ML13302A335
| ML13302A335 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 11/20/1979 |
| From: | Miller W NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Baskin K SOUTHERN CALIFORNIA EDISON CO. |
| References | |
| NUDOCS 7911300178 | |
| Download: ML13302A335 (3) | |
Text
DISTRIBUTION:
LPDR PDR Regulatory Docket Files (3)
LFMB Reactor Files (4)
DOCKET NOS. 50-206 N
20 1979 J. Miller, DOR 50-361 J. Berggren,, RSLB A. Burger,, ORB-2 H. Smith, ORB-2 H.,Rood, DPM Southern California Edison Comipany
. Lee, DPM ATTN: Mr. K. P. Baskin, Manager G. Diggs, SM Generation Engineering GFMB R/F (2)
.P. 0. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Gentlemen:
This is in response'to the following letters from you regarding-fees pursuant to 10 CFR 170 for review and approval of the plans referred to below:
- 1. Letter dated August 22, 1979, to the attention of Mrs. Reba M.
Diggs of my staff regarding fees for Safeguards Contingency Plan transmitted with letter dated March 23, 1979 for San Onofre Units 1, 2 and 3, a'd
- 2. Letter dated August 23, 1979, to the attention of Mr. R. A. Clark of the Office of Nuclear Reactor Regulation (ONRR) transmitting Security Force Training and Qualification Plan for San -Onofre Units 1, 2 and 3 as required by 10 CFR Parts 50 and 73.
Your August letters identified.above each included remittance of a check in the amount.of $400 for review and approval of the subject plans for San Onofre Unit 1 in lieu of the Class III fee of $4,000 for item 1 requested by us in our letter dated-July 3, 1979, and a similar fee for item 2.
The reasons.given by you were that OL review costs for-San Onofre 2 and 3 will include costs associated with-review of the two plans, and any action applicable-to San Onofre 2 and 3 will require duplicate actions for San Onofre Unit 1. Since the regulations in 10 CFR Parts 50 and 73 required
- operating plant licensees to submit the Contingency Plan by March 23, 1979, and-the Guard-Training Plan by August 23, 1979, the'priority for submittal,,
review and approval is with the operating plant and not those units at the station that are under consideration for issuance of an operating license (OL).
Consequently, your initial submittal of the plans was required for San Onofre Unit 1 as first priority rather than for Units 2 and 3 that have applications pending review for OLs.
It is our understanding tha.t the plans are site/station-specific and thus are considered to satisfy the March and August SU.RNAMRI....................
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20C FORM 318 (9-76) NRCM 0240
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GOVERNMENT PRINTING OFFICE: 1978 -265 7119 77//300/o!727
Southern California Edison
- 2 Company NOV 20 1979 1979 requirements for Unit 1, as well as-satisfying the OL application requirements for Units 2 and 3., Since the initial ONRR staff review time is required for-Unit 1, the time is not charged to the OL review costs for Units 2 and 3.
Also, the duplicate provision of 10 CFR 170.22 applies to applications for license amendments and, as such, should not be construed to include those matters that are under review in the context of construction permits or operating licenses. Once there is at least one essentially identical additionol operating unit at the San Onofre Station, applications for license.amendments or approvals for the two or more operating units which are received at the same time would qualify for the duplicate amendment for each second, thirdand other,units.
Even then, site-specific plans which require nRC review and approval but do not require a parallel.review for each unit at thatsite-re subject to the fees of 10 CFR 170.22.
The fee schedule under 10 CFR 170.22 was established basedon average costs for various types of actions using the manpower data forl Fa 1977. It is recognized that some actions such as physical security plans for multiple unit stations are site-specific and require minimal duplicate staff effort while other types of actions for multiple unit stations require considerable unite-specific staff effort. In these situations, the $400 duplicate amendment fee might appear excessive-for reviews such as Safeguards Contingency Plans and Guard Training, but for many other types of actions it does not.cover the costs associated with the duplicate unit effort.
Based on the above discussions, the two $400 duplicate fees are-not appropriate for your Safeguards Contingency and Guard Training Plans for San Onofre Unit 1.
Therefore, it is requested that an additional sum of $7,200 be submitted to this office within fifteen days of your receipt of this letter. This would bring your payment to the Class III fee level of $4,000 for each plan's review and approval.
Sincerely, William 0..Miller, Chief License Fee Management Branch Office of Administration AI CERTIFIED MAIL RETURN RECILT REQUETED soC LFMB:ADM--tLFMB:-ADM.-
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