ML20107G954

Responds to NRC Re Violations Noted in Insp Repts 50-438/84-04 & 50-439/84-04.Violation Re Station Battery Frothing Denied

ML20107G954
Person / Time
Site:	Bellefonte
Issue date:	05/10/1984
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 8411080340
Download: ML20107G954 (3)

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TENNESSEE VALLEY AUTHORI CH ATTANOOGA. TENNESSEE 374ol 400 Chestnut Street Tower II -

q pl:52 May 10, 1984 U.S. Nuclear Regulatory Commission Region II Attn: Mr. James P. O'Reilly, Regional Administrator 101 Marietta Street, NW, -Suite 2900 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

BELLEFONTE NUCLEAR PLANT UNIT 1 - RESPONSE TO VIOLATION 50-438/84-04 FAILURE TO DOCUMENT A CONDITION WHICH IS ADVERSE TO QUALITY This is in response to D. M. Verrelli's letter dated March 22, 1984, report

, numbers 50-438/84-04, 50-439/84-04 concerning activities at the Bellefonte Nuclear Plant which appeared to have been in violation of NRC regulations. Enclosed is our response to the citations.

Delays of this submittal were negotiated with NRC-0IE Inspector P. E. Fredrickson on April 20, 1984 and again on May 7, 1984.

If you have any questions concerning this matter, please get in touch with R. H. Shell at FTS 858-2688.

To the best of my knowledge, I declare the statements contained herein are complete and'true.

Very truly yours, TENNESSEE VALLEY AUTHORITY L. M. Mills, nager Nuclear Licensing Enclosure cc: Mr. Richard C. DeYoung, Director (Enclosure)

Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission

. Washington, D.C. 20555 Records Center (Enclosure)

Institute of Nuclear Power Operations 1100 Circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339 8411080340 841031 PDR ADOCK 05000438 G PDR 1983-TVA SOTH ANNIVERSARY An Equal Opportunity Empicyer

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• ENCLOSURE

. .' BELLEFONTE NUCLEAR PLANT UNIT 1

' RESPONSE TO SEVERITY LEVEL V VIOLATION 50-438/84-04-02 FAILURE TO DOCUMENT A CONDITION WHICH IS ADVERSE TO QUALITY Description of Deficiency 10 CFR 50.54(a)(1) requires the licensee to implement the quality assurance program described in TVA Topical Report TVA-TR-75-1A. 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 specifies the

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manner of documentation.

Contrary to the above, by March 2,1984, a condition adverse to quality, froth on the station batteries, had not been documented in accordance with BLA16.1 although it had been identified in September 1981.

1. Admission of Denial of the Alleged Violation TVA denies the violation of procedure BLA16.1 occurred as stated.

However, TVA does admit that the condition could have been entered into a formal tracking program at the time of discovery.

2. Reason for Denial In September 1981, nine months before acceptance of the unit 1 station batteries by the Division of Nuclear Power (NUC PR) from the Division of Construction (CONST), NUC PR personnel identified. froth as a concern associated with the unit 1 batteries. At this time, the condition was not documented in accordance with procedure BLA16.1 since BLA16.1 clearly states that " requirements apply to safety-related equipment that has been transferred to the Division of Nuclear Power." The unit

-1 station batteries had not been transferred. TVA personnel from NUC PR, CONST, and the Division of Engineering Design (EN DES) reviewed the station battery frothing and requested vendor evaluation of the frothing concern by phone on February 9,1982. By letter dated

. February 10, 1982, C&D Batteries Division provided the results of their evaluation to TVA by stating the following:

Typically, in such cases where this material is '

found to be on the surface of the electrolyte, it has been identified as minute fragments of glass fiber which have come loose during the handling of the mat and separator assembly during the mainte-nance of the cell as well as an excess amount of the binder used to adhere the glass mat assembly to the separator.

Consequently, sinca all matsrials used in the manu-

• fcoture cf tha cells are compatible with othse ,

components within tha es11 itself, there are no

• adverse conditions which may develop-apart from a cosmetic hppearance. .Thus, no deleterious effects ',

regarding cell life or performance will be antici-pated concerning,this matter.- ,

On June '24, .1982, NUC PR accepted transfer of station batteries 1EU-01

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and the previous results of the evaluation concerning frothing from CONST. Since.the condition adverse to quality had been identified and was considered resolved before transfer, the condition was not documented in accordance with BLA16.1.

However, as a result of NUC PR's continuing concern over the cosmetic appearance of the froth formation on unit 1 station batteries, the

-vendor performed the froth removal- procedure in December 1982. By letter dated January 16, 1984, C&D Batteries Division providel TVA the results of their further evaluation as follows:

Typically, the material found floating on the t electrolyte surface is fragments / filaments of the

. cells' retainer mat material. The mat is located

i. within the cell element between the positive plate and the separators. The mat is intended to reduce

. the shedding of active material normally experienced

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from the positive plate during the cells antici-pated service life.

l Although we have received reports that conditions

• may develop wherein the mat material may fragment ~ '

and float on, or become suspended within, the cell electrolyte, typically it does not affect or interfere with the cellp performance or life expectancy apart from the cell' having a poor cosmetic appearance.

C&D Batteries has conducted tests on cells similar to those at Bellefonte which were manufactured with.

and without a retainer mat assembly.' The net . re sult .

of all- tests was that full life -expectancy 'could be realized without the retainer mat along with equal or improved cell performance capabilities.

In rummary, at the time of discovery, TVA did not believe that the item was a condition adverse to quality and consequently, did not believe that it should have been documented as such. TVA does not believe it -

tis appropriate to initiate a review of items in accordance with BLA16.1 '

at the time of transfer which have been previously resolved by technical review by CONST and EN DES.

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