ML20056G602
| ML20056G602 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 09/02/1993 |
| From: | Adams M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Maas L SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| References | |
| TAC-L30596, NUDOCS 9309030316 | |
| Download: ML20056G602 (4) | |
Text
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wassinctow. o.c. cosss-oooi SEP 2 1993 Docket 70-1257 License SNM-1227 Mr. L. J. Maas, Manager Regulatory Compliance Siemens Power Corporation 2101 Horn Rapids Road Richland, Washington 99352-0130
SUBJECT:
PERSONNEL CHANGES AND EQUIPMENT CHANGE PROCESS (TAC NO. L30596)
This refers to your submittals of May 6 and June 15, 1993, concerning proposed changes to Chapter 11 of Part II - Safety Demonstration of your license.
These changes include updated education and experience statements for personnel responsible for safety, and changes to the Engineering Change Notice (ECN) process.
As a result of our review of your proposed revisions to the Safety Demonstration, we have determined that an amendment to Part I of the license is necessary. The amendment should be made to Chapter 2, Organization and Administration, of Part I of the license and should address the following items:
1.
Section 2.1 should include the organizational responsibilities and authority for the Manager, Waste Management Engineering, because this individual has responsibility for management of solid and liquid wastes, gaseous and liquid effluents, and other releases to the environment.
l 2.
Section 2.1 should include the organizational responsibilities and authority for the Manager, Analytical Laboratories, because this individual is responsible for analysis of radiological and environmental samples important to the safety and environmental programs.
3.
Section 2.2 should include minimum qualifications for these two Managers.
4.
The first sentence of Section 2.5 should explicitly state that the ECN procedure is one of the Standard Operating Procedures, Company l
Standards, and Policy Guides that Siemens uses to conduct business.
l 5.
Section 2.5 should identify the positions of the individuals responsible for the preparation, revision, and approval of the ECN procedure. This information should also be included in the Approval and Responsibility i
Matrix, Figure 1-2.3 (as revised in Amendment 16, issued April 27, 9309030316 930902 I~
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SEP 2 1993 1
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Mr. L. J. Maas 2
i 1993), with an area of responsibility distinct from that of ECNs.
The individual (s) responsible for approval, concurrence, and/or acceptance of the ECN procedure should include the Supervisor, Safety, as well as the affected managers in Manufacturing Engineering and Plant Operations.
i i
6.
Any modifications to the plant or processes can have effects on safety; this makes the ECN procedure unique among company procedures, standards, and guides.
Because of this unique nature of ECNs, Section 2.5 should contain more detail about the ECN procedure than the other procedures, standards, and guides. This section should list the safety-related cenditions under which an ECN will be used.
Section 11.6.1 of Part Il currently contains a, number of these conditions; Section 2.5 should include these and any other safety-related conditions under which an ECN rather than a Work Order or other change procedure would be used.
7.
The Approval and Responsibility Matrix - Figure 1-2.3 (as revised in Amendment 16, issued April 27,1993), indicates that Engineering Change Notices are prepared by a Project Engineer. They require " approval" by one of six managers (Plant Operations, Quality Control, Traffic and Warehousing, Manufacturing Technology, Materials Research, or Product Development and Testing), and " concurrence" by three Managers (Process Engineering, Plant Engineering, and Quality Control) and the Supervisor, Safety.
Distinctions among the " approve," " concur," and " accept" responsibilities indicated in the matrix should be clarified in the matrix itself or in Section 2.5.
The matrix should also indicate acceptance and audit responsibilities for ECNs.
The Safety Demonstration should include the following:
4 l.
An education and experience statement for the Manager, Waste Management Engineering.
2.
An education and experience statement for the Manager, Analytical Laboratories.
3.
The title for S.F. Kuick (Section 11.3.11) should be corrected to 1
Manager, Master Scheduling and Uranium Management.
4.
Chapter 11 should include a description of how the ECN procedure and the conditions under which it is used protect safety.
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l SEP 2 1993 l
I Mr. L. J. Maas 3
This additional information, in the form of an amendment. application, should be provided within 30 days of the date of this letter.
These changes should also be made to the license renewal application.
Please reference the above TAC No. in future correspondence related to this request.
If you have any questions regarding this matter, please contact me at i
l 301-504-2505.
Sincerely,
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'$U Mary Thoma Adams l
Licensing Section 2 l
l' ensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS l
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SEP 2 19p Mr. L. J. Maas 3
This additional information, in the form of an amendment application, should be provided within 30 days of the date of this letter. These changes should also be made to the license renewal application.
Please reference the above TAC No. in future correspondence related to this request.
If you have any questions regarding this matter, please contact me at 301-504-2505.
Sincerely, (Xigml SW*i D Mary Thoma Adams Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety i
and Safeguards, NMSS I
1 DISTRIBUTION (Control No. 2005) 356 Docket No. 70-1257 PDR NRC File Center NMSS R/F FCLB R/F Region V CHooker, RV FCSS R/F ETenEyck l
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NAME Madams'//F///
hiiarpe MToI N DATE 08/3 //93 hB/DI/93 dk/ 2./93 C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY
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