ML20211K176
| ML20211K176 | |
| Person / Time | |
|---|---|
| Issue date: | 01/31/1985 |
| From: | NRC - SAFETY/SAFEGUARDS REVIEW GROUP |
| To: | |
| Shared Package | |
| ML20211K170 | List: |
| References | |
| FOIA-86-432 NUDOCS 8606270342 | |
| Download: ML20211K176 (23) | |
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s REVIEW OF SAFEGUARDS REGULATIONS AND GUIDANCE (CATEGORIES II AND III NON-POWER REACTORS)
SAFEGUARDS INTEROFFICE REVIEW GROUP January 31, 1985 gg62g32860624 AFTERG086-432 PDR
FOREWORD The Safeguards Interoffice Review Group was formed in October,1984, at the direction of the NRC Executive Director for Operations, to review safeguards regulations and guidance. This was done to identify possible inconsistencies that could lead to misunderstanding and lack of coordination within the staff in administering safeguards requirements.
The Group has the following membership:
Robert A. Erickson, NMSS, Chairman Tom R. Allen, NMSS Paul Baker, NMSS Loren L. Bush, IE Francis X. Cameron, ELD Jane L. Gibson, NRR Gordon E. Gundersen, NMSS Carl B. Sawyer, NMSS Philip Ting, RES In preparing this report the Group was assisted and advised by others, including: Robert Dube, NMSS; Carl Withee, NMSS; Donald Carlson, NMSS; Ellen Kraus, NMSS; Nancy E. Ervin, IE; Richard P. Rosano, IE; and W. Bruce Taylor, RES. The following served as Group contacts: Walter Schwink (E00);
Richard P. Keimig (RI); Kenneth P. Barr (RII); James R. Creed (RIII); Ramon E.
Hall (RIV); and Leroy R. Norderhaug (RV). -
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Table of Contents P_aie Foreword . .
............................ iii Summary of Findings ........................ 1 Background . ...................... ...... 1 Scope and Approach . ........................ 3 Findings.Related to Categories II and III Non-Power Reactors . ... 5 I. Inconsistencies Involving Regulations and Guidance . ... 5 Protection against Radiological Sabotage . ........ 5 Security Plan Submittals . . ............... 5 Reporting Requirements . . . . . . . . . . . . . . . . . . 6 Use and Storage of Category II Special Nuclear Material . 6 Timeliness of Detection . . ............... 7 Illumination Levels in CAAs ............... 7 Temporary Storage of Category III Special Nuclear Material ....................... 8 II. Other Findings . ..................... 8 Non power Reactor Security Plans . . ........... 8 Industrial Sabotage ................... 8 Internal Inconsistency--Regulatory Guide 5.59 ...... 8 Clarity of Language in Regulations . . .......... 9 Applicant vs. Licensee Requirements for Security Plans . . . . . . ...........'.... 10 Use of the Terms " Category II" and " Category III". . . . . 10 Unclear Definitions within 10 CFR S 73.67 ........ 11 References . . . . . . . . . . . . . . . . . . . . ......... R-1 Bibliography . . . . . . . . . . . . . . . . . . . ..... ... . B-1 l
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.u REVIEWOFSAFEGUARDSREGULATIONSkNDGUIDANCE (CATEGORIES II AND III NON-POWER REACTORS)
Summary of Findings Several inconsistencies were identified in the U.S. Nuclear Regulatory Commission's (NRC's) safeguards regulations and supporting guidance for Cate-gories II and III non power reactors. In two instances, inconsistencies arise from regulations applicable to broad groups of facilities such as " fixed sites" and " utilization facilities." While Categories II and III non power reactors are by strict definition included in these groups, licensing practice and pub-lished guidance reflect the staff's understanding that these regulations are
! not applicable to non power reactors.
Other inconsistencies were noted in the documents used as guidance for licensees, the NRC licensing staff, and the NRC inspection staff. The inconsistencies involve such diverse matters as personnel screening requirements, illumination levels in controlled access areas (CAAs), and criteria for barriers used to protect Categories II and III special nuclear material (SNM).
Background
Safeguards at licensed non power reactors are regulated by the NRC under authority of the Atomic Energy Act of 1954, as amended, and the Energy Reorganization Act of 1974.1 Applicable NRC safeguards regulations are codified principally in 10 CFR 1 Nuclear research facilities, including non power reactors, constitute a special class, from the NRC's perspective. Subsection 104c of the Atomic Energy Act authorizes the Commission "to issue licenses to persons applying therefor for utilization and production facilities useful in the conduct of research and development activities of the types specified in section 31 and which are not facilities of the type specified in subsection 104b. The Commission is directed to impose only such minimum amount of regulation of the licensee as the Commis-sion finds will permit the Commission to fulfill its obligations under this Act to promote the common defense and security and to protect the health and safety of the public and will permit the conduct of widespread and diverse research and
- development."
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Parts 50, 70, and 73. Non power reactor licensees establish safeguards programs in accordance with these regulations and supporting guidance documents. The NRC i staff uses a variety of guidanct documents in carrying out the licensing and inspection of safeguards for non power reactors.
Proceedings on the application for renewal of a non power reactor license for the University of California at Los Angeles (UCLA) highlighted a lack of coor-dination and consistency in the NRC staff concerning implementation of the relevant regulations (see 17 NRC 927 and 18 NRC 802, Ref. 1). During those proceedings, the safeguards licensing staff of the Office of Nuclear Material Safety and Safeguards (NMSS) testified that NRC regulations do not require non-power reactors to protect against radiological sabotage. However, the Atomic Safety and Licensing Board interpreted 10 CFR g 73.40 as requiring such protec-tion, and cited references to sabotage protection in the UCLA security plan, i
as well as in an NRC sample security plan and certain NRC inspection documents.
The staff's position was supported by a significant body of regulatory guidance and a major policy paper on physical protection standards (SECY 77-79, Ref 2).
The Board's position reflected a literal reading of 9 73.40 and other regulatory documents whi'ch illuminated possible inconsistencies that may have developed during the evolution of safeguards regulations and supporting guidance.
Accordingly, the Board recommended that if the Commission agreej with the staff's technical justification for its position, it should amend 9 73.40(a) so that no ambiguity will exist with respect to what is required of non power reactor licensees. -
To preclude such problems in the future, NRC's Executive Director for Operations (EDO) directed NMSS to "...promptly review all NRC Safeguards regulations and pertinent associated guidance with other NRC offices (NRR, IE, and Regions, as necessary) to assure that no further misunderstanding or lack of coordination and consistency, as were manifested in the UCLA proceeding, exist or recur either in hearing-related or non-hearing-related activities." (Ref. 3)
NMSS organized the Safeguards Interoffice Review Group, including professionals from each safeguards licensing branch and representatives from other offices, to address the concerns raised by the EDO. NRC's Regional offices and the E00's 2
t office each designated persons to serve as points of contact for the Group, which held its first weekly meeting on October 18, 1984.
Scope and Approach The EDO directive to review safeguards regulations and guidance was broad in scope. In order to make the review manageable, while being fully responsive to the directive, the Group agreed to approach its work as follows:
- 1. The Group will concentrate on identifying inconsistencies in safeguards regulations and guidance, with the understanding that the resolution of those inconsistencies will be a task for the staff at large.
- 2. The Group will begin its work by reviewing regulations and guidance affecting Categories II and III non power reactors. Subsequent reviews will deal with regulations and guidance affecting other classes of licensees as follows:
Non power Reactors - Category I Nuclear Materials Transportation - Category I Nuclear Materials Transportation - Category II Nuclear Materials Transportation - Category III Fuel Fabrication Facilities - Category I Fuel Fabrication Facilities - Category II -
Fuel Fabrication Facilities - Category III Power Reactors Independent Spent Fuel Storage Installations Fuel Fabrication / Conversion Facilities and Power Reactors ,
l under IAEA Safeguards Spent Fuel Transportation New Fuel Stored at Reactors These classes of licensees may be further refined or consolidated, as appropriate, to facilitate the Group's review.
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- 3. The Group will attempt to identify and screen all relevant documents used by the NRC staff in the performance of safeguards licensing and inspection /
enforcement functions.
- 4. In the course of its reviews covering various classes of licensed activ-ities, the Group will also be alert for generic problems. These will be discussed in the Group's final report, which, accordingly, may include comments on such matters as improving NRC staff coordination; clarifying the scope of NRC regulations (in terms of the types of facilities or activities covered); clearly identifying superseded regulations and guidance; and ensuring that regulations, guidance, licensing criteria, and inspection procedures are coherent and accessible.
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FINDINGS RELATED TO CATEGORIES II AND III NON-POWER REACTORS I. INCONSISTENCIES INVOLVING REGULATIONS AND GUIDANCE Protection against Radiological Sabotage Depending upon interpretation of 10 CFR S 73.40(a), an inconsistency may exist between implementing guidance documents for Categories II and III non power reactors and 10 CFR S 73.40(a). That section of the regulations states "...each licensee shall provide physical protection against radiological sabotage and against theft of special nuclear material at the fixed sites where licensed activities are conducted." However, guidance, licensing, and inspection docu-ments relevant to Categories II and III non power reactors deal exclusively with protection against theft of SNM. These documents are consistent, in this respect, with the more detailed protection requirements for Categories II and III SNM in 10 CFR 6. 73.67 (which do not explicitly address protection against radiological sabotage).2 However, the omission of sabotage may make them inconsistent with the general requirements of 10 CFR S 73.40(a).
Security Plan Submittals An inconsistency was identified in the regulatory documents that deal with the format and content of physical protection plans for Categories II and III non-power reactors. Specifically,10 CFR S 50.34(c) requires that each applica -
tion for.a license to operate a production or utilization facility include a physical security plan that consists of two parts. Part I is to address, among other things, vital equipment and vital areas, and shculd demonstrate compliance with 10 CFR Parts 73 and 11, as applicable. Part II of the plan is to deal with tests, inspections and compliance. However, Regulatory Guide 5.59 (Ref. 4) does not discuss plan " parts," but describes instead a six-chapter format for physical protection plans covering Category II facilities, and a four-chapter format for 2 Regulatory Guide 5.59 (Ref. 4) the standard format and content guide for Cate-gories II and III security plans, does mention " industrial sabotage" in its intro-duction. However, none of the substantive parts of the Guide addresses sabotage.
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physical protection plans covering Category III facilities. The Guide (Ref. 4) does not address protection of vital areas or equipment.
Reporting Requirements An apparent inconsistency was found in the Category II licensing criteria docu-ment (Ref. 5) and the safeguards reporting requirements of 10 CFR S 73.71.
10 CFP. 6 73.71(b) appears to require that actual or attempted thefts or diver-sion of material be reported to the NRC within one .our of occurrence. On the other hand, the licensing criteria document (Ref. 5) specifies allowable theft detection times of two hours and longer for various types and quantities of
! nuclear material. Furthermore, a table which suggests a greater range of .
j reporting times is appended to the regulation, but appears to refer only to 73.71(c), dealing with events concerning security effectiveness. These incon-sistencies are perpetuated in Draft Inspection Procedure 814023 (Ref. 6).
! With regard to these inconsistencies, the Group noted that G 73.71 is under-i going revision which would, among other things, also change the one hour report-ing reference point in 6 73.71(b) from the time of occurrence to the time of discovery, as is currently specified in 73.71(c). If these revisions are made, the Category II licensing criteria document (Ref. 5), Draft Inspection Proce-dure 81402 (Ref. 6), and 6 73.71 will be consistent.
Use and Storage of Category II Special Nuclear Material -
t 10 CFR S 73.67(d) requires Category II licensees to (1) use material only in illuminated CAAs, and (2) store material only in places such as vault-type rooms, security cabinets, or their equivalent. In this regard, Draft Inspection Procedure 814213 (Ref. 7) requires inspectors to verify that SNM is used and stored only in CAAs such as vault-type rooms or approved security cabinets.
3The Group noted that some of the current IE procedures have been in effect for several years and are recognized as being significantly out of date. Accord-ingly, with respect to 81400 series procedures, the review was confined to initial draft versions of the updated procedures, which are under development within IE.
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l This would appear to preclude use or storage of SNM in reactor vessels, spent fuel pools, or other such areas. Category II licensing criteria (Ref. 5) allow l the use of SNM in temporary CAAs, which may consist of barriers such as office partitions or cordons, if authorized personnel maintain continuous control over the SNM. Howeve , this is not completely consistent with Regulatory Guide 5.59 (Ref. 4) which also allows temporary storage (unattended) of Category II SNM in temporary CAAs, if it is kept in isolation, or motion alarms are used in lieu of continuous supervision.
Timeliness of Detectiqn Licensing criteria and inspection procedures appear to differ in their treatment of timeliness of theft detection. The Category II licensing criteria document (Ref. 5), and the Category III licensing criteria document (Ref. 8) allow for variations in theft detection times, depending on nuclear material form and quantity. Regulatory Guide 5.59 (Ref. 4) also provides for variable timeliness of theft detection. However, Draft Inspection Procedures 81421 (Ref. 7) and 814314 (Ref. 9) appear to recognize only systems designed for more immediate detection.
Illumination Levels in CAAs An apparent inconsistency was identified in two different guidance documents which discuss illumination levels for CAAs. The Category II licensing criteria document (Ref. 5) states that an illumination level of 0.2 footcandles, measured horizontally at ground level, is acceptable. The inspection guidance for non-power reactors, Draft Inspection Procedure 814214 (Ref. 7) however, calls for illumination in the range of 100 to 200 footcandles, measured horizontally at 3 feet above the floor.
4See footnote 3, page 6.
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Temporary Storage of Category III Special Nuclear Material Regulatory Guide 5.59 (Ref. 4) states that temporary CAAs may be used for tem-porary storage of Category III SNM. The Guide (Ref. 4) allows temporary CAAs to have barriers consisting of office partitions, cordons, etc., but calls for isolation of the SNM or use of motion detectors, if the material is to be left unattended. The Category III licensing criteria document (Ref. 8), on the other hand, makes no mention of temporary storage of SNM, and says that CAAs used for storage of such material should have permanent barriers. Draft Inspection Procedure 814315 (Ref. 9)'also is silent on temporary CAAs and indicates the need for CAA barriers of sufficient strength to prevent forced entry.
II. OTHER FINDINGS Non power Reactor Security Plans A review of Categories II and III non power reactor licensees' security plans indicated that approximately half of them mention sabotage protection.
1 Industrial Sabotage The term " industrial sabotage" was found in several places in the regulations and guidance. Specifically, 10 CFR SS 50.34(d), 70.22(g), 70.22(j), and the introduction to Regulatory Guide 5.59 (Ref. 4) all mention industrial sabotage, even though the term has been superseded by " radiological sabotage," as defined in 10 CFR S 73.2(p).
Internal Inconsistency--Regulatory Guide 5.59 (Ref. 4)
The Group noted that Regulatory Guide 5.59 (Ref. 4) contains an apparent inter-nal inconsistency with regard to its references to the Upgrade Rule Guidance 5See footnote 3, page 6.
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Compendium (Ref. 10). Specifically, the Guide (Ref. 4) references the Compendium as a source of information on monitoring of Category III CAAs, but neglects to I also mention it in a discussion of Category II CAA monitoring.
Clarity of Language in Regulations In the course of this review, the group noted some apparent inconsistencies in regulations, which required careful study to dispel. For example, 10 CFR 50.54, Conditions of Licenses, says: "Whether stated therein or not, the following shall be deemed conditions in every license issued ...." Subsection 50.54(p) of that regulation goes on to state: "The licensee shall prepare and maintain safeguards contingency plan procedures in accordance with Appendix C of 10 CF.R Part 73 for effecting the actions and decisions contained in the Responsibility Matrix of the safeguards contingency plan." At first reading, this may appear to require that all licensees prepare contingency plans. However, we now conclude the regulation requires licensees, who already have safeguards contin- i gency plans, to prepare " procedures" for effecting those plans.
In another example,it appeared that a 93-word sentence in 10 CFR, Part 73, i
Appendix B, could be interpreted to require every licensed utilization facil-ity to establish a security organization, including guards. In this case, proper interpretation depends upon the word "respectively," which appears in the middle of that sentence quoted below:
" Pursuant to the provisions of SS 73.50 and 73.55 of 10 CFR Part 73, Requirements for Physical Protection of Plants and Materials, each licensee who is authorized to conduct certain activities with speci-fied quantities of special nuclear material pursuant to 10 CFR Part 70 and each licensee who is authorized to operate a production or utilization facility pursuant to 10 CFR Part 50, respectively, is required to establish a security organization, including trained
' and equipped guards to physically protect special nuclear material in their possession and their facilities against theft and radio-logical sabotage." (underscoring added for emphasis)
Thus, the requirement applies only to Part 70 licensees subject to 73.50 and to Part 50 licensees (power reactors) subject to 73.55. .
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" Applicant" vs. " Licensee" Requirements for Security Plans 10 CFR S 50.34(c) states, "Each application for a license to operate a produc-tion or utilization facility shall include a physical security plan." 10 CFR S 73.67(c)(1) requires each licensee having SNM of moderate strategic signi-ficance or 10 kg or more of SNM of low strategic significance to submit a security plan or amended security plan.
There is an apparent inconsistency between these rules in that $50.34(c) is an unconditional requirement that applicants submit security plans, whereas S 73.67 appears to exempt licensees possessing less than 10 kg of SNM of low strategic significance from submitting security plans.
Use of the Terms " Category II" and " Category III" The Group observed that the terms " Category II" and " Category III" are commonly used by the staff in referring to SNM of moderate and low strategic significance, respectively. (In fact, these terms have been used throughout this report.)
This terminology is employed by the IAEA, and referenced accordingly in 10 CFR Part 110, covering export and import of nuclear material. Nevertheless, it seems somewhat inconsistent to use the terms " Category II" and " Category III,"
when they are not defined in our domestic safeguards regulations. Guidance documents which employ these terms include:
Standard Review Plans (for Categories II and III) (Ref. 11)
Physical Protection Requirements (Category II Licensing Criteria) (Ref. 5)
Acceptance Criteria (Category III Licensing Criteria) (Ref. 8)
IE Manual Chapter 2545 (for non power reactors) (Ref. 12) 10 s
Unclear Definitions within 10 CFR I 73.67 The Group noted that the 10 CFR i 73.67(d) and (f) descriptions of SNM holdings constituting material of " moderate strategic significance" or " low strategic significance" do not make 15 clear whether the determination of SNM holdings is limited to that held under the^ authority of a specific license. Depending on the physical location and distribution of SNM at a given site, a variety of different multi-license arrangements would appear possible. Thus, there may be uncertainty concernirg the safeguards requirements applicable to licensees whose SNM is distributed in different locations.
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REFERENCES Cited in Text Description or Desianator
- 1. U.S. Nuclear Regulatory Commission, 1. LBP-83-25A, Atomic Safety and Licensing Board 17 NRC 927 (1983) decisions in the matter of Docket and LBP-83-67 No. 50-142-OL (proposed renewal of 18 NRC 802 (1983) facility license)
The Regents of the University of California (UCLA Research Reactor) 1983.
- 2. Memo for the Commissioners, from 2. Secy 77-79 Kenneth R. Chapman, U.S. Nuclear Regulatory Commission, Director, Office of Nuclear Material Safety and Safeguards, "NRC and Inter-national Physical Protection Standards," Secy 77-79, Feb. 11, 1977.
- 3. Memo for J. Davis, U.S. Nuclear 3. EDO Memorandum, -
Regulatory Commission, Director, dated July 3, 1984 Office of Nuclear Material Safety and Safeguards, et al., from William J.
Dircks, Executive Director for Opera-tions, OIA Investigation, "ASLB--
Allegations concerning Three NRC Employees" (dated June 12, 1984),
July 3, 1984.
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Cited in. Text Description or Designator
- 4. U.S. Nuclear Regulatory Commission, 4. Regulatory Guide 5.59, Regulatory Guide 5.59, " Standard Standard Format and Format and Content for a Licensee Content Guide for a and Physical Security Plan for the Categories II and III 1 Protection of Special Nuclear Mate- Security Plans rial of Moderate or Low Strategic Significance," February 1983.
- 5. U.S. Nuclear Regulatory Commission, 5. Category II Licensing
" Physical Protection Requirements Criteria for Special Nuclear Material of Moderate Strategic Significance,"
November 1983.
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- 6. U.S. Nuclear Regulatory Commission, 6. Oraft Inspection Inspection Procedure 81402,1 " Reports Procedure 81402 of Safeguards Events," draft, undated.
- 7. U.S. Nuclear Regulatory Commission, 7. Oraft Inspection Inspection Procedure 81421, " Fixed Procedure 81421 Site Physical Protection of Special Nuclear Material of Moderate -
Strategic Significance," draft, undated.
- 8. U.S. Nuclear Regulatory Commission, 8. Category III licensing
" Acceptance Criteria for the Review criteria of Category III Physical Protection Plans," March 4, 1983.
l 1The Group noted that the current IE procedures have been in effect for several years and are recognized to be significantly out of date. Accordingly, with respect to 81400 series procedures, the review was confined to draft versions of the updated procedures, which are under development within IE.
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Cited in Text Description or Designator
- 9. U.S. Nuclear Regulatory Commission, 9. Draft Inspection Inspection Procedure 81431,2 " Fixed Procedure 81431 Site Physical Protection of Special Nuclear Material of Low Strategic Significance," draft, undated.
- 10. U.S. Nuclear Regulatory Commission, 10. Upgrade Rule Guidance
" Fixed Site Physical Protection Compendium Upgrade Rule Guidance Compendium,"
NUREG-0669, June 1980.
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- 11. U.S. Nuclear Regulatory Commission, 11. A catalogue of standard
" Standard Review Plans Providing review plans, used by the Guidance for Fuel Facilities Safe- safeguards licensing staff; guards Licensing Branch," broken into chapters corres-September 1983. ponding to facility types (Categories II and III)
- 12. U.S. Nuclear Regulatory Commission, 12. IE Manual Chapter for
" Manual Chapter 2545, Research and non power reactors Test Reactor Inspection Program --
Operations Phase," January 27, 1984. --
2See footnote 1, p. R-2.
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BIBLIOGRAPHY Public Notices:
- 1. U.S. Nuclear Regulatory Commission, " Safeguards Requirements for Special Nuclear Material of Moderate and Low Strategic Significance," Federal Register, Vol. 44, No. 143, July 24, 1979, 43280-43285.
Code of Federal Regulations:
- 2. Code of Federal Regulations, Title 10, Chapter I (10 CFR) 6 50.34(c) -
requirements for security plan submittal 9 50.34(d) -
contingency plan submittal 9 50.34(p) -
contingency plans; no fee plan changes S 70.20 -
general license S 70.22(j) -
contingency plan submittal 9 70.22(k) -
security plans, > 10 kg Cat III 6 70.32(e) -
changes to security plans S 70.32(g) -
changes to contingency plans S 70.41 -
use of SNM -
S 70.51(b) -
MC&A records S 70.51(c) -
MC&A procedures, > 1 kg SNM S 70.51(d) -
annual inventories S 70.51(i) -
quality of records S 70.52(a) -
reporting accidental criticality or loss 9 70.52(b) -
reporting of thefts S 70.53(a) -
reporting material balance S 70.54 -
reporting transfers of SNM S 73.2(p) -
definition of radiological sabotage S 73.40(a) -
general theft / sabotage protection-fixed sites S 73.40(b) -
requirements for contingency plans S 73.40(c) -
conditions of contingency plans S 73.40(d) -
maintenance / review contingency plans B-1
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S 73.67(a) -
general safeguards requirements Cats. II and III 4
6 73.67(b) -
exemptions / distribution of material 9 73.67(c) -
security plan submittal 6 73.67(d) -
Category II fixed site requirements S 73.67(f) -
Category III fixed site requirements S 73.71(b) -
reporting requirements S 73.71(c) -
reporting requirements Pt 73, App. 8 -
guard training and qualification Pt 73, App. C - contingency planning Pt 110 -
export and import of nuclear material Regulatory Guides: Designator:
- 3. U.S. Nuclear Regulatory Commission, 3. Regulatory Guide 5.7 Regulatory Guide 5.7, " Control of Personnel Access to Protected Areas, Vital Areas, and Material Access Areas," June 1973.
- 4. U.S. Nuclear Regulatory Commission, 4. Regulatory Guide 5.12 Regulatory Guide 5.12, " General Use of Locks in the Protection and Con-trol of Facilities and Special r
Nuclear Materials," November 1973. -
- 5. U.S. Nuclear Regulatory Commission, 5. Regulatory Guide 5.29 Regulatory Guide 5.29, Nuclear Material Control Systems for Nuclear Power Plants," Rev. 1, June 1976.
- 6. U.S. Nuclear Regulatory Commission, 5. Regulatory Guide 5.44 Regulatory Guide 5.44, " Perimeter Intrusion Alarm Systems," Rev. 1, June 1976.
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Regulatory Guides: (Continued) Designator:
- 7. U.S. Nuclear Regulatory Commission, 7. Regulatory Guide 5.49 Regulatory Guide 5.49, " Internal Transfers of Special Nuclear Mate-rial," March 1973.
- 8. U.S. Nuclear Regulatory Commission, 8. Regulatory Guide 5.60 Regulatory Guide 5.60, " Standard Format and Content of a Licensee Physical Protection Plan for Strategic Special Nuclear Mate-rial in Transit," April 1980.
- 9. U.S. Nuclear Regulatory Commission, 9. Regulatory Guide 5.62 Regulatory Guide 5.62, " Reporting of Physical Security Events,"
February 1981.
Oraft IE Procedures:t
- 10. U.S. Nuclear Regulatory Commission, 10. Oraft Inspection Office of Inspection and Enforcement, Procedure 81401
" Inspection Procedure 81401, Physical -
Security Plans," draft, undated.
- 11. U.S. Nuclear Regulatory Commission, 11. Draft Inspection Office of Inspection and Enforcement, Procedure 81403
" Inspection Procedure 81403, Receipt of Fuel at Non power Reactors," draft, undated.
1The Group noted that the current IE procedures have been in effect for several years and are recognized to be significantly out of date. Accordingly, with respect to 81400 series procedures, the review was confined to draft versions of the updated procedures, which are under development within IE.
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MC&A Guidance: Designator:
- 12. U.S. Nuclear Regulatory Commission, 12. NUREG/BR-0006
" Instructions for Completing Nuclear Material Transaction Reports," NUREG/
BR-0006, Rev. 2, Dec 1, 1984.
- 13. U.S. Nuclear Regulatory Commission, 13. NUREG/8R-0007
" Instructions for Completing Mate-rial Balance Report, Physical Inven-tory Listing, and Concise Note Forms," NUREG/BR-0007, effective Jan. 1, 1980.
Effective IE Procedures:
- 14. U.S. Nuclear Regulatory Commission, 14. Active Inspection Inspection Procedure 85102, " Mate- Procedure 85102 rial Control and Accounting, Power Reactors," February 21, 1984.
- 15. U.S. Nuclear Regulatory Commission, 15. Active Inspection Inspection Procedure 81810, " Physical Procedure 81810 Protection Safeguards Information," -
October 1, 1982.
- 16. U.S. Nuclear Regulatory Commission, 16. Active Inspection Inspection Procedure 92706, "Inde- Procedure 92706 pendent Inspection Effort," Proce-dure 92706, October 1, 1980.
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l Enforcement Guidance Memoranda: Designator:
- 17. U.S. Nuclear Regulatory Commission, 17. (Unnumbered)
Office of Inspection and Enforce-ment, Memorandum, James Lieberman, to R. Carlson et al., " Citing Safe-guards Violations against Approved Plans," May 13, 1981 (unnumbered).
- 18. U.S. Nuclear Regulatory Commission, 18. (Unnumbered)
Office of Inspection and Enforce-ment, Memorandum, James Lieberman to Distribution, " Enforcement Guidance for Handling Safeguards Violations,"
July 22, 1982 (unnumbered).
- 19. U.S. Nuclear Regulatory Commission, 19. Enforcement Office of Inspection and Enforcement, Memorandum EGM-81-03 Memorandum, Oudley Thompson to J. P. O'Reilly, " Selection of Security Level," EGM-81-03, January 12, 1981.
- 20. U.S. Nuclear Regulatory Commission, 20. Enforcement Office of Inspection and Enforcement, Memorandum EGM-81 Memorandum, Dudley Thompson to R. Carlson et al., " Policy Guidance for Safeguards Enforcement,"
EGM 81-17, May 14, 1981.
- 21. U.S. Nuclear Regulatory Commission, 21. Enforcement Office of Inspection and Enforcement, Memorandum EGM-81-28 Memorandum, Richard H. Wessman to Robert Carlson et al. , " Citations Regarding Noncompliance with Physical Protection Rules,"
EGM-81-28, September 8, 1981.
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I Industry Standards: Designator:
- 22. American Nuclear Society Standards 22. ANSI Standard 15.14 Secretariat, " Physical Security of Research Reactors," ANSI Stand-ard 15.14,2 draft, undated.
- 23. Underwriters Laboratories, Inc. , 23. UL Standard 437
" Standard for Key Locks," UL 437, January 30, 1975.
- 24. Underwriters Laboratories, Inc., 24. UL Standard 768
" Standard for Combination Locks,"
UL 768, July 20, 1972.
,a 2With minor exceptions, ANSI 15.14 was found to contain essentially identical substance to the Categories II and III licensing criteria documents (" Physical Protection Requirements for SNM of Moderate Stategic Significance" (Ref. 5) and " Acceptance Criteria for the Review of Category III Physical Protection Plans" (Ref 8). Therefore, all comments contained in the body of this report which refer to either of these two documents can also be applied to ANSI 15.14.
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