ML19332E648

Responds to NRC 891005 Ltr Re Results of Insp Repts 50-348/89-15 & 50-364/89-15.Requests That Comments & Discussions from 891030 Meeting Be Taken Into Consideration for Final Disposition of SALP Rept

ML19332E648
Person / Time
Site:	Farley
Issue date:	11/27/1989
From:	Hairston W ALABAMA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8912080172
Download: ML19332E648 (3)

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",- Alabama Power Company  ;

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.*i (40 inverness C;nter Parkway

Post Office Box 1295 ' i

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- Birminfiam, Alabama 35201 '

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Telephone 205 868-5581 -

s ,i i ic. W. G. Hairston, lli

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Senior Vice President 4 Nuclear Operations . Alabarila Nwer November 27, 1989

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. Docket'Nos. 50-348-

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1: --50-364

U. S.: Nuclear Regulatory Commission

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iATTN:' Document-Control' Desk- ..

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Vashington, D. C.'20555 Ge'ntlement +1

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s Joseph M. Farley Nuclear. Plant Units 1 and 2

.7 NRC' Inspection Report Nos. 50-348/89-15 and 50-364/89-15 j By;1etter deted October 5, 1989, the NRC forwarded the results of the

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, Systematic Assessment of Licensee. Performance (SALP) Board evaluation of 1

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~Farleyl Nuclear Plant for 1989. . Alabama Power Company has reviewed this report and provides comments in an attachment.to this letter..

Alabama' Power Company appreciates the opportunity to provide comments on

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< theLSALP~ report'and requests'that these comments.be considered in the NRC's i . final conclusion. In addition to the attached comments, Alabama Power Company

,J requests that comments-and discussions from the October 30, 1989 meeting be

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> taken.into. consideration for. final disposition of the SALP report.

-If you.have any questions,'please advise. g

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Respectfully submitted,

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,/(\ W &/

4 H rst , III

-VGHiIII/BHV:md 10.58 Attachment  ;

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& '* cc Mr. S.-.D. Ebneter .

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'Mr. E. A. Reeves

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-Mr. G. F. Maxwell

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0 i o ' i; 4) 8912000172 891127

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PDR~ ADOCM 05000348

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Attachment-

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1989 SALP Comments NRC Inspection Report Mos.

u 50-348/89-15 and 50-364/89-15

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iNo.. Reference- Comment

1. PageL17 ,

The report indicates concern by the NRC (Section IV.E.1) regarding the audits performed within the security area because the security audit

! checklists reference 10CFR73.40, 73.45 and 73.46 which are not applicable for FNP. The ,

-NRC then concludes that the qualifications of L

the auditors and validity of the audit

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l findings are.in question. l 1

The conclusion reached is apparently based  !

solely on this single issue. APCo questions

' this conclusion based on the followings.

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1. The comment regarding the j qualifications of APCo auditors was I not presented at the exit meeting or in Inspection Report 89-18, which initially posed the issue of sections

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73.40, 73.45, and 73.46.

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2. The three checklist items represent i

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less than 3 percent of the more than I 105 checklist items assessed during i l;i t

the security audit reviewed. I i 3. None of the findings included in the  ;

final audit report were indicated as I being non-valid.

'4. No specific findings.related-to

' inadequate qualification of an auditor  ;

have been presented.  ;

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Page 2

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Reference Comment

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l'.- (Con t inued)- Finally, with specific regard to the

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three sections in question-(10CFR73.40, 73.45~

and 73.46), APCo recognizes the potential for

- nonapplicability of at least some of these sections.. The cr.iteria of 10CFR73.20 would

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currently exempt FNP from.the: requirements of

' 73.45 and 73.46 given the current amount of 4

- strategic nuclear. fuel maintained on site.  :

However, APCo'is. currently of the opinion that: i 1

. 10CFR73.40 does in fact apply since 10CFR73.55 h is referenced and should be audited. It is b- ' definitely not: clear how this approach represents atlack of qualifications on the part of the.FNP audit staff or casts doubt on the validity of the audit findings. 3 V

2.- :Page 21-. The report states that APCo's late submittal

.(Section:IV.G.1) offa report relating.to the cracked RHR pipe at FNP needed by the NRC to' assist in

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generic resolution of Bulletin 88-08, delayed L the NRC's technical: review of this issue.

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- No formal requests by the NRC or commitments-by APCo vere made to submit this report. APCo does not understand how the NRC'can cite this n issue as a "tency. APCo-provided this

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report - to : " immediately after receipt l from Vestir APCo cooperated completely l vith the NF~ = n issue. NRC personnel .

vere actively involved with the efforts being

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taken by APCo to evaluate and resolve this issue.

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