ML20215M488

Forwards Application for Partial Exemption from 10CFR171 Annual Fee

ML20215M488
Person / Time
Site:	Yankee Rowe
Issue date:	10/21/1986
From:	Soucy A YANKEE ATOMIC ELECTRIC CO.
To:	Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
References
TAC-67199, NUDOCS 8610300282
Download: ML20215M488 (13)

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Y4NKEE ATOMIC ELECTRIC COMPANY ,

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October 21, 1986 Mr. Victor Stello, Jr.

Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Stello:

Enclosed is an original and four copies of Yankee Atomic Electric Company's application for partial exemption from the 10 C.F.R. Part 171 annual fee. See Annual Fee for Povar Reactor Operating Licenses and Conforming Amendment, 51 Fed. n r.g . 33224 (September 18, 1986). The bases for Yankee's request for a partial exemption are set forth in the enclosed application. As we mention in the application, Yankee would be pleased to meet with the Staff regarding the application. Also, if any additional information is needed in connection with the application please feel free to call me.

Finally, one additional copy of Yankee's application for exemption is enclosed as well. Please have that copy marked and dated received by the Commission and returned to our messenger.

Very truly yours,

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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In The Matter of )

} Docket No. 50-29 YANKEE ATOMIC ELECTRIC COMPANY ) License No. DPR-3

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(Yankee Plant) )

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APPLICATION FOR PARTIAL EXEMPTION Pursuant to 10 CFR Section 171.11, Yankee Atomic Elec-tric Company (" Yankee") hereby applies for a partial exemption from the requirements of Section 171.15 of the Commission's rules and regulations.

Supporting Statement In support of this applicatica, Yankee submits the fol-lowing:

1. Yankee is a Massachusetts corporation organized in 1954 and is an " electric utility" as defined in 10 CFR Sec-tion 2.4(s). Yankee is the holder of NRC License No. DPR-3, dated July 19, 1960.

2. Sections 171.11 and 171.15 were recently adopted by the Commission, and Section 171.15 imposes an annual license surcharge on power reactor licensees, which for fiscal 1987 is

$950,000. This surcharge is in addition to the Commission's Part 170 license fees, which are use related. See Annual Fee for

Power Reactor Operating Licenses and Conforming Amendment, 51 Fed. Reg. 33,224 (September 18, 1986) (Final Rule).1 Section 171.11 provides for exemptions from that annual fee. The exemption provision states as follows:

An exemption under this provision may be granted by the Commission taking into consid-eration the following factors:

(a) Age of the reactor; (b) Size of the reactor; (c) Number of customers in rate base; (d) Net increase in KWh cost for each customer directly related to the annual fee as-sessed under this part; and (e) Any other relevant matter which the 11-censee believes justifies the reduction of the annual fee.

These criteria are addressed in the paragraphs that follow.

3. The Yankee plant is a 175 net MWe pressurized water reactor that began operating on November 10, 1960. Yankee is the oldest operating commercial nuclear power plant in the United States. Yankee's operating license expires in 11 years, and its current power contracts expire in only 5 years.2 1/ Yankee is seeking judicial review of the final rule imposing the Part 171 license fee, and submission of this exemption application is not intended to waive any of Yankee's objections to the rule.

2/ Pursuant to the power contracts referred to in the text, Yankee sells all of its energy production to 10 New England utilities, each of which sponsored Yankee's construction in the 1950's and are today Yankee's sole shareholders. Those sponsoring utilities, in turn, resell energy purchased from (Footnote 2 Continued on Next Page i

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4. Aside from being the oldest commercial reactor, Yankee is one of the smallest commercial nuclear power plants in the United States.

5. A surcharge of $950,000 in license fees will in-crease Yankee's power costs by nearly 1 mill per kilowatt hour (KWH) (a charge comparable to the entire cost of waste disposal, as presently assessed by DOE). Please note that this surcharge is on top of our current Part 170 license fees of more than

$200,000 per year.

6. An increase of this magnitude is unreasonable for such a small reactor. The impact on Yankee power costs will be approximately six times as great as it will be for a typical large, current vintage plant.

7. The decision to renew the Yankee power contracts in 1991 will be based on economics, which for a small plant like Yankee are at best marginal. Current Yankee production costs are nearly 4 cents /KWH, whereas many plants in New England have pro-(Footnote 2 Continued from Previous Page)

Yankee to their own wholesale and retail markets. Yankee has no other customers.

In this connection, it should also be noted that Yankee is often referred to as a " single asset" utility. Yankee was formed for the exclusive purpose of constructing and operating New England's first nuclear plant. Unlike other utilities, Yankee will not construct any future generating facilities, nuclear or otherwise. Once the Yankee plant is removed from service and decommissioned, Yankee Atomic will cease to operate as a utility company.

duction costs of less than three cents. An increase of $950,000 in license fees on a small plant like Yankee will widen this gap still further. The intent of the Section 171.11 exemption provi-sion is to avoid such adverse impacts on the operators of small, older reactors. See 51 Fed. Reg. at 33,227, col. 2.3

8. The sensitivity of a small reactor to increased expenses is clear in a recent analysis of 1985 nuclear utility operating and maintenance (O&M) costs (Attachment A). The study shows that despite an excellent capacity factor (80%), and tight budget controls, Yankee's O&M costs are close to the highest in the industry.

9. Furthermore, because of its small size, Yankee poses less of a potential hazard than most other commercial plants (inventory of fission product is proportional to size). More-over, Yankee is located in a very remote area, which reduces the hazard to the public still further.

-3/ Section 171.11 also refers to "[n] umber of customers in rate base" and "(n]et increase in KWh cost for each customer

directly related to the annual fee assessed under this part."

Yankee has no retail customers; as noted, all of its energy production is sold to the 10 New England utilities that own Yankee as energy supply for their respective systems. And, as indicated above, Yankee estimates that the Part 171 license fee will increase Yankee's cost per kilowatt hour by approximately 1 mill, which is about 6 times greater than the increase that will be experienced by more recent vintage plants.

10. The requested exemption is also justified in view of the fact that many of the generic costs underlying the Part 171 annual fee are not relevant to Yankee Atomic. See gen-erally, 51 Fed. Reg. 24,078, 24,079 (1986) (Proposed Rule). This includes costs associated with the following:

NRC research directed to future plant designs (id.

at 24,079, col. 3) (as explained previously, Yankee is a single-asset utility and will not construct any generating plant, nuclear or otherwise, in the future);

NRC research directed toward verified thermal hy-draulic computer codes (id. at col. 2), development of probabilistic risk assessment (PRA) technology (id. at col. 3) and earth sciences research (id. at

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24 080, col. 1) (since its inception, Yankee has independently developed substantial in-house, state-of-the-art analytical capabilities for plant engineering and design, including NRC-approved thermal hydraulic codes, fuel performance models and methods to assess seismological risk -- examples of reports which describe these capabilities are YAEC 1234, YAEC 1274P, YAEC 1300 and YAEC 1331); indeed, Yankee was licensed as an Atomic Energy Act section 104(b) power reactor demonstration project for, among other things, research and development of power reactor technology. See 1 A.E.C. 26 l (1957);

I NRC research and regulation directed to large, contemporary plants and advanced future designs (id. 24,079 at col. 2 and 24,080 at col. 3), e.g.,

plint siting criteria, construction quality l assurance and vendor topical reports related to standard designs; Review of applications for licenses to operate nuclear power reactors (id. at 24,080, col. 3);

Specialized inspection and enforcement measures (id, at 24,081, col. 1) (Yankee Atomic has an excellent overall record of high performance and

reliability and receives consistently high SALP l ratings, see Attachment B).

11. The different status of small, older generation ,

plants has been recognized in other regulatory contexts as well, e.g., the Commission's property insurance and backfitting rules (10 C.F.R. SS 50.54(w) and 50.109). Simply put, because kilowatt hour production for small, older generation plants is an order of magnitude lower than that of more recent plants, the different cost-banefit relationship of various expenses, including the new Part 171 fees, must be recognized.

12. Therefore, Yankee submits that a surcharge of

$950,000 on top of our current license fees (approximately

$200,000 per year) is unreasonable for the small Yankee plant, which is located in a rural area and has an excellent safety, regulatory and enforcement record. Yankee requests that the Part 171 fee imposed on it not exceed $50,000. We feel that this amount should be more than adequate to recognize the benefit to Yankee of the various costs that are to be recovered through the Part 171 fees.

13. In addition, repeating the exemption application process each year would be costly and time consuming for the Staff as well as Yankee. For that reason, the partial exemption requested here should be made permanent. The facts that support this application will not change in any way that would undermine the validity of the exemption.

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14. Finally, Yankee would welcome the opportunity to meet at the Staff's convenience to discuss this application; if additional information is needed in connection with the applica-tion, please contact the undersigned.

Conclusion Based upon the foregoing, Yankee respectfully requests that it be granted a permanent, partial exemption from the re-quirements of 10 CFR Section 171.15. It is Yankee's position that the surcharge levied on top of our Part 170 license fees should not exceed $50,000.

Respectfully submitted, YANKEE ATOMIC ELECTRIC COMPANY By

.A F'd A. R. Soucy

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Treasurer and Chief Financial Officer 1671 Worcester Road Fraraingham, Massachusetts 01701 Celephone: 617-872-8100 Dated: OctoberA_I, 1986

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. . . , o U.S. UTILITY OPERATING AND MAINTENANCE COSTS 1985 ,

1985 sentatenance osas less feel Total 1985 1984 Not Capacity stille sat 11s settle Mille Plant vender WM pet sent Factor Cost /RWII Cost /IGnl Costs /EWN /ENW ,

Utility o

P* 563,064,456 7.854 Union Electric callaway W 1,120 0,029,574 81.84% 313,325,457 1.660 557,674,015 7.183 h

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North Anna W 1,786 12,612,517 80.62% $22,844,640 1.811 555,487,251 4.399 3120,514,447 9.555 12.892 Virginia Power Nine Mile Point-1 C 610 4,932,333 92.30% $4,957,575 1.005 $17,567,344 3.562 848,066,096 9.745 13.245 Niagara Mohawk Power

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C 536 4,286,986 91.30% $7,333,591 1.711 830,266,060 7.060 $50,458,443 11.770 164.46 h Northern States Power Monticello I W 1128 2,942,100 90.57% 82,484,149 0.844 $8,566,434 2.912 535,602,736 12.101 Ransas cas 4 tiectric Wolf Creek 3

$85,043,757 12.226 14.591 E Wisconsin Elec. Power Point Beach W 970 6,955,765 81.864 S19,687,250 2.830 541,412,820 5.954 W 1,003 7,285,464 82.924 523,171,399 3.180 $49,014,093 6.728 891,337,369 12.537 9.936 U Northern States Power Prairie Island W 1,000 6.910,774 73.05% $18,338,908 2.654 S46,171,791 6.681 $86,750,566 12.553 16.000 Portland Cen. Electric 7tojan Virginia Power Surry W 1,556 9,690,725 71.101 325,637,668 2.646 556,892,023 5.871 8122,247,833 12.615 13.220 C onwealth Edison Quad C1ttes C 1,538 10,629,185 78.894 517,050,500 1.604 $64,638,744 6.081 8136,422,868 12.835 .14.494 Indiana 6 Michigan Elec. Cook W 2,080 12,913,018 70.874 524,543,431 1.901 580,435,162 6.229 3171,321,565 13.267 13.267 commonwealth Edison Zion W 2,080 9,927,984 54.49% $22,194,940 2.236 569,153,340 7.026 5132,221,487 13.318 10.350 810 5,354,407 75.46% $15,185.836 2.836 $35,759,964 6.679 871,454,041 13.345 13.162 Putne Yankee APC MJine Yankee C Baltimore Cat Calvert C11 tis C 1,650 9,925,994 68.674 826,466,085 2.666 872,238,896 7.278 8135,126,434 13.613 11.602 Pacific Cas & Electric Dlablo Canyon-1 W 1,073 6,530,138 69.47% S4,415,861 0.676 341,217,269 6.312 589,531,217 13.710 W 470 3,613,104 87.76% $9,039,582 2.502 531,609,327 0.749 $4 9,772,450 13.776 15.910 Bochester C6E Cinna ,

e Power Oconee 9 2,580 16,981,975 75.144 365,678,620 3.868 3123,707,389 7.285 5236,447,326 13.923 11.277 Florida PsL Turkey Point W 1,332 0,548,211 73.264 $38,690,808 4.526 $7J,203,059 8.564 8123.205,229 14.413 12.410 McCutre W 2,360 12,372,612 59.854 $50,254,446 4.062 8102,463,683 8.281 S183,038,821 14.794 12.277 Duke Power Wisc.Pubite Service Fewaunee W $03 3,699,176 83.954 $10,159,392 2.746 $31,605,251 8.544 555,099,366 14.895 12.972 p 8

1104 2,436,762 25.20% S3,434,955 1.410 $13,789,333 5.658 836,496,782 14.978 g Loutstana P6L . Waterford-3 C ~

1,664 11,975,070 82.15% S40,162,210 3.354 $79,393,730 6.630 8182,966,217 15.279 14.970 Q Florida P6L St. Lucie C 3:

55.24% $15,832,007 2.118 567,523,443 9.032 3116,259,511 15.551 15.768  %

Commonwealth Edison Dresden C 1,545 7,476,134 trj TVA Sequoyah W 2,296 12,159,737 60.46% 335,214,340 2.896 $88,979,224 7.318 $190,917,686 15.701 12.97 Arkansas P6L Arkansas Nuclear ! B 694 9,889,139 66.64% S26,348,422 2.664 577,771,284 7.864 $160,528,014 16.233 15.526 y Commonwealth dison Co. LaSalle C 2,072 8,240,293 45.404 $29,620,818 3.595 574,800,803 9.077 $135,019,312 16.385 14.591 tum.: Pnwer ca. rarley W 1,623 11.338 990 79.754 $49,522,644 4.367 $97,054,241 8.559 $185,928,694 16.397 14.371

, . ~ .*

1985 Maintenance oeN 1ess feel Totti 1985 .*

1984 .

Det Capacity Mills s.111s stills 81113 ,,*

plant vender 38s pet 3885 Factor Cost /EME Cost /BNW Coste /FWW /5tne .

, Utility

• Indian Point-2 W 864 6,650,209 87.87% 316,961,783 2.551 $58,850,522 8.849 $109,246,994 16.428 35.474 Consolidated Edison ~ . .

Fort Calhoun C 478 3,066,256 73.23% $6,168,465 2.012 $30,459,087 9.934 552,533,182 17.133 16.733 Omaha Putalle Power W 665 5,239,913 89.95% $19,770,367 3.582 552,079,482 9.939 $94,022,685 17.944 387.332 Carolina PsL Rootason-2 Susquehanna C 2,064 12,219,022 67.584 S39,292,010 3.216 $119,578,257 9.786 $220,633,961 18.057 19.270 Pa. Power 6 Light Cat awt>a-1 W 1145 3,440,514 67.30% $13,895,288 4.039 335,840,240 10.417 $63,960,632 18.590 Duke Power Connecticut Yankee W 569 4,638,105 93.054 $6,972,987 1.503 S45,550,432 9.821 386,491,013 18.648 25.673 theast Utilit ies Pilgrim C 670 4,950,9 1 84.364 519,290,891 3.896 561,244,784 12.370 $93,767,936 18.939 ston Edison Salem W 2,185 14,024,518 73.274 366,116,910 4.714 5168,287,463 12.000 $2 71,592,321 19.366 46.280 Put>1le Serv e Esc Beaver Valley-1 W 810 5,901,460 83.17% $12,602,931 2.136 $54,630,169 9.257 3117,093,911 19.842 23.653 Duquesne Light Co.

Pa!!sades C 730 5,291,419 82.75% $19,415,738 3.669 $58,495,148 11.055 3105,570,314 19.951 82.370 Consw.ers P r Summer W 885 5,230,522 67.47% S22,916,112 4.381 $71,305,650 13.633 5110,765,232 21.177 22.220 uth Carolina Esc WNP-2 C 1,100 2,556,559 26.53% S12,834,004 5.020 $40,298,965 15.763 554,306.052 21.242 WNss Match G 1500 5,075,177 38.62% $39,438,089 7.771 S69,907,327 13.774 SIO9,668,010 2I.609 32.073 Ceorgia Power C 658 3,714,347 64.83% $15,968,969 4.299 343,825,231 11.799 380,432,628 21.655 18.185 N theast Utilities M111 stone.1 810 4,166,520 58.724 S20,987,418 5.037 356,859,260 13.647 891,610,910 21.987 17.687 N.Y. Power Aut hority Fitzpatrict G C 504 2,999,402 67.944 316,135,137 5.379 346,416,147 15.475 567,187,313 22.400 19.381 vermont Yankee Vermont Yankee Byron W 1129 2,828,562 97.526 a7,845,789 2.774 534,430,565 12.172 S65,632,555 23.204 Commonwealth Edison 4.Y. Power Aut hority Indtan Point.3 W 965 4,730,307 55.96% $32,456,862 6.861 578,283,392 16.549 3119,641,863 25.293 17.492

[ 551,306,060 26.407 20.625 25.794 $31,887,384 16.412 341,745,087 21.486 (3

Dawls-Desse B 860 1,942,921 Toledo Edison Co.

w9 C Brunsvlek C 1,580 6,930,329 50.07% $79,034,889 11.404 3143,044,998 20.640 $183,182,977 26.432 26.001 y lina Ps!.

Browns Ferry C 3,195 5,543,822 19.81% 529,222,528 5.271 $99,913,079 18.022 3151,050,722 27.247 16.973 M TVA 3: __

35.65% $14,144,844 5.517 861,322,595 23.919 579,317,660 30.938 19.315 Florida Power Corp. Crystal River.3 8 821 2,563,794

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857 2,833,135 37.74% $26,327,236 9.293 857,103,143 20.156 889,001,076 31.414 Northeast Utilities M111 stone-2 C g ~~

> oyster Creet C 620 3,744,664 68.954 $29,295,585 1.023 5101,788,390 27.182 3121,133,585 J2.348 311.573 s CPU Nuclear 7'**

h 80.77% 32,699,078 2.284 336,594,913 30.969 ' $43,895,478 '37.147 37.100 Yankee W 167 1,181,669

Yanter Atomte Power ..

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C 1,108 2,654,149 54.236 S21,774,000 8.204 868,253,540 25.716 8100,975,291' 30.044 Mississippi Pst Crand Culf 3

C 515 1,926,887 42.714 $20,04 9,103 10.405 $56,023,200 29.074 875,644,195 39.257 21.327 towa Electric Lar Duane Arnold C 2,086 5,613,396 30.72% $83,302,610 14.840 3160,113,715 28.577 $ 221,4 4 2,663 39.449 20.574 Phila. Elect ric Co. Peach Botton 49.964 $135,993,42012.015 3294,533,765 26.022 3480,395,J80 42.444 44.867 Southern Cali f. Fdison San Onofre W 2,586 11,318,442 h

,e 190s tenistemenee esis less itet Tutel 190s 1904 '.

pet Capacity stille asille ast11e esitte . .

Utility plaat 9mmene as put asIE Factee Cost /RME Cost / WIN eeste /EMII /Igen C 764 1,067,740 15.95% S11,729,074 10.906 340,304,695 37.747 347,401,272 44.469 13.710 Nebrasta Pub!!c Power Cooper 7 - -

316,683,432 46.243 30.733

" Consumers Power Co. Big sock Point c 69 360,774 59.694 $3,790,069 10.530 S13,603,146 37.705 p .. .

973 1,989,805 24.71% S39,670,563 20.995 895,787,877 50.685 8108,263,286 $1.286 22.179 y Sacrarento MUD Rancho seco S y 11.944 515,846,336 19.523 368,507,012 04.502 371.e32,068 08.500 CPU Nuclear 1MI-1 8 776 811,660 CA 330 0 0.004 324,851,023 N/A SS2,940,293 II/A 352.948,203 II/A 576.279

$ Pub!!c Service Colo. rcrt St. Vrata m

E Sources:

• Only units in conumercial service for the year are incisded.

l Net Capacity itsted is Net Maniman Dependable Capacity as reported in inRC MUREC-0020,

• Licensed @etating Reactors,* January 8906.

y c Net Ceneration was taken from EERC Tarn 1 and ERA forn 422.

8 904 Mills /srWN was taken from DOE /Ein-0455 t04), *Nistorical Plant Cost and Annual Production Expenses for Selected Electric Plants 2 904.

}~ Dairyland Power Cooperative did not report figures specific to Lacrosse.

.x OUTAGES CONTINUE TO BE BIGGEST COST FACTOR (conria itfrompas,4) g figare cf 9.745 mills /KWH, down substantially from the 1984 cost 6gure of September 1984 to early July 1985 for replacement of recirculation piping, 13.245 mills /KWil. The drop corresponded to a rise in capacity factor from a utility spokesman said In 1984, the units' production costs were 20.574 66.6% in 1984 to 92.3% in 1985,which a utility spokesman attributed to the mi!!s/KWH; in 1985,39.449 mills /KWH.

24-month fuel cycle."We have found distinct benefits in the longer cycle; Florida Power Corp.'s Crystal River-3 incurved 1984 costs of 19.315 our outage time is not significantly longer than plants on 18 or even 12- mills /KWH compared with 1985 costs of 30.938 mills /KWH. A utility month cycles," the spokesman said. spokesman said the nuclear plant's 1984 " positive performance" included fligh mills /KWH production costs for 1985 were largely due to outages, the generation of almost 7.million MWH, the second highest generation of as was the casc in 1984. Nebraska Public Power District's (NPPD) Cooper, electricity of any nuclear plant in the U.S. But in 1985, the plant was out of with costs of 44.469 mills /KWH in 1985, scheduled an outage from Sep- service for 27 weeks for refueling and 250 major NRC-mandated design tember 198410 August 1985 to replace the recirculation pipes. During the modi 6 cations, the spokesman said.

outage,"a lot of valve repacking and turbine generator maintenance" was towa Electric Light & Power Co.'s Duane Arnold had an outage during done, a n'ility spokesman said, adding that an unscheduled turbine outage 1985 that lasted half the year, a utility spokesman said. He said "a lot of occurred in November 1985 for about one month. GPU Nuclear Corp.'s contractor help" added to costs, such as uttra pipefitters and electricians for Oyster Creek, with costs of 311.573 mills /KWH in 1984 and 32.348 a 10-year equipment inspection.De utility's 1984 costs were 21327 mills /KWH in 1985, accomplished a major refurbishment from February mills /KWH compared with 1985 costs of 39.449 mills /KWit

Rochester Gas & Electric Co.'s (RG&E) Ginna, ranked 16th in 1985 at 1983 to October 1984, with 1985 "a regular operating year," a GPU l

spokesman said. . 13.776 mills /KWH compared to 1984 costs of 15.910 mills /KWH, cut costs i

At Public Service Co. of Colorado's Fost St. Vrain, no electricity was because of operational fine tuning. During 1984, a spokesman said, the generated during most of 1984 and 1985 because of refueling, engineering utility completed a redesign modi 6 cation of the moisture separator reheater l and cleaned the secondary feedwater trains, which contributed to betscr per-i modifications, and environmental qualification activity. Dus the n icicar plant had costs in 1984 of 576.279 mills /KWH, and "so little generation in fonnance. Ginna's net 1985 capacity factor was 87.76% compared with 1985 that no one figured it out," a utility spokesman said. Fort St. Vrain 78.7% in 1984, the spokesman said, adding that a reduction in trip outage l

therefore ranked highest in 1985 production costs on a per KWH generated time during 1985 also added to the plant's performance.

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i basis.

Philadelphia Electric Co.'s Peach Bottom-2 and .3 were down from --Dick Afaggrert. Washington; Charles Thurston,New York

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ATTACHMENT B EXCERPT FROM SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) REPORT NO. 50-29/85-99 B. . Facility Performance Functional Area last Period This Period Recent Trend (May 1, 1982) (September 1, 1983 August 31, 1983 January 31,1985)

A. Plant Operations 1 1 Eonsistent B. Radiological Controls 2 2 Consistent C. Maintenance 1 1 Consistent D. Surveillance 1 1 Consistent E. Fire Protection and Housekeeping 1 1 Consistent

• F. Emergency Preparedness 1 1 Consistent G. Security and Safeguards 2 2 Improving H. Refueling 1 1 Consistent I. Design Control / Quality Assurance 2 2 Improving J. Licensing Activities 1 1 Consistent

• A declining trend has been noted in the area of personnel adherence to Fire Protection procedures.

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( ( f f r A U.S. GOVERNMENT PRINTING OFFICE 320-F15 1980

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,po. DATE of DOCU.f MT Daf t Afetivf D =o l Yankee Atomic Electric Company 10-21-86 1671 Worcester Road 10-23-86 LFMS-11-86 Framingham, Ma.es 01701(A.R.Souc{,

,o IrcY UTOTs on o cc of in V. Stello, Jr. (EDO) X 4

.cr.o . cis.... g co cu....c. o cari a s-eaio CLAS$18 POSI of Sect no .c1 o =iciis..,

peLE CODE o co. a' O Sv ato ao Dor _ket 8in 29 OESCa*I'Da i k 8'U'* W *8' REFEnnEO TO DaTE RECisvt0 SV DATE Ltr. requesting permanent partial exemption from 10 CFR 171 on fees C.J. Holloway 10-23 H. Denton, NRR 10-24 due to size of reactor, etc. Request w/cy for action J. Funches, NRR tha t amngnt ho nnt mnrp than (Cin nnn INFO CYS T0- 10-24 L. Solander, NRR

'"" "" per year. V. Stello, ED0 H. Thompson, NRR Application for partial exemption J. Roe. EDO G. Lear. PAD-1 P. Norry, ADM E. McKenna, PAD-1 dtd. 10/21/86.

P. Bird. ADM J. Zwolinski, BWD-1 P. Rowe, ADM R. Diggs, LFMS (3)

NOTE: A fonnal distribution for the R. Scroaains. RM Reaulatory Docket File 10 CFR 171 exemption applica- L. Hiller, RM w/ Original > for PDR

+ ion ~e 4e h a i ~' ea+ m + '-~ m u G. Johnson, RM and LPDR processing.

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W. C. Parler, GC DCS. It will"includ'e the T. Rothschild. 0GC H. Smith, NRR names included on this control form unless LFMS is infonned k Snk'0 of deletions or additions. -

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