ML20245E951

Forwards Request for Addl Info Re 890307 Application for Amend to License SNM-1067,for Response within 20 Days. Definition Not Clear as to Which Positions Perform Initial Analysis & Independent Review

ML20245E951
Person / Time
Site:	07001100
Issue date:	06/20/1989
From:	Brinkman G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Waterman C ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
References
NUDOCS 8906280001
Download: ML20245E951 (4)

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JUN 2 01989 Docket No. 70-1100 License No. $hM-1067 Combustion Engineering, Inc.

ATTN: Mr. C. R. Waterman, Vice President and General Manager Nuclear Fuel Manufacturing

.1000 Prospect Hill Road Windsor, Connecticut 06095 0500 Gentlemen:

The purpose of this letter is to express our concern regarding your untimely response to our comments.on the organizational amendment application dated March 7,.1989. The above-mentioned comments were presented to your staff at a meeting at NRC headquarters on April 17, 1989. At that time, Combustion Engineering agreed to revise and resubmit, in a timely manner, portions of the application.

The enclosure to this letter identifies several issues which require additional information. Please submit your response in the form of carefully revised re-placement pages to the application within 20 days of the date of this letter.

We will continue our review of this amendment application upon receipt of this information. If you do not respond within the specified time, we will consider the application to be abt.ndoned. If there are any questions regarding this matter, please contact Dave McCaughey of my staff at (301) 492 0669.

Sincerely, Original signod P/

Georgo H. Eldingr 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 i Nuclear Licensing Washington Nuclear Operations )

Mr. P. L. McGill, Vice President Mr. R. E. Sheeran, Manager Nuclear Fuel Accountability and Security Distribution w/encls . . . .

.. _ l G Docket 70 1100~- "PDRt c >LNRC' File Center 3 NMSS R/F IMUF R/F l IMSB R/F VLTharpe JRoth, RI Region I MHorn '

GHBidinger SSoong DAMcCaughey (2)

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DATE:6/li/89 6/d/89 6/+0/89

$ I 8906280001 890620 0FFICIAL RECORD COPY ~ "gd3 i PDR ADOCK 07001100 C PDC  ;

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REQUEST FOR ADDITIONAL INFORMATION AMENDMENT APPLICATION REVISION DATED MARCH 7, 1989 COMBUSTION ENGINEERING, INC.

DOCKET NO. 70-1100 Part I No. Section Comment

1. 2.1.4 This section states that the Senior Criticality Specialist serves as the second reviewer for criticality evaluations performed by the Nuclear Criticality Specialist (first reviewer).

However, SEction 2.1.7. states that an ,

individual with the qualifications of a Nuclear Safety Analyst shall serve as the independent reviewer for criticality calculations. There is no clear definition as to which position performs the initial analysis and which performs the independent review. Please clarify.

2. 2.2.1 These sections have unilaterally included 2.2.2 substitute qualifications in lieu of a technical 2.2.3 degree. This type of substitution is not 2.2.5 acceptable for positions responsible for making 2.2.8 decisions affecting health and safety. In '

2.2.9 situations where the licensee believes that an 2.2.11 individual not meeting the position qualifications 2.2.12 could perform the duties of a particular position, an exception to the position qualification criteria should be requested. An appropriate justification should accompany that request.

3. 2.2.5 The staff is greatly concerned with the minimum qualifications established in this section. These qualifications are inadequate to safely perform the duties described in Section 2.1.5. Reevaluate the minimum qualifications for this position.

4. 2.2.6 The 2 years of experience required in this section should be experience as a Nuclear Criticality Analyst.

5. 2.2.10 This section reflects two separate sets of minimum qualifications. Typical minimum qualifications for a technician are a high school diploma and a minimum of 1 year experience following certification in a technician trainee program. A senior technician

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.would be an individual with.a minimum of 1 year Et experience as a technician plus certification in a training program for a specific technician position. Clarify the minimum qualifications for these positions.

6.- 2.3 Include the commitment that proceedings and

, recommendations of each quarterly Facility _ Review Group (FRG) meeting be reported in writing to the Vice President & General Manager, Nuclear Fuel

. Manufacturing.

7. 2.3- Proposed operations should be' included in the FRG quarterly review.

8. 2.5.3 This section states that training records will v-be retained for the' duration of an individual's employment or when an individual.no longer requires access to controlled areas. ' Confirm that these training records are maintained for the duration of an individual's employment or a minimum of 2 years, whichever is greater.

9, 2.6 This section states that temporary changes can be made to safety-related operating procedures on the approval of the cognizant line manager so long as the changes do not alter existing safety limits. However, there is no assurance that the cognizant line manager is qualified to make the determination whether or not safety ,

limits'are altered. Confirm that the Manager of.

Radiological and Industrial Safety and Nuclear Criticality Safety Specialist are included in this hpproval process.

10. 2.6 Provide ' commitment that written procedures that affect cadiation and nuclear criticality safety (nuclear safety) will include limits and controls which are required for nuclear safety of the activity.

11. - 2.6 This section states that safety-related procedures are approved by the cognizant line manager and the Manager of Radiological Protecticn and Industrial Safety. In addition to these approvals, it is necessary that a nuclear criticality safety l approval be included.

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2.6- A commitment should be provided for periodic review of safety-related operating procedures.

A typical review should be conducted by line and nuclear safety management at least every 2 years.

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13. '2.7.1 In addition to the. routine daily inspections conducted by the technicians, monthly inspections shoulo be performed by persons having the minimum qualifications of Nuclear i Criticality Safety Specialist and Manager of Radiological Protection and Industrial Safety. lr Written reports and records of followup actions '

should be provided to appropriate line' managers and the facility review group. These inspections .,

should follow written procedures as approved by i the Program Manager, Radiological and Industrial {

Safety, (PMRIS) and Senior Criticality Specialist i (SCS). These monthly inspections should be i conducted on all working shifts every 3 months.

14. 2.7.2 Audits should be conducted quarterly by-individuals having the minimum qualifications of i the PMRIS and SCS. I 4

15. CE should maintain the annual review by the i Nuclear Safety Committee to provide oversight for j the FRG until such time that the FRG demonstrates  ;

its effectiveness.  ;

PART 11

1. 3.2 Provide resumes for the Senior Criticality Specialist, Industrial Safety Specialist, and {

Nuclear Criticality Analyst. 1 1

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