ML13310A745
| ML13310A745 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/04/1982 |
| From: | Baskin K Southern California Edison Co |
| To: | Miller W Office of Administration |
| References | |
| NUDOCS 8210260249 | |
| Download: ML13310A745 (1) | |
Text
-"-.0 Southern California Edison Company P. 0. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD, CALIFORNIA 91770 K. P. BASKIN TELEPHONE MANAGER OF NUCLEAR ENGINEERING, (213) 572-1401 SAFETY, AND LICENSING October 4, 1982 Director, Office of Nuclear Reactor Regulation Attention: William 0. Miller, Chief License Fee Management Branch Office of Administration U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Gentlemen:
Subject:
Docket No. 50-206 Amendment No. 106 San Onofre Nuclear Generating Station Unit 1 By letter dated September 23, 1982, we were notified that our determination that no fees were required for processing the subject amendment (issued as NRC Amendment No. 62 by letter dated August 25, 1982) was not acceptable. It was therefore requested that we submit $1,200 necessary for a Class II change. That amendment application requested a clarification of the required surveillance interval for performance of Safety Injection System (SIS) hydraulic valve testing. The surveillance program was included as part of previously issued Amendment No. 57 for which appropriate fees were submitted. This letter provides additional information supporting our position that additional fees are not required.
The change incorporated into the Technical Specifications as a result of the subject Amendment should not be subjected to Class II fees
($1,200) pursuant to 10 CFR 170.22 due to the nature of and reason for the change. The surveillance interval specified in Amendment No. 57 was never intended nor interpreted to require the station to heat up from mode 5 or 6 operation for the purpose of performing the 92 day interval test which requires mode 3 or 4 operating conditions. This is clearly illustrated by the fact that the subject SIS valves are not required to be operable in mode 5 or 6; and therefore, surveillance is not required. However, in order to assure proper interpretation by members of the Office of Inspection and Enforcement, a clarification of the requirement was deemed necessary. The change was not required due to our not being cognizant of this issue, but rather to assure proper interpretation. Therefore, we respectfully request that you revise your determination that a Class II fee is required.
If you have any questions in this matter or require further clarification, please contact me.
Very truly yours, 8 2 10260P49 821004 -