ML20149J365

Forwards Response to Encl 2 of Generic Ltr 88-02 Re Isap Ii. Isap II Process Could Provide Useful Tool for Balancing Resolution of Safety Performance Improvement Program Issues. Suggests Meeting Be Held.List of Topics for Meeting Encl

ML20149J365
Person / Time
Site:	Crystal River
Issue date:	02/19/1988
From:	Wilgus W FLORIDA POWER CORP.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
3F0288-16, 3F288-16, GL-88-02, GL-88-2, NUDOCS 8802230011
Download: ML20149J365 (4)

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.C ORPO R ATION February 19, 1988 3F0288-16 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Crystal River Unit 3 Docket No. 50-302 Operating Licensing No. DPR-72 Generic Letter 88-02

Dear Sir:

Attached is Florida Power Corporation's (FPC) response to Enclosure 2 of Generic Letter 88-02. FPC is pleased to express a willingness to consider pursuit of this staff initiative. We do have some reservations, but this proposal contains many elements integral to our own long range planning. These inc19de the development of a level 1 PRA used to help identify and prioritize neeaed safety improvements, utilization of integrated living scheduling techniques to plan major projects and implementation of a more complete configuration management program including significant design reconstitution attributes.

Further we have long expressed the desire to develop resolution strategies for the various generic and plant specific issues facing the NRC staff and FPC.

Finally the ISAP II process could provide a useful tool for balancing the resolution of the Safety Performance Improvement Program (SPIP) issues with other NRC and FPC generated projects.

As noted in our response to your survey, we suggest an individual meeting between our respective staffs. This could be coordinated with a periodic staff / licensee meeting which has been encouraged in several forums. A list of topics for such a meeting is also attached.

We look forward to scheduling a meeting with your staff in the near future.

Since ,

I i W. S. WI Vice President Nuclear Operations Attachrnents g23M ! 2 [0 N KRW/mm P i xc: Dr. J. Nelson Grace i Regional Administrator, Region 11 Mr. T. F. Stetka Senior Resident inspector GENERAL OFFICE: 3201 Thirty fourth Street South

• P.O. Box 14042 e St. Petersburg, Florida 33733 * (813) 866-5151 A Florida Progress Company

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FPC RESPONSES TO ENCLOSURE 2 e i Facility Name: Crystal River Unit 3 ,

l Utility: Florida Power Corporation .,

Individual Contact Name: Ken Wilson, Phone Number (904)70'i-6486 x4549 l Would you be interested in participating in ISAP II?

1. If so, in what time frame?

YES. Timing would depend on the resource demands placed on FPC.

Beginning before publication of the IPE generic letter would be considered premature.

2. Do you believe that an industry /NRC Seminar consisting of a brief discussion by NRC followed by a question and answer period would be beneficial prior to making a decision?  ;

YES. A forum which allowed the potential participant, to privately queg SEP or ISAP participants would also be beneficial.

3. Would you be interested in a one-on-one meeting with the NRC to discuss your particular facility or facilities?

YES. More than one such meeting would be essential prior to actual resource commitment by FPC.

4. If you remain undecided regarding participation, what additional information I

do you need in order to make a decision? I j See Question 5 below.

5. Do you have any potential concerns about participating in ISAP II?

The response to the following concerns / questions would be helpful in i determining FPC's interest in participation:

a FPC is unsure what level of PRA review the NRC staff anticipates and potential fees for such review. A

b. FPC would like to know how the staff will address failure rate data base (generic or plant-specific), human reliability, common cause ,

I faibres, initiating events, external events, etc.  !

c. FPC would like some insight into risk threshold (s) anticipated by the  !

staff (e.g. there will always be a largest contribution to risk). 6

d. FPC is somewhat confused by the partition of operating experience from the PRA. Our PRA incorporates operating experience into its regular maintenance, i

c. FPC would find it helpful for the staff to list some examples 1%strative of it's willingness to actually resolve generic safety issues, based on plant specific PRA insights.

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associated with )any such process,Most significant y, FPC is strongly oppo f

6. Do you have any ', suggestions for program improvement, or changes. t FPC would urge dropping the license amendment aspects. ,

i FPC would hope that our reservations expressed above do not communicate skepticism. Rather, they should demonstrate the serlousness with which we ,

would enter into such a process. '

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ADDITIONAL TOPICS FOR FPC/NRC DISCUSSIONS

1. Resolution / Plans for OSTI Items

2. Safety. Performance Improvement Program (SPIP) Status

3. Outstanding Regulatory Items

4. Plant Specific Simulator

5. Major Plan Development. (Fire, Security, ISI/IST, etc.)

6. Technical Specification Improvements

7. Configuration Management Program at CR-3

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