ML19340C800
| ML19340C800 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 12/09/1980 |
| From: | Clayton F ALABAMA POWER CO. |
| To: | Varga S Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8012170484 | |
| Download: ML19340C800 (1) | |
Text
AKbamt Pow;r Comp:ny 600 Nortn 18th Strzst Post Office Elox 2641 Birmingnam. Alabama 35291 Telephone 205 250-1000 m
F. L CLAYTON, JR.
Senior Vice President Alabama Power
!% soutyn eiannc sys:em December 9, 1980 Docket No. 50-348 Director, fluclear Reactor Regulation U. S. iluclear Regulatory Commission Phillips Building, Room 116 7920 Norfolk Avenue Betnesda, Maryland 20014 Attention: !!r. S. A. Varga Gentlemen:
JOSEPH M. FARLEY fiUCLEAR PLAr1T - UNIT 1 CLARIFICATION OF TMI ACTION PLAN REQUIREMENTS -
NUREG-0737 This letter is intended to supercede our letter of November 26, 1980 concerning the above subject due to the inadvertent use of an incorrect docket number. Alabama Power Company, due to the extensive review required to respond to fir. Eisenhot's letter of October 31, 1980 and parallel conversations with the fiRC Staff, expects to submit all technical specifi-cations required by fiUREG-0737 by December 11, 1980 and all remaining items by January 5,1981.
If there are any questions, please advise.
Yours very truly, g
m ( _.. J <. '. ' 'J ' '
- s F. L. Clayton, Jr.'
RUS:de cc: Mr. R. A. Thomas
, Mr. G. F. Trowbridge Mr. E.TA. Reeves fir. W.=H. Bradford 4
t In general, the ability of Commonwealth Edison to meet the required implementation dates for major modifications is contingent upon hardware availability and delivery.
The NRC will be notified should it become apparent that any committed implementation date l
cannot be met.
With respect to the Lessons Learned Category "A" Technical Specification changes requested by References (a) and (b),
Commonwealth Edison has submitted proposed changes for Dresden and Quad Cities Stations in Reference (c).
Exceptions to NRC guidelines were described and justified in the (Reference (c)) submittal.
1 In the case of Zion Station, the requested changes will be submitted by Fe..ruary 1, 1981, unless the NRC approves the alternate schedule discussed in Reference (e).
As described in this i
reference, this extension has no impact upon reactor safety because all of the requested items are covered by or will soon be covered by plant procedures.
Adherence to procedures is required and is enforced by the NRC.
Concerning the other Technical Specification requirements of NUREG-0737, recent actions taken on behalf of the Nuclear Regulatory Commission indicate that such Technical Specifications may cover items which are inappropriate for inclusion in an operating license.
The Atomic Safety and Licensing Appeal Board found recently l
in the matter of Zion's Spent Fuel Storage Pool Modification (ALAB-616) that:
l "What matters should and should not be made ' technical specifications' is not entirely free from doubt."
Previously, the Appeal Board ruled in the Trojan spent fuel pool case (ALAB-531) that:
"there is neither a statutory nor a regulatory requirement that every operational detail set forth in an applicant's safety analysis report (or equivalent) be subject to a
- echnical specification, to be included in the license as an absolute condition of operation which is legally binding upon the licensee unless and until changed with specific Commission approval.
Rather, as best we can discern it, the contemplation of both the Act and the regulations is that technical specifications are to be reserved for those matters to wnich the imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an aonormal situation or event giving rise to an immediate tnreat to tne public nealth and surety."
(Empnasis added; footnote omitted.)
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