ML20141C293

Forwards Response to 970417 Request for Addl Info Re Amend Request for FOL R-108.Encl Includes Changes Proposed for Amend 7 & Explanation for Question Raised in NRC Ltr

ML20141C293
Person / Time
Site:	Dow Chemical Company
Issue date:	06/16/1997
From:	Rigot W DOW CHEMICAL CO.
To:	Alexander Adams NRC (Affiliation Not Assigned)
References
NUDOCS 9706250091
Download: ML20141C293 (4)

Text

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I 4 l The Dow Chemical Company June 16,1997 udand Mcngan 48c67 Mr. Alexander Adams, Jr., Senior Project Manager Non-Power Reactor and Decommissioning Project Directorate Division of Project Support Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission  !

Dear Mr. Adams  ;

1 Enclosed is the response to your request for additional information regarding our amendment request for Facility Operating License R-108; letter dated April 17,1997.

The enclosure includer the changes proposed for amendment No. 7 and an explanation for the question raised in your letter. If you have any questions regarding this review, please contact me at (517) 636-6584.

Regards d ;L h

Ward L. Rigot Reactor Supervisor Dow TRIGA Research Reactor The Dow Chemical Company SUBSCRIBEDTO AND SWORN BEFoRE ME THISkDAYOF b(Lf/I_19 7 (

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1. Figure 6.1 has been modified to show the separation of the operations and safety arms i of the reactor's administration. The license is held by the radiation safety committee l

(RSC) which is chaired by The manager of Industrial Hygiene Research and' Technology. This person serves as a Level 1 manager as described in ANSI /ANS ,

15.1-1990. In addition, Operations report to a Senior Research Manager within Analytical Sciences I,aboratories. The Radiation Safety Committee is responsible for all aspects of radiation safety including issues related to the TRIGA reactor. For -

issues related to radiation safety the operations arm of the organization reports through the Senior Research Manager within Analytical Sciences Laboratories to the  :

l Radiation Safety Committee. The person responsible for reactor facility operations is the Facility Director and the person responsible for day-to-to day operation of the reactor is the reactor supervisor. The role of Facility Director and Reactor Supervisor .

l. may be filled by the same person.

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)_ 2. The Reactor Operations Committee reports to The Senior Research Manager within Analytical Sciences Laboratory. Members of the committee not required by the -

Technical Specifications (i.e. Radiation Safety Officer and Reactor Supervisor) are ,

appointed by This Level 1 manager.

3. The Radiation Safety Officer conununicates with the Level 3 management ( Reactor Supervisor) and this reporting line has been added. The radiation safety function reports through The Manager, Industrial Hygiene Research and Technology, a level 1 manager,

4. Section 6.1.1. has been modified to show consistency with the change noted in 1.

i Above. This change designates the Level 1 management representative as the member of the R.O.C.

5. Section 6.1.2. has been modified to acknowledge the fact the Reactor Supervisor and Facility Director may be the same person and that in this case the Level 1 l management representative appoints the Reactor Supervisor and has line management responsibilities for this individual.

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6. Section 6.2.1. has been modified to acknowledge the fact the Reactor Supervisor and Facility Director may be the same person and that in this case the Level 1 management representative will serve as the chairperson of the R.O.C.

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6. ADMINISTRATIVE CONTROLS j;

i 6.1.Oreanization The Dow TRIGA Research Reactor is owned and operated by The Dow Chemical Company.

The reactor i, administered and operated through the Analytical Sciences Laboratory of the Michigan Division of Dow Chemical USA and is located in 1602 Building of the Analytical Sciences Laboratory at the Midland, Michigan location of the Michigan Division.

6.1.1, Structure l

The structure of the administration of the reactor is shown in figure 6.1. This j l

structure cuts across the lines of management of The Dow Chemical Company.

l The individual responsible for radiation safety is the Radiation Safety Officer for the reactor who reports on matters of radiation safety to the Radiation Safety Committee and to the Reactor Operations Committee. The Radiation Safety committee

oversees the radiation safety program and is responsible for its implementation. The

! review and audit functions are performed by the Reactor Operations Committee which l is composed of at least four persons including a manager within Analytical Sciences Laboratory, the Radiation Safety Officer, and the Reactor Supervisor.

6.1.2. Responsibility l

The day-to-day responsibility for the safe operation of the reactor rests with the Reactor Supervisor.who is a licensed Senior Reactor Operator appointed by the I Facility Director or manager within Analytical Sciences Laboratory. The Reactor l Supervisor may appoint equally-qualified individuals, upon notification of the l Facility Director and the Reactor Operations Committee, to assume the responsibilities of the Reactor Supervisor. The Reactor Supervisor reports in a management sense to the Facility Director and within the reactor organization to the Reactor Operations Committee.

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1 Anundnwn No.7

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Figure 6.1. Administration l

l l Manager, Industrial Hygiene Research and Radiation Safety Senior Research 4 Manager Technology Committee Chair R.O.C.

Chair. RSC

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_J -+ racility I 1I 1IIF Director I

1r l Reactor Operations Supervisor, l Conimittee (ROC) 9 I Industrial l j

Hygiene l 4 g

-- p Reactor Supervisor l l l

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Radiation Safety Officer 4_ _ ] l Licensed SROs and ROs  ;

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I Line management responsibilities i

j Line Management Reporting l ---- Communication Reporting I'

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A Anendnent No. 7

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