ML20128K124

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Informs That NRC 850220 Recommended Tech Spec Rev Re Closing Time Limitation Unnecessary.Description of Valve Position Limits Will Be Placed in First Updated FSAR Following Completion of Mods.Rationale for Proposal Listed
ML20128K124
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 07/03/1985
From: Daltroff S
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To: Stolz J
Office of Nuclear Reactor Regulation
References
NUDOCS 8507100486
Download: ML20128K124 (2)


Text

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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 sHe rLos L. D ALTROFF stic'in'E"p'n*oEion July 3, 1985 Docket Nos. 50-277 50-278 Mr. John F. Stolz, Chief Operating Reactors Branch #4 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.

20555

SUBJECT:

Peach Bottom Atomic Power Station Containment Purge and Vent Valve Technical Specifications

REFERENCE:

Correspondence dated February 20, 1985 J. F. Stolz,yNRC, to E. G. Bauer, Jr.,

PEco

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Dear Mr. Stolz The referenced correspondence approved a greater maximum open position for the containment purge and vent valves contingent upon completion of modifications described in an April 24, 1984

letter, S. L. Daltroff, PECo, to J. F. Stolz, NRC.

Further, the referenced correspondence recommended an addition to the Technical Specifications to reflect the open position limitation, and a maximum five second closing time limitation.

A revision to the closing time specification is not necessary since Table 3.7.1, Primary Containment Isolation Valves, cf the Peach Bottom Technical Specifications currently requires a five second stroke time for the containment purge and vent valves.

The modifications to the valves will include the installation of a mechanical stop that will physically prevent the valve from exceeding the maximum open position.

This design feature will ensure compliance with the position limitations.

Consequently, ettention by the control room operator to this limitation will not be necessary.

An an alternative to specifying the valve position i

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Mr. John F. Stolz, Chiof.

July 3, 1985 i

Page 2 limits in the Technical Specifications, we propose to describe the valve position limits and their bases in the first Updated FSAR following completion of the modification.

The rationale for this proposal is as follows:

1.

The valve position limits are controlled by equipment design, and are therefore not under the control of the control room operators.

The concept of Technical Specification simplification dictates that the document should be oriented to the operators by limiting its content to the operating limits under their control.

The Updated FSAR is the appropriate document for describing the essential design features of the facility.

2.

The addition of design features to the Technical Specifications adds to the complexity and volume of the document and lessens the likelihood that operators would focus attention on matters of importance to safe operation of the facility.

3.

The addition of design features to the Technical Specifications precludes the ability to implement design changes under the provisions of 10 CFR 50.59.

Design changes subject to the license amendment process involves a significant work load for both utility and NRC staffs, and subjects plant design improvements to a very time consuming and complex review process.

This approach is offered for your consideration in the interest of Technical Specification simplification, and streamlining the licensing process.

Should you have any questions regarding this matter, please do not hesitate to contact us.

Very truly yours,

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P. Johnson, Resident Site Inspector