ML18204A405
| ML18204A405 | |
| Person / Time | |
|---|---|
| Issue date: | 10/02/2018 |
| From: | Dan Collins NRC/NMSS/DMSST |
| To: | Andersen J, Boland A, Tison Campbell, Craig Erlanger, Mike Franovich, Jack Giessner, Mark Miller, Troy Pruett, James Trapp Office of Nuclear Material Safety and Safeguards, Division of Fuel Cycle Safety, Safeguards, and Environmental Review, Office of Nuclear Reactor Regulation, Office of Nuclear Security and Incident Response, NRC/NSIR/DPCP, Office of Congressional Affairs, NRC/OE, NRC/OGC, NRC Region 1, NRC/RGN-III, NRC Region 4 |
| Lee W | |
| References | |
| Download: ML18204A405 (4) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 2, 2018 MEMORANDUM TO:
Those on the Attached List FROM:
Daniel S. Collins, Director Division of Materials Safety, Security, State and Tribal Programs
/RA S Atack for D S Collins/
Office of Nuclear Material Safety and Safeguards
SUBJECT:
REVISION OF INSPECTION PROCEDURE FOR 10 CFR PART 37 MATERIALS SECURITY PROGRAMS Attached for your review and comment is the first revision of Inspection Procedure (IP) 87137, 10 CFR Part 37 Materials Security Programs. The IP addresses the requirements outlined in Title 10 of the Code of Federal Regulations (10 CFR) Part 37, Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material.
On June 2014, the Government Accountability Office (GAO) issued an audit report (GAO-14-293) entitled Nuclear Nonproliferation: Additional Actions Needed to Increase Security of U.S. Industrial Radiological Sources. As part of the response to the report, the U.S. Nuclear Regulatory Commission (NRC) committed to evaluate a GAO recommendation to consider whether the definition of collocation should be revised for well logging facilities that routinely keep radiological sources in a single storage area but secured in separate storage containers.
The NRC evaluated this recommendation through its efforts to perform the congressional mandated review of 10 CFR Part 37. As a result of the staffs efforts, the 10 CFR Part 37 Program Review Team (PRT) determined that the definition of aggregation, previously referred to as collocation, is clear and does not need to be changed.1 In addition, the PRT determined that the security requirements in Part 37 provide adequate protection for well logging sources in storage.
As a result of the review, the PRT did make a recommendation for enhancements to guidance specific to aggregation to ensure that the implementation of appropriate security measures is understood by licensees and evaluated accordingly by inspectors. The PRT referred the recommendation to the Part 37 Implementation Working Group (IWG) for follow up. The Working Group recommended a revision to IP 87137 to enhance inspection guidance and ensure inspectors assess licensees potential to aggregate materials as part of routine inspections.
CONTACT: Willie Lee, NMSS/MSST (301) 415-8024 1 Summary of NRC Staff Program Review of 10 CFR Part 37 (Agencywide Documents Access and Management Systems Accession No. ML17019A411).
The PRT recommended that the IWG address the need for additional guidance related to the review of trustworthiness and reliability determinations for reviewing officials. The IWG recommended a revision to IP 87137. Specifically, IP 87137 is being revised to provide specific inspection guidance regarding the review of procedures developed and records used by the licensee to support its determination that the reviewing official is deemed trustworthiness and reliability if they have unescorted access to category 1 and 2 quantities of radioactive material.
Also, a correction of an error in the existing text of Section 03.01.04(c) is included in the revision.
Although this IP is for use by NRC inspectors, it may also be used by Agreement States.
Comments on the revision of IP 87137 are being sought separately from the Agreement States in parallel to this request. Written comments, from designated staff members, should be submitted to the contact listed below within 30 days from the date of this memorandum.
Comments of an editorial nature will be considered; however, the revised text may undergo additional technical editing and formatting by the NRC staff prior to publication.
If you have any questions regarding this correspondence, please contact me at (301) 415-3340 or the individual named below:
POINT OF CONTACT: Willie Lee E-MAIL: Willie.Lee@nrc.gov TELEPHONE: (301) 415-8024
Enclosure:
Revised Inspection Procedure 87137
MEMORANDUM TO THOSE ON THE ATTACHED LIST Anne T. Boland, Director, Office of Enforcement RidsOeMailCenter Resource Jim Andersen, Director, Division of Physical RidsNsirMailCenter Resource and Cyber Security Policy, NSIR Craig Erlanger, Director, Division of Fuel Cycle Safety, Safeguards and Environmental Review, NMSS RidsNmssFcss Resouce Tison Campbell, Acting Associate General Counsel, RidsOgcMailCenter Resource Licensing and Regulation, OGC Mark Miller, Director, Division of Inspection and Regional Support, NRR RidsNrrMailCenter Resource Michael X. Franovich, Director, Division of Risk Assessment, NRR RidsNrrMailCenter Resource James M. Trapp, Director, Division of Nuclear Materials Safety, Region I RidsRgn1MailCenter Resource John B. Giessner, Director, Division of Nuclear Materials Safety, Region III RidsRgn3MailCenter Resource Troy Pruett, Director, Division of Nuclear Materials Safety, Region IV RidsRgn4MailCenter Resource
SUBJECT:
MEMORANDUM RE: REVISION OF INSPECTION PROCEDURE FOR 10 CFR PART 37 MATERIALS SECURITY PROGRAMS DATED: OCTOBER 3, 2018.
ML18204A409 OFC NMMS/MSST/SMPB NMMS/MSST/MSLB NMMS/MSST NAME WLee TSmith SAtack for:DCollins DATE 7/24/2018 7/24/2018 10/2/2018 OFFICIAL RECORD COPY