ML20198C141

Forwards Comments & Request for Info on 860210 Application to Amend License SNM-1168 Discussed During 860311 Visit

ML20198C141
Person / Time
Site:	07001201
Issue date:	05/16/1986
From:	Ketzlach N NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Watters J BABCOCK & WILCOX CO.
References
NUDOCS 8605220232
Download: ML20198C141 (5)

Text

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- WY MAY I 61986 FCUP:NK 70-1201

' Babcock & Wilcox Comercial Nuclear Fuel Plant ATTN: ' Mr. J. P. Watters License and Control Administrator P.O. Box 11646 Lynchburg,~ Virginia 24506-1646 Gentlemen:

Enclosed are our comments on your amendment application dated February 10,.

'1986, which were discussed with you during our visit on March 11, 1986. These comments are in addition to other comments that you noted during our discussion.

Further action will be.taken on your amendment application upon receipt of the requested information. If you have any questions, you may call me at 301-427-4510..

Sincerely, Drig N 1signedDy*

Norman Ketzlach Uranium Process Licensir.g Section Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, NMSS

Enclosure:

As stated Distribution w/ encl ALSoong MAYoung GLTroup, RII Region II ..

eDocket:70-12014 NMSS R/F ~

e605220232 860516 FCUP R/F PDR ADOCK 07001201 VLTharpe PDR LCobb,IE PDR OFC: FCUP  : FCUF FCU  :  :  :  :

______g- ___________(____q NAME:NKetzlach/ks: WTCrod  : VLTharpe:  :  :  :

DATE / 86 / t /86 h/86 0FFICIAL RECORD COPY

e Comments on Amendment Application Dated February 10, 1986 I. Attachment I

1. Provide an organization chart that clearly outlines the reporting chain for all safety-and production-related functions (e.g., production control, health-safety, quality assurance (QA), licensing, Safety Review Board, etc.). See comment II 1.a below for additional details required.

2. Provide a resume for the Manager, Quality Assurance, that demonstrates his radiation and nuclear criticality experience.

3. Demonstrate that the new Chairman of the Safety Review Boar'd (also Manager, Operations Support) is as aware of potential facility radiation

-safety problems as the former Chairman (also Manager, Materials and Facilities) who had radiation and nuclear criticality safety functions under his surveillance.

II.Section I

1. Page 9

a. Expand the organization chart to include the operating functions-(e.g., health safety (including the technicians), nuclear safety, production control, nuclear materials control, accountability representative). The chart, without individual names should be in the appropriate license conditions section; that in a demonstration section with individual names.

b. Remove the resumes of those whose positions no lorger are a part of your organization (e.g., Health-Safety Foreman, Regulatory Control Manager).

p. Appendix A,Section I

a. (Page 9) Identify the new position of James T. Ford whose resume now appears on pages 9 and 10. If he still occupies a key role in a safety-related function, his resume should still be included.

b. (Page 10) Identify the experience of the Manager, Quality Assurance, (QA) that qualifies him to approve health physics procedures and to authorize exposures that are greater than those allowed by 10 CFR Part 20 limits, etc.

III. Sections III & IV

1. Provide justification for an apparent decrease in safety controls by replacing some of the functions of the former Regu~latory Control Manager

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to the Health-Safety or the Health Physicist, and some of his functions to the Manager of QA. Some of the functions performed by the former Manager, Materials and Facilities, are also assumed by the Manager of QA. The functions of the former Health-Safety Foreman are also assumed by the

. Health Physicist. Provide the support the Health Physicist has to perform all the indicated duties.

2.Section IV, pages 12 and 25 Identify who performs the specified services previously performed by the Health Physicist or the Health-Safety Foreman in the absence of the Health Physicist.

IV.Section V

1. Page 8, Section 5.3

a. Clarify the references to the "section". On page 7, it is referred to as a " Group".

b. Identify the experience of the Manager, QA, that meets the requirements of Section 5.3.2.

c. Correct the Revision Number of this page. It should be Revision Number 2.

2. Page 12, Section 6.1

a. Identify the position within Health-Safety that performs the periodic review of the recorded inspections.

b. If the position in 2.a above is the Health Physicist, clarify to whose attention he brings them. Obviously, they should be brought ta the attention of responsible supervision at a higher level.

c. Clarify the quarterly review of the air sample program records by the Health Physicist. He evaluates the daily sample results. The review should be made by a qualified person independent of the one who performs the evaluation of the daily results.

d. Identify the qualifications of the Manager, QA, to evaluate the adequacy of the contamination control, effluent levels, nuclear and radiation safety, and the license parameters.

e. Explain how the Health Physicist can evaluate the inadequacy of contamination control or air effluent levels when he's the one responsible for their control.

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3. Page 13, Section 6.1.1

a. Identify the position responsible for requesting Safety Review Board changes to existing procedures or new procedures, equipment, and facilities. The Safety Review Board Chairman (Manager, Operations Support) no longer has the direct line of communications (as did the Manager, Materials & Facilities) with the surveillance. performed by Health-Safety personnel.

b. Identify the permanent " technical management" membership on the Safety Review Board who is qualified to review the radiological safety of the proposed operation under review by the Board.

c. Identify the qualifications of the Manager, QA, to act as Board Chairman.

4 Page 18, Section 6.5 Provide justification for the replacement of both the Manager, Materials &

Facilities, and the Manager, Regulatory Control, by the Manager, QA, for the approval of Health-Safety Procedures.

5. 'Page 43, Section 8.1.2 Identify the qualifications of the Manger, QA, to authorize individual releases in the 21 percent to 75 percent MPC range.

6. Page 67, Section 10.2.4 Confirm that access to the RCZ area requires both notification and approval of Health-Safety.

7. Page 68, Section 10.2.5 Confirm that Radiological surveys shall be performed as contaminated ECH0-330 equipment is unloaded and prior to transport to the RCZ area.

8. Page 68, Section 10.2.6 Confirm that contaminated equipment that exceeds radiation control zone limits shall be immediately decontaminated or transported to a facility that can receive such contamination.

9. Page 68. Section 10.2.8 Confirm the radiological surveys of the RCZ shall be performed at least daily on the contaminated equipment during periods of maintenance and as necessary throughout the maintenance activity.

10. Page 68, Section 10.2.9 This section should be included.in your replacement page. It appears to have been inadvertently left out. Renumber-the remaining sections in Section 10 as needed. -

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