ML20210L587

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Responds to NRC Re Violations Noted in Insp Rept 50-328/86-39.Corrective Actions:Meeting W/Nrc Planned & LER Will Be Submitted by 861015
ML20210L587
Person / Time
Site: Sequoyah 
Issue date: 09/22/1986
From: Gridley R
TENNESSEE VALLEY AUTHORITY
To: Grace J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
0282C, 282C, NUDOCS 8610020112
Download: ML20210L587 (2)


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TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 SN 15,g gt F 38 SEP 221986 U.S. Nuclear Regulatory Commission

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Region II ATTN:

Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

Dear Dr. Grace:

SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRC-OIE REGION II INSPECTION REPORT 50-328/86 RESPONSE TO VIOLATION Enclosed is our response to Gary G. Zech's August 21, 1986 letter to S. A. White which transmitted Notice of Violation No. 50-328/86-39-01 for our Sequoyah Nuclear Plant. Enclosure 1 is our response to the subject violation. We do not recognize any other actions described herein or the subject inspection report as commitments.

If you have any questions, please get in touch with M. R. Harding at 615/870-6549.

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

Very truly yours, TENNESSEE VALLEY AUTHORITY R. Gridley, Di ector Nuclear Safety and Licensing Enclosure cc (Enclosure):

Mr. James Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. C. G. Zech Director, TVA Projects U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 8610020112 860922 PDR ADOCK 05000328 G

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e ENCLOSURE 1 RESPONSE - NRC-0IE INSPECTION REPORT NO. 50-328/a6-39 GARY G. ZECH'S LETTER TO S. A. WHITE DATED AUGUST 21, 1986 Violation 50-328/86-39-01 During the Nuclear Regulatory Commission (NRC) inspection conducted on June 23-26, 1986, a violation of NRC requirements was identified. The violation involved failure to report errors discovered in INCORE program calculations.

In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the violation is listed below:

10 CFR 50.73, paragraph (a)(2)(i)(B) requires the licensee to report in a Licensee Event Report any operation or condition prohibited by the plant's Technical Specifications.

Technical Specification 3/4.2.2 requires an axial flux curve W(z) to be used in a monthly surveillance of Fq(z). Technical Specification 3/4.2.3 requires that rod bow penalty factors be used to perform a monthly surveillance of the parameter R.

2 Contrary to the above, Cycle 3 was operated from December of 1984 through August 1985, with incorrect W(z) and rod bow penalty data used for all the monthly Fq(z) and R2 surveillances, failure to use correct W(z) and rod bow penalty data when monthly surveillances were performed did not comply with Technical Specifications. When the error was discovered, it was not reported to the NRC as required by 10 CFR 50.73.

This is a Severity Level V violation (Supplement I).

1.

Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.

2.

Reason for Violation The violation is attributed to misunderstanding of the guidance provided for reporting events of this nature.

3.

Corrective Steps Taken and Results Achieved An LER will be submitted by October 15, 1986.

4.

Corrective Steps Taken to Avoid Future Violations Due to the nature of this violation, a meeting with the NRC is considered I

necessary to ensure understanding of the reporting requirements. This j

will help ensure that events of which NRC has a high interest and which do not clearly fall under a 10 CFR 50.73 rule are properly evaluated and LERs written.

5.

Date When Full Compliance Will Be Achieved Full compliance will be achieved by October 15, 1986, when the LER is submitted.

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