ML20248H875
| ML20248H875 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 10/04/1989 |
| From: | Bidinger G, Mccaughey D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20248H870 | List: |
| References | |
| NUDOCS 8910120124 | |
| Download: ML20248H875 (8) | |
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DOCKET NO: 70-1100 LICENSEE: Combustion Engineering, Inc. (CE) )
Windsor, Connecticut
SUBJECT:
SAFETY EVALUATION REPORT, REVISED LICENSE AMENDMENT APPLICATION DATED JUNE 23, 1989, AND SUPPLEMENT DATED SEPTEMBER 15, 1989, RE ORGANIZATIONAL CHANGES
Background
On July 13, 1988, CE submitted an amendment application requesting changes in the licensed organization. On January 18, 1989, CE revised the initial 1 application due to a further restructuring of the organization. By letter .
dated February 15, 1989, the NRC staff requested that additional information be '
provided concerning the January 18, 1989, submittal. CE responded by submitting a revised application on March 7, 1989. On June 20, 1989, the NRC staff sent CE a letter identifying several issues that needed to be addressed j prior to the issuance of a license amendment. On June 23, 1989, CE submitted a l revised application and on September 15, 1989, supplemented the application.
The September 15, 1989, submittal was in response to comments provided by NRC staff identifying deficiencies in the June 23, 1989, application relating to certain position qualifications and responsibilities. The June 23 and September 15, 1989, submittals are the subject of this Safety Evaluation Report.
Discussion A. Organization (Nuclear Safety Responsibilities and Minimum Qualifications)
Vice President and General Manager, Nuclear Fuel Manufacturing The Vice President and General Manager (VP&GM), Nuclear Fuel Manufacturing (NFM), reports to the Vice President, Nuclear Fuel, who in turn repor ts to the President, Nuclear Power Businesses Division. The VP&GM has overall responsi- i bility for the safe operation of the NFM facility located in Windsor, Connecticut. This responsibility is administered through the professional staff at the NFM facility as well as the technical staff of CE's Nuclear Power Businesses Division. The organizational structure is shown in Figure 1. The VP&GM will have, as a minimum, a bachelor's degree in science or engineering, with 10 years of experience, including a minimum of 5 years in management positions in the nuclear industry.
Director, Product Development The Director, Product Development has overall responsibility for the safe operation of the nuclear fuel product development laboratory activities. The 8910120124 891004 PDR (4 DOCK 07001100 C PDC
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] OCT 4 1989 Combustion Engineering, Inc. 3 Director.is supported in executing this responsibility by a professional staff reporting directly to him, by members of the NFM staff, and by other professionals within the Nuclear Power Businesses Division. The Director will have, as a minimum, a bachelor's degree in science or engineering, with 10 years of experience, including a minimum of 5 years in management positions relating to product development activities in the nuclear industry.
Program Manager, Radiological and Industrial Safety The Program Manager, Radiological and Industrial Safety (PMRIS) reports to the VP&GM and is responsible for defining programs and standards related to radiological, critical *, and industrial safety, environmental protection, and emergency planning foi th the NFM facility and the product development laboratories. The orii ial qualifications provided for the PMRIS in the June 23, 1989, application were determined by NRC staff to be inadequate. The following qualifications were committed to by CE in the September 15, 1989, supplement. The PMRIS will have, as a minimum, a bachelor's degree in science or engineering, with 4 years of experience in health physics, including 2 years in operational health physics with uranium bioassay techniques, internal exposure controls, and radiation measurement techniques.
Senior Criticality Specialist The Senior Criticality Specialist (SCS) reports in a functional manner to the PMRIS and is responsible for executing the aspects of the PMRIS's functions which relate to criticality safety. The SCS also serves as the independent reviewer for criticality evaluations. The original qualifications provided for the SCS in the June 23, 1989, application were determined by NRC staff to be inadequate. The following qualifications were committed to by CE in the September 15, 1989, supplement. The SCS will have, as a minimum, a bachelor's degree in science or engineering, with 2 years' experience performing the duties of a Nuclear Criticality Specialist.
Radiological Protection and Industrial Safety Manager The Radiological Protection and Industrial Safety Manager (RPISM) reports to the VP&GM and is responsible for implementing the safety programs developed by the PMRIS. The original qualifications provided for the RPISM in the June 23, 1989, application were determined by NRC staff to be inadequate. The following qualifications were committed to by CE in the September 15, 1989, supplement.
The RPISM will have, as a minimum, a bachelor's degree in science or engineering, )
with 2 years experience in health physics including 1 year in operational health I physics with uranium bioassay techniques, internal exposure controls, and radiation !
measurement techniques.
Nuclear Criticality Specialist The Nuclear Criticality Specialist (NCS) reports in a functional manner to the RPISM and is responsible for executing the aspects of the RPISM's functions which relate to criticality safety. The NCS is responsible for preparing 1
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',' $ OCT 4 1989 Combustion Engineering, Inc. 4 1 criticality safety specifications and limits based upon criteria and analysis which are conducted by the NCS. The NCS will have, as a minimum, a bachelor's i degree in science or engineering, with 2 years experience performing I criticality evaluations. j J
Nuclear Criticality Analyst l The Nuclect Criticality Analyst is responsible for performing the detailed numerical calculations, as prescribed by the NCS, to verify the acceptability of fuel manufacturing facility or product development laboratory processes or equipment. The Nuclec Criticality Analyst will have, as a minimum, a bachelor's degree in science or engineering and 1 year of experience performing criticality analyses.
Radiological Protection and Industrial Safety Supervisor The Radiological Protection and Industrial Safety Supervisor (RPISS) reports to the RPISM and is responsible for the surveillance of nuclear fuel manufacturing and product development activities related to radiological, criticality, and industrial safety; environmental protection; and emergency planning. This surveillance responsibility is accomplished through the direction of the Radiological and Industrial Safety Technician's activities. The original qualifications provided for the RPISS in the June 23, 1989, application were determined by NRC staff to be inadequate. The following qualifica' cions were committed to by CE in the September 15, 1989, supplement. The RPISS will have, as a minimum, a high school diploma with 5 years of experience in one of the i safety-related areas within the RPISS's jurisdiction. Three of the 5 years of safety-related experience will have been as a senior radiological protection technician. A senior technician is an individual who has had, at a minimum, 1 year experience as a radiological safety technician.
Radiological Protection and Industrial Safety Technicians The Radiological Protection and Industrial Safety Technician (RPIST) reports to the RPISS and is responsible for the day-to-day monitoring of operations at the fuel manufacturing facility and the product development laboratories. The RPIST will have, as a minimum, a high school diploma with 1 year of experience in one of the safety-related areas within the RPIST's jurisdiction.
Production Manager The Production Manager reports to the VP&GM and is responsible for the j planning, scheduling, and control of the production process for the fabrication of fuel assemblies. The Production Manager will have, as a minimum, a high school diploma with 5 years of experience in the nuclear industry. Of the 5 years, at least 3 will be in production coordination positions. Staff has reviewed these qualifications and has determined that the educational criteria is not commensurate with the duties and responsibilities of the position.
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OCT 4 1989 Combustion Engineering, Inc. 5 .
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Therefore, the staff proposes the following license condition:
In addition to the experience requirement established in Section 2.2.11 of Part I of the application, the Production Manager shall have, as a )
minimum, a bachelor's degree in science or engineering. I i
Manager of Manufacturing Engineering I The Manager of Manufacturing Engineering reports to the VP&CM and is responsible for direction of engineering activities related to facility equipment, process, methods, and construction. The Manager is also responsible for equipment maintenance. The Manager of Manufacturing Engineering will have, as a minimum, a bachelor's degree in science or engineering with 3 years of experience in the nuclear industry.
Emergency Director The Emergency Director reports to the VP&GM and is responsible for coordinating the actions of the emergency response team members. This coordination effort includes the direction of the recovery operations for any emergency condition which may arise in the NFM facility or product development laboratories. The Emergency Director will be a member of the nuclear fuel management team and will be familiar with the NFM and product development processes and facilities.
The Emergency Director will also be familiar with the emergency plan and implementing procedures. The licensee has failed to provide criteria establishing educational and experience requirements for the Emergency Director. Acceptable qualifications for this position would be comparable to that of a senior manager.
Therefore, the following license condition is recommended:
The Emergency Director shall have, as a minimum, a bachelor's degree in science or engineering, followed by 5 years experience in management
. positions in the nuclear industry.
Facility Review Group The licensee has a Facility Review Group (FRG) which meets quarterly to review safety-related operations and to provide recommendations to the VP&GM. This review includes safety-related practices and trends, adequacy of emergency planning, effectiveness of the ALARA program, inspection and audit reports, abnormal occurrences and accidents and related corrective actions, and any proposed facility or operational changes involving nuclear criticality or radiation safety.
Findings and recommendations of the FRG are reported to the VP&GM, NFM, and the Director, Product Development with copies to the Line Managers, the Vice President, Nuclear Fuel, and the President of Nuclear Power Businesses. It is the responsibility of Line Managers in the fuel manufacturing facility and the Director of Product Development in the product development laboratories ta ensure that deficiencies identified by the FRG are addressed. The FRG is I
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OCT 4 1989 Combustion Engineering, Inc. 6 composed ~of' senior personnel from the technical staff of_CE's Nuclear Power Businesses Division having at least 5 years experience in the nuclear industry.-
The licensee has an independent safety committee which conducts an annual audit of nuclear fuel ananufacturing and product development operations. This safety committee is appointed by and reports to the President, Nuclear Power-Businesses Division. The committee is comprised of senior engineers and scientists from within the Nuclear Power Businesses Division's technical community. Written audit findings are provided to the President, Nuclear Power
' Businesses Division; Vice President, Nuclear Fuel; Vice President and General Manager, Nuclear Fuel Manufacturing; and the chairperson of the Facility Review Group. Audit findings, as well as corrective actions, will be maintained in the audit records.
Review of Resumes CE has provided resumes for individuals assigned to the positions identified as important to-safety. Staff has reviewed these resumes and concludes that, except for one position (Senior Criticality Specialist), CE has demonstrated that they have individuals who meet the minimum qualifications as proposed by the licensee or recommended by the staff. CE has proposed that the Senior Criticality Specialist have, as a minimum, 2 years of experience as a Nuclear
-Criticality Specialist. The individual assigned to this position does not have the' required 2 years of experience as a Nuclear Criticality ipecialist.
However, the individual has served as the criticality consultant to the Nuclear Safety Committee for 3 years and also hu several years of experience in reactor physics. Staff finds that the experience of the incumbent is adequate to perform the duties assigned.
B. Administrative Practices The licensee has made the commitment that line managers are responsible for the preparation of written operating procedures which incorporate radiation and nuclear criticality controls and limits. The procedures will be approved by the line manager, the RPISM, and the NCS. The preparation, review, revision, approval, and implementation of safety-related operating procedures are accomplished through a document control system. Safety-related operating procedures will be reviewed every 2 years by the appropriate line manager, the RPISM, and the NCS.
In addition, the licensee has modified the facility change request procedure.
All proposed changes in process, equipment, or facilities which affect safety j will be approved by individuals meeting the minimum qualifications of the NCS i and PMRIS. An independent review and written approval of changes which affect nuclear criticality safety will be conducted by an individual meeting the minimum qualifications of the SCS. 1 i
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OCT '4 1989 Combustion Engineering, Inc. 7 C. ' Inspections and Audits-.
Inspections The inspection function is'a normal job function of the Radiological Protection and Industrial Safety Technician. Technicians are' assigned to all operating
, shifts and as such, the inspection function is satisfied on an ongoing. basis.
On a monthly-basis, Technicians will perform a documented inspection using a prepared checklist. All discrepancies, whether revealed at time of an informal daily walk through^or the formal monthly inspection, are communicated to the line manager and a written deficiency report is submitted to the RPISM. The RPISM is responsible for assuring that corrective actions are initiated by the-appropriate line manager in a timely manner.
Audits At least quarterly, individuals meeting the minimum qualifications of the PMRIS and the SCS conduct' audits of the radiation protection and nuclear criticality
. safety practices, respectively. These audits are conducted in accordance with a written plan. A report documenting audit results is prepared and distributed to the VP&GM, the Director of Product Development, and the line managers.
D. Training Employees and visitors (as nocessary) working in the NFM facility or the product development laboratories will participate in a General Employee Training (GET) program. The GET program includes, among other topics, radiation safety and nuclear criticality safety.
In~ addition to GET, any employee or visitor working with unciad uranium in the NFM facility or any employee.or visitor working in the product development laboratories will participate in a Radiation Worker Training (RWT)-program. l The 'RWT covers radiation and criticality safety in more detail than the GET. !
To verify training effectiveness, formal training will be documented and competency demonstrated by testing.
Refresher training is provided on an annual basis and will include: (1) a module covering operational deficiencies identified at the facility and the ;
subsequent corrective actions, (2) radiation safety, and (3) criticality '
safety.
E.. Deletion of Existing License Condition Conditions 11 and 12 required that the independent criticality and radiological safety review be conducted by the Nuclear Criticality Specialist and the Manager, Health Physics, respectively.
With respect to the new organization, these independent review functions are the responsibility of the SCS and the PMRIS. Therefore, since Conditions 11 and 12 are superseded by this amendment, it is recommended that they be deleted.
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OCT '4 1989
. Combustion Engineering, Inc. 8 In addition, the time constraints on Condition 28, which required the licensee
'to replace all poly-buckets with stainless steel buckets by November 30, 1988, and Condition 29, which granted the licensee a 30-day grace period to implement changes to bring the dryer belt into conformance with license
' descriptions, have expired,-and it is recommended that they be deleted.
Conclusion / Recommendation The staff concludes that the proposed organizational changes, subject to the additional conditions developed by the staff, will have no adverse effect on the,public health and safety or'the environment. Approval of the revised amendment application is recommended.
The Region I staff has no objection to this licensing action.
OrigitalSigned Br David A. McCaughey Uranium Fuel Section Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS Approved by: b George H. Bidinger, Section Leader 0FC:IMUF: IM F: IMUF: gg NAME D ghe Tharpe HBidinger:
DATE:10d /89 10/h/89 10/$/89 0FFICIAL RECORD COPY l