ML14303A526
| ML14303A526 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley, Millstone, Salem, Nine Mile Point, Palisades, Indian Point, Hope Creek, Three Mile Island, Susquehanna, Limerick, Vermont Yankee, Crystal River  |
| Issue date: | 03/28/2014 |
| From: | Rheault C C & D Technologies |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 49967 | |
| Download: ML14303A526 (16) | |
Text
1012812014 pamqT I U.S. Nuclear Reulatorv Commission Oerations Center Event Renort i Part 21 (PAR) Event# 49967" Rep Org: C&D TECHNOLOGIES INC Notification Date I Time: 03/28/2014 13:02 (EDT)
Supplier: C&D TECHNOLOGIES INC Event Date I Time: 02/14/2012 (EDT)
Last Modification: 10/28/2014 Region: 1 Docket #:
City: BLUE BELL Agreement State: Yes County: License #:
State: PA NRC Notified by: CHRISTIAN RHEAULT Notifications: MEL GRAY R1DO HQ Ops Officer: STEVE SANDIN MARVIN SYKES R2DO Emergency Class: NON EMERGENCY BILLY DICKSON R3DO 10 CFR Section: NRR PART 21 GROUP EMAIL 21.21 (a)(2) INTERIM EVAL OF DEVIATION 21.21(d)(3)(i) DEFECTS AND NONCOMPLIANCE INTERIM PART 21 REPORT - MISALIGNED SEPARATORS IN LCR-25 STANDBY BATTERIES The following is the summary portion of the report submitted by fax:
"Subject Interim Report - Inability to Complete 10CFR Part 21 Evaluation Regarding Misaligned Separators in LCR-25 Standby Batteries "The purpose of this letter is to provide the NRC a report in general conformity to the requirements of 10CFR Part 21.21 (a)(2). On February 14, 2012 C&D Technologies, Inc. ('C&D') was informed by Entergy Operations that an LCR-25 battery installed at the Palisades Nuclear Power Plant had shown signs of misaligned separators (also known as shifted separators) of between 1/8 tol/4 [inch]. This was identified by the Palisades plant on or about November 4, 2011. On January 16, 2012, three additional cells were identified as experiencing separator misalignment.
"C&D requested that Palisades return the affected batteries for evaluation of this anomaly and issued a Return Material Authorization for that purpose. But since voltage readings were acceptable for all units involved, Palisades determined that an operability issue did not exist and opted to keep the batteries in service until their refuel outage scheduled for Fall, 2013. C&D inadvertently closed the internal corrective action without providing an Interim Report as required by 10CFR, Part 21.
"C&D has not performed a root cause technical evaluation to determine if there is any defect in the component or manufacturing process or whether the reported condition may have been due to user abuse of product, improper maintenance or other negligence or error.
"Thus, C&D is submitting this interim report to the NRC and notifying C&D's customers that use C&D LCR-25
S. *-~
10/28/2014 U.S. Nuclear Regulatory Commission OperationsCenter Event Report Page2 batteries of this interim report, and is initiating an action plan to evaluate the reported potential defect and determine whether it could pose a substantial safety hazard for any U.S. licensee using such batteries.
"If you have any questions or wish to discuss this matter or this report, please contact:
Robert Malley VP Quality and Process Engineering bmalley@cdtechno.com (215) 619-7830" The sites affected are:
Palisades - 65 x LCR-25 NUC Batteries and, Crystal River - 4 x LCR-25 NUC Batteries
- *
- UPDATE FROM LARRY CARSON TO JOHN SHOEMAKER AT 1122 EDT ON 09/16/14 * **
The following was excerpted from the final report received from C&D Technologies, Inc. via facsimile:
"Conclusion: The conclusion drawn from the return and analysis is that the misaligned separator was present from the time of assembly in the C&D facility through installation and initial operation.
"Recommendations: C&D recommends that operators of nuclear batteries perform an inspection of their batteries to detect misaligned separators. Inspection may be performed visually, and with the aid of mirrors as necessary.
"Corrective Actions: C&D has enhanced both in process and final battery inspection processes to detect and eliminate misaligned separators from shipment. C&D is also preparing an enhanced incoming inspection work form for nuclear battery operators that will better enable the operators to detect and segregate batteries with misaligned separators from use.
"Further Reporting: No further reporting is anticipated.
"C&D Contacts: Further information on this issue can be obtained from:
"Larry Carson- Nuclear Product Manager Office Phone 215-775-1314 Email: lcarson@cdtechno.com "Robert Malley-VP Quality and Process Engineering Office Phone 215-619-7830 Email bmalley@cdtechno.com" Notified R1 DO (Lilliendahl), R2DO (Sykes), R3DO (Dickenson), and NRR Part 21 Group via email.
- *
- UPDATE PROVIDED FROM ROBERT MALLEY TO JEFF ROTTON AT 1505 EDT ON 10/28/2014 ***
The following information was excerpted from the revised final report submitted by email:
This update (dated 9/22/2014 and provided to NRC on 10/28/2014) is Revision 1 to Final Report from C&D Technologies originally submitted on 9/16/2014.
"An interim report was submitted 3/27/14 while the product was being returned for analysis.
"C&D has performed an analysis of the returned product, and is submitting this report to the NRC and notifying affected C&D customers to the possibility of separator misalignment in LCR, KCR, and LCY products [versus original report affecting LCR products only].
"U.S. Licensees using batteries possibly containing the potential defect are being notified of the filing of this final
10/28/2014 U.S. Nuclear Regulatory Commission OperationsCenter Event Report Page 3 report with recommendations that they examine their batteries for any signs of similar problems.
"If you have any questions or wish to discuss this matter or this report, please contact:
"Robert Malley, VP Quality and Process Engineering, bmalley@cdtechno.com, (215) 619-7830."
List of affected plants:
NRC Region 1: Nine Mile Point, Millstone, Indian Point, Vermont Yankee, Limerick, Three Mile Island, Beaver Valley, Susquehanna, Salem, Hope Creek, Crystal River NRC Region 2: Oconee, St. Lucie, Harris, Robinson, Summer, Farley, Hatch, Vogtle, Browns Ferry, Sequoyah, Watts Bar NRC Region 3: Kewaunee, Fermi, Palisades, Braidwood, Byron, Clinton, LaSalle, Perry, Cook, Duane Arnold, Point Beach, Monticello, Prairie Island NRC Region 4: Arkansas Nuclear One, Grand Gulf, Waterford, Cooper, Fort Calhoun, Diablo Canyon Foreign: Bruce, Laguna Verde, Point Lepreau, Krsko, Darlington, Pickering, Chin Shan, Kuosheng, Maanshan, Lungmen Other: Knoll Atomic Power Laboratory Notified RI DO (Bickett), R2DO (Blamey), R3DO (Lipa), R4DO (Whitten) and NRR Part 21 Group via email.
- *
- UPDATE PROVIDED BY ROBERT MALLEY TO JEFF ROTTON AT 1143 EDT ON 10/28/2014 * **
The following was excerpted from the final report update received by fax:
"The purpose of this letter is to update a report provided to the NRC on 09/22/14 regarding misaligned separators in Class 1 E battery products. We are revising Section II for the models of the product affected, and Section VIII for the advice provided for customers. These revisions are provided below:
"(ii) Identification of the facility, the activity, or the basic component supplied for such facility or such activity within the United States which fails to comply or contains a defect.
"The products affected include LCUN and LCU model lines in addition to the previously reported LCR, KCR, and LCY products. [This did not add to the list of facilities affected]
"(viii) Any advice related to the defect or failure to comply about the facility, activity, or basic component that has been, is being, or will be given to purchasers or licensees.
"Based on experience gained through site visits and review of products that completed product life C&D is changing the criteria for inclusion in the scope of this Part 21 report. The change increases the allowable separator misalignment.
"If you have any questions or wish to discuss this matter or this report, please contact:
"Robert Malley, VP Quality and Process Engineering, bmalley@cdtechno.com, (215) 619-7830."
Notified R1 DO (Bickett), R2DO (Blamey), R3DO (Lipa), R4DO (Whitten) and NRR Part 21 Group via email.
CTTHHNOLOGIES, INC.
Power Solutions 1400 Union Meeting Road Blue Bell, PA 19422 Phone: (215) 619-7849 Fax: (215) 619-7840 September 22, 2014 VIA FACSIMILE Nuclear Regulatory Commission Operations Center 301-816-5151 VIA REGULAR MAIL Document Control Desk US Nuclear Regulatory Commission Washington, DC 20555-0001 VIA OVERNIGHT DELIVERY US Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2746
Subject:
Final Report 10CFR Part 21 Evaluation Regarding Misaligned Separators in LCR-25 Standby Batteries, Revision 1 - Original letter did not include the list of affected utilities.
The purpose of this letter is to provide the NRC a report in general conformity to the requirements of 10CFR Part 21.21 (a)(2). On February 14, 2012 C&D Technologies, Inc.
("C&D") was informed by Entergy Operations that an LCR-25 battery installed at the Palisades Nuclear Power Plant had shown signs of misaligned separators (also known as shifted separators) of between 1/8 to %".This was identified by the Palisades plant on or about November 4, 2011. On January 16, 2012, three additional cells were identified as experiencing separator misalignment.
C&D requested that Palisades return the affected batteries for evaluation of this anomaly and issued a Return Material Authorization for that purpose. But since voltage readings were acceptable for all units involved, Palisades determined that an operability issue did not exist and opted to keep the batteries in service until their refuel outage scheduled for Fall, 2013. C&D inadvertently closed the internal corrective action without providing an Interim Report as required by 10CFR, Part 21. An interim report was submitted 3/27/14 while the product was being returned for analysis.
C&D has performed an analysis of the returned product, and is submitting this report to the NRC and notifying affected C&D customers to the possibility of separator misalignment in LCR, KCR, and LCY products.
NRC Final Report September 22, 2014 Page 2 of 4 Required information per 10CFR Part 21.21 (d)(4) follows:
(i) Name and Address of the individualor Individuals informing the Commission Christian Rheault (or Designee)
President and Chief Executive Officer C&D Technologies, Inc.
1400 Union Meeting Road Blue Bell, PA 19422-0858 (ii) Identification of the facility, the activity, or the basic component supplied for such facility or such activity within the United States which fails to comply or contains a defect.
LCR, KCR, and LCY products. The specific analysis involved LCR-25 batteries; however, due to similarity in manufacturing, separator misalignment may occur in other flooded battery products.
(iii) Identification of the firm constructing the facility or supplying the basic component which fails to comply or contains a defect.
C&D Technologies, Inc.
1400 Union Meeting Road Blue Bell, PA 19422-0858 (iv) Nature of the defect or failure to comply and the safety hazard which is created or could be createdby such defect or failure to comply.
Separator misalignment was discovered in installed LCR batteries at the Palisades Nuclear Power Plant. Analysis of the batteries and manufacturing systems showed that these products with misaligned separators escaped through final battery inspection and incoming inspection at Palisades, and if the problem had gone undetected, contact between battery plates may have occurred. This would affect the operability of the battery by reducing cell voltage and capacity. Analysis of warranty data since January 2007 provides an approximate frequency of this issue in nuclear and similar commercial product of 40 ppm (0.004%).
(v) The date on which the information of such defect or failure to comply was obtained.
February 14, 2012. Interim report issued March 2014.
(vi) In the case of a basic component which contains a defect or fails to comply, the number and location of these components in use at, supplied for, being supplied for, or may be suppliedfor, manufacturedor being manufacturedfor one or more facilities or activities subject to the regulationsin this Part.
NRC Final Report September 22, 2014 Page 3 of 4 Listing attached. Due to similarity in design, all LCR, KCR, and LCY products may be affected, and C&D is notifying all applicable nuclear plants of this issue.
(vii) The corrective action which has been, is being, or will be taken; the name of the individual or organizationresponsible for the action; and the length of time that has been or will be taken to complete the action.
" Provided guidance to Palisades and the industry on the detection of misaligned separators in installed batteries (Palisades in 2012 via warranty response, industry via report issued March 2014).
" Continuous improvement activities in the production facility have resulted in the implementation of more effective inspection processes. Specific actions include:
o Nov. 2012 - Revised product flow in assembly area - The new flow eliminated a section of conveyor that was limiting the Inspector's ability to fully view each battery before the cover was installed. This allowed top view inspection of the element and more effective determination of separator misalignment.
o April 2013: Added high intensity lighting to in-process and final inspection processes to increase inspection effectiveness.
o May 2014 - Revised the flow of products through final inspection to a multi-lane setup in order to maintain part number/lot integrity and improve the spacing between cells, to allow for more effective visualization of separator alignment.
(viii) Any advice related to the defect or failure to comply about the facility, activity, or basic component that has been, is being, or will be given to purchasers or licensees, U.S. Licensees using batteries possibly containing the potential defect are being notified of the filing of this final report with recommendations that they examine their batteries for any signs of similar problems. See attached notification letter and attached list of affected plants.
(ix) In the case of an early site permit, the entities to whom an early site permit was transferred.
Not applicable.
If you have any questions or wish to discuss this matter or this report, please contact:
Robert Malley VP Quality and Process Engineering bmalley@cdtechno.com (215) 619-7830
NRC Final Report September 22, 2014 Page 4 of 4 Sincerely, ,
Christian Rheault President and Chief Executive Officer C&D Technologies, Inc.
Attachment - C&D Letter to Users of LCR, KCR, and LCY batteries entitled "Separator Misalignment KCR and LCR batteries dated 9/12/14 Attachment - Separator Misalignment LCR, KCR, and LCY batteries List of Affected Plants Cc: D. Anderson J. Miller R. Malley S. DiMauro L. Carson J. Anderson
Power Solutions 1400 Union Meeting Road Blue Bell, PA 19422 Phone: (215) 775-1314 Fax: (215) 619-7887 September 22, 2014 Customer Name and Address (see attached list)
Ref: Separator Misalignment LCR, KCR, and LCY batteries
Dear Sir/Madam:
C&D Technologies, Inc. ("C&D") is filing a report with the NRC for an incident that occurred with a safety related product at Palisades Nuclear Power Plant.
Background:
In February 2012 C&D was notified by Palisades Nuclear Power Plant that a routine inspection of their 2010 LCR-25 batteries showed misalignment in the separators, as shown on Figure la and lb. This issue had not been detected in previous inspections at Palisades and was not detected in outgoing inspection of the battery on shipment from C&D. The initial conclusion was that the separator had shifted in service.
Figure Ia Figure lb Prior to Disassembly After Jar Removal The immediate critical aspect of misaligned separators is whether the plate edges were exposed, allowing development of contact between the plates. In this case the edges were not exposed, and the battery remained in service until an outage in 2014. The battery was returned for analysis and an interim report for this issue was issued in March 2014. The initial report by C&D field service personnel suggested that the separator had shifted in service, leading to the conclusion that the separators could move spontaneously, or under the forces present in a stationary and normally operated battery.
Evaluation: The batteries were returned to C&D for disassembly and evaluation. The misaligned separator was in the same location as photographed at the site. Other than the misaligned separator there were no anomalies or defects present in the batteries, and no contact or shorting had developed around the misaligned separator. The battery had remained operable until removal from the site.
The nature of the assembly process, cell design, battery plate dimensional and mechanical properties, and separator design and mechanical properties prevent the movement of the separator parallel to the plates, once the element is seated in the jar, regardless of the forces applied to the battery or cell. Friction between the separator (specifically the glass fiber mat on the separator) and the plate surfaces prevents movement of the separator in the completed unit.
Analysis of warranty and customer input databases show a total of seven units being returned from product lines used for nuclear applications (LCR, KCR, and LCY), including the four units returned from Palisades since January 2007. The report rate for this type of issue is less than 40 parts per million.
==
Conclusion:==
The conclusion drawn from the return and analysis is that the misaligned separator was present from the time of assembly in the C&D facility through installation and initial operation.
During assembly misalignment between the separators and the plates can occur during the stacking operations and/or while the battery element is lifted and placed into the container. The visual inspection of the element at the factory did not detect the misaligned separator, and the C&D field service manual and other documentation do not describe misaligned separators as a potential defect for customer inspection.
Recommendations: C&D recommends that operators of nuclear batteries perform an inspection of their batteries to detect misaligned separators. Inspection may be performed visually, and with the aid of mirrors as necessary. The criteria are based on the distance between the edge of the separator and the edge of the positive plate. Nominal distance for K and L cells is 0.3". Criteria are:
0 0.125" to 0.3" - Nominal. No replacement required.
0 0" (Flush with edge of positive plate) to 0.125": Monitor appearance and cell voltage at monthly intervals. Any changes in cell voltage or development of material deposits (mossing) in the affected area warrant timely replacement. Replace at the next available outage if no changes in appearance or cell voltage behavior occur.
0 Flush or less than flush (separator edge between the plates) - immediately contact C&D for guidance on necessary actions as applicable.
Battery replacements can be arranged by contacting C&D. Any questions regarding interpretation of inspection results can also be directed to C&D for assistance.
Corrective Actions: C&D has enhanced both in-process and final battery inspection processes to detect and eliminate misaligned separators from shipment. C&D is also preparing an enhanced incoming inspection work form for nuclear battery operators that will better enable the operators to detect and segregate batteries with misaligned separators from use.
Further Reporting: No further reporting is anticipated.
C&D Contacts: Further information on this issue can be obtained from:
Larry Carson - Nuclear Product Manager Office Phone 215-775-1314 Email: Icarson@cdtechno.com Robert Malley - VP Quality and Process Engineering Office Phone 215-619-7830 Email: bmalley@cdtechno.com
Best Regards, Larry Carson Nuclear Product Manager C&D Technologies, Inc.
cc: C. Rheault - President and CEO D. Anderson - VP General Counsel J. Miller - VP Operations R. Malley - VP Quality and Process Engineering J. Anderson - VP New Technology and Battery Design L. Carson- Nuclear Product Manager S. DiMauro - Quality Systems Manager
Separator Misalignment LCR, KCR, and LCY batteries List of Affected Plants Company Plant Name Bruce Power Bruce CFE Laguna Verde Constellation Nine Mile Point Dominion Kewaunee Dominion Millstone DTE Electric Company Fermi Duke Energy Oconee Electric Boat KAPL Arkansas One Nuclear Entergy Operations, Inc. One Entergy Operations, Inc. Grand Gulf Entergy Operations, Inc. Indian Point Entergy Operations, Inc. Palisades Entergy Operations, Inc. Vermont Yankee Entergy Operations, Inc. Waterford Exelon Braidwood Exelon Byron Exelon Clinton Exelon LaSalle Exelon Limerick Exelon Three Mile Island First Energy Beaver Valley First Energy Perry FP&L St. Lucie Indiana-Michigan Power Cook NB Power Point Lepreau NEK Krsko NextEra Energy Duane Arnold NextEra Energy Point Beach NPPD Cooper NPPD Cooper NPPD Cooper OPG Darlington OPG Pickering OPPD Fort Calhoun PG&E Diablo Canyon PPL Susquehanna Progress Energy Crystal River
Progress Energy Crystal River Progress Progress Energy Harris Energy Harris Progress Energy Robinson Progress Energy Robinson PSEG Nuclear, LLC Salem PSEG Nuclear, LLC Hope Creek SCANA Summer Southern Nuclear Operating Farley Co. Farley Southern Nuclear Operating Hatch Co.
Southern Nuclear Operating Vogtle Co. Vogtle Taiwan Power Chin Shan Taiwan Power Kuosheng Taiwan Power Maanshan Taiwan Power Lungmen Tennessee Valley Authority Browns Ferry Tennessee Valley Authority Sequoyah Tennessee Valley Authority Watts Bar Xcel Energy Monticello Xcel Energy Prarie Island
T--cHNOLGZ INC.
P o Power Solatioas 1400 Union Meeting Road Blue Bell, PA 19422 Phone: (215) 619-7849 Fax: (215) 619-7840 October 27, 2014 VIA FACSIMILE Nuclear Regulatory Commission Operations Center 301-816-5151 VIA REGULAR MAIL Document Control Desk US Nuclear Regulatory Commission Washington, DC 20555-0001 VIA OVERNIGHT DELIVERY US Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2746
Subject:
Update Lo Final Report - 10CFR Part 21 Evaluation Regarding Misaligned Separators in LCR-25 Standby Batteries, Revision 1, Issued 09/22114 The purpose of this letter is to update a report provided to the NRC on 09122/14 regarding misaligned separators in Class 1E battery products. We are revising Section I1for the models of the product affected, and Section VIII for the advice provided for customers. These revisions are provided below:
(ii) Identification of the facility, the activity, or the basic component supplied for such facility or such activity within the United States which fails to comply or containsa defect.
The products affected include LCUN and LCU model lines in addition to the previously reported LCR, KCR, and LCY products.
(viii) Any advice related to the defect or failure to comply about the facility, activity, or basic component that has been, is being, or will be given to purchasers or licensees.
Based on experience gained through site visits and review of products that completed product life C&D is changing the criteria for inclusion in the scope of this Part 21 report.
The change increases the allowable separator misalignment. The change is -described in the attached customer communication.
NRC Final Report October 27, 2014 Page 2 of 2 If you have any questions or wish to discuss this matter or this report, Robert Malley please contact:
VP Quality and Process bmafley@cdtechno.com Engineering (215) 619-7830 Sincerely, Christian Rheault President and Chief C&D Technologies, Executive Officer Inc.
Attachment - C&D "Update on Separator Letter to Users of LCR, KCR, Misalignment in LCUN, LCU and C&D Batteries" LCY batteries entitled Cc: dated 10/27114 D- Anderson J. Miller R- Malley S. DiMauro L. Carson
mucn NO WGUSj mc Power Solutions 1400 Union Meeting Road Blue Bell, PA 19422 Phone: (215) 775-1314 Fax: (215) 619-7887 Octobe.r 27., 2014 Customer Name and Address (see attached list)
Ref: Separator Misalignment LCR, KCR, LCUN, LCU and LCY batteries
Dear Sir/Madam:
C&D Technologies issued a Part 21 notification to the NRC on 09122/14 regarding misaligned separators in our Class I E battery products. After review with several battery operators, further inspection of aged Class IE batteries both at our facilities and at operator sites, and further technical analysis we are updating the Part 21 report with the following recommendations and revisions.
Scope of Product Affected: Due to an oversight, two product lines (LCUN and LCU) were omitted from the original Part 21 report. These are now included in the population, as they have the same basic construction as the KCR and LCR batteries in the original report.
Criteria and Action Plan: The original criteria called for customer action if the separator overlap between two plate edges was less than 1/8". After the original release, C&D has had the opportunity to review batteries returned from Class 1E applications after completion of normal life
(>20years service) as well as populations of batteries in service for more than 13 years. These cells had conditions where there was less than 118" separator overlap since the date of manufacture, with no evidence of performance degradation or formation of any type of short path between the plates. Based on this additional experience we are changing the criteria for action.
Criteria: Cells where the separator is flush to both plate edges, or where the plate edges are exposed to each other without separator between the plates. This does NOT include cases where the positive plate edge only is flush or extends past the separator edge and the negative plate is within the separator. This occurs often in older cells experiencing normal positive plate growth.
Action: The action is to measure and monitor the cell voltage and to perform visual inspections on a monthly basis. Voltage trending and visual inspection will determine If a short is developing in the affected area. A voltage of 2.12V indicates a lower than normal voltage requiring action per our Installation and Operation manual, this includes individual cell charging or equalization or replacement. Please contact C&D with the inspection and voltage data for further instructions.
The original report is attached for your reference.
C&D Contcts: Further information on this issue can be obtained from:
Palisades Misaligned Separators Update Letter October 27, 2014 Page 2 of 2 Larry Carson - Nuclear Product Manager Office Phone 215-775-1314 Email: fcarson@cdtechno.com Robert Malley - VP Quality and Process Engineering Office Phone 215-619-7830 Email: bmalley@cdtechno.com Best Regards, Larry Carson Nuclear Product Manager C&D Technologies, Inc-cc: C. Rheault - President and CEO D. Anderson - VP General Counsel J. Miller - VP Operations R. Malley - VP Quality and Process Engineering J. Anderson - VP New Technology and Battery Design L. Carson - Nuclear Product Manager S. DiMauro - Quality Systems Manager TOTAL P.04