ML20155H819
| ML20155H819 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna  |
| Issue date: | 07/31/1998 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Diaz N, Shirley Ann Jackson, Mcgaffigan E, The Chairman NRC COMMISSION (OCM) |
| Shared Package | |
| ML20155H809 | List: |
| References | |
| NUDOCS 9811100291 | |
| Download: ML20155H819 (3) | |
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$u 3000 Girn ARen. Wginia 23060 804e273*3331 a.
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e MdD July 31,1998 5
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1%a5 Chairman Shirley A. Jackson Commissioner Nils J. Diaz Commissioner Edward McGaffigan i
Nuclear Regulatory Commission
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One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 1
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Dear Chairman Jackson and Commissioners Diaz and McGaffigan:
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NRC STAKEHOLDER MEETING, JULY 17,1998 l
The stakeholder meeting hold on July 17 was a candid and productive exchange l
of ideas. I was encouraged by the receptivity of everyone at the table to the j
suggestions and criticisms raised by others.
During the meeting, there were several references to the recent Technical Specification changes made at Surry and North Anna Power Stations to reflect the change in title from Plant Manager to Site Vice President.
To get an accurate perspective of these comments, you should be aware of some relevant history regarding our Technical Specificatio'1s.
In the early 90's, Virginia Power agreed to work with the NRC Staff to convert the Technical Specifications. In fact, North Anna was the pilot Westinghouse plant for a Technical Specification conversion starting in 1990. Unfortunately, the effort continued on for an unacceptably long period of time without clear direction, and with ongoing changes and additions by the NRC Staff. Instead of becoming simpler and more understandable, the Technical Specifications were becoming more complex. After spending more than $2 million over a two year period with r,o prospects of completion in sight, we reluctantly decided to withdraw from the project. - Two years ago, we agreed to convert to the improved Technical Specification format at both the Surry and North Anna Power Stations.
This effort has been delayed because we had to reallocate our resources to
- verify tha completeness and accuracy of our FSARs and to the parallel design basis documentation effort.
9811100291 981029 7
PDR ADOCK 05000338 P
PDR 98/HD0M/
Commissionar McGaffigan suggsstad aftsr the mrmting that wn could h
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rsqutsted to eliminuta ths stction of the Technical Spscifications that ind"*
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'zational titlesjHowsysTthe bian naa previously told us that they would entire Technical Specifications to the improved Te I
pg*7 issues raised at the meeting. Virginia Power ha and cordial relationship with the NRC for years. We may not always ag the NRC findings or conclusions, but we have felt free to discuss the iss frank manner. Similarly, we have found the Staff willing to listen to ou and professional in getting licensng amendments and other NRC action completed.
j However, there are areas where we believe that the NRC-licensee inte can be improved. Virginia Power, like the rest of the utility industry, has b more efficient during the last few years. We have lowered our operating c and have prioritized our activities based on safety significance. We hope would have seen comparable improvements at the NRC. We have shown safe performance cannot only be maintained, but also improved, with but more wisely utilized, urces.
enforcement actions, reque; Nevertheless, many inspections,
.or information, etc., require us to spend resources on activities that we perceive are inconsistent with their safety f(dy significance.
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The use of risk information was widely supported by all at the table. We al O
concur with the increased use of risk information in the regulatory process. The
'q Staff response in this area, however, has not always been supportive or W,
encouraging.
In September 1995, we submitted a request for a Technical i
Specification change for the allowed outage time of our diesel generators a i
North Anna Power Station based on risk information.
That request is still pending.
We have paid over $50,000 in NRC review fees alone on this proposed change and revised the submittal two times at the direction of the Cg StMf, yet the Staff is still not sure of how or whether to approve the change i
industry is being forced to work simultaneously in two realms - one risk-infor p
and one deterministic.
This causes a great deal of confusion and wastes resources, k
Timeliness was another area discussed at the stakeholder meeting. We a to see the commission and NRC management willing to improve the timeliness of NRC actions. As noted before in the emergency diesel generator allowed outage time example, some licensing actions take unreasonable amounts of time to complete. Additionally, resolution of proposed generic activities often languis in spite of the cost benefit without safety consequence.
1 For example, our l
proposed rulemaking on final audits for security, emergency planning, and A
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fitn:ss for cuty w:s suomitt:0 on Doc $mber 30, 1993, cnd hks y$t to be
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- dispositioned.
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- Again, I want to personally thank the Commission for embarking in such a i
constructive exchange with its stakeholders. We support efforts to focus the inspection and enforcement areas, to better prioritize activities, and to improve the interaction with the licensees. I hope that we can continue to work together to improve the safety and performance of our plants while maintaining cost control.
Sincerely, l
771b h t
James P. O'Hanlon cc:
Mr. L. J. Callan Mr. S. J. Collins Mr. J. F. Colvin Ms. K. D. Cyr Mr. D. A. Lochbaum Mr. C. A. McNeill, Jr.
Mr. E. A. Nye Mr. Z. T. Pate Mr H. B. Ray Mr. F. J. Remick Mr. L. A. Reyes i.
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