ML20198A025

Forwards Safety Evaluation of Licensee Response to Violation Noted in Insp Rept 50-397/85-11 Re Noncompliance W/Tech Spec Section 6.5.2.7.Licensee Correct & May Want to Amend License to Adopt STS Wording

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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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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78509180251850912Xb Dennis . Ziemann, Acting Deputy Director

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PPft W Poe g ,,la Division of Human Factors Safety

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Enclosure:

As stated

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Enclosure

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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

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individual reviews with reports to the committee by subcommittees or -

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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