ML20210H749
| ML20210H749 | |
| Person / Time | |
|---|---|
| Site: | 07000036 |
| Issue date: | 08/08/1997 |
| From: | Sharkey R ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY, ASEA BROWN BOVERI, INC. |
| To: | Weber M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| TAC-L30991, NUDOCS 9708140176 | |
| Download: ML20210H749 (25) | |
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- August 8,1997
& 9*S Docket No. 70 36 License No. SNM 33 Mr. Michael F. Weber, Chief Licensing 11 ranch Division of Fuel Cycle Safety and Safeguards U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001
Subject:
IIEMATlTE ORGANIZATIONAL AMENDMENT REQUEST
Dear Mr. Weber:
Enclosed are revised pages to Part I, Chapters I through 6, of the IIematite SNM 33 license appliemion, Changes have been made to reflect the management structure which consolidates the Focused Factory and Production Support Managers into the Director of Uranium Operations, and adds responsibilities to the Directory of Regulatory Affairs.
Also enclosed are a description of significant changes and a listing of revised pages. Six copies of this document are provided for your use.
if you have any questions on these changes, please call me or Mr. Hal Eskridge of my stafTat (314) 937-4691.
Sincerely yours, COMllUSTION ENGINEERING,INC.
Robert W. Sharkey Director, Regulatory AlTairs f(Lf muu ec:
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Enclosure to RA97/606 August 8,1997 COMBUSTION ENGINEERING,INC.
LICENSE NO.SMN-33 AMENDMENT REQUEST IIEMATITE ORGANIZATIONAL CHANGES Combustion Engineering, Inc. hereby submits a license amendment application to reflect the proposed management restructure. The two Focused Factory Manager positions (Ceramic Manufacturing and Assembly Operations) are being consolidated into the new position of Director of Uranium Operations. The position of Manager of Production Support and Supply Management will also be consolidated, with the non-production responsibilities (laboratory, security and shipping / receiving) assigned to the Directory of
- Regulatory Affairs, and production related responsibilities (facilities engineering and supplies) assigned to the Director of Uranium Operations. The Director of Regulatory
- Affairs will have adequate stafTto enable him to handle the added responsibilities. As
- NRC is aware, this staff has been expanded over the past few years and experienced personnel from the llematite organization will be added to supervise the added activities.
(Regulatory Affairs was formerly called Regulatory Compliance). The Director of Uranium Operations and the Director of Regulatory Affairs report in parallel to the Vice President, Fuel Operations, thus assuring separation of functions.
The changes in Chapters 1 through 6 have been made to change titles and responsibility
- descriptions as described above. The statement in Section 2.1 conceming resolution of dispute between managers responsible for safety is no longer necessary because of this consolidation and has been deleted. The Director of Regulatory Affairs has authority to halt any operation at the 11ematite facility, as stated in Section 2.1.3.
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Enclosure to RA97/606 August 8,1997 1,lST OF AFFECTED PAGES The pagos of the license application afTected are as follows:
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Enclosure to RA97/606-August 8,1997 A
COMBUSTION ENGINEERING,INC.
HEMATITE ORGANIZATIONAL AMENDMENT
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(d) _-
At 2 year intervals from the date of NRC approva! of this renewal application, the licensee shall update the demonstration sections of the renewal application to reflect the licensee's current operations. The updates to the application shall, as a minimum, include infonnation for the health and safety section of the application as required by 10 CFR 70.22(a) through 70.22(f) and 70.22(i) and operational data and information on environmental releases as required by 70.21. In lieu of an update at the end of the 10-year renewal period,-
the licensee may file a renewal application on or before ten years from the date of NRC approval of this renewal application.
(e)
Combustion Engineering shall perform Integrated Safety Assessments (ISAs; also termed hazard analyses) for plant processes. A schedule for such has been submitted to and approved by the NRC. New or significantly modified plant processes (as determined by the Director of Regulatory Affairs) shall
-include such hazard analyses. The guidance of the Branch Technical Position on Requirements for Operation (from the " Guidance On Management Controls / Quality Assurance, Requirements for Operatic.1, Chemical i
License No. SNM-33 Revision 2 Date: 8/08/97 Docket No. 70-36 --
Page: 6
CHAPTER 2 QRGANIZATION AND ADMINISTRATION 2,1 Organizational Resoonsibilities and Authority i
The Vice President, Fuel Operations has complete responsibility for ensuring that corporate operations related to nuclear fuel manufacturing are conducted safely and in compliance with applicable regulations. The Vice President has delegated the safety and compliance responsibility for nuclear fuel manufacturing and support activities to the Director of Uranium Operations, and the Director of Regulatory Affairs.
2.1.1 Director of Uranium Ooerations The Director of Uranium Operations reports to the Vice President, Fuel Operations.
The Director of Uranium Operations has the overall responsibility for safe operation of the Hematite facility. This includes criticelity safety, radiological anri industrial safety, environmental protection, production, accountability, packaging SNM and waste for transport, training, materials handling and storage, process and equipment engineering and maintenance, 4
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License No, SNM-33 Revision 2 Date: 8/08/97 Docket No. 70-36 Page: 2-1
1
- 2.1.2 (Deleted) 2.1,3 Director of Reaulatorv Affairs l
The Director of Regulatory Affairs reports to the Vice President, Fuel Operations.- He manages radiological protection, industrial safety, SNM accountability, criticality safety, licensing, emergency planning, environmental protection, laboratory services, shipping and receiving, transportation of SNM products and waste, security, and their associated
- training programs. His activities include review and approval of procedures for control, sampling, measurement and physicalinventory of SNM, auditing of plant operations. He reviews results from personnel and environmental monitoring and facility activities to -
ensure compliance with the requirements of License No. SNM-33. To enforce compliance, he has authority to halt any operation at the Hematite facility, and the operation shall not restart until approved by the Director of Regulatory Affairs, License No. SNM-33 Revision 2 Date: 8/08/97 Docket No. 70 Page: 2-2
2.1.4 Nuclear Criticality Soecialist
-The nuclear criticality specialist function reports to the Director of Regulatory Affairs.
The nuclear criticality specialist verifies that equipment, processes and procedures
. satisfy the criticality criteria in Chapter 4 by performing the review described in Section 2.0. Alternatively, for criticality analyses that require elaborate computational techniques, the specialist may supervise and/or review the analysis. The specialist may also perform the annual audit at Hematite required by Section 2.8.
2.1.5 Suoervisor. Health Physics The Supervisor of Health Physics reports to the Director of Regulatory Affairs. He/she supervises the health physics technicians in the radiological surveillance of activities that involve radioactive materials, in personnel radiation monitoring and in the collection and measurement of environmental samples. He/she has the authority to suspend unsafe operations.
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2.1.6 Health Physicist The Health Physicist reports to the Director of Regulatory Affairs. Activities include observation of plant operations and evaluation of results from personnel and i ~
environmental monitoring. Quantitative measurements and other observations of facility activities are compared with the requirements of License No. SNM-33.
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License No. SNM-33 Revision 1 Date: 8/08/97 Docket No. 70-36 Page: 2-3
I o Environmental protection trends o Radiation safety trends o Criticality safety practices o Industrial safety trends-o Adequa::y of emergency planning and drills o Effectiveness of A1. ARA program
- o. Internalinspection and audit reports o Abnormal occurrences and accidents including recommendations to prevent
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recurrence o Review of significant physical facility changes in the pellet shop and significant changes to operations involving radiation and/or nuclear criticality safety.
The review of findings and recommendations of corrective action shall be reported to the Director of Uranium Operations and to the Director of Regulatory Affairs for action.
The Committee Chairman determines which committee members, as a minimum, shall attend each quarterly meeting, according to the topics to be considered. The Committee submits a quarterly meeting report to the Hematite manager level personnel and the Vice President, Fuel Operations. The Committee Chairman appoints the committee members to represent, as a minimum, engineering, production, health physics, and criticahty safety. He or she may also approve alternate (s) for the members.
4 License No. SNM-33 Revision 2 Date: 8/08/97 Docket No. 70 Page: 2-5
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o6t their training functions. Operating personnel receive a re-training course in criticality control and radiation safety on a biennial basis. The effectiveness of retraining is determined by testing. Formal training shall be documented. The health physics technicians will receive professional related training at least biennially.
2.6 Ooerating Procedures Operations which affect licensed material shall be conducted in accordance with approved written procedures. Operating procedures are issued and controlled under the direction of Quality Coordinators. These procedures provide the detailed instructions for equipment operation and material handling and the limits and controls required by the License. Operating procedures are the basic control document; before issuance or revision they require signed approval by the Director of Uranium Operations and the Director of Regulatory Affairs. In the Director's absence, another individual meeting the Director's minimum education and experience requirements may provide approval.
. Health Physics activities will be conducted in accordance viith approved written procedures; these procedures must be approved by the Director of Regulatory Affairs or the Health Physicist.
Piocedures concerning the handling, processing, storing and shipping of nuclear materials are given prior review and approval by the Director of Regulatory Affairs.
Suitable control measures are prescribed, and pertinent control procedures relative to nuclear criticality safety and radiological safety are followed.
License No. SNM-33 Revision 2 Date: 8/08/97 Docket No. 70-36 Page: 2-7
Primary responsibility and authorit) to suspend unsafe operations is placed with line supervision. Within their respective responsibilities, members of Regulatory Affairs also have authority to suspend operations not being performed in accordance with an
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approved procedure, Prior to the start of a new activity affecting nuclear materials, approved procedures are y
available A review procedure has been established for changes in procesks, equipment and/or facilities prior to implementation, Regulatory Affairs authorization muct be obtained for each change involving nuclear safety or radiological safety, Regulatory Affairs reviews shall be documented, except for minor changes within existing safety parameters.
The Director of Re0ulatory Affairs shall grant approval only when:
a, A nuclear criticality safety evaluation has been performed based on the criteria and standards of Chapters 3 and 4 by a person who meets the education and experience requirernents for a Nuclear Criticality Specialist (and who may be the Director of '
Julatory Affairs This evaluation shall be in sufficient detail to permit subsequent review, b,
The criticality safety evaluation has been reviewsd by a person who fulfills th; education and experience requirements for a Nuclear Criticality Specialist (and who may be thu Director of Regulatory Affairs This individual will be different from the 4
person who performed the evaluation, This review is based on the criteria and standards of Chapter 4 and includes verification of each of the following:
License No. SNM 33 Revision 1 Date: 8/08/97 Docket No. 70 36 Paf e: 2-8 e
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- 1) assumptions
- 2) correct application of criteria of Chapter 4
- 3) completeness and accuracy of the evaluation
- 4) compliance with the double contingency criteria l
c.
The Director of Regulatory Affairs has concluded that the operation can j
be conducted in accordance with applicablo health physics criteria, j
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Review and verification shall include written approval by the reviewer.
The Director of Regulatory Affairs has the authority to determine whether other cognizant individuals, such as the Nuclear Criticality Specialist and/or the Health Physicist, have the appropriate experience and expertise to provide approvals in the stead of the Director of Regulatory Affairs for their areas of expertise, if he so determines, he may delegate his approval authority.
The minimum frequency for review, for the purpose of updating of operating procedures affecting Special Nuclear Materials and hestth physics procedures, shall be every two (2) years. Updating of operating procedures is the responsibility of the cognizant manager.
2.7 PjanLModifications The Director of Regulatory Affairs is responsible for determining the necessary safety reviews (e.g., for criticality and/or radiological safety) for pr0 posed changes or modifications to equipment for SNM processing, l
License No. SNM 33 Revision 1 Date: 8/08/97 Docket No. 70 30 Page: 2-9
handling, or storage, or related operations. The necessary management and safety reviews and approvals shall be performed prior to implementation of the change.
Significant changes, as determined by the Director of Regulatory Affairs, to operations affecting ladological and/or criticality safety are also reviewed by the Hematite Plant Safety Committee. Facility change requests requiring a criticality safety review shall be evaluated by a Nuclear Criticality Specialist, if it is deemed necessary, by any reviewer, that an inspection of equipment, procedures, and postings to assure completeness prior to startup of a new or modified process, the requirement for such an inspection will be so designated in the Change Request. Such inspections shall be documented as part of the records for this facility change, A modified process is defined as one involving a change in equipment design, SNM amount and/or configuration, or process controls when that change invalidates any aspect of the previous safety analysis.
2,8 Audits and insoections Audits and inspections shall be performed to determine if plant operations are conducted in accordance with applicable license conditions, C E policies, and written procedures.
Audits shall apply to safety related and environmental programs. Qualified personnel having no direct responsibility for the plant operation being audited shall be used to ensure unblased and competent audits, License No. SNM-33 Revision 1 Date: 8/08/97 Docket No. 70 36 Page: 2-10
Daily checks for safety related problems are made by Health Physics Technicians, who observe, note and make general observations in addition to their other duties. Problems are normally corrected on the spot by the Production Supervisor. More significant problems are listed in an exception report distributed to the Director of Uranium Operations and manager level staff. The Director of Uranium Operations is responsible for corrective action.
Planned and documented quarterly inspections cover criticality control and radiation safety. The inspection of criticality control shall be performed by an individual meeting at least the education and experience requirements of a Nuclear Criticality Specialist. The inspection of radiation safety shall be performed by an individual meeting at least the education and experience requirements of a Health Physicist, items requiring corrective action are documented in a report distributed to the Director of Uranium Operations and manager level staff. The Director of Uranium Operations is responsible for corrective action, except where another manager is specifically designated. Follow up actions taken by the Director of Uranium Operations, or other responsible manager, shall be documented.
Annual audits, in which the results of previous inspections or audits are reviewed, are conducted as an evaluation of the effectiveness of the program. These audits may also involve a detailed review of nnn safety documents such as operation procedures, shop travelers, etc., and are docum9nted by a formal report to the Vice President, Fuel Operations. Annual audits are performed by License No. SNM 33 Revision 1 Date: 8/08/97 Docket No. 70-36 Page: 2 11
a team appointed by the Vice President, Fuel Operations. Personnel on the team will not have direct responsibility for the function and areas being audited. The team shall include, as a minimum, a Nuclear Criticality Specialist and a radiation specialist who shall audit criticality and radiation safety, respectively. The radiation specialist who conducts the annual audit shall have as a minimum a Bachelor's degree in Science or Engineering with two years experience in operating health physics, including experience j
with uranium bionssay techniques, internal exposure controls and radiation j
measurement techniques. The anrual audit will review Al ARA requirements in conformance with Regulatory Guide 8.10, Revision 1 R, dated May 1977, as applicable.
The Director of Regulatory Affairs shall be responsible for follow up of recommendations made by the audit team.
2.9 lt1Ynitigations and Renolling Events specified by applicable regulations or license conditions shall be investigated and reported to NRC. The Director of Regulatory Affairs shall be responsible for conducting the investigation and documentation of reportable events.
Non reportable occurrences shall be investigated and documented as appropriate. Such reports shall be available for NRC Inspection.
License No. SNM-33 Revision 1 Date: 8/08/97 Docket No. 70-30 Page: 2-12
2.10 Records Retention of records required to be maintained by the regulations, and by the conditions of this license, shall be the responsibility of the cognizant manager. Records of Regulatory Affairs evaluations and approvals shall be retained for a period of at least six months after use of the operation has been terminated, or for two years, whichever is longer. Other safety significant records shall be retained for at least two years.
License No. SNM 33 Revision 1 Date: 8/08/97 Docket No. 70-36 Page: 2-13
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o e psameAURE EDUCATION AND E)(PerrtFNCE REQuiPrNTS FOR KEY PERSOpprt x o 1.1 =e
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Desenbed in Ser*Jon No.
Title Education Excenence (Years /Fiekfi e
6' 2.1.1 Director of Uranium Opera ^uvas Barleas, Soence or 5/ Nuclear manufactunng industry l
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2.1.2 (deleted) 4 I
2.1.3 Direc*or of Regulatory Affairs Bachelors, Soence or 4/ Health Physics with 24.i.cr4 heath l
Ergir.cc.'ig, and 1 week Ph)W with uranium twoassay technques.
trainics course in nuclear si 4=fid exposure control, r od radiabon cnbcality safety measurement technques l
2.1.4 Nuclear Cnticality Speaalist Barleics, Soence or 2iNuclear ch ;4y evaluabons, including 6 i
l o-Ergir.cc. irs months applicable to fuel manufactunng 2.1.5 Supervisor. Health Physses High Schoo! Diploma 5 Total.Nuclearindustry, with j
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.y 3/ Health Phys;cs Technsoan 2.1.6 Health Physicist Br.delors, Soence or 2@.ircr4 Health Physics W to l
Ergirewiirg fuel manufactunng 2.1.7 Health Physics Techcucian High School Diploma or 6 incidhsTTim ard expenence in i
GED Equivalent r.d;.'uun piviection actmties m o
, 2.3 Chairman, Plant Safety Committee Bachelors, Soence or 5/ Nuclear manufactunng industry
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A SE co N
CHAPTER 3 RADIATION PROTECTION 3.1 Special Administrative Reaulrements 3.1.1 ALARA PollCy It is the policy of Combustion Engineering to maintain a safe work place and healthful work envirunment for each employee and to keep radiation exposures to both employees and the general public As Low As Reasonably Achievable (ALARA). The annual audit team described in Section 2.8 considers ALARA requirements in conjunction with the intent of Regulatory Guide 8.10.
A wntien report shall be made by the Director of Regulatory Affairs to the Director of Uranium Operations every six months providing employee radiation exposure (internal and external) and effluent release data. Trends in the reported data may revea! areas where exposures and releases can be lowered in accordance with the above ALARA commitment. The data may also help to identify problems in personnel exposure, in effluent release, in process control or in equipment for measuring effluents and exposures.
License No. SNM-33 Revision 1 Date: 8/08/97 Docket No. 70 36 Page: ~ 3-1
3.1.2 RadjalicaMork Permit Procedures Short term non routine activities which do not require an operating procedure may be controlled by a Radiation Work Permit (RWP) approved by Regulatory Affairs management. Examples of activities which may be controlled by such RWPs include non routine maintenance or repair operations on equipment involved with handling radioactive materials and non routine maintenance operations in which ventilated containment systems are breached. Such RWPs specify applicable radiological controls for the activity, such as special radiological equipment, special personnel monitoring devices, protective clothing or air sampling requirements. RWPs which remain open for more than a month are reviewed on a monthly basis to ensure the controls are effective and are closed if no longer needed.
3.2 Technical RC2uirements 3.2.1 Contamination Control The facility shall be zoned to define contamination control areas and clear areas.
Appropriate protective clothing shall be worn in the contamination areas. An alpha survey meter or alpha monitor shall be provided at the exit from a contamination area.
All personnel are required to monitor their hands, and to monitor other body surfaces and personal clothing as appropriate, when exiting a contamination control area. Except for hand contamination which is easily removed with cleaning, health physics assistance and approval for release above background levels shall be required.
License No. SNM 33 Revision 1 Date: 8/08/97 Docket No. 70 36 Page: 3-2
The direction of air flow in the process buildings shall be checked at least annually and documented. Major design changes having a potential to impact air flow direction may require a re-check of the air flow direction once the design change has been completed, if the air flow direction is not acceptable, action will be taken.
Fire prevention and the potential for generating explosive atmospheres will be considered in ventilation design.
Air effluents from process areas and process equipment involving uranium in a dispersible form shall be subject to air cleaning. Exhaust stacks shall be continuously sampled when in operation.
3.2.3 Work - Area Air Samoling 3.2.3.1 MEamoling Criteria Air sampling shall be performed using fixed location samplers, personal (lapel) samplers, and air monitors.
The type of air sample collected at a specific operation or location shall depend on the type, frequency, and duration of operations being performed. One or more of these sample methods shall be employed at intervals prescribed by the Director of Regulatory j
Affairs or Health Physicist. C.eneral criteria for sampling are:
License No. SNM-33 Revision 1 Date: 8/08/97 Docket No. 70-36 Page: 3-4
DAC hours) for Class W and Class Y uranium and 8 milligrams per week for Class D uranium. A diagnostic study to evaluate intakes shall be started at these levels.
Exposure to radiation shall be monitored for individuals likely to receive, in one year from sources external to the body, in excess of 10% of the occupational dose limits of 10 CFR
- 20. The personnel monitoring device may be either a film badge (changed monthly) or a thermoluminescent dosimeter (TLD; changed quarterly). Film badges and TLDs shall be processed by a NationalVoluntary Laboratory Accreditation Program (NVLAP) accredited dosimetry processor. The action level for investigation and possible work restrictions shall be 1 rem for deep dose equivalent (DDE) on an annual basis.
Total Effective Dose Equivalent for occupational exposures shall be calculated in accordance with 10 CFR 20 using a combination of representative air sampling data, personnel radiation exposure data and/or bloassay measurement data.
1 3.2.6 S_urface Contamination 3.2.6.1 Special Surveys Non routine operations not covered by operating procedures shall be reviewed by Regulatory Affairs and a determination rnade by Regulatory Affairs if radiation safety monitoring is required.
License No. SNM-33 Revision 1 Date: 8/08/97 Docket No. 70-36 Page: 3-8
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With the exception of incidents requiring immediate evacuation, spills or other accidental releases shall be cleaned up immediately. The Production Supervisor and Regulatory i
Affairs must be notified immediately of such incidents.
3.2.6.2 Routine Surveillance Surveys shall be conducted on a regular basis consistent with plant operations and prior j
survey results. The frequency of survey depends upon the contamination levels common to the area, the extent to which the area is occupied, and the probability of l
- personnel exposures.
Material on processing equipment or fixed on surfaces shall be limited as required to control airborne radioactivity and external radiation exposures.
r The following minimum frequency schedule shall be applied to the plant contamination survey program:
Atma Survev Frecuency Action Level
- t Contamination control areas Weekly 5,000 Clear areas-Monthly 200 Lunchrooms, snack area, step-off pad areas Daily 200
- dpm/100 cm' as determined by smear survey 1
License No. SNM 33 IRevision 1 Date: 8/08/97 Docket No. 70-36 Page: 3-9 j
3.2.8 Resolratorv Protacilon The use of respiratory protection equipment will be in accordance with written operations sheets and appropriate training as required by regulation (10 CFR 20 Subpart H). Only respirators certified by the National Institute for Occupational Safety and Health /Mine Safety Administration shall be used. Protection factors from Appendix A of 10 CFR 20 (99 20.1001 20.2402) may be used when assigning actualintakes.
3.2.9 Bloassay Program A bioassay program shall be maintained for confirmation and evaluation of intakes. The primary method of calculating Committed Effective Dose Equivalent is by using breathing zone air sampling results.
3.2.10 Nonexemot Sealed Source Control 3.2.10.1 Use of nonexempt sources for training and instrument calibration shall be limited to, or under the supervision of, the Regulatory Affairs department.
3.2.10.2 Sources utilized as a functional component of devices designated for manufacturing and quality control purposes shall be operated only by personnel who have been qualified for safe practices. Health Physics shall provide appropriate monitoring support during maintenance or other operations that may entail increased exposure levels over that for normal operations.
License No. SNM 33 Revision 1 Date: 8/08/97
- Docket No. 70-36 :
Page: 3-11
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Monitoring locations may be changed only if a documented evaluation by Regulatory.
j Affairs demonstrates that a new location provides data that are as representative (or l
more representative) of conditions likely to impact on the general public, as was the i
J data from the originallocation.
Environmental samples shall be collected and analyzed as shown in Table 51. Sample j
frequency may vary due to inclement weather, plant shutdov;n nr operating co-ditions.
More frequent or additional samples may be taken as required for speed Hud.es and evnluations. Should a significant continuous upward trend be noted in any of the sampling data, corrective actions will be taken to investigate the cause. Remedial actions will be taken as appropriate t
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' License No SNM-33 Revision 1 Date: 8/08/97 Docket No. 70 36 Page: 5-3
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6.3 Emelgancv Utilities Emergency electric generators provide electric power to essential loads such as air, water, steam, instrumentation and alarms. Those loads transfer automatically to the generators upon a power outage.
l 0.4 Radioactive Waste Management Low level so:(d wastes shall be packaged in accordance with all applicable regulations and delivered to a carrier for transport to an approved disposal site.
Non-contaminated solid wastes are disposed of by a commercial waste disposal firm.
Non contaminated equipment may be disposed of to commercial scrap dealers, or by other means.
Conditions of storage of waste, waste containers, and contaminated equipment shall be included in the quarterly Regulatory Affairs inspection.
l License No. SNM 33 Revision 1 Date: 8/08/97 l
Docket No. 70 36 Page: 6-2
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