ML19327C196
| ML19327C196 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 11/08/1989 |
| From: | Malody C SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| To: | Bidinger G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 26074, CWM:89:121, NUDOCS 8911210135 | |
| Download: ML19327C196 (7) | |
Text
p, M b { U hIN AV
-%'_'((g' TR
.i ADVANCEDNUCLEA CORPOPAllON 110t HORN RAPIDt ROAD. PO D
~
A
. a.0130 SAFETY, SECUislTY, AND LICENSINo (509) 3758100 ThEx: 15287 q
Sf usuc N0V141989 ) f y,p Novembnr V
f7 )
CWM:89:1 poemro 9
en.:s Mall MCIiON As //
p3 g
/
g 900r.ET CLECK j^s 7gMgf p;
NOV1419g9)pp re.cs
.U.S. Nuclear Regulatory Commission
" S *a Attn:
l'r. George H. Bidinger, Section Leader C* C*
X, Uranium Fuel Section
'Q. _. '
I'-
Fuel Cycle Safety Branch, NMSS Division of Industrial & Medical Nuclear Safety Washington, DC 20555 License No. SNM-1227 Docket No. 70-1257 war Mr. Bidinger:
This letter is in response to your letter of October 6 1989 which requested 3
additional information with regard to the aprlication for amendment to License No. SNM-1227 dated April 27, 1989.
Enclosed with this letter are six copies of a written response to each of your questions and replacement pages to our license amendment.
If you have any additional questions, please contact me on (509) 375-8537.
Very truly yours,
/
C. W. Malody, Mana er Regulatory Compliance Jrs Enclosures As Stated 0Fo3 i
N k kOos Nook!57
,C PDC A Siemens Compny zhf[-
O I
1
c;.
^
~
- ?
r e
i ADVANCED NUCLEAR IUELS CORPORATION I
i DOCKET NO. 70-1257 l-RESPONSE TO QUESTIONS /CO M ENTS 1.
"In Section 2.3.1, identify the individuals or spec'fy minimum qualifications of individuals on the staffs of the Vice President, Operations Division, and Vice Presidant, Engineering Division, who are F
included in the membership of the Health and Safety Council."
Figure I-2.1 identifies those staff personnel having safety responsibilf ties and Safety Council membership reporting to the twc Vice
' Presidents.
Figure 1-2.2 identifies safety professionals.
Section 2.1 describes the responsibilities of those positions and Section 11.3 e
provides resumes of the current incumbents.
2.
'"In Section 2.3.2, t M reference to the Manager, Facilities and Equipment Engineering, should be removed."
The reference should have been to the Manager, Equipment and Maintenance Engineering.
A revised page 2-12 is enclosed.
3.
"In Section 2.6.2 of the existing license, the Plant Criticality Safety tngineer is required to conduct at least monthly inspections.of areas containing special nuclear material for compliance with criticality L
safety specifications and limits, as well as other safe practices.
Identify the position (s) or the minimum qualifications of the individual (s) who will perform these ' inspections."
Revised Section 2.6.2 - states that the Criticality Safety Component
[
conducts monthly audits.
Under the old organization, the Plant Criticality Safety Engineer performed monthly audits, and the Critic.tlity Safety Component of Corporate Licensing performed bi-monthly audits for a total of 18 l.
audits / year.
Under the new organization, the Plant Criticality Safety i
[
Engineer has disappeared and the Criticality Safety Component has effectively taken its place, and the nuinber of audits per year is reduced to 12.
However, where the Plant Criticality Safety Engineer was experienced in the practical application of cr'ticality safety principles and practices, he did not have the expertise necessary to conduct criticality safety analyses and therefore, perhaps lacked certain insights.
The two members of tna Criticality Safety Component who will perform the month'y audits do have criticality safety calculational expertise such that the audit depth will be greater.
u-3
-L
P r
s.
' ?
2 4.
"In the application, identify the positions or departments that are responsible for preparing and approving general employee and operator traidng' materials and certification criteria.and for implementing
.trai"ing programs."
The preparation Of detailed work and operating procedures, and the
.trafring of employees in these procedures, is the responsibility of the manager of each operation (i.e., Section 2.1.4, Jtem 1).
Establishment of minimum training requirements for various employee positions, training frequency, and conduct of such training for the various safety functions (radiological safety, fire safety, etc.) lies within the Safety, Secu.'ity, and Licensing Department. Detailed training requirements in these safety areas are outlined in the various Conpany standards.
A brief statement to training has been added to Section 2.4 (see revised page 2-13 enclosed).
5.
"In the existing license, the area responsibilities of the Manager, Equipment and Maintenance Engineering, include, but are not limited to, the combustible gas detection and alarm systems; security alarm systems; plant engineering programs for HVAC systems; site water distribution and effluent services; process equipment; pressure ver.sels; as well as cranes and hoists.
Identify the position (s) which will assume these area responsibilities."
i The responsibilities of the
- Manager, Equipment and Maintenance Engineering, have not changed.
The description of responsibilities was modified in that, on review, it ap: eared that his responsibilitles were greater than a simple listing of a dozen items.
The only changes in responsibilities resulting from the reorganization were the split between Operations and Engineering at the Vice Presidential level, and the combination of the Safety and Security function with the Corporate Licensing function at the Department level.
6.
"The Approval and Responsibility Matrix, Figure I-2.3, should show the implementation responsibilities of the listed positions and components.
l In addition, please define the term " accept" used in the matrix."
I 1
The " implement" designation has been removed from the matrix because the documents Ifsted are not implemented; they are to be followed or adhered to by all personnel.
For example, the Radiation Orotection Standards must be adhered to by any person working with radioactive n.,terial or working in a radiation zone, whether he is an canployee of the Company or J
not.
The work " accept" in the matr;r means that the organization.can and will adhere to those reautrements tha' pertain to areas and/or operations within his sphere of responsibility.
l L
L n
g s
i e
' ADEMCEDNUCLEARMELSCCRPORATKW m p.,
SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM 1227, NRC DOCKET NO. 701257
)
l PART I - LICENSE C0iiDITIONS REV.
j 20 6.-
Appropriate managers within other organizations.
7.
Key safety engineers and specialists.
Designated member's of the Council make monthly inspections of buildings and grounds #or housekeeping and safety practices, and report the findings to the Council at 'he monthly meetings.
Findings are assigned to individuals for resolution and are held open until resolved.
2.3.2 ALARA Committee An ALARA (as ' Low as Beasonably achievable) Committee maintains awareness of trends in employee radiation exposure and radioactivity content of effluent releases. The membership of the Committee includes:
1.
Manager, Regulatory Compliance (Chairman).
2.
Health Physics Specialist (Secretary).
3.
Supervisor, Radiological and'Industriel Safety.
4.
Manager, Equipment and Maintenance Engineering.
5.
Manager, Plant Mainten nce.
6.
Manager. Plant Operations.
7.
Manager, Process Support Engineering.
The ALARA Committee shall convene at least semi-annually.
The ALARA Committee shall issue a formc1 report at least annually to the Health and Safety Council reviewing employee exposures and effluent release data to determine:
1.
Trends in personnel exposures and effluents.
2.
If personnel exposures or radioactive effluents might be lowered under the concept of ALARA.
3.
If equipment for effluent and exposure centrol is properly designed, used, maintained, and inspected.
Their reports shall include review of requirea audits and inspections performed during the past year, and review of employee external exposures, bioassay results, unusual occurrences, effluent releases, in-plant airborne radioactivity, and environmental monitoring.
AMENDMENT APPUCATION DATE PAGE NO '
g, g ANF 3830 0$1 A (5<68)
\\'
,--~~~
m
/
' ADEMCSDNEJCLEARMELECORPORATKW i
y.,
SPEC!AL NUCLEAR MATERIAL LICENSE NO. SNM 1227, NRC DOCKET NO. 701257 PART I - LICENSE CONDITIONS REV.
20 2.4 Trainina in addition to normal on-the-job training amployees are instructed in radiation' protection and criticality niety requirements and procedures, industrial cafety, fire protection, end emergency procedures.
The degree of training is commensurate with each employee's position in the Company (related to general and special responsibilities), and with the extent of the employee's.. contact with radioactive. and fissionable 1
materials.
The minimum safety-related. training requirements for various employee positions are established by the Safety, Security, and Licensing Department, including training and retraining schedules and training course ' content.
Employee instruction is provided by personnel knowledgeable in the various training topics.
All formal training is documented, and records are maintained by the Safety, Security, and Licensing Departnent.
2.4.1 Jnitial Trainina Each employee is provided initial instruction adequate to allow him to safely start on-the-job training; they are provided the full instruction within two weeks after starting work.
Prior to assignment to independent operation, each employee is required to have been instructed in radiation protection, criticality safety, and emergency requirements and procedures as appropriate to his position.
P 2.4.2 Followun Trainina i
When changes are ' made 'in radiation protection, criticali'ty safety l
controls (procedures, specifications, etc.), or in emergency procedures, each employee affected is promptly informed and properly instructed.
Safety topics are routinely discussed in monthly safety meetings.
l Additionally, each employee routinely working with special nuclear material receives annual refresher instruction as.part of Advanced L
Nuclear Fuels continuing program in radiation protection and criticality safety awareness. The effectiveness of this annual refresher training is determined by giving the employees t written examination and reviewing the correct answers to the questions at the end of the test.
l 2.4.3 Health Physics Technician Trainina Health Physics Technicians are given special training related to g
I their radiation protection assignment.
Previous training is accepted if considered equivalent to' the Advanced Nuclear Fuels training program.
Despite previous acceptable training, the Health Physics Technicians are auenoueur amcam~ oan November 8, 1989 2-13 I
.NF 38300514 $$4s W
V
' ' ' ~ ADitANCED NUCLEAR MMLS CORPORATION y7 2 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM 1227, NRC DOCKET NO. 701257 PART I - LICENSE CONDITIONS REV.
I 20 h,
required to become proficient in Advanced Nuclear Fuels radiation protection and criticality safety programs, criteria, specifications, i
procedures, and routines, as demonstrated by successfully passing an Advanced Nucleat Fuels certification examination within six months after Health Physics Technician.
In addition, refresher employment as.
training is provided to all Health Physics Technicians annually.
2.4.4 Trainina Evaluations Employee awareness of, and conformity to, sefety requirements and procedures, ' as well as the effectiveness of safety training programs, shall be evaluated at least monthly by the' Radiological Safety Component for radiation protection, and by the Criticality Safety Component for criticality safety.
These Advanced Nuclear Fuels staff members have the authority to require retraining of employees. These evaluations shall be documented along with actions required by them.
2.5 00eratina Procedures. Standards and Guides Advanced Nuclear Fuels conducts its business in accordance with a rystem of St.andard Operating Procedures, Company Standards, and Policy Guides.
Advanced Nuclear Fuels is committed to controlling activities involving special nuclear materials in accordance with these approved written procedures, standards, and guides.
These documents are prepared, reviewed, revised, approved, and implemented in occordance with the Approval and Responsibility Matrix (Figure I-2.3).
Plant and facility managers are responsible for assuring compliance with all pertinent radiation protection and criticality safety procedures, specifications, and practices within their respective facilities.
Violations of radiation protection or criticality procedures, or specifications which are of repetitive or serious nature, are subject to disciplinary action.
e The Supervisor, Radiological and Industrial Safety, is responsible for assuring that Health Physics Technician activities are conducted in accordance with established and approved procedures,
- methods, and frequencies.
2.6 JJ1ternal Audits and Inspection's Audits and inspections are cunducted to determine that plant operations are conducted in compliance with regulatory requirements, license conditions, and written procedures.
These audits and inspections apply to radiation protection, critical ity safety, hazardous chemical safety, fire protecticn, and environmental protection.
Tuenoue=T *. ucinou oire.
November 8, 1989 2-14 AN74830 0St 15,681
QvQ:.4a % ppm, e b,e. b,f f, mi J.h. m.,.Q.. N.7,. ~ (".s yQ %% k f Q ; " n h..j]
e 3s-g4 j
y
.,l ';,
m,.,"*- a, _
n.
- s. ~
s'
',Q\\e o
2 -
[/ i > -
. J..
c>>.. nH.
K.wwq i ; p i.}m > n,,
i e;.cs r
. Q i't.hjg' c S: j%ff$, ]!.y pV ' N, J P,
- 4 e
ea m'
. o z.
?,$"
I d
.Y it' j'
m. p;, ty
~ y
..g ~ j / v1; 7
g W! s C 7 H;
'l GW
(
q {.,
L..+
3 q
pus y
.4 c3
.9 4. e. ". p: g.
W-
. w n
MbOM,,-, K..., t g,
- Q:.
$(., 7
+
+
+
. J _i, N N M.N p 6
,v t
~
t
> ~ 4 l 'N '. N.. ? f 3
,/wt- -,
c.i W
.. l'
.,,3 li ggr y gd, k. g.V Y
- E'
- /
- 9. ( >'
3y ' 8
=
,-9 VE WQ' Y.
r s-ig
, w: - ny. -
- -g iff
}
- [/
dyg;*%. G. 3..
m
]
,,O s
,[...
%s 5
<4.
e i
s mr I
i
,c.
,q.',.
i
- +
<, ^
- /
1 o,,
.y,-p~ - -
+.
1
@O L. -.
- 4 n q=
. a t.
'3'
,,g
, i
'.! v :
2 e,
g t
g
.,'9
{H( n h f h. %,',,,y~g
- L.,D I '1D-D2
b. :
4 y.
y s
a
- ,f.,
t s..
s i
i
}%.,,w;4
,.e i
-s, k
3 Y
.'ss p" 0( v g '
'}.
,{
i,
'"\\.
'f k,
j'k 2 b
4h g
,{
.k'
_ q(, [J,
r
[
,- k
[-] } '. - [
,,I y h hI.
i,lg.J p
g 3s weg
-j t
wt qe 5y
, m 4
a4Q yg.cs 5
s
.'s c-v4 r
nA.
- i. ~ (
, ' z f' c' j7 d
-d
~W.,. q"A 1
fin
, (,
,4 s
N..a Q pA, sy / 613['l ' '
[,,
I e
se
'33 3
f i
, h. :
<. p'
, i s qt
. p'. a 7 7,, r
.;kIs v,.,, '
,.73](, g. ' 3 min s s
$,. ~gio.
3
,.1
)C
't a
' g '...,
-5 j-
,, f 5p i{;
' l'
.2 s
. ys
- y
. }.
j y
a 4
t.
s.,
f I
.e y,
l' g
<s
- a. % e't.
,b.a to
.,1 s,
1.e, -pq.
.1.4
'lgt s
1 e
- { s.
i aa wu 48
,, [P -
t'([
.. g s
- . c 2
}
y n. e t
,E
' M+<I,
( (f
'hi' ' \\
. ' I 'y g.
' )
my[,gw
.j'..G
+
..u, m..sb y< -
,m..
'2..
j
'4, p.
5 %.,
,a
-m t.-
,._g
L
/
g
.P
+,.t.1
+u.,l.u v f,* 'f.7.:.r f.,.,.,).y'.
,.sg;^
g'i.f y" h} g s i.J t' f,
'd k' 5 9
9 ?
e,G, i,3:
e'
', t:
a t
g
.ic4 -
i hg%
9t,gUL, f <e<
.t 4 n
., +.
t4;6 e'1
.).
,,.- ( n y-3 s
s I,h ' [
id. -
/
. [,-
D ". ' li ;
i ;II i r
e-
)
i
&+.
- UDCKET4.0lL ' Q ]2S.
j$ jl
' T-JCONTROLLNOW- [/,3M O, ]'
~
.a, b i'
. +.
iP l j
?
d DATE.RCVD.
a,
~ ~ ~
~
g-g GCg" '
4 '
k, b
w p ~y ~
- rcur-9
,pDR
~
- mya, w-pg -_
fppg._
4 e
e
. n
..;.g g
y,
y y
- m. w n s p s,.
.. c i
.L 97 g g g'ggy< -/
x v
r pyt a
n.
~
y ;";
m
~ -_.
??
'$hM WhQQf h.
n i
(w'. @o:? M -
4
- m 5
- FCTC a'f __ f,
D h iE ).
e,
/.
h f
[QEg-
,0 m gg y.-
an f,f I
- mgp
~
..g s.
a w,
o-l siQ
. f ~<.
a
+', ".
i, ad d
' A.
a :-
.'~
),
O
,u d..,
py S..
e..y vir7 g.
r c
, q ;.
gn '.
c
.x.
,h.';
} \\Ih-I...
' _. u. 'a r '
,. !.. <* q _f 'i
- li kf a
l-,
g, 'c,
- t. i r {>
s'.
%. +.,
. g *y e
2 t
4 hr.,, 3.
L.,
s 4
(
.o I
Ef n,.
5
}
y
,;/ ?fJ))7..g p.4 j t.'
p
'S 4
p1 r
y I
e'7 a
x.
,5h.
e4,o 3.,x w j
1
- n; l >
Mit a s g
4,oy3-
-) ? t ',
N i y:c T d,, q'. o!s-5,
q m,.
r
.%m,
+
sw
' h~
- 3. ;
y e
.h(w,.yu_ s at
(
':- q r
y r
s
<.l fYQ& s]U,((N y'+
w p.g6,
4
, ppt ~.t g,-
b
' Y k. Jl f.h.. \\(i
,%h di s%pp ' y( 3
+
4
- w,.pij '.. f9(s p;2,
y, o
.h..
i;J!
s
' L-lx p % (R ff.Qg, Q',
.g 6 %,, r 7 _vg., -'.
)-
i g,; 9 i.!4 a p? 'L.s\\q
.s.'re -
y h,g [n> \\ 'y W..'.
a # ' 9 */j., ' 1',) [ ',
3 4
't y% 7 e y
4b
-4 3.1 4
e f
rJ '
9
.y n z p '
s,,!,r s2 s,
ik j.
wy 6
m e% MC a ; rp 4p[/
N.
k
'. k
'Ab
. g..
').
} ply}%Q ' ;%q]Q{ x 3:.
- A-&l.;,
,w s
. y_
n,.,
w eM,' s.
~
1> -.m m ~f.s.?-
s'y '-~o-
.s.
.,l' 9
Q t
n i
a
+<'m y,,
a' 4,, m ' ~ J; y 5
3 an
,