F.R. S2.105 (a) (4) , which requires notice of the proposed action, and 10 C.F.R. S2.105(d), which provides thirty days from the date of notice for any inter-ested person affected by the proceeding to file a request for a hearing or petition for leave to intervene if a hearing has already been requested.

Of course, the NRC did not afford potentially interest-ed parties such as AWPP an opportunity to request a hearing and seek leave to intervene in this proceeding until publi-cation in the Federal Register on March 12, 1987 of its proposed action on the amendment requested by Licensee.

That procedure followed the regulations under 10 C.F.R.

SS2.105 and 50.91. The period for filing a timely request

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for hearing expired on April 13, 1987. AWPP's petition was not submitted - during that period, but rather five months prior to commencement of the proceeding. As stated in 10 C.F.R. S2.717, a " proceeding is deemed to commence when a notice of hearing or a notice of proposed action pursuant to S2.105 is issued."

Thus, under the regulations, Licensee's filing of its application for the requested amendment did not give rise to an opportunity for hearing. That right is created by Section 2.105 and the related implementing provisions under Part 2 of the Commission's regulations. Under those regu-lations, the right to a hearing can be invoked only after due notice by publication in the Federal Register. Inasmuch as AWPP's petition was received five months prior to formal notice by publication, it was a legal nullity and could not be reactivated at some later date by a docketing officer to constitute a timely, valid request.

In neither the Secretary's memorandum of April 29, 1987 nor Mr. Clement's letter dated September 10, 1986 is any basis shown for the Secretary to " hold" a premature hearing request in suspension on the theory that, at a later time, it will ripen into a valid request. There is no regulation, and Licensee is unaware of any Commission order or policy, by which the Secretary has been instructed or authorized to

" hold" a request for hearing submitted in advance of the formal notice providing opportunity for hearing. Hence, Licensee submits that the actions of the Secretary are in no

way binding _on this Board. Nor can they commit the Commis-sion to accepting AWPP's invalid petition.

Certainly, nothing within the enumerated powers dele-gated to the Secretary under 10 C.P.R. S2.772 suggests that the Secretary has discretion to retain and reactivate an invalid petition. On the contrary, the Secretary has an obligation under Section 2.772 (i) to deny any request for a hearing, such as AWPP's petition, which fails to comply with the Commission's pleading requirements or fails to set forth an arguable basis for further proceedings.

As in the recent rejection of a filing by the Chief Administrative Judge on behalf of the Licensing Board Panel, the Secretary has rejected filings as unauthorized.NI The Secretary provides no explanation as to why the contrary position ns taken in retaining and then forwarding Mr.

Romano's petition,N! or conversely, in not forwarding a similar petition by Mr. Robert Anthony.E#

The effect of granting a hearing upon the request by AWPP would be to expand the notice of opportunity of hearing

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11/ Public Service Company of New 11ampshire (Seabrook Station, Units 1 and 2), " Order" (April 17, 1987).

12/ Moreover, the Secretary's referral under Section 2.772(j) was incorrect insofar as it implies that, by virtue of his premature petition, AWPP "is entitled to further proceedings." As shown above, no basis exists for "further proceedings."

M/ See letter from Troy B. Conner, Jr., to Judge B. Paul Cotter (May 7, 1987).

.five months prior to its issuance. As stated in the order designating the members of this Board pursuant to the Commission's delegation, "[t]his Board is being established i pursuant to a notice published by the Commission on March 12,-1987, in the Federal Register (52 F.R. 7675-76, 7691-93) entitled, ' Consideration of Issuance of Amendment to Facili-ty Operating License and Proposed no Significant Hazards Consideration Determination and Opportunity for Hear-ing.'" D Therefore, this Board must limit the grant of any hearing or intervention strictly in compliance with the underlying notice which commenced the proceeding.

It is well settled that, in determining the scope of its jurisdiction in ruling upon requests for a hearing and intervention, "a Licensing Board must respect the terms of

the notice of hearing published by the Commission for the i

proceeding in question." b As the Appeal Board summarized in the Catawba proceeding:

J Adjudicatory boards do not have

, plenary subject matter jurisdiction in Commission proceedings. Under ,the Atomic Energy Act, the Nuclear Regulato-ry Commission is empowered to administer I the licensing provisions of the Act and i use licensing boards "to conduct such l hearings as the Commission may direct."

i 14/ See Philadelphia Electric Company (Limerick Generating Station, Unit No. 1) , Docket No. 50-352-OLA,

" Establishment of Atomic Safety and Licensing Board" i (May 7, 1987),

i i 15/ Commonwealth Edison Company (Carroll County Site),

ALAB-601, 12 NRC 18, 24 (1980) (citing cases).

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1 The boards, therefore, are delegates of.

the Commission and, as such, they may exercise authority over only those matters that the Commission commits to-them. The various hearing notices are the means by which the Commission identifies the subject matters of .the

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hearings-and delegates to the boards the authority to conduct proceedings.16_/

The request by AWPP was invalid when received since it twas not in response to any notice of opportunity for hear-Ing. It cannot be transformed into a valid request merely by the passage of time and subsequent publication of an

. opportunity for hearing. Because of the controlling regu-t t

lations and limited jurisdiction of this Board pursuant to its delegated authority under the formally published notice e of proposed action and opportunity for hearing, the actions by the Office of - the Secretary cannot create additional hearing rights. . Nor may the actions by the Of fice of the

, Secretary be permitted to prejudice the legal rights of NRC j applicants and licensees under the Commission's regulations t and its published notices. As there is no legal basis for AWPP's equest for hearing, the proceeding should be dis-missed.

1 16/ Duke Power Company (Catawba Nuclear Station, Units 1 and ~2 ) , - ALAB-825, 22 NRC 785, 790 (1985) (footnotes omitted).

_ 14 II. AWPP Has Not Met The Requirements For Representational Standing The request for hearing in this instance was filed on behalf of AWPP by Mr. Romano, identified as chairman of AWPP. AWPP was a party to the operating license proceeding for Limerick and Mr. Romano was its designated representa-tive.NI Prior participation by an organizational inter- l venor in an earlier proceeding, however, does not establish its interest with regard to a separate, subsequent proceed-ing for the same facility.EI In this new amendment proceeding, AWPP has made no attempt to meet the requirements under the Commission's rules and precedents for participation by an organization.

For example, the petition does not demonstrate that any member of AWPP has requested that organization to represent him or her in this proceeding. Nor does the petition state that, by whatever internal procedures govern the orga-nization, AWPP has authorized Mr. Romano to act as its designated representative if intervention should be granted.

In fact, the petition gives no evidence that AWPP is any-thing more than Mr. Romano himself and perhaps his own family.

1]/ See Limerick, LBP-82-43A, 15 NRC 1423, 1438 (1982).

-18/ See Philadelphic Electric Company (Peach Bottom Atomic Power Station, Units 2 and 3), LBP-75-22, 1 NRC 451, 454-55 (1975), Wisconsin Electric Power Company (Point (Footnote Continued)

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Whether the petition is viewed as a request by AWPP or Mr. Romano personally,E the petition is deficient. It fails to address, much less meet, the requirements of 10 C.F.R. SS2.714 (a) (2) and (d) for demonstrating the specific interest of any AWPP member (including Mr. Romano) in this proceeding or explaining how that interest may be affected by the outcome of the proceeding. AWPP's claim that it "has indicated its concerns" regarding " personal health and property" and potential " financial loss" merely parrots certain words from the regulations and is wholly conclusion-ary. Such allegations hardly suffice to demonstrate any concrete interest in the outcome of the proceeding.

Next, AWPP refers to earlier licensing actions by the NRC, alleging that on the basis of the prior record in those proceedings, Licensee "does not merit" the requested amend-ment.EI These allegations, including the reference to the 19/ It is now well settled that " organizations . . . are not clothed with independent standing to intervene in NRC licensing proceedings. Rather, any standing which

[an organization] may possess is wholly derivative in character." Houston Lighting and Power Company (Allens Creek Nuclear Generating Station, Unit 1) , ALAB-535, 9 NRC 377, 390 (1979).

M/ Apparently, AWPP is referring to a quality assurance contention it litigated unsuccessfully in the operating license proceeding. See Limerick, ALAB-819, 22 NRC 681, 727 (1985). In a "posteript," AWPP also incorrectly characterizes correspondence between the NRC and Licensee relating to Amendment No. 1 to the operating license for Limerick, which is not at issue here.

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Chernobyl accident, fail to establish that AWPP or any of its members has an interest in the outcome of the instant proceeding.

AWPP's allegation that the requested amendment " seeks

-to decrease the safety guid511nes in the NRC regulations" is untenable on its face inasmuch as the application does not involve a request for an exemption from any safety require-ment. In any event, AWPP does not show how the requested change in reporting requirements for iodine spiking, however characterized, would affect any interest of AWPP or its members. Equally untenable is AWPP's apparent assertion that the proposed amendment will result in " uncontrolled amounts" of Iodine-131. As noted, the requested change "does not increase the current limits on specific [ coolant iodine] activity and, therefore, does not increase the radiological consequences of any accident in which reactor coolant is postulated to be released to the environment."EI Hence, even assuming that the Board were to treat the petition as a request by Mr. Romano to participate as an intervenor (or to base AWPP's standing solely upon Mr.

Romano's representations regarding his own interests), the petition is insufficient. The Commission has ruled that an assertion of " injury in fact" to the petitioner himself, and not a generalized grievance shared by the public at large, M/ 52 Fed. Reg. at 7693.

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is necessary for standing. In Transnuclear, Inc.,

CLI-77-24, 6 NRC 525 (1977), the Commission held that standing must meet federal judicial standards:

Under the most recent Supreme Court decisions on standing, a party seeking relief must " allege some threatened or actual injury resulting from the puta-tively illegal action. . . . One focus of the " injury in fact" test is the concept that a claim will not normally be entertained if the " asserted harm is a ' generalized grievance' shared in substantially equal measure by all or a large class of citizens . . . ." Thus, even if there is a generalized asserted harm, the Petitioners must still show a distinct and palpable harm to them.2_2/

The Commission reviewed and reaffirmed these require-ments for standing in rejecting intervention requested in Westinghouse Electrical Corporation (Export to South Korea),

CLI-80 .50, 12 NRC 253 (1980). The Commission again em-phasized the importance of stating some " injury in fact" to the petitioner himself as a basis for establishing the requisite personal interest for intervention:

In developing the " injury in fact" requirement, the Court has held that an organization's mere interest in a problem, "no matter how long-standing the interest and no matter how qualified the organization is in evaluating the problem," is not sufficient for standing

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22/ 6 NRC at 530-31 (citations omitted). The Commission has frequently reiterated that it "will apply judicial concepts of standing to determine hearing and intervention rights under Section 189a. of the Atomic Energy Act." Public Service Company of Indiana (Marble Hill Nuclear Generating Station, Units 1 and 2) ,

CLI-80-10, 11 NRC 438, 439 (1980).

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problem, "no matter how long-standing the interest and no matter how qualified the organization is in evaluating the problem," is not sufficient for standing to obtain judicial review. . . . The organization seeking relief must allege that it will suffer some threatened or actual injury resulting from the agency action. . . . "[Aln organization's abstract concern with a subject that could be affected by an adjudication does not substitute for the concrete injury, required by article III."2,3] 3 The Appeal Board has followed the same approach in limiting intervention to those who have particularized specific injury and do not merely seek to vindicate the general public interest. Intervention was rejected, for example, in the Sheffield proceeding,- where "neither peti-tioner has identified, let alone particularized, any specif-ic injury that it or its members would or might sustain . .

. . "E The Appeal Board in Sheffield further emphasized that interventien is unavailable "to vindicate broad public interests said to be of particular concern to [ petitioners) and their members" because the rules require "a concrete demonstration that harm to the petitioner (or those it 12 NRC at 258. The federal cases on standing upon 2_3_/

which the Commission has always relied continue to be good law. See United Automobile, Aerospace and Agricultural Implement Workers of America v. Brock, 54 U.S.L.W. 4764, 4766 (U.S. June 24, 1986).

24/ Nuclear Engineering Company, Inc. (Sheffield, Illinois, Low-Level Radioactive Waste Disposal Site) , ALAB-473, 7 NRC 737, 741 (1978).

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represents) will or could flow from a result unfavorable'to it - whatever that result might be."EI Under.these prece-dents, AWPP (or Mr. Romano personally) has clearly failed to-establish the requisite concrete, personal interest in the outcome of the proceeding necessary to establish its - (or his); standing.

In another line of cases, the Appeal ~ Board has also stated that "close proximity [to a nuclear plant] has always been deemed to be enough, standing alone, to establish the requisite interest" for interven' tion. The Appeal Board '

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later clarified that decision to mean that " persons who live in.close proximity to a reactor site are presumed to have a cognizable interest in licensing proceedings involving that reactor."E! The Board in the Palisades proceeding con-i strued those decisions to mean that "close proximity" to'the facility merely raised a presumption of standing and that further demonstration of a " cognizable interest" personal to the intervenor is necessary for standing.2_8_/ Mr. Romano l

25/ Id. at 741, 743. See also Allied-General Nuclear Services (Barnwell Fuel Receiving and Storage Station),

ALAB-328, 3 NRC 420 (1976).

26/ Virginia Electric and Power Company (North Anna Nuclear Power Station, Units 1 and 2), ALAB-522, 9 NRC 54, 56 (1979).

i M/ Allens Creek, ALAB-535, 9 NRC at 393 (emphasis added).

28/ Consumers Power Company (Palisades Nuclear Power Facility), LBP-81-26, 14 NRC 247, 253-55 (1981).

does not live in "close proximity" to the Limerick plant, at least in terms of the proposed license amendment and any potential interest in its issuance. E In an operating license amendment proceeding in

' Pilgrim, the Licensing Board applied stricter requirements for standing than those applicable to operating license ,

proceedings. The Board held:

This case concerns a request for a license amendment and it is not con-trolled by the same standing consid-erations that govern standing when an operating license is sought. Whatever the risk to the surrounding community from a reactor and its associated fuel pool, the risk from the fuel pool alone is less and the distance of residence from the pool for which standing would be appropriate would, accordingly, be less. Consequently, we do not consider residence 43 miles from this plant to be adequate for standing. We need not decide how close residence might be before standing would be established.3_0/

In Licensee's view, the same principle controls here.

Close proximity to a reactor may give rise to a presumption -

-29/ The Board can take official notice that Ambler, Pennsylvania lies some 19 miles southeast of the Limerick plant.

-30/ Boston Edison Company (Pilgrim Nuclear Power Station) ,

LBP-85-24, 22 NRC 97, 99 (1985), aff'd, ALAB-816, 22

NRC 461 (1985) (emphasis in original) . In affirming, the Appeal Board expressly left open the question of "whether either [ petitioner's] place of residence or his consumption of food products originating in the vicinity of the facility serves to clothe (petitioner]

with the requisite mantle of standing to challenge the proposed amendment to the Pilgrim operating license."

Pilgrim, ALAB-816, 22 NRC at 465.

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of standing in an operating license proceeding because practically any petitioner who lives within 40 or 50 miles of the plant or closer can allege some concern over opera-tion of the reactor if a serious accident should occur. The instant proceeding, however, is not for the purpose of licensing the operation of Limerick Unit 1, but merely providing a very narrow amendment to the plant's reporting requirements as contained in its Technical Specifications.

To summarize'the potential impact of the minor adminis-trative changes in reporting requirements requested by Licensee at the suggestion of the NRC, this amendment "does not involve any change in the design of plant equipment or reactor operator practices that could impact the probability or consequences of an accident and does not involve degrada-tion of any of the conservative assumptions used in staff's previously performed dose assessment analysis."E Hence, the amendment does not " vary or affect any plant operating condition or parameter."El In terms of potentially affect-ed interests, it is extremely difficult if not impossible to conceive of any manner in which AWPP (or Mr. Romano as a representative member, who resides 19 miles from the plant) could be affected by this minor change.

Conclusion 31/ 52 Fed. Reg. at 7693.

32/ Id.

- 22.-~ l For the reasons discussed above, the premature request for hearing by AWPP is invalid and beyond the notice of opportunity for hearing. It therefore does not constitute a valid request for hearing which can be the basis for further proceedings before this Board. Moreover, . the petition is deficient under the rules for intervention in failing to demonstrate any concrete, personal interest on the part of AWPP's members in the outcome of the proceeding. According-ly, the request for a hearing should be dismissed for lack of jurisdiction or. denied for failure to meet standing requirements. In either event, this proceeding should be terminated.

Respectfully submitted, CONNER & WETTERHAHN, P.C.

3 e r i } ( r, r ') L I U > l'] _

Troy B.Cfonner, Jr. '

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Mark J. Wetterhahn Robert M. Rader Counsel for Licensee May 20, 1987 c y . , _ .,-_.__e _ , , , _ . , . _ _ , - - . 7,_ - ,.._.-._.___.,.e___ y _. _ , _ _ _ . . . - - . . . _ _ ,

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!ss' TO ALL LICENSEES AND APPLICANTS FOR OPERATING POWER REACTORS A 0F CONSTPUCTION PERMITS FOR POWER REACTORS V1 .

Gentlemen:

SUBJECT:

Reporting Requirements on Primary Coolant Iodine Spikes (Generic Letter No. 85- 19 )

Generic Letter No. 83-43 was issued on December 19, 1983, to provide guidance on Technical Specification revisions required as the result of the revisions to 10 CFR 50.7? (! mediate Notification Requirements of Significant Events at Operating Nuclear Power Reactors) and of implementation of 10 CFR 50.73 (Licensee Event Report System). That generic letter discussed changing the requirement from a Licensee Event Report to a Special Report for operating conditions where the specific activity limits of the reactor coolant are exceeded.

As part of our continuing program to delete unnecessary reporting require-ments, we have reviewed the reporting requirements related to primary coolant specific activity levels, specifically primary coolant iodine spikes. We have detemined that the reporting requirements for iodine spiking can be reduced from a short-term report (Special Report or Licensee Event Report) to an item which is to be included in the Annual Report. The information to be included in the Annual Report is similar to that previously required in the Licensee Event Report but has been changed to more clearly designate the results to be included from the specific activity analysis and to delete the information regarding fuel burnup by core region.

In our effort to eliminate unnecessary Technical Specification requirements, we have also determined that the existing requirements to shut down a plant if coolant iodine activity limits are exceeded for 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a 12-month period can be eliminated. The quality of nuclear fuel has been greatly improved over the past decade with the result that normal coolant iodine activity (i.e. in the absence of iodine spiking ) is well below the limit.

Appropriate actions would be initiated long before accumulating 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> above the iodine activity limit. In addition, 10 CFR 50.72(b)(1)(ii) recuires the NPC to be imediately notified of fuel cladding failures that exceed expected values or that are caused by unexpected factors. Therefore, i this Technical Specificaticn limit is no longer considered necessary on the basis that proper fuel management by licensees and existing reporting recuirements should preclude ever approaching the limit.

Licensees are expected to continue to monitor iodine activity in the primary coolant and take responsible actions to maintain it at a reasonably low level (i.e., accurulated time with high iodine activity should not approach 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br />).

RECElVEb OCT i h.

6 8509240257 2d y 3.G.H00m

.?-

Enclosed are model Techr.ical Specifications ir, Standard Technical Specification (STS} format shwing the revisions that ryty be used in a submittal n' proposed Technical Specifications or proposed thanges to e.xisting Technical Specifications.

These chances will also be incorportted in the next revisinr of the STS for all nuclear power reactor vendors. The changes are indicated by a line in the margin of the Action Statement for the Limiting Condition for Operation. A Technical Specification amendment request should be submitted to the NPI for each facility which currently has Technical Specification reporting requirements upon exceeding coolant iodine activity limits or which has a requirement tn shut down after 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> with iodine abcve the limit. Your reouest should include appropriate changes to the bases section of ynur Technical Specifi-cations.

As a matter nf information, when Technical Specificction changes or other preposed license amendments and approvals (i.e., proposed facility modifications requiring NP.C approval} are required as a result of this or arother generic letter, they are sub,iect to the fee provisions of 10 CFR 170 and a S150 application fee should accompany ycur request (see 10 CFR *.70.12(c) and 170.21).

If you have any questions relating to this subject, pleese contact M. Virgilio of my staff on (301 492-8947).

This request has been approved by CPR Clearance Number 3150-0011, which expires September 30,1936.

Sincerely, Huth . Thompson. tnr 0 for of Licensing

Enclosure:

"Vedel Technical Specifications showing Fevisions to STS Reporting Requirements for Primary fcolant Specific Activity" l

List of Generic Letters l

{

l i

REACTOR COOLANT. -~ SYSTEM .

3/4.4.8 SPECir*IC ACTIVITY LIMITING CONDITION FOR OPERATION 3.4.8 The specific activity of the reactor coolant shall be lietted to:

a. Less than or equal to 1 microcurie per gram DOSE EQUIVALENT I-131, and

~

b. Less than or equal to 100/l microCuries per gram of gross radioactivity.

APPLICABILITY: MODES 1, 2, 3, 4, and 5.

ACTION:

MODES 1, 2 and 3*:

a. With the specific activity of the reactor coolant greater than 1 microcurie per gram DOSE EQUIVALENT I-131 for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during one continuous time interval or exceeding the limit line shown on Figure 500*F 3.4-1, within be in at 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; andleast HOT STAND 8Y with T*V8 less than

b. With the specific activity of the reactor coolant greater than 100/l microcuries per gram, be in at least HOT STAND 8Y with T"V9 less than 500*F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

MODES 1, 2, 3, 4, and 5:

With the specific activity of the reactor coolant greater than 1 microcurie per gram DOSE EQUIVALENT I-131 or greater than 100/l micro-Curies per gram, perform the sampling and analysis requirements of Item 4.a) of Table 4.4-4 until the specific activity of the reactor coolant is restored to within its limits.

SURVEILLANCE REQUIREMENTS 4.4.8 The specific activity of the reactor coolant shall be determined to be within the limits by performance of the sampling and analysis pFogram of Table 4.4-4.

'With T,y greater than or equal to 500*F. j i

l W-STS 3/4 *- 28 l

1

REACTOR COOLANT SYSTEM ,.

3/4.4.8 SPECIFIC ACTIVITY LIMITING COND'ITION FOR OPERATION 3.4.8 The specific activity of the primary coolant shall be limited to: f

a. Less than or equal to 1.0 microcurie / gram DOSE EQUIVALENT I-131', and

b. Less than or squal to 100/E microcuries/ gram.

APPLICABILITY: MODES 1, 2, 3, 4 and 5.

ACTION:

MODES 1, 2 and 3*:

a. With the specific activity of the primary coolant greater than 1.0 microcurie / gram DOSE EQUIVALENT I-131 for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during one continuous time interval or exceeding the limit line shown on Figure 3.4-1, be in at least H0T STANDBY with T"V9 less than 500*F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

, b. the specific activity of the primary coolant greater than With_E 100/ microcuries/ gram, be in at least HOT STANDBY with Tless avg than 500*F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

MODES 1, 2, 3, 4 and 5:

With the specific activity of the primary coolant greater than 1.0 microcurie /

gram DOSE EQUIVALENT I-131 or greater than 100/l microcuries/ gram, perfom the sampling and analysis requirements of ites 4 a) of Table 4.4-4 until the speci-fic activity of the primary coolant is restored to within its limits.

SURVEILLANCE REQUIREMENTS l

4.4.8 The specific activity of the primary coolant shall be determined to be within the limits by perfomance of the sampling and analysis program of Table 4.4-4. -

l With T,yg greater than or equal to 500*F.

CE-STS 3/4 4-23 l

l

, . REACTOR COOLANT SYSTEM 3/4.4.9 SPECIFIC ACTIVIT_Y_

LIMITING CONDITION FOR OPERATION 3.4.3 The specific activity of the primary coolant shall be limited to:

. a. Less than or equal to 1.0 microcurie / gram DOSE EQUIVALENT I-131, and

b. Less than or equal to 100/l microcuries/ gras .

APPLICABILITY: MODES 1, 2, 3, 4 and 5.

ACTION:

MODES 1, 2 and 3*.

a. With the specific activity of the primary coulant greater than 1.0 microcurie / gram DOSE EQUIVALENT I-131 for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during one continuous time interval or exceeding the limit line shown on Figure 3.4-1, be in at least HOT STANDBY with T less avg than 500*F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

b. With the specific activity of the primary coolant greater than 100/l microcuries/ gram be in at least HOT STAND 8Y with T**9 less than 500*F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

MODES 1, 2, 3, 4 and 5:

a. With the specific activity of the primary coolant greater than 1.0 microcurie / gram DOSE EQUIVALENT I-131 or greater than 100/l microcuries/

gram perform the sampling and analysis requirements of item 4 a of Table 4.4-4 until the specific activity of the primary coolant is restored to within its limits.

SURVEILLANCE REQUIREMENTS 4.4.9 The specific activity of the primary coolant shall be determined to be within the limits by performance of the sampling and analysis program of Table 4.4-4.

"With T,y, greater than or equal to 500*F.

B&W-STS 3/* -21

REACTOR COOLANT SYSTEM 3/4.4.5 SPECIFIC ACTIVITY LIMITING CONDITION FOR OPERATION 3.4.5 The specific activity of the primary coolant shall be limited to: ,

a. Less than or equal to 0.2 microcuries per gram DOSE EQUIVALENT I-131, and

'b. Less than or equal to 100/l microcuries per gram.

1 APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, 3 and 4.

ACTION:

a. In CPERATIONAL CONDITIONS 1, 2 or 3 with the specific activity of the primary coolant;

1. Greater than 0.2 microcuries per gram DOSE EQUIVALENT I-131 but less than or equal to 4.0 microcuries per gram DOSE EQUIVALENT I-131 for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during one continuous time interval or greater than 4.0 microcuries per gram DOSE EQUIVALENT I-131, be in at least HOT SHUTDOWN with the main steam line isolation valves closed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

2. Greater than 100/l microcuries per gram, be in at least NOT SHUT-DOWN with the main steamline isolation valves closed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. .

b. In OPERATIONAL CONDITIONS 1, 2, 3 or 4, with the specific activity of the primary coolant greater than 0.2 microcuries per gram DOSE EQUIVA-LENT I-131 or greater than 100/l microcuries per gram, perfore the sam-pling and analysis requirements of Item da of Table 4.4.5-1 until the l

specific activity of the primary coolant is restored to within its limit,

c. In OPERATIONAL CONDITION 1 or 2, with:

1. THERMAL POWER changed by more than 15% of RATED THERMAL POWER 1

in one hour *, or

2. The off gas level, at the SJAE, increased by more than (10,000) microcuries per second in one hour during steady state operation at release rates less than (75,000) microcuries per second, or

3. The off gas level, at the SJAE, increased by more than (15)% in one hour during steady state operation at release rates greater than (75,000) nicrocuries per second, perform the sampling and analysis requirements of Item 4b of Table 4.4.5-1 until the specific activity of the prima'ry coolant is restored to within its limit.

SURVEILLANCE REQUIREMENTS 4.4.5 The specific ac+ivity of the reactor coolant shall be demonstrated to be within the limits b, performance of the sampling and analysis program of Table 4.4.5-1.

1 "Not applicable during the startup test prograr l GE-STS (BWR/4) 3/4 4-15

REACTOR COOLANT SYSTEM ,

3/4.4.5 SPECIFIC ACTIVITY i

LIMITING CONDITION FOR OPERATION 3.4.5 The specific activity of the primary c'oolant shall be limited to:

a. Less than or equal to 0.2 microcuries per gram D0SE EQUIVALENT I-131, and

b. Less than or equal to 100/E aicrocuries per gram.

APPLICA81LITY: OPERATICNAL CONDITIONS 1, 2, 3 and 4.

ACTION:

a. In OPERATIONAL CONDITIONS 1, 2 or 3 with the specific activity of the primary coolant;

1. Greater than 0.2 microcuries per gram DOSE EQUIVALENT I-13 but less than or equal to 4.0 microcuries per gram DOSE EQUIVALENT I-131 for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during one continuous time interval or greater than 4.0 microcuries per gram DOSE EQUIVALENT I-131, be in at least HOT SHUTDOWN with the main steam line isolation valves closed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

2. Greater than 100/l microcuries per gram, be in at least HOT SHUT-DOWN with the main steamline isolation valves closed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />

b. In OPERATIONAL CONDITIONS 1, 2, 3 or 4, with the specific activity of the primary coolant greater than 0.2 microcuries per gram DOSE EQUIVA-LENT I-131 or greater than 100/I alcrocuries per gram, perform the sam-pling and analysis requirements of Ites 4a of Table 4.4.5-1 until the specific activity of the primary coolant is restored to within its limit.

c. In OPERATIONAL CONDITION 1 or 2, with:

1. THERMAL POWER changed by more than 15% of RATED THERMAL POWER in one hour", or

2. The off gas level, at the SJAE, increased by more than (10,000) nicrocuries per second in one hour during steady state operation at release rates less than (75,000) nicrocuries per second, or

3. The off gas level, at the SJAE, increased by more than (15)% in one hour during steady state operation at release rates greater than (75,000) nicrocuries per second, perfore the sampling and analysis requirements of Item 4b of Table 4.4.5-1 until the specific activity of the prima'ry coolant is restored to within its limit.

SURVEILLANCE REQUIREMENTS 4.4.5 The specific activity of the reactor coolant shall be demonstrated to be within the limits by performance of the sampling and analysis program of Table 4.4.5-1.

"Not applicable during the ::1. . . . .;;; - :.- -

GE-STS (SWR /5) 3/4 4-1'

,---se,--e- - - . - - - -,--m- - -m- - - , , - - . , - - - + - - , - -- - - .----wv----,-----w-y,--,----*----r- - - - -t,--w , - - - - -7 sw

REACTOR COOLANT SYSTEM ,

3/4.4.5 SPECIFIC ACTIVITY LIMITING CONDITION FOR OPERATION 3.4.5 The specific activity of the primary coolant shall be limited to:

a. Less than or equal to 0.2 microcuries per gram DOSE EQUIVALENT I-131, and

b. Less than or equal to 100/l microcuries per gram.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, 3 and 4.

ACTION:

a. In OPERATIONAL CONDITIONS 1, 2 or 3 with the specific activity of the primary coolant; .

1. Greater than 0.2 microcuries per gram DOSE EQUIVALENT I-131 but less than or equal to 4.0 microcuries per gram DOSE EQUIV.iLENT I-131 for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during one continuous time interval or greater than 4.0 microcuries per gram DOSE EQUIVALENT I-1;1, be in at least HOT SHUTDOWN with the main steam line isolation valves closed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

2. Greater than 100/l microcuries per gram, be in at least HOT SHUT-DOWN with the main steamline isolation valves closed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

b. In OPERATIONAL CONDITIONS 1, 2, 3 or 4, with the specific activity of the primary coolant greater than 0.2 microcuries per gram DOSE EQUIVALENT I-131 or greater than 100/l microcuries per gram, perform the sampling and analysis requirements of Item 4a of Table 4.4.5-1 until the specific activity of the primary coolant is restored to within its limit.

c. In OPERATIONAL CONDITION 1 or 2, with:

1. THERMAL POWER changed by more than 15% of RATED THERMAL POWER in one hour", or

2. The off gas level, at the SJAE, increased by more than (10,000) microcuries per second in one hour during steady state operation at release rates less than (75,000) microcuries per second, or

3. The off gas level, at the SJAE, increased by more than (15)% in one hour during steady state operation at release rates greater than (75,000) microcuries per second, perform the sampling and analysis requirements of Item 4b of Table 4.4.5-1 until the specific activity of the primary coolant is restored to within its limit.

SURVEILLANCE REQUIREMENTS 4.4.5 The specific activity of the reactor coolant shall be demonstrated to be within the limits by performance of the sampling and analysis program of Table 4.4.5-1.

"Not appl 1caDle during the startup test prograr.

GE-ST5 (BWR/6) 3/4 4-14

ADMINISTRATIVE CONTROLS ANNUAL REPORTS (Add the following to this section) .

The results of specific activity analysis ih which the primary coolant exceeded the limits of Specification 3.4.8 (W and CE plants),

3.4.9 (B&W plants) or 3.4.5 (GE plants). The following information shall be included: (1) Reactor power history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior l

to the first sample in which the limit was exceeded; (2) Results of the last isotopic analysis for radiciodine performed prior to ex-ceeding the limit, results of analysis while limit was exceeded and results of one analysis after the radiciodine activity was reduced to less than limit. Each result should include date and time of sampling and the radiciodine concentrations; (3) Clean-up system flow history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (4) Graph of the I-131 concentration and one other radiciodine isotope concentration in microcuries per gram as a function of time for the duration of the specific activity above the steady-state level; and (5) The time duration when the specific activity of the primary coolant exceeded the radiciodine limit.

STS-ALL PLANTS

LIST OF RECENTLY ISSUED GENERIC LETTERS

.. GENERIC LETTER NO. SUBJECT DATE 85-03 Clarification of Equivalent Control Capacity 1/28/85 For Standby Liquid Control Systems 85-04 Operator Licensing Examinations 1/29/85 85-05 Inadvertent Boron Dilution Events 1/31/85 85-06 Quality Assurance Guidance for ATWS Equipment that is not Safety-Related 4/16/85 85-07 Implementation of Integrated Schedules 5/02/85 for Plant Modifications 85-08 10 CFR 20.408 Termination Reports - Format 5/23/85 -

85-09 Technical Specifications for Generic Letter 83-28, Item 4.3 5/23/85 85-10 Technical Specifications for Generic Letter 83-28, Items 4.3 and 4.4 5/23/85 85-11 Completion of Phase II of " Control of 6/28/85 Heavy Loads at Nuclear Power Plants" NUREG-0612 85-12 Implementation of TMI Action Item II.K.3.5,

" Automatic Trip of Reactor Coolant Pumps" 6/28/85 85-13 Transmittal of NUREG-1154 Regarding the Davis Besse Loss of Main and Auxiliary Feedwater Event 8/5/85 84-14 Commercial Storage at Power Reactor Sites of Low Level Radioactive Waste not Generated by the Utility 8/1/85 85-15 Information Relating to the Deadlines for Compliance with 10 CFR 50.49, " Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants 8/6/85 85 16 High Baron Concentrations 8/23/85 85-17 Availability of Supplements 2 & 3 to NUREG-0933, "A Prioritization of Generic Safety Issues S/23/85 85-18 Operator Licensing Examinations 9/27/85 85-19 Reporting Requirements on Primary Coolant 9/27/85 Iodine Spikes

s.

e 00(nE TEi UWC UNITED STATES OF AMERICA 87 ftAY 22 P5:10 NUCLEAR REGULATORY COMMISSION 3 . . u . a i t,6 i Before the Atomic Safety and Licensingkh,arE:Nf5 5VICI-MANCH In the Matter of k/

Philadelphia Electric Company ) Docket No. 50 !352-OLA

)

C6 r

(Iodine SPIKES)5 (Limerick Generating Station, )

Units 1 and 2) ) _~,

g N ggSl6",L.Q.'h-01 Jg CERTIFICATE OF SERVICE ' #

G I hereby certify that copies of " Licensee's Answ Opposition to Request for Hearing and Leave to Intervene by Air and Water Pollution Patrol" and Notices of Appearance for Troy B. Conner, Jr., Mark J. Wetterhahn, Robert M. Rader and Nils N. Nichols all dated May 20, 1987 in the captioned matter have been served upon the following by deposit in the United States mail this 20th day of May, 1987:

Sheldon J. Wolfe, Benjamin H. Vogler, Esq.

Chairman Counsel for NRC Staff Atomic Safety and Office of the General Licensing Board Panel Counsel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Richard F. Cole Docketing and Service Atomic Safety and Section Licensing Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Mr. Frank R. Romano Dr. Peter A. Morris 61 Forest Avenue Atomic Safety and Ambler, Pennsylvania 19002 Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 t

b .

2-

'~

Robe ~rt M. Rad 5r '

00toEIE:

USN4C UNITED STATES OF AMERICA 17 MRf 22 PS :10 NUCLEAR REGULATORY COMMISSION Je f Before the Atomic Safety and LicensidifB6ardL.EWICI.

yvunc . .

In the Matter of )

)

Philadelphia Electric Company ) Docket No. 50-352-OLA

) (Iodine Spikes)

(Limerick Generating Station, )

Unit 1) )

-NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney herewith enters an appearance on behalf of the Licensee in the captioned matter. In accordance with S2.713, 10 C.F.R. Part 2, the following information is provided:

Name -

Troy B. Conner, Jr.

Address - Conner & Wetterhahn, P.C.

Suite 1050 1747 Pennsylvania Avenue, N.W.

Washington, D.C. 20006 Telephone Number -

202/833-3500 Admission -

United States Court of Appeals District of Columbia Circuit United States Supreme Court Name of Party -

Philadelphia Electric Company Notice is further given pursuant to S2.708, 10 C.F.R. Part 2, that service upon the Licensee should be made upon the undersigned.

w

.. , - )

/ b f i f .0 f r )! v.  ? l).

Troy /B. Conner, Jr. ,,/

Dated at Washington, D.C.,

this 20th day of May, 1987.

DCLKEllE UNITED STATES OF AMERICA UWRC NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board ld 0 0FFICE 0: E d kj'd

• In the Matter of ) 00ChLlygyC Philadelphia Electric Company ) Docket No. 50-352-OLA

) (Iodine Spikes)

(Limerick Generating Station, )

Unit 1) )

NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney herewith enters an appearance on behalf of the Licensee in the captioned matter. In accordance with S2.713, 10 C.F.R. Part 2, the following information is provided:

Name -

Mark J. Wetterhahn Address - Conner & Wetterhahn, P.C.

Suite 1050 1747 Pennsylvania Avenue, N.W.

Washington, D.C. 20006 Telephone Number -

202/833-3500 Admission - United States Court of Appeals District of Columbia Circuit United States Supreme Court Name of Party - Philadelphia Electric Company r/S l

'e Marf/ J . ~ Wetterhahn Dated at Washington, D.C.,

this 20th day of May, 1987.

UNITED STATES OF AMERICA 60' KE if ?

NUCLEAR REGULATORY COMMISSION N Before the Atomic Safety and Licegingvgrd :5 09 In the Matter of ) 0FFIC. o ..*Y

) 00CKElit G A fi'VICI Philadelphia Electric Company ) Dockettf$fT0-352-OLA

) (Iodine Spikes)

(Limerick Generating Station, )

Unit 1) )

NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney herewith enters an appearance on behalf of the Licensee in the captioned matter. In accordance with S2.713, 10 C.F.R. Part 2, the following information is provided:

Name -

Robert M. Rader Address - Conner & Wetterhahn, P.C.

Suite 1050 1747 Pennsylvania Avenue, N.W.

Washington, D.C. 20006 Telephone Number -

202/833-3500 Admission -

United States Court of Appeals District of Columbia Circuit United States Supreme Court Name of Party -

Philadelphia Electric Company Rdbert M. Rader ~~

~

Dated at Washington, D.C.,

this 20th day of May, 1987.

i 1

UNITED STATES OF AMERICA f((h:

NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board '87 MY 22 P5:09 In the Matter of ) Off!"

00Chliirm X b d}Er

) BPANC" Philadelphia Electric Company ) Docket No. 50-352-OLA

) (Iodine Spikes)

(Limerick Generating Station, )

Unit 1) )

NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney herewith enters an appearance on behalf of the Licensee in the captioned matter. In accordance with S2.713, 10 C.F.R. Part 2, the following information is provided:

Name -

Nils N. Nichols Address -

Conner & Wetterhahn, P.C.

Suite 1050 1747 Pennsylvania Avenue, N.W.

Washington, D.C. 20006 Telephone Number -

202/833-3500 Admission -

West Virginia Supreme Court Name of Party -

Philadelphia Electric Company Nils P. Nichols Dated at Washington, D.C.,

this 20th day of May, 1987.

_ - _ _ _ _ _ _ _ _ _