ML20058P525
| ML20058P525 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 10/14/1993 |
| From: | Edgar J SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| To: | Pierson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| TAC-L30596, NUDOCS 9310250065 | |
| Download: ML20058P525 (12) | |
Text
.
S.E EMENS October 14,1993 j
U.S. Nuclear Regulatory Commission Attn: Mr. Robert C. Pierson, Chief
)
Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS Washington, DC 20555 Ucense No. SNM-1227 Docket No. 70-1257
Dear Mr. Pierson:
Re:
Letter, MT Adams to LJ Maas," Personnel Changes and Equipment Change Process (TAC No. L30596), dated September 2,1993 Per recent telephone conversations with Mary Adams of your staff and a meeting on September 30 with Mary Adams and Mike Lamastra, enclosed are Siemens Power Corporation's (SPC's) replies to the requests for additional information in the referenced letter.
If you need further information, please call me at 509-375-8663.
Very truly yours, de.(
L James B. Edgar Staff Engineer, Licensing JBE:pm i
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.l Siemens Power Corporation Nuclex Dusan Engmeng and A%nutaaunrg Facuy 2101 Horn Ranm Rw1 PO B7x 130 P;d;!and, WA 99352 0130 lei (509) 375-8100 Fax (509) 375 8402 9310R50065 9I1014 PDR ADOCK 07001257 ?
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k License Part I NRC Reauests t
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, arid other releases to the environment.
2.
Section 2.1 should include the organizational usponsibilities 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.
SPC Reply SPC agrees that the responsibilities and authorities as well as minimum qualifications for the Manage. of Waste Management Engineering and the Analytical Laboratories should be included in Sections 2.1 and 2.2, respectively of the license application. We intend to make these changes in the near future. Making these changes however should not affect SPC's notifications of May 6 and June 15,1993 of revisions to Part 11 (Chapter 11) of our license application.
NRC Reauest i
4.
The first sentence of Section 2.5 should explicitly state that the ECN procedure is one of the Standard Operating Procedures, Company Standards, and Policy Guides that Siemens uses to conduct business.
SPC Reply SPC confirms that the ECN procedure is one of the procedures, standards, and guides used l
to conduct its business. We do not agree that this fact needs to be explicitly stated in Section 2.5. It is our understanding that the NRC agrees that SPC's confirmation of this fact in this letter is sufficient.
NRC Reauest 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 -
i also be included in the Approval and Responsibility Matrix, Figure 1-2.3 (as revised in Amendment 16, issued April 27,1993), 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.
l Page 2 October 14,1993 SPC Reply Because the ECN procedure is a procedure that SPC, in Section 2.5, has committed to operating under, we da not agree that such information needs to be restated as a license condition in Section 2.5. We have modified the Approval and Responsibility Matrix to add a line pertaining to review and approval of the ECN procedure. The ECN procedure now requires approval of the Manager, Manufacturing Engineering and the concurrence of the Manager, Safety, Security and Licensing. The review of the affected managers, e.g. Manager, Plant Operations, better serves safety when applied to a specific ECN rather than the ECN procedure.
The ECN procedure, as well as all other SOP's, are available for NRC inspectors to examine at any time.
NRC Reauest 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 t
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 conditions 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.
SPC RepIV SPC agrees that the ECN procedure is a very important one vis-a-vis the effects on safety from plant equipment changes, but does not agree that it is unique. SPC feels that violation of any procedure can affect safety. As stated in the SPC replies above, the procedure is available for examination by the NRC; it is already described quite thoroughly in Chapter 11; and SPC has committed, in Section 2.5, to operating in accordance with it. We do not, therefore, agree that this procedure needs to be redescribed in Chapter 2.
NRC Reauest 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, on Product Development and Testing), and " concurrence" by three l
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.
4
Page 3 October 14,1993 SPC Repiv I
As used in the Approval and Responsibility Matrix:
Approve means overall agreement that the document has been properly and completely reviewed and should be issued for use.
Concur means that the person has reviewed the document within his area of expertise and agrees with it.
Accept means that the person responsible for compliance with the terms of the document agrees with it. (There are documents listed on the matrix; e.g., ECN's and
)
Criticality Safety Analyses, which also require acceptance of completed work).
j j
Shortened versions of these definitions have been added to the matrix. Revised pages 2-21 and 2-23 for the existing license and the 8/26/92 renewal application, respectively, are enclosed.
An ECN is not a document which is " accepted" or " audited" within the context of the above definitions, rather the work done under an ECN is reviewed and accepted by a number of j
individuals and groups, as described in Chapter 11 and in the ECN procedure itself.
License Part 11 NRC Reauests 1.
An education and experience statement for the Manager, Waste Management Engineering.
2.
An education and experience statement for the Manager, Analytical Laboratories.
SPC Repiv As discussed in the answer to NRC requests 1,2, and 3 in Part I, SPC agrees that the managers of Waste Management Engineering and the Analytical Laboratories should be included and we intend to include their education and experience statements in the near future. Also as stated previously, we do not believe that these future changes should affect SPC's May 6 and June 13,1993 notifications.
J l
NRC Reauest 1
3.
The title for S.F. Kuick (Section 11.3.11) should be corrected to Manager, Master Scheduling and Uranium Management.
Page 4 October 14,1993 SPC Reolv Page 11-20 has been revised to show S.F. Kuick as Manager, Master Scheduling and Uranium Management and copies are included herewith for the existing license and the 8/26/92 renewal application.
NRC Reauest 4.
Chapter 11 should include a description of how the ECN procedure and the conditions under which it is used protect safety.
SPC Reoiv Paragraph 11.6.1 has been revised to describe the safety enhancement aspects of the ECN procedure. Copies of revised pages 11-48,11-49,11-50, and 11-51 for both the existing license and the 8/26/92 renewal application are included herewith.
t P
5 1
SiemenS Power Corporation - Nuclear Division eus.2 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO,70-1257 7-.
PART 11 - SAFETY DEMONSTRATION ggy.
i l 11.3.11 Manaaer. Master Schedulina and Uranium Manaaement - S. F. Kulck t
l Education I
BS Chemistry 1978
'Jniversity of Michigan MBA Finance 1980 University of Michigan l Experience t
1980 1983 j
i Employed by Exxon Corporation, N.Y., N.Y.
i l*
Financial analyst responsible for eamings reporting and analysis.
l
> 1983-Present j
i
- Employed by Siemens Power Corporation, Richland WA.
Senior Accountant 1983-1987. Responsible for manufacturing accounting, tax l
accounting, and German affiliate matters.
l l
Cost model and estimating analyst from 1987-1990. Responsible for cost
{
estimates for bids and proposals and special cost studies and other types of l
l economic analyses.
l l
Project Manager from 1990-1992. Technical coordinator and project manager l
for several foreign customers in Germany, Sweden, and Japan.
i Manager, Master Scheduling and Uranium Management 1992 to present.
Responsible for manufacturing planning and scheduling and management of l
uranium supplies and inventory.
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October 14,1993 j
11-20 3
j 4
SPC ND:3330 947 (R1/07/92) l
4 p
SiemenS Power Corporation - Nuclear Division EMF-2 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 L
PART 11 - SAFETY DEMONSTRATION
- ngy, i
I 11.5.2 Followup Trainina When changes are made to processes involving special nuclear materials, radiation protection procedures, criticality safety controls (procedures, specifications, limits, etc.), fire protection or emergency response procedures, each employee affected is promptly informed and properly instructed by his/her manager or supervisor.
l Additionally, each employee who routinely works with special nuclear material receives
! annual refresher instruction as part of SPC's continuing program in radiation l protection and criticality safety awareness. This training is provided by radiological
~
! and nuclear safety personnel knowledgeable in the various training topics. The i
l effectiveness of this annual refresher training is determined by giving the employees a f
written examination and reviewing the correct answers to the questions at the end of 1
! the test.
l All employees routinely discuss safety topics in monthly or quarterly scheduled safety meetings.
r i 11.5.3 Emeroency Response Trainina l Training in operating plant fire extinguishers is offered to all employees on an annual l basis.
Plant Emergency Response Team members are offered training in incipient fire fighting techniques, advanced first aid, self-contained breathing apparatus in a smoke-filled j
environment, and chemical and radiologicalincident stabilization techniques on an j
i l
annual basis.
j j
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I Semi-annual training is provided to all employees in the proper response to a criticality i
accident when a preannounced criticality evacuation drillis conducted. Periodic l
l
- training is provided to employees in the proper response to a fire alarm when j~
' unannounced fire drills are conducted.
j j
- 11.6 Chanaes in Facilities and Eaulpment 11.6.1 Enalneerina Chanae Notice i
i
' Changes in facilities and equipment involving licensed materials are accomplished j
through application of the Engineering Change Notice (ECN) procedure, which is i
(
I issued and maintained by Manufacturing Engineering. This procedure provides i
i instruction for authorizing and documenting the installation of new equipment, l
facilities, and services and modifications to existing equipment, facilities, and services.
j j
The procedure defines what kinds of work or changes require use of an ECN and l
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, what kinds of work may be accomplished via a work order. It also enhances safety by I
l uSGhmcuose October 14,1993 11-48 l
1
- - "l I
SPC NO 3330.947 (R-1/0792)
SiemenS Power Corporation - Nuclear Division eup.2
, SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 PART II - SAFETY DEMONSTRATION nev.
equiring hazards reviews, ensuring that drawings and diagrams are updated to reflect
! "as built" conditions, and confirming that SOP's are updated and the required training j performed.
l
! 11.6.1.2 Initiation and Review I
l l The initiation and review process incl +s the preparation of an ECN package and its j review by industrial and enticality safety specialists, as well as Plant Engineering and
- the user organization. During this review period it is determined if a criticality safety i
- evaluation is required. If so, it is formally requested from and completed by the l
Criticality Safety Component.
11.6.1.3 Documentation Each ECN is given a number and a title which are entered in a logbook. The ECN
, form and applicable documents are stored in an ECN file and retained per regulations
, and Company policy.
l l
11.6.1.4 Review Prior to Execution i Depending upon the nature of the modification, a varying number of people must
! approve or concur prior to execution of the work described in the ECN. Some
, modifications require more extensive review by engineering groups than do others.
! All, however, require concurrence by Safety and the user organization.
11.6.1.5 Execution l
Work specified by the ECN may be accomplished by either SPC Maintenance j
j j SPC maintenance work or the type of work involved. ECN packages are issued to j
craftsmen or by local construction contractors depending on the current backlog of j
l
- different personnel in SPC depending upon which organization does the work.
l i
l 11.6.6 Acceptance of Completed Work I
i For work not involving fissile material formal acceptance is accomplished by at least the user's group, Safety, and the group responsible for the work.
For projects involving fissile material a physical review of the installation by a Criticality Safety Review team must be made prior to the introduction of fissile material. This review team consists of the Criticality Safety Specialist, a user's group supervisor, and the engineer responsible for the work and the review is documented by the signature of the Criticality Safety Specialist on the ECN form.
l i
f IAM Ni t N APPLICATON D i[
PAGE NOa j
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Siemens Power Corporation - Nuclear Division EMF-2 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 i
PART 11 - SAFETY DEMONSTRATION
- ggy, l --.-
- if the ECN involves work by outside contractors, the Manager, Facilities / Landlord signs l the ECN indicating that all required contractor work was performed as required, j Final acceptance of work and agreement that the new or modified facilities and/or l equipment can be turned over to the operating organization may require the
! convening of a Startup Council and/or the performance of an acceptance test.
j 11.6.2 Startup Council I
! If a Startup Councilis required to be convened, the council will be responsible for
! reviewing and concurring with projects for conformance to plant production and
, schedule requirements and safety requirements Startup Council concurrence is i
! usually required for system operation; however, final authority for approving actual
! startup rests with the responsible manager.
While the Council is staffed to be appropriate with the project content, the basic
' Council for most projects consists of:
Manager, Manufacturing Engineering (Chairman)
!
- Manager, Plant Engineering (Secretary) l
- Manager, Quality Assurance l
- Manager, Safety, Security, and Ucensing l
i i
Manager, Process Engineering j
l Responsible operations manager j
i Startup Coordinator l
11.6.3 Acceptance Test l
l t
i i
- if an acceptance test is required, it is carried out under an Acceptance Test Procedure j
i (ATP). The purposes of the ATP are (1) to outline the requirements for documenting l
l the testing of work for proper installation, for conformance to the criteria and i
j j specifications to which the work was done, and for confirmation that the modified j
i facilities and/or equipment are ready for safe operation; and (2) to assure that the l
, Master Equipment File is supplied with appropriate documents as required by the ATP.
l
! The ATP is reviewed prior to performance by Engineering, Safety, and the responsible operations manager. Final acceptance after performance of the ATP is documented l by signatures of Engineering, the responsible operations manager, and the Criticality Safety Review Team, if the work involved fissile material.
j 11.6.4 Records l
l The ECN record file is maintained by Plant Engineering and includes the original ECN's, a set of detailed drawings, specifications, applicable excavation and j
penetration permits, copy of any Criticality Safety Evaluation requests, and the
- AVE NDMEN1 APPLICATION DATE:
l PAGE NO:
I October 14,1993 l
11-50 l
SPC-ND:3330 947 (R-1/0792) j
Siemens Power Corporation - Nuclear Division EM F-2 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 PART 11 - SAFETY DEMONSTRATION ggy.
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l completed ATP. Copies of safety and hazards analyses are maintained by the project l engineer and/or the persons performing the analyses.
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October 14,1993 11-51 i
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