ML20210D202
| ML20210D202 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 12/10/1986 |
| From: | Asmussen K GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER |
| To: | Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 27690, NUDOCS 8702100035 | |
| Download: ML20210D202 (10) | |
Text
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GA Technologies Inc.
DQcqIfQ PO. BOX 85608 SAN OtEGo. CAUFORNIA 92138 9 USl/#g gg (619; 455-3000
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Mr. William T. Crow, Acting Chief 6
{ u.s.NunEAR REcuurcay Uranium Fuel Licensing Branch Division of Fuel Cycle & Material Safety 00 2 W 1 Office of Nuclear Material Safety & Safeguards
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U.S. Nuclear Regulatory Commission h.
Washington, D.C. 20555 Ml'
Subject:
Docket 70-734 : SNM-696; Report of Change to Organization (7 copies)
Reference:
K. E. Asmussen (GA) letter 696-9047 to William T. Crow (NRC) dated September 25, 1986
Dear Mr. Crow:
Following the recent acquisition of GA Technologies Inc. (GA) by a privately held company owned by Messrs. Neal Blue end Linden Blue, there l
have been some management personnel and organizational changes.
The i
purpose of this letter is to advise you of those changes and to submit revisions to selected pages of our license which were affected by one of these changes.
The pages were revised pursuant to Section 3.1 of our license.
GA has been restructured into six major components reporting directly to Mr. Neal Blue as Chairman and Chief Executive Officer.
The six major components and their respective leaders are:
. Institute for Development and Application of Advanced Technologies.
Dr. Tihiro Ohkawa, Vice Chairman and Senior Vice President, will head the Institute, which will function as a generator of innovative technology initiatives and as a resource available to all company divisions in addressing the application of their respective technologies.
. Fusion Division.
Dr. David O.
Overskei, Senior Vice President, will be in charge of GA activities relating to nuclear fusion.
. Defense Division.
Dr. Thomas A. Dillon, Senior Vice President, will be responsible for all GA defense-related ef forts, except for the subsidiary defense production activities included within the Enterprises Division.
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,. Enterprises Division.
Mr. Reau Graves, Jr.,
Senior Vice President, will head the Enterprises Division, which is intended to give recognition and support for GA 's existing and future subsidiary business enterprises.
. Reactor Division.
Mr. Linden Blue, Vice Chairman, will. direct this division, whose major thrust will be the ultimate commercialization of the Modular ~HTGR (MHTGR) and allied programs.
. Administrative Division. Mr. Ed Jones, Senior Vice President, will be responsible for this division, which will include Contracts & Law, Services, and Finance.
The company will receiva direction from a Board of Directors as well as advice from a Board of Advisors.
All functions-responsible for assuring compliance with applicable license requirements remain unchanged and are,still a part of the Human Resources organization of GA.
The only change relevant to the compli-ance functions is that the director of Human Resources, who used to report to the president of GA, now reports directly to a member of GA's Board of Directors.
More specifically, Mr.
R.
Rademacher, director of Human Resources, now reports to Mr. R. Graves as a member of the Board of Directors.
Further, note that Mr. Graves is also the Senior Vice President responsible for the Enterprises Division.
With Human Resources reporting directly to a member of the Board of Directors who is also a Senior Vice President, ready access to, and support from, the highest levels of GA management remains assured for the compliance functions.
Accordingly, Figure II 3.1-1 of our license, " Radioactive Materials Management Organization Chart," has been revised to reflect the above described reporting relationship.
This is represented on Figure II 3.1-1 by a " double", or " partitioned," box representing Mr. Graves' dual positions as a member of the Board of Directors and as a Senior Vice President.
Finally, in the referenced letter, it was reported that Industrial Safety reports to " Licensing and Nuclear Compliance."
In order to be more descriptive of all of its responsibilities, Licensing and Nuclear Compliance is now known as " Licensing, Safety and Nuclear Compliance."
Accordingly, various pages of Section 3 have been revised (the change is identified by a ruled margin).
However, inasmuch as the change is in name only, and the change is somewhat subtle, no special effort will be made to revise all of our other various plans and documents simply for the purpose of changing this name.
Rather, the name will be changed when other substantive changes necessitate page revisions.
In the interim, " Licensing and Nuclear Compliance" and " Licensing, Safety and Nuclear Compliance" may be used to refer to one and the same function.
.. If you have any questions regarding the above, please contact me at (619) 455-2823.
Very truly yours, M [ bee _ee-Keith E. Asmussen, Manager Licensing, Safety and Nuclear Compliance KEA/mk Attachments: Revised pages II 3-2, II 3-6, II 3-10, II 3-11, II 3-14 and revised Figure II 3.1-1 all of SNM Specifications Volume cc:
Dr. Willard Brown, NRC Washington Mr. John B. Martin, Regional Administrator, NRC Region V l
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s 3.2.2 Compliance Functions All functions responsible for assuring compliance with applicable license 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, Safety and Nuclear Compliance, Nuclear Material Accountability, Statistics &
Measurement Control, Security, and Health Physics.
The Director of Human Resources, or his designee, 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 j
assure compliance with related policies, procedures, regulations and license conditions. ' The Director of Human Resources reports directly to a member of the Board of Directors 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 Licen sing. Safety and Nuclear Compliance (LSNC)
This function administers licenses and reviews and approves all Work Authorizations (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 the prep-aration and processing of applications, disseminates license 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, health physics, and industrial j
safety functions.
I i
l License No.
S NM-696 License Amendment No.
Page i
Revision No.
10 Date 12/86 Released By II 3-2
_ _ _ _ _. _, _ _ _. _ _ -, _ _ _ _. - _,.,.. _ _.. _. ~, _
3.3.2 Compliance Functions The Director of Human Resources is responsible for assuring compliance with applicable licensing requirements and controlling the radiological and nuclear safety ano 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, Safety and Nuclear Compliance shall have demon-strated his/her proficiency in activities relevant to the functions assigned, as defined in Paragraph 3.2.2.1.
Demonstration of this proficiency shall be based on the manager's qualifications which shall include an accredited four-year college degree in science, engineering or other related field, a minimum of two years applicable work experience and/or training in nuclear industry management, and a knowledge of nuclear safety and health physics.
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 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.
1 The Manager, Nuclear Safety shall have demonstrated his/her proficiency in activities of nuclear safety and outside reactor criticality safety, such i
as defined in paragraph 3.2.2.3.
Demonstration of this proficiency shall be based on the manager's qualifications which 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 4
and/or training plus two years of other nuclear safety experience and/or training.
License No.
S NM-696 License Amendment No.
Page Revision No.
10 Date 12/86 Released By II 3-6
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4 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-
_ uirements and instructions for obtaining Work Authorizations (WA) are to be q
maintained in current form in the Radiological Safety Guide. The basic pro-cedure for obtaining approval of a Work Authorization is described in section i
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, Safety and Nuclear Compliance, 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 l.
' 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.
j i-License No.
S NM-696 License Amendment No.
Page Revision No.
10 Date 12/86 Released By II 3-10
t 2.
The WA and appropriate safety related information shall be approved in writing by Health Physics, Nuclear Safety, Nuclear Material Ac-countab'ility, and Licensing, Safety and Nuclear Compliance.
In add-ition, the request shall be sent to (1) Security for approval if physical protection 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 or U-233, 200 gm of encapsulated plutonium, or any quantity of unencapsulated plutonium of any isotope.
If a license modification is required, Licensing, Safety and Nuclear Compliance shall make the determina-tion and take appropriate action with governmental regulatory authorities. Any reviewer shall seek outside expertise as deemed necessary.
i 3.
Af ter the WA has been approved in writing, authorization shall be deemed granted. Authorization shall include any special conditions j
required by the license and such other conditions as the reviewers deem necessary.
4 The originating department shall' revise, where appropriate, the t
operating procedures and practices before implementing requested j
work. The current version of Work Authorization and the approved I
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.
S NM-696 License Amendment No.
Page Revision No.
10 Date 12/86 Released By II 3-11 L
3.6.2 Audit s 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 comoliance with approved plans and proced-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 hnplement needed corrective action.
- 3. 7 OPERATING POLICIES AND PROCEDURES 3.7.1 General Policies applicable to work with materials subject to this license shall 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, Safety and 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 proce-dures providing such procedures are within approved policies and criteria.
3.7.2 Activities Requiring Procedures Procedures are required for all activities in which materials subject to this license are physically handled, stored and chemically or physically changed.
- These shall be conducted according 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.
License No.
S NM-696 License Amendment No.
Page Revision No.
10 Date 12/86 Released By II 3-14
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