ML20155G226

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Responds to Generic SER Re Resolution of USI A-46.Based on Results of Review of Generic Implementation Procedure,Util Will Either Continue to Pursue Generic Resolution or File plant-specific Response
ML20155G226
Person / Time
Site: Farley Southern Nuclear icon.png
Issue date: 10/06/1988
From: Hairston W
ALABAMA POWER CO.
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR NUDOCS 8810140138
Download: ML20155G226 (2)


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' Alabama Power Company 600 Norta 18th Street Post Ofhce Box 2641 Birmingham. Alabama 352014400 Telephone 205 2501837 W.G.:la rston,Ill Senior Vice President M

Nuclear Operations Alabama Power the sotthern e'ectsc sptem October 6, 1988 Docket No. 50-348 U.S. Nuclear Regulatory Commission ATTN:

Document Control Desk Vashington, D.C.

20555 Gentlemen Joseph H. Earley Nuclear Plant - Unit 1 Response to Generic SER on Resoaution of Unresolved Safety Issue A-46 On July ?.9, 1988, the NRC Staff issued a Safety Evaluation Report (SER) on Revision 0 of the Generi Implementation Frocedure (GIP) developed by the Seismic Qualification Utility Group (500G). The letter to SOUG enclosing the SER requests that SQUG member utilities provide to the NRC, within 60 days, a schedule for implementing the GIP.

By letter dated August 19, 1988 to Mr. Shao, SOUG clarified that the sixty days vould expire on October 7, 1988. This letter responds to the NRC's request.

According to the generic schedule m'omitted by SQUG in its October 9,1987 letter, the final revision of the RIP was to be completed by the end of calendar 1988, followed by NRC reviev in the first quarter of 1989; havr'ver, given the delay in issuing the SER for Revision 0 of the GIP, this objective is probably no longer achievable.

Completion of the final revision of the GIP in the first quarter of 1989 is dependent upon:

(1) satisfactory and timely resolution of all outstanding issues, (2) a.:complishment of all interim milestones as set forth in the generic schedule and (3) continued agreement between SQUG and NRC on major technical and licensing issues.

As the SER acknowledges, the GIP is not yet complete.

Several technical areas have not yet been fully included in the GIP.

Moreover, the SER does not resolve certain licensing issues central to completion of the GIP raised in Part 1 of Revision 0.

Alabama Pover Company vill not be in a position to establish the scope of its USI A-46 commitment until the GIP is completed and all licensing issues resolved. Given the magnitude of the effort required to achieve resolution of USI A-46, final implementation must be carefully integrated into outage schedul'es.

Assuming the GIP is completed during the first quarter of 1989 and a final SER vith no open items or significant change in vork scope is issued in the second quarter 8810140138 881006 h

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Page 2 of-1989, the plant valkdown associated with the resolutien of this issue can be' undertaken by the conclusion of the Unit 1 tenth refueling outage (i.e...second refueling outage after the final SER is issued and open items

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resolved). This outage vill commence on or about March 8, 1991. 'This schedule may be contingent upon the availability of limited industry resources for which many licensees vill be competing. -Identification of safe shutdown equipment and other tasks necessary to prepare for the walkdown vill be accomplished prior to this outage.

If the schedule for GIP development and NRC review slips further, the walkdown and other activities vould have to be delayed.

Alabama Power Company will reviev the final GIP after approval by the NRC and resolution of all outstanding issues.

Based on this review, Alabama Power Company will either continue to pursue a generic resolution of USI A-46 or file a plant-specific response.

Should the generic resolution be pursued, Alabama Power Company may, at its option, elect not to perform certain aspects of the generic program based upon suitable justification.

Ar rtated in our previous letter, Alabama Power Company also reserves the right to contest the Staff's backfitting analysis associated with USI A-46.

If you have any questions, please advise.

Respectfully submitted, ALABAMA POVER COMPANY

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VGH,III/BHVidst-V8.44 cc Mr. L. B. Long Dr. J. N. Grace Mr. E. A. Reeves Mr. G. F. Maxwell l

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