ML20054K176

Comments Re Systematic Assessment of Licensee Performance Rept.Rept Accurately Assesses Performance in Areas Evaluated.Statement Re Failure to Submit Timely Request for Exemption Is Incorrect

ML20054K176
Person / Time
Site:	Farley
Issue date:	05/07/1982
From:	Clallyton F, Clayton F ALABAMA POWER CO.
To:	Robert Lewis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20054K168	List: IR 05000348/1982008 ML20054K167 ML20054K176
References
NUDOCS 8207010269
Download: ML20054K176 (2)

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Malling Addr:ss Alabama Power Company

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600 North 18th Street Post Office Dox 2641 ,.. gq .N Bumingham Alabama 35291 Il'q g p' } c'

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Totephono 205 783-6081 - '

F. L. Clayton, Jr.

%" MS"f/"' g ;g y n All : 30 Alabama Power ite southra @cctre system May 7, 1982 Docket Nos. 50-348 50-364 Mr. R. C. Lewis, Director Division of Project and Resident Programs U. S. Nuclear Regulatory Commission 101 Marietta Street, N.W. Suite 3100 Atlanta , Ga. 30303 RE: Systemmatic Assessment of Licensee Performance (SALP)

Board Report for FNP Units 1 and 2 Dated April 22, 1982

Dear Sir:

Alabama Power Company has reviewed the referenced report and believes that this report accurately assesses our performance in the areas evaluated by the SALP Board in all but one case.

In Section IV.A.6.a, the statement is made that the " licensee failed to submit a timely request for exemption for meeting Appendix R". 10CFR50.48 and Appendix R became effective on February 17, 1981.

10CFR50.48(c)(6) requested that "in the event that a request for exemption from a requirement to comply with one or more of the pro-visions of Appendix R . . . (it shall be) . . . filed within 30 days of the effective date of this rule." On March 19, 1981, Alabama Power Company filed a detailed plan and schedule for compliance with Appendix R for both Units 1 and 2 which clearly showed, as stated in that letter, that several of these completion dates are "beyond the NRC (required) schedule." This letter was discussed on several occasions with the NRC Staff at which time it was brought to our attention that the March 19, 1981 letter did not reference the exemption section of the rule and probably needed clarification. On June 23, 1981, Alabama Power Company submitted a supplement to the initial letter stating that while we "did not explicitly request an exemption from the Nuclear Regulatory Commis-sion . . . we hereby advise you that the intent of that letter was to seek exemptions . . . and (is) herein restated." Based on discussions with the NRC Staff and on evaluation of these letters, Alabama Power Company concludes that the referenced statement from the SALP report is incorrect.

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PDR ADOCK 05000348 P PDR t

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Mr. R. C. Lewis May 7, 1982 Page 2 If there are any questions, please contact us.

Very truly yours, h f ev F. L. Clayton, fr.

m e FLCJr/ MAL:awm cc: Mr. R. A. Thomas Mr. G. F. Trowbridge Mr. J. P. O'Reilly Mr. E. A. Reeves Mr. W. H. Bradford

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