ML20084G396

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Responds to SALP Repts 50-348/83-24 & 50-364/83-22 for Aug 1982 - Jul 1983.Section 9 of SALP Board Assessment, Statement & Treatment of Bases for Evaluation Contain Inaccuracies of Fact & Inadequate Application of Principles
ML20084G396
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 11/28/1983
From: Clayton F
ALABAMA POWER CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20084G364 List:
References
NUDOCS 8405070215
Download: ML20084G396 (3)


Text

Milling Addrats Alabama Power Company 600 North 18t.i Street

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Post Office Box 2641 Birmingham. Alabama 35291

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Telephone 205 783-6081 F. L Clayton, Jr.

,n Senior Vice President

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Flintridga Building MabaniaPote the so 2em electnc system November 28, 1983 Docket Nos. 50 48 50- 4 U. S. Nuclear Regulatory Commission Region II, Suite 3100 101 Marietta Street N. W.

Atlanta, GA 30303 Attention: Mr. J. P. O'Reilly 4

Systematic Assessment of Licensee Performance (SALP) for the Period 08-01-82 through 07-31-83 NRC Report Nos. 50-348/83-24 and 50-364/83-22 Dated October 18, 1983 Gentlemen:

The subject SALP report was reviewed with Alabama Power Company in a meeting in Birmingham. on November 10, 1983. As stated in that meeting, the conclusions of Section 9, " Licensing Activities," of the SALP report necessitate that Alabama Power Company make a formal response.

Concerning Section 9 of the SALP Board Assessment, it is the opinion of Alabama Power Company that the NRC's statement and treatment of the bases fcr the evaluation contain inaccuracies of fact,' inadequate-and/or inconsistent application of good licensing principles, and, in one case, an unfounded judgement.

It is also perceived that simply the number of licensing requests related-to the Farley Nuclear Plant has negatively prejudiced the NRC evaluation. Alabama Power Company has held informal discussions with the Director, Division of Licensing and the Region II Administrator concerning this section of the Assessment.

Your forwarding letter invites coments on the SALP Board Assessment.

It provides for enclosure of such coments and the SALP Board Assessment under an NRC cover letter to the NRC Public Document Room. Your forwarding letter also states that the NRC cover letter l

would include, if appropriate, the NRC's position on matters relating to I

the status of our safety programs. Currently, there appear to be no-l l

8405070215 840417 PDR ADOCK 0500034 0

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November 28, 1983 Mr. J. P. O'Reilly U. S. Nuclear Regulatory Comission Page 2 provisions for rectifying problems involving the bases used for this SALP evaluation. It is therefore requested that the NRC review Section 9 of the SALP Board Assessment with respect to our coments as stated above and advise us of an appropriate course of action.

If you have any questions, please advise.

Yours very truly, 9

F / L. Cl ay

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FLCJ r/RLG:grs-D15 cc: Mr. R. A. Thomas lu. G. F. Trowbridge Mr. D. G. Eisenhut Mr. S. A. Varga Mr. E. A. Reeves Mr. W. H. Bradford e

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ENCLOSURE 4 SUPPLEMENTAL LICENSING ACTIVITIES ANALYSIS 9.

Licensing Activities a.

Analysis Licensee management continued, by detailed involvement and control, to assure quality performance in the area of licensing activities.

Corporation management was frequently involved in site activities.

As noted in the previous SALP evaluation relating to NUREG-0737, licensee management performance was excellent in the post-TMI effort. Management continued in this excellent manner using an integrated implementation schedule for Supplement I to NUREG-0737 items; however, the licensee's planning for final completion of these items thru 1988 does not appear to be timely. The final schedule is still being negotiated.

The licensee appeared to have a clear understanding of the technical and legal issues involved.

He has been responsive to generic regulatory issues and in only a few instances are delays in resolution of generic issues attributable to the licensee.

Activities during this report period included the following issues:

Responses to NUREG 0737 items Several one-time Technical Specification (TS) changes Masonry wall modifications extension Deletion of boron injection system Increase in spent fuel storage capacity Two license condition changes One emergency authorization In several instances, the initial submittal did not contain sufficient infonnation or justification to support the requested actions.

Because of this, significant staff review time and supplemental submittals were required to obtain acceptable resolution.

The licensee has continued to improve its headquarters-to-plant coordination, planning and consnunications related to licensing activities.

Licensee planning has shown a definite improvement over the previous year. Since January 1983, the licensee issued a monthly report identifying the status of licensing actions and the needs of the licensee. This has been helpful. However, we were not able to agree with the licensee's assignment of priorities and schedular needs in all cases. Accordingly, the licensee was requested to further characterize and prioritize his requests for staff review. The licensee's responses and cooperation to this initiative have been excellent and periodic meetings to discuss the overall status of all licensing items have been scheduled.

It is anticipated that this effort will result in a mutual understanding of priorities and schedules and allow both the licensee and the staff to utilize their resources in the most effective manner possible.

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