ML19305C586

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IAEA - Brazil Presentations - Us NRC Security Requirements (3 of 4)
ML19305C586
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Issue date: 10/09/2019
From: Jason Vonehr
NRC Region 4
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U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment U.S. NRC Security Requirements Jason vonEhr Health Physicist U.S. NRC Region IV 9 October 2019

Objectives for NRC Security Requirements Presentation

  • To introduce the basis for the NRC Security Requirements and their background
  • To review the applicability of the different security regulatory requirements
  • To review the application of these requirements with well logging operations 2 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment

Byproduct radioactive material security since September 11, 2001 2018 Mar - 10 CFR Part 37 rulemaking plan for NEI proposed revisions due Aug - Response to SRM on Baran COM due Mar - 10 CFR Part 37 compatibility for Agreement States Mar - Nuclear Security Summit 2016, Washington DC Dec - Report to Congress on effectiveness of Part 37 due 2016 Jan - NRC, DOT and DHS Transportation Security MOU Apr - Commence 10 CFR Part 37 Program Review 2015 Mar - 10 CFR Part 37 compliance for NRC licensees and Nuclear Security Summit, Hague, Netherlands Apr - NRC Rescinds Orders against NRC licensees and Report to Congress Jun- GAO issues Additional Actions Needed to Increase the Security of Industrial Radiological Sources 2014 Aug - Third Task Force Report on Source Security Issued Dec - FY15 Energy Water Appropriations Act Mar - FRN 10 CFR Part 37 and Part 37 Implementation Guidance published May - License Verification System deployed 2013 Mar - Commission Approves Part 37 and Nuclear Security Summit, Seoul, South Korea Aug - Web-Based Licensing deployed Oct - GAO Additional Actions Needed to Improve Security of Sources at Medical Facilities 2012 Nov - NRC Hosts International Regulators Conference Jul - NRC Policy Statement for Security and use of cesium chloride Apr - Nuclear Security Summit, Washington, DC sources 2011 Jun - NRC Proposed Rule Part 37 Sep - NRC and NNSA Joint Report to Congress on Protecting Radioactive Sources Aug - Report by Radiation Source Protection and Security Task Force 2010 Jan - Licensee NSTS Reporting Begins Jun - NSTS Expansion Rule - not approved Dec - NRC Trustworthiness and Reliability Order for unescorted 2009 access to Category 1 and 2 for Service Providers Feb - NAS Radiation Source Use and Replacement Study Sep - NRC Pre-licensing guidance revised 2008 Jul GAO Actions Taken by NRC to Strengthen licensing process for Radioactive Sources Not Effective Dec - NRC and Agreement State Unescorted Access Fingerprinting Requirements 2007 Aug Radiation and Source Protection and Radiation Task Force Report Sep-Nov SGI Fingerprinting Orders Nov Part 20 National Source Tracking 2006 Jul Part 110 export and import rule, Category 1 and 2 NRC Transporters of Category 1 Orders Aug Energy Policy Act of 2005 2005 Nov NRC and Agreement State Increased Controls Requirements Jan IAEA, Code of Conduct on the Safety and Security of Radioactive Sources 2004 NRC Manufacturers and Distributors Order Jun G-8 Summit, Sea Island, Georgia, USA May NRC and DOE Report, Radiological Dispersal Devices Jun NRC Irradiator Orders 2003 Security advisories issued for voluntary security measures 2002 Security requirements for inadvertent entry and simple theft are in 10 CFR Part 20.1801 and 20.1802, plus other 2001 3 sections

Background - NRC Security Requirements Security Requirements as of today

  • 10 CFR Part 37 - for aggregate category 1 & 2 quantities of radioactive material
  • Additional commitments made by the licensee tied to the license, e.g. procedures for key-control or activation restrictions for prompt fission neutron sources (accelerator-based neutron generators) 4 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment

Security in Part 20 Security Requirements as of today

  • 10 CFR 20.1802 - control and surveillance of licensed material not-in-storage Applies to all NRC licensed materials, sealed and unsealed, regardless of device, quantity (with minor exceptions), or authorized use 5 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment

Security in Part 39 Security Requirements as of today

  • 10 CFR 39.31 - (transport and storage) locked and physically secured to prevent tampering or removal by unauthorized personnel, minimize danger from explosion or fire
  • 10 CFR 39.71 - Supervision of sources at temporary job sites during handling or when not in storage Specific to sources regulated under 10 CFR Part 39 6 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment

Security in Part 37

  • Applies only to aggregate category 1 and 2 quantities of radioactive material
  • Categories of radioactive quantities referenced from IAEA Safety Standards, Categorization of Radioactive Sources
  • NRC

Reference:

10 CFR Part 37, Appendix A 7

U.S. National Materials Management Program

- Integrated Source Management Portfolio

  • Up-to-date accounting
  • Stores Category 1 and
  • Automates verification of Category 1 and 2 2 licenses checks using WBL and sources in the U.S.
  • Capability to serve as NSTS data
  • Over 1,400 licensees nationwide license
  • Users - regulators, and 80,000 sources repository for over government agencies,
  • Annual Inventory 20,000 licenses distributors/ licensees Reconciliation
  • Needed to support
  • Deployed 2013
  • Deployed 2008 license verification
  • Deployed 2012

- Integrated Source Management Portfolio

General Purpose of 10 CFR Part 37 To provide reasonable assurance of the security of Category 1 and Category 2 radioactive material by protecting from theft or diversion 9

Inspection Procedure

  • Provides specific inspection guidance for three focus areas:

- Background Investigations and Access Authorization Programs

- Physical Protection Requirements During Use

- Physical Protection During Transit 10

10 CFR Part 37 Appendix A, Table 1 Values for sources typically used in well logging Units of compliance are in TBq (Regulatory Standard Conversion)

Radioactive Material Category 1 Category 1 Category 2 Category 2 (TBq) (Ci) (TBq) (Ci)

Americium-241/Beryllium 60 1,620 0.6 16.2

(.5994) 16.2 Cesium-137 100 2,700 1 27.0

(.9990) 27.0 11

Aggregated Sources

1. The aggregate activity of multiple, collocated sources of the same radionuclide should be included when the total activity equals to or exceeds the Cat 1 or Cat 2 thresholds (pages 9-11 of NUREG 2155, Rev 1).
2. The terabequerel (TBq) value is the Regulatory Standard.
3. Radioactive materials are to be considered aggregated or collocated if breaching a Common Physical Security Barrier (e.g., a locked door at the entrance to a storage room) would allow access to the radioactive material or devices containing the radioactive material.
4. If several radionuclides are aggregated, the Sum of Fractions method for evaluating combinations of multiple sources or multiple radionuclides is to be used. Unity Rule
5. The curie (Ci) values are rounded to two significant figures for informational purposes only.

12 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment

Aggregate & Unity Rule The aggregated radioactive material of the same radionuclide should be included when the total activity equals or exceeds the Cat 1 & Cat 2 threshold.

If several radionuclides are aggregated, the sum of the fractions of the activity of each source where, (Activity of radionuclide source) ÷ (Threshold activity value for source).

Does the sum of the fractions equal to or exceed one?

13

10 CFR Part 37 - Subparts Addresses:

Subpart A - General Provisions Subpart B - Background Investigations and Access Control Programs Subpart C - Physical Protection Requirements During Storage / Use Subpart D - Physical Protection in Transit 14

10 CFR 37 Subpart B - Background Investigations and Access Control Program

  • Limit unescorted access to approved individuals
  • Trustworthiness & Reliability

- Initial investigation and Reinvestigation every 10 Years

- Determinations and documentation made by licensees Reviewing Official

- Annual Review Audit of access authorization program content and implementation 15 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment

10 CFR 37 Subpart C - Physical Protection During Storage & Use

  • Development and Implementation of a Written Security Program and Security Plan implementing procedures

- Training on the licensees security program, responsibilities, etc.

  • Establish permanent or temporary Security Zones
  • Monitor, detect, assess, respond

- Maintenance and testing of systems

- LLEA coordination (annual review)

  • Requirements for mobile/portable devices (important for well logging)
  • Annual training & review of the security program 16 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment

Principle Requirements of a Security Program Monitor, Detect, Assess, Respond

  • Continuous monitoring of points of access
  • Immediate detection of unauthorized access

- All reasonably foreseeable unauthorized access

  • Detect unauthorized removal of material
  • Assessment by automated devices or trained personnel
  • Initiation of armed response without delay 17 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment

Subpart C: Physical Protection Requirements During Use 10 CFR 37.41(a)

Applicability:

  • Licensees that possess an aggregated Category 1 or Category 2 quantity
  • New licensee before taking possession of aggregated Category 1 or Category 2 quantity
  • Existing licensees newly subject to 10 CFR 37

- Notify NRC (AS) 90 days before aggregating Category 1 or Category 2 quantity 18 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment

Subpart C: Physical Protection Requirements During Use 10 CFR 37.41(b)

General Performance Objective

  • Each licensee shall establish, implement, and maintain a security program that is designed to monitor and, without delay, detect, assess, and respond to an actual or attempted unauthorized access to Category 1 or Category 2 quantities of radioactive material 19 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment

Requirements for Mobile Devices (1)

(10 CFR 37.53(a))

  • Licensees that possess mobile devices containing Category 1 or Category 2 quantities of radioactive material must:

- Have two independent physical controls that form tangible barriers to secure the material from unauthorized removal when the device is not under direct control and constant surveillance by the licensee 20 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment

Requirements for Mobile Devices (2)

  • 2 independent physical controls 21

Requirements for Mobile Devices (3)

  • Vehicle disabling mechanism (w/ exception) 22

Aggregation DURING TRANSPORT RAM and devices are automatically considered aggregated during transport Applies whether or not vehicle/trailer have been immobilized Regardless of position of RAM or devices in or on vehicle/trailer Regardless of number and configuration of physical barriers RAM/devices in or on separate vehicles/trailers within close proximity at a site/location, are considered aggregated (Regulatory Issue Summary 2007-07) 23

10 CFR 37 Subpart D- Physical Protection in Transit

  • Verification of license before transfer
  • Pre-planning and coordination of arrival time/confirm receipt
  • Different requirements for Category 1 versus Category 2 shipments
  • Requirements for communications
  • Package tracking, investigations
  • Reporting of events 24 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment

Aggregated Sources Sources were stored in a bunker room which was locked &

physically secured 25

Aggregated Sources Sources were stored in a lock box which was locked &

physically anchored to the ground.

26

Storage Bunkers 27

Aggregated Sources Sources were individually locked stored down-hole within a chain-link fence locked & physically secured. 28

Aggregated Sources Sources were stored in down-hole sleeves within a chain-link fence locked & physically secured. A locked steel rod linked all the sleeves through eye bolts atop each cover. 29

Aggregated Sources Sources were stored down-hole behind a locked and physically secured door. 30

Aggregated Sources Sources were stored in cages inside a room behind a locked and physically secured door. Each cage has a locked lid 31

Does 10 CFR Part 37 Apply?

Down-hole storage with Two (2) independent physical barriers. Co-Located??

32

Aggregated Sources Sources were stored in down-hole storage with Two (2) independent locks. Trust But Verify 33

10 CFR Part 37 Implementation Guidance NUREG-2155 (Rev.1) https://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr2155/

Direct PDF:

https://www.nrc.gov/docs/ML1501/ML15016A172.pdf 34

NUREG-2155: Implementation Guidance

  • Intended for use by applicants, licensees
  • Presented in Question/Answer format, and is separated by each requirement of Part 37
  • Different approaches are acceptable if they satisfy the requirements 35 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment

Regulation text Plain language explanation Question and Answer 36

NUREG-2155: Implementation Guidance

  • Annex A:

- Additional Guidance for Evaluating an Individuals Trustworthiness and Reliability

  • Annex B:

- Sample Consent Form for Background Investigations

  • Annex C:

- Examples of Reportable Suspicious Activities (10 CFR 37.57(b))

  • Annex D:

- Template for Advance Notifications (Cat 1) (10 CFR 37.77(b))

  • Appendix A

- Table of Category 1 & 2 RAM 37

10 CFR Part 37 Best Practices Guidance NUREG-2166 https://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr2166/

Response to Government Accountability Office report findings and recommendations (Sept 2012) https://www.gao.gov/products/G AO-12-925 38

NUREG-2166 Physical Security Best Practices for the Protection of Risk Significant Radioactive Material

- Description of an effective Physical Protection Program

- Administrative Security Measures

- Physical Security Best Practices that apply to all facilities

  • Defining the Security Zone
  • Monitoring the Security Zone
  • Alarm Assessment and Response

- Physical Security best practices for Mobile and Transportation Operations 39 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment

NUREG-2166 Physical Security Best Practices for the Protection of Risk Significant Radioactive Material

- Appendices

  • Developing a Physical Security Plan
  • Physical Security best practices for:

- Panoramic and Underwater Irradiators

- Self-shielded Irradiators

- Fixed Gauges

- Medical Devices that contain Risk-Significant Radioactive Material

- Manufacturing and Distribution Facilities

- Well Logging Sources

- Industrial Radiography Sources

  • National Nuclear Security Administration (NNSA) security initiatives (Formerly Global Threat Reduction Initiative -

GTRI; now Office of Radiological Security - ORS) 40 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment

Best Practices Document

  • Supplement existing guidance for licensees on how to adequately secure equipment containing high-risk radiological sources and conduct trustworthiness and reliability NOT A BEST PRACTICE determinations.

41

Objectives for NRC Security Requirements Presentation

  • Understand the basis for the NRC Security Requirements and their background
  • Understand the applicability of the different security regulatory requirements
  • Understand the application of these requirements with well logging operations 42 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment

Questions?

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