ML20057D134

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Requests Addl Info Re 930719 Application Requesting Amend to Matl License SNM-33 for Organizational Changes
ML20057D134
Person / Time
Site: 07000036
Issue date: 09/30/1993
From: Tokar M
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Rode J
ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
References
TAC-L30595, NUDOCS 9310010154
Download: ML20057D134 (3)


Text

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Docket 70-36 License SNM-33 SEP 3 01993 Mr. J. A. Rode, Plant Manager Hematite Nuclear Fuel Manufacturing Combustion Engineering, Inc.

P.O. Box 107 Hematite, MO 63047

Dear Mr. Rode:

SUBJECT:

ORGANIZATIONAL CHANGES (TAC N0. L30595)

This refers to your application dated July 19, 1993, requesting i

an amendment to Materials License SNM-33 for organizational changes.

Our review of your application has identified additional information that is needed before final action can be taken on your request. The additional information, specified in the enclosure, should be provided within 30 days of the date of this letter.

Please reference the above TAC No. in future correspondence related to this request.

i If you have any questions regarding this matter, please contact Mr. Sean Soong of my staff at (301) 504-2604 or me at (301) 504-2590.

B Michael Tokar,y Section Leader t

Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS

Enclosure:

As stated cc w/ encl:

4 Mr. J. F. Conant, Manager Nuclear Materials Licensing l

l Distribution w/ encl. (Control No. 3305) l Docket 70-36 PDR/LPDR NRC File Center NMSS R/F l

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Request for Additional Information Appilcation Dated July 19, 1993 Combustion Engineering, Inc. (CE) i Docket 70-36 I

General Comments:

1.

CE should include the controls and limits that are important to safety in the license and supporting documents such as the operation sheets.

2.

Section 2.6 states that limits and controls in the license are contained in operation sheets. These limits and controls are a necessary ingredient to the safety of the operation and should be maintained at all times.

In addition, it is imperative to i

ensure that when items that may affect safety are replaced, these changes should be made under the auspices of a formal program that provides for review.

Please provide a description of the program that CE utilizes to accomplish these objectives.

Specific Comments:

Paae Comment t

I.2-1 Section 2.1.1 should clarify that the Plant Manager is responsible for delegating an individual to his position during his absence.

)

1.2-3 In Section 2.1.5, delete "or at other nuclear fuel locations."

1.2-6 Revise Section 2.6 as follows:

I Include the position title of the individual who is responsible for determining the need for the Focused Factory Manager's approval of the operating l

procedures.

t 4

The Nuclear Criticality Specialist (NCS) and the Health Physicist (HP) may not sign the operating j

procedures in lieu of the Manager, Regulatory Compliance.

l The Manager, Regulatory Compliance, may conduct the nuclear criticality safety evaluation only when he meets the qualification requirements for an NCS as defined in page I.2-12.

l I.2-7 In Section 2.6, replace " involving nuclear materials" with "affecting nuclear materials."

I

2 1.2-9 In Section 2.7, the quarterly inspection of radiation safety should be conducted by an individual who meets the qualification requirements for the HP as defined on page I.2-12.

I.2-12 Experience requirements for the Manager, Regulatory Compliance, should include industrial safety.

Experience requirements for the Focused Factory Managers should include engineering design and process for nuclear manufacturing industry.

Experience requirements for the Nuclear Criticality Specialist should include 1 year of conducting nuclear criticality evaluations for a fuel fabrication facility.

Provide justification for reducing the years of required experience for the Manager, Regulatory Compliance.

I.3-6 Section 3.2.4 should indicate whether the Health Physicist or Supervisor, Health Physics, has responsibility for determining if radiation safety monitoring is required for all non-routine operations.

11.4-1 Section 4.1 should identify the position title of the individual who is responsible for posting the criticality and radiological safety limits in each work station. Also, clarify that the Production Supervisors are responsible for assuring that these j

safety limits, as required by the license and/or regulations, are properly posted.

l