ML20093E066

Discusses Util Disagreement Re Fee Required for Exemption from ASME Code,Section IX Inservice Insp Requirements,On Basis That Exemption Reviewed & Approved by Virtue of Sample Plans Inclusion in Tech Specs.Fee Encl

ML20093E066
Person / Time
Site:	Mcguire, McGuire
Issue date:	07/12/1984
From:	Tucker H DUKE POWER CO.
To:	Adensam E, Harold Denton Office of Nuclear Reactor Regulation
References
TAC-54882, TAC-54883, NUDOCS 8407170368
Download: ML20093E066 (3)

Text

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'; Dunn POWER Co>mory l'.O. HOX !!f31(IO CIIAHLOTTP, N.G. 211242 HALII.TUCKEH rer.enioxe j"*l===Q July 12,1984 (704) ora-4sn Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Ms. E. G. Adensam, Chief Licensing Branch No. 4

Subject:

McGuire Nuclear Station Docket Nos. 50-369, 50-370 Snubber Functional Tests /ASME Code Section XI Technical Specification Surveillance Requirement 4.7.8 states that each snubber required by T.S.3.7.8 shall be demonstrated operable by performance of an Augmented Inservice Inspection Program (as given in T.S.4.7.8a-1) and the requirements of Specification 4.0.5. Part of this Augmented Inspection Program (T.S.4.7.8e) is that during the first refueling shutdown and at least once per refueling thereafter, a representative sample of snubbers shall be tested using one of the three sample plans given. The sample plan is to be selected and the NRC notified prior to the test period.

My letter to Mr. J. P. O'Reilly (N2C/0IE) dated February 14, 1984 notified the NRC that Duke had selected sample plan No. 2 (T.S.4.7.8.e(2)) for the functional testing which was performed during the McGuire Unit 1 first refueling . McGuire Technical Specifications require that inservice inspection and testing of various components be performed in accordance with Section XI of the ASME Code and a:mlicable addenda. Snubber testing is included in the edition of the Code which McGuire is using. The Code testing requirement must be followed unless written relief has been granted by the NRC. Since the plan for snubber selection being used by Duke differed from that in Section XI of the ASME Code, it was subsequently determined that formal acknowledgement of the exemption to the Code would be appropriate. Consequently, my letter of April 12, 1984 requested writ-ten relief from the ASME Code requirement pursuant to 10 CFR 50.55a(g)(6)(1).

No fees pursuant to 10 CFR 170.22 were remitted with this request.

Ms. Reba M. Diggs' letter of May 1, 1984 indicated that preliminary review of the April 12, 1984 relief request application determined that a class II fee (Unit 1) and a class I fee (Unit 2) were required, and requested that Duke Power remit the sum of $1,600.00. In accordance with this request, a check in the amount of $1,600.00 is enclosed. However, Dubc Power disagrees that a fee is required for the exemption on the basis that the exemption has already been reviewed and approved by virtue of the various sample plans inclusion in the Technical Specifications (the exemption request was basically for formal documentation purposes). Accordingly, it is hoped that the ONRR Staff's final review of the request concurs with this ponition and the necessary adjustments made.

This matter has previously been discussed with Mr. R. Birkel of your Staff.

Should there be any questions regarding this matter, please advise. g go 8407170368 840712 a i

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Mr. Harold R. Denton July la,1984 Page 2

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, Very truly yours, ,,

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Hal B._ Tucker PBN:glb Enclosure cc: W. T. Orders Senior Resident Inspector McGuire Nuclear Station Mr. James P. O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission

' Suite 2900 101 Marietta Street, NW

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-Atlanta, Georgia 30323' i

This check (no.736608) includes a $150 fee to be used for Oconee Nuclear Station in the near future. That submittal will refer to this check no. 736608 and this submittal of July 12, 1984.

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