ML20064D025
| ML20064D025 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 10/17/1978 |
| From: | David Williams ARKANSAS POWER & LIGHT CO. |
| To: | Miller W NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| 2-108-10, NUDOCS 7810310075 | |
| Download: ML20064D025 (2) | |
Text
.. f H ELPIN G BUILO A R KA N B A B ARK ANS AS POWER S LIGHT COMPANY l
90 SQx 551 YTTLE AoCX, A AM ANS AS 72203 850U 371 -4000 Y
October 17, 1978 2-108-10 Director of Office of Administration ATTN:
William O.
Miller, Chief License Fee Management Branch U.
S.
Nuclear Regulatory Commission Washington, D.
C.
20555
Subject:
Arkansas N-er On Unit Two Docket No 50-368 License No NPF-6 License Ame ent ee (File: 2-1510)
Gentlemen:
In response to your letter of September 29, 1978, on the above subject, the following is provided.
j From a/ October 20, 1978 telecon (between your Reba Diggs and our Ted Enos), we understand that your letter indicated in-correctly that your evaluation of class determination was not complete.
We now understand your evaluation is complete and that your final determination indicated the subject amendment should be a class III amendment.
According to 10CFR 170, a Class III amendment must involve the review of a single safety issue.
The bases for specification 3.h.1 clearly indicates that the purpose of the Specification is to assure adequate heat removal (decay heat removal in modes 3,h, and 5).
If csre heat removal was not necessary, none of the bases presented in the technical specification vould be applicable.
Therefore, until such time as the reactor has been initially made critical, the bases for Specification 3.h.1 indicates that the specification serves no purpose.
g RECEIVED BY J.FM,8
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I, 2-108-10 Mr. William O.
Miller October 17, 1978 fu We therefore conclude that the relief granted to Specifi-cation 3.k.1 did not involve the review of.a safety issue as
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it did noi deviate from the intent of the specification, or the bayes, but merely altered requirements for a mode of operation not specifically covered by existing specifica-tions and permitted the licensee to perform repairs in a safer mapaor than allowed under the more generalized require-ments.
It is therefore, only administrative in nature.
Therefore, we do not agree with your determination that the subject Amendment was a Class III amendment as outlined in 10CFR 170.
We believe our original determination of amendment Class II is correct as no safety issue was involved.
Following review of the above information, if you do not concur f
with our determination of classification, please proeide a basis for your determination so we may better understand how it was made and avoid future confusion on license fees.
Ve truly yours, h yt Daniel H. Williams Manager, Licensing DHW/JTE/ev
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