ML030090398

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Comment of S.P. Sarver on Behalf of Virginia Electric & Power Co., and Dominion Nuclear Connecticut on Third Year Implementation of the Reactor Oversight Process
ML030090398
Person / Time
Site: Millstone, Surry, North Anna  Dominion icon.png
Issue date: 12/27/2002
From: Sarver S
Dominion Nuclear Connecticut, Virginia Electric & Power Co (VEPCO)
To: Lesar M
NRC/ADM/DAS/RDB
References
67FR70468 00019, GL02-072
Download: ML030090398 (2)


Text

Dominion Generation 5000 Dominion Boulevard, Glen Allen, VA 23060 Dominion December 27, 2002 Ji f-*-i Mr. Michael T. Lesar GL02:072 co x~1 Chief, Rules and Directives Branch Office of Administration Mail Stop T6-D59 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 COMMENTS ON THE THIRD YEAR OF IMPLEMENTATION OF THE REACTOR OVERSIGHT PROCESS

Dear Mr. Lesar:

Virginia Electric and Power Company (Dominion) and Dominion Nuclear Connecticut appreciate the opportunity to provide the following comments on the third year of implementation of the reactor oversight process as requested in the Federal Register, volume 67, number 226, page 70468, on November 22, 2002.

Dominion fully supports the comments submitted by the Nuclear Energy Institute (NEI) on December 20, 2002.

Dominion would also like to point out that although the Reactor Oversight Process has done a reasonable job of focussing licensee and NRC resources on safety significant issues, there have been some noteworthy opportunities missed to further assure that plants are being operated and maintained safely.

Specifically, many NRC resources continue to be used to inspect non-risk significant areas, such as excessive verification of performance indicators, and excessive inspections of areas where industry performance is at an acceptable level of safety, such as the ALARA (As Low As Reasonably Achievable) inspection module in the Occupational Radiation Safety cornerstone. These NRC resources would be better used to follow-up with generic safety issue inspections that are risk significant, such as inspection of licensee programs to ensure compliance with GL 88-05, "Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary Components in PWR Plants."

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If you would like further information, please contact:

Mr. Don Olson donolson@dom.com, or (804) 273-2830 Respectfully, S a Director Nuclear Licensing and Operations Support