ML20140C873
| ML20140C873 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 01/14/1986 |
| From: | Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| References | |
| NUDOCS 8601290014 | |
| Download: ML20140C873 (4) | |
See also: IR 05000338/1985012
Text
"
'4 '
J{P
o
o
N1
IJAN 141986
Virginia Electric and Power Company
LATTN: Mr. W. L. Stewart, Vice President,
Nuclear Operations
P. O. Box 26666
Richmond, VA 23261
.
'
Gentlemen:
SUBJECT:
REPORT NOS. 50-338/85-12 AND 50-339/85-12
This refers to your June 20, 1985 response to our Notices of Violation and
Deviation issued on May 20, 1985, concerning licensed activities conducted at
your North Anna facility, and our July 2,1985 acknowledgement of your response.
Our evaluation, which was in progress on July 2, has since been completed and is
enclosed with this letter.
NRC Region II was unable to evaluate the acceptability of your response to the
Notice of Deviation with respect to the licensing basis for the North Anna units
and, therefore, referred the matter to the Office of Nuclear Reactor Regulation
(NRR) for resolution.
In a memorandum from L.S. Rubenstein to R. D. Walker,
dated December 16, 1985, NRR forwarded its conclusion that no safety problem
would result by deleting the reference to the turbine load limiter from the
North Anna Units I and 2 FSAR.
Your response to the Notice of Deviation is
acceptable. NRC Region II will examine the implementation of your corrective
actions during a future inspection.
After careful consideration of the basis for your denial of the Violation, we
have concluded, for the reasons given in the enclosure, that the Violation as
stated in the Notice is valid.
In accordance with the requirements of 10 CFR 2.201(a), please provide us, within
30 days of the date of this letter, with written statements of the actions you
have taken or plan to correct and prevent recurrence of this Violation and the
date when full compliance will be achieved.
The responses directed by this letter are not Subject to the clearance procedures
of the Office of Management and Budget issued under the Paperwork Reduction Act
of 1980, PL 96-511.
1
We appreciate your cooperation in this matter.
1
Sincerely,
'
ORIGINAL slGNED By
VIRGIL L. BROWNLEE
Roger D. Walker, Director
Division of Reactor Projects
Enclosure: (See page 2)
$0$00
0
0
i\\
r20l
-
-
- - -
-
-
-
-
-
e
.
Virginia Electric and Power Company
2
-Enclosure:
Staff Evaluation of Licensee
Response
cc w/ encl:
vif. W. Harrell, Station Manager
TAC E. Clark, Manager -
,,
Nuclear Programs and Licensing
.
bec w/ enc 1:
DNRC Resident Inspector
Document Control Desk
Commonwealth of Virginia
,
l
l
l
l
l
[
le.(
RII ,
RII ,
RII
(
SfiTod
dE
l
,
50tfenther:bhg
G. J kins
ll
l5.h
1/j)/86
1//86 1//f/86 . .
e . ENCLOSURE STAFF EVALUATION OF LICENSEE RESPONSE The staff has reviewed NRC Inspection Report Nos. 50-338, 339/85-12, the licensee's response dated May 20, 1985, the "D.C. Distribution System" performance test (PT) procedures (1-PT-85 and 2-PT-85), and applicable sections of the facility's Technical Specification (TS). Inspection Report 50-338, 339/85-12 documented the fact that on May 1, 1985, the electrolyte levels of at least one pilot cell (battery 2-II) and numerous other cells in seven of the eight batteries on both Units 1 and 2 were clearly above the maximum level indication marks. This resulted from the licensee's failure to properly conduct station battery surveillance testing as required by TS 4.8.2.3.2 and implemented by 1-PT-85 and 2-PT-85. The licensee responded that the Violation was not correct as stated in the NRC report. They stated that the electrician who performed the PT on April 30, 1985 found the electrolyte levels in the pilot cells on batteries 2-I, 2-II, 2-III, and 2-IV at a level slightly above the upper fill mark due to gas butidup, but that he was able to return the levels to within the PT's acceptance criteria by tapping on the cell casings to degas the batteries. The licensee further stated that, when the batteries were reinspected after being notified of a problem by the NRC resident inspectors on May 1,1985, one pilot cell and several other cells were found to have levels exceeding the upper fill marks. TS surveillance requirement 4.8.2.3.2 states in part that each 125 volt battery be verified operable at least once every seven days by ensuring that the electrolyte level of each pilot cell is between the minimum and maximum level indication marks. Test procedure 1/2-PT-85 requires that the individual performing the test verify that the electrolyte levels of the pilot cells are between the maximum level and one inch below that level. The pilot cells are selected to be representative indicators of overall battery performance. When a pilot cell parameter (e.g. electrolyte level) is noted to deviate from specification there is a distinct probability that other cells within the battery will also exhibit the same condition. The electrician who performed the PT on April 30, 1985, identified a high electrolyte level condition in several pilot cells and degased those cells to obtain an in-specification reading, thereby, allowing him to initial the PT as satisfactory. Obtaining and recording a temporarily satisfactory level reading does not constitute proper performance of the surveillance test. In this case, the electrolyte level again rose to an out-of-specification condition by the time the resident inspectors checked the batteries on the next day (May 1,1985). Since the battery cell electrolyte levels had been adjusted to the top of the operating band approximately two weeks before this incident, any amount of gas accumulation would repeatedly raise the level beyond acceptable limits. Rather than tapping the cell casings to temporarily remove the accumulated gas, prudent action should have been initiated by recording the condition as found and - . - - - - - -
- -, ' JA N 141986 Enclosure 2 obtaining a formal resolution. Additionally, TS Surveillance intervals establish the minimum frequency at which selected parameters must be checked to verify compliance. If experience shows that more frequent checks are necessary to maintain TS requirements then they should be adopted. The electrician who discovered the excessively high pilot cell levels on April 30, 1985, neglected the fact that other cells in the batteries could and, in fact, did exhibit the same condition. This too constitutes improper performance of the surveillance test in that numerous battery cells were allowed to remain in a condition adverse to quality after their adjacent pilot cells were degassed to restore an in-specification level reading. Based upon this evaluation, the staff must conclude that 1/2-PT-85 was improperly performed on April 30, 1985 and that the Violation did occur as stated in the Notice. i }}