ML20213G207
| ML20213G207 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 05/12/1987 |
| From: | Mcdonald R ALABAMA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR GL-87-02, GL-87-2, NUDOCS 8705180185 | |
| Download: ML20213G207 (2) | |
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Birmingham. Alabama 35291-0400 Telephone 205 2501835 L
"$o%ce"Cen, A!abama Power tre sourtwn dxtrc system May 12, 1987 Docket Nos. 50-348 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Gentlemen:
Joseph M. Farley Nuclear Plant - Units 1 and 2 Request for Extension of the 60-Day Reporting Provisions of Generic Letter 87-02 On February 19, 1987, the Nuclear Regulatory Commission (NRC) Staff issued Generic Letter 87-02, " Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI)
A-46."
In the Generic Letter the Staff requests that each licensee " provide within 60 days of receipt of this letter a schedule for implementation of the seismic verification program at your facility." For the reasons set forth below, Alabama Power Company requests that the Staff extend the time for response until sixty days after the availability of guidance regarding generic implementation of the seismic verification program, including issuance of the Staff's generic Safety Evaluation Report (SER) approving the Seismic Qualification Utility Group (SQUG) generic implementation program and resolution of outstanding issues associated with that SER. This extension will also allow for evaluations of alternatives other than SQUG to be completed.
In Generic Letter 87-02 the NRC Staff provides direction for resolution of USI A-46 and requests that licensees commit to resolve this issue either generically in conjunction with SQUG or individually. The Staff also requests that licensees inform the Staff of their decision and provide a schedule for implementation of the resolution program within sixty days of receipt of Generic Letter 87-U2. Significantly, the full scope of and implementation guidance for ile generic SQUG resolution program have not yet been fully developed, much less finalized. Until this information is available in finc) form, Alabama Power Company will be unable to evaluate (1) the application of the generic program to Farley Nuclear Plant, (2) whether participation in the generic program is preferable, and (3) the schedule for implementation.
It would be contrary to sound administrative practice and wasteful of industry and Staff resources for licensees to 0705180105 870512 L
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e U. S. Nuclear Regulatory Commission May 12, 1987 Page 2 attempt to select the A-46 resolution approach best suited to their facility and estimate the implementation schedule until information on the generic resolution option has been fully developed and finalized.
Generic Letter 87-02 is not applicable for Farley Unit 2 since during the licensing process the NRC Staff determined that there was adequate margin of safety under the postulated seismic event as required by Standard Review Plan 3.10; and as such, Unit 2 is adequately qualified. Farley Unit I was designed and built to essentially the same configuration and contains similar or the same types of equipment as Unit 2.
Alabama Power Company is evaluating the alternative of showing similarity of equipment and design between Units 1 and 2, and thus demonstrating Unit 1 is likewise seismically qualified.
In addition, Alabama Power Company is reviewing the backfitting implications of Generic Letter 87-02, and reserves the right to contest the Staf f's backfitting analysis at the conclusion of this review.
Accordingly, Alabama Power Company requests that the Staff extend the time for response to Generic Letter 87-02 until after the availability of guidance regarding generic implementation of the seismic verification program, including issuance of the Staff's generic SER approving the SQUG generic implementation program and resolution of outstanaing issues associated with that SER. This extension will also allow for evaluations of alternatives other than SQUG to be completed. This request is consistent with connitments made by the NRC Staff to the Consnittee to Review Generic Requirements.
It is Alabama Power Company's understanding that a similar extension request was submitted on behalf of SQUG member utilities and was subsequently granted by NRC letter dated April 28, 1987.
If you would like to discuss this request or have questions concerning its scope, we would welcome the opportunity to meet with you and further present our concerns regarding this issue.
Respectfully submitted, ALABAMA POWE MPANY
@/b R. P. Mcdonald RPM /BHW: dst-D-T.S.7 cc: Mr. L. B. Long Dr. J. N. Grace Mr. E. A. Reeves Mr. W. H. Bradford
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