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  
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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I 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.

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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 M. L. Bowling, Manager Nuclear Licensing and Programs i

g52 175 930529 50 SBFR18228 ppg 1

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