ML20235W012
| ML20235W012 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 02/21/1989 |
| From: | Hairston W ALABAMA POWER CO. |
| To: | Ernst M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8903100458 | |
| Download: ML20235W012 (2) | |
Text
- _ _
-+-
e Allbama Power Company ;
40 Invirniss Centrr Parkway Post Office Box 1295 Birmingham, Alabama 35201 Telephone 205 d68-5581 U3 f-W. G. Hairston, Ill d
Senior Vice President Alaban@ower Nuclear Operations February'21, 1989 the southem electnc system Docket Nos. 50-348
'O 50-364
"[
3*
e0 Mr. M. L. Ernst Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street Northwest Suite 2900 Atlanta, Georgia 30323
Dear Mr. Ernst:
Joseph M. Farley Nuclear Plant - Units 1 and 2 Safety System Functional Inspection (SSFI)
Alabama Power Company has learned through recent conversations with your staff that Region II plans to conduct an SSFI at Farley Nuclear Plant during the Unit 2 Sixth Refueling Outage, which is scheduled to commence on March 24, 1989.. Alabama Power Company requests that the SSFI not be conducted, as planned. We vould like the opportunity to complete our own self assessment prior to the NRC performing an SSFI of Farley Nuclear Plant. Our plan for,a self assessment includes the SSFI technique for ensuring the operational readiness of a selected system, and also incorporates some features.of a Safety System Outage Modification Inspection (SSOMI) that are intended to address the adequacy of other aspects of our Configuration Management Program.
It is our understanding that the NRC encourages utilities to take the initiative in the area of SSFIs and perform self-assessments. Our plan to perform a self-initiated assessment in 1989 is in concert with this understanding.
In fact, it was through our conversations with Region II regarding our plan for a self-initiated assessment in 1989 that we learned of the NRC's plan to perform an SSFI at Farley Nuclear Plant during the Unit 2 Sixth Refueling Outage.
We believe a self-assessment would be more beneficial to Alabama Power Company than responding to an NRC SSFI.
Staffing the self-assessment team with our people provides an opportunity and a means for the team members to gain a better assessment of the overall process in which Parley Nuclear Plant is designed and operated. The results of participation in such an effort and the lessons learned would be more lasting than responding to an NRC SSFI. An added advantage is that the team members vill gain experience in this special inspection technique, which can be carried forth into future self-initiated assessments.
Alabama Power Company also recognizes that participation by experienced consultants in self-assessments can provide objectivity and ensure thoroughness. Accordingly, our plan for the self-assessment includes f
participation by an experienced consultant.
8903100450 890221 I
\\\\
PDR ADOCK 05000340 ('
,ygo/
G PNU
Mr. M. L. Ernst U. S. Nuclear Regulatory Commission Page 2 Alabama Power Company has two refueling outages scheduled for 1989, the Unit 2 Sixth Refueling Outage in the Spring and the Unit 1 Ninth Refueling Outage in the Fall.
Our self-assessment is scheduled to be conducted in-the Summer, between the two outages. As a result of these activities, 1989 vill be a taxing and difficult year for the personnel of Alabama Power Company, the Architect / Engineers and the NSSS vendor that support the operation of Farley Nuclear Plant.
Should the NRC proceed with the SSFI during the Unit 2 Sixth Refueling Outage, as planned, even further demands vill be placed upon these personnel.
Furthermore, the personnel that vill be participating in our planned self-assessment vill be diverted-from these activities in order to prepare for, and respond to,-the NRC SSFI. This vill, most likely, result in the postponement of our self-assessment efforts.
Alabama Power Company, therefore, requests that the NRC reconsider the plan to conduct an SSFI at Farley Nuclear Plant during the Unit 2 Sixth Refueling Outage and allow us the opportunity to proceed, as planned, with our self-assessment. The deferment of the NRC SSFI until after we complete our self-assessment would result in better utilization of resources, overall, by Alabama Power Company, and would also enhance our ability to respond to the NRC during the SSFI. Most importantly, the cumulative effects of our self-assessment and the NRC SSFI would enhance the long-term design and operation of Farley Nuclear Plant. The results of this self-assessment would be made available to the NRC for review.
If we can be of any assistance in your consideration of this request, l
please let me know.
Yours truly, 1
id.). l$s V. G. Hairston, III VGH,III/LCTimV.402 cc:
Mr. E. A. Reeves Mr. G. F. Maxwell U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Uashington, D. C. 20555 l