ML20079A149

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Interim Licensing Criteria for Physical Protection of Certain Storage of Spent Fuel
ML20079A149
Person / Time
Issue date: 11/30/1994
From: Dwyer P
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
References
NUREG-1497, NUDOCS 9412300178
Download: ML20079A149 (20)


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NUREG-1497 Interim Licensing Criteria for Physical Protection of Certain Storage of Spent Fuel l

U.S. Nuclear Regulatory Commission OITice of Nuclear Material Safety and Safegu. -ds P. A. Dwyer pW ""%,

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j AVAILABILITY NOTICE 1

Availability of Reference Materials Cited in NRC Publications j

Most documents cited in NRC publications will be available from one of the following sources:

}

1.

The NRC Public Document Room, 2120 L Street NW., Lower Level, Washington, DC 20555-0001 2.

The Superintendent of Documents, U.S. Government Printing Office, P. O. Box 37082, Washington, DC 20402-9328 4

2.

The National Technical Information Service, Springfield, VA 22161-0002 i

j Although the listing that follows represents the majority of documents cited in NRC publica-j tions, it is not intended to be exhaustive.

t j

Referenced documents available for inspection and copying for a fee from C > i,AC Public j

Document Room include NRC correspondence and internal NRC memoranda; NRC bulletins.

l circulars, information notices, inspection and investigation notices; licensee event reports; vendor reports and correspondence; Commission papers; and applicant and licensee docu-1 ments and correspondence.

i The following documents in the NUREG series are available for purchase from the Government Pnnting Office: formal NRC staff and contractor reports, NRC-sponsored conference pro-l ceedings, international agreement reports, grantee reports, and NRC booklets and bro-chures. Also available are regulatory guides, NRC regulations in the Code of Federal Regula-tions, and Nuclear Regulatory Commission issuances.

Documents available from the National Technical Information SerWee include NUREG-series reports and technical reports prepared by other Federal agencies and reports prepared by the Atcmic Energy Commission, forerunner agency to the Nuclear Regulatory Commission.

Documents available from public and special technical libraries include all open literature items, such as books, journal articles, and transactions. Federal Register notices, Federal and State legislation, and congressional reports can usually be obtained from these libraries.

Documents such as theses, dissertations, foreign reports and translations, and non-NRC con-i ference proceedings are available for purchase from the organization sponsoring the publica-tion cited.

Single copies of NRC draft reports are available free, to the extent of supply, upon written request to the Office of Administration, Distribution and Mail Services Section, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.

Copies of industry codes and standards used in a substantive manner in the NRC regulatory.

process are maintained at the NRC Library, Two White Flint North,11545 Rockville Pike, Rock-ville, MD 20852-2738, for use by the public. Codes and standards are usually copyrighted and may be purchased from the originating organization or, if they are American National Standards, from the American National Standards institute,1430 Broadway, New York, NY 10018-3308.

l NUREG-1497 Interim Licensing Criteria for Physical Protection of Certain Storage of Spent Fuel Manuscript Completed: October 1994 Date Published: November 1994 P. A. Dwyer Division of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 1

\\,...../

ABSTRACT

'lhis cocument presents interim criteria to be used in the partment of Energy, designed and constructed specifically physical protection licensing of certain spent fuel storage for the storage of spent fuel; the proposed geologic repos-installations. Installations that will be reviewed under this itory operations area; or permanently shutdown power J

criteria are those that store power reactor spent fuel at de-reactors still holding a ihrt 50 license. This criteria applies commissioned power reactor sites; independent spent to both dry cask and pool storage. Ilowever, the criteria in fuel storage installations hicated outside of the owner-this document does not apply to the storage of spent fuel controlled area of operating nuclear power reactors; mon-within the owner-controlled area of operating nuclear itored retrievable storage installations owned by the De-power reactors.

iii NUl(EG-1497

CONTENTS Page Abstract....................................................................................

iii

1. I n t rod u ct io n........................................................ -...........................

1 2.

Background...................................................................................

1

3. Basic Performance Capabilities.................................................................

1

4. Physical Protection Plan Components.............................................................

2 4.1 Introduction and Schedule for Implementation................................................

2 4.2 Gen eral Performance Obj ectives.............................................................

2 4 3 Security Organization.......................................................................

2 43.1 Establishment of Security Organization...............................................

2 43.2 Secu ri ty Au d it s.................................................................

2 433 Qualifications for Employment in Security..............................................

2 43.4 Security Force Training............................................

2 3

43.5 Records.............

4.4 Physical Barrier Syst e m....................................................................

3 4.4.1 G e n e ral Layo u t..................................................................

3 3

4.4.2 Physical Barriers 4.43 Secu rity Post (s)....................................................................

3 4.4.4 Illumination..

3 4.5 Access Control Subsystems and Procedures.....................................................

3 4.5.1 Identification System..

3 4.5.2 Access to Prot ect ed Areas...........................................................

3 4.5.3 Access Controls at the Protected Area................................................

4 4.5.4 Escorts and Escorted Individ uals...................................................

4 4.5.5 Key and Lock Con t rol..........................................................

4 4.5.6 Records.....

4 4.6 Detection. Surveillance, and Alarm Subsystems..............................................

4 4.6.1 Isolation Zone Penetration.....

4 4.6.2 Alarm Annunciation at Security Post.............................................

4 4.63 Power Sources..

4 4.6.4 Compon en t S upe rvision........................................................

4 4.6.5 Protected Area Monitoring and Assessment........

5 4.7 Communications Subsystems...............

5 4.7.1 Security Force Communications.....................................................

5 4.7.2 Alarm Station Communications.....................................................

5 4.73 Power Sources............

5 4.8 Test and Maintenance Program 5

4.8.1 Specification Tbst s...................................................................

5 4.8.2 Operationa l Tests......................................................

5 v

NUREG-1497

CONTENTS (continued)

Page 4.83 Repairs and Maintenance...............

5 4.9 Contingency Response Plan and Procedures.................

5 4.9.1 Contingency Plan Documentation...

5 4.9.2 Response Force Uaison..

5 4.93 Response 1% :ed u res.....................................................

6 4.9.4 Records...

6 APPENDIX A - PHYSICAL PROTECflON PLAN FORM AT............

7 APPENDIX H - GLOSSARY OF TERMS 9

APPENDIX C - LIST OF SELECTED GUIDANCE DOCUMENTS 11 vi NUREG-1497

l

1. INTRODUCTION paragraph (o) of this section.10 CFR 72.180 specifies the physical security plan to address compliance with the applicable requirement of 10 CFR Ibrt 73.

' Itis document presents interim criteria for use in the licensing review of physical protection plans for those Specific requirements for the protection of spent fuel independent spent fuel storage installations subject to exist under Subpart K to Ibrt 72, " General License for review by the Office of Nuclear Material Safety and Storage of Spent Fuel at Power Reactor Sites.'* liowever, Safeguards (NMSS). These installations are those that as indicated, these requirements apply only to the storage store commercial power reactor spent fuel at: 1) of spent fuel at power reactor sites. Requirements for the l

decommissioned power reactor sites; 2) independent protection of spent fuel stored at decommissioned power spent fuel storage installations located outside of the reactors; independent spent fuel storage installation owner-controlled area at operating nuclear power located outside of the owner-controlled area at operating j

reactors; 3) monitored retrievable storage (MRS) power reactors; monitored retrievable storage installations owned by the Department of Energy, installations owned by the Department of Energy, l

designed and constructed specifically for the storage of designed and constructed specifically for the storage of l

spent fuel: 4) the proposed geologie repository operations spent fuel; the proposed geologic repository operations area; or 5) permanently shut-down power reactors r*.ill area; and permanently shut-down power reactors still holding a Part 50 license. The criteria presented in this holding a lbrt 50 license are not specified. Accordingly, document applies to both dry cask and pool storage.

pending a rulemaking initiative,10 CFR 73.50 is being selectively used as the applicable requirement of Ibrt 73.

These criteria are not applicable to the protection of spent fuel stored within the owner-controlled area of operating 10 CFR 73.50 applies to a licensee who possesses, uses or power reactors. The physical protection measures called stores formula quantities of strategic special nuclear for at a site associated with an operating power reactor material which is not readily separable from other often take advantage of measures required under 10 CFR radioactive material and, which has a total external 73.55 for protection of the reactor. An example of this radiation dose rate in excess of 100 rem per hour at a l

l might be the use of an armed guard force (required to distance of 3 feet from any accessible surface without protect the power reactor) to respond to a contingency at intervening shielding other than at a nuclear reactor an adjacent storage installation. Because of their facility licensed pursuant to Part 50. Title 10 of the Code association with an operating power reactor, such storage of Federal Regulations.10 CFR 73.50 was specifically installations are subject to oversight and review by the developed for the physical protection of formula Office of Nuclear Reactor Regulation.

quantities of strategic special nuclear and later revised to

'lhis document is comprised of three major parts: 1) a description of the basic capabilities needed for physical The NRC staff believes that the requirements of 10 CFR protection at affected sites; 2)a description of the specific 73.50 can be selectively implemented because design l

criteria used to review affected physical protection plans; features of the spent fuel and its storage mechanism l

and 3) several appendices. The appendices contain a provide a degree of inherent physical protection for the format which may be used in the development of an fuel. In addition, because the requirements of 10 CFR applicant's physical protection plan, a glossary of terms 73.50 were originally developed to encompass fuel consistent with definitions found in the Code of the reprocessing facilities, the regulation contemplated Federal Regulations and a listing of selected guidance protection for unencapsulated, reprocessed strategic documents.

special nuclear material. Hence,10 CFR 73.50 may present excessive requirements for the protection of The criteria in this document describe typical methods for irradiated spent fuel that has not been chemically providing physical protection of affected spent fuel separated into its constituent parts through reprocessing.

storage installations. Other methods may be acceptable based on review by NMSS, U. S. Nuclear Regulatory Basic physical protection performance capabilities were Commission (NRC).

developed that form the basis for selective implementation of 10 CFR 73.50. These capabilities are

2. BACKGROUND described in section 3.

Licensing requirements for the independent storage of 3

BASIC PERFORMANCE spent nuclear fuel and high level radioactive waste are CAPABILITIES presented in 10 CFR Part 72. Requirements for the contents of a license application to independently store spent fuel are presented under 10 CFR 72.24, with the The general design objective of a system used to protect physical protection plan specifically called out under the storage of spent fuel at a facility treated by this 1

NUREG-1497 l

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document is to minimize the possibilities for radiological 4.3 Security Organization sabotage of the spent fuel.

43.1 Establishment of Security j

To achieve this objective, the physical protection system Organization should provide for the following performance capabilities:

i j

This section should affirm that a security organization will l

1) The establishment of a security organization with be established, comprised of a minimum of two watchmen written procedures:

per shift to provide for monitoring of detection and assessment subsystems, for performance of access control i

functions, and for communicating with a designated j

2) the use of physical barriers to control access to the response force or local law enforcement agency in the spent fuel:

event of detection of unauthorized penetration or actisities.

1

3) procedures and controls to assure only authorized individuals are granted access to the spent fuel Supportive 10 CFR 73.50 requirement:

1 10 CFR 73.50(a)(1).

l

4) detection and assessment of unauthorized penetration or activities by an individual or 43.2 Security Audits individuals within the protected area containing l

the spent fuel; and This section should affirm that security audits will be i

conducted at least every 24 months by individuals

5) the capability for timely communications of independent of both security program management and 1

j unauthorized penetration or activities to a Personnel who have direct responsibility for

}mplementat,on of the security program.The review must i

designated response force through a continuously manned alarm station, not necessarily within the include an evaluation of the effectiveness of the physical protected area, and via one other redundant pr tection system and an audit of commitments i

means sufficient to permit response.

established with local law enforcement agencies. These q

reports must be maintained m an auditable form, available for inspection, for a period of three years.

4 PHYSICAL PROTECTION PLAN Supportive 10 CFR 73.50 requirement: None COMPONENTS 1

I 4.1 Introduction and Schedule 433 Qu lifications for Employment for Implementation in Secunty This section should affirm that an individual, including a This section should indicate the corporate name of the watchman, granted unescorted access to the protected applicant, facility name, and facility location. Ihe area where spent fuel is stored should undergo screening i

applicant should describe the type of facility operated, the prior to the granting of such access.The screening should J

generallayout of the facility and the surrounding area. A typically include a Federal Bureau of Investigations schedule for implementation of the plan, developed in criminal history check, or equivalent; a presious j

coordination with the NRC, should also be included.

employment check; and two reference checks.

I Supportive 10 CFR 73.50 requirement: none.

Supportive 10 CFR 73.50 requirement:

f Authority for plan submittal under 10 CFR 73.50(a)(4).

10 CFR 72.24(o).

4, 43.4 Security Force Training 4.2 General Performance Objectives This section should affirm that a Guard Force ' Raining and Qualification Plan has been submitted for NRC In this section, the applicant should confirm that the approval or has been previously approved. 'Ihe plan general design objective of a system implemented to should document that the applicable criteria of Appendix 4

j protect tne storage of spent fuel is to protect the facility B to Part 73 will be or are being met. 'Ihe applicable from radiological sabotage.

criteria of Appendix B are: 1) educational development (possession of a high school diploma or equivalent); 2) no Supportive 10 CFR 73.50 requirement: none.

felony convictions involving the use of a weapon or that Applicable requirement is 10 CFR 72.182.

reflect on the individual's reliability; and 3) physical 2

NUREG-1497 i

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qualifications that indicate no physical weaknesses or means, such as by a locallaw enforcement agency or other abnormalities that would adversely affect performance of approved designated response force.

assigned security job duties. The Guard Force Training and Qualification Plan may be included as a chapter or Supportive 10 CFR 73.50 requirement:

appendix to the physical protection plan.

10 CFR 73.50(dXI).

Supportive 10 CFR 73.50 requirement:

4.4.4 Illumination 10 CFR 73.50(h).

This section should affirm that a means of illumination 43.5 Records will be provided sufficient to perform assessment of unauthorized penetration oc activitics within the This section should affirm that the following records will protected area and associated isolation zones.

l be established, maintained and retained as records: (1)

Illumination need be provided only during periods of screening recorcs until the affected individual terminates assessment if such illumination does not interfere with employment and (2) training and qualification records for the operation of assessment equipment, such as closed a period of three years after the record is made.

circuit television (CCIV), if used. If CCIV is used, illumination should be such as to permit proper and timely Supportive 10 CFR 73.50 requirement:

operation of the camera. In all cases,0.2 footcandles is 10 CFR 73.50(aX4).

considered the minimum illumination needed to properly view the area of assessment.

4.4 Physical Barrier System Supportive 10 CFR 73.50 requirement:

10 CFR 73.50(bX5).

4.4.1 General Layout His section should affirm that spent fuel will be stored 4.5 Access Control Subsystems only within a protected area.

and Procedures l

Supportive 10 CFR 73.50 requirements:

4.5.1 Identification System 10 CFR 73.50(bX1) and (2).

This section should describe the identification system 4.4.2 Physical Barriers used at the facility, ne system should provide unique identification ofindividuals granted unescorted access to This section should affirm that access to stored spent fuel the protected area through such means as a picture requires passage through or penetration of two barriers, identification system using a driver's license photograph, one at the perimeter of the protected area and one other a name badge system using a difficult to counterfeit badge physical barrier offering substantial penetration medium, or facial recognition. Justification for use of resistancc. The physical barrier at the perimeter of the facial recognition should be provided, such as, longterm protected area should, as a minimum, be as described employment and small site population. In addition, the under 10 CFR 73.2. A barrier that offers substantial identification system should uniquely identify individuals resistance to penetration may be provided by a variety of requiring escort while within the protected area.

measures.nese measures include penetration resistance provided by the storage cask for the spent fuel or building Supportive 10 CFR 73.50 requirement:

walls, such as those of a reactor or fuel building. Isolation 10 CFR 73.50(cX3).

J zones should be provided on either side of the physical barrier at the perimeter of the protected area. These 4.5.2 Access to Protected Areas zones should be mamtamed free of cautter and should typically be 20 feet wide.

This section should describe procedures for determining an individual's need for access to the protected area.

4.43 Security Post (s)

Access to protected areas should be limited to individuals authorized unescorted access or authorized escorted his section should affirm that a security post will be individuals who require such access in order to perform provided for the stationing of watchmen and the job duties. Procedures should also be desenbed for monitoring of assessment systems, if used, and of dealing with required access of emergency response detection systems. The post need not be located within vehicle personnel.

the protected area where spent fuel is stored but should be continuously manned. In addition, detection systems Supportive 10 CFR 73.50 requirement:

should be monitored via one other continuously manned 10 CFR 73.50(cX4).

3 NUREG-1497

4.53 Access Controls at the Protected Area 4.6 Detection. Surveillance, and This section should describe procedures for granting Alarm Subsystems access of individuals, packages and vehicles into the protected area. Typically, authorization should be 4.6.1 Isolation Zone Penetration checked and individuals, packages, and vehicles should be subjected to a search for explosive devices. This search This section should describe the applicant's commitments should be conducted by use of handheld equipment.

for a detection capability of unauthorized penetrations designed to detect explosives. Watchmen, who have been through the interior isolation zone at the perimeter of the granted unescorted access to the protected area and are protected area. Generic equipment type, along with i

on official duty, need be subjected to authorization check associated detection capabilities, should be desented.

and explosive search only at first entrance to the Detection capabilities specified in Regulatory G uide 5.44, I

protected area at work shift initiation.

" Perimeter Intrusion Alarm Systems" should be met.

Supportive 10 CFR 73.50 requirement:

l Supportive 10 CFR 73.50 requirements:

10 CFR 73.50(b)(4).

l j

10 CFR 73.50(cXI) and (2).

4.5.4 Escorts and Escorted Individuals This section should describe the system for annunciation his section should describe individuals by job function, of detection of isolation zone penetrations within the who may be designated as escorts and procedures used for security post and one redundant location and commit the escorting individuals during both routine and emergency applicant to indicate the status of all alarms and alarm situations. Such procedures should describe individuals zones within the security post and the redundant location.

requiring escort, identification procedures, and training that escorts receive.

Supportive 10 CFR 73.50 requirement:

10 CFR 73.50(bX4).

l Supportive 10 CFR 73.50 requirement:

10 CFR 73.50(cX5).

4.63 Power Sources 1

4.5.5 Key and Lock Control This section should describe types of security equipment capable of being operated from mdependent power his section should describe the key and lock control s urces, duration of operation in the event of loss of system that will be developed and maintained to limit normal power, and indication given on loss of normal access to and within the protected area to authorized Power and switch over to standby power. 'Iypes of individuals. 'lypically, keys and locks should be rotated or equipment provided with mdependent power sources changed annually, when an individual with access to keys would typically include intrusion detection equipment, or locks has unescorted access withdrawn, or when there alarm annunciation equipment, lighting, any equipment is evidence of compromise of the keys, locks or the system used to provide assessment of alarms, and equ pment for controlling the keys or locks.

commumcating with a designated response force or local law enforcement agency. Duration of standby power Supportive 10 CFR 73.50 requirement:

capability would typically equal or exceed twice the 10 CFR 73.50(cX7).

response time of a local law enforcement agency or designated response force.This section should alsoaffirm that switch-over to standby power will be automatic and 4.5.6 Records not cause false alarms.

This section should affirm that records will be established, Supportive 10 CFR 73.50 requirement:

maintained and retained for: (1) current written 10 CFR 73.50(e)(4) for communications procedures that permit access control personnel to eqdipment.

identify authorized versus unauthorized entry for the period the applicant stores spent fuel, (2) the record of 4.6.4 Component Supervision escorted individuals for a period of three years from the date of the record, and (3) written procedures for key and His system should describe the physical protection lock control for the period the applicant stores spent fuel.

afforded alarm systems, including transmission media, to ensure that the system is not being tampered with, Supportive 10 CFR 73.50 requirements:

compromised, or on standoy power, without the 10 CFR 73.50(aX3),(cX5), and (cX7).

knowledge of the licensee.

4 NUREG-1497

Supportive 10 CFR 73.50 requirement:

Supportive 10 CFR 73.50 requirement:

10 CFR 73.50(dXI).

10 CFR 73.50(f).

4.6.5 Protected Area Monitoring 4.8.2 Operational Tests and Assessment This section should describe the testing program for his section should describe methods used to monitor the maintaining physical protection.related equipment in protected area for unauthorized penetrations or activities operable condition. This discussion should include the and to assess unauthorized penetrations. Monitoring purpose and intended level of the testing and capability would typically be provided by a random patrol mamtenance program, specific methods for the testing of conducted once every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. With respect to the equipment subject to the program and periodicity of assessment. remote assessment is preferred, for example the testing. In general, operational testing should be via closed circuit television or a video capture system.

conducted daily (go/no go) either remotely through However, adequate assessment may also be provided self-checking circuitry or onsite, and performance testing through onsite assessment by a watchman if an acceptable conducted once every 18 months unless operaf:'nal justification of timely assessment can be provided.

testing indicates a need for corrective action. In this evat, performance testing should be conducted after necessary Supportive 10 CFR 73.50 requirements:

maintenance.

10 CFR 73.50(b)(3) and (gX3)(ii).

Supportive 10 CFR 73.50 requirements:

4.7 Communicat,ons Subsystems 10 CFR 73.50(1), (2) and (3).

i 4.7.1 Security Force Communications 4.83 Repairs and Maintenance his section should describe how each watchman will be This section should describe procedures used in perform-capable of maintaining continuous communications with ing repairs and maintenance of physical protection the security post. Typically, this capability would be met by systems in order to maintain equipment in operable supplying watchmen with two-way radio communications.

condition. Compensatory measures to be used during periods of equipment degradation or failure should also Supportive 10 CFR 73.50 requirement:

be described.

10 CFR 73.50(eXI).

Supportive 10 CFR 73.50 requirement:

4.7.2 Alarm Station Communications 10 CFR 73.50(f).

l His section should describe redundant systems used t 4.9 Contingency Response Plan ensure the capability of maintaining communications with a designated response force or local law enforcement and Procedures agency. These redundant communications systems would typically be provided via radio and commercial telephone.

4.9.1 Contingency Plan Documentation Supportive 10 CFR 73.50 requirements:

This section should commit the applicant to having an pproved safeguards contingency plan for dealing with 10 CFR 73.50(eX2) and (3).

anticipated threats. The plan should be developed in l

4.73 Power Sources ordance with the criteria in Appendix C to Part 73 but need only m, elude a responsibility matrix and response his section should describe methods used by the licensee procedures. The level of detail provided in the plan to keep non-portable communications equipment should be commensurate with the level of threat. He I

controlled by the licensee operable in the event of loss of contingency plan may be a chapter or appendix to the normal power.

physical protection plan.

l Supportive 10 CFR 73.50 requirement Supportive 10 CFR 73.50 requirement:

10 CFR 73.50(e)(4).

10 CFR 73.50(g)(1).

4.8 Test and Maintenance Program 4,9.2 Response Force Liaison 4.8.1 Specification Tests This section should describe documented response arrangements that the applicant has made with a hxallaw This section should affirm that, at initial installation, enforcement agency or an approved designated response equipment will be tested to manufacturer's specifications.

force. It should describe estimated response times.

5 NUREG-1497

Supportive 10 CFR 73.50 requirement:

4.9.4 Records 10 CFR 10 CFR 73.50(gX2).

This section should describe how the applicant will establish, maintain and retain as a record the current 4.9.3 Response Procedures safeguards contingency plan and also arrangements made This section should describe the applicant's response with a k) cal law enforcement agency or an approved procedures for dealing with detection of unauthorized designated response force for as long as the applicant presence or activities within the protected area.

stores spent fuel.

Supportive 10 CFR 73.50 requirements:

Supportive 10 CFR 73.50 requirements:

10 CFR 73.50(aX3) and (gXI).

10 CFR 73.50(gXI) and (2).

6 NUREG-1497

4 APPENDIX A - PilYSICAL PROTECTION PLAN FOlGIAT If this format is used, the applicant should follow the A.2 Physical Specifications of numbering system of this NUREG. Under some Submittal circumstances, certam subsections may not be applicable to a specific application. If so, this should be clearly stated All material submitted in an application should conform and sufficient information should be provided to support to the following physical dimensions of page size, quality this conclusion.

of papers and inks, numbering of pages, etc.

He applicant may wish to submit information in support A.2.1 Paper Size of an application that is not required by regulations and is Text pages should be 8.5 x 11 inches in dimension.

not essential to the description of the applicant's physical protection program. Such information could include, for Drawings and graphics: 8.5 x 11 inches, preferred; example, historical data submitted in demonstration of however, a larger size is acceptable provided the finished certain criteria, discussion of alternatives considered by copy, when folded, does not exceed 8.5 x 11 inches.

the applicant, or supplementary data regarding assumed models, data, or calculations. This information should be A.2.2 Paper Stock and Ink provided m an appendix to the plan.

Suitable quality in substance, paper color, and ink density Upon completion of the plan, the applicant should use the table of contents of this document as a checklist to ensure that each subject has been addressed.

A.2.3 Paper Margins A margin of no less than one inch is to be maintained on the top, bottom, and binding side of all pages submitted.

A.1 Style and Composit. ion A.2.4 Printing A table of contents should be included in each submittal.

Composition: text pages should be single spaced. 'I)pe face and style: should be suitable for microfilming.

The applicant should strive for clear, concise presentation Reproduction: may be mechanically or photographically of information. Confusing or ambiguous statements and reproduced. All pages of the text may be printed on both general statements of intent should be avoided. Defi.

sides, and images should be printed head to head.

nitions and abbreviations should be consistent throughout the submittal, and consistent with generally accepted A.2.5 Binding usage.

Pages should be punched for loose leaf ring binding.

Whenever possible, duplication of information should be A.2.6 Page Numbering avoided.The information included in other sections of the application may be covered by specific reference to those Pages should be numbered sequentially throughout the sections.

main part of the document. Any appendices may be numbered separately if desired. Each page of the physical protection plan should contain a page number; a revision Where numerical values are stated, the number of number, if applicable; and a date.

significant figures should reflect the accuracy or precision to which the number is known.The use of relative values A.3 Procedures for Updating or should be clearly indicated. Drawings, diagrams, and Revising Pages tables should be used when information may be presented more adequately or conveniently by such means. These The updating or revising of data should be on a illustrations should be located in the section where they replacement page basis.The changes or revised portions are first referenced. Care should be taken to ensure that of each page should be highlighted by a vertical line. The the information presented in drawings is legible, that line should be on the margin opposite the binding margin symbols are defined, and that drawings are not reduced to for each line changed or added. All pages submitted to the extent that they cannot be read by unaided, normal update, revis, or add pages to the plan are to show the eyes.

date of the cLnge.The transmittalletter should include 7

NUREG-1497

..__- = _. - _

~. _ _ _ __ _ _..

the index page listing fhe pages to be inserted and the submitted as a separate enclosure. Other proprietary and pages to be removed. When major changes or additions classified information should be clearly identified and are made, pages for a revised-table of contents should be submitted in separate enclosures. Each such submittal of provided.

proprietary information should request exemption from public disclosure, as required in paragraph 2.790(b) of 10 A.4 Number of Copies CFR lbrt 2.

The applicant should submit the appropriate number of A.6 Compatibility copies of each required submittal in accordance with 10 CFR 72.16.

The applicant should ensure that the physical protection E >mpatible with the other sections of the A.5 Public Disclosure (p";c3t;on NRC has determined that public disclosure of the details i

of physical protection programs is not in the public A.7 Schedule for Submittal interest, and such details are withheld in accordance with paragraph 2.790(d) of 10 CFR Ibrt 2. Thus, the physical The applicant should contact NRC to determine a nrot<~ tion section of each application should be schedule for physical protection plan submittal.

7 i

i 1

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I f

8 NUREG-1497

I l

l APPENDIX B - GLOSSARY OF TERMS I

These terms are excerpted from Title 10 of the Code of Physical barrier means: (1) fences constructed of No.11 Federal Regulations, Parts 72 and 73.

American wire gauge, or heavier wire fabric topped by I

three strands or more of barbed wire or similar material Guard means a uniformed individual armed with a on brackets angled inward or outward between 30 degrees firearm whose primary duty is the protection of special and 45 degrees from the vertical, with an overall height of nuclear material against theft, the protection of a plant not less than eight feet, including the barbed topping; (2) against radiological sabotage, or both.

building walls, ceilings, and floors constructed of stone, brick, cinder block, concrete, steel, or comparable Independent spent fuel storage installation or ISFSI materials (openings in which are secured by grates, doors, means a complex designed and constructed for the or covers of cc..struction and fastening of sufficient

[

interim storage of spent nuclear fuel and other strength such that the integrity of the wall is not lessened i

radioactive materials associated with spent fuel storage.

by any opening), or walls of similar construction, not part 4

An ISFS1 which is h>cated on the site of another facility of a building, provided with a barbed topping described in may share common utilities and services with such a paragraph (1) of this definition of a height of not less than facility and be physically connected with such other facihty eight feet; or (3) any other physical obstruction and still be considered independent; provided that such constructed in a manner and of materials suitable for the sharing of utilities and services or physical connections purpose for which the obstruction is intended.

does not:(1) increase the prooability or consequences of an accident or malfuncthm of components, structures or Spent nuclear fuel or spent fuel means fuel that has been systems that are important to safety, or (2) reduce the withdrawn from a nuclear reactor following irradiation, margin of safety as defined in the basis for any technical has undergone at least one year's decay since being used specification of either facility.

as a source of energy in a power reactor, and has not been chemically separated into its constituent elements by Isolation zone means any area adjacent to a physical reprocessing. Spent fuel includes the special nuclear barrier, clear of all objects which could conceal or shield material, byproduct material, source material and other an individual.

radioactive materials associated with fuel assemblies.

Monitored retrievable storage installation or MRS Strategic special nuclear material means uranium-235 means a complex designed, construction and operated by (contained in uranium enriched to 20 percent or more in the Department of Energy for the receipt, transfer, the U-235 isotope), uranium-233, or plutonium.

handling, packaging, possessing, safeguarding, and storage of spent nuclear fuel aged for at least one year and Watchman means an individual, not necessarily solidified high-level radioactive waste resulting from uniformed or armed with a firearm, who provides civilian nuclear activities, pending shipment to a high protection for a plant and the special nuclear material level waste repository or other disposal.

therein in the course of performing other duties.

r j

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9 NUREG-1497 m

7

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APPENDIX C - LIST OF SELECTED GUIDANCE DOCUMENTS While not developed specifically for the physical NUREG 1321. Testing Standards for Physical Protection protection of stored spent fuel, these documents Systems at Category I fuel Cyr/c Facilities, October 1991.

published by the NRC may be useful in the general development of physical protection systems.

NUltEG 1328, Entry / Erit Control at Fuel Fabrication Regulatory Guide 5.7, Entry / Exit Control for Protected Facilities Using or Possessing formula Quantities ofStrategic Areas, Mtal Areas and Material Access Areas May 1980.

Special Nuclear Material, December 1988.

Regulatory Guide 5.12 General Use of Locks in the Protection and Control of Facilities and Special Nuclear NUREGICR 5721, Mdeo Systemsfor Alarm Assessment, September 1991.

Materials, November 1973.

Regulatory Guidc 5.44, Perimeterintrusion Alarm Systems, NUREGICR 5723, Security System Signal Supenision, May 1980.

September 1991.

l l

11 l

NUREG-1497

\\

NRC Foeu 335 U.S. NUCLE AR REGULQTDRY COMMISSION

1. HE POR T NUM B E R
  1. ! no.

$IM.'lTo",,"w;m^O';,$i"~"*'~

C w na BIBLIOGRAPHIC DATA SHEET

'S"'""'""'"'"'"*"*>

NUREG-1497

2. TITLE AND SUBilTLE l

Interim Licensing Criteria for Physical Protection 3.

DATE REPORT PUBLISHE D of Certain Storage of Spent Fuel l

==

n aa November 1994

4. FIN OR GR ANT NUMBE R 5 AUTHOR (S)
6. TYPE OF REPORT
p. A. Dwyer Technical
1. PE R1OD COV E R E D IInclustee O*reet
6. PE R F 0RMING, ORGAN tZ AT l0N - N AME ANO ADDR ESS 199 NnC. preen
  • Omnen. Otter or neeton. v.s Nucka neouktors comoma.orr. amt makes omrvu. et conesarwr.

, ir y m.,u,,

so Division oIFuel Cycle Safety and Safeguards Office of Nuclear Materials Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 9 SPONSOR lNG ORG ANIZATION - N AME AND ADDR ESS st!Nac. ryor mme n stmar" tr eontracuor. oroeuw Nnc omisen. orrme er nesen. u s Nucuar anpuutom commewun.

cmr mesma emfreatt Division of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

10. SUPPLEMENTARY NOTES
11. ABSTR ACT (200. ores er est This document presents interim criteria to be used in the physical protection licensing of certain spent fuel storage installations. Installations that will be reviewed under this criteria are those that store power reactor spent fuel at decommissioned power reactor sites; independent spent fuel storage installations located outside of the owner-controlled area of operating nuclear power reactors; monitored retrievable storage installations owned by the Department of Energy, designed and constructed specifically for the storage of spent fuel; the proposed geologic repository operations area; or permanently shutdown power reactors still holding a Part 50 license. This criteria in this document does not apply to the storage of spent fuel within the owner-controlled area of operating nuclear power reactors.
12. K E Y WOR DS/DESCR'PTOR S (Ler wonfa or phraues ther ein ms,sr resentshers m tacereng the moort. /
13. AvAitAeiLe i y s! A1 e ut N1 physical protection, physical security, spent fuel Unlimited
14. bk CURI i Y CLA551f IC A iION lihos Page)

Unclassified (The normot)

Unclassified ib. NUMBER OF PAGkS 16 PRICE NRC FORM 3n (2491

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NOVEMBER 1994 OF CERTAIN STORAGE OF SPENT FUEL UNITED STATES NUCLEAR REGULATORY COMMISSION FIRST CLASS Mall POSTAGE AND FEES PAfD WASHINGTON, D.C. 20555-0001 USNRC PERMIT NO. G-67 OFFICIAL BUSINESS PENALTY FOR PRIVATE USE, $300 i