ML20202G858
| ML20202G858 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 05/23/1986 |
| From: | Asmussen K GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER |
| To: | Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 27015, 696-9009, NUDOCS 8607160128 | |
| Download: ML20202G858 (22) | |
Text
/6-73(/
h TG 396-SS
~
FM GATechnologies In Reply
~
G A Technologies Inc.
Po BOX 85608 SAN DiEGO. CAufoRNIA 92138 23 May 1986 g
(619) 455-3000 j
EECL s, g-80CKUED p\\
5 D 29 F @ El 8N>
Mr. William T. Crow, Acting Chief Uranium Fuel Licensing Branch huth 7
Division of Fuel Cycle & Material Safety
' DocxDCLtax
~
S -
U.S. Nuclear Regulatory Commission g,-
j-Washingtcn, DC 20555
-n>
Subject:
Docket 70-734: SNM-696; Report of Changes to Organization.
(7 copies)
Dear Mr. Crow:
Recent retirements of certain GA Technologies Inc. (GA) personnel have lead to some changes to our organizational structure.
These changes have been discussed at length with NRC staff, Region V and Headquarters.
In particular they address the retirements of F. Bold (Health Physics &
Safety Services), R. Wolf (Corporate Secretary), and M. Merrill (Nuclear Sa fety).
With the retirement of F. Bold, Emergency Services now reports to the Manager of Security, and Health Physics reports to the Manager of Lic-ensing and Nuclear Compliance. 'Ihe Health Physics function will continue to be managed by L. Quintana.
Those compliance functions that had. reported to the corporation's secre-tary now report to the Director of Human Resources through Licensing and Nuclear Compliance. Licensing and Nuclear Compliance includes those func-tions that had previously comprised " Licensing and Nuclear Material Con-trol" plus Nuclear Safety and Health Physics.
These changes obviate the " dotted line" reporting relationship that had existed between Security (and Health Physics) and the corporation's sec-retary. All functions responsible for compliance are now consolidated under one pyson, namely, the Director of Human Resources who, as before, reports directly to the corporation's president.
Succeeding M. Herrill as Manager of Nuclear Safety is Vladislav Malakhof.
Mr. Malakhor's qualifications for this position have been the subject of telephone discussions with Mr. N. Ketzlach (NRC Headquarters) and Mr.
Malakhof was interviewed in person by Messrs. Ketzlach and Brock (NRC Reg. V) during the period March 31 through April 2, 1986, when Messrs.
Ketzlach and Brock visited GA's
'a_ cili ties. A copy of Mr. Malakhor's resume is attached.
(maanu Fce Cakcho;ry".Appli a c uce w,..
86071
{
oh34
'. N[j[,!
PDR PDR s j; e c Fr.a.. Ag A,
CCe Check fic 'd... Jffi [, ', ',',
C 10955 JOHN JAY HoPKINS CR AN F 30
[lkdR'NIA 9 i
Q*g
[
l
W. T. Crow 696-9009 As a result of the above, and pursuant to Section 3.1 of our license, selected pages of Section 3 have been revised.
In making the revisions, the pagination changed. 'Iherefore, for your convenience, we have en-c?osed Section 3 in its entirety with changes identified by a ruled margin.
Under separate cover, we are also submitting to NRC revised pages to various of our plans which support our license.
If you have any questions regarding the above, please contact me at (619)
-455-2823 Very truly yours, Keith E. Asmussen Manager, Licensing &
Nuclear Compliance KEA:he Attachments:
- 1. V. Malakhof's resume.
- 2. Section 3, SNM-696 Specifications Volume.1.
cc: John B. Martin, Regional Administrator, Reg. V, NRC.
~,
--y
Mr. Vladislav Malakhof, Manager, Nuclear Safety BS Mechanical Engineering, University of Missouri,1962 MS Nuclear Engineering, University of California, 1964 Registered Professional Engineer (Nuclear), California Mr. Malakhof joined GA Technologies Inc. (GA) in 1963 and has worked for 23 years in the field of reactor physics and criticality safety evaluations.
His primary area of experience is in the core physics analysis of HTGRs.
The activities in this area were: (a) spectrum calculations and preparation of microscopic cross-sections, (b) fuel zoning and depletion calculations.
(c) design of control rod, reserve shutdown system and lumped burnable poison, (d) reactor kinetics and accident analysis, (e) design of external neutron sources, (f) the fuel accountability for the FSV core, (g) the correlation of measured and calculated results, (h) the design of reload segments for the FSV core, and (1) the writing of safety analysis reports (SAR).
He also was in-volved in the correlation of measured and calculated results for the Peach Bottom and Ft. St. Vrain HTGR's. For the latter reactor he participated in the inside loading and zero-power te : ting. Since 1976 he has been a member of the Material Review Board which brought him into close contact with fuel manu-facturing problems and their solutions, and familiarized him with procedures and processes involved in fuel production. As the project manager of Fuel Test Element Post Irradiation Examination he became familiar with the criti-cality and radiological safety in the Hot Cell.
His secondary area of experience is in criticality safety analysis. The activities in this area were: (a) the safety analysis of HTGR fuel particles, rods or elements during manufacturing, (b) the safety analysis of fresh and spent fuel shipping casks, and (c) the safety analysis of fuel transfer machine and storage wells.
He is the co-author (with Dr. Baxter) of the Nuclear Criticality Safety Guide for specific application to HTGR fuel. He also has been since 1977.a member of GA's Criticality and Radiation Safety Committee, where.his duties were to
~ -. -.. =.
k carry out the secondary independent review of cEiticality safety at GA.
As a i
coaunittee member he conducted review and audits not only of fuel fabrication areas but also other SNM containing areas.
J 1
4 1
J J
A i
N.
4 4
e 8
4 4
l
~
3 ORGANIZATION AND ADMINISTRATIVE PROCEDURES 3.1 GENERAL s
This section describes the organizations, positions, and administrative procedures utilized to control the use of special nuclear material (see Fig.
II 3.1-1).
The licensee may change organizational responsibilities, reporting loca-tions and names providing such changes do not adversely affect the implementa-tion of license conditions and are reported to the NRC within 60 days after the change has been made.
3.2 RESPONSIBLE ORGANIZATIONS 3.2.1 Operating Groups All operating groups are required by company policy to conduct their respective activities within federal, state, and local rules and regulations, license criteria, and company policy, criteria and established practices.
Such policy requires operating groups to conduct their operations so that radiation exposures to employees and the general public are as low as reasonably achievable.
The responsibility for safe operation and control of activities in a specific SNM or restricted area and for the safety of the environs as in-fluenced by the activities conducted therein shall be vested in the manager of each facility or his or her designee. The manager or designee shall ensure that the conduct of activities within the area is in compliance with all ap-plicable criteria, rules and practices as set forth in Work Authorizations issued under this license implementing the Commission's regulations.
By con-tinuous supervision, the manager can take any corrective action necessary to assure license compliance.
License No.
S NM-696 License Amendment No.
Page Revision No.
8 Date S/86 Released By II 3-1
3.2.2 Compliance Functions All functions responsible for assuring compliance with applicable license l
requirements and controlling the radiological and nuclear safety and safe-guards of licensed material are part of the Human Resources organization of GA Technologies Inc.
Namely, these functions are:
Nuclear Safety, Licensing and Nuclear Compliance, Nuclear Material Accountability, Statistics & Measurement Control, Security, and Health Physics.
The Director of Human Resources, or his designee, will establish the k
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 Director of Human Resources reports directly to the president of GA Technologies Inc. (see Figure II 3.1-1).
The compliance functions are described below and are headed by managers or supervisors which are synonymous titles for signifying the responsible person.
3.2.2.1 Licensing and Nuclear Compliance (LNC)
This function administers licenses and reviews and approves all Work Authorizatio7s (WA) involving SNM for compliance to applicable regulation and license conditions. This function provides interpretation of licenses and regulations, determines the need for licensing actions, coordinates tha prep-aration and processing of applications, disseminates licerse requirements to operating organizations, and maintains or oversees maintenance of master lic-ense records to permit independent review by NRC or GA audit functions.
In addition, this function supervises and is responsible for the overall plan-ning, coordination, and administration of the special nuclear material meas-urement control and accounting, nuclear safety, and health physics functions.
I License No.
SNM-696 License Amendment No.
Page Revision No.
8 Date 5/86 Released By II 3-2
3.2.2.2 {c en Physics I
This function assures compliance with Title 10 Code sof Federal Regula-tions, Parts 19 and 20 and license-imposed radiological safety requirements.
This function provides a review and approval function for radiological safety of proposed activities involving SNM, an ongoing monitoring of SNM activities, and provides services such as personnel monitoring, dose rate measurement, ra-dioactive material detection and assay, air and water sampling and environmen-tal monitoring.
Health Physics maintains a manual entitled " Radiological Safety Guide," implementing the procedural requirements for radiological safety and approves the content of training programs in radiological safety.
I The major responsibilities of the Health Physics Technicians are to conduct routine, special and emergency radiological surveys on all operations, equipment, facilities and personnel in any controlled area and to provide advisory and monitoring services in radiological and nuclear safety.
3.2.2.3 Nuclear Safety l
This function assures nuclear criticality safety.
This function pro-vides review and approval, for nuclear safety purposes, of proposed SNM activities, reviews proposed changes in processes, equipment, and procedures, and performs frequent inspection and monitoring to assure adequate implemen-tation of nuclear safety controls. This function approves for adequacy all determinations of criticality limits and provides and/or obtains independent verification thereof as well as approves the content of training programs in nuclear criticality safety.
3.2.2.4 Nuclear Materials Accountability (NMA)
This function assures compliance with SNM custody and control regula-rules and practices. This function implements the program for accountability, custody and control of special nuclear material.
NMA maintains a manual of SNM accounting control procedures.
NMA assures compliance with safeguards material control and accountability regulations and license conditions.
License No.
SNM-696 License Amendment No.
Page Revision No.
8 Date 5/86 Released By II 3-3
3.2.2.5 statistics & Measurement control (SMC)
This function is responsible for implementing the measurement contrt; program as it relates to SNM control and accountability.
This function as-sures SNM measurement quality by monitoring and evaluating applicable infor-mation, practices and procedures.
This function is also responsible for maintaining a SNM Measurements & Statistical Control Manual setting forth the procedures for implementation of measurements, measurement control and sta-tistical control requirements, and implements the program for furnishing measurement and statistical information for inventories, receipts, and shi pments.
3.2.2.6 Security This function provides security measures to prevent unauthorized access to special nuclear material and to provide appropriate industrial security.
The security function is responsible for assuring compliance with Security regulations and license conditions.
This includes maintaining a force of guards who carry out the required guard orders established by the Manager of Security or his designee.
The security functions include the following:
(1) maintenance of a Security Office, (2) responsibility for the physical protec-tion of controlled areas, protected areas, vital areas, and material access areas, as required, (3) provision for monitoring the fire and intrusion alarms and related communication systems, (4) implementation of security inspection procedures, and (5) assuring adequate physical protection of classified in-formation.
License No.
SNM-696 License Amendment No.
Page Revision No.
8 Date 5/86 Released By II 3-4
i 3.2.3 Criticality and Radiation Safety Committee (CRSC) -
The CRSC reports to the office of the President via a designated vice-president. Committee members who have diverse expertise and qualifications prescribed in Section 3.3.3, are appointed by the company's Executive Com-mittee. A written policy statement establishes committee and member respon-sibilities. As a minimum, the committee:
(1) acts in a radiological safety advisory capacity; (2) reviews policies and criteria established for safety of SNM operations; (3) provides second level of review for nuclear safety analy-sis; and (4) audits work involving radioactive materials for conformance to and effectiveness of applicable procedures and practices including a review to determine how exposures might be reduced to meet ALARA.
All results of CRSC meetings will be documented.
3.3 POSITION QUALIFICATIONSe & TRAINING 3.3.1 Facility Managers A Facility Manager shall have demonstrated his/her proficiency in activ-ities relevant to the functions assigned, as defined in paragraph 3.2.1.
Dem-onstration of this proficiency shall be based on the manager's qualifications which shall include an accredited four-year college degree, a minimum of_ two years applicable. work experience and/or training in nuclear activities, and knowledge of the licensee's radiation protection program.
'A two-year degree plus five years of directly applicable experience or a high school diploma (or equivalent) plus 10 years of directly applicable experience may be considered equivalent to an accredited four-year college degree and appropriate work experience, subject to a determination by the Secretary and the Director of Human Resources that proficiency has been demonstrated. A master's or doctor's degree in science or engineering from an accredited col-lege is considered equivalent to two years of applicable experience.
License No.
S NM-696 License Amendment.No.
Page Revision No.
8 Date 5/86 Released By II 3-5 t
3.3.2 Como11ance Functions The Director of Human Resources is responsible for assuring compliance l
with applicable licensing requirements and controlling the radiological and nuclear safety and safeguards of licensed material,' as generally defined in Paragraph 3.2.2.
Incumbents must have a minimum of five years of nuclear industry management experience of a high level general management nature.
The Manager, Licensing and Nuclear Compliance shall have demonstrated I
his/her proficiency in activities relevant to the functions assigned, as defined in Paragraph 3.2.2.1.
Demonstration of this proficiency shall be l
based on the manager's qualifications which shall include an accredited four-year college degree in a relevant field and a minimum of two years applicable work experience and/or training in nuclear facility activities.
The Manager of Health Physics shall have demonstrated his/her proficiency in nuclear health physics activities, and the evaluation of potential radio-logical hazards, such as defined in paragraph 3.2.2.2.
Demonstration of this l
proficiency shall.be based on the manager's qualifications which shall include an accredited four-year college degree in the physical sciences, biological sciences, or other related field and a minimum of two years experience in phases of nuclear health physics relating to GA licensed activities and the evaluation of potential radiological hazards therefrom, or equivalent work experience or training.
The Manager, Nuclear Safety shall have demonstrated his/her proficiency in activities of nuclear safety and outside reactor criticality safety, such as defined in paragraph 3.2.2.3.
Demonstration of this proficiency shall be I
based on the manager's qualifications waich shall include an accredited four-year college degree in science, engineering or other related field and a min-imum of two years experience and/or training in nuclear safety activities re-lated to nuclear fuel fabrication operations, or one year of such experience and/or training plus two years of other nuclear safety experience and/or training.
License No.
SNM-696 License Amendment No.
Page Revision No.
8 Date S/86 Released By II 3-6 J
t The Manager, Nuclear Materials Accountability shall have demonstrated his/her proficiency in activities relevant to the functions assigned, as de-fined in Paragraph 3.2.2.4 Demonstration of this proficiency shall be based on the manager's qualifications which shall include an accredited four-year college degree in a relevant field and a minimum of two years applicable work experience and/or training in nuclear material accountability and control activities.
The Manager, Statistics and Measurement Control shall have demonstrated his/her proficiency in activities relevant to the functions assigned, as defined in paragraph 3.2.2.5.
Demonstration of this proficiency shall be based on the manager's qualifications wiich shall include an accredited four-year college degree in science, engineering or other related field and a minimum of two years applicable work experience and/or training in quality assurance / control, statistics, nuclear measurements, or related activities.
I The Manager, Security, shall have demonstrated his/her proficiency in activities relevant to the functions assigned, as defined in paragraph 3.2.2.6.
Demonstration of this proficiency shall be based on the manager's qualifications which shall include an accredited four-year degree and a minimum of two years applicable work experience and/or training in managing or implementing security programs in the nuclear industry.
A Health Physics Technician shall have demonstrated his/her proficiency in activities relevant to the functions assigned, as described in Section i
3.2.2.2.
Demonstration of this proficiency shall be based on the technician's l
qualifications which shall include a high school diploma or equivalent, and a I
minimum of two years applicable work experience and/or training related to nuclear activities, including at least three (3) weeks of specific on the job training.
License No.
S NM-696 License Amendment No.
Page Revision No.
8 Date 5/86 Released By II 3-7
-- -~-
y
~ - - - - - -
w eg n
~
-+m
- w
3.3.3 CRSC Members of the committee shall have expertise in their special fields.
Such expertise shall, as a minimum for technical members, require an accredi-ted college degree or equivalent training in a field appropriate to their specialties and a minimum of two years related experience.
For nontechnical members, a minimum of three years experience in an appropriate field is re-quired.
The fields of specialty shall include as a minimum, disciplines from nuc-lear physics, reactor physics, health physics, chemistry and statistics. A member may represent more than one field of specialty.
3.3.4 Indecendent Nuclear Safety Reviewers Employees performing independent nuclear safety analysis and review shall have similar qualifications to those specified in Section 3.3.2 for the Mana-ger, Nuclear Safety. Each of the parties may have their relevant experience in a different specific phase, but this will allow broader expertise to be utilized.
In each case individuals shall have their qualifications reviewed and approved by the Manager of the reviewing organization, Nuclear Safety or the Chairman, CRSC.
3.3.5 Training Authorized Users - Employees who handle SNM other than under the direct supervision of another trained individual, must have satisfactorily completed the Radiological Safety Course which includes the following topics: ALARA practices, an introduction to 10 CFR 19 and 10 CFR 20, radiological instrumen-tation and controls, decontamination procedures, fire protection and emergency procedures. General subjects such as the nature and sources of radiation, License No. SNM-696 License imendment No.
Page Revision No.
8 Date 6/86 Released By II 3-8
units, methods. of controlling contamination, interactions of radiation and matter, biological effects of radiation, use of monitoring equipment, prin-ciples of nuclear criticality safety and risks from occupational radiation exposure are also covered.
The course is presented by lectures and demon-strations including the use of selected audiovisual aids.
The understanding of the employees and the effectiveness of the training course are evaluated with an examination given at the end of the course. Em-ployees are required to pass the written examination with a grade of 70 per-cent before being allowed to handle radioactive material without direct super-vision. The exam includes radiological practices and nuclear safety princi-ples.
The Manager, Health Physics, or other qualified designee is responsible for the radiological safety training course content.
Retraining - Retraining on selected subjects will be done annually.
Sub-jects will include both radiological and nuclear safety controls.
The under-standing of the employees and the program's effectiveness will be evaluated with an examination which must be satisfactorily completed with a score of 70 percent. Records of the training will be kept which will include the date held, subject matter covered, attendees, instruction and test results.
The Manager, Health ~ Physics or other qualified designee is responsible for this training.
Health Physics Technician Training - All Health Physics Technicians shall successfully complete the Radiological Safety Course described above and re-ceive on-the-job training.
Additional Nuclear Safety Training shall be given to enable them to do nuclear safety monitoring on a " continuous basis" in areas where more than 500 grams of U-235 is handled.
Training will include topics such as characteristics of criticality, principles of nuclear safety, specific SNM station limits and justifying criteria and details of postulated criticality accidents.
Records of training include the date held, subject matter covered, at-
% - - tendees, instructor and test results.
Such-records will be kept for two years or longer if so required by Part 19 or 20.
License No.
SNM-696 License Amendment No.
Page Revision No.
8 Date 5/86 Released By II 3-9
3.4 WORK AUTHORIZATIONS Any operating group desiring to initiate new work or to make changes in previously approved work involving special nuclear material subject to this license may do so only upon receipt of proper authorization.
Procedural re-quirements and' instructions for obtaining Work Authorizations (WA) are to be maintained in current form in the Radiological Safety Guide. The basic. pro-cedure fcr obtaining approval of a Work Authorization is described in section 3.4.1 and is shown schematically in Figure II 3.4.1.
Changes to this proced-ure require review and approval by the Manager of Licensing & Nuclear Com-pliance, the Director of Human Resources, and the Chairman of CRSC, or their designees.
All such changes must be within limitations of this license.
The criteria for WA approval are contained in Section 3.4.2.
3.4.1 Procedure for Approval of Work Authorizations 1.
The operating group desiring to do the work shall prepare a Work Au-thorization (WA) request identifying the proposed work and quantity and form of SNM to be used as well as drafts of the necessary safety related procedures, equipment features, and process characteristics.
The WA shall be approved in writing by the applicable manager who must assert that all license and company criteria and procedures for radiological safety, criticality, material accountability and con-trol, and physical protection requirements will be met.
Also, he must assert that other applicable safety related features of the work, such as structural integrity, potential of fire or explosion and the like, are adequately considered and suitable provisions have been incorporated.
The approved WA and backup information shall then be forwarded to Health Physics.
i License No.
SNM-696 License Amendment No.
Page Revision No.
8 Date 5/86 Released By II 3-10
2.
The WA and appropriate safety related information shall be approved in writing by Health Physics, Nuclear Safety, Nuclear Material Ac-countability, and Licensing & Nuclear Compliance.
In addition, the request shall be sent to (1) Security for approval if physical pro-tection requirements for the area are to be modified, and (2) CRSC for approval if the WA is for new or changed work involving new or revised nuclear safety analysis and involves a quantity of SNM greater than 350 gm of U-235, 200 gm of U-233, 200 gm of encapsu-lated plutonium, or any quantity of unencapsulated plutonium of any isotope.
If a license modification is required, Licensing & Nuclear Compliance shall make the determination and take appropriate action I
with governmental regulatory authorities. Any reviewer shall seek outside expertise as deemed necessary.
3 After the WA has been approved in writing, authorization shall be deemed granted.
Authorization shall include any special conditions required by the license and such other conditions as the reviewers deem necessary.
4 The originating department shall revise, where appropriate, the operating procedures and practices before implementing requested work. The current version of Work Authorization and the approved procedures will be available in or near the applicable work area.
5.
All SNM Work Authorizations will be re-reviewed and approvals updated at least every three years.
6.
Work Authorization records including supporting criticality analysis shall be retained for at least six months following the expiration date of the authorization.
License No.
SNM-696 License Amendment No.
Page Revision No.
8 Date 5/86 Released By II 3-11
3.4.2 CRITERIA FOR WA APPROVAL Evaluation of each request fbr WA approval shall include but not be limited to the following determinations by the manager, or designee, of the respective responsible compliance functions:
1.
That the proposed work is within currently authorized license limits.
2.
That radiological safety is properly assured. This includes a review of operational methods to attain "as low as reasonably achievable" radiation exposures.
3.
That criticality safety has been reviewed and adequate provisions are incorporated.
4 That new or revised nuclear safety analysis has been separately verified by two independent parties.
Analysis of solid angles of interaction require verification by a single independent' party.
5.
That proper SNM accountability control is. provided.
6.
That proper material protection for SNM is provided and that ap-plicable limits and regulations are observed.
7.
That an assessment of the effluents has been performed and proper i
provisions for control exist.
8.
That industrial safety practices and procedures are considered as they relate to radiological and nuclear safety.
l l
License No.
SNM-696 License Amendment No.
Page Revision No.
8 Date 5/86 Released By II 3-12
3.5 RADIOLOGICAL WORK PERMIT The Radiological Work Permit (RWP) is intended primarily for authori-zation of temporarily assigned GA employees who are not on a Work Authori-zation, or outside contractors or subcontractor personnel who will perform 4
limited or routine work in a Controlled Area, but whose exposure to possible radiation or contamination is incidental to their function.
3.6 INTERNAL INSPECTION AND AUDIT 3.6.1 Inspections and Reviews Inspections and reviews of activities involving materials subject to this license are performed by Health Physics, Nuclear Safety, Nuclear Material l
4 Accountability, and Security. A Health Physics quarterly inspection
- of the i
SNM activities subject to this license shall be made by the Manager. Health Physics or qualified designee.
The Manager, Nuclear Safety, or his designee performs criticality inspections
- of all areas possessing SNM as follows: at least once annually for all areas and at least quarterly for areas possessing more than 500 g of fissile SNM. The NHA inspections and reviews are conducted in accordance with requirements of the license Safeguards Amendment SG-1 and the approved FNMC Pl'n.
Security conducts tests and inspections as required l
by the license Safeguards Amendment SG-1 and approved security plans. Find-ings as a result of inspections shall be reported in writing to the facility manager, the Directors of the operating division, the Director of Human Resources, and the Chairman of CRSC. The Director of Human Resources or his designee shall follow up and assure that necessary corrective actions are 4
taken.
'These shall be conducted according to a written plan which will include, but not limited to, the scope of identified discrepancies, unusual events, corree-tive actions, review of operations involving any substantially new activity.
a l
License No.
SNM-696 License Amendment No.
Page Revision No.
8 Date 5/86 Released By -
II 3-13 i
t 3.6.2 Audits Audits
- are performed by the CRSC at least once each calendar year with no interval over 15 months for areas containing more than 500 gm of SNM to verify that work is being done in compliance with approved plans and proced-i ures.
Such audits are reported in writing to the responsible management, the audited organization, and the Director of Human Resources. Copies of the audit reports will be forwarded to the.affected Vice Presidents. The Director of Human Resources or his designee shall follow up problem areas and implement needed corrective action.
3.7 OPERATING POLICIES AND PROCEDURES 3.7.1 General Policies applicable to work with materials subject to this license shall j
be approved by the Director of Human Resources, or his designee, and as applicable, receive prior review by CRSC.
Design criteria applicable to work with materials subject to this license shall be approved by the Manager, Licensing & Nuclear Compliance, and the Manager, Nuclear Safety, or their designees, and as applicable receive prior review by CRSC. Any operating department may have additional and more stringent criteria or procedures providing such procedures are within approved policies and criteria.
3.7.2 Activities Reauiring Procedures Procedures are required for all activities in which materials subject to l
this license are physically handled, stored and chemically or physically chan ged.
i I
'These shall be conducted acccrding to a written plan which will include, but not limited to, the scope of identified discrepancies, unusual events, correc-tive actions, review of operations involving any substantially new activity.
1 License No.
SNM-696 License Amendment No.
Page Revision No.
8 Date 5/86 Released By II 3-14
3.7.3 Unusual Events Any unusual event which significantly threatens or lessens the effective-ness of radiological or health safety provisions of the license will be in-vestigated and reported to the Director of Human Resources, and the applicable vice presidents. The Director of Human Resources is responsible for conduct-ing an investigation and documenting the corrective action or reports result-ing therefrom. NRC shall be notified in accordance with requirements of 10 CFR 19, 20, 21, 70 or 73 License No.
SNM-696 License Amendment No.
Page Revision No.
8 Date 5/86 Released By II 3-15
PRESIDENT VIA COGNIZANT VICE PRESIDENT I
f STANDING DIRECTOR OTHER COMMITTEES" llUMAN RESOURCES VlCE PRESIDENTS I
OillER l
l OPERATING DIVISIONS LICENSINO AND SECURIIY NUCLE AR COMPtlANCE I
I I
I I
I I
I NUJtEAR SIAilSilCS AND NUCLEAR HEALTH SECURiiY EMERGENCY INDUSTRIAL "N
SAFETY PHYSICS OfflCERS SE RVICES SAFETY ACC NT AbillIY RL I
l I
i l
I I
SIDHAGE l
l SmmnG1 l
g g
i RECilVING g
i I
l l
AND ONSiit l
IllAN5P0lli l
l l
l l
1 I
i 1
m:I..;
i i
i i
....,. i.;..........g..
g
. 6........bM!.v!.,....
- lNCLUDES:
CRiflCALITY AND RADIATION SAFETY COMMITTEE SAFEGUARDS MANAGEMENT REVIEW COMMITTEE SECURITY MANAGEMENT AUOli COMMiliEE TRIGA CRITICAllIY SAF ETY COMMITTEE REVISED APRIL 1986 Fig. il 3.1-1. Radioactive Materials Management Organization Chart
f b
lI HEALTH PHYSICS '
ORIGINATING DEPT ORIGINATING DEPARTMENT COMPLIANCE FUNCT10NS,
ISSUES WO RK MODIFIES PREPARES AND 00TAINS AUTHORIZATIONS PROCEDURES DEPARTMENT MANAGEMENT %
REVIEW AND APPROVE FORR WITH SPECIAL 4
IF NECESSARY APPROVAL Full SPECIFIC
- 1. RADIOLOGICAL SAFETY CONDITIONS' IMPLEMENTWO$K WORK AUTitulilZATION 2.- NUCLEAR SAFETY IF,ANY AUTH0HlZAT10N 3.SNM ACCOUNTABILITY 1
- 4. PHYSICAL PROTECTION s
- 5. LICENSING CONSIDERATIONS
'6. EF[LUENTS;
.L_
[
i
?
l i
i q
1 1
6 t
l l
s h (
r a t,
2 6
l 5
4 i
.o o
ffCRSCl GOVERNMENT
.[
f CR TICAL TY' REVIEW &
T LICENSE.
REVIEW &
APPROVE MODIFICATION APPROVE
.g FIG.Il3.41 PROCEDURE FOR AUTHORIZING WORK 4
4 f
1
['
DOCKET NO.
/
CONTROL hV
[ M[hd DATE OF DOC.
DATE RCVD..[ 87 FLTF PDR FCAF LPDR WM I&E REF.
V WMUR SAFECUARDS FCTC OTHER DESCRIPTION:
/
/
/
/.
6<7M/8l, wiria SW t
1 1
,