ML20206Q491

Discusses Intentional Entry Into TS Limiting Condition for Operation 3.0.3 by Licensee

ML20206Q491
Person / Time
Site:	Palo Verde
Issue date:	06/17/1987
From:	Murley T Office of Nuclear Reactor Regulation
To:	Davis A, Grace J, Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20206Q315	List: IA-99-174, Discusses Intentional Entry Into TS Limiting Condition for Operation 3.0.3 by Licensee ML20206Q311 ML20206Q381 ML20206Q457 ML20206Q491
References
FOIA-99-174 NUDOCS 9905190143
Download: ML20206Q491 (1)

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Enclosure 2

,s June 17, 1987

.fiMORANDUM FOR: Villiam T. Russell, Pepional Administrator, Region 1 J. Nelson Grace, Regional Administrator, Region 11 A. Bart Davis, Regional Administrator, Region 111 P.obert D. Martin, Regional Administrator, Region IV John B. Hertin, Regional Administrator, Region v .

1 FROM: Thomas E. Murley, Director l Office of Nuclear Reactor Regulatior , l

SUBJECT:

INTENTIONAL ENTR'f INTO TECHNICAL SPECIFICATION .

LIMITING CONDITION FOR OPERATION 3.0.3 l

This is in response to Region V's merorandum of March 18, 1987, (Enclosure 1) l wherein they referred to an inappropriate use of Technical Specification l Limiting Condition for Operation (LCO) 3.0.3 by the Palo Verde licensee. It was suggested that it might be beneficial for NRR to issue some generic l comunication to reiterete NRC's position on the intended purpose of LC0 3.0.3  !

and clarify the NRC's expectation concerning licensee management control of I entry into it.

LCO 3.0.3 is not intended to be used as an operational convenience which permits reduncant safety systems to be out of service for a limited period of time. Its intended purpose is to provide guidance on the time limits for an

" orderly" shutdown when the individual Limiting Conditions for Operation or ACTION statements in other specifications cannot be complied with. Voluntary entry inte LCO 3.0.3 deliberately reroves the last echelon of defense against deleterious events by allowing removal of a system from service when its redundant counterpart is already out of service or inoperable. An action such as this would show a significant disregard for plant safety and is unacceptable.

It should also be emphasized that removal of a system from service is justified -

i only for test, maintenance, or repair purposes.

On June 4,1987 as part of the short term Technical Specifications improvement Program we issued Generic letter 87-09 which, among other things, addresses this subject in a rewritten BASES for LCO 3.0.3 (Enclosure 2). Additionally, we recomend that all Regions increase comunication with resident inspectors and pitnt management on this subject, thereby promoting a heightened awareness by the inspectors, licensee management and plant personnel of the intended -

limited use of LCO 3.0.3. We believe these actions ..

will be sufficient to signed by, address this problem.

M">8 LAMi%dM l Thomas,E. Murley, DirR tor Office of Nuclear Reictor Regulation Y

9905190t43 9905tB 174 PDR NBE C/' s- -

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