ML20235D718

Responds to Region V 870318 Memo Re Inappropriate Use of Tech Spec Limiting Condition for Operation (LCO) 3.0.3. Generic Ltr 87-09 Issued to Address Subj in Rewritten Bases for LCO 3.0.3

ML20235D718
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
ML20235D721	List: ML20235D718 ML20245A620
References
GL-87-09, GL-87-9, NUDOCS 8709250321
Download: ML20235D718 (1)

Text

'

t June 17, 1987

• ' g MEMORANDUM FOR: William T. Russell, Regional Administrator, Region I J. Nelson Grace, Regional Administrator, Region II I A. Bert Davis, Regional Administrator, Region III lb

• Robert D. Martin, Regional Administrator, Region IV John B. Martin, Regional Administrator, Region V 1

FROM: Thomas E. Murley, Director Office of Nuclear Reactor Regulation

SUBJECT:

INTENTIONAL ENTRY INTO TECHNICAL SPECIFICATION LIMITING CONDITION FOR OPERATION 3.0.3 This is in response to Region V's memorandum of March 18, 1987, (Enclosure 1) wherein they referred to an inappropriate use of Technical Specification Limiting Condition for Operation (LCO) 3.0.3 by the Palo Verde licensee. It I

was suggested that it might be beneficial for NRR to issue some generic communication to reiterate NRC's position on the intended purpose of LCO 3.0.3 and clarify the NRC's expectation concerning licensee management control of entry into it.

LCO 3.0.3 is not intended to be used as an operational convenience which permits redundant 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 into LCO 3.0.3 deliberately removes 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 s only for test, maintenance, or repair purposes. ystem from service is justified 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 recommend that all Regions increase communication with resident inspectors and plant management on this subject, thereby promoting a heightened awareness by the inspectors, licensee management and plant personnel of the intended limited use of LC0 3.0.3. We believe these actions will be sufficient to address this problem. .. signed bz hMMurley, Direttor Thomas ,E.

Office of Nuclear Reifetor Regulation

Enclosures:

As stated h

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