ML20151G215

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Discusses Selection of Severity Levels for Enforcement Guidance Memos.Agrees W/Classification of Case Cited in Encl Oreilly 810219 Memo Attachment.W/O Encl
ML20151G215
Person / Time
Issue date: 02/25/1981
From: Thompson D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To: Snyder G, Streeter J, Upright C
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
ML20151G218 List:
References
FOIA-88-353 EGM-81-12, NUDOCS 8104300284
Download: ML20151G215 (2)


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UNITED sTATIs F

NUCLEAR REGULATORY COMMISSION e

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EGM-81-12 FE2 2 51001 MEMORANDUM FOR:

Gary Snyder Region I t

Charles Upright, Region II John Streeter, Region III Walter Vetter, Region IV Allen Johnson, Region V i

FROM:

Dudley Thompson, Director Enforcement and Investigations, IE l-[r'

SUBJECT:

EGM - SELECTION OF SEVERITY LEVEL M'

TheviolationdiscussedinthisEGMwasclassifiedbyRegionIIasSeherity Level IV. Based on a literal reading of the guidance.provided.in the pro-posed NRC Enforcement Policy supplements, a higher severity level could be assigned. After staff review and confinning recormendations, I agree that the lower severity level was the proper course in this case. The facts of this case are as stated in the Enclosure to O'Reilly's memo dai.ed February 19, 1981 (copy enclosed).

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The proposed Enforcement Policy classifies "A Technical Specification Limiting Condition for Operation being exceeded where the appropriate Action Statement was not. satisfied;" as a Severity Level III. Region II classified the violation as a Severity 1.evel IV based on the following mitigating circumstances:

l.

The.LCO which was hiolated is intended to maintain the boric acid in solution.

The boric acid remained in solution due to continue recirculation i

of the solution with the "A" pump while the heat tracing was being repaired.

2.

A low temperature alarm for the heat trace was in service.

3.

Prompt action was taken to return the heat trace circuits to service.

4 Prompt action was taken by the licensee to meet the LCO Action Statcment when the condition was identified.

That is, reactor shutdown was initiated.

We agree with this classification and feel that this case should be used as an example of mitigating circumstances to reclassify a violation downward.

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,% f ^k Dudley ompson, Director Enforcement and Investi Office of Inspection > gations

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Enclosure:

as stated p

See next page for cc's.

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