ML20107G933

Submits Second Revised Response to NRC 840906 Telcon & Re Violations Noted in Insp Repts 50-438/84-04 & 50-439/84-04.Corrective Actions:Battery Cells Replaced & Reported on 840822 as NRC Bln Eeb 8416

ML20107G933
Person / Time
Site:	Bellefonte
Issue date:	09/19/1984
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20107G927	List: ML20107G933 ML20107G939 ML20107G954
References
NUDOCS 8411080328
Download: ML20107G933 (3)

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• TENNECCEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 400 Chestnut Street Tower II Se 19 84 SEP 25 Et3ebe[3  :< ,1984 U.S. Nuclear Regulatory Commission Region II Attn: Mr. James P. O'Reilly, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

Dear Mr. O'Reilly:

BELLEFONTE NUCLEAR PLANT UNIT 1 - SECOND REVISED RESPONSE TO VIOLATION 50-438/84-04-02 FAILURE TO DOCUMENT A CONDITION WHICH IS ADVERSE TO QUALITY Enclosed is TVA's second revised response to the subject violation. This revision is in response to a TVA/NRC telecon on September 6,1984. TVA's  ;

previous nisponses to D. M. Verre111's letter dated March 22, 1984 were  !

submitted on May 10 and June 20, 1984. I If you have any questions concerning this matter, please get in touch with R. H. Shell at FTS 858-2688.

Very truly yours, TENNESSEE VALLEY AUTHORITY Q

\, .

• L. M. Mills, Msnager Nuclear Licensing Enclosure 4 co: Mr. Richard C. DeYoung, Director (Enclosure) j Office of Inspection and Enforcement U.S. Nuolear Regulatory Commission Washington, D.C. 20555 Records Center (Enclosure)

Institute of Nuolear Power Operations 1100 Circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339 l l

8411090328 041031 PDR ADOCK 05000430 0 PDR An Equal opportunity trnployar

, ,7 ENCLOSURE BELLEFONTE NUCLEAR PLANT UNIT 1 SECOND REVISED RESPONSE TO SEVERITY LEVEL V VIOLATION 50-418/94-04-02 FAILURE TO DOCW1ENT A CONDITION WHICH IS ADVERSS TO QUALITY Description of Deficien'cy 10 CFR 50.54(a)(1) requires the licensee to implement the quality assurance program described in TVA Topical Report TVA-TR-75-1 A. Section 17.2.5 of the report requires that activities affecting safety-related functions be conducted in compliance with the Office of Power procedures. Procedure BLA 16.1, Identification of Conditions Adverse to Quality and Corrective  ;

Action, requires documentation of conditions adverse to quality within three working days of identification of the condition and spectries the manner of documentation.

Contrary to the above, by March 2,1934, a condition adverse to quality, froth on the station batteries, had not been documented in nocordance with BLA 16.1 although it had been identified in September 1981.

TVA Response

1. Admission or Dantal of the A11 egad Violation TVA denies the viointion of procedure DLA 16.1 occurred as stated.

However, TVA does admit a violation in that the condition should have been documented on a TVA Division of Construction (CONST) Quality Control Invostigation Report (QCIR) in nocordance with Bellefonte Nuclear Plant Quality Control Procedure (BNP-QCP) 10.26 before receipt of formal documentation which confirmed that a condition adverse to quality did not i

oxist.

2. Hessons for the Violation In September 1991, TVA's Division of Nuolear Power (NUC PR) personnel identified a frothing condition in the unit 1 station batteries. CONST personnel were notified of this condition because the bstterien had not been transferred to the plant operations division (i.e., NUC PR). NUC PR personnel were concerned beonuse the presence of the froth could impete the visual examination of electrolyte level in the batterien, which in 4 maintenance requirement. The roeronsible CONST engineer informally contacted TVA's Office of Cngineering (02) and the vendor, C4D Datterien Division, shortly after identiff ontion of the con 11 tion, but sometime before receipt of the CAD letter dated February 10, 1992. Initial renconse from thode partien in<lionted that the frothing win not a condition adverse to quality and would not result in any deleterioun affects to the batterien.

~

The responsib13 CONST enr.ineer made ta incorrect decisi n reg:rdinst '

t document tion cf the fr; thing condition, in th;t th0 informal information provided was considered to be adequate such that initiation of a QCIR was not required. BNP-QCP-10.26, R4, " Quality Control Investigation Reports," which was in effect in September 1981, required that any information, irregularity, or suspected deficient equipment which could result in a nonconformance should be reported immediately for prompt investigation and evalustion in accordance with the procedure.

3. Corrective Stars Taken and Results Achieved Upon identification of a potential violation by the NRC Inspector, CONST initiated nonconformance report (NCR) 2856, which described the froth and requested evaluation of the condition by 08 and the vendor. The OE response reiter1tted all previous statements in that it indicated the froth should be removed as necessary to prevent interference with normal maintenance procedures. NCR 2856 was closed on June 8, 1984 (However, after NCR 2856 was closed, the *rendor notified TVA that the battery cells would be replaced due to the problems with the " riegel wrap" retainer material. TVA reported this condition under 10 CFR 50.55(e) on August 22, 1994, as NCR BLN EED 8416.)

4. Corrective Steps Taken to Avnto Further Violm* tons TVA considers the incorrect decision made by the responsible CONST engineer to be an isointed occurrencel therefore, no further motion is required.

5. Data Whan Fu n Complianon Will Be Achieved TVA is currently in full compliance.

na nico UNITED STATES

• 'o NUCLEAR REGULATORY COMMISSION g o REilON 11 3 I 101 M ARIETTA STR EET, N.W.

• ATLANTA, GEORGIA 30303 s*****/ SEP 101984 Tennessee Valley Authority ATTN: Mr. H. G. Parris Manager of Power and Engineering 500A Chestnut Street Tower II Chattanooga, TN 37401 Gentlemen:

SUBJECT:

REPORT NOS. 50-438/84-04 AND 50-439/84-04 Thank you for your responses of May 10 and June 20, 1984, to our Notice of Violation issued on March 22, 1984, concerning activities conducted at your Bellefonte facility. We have evaluated your responses and found that they meet the requirements of 10 CFR 2.201. We have discussed this response with your staff and agreed that a supplemental response will be issued. Per a telephone conversation between T. E. Conlon and R. H. Shell on September 5,1984, the supplemental will be submitted by September 29, 1984.

We appreciate your cooperation in this matter.

Sincerely, aA a.

D id M. V#rrelli, Chief Reactor Projects Branch 1 Division of Reactor Projects cc: E. Condon, Bellefonte Nuclear Plant Engineering Coordinator A. M. Qualls, Plant Manager J. W. Anderson, Manager Office of Quality Assurance H. N. Culver, Chief, Nuclear Safety Staff W. R. Brown, Jr., Bellefonte Nuclear Plant Project Manager D. L. William:, Jr., Supervisor Licensing Section K. D. Mali, Project Engineer L. S. Cox, Construction Project Manager t

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