ML20137C978

Safety Evaluation Supporting Amend 3 to License SNM-696 Re Changes in Organizational Functions Responsible for Radiological & Nuclear Safety & Safeguards

ML20137C978
Person / Time
Site:	07000734
Issue date:	01/08/1986
From:	Crow W, Ketzlach N NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20137C956	List: ML20137C952 ML20137C978 ML20137C984
References
NUDOCS 8601160467
Download: ML20137C978 (3)

Text

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JAN 8 1986 FCUP:NK DOCKET N0: 70-734 APPLICANT: GA Technologies, Inc.

FACILITY: San Diego, California

SUBJECT:

REVIEW OF LICENSE AMENDMENT APPLICATION DATED DECEMBER 5, 1985

Background

GA Technologies, Inc (GA), by application dated December 5, 1985, requested authorization to change its organizational structure as follows:

1. Separate the Qualit Assurance and Compliance Functions (formerly both in same Division of GA .

2. Transfer the Security, Health Physics, and Industrial Safety functions to Human Resources under its Director who reports to the Vice President, Finance and Administration [to whom the Director of the former Quality Assurance and Compliance Division (QACD) reported].

3. Transfer the Nuclear Safety, SNM Measurement Control, Nuclear Material Accountability, and Licensing Administration functions to the Secretary of GA. The latter reports directly to the President.

4. Health Physics and Safety Services, while reporting to the Director, Human Resources, in their daily (more routine) activities, have reportin~g responsibilities to the Secretary for matters regarding the establishment and implementation of company policies and procedures to ensure conformance with governmental requirements as stipulated in regulations, permits, and licenses which involve Health Physics and Security.

Discussion A. Nuclear Safety

. The Manager, Nuclear Safety, has the same responsibilities as those specified previously. However, the minimum qualifications for.the position have been expanded and clarified. They include the following:

(1) Accredited 4-year college degree in' science, engineering, or other i,

related field..

(2). Two years experience and/or training in nuclear safety activities related to nuclear fuel fabrication operations, or 1 year of such experience and/or training plus 2 years of other nuclear safety experience and/or training. -

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GA Technologies, Inc. 2 (3) Demonstrated proficiency in activities of nuclear safety and outside of reactor criticality safety involving SNM activities similar to those at GA.

Although the Health Physics Technicians in the Health Physics and Safety Services Section of the Human Resources Department are not part of the organization to which the Manager, Nuclear Safety reports, they continue to provide monitoring services in nuclear safety for the Manager, Nuclear Safety.

It is reasonable to assume the services will be performed adequately since the Manager, Nuclear Safety, reports directly to the Office of the Secretary which is one position level above that of the Director, Human Resources, to whom the Manager, Health Physics and Safety Services, reports. The training and minimum qualifications for the technicians remain unchanged. The independent review requirements for the nuclear safety analyses made by the Manager remain the same. The reviewer must meet the minimum qualifications of the Manager, Nuclear Safety as before. The Criticality and Radiation Safety Committee (CRSC), used to report to the Director, Quality Assurance and Compliance Division. They will report to the Office of the President via a designated vice president. The members are appointed by the Company's Executive Committee. The minimum qualifications of the technical members of the CRSC remain the same. The minimum experience "in an appropriate field" for the non-technical members of the Committee has been reduced from 5 to 3 years.

This should be adequate.

Based on the above, the staff has concluded the nuclear criticality safety controls under the new organization at GA are adequate.

B. Radiation Safety The functions in Health Physics remain the same under the new organization.

The reporting chain for daily operations is now to the Director, Human Resources instead of the Director QACD. In matters of company policies and procedures the Manager, Health Physics and Safety Services reports to the Office of the Secretary (see Section A. above under " Discussion"). The minimum qualifications of both the Manager and Health Physics Technicians remain the same. Therefore, the staff has concluded the Health Physics Program under the new organization is adequate.

C. Licensing and Nuclear Material Control The licensing functions of the Manager, Licensing and Nuclear Material Control, remain the same as those of the former Manager, Licensing. His minimum qualifications are as follows:

(1) Four year college degree in a relevant field (2) Two years applicable work experience and/or training in nuclear facility activities  :

The staff has concluded the above are adequate qualifications for the Manager, Licensing and Nuclear Material Control to perform the GA licensing activities.

The Division of Safeguards has determined the GA organization for the control and physical security of nuclear materials is adequate. Therefore, that part of the organization responsible for licensing and nuclear material control is I adequate.

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GA Technologies, Inc. 3 D. Management of Safety Oroanization The corporation's Secretary and the Director of Human Resources will establish the necessary policies of operation, cause them to be published in company wide guides and manuals, and coordinate related activities with operating groups to assure compliance with related policies, procedures, regulations, and license conditions. The Health Physics and Safety Services is the only safety-related group reporting to the Director, Human Resources. All others report to the Secretary. However, matters regarding the establishment and the implementa-tion of company policies and procedures to ensure confomance with governmental requirements as stipulated in. regulations, permits, and licenses involving Health Physics are subject to coordination with, and review and approval by tha Secretary.

Both the Secretary and the Director, Human Resources, have a minimum of 5 years of " nuclear industry management experience of a high level general management nature." This should be adequate for identifying when technical staff advice is necessary for making appropriate decisions on matters related to safety.

E. Environmental Protection There is no requested change to the environmental protection requirements of the facility. The requested changes are administrative and organizational. -In accordance with 10 CFR 51.22(c)(11), neither an Environmental Assessment nor an Environmental Impact Statement is necessary for this proposed action.

General The application dated December 5, 1985, was discussed with Mr. R. D. Thomas, Region V, Chief, Nuclear Materials Safety Section, on December 31,:1985. He foresaw no safety or environmental problem with the requested authorization.

Drietnalsten:ct F. Xet:51ach Norman Ketzlach . .

Uranium Process Licensing Section.

Uranium Fuel Licensing Branch Division of Fuel Cycle and

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Material Safety, NMSS' -

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