View source for L-89-016, Forwards Request for Enforcement Hearing Re Enforcement Action EA-88-113 to Question Justification of Imposed Order Concerning Operability of Train a ECCS Subsystem Charging Pumps for Use in Recirculation Mode

{{Adams
| number = ML20247Q851
| issue date = 06/01/1989
| title = Forwards Request for Enforcement Hearing Re Enforcement Action EA-88-113 to Question Justification of Imposed Order Concerning Operability of Train a ECCS Subsystem Charging Pumps for Use in Recirculation Mode
| author name = Hairston W
| author affiliation = ALABAMA POWER CO.
| addressee name = Lieberman J
| addressee affiliation = NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000348, 05000364
| license number = 
| contact person = 
| document report number = EA-88-113, NEL-89-0168, NEL-89-168, NUDOCS 8906070065
| package number = ML20244B679
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 1
| project = 
| stage = Request
}}

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 ~l IAlab2ma Pown Company 40 inverne'ts Cents Parkway
                   /*1  Post Office Box 1295          .,,=
                                                         ~
Birmingham, Alabama 35201
(,e               Telephone 205 808-5581 -
W. G. Hairston, til .
['-          '
Senior Vice President Nuclear Operations                                                       ~ AlabamaPower
                                                                    ? June 1, 1989-             ' '** *#* 6**''* W" Docket Nos.;50-348 50-364 4                     Enforcement' Action 88-113 Mr. James Lieberman Director Office of Enforcement United States Nuclear Regulatory Commission Washington, D. C. 20555   .
                         -Attention: Document Control Dert

==Subject:==
Farley Nuclear Plant Units 1 and 2, EA 88-113,
                                         -Request for an Enforcement Hearing

==Dear Mr. Lieberman:==

This letter transmits Alabama Power Company's Request for an Enforcement Hearing. It is the position of Alabama Power Company that
                         -the uncontradicted evidence in this matter is that the Train A Emergency-
                         . Core' Cooling System (ECCS) subsystem charging pumps on Units 1 and 2 were operable for use in the recirculation mode and, accordingly, that the Train.
A ECCS subsystem was operable. Alabama Power Company has previously provided the Staff with the basis for this position. The NRC Staff has disagreed, but has not provided us with any objective engineering evidence that refutes it.
                                                 ~
Moreover, it,is Alabama Power Company's position that management's-action-in response to the accumulation of hydrogen was proper, reasonable and within the requirements of the Technical Specifications and Final Safety Analysis Report for its J. M. Farley Nuclear Plant.- Alabama Power Company considers that it would be wrong to admit to a violation of an operability requirement when, in its best judgment, the pumps would have performed their intended function.
Alabama Power Company is always willing to discuss the matter further in any appropriate forum should you desire to do so.
Respectfully submitted, id}. EaEmc W. G. Hairston, III WGH:emb/NEL-89-0168 Enclosure 8906070065 890601 PDR       ADOCK 05000348
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