ML20153H177

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Discusses Selection of Severity Level IV for 810114 Loss of Heat Tracing at Robinson 2.Mitigating Circumstances Listed
ML20153H177
Person / Time
Site: Robinson, 05000000
Issue date: 02/19/1981
From: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Thompson D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML20151G218 List:
References
FOIA-88-353 NUDOCS 8809090109
Download: ML20153H177 (3)


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UNITED STATES NUCLEAR REGULATORY COMMISSION b'

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MEMORANDUM TOR: Dudley Thompson, Director, Enforcement and Investigation Staff, Office of Inspection and Enforcement TROM:

James P. O'Reilly, Director, Region II

SUBJECT:

SEIICTION OF SE\\T.RITY LEVEL i

The violation discussed in the enclosure to this memorandum has been classified by Region 11 as Severity Level IV. Based on a literal reading of the detailed guidance provided in the supplements to the proposed enforcement policy, a different severity level could be assigned if one failed to properly consider l

relative significance.

Background information and our basis for selecting the severity level are described in the enclosure.

Ve plan to issue this citation by February 20, 1981. If you have any questions or concerns, please contact C. M. Upright, telephone 242-5623.

Ve recommend that this example be included in future guidance on ;be enforcement policy.

C p

J es P. O'Reilly

Enclosure:

Selection of Severity Level l

0809090109 000017 PDR FOIA UNNERSTABB-353 PDR

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e Multiple Addressees 2

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V. Stello R. DeYoung J. Sniezek H. Thornburg N. Moseley B. Grier RI J. O'Reilly, RII J. Keppler, RIII K. Seyfrit, RIV R. Engelken, RV T. Brockett J. Metzger G. Barber J. Riesland s,.

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l ENCLOStlRE SE11C710N OF SVERITY IIVEL

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Deneyized Heat Trace Circuits - H. B. Robinson 2 At 9:35 a.m. on January 14, the licensee issued i clearance to work on beric acid transfer pump "A" heat trace circuits. The instrsctions for work on Boric Acid Transfer Pump "A" are contained in Robinson's Operations Work Procedure C".*C-6 in Revision 5 of Standing Order No. 9.

The clearance was placed in accordance with the procedure as interpreted by the operator. About two hours later an I end C technician performing a daily periodic test on heat tracing noted heat trace circuits for both the "A" and "B" Boric Acid Transfer Pump were denergized.

Tne I and C technician reported the conditions to the shif t foreman. The shift ferenan started reactor shutdovu in accordance with 10 CFR 50.36(c)(2), since Technical Specification 3.2.3.e, which requires at least one operable channel of heat tracing on the flow path from the boric acid tanks, could not be met.

Reactor power had been reduced 25 mwe when heat tracing was restored to the "B" pump. The temperature in the line did not go below 175 degrees T compared to a 1.z:i t of 145 degrees y and flow through the line was demonstrated in that the i

reactor was being shutdown by deborating with the "B" pump.

Tne loss of heat tracing was caused by an inadequate clearance procedure which

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vas itterpreted to authorize opening the breaker on El primary and El secondary.

T:ese breakers also denergize E2 primary and I2 secondacy and Circuit 5 primary a:d secondary which are the heat trace circuits for the "B" pump and the filter respectively.

The licensee stated the intent of the procedure was that the f uses would be pulled for the affected heat trace circuits rather than open the breakers.

Tr.is nolation has been classifia.d as a Severity Level IV vice a Level III based c: the following citigating circumstances.

l 1.

The LCO which was violated is intended to na:,ntain the boric acid in solution.

i The beric acid remained in solution due to continue recirculation of the l

I solution with the "A" punp while the heat tracing was being repaired.

1.

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

3.

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

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Prompt action van taken by the licensee to meet regulatory requirements.

That is, reactor shutdown was initiated.

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