ML17229A730

Requests Waiver of Insp Fees for Pilot Fire Protection Functional Insp Conducted at St Lucie Plant.Basis for Util Request,Explained

ML17229A730
Person / Time
Site:	Saint Lucie
Issue date:	05/12/1998
From:	Stall J FLORIDA POWER & LIGHT CO.
To:	Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
References
50-335-98-201, 50-389-98-201, L-98-127, NUDOCS 9805220088
Download: ML17229A730 (4)

Text

CATEGORY REGULATORY INFORMATION DISTRIBUTI SYSTEM (RIDS)

ACCESSION NBR:9805220088 DOC.DATE: 98/05/12 NOTARIZED: NO DOCKET FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power & Light Co. 05000335 50-399 St. Lucie Plant, Unit 2, Florida Power E Light Co. 05000389 AUTH.NAME AUTHOR AFFILIATION STALL,J.A. Florida Power 6 Light Co.

RECIP.NAME RECIPIENT AFFILIATION CALLAN,L.J. Ofc of the Executive Director for Operations

SUBJECT:

Requests waiver of insp fees for pilot fire protection functional insp conducted at St Lucie Plant. Basis for util C request, explained.

DISTRIBUTION CODE: IE01D COPIES RECEIVED: LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-3 PD GLEAVESFW 0 INTERNAL: ACRS AEOD/SPD/RAB 1 R

DEDRO '1 PILE CENTE NRR/DRCH/HHFB 1 PM/PECB NRR/DRPM/PERB 1 NUDOCS-ABSTRACT OE DIR 1 OGC/HDS3 RGN2 FILE 01 1 EXTERNAL: LITCO BRYCE,J H NOAC NRC PDR NUDOCS PULLTEXT D

U E

N NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL

Florida Power 8t Light Ccmptiny.6351 S. Ocean Drive, Jensen Beach, FL34957 May 12, 1998 APL L-98-127 10 CFR 170.5 10 CFR 170.21 L. Joseph Callan Executive Director for Operations U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 RE: St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Inspection Report 98-201 Request for Waiver of Inspection Fees for Pilot Fire Protection Functional Ins ection

Dear Mr. Callan:

Florida Power & Light Company (FPL) respectfully requests a waiver of inspection fees for the NRC Region II pilot Fire Protection Functional Inspection (FPFI) conducted at St. Lucie Plant.

The basis for this request is explained below.

The NRC user fee regulations at 10 CFR Part 170 state that fees will not be assessed against licensees for requests/reports submitted to the NRC to assist the NRC "as a means of exchanging information between industry organizations and the NRC for the purpose of supporting generic regulatory improvements or efforts." 10 CFR 170.21.J..endnote (4).

As stated in a September 16, 1997 memorandum from S. J. Collins (Director, Office of Nuclear Reactor Regulation) to R. M. Scroggins (Office of the Controller), the primary purpose of the pilot FPFI inspections "is to test the draft FPFI procedure and to identify the need for any revisions before the procedure is incorporated into the reactor inspection program." The pilot FPFI therefore meets the criteria in Part 170 for a waiver of fees in that (1) the pilot FPFI effort

(

will assist the NRC in developing a generic fire protection inspection methodology, (2) the pilot FPFI represents an exchange of information between power reactor licensees inspected and NRC that could affect licensees other than those inspected in the pilot program, and (3) the pilot FPFI will provide a generic improvement to NRC's fire protection inspection'activities.

'rr805220088 9805i2 PDR ADOCK 05000335 8 PDR an FPL Group company

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-127 Page 2 This conclusion is also consistent with the position stated in a February 28, 1992 letter from R. M. Scroggins to W. H. Rasin (Nuclear Management and Resources Council) that waiver of inspection fees for pilot team inspections are appropriate because the inspections "are conducted to assist in the development of the NRC inspection program and represent trial runs of newly developed inspection procedures." While that letter applies to FY 1992, the underlying considerations remain valid and apply fully to the pilot FPFI conducted at St. Lucie.

Accordingly, FPL respectfully submits that the pilot FPFI at St. Lucie meets the criteria in 10 CFR Part 170 for a waiver of inspection fees.

Please contact us if there are any questions about this request.

Very truly yours, J. A. Stall Vice President St. Lucie Plant JAS/GRM cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St. Lucie Plant