ML19208D292
| ML19208D292 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 09/24/1979 |
| From: | Vandenburgh D YANKEE ATOMIC ELECTRIC CO. |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| WYR-79-108, NUDOCS 7909280203 | |
| Download: ML19208D292 (3) | |
Text
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Proposed Change No. 167 Telephone 617 366-9011 TWX 710-390-0739 YANKEE ATOMIC ELECTRIC COMPANY
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September 24, 1979 United States Nuclear Regulatory Commission Washington, D.C.
20555 Attention: Office of Nuclear Reactor Regulation
Reference:
a) License No. DPR-3 (Docket No. 50-29) b) USNRC Letter to YAEC dated July 23, 1979
Dear Sir:
Pursuant to the request for a license amendment delineated in Reference b) and Section 50.59 of the Commission's Rules and Regulations, the Yankee Atomic Electric Company hereby requests the authorization to make the following changes:
PROPOSED CHANGE: Reference is made to Yankee Rowe Operating License No.
DPR-3 We propose to modify the license as follows:
a.
Delete from Appendix A, Technical Specifications, Specification and Bases 3/4.7.1.6 S=condary Water Chemistry, pages 3/4 7-10, 3/4 7-11, 3/4 7-12 and B 3/4/ 7-3 b.
Add Section 2.C(5) Secondary Water Chemistry !!onitoring The licensee shall maintain a secondary water chemistry monitoring program to inhibit steam generator tube degradation. This program shall include:
(a)
Identification of a sampling schedule for the critical parameters and limits for these parameters; (b)
Identification of the procedures used to quantify parameters that have critical limits; (c)
Identification of process sampling points; (d)
Procedures for the recording and management of data; (e)
Procedures defining corrective actions for off normal chemistry conditions; and (f) A procedure identifying the authority responsible for the interpretation of the data, and the sequence and timing of administrative events required to initiate corrective action.
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United States Nuclear Rcgulatory Commission September 24, 1979 Attention: Office of Nuclear Reactor Regulation Page 2 REASON FOR CHANGE: This proposed change will incorporate into the Yankee Rowe Operating License, and License Condition requested in Reference b).
BASIS: The above described proposed change would provide assurance that the licensee would devote proper attention to controlling secondary water chemistry, while also providing the needed flexibility to more effectively deal with any off-normal conditions that might arise.
SAFETY CONDITIONS: This proposed change does not present any hazard considerations not described or implied in the license application as amended.
This proposed change has been reviewed by the Nuclear Safety Audit and Review Committee.
FEE DETERMINATION:
Reference (b) requests that a Class III fee be submitted with this amendment application. YAEC takes exception to that request for the following reasons.
It is Yankee's position that this submittal clearly falls into that category of amendment described under footnote 2 of 10 CFR 170.22 which states:
" Class I, II or III amendments which result from a written Commission request for the application may be exempt from f'?s when the amendment is to simplify or clarify license or technical specifications; the amendment has only minor safety significance and is issued for the convenience of the Commission."
Yankee feels that the fee exemption should apply for two reasons:
1.
The license conditions, when incorporated into the Yankee Rowe operating license, will do nothing more than define requirements for a secondary water chemistry monitoring program similar to the program which has been in effect at Yankee Rowe since it first went to operation in 1960.
It is precisely for this reason that we feel that the amendment when issued will be strictly for license clarification purposes, and for the convenience of the Commission only, as the addition of words describing program requirements will neither add or detract from the program currently being implemented.
2.
In addition to the above, Yankee feels that any fee charged for an amendment review should be commensurate with the manpower allocation which was necessary to perform that review, and as in this case no tcchaical review was or will be necessary, then no fee should be imposed. For the above reasons, no fee is submitted with this license amendment request.
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United States Nuclear Regulatory Commission September 24, 1979 Attention: Office of Nuclear Reactor Regulation Page 3 SCHEDULE OF CHANGE: The Yankee Rowe Operating License will be amended immediately upon Commission approval.
Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY D. E. Vandenburgh Senior Vice President COMMONWELATH OF MASSACHUSETTS)
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COUNTY OF WORCESTER
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Then personally appeared before me, D. E. Vandenburgh, who, being duly sworn, did state that he is a Senior Vice President of Yankee Atomic Electric Company, that he is duly authorized to file, execute and sign the foregoing request in the name and on the behalf of Yankee Atomic Electric Company, and that the statements therein are true to the best of his knowledge and belief, w
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Robert H. Groce Notary Public
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My Commission Expires September 14, 1984 V
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