ML20244E625
| ML20244E625 | |
| Person / Time | |
|---|---|
| Issue date: | 01/20/1987 |
| From: | Heltemes C NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20149C371 | List:
|
| References | |
| NUDOCS 8701280574 | |
| Download: ML20244E625 (2) | |
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- '/ 'o,, UNITED STATES 8- o. NUCLEAR REGULATORY COMMISSION WASHINGTON,0. C. 20555 Jf . ,I p k% . . . . . .o# JAN 2 01987
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MEMORANDUM FOR: Harold R. Denton, Director Office of Nuclear Reactor Regulation FROM: C. J. Heltemes, Jr., Director Office for Analysis and Evaltation of Operational Data
SUBJECT:
SHORT TERM TECHNICAL SPECIFICATION IMPROVEMENTS Enclosed are our comments on the Short Term Technical Specification Improve-ments Generic Letter as requested by you in your memorandum of December 31,
- 1986. In general, we have no objection to the proposed changes, but the bases for the staff position and some generalized conclusions do not appear to be supported by operational experience. Some detailed connents are enclosed.
Any questions on our cocinents can be addressed to Marc Harper (X24497).
C.L I V. Heltemeq , Jr. , Director J Off for An'llysis and Evaluation of Operational Data
Enclosures:
As Stated j19 9.9 @yW
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Enclosure COMMENTS ON SHORT TERM TECHNICAL SPECIFICATION IMPROVEMENTS
- 1. In general, we believe that the proposed changes in the applicability of the Limiting Conditions for Operation (LCOs) and Surveillance Requirements in Section 3/4.0 of_ the Standard Technical Specifications (STS) are reasonable.
However, we believe the staff's justification for the position taken in con-nection_.with these proposed changes is not well supported by actual plant
- operating experience.
From our review of numerous LERs for many LWRs over a significant number of years,_ very few LERs can be recalled which describe a plant transient occurring while the plant was shutting down. Thus, it would appear that a plant shutdown evolution (which is not a " transient state") does not in and of itself increase the potential for an upset condition. Therefore,there would be no significant difference'in the probability of a plant upset or the consequences attendant to a plant upset which could be drawn from testing during a shutdown evolution versus testing at steady-state power. This would undennine the basis for the staff's position / justification for these changes.
- 2. There are a number of general statements and conclusions in the document that do not appear to have an adequate basis. Some examples are on page 4 of' the discussion in Enclosure 1 (it is likely that the surveillance would be conducted at thu same time that the plant is being shut down; it increases the risk to the plant and public safety; it is overly conservative to assume that systems or components are inoperable; it is concluded that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would be an acceptable time limit, etc.) ,
- 3. Before the generic letter is issued to the licensees, the regions should be given an opportunity to review and connent on the proposed technical specifi-cation improvements.
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