ML20209E881

Responds to Generic Ltr 85-07 Re Use of License Condition for Assuring Satisfactory Schedules for Plant Mod. Requirement Re Integrated Living Schedule Unnecessary. Cooperative Scheduling Effort Preferable

ML20209E881
Person / Time
Site:	Farley
Issue date:	06/28/1985
From:	Mcdonald R ALABAMA POWER CO.
To:	Varga S Office of Nuclear Reactor Regulation
References
GL-85-07, GL-85-7, NUDOCS 8507120335
Download: ML20209E881 (4)

Text

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Molling AddtCss Alabama Power Company 600 Morth 18th Street Post Office Box 2641 Birmingham, Alat'ama 35291 Telephone 205 783-6090 R. P. Mcdonald Senior Vice President Alaban,1a Power Flintridge Buuding ew..n.:

June 28,1985 Docket Nos. 50-348 50-364 Director, Nuclear Reactor Regulation U. S. Nuclear Regulatory Comission Washington, D.C.

20555 Attention: Mr. S. A. Varga Joseph M. Farley Nuclear Plant - Units 1 and 2 Generic Letter 85-07; Integrated Schedules Gentlemen:

Generic Letter 85-07 requested a response concerning the use of a formal license condition for assuring satisfactory schedules for implementing necessary plant modifications. Alabama Power Company endorses the goal set forth by the NRC in Generic Letter 85-07 which is the exchange of necessary informacion on licensee schedules for the purpose of providing the NRC with the means to evaluate implementation schedules in an integrated context. However, Alabama _ Power Company does not feel that the mechanism proposed (i.e., a license condition requiring submittal of an Integrated Living Schedule) is necessary to accomplish the intended goal. What is :

necessary, as indicated in the Generic. Letter, is a cooperative effort between the NRC and Alabama Power Company in the scheduling of completion dates for plant modifications. This cooperative effort will allow both the NRC and Alabama Power Company to most efficiently utilize their individual resources.

In order to establish and maintain this cooperative effort, there must be an adequate exchange of information concerning schedules for implementation of both NRC mandated modifications and licensee initiated plant changes, inspections and maintenance. The benefit of such a cooperative effort and exchange of.information.would be to aid a structured, pre-planned approach to evaluation of scheduling for NRC required modifications by the NRC as opposed to review of scheduling for new modifications as isolated cases. Accordingly, Enclosure 2 to Generic Letter 85-07 has been completed and is attached.

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Mr. S. A. Varga June 28, 1985 U. S. Nuclear Regulatory Commission Page 2 1

A five-year integrated schedule is utilized by Alabama Power Company as an aid in scheduling various plant work activities. Major license and i

design modifications, maintenance, license submittals and inspection i

activities are included and the schedule is updated approximately annually.

i Our five-year integrated schedule was first provided to the NRC in January 1985 as part of the reactor vessel level review. Alabama Power a

I Company agrees with the NRC concept of incorporating new licensing items i

into the existing integrated schedule in lieu of developing independent schedules for each item and intends to provide an updated five-year schedule l

to the NRC on an as-needed basis rather than submitting the proposed license I

condition for integrated schedules.

In order to accomplish the objectives of Generic Letter 85-07, Alabama

-Power Company proposes to meet with the NRC Staff on a periodic basis to discuss the schedules for licensing activities. This proposed method for j_

working with the NRC Staff on integrated schedules is similar to that which i

Alabama Power Company and the NRC Staff are currently utilizing.

If a i

license condition for integrated schedules were imposed, additional NRC and Alabama Power Company manpower and time would be required each time the schedule was modified. The implementation of a license condition for integrated schedules would not, in the opinion of Alabama Power Company, accelerate the completion of licensino activities.

i Alabama Power Company desires' to work with the NRC Staff to ensure that i

licensing activities are integrated with other work activities and completed in a timely manner. The existing working relationship between Alabama Power Company and the NRC Staff, which has been demonstrated in the scheduling of Technical Specifications review, will enable the objectives of Generic Letter 85-07 to be accomplished without a license amendment.

If you have any questions, please advise.

Yours very tr y,

lC R. P. Mcdonald r

RPM / JAR:ddb-7 l

Attachment cc: Mr. L. B. Long Dr. J. N. Grace Mr. E. A. Reeves Mr. W. H. Bradford i

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ATTACHMENT ENCLOSURE 2 RESPONSE FORMAT - GENERIC LETTER 85-07 PLANT NAME:

FARLEY NUCLEAR PLANT UTILITY:

ALABAMA POWER COMPANY I.

INTENTIONS A.

Intend to work with the staff to develop an ILS B.

Have reservations that must be resolved before developing ILS C.

Do not presently intend to negotiate an ILS with the staff D.

Plan to implement an informal ILS only X

II.

STATUS A.

.I.f you answered I.A above:

1.

Have you settled on a method for prioritizing the work at your plant (s)?

Circle One:

Yes No If yes, select best description:

Engineering judgement Analytic Hiearchy process Risk based analysis Cost-benefit analysis Other (please describe)

If no, provide estimated date for selecting a methodology:

Date or If not presently available, provide estimated date for scheduling the selection of a methodology:

l 2.

What is your estimated date for making a submittal to the NRC-or If not presently available, planned date for scheduling a submittal to the NRC

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V B.

If you answered I.B above:

1.

Please explain your reservations on separate sheet (s) or provide your schedule for supplying an explanation See separate sheet (s) or Separate submittal scheduled for (Date) 2.

If available to meet with the staff to discuss your concerns, propose a time frame for such a meeting and provide a contact that can make arrangements Contact / Time Frame Phone Number C.

If you answered I.C 1.

Would you be willing to meet with the staff to discuss the development of an ILS for your facilityfs)?

Circle One:

Yes No If yes, propose a time frame for such a meeting and provide a contact that can make arrangements.

Contact Time Frame i

Phone Number 3

If no, any constructive coments you have would be appreciated.

III.

ADDITIONAL ITEMS l

Please~make any suggestions you may have as to how a utility sponsored availability / reliability pro.iect might be credited for plant safety enhancement. Provide additional constructive coments as appropriate.

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