ML20205T668
| ML20205T668 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 03/27/1987 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8704070358 | |
| Download: ML20205T668 (8) | |
Text
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. DUKE POWER GOMPANY P.O. DOK 33180 -
CHARLOTTE, N.O. 28242 HAL B. TUCKER N8NO" v303 Pats 5 DENT NUGLEAR PROst%f3Off March 27, 1987 U.'S. Nuclear Regulatory Commission Attention: Doctsment Control Desk Washington, D. C. 20555
Subject:
Catawba Nuclear Station Docket Nos. 50-413 and 50-414
Dear Sir:
By letter dated January 30,1987 (Attachment 1), the NRC requested that Duke Power Company (Duke) remit additional licensing fees in the amount of $4 150. The 3
requested fees were related to the Staff's review of the Inservice Test (IST)
Program for Pumps and Valves for Catawba Unita 1 and 2.
After reviewing this request, the referenced submittals, the Catawba SER and Supplements and the operating licenses for the Catawba units, it is our conclusion that the fee schedules of 10 CFR 170 were incorrectly applied.
The IST program for Catawba Unit I was submitted on March 9, 1983 in conjunction with the NRC Staff's review of Duke's application for an operating license. ' As -
discussed in Supplement 2 to the Catawba SER (Attachment 2), the Staff conducted a preliminary review of the IST program and conditionally granted the relief requests until such time as the Staff completed its review (See attached FOL NPF-24, License Condition 4; FOL NPF-31, License Condition 5; and FOL NPF-35, License Condition 5).
The IST program for Catawba Units 1 and 2 was approved on January 8, 1987 (Attachment 6).
As can be seen, the IST program for Catawba Unit I was submitted nearly two years j
prior to issuance of the full power license, allowing ample opportunity for NRC.
Staff review. If review of the IST program had been completed prior to issuance of the full power license the review fee'would have been included.in the operating 1
license fee pursuant to 10 CFR 170.21. By delaying the review of the Catawba Unit j
1 IST program until well after issuance of the-full power license, the Staff is in j
effect circumventing the ceiling fee for an operating license review. Such a j
situation is understandable when resolution of an issue is deferred until after issuance of the operating license because additional analyses or input is required from an applicant / licensee. In a situation, such as discussed above, where no
]
further input is required from the applicant / licensee, it seems inappropriate for-i the NRC to collect additional fees that have resulted solely from NRC Staff inability to complete the review in a timely manner.
1 I
Review of our files also indicates that on January 9, 1985 Duke was requested to j
remit a $150. application fee following the submittal of Revisions 2 and 3 to_the Unit 1 IST program (Attachment 7).
On January 15, 1985, Duke responded (Attachment j
- 8) by noting that Revisions 2 and 3 transmitted no new material from that previously submitted on March 9,1983.
However, the application for was subsequently paid on January 22,1985 (Attachment 9).
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i U. S. Nucisar Rigulctory Commicaica February 24, 1987 Page 2 A review of recent invoices received from the NRC indicates that, as of November 4, 1986, Duke had been billed (Attachment 10) an additional $25,108. for review of the IST program on Catawba Unit 1.
Since the IST Program was approved on January 8, 1987, it is expected that additional fees will be billed.
In the case of Catawba Unit 2, the IST program was submitted as a follow on to the Unit 1 program on October 25, 1985. The low power license for Catawba Unit 2 (NPF-48) was issued on February 24, 1986.
Since submittal of the IST program did not constitute an amendment request or required approval for an existing license, no application fee was required by 10 CFR 170.21.
It is therefore Duka's conclusion that the NRC's request for a license amendment fee of $4,000. to cover the cost of the review of the Catawba Unit 1 IST program is inappropriate since the requested fee is applicable to license amendments, and Catawba Unit I had not been licensed at that time.
Furthermore, fees for review of the IST program should have been included in the operating license fee, for which Duke paid the maximum $3,077,400. fee.
Further, the $150. application fee requested for review of the Catawba Unit 2 IST program was inappropriate and a moot point since the review is already complete.
Therefore, pursuant to 10 CFR 170.51, it is requested that the NRC's request for additional fees dated January 30, 1987 be rescinded.
Furthermore, the $150.
application fee which was remitted on January 22, 1985 along with the $25,108.
previously invoiced and paid should be refunded or credited to Catawba Unit 1.
Very truly yours, d
Y Hal B. Tucker ROS/07/sbn Attachments xc:
Dr. J. Nelson Grace, Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Dr. K. Jabbour Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Cornission Washington, D. C.
20555 Mr. P. K. Van Doorn NRC Resident Inspector Catawba Nuclear Station
ATTACHMENT 1
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UNITED STATES o
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ATTN: Mr. Hal B. Tucker, Vice President *%'
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P.O. Box 33189 422 South Church Street Charlotte, NC 28242 Gentlemen:
By letter dated March 9,1983, your Company submitted to the Office of Nuclear Reactor Regulation (0NRR) for review the Inservice Test (IST)
Program for Pumps and Valves for the Catawba Nuclear Station Unit No.1.
Fees pursuant to 10 CFR 170.22 of the March 23, 1978 regulations were not remitted with this request.
Based on information provided by the ONRR staff as the result of their preliminary review of your March 9 submittal, it has been determined that a Class III fee is appropriate since the review will involve consideration of a single safety issue. Therefore, your Company is requested to remit the sum of $4,000 to this office for the March 9 submittal.
If the ONRR staff's final review of your IST Program for Pumps and Valves reveals that this fee is not appropriate, you will be notified and any necessary adjustments will be made.
By letter dated October 25, 1985, your Company submitted the IST Program for Pumps and Valves for Catawba Nuclear Station Unit No. 2.
Since this submittal was filed after June 20, 1984, it is subject to the fee provisions of the revised 10 CFR 170 which became effective on June 20, 1984. Therefore, your Company is requested to remit the required appliation fee af $150 for thie submittel. Year *^cmpary.c','1 50 bil bd for any additional review costs in accordance with 10 CFR 170.12(c) and 170.21.
In sumary, your Company is requested to remit a total of $4,150 to this office.
Sincerely, f
Reba M. Diggs Facilities Program Coordinator License Fee Management Branch Division of Accounting and Finance Office of Resource Management nth)M y
'f ATTACHMENT 2 The staff has not completed a detailed review of the applicant's submittals; however, on the basis of its preliminary review, the staf f finds that the general approach of using the EPRI test results to demonstrate operability of the safety valves, PORVs, and PORV block valves is acceptable.
The applicant's submittal notes that Catawba Units 1 and 2 use safety valves, PORVs, and PORV block valves of essentially the same size and model that performed satisfac-torily for test sequences considered representative or that bound conditions that Catawba Units 1 and 2 valves could be exposed to.
On the basis of its preliminary review, the staff has concluded that the appli-cant's general approach to responding to this TMI item is acceptable and pro-vides adequate assurance that Catawba Units 1 and 2 reactor coolant system over-pressure protection systems can adequately perform their intended functions for the period during which the staff completes its detailed review.
If the comple-tion of the detailed review reveals that modifications or adjustments to safety valves, PORVs, PORV block valves, or associated piping are needed to ensure that all intended design margins are present, the staff will require that the appli-cant make appropriate modifications.
3.9.6 Inservice Testing of Pumps and Valves In the SER, the staff stated that the applicant had not yet submitted a program for inservice testing of pumps and valves and, therefore, the staff had not completed its review.
The applicant has submitted by letter dated March 9, 1983, an inservice testing program for pumps and valves.
The applicant has stated that the preservice and inservice testing program will meet the requirements of 10 CFR 50.55a(g), including the 1980 Edition of the ASME Boiler and Pressure Vessel Code,Section XI through the Winter 1980 Addenda. The applicant requested relief from these Code requirements pursuant to 10 CFR 50.55a(g)(5)(iii) for certain pump and valve tests.
[Atthistime,thestaffhasnotcompleteditsdetailedreviewoftheapplicant's submittal.
However, the staff has evaluated the applicant's request for relief.
On the basis of its review, the staff finds that it is impractical within the limitations of design, geometry, and accessibility for the applicant to meet certain of the ASME Code requirements.
Imposition of these requirements would, in the staff's view, result in hardships or unusual difficulties without a i
compensating increase in the level of quality or safety.
Therefore, pursuant to 10 CFR 50.55a(g)(6)(i), the staff believes that the relief that the appli-cant has requested from the pump and valve testing requirements of the 1980 Edition of ASME Section XI through the Winter 1980 Addenda should be granted for a period of no longer than 2 years from the date an operating license is issued or until the staff's detailed review has been completed, whichever comes first.
The staff, therefore, will condition the license to reflect the above discussion.
If completion of the staff's review results in additional testing requirements, the staff will require that the applicant comply with 1em.
8 0
Catawba SSER 2 3-11
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NPF-24 ATTACHMENT 3 (g)
T.S. 3.8.1.2.b. and A.C. Sources - Shutdown - OPERABLE 4.8.1.2 diesel generator not required.
(3) Antitrust Conditions Duke Power Company shall comply with the antitrust conditions delineated in Appendix C to this license.
(4) Inservice Testing of Pumps and Valves (Section 3.9.6, SSER #2)*
Pursuant to 10 CFR Part 50.55a and for the reasons set forth in Section 3.9.6 of SSER #2, the relief identified in the submittal dated March 9, 1983, that Duke Power Company has requested from the pump and valve testing (requirements of 10 CFR Part 50, Section 50.55a(g)(3) and (g)(4) 1) is granted for that portion of the initial 120-month period during which the staff completes it review.
(5) Inservice Inspection Program (Sections 5.2.4 and 6.6, SSER #2)
Within six months of the date of this license, Duke Power Company i
shall submit the inservice inspection program for staff review and approval.
(6)
Initial Startup Test Program (Section 14, SER, SSER #3)
Duke Power Company shall conduct those aspects of the post-fuel-loading initial test program described in Chapter 14 of the FSAR, as amended, which are consistent with the limits of this license without making any major modifications unless such modifi-cations have prior NRC approval. Major modifications are defined as:
(a) elimination of any safety-related test; (b) modification of objectives, test method, or acceptance criteria for any safety-related test **;
I
- The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.
- Safety-related tests are those tests which verify the design, construction and operation of safety-related systems, structures, and equipment.
V NPF-31 ATTACHMENT 4 O ~
(4) Antitrust Conditions Duke Power Company shall comply with the antitrust conditions delineated in Appendix C to this license.
(5)
Inservice Testing of Pumps and Valves (Section 3.9.6, SSER #2)
Pursuant to 10 CFR Part 50.55a and for the reasons set forth in Section 3.9.6 of SSER #2, the relief identified in the submittal dated March 9, 1983, July 10, 13, 18, 23, 27, October 1, and November 6, 1984, that Duke Power Company has requested from the pump and valve testing requirements of 10 CFR Part 50, Section 50.55a(g)(3) and (g)(4)(1) is granted for that portion of the initial 120-month period until the staff completes its review or until December 1,1986, whichever is earlier.
(6) Inservice Inspection Program (Sections 5.2.4 and 6.6, SSER #2)
By January 18, 1985, Duke Power Company shall submit the inservice inspection program for staff review and approval.
(7) Environmental Equioment Oualification (Section 3.11, SER, SSER #3, SSER e4)
Prior to March 31, 1985, Duke Power Company shall environmentally qualify all electrical equipment as required by 10 CFR 50.49.
(8) Fire Protection Program (Section 9.5.1, SER, SSER #1, SSER #2, SSER 73, SSER #4)
(a) Duke Power Company shall maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility through Revision 11 and as approved in the SER through Supplement 4, subject to provisions b & c below.
(b) Duke Power Company may make no change to features of the approved fire protection program which would decrease the level of fire protection in the plant without prior approval of the Commission. To make such a change Duke Power Company must submit an application for license amendment pursuant to 10 CFR 50.90.
(c) Duke Power Company may make changes to features of the approved fire protection program which do not decrease the level of fire protection without prior Commission approval, provided:
(1) sucn changes do not otherwise involve a change in a
NPF-35 ATTACHMENT 5 (4) Antitrust Conditions Duke Power Company shall comply with the antitrust conditions delineated in Appendix C to this license'.
(5) Inservice Testina of Pumps and Valves (Section 3.9.6, SSER #2, SSER F4)
Pursuant to 10 CFR Part 50.55a and for the reasons set forth in Section 3.9.6 of SSER #2, the relief identified in the submittals dated March 9,1983, July 10,13,18, 23, 27, October 1, and November 6, 1984, that Duke Power Company has requested from the pump and valve testing requirements of 10 CFR Part 50, Section 50.55a(g)(3) and (g)(4)(i) is granted for that portion of the initial 120-month period until the staff comoletes its review or until December 1,1986, whichever is earlier.
(6)
Inservice Inspection Proaram (Sections 5.2.4 and 6.6, SSER #2*)
By May 31, 1985, Duke Power Company shall submit the balance of the inservice inspection program as described in its letter dated January 8,1985, for staff review and apprcval.
(7) Environmental Eouinment Qualification (Section 3.11, SER, SSER #3, SSER #4)
Prior to March 31, 1985, Duke Power Company shall environmentally qualify all electrical equipment as required by 10 CFD 50.49.
(8) Fire Protection Program (Section 9.5.1, SER, SSER #1, SSER #2, 55ER 73, SSEP FA)
(a) Duke Power Company shall maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility through Pevision 11 and as approved in the SER through Supplement 4, subject to provisions b & c below.
(b) Duke Power Company may make no change to features of the approved fire protection progran which would decrease the level of fire protection in the plant without prior approval of the Commission.
To make such a change Duke Power Ccmpany must submit an aoplication for license amendment pursuant to 10 CFR 50.90.
Ici Duke Power Company may make changes to featuras of the approved fire protec*.f on program which do not decrease the level of fire protection without prior Commission approval, provided:
- Safety evaluation attached to D. Eisenhut letter dated January 17, 1985.
To be incorporated in SSER #5
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ATTACHMENT 6
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UNITED STATES
~t NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 i
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1987 9
Docket Nos.:
50-413
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'M 1 5 1937 Mr. H. B. Tucker, Vice President i
Nuclear Production Department
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U C *ser Duke Power Ccmpany 422 South Church Street Charlotte, North Carolina 28242
Dear Mr. Tucker:
Subject:
Transmittal of Safety Evaluation Report and Technical Evaluation Report Regarding Pump and Valve Inservice Testing Program -
Catawba Nuclear Station, Units 1 and 2 By letters dated March 9,1983, and October 25, 1985, you requested Code re-lief from the pump and valve testing requirements of 10 CFR Part 50, Section 50.55a(g)(3) and (g)(4)(1) for Catawba Nuclear Station, Units 1 and 2, respectively. Additional submittals revised your initial inservice testing (IST) program for Unit 1 up to Revision 12 and for Unit 2 up to Revision 3.
This relief was granted for Unit I until December 1,1086, by Facility Operating 1.icense NPF-35.
Based on the enclosed safety evaluation reg. ort (SER) and technical evaluation report (TER), the staff finds your IST programs and eccompanying requests for relief acceptable with exceptions. We have sumarized the exceptions in the enclosed SER. The basis for our conclusions is provided in the enclosed SER and the associated TER dated November 1986.
The Comission staff has reviewed your requests for relief pursuant to 10 CFP 50.55a(g)(6)(1). Such relief is hereby granted. Our review has deter-mined that the Code requirements for the components specified in your submittals (with exceptions listed in our SER) are impractical and tFe grarting of the re-lief is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest, given due consideration to the burden upon the licensee that could result if the require-m nts were imposed on the facility.
Sincerely, 1
{}.LLW.
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Yo ngblood, Director PWR Proj ct Directorate #4
_[ h Divisio of PWR Licensing-A
Enclosures:
As stated cc: See next page
l Safety Evaluation Report Pump and Valve Inservice Testing Program Catawba fluclear Station, Units 1 and 2 Docket hos. 50-413 ard 50-414 1.0 Introduction By letter dated f4 arch 9,1983, Duke Power Company (the licensee) submitted its first ten-year Inservice Testing (IST) Program on pumps and valves for Catawba Nuclear Station, Unit 1.
By letters dated July 10, 13, 18, 23, 27, October 1, Decreber 17, 1984, February 15, March 29, September 5, November 27, 1985, and March 3,1986, the licensee submitted Revisions 1 through 12 to Unit 1 IST program. A November 6, 1984, submittal supplemented revisions 2 and 3 submitted on July 13 and 18,1984, by identifying additional changes.
Similarly, by letter dated October 25, 1985, the licensee submitted an IST program for Catwba Unit 2 pumps and valves.
By letters dated November 27, 1985, March 3, and June 23, 198f, the licensee submitted Revisions 1 through 3 to Unit 2 IST program.
Section 50.55a, " Codes and Standards," of 10 CFR Part 50 requires, in part, that certain safety-related pumps and valves meet the reouirements of Section XI of the American Society of idechanical Engineers (ASME)
Boiler and Pressure Vessel Code (hereafter "the Code").
Pursuant to 10 CFR 50.55a(g)(5)(iii) the licensee has requested relief from some of the testing requirements of Section XI of the ASME Code for certain purps and valves that he has detennined are impractical to test.
It should be noted that any additional requests for relief submitted by the licensee after the revisions noted above should ict be implemented by the licensee prior to NRC review and approval.
The flRC consultant, EG&G Idaho, Inc., has reviewed the licensee's IST program (through Revision 12 for Unit 1 and Revision 3 for Unit 2) and associatea requests for specific reliefs frem the ASME Code,Section XI, and prepared the attached Technical Evaluation Report of the licensee's IST program for the Catawba Nuclear Station, Units 1 and 2.
The staff has reviewed the evaluation and concurs in its bases and findings. The results of the review are provided below, y 1(,lY.t_ ) {'l Aa l t
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WASHINGTON. D.C. 20555 Ta I
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Docket No. 50-413 Duke Power Company ATTN: Mr. Hal B. Tucker, Vice President Nuclear Production Post Office Box 33189 422 South Church Street Charlotte, North Carolina 28242 Gentlemen:
We have received copies of the following applications which were filed with the Office of Nuclear Reactor Regulation (0NRR) for review in connection with the Catawba Nuclear Station Unit No.1.
Fees pursuant to 10 CFR 170 were not remitted with these applications.
i 1.
July 13 and 18, 1984 letters, as revised November 6, 1984, which transmitted Revisions 2 and 3 to the Pump and Valve Inservice Testing Program and requested relief from certain ASME Code requirements.
2.
A November 21,1984 transmittal relating to Internal Corrosion Protection for Fuel Oil Storage Tanks.
3.
A December 17, 1984 transmittal relating to changes to the post-fuel-loading initial test program described in Chapter 14 of the Final Safety Analysis Report.
Since your applications were filed after the June 20, 1984 effective date of the revision to 10 CFR 170 on fees and require NRC review and approval they are subject to the provisions of the revised rule. This rule requires licensees to remit an application fee of $150 with each application for license amendment, relief, exemption and other request.
Therefore, it is requested that your Company remit the required application fees of
$450 for these requests. Your Company will be billed for any additional costs for the review of ynne anplicatinns in accorta.?,r.a. witA 1.Il GD.
170.12(c)and170.21.
t Sincerely, n
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N Reba M. Diggs v
Facilities Program Coordinator License Fee Management Branch Office of Administration vij%yf %
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ATTACHMENT 8 DUKE Po#ER GOMPANY P.O. DOX 33180 CIIARLOTTE N.C. 28242 ILO. B. TUCKER m.p.r soewv TELEPHONE (704) 073-4531
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January 15, 1985 Ms. Patricia G. Norry, Director Office of Administration U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Attention: Ms. Reba M. Diggs License Fee Management Branch Re: Catawba Nuclear Station, Unit 1 Docket No. 50-413
Dear Ms. Norry:
In response to Ms. Diggs letter of January 9, 1985 please find attached a check in the amount of $300.00.
The applicat. ion fee for item 1 concerning our November 6,1984 letter which retransmitted revisions 2 and 3'to the IWV/IWP Inservice. Testing Program should not have been included. This letter transmitted revisions to our program which was originally submitted for NRR's review and approval on March 9, 1983.
Thus, this letter transmitted no new material and the material that was transmitted was to be incorporated into our previously transmitted progra::r. The IWP/IWV program is part of the Operating License Application and the fee for its reviews should be included in the fee for the Operating License Application for Catawba, Unit 1.
Very truly yours, O
/g Hal B. Tucker RWO: sib Attachment Mr. James P. O'Reilly, Regional Administrator cc:
U. S. Nuclear Regulatory Coc: mission Region II 101 Marietta Street, NW, Suite 29'J0 Atlanta, Georgia 30023 h1C Resident Inspector Catawba Nuclear Station h~
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e ATTACHMENT 9 DUKE POWER GOMP.OT P.O. DOX 33189 CHARLOTTE. N.C. 28242 iud.B. TUCKER vics..esment TELEPHO.YE (704) 373-4331
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January 22, 1985 Ms. Patricia G. Norry, Director Office of Administration U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Attention: Ms. Reba M. Diggs License Fee Management Branch Re: Catawba Nuclear Station, Unit 1 Docket No. 50-413
Dear Ms. Norry:
In response to Ms. Diggs letter of January 9, 1985 and as a supplement to my letter of January 15, 1985, please find attached a check in the amount of $150.00.
Based on further discussions with members of the NRC/NRR Staff, it was concluded that our submittal of November 6,1984 did constitute an item warranting the $150.00 fee.
have caused.
We apologize for any inconvenience this may Very truly yours, Lt. GLys/
Hal B. Tucker RWO: sib Attachment Mr. James P. O'Reilly, Regional Administrator cc:
U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Catawba Nuclear Station Robert Guild, Esq.
P. O. Box 12097 Charleston, South Carolina 29412 1
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Docket Nos. 50-413/414 Duke Power Company ATTN: Mr. Hal B. Tucker Vice President Janet M. Rodriguez Nuclear Production P.O. Box 33189 g
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asma 422 South Church Street 492-4200 Charlotte, NC 28242 aamarr oncnemo This bill is for the review of Part 50 applications filed on or after June 20, 1984 for reactor license amendments, exemptions, relief and other related approvals for the six-month period from Jun2 23,1985 through December 21, 1985, pursuant to 10 CFR 170.12(t)and170.21. Contractual costs cover the period June 1, 1985 through December 31, 1985.
Appl. Date Subject TAC No.
Catawb1 Nuclear Station 7/13/84 &
Inservice testing of sumps & valves /
56487
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$14.037 7/18/84 (5 hrs 9 $62 p/h.and S13,727 in ontractual costs) suppl.
Total costs as of this billing
$25.108 2/15/85 1/18/85 ISI program 56630 62 Suppl.
(1 hr 9 $62 p/h) 5/22/85 Total costs as of this billing = $310 3/15/05 Ext. of deadline for environmental qualifi-57330 3,105 cation of equipment (52.5 hrs 9 $62 p/h - less $150 appl. fee) 3/18/85 License Condition 23 59394 222 (6 hrs 9 $62 p/h - less $150 appl. fee) 3/29/85 Hydrogen control measures 56633 4,650 (75 hrs 9 $62 p/h)
Total costs as of this billing = $5.890 FACILITY REVENUE CODE: AA903 AMD rU (see next page)
TER448. Iressest we econse fmm es irweios esos et the annual rees of E Peyment is due bienesseessy Housever, besmet we be mened if payment is mesmed om E assys from es bwome does.
NOTE.
If hem eso any guesenne about es asisesnoe or amount of the debt, coneset the kwevhhael named stune. For NRC siebt caem:elon M. in-m
% ine'est and penery provimens, ese 31 U.S.C. W17,4 CFR 101-105, and 10 CFR 15. The revocanon of e demos asses not weiwe er eNect any debe men due from a teenses. See 10 CFR 170.41 sogen$ng fesure try en apphoent or teenses to pey proevibed less.
PRESENT AND SEPARATED EMPLOYEES: Ademonse Terms and Cendreone and Noone of Due Process RWes on the roweres side of the form ese y to s
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