ML20235L331

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Forwards Request for Addl Info Re 890118 Application for Amend to License SNM-1067.Response Should Be Submitted within 20 Days of Ltr Date
ML20235L331
Person / Time
Site: 07001100
Issue date: 02/15/1989
From: Bidinger G
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Mcgill P
ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
References
NUDOCS 8902270476
Download: ML20235L331 (5)


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. Docket No.. 70-1100 FEB 15 B89 License No. SNM-1067

' Combustion Engineering, Inc.

ATTN: Mr. P. L. McGill, Vice President Nuclear Fuel 1000 Prospect Hill Road,

Windsor, Connecticut 06095-0500-

. Gentlemen:

We have initiated our review of psur license amendment application dated January 18, 1989, which reviru year July 13,'1988, amendment application. The enclosure to this letter idenh,ies several significant issues which require additional'information. Please submit your response to these comments in the form of carefully revised pages to the application within 20 days of the date of this letter.

We will continue our review upon receipt of the information.

If there are any questions regarding this matter, please contact Dave McCaughey of rqy staff at (301)492-0669.

Sincerely, IN George H. Bidinger, Section Leader Uranium Fuel Section Fuel Cycle Safety Branch

' Division of Industrial and Medical Nuclear Safety, NMSS

Enclosure:

As stated cc w/encls:

Mr. A. E. Scherer, Director Mr. C. B. Brinkman, Manager Nuclear Licensing Washington Nuclear Operations Mr. C. R. Waterman, Vice President Mr. R. E. Sheeran, Manager and General Manager Accountability and Security Nuclear Ft.el Manufacturing

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REQUEST FOR SUPPLEMENTAL INFORMATION AMENDMENT APPLICATION DATED JANUARY 18, 1989 No. Section Comment 1.

2.1 These sections refer to the Nuclear Power Systems Division.

2.2 Other sections refer to the Nuclear Power Businesses Division.

Please clarify.

2.

2.5.3 All positions with key safety-related responsibilities should be 2.5.5 established in Section 2.2.

In connection with this, minimum 2.5.15 qualifications for all established positions in 2.2 should be included in Section 2.5.

In the amendment application, Sections 2.5.3, 2.5.5, and 2.5.15 provide minimum qualifications for positions not established in Section 2.2.

Provide the duties and responsibilities for these positions.

In addition, a systematic correlation between these two sections (2.2 and 2.5) should be employed.

For example, the duties and responsibilities for the Vice President &' General Manager'(VP&GM) should be established in Section 2.2.1 with minimum qualifications provided in Section 2.5.1; the responsibilities and qualifications of the Director of Product Development should be in Sections 2.2.2 and 2.5.2, respectively; etc.

Use of an organizational chart provides an acceptable method for depicting the flow of responsibility within an organization.

However, if this method is used, all key safety-related management and technical positions should be included in the chart. The application does not include the Supervisor, Health Physics and Safety on the organizational chart.

Please clarify.

3.

2.2.1 The Director, Product Development, is responsible for nuclear and radiological safety. A safety staff, however, has not been provided for the Director. Although there is some implication that the safety staff of the VP&GM will provide safety services, the VP&GM has no specified responsibility to provide such services.

Please clarify the VP&GM's responsibilities and describe the mechanisms to provide such services.

4.

2.2.2 This section states that the Program Manager of Radiological and Industrial Safety (PMRIS) has responsibility for establishing the nuclear criticality safety (NCS) controls. The PMRIS does not have the qualifications to establish and be responsible for i

an effective NCS program. The person responsible for the initial NCS analysis should have as a minimum, a bachelors degree in science n

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l or engineering and 1 year experience in nuclear criticality safety.

The person responsible for the independent review should possess j

& bachelors degree in science or engineering and 2 years exper-

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ience in NCS as a nuclear criticality safety specialist at a fuel fabrication facility.

Confirm that the persons responsible for the NCS program meet these qualifications. This section j

should contain the responsibilities of the specialist and senior specialist. Their minimum qualifications should be in Section 2.5, and the requirements for the safety analysis should be in Section 4.1.3, Part I.

5..

2.2.2 This section states that if an operation is halted because of criticality safety considerations, the PMRIS or the Safety Committee could be contacted to determine necessary corrective actions to be taken.

Neither the PMRIS nor the Safety Committee have the qualifications to determine corrective actions with respect to nuclear criticality safety. The individual that provides these services should have, as a minimum, the qualifications of a senior nuclear criticality safety specialist (see comment 4, above.)

6.

2.4 The current license provides in Sections 2.4.1 and 2.4.2 the approval authority for key safety-related positions within product development and nuclear fuel manufacturing. The amendment application deletes any management system for approving appointments to positions which are important to safety within the nuclear fuel manufacturing department. Provide the approval authority for key safety-related positions within the nuclear fuel manufacturing department.

7.

2.5.1 When establishing minimum qualifications, the two important 2.5.5 elements are education and experience. A typical educational 2.5.8 requirement for a manager or specialist is a bachelors degree 2.5.11 in engineering or physical science.

For the technicians, a high 2.5.12 school diploma is acceptable. As stated in the amendment 2.5.15 application, the term " equivalent" is not an acceptable substitution for a bachelors degree or a high school diploma. Please be more definitive.

8.

2.5.1 As stated in Section 2.2.2 of the amendment application, the VP&GM is responsible for all nuclear fuel manufacturing activities, which include both nuclear and radiological safety.

This is a significant responsibility and minimum qualifications for a position with these responsibilities should reflect as such.

However, as stated in Section 2.5.1 of the application, the qualification of 3 years supervisory experience is not commensurate with the duties end responsibilities of the VP&GM as described in Section 2.2.2.

A minimum of 10 years experience including a minimum of 5 years in management in the nuclear industry would correspond to qualifications necessary to perform as a VP&GM.

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9.

2.5.5 The ap)11 cation states that the Nuclear Criticality Specialist shall lave experience in outside-of-reactor nuclear criticality safety or nuclear fuel manufacturing facility criticality I

safety. Although this type of experience is acceptable, the amount of such experience must also be specified. Typically, an NCS specialist who performs the initial analysis should have a bachelors degree in science or engineering and a year of training 1

in outside-of-reactor nuclear criticality safety. A specialist whoperformstheindependentreviewoftheanalysis(e.g., senior nuclear criticality safety specialist) should have a minimum of

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2 years experience as an NCS specialist. Confirm that the experience requirements conform to the duties and responsibilities of this position.

10.

2.5.9 The minimum qualifications provided in Section 2.5.5 for the Nuclear Criticality Specialist are not commensurate with the responsibility of performing an independent criticality safety review.

See NRC Comment No. 9.

11. 2.5.12 This section does not provide the amount of experience required to perform the duties and responsibilities assigned.

Typically, a manager who is responsible for establishing, implementing, and evaluating health and safety programs should have a minimum of 4 years experience in the safety functions being managed. The 4 years experience should be composed of 1 year as a safety specialist trainee, 2 years as a safety specialist, and 2 years as a senior safety specialist. Specify the minimum amount of experience required for this position.

12. 2.5.14 Section 2.2.2 of the application states that the Manager, Radiological and Industrial Safety, is res)onsible for the surveillance of all NFM activities in whici radioactivity is involved to ensure that the health and safety standards set forth in the license are met. The minimum qualifications described for this position are not commensurate with the duties and responsibilities of the position. Typical minimum

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qualifications for a position with these duties and 1

responsibilities are a bachelors degree in science or I

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engineering and 4 years experience in health physics at a fuel fabrication facility. The 4 years experience should be composed of 1 year as a radiation safety specialist trainee,1 year as a radiation safety specialist, and 2 years as a senior radiation safety specialist.

13. 2.5.15 There are no minimum experience requirements established for the Consultant. More significantly, until position responsibilities are established in Section 2.2, we are unable to judge the adequacy of this section.

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2.6.2 Page I.2-12 of the currerit license provides that the Supervisor.

of Health Physics and Safety or the Manager NLSA&S will assure that training is conducted. The current application deletes the Manager NLSA&S. Please rectify this situation.

15. -2.6.3

.The last sentence in this section is incomplete. Please correct this oversight.

16. 2.7.1 Confirm that records of evaluations and independent reviews are.

maintained for at least 2 years or 6 months after termination of the activity, whichever is longer.

17. 2.8.1 This.section states that operations in Froduct Development will be audited monthly to verify the adequacy of the Radiation Protection. Program. However, no mention is made of auditing the NCS Program. Confirm that operations in product development are audited monthly by an individual meeting the minimum qualifications of an NCS specialist to determine the adequacy of the NCS Program.

18.

2.8.2 The application states that the NFM operathns will be audited once each month for radiological safety by an individual who meets the minimum qualifications of a Radiation Specialist.

However, the qualifications and responsibilities for this position are not described. Please clarify.

Third bullet - The Manager of Radiological and Industrial Safety is not qualified to assess the adequacy of the criticality safety program. See qualifications as-described in NRC Comment No. 4.

19.

Resumes are used to demonstrate that individuals assigned to safety-related positions described in Chapter 2 meet the minimum qualifications of the position.

Therefore, resumes should be submitted which identify the position and title -currently held by the individual. Some resumes submitted with the amendment application do not correspond with the positions described in Chapter 2(e.g.,VP&GM,PMRIS,etc.).

Per our discussion on January 25, 1989, serious consideration should be given to the development of a safety committee who is established by and reports directly to the VP&GM, Nuclear Fuel Manufacturing. This committee should meet quarterly and should be responsible for review of plant operations, proposed operations, reports of inspection, audits, and unusual events (see Section 2.3 ofReg. Guide 3.52datedNovember1986).

It is also recommended that a quality check be performed on the format, pagination, and logic of the application prior to submitting the revised I

pages. Many comments above reflect a failure to perform this quality check.