ML20198A345

Forwards Safety Evaluation Re Licensee Response to Violation III Noted in Insp Rept 50-397/85-11.Licensee Interpretation of Tech Spec Correct.Process Initiated to Revise Wording in Tech Specs to Conform to STS

ML20198A345
Person / Time
Site:	Columbia
Issue date:	10/24/1985
From:	Thompson H Office of Nuclear Reactor Regulation
To:	Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
CON-WNP-0835, CON-WNP-835 TAC-59581, NUDOCS 8510290555
Download: ML20198A345 (1)

See also: IR 05000397/1985011

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CCT 2.1 1985

Docket No.: 50-397

MEMORANCUM FOR: Dennis F. Kirsch, Acting Director

Divisicn of Reactor Safety and Projects

FROM: Hugh L. Thompson, Jr. , Director

Division of Licensing

SUBJECT: EVALUATION OF WPPSS RESP 0!lSE TO NOTICE OF VIOLATION REGARDING

USE OF CORPORATE NUCLEAR SAFETY REVIEW BOARD FOR WNP-2

REFERENCE: llenorandum: Kirsch to Thompson, " Request for Transfer of

Responsibility for Evaluation of Licensee's Response to

Violation Number III in Inspection Report Number 50-397/85-11,"

dated August 29, 1985.

The review requested by the referenced nenorandum has been accomplished by the

Divisicn of Human Factors Safety ano the resulting Safety Evaluation is ercicsed.

As indicated, NRR has ccncluded that the licensee's interpretatien of the

Technical Specification is correct.

To preclude possible misinterpretations in the future, we have initiated our

process to revise the wording in the UNP-2 Technical Specifications to conform

to that of the Standard Technical Specifications.

This memorandum completes the action recuired by TIA No. 85-62 and closes

TAC No. 59581.

Fraf: MirM h/ for

Hugh L. Thcepson, Jr. , Director

Division of Licensing

Enclosure:

As stated

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SEP 121985

MEMORANDUM FOR: Thomas M. Novak, Assistant Director

for Licensing

Division of Licensing

FROM: Dennis L. Ziemann, Acting Deputy Director

Division of Human Factors Safety

SUBJECT: EVALUATION OF WASHINGTON PUBLIC POWER SUPPLY SYSTEM

USE OF CORPORATE NUCLEAR SAFETY REVIEW BOARD FOR

WASHINGTON NUCLEAR PLANT, UNIT 2 (TAC N0. 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 Washington Nuclear 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 requtrements of Section

6.5.2.7 of the WNP-2 Technical Specifications.

Our evaluation of the licensee's response 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 correct. To preclude

possible future questions, the licensee may want to amend the WNP-2 Technical

Specifications to incorporate the revised wording that now appears in the

Standard Technical Specifications.

This review was performed by L. Crocker, Licensee Qualifications Branch.

There are no known dissenting opinions.

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Dennis L. Ziemann, ting Deputy Director

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Division of Human Factors Safety

Enclosure:

As stated

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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 thes'e 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

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 CNSR8.) 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 preclude 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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