ML20137A072

Clarifies Licensee Safeguards Guidance Group Bulletin 38 Re Protection Against Unauthorized SSNM Removal from Matl Access Areas.Alternative Measures Designed to Prevent SSNM Theft Outside of Matl Access Areas Provided

ML20137A072
Person / Time
Site:	07000371
Issue date:	11/07/1985
From:	Burnett R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Kirk W UNC, INC. (FORMERLY UNC RESOURCES, INC.)
References
NUDOCS 8601140153
Download: ML20137A072 (2)

Text

'

.\ .  ; -  ;

UNITED STATES fgg '

8 o NUCLEAR REGULATORY COMMISSION 7, f WASHINGTON. D. C. 20555

\..../

DESIGNATED ORIGINAL NY O 't &

SOMI:0FS70-371 UNC Naval Products Division of UNC Resources, Inc.

ATTN: Mr. William F. Kirk, Manager Nuclear and Industrial Safety 67 Sandy Desert Road Uncasville, Connecticut 06382 Gentlemen:

This is in response to inquiries we have received requesting clarification and further guidance concerning the provisions of Licensee Safeguards Guidance Group (LSGG) Bulletin #38.

In brief, the Bulletin intends to amplify the importance of maintaining the integrity of material access area (MAA) fixed barriers (walls, floors and ceilings) such that they do not have openings or passageways which vill allow unauthorized removal of the SSNM contained therein. The Bulletin discusses some specific measures which may be used to counter diversion of SSNM through such openings / passageways from within MAAs. However, it does not provide alternatives or describe detailed measures to prevent recovery by an adversary of diverted SSNM outside of MAAs.

Prior to issuance of the Bulletin, we did not fully anticipate the situations which exist that cannot be effectively corrected from within the MAAs at a reasonable cost. The following is intended to supplement the Bulletin by providing broad guidance for measures to prevent recovery by an adversary of SSNM which may be diverted through MAA barriers in those instances where __

reasonable preventive measures cannot be provided from within an MAA.

a) Provide physical and/or procedural measures which will give high assurance against acce sibility of passageways and openings which exit MAA barriers. These measures may include grills, cages, tamper indicating seals, locks, alarms, random patrols, periodic SSNM monitoring, etc. In some instances, the inaccessibility of a passageway / opening either inside or outside of the MAA may, in itself, be sufficient to provide the desired level of assurance.

b) The Bulletin applies to all MAAs. The strictest adherence possible is expected for thnse areas which contain unencapsulated SSNM.

However, small openings or passageways through barriers of MAAs which contain only large encapsulated items of SSNM which cannot be placed into such openings / passageways are of less concern, provided internal barriers and procedures are in place to prevent smaller items containing SSNM from being brought into areas containing only encapsulated SSNM in the form of large items.

8601140153 851107 PDR ADOCK 07000371 C PDR

NOV071985 Finally, I wish to clarify that licensees are not restricted to the corrective measures which are discussed in Bulletin 38. The test of " acceptability," by whatever physical and procedural measures are used, is the resulting assurance that unauthorized diversion of SSNM via the MAA barriers is prevented.

The foregoing information is supplemental to the guidance contained in Bulletin 38. Accordingly, it should be filed along with the Bulletin in NUREG 0669, " Fixed Site Physical Protection Upgrade Rule Guidance Compendium."

Mr. C. N. Smith of my licensing staff is now the primary point of contact for matters pertaining to Bulletin 38. He can be contacted by phone at (301) 427-4758.

Sincerely,

' T Robert F. Burnett, Director Division of Safeguards Office of Nuclear Material Safety and Safeguards cc: R. Keimig, RI W. Kushner, RI W. Madden, RI G. Smith, RI

__