ML19274E355
| ML19274E355 | |
| Person / Time | |
|---|---|
| Site: | 07000025 |
| Issue date: | 02/19/1979 |
| From: | Remley M ROCKWELL INTERNATIONAL CORP. |
| To: | Burnett R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 7903230068 | |
| Download: ML19274E355 (2) | |
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,d Telegnone:(213) 341 1000 RoCkWe.11 M Internat10Dal j.'cceiv J C7.......bh TVot 910L 494-1237 Telex: 181017 February 19, 1979 In reply refer to 79ESG-1851 1
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Robert F. Burnett, Director i
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Division of Safeguards Office of Nuclear Material Safety and Safeguards By..... -
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Dear Mr. Burnett:
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Subject:
Security Personnel Training Plan, Docket No.70-25_
As required by the recent changes in Section 73. 50(h) of 10 CFR 73, the Energy Systems Group training and qualification plan for security per-sonnel is submitted for your review and approval. This plan has been developed in accordance with the requirements described in Appendix B of 10 CFR, Part 73.
The plan outlines the processes for selecting, training, and qualifying security personnel to provide protection against industrial sabotage and theft or diversion of special nuclear material associated with the activities authorized in Special Nuclear Material License SNM-21. Ten copies of ESG-79-4, " Security Personnel Train-ing and Qualification Plan for Rockwell International Energy Systems Group Headquarters Facility," which describes our program, are enclos e d.
As indicated in the document, the plan contains information of a type specified in 10 CFR 2. 790(d) and is therefore deemed to be commer-cial and financial information within the meaning of 10 CFR 9. 5(a)(4) and shall not be subject to public disclosure.
Discussions with members of the Division of Safeguards staff have indi-cated that the review and licensing action on this submission is subject to an aoplication fee of $8,300 for a major safeguards amendment to our Special Nuclear Material License SNM-21. as specified in Section 170. 31 (1A) of 10 CFR 170.
Therefore, we are enclosing our check in the amount of $3. 300 payable to the U. S. Nuclear Regulatory Commission in payment for the fee.
Howe ee:. ve wish to point out that this submission of the enclosed plan is bein rrade solely in responu to a new regulatory requirement. We have not been and currently are not applying for any new authority or activity to be implemented under SNM-21, nor are cze applying for any license amendment.
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R. F. Burnett
'N February 19, 1979 J
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_'3 Previously approved plans describing our special nuclear materials safeguards programs have contained the basic requirements for training and qualification of the security personnel, and the current submission provides more detailed description of extensions of the existing program. We submit that licensees required to comply with new regulations should not be subject to the imposition of appli-cation fees for amendments to existing licenses. We believe the current interpretation of the applicability of license amendment ap-plication fees in this case is highly irregular, and we solicit review and reconsideration.
If you have questions or require additional information, please con-tact me at (213) 341-1000, Extension 2238.
Sincere 1 M. E. Remie, Di ct ar Health, Safety and Ra lation Services MER:cc Enclo sure s : 1) Ten (10) copies of ESG-79-4
- 2) ESG Check in the amount of $8,300
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fl0TICE T0 flRC PUBLIC DOCUMElli ROOM The following item (s) are being withheld from public disclosure pursuant to the Atomic Energy Act of 1954, as amended, and the Energy Reorganization Act of 1974.
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