ML18299A104

Global Nuclear Fuel - Americas LLC - Chapter 2.0, Organization and Administration

ML18299A104
Person / Time
Site:	07001113
Issue date:	10/26/2018
From:	Global Nuclear Fuel
To:	Office of Nuclear Material Safety and Safeguards
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2.1 CHAPTER 2.0 ORGANIZATION AND ADMINISTRATION 2.1 POLICY The GNF-A policy is to maintain a safe work place for its employees, to protect the environment, and to assure operational compliance within the terms and conditions of special nuclear material licenses and applicable NRC regulations.

2.2 ORGANIZATIONAL RESPONSIBILITIES AND AUTHORITY 2.2.1 KEY POSITIONS WITH RESPONSIBILITIES IMPORTANT TO SAFETY (FIGURE 2.1)

Responsibilities, authorities, and interrelationships among the GNF-A organizational functions with responsibilities important to safety are specified in approved position descriptions and in documented and approved practices.

2.2.1.1 GNF-As Facility Manager The GNF-A Facility Manager is the individual who has overall responsibility for safety and activities conducted at GNF-A. The Facility Manager directs operations by procedure, or through other management personnel. The activities of the Facility Manager are performed in accordance with GNF-As policies, procedures, and management directives. The Facility Manager provides for safety and control of operations and protection of the environment by delegating and assigning responsibility to qualified Area Managers.

The minimum qualifications of a Facility Manager is a BS or BA degree and two years experience in manufacturing operations or equivalent. The Facility Manager is knowledgeable of the safety program concepts as they apply to the overall safety of a nuclear facility, and has the authority to enforce the shutdown of any process or facility. The Facility Manager must approve restart of an operation they request be shutdown.

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2.2 Figure 2.1 GNF-A Organization Chart (Typical)

Global Nuclear Fuel, LLC Facility Manager Area Managers Configuration Management Function Environment, Health & Safety Function Manager Criticality Safety Function Radiation Safety Function Environmental Protection Function Chemical Safety Function Site Security Function Shift Supervisors Fire and Emergency Preparedness Functions Integrated Safety Analysis Function

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2.3 2.2.1.2 Area Manager The Area Manager is the designated individual who is responsible for ensuring that activities necessary for safe operations and protection of the environment are conducted properly within their designated area of the facility in which uranium materials are processed, handled or stored. Designated Area Manager responsibilities include:

Assure safe operation, maintenance and control of activities Assure safety of the environs as influenced by operations Assure performance of integrated safety analyses for the assigned facility area, as required Assure application of assurance elements to safety controls, as appropriate Assure configuration control for safety controls for the assigned facility area, as required Use approved written operating procedures which incorporate safety controls and limits Provide adequate operator training The minimum qualifications of an Area Manager are one of the following three options:

Option 1, a combination of:

• BS/BA degree in a technical field;

• Two years supervisory or technical experience in a nuclear, manufacturing or other technical field; and,

• One year of supervisory or technical experience in nuclear operations.

Option 2, a combination of:

• BA (non-technical) / AA degree;

• Three years supervisory or technical experience in a nuclear, manufacturing or other technical field; and,

• One year of supervisory or technical experience in nuclear operations.

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2.4 Option 3, a combination of:

• High School diploma;

• Five years supervisory or technical experience in a nuclear, manufacturing or other technical field; and,

• Two years of supervisory or technical experience in nuclear operations.

Area Managers shall be knowledgeable of the safety program procedures (including chemical, radiological, criticality, fire, environmental and industrial safety) and shall have experience in the application of the program controls and requirements, as they relate to their areas of responsibility. The assignment of individuals to the position of Area Manager is approved by the Facility Manager, and the listing of Area Managers by area of responsibility is maintained current at the facility.

2.2.1.3 Integrated Safety Analysis Function The integrated safety analysis function designated responsibilities include:

Establish and maintain the integrated safety analysis program and identify items relied on for safety (IROFS)

Establish and maintain the assurance program for safety controls Provide advice and counsel to Area Managers on matters of the integrated safety analysis program Minimum qualification requirements for the manager of the integrated safety analysis function are a BS or BA degree or equivalent and two years experience in related manufacturing assignments; or a high school diploma with eight years of manufacturing experience. The manager of the integrated safety analysis function shall have experience in the understanding and management of the assigned programs.

2.2.1.4 Configuration Management Function Establish and maintain the configuration control system for fuel manufacturing equipment and safety controls, and related record retention Establish and maintain the operating procedure systems

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2.5 Minimum qualification requirements for the manager of the configuration management function are a BS or BA degree or equivalent and two years experience in related manufacturing assignments; or a high school diploma with eight years of manufacturing experience. The manager of the configuration management function shall have experience in the understanding and management of the assigned programs.

2.2.1.5 Shift Supervisor Shift supervisors are provided as the interface between management and facility operators. Shift supervisor responsibilities include:

Provide day to day work direction to operators and other workers.

Assure safe operation and control of activities Assure adherence to written operating procedures and controls Provide adequate operator oversight and guidance Identify and communicate off-normal conditions The minimum qualifications for shift supervisor are a High School diploma and one of the three qualifications outlined below.

One year supervisory experience in a nuclear, manufacturing or technical field Two years of technical experience in nuclear or manufacturing operations, or Three years of operator experience in nuclear operations 2.2.1.6 Criticality Safety Function The criticality safety function is administratively independent of production responsibilities and has the authority to shutdown potentially unsafe operations.

This function must approve restart of an operation they request be shutdown.

Designated responsibilities include:

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2.6 Establish the criticality safety program including design criteria, procedures and training Provide criticality safety support for nuclear operations including integrated safety analyses and configuration control Assess normal and credible abnormal conditions Determine criticality safety limits for controlled parameters Perform methods development and validation to support criticality safety analyses Perform neutronics calculations, write criticality safety analyses and approve proposed changes in process conditions or equipment involving fissionable material Specify criticality safety control requirements and functionality Provide advice and counsel to Area Managers on criticality safety control measures, including review and approval of operating procedures Support emergency response planning and events Assess the effectiveness of the criticality safety program through audit programs The criticality safety function manager shall hold a BS or BA degree in science or engineering, have at least four years experience in assignments involving regulatory activities, and have experience in the understanding, application and direction of nuclear criticality safety programs.

Minimum qualifications for a senior engineer within the criticality safety function are a BS or BA degree in science or engineering with at least three years of nuclear industry experience in criticality safety. A senior engineer shall have experience in the assigned safety function, and has authority and responsibility to conduct activities assigned to the criticality safety function.

Minimum qualifications for an engineer within the criticality safety function are a BS/BA degree in science or engineering. An engineer shall have experience in the assigned safety function, and has authority and responsibility to conduct activities assigned to the criticality safety function, with the exception of independent verification of criticality safety analyses.

2.2.1. 7 Radiation Safety Function The radiation safety function is administratively independent of production responsibilities and has the authority to shutdown potentially unsafe operations.

This function must approve restart of an operation they request be shutdown.

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2.7

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2.8 Designated responsibilities include:

Establish the radiation protection and radiation monitoring programs Establish the radiation protection design criteria, procedures and training programs to control contamination and exposure to individuals Evaluate radiation exposures of employees and visitors, and ensure the maintenance of related records Conduct radiation and contamination monitoring and control programs Evaluate the integrity and reliability of radiation detection instruments Provide radiation safety support for integrated safety analyses and configuration control Provide analysis and approval of proposed changes in process conditions and process equipment involving radiological safety Provide advice and counsel to Area Managers on matters of radiation safety Support emergency response planning and events Assess the effectiveness of the radiation safety program through audit programs Oversight of the respiratory protection program The radiation safety function manager shall hold a BS or BA degree or equivalent, have at least two years experience in assignments that include responsibility for radiation safety, and have experience in the understanding, application and direction of radiation safety programs.

Minimum qualifications for a senior member of the radiation safety function are a BS or BA degree or equivalent with at least two years of nuclear industry experience in the assigned function. Alternate minimum experience qualification for a senior member of the radiation safety function is professional certification in health physics. A senior member shall have experience in the assigned safety function, and has authority and responsibility to conduct activities assigned to the radiation safety function.

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2.9 2.2.1.8 Environmental Protection Function The environmental protection function is administratively independent of production responsibilities and has the authority to shutdown operations with potentially uncontrolled environmental conditions. This function must approve restart of an operation they request be shutdown.

Designated responsibilities include:

Identify environmental protection requirements from federal, state and local regulations which govern the GNF-A operation Establish systems and methods to measure and document adherence to regulatory environmental protection requirements and license conditions Provide advice and counsel to Area Managers Evaluate and approve new, existing or revised equipment, processes and procedures involving environmental protection activities Provide environmental protection support for integrated safety analyses and configuration control Assure proper federal and state permits, licenses and registrations for non-radiological discharges from the facilities Minimum qualifications for the manager of the environmental protection function are a BS or BA degree or equivalent and two years of experience in assignments involving regulatory activities or equivalent.

2.2.1.9 Chemical and Fire Safety Functions The chemical and fire safety functions are administratively independent of the production responsibilities and have the authority to shutdown operations with potentially hazardous health and safety conditions. These functions must approve restart of an operation they request be shutdown.

Designated responsibilities include:

Identify fire protection requirements from federal, state, and local regulations which govern the GNF-A operations Develop practices regarding non-radiological chemical safety affecting nuclear activities

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2.10 Provide advice and counsel to Area Managers on matters of chemical and fire safety Provide consultation and review of new, existing or revised equipment, processes and procedures regarding chemical safety and fire protection Provide chemical and fire safety support for integrated safety analyses and configuration control Minimum qualifications of the managers of the chemical and fire safety functions are a BS or BA degree or equivalent and two years of experience in related assignments.

2.2.1.10 Site Security and Emergency Preparedness Functions The site security and emergency preparedness functions are administratively independent of the production responsibilities. Designated responsibilities include:

Provide physical security for the site Establish and maintain the emergency preparedness program, including training and program evaluations Provide advice and counsel to Area Managers on matters of physical security and emergency preparedness Maintain agreements and preparedness with off-site emergency support groups Minimum qualifications of the managers of the site security and emergency preparedness functions are a BS or BA degree, or equivalent and one year of experience in related assignments, or a high school diploma with eight years of experience in related assignments.

2.2.1.11 Environment, Health & Safety (EHS) Function The EHS function is administratively independent of production responsibilities but has the authority to enforce the shutdown of any process or facility in the event that controls for any aspect of safety are not assured. This function has designated overall responsibility to establish the radiation safety, criticality safety, environmental protection, chemical safety, fire protection and emergency preparedness programs to ensure compliance with federal, state and local regulations

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2.11 and laws governing operation of a nuclear manufacturing facility. These programs are designed to ensure the health and safety of employees and the public as well as protection of the environment.

The manager of the EHS function must hold a BS or BA degree or equivalent and have five years of management experience in assignments involving regulatory activities. The manager of the EHS function must have appropriate understanding of health physics, nuclear criticality safety, environmental protection, and chemical and fire safety programs.

2.2.2 MANAGEMENT CONTROLS Management controls for the conduct and maintenance of GNF-As health, safety and environment protection programs are contained in documented plant practices described in Section 11, and approved by cognizant management. Such practices are part of a controlled document system, and appropriately span the organizational structure and major plant activities to control interrelationships, and to specify program objectives, responsibilities and requirements. Personnel are appropriately trained to the requirements of these management controls, and compliance is monitored through internal and independent audits and evaluations.

Management controls documented in practices address requirements including:

Configuration Management Integrated Safety Analysis Radiation Safety Criticality Safety Environmental Protection Chemical Safety Fire & Explosion Safety Emergency Preparedness Quality Assurance Training Procedures

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2.12 Maintenance Audits Incident Investigation & Reporting Fissile Material Accountability and Control Worker Concerns Program Management Measures Necessary to Maintain Items Relied on for Safety 2.3 TRAINING AND CONTINUING ASSURANCE Personnel training and continuing assurance is conducted as necessary to provide reasonable assurance individuals are qualified, continue to understand, and recognize the importance of safety while performing assigned activities.

Training is provided for each individual at GNF-A, commensurate with assigned duties. Training and qualification requirements are met prior to personnel fully assuming the duties of safety-significant positions, and before assigned tasks are independently performed.

Formal training relative to safety includes radiation and radioactive materials, risks involved in receiving low level radiation exposure in accordance with 10 CFR 19.12, basic criteria and practices for radiation protection, nuclear criticality safety principles not verbatim, but in general conformance with ANSI/ANS 8.19 and ANSI/ANS 8.20 guidance, chemical and fire safety, maintaining radiation exposures and radioactivity in effluents As Low As Reasonably Achievable (ALARA), and emergency response.

The system established for management assurance and record retention of training and retraining is described in Chapter 11.

2.3.1 NUCLEAR SAFETY TRAINING Training policy requires that employees complete formal nuclear safety training prior to unescorted access in the airborne radioactivity controlled area (see Chapter 11, Section 11.4.2.2).

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2.13 2.3.2 OPERATOR TRAINING Operator training is performance based, and incorporates the structured elements of analysis, design, development, implementation, and evaluation. Job-specific training includes applicable procedures and safety provisions, and requirements. Emphasis is placed on safety requirements where human actions are important to safety.

Operator training and qualification requirements are met prior to process safety-related tasks being independently performed or before startup following significant changes to safety controls.

2.4 SAFETY COMMITTEES 2.4.1 WILMINGTON SAFETY REVIEW COMMITTEE The functions of the Wilmington Safety Review Committee include responsibility for the following:

An annual ALARA review which considers:

Programs and projects undertaken by the radiation safety function and the Radiation Safety Committee Performance including, but not limited to, trends in airborne concentrations of radioactivity, personnel exposures, and environmental monitoring results Programs for improving the effectiveness of equipment used for effluent and exposure control Review of major changes in authorized plant activities which may affect nuclear or non-nuclear safety practices Professional advice and counsel on environmental protection, and criticality, radiation, chemical and fire safety issues affecting the nuclear activities.

The committee is responsible to the Facility Manager. Its proceedings, findings and recommendations are reported in writing to the Facility Manager and to appropriate staff level managers responsible for operations which have been reviewed by the committee. Such reports shall be retained for at least three years.

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2.14 The committee holds at least three meetings each calendar year with a maximum interval of 180 days between any two consecutive meetings.

2.4.2 RADIATION SAFETY COMMITTEE The objective of the Radiation Safety Committee is to maintain occupational radiation exposures as low as reasonably achievable (ALARA) through improvements in fuel manufacturing operations.

The committee meets monthly to maintain a continual awareness of the status of projects, performance measurement and trends, and the current radiation safety conditions of shop activities. The maximum interval between meetings does not exceed 60 days.

A written report of each Radiation Safety Committee meeting is forwarded to cognizant Area Managers and the manager of the EHS function. Records of the committee proceedings are maintained for three years.

The committee consists of managers or representatives from key manufacturing functions with activities affecting radiation safety.

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7.1 CHAPTER 7.0 FIRE SAFETY GNF-As fire protection is achieved by a combination of fire prevention measures and response systems. Such measures and systems are designed and maintained in accordance with applicable federal, state, and local codes, appropriate industry standards and prudent practices. The National Fire Protection Association (NFPA) codes and standards are most commonly cited and are used as guidance.

7.1 FIRE PROTECTION PROGRAM RESPONSIBILITY The Fire Protection Program is owned and administered by Emergency Preparedness and Fire Protection organization. Additionally, the Emergency Organization is comprised of functional groups capable of assisting and/or advising in the prevention, response to and controlling of emergency situations. The structure of the Emergency Organization is detailed within the Radiological Contingency and Emergency Plan (RC&EP) for GNF-A.

7.2 FIRE PROTECTION PROGRAM Fire Hazard Analyses (FHA) are prepared as needed for licensed activities and the results are incorporated into the GNF-As Integrated Safety Analysis (ISA) program and/or site process reviews. The ISA program includes a provision for fire safety review as described in Chapter 3.

Routine inspection, testing and maintenance of the fire protection system are typically conducted by GNF-A and site maintenance functions under the oversight of the Fire Protection function. Responsibility for maintenance, operation, and engineering of the fire protection system and equipment is specified in approved GNF-A procedures.

Review and control of modifications of the licensed facility or processes to minimize fire hazards is part of configuration management described in Chapter 11.

An approved hot work procedure utilizing a hot work permit is provided to control welding, torch cutting, and other activities as a means of fire prevention.

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7.2 New employees and contractors are trained on basic fire protection topics during orientation programs. The Emergency Response Organization (ERO) is given training as described inthe RC&EP.

A system is provided to enable reporting of fire incidents to the ERO.

In order to ensure emergency response readiness, drills and exercises are conducted as described in the RC&EP.

7.3 ADMINISTRATIVE CONTROLS (See Chapter 11, Section 11.6.4) 7.4 BUILDING CONSTRUCTION 7.4.1 FMO/FMOX AND OUT BUILDING The FMO/FMOX and out buildings were designed in accordance with applicable local, state, federal and national codes, standards and/or regulations in effect at the time of construction with respect to fire safety. The buildings used to process and store hazardous materials were designed to provide containment of such material under postulated conditions of fire and explosion.

7.4.2 DRY CONVERSION PROCESS FACILITY (DCP)

The building was designed in accordance with applicable local, state, federal and national codes, standards and/or regulations in effect at the time of construction with respect to fire safety. The building was designed to provide containment of material under postulated conditions of fire and explosion. Recognizing the requirement for moderation restriction, certain areas within the DCP facility are compartmentalized with minimum 2-hour fire walls to control the spread of fire.

7.5 VENTILATION SYSTEMS Ventilation systems are provided and arranged to ensure that radiologically controlled areas are kept under slightly negative pressure. Exhaust ventilation from

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7.3 process areas functions to remove smoke from the areas in the event of a fire and exhaust to the outside through high-efficiency particulate air (HEPA) filters.

7.6 PROCESS FIRE SAFETY Potential fire hazards are determined and analyzed in the FHAs, and are mitigated via systems, features and personnel using industry accepted methods and procedures.

7.7 FIRE DETECTION AND ALARM SYSTEMS 7.7.1 DETECTION DEVICES Areas where automatic detection of products of combustion or flammable gas is warranted, the following device types are installed:

Smoke Detectors Heat Detectors Hydrogen Detectors 7.7.2 ALARMS Fire Protection system alarms and trouble signals are transmited to the continuously manned central alarm station. Audible fire alarms are installed in specified locations throughout the facility to provide notification to personnel. Additionally, manual fire alarm stations (pull-boxes) are installed in appropriate locations throughout the facility and serve to activate a coded fire alarm.

7.8 FIRE SUPPRESSION EQUIPMENT GNF-As fire protection system is designed in accordance with the applicable NFPA standards.

Selection of equipment for suppression of fire takes into account the severity of the hazard, the type of activity to be performed, the potential consequences of a fire, and

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7.4 the potential consequences of use of the suppression equipment (including, risk of accidental criticality).

Automatic sprinkler systems are specifically excluded from areas where moderation restriction is the primary nuclear criticality safety-controlled parameter.

Portable fire extinguishers, of sufficient capacity, quantity and type of suppression agent used, are available and maintained throughout the facility.

7.9 FIRE PROTECTION WATER SYSTEM The fire protection water system consists of two fire pumps taking suction from separate water sources. Prime components of the fire protection system are as follows:

Elevated tank capable of supplying dedicated water to and automatic electric fire pump.

Surface water reservoir supplying dedicated water to an automatic diesel driven fire pump and equipped with a dry hydrant connection for pumper truck use.

A fire main loop around the prime production facilities.

A series of branch headers supplying fire protection water to sectionalized sprinkler systems and hose connections in each building.

A supervised alarm system providing full time coverage of prime fire protection signals such as sprinkler system supply valve closing, sprinkler system water flow, fire pump operations, and smoke detection operation.

7.10 EMERGENCY RESPONSE ORGANIZATION The ERO consists of Emergency Response Technicians (ERTs) and Emergency Medical Technicians (EMTs). ERTs are trained for fire and hazardous material response. Fire training of ERTs is conducted for the response to incipient stage fires in accordance with the RC&EP.

GNF-A maintains pre-fire plans and emergency response procedures that provide information needed by fire-fighting personnel responding to an emergency. Outside agency fire departments are contacted for more serious fires which include structural fires.

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8.1 CHAPTER 8.0 RADIOLOGICAL CONTINGENCY AND EMERGENCY PLAN GNF-A shall maintain and execute the response measure in the Radiological Contingency and Emergency Plan as specified in Safety License conditions of Materials License SNM-1097; or as further revised by the licensee consistent with 10 CFR 70.32(i). The Radiological Contingency and Emergency Plan incorporates the requirements established by the Emergency Planning and Community Right-to-Know Act of 1986, Title III, Publication L 99-499.

GNF-A will make no changes to the Radiological Contingency and Emergency Plan which would decrease its effectiveness without prior approval of the NRC.

Changes that do not decrease the effectiveness of the Radiological Contingency and Emergency Plan, will be reported within six months of the change to the Director, Division of Nuclear Security, Office of Nuclear Security and Incident Response, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555.

The requirements of the Radiological Contingency and Emergency Plan are implemented through approved documented procedures maintained by GNF-A.

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11.1 CHAPTER 11.0 MANAGEMENT MEASURES 11.1 MANAGEMENT MEASURES 11.1.1 REASONABLE ASSURANCE GNF-A commits to apply Management Measures on a continuing basis to IROFS for the purpose of providing reasonable assurance that the IROFS are available and able to perform their function when needed.

11.1.2 GRADED APPLICATION OF MANAGEMENT MEASURES TO IROFS GNF-A applies Management Measures in a graded approach based on unmitigated risk as described in Chapter 3 (See Section 3.5).

11.2 CONFIGURATION MANAGEMENT (CM) 11.2.1 CONFIGURATION MANAGEMENT POLICY GNF-A commits to maintain a formal configuration management process, governed by written, approved practices, and ensures that plant design changes do not adversely impact safety, health, or environmental protection programs at GNF-A.

The following items are addressed prior to implementing a change:

The technical basis for the change The impact of the change on safety, health and control of licensed material Modifications to existing operating procedures including any necessary training or retraining before operation Authorization requirements for the change For temporary changes, the approved duration (expiration date) of the change

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11.2 The impacts or modifications to the ISA, ISA Summary and any other component of the overall safety program The configuration management (CM) program ensures that the information used to operate and maintain safety controls is kept current.

The CM program includes the following activities:

Maintenance of the design information for the plant Identification of all IROFS Control of information used to operate and maintain the plant Documentation of changes Assurance of adequate safety reviews for changes Periodic comparison assessment of the conformance of specific safety controls to the documentation of plant design basis 11.2.2 DESIGN REQUIREMENTS Written plant practices define the development, application, and maintenance of the design specifications and requirements. Plant design specifications and requirements are maintained as controlled information. The specific content of the information depends on the age of the design and the requirements in place at the time of design.

As a minimum, the information required for safe operation of the facility is available.

11.2.3 DOCUMENT CONTROL Documented plant practices define the control system, including creation, revision, storage, tracking, distribution and retrieval of applicable information including:

ISA documentation Operating procedures Drawings for safety related systems, structures and components Technical specifications and requirements

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11.3 Software for safety controls Calibration instructions Functional test instructions The documented plant practices describe the responsibilities and activities that maintain consistency between the facility design, the physical facility, and the documentation. They also describe how the latest approved revisions are made available for operations.

11.2.4 CHANGE CONTROL GNF-A maintains written plant practices describing the configuration management program for controlling design change, including approval to install and operate facility, process, or equipment design changes. These practices stipulate that a trained and approved safety reviewer determine if the applicable ISA is impacted by the facility change. If there is an impact to the ISA, it is identified and the change is flagged for review and approval by an ISA team in accordance with the process described in Chapter 3.

The written plant practices also prescribe controls and define the distinction between types of changes, ranging from replacement with identical designs that are authorized as part of normal maintenance, to new or different designs that require specified review and approval.

11.

2.5 ASSESSMENT

S Planned and scheduled internal and independent audits are performed to evaluate the application and effectiveness of management controls and implementation of programs related to activities significant to plant safety. Audits are performed to assure that operations are conducted in accordance with the operating procedures, and to assure that safety programs reflected in the operating procedures are maintained.

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11.4 11.2.6 DESIGN RECONSTITUTION The current plant design was reconstituted in accordance with the requirements specified in 10 CFR 70.62.

GNF-A submitted a plan as required by 10 CFR 70.62 (c) (3) (i) and this plan was approved by the NRC on June 11, 2002 (TAC NO. L31607).

GNF-A performed the design reconstitution in accordance with their approved plan and submitted the completed summary required by 10 CFR 70.62 (c) (3) (ii) on October 12, 2004. Periodic updates as required by the regulations (10 CFR 70.72 (d)

(2&3)) are submitted to the NRC.

11.3 MAINTENANCE The purpose of planned and scheduled maintenance of safety controls is to assure that systems are kept in a condition of readiness to perform the planned and designed functions when required.

Area Managers are responsible for assuring the operational readiness of safety controls in their assigned facility areas.

The maintenance function utilizes a systems-based program to plan, schedule, track and maintain records for maintenance activities. Maintenance instructions are an integral part of the maintenance system for maintenance activities. Key maintenance requirements for safety controls such as calibration, functional testing, and replacement of specified components are derived from integrated safety analyses described in Chapter 3.

Maintenance activities generally fall into the categories described in the following sections.

11.3.1 CORRECTIVE MAINTENANCE Corrective Maintenance refers to situations where repairs, replacements or major adjustments such as re-calibration take place.

GNF-A commits to promptly perform corrective actions to remediate unacceptable performance deficiencies in IROFS.

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11.5 The maintenance planning and control system provides documentation and records of systems and components that have been repaired or replaced.

When a component of a specified safety control is repaired or replaced, the component is functionally verified via post maintenance testing to assure that it has the capability to perform its planned and designed function when called upon to do so.

If the performance of a repaired or replaced safety control could be different from that of the original component, the change to the safety control is specifically approved under the configuration management program and pre-operationally tested to assure it is likely to perform its desired function when called upon to do so.

11.3.2 PREVENTATIVE MAINTENANCE Preventative Maintenance refers to activities that are performed as precautions to help ensure that systems remain operational and avoid unexpected failures.

Examples of safety controls included for scheduled preventive maintenance are:

Radiation Measurement Instruments Criticality Detection Devices Effluent Measurement & Control Devices Emergency Power Generators Fire Detection and Control Systems Pressure Relief Valves Air Compressors Steam Boilers 11.3.3 SURVEILLANCE/MONITORING GNF-A utilizes active engineered controls that are integrated into the routine plant operations to the degree practical. In these systems the IROFS are near continuously monitored by the digital control system as a routine part of the operating process.

Degradations or failures in these cases result in immediate safe shutdown of the operations.

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11.6 IROFS associated with passive engineered systems are typically fixed physical design features to maintain safe process conditions. Assurance is maintained through pre-operational audit and periodic verification of effectiveness as prescribed in the ISA process described in Chapter 3, and includes consideration of the importance of the IROFS as well as quality and reliability information.

IROFS relying on geometry-based controls, where the geometry is subject to undetected change in routine operation, are periodically verified on a schedule commensurate with the potential for change in the parameters of interest.

Examples of active engineered controls that are integrated into routine plant operations include all IROFS managed by the distributed control system (e.g.

PROVOX) or hardwired interlocks.

Examples of passive engineered IROFS would include process equipment design features such as physical separation of storage fixtures (floor storage fixtures, installed can-conveyor separation); or other process design characteristic (air breaks, overflows, orifice sizing, restricting vessel feeds, hood physical restraints, etc.).

Examples of geometry-based IROFS would include design control of process equipment physical dimensions (pellet tray dimensions, boat size, container volume, pipe tank ID, annular tank thickness, slab tank thickness) and/or use of neutron absorbers.

11.3.4 FUNCTIONAL TESTING GNF-A commits to perform post-maintenance testing to verify that the maintenance activity did not adversely affect the functionality of the IROFS associated with the maintenance work.

GNF-A commits to perform functional tests in accordance with written instructions that define the method for the test and the required acceptable results. The results of the tests are also recorded and maintained.

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11.7 11.4 TRAINING AND QUALIFICATIONS 11.4.1 ORGANIZATION AND MANAGEMENT OF THE TRAINING FUNCTION Training programs at the GNF-A facility for personnel who perform activities relied on for safety are provided through shared responsibility between EHS safety disciplines, Operations and Human Resources functional organizations. Area Managers are responsible for the content and effective conduct of training for operations personnel. Records are maintained on each employees qualifications, experience, training, and retraining.

Facility administrative procedures establish the requirements for indoctrination and training of personnel performing activities relied on for safety and to ensure that the training program is conducted in a reliable and consistent manner throughout all training areas.

Training records are maintained to support management information needs associated with personnel training, job performance, and qualifications. Training records are retained in accordance with records management procedures.

11.4.2 FUNCTIONAL AREAS REQUIRING TRAINING Training is provided for each individual at GNF-A, commensurate with assigned duties (or roles). Training and qualification requirements are met prior to personnel fully assuming the duties of safety-significant positions, and before assigned tasks are independently performed.

Functional areas requiring training may be grouped into one of three broad categories:

General Employee Training Technical Training Developmental Training The objective of the training program is to ensure safe and efficient operation of the facility and compliance with applicable regulatory requirements. Training requirements shall be applicable to, but not restricted to, those personnel who have a direct relationship to the operation, maintenance, testing, or other technical aspects of the facility IROFS.

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11.8 Continuing or periodic retraining courses shall be established when applicable to ensure that personnel remain proficient. Periodic training generally is conducted to ensure retention of knowledge and skills important to facility operations. The training may consist of periodic retraining exercises, instructions, or review of subjects as appropriate to maintain the proficiency of all personnel assigned to the facility.

Chapter 8, Radiological Contingency and Emergency Plan, provides additional information on personnel training for emergency response tasks.

11.4.2.1 General Employee Training General Employee Training (GET) encompasses those quality assurance, radiation protection, industrial safety, environmental protection, emergency response, and administrative procedures established by facility management and applicable regulations. The industrial safety training for GNF-A complies with applicable section of the Occupational Safety and Health Administration (OSHA) regulations such as 29 CFR 1910 and with 10 CFR 19 (Notices, Instructions, and Reports to Workers: Inspection and Investigations). Continuing training is conducted in these areas as necessary to maintain employee proficiency. All persons under the supervision of facility management (including contractors) must participate in GET; however, certain facility support personnel, depending on normal work assignment, may not participate in all topics of this training. Temporary maintenance and service personnel receive GET to the extent necessary to assure safe execution of their duties. Certain portions of GET may be included in new employee orientation program implementation.

GET topics are listed below:

General administrative controls and procedures and their use Quality Assurance policies and procedures Nuclear Safety (Criticality/Radiological)

Industrial, Chemical, Fire, Health and First Aid Emergency Plan and implementing procedures Fire protection

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11.9 New Employee Orientation Environmental Protection 11.4.2.2 Nuclear Safety Training Training programs are established for the various job functions (e.g., operations, radiation protection technicians, contractor personnel) commensurate with criticality safety and radiation safety responsibilities. Visitors to the airborne radioactivity controlled area are trained in the formal training program or are escorted by trained personnel.

Formal Nuclear Safety training includes information about radiation and radioactive materials, risks involved in receiving low level radiation exposure in accordance with 10 CFR 19.12, basic criteria and practices for radiation protection, nuclear criticality safety principles not verbatim, but in general conformance with applicable objectives contained in ANSI/ANS 8.19 and ANSI/ANS 8.20 national consensus standard guidance.

Training policy requires that employees must complete nuclear safety training prior to unescorted access in the airborne radioactivity controlled area. Methods for evaluating the understanding and effectiveness of the training includes passing an initial examination covering formal training contents and observations of operational activities during scheduled audits and inspections.

Such training is typically performed using computer based training, but may be performed by authorized instructors. Training program contents are reviewed on a scheduled basis by the manager of the criticality safety and radiation safety functions to ensure that training program contents are current and adequate.

Previously trained employees who are allowed unescorted access to the airborne radioactivity controlled area are retrained at least every two years. The effectiveness of the training program is evaluated by either initial training exam or re-training exam. Visitors are trained commensurate with the scope of their visit and/or escorted by trained employees.

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11.10 11.4.2.3 Industrial, Chemical, Fire, Health and First Aid Industrial, Chemical, Fire Safety, Health and First Aid safety orientation of new or transferred employees is an important part of establishing the proper safety attitude among plant employees and insuring that they are aware of safety procedures, rules and hazards involving assigned duties. New employee orientation in performance of duties may include, as appropriate, the review of:

OSHA General Duty Clause Employee Responsibilities Employer Responsibilities General Site Safety Rules Hazard Communication Training Fire Extinguisher Training Emergency Evacuation Procedure Job Hazards Analysis (JHA)

Material Safety Data Sheets (MSDS)

Lock-Out-Tag-Out Awareness 11.4.2.4 Technical Training Technical training is designed, developed and implemented to assist facility operations and maintenance personnel in gaining an understanding of the applicable fundamentals, procedures, and technical practices common to a nuclear fuel conversion and fabrication facility. Technical training consists of initial training, on-the-job training, continuing training, and special training, as applicable to assigned technical duties of the job function (or role). This may include, but is not limited to, the following topics:

On-the-Job Training Process Specific Training Mechanical Maintenance

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11.11 Controls, Instrumentation, Electrical Maintenance Chemistry 11.4.2.5 Development Training Developmental Training is a broad category implemented to assist facility operations supervisory, and management personnel in gaining additional understanding of fundamentals and technical practices common to assigned job duties (or roles).

Developmental training typically utilizes internal/external professionals via formal workshop, tutorials, and select training programs.

11.4.3 POSITION TRAINING REQUIREMENTS Operator training is performance based, and incorporates the structured elements of analysis, design, development, implementation, and evaluation commensurate with assigned duties.

Minimum training requirements are developed for positions whose activities are relied on for safety. Initial identification of job-specific training requirement is based on individual employee experience. Entry-level criteria (e.g., education, technical background, and/or experience) for these positions are contained in position descriptions.

Job-specific training is performance based and established with relevant technical EHS safety discipline and operations leadership to develop a list of qualifications for assigned duties (or roles). Changes to facilities, processes, equipment, or job duties are incorporated into revised lists of qualifications.

11.4.4 BASIS OF TRAINING AND OBJECTIVES The training program is designed to prepare initial and replacement personnel for safe, reliable, and efficient operation of the facility. Emphasis is placed on safety requirements where human actions are important to safety.

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11.12 11.4.5 EVALUATION OF TRAINEE LEARNING Trainee understanding and proficiency is evaluated through observation/

demonstration or oral or written examinations, as appropriate. Such evaluations measure the trainees skill and knowledge of job performance requirements.

Operator training and qualification requirements are met prior to process safety-related tasks being independently performed or before startup following significant changes to safety controls.

11.4.6 CONDUCT OF ON-THE-JOB TRAINING On-the-Job training (OJT) is a systematic method of providing the required job related skills and knowledge for a position. This training is conducted in the work environment. Applicable tasks and related procedures make up the OJT/qualifications program for each technical area which is designed to supplement and complement training received through formal classroom, laboratory, and/or simulator training. The object of the program is to assure the trainees ability to proficiently perform job duties as required for the assigned role. Refer to Section 11.4.3.

Completion of on-the-job training is demonstrated through actual task actions using the conditions encountered during the performance of assigned duties (or roles) including references, tools, and equipment conditions reflecting the actual task to the extent practical.

11.4.7 EVALUATION OF TRAINING EFFECTIVENESS Periodic evaluations of training program content and requirements are performed to assess program effectiveness. The trainees provide feedback after completion of classroom or computer based training session to provide data for this evaluation.

These evaluations identify program strengths and weaknesses, determine whether training content matches current job needs, and determines if corrective actions are needed to improve program effectiveness.

Independent audits of EHS safety disciplines may also be used to provide independent evaluations of overall training program effectiveness (see Section

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11.13 11.6.5 of this Chapter) as it relates to the ISA program, IROFS implementation, protection of the public, worker, and environment.

Evaluation objectives applicable to the overall organization and management of the GNF-A training programs may include, but are not limited to:

Management and administration of training and qualification programs Development and qualification of the matrix organization Design and development of training programs, content, and conduct of training, and trainee examinations / evaluations.

Training program interface with facility configuration management practices Training program assessments and evaluations 11.4.8 PERSONNEL QUALIFICATION The qualification requirements for key management positions are described in Chapter 2, Organization and Administration. Education, experience, training and qualifications are specified in this chapter.

Qualification and training requirements for operations personnel shall be established and implemented in accordance with internal plant procedures (e.g, Human Resource).

11.4.9 RECORDS The system established for maintaining records of training and retraining of personnel who perform activities relied on for safety is described in Section 11.8.

11.5 PROCEDURES Licensed material processing or activities will be conducted in accordance with properly issued and approved management control procedures.

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11.14 11.5.1 OPERATING PROCEDURES Area Managers are responsible to assure preparation of written, approved and issued operating procedures incorporating control and limitation requirements established by the criticality safety function, the radiation safety function, the environmental protection function and the chemical and fire safety function. Integrated safety analysis results as described in Chapter 3 are used to identify procedures necessary for human actions important to safety. Operating procedures are initiated and controlled by a configuration management system. Area Managers ensure that operating procedures are made readily available in the work area and that operators are trained to the requirements of the procedures and that conformance is mandatory.

Operators are trained to report inadequate procedures, and/or the inability to follow procedures.

Nuclear safety control procedure requirements for workers in uranium processing areas are incorporated into the appropriate operating, maintenance and test procedures in place for uranium processing operations.

The safety program design requires the establishment and maintenance of documented procedures for environmental, health and safety limitations and requirements to govern the safety aspects of operations. Requirements for procedure control and approval authorities are documented. Procedure review for updating frequencies are as follows:

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11.15 Document Review Frequency Reviewing & Approving Functional Manager Operating Procedures (OPs)

{Note: Nuclear Safety Release/Requirement (NSR/R) limitations and requirements are incorporated into OPs}

When changed (1)

Area Manager and Affected EHS Discipline (Radiation, Criticality, Environmental, Industrial (4), or MC&A)

Operating Procedures (OPs)

Every 3 Years (3)

Area Manager and Affected EHS Discipline (Radiation, Criticality, Environmental, Industrial (4), or MC&A)

Common Procedures (CPs) and Work Instructions (WIs)

Every 2 Years (2)

Radiation & Criticality Safety, Environmental Protection, Industrial(4), or MC&A Nuclear Safety Instructions (NSIs)

Every 2 Years (2)

Radiation & Criticality Safety Environmental Protection Instructions (EPIs)

Every 2 Years (2)

Environmental Protection

1) The safety awareness portions of these OPs are reviewed and updated by the appropriate environment, health, and safety (EHS) discipline when warranted based on process related facility change requests.

2) Every 2 years means a maximum interval of 26 months.

3) Every 3 years means a maximum interval of 39 months

4) EHS Discipline - Industrial means normal worker safety, chemical safety, and fire and explosion protection.

11.5.2 MANAGEMENT CONTROL PROCEDURES Licensed material activities are conducted in accordance with management control programs described in administrative and general plant practices approved and issued by cognizant management at a level appropriate to the scope of the practice.

These documented practices direct and control activities across the manufacturing functions, and assign functional responsibilities and requirements for these activities.

These practices are reviewed for updating at least every two years (26 months).

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11.16 11.6 AUDITS AND ASSESSMENTS 11.6.1 CRITICALITY, RADIATION, CHEMICAL AND FIRE SAFETY AUDITS Representatives of the criticality safety function, the radiological safety function, and the chemical and fire safety function conduct formal, scheduled safety audits of fuel manufacturing and support areas in accordance with documented, approved practices. These audits are performed to determine that operations conform to criticality, radiation, and chemical and fire safety requirements.

Criticality and radiological audits are performed periodically, in accordance with documented, approved practices, such that all applicable process and support areas will be audited at least every two (2) years. These audits are performed under the direction of the manager of the criticality safety function and the manager of the radiation safety function. Chemical and fire safety audits are performed under the direction of the chemical and fire safety function manager. Personnel performing audits do not report to the production organization and have no direct responsibility for the function and area being audited.

Audit results are communicated in writing to the cognizant Area Manager and to the manager of the environment, health & safety function. Required corrective actions are documented and approved by the Area Manager, and tracked to completion by the environment, health & safety function.

Radiation protection personnel within the radiation safety function conduct weekly nuclear safety inspections of fuel manufacturing and support areas in accordance with documented procedures. Inspection findings are documented and sent to the affected Area Manager for resolution.

Records of the audit or inspection, instructions and procedures, persons conducting the audits or inspections, audit or inspection results, and corrective actions for identified violations of license conditions are maintained in accordance with procedural requirements for a minimum period of three years.

11.6.2 ENVIRONMENTAL PROTECTION AUDITS

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11.17 An audit schedule of the environmental protection program is developed by the environmental protection function on an annual basis. Audits are conducted in accordance with documented practices to ensure that operational activities conform to documented environmental requirements.

Personnel under the direction of the manager of the environmental protection function perform the environmental protection audits. Personnel performing the audits do not report to the production organization and have no direct responsibility for the function and area being audited.

Audit findings are communicated to the cognizant Area Manager, who is responsible for nonconformance corrective action commitments in accordance with documented practices. The manager of the environmental protection function or delegate is responsible for resolution follow-up for identified nonconformance. Audit results in the form of corrective action items are reported to the GNF-A Facility Manager and staff for monitoring of closure status.

11.6.3 INDEPENDENT AUDITS GNF-A commits to perform triennial independent audits of its safety program elements (radiation protection, criticality safety, chemical safety, fire and explosion protection, industrial safety and environmental protection). The audit team will consist of appropriately trained and experienced individuals who are not involved in the routine performance of the work or program being audited. The audit scope includes compliance to procedures, conformance to regulations and the overall adequacy of the safety program.

Audit results are reported in writing to GNF-As Facility Manager, the Area Managers, the manager of the radiation safety function, and the manager of the criticality safety function, as appropriate. The findings of the audit are assigned to the appropriate safety function or Area Managers. The assigned responsible individual takes the necessary steps to investigate the finding and identify appropriate corrective actions to address and correct the finding.

The corrective actions resulting from the audit are entered into the management tracking system and reported and tracked to completion by the Facility Manager.

11.6.4 FIRE SAFETY Fire protection audits and inspections include:

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11.18 Internal formal quarterly audits, supplemented by routine informal inspections.

Independent auditors perform scheduled fire protection, prevention and inspections of the facility. Action plans are developed to address findings arising from such inspections.

These audits and inspections verify that ignition sources and combustibles are properly controlled.

11.6.5 WORKER CONCERNS GNF-A commits to maintain a safety conscious work environment. All workers are encouraged to report potentially unsafe conditions to their supervisor, management or the safety organization. Reported concerns are promptly investigated, assessed and resolved.

11.7 INCIDENT INVESTIGATIONS GNF-A commits to maintain a system to identify, track, investigate and implement corrective action for abnormal events (unusual incidents). The system includes the following requirements and features:

The system operates in accordance with written procedures Abnormal events are documented, tracked and reported to the Area Managers, the safety functions and facility management Abnormal events associated with IROFS or their associated management measures are specifically identified Each event is considered in terms of regulatory reporting criteria Events are considered in terms of severity and compliance with regulations or license conditions.

All condition reports require investigation, a determination of root or most probable cause and the identification of required corrective action More significant condition reports require a formal, systematic determination of root cause (typically using an independent, qualified team), definition of corrective actions and a higher level management review and approval of the investigation and corrective actions

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11.19 Monthly reports covering condition reports and their status are issued to the Facility Manager, Area Managers and the safety functional managers Events are graded for the purpose of an ongoing management evaluation of facility performance and used as one element in driving safety culture focus Records of the events and the documented evidence of closure are maintained for a minimum of three years Condition report information is used where appropriate when performing ISAs 11.8 RECORDS MANAGEMENT Records appropriate for integrated safety analyses, IROFS, the application of management measures to IROFS, criticality and radiation safety activities, training/retraining, occupational exposure of personnel to radiation, releases of radioactive materials to the environment, and other pertinent safety activities are maintained in such a manner as to demonstrate compliance with license conditions and regulations.

Records of integrated safety analyses and the identification of IROFS are retained during the conduct of the activities analyzed and for six months following cessation of such activities to which they apply or for a minimum of three years.

Records of criticality safety analyses are maintained in sufficient detail and form to permit independent review and audit of the method of calculation and results. Such records are retained during the conduct of the activities and for six months following cessation of such activities to which they apply or for a minimum of three years.

Records associated with personnel radiation exposures are generated and retained in such a manner as to comply with the relevant requirements of 10 CFR 20. The following additional radiation protection records will be maintained for at least three years:

Records of the safety review committee meetings Surveys of equipment for release to unrestricted areas Instrument calibrations Safety audits

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11.20 Personnel training and retraining Radiation work permits Surface contamination surveys Concentrations of airborne radioactive material in the facility Radiological safety analyses Records associated with the environmental protection activities described in Chapter 10 are generated and retained in such a manner as to comply with the relevant requirements of 10 CFR 20 and this license.

11.9 OTHER QA ELEMENTS GNF-A performs a broad spectrum of work that requires the application of QA measures. This includes work-requiring conformance to 10 CFR 50, Appendix B, 10 CFR 71, Subpart H as well as certain aspects of 10 CFR 70. As a result of these over arching quality requirements, GNF-As management system is structured to provide a full scope of QA elements and apply them as appropriate.

With regard to 10 CFR 70, particularly the identification and maintenance of IROFS and the management measures (discussed in this Chapter) that assure the availability of the IROFS to perform their intended function when required, the following information outlines the classic QA Elements and summarizes the manner in which they are applied for the operations. The following assurance elements are applied to IROFS and the management measurements at GNF-A:

Organization - GNF-A operates to a documented organizational structure in which responsibility and authority is clearly identified Program - GNF-A operates to written policies, procedures and instructions.

Design Control - GNF-A policies and procedures outline a program to provide design control for IROFS including the management measures necessary to assure their successful operation (see CM program Section 11.2).

Procurement Documentation Control - GNF-A policies and procedures require the definition of procurement specifications, review and approval of procurement to assure they are compatible with regulatory requirements

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11.21 Instructions, Procedures, and Drawings - GNF-A uses instructions, written procedures and drawings to document configuration, processes and methods for doing work Document Control - GNF-A implements document control as described here in Chapter (11.5).

Control of Purchased Materials, Equipment, and Services - GNF-A procedures require that purchased materials, equipment or services be secured from appropriately qualified vendors and that as appropriate vendor certifications or in-house dedication of the items or work are provided Identification and Control of Materials, Parts, and Components Control of Special Processes - GNF-A procures materials from qualified vendors to documented specifications that include where necessary control of special processes. Internally the change control process, Production Tests, Engineering Evaluation Tests, Radiation Work Permit and Temporary Operating Procedure routines control special situations.

Internal Inspections - GNF-A uses pre-operational audits for IROFS to verify that parts, configuration and operations are as intended.

Test Control - GNF-A implements a functional test program for IROFS as defined in this Chapter.

Control of Measuring and Test Equipment - GNF-A maintains measuring and test equipment in accordance with procedures.

Handling, Storage, and Shipping Controls -GNF-A process for procuring materials include where appropriate handling and shipping controls to ensure the validity of the items received. In addition where shelf life is important controls are implemented to ensure these limits are implemented for the item.

Inspection, Test, and Operating Status - Where the ISA and associated IROFS require this type of marking; items are so marked and maintained.

Control of Nonconforming Materials, Parts, or Components - GNF-A maintains a non-conforming materials program.

Corrective Action - GNF-A procedures for investigating the failure of IROFS require the definition of root cause and corrective action.

Records - Where specific actions are required, GNF-A maintains records to demonstrate the action has been completed.

Audits - GNF-A provides audits as defined in this Chapter.