International Isotopes Fluorine Products, Inc. (IIFP) 

A Wholly Owned Subsidiary of 

International Isotopes, Inc. (INIS) 

Fluorine Extraction Process & Depleted 

Uranium De-conversion 

(FEP/DUP) Plant 

 

License Application 

Chapter 2 

Organization and Administration 

Revision B 

October 27, 2011 

LA-IFP-001 Revision B CHAPTER 2 
LA-IFP-001 Revision B CHAPTER 2 October 27, 2011 

 Page 2-ii

TABLE OF CONTENTS 

LIST OF FIGURES ................................................................................................................................ 2-iii 

LIST OF TABLES .................................................................................................................................. 2-iii 

ACRONYMS and ABBREVIATIONS (Provided In License Application Chapter 1 Revision B) 

2 ORGANIZATION and ADMINISTRATION ................................................................................ 2-1

2.1 ORGANIZATIONAL STRUCTURE .................................................................................... 2-2

2.1.1 Corporate Background .............................................................................................. 2-2

2.1.2 Design and Construction Organizational Structure ................................................... 2-2

2.1.3 Transition from Design and Construction to Startup and Plant Operation ................ 2-4

2.1.4 Plant Operation Organizational Structure ................................................................. 2-4

2.2 KEY MANAGEMENT POSITIONS, RESPONSIBILITIES AND QUALIFICATIONS .... 2-6

2.2.1 INIS President and Chief Executive Officer ............................................................. 2-6

2.2.2 INIS Corporate Environmental, Safety and Health and Quality Assurance Managers .. 

 ................................................................................................................................... 2-6

2.2.3 IIFP President ............................................................................................................ 2-7

2.2.4 IIFP Chief Operations Officer .................................................................................. 2-7 

2.2.5 Engineering Manager ................................................................................................ 2-8

2.2.5.1 Plant Engineering and Maintenance Manager ....................................... 2-8

2.2.5.2 Maintenance Supervisors ....................................................................... 2-9 

2.2.5.3 Configuration Management Manager .................................................... 2-9 

2.2.5.4 Human Factors Engineer ....................................................................... 2-9

2.2.6 Design and Build Contractor ................................................................................... 2-10

2.2.7 IIFP Quality Assurance Manager ........................................................................... 2-10

2.2.8 IIFP Environmental, Safety and Health Manager ................................................... 2-11

2.2.8.1 Fire Protection Lead ............................................................................ 2-11

2.2.8.2 Radiation Protection Manager ............................................................. 2-11

2.2.8.3 Emergency Preparedness/Security Lead .............................................. 2-12

2.2.8.4 Industrial Safety/Industrial Hygiene Lead ........................................... 2-12

2.2.8.5 Environment Lead ............................................................................... 2-13

2.2.9 Plant Manager ......................................................................................................... 2-13

2.2.9.1 Facility Safety Engineer....................................................................... 2-13

2.2.9.2 Area Shift Supervisors ......................................................................... 2-14

2.2.9.3 Shift Superintendents ........................................................................... 2-14

2.2.10 Facility Safety Review Committee .......................................................................... 2-15

2.2.11 Training Manager .................................................................................................... 2-15 

2.3 MANAGEMENT MEASURES ........................................................................................... 2-16

2.3.1 Configuration Management ..................................................................................... 2-16

2.3.2 Maintenance ............................................................................................................ 2-16

2.3.3 Training and Qualifications ..................................................................................... 2-16

2.3.4 Procedures ............................................................................................................... 2-17

2.3.5 Audits and Assessments .......................................................................................... 2-17 

2.3.6 Incident Investigations and Corrective Actions ...................................................... 2-17

2.3.7 Employee Concerns ................................................................................................. 2-18

2.3.8 Records Management and Document Control ........................................................ 2-18

2.3.9 Written Agreements with Off-site Emergency Resources ...................................... 2-19

REFERENCES .................................................................................................................................. 2-20 
LA-IFP-001 Revision B CHAPTER 2 October 27, 2011 

 Page 2-iii

 

 

LIST OF FIGURES 

Figure 2-1 IIFP Project Design and Construction Organization .......................................................... 2-3

Figure 2-2 Plant Operation Organization ............................................................................................. 2-5

LIST OF TABLES 

No List of Tables Entries 

 
LA-IFP-001 Revision B CHAPTER 2 October 27, 2011 

Page 2-1

2 ORGANIZATION and ADMINISTRATION 

International Isotopes Fluorine Products, Inc. (IIFP), a wholly owned subsidiary of International Isotopes, 

Inc. (INIS), will build and operate a depleted uranium processing facility (plant) near Hobbs in Lea 

County, New Mexico. A summary of the planned facility description is provided in the IIFP License 

Application (LA), Revision B Chapter 1 “General Information.” 

Chapter 2 presents a description of the organization structure responsible for managing the design, 

construction, startup and operation of the IIFP Facility (also referred to as the Fluorine Extraction Process 

and Depleted Uranium De-conversion Plant). Key management and supervisory positions and functions 

are described, including personnel qualifications for each key position. This chapter also includes a 

summary description of the management system and administrative procedures for effective 

implementation of Environmental, Safety and Health (ESH) functions at the IIFP Facility. More detail 

about management measures is provided in the IIFP LA, Revision B Chapter 11 “Management 

Measures.” 

The IIFP Chief Operations Officer (COO) is delegated the authority by the IIFP President with the 

approval of the INIS President and Chief Executive Officer (CEO) for the responsibilities for the design, 

construction, startup and operations of the facility as well as safety and regulatory compliance. The IIFP 

policy is to ensure and maintain a safe work place for its employees, to protect the public and the 

environment relative to the operation of its plant and to assure operational compliance with the terms and 

conditions of the U.S. Regulatory Commission (NRC) license and applicable federal, state and local 

regulations. The COO reports directly to the President of IIFP who in turn reports directly to the 

President/CEO of International Isotopes, Inc. The INIS President/ CEO reports to the Board of Directors 

of INIS and ensures corporate policies are established and that policy direction is communicated. The 

IIFP COO has overall responsibility for facility safety and regulatory compliance, whereas the IIFP 

President, through policies, management reviews and delegation is ultimately responsible for ensuring 

safety, security and protection of the environment relative to the IIFP Facility. 

During the licensing and design stages of the facility, IIFP will have only limited positions filled and in 

the case where positions are vacant, corporate managers of INIS will fill the given responsibilities. For 

example, the INIS corporate ESH Manager will initially fulfill the licensing, safety and regulatory affairs 

responsibility for the IIFP organization until such time that it is appropriate to hire a full time ESH 

Manager for IIFP. Also the President/CEO of INIS or the President of IIFP will have responsibility and 

carry out the duties of the IIFP COO until such time the COO is hired and assumes his/her overall 

responsibilities. Throughout the project development and growth in organization structure INIS and IIFP 

management will make certain that very clear delineation of responsibility is maintained. 

IIFP employs the principle of keeping radiation exposures to employees and the general public as low as 

reasonably achievable (ALARA). Additionally, the IIFP organization is structured to maintain appropriate 

independency between the safety, quality organizations and the operations organizations to ensure that 

production does not take priority over safety. 

INIS is implementing International Organization for Standardization (ISO) 9001 in their existing Quality 

Management System (QMS) at the corporate office and Idaho production facility. INIS corporate quality 

processes and implementing procedures will be incorporated appropriately into the IIFP Quality 

Assurance (QA) Program. IIFP is also incorporating a graded approach into the IIFP QA Program that 

will ensure compliance with necessary regulatory requirements. A description of the IIFP QA Program 

and graded approach is provided in the IIFP LA, Revision B Appendix A, “Quality Assurance Program 

Description.” 
LA-IFP-001 Revision B CHAPTER 2 October 27, 2011 

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2.1 ORGANIZATIONAL STRUCTURE 

The following sections address the organizational structure for the IIFP Facility including corporate 

ownership, organization structure during design, construction, startup and operations. 

2.1.1 Corporate Background 

International Isotopes, Inc. was formed as a Texas corporation in 1995. Its wholly owned subsidiaries are 

International Isotopes Idaho Inc., International Isotopes Fluorine Products, Inc. and International Isotopes 

Transportation Services, Inc., all of which are Idaho corporations. INIS headquarters and all operations 

are currently located within two facilities in Idaho Falls, Idaho. 

INIS currently operates under three separate NRC possession and use licenses, maintains a specific 

license to import and export Category 1 and Category 2 quantities of radioactive material, maintains an 

NRC Approved QA Plan for the shipment of Type B quantities of radioactive materials, maintains two 

U.S. Department of Transportation Special Form Certificates and several Sealed Source and Device 

Registry Safety Evaluations. This License Application is being prepared to support a separate and 

additional NRC operating license for the uranium de-conversion and fluorine extraction processing 

facility planned for Lea County New Mexico. 

The President of International Isotopes Fluorine Products, Inc. will report directly to the President/CEO 

of INIS. All further position descriptions contained in this chapter refer directly to positions within the 

IIFP subsidiary unless specifically mentioned otherwise. 

2.1.2 Design and Construction Organizational Structure 

IIFP management is responsible with delegated authority from the INIS President/CEO for the design, 

engineering, construction, startup, operation, maintenance, modification, testing and final facility 

decommissioning. 

In the early stages of the project concept, INIS hired a contractor to help develop the IIFP Facility Project. 

The contractor has experience in uranium and fluorine technologies and related commercial operations 

including the environmental, safety and health aspects. The contractor’s scope of work included 

developing and managing early project activities and preparing a conceptual design of the plant. The 

contractor was also hired to prepare the NRC License Application and the Environmental Report for the 

project. 

The facility site evaluation and selection was conducted by INIS and its experienced contractors. The 

selected site at Hobbs, New Mexico is described in the IIFP LA, Revision B Chapter 1. 

A Design and Build (DB) Contractor will be contracted to perform detailed design and construction of the 

IIFP Facility. 

The “design and build” terminology is used synonymously with design and construction work as shown 

in Figure 2-1, “IIFP Project Design and Construction Organization.” 

While the project is in licensing, design and construction, the President/CEO of INIS may also act as the 

President of IIFP until that position is filled. One of the first positions that will be filled in the IIFP 

organization will be the Chief Operations Officer (COO) who will take direct responsibility, and will be 

delegated the commensurate authority by the IIFP President, for all aspects of the project including 
LA-IFP-001 Revision B CHAPTER 2 October 27, 2011 

Page 2-3

selecting additional IIFP management staff. As the project progresses into construction, startup and 

finally operations, the COO will add appropriate management positions in order that they gain knowledge 

of the plant at the appropriate stages and in order to put additional staff and programs in place to support 

the safe operation of the facility. Figure 2-1 presents the planned project organization during the project 

design and construction. 

 

Figure 2-1 IIFP Project Design and Construction Organization 

As shown in Figure 2-1, the COO is responsible, with delegated commensurate authority from the IIFP 

President, for managing the administration, ESH, QA, Engineering and Training for the IIFP Facility. The 

COO is also responsible for overseeing the supporting contractor functions during the licensing, design 

and construction of the IIFP Facility. Once an IIFP Engineering Manager is hired, the COO will delegate 

authority to the Engineering Manager for providing the day-to-day oversight of the DB Contractor and 

ensuring professional and contractor support is in place to perform any required Integrated Safety 

Analysis (ISA) Summary and licensing documentation during the design and construction of the IIFP 

Facility. Until the Engineering Manager position is filled, the COO (or the IIFP President if the COO 

position is not yet filled) carries out these Engineering Manager responsibilities. The INIS parent 

company will provide the QA and ESH Management support to the IIFP COO during the licensing and 

design stages of the project. Prior to start of construction activities IIFP will establish full time Quality 

Assurance and ESH managers for the facility. Procurement for the commercial plant project is generally 
LA-IFP-001 Revision B CHAPTER 2 October 27, 2011 

Page 2-4

performed by the DB Contractor but in some cases may be performed by IIFP or subcontractors. The IIFP 

QA function ensures that evaluation and pre-approval of vendor qualification is performed where the 

procurement involves IROFS as identified in the IIFP ISA Summary, Revision B. This review and preapproval is to ensure the vendor quality assurance programs are in accordance with the requirements of 

the IIFP QA Program. Likewise, the QA function ensures reviews of vendor performance in accordance 

with the IIFP QA Program where the procurement involves QA Levels 1 and 2 systems, structures and 

components as defined by the IIFP QA Program documentation. 

Configuration management (CM) and design modification safety reviews are discussed in Section 2.3.1. 

Position descriptions of key management personnel in the design and construction organization will be 

accessible to affected personnel and the NRC. 

2.1.3 Transition from Design and Construction to Startup and Plant Operation 

Prior to the end of construction, the focus of the organization will shift from design and construction to 

initial startup and operation. At an appropriate time during construction, IIFP will supplement and expand 

the initial organization structure to include a Plant Manager (PM) and other management positions and 

disciplines necessary to ensure readiness of the facility for safely starting and effectively transitioning 

from construction activities to operating activities. These additional positions will be hired well in 

advance of the scheduled start up of operations and may serve in interim organizational roles during the 

construction stage of the project. 

During this transition, the IIFP Plant ESH and QA Managers report to the COO regarding ESH and QA 

matters related to design and construction. Both the ESH Manager and QA Manager have the 

responsibility and authority to elevate and report any ESH or QA unresolved concern to the IIFP 

President. All ESH and QA reported concerns will be followed through to resolution and documented. 

This reporting authority of the IIFP ESH and QA Managers is intentionally structured to provide 

significant continued focus on the ESH goals and stop-work authority during design, construction and 

transition periods when the operating organization may not yet be fully implemented. 

When construction of the facility and process systems is complete, the equipment and systems undergo 

acceptance testing as in accordance with the QA Program and approved written procedures. Following 

successful completion of integrated equipment and systems testing and acceptance, the responsibilities for 

managing the facility equipment and systems are transferred from the Design and Construction 

Organization to the Plant Operation Organization as shown in Figure 2-2 by means of a transition plan. 

The COO and Plant Manager ensure the development of a transition plan and an orderly, safe and 

thorough turnover to the IIFP Plant Operation Organization. The turnover includes the physical systems, 

corresponding design information, records of the facility and as-built drawings. Following turnover, the 

Plant Operation Organization is responsible for facility safe operations, maintenance, configuration 

management and facility safety reviews of modifications affecting the as-built plant. 

The design basis for the facility is maintained during the transition from construction to operations 

through the CM Program described in Section 2.3.1 below and in the LA, Revision B Chapter 11. 

2.1.4 Plant Operation Organizational Structure 

The IIFP Plant Operation Organization structure and lines of communication are shown in Figure 2-2. 

IIFP has responsibility for pre-operational testing, startup, operations and maintenance of the IIFP 

commercial plant. 
LA-IFP-001 Revision B CHAPTER 2 October 27, 2011 

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Figure 2-2 Plant Operation Organization 

The Chief Operations Officer reports directly to the IIFP President who, in turn reports to the INIS 

President/ CEO. The COO is responsible with delegated authority from the IIFP President for the overall 

operation, maintenance, administration and regulatory compliance of the IIFP Facility. In the discharge 

of these responsibilities, the COO leads the activities of the plant, including the following functions: 

• Quality Assurance 

• Plant Management (Operations/Technical) 

• Engineering and Maintenance 

• Administration 

• Training 

• Environmental, Safety and Health 

• Facility Safety Review Committee (FSRC) including the ALARA Committee 

The responsibilities, authorities and lines of communication of key management positions within the plant 

organization are discussed in Section 2.2 “Key Management Positions, Responsibilities and 

Qualifications.” 
LA-IFP-001 Revision B CHAPTER 2 October 27, 2011 

Page 2-6

Position descriptions for key management personnel in the operating organization will be accessible to 

affected personnel and to the NRC. 

2.2 KEY MANAGEMENT POSITIONS, RESPONSIBILITIES AND QUALIFICATIONS 

This section describes the key functional positions responsible for managing the safe design, construction 

and operation of the IIFP Facility. The responsibilities, authorities, qualifications and lines of 

communication for each key management position are provided in this section. 

Responsibilities, authorities and inter-relationships of the IIFP operating organizational groups, who have 

responsibilities important to ESH and Quality Assurance, are specified in approved written position 

descriptions. 

2.2.1 INIS President and Chief Executive Officer 

The INIS President and Chief Executive Officer reports to and receives policy direction from, the INIS 

Board of Directors. The President/CEO is responsible for establishing policies and providing overall 

direction and management of all INIS corporate activities. The President/CEO also ensures that INIS 

corporate policies for the ESH and QA Programs are maintained and transmitted to all levels of 

management and implemented appropriately through approved written procedures. The President/CEO 

shall have as a minimum a bachelor’s degree in a scientific field or business. At least eight (8) years of 

work experience is required with the proven ability in management of a commercial chemical, 

radiological, or nuclear related operations or engineering organization, overall leadership qualities and the 

commitment to safety, quality and regulatory compliance. 

2.2.2 INIS Corporate Environmental, Safety and Health and Quality Assurance Managers 

The INIS Corporate ESH and Quality Assurance Managers are appointed by the INIS President/CEO and 

are responsible for ensuring development and communication of the parent INIS corporate ESH and QA 

policies that will ensure safe operation and meet the licenses, permit and product requirements. 

During the early stages of the IIFP project, the INIS Corporate ESH and QA Managers temporarily have 

duties that will later be fulfilled by the IIFP ESH and QA Manager, respectively. When the positions of 

IIFP ESH and QA Managers are filled, any of the IIFP Facility ESH and QA responsibilities, duties and 

authorities that were temporarily being performed by INIS Corporate staff will transfer to the IIFP ESH 

and QA Managers. 

The INIS Corporate ESH Manager is responsible for initially establishing an IIFP system that will 

identify and evaluate potential or new regulatory requirements applicable to the IIFP Facility. During the 

design and construction stages, this ESH Manager ensures that environmental technical and licensing 

support, as requested by the COO or IIFP President/CEO, is provided. The INIS Corporate ESH Manager 

also provides technical support for the federal, state and local environmental related permit application. A 

primary responsibility of this ESH Manager during the design/construction stage of the project is to 

prepare responses and interact with the NRC for Requests for Additional Information (RAIs) relative to 

the IIFP License and Environmental Report. The INIS Corporate ESH Manager also provides support for 

ensuring that effective audit, feedback, investigative and corrective action programs are in place across 

the parent and subsidiary corporate organizations that will provide prompt response in preventing and 

correcting ESH related incidents. 
LA-IFP-001 Revision B CHAPTER 2 October 27, 2011 

Page 2-7

The INIS Corporate QA Manager is responsible for the overall development and implementation of all 

aspects of the corporate Quality Assurance Program. The INIS Corporate QA Manager also provides 

support for ensuring the QA policies, effective audit, investigative and corrective action programs are in 

place across the parent and subsidiary corporate organizations that will provide prompt response in 

preventing and correcting Quality Assurance issues and events. 

The INIS Corporate ESH and QA Managers provide advice, oversight and consultation in assisting the 

IIFP QA and ESH Managers in matters of regulatory compliance and ESH and QA program objectives. 

The INIS Corporate ESH and Assurance Managers shall have a minimum a bachelor’s degree in an 

engineering or scientific field and five (5) years of related experience in chemical, radiological or nuclear 

facilities. 

2.2.3 IIFP President 

The IIFP President reports directly to the INIS President/CEO and is responsible for establishing policies 

and providing overall direction and management of all IIFP activities. The IIFP President also ensures 

that policies for the ESH and QA Programs are maintained and transmitted to all levels of IIFP 

management and implemented appropriately through approved written procedures. The IIFP President 

shall have as a minimum a bachelor’s degree in a scientific discipline or industrial supervision related 

field. At least five (5) years of work experience is required with demonstrated proficiency in management 

of a commercial chemical, radiological, or nuclear related operations or engineering organization, overall 

leadership qualities and a commitment to safety, quality and regulatory compliance. 

2.2.4 IIFP Chief Operations Officer 

The IIFP Chief Operations Officer is selected by the IIFP President. In the role of COO, he/she is 

responsible for managing the design, detailed engineering, construction, pre-startup, procurement, 

configuration management, quality assurance, ESH, subcontracting, project control and records. 

The COO is the individual with the overall responsibility for safety and operational activities of the IIFP 

Facility. The responsibilities of the COO are defined by IIFP policies, procedures and instructions. The 

COO is responsible for the safe conduct and control of operations and protection of employees. The COO 

also has responsibility for regulatory compliance with the facility NRC licenses and other federal, state 

and local permits or licenses. The COO ensures proper selection of staff for the key positions including 

positions for the Facility Safety Review Committee and ALARA Committee. 

The COO shall have the authority to enforce the shutdown of any construction or pre-start activity. The 

COO will also delegate facility shutdown authority to appropriate organizations and line managers. The 

COO must approve restart of any activity that was shut down due to safety and/or regulatory concerns. 

The COO shall have as a minimum a bachelor’s degree in a scientific discipline or industrial supervision 

related field and five (5) years of experience in a chemical, radiological, or nuclear related operations or 

engineering organization. The experience shall include responsible assignments involving engineering or 

facility operations management. The COO shall be cognizant of the IIFP licensing documentation and the 

overall ESH and QA requirements of the facility design and construction. 
LA-IFP-001 Revision B CHAPTER 2 October 27, 2011 

Page 2-8

2.2.5 Engineering Manager 

The Engineering Manager reports directly to the COO. During the design and construction stages, the 

Engineering Manager ensures professional staffing or contractor support is in place to perform ISA and 

licensing documentation. This support includes, but is not limited to: 1) design modifications review and 

determination of Items Relied on for Safety (IROFS, 2) design changes review and determinations related 

to IROFS, in accordance with the IIFP QA Program or 3) response to the NRC involving RAIs relative to 

design changes or modifications. During start-up and operations stages of the facility the Engineering 

Manager is responsible for providing all facility engineering support, configuration management and 

plant engineering maintenance. 

The Engineering Manager also has responsibility for ensuring the directing and scheduling of 

maintenance activities, including ensuring safe design and reliability of process and support equipment 

and providing maintenance support for equipment and systems. The Engineering Manager is responsible 

for overseeing engineering projects and the development of design changes to the facility and for ensuring 

the establishment and implementation of engineering and maintenance policies and procedures. Other 

responsibilities typically include, but are not limited to, activities such as: 1) providing design authority 

for engineering projects, 2) overseeing maintenance of the approved design status and 3) assuring 

coordinating and maintaining testing programs for the facility, to include testing of systems, structures 

and components (SSCs) to ensure the SSCs are functioning as specified in design documents. 

The Engineering Manager ensures that design change reviews and analyses are documented, follow 

requirements of the IIFP QA Program and CM Program and are reported, reviewed and approved in 

accordance with IIFP procedures during the design and construction of the facility. Once IIFP staffs the 

Facility Safety Engineer (FSE) position, the ISA and related controls and the licensing amendment 

process become the responsibility of the Facility Safety Engineer. The responsibilities and qualifications 

for the FSE are described in Section 2.2.9.1. 

The Engineering Manager shall have as a minimum a bachelor's degree in an engineering or scientific 

field and a minimum of five (5) years of experience in implementing and managing technical or 

engineering programs or operations in a chemical, radiological or nuclear facility. Educational 

requirement may be substituted with relevant military and/or civilian work experience. 

2.2.5.1 Plant Engineering and Maintenance Manager 

The Plant Engineering and Maintenance Manager reports to the Engineering Manager and has 

responsibilities for supervising day-to-day engineering services and management for the preventive and 

corrective maintenance support for the IIFP Facility. 

The Plant Engineering and Maintenance Manager has responsibility for ensuring the directing and 

scheduling of maintenance activities, including ensuring safe functionality and reliability of process and 

support equipment and providing maintenance support for equipment and systems. Other responsibilities, 

typically include, but are not limited to, activities such as: 1) corrective and preventive maintenance of 

facility equipment, 2) assuring adequate qualified staffing and training of maintenance and engineering 

support personnel, 3) assuring development and implementation of maintenance procedures and 4) 

coordinating and implementing testing programs for the facility, to include testing of systems, structures 

and components to ensure the SSCs are functioning as specified in design documents. 

The Plant Engineering and Maintenance Manager shall have as a minimum a bachelor's degree in an 

engineering or scientific field and a minimum of five (5) years experience in implementing and 
LA-IFP-001 Revision B CHAPTER 2 October 27, 2011 

Page 2-9

supervising a plant engineering or maintenance program in a chemical, radiological or nuclear facility. 

Educational requirement may be substituted with relevant military and/or civilian work experience. 

2.2.5.2 Maintenance Supervisors 

The Maintenance Supervisors report to the Plant Engineering and Maintenance Manager and have 

responsibilities for corrective and preventive maintenance, measuring and test equipment calibrations, 

equipment fabrication and repairs in the shop and field and development and implementation of 

maintenance procedures. The Maintenance Supervisors implement maintenance procedures for ensuring 

safe and reliable equipment, systems, structures and components and for reviewing maintenance work 

requests to assist in determining if the work involves IROFS or modifications. 

The Maintenance Supervisors ensure that preventive and corrective maintenance is implemented in a safe 

and efficient manner in accordance with the work schedule and plan. Duties include, but are not limited 

to: 1) ensure that plant work for IROFS is performed using written procedures as applicable, 2) oversee 

activities to ensure radiation doses are ALARA and 3) schedule and ensure adequate training for 

maintenance personnel. A Maintenance Supervisor assigned to each shift is also the Emergency Response 

Team Leader (ERTL) on the back-shifts, weekends and holidays and carries out that responsibility as 

described in the IIFP LA, Revision B “Emergency Management Plan.” 

Maintenance Supervisors shall have as a minimum a high school diploma and at least four (4) years of 

lead maintenance experience in the field of mechanical, electrical, or instrument maintenance in a 

chemical, radiological or nuclear facility, or a bachelor’s degree in engineering or scientific field with at 

least two (2) years of practical maintenance experience in a chemical, radiological or nuclear facility. 

2.2.5.3 Configuration Management Manager 

The IIFP Configuration Management Manager (CMM) reports to the Engineering Manager and has 

responsibility for maintaining the CM program and procedures. The CMM also ensures applicable CM 

evaluations and decisions are documented and entered into recordkeeping in accordance with plant 

procedures. The CMM ensures that audits are conducted on CM performance, evaluations and decisions. 

Reports of those findings are reported to the FSRC, accordingly. 

The CMM shall have at least four (4) years of appropriate responsible experience of working with CM 

program implementation in a chemical, radiological or nuclear facility. 

2.2.5.4 Human Factors Engineer 

IIFP commits to adding a professional with a human factors engineering (or human factors) background 

to the IIFP project. IIFP will employ this individual either as a contractor or an employee. The Human 

Factors Engineer will report directly to the IIFP Engineering Manager. The individual in this position has 

the responsibility for developing and finalizing the IIFP Human Factors Engineering (HFE) 

Implementation Plan and for overseeing the incorporation and implementation of the HFE Plan elements 

within the applicable HFE scope during the design, engineering and start up of the facility. The Human 

Factors Engineering position is included as part of the staff shown in the “Design and Build Contractor” 

organization box during design and construction stage of the Project and is included in the “Process 

Engineers” organization box of Figure 2-2, “Plant Operation Organization” once the IIFP operation 

begins. 
LA-IFP-001 Revision B CHAPTER 2 October 27, 2011 

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The Human Factors Engineer shall have as a minimum a bachelor’s degree in Human Factors 

Engineering or a bachelor’s degree in a scientific discipline or psychology with an emphasis on human 

factors. Additionally, the Human Factors Engineer shall have at least three (3) years of experience in the 

application of human factors engineering or human factors in a commercial or military setting. The 

educational requirement may be waived if it is deemed that the candidate has relevant and sufficient 

military and/or commercial experience in Human Factors beyond the minimum experience requirements. 

2.2.6 Design and Build Contractor 

The Design and Build Contractor is selected by the INIS President/CEO and approved by the INIS Board 

of Directors. The DB Contractor, under a formal approved written contract with IIFP, is responsible for 

performing the detailed design, engineering, procurement and construction of the IIFP Facility. The DB 

Contractor assigned project manager is the lead-official representative of the design/build contract. In the 

initial design stage, the DB Contractor will report directly to the COO. Once the Engineering Manager 

position is filled the DB Contractor will report directly to the Engineering Manager. The DB Contractor 

coordinates work on the project and controls the subcontractors, inspections and start-up functions to 

ensure safe design, construction, acceptance testing and turnover to the IIFP Plant Operation 

Organization. 

During the detailed design, construction and start-up stage of the project, the DB Contractor will also 

ensure, as part of the written contract, that design meets all the applicable federal, state and local codes 

and standards. 

The approved DB Contractor shall have as a minimum a demonstrated safe record of experience in 

design, engineering, procurement and construction of chemical, radiological or nuclear facilities at project 

complexity levels at least equivalent with that of the IIFP Project. The DB Contractor shall also have the 

professional and trade craft capabilities of either performing or subcontracting for design, engineering, 

procurement, construction and support of acceptance testing for the plant process equipment, systems and 

facility infrastructure. 

2.2.7 IIFP Quality Assurance Manager 

The IIFP Quality Assurance (QA) Manager reports to the COO, but has an interacting relationship with 

Engineering, Training, ESH and Plant Manager organizations, other IIFP Facility managers and INIS QA 

corporate staff, on matters of QA policies, new QA requirements and overall QA performance. The IIFP 

QA Manager is responsible for establishing and maintaining the IIFP QA Program. Line management and 

their staff are responsible for ensuring implementation of the QA Program and compliance with the 

Program. The QA Manager position is independent from operational and safety organizations. The QA 

Manager has authority to elevate and report any QA unresolved concerns to the IIFP President and the 

INIS Corporate QA Manager. The IIFP QA Manager is responsible to ensure that such QA concerns will 

be followed through to resolution and documentation. 

The IIFP QA Manager ensures compliance with the program elements identified in Revision B Chapter 

11 of the License Application and the Revision B “Quality Assurance Program Description,” Appendix 

A of the License Application. Those elements include the QA Program; qualification and certification of 

personnel; work control; design control; procurement document control; instructions, procedures and 

drawings; document control; control of purchased items and services; identification and control of 

materials, parts and components; control of special processes; test control; inspection; control of 

measuring and test equipment; inspection, test and operating status; control of non-conforming items; 

corrective actions; and audits/assessments. 
LA-IFP-001 Revision B CHAPTER 2 October 27, 2011 

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The QA Manager has plant shutdown authority in matters relative to QA and ensures through the Plant 

Manager and COO that such shutdowns are implemented in a safe and orderly manner. The QA Manager, 

or Designee, must approve the restart of any operation shutdown by reasons of QA matters or by the QA 

function. 

The IIFP QA Manager shall have as a minimum a bachelor’s degree in engineering, science or related 

field and five (5) years of experience in the implementation of a QA Program at a chemical, radiological 

or nuclear facility. 

2.2.8 IIFP Environmental, Safety and Health Manager 

The IIFP Environmental, Safety and Health (ESH) Manager reports to the IIFP COO, but also has an 

interacting relationship with all managers on matters of ESH policies, regulatory requirements, plant 

safety and environmental compliance. In addition, the ESH Manager has the authority to elevate any ESH 

unresolved concerns to the IIFP President and the INIS Corporate ESH Manager. The IIFP ESH Manager 

is responsible to ensure that such concerns will be followed through to resolution and documentation. 

The IIFP ESH Manager has the responsibility to establish and oversee the Radiation Protection, Industrial 

Safety/Industrial Hygiene, Fire Protection, Emergency Preparedness/Security and Environmental 

Protection Programs to ensure compliance with applicable federal, state and local regulations and 

requirements. Those programs are designed to ensure the health and safety of employees and the public, 

as well as the protection of the environment. The ESH Manager has plant shutdown authority in matters 

relative to ESH and ensures through the Plant Manager and COO that such shutdowns are implemented in 

a safe and orderly manner. The ESH Manager, or Designee, must approve the restart of any operation 

shutdown by reasons of ESH matters or by the ESH function. 

The IIFP ESH Manager shall have as a minimum a bachelor’s degree in engineering, science or related 

field and five (5) years of responsible assignments of ESH activities at chemical, radiological or nuclear 

facilities. 

2.2.8.1 Fire Protection Lead 

The Fire Protection Lead (FP) reports to the IIFP ESH Manager and has responsibilities for developing 

fire protection plans and procedures and for ensuring that day-to-day fire protection activities are 

implemented in accordance with the Fire Protection Plan and procedures. The FP Lead ensures that 

inspections, audits and surveys are performed on fire protection systems, equipment and controls in 

accordance with established frequencies and procedures. 

The FP Lead shall be trained in the field of fire protection and have at least two (2) years practical 

experience in fire protection activities at a chemical, radiological or nuclear facility. 

2.2.8.2 Radiation Protection Manager 

The Radiation Protection Manager (RPM) is administratively independent of production operations and 

reports directly to the IIFP ESH Manager. The RPM also has the authority to report to the IIFP COO any 

unresolved concerns related to ESH and radiation protection. The RPM is responsible for effectively 

implementing the IIFP Radiation Protection Program (RPP) and for ensuring the facility is staffed with 

suitably trained radiation personnel. The RPM must approve restart of any operation that was shut down 

by the radiation protection (RP) function or as a result of radiation protection concerns. The RP staff, 
LA-IFP-001 Revision B CHAPTER 2 October 27, 2011 

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including technicians and support personnel, report to the RPM. Major responsibilities of the RPM and 

the RP staff include, but are not limited to, the following: 

• Establish and maintain the RP programs, procedures and training 

• Conduct radiation and contamination monitoring and control programs 

• Evaluate radiation exposures of employees, contractor personnel and visitors and ensure the 

maintenance records and reporting of results 

• Establish and maintain the ALARA program, including being a key member of the ALARA 

Committee 

• Evaluate the integrity and reliability of radiation detection instruments 

• Provide support for Integrated Safety Analyses and configuration control 

Additional responsibilities of the RPM and RP staff are provided in the IIFP LA, Revision B Chapter 4 

“Radiation Protection.”

The Radiation Protection Manager shall have as a minimum a bachelor’s degree in engineering or a 

scientific field and a minimum of five (5) years responsible experience that includes assignments 

involving responsibility for RP and the application and direction of RP programs. 

2.2.8.3 Emergency Preparedness/Security Lead 

The Emergency Preparedness/Security (EP/S) Lead is a staff person reporting to the IIFP ESH Manager 

and has responsibilities for developing emergency planning and preparedness programs and procedures. 

This position also develops and maintains facility security procedures and oversees implementation of 

facility security. The EP/S Lead assesses the effectiveness of the security and facility emergency 

preparedness programs, designs and ensures the implementation of drills and exercises and provides 

feedback to the ESH Manager and emergency response organization for corrections and improvements. 

The Emergency Preparedness/Security Lead shall have a minimum of five (5) years responsible 

experience in the development, implementation and leadership of emergency planning and preparedness 

programs and procedures. At least two (2) of those years’ experience must be related to chemical, 

radiological or nuclear facilities. Additionally, the EP/S Lead shall have either one (1) year of responsible 

industrial physical security experience or an appropriate security training certificate. 

2.2.8.4 Industrial Safety/Industrial Hygiene Lead 

The Industrial Safety/Industrial Hygiene Lead (ISIH) is a professional staff person that reports to the IIFP 

ESH Manager and has responsibility for: 1) developing and implementing the plant safety industrial 

safety, hazards communications and industrial hygiene programs and procedures, 2) ensuring 

development or provision of safety training materials, 3) assisting in the training of employees in safety, 

4) assuring audits, inspections and assessments are conducted relative to safe conditions and practices 

including follow through to resolution of significant findings, 5) performing monitoring and evaluations 

of workplace conditions and environment to ensure established safe controls and acceptability and 6) 

advising and ensuring compliance of Occupational Safety and Health Administration (OSHA) 

requirements. 

The ISIH Lead shall have a bachelor’s degree in engineering or occupational safety and health and a 

minimum of three (3) years of responsible experience in safety programs at a chemical, radiological or 

nuclear facility. 
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2.2.8.5 Environment Lead 

The Environment Lead reports to the IIFP ESH Manager and has responsibilities in supporting the ESH 

Manager, including but not limited to: 1) developing of environmental programs and procedures, 2) 

leading monitoring and measuring activities, 3) developing and maintaining environmental related 

permits, 4) assisting in training of employees in environmental matters, 5) conducting audits and 

inspections, 6) preparing and providing environmental data and reports and 7) interacting with federal, 

state and local representatives in ensuring compliance with permit requirements and conditions. 

The Environment Lead shall have a bachelor’s degree in engineering or scientific field and at least two 

(2) years environmental related experience in a chemical, radiological or nuclear facility. 

2.2.9 Plant Manager 

The Plant Manager (PM) reports directly to the COO. The PM is responsible for implementing safe 

practices, procedures and activities related to the operation of the production processes, utilities, 

environmental protection and waste treatment systems, fire system, laboratory and warehouses. The PM is 

responsible for the safe conduct and control of operations and protection of employees. The PM also has 

responsibility for day-to-day regulatory and procedural compliance associated with the facility operations. 

The PM is responsible for hiring and training of qualified staff and operating personnel in the Plant 

Management organization. 

During initial start up of the facility the Plant Manager is responsible for coordinating with the Training 

Manager (TM) for developing safe and effective operating procedures and training program plans. The 

PM is responsible for staffing of the operations organization and for ensuring operational readiness and 

acceptance testing plans, schedules and documentation during startup. 

The PM shall be responsible for application of the safety related programs to facility operations and shall 

have the authority to enforce the shutdown of any process or building. The PM will also delegate facility 

shutdown authority to appropriate organizations and line managers. The PM must approve restart of an 

operation that was shut down due to safety and/or regulatory concerns. 

The PM shall have as a minimum a bachelor’s degree and five (5) years of experience in chemical, 

radiological, or nuclear related operations. The experience shall include senior responsible assignments 

involving engineering or facility operations management. The PM shall be cognizant of the IIFP licensing 

documentation and the overall ESH requirements of the IIFP Facility. 

2.2.9.1 Facility Safety Engineer 

The Facility Safety Engineer(s) (FSE) reports directly to the Plant Manager and has responsibility for 

performing technical safety analysis and regulatory evaluations for IROFS relative to modifications and 

change management. 

The FSEs are also responsible for determining and providing ISA results and recommendations to the 

Facility Safety Review Committee (FSRC) and IIFP management. The FSE ensures adequate analysis, 

ISA Summary revisions and the reporting of such analysis and determinations. 
LA-IFP-001 Revision B CHAPTER 2 October 27, 2011 

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The FSEs ensure documentation and recordkeeping of safety analyses and determinations in accordance 

with the IIFP QA, CM and Document Control and Records programs. 

The FSE shall have as a minimum a bachelor’s degree in engineering or a scientific field and at least four 

(4) years of experience in a radiological or nuclear-related facility of which two (2) of those years shall be 

in application of safety analysis methodologies. 

2.2.9.2 Area Shift Supervisors 

Operational functions of the IIFP Facility have designated Area Shift (day and other work shifts) 

Supervisors who are responsible for implementing safe and efficient operations at the Plant site. 

The Area Shift Supervisors report directly to the Plant Manager and have responsibilities in designated 

production and utility areas of the plant. Their duties include, but are not limited to: 1) ensuring safe 

operation of the facility and support equipment, 2) ensuring IROFS are available and perform as intended, 

3) overseeing activities to ensure radiation doses are ALARA, 4) managing of depleted uranium 

hexafluoride (DUF6) cylinder handling, 5) managing chemical inventories and material logistics, 6) 

scheduling and supervising of operations personnel, 7) ensuring operational aspects of IROFS are being 

maintained in accordance with QA requirements, 8) scheduling and ensuring adequate operator training 

and 9) ensuring that usable and adequate supplies of safety, emergency, fire protection and spill 

prevention/control equipment are maintained. 

The Area Shift Supervisors shall have as a minimum a bachelor’s degree in a technical field and two (2) 

years of experience in operations of a chemical or nuclear facility or a high school diploma with five (5) 

years of operations experience, two (2) of which are in chemical or nuclear facility. 

2.2.9.3 Shift Superintendents 

The Shift Superintendents report directly to the Plant Manager. A Shift Superintendent (SSP) is assigned 

and scheduled for each work shift including weekends and holidays. The SSP when scheduled on the 

back shift (afternoons, nights, holidays and weekends) has the role in coordinating the IIFP Facility 

operational and maintenance tasks and support activities. This role includes: 1) assuring coordination 

among work groups in the authorization of safety and radiological permits, 2) arranging any additional or 

replacement qualified staff, as needed, for the work shift to support planned and emerging work activities, 

3) ensuring corrective response and reporting for any abnormal events and 4) setting priorities and 

coordinating activities among the various shift functional groups when emerging or unexpected task 

requirements arise. When the SSP is scheduled to work on the day shift, he/she assists in emergency 

preparedness, planning and related training, supports the Plant Manager on special projects and 

assignments and attends refresher training as needed. The Shift Superintendent has the authority to stop 

work and shut down operations in a safe and orderly manner in matters related to ESH or QA. 

Additionally, the Shift Superintendent takes the lead role of the facility Emergency Director until the 

COO, or Designee, can assume that role in the event of an emergency. Once relieved of the Emergency 

Director role, the SSP then fills the role of the Field Incident Commander during the emergency event. 

The role and responsibilities of the SSP during declared emergencies are specifically stated in the IIFP 

LA, Revision B “Emergency Management Plan.” 

The Shift Superintendent shall have as a minimum a bachelor’s degree in an engineering or scientific field 

and a minimum of four (4) years of responsible experience in supervising and implementing chemical, 
LA-IFP-001 Revision B CHAPTER 2 October 27, 2011 

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radiological or nuclear-related operations programs. Educational requirement may be substituted with 

relevant military and/or civilian work experience. 

2.2.10 Facility Safety Review Committee 

The Facility Safety Review Committee (FSRC) is appointed by the COO. The FSRC reports to the COO 

in providing technical and administrative review for ISA determinations and decisions that involve 

IROFS and proposed modifications to equipment, systems, structures or components. The FSRC conducts 

audits and reviews of operations that could affect safety or health of the worker, public safety or 

environmental impacts. The FSRC consists of the Chairperson, who is appointed by the COO and shall 

have as a minimum at least one (1) member from each of the following organizations: ESH, radiation 

protection, QA, safety, training, engineering and Plant Manager. The ALARA Committee, as discussed in 

LA Revision B Chapter 4 supports the FSRC in matters related to radiation protection. The scope of 

activities reviewed and audited by the FSRC shall include, but are not limited to, the following: 

• Changes in facility, equipment, systems, structures or components IROFS designs in accordance 

with the IIFP QA Program 

• Radiation protection 

• Hazardous chemical safety 

• Environmental protection 

• Fire protection and safety 

• Industrial safety/industrial hygiene 

• ALARA policy implementation 

• Critiques of unusual events and adverse audit findings 

Requirements and minimum frequencies for audits conducted by the FSRC will be defined in the IIFP 

Quality Assurance Program implementation procedures. 

Members of the FSRC shall have as a minimum a bachelor’s degree in engineering or scientific field and 

at least three (3) years appropriate experience in their respective discipline in a chemical or nuclear 

facility. A minimum of five (5) years of experience in their respective discipline or job function in a 

chemical or nuclear facility may be substituted for the bachelor’s degree. 

2.2.11 Training Manager 

The Training Manager (TM) reports directly to the COO. During design and construction of the facility 

the TM is responsible for coordination with engineering in order to develop operating procedures for the 

various facility systems and for developing training programs for initial and recurrent operator, 

engineering, maintenance and support personnel. During facility operations the TM is responsible for the 

ongoing conduct of these training programs as well as well as maintain the facility document control 

system. 

The TM shall have as a minimum a bachelor’s degree in engineering or scientific field and a minimum of 

five (5) years in a chemical, radiological or nuclear facility, with at least three (3) of those years in 

responsible operations l assignments. The TM should have prior experience in nuclear facility training 

programs including conduct of operations principals and philosophies. 
LA-IFP-001 Revision B CHAPTER 2 October 27, 2011 

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2.3 MANAGEMENT MEASURES

Management measures discussed below are the formal methods applied to maintain IROFS at a needed 

level of reliability and availability. IIFP may also apply formal management measures to other important 

aspects of the facility operation. These methods ensure that protection and mitigation features are 

adequate to keep accidents within the bounds of acceptable risk. Management measures are applied, as a 

minimum, to all structures, systems and components associated with the performance of any IROFS. 

No management measure requirements or guidance is provided in 10 CFR Part 40 (CFR, 2009a), so the 

program elements defined in 10 CFR 70.4 (CFR, 2009b) were followed and are discussed below. 

Management measures are discussed in more detail in Revision B Chapter 11 of the IIFP LA. 

2.3.1 Configuration Management 

Configuration Management Program elements are specified in 10 CFR 70.72 (CFR, 2009d). The IIFP is a 

10 CFR 40 (CFR, 2009a) licensed facility, but owing to requirements for an ISA of the facility and 

associated IROFS, a CM Program is applicable. Such a program is implemented to ensure adequate 

change control for facility operations. Configuration management and control assures that any facility or 

process changes are evaluated appropriately and such changes are reflected in updated drawings, 

procedures and other facility documents. Configuration management ensures that all but “like kind or 

previously approved equivalent” replacement of equipment and minor non-process changes receives 

review and approval from the safety and licensing organizations. The impact of these changes 

(modifications) are evaluated and documented by the individual organizational groups. Corresponding 

safety and licensing documentation is updated in a timely manner following approval of the change. 

2.3.2 Maintenance 

The IIFP Maintenance Program shall be implemented prior to beginning the operations stage of the IIFP 

Facility. Maintenance activities include general repair and upkeep of facilities and processes along with 

preventive maintenance and testing of IROFS and important process controls. These activities are 

coordinated through safety group reviews and approval via safety work orders, hot work permits and 

radiation work permits (RWPs), as needed. Any maintenance activities on specific systems are evaluated 

for their impact on other, nearby systems. 

2.3.3 Training and Qualifications 

Training and qualifications requirements are established for each functional type of work. Qualifications 

will include minimum education, technical background, experience, etc., along with physical skills 

needed to perform individual tasks. Employees are provided formal classroom training and on-the-job 

(OTJ) training specific to their duties, as applicable. Workers shall read, understand and follow formal 

area procedures when performing work. Additionally, workers shall understand and obey requirements in 

work orders, hot work permits and radiation work permits (RWPs) along with posted limits and controls. 

Job Task Analysis is used, as needed, to supplement training when tasks associated with IROFS are 

involved. 

Along with job specific training mentioned above, all employees are given formal general employee 

training and safety training, as needed. General worker training includes site access information and an 

overview of site hazards, emergency alarms and evacuation plans. Safety training may include radiation 

worker training, hazards communication and general health and safety training. Training and qualification 
LA-IFP-001 Revision B CHAPTER 2 October 27, 2011 

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related documentation is maintained as quality records. Continuing training and improvement is stressed 

for the entire workforce. 

2.3.4 Procedures 

Production work aside from routine custodial and office duties are governed by approved procedures, 

where applicable. Additionally, program requirements, including these management measures, are 

implemented via procedures, where applicable. Procedures are necessary to provide consistent and 

reliable performance of site wide activities. IROFS and other safety related items are highlighted in work 

procedures, typically as “cautions” and “warnings.” 

Procedures are developed and approved by the responsible organizations. Employees are trained on all 

procedures they follow as part of their work assignments. Work procedures and supplemental safety 

related procedures are expected to be located in the general work areas. Temporary work shall be 

performed under temporary work orders or RWPs. 

Facility and process changes require procedure updates in the form of revisions. Such revisions shall be in 

place before restart of the operation can commence. Changes to safety systems and safety basis 

documentation shall also be incorporated into respective procedures. Employees are retrained on the 

revised procedures before the restart of work. 

2.3.5 Audits and Assessments 

Audits and/or inspections are periodically performed on many operations at the facility site, both for 

production and nonproduction related activities, where applicable. Assessments are also routinely 

performed, but are generally focused on support programs such as environmental, health and safety 

programs. Audits/inspections focus on review of certain aspects of compliance whereas assessments look 

more generally at program and process performance. The frequency of audits/inspections and assessments 

vary based on the safety aspects of the activities performed. Inspections are expected to be routine and 

frequent. Most production areas walk down and inspect work areas daily. Safety organizations perform 

routine inspections over various process areas. The more formal audits are performed quarterly or 

annually and generally focus on safety and regulatory compliance issues. Program or process assessments 

are performed on an as-needed basis based on performance trends and identified needs. Records of audit, 

inspections and assessments are maintained as a quality record. 

2.3.6 Incident Investigations and Corrective Actions 

Incidents and accidents are formally investigated in accordance with the IIFP QA Program and as 

described in the LA, Revision B Chapter 11 Section 11.6 “Incident Investigations and Corrective Action 

Program.” Where applicable the investigations are performed by IIFP personnel with knowledge of the 

process systems involved, the safety areas affected and formal incident/accident investigation 

methodologies. When an incident occurs, management forms a qualified team that determines root causes 

of the event and develops recommendations to reduce the likelihood of recurrence. Lessons learned are 

also developed so other organizations can review their operations for similar type initiators. 

Incidents/accidents are tracked and trended to identify weaknesses in types and areas of operation and to 

look for common causes of events. Corrective actions are assigned and tracked programmatically to 

ensure that timely and adequate corrections to deficiencies are incorporated. Any required plant changes 

as a result of corrective actions follow the management methods described above. Corrective actions are 
LA-IFP-001 Revision B CHAPTER 2 October 27, 2011 

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closed out in facility records when implementation is complete or adequate justification for not 

implementing the corrective action is properly documented. 

2.3.7 Employee Concerns 

All IIFP employees and contractor personnel working on-site have the responsibility and right to initiate a 

“stop work” process, relative to any safety or health concerns, in accordance with the project or facility 

procedures to ensure the workplace and associated work activities are safe. 

Employees are trained to notify the designated-work-activity IIFP supervisor of a concern or questionable 

safety practice or condition. Contractors and sub-contractors receive orientation on the responsibility and 

reporting of personnel safety/health concerns. The IIFP supervisor who is notified evaluates the activity 

or condition and determines if the activity is in safe compliance with the procedure, or if the procedure 

requires a change to improve the safety of the work or condition. Any IIFP supervisor has the authority to 

stop the work task and request technical assistance and advice from the ESH lead staff for resolving the 

safety concern before resuming the work activity. If the concerned person remains concerned with the 

proposed resolution, they have the right and responsibility to elevate the concern to the Shift 

Superintendent or Area Shift Supervisor and/or the ESH Manager for further review and resolution. 

If a “stop work” decision is made, the Shift Superintendent or Area Shift Supervisor is notified to ensure 

the stoppage does not adversely affect the equipment, processes, systems or facility such as to cause 

unsafe conditions or potential chemical releases. Except in cases of immediate or life-safety emergencies, 

the Shift Superintendent or Area Shift Supervisor is notified prior to the actual “stop-work” action. 

Employees and contractors are also trained to be aware that other avenues of reporting and resolving 

safety concerns are available and that employees and other persons on-site have the right and 

responsibility to utilize those resources. Persons working on-site have access to the following methods for 

reporting, correcting or improving quality or safety related concerns and suggestions: 

• Direct contact with any member of the ESH or QA organizations 

• Immediate notification of any line supervisor, Shift Superintendent or facility management 

• Submittal of a safety suggestion in accordance with the Industrial Safety Suggestion Program 

procedures 

• Notification to any member of the FSRC or ALARA committee 

• “Open door” with the ESH Manager, QA Manager, COO, Plant Manager or the IIFP President 

• NRC requirements under 10 CFR 19, “Notices, Instructions and Reports to Workers: Inspection 

and Investigations,” (CFR, 2009c) 

• Unusual event or potential problem report form submitted to their immediate supervisor or the 

Shift Superintendent office per the IIFP Performance Assessment and Improvement procedure 

2.3.8 Records Management and Document Control 

Records associated with the above management measures program elements are retained in accordance 

with applicable QA procedures. The records are systematically controlled and stored and are easily 
LA-IFP-001 Revision B CHAPTER 2 October 27, 2011 

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retrievable for individuals, groups, programs and activities. All facility and process design elements and 

items relating to environmental protection and to the safety and health of workers and the public are 

maintained as a quality record. The Records and Documents organization is ultimately responsible for 

maintaining facility records, though some records retention will be delegated to specific organizations 

such as with Training document control. 

2.3.9 Written Agreements with Off-site Emergency Resources 

The approach to address site emergencies and the use of off-site emergency resources are described in 

Revision B Chapter 8 “Emergency Management” of the IIFP LA and Revision B of the “Emergency 

Management Plan.” 

 
LA-IFP-001 Revision B CHAPTER 2 October 27, 2011 

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REFERENCES 

CFR, 2009a Title 10, Code of Federal Regulations, Part 40, “Domestic Licensing of Source 

Material,” U.S. Regulatory Commission, 2009. 

CFR, 2009b Title 10, Code of Federal Regulations, Section 70.4, “Definitions,” U.S. Nuclear 

Regulatory Commission, 2009. 

CFR, 2009c Title 10, Code of Federal Regulations, Part 19, “Notices, Instructions and Reports to 

Workers: Inspection and Investigations,” U.S. Nuclear Regulatory Commission, 2009. 

CFR, 2009d Title 10, Code of Federal Regulations, Section 70.72, “Facility Changes and Change 

Process,” U.S. Nuclear Regulatory Commission, 2009.