ML19332E648

Responds to NRC Re Results of Insp Repts 50-348/89-15 & 50-364/89-15.Requests That Comments & Discussions from 891030 Meeting Be Taken Into Consideration for Final Disposition of SALP Rept

ML19332E648
Person / Time
Site:	Farley
Issue date:	11/27/1989
From:	Hairston W ALABAMA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8912080172
Download: ML19332E648 (3)

Text

7-

",- Alabama Power Company

.*i (40 inverness C;nter Parkway

Post Office Box 1295 '

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- Birminfiam, Alabama 35201 '

Telephone 205 868-5581 -

s,i i ic.

W. G. Hairston, lli Senior Vice President Nuclear Operations.

Alabarila Nwer 4

November 27, 1989 7

1:

. Docket'Nos. 50-348-

--50-364

U. S.: Nuclear Regulatory Commission iATTN:' Document-Control' Desk-Vashington, D. C.'20555 Ge'ntlement

+1 s

Joseph M. Farley Nuclear. Plant Units 1 and 2 NRC' Inspection Report Nos. 50-348/89-15 and 50-364/89-15 j

.7 By;1etter deted October 5, 1989, the NRC forwarded the results of the j

, Systematic Assessment of Licensee. Performance (SALP) Board evaluation of 1

~Farleyl Nuclear Plant for 1989.. Alabama Power Company has reviewed this report and provides comments in an attachment.to this letter..

Alabama' Power Company appreciates the opportunity to provide comments on s

theLSALP~ report'and requests'that these comments.be considered in the NRC's i

. final conclusion.

In addition to the attached comments, Alabama Power Company

,J requests that comments-and discussions from the October 30, 1989 meeting be taken.into. consideration for. final disposition of the SALP report.

-If you.have any questions,'please advise.

g Respectfully submitted,

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-VGHiIII/BHV:md 10.58 Attachment

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cc Mr. S.-.D. Ebneter

'Mr. E. A. Reeves

-Mr. G. F. Maxwell

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8912000172 891127 PDR~ ADOCM 05000348

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Attachment-1989 SALP Comments NRC Inspection Report Mos.

50-348/89-15 and 50-364/89-15 u

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Reference-Comment

1.

PageL17 The report indicates concern by the NRC (Section IV.E.1) regarding the audits performed within the security area because the security audit checklists reference 10CFR73.40, 73.45 and 73.46 which are not applicable for FNP. The

-NRC then concludes that the qualifications of L

the auditors and validity of the audit 4

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findings are.in question.

1 The conclusion reached is apparently based solely on this single issue.

APCo questions this conclusion based on the followings.

p.

1. The comment regarding the j

qualifications of APCo auditors was not presented at the exit meeting or in Inspection Report 89-18, which initially posed the issue of sections 73.40, 73.45, and 73.46.

1

2. The three checklist items represent i

less than 3 percent of the more than 105 checklist items assessed during i

l;i the security audit reviewed.

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3. None of the findings included in the final audit report were indicated as being non-valid.

'4. No specific findings.related-to inadequate qualification of an auditor have been presented.

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Reference Comment l'.- (Con t inued)-

Finally, with specific regard to the three sections in question-(10CFR73.40, 73.45~

and 73.46), APCo recognizes the potential for

- nonapplicability of at least some of these sections.. The cr.iteria of 10CFR73.20 would currently exempt FNP from.the: requirements of 73.45 and 73.46 given the current amount of

- strategic nuclear. fuel maintained on site.

4 However, APCo'is. currently of the opinion that:

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. 10CFR73.40 does in fact apply since 10CFR73.55 1

is referenced and should be audited. It is definitely not: clear how this approach b-represents atlack of qualifications on the part of the.FNP audit staff or casts doubt on the validity of the audit findings.

3 2.-

Page 21-.

The report states that APCo's late submittal V

.(Section:IV.G.1) offa report relating.to the cracked RHR pipe at FNP needed by the NRC to' assist in generic resolution of Bulletin 88-08, delayed L

the NRC's technical: review of this issue.

1

- No formal requests by the NRC or commitments-by APCo vere made to submit this report. APCo does not understand how the NRC'can cite this issue as a

"tency.

APCo-provided this n

report - to :

" immediately after receipt l

from Vestir APCo cooperated completely l

vith the NF~

= n issue.

NRC personnel L

vere actively involved with the efforts being i-taken by APCo to evaluate and resolve this issue.

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