ML20198A025
| ML20198A025 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 09/12/1985 |
| From: | Ziemann D Office of Nuclear Reactor Regulation |
| To: | Novak T Office of Nuclear Reactor Regulation |
| References | |
| CON-WNP-0824, CON-WNP-824 TAC-59581, NUDOCS 8509180251 | |
| Download: ML20198A025 (3) | |
See also: IR 05000397/1985011
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DISTRIBUTION:
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SEP 121985
HBocher
LCrocker
MEFORANDUM FOR:
Thomas M. Novak, Assistant Director
for Licensing
Division of Licensing
FROM:
Dennis L. Ziemann, Acting Ceputy Director
Division of Human Factors Safety
SUBJECT:
EVALUATION OF M CTON pV3LIC POWEP SUPPLY S D
USE OF CORPORATE NUCLEAR SAFETY KE.W Ea anapn
WASHINGTON NUCLEAR PLANT, UNIT 2 (TAC NO. 59581)
A memorandum dated August 29, 1985, from D. F. Kirsch to H. L. Thompson,
requested that NRR assume lead responsibility for evaluation of the position
taken by Washington Public Power Supply System (WPPSS) regarding a notice of
violation issued by Region V for the Washingten ?!uclear Plant, Unit 2
(WNP-2). The violation was noted in Inspection Report 50-397/85-11 and
charged that the Corporate Nuclear Safety Review Board (CNSRB) for WNP-2 was
not performing its duties in accordance with the requirements of Section
6.5.2.7 of the WNP-2 Technical Specifications.
.
Our evaluation of the licensee':
esponse is enclosed.
In light of our
understanding of how other licensees use the corporate level review groups
and our knowledge of the intent of Section 6.5.2.7 of the Standard Technical
Specifications, we have concluded that the licensee is enrrect.
To preclude
pnssible future questions, the licensee may want to amend the WNP-2 Technical
Specifications to incorporate the revised wording that now appears in the
Standard Technt. cal Specifications.
This review was performed by L. Crocker, Licensee Qualifications Branch.
There are no kncwn dissenting opinions.
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Dennis
. Ziemann, Acting Deputy Director
Division of Human Factors Safety
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Enclosure
SAFETY EVALUATION
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
WASHINGTON NUCLEAR PLANT, UNIT 2
DOCKET NO. 50-397
During an inspection at Washington Nuclear Plant, Unit 2 (WNP-2) a violation
was identified regarding the performance of the Corporate Nuclear Safety
Review Board (CNSRB).
The violation was documented in Inspection Report
50-397/85-11. Specifically, the inspector found that the full CNSRB was not
reviewing all safety evaluations of procedure changes, modifications, and
tests and experiments.
Section 6.5.2.7 of the WNP-2 Technical Specifications states that "The CNSRB
shall review:" and includes a list of items a through j that are to be
reviewed. A literal interpretation of these words is that the CNSRB as a
group should perform the reviews.
The licensee's response to the Notice of Violation, documented in a letter to
the Regional Administrator dated July 2,1985, denied the alleged violation.
The licensee contends that the words, "The CNSRB shall review," do not state
that each member shall review each item and that the phrase does not preclude
individual reviews with reports to the committee by subcommittees or
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technical specialists.
The NRR staff agrees with the licensee's interpretation.
The Technical
Specifications for WNP-2 were based on Revision 4 to the Standard Technical
Specifications for Boiling Water Reactor (BWR) plants, which contained the
phrase, "The (CNRAG) shall review:."
(The term CNRAG in the Standard
Technical Specifications is the generic term for the corporate level review
committee that the licensee refers to as the CNSRB.) The staff recognized
the possible narrow interpretation of the Technical Specification words and,
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in Revision 5 to the Standard Technical Specifications, the words were
changed to "The (CNRAG) shall be responsible for the review of:," thereby
explicitly acknowledging that it was not intended that the full committee had
to participate in each review.
We conclude, therefore, that the licensee was not in violation of the intent
of the WNP-2 Technical Specifications.
The licensee's interpretation of the
meaning of Section 6.5.2.7 is the same as the interpretation of the NRR-
staff.
To precl,ude possible future questions, the licensee may wish to amend the
WNP-2 Technical Specifications to conform to the revised wording of
Revision 5 to the Standard Technical Specifications.
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