ML20140C873

Forwards Evaluation of 850620 Response to 850520 Notices of Violation & Deviation from Insp Repts 50-338/85-12 & 50-339/85-12.Response to Notice of Deviation Acceptable,Per NRR Review.Violation Remains as Stated

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

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IJAN 141986

Virginia Electric and Power Company

LATTN: Mr. W. L. Stewart, Vice President,

Nuclear Operations

P. O. Box 26666

Richmond, VA 23261

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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.

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We appreciate your cooperation in this matter.

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Sincerely,

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ORIGINAL slGNED By

VIRGIL L. BROWNLEE

Roger D. Walker, Director

Division of Reactor Projects

Enclosure: (See page 2)

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-Enclosure:

Staff Evaluation of Licensee

Response

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vif. W. Harrell, Station Manager

TAC E. Clark, Manager - ,,

Nuclear Programs and Licensing

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DNRC Resident Inspector

Document Control Desk

Commonwealth of Virginia

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                                            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

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                                                                                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.
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