ML14203A135
| ML14203A135 | |
| Person / Time | |
|---|---|
| Issue date: | 03/19/2014 |
| From: | Adelaide Giantelli NRC/FSME/DMSSA/NMPD/SMPB |
| To: | Landis R Nuclear Energy Institute |
| Goldberg P | |
| References | |
| Download: ML14203A135 (2) | |
Text
From: Giantelli, Adelaide To: "LANDIS, Raymond (rll@nei.org)"
Cc: Goldberg, Paul; Lee, Willie; DeCicco, Joseph
Subject:
Part 37 Exemption Request Template Date: Wednesday, March 19, 2014 8:39:59 AM Good morning Ray, This is just a follow-up to our discussion during the March 4th meeting. Weve completed our review of the Part 37 Exemption Request Template and our comments are below.
- 1. Radiological controls are adequate to control radiation exposure during normal operations, but may not be adequate to satisfy Part 37 requirements. Part 37 requires a physical protection program to provide reasonable assurance of the security of category 1 and 2 quantities of radioactive material. The objective is for the licensee to detect malicious activity and to call for local law enforcement to respond to the event.
- 2. The provided template is generic, however an exemption request should be specific to address each licensees unique situation. An exemption request should contain the following:
- A description of the exemption being sought, the regulatory requirements involved, why it is being requested, how it relates to plant operations, whether the licensee is requesting a temporary or permanent exemption, and any effect on the plants licensing basis;
- The licensee's safety analysis and/or justification for the proposed exemption. The licensee should address why it believes that the exemption being sought is authorized by law, how approval will not present an undue risk to the public health and safety, and why it is consistent with the common defense and security;
- The licensees safety analysis that supports the proposed exemption should include technical information in sufficient detail, including risk assessment impacts (as appropriate),
to enable the NRC staff to make an independent assessment regarding the acceptability of the proposal; and
- The submittal should also include the licensees requested schedule for staff issuance of the exemption, and any plant operational considerations affected by the staffs decision.
Please contact me if you have any questions.
- Regards, Adelaide Adelaide S. Giantelli Chief, Source Management and Protection Branch office: 301-415-3521 color NRC seal
From: Giantelli, Adelaide Sent: Monday, February 24, 2014 9:43 AM To: LANDIS, Raymond (rll@nei.org)
Cc: Goldberg, Paul; Lee, Willie; DeCicco, Joseph
Subject:
Part 37 Security Plan Template Good morning, Weve completed our review of the Part 37 Security Template and our comments are attached. We are continuing to work on a draft enforcement guidance memorandum to address large components and robust structures. Please contact me if you have any questions.
- Regards, Adelaide Adelaide S. Giantelli Chief, Source Management and Protection Branch office: 301-415-3521 color NRC seal