ML17290A400

Application for Amend to License NPF-21,changing TS 6.0, Adminstrative Controls to Clearly Assign Corporate Responsibility for Overall Plant Nuclear Safety,Including Review & Audit Functions

ML17290A400
Person / Time
Site:	Columbia
Issue date:	06/02/1993
From:	Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17290A401	List: ML17290A400 ML17290A402
References
GO2-93-131, NUDOCS 9306110037
Download: ML17290A400 (9)

Text

ACCEI ERA 0 DOCUMENT MS UTION SYSTEM REGUL RY INFORMATION DISTRIBUT .4 SYSTEM (RIDS)

ACCT'SSION NB/:9306110037 DOC.DATE: 93/06/02 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 Document Control Branch (Document Control Desk)

SUBJECT:

Application for amend to License NPF-2l,changing TS 6.0, "Adminstrative Controls" to clearly assign corporate responsibility for overall plant nuclear safety, including review 6 audit functions.

DISTRIBUTION CODE: AOOID TITLE: OR COPIES RECEIVED:LTR Submittal: General Distribution

( ENCL / SIZE:

NOTES:

REC1PIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PDV LA 1 1 PDV PD 1 1 CLIFFORD,J 2 2 INTERNAL: ACRS 6 6 NRR/DE/EELB 1 1 NRR/DORS/OTSB 1 1 NRR/DRCH/HICB l. 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 ~RIB 1 0 OGC/HDS1 1 0 EG FILE Ol 1 1

EXTERNAL: NRC PDR 1 1 NSIC 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTETH CONTACI'HE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDI TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL 19

WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. BaFt 968 ~ 3000 George Wasbfngton Way ~ Rtcbland, Wasbfngton 99352-0968 ~ (509) 372-5000 June 2, 1993 G02-93-131 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: CNSRB 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 responsibilities. of the Corporate Nuclear Safety Review Board (CNSRB) as described in Specifications 6;5.2.1, 6.5.2.8.i, and 6.5.2.9 be changed to be consistent with the corporate responsibilities for nuclear safety as described in Technical Specification 6.2.1.c. Specification 6.2.1.c identifies the Assistant Managing Director for Operations (AMDO) as having "corporate responsibility for overall plant nuclear safety...." The CNSRB activities as presently described in Technical Specifications 6,5,2.1, 6.5.2.8.i, and 6.5.2.9 specify reporting to, and taking direction from, the Managing Director. The corporate manager having responsibility for overall plant nuclear safety should be the manager giving direction to and receiving reports of activities from the CNSRB. Accordingly, changes to Specifications 6.5.2.1, 6.5.2.8.i, and 6.5.2.9 are requested (see attached) to appropriately align these activities in accordance with 6.2.1.c.

These changes are requested so that the AMDO is clearly assigned corporate responsibility for overall plant nuclear safety, including review and audit functions. The CNSRB brings an important element of expertise to, and detachment from, plant operations. As such the board should be responsible to and take direction from the corporate officer designated as responsible for overall corporate nuclear safety. Accordingly the changes requested to 6.5.2.1, 6.5.2.8.i, and 6.5t2.9 are intended to clarify the use of the CNSRB.

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Pag6 2 REQUEST FOR AMENDMENTTO TECHNICAL SPECIFICATION 6.0, ADMINISTRATIVECONTROLS: CNSRB In reviewing the origins of the specifications stating that the Managing Director should be the individual providing direction to, and receiving reports from, the CNSRB it was recognized that at the time of issuance of the original Technical Specifications the AMDO position did not exist.

Hence, it was logical to assign these duties to the Managing Director as he was the individual having corporate responsibility for overall nuclear safety at that time. Subsequently, amendment 63 to the Technical Specifications approved designation of the new position and title for the Assistant Managing Director for Operations as the individual having corporate responsibility for overall plant nuclear safety. The CNSRB relationship to the AMDO was not established at that time.

A potentially negative aspect of this change is that the Managing Director is one level of .

management removed from the CNSRB. However the members of the CNSRB will remain as appointees by the Managing Director per Specification 6.5.2.2 and the reporting responsibility of the AMDO to the Managing Director will ensure that the Managing Director remains cognizant of overall nuclear safety concerns. The same reporting responsibility will also allow the Managing Director to have input to the direction of the CNSRB. For these reasons this potentially negative aspect is considered to have little impact on the overall level of nuclear safety at WNP-2.

The Supply System has reviewed the changes in CNSRB reporting responsibility and direction assignment 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. Again, the changes are administrative in nature and involve no physical alteration of the plant or changes to setpoints or operating parameters. The responsibili-ties and composition of the CNSRB remain the same. The direction to be provided to the CNSRB will come from the corporate officer designated as responsible for overall corporate nuclear safety and as such will have the potential for being more focused on important issues of nuclear safety. Hence, the oversight review and audit responsibilities of the CNSRB for nuclear safety are not affected by this change. Therefore the probability or consequences of previously reviewed accidents is not affected by these changes.

2) Create the possibility of a new or different kind of accident from any accident previously evaluated. Again, 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.

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Pagb 3 REQUEST FOR AMENDMENTTO TECHNICAL SPECIFICATION 6.0, ADMINISTRATIVECONTROLS: CNSRB

3) Involve a significant reduction in a margin of safety. The proposed changes are administrative changes which do not decrease the competence of the CNSRB. The composition and responsibilities of the CNSRB are not changed by this request. Because the direction will come from the corporate officer designated as responsible for overall nuclear safety the effectiveness of the CNSRB has a potential for being better focused.

For these reasons the margin of safety created by the review and audit functions of the CNSRB is not diminished by this change.

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 efflucnts 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.

Sincerely J. V. Parrish (Mail Drop 1023)

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

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STATE OF WASHINGTON )

Subject:

Request for Amend to TS 6.0

) Admini ive n r 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

. Parrish, Assistant Managing Director perations On this date personally appeared before me J. V. PARRISH, to me known to be the individual who executed the foregoing instrument, and acknowledged that he signed the same as his free act and deed for the uses and purposes herein mentioned.

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

Notary Public in and for the STATE OF WASHINGTON MyC i i ~5 Residing at Kennewick Washin t n Epi

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