ML17319B097

Responds to NRC 811102 Ltr Re Payment of Submittal Processing Fees for Requests for Tech Spec Mods.Util Does Not Concur That 10CFR170.22 Fees Are Applicable to Submittals Re RPI Sys

ML17319B097
Person / Time
Site:	Cook
Issue date:	12/11/1981
From:	Jurgensen R AMERICAN ELECTRIC POWER CO., INC.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
AEP:NRC:0636, AEP:NRC:636, NUDOCS 8112110252
Download: ML17319B097 (6)

Text

REGULATORY lNFORMAtTION DISTRIBUTION >SY I'EM (RIDS)

'AOCE>SSION NBR: 8 1 121 1 0252 DOC, DATE: 8 1/12/1 1 NOTARIZED: NO DOCKET FACIL: 50 3k5 Donald O ~ Cook Nuclear Power 'Pl ant P 'Un),t 1 P Indiana L 0500031'5 50-316 Donald C ~ Cook .Nuclear Power Pl ant P

'Uni t 2P Indiana 8 05000316 AUTH ~ NAME AUTHOR AFF ILIAT ION JURGENSONE R ~ W ~ American Electr i c IPower 'Co, < Inc, IRBC I'P ~ NAME RECIPIENT AFFILIATION DENTON P H, R ~ ,Office of Nuclear Reactor Regul ationi Director SUB JEOT: Responds >to NRC 8 1 1 1 02 l~t r r e Payment of >submit ta 1

,processing fees for >r equests for ! Tech 'Specs mods ~ Ut i 1 does

.not concur that 1 OCFR 1 70 22 fees ar.e -applicable >to

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0 AMERICAN ELECTRIC POWER Service Corporation 2 Broadway, New York, N. Y. 10004 (2l2) 440-9000 tel (~"

AEP:NRC:0636 Donald C. Cook Nuclear Plant Unit Nos. 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 ASSESSMENT OF SUBMITTAL PROCESSING FEES Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Denton:

This letter is in response to Mr. W. 0. Miller's letter of November 2, 1981 regarding payment of submittal processing fees for several requests made by Indiana 8 Michigan Electric Company (ISMECo) for modification of the Cook Plant Technical Specifications. The attachment to Mr. Miller s letter contains a list of the applicable correspondence between ISMECo and the NRC Staff and indicates the fee assessed by the Office of Nuclear Reactor Regulation (ONRR) for each request. We have reviewed Mr . Miller's letter and the associated correspondence. Our comments are given below.

In our AEP:NRC:00145 submittal dated March 19, 1979, I8MECo requested expeditious processing of the revi'sed Technical Specifications to preclude the future submittal of LERs due to false indication of the RPI system.

Payment in the amount of $ 1,600.00 accompanied this submittal. An additional payment in the amount of $ 2,800.00 accompanied our AEP:NRC:00145A submittal dated August 30, 1979 as requested in Mr. Miller's letter of July 16, 1979.

Mr. Schwencer's letter of October 29, 1979 states that:

"... The staff has determined that the "indicated position" requirement may be fulfilled by voltage measurements obtained from the position indication mechanism (and therefore no LER be submitted) provided a sufficient data base has been established..."

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Mr. Harold R. Denton, D ector AE .NRC:0636 In our response to Mr . Schwencer's letter dated January 16, 1980 (AEP:NRC:0311) we stated that measurements were taken, and wi 11 be taken in the future, as required, to obtain the necessary correlation between L.V.D.T. coil voltage and rod position. Thus, the requirements set forth in Mr. Schwencer's letter were satisfied. However, I8MECo felt that our originally proposed Technical Specifications more clearly defined the operator actions required in the event that the RPI system were to indicate rod misalignment greater than + 12 steps.- During subsequent telephone discussions with the Staff, I8MECo was informed that the NRC considered the requested changes unnecessary owing to the clarification contained in Mr . Schwencer's letter. Based on the discussions with the Staff, ISMECo's letter No. AEP:NRC:00271C, dated June 17, 1980, was prepared withdrawing the Technical Specification change request.

In that AEP:NRC:00271C submittal, I&MECo noted that the clarification contained in Mr. Schwencer's letter was applicable to all plants with Westinghouse supplied RPI systems and was not the result of a Cook Plant specific review. ISMECo also noted that we had been informed by members of your Staff that no review had started on our request. Accordingly, ISMECo requested refund of the $ 4,400.00 previously submitted.

ISMECo concurs with the ONRR fee assessments for the remaining Technical Specification change requests addressed in the attachment to Mr. Miller's letter. However, for reasons cited above, I8MECo does not believe 10 CFR 170.22 fees to be applicable to our submittals regarding the RPI system and has deducted $ 4,400.00 from the- requested payment of $ 8,300.00.

Accordingly, enclosed please find a check for $ 3,900.00.

ISMECo would also like to request timely processing of the Technical Specification changes forwarded to the NRC via our AEP:NRC:00109 and AEP:NRC:00111 submittals dated December 22, 1978 and February 13, 1979, respectively.

This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to insure its accuracy and complete-ness prior to signature by the undersigned.

Very truly yours, C

R. . Jur se Assistant ice resident RWJ:clb Nuclear Engineering enclosure cc: John E. Dolan - Columbus R. S. Hunter D. V. Shaller - Bridgman R. C. Callen G. Charnoff Joe Williams, Jr.

W. 0. Miller - NRC NRC Resident Inspector at Cook Plant - Bridgman

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