ML20135C725
| ML20135C725 | |
| Person / Time | |
|---|---|
| Site: | Dow Chemical Company |
| Issue date: | 02/24/1997 |
| From: | Rigot W DOW CHEMICAL CO. |
| To: | Alexander Adams NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9703040234 | |
| Download: ML20135C725 (5) | |
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The Dow Chemical Company Mdiand. Mctogan 48667 February 24,1997 i
Mr. Alexander Adams, Jr., Senior Project Manager Non-Power Reactor and Decommissioning Project Directorate Division of Project Support Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Dear Mr. Adams Enclosed is the response to your request for additional information regarding our amendment request for Facility Operating License R-108; letter dated December 17, i
i 1996. The enclosure includes the changes proposed for amendment No. 7 ati an explanation for the question raised in your letter. If you have any questions regarding this review, please contact me at (517) 636-6584.
Regards k
Ward L. Rigot Reactor Supervisor Dow TRIGA Research Reactor The Dow Chemical Company
>l 9703040234 970224 PDR ADOCK 05000264 P
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j 040007 Onuue n>. n?aa CONNIE M. MARCH MARY PUBUC, MIDLAND COUNTY, WCHu WY COMMIS$10N EXPIRES DECEMBER 23,2000 l
- 1. Figure 6.1 has been modified to show the separation of the operations and safety arms of the reactor's administration. The license is held by the radiation safety committee (RSC) which is chaired by The manager of Industrial Hygiene Research and Technology. This person serves as a level 1 manager as described in ANSI /ANS 15.1-1990. In addition, Operations report to a Senior Research Manager within Analytical Sciences Laboratories. This person also is considered a Level 1 manager.
The person responsible for reactor facility operations is the Facility Director and the person responsible for day-to-lo day operation of the reactor is the reactor supervisor.
The role of Facility Director and Reactor Supervisor may be filled by the same person.
- 2. The Reactor Operations Committee reports to The Senior Research Manager within Analytical Sciences Laboratory. Members of the committee not required by the Technical Specifications (i.e. Radiation Safety Officer and Reactor Supervisor) are appointed by This Level 1 manager.
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- 3. The Radiation Safety Officer communicates with the Level 3 management ( Reactor Supervisor) and this reporting line has been added. The radiation safety function reports through The Manager, Industrial Hygiene Research and Technology, a level 1 manager.
- 4. Section 6.1.1. has been modified to show consistency with the change noted in 1.
Above. This change designates the Level 'l management representative as the member of the R.O.C.
- 5. Section 6.1.2. has been modified to acknowledge the fact the Reactor Supervisor and Facility Director may be the same person and that in this case the Level 1 management representative appoints the Reactor Supervisor and has line management responsibilities for this individual.
- 6. Section 6.2.1. has been modified to acknowledge the fact the Reactor Supervisor and Facility Director may be the same person and that in this case the Level 1 management representative will serve as the chairperson of the R.O.C.
- 6. ADMINISTRATIVE CONTROLS 6.1. Organization j
i The Dow TRIGA Research Reactor is owned and operated by The Dow Chemical Company.
The reactor is administered and operated through the Analytical Sciences Laboratory of the Michigan Division of Dow Chemical USA and is located in 1602 Building of the Analytical
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Sciences Laboratory at the Midland, Michigan location of the Michigan Division.
t 6.1.1.
Structure The structure of the administration of the reactor is shown in figure 6.1. This structure cuts across the lines of management of The Dow Chemical Company.
The individual responsible for radiation safety is the Radiation Safety Officer for i
l the reactor who reports on matters of radiation safety to the Radiation Safety Committee and to the Reactor Operations Committee. The review and audit i
j' functions are performed by the Reactor Operations Committee which is composed of at least four persons including a manager within Analytical Sciences Laboratory, l
the Radiation Safety Officer, and the Reactor Supervisor.
l 6.1.2.
Responsibility The day-to-day responsibility for the safe operation of the reactor rests with the t
Reactor Supervisor who is a licensed Senior Reactor Operator appointed by the Facility Director or manager within Analytical Sciences Laboratory. The Reactor l
Supervisor may appoint equally-qualified individuals, upon notification of the Facility Director and the Reactor Operations Committee, to assume the responsibilities of the Reactor Supervisor. The Reactor Supervisor reports ir. a l
management sense to the Facility Director and within the reactor organization to the l
Reactor Operations Committee.
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Anwndnwnt No. 7 l
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Figure 6.1. Administration f
l Manager, Industrial Hygiene Research and Radiation Safety Manager, Analytical Technology Committee Sciences Laboratory Chair R.O.C.
Chair, RSC IkA l
1 1r l
l pj Facility qy qyqy Director I
1r I
Reactor Operations Supervisor, l
Committee (ROC) qy Industrial l
1 Hygiene l
4 Jg l
l Reactor Supervisor l
l F--*
If I
I I
1r e---I I
l Licensed Radiation Safety q_ _ _ _ J l
Line management responsibilities Line Management Reporting 1
- - - - Communication Reporting f
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d Amendment No. 7
- 33
6.2. Review and Audit The review and audit functions shall be the responsibility of the Reactor Operations Committee (ROC).
6.2.1.
Charter and Rules
- a. This Committee shall consist of Facility Director, who shall be designated the chair of this committee; the Radiation Safety Officer; the Reactor Supervisor; and one or more
- persons who are competent in the field of reactor operations, radiation science, or reactor / radiation engmeeting. In the event that the positions of theReactor Supervisor and Facility Director are filled by the same person, a manger within Analytical Sciences Laboratory shall serve as the chair of the committee.
- b. A quorum shall consist of a majority of the members of the ROC. No more than.
one-half of the voting members present shall be members of the day-to-day reactor operating staff.
- c. The Committee shall meet quarterly and as often as required to transact business.
- d. Minutes of the meetings shall be kept as records for the facility,
- e. In cases where quick action is necessary members of the ROC may be polled by telephone for guidance and approvals,
- f. The ROC shall report at least twice per year to the Radiation Safety Committee.
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i Anwndment No. 7 35
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