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{{#Wiki_filter:'CBCEI ERAT DOCUMENT DIST UTION SYSTEM REGULAT Z INFORMATION DISTRIBUTION YSTEM (RIDS)ACCESSION'NBR:9305170154 DOC.DATE: 93/05/10 NOTARIZED:
{{#Wiki_filter:'CBCEI ERAT                   DOCUMENT DIST                   UTION SYSTEM REGULAT     Z INFORMATION DISTRIBUTION         YSTEM (RIDS)
YES FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe AUTH.NAME AUTHOR AFFILIATION PARRISH,J.V.
ACCESSION 'NBR:9305170154           DOC.DATE: 93/05/10       NOTARIZED: YES         DOCKET FACIL:50-397   WPPSS   Nuclear Project, Unit 2, Washington Public             Powe 05000397 AUTH. NAME           AUTHOR     AFFILIATION PARRISH,J.V.         Washington Public Power Supply System RECIP.NAME           RECIPIENT AFFILIATION                                                 R Document Control Branch (Document Control Desk)
Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)DOCKET 05000397 R


==SUBJECT:==
==SUBJECT:==
Application for amend to License NPF-21,changing provisions in TS Section 6.2.3,"Nuclear Safety Assurance Div" Section 6.5.1,"Plant Operations Committee" to reflect realignment of QA Directorate.
Application for amend to License NPF-21,changing provisions in TS Section 6.2.3, "Nuclear Safety Assurance Div" Section 6.5.1, "Plant Operations Committee" to reflect realignment of QA Directorate.
DISTRIBUTION CODE: AOOID COPIES RECEIVED:LTR ENCL i SIZE: 5+TITLE: OR Submittal:
DISTRIBUTION CODE: AOOID TITLE:  OR COPIES RECEIVED:LTR Submittal: General Distribution ENCL   i SIZE:   5+
General Distribution NOTES: RECIPIENT ID CODE/NAME PDV LA CLIFFORDPJ COPIES LTTR ENCL 1 1 2 2 RECIPIENT ID CODE/NAME PDV PD COPIES LTTR ENCL 1 1 D D INTERNAL: ACRS NRR/DORS/OTSB NRR/DSSA/SCSB NRR/DSSA/SRXB OC/LF B~F~Ol EXTERNAL: NRC PDR 6 6 1 1 1 0 1 1 1 0 1 1 1 1 NRR/DE/EELB NRR/DRCH/HICB NRR/DSSA/SPLB-NUDOCS-ABSTRACT OGC/HDS1 NSIC 1 1 1 1 1 1 1 1 1 0 1 1 D D NOTE TO ALL"RIDS" RECIPIENTS:
NOTES:
PLEASE HELP US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-31 (EXT.504-2065)TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDI D TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 19 WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O.Bm 968~3000 Geotge%'asbtngton Way~Rtcbland, Wasbtngton 993524968~(509)372-5000 May 10, 1993 G02-93-107 Docket No.50-397 U.S.Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.20555 Gentlemen:
RECIPIENT              COPIES              RECIPIENT         COPIES ID CODE/NAME           LTTR ENCL         ID CODE/NAME       LTTR ENCL          D PDV LA                      1      1      PDV PD                 1     1 CLIFFORDPJ                  2      2 D
INTERNAL: ACRS                         6      6      NRR/DE/EELB            1    1 NRR/DORS/OTSB               1      1      NRR/DRCH/HICB          1    1 NRR/DSSA/SCSB                1     0     NRR/DSSA/SPLB          1    1 NRR/DSSA/SRXB                1      1    -NUDOCS-ABSTRACT       1    1 OC/LF  B                    1      0      OGC/HDS1               1     0
              ~F  ~        Ol        1     1 EXTERNAL: NRC PDR                      1     1     NSIC                  1     1 D
D D
NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-31 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDI TOTAL NUMBER OF COPIES REQUIRED: LTTR               22   ENCL   19
 
WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Bm 968 ~ 3000 Geotge %'asbtngton Way ~ Rtcbland, Wasbtngton 993524968 ~ (509) 372-5000 May 10, 1993 G02-93-107 Docket No. 50-397 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:


==Subject:==
==Subject:==
WNP-2 OPERATING LICENSE NPF-21 REQUEST FOR AMENDMENT TO TECHNICAL SPECIFICATION 6.0, ADMINISTRATIVE CONTROLS In accordance with the Code of Federal Regulations, Title 10 Parts 50.90 and 2.101, the Supply System hereby submits a request for amendment to the WNP-2 Technical Specifications.
WNP-2 OPERATING LICENSE NPF-21 REQUEST FOR AMENDMENT TO TECHNICAL SPECIFICATION 6.0, ADMINISTRATIVECONTROLS In accordance with the Code of Federal Regulations, Title 10 Parts 50.90 and 2. 101, the Supply System hereby submits a request for amendment to the WNP-2 Technical Specifications. This proposal requests that the provisions in Section 6.2.3, NUCLEAR SAFETY ASSURANCE DIVISION (NSAD) and Section 6.5.1, PLANT OPERATIONS COMMITTEE (POC) be changed, as attached, to allow the implementation of a staff reorganization intended to be more effective in identifying opportunities for performance improvement. Specifically the Quality Assurance Directorate is being realigned to accomplish this objective.
This proposal requests that the provisions in Section 6.2.3, NUCLEAR SAFETY ASSURANCE DIVISION (NSAD)and Section 6.5.1, PLANT OPERATIONS COMMITTEE (POC)be changed, as attached, to allow the implementation of a staff reorganization intended to be more effective in identifying opportunities for performance improvement.
Currently, the Quality Assurance Directorate has three Division Managers reporting to the Director, Quality Assurance. These three Divisions are the Nuclear Safety Assurance Division, Operational Assurance Programs Division and the Programs and Audits Division. Under the proposed realignment, the Quality Assurance Directorate will be comprised of two Divisions:
Specifically the Quality Assurance Directorate is being realigned to accomplish this objective.
Quality Assessments and Quality Support. The proposed realignment will focus all of the current independent oversight functions performed by the Nuclear Safety Assurance Division, Operational Assurance Programs Division and Programs & Audits Division into one Division (Quality Assessments). The Quality Support Division will include the Operating Experience Review (OER) staff and the Operating Experience Analysis and Resolutions, Plant Quality Control and Procurement Quality Assurance Departments as they are currently constituted.
Currently, the Quality Assurance Directorate has three Division Managers reporting to the Director, Quality Assurance.
The OER staff within Nuclear Safety Assurance examines unit operating characteristics, NRC issuances, industry advisories, Licensee Event Reports, and other sources of unit design and operating experience information which may indicate areas for improving safety of WNP-2.
These three Divisions are the Nuclear Safety Assurance Division, Operational Assurance Programs Division and the Programs and Audits Division.Under the proposed realignment, the Quality Assurance Directorate will be comprised of two Divisions:
Detailed recommendations for revised 'procedures, equipment, modifications, maintenance
Quality Assessments and Quality Support.The proposed realignment will focus all of the current independent oversight functions performed by the Nuclear Safety Assurance Division, Operational Assurance Programs Division and Programs&Audits Division into one Division (Quality Assessments).
              >V008>.
The Quality Support Division will include the Operating Experience Review (OER)staff and the Operating Experience Analysis and Resolutions, Plant Quality Control and Procurement Quality Assurance Departments as they are currently constituted.
                                                                                            ,oX qgpsf70f 54 9305 PDR     ADQCK o PDR P
The OER staff within Nuclear Safety Assurance examines unit operating characteristics, NRC issuances, industry advisories, Licensee Event Reports, and other sources of unit design and operating experience information which may indicate areas for improving safety of WNP-2.Detailed recommendations for revised'procedures, equipment, modifications, maintenance
 
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Page 2'EQUEST FOR AMENDMENT TO TECHNICAL SPECIFICATION 6.0, ADMINISTRATIVE CONTROLS activities, operations activities, and other similar activities are made by this organization.
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Under the proposed realignment, all of these functions will continue to be performed by the OER staff reporting directly to the Quality Support Division Manager.The Nuclear Safety Engineering staff within Nuclear Safety Assurance also perform assessments of WNP-2 activities to provide independent verification that activities important to WNP-2 safety are performed correctly and human errors are reduced as much as practical.
 
After the proposed realignment, these assessment functions will be accomplished within the Quality Assessments Division.As stated above, the Quality Assessments Division will encompass the assessment functions formerly performed by the Nuclear Safety Assurance staff, the Operational Assurance Programs staff and the Programs and Audits staff.These organizations have become more performance-based in their reviews.Utilizing a functional area approach, all members of the Quality Assessments Division will be responsible for verifying through field observations, interviews and procedure and document reviews, the safe and efficient operation of WNP-2.As an integral part of this activity, all personnel will be expected to recommend enhancements, including procedure changes, which will assist in improving WNP-2 operations.
Page   2
Consolidation of the assessment staff will assist in increasing resources for more in-depth coverage and improved coordination of reviews.Our review of the impacts of the proposed changes has also included consideration of any negative aspects.In our view, there is a small potential negative aspect that involves the distribution of Section 6.2.3 functions throughout the Directorate rather than maintaining it focused within the Nuclear Safety Assurance Division.The Nuclear Safety Assurance Division (NSAD)is currently chartered, among other functions, with ensuring and improving overall nuclear safety of WNP-2.The alignment being proposed will retain all of the NSAD functions within the Quality Support Division except for safety verification functions which move to the Quality Assessments Division.As stated above, verification of safety has been an important part of the current responsibilities of our oversight organizations.
'EQUEST FOR AMENDMENTTO TECHNICAL SPECIFICATION 6.0, ADMINISTRATIVECONTROLS activities, operations activities, and other similar activities are made by this organization. Under the proposed realignment, all of these functions willcontinue to be performed by the OER staff reporting directly to the Quality Support Division Manager.
This will continue with the new alignment within the Quality Assessments Division and is not considered a negative impact.Management practices will be implemented to assure that the NSAD functions are performed by a composite of staff members that is at least the equivalent of the present NSAD.No other potential negative aspects of this proposed realignment are believed to exist.A change to Section 6.5.1.2 of the Technical Specifications is being proposed to change the membership of POC from the Plant QA Manager to the Manager, Quality Assessments, This is an administrative change associated with the change in position titles for the proposed realignment.
The Nuclear Safety Engineering staff within Nuclear Safety Assurance also perform assessments of WNP-2 activities to provide independent verification that activities important to WNP-2 safety are performed correctly and human errors are reduced as much as practical. After the proposed realignment, these assessment functions will be accomplished within the Quality Assessments Division.
I'l~~L\
As stated above, the Quality Assessments Division will encompass the assessment functions formerly performed by the Nuclear Safety Assurance staff, the Operational Assurance Programs staff and the Programs and Audits staff. These organizations have become more performance-based in their reviews. Utilizing a functional area approach, all members of the Quality Assessments Division willbe responsible for verifying through field observations, interviews and procedure and document reviews, the safe and efficient operation of WNP-2. As an integral part of this activity, all personnel willbe expected to recommend enhancements, including procedure changes, which will assist in improving WNP-2 operations. Consolidation of the assessment staff will assist in increasing resources for more in-depth coverage and improved coordination of reviews.
Page 3'EQUEST FOR AMENDMENT TO TECHNICAL SPECIFICATION 6.0, ADMINISTRATIVE CONTROLS In summary, all of the functions currently being performed by the Nuclear Safety Assurance Division to satisfy the requirements of Section 6.2.3 of the Technical Specifications will continue to be accomplished"within the Quality Assurance Directorate.
Our review of the impacts of the proposed changes has also included consideration of any negative aspects.       In our view, there is a small potential negative aspect that involves the distribution of Section 6.2.3 functions throughout the Directorate rather than maintaining it focused within the Nuclear Safety Assurance Division. The Nuclear Safety Assurance Division (NSAD) is currently chartered, among other functions, with ensuring and improving overall nuclear safety of WNP-2. The alignment being proposed will retain all of the NSAD functions within the Quality Support Division except for safety verification functions which move to the Quality Assessments Division. As stated above, verification of safety has been an important part of the current responsibilities of our oversight organizations. This will continue with the new alignment within the Quality Assessments Division and is not considered a negative impact.
With respect to the proposed Section 6.2.3 and Section 6.5.1.2 Technical Specification changes, the Supply System has reviewed these changes per 10CFR50.92 and has determined that they do not represent a significant hazards consideration because they do not: 1)Involve a significant increase in the probability or consequences of an accident previously evaluated.
Management practices will be implemented to assure that the NSAD functions are performed by a composite of staff members that is at least the equivalent of the present NSAD. No other potential negative aspects of this proposed realignment are believed to exist.
The changes are administrative in nature and involve no physical alteration of the plant or changes to setpoints or operating parameters.
A change to Section 6.5.1.2 of the Technical Specifications is being proposed to change the membership of POC from the Plant QA Manager to the Manager, Quality Assessments, This is an administrative change associated with the change in position titles for the proposed realignment.
Also, the Independent Safety Engineering Group gSEG)functions will be accomplished by staff of the same or better qualifications.
 
Therefore, the probability of an accident precursor failing to be recognized; the plant response to accidents, and therefore consequences of previously reviewed accidents; and, the ability of discovering a poor plant response to an accident will be unchanged or enhanced with this proposed, new alignment.
I 'l   ~ ~ L
The change in substituting the Manager, Quality Assessments for the Plant QA Manager as a member of POC is an administrative change.For these reasons, there will be no significant increase in the probability or consequences of an accident previously evaluated as a result of these changes.2)Create the possibility of a new or different kind of accident from any accident previously evaluated.
    \
Because no change is being made to the design, operation, maintenance, or testing of the plant, a new mode of failure is not created.Therefore, these changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
 
3)Involve a significant reduction in a margin of safety.The proposed changes are administrative changes which do not decrease the competence of staff within the Quality Assurance Directorate.
Page 3
The functions previously provided by the Nuclear Safety Assurance Division to meet the Technical Specification Section 6.2.3 requirements and the guidelines of NUREG-0737 will continue to be provided within the Quality Assurance Directorate.
'EQUEST FOR AMENDMENTTO TECHNICAL SPECIFICATION 6.0, ADMINISTRATIVECONTROLS In summary, all of the functions currently being performed by the Nuclear Safety Assurance Division to satisfy the requirements of Section 6.2.3 of the Technical Specifications willcontinue to be accomplished"within the Quality Assurance Directorate. With respect to the proposed Section 6.2.3 and Section 6.5.1.2 Technical Specification changes, the Supply System has reviewed these changes per 10CFR50.92 and has determined that they do not represent a significant hazards consideration because they do not:
The potential negative impacts are considered to be minimal and do not involve a significant reduction in a margin of safety.The change in substituting the Manager, Quality Assessments for the Plant QA Manager as a member of POC is an administrative change and also does not involve a significant reduction in a margin of safety.  
: 1)     Involve a significant increase in the probability or consequences of an accident previously evaluated. The changes are administrative in nature and involve no physical alteration of the plant or changes to setpoints or operating parameters. Also, the Independent Safety Engineering Group gSEG) functions will be accomplished by staff of the same or better qualifications. Therefore, the probability of an accident precursor failing to be recognized; the plant response to accidents, and therefore consequences of previously reviewed accidents; and, the ability of discovering a poor plant response to an accident will be unchanged or enhanced with this proposed, new alignment. The change in substituting the Manager, Quality Assessments for the Plant QA Manager as a member of POC is an administrative change. For these reasons, there will be no significant increase in the probability or consequences of an accident previously evaluated as a result of these changes.
~)'l't Page 4 REQUEST FOR AMENDMENT TO TECHNICAL SPECIFICATION 6.0, ADMINISTRATIVE CONTROLS As discussed above, the Supply System concludes that these changes do not involve a significant hazards consideration, nor is there a potential for a significant change in the types or significant increase in the amount of any effluents that may be released offsite, nor does the change involve a significant increase in individual or cumulative occupational radiation exposure.Accordingly, the proposed changes meet the eligibility criteria for categorical exclusion set forth in 10CFR51.22(c)(9) and therefore, per 10CFR51.22(b), an environmental assessment of these changes is not required.This Technical Specification change request has been reviewed and approved by the WNP-2 Plant Operations Committee and the Supply System Corporate Nuclear Safety Review Board.In accordance with 10CFR50.91, the State of Washington has been provided a copy of this letter.Conclusion of the review and issuance of the amendment would be appreciated by July 1, 1993, so that full implementation of the QA Directorate proposed realignment may be implemented at that time.Sincerely,.V.Parrish (Mail Drop 1023)Assistant Managing Director, Operations Attachments CC: W Bishop, EFSEC JB Martin, NRC RV JW Clifford, NRC NRC Site Inspector, 901A BH Faulkenberry, NRC RV NS Reynolds, Winston&Strawn DL Williams, BPA/399 STATE OF WASHINGTON
: 2)     Create the possibility of a new or different kind of accident from any accident previously evaluated. Because no change is being made to the design, operation, maintenance, or testing of the plant, a new mode of failure is not created. Therefore, these changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
))COUNTY OF BENTON)
: 3)     Involve a significant reduction in a margin of safety. The proposed changes are administrative changes which do not decrease the competence of staff within the Quality Assurance Directorate.     The functions previously provided by the Nuclear Safety Assurance   Division to meet the Technical Specification Section 6.2.3 requirements and the guidelines of NUREG-0737 willcontinue to be provided within the Quality Assurance Directorate. The potential negative impacts are considered to be minimal and do not involve a significant reduction in a margin of safety.
The change in substituting the Manager, Quality Assessments for the Plant QA Manager as a member of POC is an administrative change and also does not involve a significant reduction in a margin of safety.
 
  ~ )'
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't
 
Page 4 REQUEST FOR AMENDMENTTO TECHNICAL SPECIFICATION 6.0, ADMINISTRATIVECONTROLS As discussed above, the Supply System concludes that these changes do not involve a significant hazards consideration, nor is there a potential for a significant change in the types or significant increase in the amount of any effluents that may be released offsite, nor does the change involve a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed changes meet the eligibility criteria for categorical exclusion set forth in 10CFR51.22(c)(9) and therefore, per 10CFR51.22(b), an environmental assessment of these changes is not required.
This Technical Specification change request has been reviewed and approved by the WNP-2 Plant Operations Committee and the Supply System Corporate Nuclear Safety Review Board.
In accordance with 10CFR50.91, the State of Washington has been provided a copy of this letter.
Conclusion of the review and issuance of the amendment would be appreciated by July 1, 1993, so that full implementation of the QA Directorate proposed realignment may be implemented at that time.
Sincerely,
. V. Parrish (Mail Drop 1023)
Assistant Managing Director, Operations Attachments CC:     W Bishop, EFSEC JB Martin, NRC RV JW Clifford, NRC NRC Site Inspector, 901A BH Faulkenberry, NRC RV NS Reynolds, Winston & Strawn DL Williams, BPA/399
 
STATE OF WASHINGTON )                              


==Subject:==
==Subject:==
Request for Amend to TS 6.0 A mini iv nr 1 I.J.V.PARRISH,-being duly sworn, subscribe to and say that I am the Assistant Managing Director, Operations for the WASHINGTON PUBLIC POWER SUPPLY SYSTEM, the applicant herein;that I have the full authority to execute this oath;that I have reviewed the foregoing; and that to the best of my knowledge, information, and belief the statements made in it are true.DATE , 1993 J.arrish, Assistant Managing Director Operations On this date personally appeared before me J.V.PARRISH, to me known to be the individual
Request for Amend to TS 6.0
'ho executed the foregoing instrument, and acknowledged that he signed the same as his free act and deed for the uses and purposes herein mentioned.
                              )                                    A mini       iv   nr 1 COUNTY OF BENTON              )
GIVEN under my hand and seal this~day of 1993.No Public in d for the STATE OF WASHINGTON Residing at Kennewick W hin on MIC I I 2*24~A'I I I I I l"<<r/,)/)'I eM}}
I. J. V. PARRISH,-being duly sworn, subscribe to and say that       I am the Assistant Managing Director, Operations for the WASHINGTON PUBLIC POWER SUPPLY SYSTEM, the applicant herein; that I have the full authority to execute this oath; that I have reviewed the foregoing; and that to the best of my knowledge, information, and belief the statements made in it are true.
DATE                                   , 1993 J.     arrish, Assistant Managing Director Operations On this date personally appeared before me J. V. PARRISH, to me known to be the individual executed the foregoing instrument, and acknowledged that he signed the same as his free
                                                                                                  'ho act and deed for the uses and purposes herein mentioned.
GIVEN under my hand and seal this   ~day of                                         1993.
No       Public in d for the STATE OF WASHINGTON Residing at Kennewick W hin on MIC         I I   2*24   ~A'I I     I   I
 
Il"
    <<r/,)
          /)'I eM}}

Revision as of 12:48, 29 October 2019

Application for Amend to License NPF-21,changing Provisions in TS Section 6.2.3, Nuclear Safety Assurance Div & Section 6.5.1, Plant Operations Committee to Reflect Realignment of QA Directorate
ML17290A296
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 05/10/1993
From: Parrish J
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17290A297 List:
References
GO2-93-107, NUDOCS 9305170154
Download: ML17290A296 (10)
v • d • e


Text

'CBCEI ERAT DOCUMENT DIST UTION SYSTEM REGULAT Z INFORMATION DISTRIBUTION YSTEM (RIDS)

ACCESSION 'NBR:9305170154 DOC.DATE: 93/05/10 NOTARIZED: YES DOCKET FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION PARRISH,J.V. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION R Document Control Branch (Document Control Desk)

SUBJECT:

Application for amend to License NPF-21,changing provisions in TS Section 6.2.3, "Nuclear Safety Assurance Div" Section 6.5.1, "Plant Operations Committee" to reflect realignment of QA Directorate.

DISTRIBUTION CODE: AOOID TITLE: OR COPIES RECEIVED:LTR Submittal: General Distribution ENCL i SIZE: 5+

NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL D PDV LA 1 1 PDV PD 1 1 CLIFFORDPJ 2 2 D

INTERNAL: ACRS 6 6 NRR/DE/EELB 1 1 NRR/DORS/OTSB 1 1 NRR/DRCH/HICB 1 1 NRR/DSSA/SCSB 1 0 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 -NUDOCS-ABSTRACT 1 1 OC/LF B 1 0 OGC/HDS1 1 0

~F ~ Ol 1 1 EXTERNAL: NRC PDR 1 1 NSIC 1 1 D

D D

NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-31 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDI TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 19

WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Bm 968 ~ 3000 Geotge %'asbtngton Way ~ Rtcbland, Wasbtngton 993524968 ~ (509) 372-5000 May 10, 1993 G02-93-107 Docket No. 50-397 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:

Subject:

WNP-2 OPERATING LICENSE NPF-21 REQUEST FOR AMENDMENT TO TECHNICAL SPECIFICATION 6.0, ADMINISTRATIVECONTROLS In accordance with the Code of Federal Regulations, Title 10 Parts 50.90 and 2. 101, the Supply System hereby submits a request for amendment to the WNP-2 Technical Specifications. This proposal requests that the provisions in Section 6.2.3, NUCLEAR SAFETY ASSURANCE DIVISION (NSAD) and Section 6.5.1, PLANT OPERATIONS COMMITTEE (POC) be changed, as attached, to allow the implementation of a staff reorganization intended to be more effective in identifying opportunities for performance improvement. Specifically the Quality Assurance Directorate is being realigned to accomplish this objective.

Currently, the Quality Assurance Directorate has three Division Managers reporting to the Director, Quality Assurance. These three Divisions are the Nuclear Safety Assurance Division, Operational Assurance Programs Division and the Programs and Audits Division. Under the proposed realignment, the Quality Assurance Directorate will be comprised of two Divisions:

Quality Assessments and Quality Support. The proposed realignment will focus all of the current independent oversight functions performed by the Nuclear Safety Assurance Division, Operational Assurance Programs Division and Programs & Audits Division into one Division (Quality Assessments). The Quality Support Division will include the Operating Experience Review (OER) staff and the Operating Experience Analysis and Resolutions, Plant Quality Control and Procurement Quality Assurance Departments as they are currently constituted.

The OER staff within Nuclear Safety Assurance examines unit operating characteristics, NRC issuances, industry advisories, Licensee Event Reports, and other sources of unit design and operating experience information which may indicate areas for improving safety of WNP-2.

Detailed recommendations for revised 'procedures, equipment, modifications, maintenance

>V008>.

,oX qgpsf70f 54 9305 PDR ADQCK o PDR P

t 1

\

Page 2

'EQUEST FOR AMENDMENTTO TECHNICAL SPECIFICATION 6.0, ADMINISTRATIVECONTROLS activities, operations activities, and other similar activities are made by this organization. Under the proposed realignment, all of these functions willcontinue to be performed by the OER staff reporting directly to the Quality Support Division Manager.

The Nuclear Safety Engineering staff within Nuclear Safety Assurance also perform assessments of WNP-2 activities to provide independent verification that activities important to WNP-2 safety are performed correctly and human errors are reduced as much as practical. After the proposed realignment, these assessment functions will be accomplished within the Quality Assessments Division.

As stated above, the Quality Assessments Division will encompass the assessment functions formerly performed by the Nuclear Safety Assurance staff, the Operational Assurance Programs staff and the Programs and Audits staff. These organizations have become more performance-based in their reviews. Utilizing a functional area approach, all members of the Quality Assessments Division willbe responsible for verifying through field observations, interviews and procedure and document reviews, the safe and efficient operation of WNP-2. As an integral part of this activity, all personnel willbe expected to recommend enhancements, including procedure changes, which will assist in improving WNP-2 operations. Consolidation of the assessment staff will assist in increasing resources for more in-depth coverage and improved coordination of reviews.

Our review of the impacts of the proposed changes has also included consideration of any negative aspects. In our view, there is a small potential negative aspect that involves the distribution of Section 6.2.3 functions throughout the Directorate rather than maintaining it focused within the Nuclear Safety Assurance Division. The Nuclear Safety Assurance Division (NSAD) is currently chartered, among other functions, with ensuring and improving overall nuclear safety of WNP-2. The alignment being proposed will retain all of the NSAD functions within the Quality Support Division except for safety verification functions which move to the Quality Assessments Division. As stated above, verification of safety has been an important part of the current responsibilities of our oversight organizations. This will continue with the new alignment within the Quality Assessments Division and is not considered a negative impact.

Management practices will be implemented to assure that the NSAD functions are performed by a composite of staff members that is at least the equivalent of the present NSAD. No other potential negative aspects of this proposed realignment are believed to exist.

A change to Section 6.5.1.2 of the Technical Specifications is being proposed to change the membership of POC from the Plant QA Manager to the Manager, Quality Assessments, This is an administrative change associated with the change in position titles for the proposed realignment.

I 'l ~ ~ L

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'EQUEST FOR AMENDMENTTO TECHNICAL SPECIFICATION 6.0, ADMINISTRATIVECONTROLS In summary, all of the functions currently being performed by the Nuclear Safety Assurance Division to satisfy the requirements of Section 6.2.3 of the Technical Specifications willcontinue to be accomplished"within the Quality Assurance Directorate. With respect to the proposed Section 6.2.3 and Section 6.5.1.2 Technical Specification changes, the Supply System has reviewed these changes per 10CFR50.92 and has determined that they do not represent a significant hazards consideration because they do not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated. The changes are administrative in nature and involve no physical alteration of the plant or changes to setpoints or operating parameters. Also, the Independent Safety Engineering Group gSEG) functions will be accomplished by staff of the same or better qualifications. Therefore, the probability of an accident precursor failing to be recognized; the plant response to accidents, and therefore consequences of previously reviewed accidents; and, the ability of discovering a poor plant response to an accident will be unchanged or enhanced with this proposed, new alignment. The change in substituting the Manager, Quality Assessments for the Plant QA Manager as a member of POC is an administrative change. For these reasons, there will be no significant increase in the probability or consequences of an accident previously evaluated as a result of these changes.
2) Create the possibility of a new or different kind of accident from any accident previously evaluated. Because no change is being made to the design, operation, maintenance, or testing of the plant, a new mode of failure is not created. Therefore, these changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
3) Involve a significant reduction in a margin of safety. The proposed changes are administrative changes which do not decrease the competence of staff within the Quality Assurance Directorate. The functions previously provided by the Nuclear Safety Assurance Division to meet the Technical Specification Section 6.2.3 requirements and the guidelines of NUREG-0737 willcontinue to be provided within the Quality Assurance Directorate. The potential negative impacts are considered to be minimal and do not involve a significant reduction in a margin of safety.

The change in substituting the Manager, Quality Assessments for the Plant QA Manager as a member of POC is an administrative change and also does not involve a significant reduction in a margin of safety.

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Page 4 REQUEST FOR AMENDMENTTO TECHNICAL SPECIFICATION 6.0, ADMINISTRATIVECONTROLS As discussed above, the Supply System concludes that these changes do not involve a significant hazards consideration, nor is there a potential for a significant change in the types or significant increase in the amount of any effluents that may be released offsite, nor does the change involve a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed changes meet the eligibility criteria for categorical exclusion set forth in 10CFR51.22(c)(9) and therefore, per 10CFR51.22(b), an environmental assessment of these changes is not required.

This Technical Specification change request has been reviewed and approved by the WNP-2 Plant Operations Committee and the Supply System Corporate Nuclear Safety Review Board.

In accordance with 10CFR50.91, the State of Washington has been provided a copy of this letter.

Conclusion of the review and issuance of the amendment would be appreciated by July 1, 1993, so that full implementation of the QA Directorate proposed realignment may be implemented at that time.

Sincerely,

. V. Parrish (Mail Drop 1023)

Assistant Managing Director, Operations Attachments CC: W Bishop, EFSEC JB Martin, NRC RV JW Clifford, NRC NRC Site Inspector, 901A BH Faulkenberry, NRC RV NS Reynolds, Winston & Strawn DL Williams, BPA/399

STATE OF WASHINGTON )

Subject:

Request for Amend to TS 6.0

) A mini iv nr 1 COUNTY OF BENTON )

I. J. V. PARRISH,-being duly sworn, subscribe to and say that I am the Assistant Managing Director, Operations for the WASHINGTON PUBLIC POWER SUPPLY SYSTEM, the applicant herein; that I have the full authority to execute this oath; that I have reviewed the foregoing; and that to the best of my knowledge, information, and belief the statements made in it are true.

DATE , 1993 J. arrish, Assistant Managing Director Operations On this date personally appeared before me J. V. PARRISH, to me known to be the individual executed the foregoing instrument, and acknowledged that he signed the same as his free

'ho act and deed for the uses and purposes herein mentioned.

GIVEN under my hand and seal this ~day of 1993.

No Public in d for the STATE OF WASHINGTON Residing at Kennewick W hin on MIC I I 2*24 ~A'I I I I

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