ML18036B098

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Responds to NRC 921123 Ltr 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  Tennessee Valley Authority icon.png
Issue date: 12/17/1992
From: ZERINGUE O J
TENNESSEE VALLEY AUTHORITY
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9212210328
Download: ML18036B098 (9)


See also: IR 05000259/1992038

Text

A.CCEI ERATED DOCVMENT DISTJUBUTION

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[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 1 1 1 2 2 2 2 1 1'1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 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 1 1 1 1 1 1 1 1 1 1 1 2 2 1 1 1 1 1 1 1 1 D NOTE TO ALL RIDS" RECIPIENTS:

0 PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK.ROOM Pl-37 (EXT.504-2065)TO ELIMINATE YOUR NAME FROh1 DISTRIBUTION

LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 27 ENCL 27

I t(

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

s

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.