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{{#Wiki_filter:Enclosure 8 Case Study 4: Do we need to clarify what is meant by "operational convenience" Meeting Summary of the January 27 & 28 Meeting with NRC/TSTF Dated March 9, 2009 Case Study 4: Do we need to clarify what is meant by "operational convenience The term "operational convenience" appears four times in the Bases of each ISTS NUREG. It does not appear in the Specifications.
{{#Wiki_filter:Enclosure 8 Case Study 4: Do we need to clarify what is meant by "operational convenience" Meeting Summary of the January 27 & 28 Meeting with NRC/TSTF Dated March 9, 2009
The LCO 3.0.2 Bases state: The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally.
 
The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems.
Case Study 4: Do we need to clarify what is meant by "operational convenience The term "operational convenience" appears four times in the Bases of each ISTS NUREG. It does not appear in the Specifications.
Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be made for operational convenience.
The LCO 3.0.2 Bases state:
Additionally, if intentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead. Doing so limits the time both subsystems/divisions of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered. Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.The LCO 3.0.3 Bases state: This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.
The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems. Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be made for operational convenience. Additionally, if intentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead. Doing so limits the time both subsystems/divisions of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered. Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.
The SR 3.0.2 Bases state: The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.
The LCO 3.0.3 Bases state:
The SR 3.0.3 Bases state: Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence.
This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.
Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals.
The SR 3.0.2 Bases state:
While up to 24 hours or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity.
The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.
The determination of the first reasonable opportunity should ....The term "operational convenience" is not used in the Standard Review Plan (NUREG-0800), the NRC Enforcement Manual, or NUREG-1022, "Event Reporting Guidelines." 12 A wide search of the NRC ADAMS system was also performed without discovering any additional information that could be used to support a definition.
The SR 3.0.3 Bases state:
The term "operational convenience" first appears in the model Technical Specifications in Generic Letter 87-09, "Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements." The Model BWR Technical Specifications 3.0 Bases (Generic Letter 87-09, Enclosure  
Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence.
: 5) only mentioned "operational convenience" in LCO 3.0.3 Bases. However, the PWR 3.0 Bases, Generic Letter 87-09 Enclosure 3, included the "operational convenience" limitation in the LCO 3.0.1 Bases. See the attached pages. In both cases, the term "operational convenience" was equated with "routine voluntary removal of a system(s) or component(s) from.service in lieu of other alternatives that would not result in redundant systems or components being inoperable." Also, in both the PWR LCO 3.0.1 Bases and the PWR and BWR LCO 3.0.3 Bases, the discussion of "operational convenience" was in the context of Actions requiring a shutdown.It appears that during the development of Revision 0 of the ISTS NUREGs, the term "operational convenience" was separated from the concept of "routine voluntary removal of a system(s) or component(s) from service in lieu of other alternatives that would not result in redundant systems or components being inoperable" used in Generic Letter 87-09 and the term was introduced into the SR 3.0.2 and SR 3.0.3 Bases in circumstances in which the Generic letter 87-09 intent was not applicable.
Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals. While up to 24 hours or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should ....
The NRC Inspection Manual, Part 9900 -Technical Guidance, document entitled, "Voluntary Entry into Limiting Conditions for Operation Action Statements to Perform Preventative Maintenance," states: Performing on-line PM (e.g., emergency diesel generator overhaul at power) requires intentionally entering the technical specifications (TS) limiting conditions for operation (LCO)for the affected system. If a licensee does this, it must complete the PM and restore operability within the time specified in the appropriate action statement of the LCO (i.e., the allowed outage time (AOT) 1). Intentional entry into an action statement of an LCO is not a violation of the TS (except in certain cases, such as intentionally  
The term "operational convenience" is not used in the Standard Review Plan (NUREG-0800),
'creating a loss of function situation or entering LCO 3.0.3 simply for operational convenience).
the NRC Enforcement Manual, or NUREG-1022, "Event Reporting Guidelines."
For example, TS allow licensees to perform surveillance testing during power operation, even though such testing requires entry into LCO action statements.
12
TS permit entry into LCO action statements to perform surveillance testing for a number of reasons. One reason is that the time needed to perform most surveillances is usually only a small fraction of the AOT associated with the action statement.
 
Another reason is that the benefit to safety (increased level of assurance of reliability and verification of OPERABILITY) derived from meeting surveillance requirements is considered to more than compensate for the risk to safety from operating the facility in an LCO action statement for a small fraction of the AOT.This discussion is consistent with the Generic Letter 87-09 discussion.
A wide search of the NRC ADAMS system was also performed without discovering any additional information that could be used to support a definition.
The Inspection Manual reference to "intentionally creating a loss of function situation" is comparable to the Generic Letter 87-09 discussion of alternatives that would result in redundant systems orcomponents being inoperable.
The term "operational convenience" first appears in the model Technical Specifications in Generic Letter 87-09, "Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements." The Model BWR Technical Specifications 3.0 Bases (Generic Letter 87-09, Enclosure 5) only mentioned "operational convenience" in LCO 3.0.3 Bases. However, the PWR 3.0 Bases, Generic Letter 87-09 Enclosure 3, included the "operational convenience" limitation in the LCO 3.0.1 Bases. See the attached pages. In both cases, the term "operational convenience" was equated with "routine voluntary removal of a system(s) or component(s) from.service in lieu of other alternatives that would not result in redundant systems or components being inoperable."
13 Based on the discussion presented above, the definition of entering Actions for "operational convenience" is "routine voluntary removal of a systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable." Recommendation The Bases should be modified to be consistent with the intent of the phrase "operational convenience" as originally presented in Generic Letter 87-09. The LCO 3.0.1 Bases should be modified to state: The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally.
Also, in both the PWR LCO 3.0.1 Bases and the PWR and BWR LCO 3.0.3 Bases, the discussion of "operational convenience" was in the context of Actions requiring a shutdown.
The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems.
It appears that during the development of Revision 0 of the ISTS NUREGs, the term "operational convenience" was separated from the concept of "routine voluntary removal of a system(s) or component(s) from service in lieu of other alternatives that would not result in redundant systems or components being inoperable" used in Generic Letter 87-09 and the term was introduced into the SR 3.0.2 and SR 3.0.3 Bases in circumstances in which the Generic letter 87-09 intent was not applicable.
Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be used for made for .perational ecnvenieneet routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.
The NRC Inspection Manual, Part 9900 - Technical Guidance, document entitled, "Voluntary Entry into Limiting Conditions for Operation Action Statements to Perform Preventative Maintenance," states:
ifintentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead. Doing so limits the time both subsystems/divisions of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered. Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable whenthis time limit expires, if the equipment remains removed from service or bypassed.The LCO 3.0.3 Bases are correct as written.The SR 3.0.2 Bases should be revised to state: The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an ,prati....
Performing on-line PM (e.g., emergency diesel generator overhaul at power) requires intentionally entering the technical specifications (TS) limiting conditions for operation (LCO) for the affected system. If a licensee does this, it must complete the PM and restore operability within the time specified in the appropriate action statement of the LCO (i.e., the allowed outage time (AOT) 1). Intentional entry into an action statement of an LCO is not a violation of the TS (except in certain cases, such as intentionally 'creating a loss of function situation or entering LCO 3.0.3 simply for operational convenience). For example, TS allow licensees to perform surveillance testing during power operation, even though such testing requires entry into LCO action statements. TS permit entry into LCO action statements to perform surveillance testing for a number of reasons. One reason is that the time needed to perform most surveillances is usually only a small fraction of the AOT associated with the action statement. Another reason is that the benefit to safety (increased level of assurance of reliability and verification of OPERABILITY) derived from meeting surveillance requirements is considered to more than compensate for the risk to safety from operating the facility in an LCO action statement for a small fraction of the AOT.
This discussion is consistent with the Generic Letter 87-09 discussion. The Inspection Manual reference to "intentionally creating a loss of function situation" is comparable to the Generic Letter 87-09 discussion of alternatives that would result in redundant systems orcomponents being inoperable.
13
 
Based on the discussion presented above, the definition of entering Actions for "operational convenience" is "routine voluntary removal of a systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable."
Recommendation The Bases should be modified to be consistent with the intent of the phrase "operational convenience" as originally presented in Generic Letter 87-09. The LCO 3.0.1 Bases should be modified to state:
The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems. Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be used for made for   .perational   ecnvenieneet routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable. Addi.ie*.a*ly.-if ifintentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead. Doing so limits the time both subsystems/divisions of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered. Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable whenthis time limit expires, if the equipment remains removed from service or bypassed.
The LCO 3.0.3 Bases are correct as written.
The SR 3.0.2 Bases should be revised to state:
The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an ,prati....
cenvenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.
cenvenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.
The SR 3.0.3 Bases should be revised to state: Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used repeatedly as an operational convenience-to extend Surveillance intervals (other than those consistent with refueling intervals).
The SR 3.0.3 Bases should be revised to state:
14 4- v~jUNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV Z; 611 RYAN PLAZA DRIVE, SUITE 400*- ARLINGTON, TEXAS 76011-4005 August 9, 2004 Gregg R. Overbeck, Senior Vice President, Nuclear Arizona Public Service Company P. 0. Box 52034 Phoenix, Arizona 85072-2034
Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used repeatedly as an operational convenience- to extend Surveillance intervals (other than those consistent with refueling intervals).
14
 
4-     v~jUNITED                       STATES NUCLEAR REGULATORY COMMISSION REGION IV Z;                     611 RYAN PLAZA DRIVE, SUITE 400
  *-
* ARLINGTON, TEXAS 76011-4005 August 9, 2004 Gregg R. Overbeck, Senior Vice President, Nuclear Arizona Public Service Company P. 0. Box 52034 Phoenix, Arizona 85072-2034


==SUBJECT:==
==SUBJECT:==
PALO VERDE NUCLEAR GENERATING STATION -NRC INTEGRATED INSPECTION REPORT 05000528/2004003, 05000529/20041003, 05000530/2004003
PALO VERDE NUCLEAR GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000528/2004003, 05000529/20041003, 05000530/2004003


==Dear Mr. Overbeck:==
==Dear Mr. Overbeck:==
On June 30, 2004, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palo Verde Nuclear Generating Station, Units 1, 2, and 3, facility.
 
The enclosed integrated report documents the inspection findings, which were discussed on July 8, 2004, with you and other members of your staff.The inspection examined activities conducted under your licenses as they relate to safety and compliance with the Commission's rules, and regulations and with the conditions of your licenses.
On June 30, 2004, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palo Verde Nuclear Generating Station, Units 1, 2, and 3, facility. The enclosed integrated report documents the inspection findings, which were discussed on July 8, 2004, with you and other members of your staff.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
The inspection examined activities conducted under your licenses as they relate to safety and compliance with the Commission's rules, and regulations and with the conditions of your licenses. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents eleven NRC identified and self-revealing findings of very low safety significance (Green). Ten:of thesefindings were determined to involve violations of NRC requirements; however, beca-use-of the very low safety significance and because they were entered into your corrective action program, the NRC is treating these findings as noncited violations (NCVs) consistent With Section VI.A of the NRC Enforcement Policy. Additionally, three licensee-identifieid vioiations, which Were determined to be of very low safety significance, are listed in Section 40A7 of this report. If you contest the noncited violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011-4005; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington DC 20555-0001; and the NRC Resident Inspector at Palo Verde Nuclear Generating Station, Units 1, 2, and 3, facility.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, it's enclosure, and your response (if any) will be made available electronically for public inspection Description.
This report documents eleven NRC identified and self-revealing findings of very low safety significance (Green). Ten:of thesefindings were determined to involve violations of NRC requirements; however, beca-use-of the very low safety significance and because they were entered into your corrective action program, the NRC is treating these findings as noncited violations (NCVs) consistent With Section VI.A of the NRC Enforcement Policy. Additionally, three licensee-identifieid vioiations, which Were determined to be of very low safety significance, are listed in Section 40A7 of this report. If you contest the noncited violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011-4005; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington DC 20555-0001; and the NRC Resident Inspector at Palo Verde Nuclear Generating Station, Units 1, 2, and 3, facility.
In March 2001, the licensee determined that the 42-inch containment purge isolation Valve CP-UV-2A/3B, had unreliable seals against containment pressure and declared the valves inoperable.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, it's enclosure, and your response (if any) will be made available electronically for public inspection
On June 15, 2001, the licensee developed an interim strategy for containment purge Penetrations 56 and 57 due to the inability to satisfy Technical Specification Surveillance Requirement 3.6.3.6. 11eilbtejimtstriKli4; Iv&v d~iecl' ring the inboardi aMndY OarF04 akbsIi MSVIn ap n talin liinýh ftehinicagh Spcfiai nspectors cfncuged to hcoply with the requred tactions oeci fa 3 onfrition t) icn Modes 1-4. Thi ategyRis¢cntion uie a Sthe&&t6mcoe ofrlektt fraimeslof the nes and to be explicith jus tife of t linsas pfeangeqont tm1 2, and 3. b0 n have ieentdatothefrav aablE oprtunegy ftmllowine e 42inot ntiit$pp2 nt cofgrain concluspot forsd fjsiicto o netoa entryiinto Ythe 2 atosoTechn i~a Sp ecificationBae 3.0.23tae, Condition , durating Mtodes_ýnr into Timey csho orti be made convenietinc The ispentiorsedtherined tf hat N h concluded.
 
Thahe icese'usheue to correct the nonconforming condition i ieymne through permanent plant modification did notmeerRmgieines.thveGoethnei Letter 91-18,anc teriorti corneton Liensees Refgding wNs inasiroecpio abl sec tion onal Resolution Deg a Noncnformigni tios"satin parts ta nthe N expec time parteof the degnficincy trckf diocuminsthatipotnthall inspectors conclded that reuatr permaens plathe modifcatin eshseod haesieng im ented at the fersmtavailoaes opUningtyePhs followinghientinM uaChpe009"Sgificatoofhedgadannncfrmngcondetrintion.Ti actuions of Technlica'l Sp;,ecifilcationi 3.63 Codiio D, duin MoEs1. Tml corrctin o th noconbrmng ondtio ýwould haeietife thcnerfr R revyiew~ oaliensea aoniendmeant , thog 10dfial CFR 50.O59(c)(1)
Description. In March 2001, the licensee determined that the 42-inch containment purge isolation Valve CP-UV-2A/3B, had unreliable seals against containment pressure and declared the valves inoperable. On June 15, 2001, the licensee developed an interim strategy for containment purge Penetrations 56 and 57 due to the inability to satisfy Technical Specification Surveillance Requirement 3.6.3.6. 11eilbtejimtstriKli4; d~iecl' ring the inboardi aMndYOarF04 Iv&v                                                          akbsIi MSVIn ap               n   talin li nýh cfncuged   to hcoply with the requred                   tactions oeci                   fa           3 onfrition t) icn Modes 1-4. Thi                 ategyRis¢cntion       uie           a Sthe&&t6mcoe             ofrlektt fraimeslof the               andnes refcontlI*e to be explicith jus                             tife t of linsas pfeangeqont tm1 2, and 3.                   b0 n       have                 ieentdatothefrav                   aablE oprtunegy     ftmllowine e 42inot
Aonalysis.
* ntiit
thahe faiure' sheue to correct the nonconforming condition i ieymne through.permanent plant modification did ete meor tant min oss. G ignic f ecance it onl becorausen the Licensee's feailredosbitg a lIcnspecto Mamndmlentipctedn the NRC'souinf Dgabilit tod perormctsreglaoryin funcition., sthies, fning isrt asocatedwt the barrxecsimer amete r that integrity cornerstone.
$pp2           nt       cofgrain                                                     Spcfiai ftehinicagh                nspectors csho orti      be made        for*fperatimng        convenietinc              The ispentiorsedtherined tf Nhat h concluspot                   forsd np*:*nrtelc                    fjsiicto             o netoa         entryiinto Ythe 2 atosoTechnSp        i~aecificationBae        3.0.23tae, Condition , durating Mtodes_ýnr into           Timey teriorticorneton  Liensees RefgdingwNs inasiroecpio                               ablsec tiononal Resolution Deg actuions   of aTechnlica'l Noncnformigni Sp;,ecifilcationi3.63 Codiio     tios"satin        parts D, duin   taMoEs1. N expec nthe      Tml time corrctin o th noconbrmng ondtio ýwould                               haeietife thcnerfr                       R revyiew~ oaliensea aoniendmeant thog              ,       10dfialCFR 50.O59(c)(1) permaens concluded.Thaheplathemodifcatin icese'usheue eshseod to correcthaesieng the nonconformingim theentedcondition iat ieymnefersmtavailoaes through Aonalysis. thahe   faiure'                 to correct the nonconforming condition sheue                                            i     ieymne             through.
Thinfi todne wasiotnlsdtiedfapiid ab toliratngeal eqa eanftaoement.
permanent plant modification did notmeerRmgieines.thveGoethnei Letter 91-18,anc becorausentheLicensee'sfeailredosbitg                      a lIcnspecto Mamndmlentipctedn the NRC'souinf Dgabilit todperormctsreglaoryin funcition.,                         fning isrt sthies,           asocatedwt     the       barrxecsimer parteof the degnficincy trckf              diocuminsthatipotnthall inspectors concldedthat                  reuatr prassessth signtmdificanefiolationsd thatepotental impactmortimpedthe                                freguvalatory oporocesith opUningtyePhs  findoing.can befiassesed uaChpe009"Sgificatoofhedgadannncfrmngcondetrintion.Ti followinghientinM                        sinthe          signific and ocodetrminatonitioproc n ss permanent plant        modification didete                        meor              tantG minoss.        f ignicecance        it onl cocusing the Phas~el1,worksh               inMnalk et             Chapute069"Sgificatinfritnince Denterminationth amete that      r            Thinfi cornerstone.
Atihoeng the singrificanctation.
integrity            wasiotnlsdtiedfapiid todne            ab toliratngeal                  eqa perocness, eanftaoement. pathfindingato Atihoeng the    is determined       to have singrificanctation.      veymowe T      shafetyno       significancebeasitol peroessconodesigned              t afetdtebririntegrity cornerstone.
T peroess conodesigned t prassessth signtmdificanefiolationsd thate potental impactmortimped the freguvalatory oporocesith findoing.can be fiassesed sin the signific and ocodetrminatonitio n proc ss cocusing the Phas~el 1, worksh et inMnalk Chapute069"Sgificatinfritnince Denterminationth perocness, path findingato is determined to have veymowe shafetyno significancebeasitol afetdtebririntegrity cornerstone.
Tifndgwascnsdethedinstallto                                  fblin fltadiingsadeutl mainsstaied containmecnt inegrity.                     uig h               iniiacedtrintopoes Enclosure}}
Tifndgwascnsdethed installto fblin fltadiingsadeutl mainsstaied containmecnt inegrity.
uig h iniiacedtrintopoes Enclosure}}

Latest revision as of 08:27, 14 November 2019

Enclosure 8: Case Study 4: Do We Need to Clarify What Is Meant by Operational convenience- Meeting Summary of the January 27 & 28 Meeting with Nrc/Tstf
ML090640442
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 01/27/2009
From:
NRC Region 4
To:
Marrero, Abe, NRR/DIRS, 415-8531
Shared Package
ML090690151 List:
References
IR-04-003
Download: ML090640442 (5)
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Text

Enclosure 8 Case Study 4: Do we need to clarify what is meant by "operational convenience" Meeting Summary of the January 27 & 28 Meeting with NRC/TSTF Dated March 9, 2009

Case Study 4: Do we need to clarify what is meant by "operational convenience The term "operational convenience" appears four times in the Bases of each ISTS NUREG. It does not appear in the Specifications.

The LCO 3.0.2 Bases state:

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems. Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be made for operational convenience. Additionally, if intentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead. Doing so limits the time both subsystems/divisions of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered. Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.

The LCO 3.0.3 Bases state:

This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.

The SR 3.0.2 Bases state:

The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.

The SR 3.0.3 Bases state:

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence.

Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should ....

The term "operational convenience" is not used in the Standard Review Plan (NUREG-0800),

the NRC Enforcement Manual, or NUREG-1022, "Event Reporting Guidelines."

12

A wide search of the NRC ADAMS system was also performed without discovering any additional information that could be used to support a definition.

The term "operational convenience" first appears in the model Technical Specifications in Generic Letter 87-09, "Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements." The Model BWR Technical Specifications 3.0 Bases (Generic Letter 87-09, Enclosure 5) only mentioned "operational convenience" in LCO 3.0.3 Bases. However, the PWR 3.0 Bases, Generic Letter 87-09 Enclosure 3, included the "operational convenience" limitation in the LCO 3.0.1 Bases. See the attached pages. In both cases, the term "operational convenience" was equated with "routine voluntary removal of a system(s) or component(s) from.service in lieu of other alternatives that would not result in redundant systems or components being inoperable."

Also, in both the PWR LCO 3.0.1 Bases and the PWR and BWR LCO 3.0.3 Bases, the discussion of "operational convenience" was in the context of Actions requiring a shutdown.

It appears that during the development of Revision 0 of the ISTS NUREGs, the term "operational convenience" was separated from the concept of "routine voluntary removal of a system(s) or component(s) from service in lieu of other alternatives that would not result in redundant systems or components being inoperable" used in Generic Letter 87-09 and the term was introduced into the SR 3.0.2 and SR 3.0.3 Bases in circumstances in which the Generic letter 87-09 intent was not applicable.

The NRC Inspection Manual, Part 9900 - Technical Guidance, document entitled, "Voluntary Entry into Limiting Conditions for Operation Action Statements to Perform Preventative Maintenance," states:

Performing on-line PM (e.g., emergency diesel generator overhaul at power) requires intentionally entering the technical specifications (TS) limiting conditions for operation (LCO) for the affected system. If a licensee does this, it must complete the PM and restore operability within the time specified in the appropriate action statement of the LCO (i.e., the allowed outage time (AOT) 1). Intentional entry into an action statement of an LCO is not a violation of the TS (except in certain cases, such as intentionally 'creating a loss of function situation or entering LCO 3.0.3 simply for operational convenience). For example, TS allow licensees to perform surveillance testing during power operation, even though such testing requires entry into LCO action statements. TS permit entry into LCO action statements to perform surveillance testing for a number of reasons. One reason is that the time needed to perform most surveillances is usually only a small fraction of the AOT associated with the action statement. Another reason is that the benefit to safety (increased level of assurance of reliability and verification of OPERABILITY) derived from meeting surveillance requirements is considered to more than compensate for the risk to safety from operating the facility in an LCO action statement for a small fraction of the AOT.

This discussion is consistent with the Generic Letter 87-09 discussion. The Inspection Manual reference to "intentionally creating a loss of function situation" is comparable to the Generic Letter 87-09 discussion of alternatives that would result in redundant systems orcomponents being inoperable.

13

Based on the discussion presented above, the definition of entering Actions for "operational convenience" is "routine voluntary removal of a systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable."

Recommendation The Bases should be modified to be consistent with the intent of the phrase "operational convenience" as originally presented in Generic Letter 87-09. The LCO 3.0.1 Bases should be modified to state:

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems. Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be used for made for .perational ecnvenieneet routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable. Addi.ie*.a*ly.-if ifintentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead. Doing so limits the time both subsystems/divisions of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered. Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable whenthis time limit expires, if the equipment remains removed from service or bypassed.

The LCO 3.0.3 Bases are correct as written.

The SR 3.0.2 Bases should be revised to state:

The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an ,prati....

cenvenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.

The SR 3.0.3 Bases should be revised to state:

Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used repeatedly as an operational convenience- to extend Surveillance intervals (other than those consistent with refueling intervals).

14

4- v~jUNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV Z; 611 RYAN PLAZA DRIVE, SUITE 400

  • -
  • ARLINGTON, TEXAS 76011-4005 August 9, 2004 Gregg R. Overbeck, Senior Vice President, Nuclear Arizona Public Service Company P. 0. Box 52034 Phoenix, Arizona 85072-2034

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000528/2004003, 05000529/20041003, 05000530/2004003

Dear Mr. Overbeck:

On June 30, 2004, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palo Verde Nuclear Generating Station, Units 1, 2, and 3, facility. The enclosed integrated report documents the inspection findings, which were discussed on July 8, 2004, with you and other members of your staff.

The inspection examined activities conducted under your licenses as they relate to safety and compliance with the Commission's rules, and regulations and with the conditions of your licenses. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

This report documents eleven NRC identified and self-revealing findings of very low safety significance (Green). Ten:of thesefindings were determined to involve violations of NRC requirements; however, beca-use-of the very low safety significance and because they were entered into your corrective action program, the NRC is treating these findings as noncited violations (NCVs) consistent With Section VI.A of the NRC Enforcement Policy. Additionally, three licensee-identifieid vioiations, which Were determined to be of very low safety significance, are listed in Section 40A7 of this report. If you contest the noncited violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011-4005; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington DC 20555-0001; and the NRC Resident Inspector at Palo Verde Nuclear Generating Station, Units 1, 2, and 3, facility.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, it's enclosure, and your response (if any) will be made available electronically for public inspection

Description. In March 2001, the licensee determined that the 42-inch containment purge isolation Valve CP-UV-2A/3B, had unreliable seals against containment pressure and declared the valves inoperable. On June 15, 2001, the licensee developed an interim strategy for containment purge Penetrations 56 and 57 due to the inability to satisfy Technical Specification Surveillance Requirement 3.6.3.6. 11eilbtejimtstriKli4; d~iecl' ring the inboardi aMndYOarF04 Iv&v akbsIi MSVIn ap n talin li nýh cfncuged to hcoply with the requred tactions oeci fa 3 onfrition t) icn Modes 1-4. Thi ategyRis¢cntion uie a Sthe&&t6mcoe ofrlektt fraimeslof the andnes refcontlI*e to be explicith jus tife t of linsas pfeangeqont tm1 2, and 3. b0 n have ieentdatothefrav aablE oprtunegy ftmllowine e 42inot

  • ntiit

$pp2 nt cofgrain Spcfiai ftehinicagh nspectors csho orti be made for*fperatimng convenietinc The ispentiorsedtherined tf Nhat h concluspot forsd np*:*nrtelc fjsiicto o netoa entryiinto Ythe 2 atosoTechnSp i~aecificationBae 3.0.23tae, Condition , durating Mtodes_ýnr into Timey teriorticorneton Liensees RefgdingwNs inasiroecpio ablsec tiononal Resolution Deg actuions of aTechnlica'l Noncnformigni Sp;,ecifilcationi3.63 Codiio tios"satin parts D, duin taMoEs1. N expec nthe Tml time corrctin o th noconbrmng ondtio ýwould haeietife thcnerfr R revyiew~ oaliensea aoniendmeant thog , 10dfialCFR 50.O59(c)(1) permaens concluded.Thaheplathemodifcatin icese'usheue eshseod to correcthaesieng the nonconformingim theentedcondition iat ieymnefersmtavailoaes through Aonalysis. thahe faiure' to correct the nonconforming condition sheue i ieymne through.

permanent plant modification did notmeerRmgieines.thveGoethnei Letter 91-18,anc becorausentheLicensee'sfeailredosbitg a lIcnspecto Mamndmlentipctedn the NRC'souinf Dgabilit todperormctsreglaoryin funcition., fning isrt sthies, asocatedwt the barrxecsimer parteof the degnficincy trckf diocuminsthatipotnthall inspectors concldedthat reuatr prassessth signtmdificanefiolationsd thatepotental impactmortimpedthe freguvalatory oporocesith opUningtyePhs findoing.can befiassesed uaChpe009"Sgificatoofhedgadannncfrmngcondetrintion.Ti followinghientinM sinthe signific and ocodetrminatonitioproc n ss permanent plant modification didete meor tantG minoss. f ignicecance it onl cocusing the Phas~el1,worksh inMnalk et Chapute069"Sgificatinfritnince Denterminationth amete that r Thinfi cornerstone.

integrity wasiotnlsdtiedfapiid todne ab toliratngeal eqa perocness, eanftaoement. pathfindingato Atihoeng the is determined to have singrificanctation. veymowe T shafetyno significancebeasitol peroessconodesigned t afetdtebririntegrity cornerstone.

Tifndgwascnsdethedinstallto fblin fltadiingsadeutl mainsstaied containmecnt inegrity. uig h iniiacedtrintopoes Enclosure

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