ML18036B098

Responds to NRC Re Violation Noted in Insp Repts 50-259/92-38,50-260/92-38 & 50-296/92-38 on 921102-06. Corrective Actions:Support Calculation Revised to Incorporate Loads from Latest Stress Analysis

ML18036B098
Person / Time
Site:	Browns Ferry
Issue date:	12/17/1992
From:	Zeringue O TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9212210328
Download: ML18036B098 (9)

Text

A.CCEI ERATED DOCVMENTDISTJUBUTION SYSTEM r>'EGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9212210328 DOC.DATE: 92/12/17 NOTARIZED: NO DOCKET

~SCIL:50-059 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH.NAME AUTHOR AFFILIATION ZERZNGUE,O.J.

Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 921123 lre re violation noted in Insp Repts 50-259/92-38,50-260/92-38

& 50-296/92-38 on 921102-06.-

Corrective actions:support calculation revised to incorporate loads from latest stress analysis.

DISTRIBUTION CODE:

IEOID COPIES RECEIVED:LTR I

ENCL

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SIZE:

TITLE: General (50 Dkt)-Znsp Rept/Notice of Violation Response NOTES:

S INTERNAL:

RECIPIENT ID CODE/NAME HEBDONPF WILLIAMSiJ.

ACRS AEOD/DEZB AEOD/TTC NRR MORISSEAUPD NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NRR/PMAS/ILRB12 OE-DXR REG FILO 02 EXTERNAL: EGSG/BRYCEPJ H.

NSIC COPIES LTTR ENCL 1

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RECIPIENT ID CODE/NAME ROSSPT.

AEOD AEOD/DSP/TPAB DEDRO NRR/DLPQ/LHFBPT NRR/DOEA/OEAB NRR/PMAS/ILPB NUDOCS-ABSTRACT OGC/HDS3 RGN2 FILE 01 NRC PDR COPIES LTTR ENCL 1

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NOTE TO ALL RIDS" RECIPIENTS:

0 PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK.

ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROh1 DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 27 ENCL 27

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TenneSSee Valley AutnOirty, POSt OttiCe BOX 2000. DeCatur. Atabama 35609.2000 O. J. "Ike" Zering Ue Vice President, Browns Ferry Nuclear Plant OEC 1 7 1992 U.S. Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, D.C.

20555 Gentlemen:

In the Matter of Tennessee Valley Authority Docket Nos. 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) NRC INSPECTION REPORT 50-259, 50-260, 50-296/92-38 REPLY TO NOTICE OF VIOLATION (NOV)

This letter provides TVA's reply to the NOV transmitted by letter from C. A. Julian to M. 0. Medford dated November 23, 1992.

In this letter, NRC cited TVA with a violation involving one example of a pipe support not being qualified to the latest revision of the piping stress analysis.

NRC further stated the "the violation is of concern because it indicated an inattention to design control in the pipe support calculations which could result in overstress of support members."

TVA agrees that the violation occurred;

however, TVA believes that the violation was caused by an isolated human error.

This conclusion is based on' TVA's investigation of this event.

This investigation consisted of reviewing a substantial number of other pipe support calculations.

The results of this investigation revealed that all the support calculations reviewed were in compliance with the applicable design criteria.

Additionally, since this incident was found to be an isolated case and modification to the support was not required, the occurrence has minor safety or environmental significance.

Accordingly, TVA determined that if the incident had been left uncorrected, a

more serious condition would not have developed.

The enclosure to this letter is TVA's "Reply to the Notice of Violation" (10 CFR 2.201).

92122i0328 92i2i7 PDR ADOCK 050002S9 Q

PDR

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U.S. Nuclear Regulatory Commission DEC i 7 1992 If you have any questions, please telephone G. D. Pierce, Interim Manager of Site Licensing, at (205) 729-7566.

Sincerely,

. Zeringue Enclosure cc,(Enclosure):

NRC Resident-Inspector Brogans Ferry Nuclear Plant Route 12, Box 637

Athens, Alabama 35611 Mr. Thierry M. Ross, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

Tennessee Valley Authority Browns Ferry Nuclear Plant (BFI)

Reply to Kotice of Violation (ROV)

Inspection Report Eumber 2

2 2-RESTA OP VIOLATIO "During an HRC inspection conducted on Hovember 2-6, 1992, a violation of HRC requirements was identified.

In accordance with the "General Statement of policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:

10 CFR Part 50, Appendix B, Criteria III, Design Control requires that design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed the original design unless the applicant designates another responsible organization.

TVA Nuclear Engineering procedure HEP-3.1, Attachment 4, Page 1 of 1 states that design inputs, including information such as loads, temperature,

. shall be correctly selected

current, referenced, and applied.

TVA Rigorous Analysis Handbook, Section No. BFN-RAH-401, Rigorous Analysis Checklist requires that the correct support loads from the post processor output, or adjusted loads from'hand calculations, have been transmitted to the support designer.

Contrary to the above, Support Ho. 2-47B46480029 (Calculation Ho.

CD-Q20?0-881980) was not qualified per the latest stress calculation Ho. CD-Q2070-880983, Rev. 2.

Instead, the support calculation qualified the'upport by using the stress loads from Rev.

1 of the stress calculation which were significantly lower than the latest stress loads.

This is a Severity Level IV violation (Supplement I)."

~ S VIO TIO s

o eVoato The violation occurred because of an isolated human error that resulted in a pipe support (2-47B464H0029) not being qualified to the latest revision of the piping stress analysis (Hl-270-2R).

An evaluation vas performed on 70 pipe support calculations to determine if this error occurred in other calculations.

The

'results of this review revealed no reoccurrence of this error.

Therefore, based on the results of. this investigation, TVA has determined that the error, vhich resulted in this violation, vas an isolated case.

o rective Ste s

a%en and Results Achieved During the inspection, TVA revieved 18 of the 38 safety related pipe supports associated vith the affected pipe stress problem (Hl-270-2R).

TVA verified that all of these supports',

except the support that vas found during the HRC inspection, considered the loads from the latest stress analysis.

Subsequent to the inspection,,

TVA completed its review of the remaining 20 of the 38 safety related pipe supports associated vith the affected pipe stress analysis (Hl-270-2R) to verify that the latest loads were considered.

It vas determined that the support calculations vere designed with loads either higher or equal to those in the latest stress

analysis, except for the support that vas found during the HRC inspection.

TVA has revised the support calculation to incorporate the latest loads, determined that no modification to the support vas required, and determined that system operability was not affected.

In addition, 32 additional safety related supports from nine systems received the same reviev as part of TVA's evaluation.

This additional review revealed that the supports were designed using loads equal to or greater than the loads generated by the appropriate pipe stress analysis.

ec ive Ste s That have een or il e

aken o Prevent ec rence Existing TVA design procedures prescribe requirements that ensure the transmittal and receipt of revised support loads.

These procedures also require that this information be incorporated into the appropriate documentation during the design change process.

Since TVA has determined that this is an isolated human error and does not indicate a failure of TVA's Quality Assurance

Program, no additional corrective steps are required.

ate en Fu Com liance i 1 Be chic ed TVA considers that full compliance has been achieved.