ML20245A620
| ML20245A620 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/18/1987 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20235D721 | List: |
| References | |
| NUDOCS 8704300349 | |
| Download: ML20245A620 (2) | |
Text
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UNITED STAMS ENCLOSURE 1
..JCLEAR REGULATCRY COMMISSK.
,, f j
t REGION Y e
1450 MARIA LAasE.SulTE 210 WWALNUT CREEK, CALIFORNIA 94888
. MAR 181987
' MEMORANDUM FOR: Harold R. Denton, Director Office of Nuclear Reactor Regulation FROM:
J. B. Martin, Regional Administrator
~
Region V
SUBJECT:
INTENTIONAL ENTRY INTO TECHNICAL SPECIFICATION LIMITING CONDITION FOR OPERATION 3.0.3 J
As the result of our review of a recent event which occurred at the Palo.
Verde site, wherein a shift supervisor intentionally bypassed an engineered safety feature as an apparent operational convenience, and thereby entered limiting condition for operation (LCO) 3.0.3, Region V has concluded that it may be beneficial for the NRC to reiterate to both the NRC staff and power reactor licensees, the intent of LCO 3.0.3 and our expectations concerning licensee management control of entry into LCO 3.0.3.
Licensee entry into l
this section of the Technical Specifications appears to occur for one of the i
i following three raasons:
Unintentional entry due to equipment failure, design error, procedural I
error, or personnel error, which places the facility outside the ACTION i
statement of other LCO's.
Intentional entry to perfom a maintenance or surveillance task on O
equipment with some type of unusual design feature which necessitates i
entry into LCO 3.0.3 to perfom the task.
Intentional entry for operational convenience.
j j =-
Region V recognizes that occasional entry into LCO 3.0.3 for surveillance or
]
maintenance purposes may be appropriate, however, this activity should be well thought-out in advance and strictly controlled by management oversight and appropriate procedures. Further, licensees should be encouraged to eliminate, where practical, those design features which result in repeated f
entries into LCO 3.0.3.
Region V contends that intentional entry into LCO 3.0.3 for operational convenience should not be made, except under extremely l
unusual circumstances where. a detailed review by the licensee has concluded that no reduction in safety.will result.
I Although this issue may have been addressed in past NRC guidance to licensees, a reiteration of the NRC positierr ntry into LC0 3.0.3 via an Information Notice or a Generic LetterTppears a propriate.
,q
. B. Martin, Regional Administrator Region V
?
i 4
t ENCLOSURE 2 BASES,
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Specification 3.0.3 establishes the shutdown ACTION requirements that3\\
implemented when a Limiting Condition for. Operation is not met and th'e
{
- condition is not specifically addressed by the associated ACTION require t
The purpose of this specification is to delineate the time limits for pla
'the unit in a safe shutdown MODE when plant operation cannot be maintain within the. limits for safe operation defined.by the Limiting Conditions for Operation and its ACTION requirements.
It is not intended to be used as an j
operational convenience which pemits (routine) voluntary removal of redund i
systemt, or. components from service in Iteu of other alternatives that wo I
result in redundant systems or components being inoperable.
allowed to One hour is operation. prepare for an orderly shutdown,before. initiating a change in plant i
This time pemits the' operator to coordinate the reduction in i
electrical generation with the load dispatcher to ensure the stability andi availability of the electrical grid, MODES of operation permit the shutdown to proceed in a cont manner that is well within the specifico'.naximum cooldown rate and within 4
cooldown capabilities of the facility assuming only the minimum required equipment is OPERABLE.
This reduces thermal stresses on components of the-i O,
primary coolant system and the potential for a plant upset that could ch!
safety systems under conditions for which this specification' applies.
i o
if remedial measures permitting limited continued operation of the facilit under the provisions of the ACTION requirements are completed, the shutd y
may be teminated.
from the point in time there was a failure to meet a limiting i
,0peration.
Therefore, the shutdown may be terminated if the ACTIONr
' requirements have been met er the time limits of the ACTION requirem not expired, thus providing an allowance for the completion of the requi actions.
)
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