ML20149H324
| ML20149H324 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 02/15/1988 |
| From: | Mcdonald R ALABAMA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| GL-85-07, GL-85-7, NUDOCS 8802190215 | |
| Download: ML20149H324 (2) | |
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4 Alabama Power Company 600 North 18th Street Post Office Box 2641 Birmingham, Alabama 35291 o400 Telephone 205 250-1835 a
R. P. Mcdonald Senior Vice President Alabama Power the southern elEctrc system February 15, 1988 Docket Nos. 50-348 50-364 U. S. Nuclear Regulatory Cor. mission ATTN: Document Control Desk Washington, D. C. 20555 Gentlemen:
l Joseph M. Farley Nuclear Plant - Units 1 and 2 Integrated Schedules for Plant Modifications l
Alabama Power Company has reviewed the proposed policy statement, l
"Integrated 3chedules for Implementation of Plant Modifications" contained l
in Volune 52, No. 228 ef the Federal Register dated November 27, 1987.
As discussed in our June 28, 1985 response to Generic Letter 85-07, Alabama Power Company does not feel an integrated schedule license amendment would accelerate or enhance the effort to complete licensing activities.
A five-year integrated schedule is utilized by Alabama Power Company as an aid in scheduling various plant work activities.
The five-year integrated schedule was first provided to the NRC in January 1985 as part of the reactor vessel level review, Major license and design modifications, maintenance, license submittals and inspection activities are included and l
the schedule is updated approximately annually. A more detailed and dynamic scheduling and planning process is used for activities scheduled to occur within a two year timeframe.
Alabana Power Company agrees with the NRC concept of scheduling new licensing itens in an integrated fashion in lieu of developing independent schedules for each item. Consequently, Alabama Power Company encourages the concept presented in the proposed policy whereby the NRC Staff evaluates the plant specific schedules for NRC required activities considering all pertinent ongoing activities, their relative priorities, and utility
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resource constraints.
If a license condition for integrated schedules was imposed, or a formal integrated scheduling plan was submitted to the NRC, additional NRC and
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Alabama Power Company manpower and time would be required each time the schedule was nodified. The adoption of these methods would not, in the opinion of Alabama Power Company, accelerate the completion of licensing activities.
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58802190215 880215 PDR ADOCK 05000348 P
s U. S. Nuclear Regulatory Commission Page 2 I
Alabama Power Company desires to work with the NRC Staff to ensure that licensing activities are integrated with other work activities and completed in a tinely manner.
The existing working relationship between Alabama Power 1
Company and the NRC Staff, which has been effective to date, will meet the basic objectives of the proposed policy statement without the inposition of unnecessary administrative burdens on the NRC Staff or the 1icensee.
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If there are any questions, please advise.
Respectfully submitted, ALABAftA P En0ltPANY a
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