ML20077H140

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Forwards Suppl to Schedule Submitted in 830415 Response to Generic Ltr 82-33,Suppl 1 to NUREG-0737, Requirements for Emergency Response Capability, Due to Initial Progress to Satisfy Goal of Implementation in 3 1/2 Yrs
ML20077H140
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 08/05/1983
From: Clayton F
ALABAMA POWER CO.
To: Varga S
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737 GL-82-33, NUDOCS 8308090626
Download: ML20077H140 (6)


Text

r Wh Alabama Power Company

>, 600 North 18th Street Post Offica Box 2641.

Birmingham Alabama 35291 Telephone 205 783-6081 F. L. Clayton, Jr.

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AlabamaPbwer the southem electrcsystem August 5,1983 Docket Nos. 50-348 50-364 Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Attention: Mr. S. A. Varga Joseph M. Farley Nuclear Plant - Units 1 and 2 NRC Generic Letter 82-33, " Supplement 1 to NUREG-0737 -

Requirements for Emergency Response Capability,"

dated December 17, 1982 Gentlemen:

In letter dated April 15, 1983, Alabama Power Company submitted l-its Preliminary Farley ERC Integrated Implementation Plan and Schedule to address the basic provisions and clarifications of Supplement 1 to NUREG-0737. The Preliminary Farley ERC Integrated Implementation Plan l

and Schedule identified firm completion dates for key activities scheduled during 1983 and outlined the current planning to implement the modifications to the existing emergency response facilities. This l

preliminary schedule showed SPDS as the primary activity with which the other initiatives must integrate. Alabama Power company scheduled the complete installation of the emergency response capability (ERC) integrated system for no later than the 8th refueling outage (October 1988) at Unit 1 and no later than the 5th refueling outage (June 1988) at Unit 2.

In recognition of the value of the enhancements to be provided by the ERC integrated system, Alabama Power Company. established a goal of three and one-half years to implement the ERC integrated system. Based on discussions with the NRC Farley Nuclear Plant Project l

Manager, Mr. E. A. Reeves, and the ongoing completion of scheduled activities, Alabama Power Company herein provides a supplement to the schedule submitted in the letter dated April 15, 1983 as a result of the initial progress in developing a tentative' schedule to satisty Alabama Power Company's goal of ERC implementation in three and one-half years and schedule advancements to the Preliminary Farley ERC Integrated Implementation Plan and Schedule.

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Mr. S. A. Varga August 5,1983 U. S. Nuclear Regulatory Commission Page 2 1

' Al'abama Power Company developed the _ Preliminary Farley ERC Integrated Implementation Plan and Schedule considering those known activities whose performance may contribute to a ~ fully integrated, 1-cost-effective and. safely implemented ERC system. These schedules and durations are based on the installation of certain physical i

modifications during the cold shutdown mode of refueling outages and 4

other modes of plant operation when the safe functioning of the plant would not-be jeopardized. During the implementation of this project, it will be determined how the overall schedule can be shortened.

It is i

anticipated that schedule advancements nay be obtained by reducing the duration to complete some activities, deleting or altering the scope of i

the identified activities or manipulating the sequence in which these activities would be performed. Alabama Power Company is anxious to advance the installation and operational dates for the ERC integrated system and will make every reasonable effort to do so. As stated in letter dated April 15, 1983, Alabama Powe 'ompany will provide an update to the Preliminary Farley ERC Integie.ed Implementation Plan and Schedule by December.15,1983 based on completion of scheduled activities, further planning, completion of conceptual designs, and schedule advancements made as a result of the goal to implement the ERC i

integrated system in approximately three and one-half years.

Alabama Power Company expressed its' desire in the letter dated

' April 15,1983 to discuss the Preliminary Farley ERC Integrated Implementation Plan and Schedule with the NRC Farley Nuclear Plant Project Manager, Mr. E. A. Reeves, and other members of the NRC. Staff in order to assure implementation of the emergency response activities within a reasonable timeframe and the optimization of the resources of 1

both organizations. During May 3 through 6,1983, Mr. E. A. Reeves l

visited.Farley Nuclear Plant and-the Alabama Power Company Corporate t

Office. While at.Farley Nuclear Plant, Mr. E. A. Reeves.was given a tour of systems that provide the existing emergency response capabilities and attended a meeting. held by representatives of the Farley Staff, Corporats Office, and the architect-engineering organizations of Southern Company Services and Bechtel Power Corporation. Mr. E. A. Reeves witnessed during this meeting the development of a proposed tentative schedule to satisfy. Alabama Power Company's goal of ERC implementation within three and one-half years.

This proposed tentative three and one-half year schedule was developed based on vendor contacts, development of a preliminary list of plant variables to be: monitored by the SPDS, timing of vendor walkdowns and the completion of other scheduled activities. During his visit to the Alabama Power Company Corporate Office, discussions were held with Mr.

E.' A. Reeves to explain the basis for both the Preliminary Farley ERC Integrated Implementation Plan and Schedule and the proposed tentative schedule to satisfy Alabama Power Company's goal of ERC implementation within three and one-half years, m

Mr. S. A. Varga August 5, 1983 U. S. Nuclear Regulatory Commission Page 3.

On July 29, 1983, Alabama Power Company-submitted the Farley Nuclear Plant Procedures Generation Package (PGP) to the NRC. This PGP

. includes the writer's guide and descriptions of the verification and validation programs, training program and the method to convert the Westinghouse Owners Group generic technical guidelines into plant-specific emergency operating procedures. The PGP was submitted by Alabama Power Company to the NRC in accordance with the schedule provided in Attachment 4 of letter dated April 15, 1983.

Based on discussions with Mr. E.'A. Reeves and the ongoing completion of scheduled activities, Alabama Power Company provides the attached list of milestones and completion dates to supplement the schedules submitted in Attachment 4 of the letter dated April 15, 1983.

These identified completion dates are considered firm; however, completion dates for certain milestones cannot be identified at this time.. The determination of completion dates for certain milestones necessitates information, such as a plant-specific design that may only be.available' from a plant walkdown during an outage, that requires a reasonable timeframe to accumulate.

In letter dated April 15, 1983, Alabama Power Company outlined the basis for the unavailability of certain completion dates and the need to determine the scope, duration, coordination and identity of necessary activities to satisfy the provisions of NUREG-0737, Supplement 1.

Alabama P]wer Company will determine-those completion dates and submit to the NRC an update to the Preliminary Farley ERC Integrated Implementation Plan and Schedule by December 15 1983.

Alabama Power Company believes that the ongoing completion of scheduled activities, such as the PGP submittal, and working discussions with the NRC Farley Nuclear Plant Project Manager to develop the attached supplemental' completion dates is a demonstration of good-faith efforts to meet or exceed the NRC guidance provided in Supplement 1 to NUREG-0737 and to safely implement a fully integrated and cost-effective ERC system within a reasonable timeframe.

Yours truly, f

. L. Clayto, Jr./

FLC/ MAL:grs-D35 Attachment cc:.See Page 4

4 Mr. S. A. Varga August 5, 1983 U. S. Nuclear Regulatory Comission Page 4 i

cc: Mr. R. A. Thomas Mr. G. F. Trowbridge Mr. J. P. O'Reilly Mr. E. A. Reeves Mr. W. H. Bradford Dr. I. L. Myers b

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Attachment NUREG-0737, Supplement 1 Milestones and Completion Dates Supplement to APCo letter dated April 15, 1983 Milestone Completion Date Safety Parameter Display System (SPDS)

Submittal of Written November 1983 Safety Analysis Submittal of Implementation Plan November 1983 Fully operable SPDS Updated schedule to be submitted by December 15, 1983 Operator training with SPDS Updated schedule to be submitted by December 15, 1983 Regulatory Guide Submittal of RG 1.97 March 1984 Compliance Report Completion of RG 1.97 Updated schedule to be modifications submitted by December 15, 1983 Control Room Design Submittal of CRDR Program October 1983 Plan Submittal of CRDR Summary Report Updated schedule to be submitted by December 15, 1983 Submittal of schedule to resolve Updated schedule to be identified human engineering submitted by December 15, discrepancies 1983

Attachment Page 2

- Mil estone Completion Date Emergency Operating Procedures (E0Ps)

Submittal of Procedures July 1983 Generation Package Implementation of upgraded Nine months after the E0Ps Westinghouse Owners Group approves the Generic Emergency Response Procedure Guidelines, Revision 1.

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