ML26022A037
| ML26022A037 | |
| Person / Time | |
|---|---|
| Site: | BWX Technologies |
| Issue date: | 01/13/2026 |
| From: | Freudenberger R BWXT |
| To: | Office of Nuclear Material Safety and Safeguards |
| References | |
| 26-003 | |
| Download: ML26022A037 (0) | |
Text
BWX Technologies, Inc.
January 13, 2026 26-003 ATTN: Document Control Desk Director, Office of Nuclear Material Safety and Safeguards U.S Nuclear Regulatory Commission Washington D.C. 20555-0001
Reference:
- 1) License SNM-42, Docket No. 70-27
Subject:
Revision to Chapter 2, Organization and Administration, of License SNM-42 License Application
Dear Sir or Madam:
(
BWXT Nuclear Operations Group, Inc., Lynchburg (BWXT NOG-L), forwards to the U. S.
Nuclear Regulatory Commission (NRC) the enclosed revision to Chapter 2, Organization and Administration, of the SNM-42 License Application (LA), in accordance with License Condition S-13. BWXT NOG-L has determined that the revisions, summarized below, meet the provisions as defined by License Condition S-13. A copy of the revised Chapter 2 of the LA is included in to this letter.
Section All Sections 2.1.7 Manager, Radiation Protection 2.1.8 Health Physicists 2.1.29 Director, Facilities Management &
Infrastructure Planning Department BWXT Nuclear Operations Group, Inc.
PO. Box 785 Lynchburg VA 24505 USA t + I 434 522.6000 www bwxt com Description of Change A number of grammatical and typographical changes were made through out the document.
All Staff "Manager" titles were changed to "Director" to reflect the position, as defined by BWX Technologies, Inc. (parent company)
The qualifications for manager were changed from five to three years. Additionally, wording was changed for degree needed for the position.
An additional set of qualifying conditions were added.
The other sections were slightly modified.
This Director position was added to the license. Some responsibilities previously under the Director of Operations are now under Facilities Management.
i)
People Strong INNDVATIDN DRIVEN >
This is a new Director level position that is over all 2.1.30 Director, Project Management Department project managers at BWXT.
Re-worded
- statement to for clarity.
Removed references to specific sections in order to 2.2.1.3, 2.2.2.3, 2.2.3.3, 2.2.4.3, 2.2.5.3 avoid confusion. Minor wording changes.
Organization Chart Updated to reflect the new departments License Condition S-13 states that BWXT NOG-L may make changes to the License Application that do not reduce the effectiveness of the License Application, without prior NRC approval, if the change meets criteria listed below:
The change does not decrease the level of effectiveness of the safety basis as described in the License Application.
The organizational changes do not change the function of BWXT's safety basis and do not reduce the effectiveness of the License Application. They are generally, clarifications. The change in qualification with regards to Health Physics are not directly related to the safety basis and align with the methodology of qualification(s) for a Nuclear Criticality Safety Engineer.
The change does not result in a departure from the approved methods of evaluation described in the License Application.
The organizational changes in Chapter 2 do not change approved methods of evaluation described in the License Application. The change in qualification with regards to Health Physics are not directly related to the evaluation methods described in the license. These methods are defined in various chapters of SNM-42 and Quality Work lnsfructions for individual contributors.
The change does not result in a degradation of safety.
The organizational changes to Chapter 2 do not change the function of safety application at the facility.
The change does not affect compliance with applicable regulatory requirements.
The changes do not affect compliance with the applicable regulatory requirements. The performance requirements of 10 CFR 70.61 are maintained.
The change does not conflict with an existing license condition.
The organizational changes to Chapter 2 do not conflict with the current license conditions.
Within six months after each change is made, the licensee would submit the revised chapters of the License Application to the Director, Office of Nuclear Material Safety and Safeguards, using an appropriate method listed in 10 CFR 70.S(a), and a copy to the appropriate NRC Regional Office.
The submittal of this letter satisfies this requirement.
If you have questions or require additional information, please contact Daniel Ashworth, Manager of Licensing and Safety Analysis, at dlashworth@bwxt.com or 434-522-5472.
Sincerely, Richard J. Freudenberger Director, Environment, Safety, Health & Safeguards BWXT Nuclear Operations Group, Inc. - Lynchburg Enclosure cc:
NRC, J. Downs, Senior Project Manager NRC, Resident Inspector NRC, Region II
ENCLOSURE 1 Revised Chapter 2 of the SNM-42 License Application (22 pages)
SNM-42 CHAPTER2 ORGANIZATION AND ADMINISTRATION
SNM-42, CHAPTER 2 ORGANIZATION AND ADMINISTRATION TABLE OF CONTENTS Chapter Title 2.0 2.1 Introduction Organizational Responsibilities, Authority, and Qualifications 2.1.1 General Manager 2.1.2 Director, Environment, Safety, Health & Safeguards Department 2.1.3 Manager, Nuclear Safety & Licensing 2.1.4 Manager, Licensing & Safety Analysis 2.1.5 Manager, Nuclear Criticality Safety 2.1.6 Nuclear Criticality Safety Staff 2.1.7 Manager, Radiation Protection 2.1.8 Health Physicists 2.1.9 Health Physics Front Line Manager at the L TC 2.1.10 Health Physics Technicians at the L TC 2.1.11 Radiation Control Front Line Managers 2.1.12 Radiation Control Technicians 2.1.13 Manager, Environmental Protection & Industrial Safety 2.1.14 Manager, Waste Operations 2.1.15 Manager, Industrial Health & Safety 2.1.16 Industrial Health & Safety Specialists 2.1.17 Manager, Environmental Engineering 2.1.18 Environmental Protection Engineers 2.1.19 Manager, Safety Culture & Learning 2.1.20 Manager, Safety Culture & Regulatory Training 2.1.21 Training Specialist 2.1.22 Manager, Nuclear Materials Control 2.1.23 Director, Engineering Department 2.1.24 Director, Quality Control Department 2.1.25 Manager, Quality Engineering 2.1.26 Director, Operations Department 2.1.27 Director, Uranium Processing and Research Reactors Department 2.1.28 Director, Security Department 2.1.29 Director, Facilities Management & Infrastructure Planning Department 2.1.30 Director, Project Management Department 2.1.31 Managers of Non-NOG-L Divisions 2.1.32 Committee Chairmen 2-1 2-1 2-1 2-1 2-2 2-2 2-2 2-3 2-4 2-4 2-5 2-5 2-5 2-6 2-6 2-7 2-7 2-7 2-8 2-8 2-9 2-9 2-9 2-9 2-9 2-10 2-10 2-10 2-11 2-11 2-11 2-12 2-12 2-12 Date: 7/23/2025 Page:
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CHAPTER2 ORGANIZATION AND ADMINISTRATION TABLE OF CONTENTS (Cont'd)
Chapter 2.2 2.3 Safety Committees 2.2.1 Change Review Board 2.2.2 ALARA Committee 2.2.3 Emergency Preparedness Committee 2.2.4 Safety Review Committee 2.2.5 Industrial Health & Safety Committee Approval Authority for Personnel Selection Figure 2-1: The Site Organization Chart Date: 7/23/2025 SNM-42, CHAPTER 2 2-12 2-12 2-14 2-15 2-16 2-17 2-18 2-19 Page:
2-ii
SNM-42, CHAPTER 2 2.0 Introduction 2.1 The basic safety philosophy of the site encompasses the commitment that license requirements will be literally complied with, and in the role of employer, that the company is responsible for providing employees with a safe work place. The site is committed to a Radiation Protection Program which strives to meet the ALARA (As Low As Reasonably Achievable) principle.
Each employee is responsible for obeying safety limits and instructions, whether posted, outlined in procedures, or presented in training sessions. The Front Line Manager is the company's first line safety representative and is primarily responsible for promoting and enforcing safety standards and proper work methods. Advisory and staff functions assist line management in the analyses of operations within their control and provide guidance in the establishment of safe working practices and adherence to controls.
The safety function has lines of authority separate from those of production. Therefore, safety positions are able to coordinate and assist management, supervision, and the individual employee by providing direction towards a total safety effort. The safety function consists of a complex program that includes review and approval of operations, comprehensive training, and a system of audits and overchecks.
Organizational Responsibilities, Authority, and Qualifications The functional organization responsible for nuclear criticality safety, radiation protection, industrial safety, emergency preparedness, and environmental protection is described below.
The managerial positions for areas where personnel work directly with licensed material are also described.
2.1.1 2.1.2 General Manager The General Manager has the ultimate responsibility for ensuring that operations at the Mt. Athos site are conducted safely and in compliance with applicable federal, state, and local regulations and license conditions. The General Manager shall oversee all Lynchburg facility operations. The General Manager shall delegate to his staff the various duties and responsibilities required to conduct day-to-day operations.
The General Manager shall be the Chairman of the Safety Review Committee.
The General Manager shall have a bachelor's degree and at least 10 years of management experience in a nuclear-related field of endeavor.
Director, Environment, Safety, Health & Safeguards Department The Director of the Environment, Safety, Health & Safeguards Department reports directly to the General Manager. The Director shall have overall responsibility for safety programs. Management authority and responsibility shall include Nuclear Safety & Licensing, Environmental Protection & Industrial Safety, Nuclear Material Control & Accountability, and Safety Culture & Learning. The Director shall have the authority to suspend any activity to ensure safety or compliance.
Date: 7/23/2025 Page: 2-1
2.1.3 2.1.4 SNM-42, CHAPTER 2 The Director of the Environment, Safety, Health & Safeguards Department shall have a bachelor's degree and at least six years' management experience in the nuclear industry.
Manager, Nuclear Safety & Licensing The Manager of Nuclear Safety & Licensing shall report directly to the Director of Environment, Safety, Health & Safeguards. The Manager shall have responsibility for the day-to-day plant safety in the fields of Radiation Protection and Nuclear Criticality Safety. Reporting to the Manager of Nuclear Safety & Licensing are the Manager of Licensing & Safety Analysis, the Manager of Nuclear Criticality Safety, and the Manager of Radiation Protection. The Manager of Nuclear Safety and Licensing shall have the authority to suspend any operation or activity that is judged to be unsafe or contrary to license conditions or other regulatory requirements.
The Manager of Nuclear Safety & Licensing shall have a bachelor's degree and at least six years in nuclear regulatory or safety-related responsibilities.
Manager, Licensing & Safety Analysis The Manager of Licensing & Safety Analysis reports to the Manager, Nuclear Safety
& Licensing. The Manager shall be responsible for directing the Integrated Safety Analysis process, documenting and reporting the results of the analysis and for Licensing activities. The Manager shall be responsible for the administration of License SNM-42 and for communication between the site and the U.S. Nuclear Regulatory Commission. The Manager shall have the authority to suspend activities which is judged to be unsafe or contrary to license or regulatory requirements.
The Manager of Licensing & Safety Analysis shall have a bachelor's degree and at least five years in nuclear regulatory or safety-related responsibilities.
2.1.5 Manager, Nuclear Criticality Safety The Manager of Nuclear Criticality Safety shall report to the Manager of Nuclear Safety & Licensing. The Manager shall be responsible for maintaining properly verified and validated calculational and evaluation capabilities in the area of nuclear criticality safety. The Manager shall be responsible for providing criticality safety evaluations and audits and for ensuring independent Quality Assurance (QA) checks for all evaluations and calculations.
The Manager of Nuclear Criticality Safety shall be responsible for administration of the nuclear criticality safety program including the posting of limits and controls, issuance of nuclear criticality safety procedures, the technical content of Nuclear Criticality Safety training, and inspection and surveillance of SNM handling and processing. The Manager shall have the authority to suspend activities which is judged to be unsafe or contrary to license or regulatory requirements.
Date: 7/23/2025 Page: 2-2
SNM-42, CHAPTER 2 The Manager of Nuclear Criticality Safety shall have a bachelor's degree in a physical science or engineering. The Manager must have at least two years' experience as a nuclear criticality safety engineer at the Lynchburg facility or at least three years' experience as a nuclear criticality safety engineer at another nuclear facility.
2.1.6 Nuclear Criticality Safety Staff Nuclear Criticality Safety Staff shall report to the Manager of Nuclear Criticality Safety. The NCS Staff is comprised ofNCS Engineers, Senior NCS Engineers, and NCS Engineers-in-Training. The Staff shall be responsible for NCS evaluations, calculations, quarterly audits and weekly inspections. Senior NCS Engineers shall perform QA checks of work performed by other NCS Staff members as directed by the Manager of Nuclear Criticality Safety. A Nuclear Criticality Safety Engineer-in-Training may independently perform quarterly audits and weekly inspections if approved by the Manager of Nuclear Criticality Safety. The Staff shall serve as team members for an Integrated Safety Analysis (ISA) in the area of criticality safety. The NCS Staff shall have the authority to suspend activities which they judge to be unsafe or contrary to license or regulatory requirements. An NCS Staff member shall have, as a minimum, a bachelor's degree in a physical science or engineering.
A Nuclear Criticality Safety Engineer must have met one of the following:
2.1.6.1 one year's experience as an NCS Engineer-in-Training performing NCS safety evaluations at the Lynchburg facility under the direct supervision of a qualified NCS Engineer or the Manager, Nuclear Criticality Safety, or 2.1.6.2 a Master's degree in physics or nuclear engineering and a minimum of six months' experience as an NCS Engineer-in-Training performing NCS safety evaluations at the Lynchburg facility under the supervision of a qualified NCS Engineer or the Manager, Nuclear Criticality Safety, or 2.1.6.3 two years' experience performing NCS safety evaluations in connection with SNM handling facilities, or 2.1.6.4 two years' experience performing reactor physics calculations and one year's experience performing NCS safety evaluations in connection with SNM handling facilities.
A Senior Nuclear Criticality Safety Engineer shall have, as a llllillmum, two additional years of experience (over and above that required of an NCS Engineer) performing NCS safety evaluations in connection with SNM handling facilities.
Date: 7/23/2025 Page: 2-3
SNM-42, CHAPTER 2 2.1.7 Manager, Radiation Protection 2.1.8 The Manager of Radiation Protection shall report to the Manager of Nuclear Safety
& Licensing. The Health Physics Front Line Manager, the Health Physicists and the Radiation Control Front Line Managers shall report to the Manager of Radiation Protection. The Manager of Radiation Protection shall be responsible for the protection of personnel, property, and the environment from contamination with radioactive materials, the protection of personnel from external radiation exposure, and the administration of an effective ALARA program. The Manager shall have the authority to suspend any activity that he judges to be contrary to good radiation protection practice or detrimental to the environment.
The Manager shall be responsible for the technical content of Radiation Protection Training programs.
The Manager of Radiation Protection shall have a BS/BA degree in science or engineering, and at least three years of experience in applied health physics in a program dealing with radiation safety problems similar to the one managed.
Health Physicists Health Physicists (HP) report to the Manager of Radiation Protection or the Health Physics Front Line Manager as appropriate. They shall be responsible for specific programs in the areas of personnel radiation protection, monitoring, and survey instrumentation, and environmental radiation protection. The Health Physicists shall establish programs for internal exposure control, environmental monitoring and emergency preparedness, external dosimetry and record keeping, facility contamination control, and radiation instrument calibration. They shall have the authority to suspend any activity that they judge to be contrary to good radiation protection practice or environmental radiation protection. Health Physicists shall perform as team members for an ISA in the areas of radiation protection.
A Health Physicist shall have, as a minimum:
2.1.8.1 a BS/BA degree in science or engineering, and at least two years' experience in applied health physics, or 2.1.8.2 a BS/BA degree in science or engineering, and one year's experience as a HP-in-Training at the Lynchburg facility under the direct supervision of a qualified HP or the Manager, Radiation Protection 2.1.8.3 a Master's in Health Physics, and six months' experience as a HP-in-Training at the Lynchburg facility under the direct supervision of a qualified HP or the Manager, Radiation Protection Date: 7/23/2025 Page: 2-4
SNM-42, CHAPTER 2 2.1.9 Health Physics Front Line Manager at the LTC The Health Physics Front Line Manager at the Lynchburg Technology Center
("L TC") shall report to the Radiation Protection Manager. The Health Physicists and the Health Physics Technicians at the L TC shall report to the Radiation Protection Manager. The Health Physics Front Line Manager shall be responsible for the radiation protection program as it relates to activities at the LTC. The Front Line Manager shall have the authority to suspend any activity that is judged to be unsafe, contrary to license conditions, or contrary to good radiation protection practice.
The LTC Health Physics Front Line Manager shall have a bachelor's degree in physical science or engineering and at least five years' experience as a health physicist.
2.1.10 Health Physics Technicians at the LTC Health Physics Technicians at the L TC shall report to the Health Physics Front Line Manager. They perform radiation and contamination surveys, perform calibration of radiation detection instruments, collect and issue personnel dosimetry devices, perform routine plant inspections and implement the air-sampling program.
The LTC Health Physics Technicians shall be trained in the aspects of radiation protection needed to properly conduct their job. This training shall be provided and established by the Manager, Radiation Protection. The Health Physics Technicians shall be under the direct supervision of a qualified individual until all of the necessary training is completed and Radiation Protection management is satisfied with the technician's performance. Previous direct experience can be used to determine the amount and extent of training necessary.
2.1.11 Radiation Control Front Line Managers Radiation Control Front Line Managers shall report to the Manager, Radiation Protection. They shall be responsible for directing and coordinating the activities of the radiation control technicians. They shall review the results of the technicians' daily activities and assist in the resolution of problems.
The Radiation Control Front Line Managers shall have formal training related to the functional duties within the radiation control areas, i.e., environmental protection, bioassay, contamination control, instrument calibration, etc., and four years' technical and supervisory experience in the radiation control field.
Date: 7/23/2025 Page: 2-5
SNM-42, CHAPTER 2 2.1.12 Radiation Control Technicians Radiation Control Technicians shall report to the Radiation Control Front Line Managers. Radiation Control Technicians perform radiation and contamination surveys, perform calibration of radiation detection instruments, collect and issue personnel dosimetry devices, perform routine plant inspections and implement the air sampling program. They also perform inspections of radiation and criticality safety activities by observing conditions and acts of people in the areas.
The Radiation Control Technicians shall be trained in the aspects of radiation control needed to properly conduct their job. This training shall be provided and established by the Manager, Radiation Protection. The Radiation Control Technicians shall be under the direct supervision of a qualified individual within the Radiation Control Section until all of the necessary training is completed and Radiation Protection management is satisfied with the technician's performance. Previous direct experience can be used to determine the amount and extent of training necessary. They shall also be trained in the Nuclear Criticality Safety requirements of operations to the extent necessary to perform inspections.
2.1.13 Manager, Environmental Protection & Industrial Safety The Manager of Environmental Protection & Industrial Safety shall report directly to the Director of Environment, Safety, Health & Safeguards. The Manager shall have responsibility for the day-to-day plant safety in the fields of Environmental Protection and Industrial Safety. The Manager shall have the authority to suspend any activity that in their judgment poses an unnecessary risk to employees, the environment, or to facility safety.
The Manager shall be responsible for emergency preparedness, emergency equipment maintenance, and coordination of emergency team activities and assigning the Emergency Preparedness Officer (EPO), an Industrial Safety Specialist, who performs the duties of the EPO described in the Emergency Plan.
The Manager shall be responsible for monitoring the Environmental Protection program to ensure compliance with local, State, and federal regulations relative to the non-radiological aspects of the control of air emissions, waste water treatment, solid waste management and the storage and transportation of hazardous materials. In addition, the Manager is responsible for directing engineering changes to facilities to meet these requirements.
The Manager of Environmental Protection & Industrial Safety shall have a bachelor's degree and at least six years in environmental, regulatory or safety-related responsibilities.
Date: 7/23/2025 Page: 2-6
SNM-42, CHAPTER 2 2.1.14 Manager, Waste Operations The Manager of Waste Operations shall report to the Manager of Environmental Protection & Industrial Safety. The Manager shall be responsible for overseeing operations of the wastewater treatment facility and the solid waste treatment facilities.
The Manager shall be responsible for ensuring that safety limits and controls are followed. The Manager shall have the authority to suspend operations if necessary.
The Manager shall be responsible for obtaining approval per section 11.1 before altering processes or equipment or installing new processes or equipment that affect nuclear criticality safety, radiation protection, or license conditions.
The Manager of Waste Operations shall have a bachelor's degree and three years' experience in a waste treatment operation or related field.
2.1.15 Manager, Industrial Health & Safety The Manager of Industrial Health & Safety shall report to the Manager of Environmental Protection & Industrial Safety. The Manager shall be responsible for the industrial health and safety programs. The Manager shall be responsible for the protection of plant personnel, equipment and material from fire and chemical hazards.
The Manager shall be responsible for training in fire protection, chemicals, and hazardous materials. The Manager shall have the authority to suspend any activity that in their judgment poses an unnecessary risk to employees, the environment, or to facility safety.
The Manager oflndustrial Health & Safety shall have a bachelor's degree in industrial safety or industrial hygiene (or equivalent) and at least three years' experience in industrial safety, industrial hygiene, or fire protection.
2.1.16 Industrial Health & Safety Specialists Industrial Health & Safety Specialists shall report to the Manager oflndustrial Health
& Safety, except for the Emergency Preparedness Officer, who reports to the Manager of Environmental Protection and Industrial Safety. They shall provide technical support in the areas of Fire Protection, Industrial Safety, Chemical Safety, Industrial Hygiene and Emergency Preparedness. Industrial Health & Safety Specialists shall establish programs for chemical exposure monitoring, hazardous materials, emergency response, hearing conservation, fire protection, respiratory protection (for non-radioactive hazards) and personal protective equipment, asbestos abatement, recordkeeping, general safety audits, OSHA compliance, accident investigation, and work-place environmental monitoring. Industrial Health & Safety Specialists shall perform as team members for an ISA in the areas of fire protection and chemical safety. With regards to team member experience for Chemical and Fire related ISA meetings, the complexity of the process modification is taken into consideration to ensure that experienced engineers are utilized for participation in these meetings.
Engineers that are assigned either have training or experience commensurate with Date: 7/23/2025 Page: 2-7
SNM-42, CHAPTER 2 the type of hazards that may be present and may consult with engineers who are subject matter experts.
They shall have the authority to suspend any activity that in their judgment poses an unnecessary risk to employees, the environment, or to facility safety.
An Industrial Health & Safety Specialist shall possess, as a minimum:
2.1.16.1 2.1.16.2 2.1.16.3 2.1.16.4 2.1.16.5 2.1.16.6 A bachelor's degree in Fire Protection or Fire Protection Engineering, or A bachelor's degree in Industrial Safety or Safety Engineering, or A bachelor's degree in Industrial Hygiene or Occupational Health &
Safety, or A bachelor's degree in a physical science, course work in Industrial Safety, Industrial Hygiene, or Fire Protection, and one year's experience in Safety Program Administration, or A non-degreed safety professional with 5 years' experience in industrial or regulatory safety positions.
For these individuals to perform an ISA, they must have experience in fire protection and chemical safety commensurate with the process being evaluated.
2.1.17 Manager, Environmental Engineering The Manager of Environmental Engineering shall report to the Manager of Environmental Protection & Industrial Safety. The Manager shall be responsible for monitoring the Environmental Protection program to ensure compliance with local, State, and federal regulations relative to the non-radiological aspects of the control of air emissions, waste water treatment, solid waste management and the storage and transportation of hazardous materials. In addition, the Manager shall be responsible for directing engineering changes to facilities to meet these requirements. The Environmental Protection Engineers shall report to the Manager.
The Manager of Environmental Engineering shall have a bachelor's degree in Chemistry, Biology, Engineering or a related subject and at least three years' experience in environmental protection.
2.1.18 Environmental Protection Engineers Environmental Protection Engineers shall report to the Manager of Environmental Engineering. They shall provide technical support for air permitting, wastewater permitting, pollution prevention, solid waste management and waste treatment operations.
Date: 7/23/2025 Page: 2-8
SNM-42, CHAPTER 2 Environmental Protection Engineers shall have a bachelor's degree in a physical science, course work in the physical sciences and one year's experience.
2.1.19 Manager, Safety Culture & Learning The Manager of Safety Culture & Learning shall report to the Director of Environment, Safety, Health & Safeguards. The Manager shall have responsibility for the day-to-day plant safety in the fields of Safety Culture & Regulatory Training and Workforce Development & Training. Reporting to the Manager is the Manager of Safety Culture & Regulatory Training. The Manager shall have the authority to suspend activities which are judged to be unsafe or contrary to license or regulatory requirements.
The Manager of Safety Culture & Learning shall have a bachelor's degree and at least six years in nuclear regulatory or safety-related responsibilities.
2.1.20 Manager, Safety Culture & Regulatory Training The Manager of Safety Culture & Regulatory Training reports to the Manager, of Safety Culture & Learning. The Manager shall be responsible for administering nuclear safety training. The Manager shall have the authority to suspend activities which are judged to be unsafe or contrary to license or regulatory requirements.
The Manager of Safety Culture & Regulatory Training shall have a bachelor's degree and at least five years in nuclear regulatory or safety-related responsibilities.
2.1.21 Training Specialist The Training Specialist shall report to the Manager of Safety Culture & Regulatory Training.
This position shall be responsible for nuclear related safety training activities.
The Training Specialist shall have a high school degree and seven years related experience in the nuclear field, a two-year degree with four years related experience in the nuclear field, or a bachelor's degree with two years related experience in the nuclear field.
2.1.22 Manager, Nuclear Materials Control
Reference:
Fundamental Nuclear Material Control Plan, §4.1.1.
2.1.23 Director, Engineering Department The Director of the Engineering Department shall report to the General Manager. The Director shall have the overall safety responsibility for the various operations under his direction. The Director shall be responsible for ensuring that safety limits and controls are followed. The Director shall have the authority to suspend operations if Date: 7/23/2025 Page: 2-9
SNM-42, CHAPTER 2 necessary. The Director shall be responsible for obtaining approval per section 11.1 before altering processes or equipment or installing new processes or equipment that affect nuclear criticality safety, radiation protection, industrial health & safety, or license conditions.
The Director of the Engineering Department shall have a bachelor degree and six years' management experience in a nuclear-related field. The Director must have a sufficient background in plant operations to provide the capability for making sound safety decisions.
2.1.24 Director, Quality Control Department The Director of the Quality Control Department shall report to the General Manager.
The Director shall be responsible for the Quality Control and Quality Assurance Programs. The Director shall have the overall safety responsibility for the various operations under their direction. The Director shall be responsible for ensuring that safety limits and controls are followed. The Director shall have the authority to suspend operations if necessary. The Director shall be responsible for obtaining approval per section 11.1 before altering processes or equipment or installing new processes or equipment that affect nuclear criticality safety, radiation protection, industrial health & safety or license conditions.
The Director of the Quality Control Department shall have a bachelor's degree and six years' management experience in a nuclear-related field. The Director must have a sufficient background in plant operations to provide the capability for making sound safety decisions.
2.1.25 Manager, Quality Engineering The Manager of Quality Engineering shall report to the Director of Quality Control.
The Manager shall be responsible for overseeing the QA audit program.
The Manager of Quality Engineering shall have a bachelor's degree and three years' management experience, or equivalent work experience including a minimum of ten years' NOG-L management experience. The Manager of Quality Engineering shall also have sufficient background in plant operations to provide the capability of oversight of the Quality Audit function.
2.1.26 Director, Operations Department The Director of the Operations Department shall report to the General Manager. The Director shall have the overall safety responsibility for the various operations under their direction. The Director shall be responsible for ensuring that safety limits and controls are followed. The Director shall have the authority to suspend operations if necessary. The Director shall be responsible for obtaining approval per section 11.1 before altering processes or equipment or installing new processes or equipment that affect nuclear criticality safety, radiation protection, or license conditions.
Date: 7/23/2025 Page: 2-10
SNM-42, CHAPTER 2 The Director, Operations shall have a bachelor degree and six years' management experience in a nuclear-related field. The Director must have a sufficient background in plant operations to provide the capability for making sound safety decisions.
2.1.27 Director, Uranium Processing and Research Reactors Department The Director of the Uranium Processing and Research Reactors Department shall report to the General Manager. The Director shall be responsible for operations in Recovery, downblending, uranium fuel fabrication, Research Test Reactors, R&D and associated reclamation. The Director shall have the authority to suspend operations if necessary. The Director shall be responsible for obtaining approval per section 11.1 before altering processes or equipment or installing new processes or equipment that affect nuclear criticality safety, radiation protection, or license conditions.
The Director of the Uranium Processing and Research Reactors Department shall have a bachelors' degree and six years' management experience in a nuclear-related field. The Director must have a sufficient background in plant operations to provide the capability for making sound safety decisions.
2.1.28 Director, Security Department The Director of the Security Department shall report to the General Manager. The Director shall have overall responsibility for Security. The Director shall have the authority to suspend any activity to ensure security and compliance.
The Director of the Security Department shall have at least a bachelors' degree and six years' management experience at a nuclear facility, or related field.
2.1.29 Director, Facilities Management & Infrastructure Planning Department The Director of the Facilities Management & Infrastructure Planning Department shall report to the General Manager. The Director shall have the overall safety responsibility for the various operations under their direction. The Director shall be responsible for ensuring that safety limits and controls are followed. The Director shall have the authority to suspend operations if necessary. The Director shall be responsible for obtaining approval per section 11.1 before altering processes or equipment or installing new processes or equipment that affect nuclear criticality safety, radiation protection, or license conditions.
The Director, Facilities Management & Infrastructure Planning shall have a bachelor degree and six years' management experience in a nuclear-related field. The Director must have a sufficient background in plant operations to provide the capability for making sound safety decisions.
Date: 7/23/2025 Page: 2-11
SNM-42, CHAPTER 2 2.1.30 Director, Project Management Department The Director of the Project Management Department shall report to the General Manager.
The Director shall be responsible for the Project Management and Production Control Programs. The Director shall have the overall safety responsibility for the various operations under his direction. The Director shall be responsible for ensuring that safety limits and controls are followed. The Director shall have the authority to suspend operations if necessary. The Director shall be responsible for obtaining approval per section 11.1 before altering processes or equipment or installing new processes or equipment that affect nuclear criticality safety, radiation protection, industrial health & safety or license conditions.
The Director, Project Management shall have a bachelor's degree and six years' management experience in a nuclear-related field. The Director must have a sufficient background in plant operations to provide the capability for making sound safety decisions.
2.1.31 Managers ofNon-NOG-L Divisions Managers at the Mt. Athos site from non-NOG-L divisions shall report functionally to the General Manager for the purposes of safety and compliance with regulations and with the license while operations under their direction are being conducted in areas covered by this application. They shall have the overall safety responsibility for operations under their direction. They shall have the authority to suspend operations if necessary. They shall be responsible for obtaining approval per section 11.1 before altering process or equipment or installing new process or equipment that affect nuclear criticality safety, radiation protection, or license conditions.
Managers from Non-NOG-L Divisions shall have a bachelor's degree and sufficient background in plant operations to provide the capability for making sound safety decisions.
2.1.32 Committee Chairmen Chairmen of committees described in Chapter 2 shall have at least a bachelor's degree and two years' experience in the nuclear industry.
2.2 Safety Committees 2.2.1 Change Review Board 2.2.1.1 Purpose Date: 7/23/2025 The Change Review Board (CRB) shall review and approve changes or additions to processes or equipment that involve the use oflicensed material and could significantly affect its safety or the safety of personnel.
Page: 2-12
SNM-42, CHAPTER 2 2.2.1.2 Meeting Frequency The CRB shall meet as often as necessary to review and approve proposed changes.
2.2.1.3 Membership The membership of the CRB shall consist of the following, as a minimum:
Chairman - A manager, appointed by the General Manager.
Member -
Manager, Nuclear Safety & Licensing Member -
Manager, Environmental Protection & Industrial Safety
- Member - Section Manager from Operations and/or Facilities Mgmt.
Infrastructure Planning
- Member - Section Manager from Engineering
- Member - Manager(s) representing Non-NOG-L Divisions for changes in operations under their control.
- The non-NOG-L Division Manager(s) can substitute for Operations and Engineering when changes to non-NOG-L processes and equipment are to be approved.
Alternates for any of the above positions are designated by position, procedure or in writing to the Chairman by the member.
A Vice-Chairman shall be appointed in writing by the General Manager.
2.2.1.4 Quorum Full attendance is required for approval of proposed changes.
2.2.1.5 Records and Reports Date: 7/23/2025 Meeting minutes shall be maintained on file for three years. Summary reports of committee activities shall be presented to the Safety Review Committee for their review and recommendations, if appropriate. If actions are required, they shall be tracked to completion.
Page: 2-13
SNM-42, CHAPTER 2 2.2.2 ALARA Committee 2.2.2.1 Purpose The ALARA Committee shall ensure development and implementation of the ALARA program. The Committee shall accomplish this by establishing goals and objectives for implementing the ALARA philosophy; establishing a system to measure the success of program goals and objectives; and periodically reviewing results and implementing corrective actions when attainment of specific objectives appears to be jeopardized.
2.2.2.2 Meeting Frequency The ALARA Committee shall meet at least once each calendar quarter.
2.2.2.3 Membership ALARA Committee membership shall consist of the following, as a mlillllum:
Chairman -
Vice Chairman -
Member-Member-Member-Member-Member-Member-Appointed by the General Manager Manager, Nuclear Safety & Licensing Representative of Radiation Protection Representative of Engineering Representative Operations and/or Facilities Infrastructure Planning Representative of Environmental Protection Representative of Nuclear Materials Control L TC Health Physics Front Line Manager Mgmt.
Alternates for any of the above members shall be designated in writing to the Chairman by the member.
2.2.2.4 Quorum A quorum shall consist of the Chairman or Vice Chairman and a simple majority of the members.
2.2.2.5 Records and reports Date: 7/23/2025 Meeting minutes shall be maintained on file for at least three years.
Summary reports of committee activities shall be presented to the Safety Review Committee for their review and recommendations, if appropriate.
If actions are required, they shall be tracked to completion.
Page: 2-14
SNM-42, CHAPTER 2 2.2.3 Emergency Preparedness Committee 2.2.3.1 2.2.3.2 2.2.3.3 2.2.3.4 2.2.3.5 Date: 7/23/2025 Purpose The Emergency Preparedness Committee (EPC) shall oversee and direct implementation of the emergency plan.
Meeting Frequency The EPC shall meet at least once each calendar quarter.
Membership Membership of the EPC shall consist of the following, as a minimum:
Chairman -
Appointed by the General Manager Vice Chairman - Manager, Environmental Protection & Industrial Safety Member -
Representative of Licensing & Safety Analysis Member -
Representative of Nuclear Criticality Safety Member -
Representative of Radiation Protection Member -
Representative of Industrial Health and Safety Member -
Representative of Environmental Protection Member -
Representative oflndustrial Engineering Member -
Representative of Security Member -
Representative of Nuclear Materials Control Member -
Representative of Waste Operations Alternates for any of the above members shall be designated in writing to the Chairman by the member.
Quorum A quorum shall consist of the Chairman or Vice Chairman and a simple majority of the members.
Records and reports Meeting minutes shall be maintained on file for at least three years.
Summary reports of committee activities shall be presented to the Safety Review Committee for their review and recommendations, if appropriate.
If actions are required, they shall be tracked to completion.
Page: 2-15
SNM-42, CHAPTER 2 2.2.4 Safety Review Committee 2.3.4.1 2.2.4.2 2.2.4.3 2.2.4.4 Date: 7/23/2025 Purpose The Safety Review Committee shall assess the adequacy and effectiveness of the safety programs at the Site, especially those that relate to nuclear criticality safety and radiation protection. The Safety Review Committee shall also review the effectiveness of the other safety committee activities and recommend actions to correct weaknesses.
Meeting Frequency The Safety Review Committee shall meet at least once each calendar quarter.
Membership The following individuals shall be members of the Safety Review Committee:
Chairman -
Vice Chairman -
Member-Member Member Member-Member Member-Member-Member-Member-Member-General Manager Director, Environment, Safety, Health & Safeguards Director, Security Department Director, Uranium Processing and Research Reactors Department Director, Quality Control Department Director, Operations Department and/or Facilities Mgmt. Infrastructure Planning Director, Engineering Department Chairman, ALARA Committee Chairman, EPC Chairman, CRB Chairman, Industrial Health & Safety Committee Selected representative(s) from Non-NOG-L Divisions working at the site Alternates for any of the above members are designated by position, procedure, or in writing to the Chairman by the member.
Quorum A quorum shall consist of the Chairman or Vice Chairman and a simple majority of the members.
Page: 2-16
SNM-42, CHAPTER 2 2.2.4.5 Records Committee records shall be kept on file for at least three years.
2.2.5 Industrial Health and Safety Committee 2.2.5.1 Purpose 2.2.5.2 2.2.5.3 The Industrial Health and Safety Committee shall assess the adequacy and effectiveness of the Health and Safety programs at the Site, especially those that relate to fire protection and chemical safety.
Meeting Frequency The Industrial Health and Safety Committee shall meet at least once each calendar quarter.
Membership The following individuals shall be members of the Industrial Health and Safety Committee:
Chairman -
Vice Chairman -
Member-Member-Member-Member-Member-Member-Member-Member-Member-Appointed by General Manager Manager, Environmental Protection & Industrial Safety Manager, Industrial Health & Safety Representative of Uranium Processing and Research Reactors Representative of Industrial Engineering Representative of Operations and/or Facilities Mgmt.
Infrastructure Planning Representative of Environment, Safety, Health, &
Safeguards Representative ofRTRT Representative of Quality Control Representative of Security Selected representative(s) from Non-NOG-L Divisions working at the site Alternates for any of the above members shall be designated in writing to the Chairman by the member.
2.2.5.4 Quorum Date: 7/23/2025 A quorum shall consist of the Chairman or Vice Chairman and a simple majority of the members.
Page: 2-17
SNM-42, CHAPTER 2 2.2.5.5 Records Committee records shall be kept on file for at least three years.
2.3 Approval Authority for Personnel Selection The following managers shall be appointed by the General Manager:
- Director, Environment, Safety, Health & Safeguards Department
- Director, Security Department
- Director, Uranium Processing and Research Reactors Department
- Director, Quality Control Department
- Director, Engineering Department
- Director, Operations Department
- Director, Facilities Management & Infrastructure Planning Department
- Director, Project Management Department Other managers specified in Section 2 shall be appointed by their respective Director.
Date: 7/23/2025 Page: 2-18
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