ML19256F611
| ML19256F611 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 12/10/1979 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7912190562 | |
| Download: ML19256F611 (2) | |
Text
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0 Wisconsin Electnc eaara coupasr 231 W. MICHIGAN, P.O. BOX 2046, MILWAUKEE, wl 53201 December 10, 1979 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. NUCLEAR REGULATORY COMMISSION Washington, D. C.
20555 Attention: Mr. William 0. Miller, Chief License Fee Management Branch Gentlemen:
DOCKET NOS. 50-266 AND 50-301 LICENSE AMENDMENT FEES TECHNICAL SPECIFICATI0tl CHAi4GE REQUEST NO. 59 P0lHT BEACH NUCLEAR PLANT UNITS 1 AND 2 We have received your letter dated November 13, 1979 regarding license amendment approval fees for the Technical Specification Changes we requested with our letter dated July 10, 1979. The proposed changes involve qualification requirements for the position of Radiation Protection Manager (RPM).
You will recall, that these changes were originally requested by the NRC in letters dated February 24 and September 2,1977 and April 19, 1978, in order to document the level of competence described in NRC Regulatory Guide 1.8 for the RPM position. We have objected to such a Technical Specification change on the basis that it is not needed as described in our correspondence dated October 23,1975, April 28 and October 13, 1977, and June 30, 1978. Nevertheless, after several conversations with menbers of your Staff, we complied with the Staff request and submitted a Technical Specification change request regarding RPM quali fications.
We consider that a license amendment fee is not appropriate for this Technical Specification change.
In your Noventer 13 letter, you rejected this determination on the basis that the application involves consideration of a single safety issue. We do not agree that this change in qualification require-ments for the Radiation Protection Manager is necessarily a safety issue.
Nevertheless, this license amendment should still remain exempt from fees under the provision of Footnote 2 of Section 170.22A, since the footnote is applicable to Class III, as well as Class I and II amendments. We maintain that this amendment request was submitted for the convenience of the Commission to clarify the existing Technical Specifications. Ve trust that your reconsideration of this issue will sustain our argument.
1626 048 Y j912,100 6 6 2
Mr. Harold R. Denton, Director December 10, 1979 Should you continue to maintain that an approval fee for this license amendment approval is mandatory, we would offer the following alternative. We believe that these RPM qualification requirements are not strictly required for absolute compliance with the Commission regulatiuns. These changes were proposed at the request of NRC Staff in order to document the level of competence visualized by NRC Regulatory Guide 1.8, Revision 1, although compliance with Regulatory Guide positions is not required by the Regulations. We have proposed a basis for the acceptability of our present Technical Specification qualification commitment in past correspondence. We believe our present requirements for the RPM position satisfy the intent of the Regulatory Guide position. Since the continued safe operation of the plant and the protection of the public healtn and safety would be unaffected by these proposed changes, we would be willing, at your option, to withdraw this license amndment mquest.
Very truly yours, C. W. Fay, Director Nuclear Power Department 1626 049