ML20153H423

Forwards Detailed Discussion of Selection of Severity Level Re Disabling All Svc Water Sys on 801209 at Brunswick Unit 2.Citation Will Be Issued on 810316

ML20153H423
Person / Time
Site:	Brunswick, 05000000
Issue date:	03/10/1981
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: ML20151G215 ML20151G381 ML20151K616 ML20153H145 ML20153H177 ML20153H189 ML20153H199 ML20153H369 ML20153H423 ML20153H497 ML20153H506 ML20153H526 ML20153H538 ML20153H559
References
FOIA-88-353 NUDOCS 8809090172
Download: ML20153H423 (3)

Text

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• [I.) , \ - UNITED STATES b'^ 'U

.-  % NUCLEAR REGULATORY COMMISSION l t, (* !, .I REGION 11 y 1,

",,8 101 MARIETTA St., N.W., SulTE 3100

%'D ATLANTA,0 E ORCIA 30303

"* MAk.!, O :ss)

SSINS 6025 ndP MEMORANDUM FOR: Dudley Thompson, Director, Enforcement and Investigation Staff, Office of Inspection and Enforcement FROM: James P. O'Reilly, Director, Region II

SUBJECT:

SELECTION OF SEVERITY LEVEL The violation discussed in the enclosure to this memorandum has been classi-4 fied by Region II 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 relative significance; Background information and our basis for.

select'ng the severity level are described in the enclosure.

We pla i to issue this citation by March 16, 1981. If you have any questions or co.ecerns, please contact C. M. Upright, telephone 242-5623.

We recomend that this example be included in future guidance on the enforce-

=... ment policy.

e.:..). 6%nk0 M 10 ames P. O'Reilly

Enclosure:

Selection of Severity L

, cc: Enforcement Coordinators, Reg n I, l RIII, RIV, RV

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. . . . . . 1 Enclosure SELECTION OF SEVERITY LEVEL i Disabling All Service Water Systems For Maintenance - Brunsw'ck' 2 At 1420 hours0.0164 days <br />0.394 hours <br />0.00235 weeks <br />5.4031e-4 months <br /> on December 9,1980, with Unit 2 in cold shutdown the Unit 2 con-i ventional and nuclear service water systems were secured to repair the 2A con-  !

ventional service water pump dfscharge check valve. Primary coolant temperature 4

"; at this time was less than 120 F. At 1615 hours0.0187 days <br />0.449 hours <br />0.00267 weeks <br />6.145075e-4 months <br />, R4R pumps ("A" loop) were secured  ;

to reduce coolant heat input from the pumps. Primary coolant temperature at this  !

time was approximately 1500,F. Due to unexpected problems, repairs to the valve  ;

took longer than anticipated. At 2015 hours0.0233 days <br />0.56 hours <br />0.00333 weeks <br />7.667075e-4 months <br />, the conventional and nuclear service i water systems ure returned to service following the check valve replacement. ,

Pri. nary. coolant temperature at this time, as read at the vessel bottom head drain, j was 1470F. At 2033 hours0.0235 days <br />0.565 hours <br />0.00336 weeks <br />7.735565e-4 months <br />, shutdown cooling was initiated with the "B" loop of  ;

RHR and the coolant temperature reached a local maximum of 2560F,  !

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The reactor head vents were open during this tirre with :ero pressure in the reactor vessel. Primary coolant temperature did not reach the boiling point as there was no ,

i exhaust of steam from the open head vent. 1 During the time from 1420 to 2015 hours0.0233 days <br />0.56 hours <br />0.00333 weeks <br />7.667075e-4 months <br />, all service water pumps were inoperable.

This is. contrary to Technical Specification (TS) 3.7.1.2.b., which requires that  !

during cold shutd:wn there shall be at least three operable service water pumps, j

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TS 3.7.1.2.b further requires in the action statement that with only one service j water pumo operable restore at least two service water pumps to OPERABLE status

within 7 days or declare the core spray system, the LPCI system and the diesel

generator inoperable and take the ACTION required by Specifications 3.5.3.1, i i 3.5.3.2 and 3.8.1.2. i l

Contrary to this requirement, for a period of approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> no service I i water pumps were operable on Unit 2 and the LPCI system, the core spray system i and the diesel generators were not declared inoperable, which exceeds the Limit- ,

l ing Condition for Operation, and failure to verify the operability of at least l

} one LPCI subsystem within four hours, violates the appropriate action statement i i

requirements referenced above.  !

! This violation has been classified as a severity level IV vice a severity level  !

] III based on the following mitigating circumstan:es. l i

1. The Unit I service water system was operable and could have been manually cross connected if necessary, with the Unit 2 service water system. This ]

1. capability was recognized when the Unit 2 service water system was taken l out of service for maintenance. When the licensee operations supervisor  ;

! realized the cross connection capability could not be utilized to satisfy i i technical specification requirements for o;erability NRC was notified. I j The licensee entered this condition based on a misinterpretation of the

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Technical Specification, thinking that operable Unit 1 service water pumps with manual cross connect capability would satisfy the Unit 2 requirements.

2. Additionally, fire water was available for diesel generator cooling.

3. Even without service water the core spray systems were still capable of supplying water to the reactor vessel from the condensate storage: tank in ,

an emergency, t

4. When it was recognized that these conditions were in excess of the Technical i

Specifications, the service water system was restored as soon as reasonably possible, ,

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