ML20216E425
| ML20216E425 | |
| Person / Time | |
|---|---|
| Site: | Waltz Mill |
| Issue date: | 09/07/1999 |
| From: | Rich Smith CBS, INC./CBS NEWS |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9909140037 | |
| Download: ML20216E425 (11) | |
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CBS Corporation Richard K. smith Director- Environmental Remediation 1I stanwis street, Room 383 Pittsburgh. PA 15222 Phone: 412-642-3285 September 7,1999 ras.4:2u2-3957 F-mail: smithrk@ westinghouse.com
' Document Control Center U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 i
Subject:
Request For Amendment to USNRC License Number TR-2, Docket No. 50-22 to ;
address pending organizational changes !
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References:
- 1. USNRC Letter to R. K. Smith dated March 25,1999 i
- 2. Westinghouse Letter to USNRC dated November 17,1998
- 3. Westinghouse Letter to USNRC dated September 28,1998 j l
- 4. Westinghouse Letter to USNRC dated July 10,1998
- 5. Westinghouse Letter to USNRC dated July 31,1997
Dear Sirs:
I CBS Corporation ("CBS"), successor by corporate name change to Westinghouse Electric Corporation, hereby submits this application for a license amendment to the possession only license for the Westinghouse Test Reactor , License Number TR-2, Docket Number 50-022 (the "TR-2 License"). The purpose of the application is to address organizational changes only necessitated by Westinghouse Electric Company's (" Westinghouse") plans to eliminate the Waltz Mill Site Manager's position.
On July 2,1999 Westinghouse Electric Company (" Westinghouse") announced that the position of Waltz Mill Site Manager was being eliminated. The former Site Manager will retain the l responsibilities of the Waltz Mill Site Manager relative to the TR-2 Decommissioning Project j until NRC approves this amendment for the elimination of the Waltz Mill Site Manager position. r l The organizational structure of the Westinghouse Test Reactor Decommissioning Project is described in the Facility License No. TR-2 for the Westinghouse Test Reactor (Reference 1); and
- in Section 2.4 of the Final Decommissioning Plan (Reference 5). Section 2.4 describes the l
responsibilities of the Site Manager and the makeup of the Radiation Safety Committee. As a result of the organizational change by Westinghouse, Section 2.4 of the Decommissioning Plan has been rewritten (see Exhibit A) to reflect the changes to be implemented by CBS.
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O'nce this Request for Amendment is approved, the Site Manager responsibilities will be reassigned. The CBS TR-2 Decommissioning Project Director ("CBS Project Director") will assume direct responsibility for operational oversight of activities conducted under the TR-2 license. The CBS Project Director reports directly to CBS's Director of Environmental Remediation. The Waltz Mill Site personnel will continue to provide support for operations, engineering , industrial hygiene, safety, security, environmental compliance, facilities and radiation protection pursuant to a contract with CBS. The Waltz Mill Site Radiation Safety Officer (RSO) will continue to provide oversight of the radiation safety program for the project. i The Decommissioning Program Manager will report to CBS through a contract agreement. A Radiation Safety Committee (RSC), separate from the existing SNM-770 RSC, will be established to monitor decommissioning operations to ensure they are being performed safely and in accordance with federal, state, and local regulatory requirements (NRC, EPA, PADEP, 1 DOT, etc.). The chairperson and members of this RSC will be appointed by CBS's Director of Environmental Remediction.
In support of this Application for a license amendment is an analysis of"No Significant liazards {
Consideration For The Change in TR-2 Organization." See Exhibit B.
If you have any questio,s concerning this submittal, please contact me at the above address or telephone number.
Sincerely, l
Richard K. Smith, Director Environmental Remediation Attachment ec: Mr. Theodore S. Michaels, Senior Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Wayne Vogel, Radiation Safety Officer )
Westinghouse Electric Company James Yusko, Radiation Health Physicist PA Department of Environmental Protection A. Joseph Nardi, Supervisory Engineer Energy Systems, Regulatory Affairs
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Copies transmitted: 3 notarized and 5 conformed COMMONWEALTil OF PENNSYLVANIA )
)' SS:
COUNTY OF ALLEGHENY )
Before me, the undersigned notary public, this day personally appeared Richard K. Smit; .. CBS Corporation,11 Stanwix Street, Pittsburgh, PA 15222, to me known, who being duty swom according to law, deposes and says: that the statements sworn to in this letter and attachment are correct and accurate to the best of his knowledge.
Signature of affiant Subscribed and sworn to before me this 7 day of 1999 tM YMG t -
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Notait Public Notanal Seal Mary Coheen Galvin. Notary Public Pittsburgh, Allegheny County My Commission Expires Nov.22,1999 Member, Pennsylvania Associall0n of Notaries I
I Exhibit A Replacement Pages for the Organizational Structure described in the Approved Decommissioning Plan for the Westinghouse Test Reactor Facility License Number TR-2, l
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0 Westinghouse Test Reactor Decommissioning Plan Revision I to Section 2.4 2.4 DECOMMISSIONING ORGANIZATION AND RESPONSIBILITIES )
The Westinghouse Test Reactor Decommissioning organization complies with the existing license and applicable regulatory requirements.
The direct responsibility for operational oversight of activities conducted under the TR-2 License and the TR-2 Radiation Protection Program rests with the CBS TR-2 Decommissioning Project Director who is located on-site and repons directly to CBS Corporation's Director of Environmental Remediation The Project Director will have overall responsibility for the TR-2 licensed facility. The Waltz Mill Site will continue to provide support for operations, engineering, industrial hygiene, safety, security, environmental compliance, facilities support, radiation protection and quality assurance through a contractual arrangement with CBS.
Reporting through a contract arrangement to CBS is the Industrial Hygiene, Safety and Environmental Compliance Manager to whom the Radiation Safety Officer (RSO) reports.
The RSO is responsible for the establishment and guidance of programs in radiation protection. !
To maintain a uniform program that addresses public safety for the Waltz Mill Site, the RSO l position for the TR-2 License will be filled by the RSO for the SNM-770 License. The RSO also evaluates potential and/or actual radiation exposures, establishes appropriate control measures, approves written procedures, and ensures compliance with pertinent policies and regulations. Under the RSO's direction, health physics personnel administer the established site policy, collect samples, perform analyses, take measurements, maintain records, and generally assist in performing the technical aspects of the radiation protection program. The RSO will be supported by adequate staff, facilities and equipment and will hold a position within the organizational structure providing direct access to senior management.
The Decommissioning Team Program Manager reports to CBS through a contract arrangement. The Decommissioning Team Program Manager will coordinate the elements of the functional groups of the Waltz Mill decommissioning organization, Decommissioning Team, and decommissioning contractors, as it applies to decommissioning activities. The Decommissioning Team reports to the Decommissioning Team Program Manager.
The Radiation Safety Committee has been established to monitor decommissioning operations to ensure they are being performed safely and according to federal, state, and local regulatory requirements (NRC, EPA, PADEP, DOT, etc.). Members of this committee will be appointed by the CBS Director of Environmental Remediation and will include members of the Radiation Safety Committee (RSC) for the SNM-770 license. The RSC will review major decommissioning activities dealing with radioactive material and radiological controls. In
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addition, the Radiation Safety Committee will review and approve changes to the Decommissioning Plan that do not require prior NRC approval.
The number and titles of key functions / positions shown on Figure 2-13 may be modified during the course of the decommissioning project. However, the following key positions will not be eliminated while decommissioning activities are in progress, without prior NRC approval:
CBS TR-2 Decommissioning Project Director Radiation Safety Officer Radiation Safety Committee i
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WTR DECOMMISSIONING PROJECT REPONSIBILITY MATRIX CBS Corporation Westinghouse Electric Co- Environmental Remediation (2)
Radiation Safety Westinghouse Committee Law Contracts & CBS General Counsel TR-2 Decommissiong Regulatory Affairs Project Director I
i Radiation Safety
- Officer (Note 1) (2)
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Decommissioning Team Program Manager Manager Facilities Industrial Hygiene Manager Safety and Environmental Project Compliance Technical Lead Radiation Safety [~"'"~'~
Officer (Note 1) l GTS Duratek MK Quality IIcalth Physics Operations Assurance Manager Manager Notes:
(1) The Radiation Safety OtTicer reports to the industrial flygiene. Safety and Environmental Compliance Manager and is also the Secretary of the Radiation Safety Committee.
(2) Denotes a Contractual Relationship.
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Exhibit B "No Significant flazards Consideration For The Change in The Organizational Structure of the Westinghouse Test Reactor Facility License Number TR-2, Docket 50-022 Decommissioning Project."
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- Exhibit B "No Significant Hazards Consideration For The Change in The Organizational Structure of the Westinghouse Test Reactor Facility License Number TR-2, Docket 50-022 Decommissioning Project."
REFERENCE 10 CFR 50.91(a)
The proposed change that is the subject of the requested amendment has been evaluated against the standards of 10 CFR 50.92(c) and it has been determined to not involve any significant hazards consideration in that licensed activities in accord with the proposed amendment:
- 1) Would not involve a significant increase in theprobability or consequences ofan accidentpreviously evaluated.
The proposed amendment will change the organizational structure for the TR-2 Decommissioning Project as described in the Westinghouse Test Reactor ("WTR facility") Decommissioning plan and approved in the TR-2 license, a possession only license (the "TR-2 License"). This amendment request is necessary because on July 2, 1999 Westinghouse Electric Company, LLC, announced that the current Waltz Mill Site Manger is being reassigned and the Waltz Mill Site Manager position will be eliminated pending the necessary approvals by the NRC. As a result the Waltz Mill site manager's responsibilities related to the Westinghouse Test Reactor and the TR-2 license are being reassigned to the on-site CBS TR-2 Decommissioning Project Director. CBS retains the WTR facility and TR-2 license and the responsibility to continue the on-going decommissioning and license termination activities in accordance with the
" Decommissioning Plan" previously approved by the NRC.
Under the provisions of the Decommissioning Plan, Westinghouse personnel at the Waltz Mill Site currently provide certain oversight activities with respect to radiation safety for the WTR facility decommissioning project. These oversight activities primarily involve the review and approval of decommissioning activities through the Radiation Safety Committee that is established under the site's TR-2 license, it will be necessary for CBS and Westinghouse to continue to coordinate the activities conducted under the active SNM-770 license that support the TR-2 decommissioning activities.
1 in order to complete the decommissioning of the WTR facility as described in the Decommissioning Plan, CBS has established contractual agreements with Westinghouse Electric Co. to supply continued site support and services to the Westinghouse Test Reactor Facility. CBS has also entered into contracts with other third party organizations as described in the Decommissioning Plan. These contracts will remain in place between
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CBS and each respective third party so that there will be no effective change in the personnel associated with the on-going decommissioning project under the TR-2 License.
CBS continues to retain full responsibility for the project.
There is no change in the financial qualification of CBS to continue to hold the TR-2 License.
In summary, the CBS personnel responsible for decommissioning activities under the TR-2 License will continue to be technically qualified to carry out licensed activities.
Other than the reassignment of the Waltz Mill Site Manager responsibilities under the Decommissioning Plan, there is no effective change in the personnel who are responsible to complete the TR-2 License decommissioning effbrt. Waltz Mill Site personnel l
continue to be contractors to CBS. Thus, the requested amendment does not involve any changes in the conduct oflicensed activities, which will continue in their current fann without interruption.
In addition, the proposed amendment requires no physical change to the WTR facility or changes to the Technical Specifications or procedures under the TR-2 License (Although Technical Specification Section 6.0 Administrative Control, is affected by this amendment it does not require a change). The proposed change does not increase the probability of an accident previously evaluated because it does not affect any initiators in any of the previously evaluated accidents. The proposed change does not increase the consequence of any accident previou: y evaluated because it does not affect any of the items on which the consequence depends.
Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2) Il'ould not create the possibility ofa new or dillerent kind ofaccidentfrom any accident previously evaluated.
The proposed amendment does not modify the WTR facility configuration or licensed activities. Thus no new accident initiators are introduced.
Therefore, the proposed amendment does not create the possioility of a new or different accident from any accident previously evaluated.
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.f) Would not involve a significant reduction in a margin ofsafety. j 1
CBS personnel responsible for decommissioning activities under the TR-2 License will continue to be technically qualified to carry out licensed activities. In connection with the organizational change, there will be no effective change in the personnel who are responsible to complete the TR-2 License decommissioning effort as described in the Decommissioning Plan, other than the Waltz Mill Site Manager. The Waltz Mill Site Manager's responsibility as it pertains to the WTR and the TR-2 License has been assigned to the On-Site CBS TR-2 Decommissioning Project Director. Waltz Mill Site personnel will continue to be contractors to CBS. Thus, the requested amendment does not involve any changes in the conduct oflicensed activities, which will continue in their current form without interruption.
Therefore, the proposed amendment does not involve a significant reduction in a margin ofsafety.
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