ML20044E572

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Comment Supporting Proposed Generic Ltr for Relocation of TS Tables on Instrument Response Time Limits
ML20044E572
Person / Time
Site: Surry, North Anna  Dominion icon.png
Issue date: 05/19/1993
From: Bowling M
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-58FR18118 58FR18118, NUDOCS 9305250175
Download: ML20044E572 (1)


Text

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93 m 21 N055 VIRGINIA POWC*t May 19, 1993 Chief, Rules Review and Directives Branch Serial No.93-305 .!~

U. S. Nuclear Regulatory Commission NL&P/RBP .

Washington, D. C. 20555 Gentlemen:  ;

VIRGINIA ELECTRIC AND POWE1 COMPANY ,

COMMENTS ON PROPOSED GENERIC LETTER FOR '

HELOCATION OF THE TECHNICAL SPECIFICATION TABLES ON i INSTRUMENT RESPONSE TIME LIMITS .

Virginia Power has reviewed the Nuclear Regulatory Commission's (NRC's) Federal ,

Register notice dated April 7,1993 which procosed to issue a generic letter providing j guidance for the voluntary relocation of tables for instrument response time limits from Technical Specifications to the Updated Final Safety Analysis Report (UFSAR). ,

Relocating the tables for reactor trip system and engineered safety feature actuation  !

system instrument response times from the Technical Specifications to the UFSAR will  ;

not alter these surveillance requirements. However, the proposed change will allow the licensee to administratively control changes to response time limits in accordance ,

with 10 CFR 50.59 without the need to process a license amendment request. I We endorse the proposed generic letter and believe that the proposed change will l result in an improved usage of Technical Specification. The NRC staff should be  !

commended for the proposed generic letter as it provides both a human factors j improvement to Technical Specifications while also providing a reduction in regulatory i requirements that are burdensome and unnecessary. ,

Very truly yours, l l

MAQ l

M. L. Bowling, Manager l Nuclear Licensing and Programs i g52 175 930529 50 SBFR18228 ppg 1 i

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