ML20247E933

Forwards Response to NRC Re Questionnaire on Backfitting Process & Estimated Implementation Costs for Certain Generic Issues

ML20247E933
Person / Time
Site:	Farley
Issue date:	05/18/1989
From:	Hairston W ALABAMA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-88-01, GL-88-03, GL-88-1, GL-88-3, IEB-88-001, IEB-88-002, IEB-88-005, IEB-88-1, IEB-88-2, IEB-88-5, NUDOCS 8905260376
Download: ML20247E933 (3)

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- Alabama Power Company

-. 40 inverness Center Parkway . ]

y Post Office Box 1295 Birmingham, Alabama 35201

. Telephone 205 868-5581 i

W. G. Hairston, til Senior Vice President Nuclear Operations gghgg pgggp May 18, 1989 ' * * * '*'" * *

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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 g

Response to NRC Questionnaire Regarding the Backfitting Process In response to your letter of April 7, 1989, Alabama Power Company provides.the attached response. Attachment 1 addresses your questionnaire itself. . Attachment 2 provides estimated implementation costs for certain.

generic issues. In addition, Alabama Power Company endorses the comments of-NUMARC to be provided on May 19, 1989. As a general comment, however, it is felt that a better understanding and application of the intent of the Backfit Rule by the NRC staff is needed. Staff positions are being .

imposed through inspection and enforcement without being subjected to the-backfitting process. In addition, cursory or inaccurate cost benefit analyses are performed to justify impositions of requirements outside the rulemaking arena.

If you' ave h any questions, please advise.

Respectfully submitted, al. . /9 W V. G. Hairston, III VGH,III/ JAR:nV.717 Attachments cc Mr. S. D. Ebneter Mr. E.'A. Reeves Mr. G. F. Maxwell Mr. E. L. Jordan 8l

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Attachment-1 Questionnaire kI P 1. Are NRC procedures (i.e.,~ Manual Chapter 0514) sufficiently clear and effective

- C on how backfits are identified and transmitted to licensees, and how claims of i backfit and appeals are handled? If not, vould you please comment on the need for specific improvement?

Alabama Power Company endorses NUBARG response.

2. Is NRC staff practice consistent with the 0514 process in identifying and implementing backfits? If not, would you please comment on any specific observed inconsistencies?

Alabama Power Company endorses NUBARG response.

3. In the past year have you experienced, in your judgment, the imposition of one or more backfits, which would not fit one of the exceptions listed in 10CFR50.109(a)(4) or did not have a regulatory analysis, for which you did not file a claim or appeal? If so, please indicate why you did not file a claim or appeal.

In the area of environmental qualification, it is felt that the NRC is attempting to impose new standards on the industry through enforcement. An example of this can be seen in an October 17, 1988 letter from Alabama Power Company to the NRC (pertinent excerpts provided below) in which Alabama Power Company acquiesced to backfits which were effectively imposed outside of the backfitting process.

Claims or appeals were not able to be made due to the time constraints imposed by the NRC staff.

"Vithout vaiving this position (that ASCO solenoid valves are environmentally qualified without cable entrance seals and Raychem/ Chico seals are environmentally qualified on NAMCO limit switches), however, Alabama Power Company, as it has previously committed, has replaced Raychem/ Chico seals that were installed on environmentally qualified NAMCO EA-180 limit switches inside the Unit 1 Containment with NAMC0 EC-210 connectors. Alabama Power Company will similarly upgrade all environmentally qualified NAMCO EA-180 limit switches inside Unit 2 Containment (which are listed in Attachment 1) no later than startup from the Unit 2 sixth refueling cutage. Additionally, Alabama Power Company hereby commits to install NANCO EC-210 connectors qualified to the requirements of 10CFR50.49 on those environmentally qualified NAMCO limit switches in the main steam valve room, (which are listed in Attachment 2) during the Unit 1 ninth and Unit 2 sixth refueling outages unless NRC concurrence with Alabama Power Company's position can be obtained prior to installation. In addition, Alabama Power Company will add fuses to the electrical circuitry of certain limit switches and therefore the third item of the May 11, 1988 letter with reFard to expediting investigation and resolution of identified ground conditions on the 125VDC Auxiliary . Building battery system vill no longer apply.

L Further, and again without vaiving the abuve positien, it is Alabama Power Company's plan to install Conax ECSA cable entrance seals qualified to the requirements of 10CFR50.49 on those ASCOs listed in Attachment 3 during the Unit i ninth and Unit 2 sixth refueling outages, unless NRC concurrence with Alabama Power Company's position can be obtained prior to installation."

4. Please describe any impediments or weaknesses in the backfit process, or in the communications and understanding of that process, and any suggestions for improvements.

Alabama Power Company endorses NUBARG response.

JAR /m.V.7.18 i

. Attachment 2 Backfits imposed in 1988 l

Issue APCo Estimated Cost

1. NRC Bulletin 88-01 $ 250,000

2. NRC Bulletin 88-02 $1,310,000

3. NRC Bulletin 88-05 $ 50,000

4. Generic Letter 88-01 N/A to FNP

5. Generic Letter 88-03 $ 350,000 JAR /m.V.7.19

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