ML20209D788

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Comments on Proposed Fire Protection Tech Specs.Some Tech Specs Seem More Philosophical than Necessary & Should Go in Background Section.C Grimes Response Included.Numbering Sys Explained
ML20209D788
Person / Time
Issue date: 12/11/1984
From: Shields B
NRC
To: Charemagne Grimes, Rosa F
NRC
Shared Package
ML20209D558 List:
References
FOIA-86-274 NUDOCS 8501280108
Download: ML20209D788 (1)


Text

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UNITED STATES NUCLEAR REGULATORY COMMISSION g

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Faust Ibsa Chris Grines FKH:

Bill Shields a'

SLBJECT:

PIOPCSED FIE PK7IECIICN 'lEC11 SPECS My cnly cxment is that scue of the.'Dech Specs (including the proposed 3/4.7.13 & 14) are rather more philoscghical than necessary. See pages B 3/4 3-5,6, B 3/4 7-6,7, for kle. (As an aside, Wre did this incredible nurnbering system oczne fran?) My preference is that 'Dech Specs state specifically what is required without explaining why. 'Ibe why could go in a backgIcund section somewhere if necessary. I see no reason to add 3/4.7.13 & 14 at all, since it merely states the " defense in depth" principle.

I have no ocments cm other proposed changes.

Bill -

The Tech Spec numbering sequence was developed as follows: Section 3.X.Y is the set of LCOs for system X and subsystem Y Section 4.X.Y is the surveillance requirements for the same system and subsystem.

They are combined into section 3/4 so that the LCOs and surveillance requirements would appear together for each subsystem.

Section B_3/4.X.Y is the " bases" and provides the background for the LCOs and surveillance for that subsystem; they are not specs and are intended to be philosophical.

The specific section you referred to is in the bases.

Chris cc: F. Rosa

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