ML20076E877

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Submits Response to Generic Ltr 83-02 Re Implementation of NUREG-0737 Items.No Tech Spec Changes Required for Items I.A.1.1.3,I.A.1.3,II.E.4.1,II.E.4.2.5,II.E.4.2.6, II.E.4.2.7,II.K.3.3,II.K.3.13,II.K.3.22 & III.K.3.15
ML20076E877
Person / Time
Site: Pilgrim
Issue date: 05/24/1983
From: Harrington W
BOSTON EDISON CO.
To: Eisenhut D
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.1, TASK-1.A.1.3, TASK-2.E.4.1, TASK-2.E.4.2, TASK-2.K.3.03, TASK-2.K.3.13, TASK-2.K.3.19, TASK-2.K.3.22, TASK-2.K.3.27, TASK-2.K.3.45, TASK-TM 83-136, GL-83-02, GL-83-2, NUDOCS 8306010334
Download: ML20076E877 (2)


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BOETON EDISON COMPANY B00 BovLaTON STREET BOSTON. MASSADHUBETTs 02199 WILLIAM D. HARRtNGTON May 24, 1983 BECo Letter No.83-136

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Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.

20555 License No. DPR-35 Docket No. 50-293 Response to Generic Letter 83-02

Dear Sir:

The subject letter contained model technical specifications concerning a number of NUREG-0737 items scheduled for implementation by December 31, 1981. Licensees were requested to review the model technical specifications and submit applica-tions for license amendments where applicable.

Based on our review, we have determined that no technical specification changes are necessary per the reasons outlined below:

(1) STA Training (I.A.1.1.3)

Not Applicable. BECo already has Tech. Spec. for STA.

(2) Limit Overtime (I.A.1.3)

No Tech. Spec. needed.

Boston Edison believes it is more prudent and effective to control overtime policy in conjunction with our administrative policies rather than in an inflexible manner such as a license amendment via technical specifications.

(3) Dedicated Hydrogen Penetrations (II.E.4.1)

No Tech. Spec. needed. BECo has made a modification to the containment vent and purge system for the purposes of Post Accident Containment Combustible Gas Control. The valves of this modification are tested in accordance with Appendix J testing program. A description of this modification was provided to NRC in BECo Letter #82-159 dated June 4,1982.

(4) Containment Pressure Setpoint (II.E.4.2.5_)

N/A per NRC discussion section.

(5)

Containment Purge Valves (II.E.4.2.6)

N/A - NRC states that each utility will be reviewed separately for Tech.

Spec. need.

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CO3 TON EDCON COMPANY Mr. Darrell G. Eisenhut, Director May 24,1983 Page 2 (6) Radiation Signal on Purge Valves (II.E.4.2.7)

N/A - NRC currently reviewing Owners' Group submittal.

The need for Tech.

Specs. will be evaluated after the technical resolution of this issue is completed.

(7) Reporting SV and RV Failures and Challenges (II.K.3.3)

No Tech. Spec. needed. BECo already reports failures and provides challenges of SRV's in monthly operating reports to NRC.

(8)

RCIC Restart & RCIC Suction (II.K.3.13, II.K.3.22)

No Tech. Spec. needed.

Our existing Tech. Specs. already cover these sys-tems, as the modifications required by NRC were logic changes and testing was addressed via procedure update.

Additionally, BECo has provided tech-nical exception to Item II.K.3.22 (RCIC Suction).

(9)

Isclation of HPCI & RCIC Modification (III.K.3.15)

No Tech. Spec. needed.

PNPS Tech. Spec. Table 3.7.1, Page 162, already provides closure time requirements for HPCI & RCIC.

The time delay relay added per this NUREG item is already added to the response time as part of the maximum allowable operating time (seconds).

(10) Interlock on Recirculation Pump Loops (II.K.3.19)

N/A - Concerns non jet pump plants.

(11) Common Reference Level (II.K.3.27)

N/A - BECo does not have a figure in Tech. Specs. defining reactor vessel water levels.

(12) Manual Depressurhation (II.K.3.45)

N/A - NRC states that no Tech. Specs, are required.

Should you have any additional questions or concerns on this subject, please do not hesitate to contact us.

Very truly yours,

.