ML20211K275

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Review of Safeguards Regulations & Guidance Category I Nuclear Fuel Facilities Physical Security
ML20211K275
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Issue date: 06/30/1986
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NRC - SAFETY/SAFEGUARDS REVIEW GROUP
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FOIA-86-432 NUDOCS 8606270361
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REVIEW OF SAFEGUARDS REGULATIONS & GUIDANCE Category I Nuclear Fuel Facilities--

Physical Security SAFEGUARDS INTEROFFICE REVIEW GROUP June 1986 8606270361 G60624 PDR FOIA AFTERGOG6-432 PDR

TABLE OF CONTENTS Page Foreword ........................................................ v Review of Safeguards Regulations and Guidance (Category I Nuclear Fuel Facilities--Physical Security) ............................. 1 Summary of Findings ........................................... 1 Background ........................... ............. .......... 1 Scope and Approach ............................................ 1 Regulatory Overview ........................................... 3 Findings Related to Category I Nuclear Fuel Facilities--

Physical Security ............................................. 4 I. Inconsistencies in NRC Safeguards Regulations ............... 4 Inconsistencies in Regulations Governing Licensee Audits .... 4 Outdated Terms and References in Regulations ................ 4 II. Inconsistencies in Regulatory Guides ....................... 5 III. Other Findings ............................................ 8 Minor Ambiguities in Inspection Procedures ................ 8 Minor Ambiguities in Miscellaneous Guidance ............... 8 References ...................................................... R-1 Bibliography .................................................... B-1 iii

FOREWORD

! The Safeguards Interoffice Review Group was formed at the direction of the NRC 4

l Executive Director for Operations, to review safeguards regulations and guidance.

! This was done to identify possible inconsistencies that could lead t'o misunder-

  • t standing and lack of coordination, within the staff, in administering safeguards i ,

requirements.

The Group currently has the following membership:

Robert A. Erickson, NMSS, Chairman i Paul Baker, NMSS

Loren L. Bush, IE ,

i j Francis X. Cameron, ELD 1 Stanley L. Dolins, NMSS J

Jane L. Gibson, NRR I

Gordon E. Gundersen, NMSS j Philip Ting, RES l

In preparing this report, the Group was assisted and advised by others, inclu-l ding: Nancy Ervin, IE; Richard Rosano, IE; Sandra Frattali, NMSS; and Ellen j Kraus, NMGS. The following served as Group contacts: Walter Schwink (ED0);

{ Richard P. Keimig (RI); Kenneth P. Barr (RII); James R. Creed (RIII); Richard L.

I Bangart (RIV); and James L. Montgomery (RV).

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REVIEW 0F SAFEGUARDS REGULATIONS AND GUIDANCE Category I Nuclear Fuel Facilities--Physical Security Summary of Findings Several inconsistencies were identified in NRC rules governing licensee audits.

A number of Regulatory Guides were found to be obsolescent. Finally, several minor ambiguities were noted in Inspection Procedures and miscellaneous 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 coor-dination and consistency in the NRC staff, concerning implementation of the rele-vant regulations (17 NRC 927 and 18 NRC 802, see Ref. 1). To preclude such prob-lems in the future, NRC's Executive Director for Operations (ED0) 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 laci, of coordination and consistency, as were manifested in the UCLA proceeding, exist or recur either in hearing-related

! or non-hearing-related activities." (See Ref. 2.)

NMSS organized the Safeguards Interoffice Review Group to address the concerns raised by the EDO. NRC's Regional offices and the ED0's office each designated persons to serve as points of contact for the Group.

Scope and Approach l

The EDO directive to review safeguards regulations and guidance was broad in scope. In order to make the review manageable, wnile being fully responsive to the directive, the Group agreed to approach its work as follows:

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1. The Group will concentrate on identifying inconsistencies in safeguards regulations and guidance, with the understanding that resolution of those ,

inconsistencies is a task for the staff at large.

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

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

Non power Reactors - Category I (report issued April 15, 1985, see Ref. 4)

Spent Fuel Transportation (report issued May 3, 1985, see Ref. 5)

Categories II and III - Special Nuclear Material Transportation (report issued July 31, 1985, see Ref. 6)

Category I - Special Nuclear Material Transportation (report issued October, 1985, see Ref. 7)

Fuel Facilities - Categories II and III, Physical Security, (report issued January, 1986, see Ref. 8) >

Fuel Facilities - Category I (Physical Security -- current report)

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

Fuel Facilities - Category III (Material Control and Accountability) .

Power Reactors Independent Spent Fuel Storage Installations ,

Fuel Fabrication / Conversion Facilities and Power Reactors under IAEA Safe-guards New Fuel Stored at Reactors

3. The Group will 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 activities, the Group will 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 the NRC regulations (in terms of the types of facilities or activities 2

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 Licensed nuclear facilities, activities and special nuclear material are regu-lated by the NRC under authority of the Atomic Energy Act of 1954, as amended, and the Energy Reorganization Act of 1974. Applicable NRC safeguards regula-tions are codified principally in 10 CFR Parts 50, 70, 73, and 74. Special nuclear material licensees establish safeguards programs in accordance with these regulations and supporting guidance documents. The principal regulations pertaining to physical protection of Category I nuclear fuel facilities are 10 CFR 73.45 and 73.46.

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FINDINGS RELATED TO CATEGORY I NUCLEAR FUEL FACILITIES (PHYSICAL SECURITY)

I. INCONSISTENCIES IN NRC SAFEGUARDS REGULATIONS Inconsistencies in Regulations Governing Licensee Audits 10 CFR 73.40, which contains general requirements for physical protection at all fixed sites, includes licensee audit requirements which appear to be inconsistent with those specified in 10 CFR 73.46 for Category I fuel facilities. For example, regarding contents of audits, 73.40(d) calls for "a test of the safeguards system along with commitments established for response by local law enforcement author-ities." In contrast, 73.46(g)(6) calls for " evaluation of the ef fectiveness of the physical protection system...and an audit of commitments established for response by local law enforcement authorities." 73.40(d) requires audit results, "along with recommendations fer improvements" to be documented, while 73.46(g)(6) requires audit results, "along with recommendations, corrections and improve-ments...." to be documented. Finally, 73.40(d) requires reports of these audits to be kept at the plant for inspection for a period of two years, while 73.46(g)(6) specifies a period of five years.

Outdated Terms and References in Regulations In a discussion of license applications covering Category I nuclear fuel faci-lities, 10 CFR 70.22(j) makes reference to " industrial sabotage, as defined in Part 73." However, that term is no longer used in Part 73, having been replaced by " radiological sabotage." An outdated cross-reference appears in 10 CFR 70.32(g),

which refers to 73.30(g) as one of the rules covering safeguards contingency plans, although 10 CFR Part 73 no longer contains section 73.30. -

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. j II. INCONSISTENCIES IN REGULATORY GUIDES In the course of reviewing NRC Regulatory Guides applicable to Category I nu-clear fuel facilities, the Group found numerous inconsistencies attributable to Regulatory Guide obsolescence. This was reflected in such things as outdated terminology and references to regulations which no longer exist. Specific examples of such findings are listed below.

Regulatory Guide 5.7, May, 1980 (" Entry / Exit Control For Protected Areas, Vital Areas, and Material Access Areas")

10 CFR 73.46(d), Access control subsystems and procedures, contains spec-ial provisions for persons having NRC or DOE access authorization. How-ever, Regulatory Guide 5.7 (see Ref. 9), NRC's current guidance on entry / exit controls, discusses only DOE authorizations and does not mention NRC access authorizations.

Regulatory Guide 5.12, November, 1973 (" General Use of Locks")

The introduction to Regulatory Guide 5.12 (see Ref. 10) refers to "indus-trial sabotage" rather than the current term " radiological sabotage."

Regulatory Guide 5.14, May, 1980 ("Use of Observation Techniques in Material Access Areas")

On page 3 of the Regulatory Guide (see Ref. 11), 73.46(e)(9) is incorrectly identified as one of several sections in Part 73 which gives " examples of specific visual surveillance techniques." On that same pege, in Section 6, Operating Procedures, the Regulatory Guide refers to " reporting procedures required by paragraphs 73.45(g) and 73.71(b) of 10 CFR Part 73." However, 73.45(g) deals solely with the response capability to be provided by a physical protection program and does not deal with " reporting procedures."

Regulatory Guide 5.15, January, 1974 (Security Seals)

In its introduction, Regulatory Guide 5.15 (see Ref. 12) refers to rules which no longer exist, such as 10 CFR 73.30(c) and 73.41(c).

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Regulatory Guide 5.17, January, 1974 (" Truck Identification Markings")

This Regulatory Guide (see Ref. 13) is obsolete. It concerns implementa-tion of a regulatory requirement which no longer exists (10 CFR 73.31(e)).

Regulatory Guide 5.20, January,1974 (" Training, Equipping and Qualifying of Guards and Watchmen")

The opening paragraph in Regulatory Guide 5.20 (see Ref. 14) contains references to subsections "73.30 through 73.36 of 10 CFR Part 73," which no longer exist. The Regulatory Guide contains references to " industrial sabotage." Discussions of " watchmen," and " watchmen on patrol," in sec-tions B and C of the Guide, are no longer consistent with NRC regulatory definitions in 10 CFR 73.2. Finally, the arms qualification program out-lined in Appendix C of the Regulatory Guide differs considerably from that of 10 CFR Part 73, Appendix B, which is NRC's current regulation covering weapons training and qualification, among other things, for security personnel.

Regulatory Guide 5.30, June,1974 (" Materials Protection Contingency Measures for Uranium and Plutonium Fuel Manufacturing Plants")

Regulatory Guide 5.30 (see Ref.15) is obsolete in its entirety and should be withdrawn. It refers to regulations which no longer exist, employs outdated terminology, and describes methods which are no longer acceptable to the NRC staff for implementing safeguards regulations.

The most current guidance on this subject is contained in Regulatory Guide 5.55 (see Ref. 16) issued for comment in March 1978. Althought not officially reissued as a " final" document, Regulatory Guide 5.55 is currently used by licensees and the NRC staff.

Regulatory Guide 5.43, January, 1975 (" Plant Security Force Duties")

1 In discussing security audits on page 2, Regulatory Guide 5.43 (see l Ref. 17) suggests that a " member" of the plant security organization should 6

be responsible and " report directly to the upper management individual 4 who has overall security responsibility." This may be inconsistent with

) 10 CFR 73.46(g)(6) which requires such reviews and audits to be performed l

by " individuals independent of both security management and security super-vision." Discussions on page 2 and page 4 of this Regulatory Guide con-cerning use of deadly force by security personnel, pre-date NRC's current rule in 10 CFR 73.46(h)(5) covering this subject.

Regulatory Guide 5.52. July,1980 (" Standard Format and Content of a Licensee Physical Protection Plan for SSNM at Fixed Sites")

A note on the cover of Regulatory Guide 5.52 indicates that transportation material has been removed from the Regulatory Guide (see Ref.18) and is now found in Regulatory Guide 5.60 (see Ref. 19), which covers protection plans for SSNM in transit. Nevertheless, the introduction to Regulatory Guide 5.52 contains a reference to 10 CFR 70.22(g), which deals with trans-portation plans.

There appears to be a contradictian in Regulatory Guide 5.52 (see Ref. 18) regarding treatment of sealed packages. A note at the foot of page 83 states "all sealed packages, except packages sealed with authorized tamper-indication seals, are opened prior to entry into the MAA." (Emphasis added.) However, footnotes on pages 84 and 85 both state "all sealed packages are opened prior to entry into the MAA." (Emphasis added.)

Regulatory Guide 5.57, June, 1980 (" Shipping and Receiving Control of SSNM")

10 CFR 73.71 requires each licensee to notify the NRC Operations Center promptly of any incident in which an attempt has been made, or is believed  !

to have been made, to commit a theft or unlawful diversion of special nuc-lear material. However, in discussing shipping and receiving of SSNM, Regulatory Guide 5.57 (see Ref. 20) states that if the contents of any con- )

, tainer appear to have been removed, the Director of the NRC Inspection and Enforcement (IE) Regional Office should be notified immediately in accor-

-dance with 73.71.

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III. OTHER FINDINGS Minor Ambiguities in Inspection Procedures Almost all the NRC Inspection Procedures applicable to Category I nuclear fuel facilities were issued in 1984 and are therefore generally consistent with cur-rent NRC regulations and guidance. One minor inconsistency which the Group noted appeared in Inspection Procedure 81601 (See Ref. 21), Section 02, which contains references to nonexistent regulations (70.32(g)(2)(i) and (73.30)).

Another possible inconsistency appears in Inspection Procedure 81046 (see Ref. 22), Section 03.02, C, which states "The licensee must change or rotate keys, locks, key codes, and combinations at least once every 12 moaths."

This position is consistent with guidance affecting power reactors. It is also consistent with 10 CFR 95.25, concerning protection of classified information, which requires lock combinations to be changed "at least once every year." However, Regulatory Guide 5.12 (see Ref.10), which deals with protection of facilities and special nuclear material, recommends such action "at least twice every year" (page 5.12-4, Section C.8).

Minor Ambiguities in Miscellaneous Guidance Following publication of NRC's final Upgrade Rule in 1979 (44 FR 68184, see Ref. 23) the Division of Safeguards formed a " Licensee Safeguards Guidance Group" which prepared a series of 38 guidance " bulletins" which were issued by the Division Director. Generally, these bulletins accurately reflect NRC rules and guidance. However, guidance in Bulletin Number 3

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(see Ref. 24) appears to be inconsistent with 10 CFR 73.46(d)(4) which l requires that the individual responsible for the last access control func-tion (controlling admission to the protected area) shall be isolated within a structure, with bullet-resisting walls, doors, ceiling, floor, and windows.

In this regard, the guidance bulletin states that the occasional authorized l use of railroad track and truck entry points without special bullet-resistant enclosures is permitted. Another ambiguity was found in Bulletin Number 30 (see Ref. 25) which referenced nonexistent 10 CFR 73.45(c)(2).

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l REFERENCES (Category I Nuclear Fuel Facilities--Physical Security)

Cited in Text

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 l license). The Regents of University of California (UCLA Research Reactor) l 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, OIA Investigation, "ASLB--Allegations concerning three NRC Employees" (dated June 12, 1984), July 3, 1984.
3. U.S. Nuclear Regulatory Commission, Safeguards Interoffice Review Group,

" Review of Safeguards Regulations and Guidance (Categories II and III Non-Power Reactors)," January 31, 1985.

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

" Review of Safeguards Regulations and Guidance (Category I Non power Re-actors)," April 15, 1985.

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

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

May 3, 1985.

6. U.S. Nuclear Regulatory Comission, Safeguards Interoffice Review Group,

" Review of Safeguards Regulations and Guidance (Transportation of Cate-gories II and III special Nuclear Material)," July 31, 1985.

7. U.S. Nuclear Regulatory Comission, Safeguards Interoffice Review Group,

" Review of Safeguards, Regulations and Guidance (Transportation of Cate-gory I Special Nuclear Material)," October 1985.

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References, Cont.

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

" Review of Safeguards Regulations and Guidance (Categories II and III Nuclear Fuel Facilities -- Physical Security)," January 1986.

9. U.S. Nuclear Regulatory Commission, Regulatory Guide 5.7, " Entry / Exit Con-trol for Protected Areas, Vital Areas, and Material Access Areas," May 1980. ,
10. U.S. Nuclear Regulatory Commission, Regulatory Guide 5.12, " General Use of Locks in the Protection and Control of Facilities and Special Nuclear Material," November 1973.
11. U.S. Nuclear Regulato.'y Commission, Regulatory Guide 5.14, "Use of Obser-vation Techniques in Material Access Areas," May 1980.
12. U.S. Nuclear Regulatory Commission, Regulatory Guide 5.15, " Security Seals,"

January 1974.

13. U.S. Nuclear Regulatory Commission, Regulatory Guide 5.17, " Truck Identifi-4 cation Markings," January 1974.
14. U.S. Nuclear Regulatory Commission, Regulatory Guide 5.20, " Training, Equip-ping, and Qualifying of Guards and Watchmen," January 1974.
15. U.S. Nuclear Regulatory Commission, Regulatory Guide 5.30, " Materials Pro-tection Contingency Measure for Uranium and Plutonium Fuel Manufacturing Plants," June 1974.
16. U.S. Nuclear Regulatory Commission, Regulatory Guide 5.55, " Standard q Format and Content of Safeguards Contingency Plans for Fuel Cycle j Facilities," March 1978 (for comment).

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17. U.S. Nuclear Regulatory Commission, Regulatory Guide 5.43, " Plant Security Force Duties," January 1975.

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References, Cont.

18. U.S. Nuclear Regulatory Commission, Regulatory Guide 5.52, " Standard Format and Coc;ent of a Licensee Physical Protection Plan for SSNM at Fixed Sites,"

July 1380.

19. U.S. Nuclear Regulatory Commission, Regulatory Guide 5.60, " Standard Format and Content of a Licensee Physical Protection Plan for Strategic Special Nuclear Material in Transit," April 1980.
20. U.S. Nuclear Regulatory Commission, Regulatory Guide 5.57, " Shipping and Receiving Control of Strategic Special Nuclear Material," June 1980.
21. U. S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Inspection Procedure 81601, " Safeguards Contingency Plan Implementation Review," May 9, 1984.
22. U.S. Nuclear Regulatory Commission, Office of Inspectio1 and Enforcement, Inspection Procedure 81046, " Locks, Keys, and Combinations," May 9, 1984.
23. U.S. Nuclear Regulatory Commission, " Fixed Site Physical Protection Upgrade Rule," Federal Register, Vol. 44, 1979, 68184.
24. U.S. Nuclear Regulatory Commission, Division of Safeguards, Licensee Safe-guards Guidance Group, Bulletin No. 3, August 7, 1980.

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25. U.S. Nuclear Regulatory Commission, Division of Safeguards, Licensee Safeguards Guidance Group, Bulletin No. 30, November 20, 1980.

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BIBLIOGRhPHY (Category I Nuclear Fuel Facilities -- Physical Security)

Code of Federal Regulations

1. Code of Federal Regulations, Title 10, Chapter 1 10 CFR Part 11 - Criteria and Prcedures for Determining Eligibility for Access i to or Control over Special Nuclear Material 10 CFR Part 50 - Domestic Licensing--Utilization Facilities 50.34 - Contents of Applications: Technical Information (c), (d),

and (e) 10 CFR Part 70 - Domestic Licensing--Special Nuclear Material 70.22(g) - Plan for physical protection of SNM in transit, and licensee safeguards contingency plan or response procedures 70.22 - Contents of Applications (h)(j) and (1) 70.32 - Conditions of Licenses (e) and (g) 10 CFR Part 73 - Physical Protection of Plants and Material 73.2 - Definitions 73.20 - General Performance Objective and Requirements 73.21 - Requirements for the protection of safeguards information 73.40 - Physical Protection: General Requirements at fixed sites 73.40(d) - Safeguards contingency plan, implementation, revision, maintenance 73.45 - Performance capabilities for fixed site physical protection systems 73.45(g) - Response 73.46 - Fixed site physical protection systems, subsystems, com-ponents, and procedures 73.46(d) - Access control subsystems and procedures l

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Bibliography, Cont 73.46(d)(4) - Access control subsystem and procedures--control of pro-tected area 73.46(e)(9) - Detection, surveillance, and alarm subsystems and proce-dures--material access areas observation methods 73.46(g)(6) - Test and maintenance programs--security program review 73.46(h)(5) - Contingency and response plans, procedures--sufficient force 73.70 - Records 73.71 - Reports of unaccounted-for shipments, suspected thefts, unlawful diversion, radiological sabotage, or events which significantly threaten or lessen the effectiveness of safeguards (b)(c) 73.72 - Requirement for advance notice of shipment of special nu-clear material Part 73 Appendix B - General Criteria for Security Personnel Part 73 Appendix C - Licensee Safeguards contingency plans 10 CFR Part 74 - Nuclear Material Control and Accounting for Special Nuclear Material of Low Strategic Significance 10 CFR Part 95 - Security Facility Approval and Safeguarding of National Security Information and Restricted Data

2. Regulatory Guides U.S. Nuclear Regulatory Commission, Regulatory Guide 5.10, " Selection and Use of Pressure-Sensitive Seals on Containers for Outside Storage of Special Nuclear Material," July 1973. .
3. Inspection Procedures U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Inspection Procedure 81810, " Physical Protection of Safeguards Information,"

= October 1, 1982.

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Bibliography, Cont U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Inspection Procedure 81815, " Authorization for Access to National Security Information (NSI) and Restricted Data (RD)," October 1, 1982.

U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Inspection Procedure 81820, " Physical Protection Facility Approval for NSI and RD," October 1, 1982.

U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Inspection Procedure 81821, " Safeguarding NSI and RD; Storage and Use,"

October 1, 1982.

U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Inspection Procedure 81020, " Management Effectiveness -- Security Program,"

May 9, 1984.

U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Inspection Procedure 81018, " Security Plan and Implementing Procedures,"

May 9, 1984.

U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Inspection Procedure 81022, " Security Organization," May 9, 1984.

U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Inspection Procedure 81034, " Security Program Audit," May 9, 1984.

l U.S. Nuclear Regulatory Commission, Office of Inspection ard Enforcement, Inspection Procedure 81038, "Facords and Reports," May 9, 1984.

U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Inspection Procedure 81042, " Testing and Maintenance," May 9, 1984.

U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Inspection Procedure 81052, " Physical Barriers - Protected Areas," May 9, 1984.

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Bibliography, Cont U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Inspection Procedure 81054, " Physical Barriers - Vital Areas, Material Access Areas, and Controlled Access Areas," May 9, 1984.

U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Inspection Procedure 81058, " Security System Power Supply," May 9, 1984.

U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Inspection Procedure 81062, " Lighting," May 9, 1984.

U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Inspection Procedure 81064, " Compensatory Measures," May 9, 1984.

U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Inspection Procedure 81066, " Assessment Aids," May 9, 1984.

U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Inspection Procedure 81070, " Access Control - Personnel," May 9, 1984.

U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Inspection Procedure 81073, " Access Control (Fuel Facility) - Packages, Material, and SSNM," May 9, 1984.

U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Inspection Procedure 81074, " Access Control - Vehicles," May 9, 1984.

U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Inspection Procedure 81078, " Detection Aids - Protected Areas," May 9,1984. '

U.S. Nuclear Regulatory Connission, Office of Inspection and Enforcement, Inspection Procedure 81080, "VA, MAA, and CAA," May 9, 1984.

U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Inspection Procedure 81084, " Alarm Stations," May 9,1984.

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Bibliography, Cont U.S. Nuclear Re-gulatory Commission, Office of Inspection and Enforcement, Inspection Procedura 81088, " Communications," May 9, 1984.

U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Inspection Procedure 81501, " Personnel Training and Qualifications -

General Requirements," May 9, 1984.

U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Chapter 2610, " Resident Inspection Program at NFS Plant, Erwin, Tenn.,"

January 9, 1986.

U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Sixteen NFS Resident Inspection Procedures, all dated January 9,1986.

4. Licensee Safeguards Guidance Group Bulletins U.S. Nuclear Regulatory Commission, Office of Nuclear Material Safeguards and Safety, Division of Safeguards, 38 Licensee Safeguards Guidance group bulletins, 1980.

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