ML19332E648
| 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) | |
Text
- 7- ..
",- Alabama Power Company ;
.*i (40 inverness C;nter Parkway
Post Office Box 1295 ' i
- -
- - Birminfiam, Alabama 35201 '
- ,
Telephone 205 868-5581 -
s ,i i ic. W. G. Hairston, lli Senior Vice President 4 Nuclear Operations . Alabarila Nwer November 27, 1989 7 ' '
. Docket'Nos. 50-348-1: --50-364
- U. S.: Nuclear Regulatory Commission iATTN:' Document-Control' Desk- ..
Vashington, D. C.'20555 Ge'ntlement +1 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 j
, Systematic Assessment of Licensee. Performance (SALP) Board evaluation of 1
~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 s
< 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
> taken.into. consideration for. final disposition of the SALP report.
-If you.have any questions,'please advise. g Respectfully submitted,
,/(\ W &/
4 H rst , III
-VGHiIII/BHV:md 10.58 Attachment ;
)
& '* cc Mr. S.-.D. Ebneter .
- .
'Mr. E. A. Reeves
-Mr. G. F. Maxwell
.) f ,
L ,
l 0 i o ' i; 4) 8912000172 891127 PDR~ ADOCM 05000348
'FL Lt_ ..._ __ , _ _ _ _ . _ _ . _ _ _ _ _._. _ _
n I i
4.: .. . :)
..f t <
I
&i -
Attachment-1989 SALP Comments NRC Inspection Report Mos.
u 50-348/89-15 and 50-364/89-15
. , t
?
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 4
l 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.
p.
- 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 73.40, 73.45, and 73.46.
1
- 2. The three checklist items represent i 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. ;
l? i
~
L L
1
~ . . _ . .. _
~
y n: c 9;E Lv .
AL (f% ;,en. < h; V - . . . .
- Page 2 r :'
H INo. ,
Reference Comment l'.- (Con t inued)- Finally, with specific regard to the 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 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 generic resolution of Bulletin 88-08, delayed L the NRC's technical: review of this issue.
1
- 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 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 L
i- ,
taken by APCo to evaluate and resolve this issue.
b l
r V
- ?
- < [
, VGH,III/BHV:md 11.39 Y
Y * * -- e-- + w-ne , . . . .-. , , _ _