ML20211K235

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Review of Safeguards Regulations & Guidance (Categories II & III SNM Transportation)
ML20211K235
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Issue date: 07/31/1985
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NRC - SAFETY/SAFEGUARDS REVIEW GROUP
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REVIEW 0F SAFEGUARDS REGULATIONS AND GUIDANCE (Categories II and III Special Nuclear Material Transportation)

SAFEGUARDS INTEROFFICE REVIEW GROUP July 31, 1985 62 4 860624 AFTERGOB6-432 PDR f

i TABLE OF CONTENTS 1 Page Foreword ....................................................... iii Su mm a ry o f F i n d i n g s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Background ..................................................... 1 i

Scope and Approach ............................................. 2 R e g ul a t o ry Ov e r v i ew . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Findings Related to Transportation of Categories II and III Sp ec i al Nucl ear Ma te ri al . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 R e g ul a t o ry Gu i d a n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 i Regulatory Guides 5.59 and 5.62 Are Inconsistent with 10 C F R 7 3 . 71 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Safeguards Response Procedures -- Questionable Example in 1

Re g ul a t o ry Gu i d e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Im po rt No ti f i c a ti o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Expan sion of Requi rement by Regul atory Guide . .. . . . . . . . .. . . . . 6 Minor Di sc repancies in Regul atory Guide 5. 59 . . . . . . . . .. . .. . .. 6 I n s p e c t i o n Gu i d a n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Regulatory Citation Errors in Inspection Procedures ......... 7 Clarification of Wording - Checking Integrity of Containers and Seals ...................................... 7 l

Cl ari fi cation of Wo rding - Repo rts . . . . . . . . . . . . . . . . . . . . . . . . . . 7  ;

! Licensing Guidance ............................................. 9 Regulatory Citation Errors in Standard Review Plans ......... 9 -

i I m po r t No ti f i c a t i o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 l Sec ur i ty Pl an s fo r S NM Shi pment s . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 i

Regulations.................................................... 11 Inconsistency between 10 CFR 74.11 and 10 CFR 73.71......... 11 Lack of Parall el Requi rements in 10 CFR 73.67 . . . . . . . . . . . . . . . 11 Relative Urgency for Investigating Lost Shipments

IsUnclear................................................ 11 Anbiguous Reporting Requirement in the Regulations

( 10 C F R 7 3 . 71 ) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 j M i s c el l a n eo u s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 Use of the Terms " Category !!" and " Category III" ........... 13 I

References ...................................................... R-1 Bibliography ................................................... B-1 V

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i FOREWORD i -

4 The Safeguards Interoffice Review Group was formed in October,1984 at the t

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 i

j in administering safeguards requirements.

l The Group currently has the following membership:

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Robert A. Erickson, NMSS, Chairman Paul Baker, NMSS Loren L. Bush, IE f

Francis X. Cameron, ELD .

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Stanley L. Dolins, NMSS ,

Jar.a L. Gibson, NRR

! Gordon E. Gundersen , tNSS i'

Charles R. Hillman, NMSS j; Philip. Ting, RES

in preparing this repor'., the Group was assisted and advised by others, includ- ,

1 l ing: Richard Rosano," IE; Ellen Kraus, fNSS; William C. Hawkins, NMSS; Stanley P. Turel, RES; and Norman Ketzlach, NMSS. The following served as Group contacts:

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, Walter Schwink (FCO); Richard P. Kaimig (RI); Kenneth P. Barr (Ril); James R. I i Creed (R!ll); Ramon E. Hall (RIV); and James L. Montgomery (RV).

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REVIEW 0F SAFEGUARDS REGULATIONS AND GUIDANCE  :

l (Categories II and III Special Nuclear Material Transportation)

Summary of Findings l In its review of NRC safeguards regulations and guidance concerning transporta-I

! tion of Categories 11 and III special nuclear material, the Safeguards Inter-jl office Review Group identified a number of minor inconsistencies and ambiguities 1

in regulatory guidance, inspection guidance, licensing guidance and in some of the regulations themselves. Most of these inconsistencies concern when or where reports should be submitted to the NRC. The Group also identified a number of 1

incorrect references to NRC regulations in the guidance documents.

Background

Proceedings on the application for renewal of the non-power reactor license for

the University of California at Los Angeles (UCLA) highlighted a lack of coordi-nation and consistency in the NRC staff concerning implementation of the relevant regulations (17 NRC 927 and 18 NRC 802, see Ref.1). To preclude such problems in the future, NRC's Executive Director for Operations (E00) directed NMSS to

. . . promptly review all NRC Safeguards regulations and pertinent associated j ..

i guidance with other NRC offices (NRR, IE, and Regions, as necessary) to assure i

j that no further misunderstanding or lack of coordination and consistency, as were j manifested in the UCLA proceeding, exist or recur either in hearing-related or l non-hearing-related activities." (See Ref. 2.)

1 NMSS organized the Safeguards Interoffice Review Group to address the concerns i

raised by the E00. NRC's Regional offices and the E00's office each designated persons to serve as points of contact for the Group, which held its first weekly meeting on October 18, 1984.

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Scoce and Approach The ED0 directive to review safeguards regulations and guidance was broad in scope. In order to make the review manageable, while being fully responsive j to the directive, the Group agreed to approach its work as follows
1. The Group would concentrate on identifying inconsistencies in safeguards regulations and guidance, with the understanding that resolution of those

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inconsistencies is a task for the staff at large.

2. The Group would review regulations and guidance affecting various classes i of licensees as follows:

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Non-power Reactors - Categories 11 and III (report issued January 31, 1985, see Ref. 3)

Non-power Reactors - Category I (report issued April 15, 1985, see Ref. 4) j Spent Fuel Transportation (report issued May 3,1985, see Ref. 5)

. Categories II and III - Special Nuclear Material Transportation .

Category 1 - Strategic Special Nuclear Material Transportation Fuel Fabrication Facilities - Categories !! and III (Physical Security)

Fuel Fabrication Facilities - Category I (Physical Security)

Fuel Fabrication Facilities - Categories I and II (Material Control and Accountability)

Fuel Fabrication Facilities - Category 111 (Material Control and Accounta-bility)

Power Reactors Independent Spent Fuel Storage Installations Fuel Fabrication / Conversion Facilities and Power Reactors under IAEA Safe-4 guards New Fuel Stored at Reactors 1

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(These groupings of regulations and guidance are subject to change, as appropri-ate, to facilitate their review.)

3. The Group would attempt to identify and screen all relevant documents used by the NRC staff in performance of safeguards licensing and inspection /

enforcement functions.

4. In the course of its reviews covering various classes of licensed activi-ties, the Group would also be alert for generic problems. These may be discussed in the Group's final report, which, accordingly, could include comments on such matters as improving NRC staff coordination; clarifying the scope of NRC regulations (in terms of the types of facilities or activ-1 ities covered); clearly identifying superseded regulations and guidance; and ensuring that regulations, guidance, licensing criteria, and inspection procedures are coherent and readily available to all responsible staff.

Regulatory Overview Safeguards for special nuclear material transportation are regulated by the NRC under authority of the Atomic Energy Act of 1954, as amended, and the Energy Reorganization Act of 1974. Applicable NRC safeguards regulations are codified-principally in 10 CFR Parts 50, 70, 73, and 74. Special nuclear material trans-portation licensees establish safeguards programs in accordance with these regu-lations and supporting guidance documents. The terms " Category 1," " Category II,"

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and " Category III," respectively, denote special nuclear material of "high" (for-mula quantity), moderate, and low strategic significance.I Requirements for the physical protection of Categories II and III special nuclear material transporta-tion are contained in 10 CFR 73.67. Requirements for reports of lost or unaccounted for shipnents are contained in 10 CFR 73.71 and 74.11. Requirements for advance notice of shipment are given in 10 CFR 73.72.

I As defined in 10 CFR 73.2:

Formula quantity means: strategic special nuclear naterial in any combination in a quantity of 5, 000 grams or more computed by the formula, grams = (grams 1 contained U-235) + 2.5 (grams U-233 + grams plutonium). Strategic special nuclear material means uranium-235 (contained in uranium enriched to 20 percent or more in the U-235 isotope), uranium-233, or plutoniu'm.

Special nuclear material of moderate strategic significance means:

(1) Less than a formula quantity of strategic special nuclear material but more than 1000 grams of uranium-235 (contained in uranium enriched to 20 percent or more in the U-235 isotope) or more than 500 grams of uranium-233 or pluto-nium or in a combined quantity of more than 1000 grams when computed by the equation, grams = (grams contained U-235) + 2 (grams U-233 + grams plutonium),

or (2)10,000 grams or more of uranium-235 (contained in uranium enriched to 10 per-cent or more but less than 20 percent in the U-235 isotope).

Special nuclear material of low strategic significance means:

(1) Less than an amount of strategic special nuclear material of moderate strate-gic significance . . . but more than 15 grams of uranium-235 (contained in ,

uranium enriched to 20 percent or more in the U-235 isotope) or 15 grams of uranium-233 or 15 grams.of plutonium or the combination of 15 grams when computed by the equation, grams = grams contained U-235 + grams plutonium

+ grams U-233, or  !

(2) Less than 10,000 grams but more than 1000 grams of uranium-235 (contained in uranium enriched to 10 percent or more but less than 20 percent in the U-235 isotope), or (3)10,000 grams or more of uranium-235 contained in uranium enriched above natural but less than 10 percent in the U-235 isotope.

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FINDINGS RELATED TO TRANSPORTATION OF CATEGORIES II AND III SPECIAL NUCLEAR MATERIALS REGULATORY GUIDANCE Regulatory Guides 5.59 and 5.62 Are Inconsistent with 10 CFR 73.71 10 CFR 73.71(a) requires each licensee who conducts a trace investigation of a lost or unaccounted for shipment of special nuclear material (SNM) of moderate or low strategic significance to notify the NRC Operations Center as soon as possible (and in all cases within one hour) and to file a written report, within l

15 days, to the appropriate NRC Regional Office. However, in discussing reports of material lost or unaccounted for, Regulatory Guide 5.59 (see Ref. 6), in Sec-tion 9.7 does not mention NRC's ' erations Center. Instead, it refers to report-ing "immediately to the appropriate NRC Regional Office in accordance with 73.71."

This same inconsistency appears in Regulatory Guide 5.62, Section C (see Ref. 7) and is similar to the inconsistencies noted under Clarification of Wording -

Reports, page 7 of this report.

Safeguards Response Procedures - - Questionable Example in Regulatory Guide -

10 CFR 73.67(e)(3)(iv) requires licensees who arrange for in-transit physical protection of Sffi of moderate strategic significance to " establish and naintain response procedures for dealing with threats of thefts or thefts of such material."

In explaining the intent of this requirement, Regulatory Guide 5.59 (see Ref. 6),

in Section 9.4, states: "For example, if the shipper is informed by the carrier that adverse weather conditions have temporarily prevented further progress of the shipment, the licensee should inform the receiver of a new estimeted time of arrival ." This example seems more appropriate to Section 73.67(e)(3)(1)(B), con-cerning notification of delays in scheduled shipment.

Import Notifications 10 CFR 73.67(g)(5)(ii) requires each licensee who imports Sffi of low strategic significance to " Notify the person who delivered the material to a carrier for transport of the arrival of such material." Commenting on this, Regulatory 5

Guide 5.59 (see Ref. 6), Section 9.2 states: "The intent of this regulation is to ensure that the exporter is notified that the material has arrived safely." However,

" person," as used in the regulation, may include a broader class of individuals than the " exporter" referred to in the Guide.

Expansion of Requirement by Regulatory Guide With regard to SNM of low strategic significance,10 CFR 73.67(g)(3)(1) requires

licensees to " Establish and maintain response procedures for dealing with threats l

l of thefts or thefts of such material." In Regulatory Guide 5.59, Section 7.1 (see Ref. 6), a discussion of this. requirement concludes with the sentence: " Ensure that the NRC will be notified immediately in the event of theft or attempted theft of the material." This appears to be an expansion of the actual regulatory require-  ;

ment being discussed and would be more properly keyed to the requirements of 10 CFR 73.67(g)(3)(iii),10 CFR 74.11, and 1,0 CFR 73.71, which contain reporting require-ments.

l Minor Discrepancies in Regulatory Guide 5.59 F.egulatory Guide 5.59 (see Ref. 6), in Section 7.3, Inspection, referring to 10 CFR 73.67(e)(1)(iii), discusses " . . . cor. firming the integrity of a shipment through

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inspections just prior to commencement and during the shipment. . . . " Howev'er ,

the regulation requircs checking the integrity of the container prior to shipment, l but not during the shipment. .

Similarly, Regulatory Guide 5.59, Section 9.1, paragraph 2., Notification of Ship-ment Delays, states: " Notifications to the licensee should be made by the carrier i

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, or transport personnel whenever unforeseen conditions arise that threaten to delay the shipment significantly beyond the estimated arrrival time . . . . " (Emphasi s added.) However, the pertinent section of the regulttion, 73.67(e)(3)(1)(B), does not contain the qualifier "significantly." Rather, it requires arrangements "for notification of any delays in the scheduled shipment . . . . " (Emphastsadded.)

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INSPECTION GUIDANCE Regulatory Citation Errors in Inspection Procedures l Section 73.67(a)(1) requires licensees transporting Category II or III material to provide a physical protection system as a general performance objective.

Section 021 of Inspection Procedures 81335 (see Ref. 8) and 81340 (see Ref. 9) requires verification of a " physical protection system," but cites sections 73.67 (e) and (g) respectively, which describe detailed compcnents of required systems, rathdr than citing the general perfonnance requirement in 73.67(a)(1).

Clarification of Wording - Checking Integrity of Containers and Seals l

The first footnote in Inspection Procedures 81335 (see Ref. B) and 81340 (see I

j Ref. 9), as presently worded, may suggest that checking the integrity of containers and seals would be accomplished only in export shipments. However, 73.67(e)(2)(1) and 73.67(g)(2)(i), the cited references for each footnote, require such a check for all shipments. .

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Clarification of Wording - Reports Inspection Procedure 81335 (see Ref. 8), Section 0219, says the licensee must ,,  !

! report the initiation of a trace investigation, and submit a written report to l

{ ~ the "NRC," without specifying where the report must go. The referenced section l of the rule, 73.71(a), however, specifies that the report must go to the Regional l Office, and 73.67(e)(3)(vii) (incorrectly omitted) specifies that the initial j

! (telephonic) report must go to the Regional Administrator. The same discrepancy (i.e., not specifying where the report must go) exists in Section 022a. Simil arly ,

) Section 021d of Inspection Procedure 81340 (see Ref. 9) mentions only the "NRC" as the recipient of notifications of trace investigations and follow up reports.

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The inspection procedures could be more specific about this, since the cited refer-j ences, 73.71(a) and 73.67(g)(3)(iii), are quite specific about where reports should be sent--to the NRC Operations Center, to the Regional Administrator, and to the Director, Office of Inspection and Enforcement. '

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LICENSING GUIDANCE Regulatory Citation Errors in Standard Review Plans The licensing " Standard Review Plans" for Categories II and III transportation (see Refs.10 and 11), both appear to contain a number of regulatory citation errors, pointing to parts of 10 CFR 73.67 which do not pertain to the subjects being reviewed. These are listed below.

i Category II Areas Listed Corresponding (incorrect) in Standard Review Plan Regulatory References Cited in Review Plan

- In-Transit Security Responsibilities

! - Unescorted Access Authorization 10 CFR 73.67(e)(2)(iii)

Identification of Persons to Do Screenino i - Describes procedures to point 10 CFR 73.67(e)(5) where responsit.ility . transfers

! - Describes Security Measures 10 CFR 73.67(e)(6)(i)

(plus 9 subheadings)

- NRC request for additional 10 CFR 73.67(e)(1) information

- Provision for notification of 10 CFR 73.67(e)(1) shipnent delay

! - Make notification promptly to 10 CFR 73,.67(e)(1)

NRC of receipt 1

Category III Areas Listed Corresponding (incorrect) in Standard Review Plan Regulatory References Cited in Review Plan

- Licensee shipper is responsi- 10 CFR 73.67(g)(1) ble if receiver is not a licensee t i

- When both shippdr and receiver 10 CFR 73.67(g)(ii) 4 licensee are responsible

- Describes Security Measures 10CFR73.67(g)(5)(1)

(plus 6 subheadings) 9

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importNotifications 10 CFR 73.67(g)(5)(11) requires each licensee who imports SPN of low strategic significance to " Notify the person who delivered the material to a carrier for transport of the arrival of such material." Regarding this requirement, the Standard Review Plan refers to notifying the " shipper" of receipt. How-ever, it is not clear that the " person" referred to in the regulation is nec-essarily the " shipper." (A similar discrepancy was found in Regulatory Guide 5.59, Section 9.2 (Ref. 6), which is described elsewhere in this report.)

Security Plans for SNM Shipments 10 CFR 73.67(a)(1) requires each licensee who possesses, uses or transports SNM of moderate or low strategic significance to ". . . establish and maintain a physical protection system . . . ." 10 CFR 73.67(c)(1) further requires each licensee who transports SfN of moderate strateg1~c significance, or 10 kg or more of SfN of low strategic significance, to submit a security plan. However, licen-sees are not required to submit security plans covering transport of less than 10 kg of SfN of low strategic significance. The apparent ambiguity is that NRC staff has routinely expected a licensee transporting less than 10 kg of SfN of-low strategic significance to satisfy the " physical protection system" require-ment of 73.67(a) by having a Physical Security Plan, although that Physical Security Plan need not be submitted to NRC for approval .

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REGULATIONS Inconsistency between 10 CFR 74.11 and 10 CFR 73.71 10 CFR 74.11 requires licensees to report theft or attempted theft of SNK immedi-ately to the appropriate NRC Regional Office in accordance with the procedures in l

73.71. However,10 CFR 73.71 requires such initial reports to be made only to the NRC Operations Center. ( According to 73.71(a) and (b), reports to the Regional Offic'e are required to be submitted in writing within 15 days. 73.71(c) requires certain other written reports to be submitted to the Regional Office within 5 days.)

Lack of Parallel Requirements in 10 CFR 73.67 10 CFR 73.67(e)(3)(vii) requires a licensee to notify immediately the NRC Regional Office Administrator about actions to trace lost or unaccounted for shipments of SNM of moderate strategic significance. However, this section says nothing about the requirement to report to NRC's Operations Center in accordance with 10 CFR 73.71. (The 73.71 reporting requirement h mentioned in 10 CFR 73.67(g)(3)(iii) -

the section dealing with SNM of low strategic significance.)

Relative Urgency for Investigating Lost Shipment Is Unclear ,

The requirements in 10 CFR 73.67 for tracing lost or unaccounted for shipments of

.SNM of moderate and low strategic significance appear inconsistent with the respective importance of the materials. 10 CFR 73.67(e)(3)(vi), referring to SNM of moderate strategic significance, requires the licensee to " initiate immediately a trace investigation of any shipment that is determined to be lost or unaccounted for af ter a reasonable time beyond the estimated arrival time." In contrast, Sec-tion 73.67(g)(3)(iii), concer'ning StN of loy strategic significance, unconditionally requires the licen'see to " Conduct immediately a trace investigation of any shipment that is lost or unaccounted for after the estimated arrival time. . . ." Thus, tracing lost shipments of low strateg.ic significance appears more urgent than trac-ing lost shipments of moderate strategic significance.

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Ambiguous Reporting Requirement in the Regulations (10 CFR 73.71) j 10 CFR 73.71(c) requires each licensee to ". . . notify the NRC Operations Center via the Emergency Notification System as soon as possible, and in all cases within one hour, of any event which significantly threatens or lessens the effectiveness of a physical security system as established by regulations in this chapter . . . ."

However, a table that follows, setting out reporting times for various events,

! indicates that for breakdown of security systems protecting SNM of moderate strategic significance, the reporting time to NRC is "within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />." The table does not I address systems protecting SNM of low strategic significance.

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MISCELLANEOUS

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Use of the Terms " Category II" and " Category III" The terms " Category II" and " Category III" appear in this report and are commonly used by the NRC staff in referring to SIN of modarate and low strategic signifi-cance, respectively. This terminology is employed by the IAEA, and referenced accordingly in 10 CFR Part 110, covering export and import of special nuclear l j material. Nevertheless, it seems inconsistent to use the terms " Category II" and )

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" Category III," when they are not defined in our domestic safeguards regulations.

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REFERENCES

1. U. S. Nuclear Regulatory Commission, Atomic Safety and Licensing Board deci-sions in the matter of Docket No. 50-142-01 (Proposed renewal of facility license), The regents of the University of California (UCLA Research Reactor) 1983.
2. Memo for J. Davis, U. S. Nuclear Regulatory Commission, Director, Office of Nuclear Material Safety and Safeguards, et al ., from William J. Dircks, Executive Director for Operations, 0IA In,vestigation, "ASLB Allegations Concerning Three Enployees" (dated June 12, 1984), July 3, 1984.
3. U. S. Nuclear Regulatory Commission, Safeguards Interoffice Review Group,

" Review of Safeguards Regulations and Guidance (Non-power Reactors -

Categories II and III)," January 31, 1985.

4. U. S. Nuclear Regulatory Commission, Safeguards Interoffice Review Group,

" Review of Safeguards Regulations and Guidance (Non-power Reactors -

Category I)," April 15, 1985 -

5. U. S. Nuclear Regulatory Commission, Safeguards Interoffice Review Group,

" Review of Safeguards Regulations and Guidance (Spent Fuel Transportation),"

May 3, 1985.

6. U. S. Nuclear Regulatory Commission, Regulatory Guide 5.59," Standard Format and Content for a Licensee Physical Security Plan for the Protection of Special Nuclear Material of Moderate or Low Strategic Significance," Rev.1, February 1983.

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REFERENCES, Cont.

7. U. S. Nuclear Regulatory Commission, Regulatory Guide 5.62, " Reporting of Physical Security Events," February 1981.
8. U. S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Inspection Procedure 81335, " Physical Protection of SNi of moderate Strategic Significance (MSNM)," July 1,1983.
9. U. S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Inspection Procedure 81340, " Physical Protection of SNM of Low Strategic Significance (LSNM)," July 1,1983.
10. U. S. Nuclear Regulatory Commission, " Category II Transportation Physical Protection Plan," drawn up by the Material Transfer SG Licensing Branch, Division of. Safeguards, NMSS, August 1983.
11. U. S. Nuclear Regulatory Commission, " Category III Transportation Physical Protection Plan," drawn up by the Material Transfer SG Licensing Branch, Division of Safeguards, NMSS, August 1983. -

l BIBLIOGRAPHY Public Notice

1. U. S. Nuclear Regulatory Commission,10 CFR Parts 70 and 74, " Amended Material Control and Accounting Requirements for Special Nuclear Material of Low Strategic Significance," Federal Register, Vol. 50, No. 27, Februa ry 25, 1985.

Code of Federal Regulations

2. Code of Federal Regulations, Title 10, Chapter 1 Section or Subsection Subject 70.4 Definitions 70.4(m) SNR definitions 70.4(t) Effective kilograms of special nuclear material definitions 70.4(u) Special nuclear material scrap material 70.4(v) Transient shipment definition -

70.12 Carriers 70.41(a),(b) Licensee authorized use of SNM 70.42 Transfer of SNM 70.52 Reports of accidental criticality or loss or (attempted) theft of SNM 73.2 Definitions 73.2(r)(1) . Describes appropriate Nuclear Regul atory Commission Regional Office for domestic shi pments l

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BIBLIOGRAPHY, Cont.

73.2(r)(2) Describes appropriate NRC Regional Office for export shipments 73.2(r)(3) Describes appropriate NRC Regional Office for import shipments 73.2(u) Armed escort definition 73.2(x)(1)(2) Defines StN of moderate strategic significance 73.2(y)(1)(2)(3) Defines SNM of low strategic significance 73.2(cc) Transport definitions 73.67 Licensee fixed site and in-transit requirements for the physical protection of SfN of moderate and low strategic significance 73.67(a) General performance objectives 73.67(b) Licensee exemptions 73.67(c)(1)(2) Security plans for licensees with StN of moderate strategic significance or 10 kg

.or more of low strategic significance ,,

73.67(e) In-transit requirements for special nuclear material of moderate strategic significance 73.67(e)(1) Explains who is subject to in-transit require-ments for StN of moderate strategic significance 73.67(e)(1)(1) Advance notification 73.67(e)(1)(ii) Receive confirmation ]

73.67(e)(1)(iii) Integrity check 73.67(e)(1)(iv) In-transit physical protection arrangemer.~cs and i

exception B-2

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. s BIBL10 GRAPHY, Cont.

73.67(e)(2)(1) Integrity check 73.67(e)(2)(ii) Notification of receipt 73.67(e)(2)(iii) In-transit physical protection arrangements and exception 73.67(e)(3) Addresses licensee who arranges for in-transit' physical protection of SfN of moderate stra-tegic significance or who takes delivery free-on-board 73.67(e)(3)(1) Telephone or radio communicnion arrangements 73.67(e)(3)(1)(A) Periodic confirmatior. of shipment status 72.67(e)(3)(1)(B) Delay notification 73.67(e)(3)(1)(C) Emergemy response request 73.67(e)(3)(ii) %terial in-transit-time minimization 73.67(e)(3)(iii) Screening of licensee employees involved in material transport 73.67(e)(3)(iv) Response procedures for theft (threats) 73.o7(e)(3)(v) Notification arrangements 73.67(e)(3)(vi) Trace investigation of missing shipment 73.67(e)(vii) Noti fication 73.67(e)(4) Addresses licensees arranging physical . pro-tection of in-transit SSNM in quantities of moderate strategic significance or who take delivery free-on-board l

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BIBLIOGRAPHY, Cont.

73.67(e)(4)(1) Shipment requirements 73.67(e)(4)(ii) Material maintenance 73.67(g) In-transit requirements for special nuclear material of low strategic significance 73.67(g)(1) Responsibilities of licensee transporting or

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delivering for transport SNi of low strategic significance 73.67(g)(1)(1) Advance notification 73.67(g)(1)(ii) Confinnation receipt 73.67(g)(1)(iii) Secure container requ'irement 73.67(g)(1)(iv) Integrity check 73.67(g)(1)(v) In-transit material physical protection arrange-ment and exception 73.67(g)(2) Requirements for licensees who receive SNM of low strategic significance -

73.67(g) (3 ) Requirenents for licensee (shipper or receiver) arranging for physical protection of SNM of low strategic significance while in transit, or who takes delivery of such, free-on-board 73.67(g)(4) Requirenents for compliance, of licensees who export SNK of low strategic significance B-4

. BIBLIOGRAPHY, Cont.

73.67(g)(5) Requirements for licensees who import SN3 of low strategic significance 73.70 Records 73.70(g) Specific records to be kept of SNM shipments subject to requirements of this part 73.71 Reports of unaccounted for shipments, suspected thefts, unlawful diversion, radiological sabo-tage, or events which significantly threaten or lessen the effectiveness of safeguards 73.71(a) Notification requirements for licensee conducting trace investigations of missing shipments 73.71(b) Notification requirements for licensee cognizant of attempts made, or believed to be made to commit theft or unlawful diversion of its SNM, or to . commit act of radiological sabotage against its plant or transportation system.

73.71(c) Notification requirements for licensee under specific or general license, of event significantly threatening or lessening effectiveness of physical

~.

- security system.

i l B-5

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BIBLIOGRAPHY, Cont.

73.72 Requirement for advance notice of shipment of special nuclear material 73.72(a) Notifications about shipments containing formula quantities of SSNM, or SNM of moderate strategic significance containing in any part SSNM 73.72(b) Specific information to be furnished in advance notice 73.72(c) NRC Regional Office Administrator prior notification and shipment change notifi-cation .

Part 73, Appendix B, V. B. General Criteria for Security Personnel, ,

Transportation Part 73, Appendix D Physical Protection of Irradiated Reactor Fuel in Transit, Training Program Subject Schedul e Part 74 See Bibliography No. 1 Part 75.43 Circumstances requiring adv'ance notification 75.44 Timing of advance notification 75.45 Content of advance notification l

140.91-III Definitions 150.21 Transportation of special nuclear material by aircraft .

B-6

.' . . i BIBLIOGRAPHY, Cont.

Regulatory Guide

3. U. S. Nuclear Regulatory Commission, Regulatory Guide 5.15, "5acurity Seals for the protection and control of special nuclear material,"

January 1974.

Inspection and Enforcement Manual

4. U. S. Nuclear Regulatory Commission, Inspection and Enforcement Manual Chapter 2681, "Saf'eguards Inspection of Fuel Facilities, Transport of SNM and Irradiated Fuel, and SNM Imports and Exports," April 10, 1985.

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i B-7

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