ML19084A048
| ML19084A048 | |
| Person / Time | |
|---|---|
| Site: | Erwin |
| Issue date: | 04/01/2019 |
| From: | Jacob Zimmerman NRC/NMSS/DFCSE/FLB |
| To: | Freudenberger R Nuclear Fuel Services |
| Ramsey K | |
| Shared Package | |
| ML19084A021 | List: |
| References | |
| EPID L-2018-SPR-0005 | |
| Download: ML19084A048 (3) | |
Text
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION SAFEGUARDS EVALUATION REPORT DOCKET NO.: 70-143 LICENSEE: NUCLEAR FUEL SERVICES, INC., SNM-124
SUBJECT:
AMENDMENT 11 - APPROVAL OF PHYSICAL PROTECTION PLAN, REVISION 20 (ENTERPRISE PROJECT IDENTIFIER (L-2018-SPR-0005)
1.0 BACKGROUND
By letter dated September 21, 2018, Nuclear Fuel Services, Inc. (NFS) submitted Revision 20 of the Physical Protection Plan (PPP) for review and approval by the U.S. Nuclear Regulatory Commission (NRC) in accordance with Title 10 of the Code of Federal Regulations (10 CFR)
Section 70.34 (Agencywide Documents Access and Management System [ADAMS] Accession Number ML18270A377). On November 29, 2018, NRC staff issued a request for additional information (ADAMS ML18323A357). On January 31, 2019, NFS submitted their response to the request (ADAMS ML19036A893).
By letter dated March 8, 2019, NFS resubmitted Revision 20 of the PPP (ADAMS ML19071A086) for review and approval by the NRC in accordance with 10 CFR 70.34. In addition to the two previous 10 CFR 70.34 changes submitted in the September 21, 2018, PPP, this submittal requested NRC approval to remove an administrative change proposed in the original submission.
Revision 20, dated March 8, 2019, replaces Revision 19 in its entirety.
2.0 REGULATORY EVALUATION
The purpose of this review was to determine whether the changes made to Revision 20 of the NFS PPP under the provision of 10 CFR 70.34 would maintain the safeguards effectiveness of the facilitys physical protection program.
3.0 TECHNICAL EVALUATION
3.1 The NRC staff reviewed the revisions submitted per 10 CFR 70.34 for PPP Revision 20, dated September 21, 2018.
The Enclosure is transmitted with documents containing Sensitive Security-Related Information. When separated from Sensitive License Conditions and the Safeguards Evaluation Report, this Enclosure is decontrolled.
Enclosure 2 OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION 3.1.1 Interim Compensatory Measure (ICM) Order number EA 02-CAT I, dated August 21, 2002, Requirements A.2., A.3., and D.3.
Change # 1: Sections 2.1 and 3.0. The licensee had previously committed to meet an alternative measure instead of the ICM requirements. In Revision 20, NFS has removed the commitment to meet an alternative measure and, instead, provided justification that they are now meeting the original ICM requirements.
RAI 1: In order to ensure all aspects of the ICM Order Requirements A.2.,
A.3., and D.3. are being met, revise the section with additional information.
NFS Response - The licensee supplied additional information on the justification for meeting all aspects of the applicable ICM requirements.
This information is Confidential-National Security Information.
Meeting the original requirements instead of an alternative measure does not reduce the safeguards effectiveness of the physical protection program.
3.1.2 Paragraph 73.45(g)(3)(ii) of 10 CFR. Provide for response by assigned security organization personnel which is sufficiently rapid and effective to achieve the predetermined objective of the response.
Change # 2: Section 5.3.1. The licensee adjusted the security response within the owner controlled area.
Adjusting a security response while maintaining comparable coverage does not reduce the safeguards effectiveness of the physical protection program.
3.2 The NRC staff reviewed the revisions submitted per 10 CFR 70.34 for PPP Revision 20, dated March 8, 2019.
3.2.1 Section 70.9 of 10 CFR. Information provided to the Commission by an applicant for a license or by a licensee or information required by statute or by the Commissions regulations, orders, or license conditions to be maintained by the applicant or the licensee shall be complete and accurate in all material respects.
Change # 1: Section 1.0. The licensee removed language submitted as a 10 CFR 70.32(e) change in the September 21, 2018 version.
Removing a proposed administrative change does not reduce the safeguards effectiveness of the physical protection program.
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION 2
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION 4.0 ENVIRONMENTAL REVIEW This action is related solely to safeguards matters that do not involve any significant construction impacts. The revised security measures are considered procedural matters that are categorically excluded from an environmental review under 10 CFR 51.22(c)(12)(i).
Therefore, neither an environmental assessment nor an environmental impact statement is warranted for this action.
5.0 CONCLUSION
The NRC staffs review of the licensees PPP, Revision 20, dated September 21, 2018, additional information, dated January 31, 2019, and the resubmitted PPP, dated March 8, 2019, contain information that has been marked as CONFIDENTIAL-NSI by the applicant, pursuant to 10 CFR Part 95.
The methods and procedures outlined in NFSs PPP Revision 20, dated March 8, 2019, satisfy the performance objectives, systems capabilities, and reporting requirements specified in 10 CFR 73.45, 73.46 and all classified NRC Orders. Therefore, NRC staff finds the NFS PPP Revision 20, dated March 8, 2019, is acceptable and provides reasonable assurance that the requirements for the physical protection of Strategic Special Nuclear Materials will be met.
6.0 REFERENCES
10 CFR 73.45, Performance capabilities for fixed site physical protection systems.
10 CFR 73.46, Fixed site physical protection systems, subsystems, components, and procedures.
Process Control Limit Order, dated July 20, 2000 (C-NSI)
Interim Compensatory Measure Order number EA 02-CAT I, dated August 21, 2002 (S-NSI)
Interim Compensatory Measure Order number EA 03-DBT, dated April 29, 2003 (S-NSI)
Request for Additional Information, dated November 29, 2018 (C-NSI)
NFS Response to Request for Additional Information, dated January 31, 2019 (C-NSI)
PRINCIPAL CONTRIBUTORS:
Rebecca Stone, NSIR/DPCP 301-287-9299 Johari Moore, NSIR/DPCP 301-287-3787 OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION 3