ML20237F249

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Rev 3 to Security Plan, for Framatome Cogema Fuels
ML20237F249
Person / Time
Site: 07001201
Issue date: 06/30/1998
From: Maria Moore
FRAMATOME COGEMA FUELS (FORMERLY B&W FUEL CO.)
To:
Shared Package
ML20237F244 List:
References
PROC-980630, NUDOCS 9809020150
Download: ML20237F249 (16)


Text

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Cmiment flevision/ Approval Record 1

Document Revision / Approval Record

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Reason for Action o Initial Release a Revision Current Revision

/ Procedure a Deactivation New Revision D Annual Review Record of Revisions wse this space for Coments for Annual Review and Deactivation)

%e FCF Secuerry Pt#J HAS 86fd REVISED TO REFLCc r THC Gu.orJyJ& l s.

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Prepared by Date (p.go.gg Independent Review Date P4. HOORE Review and Approval Signatures k

6-3o-99 Manager. Safety & Licensing

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9009020150 900630 PDR ADOCK 07001201 C

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FRAMATOME COGEMA FUELS, LYNCHBURG MANUFACTURING FACILITY USNRC LICENSE SNM-1168, DOCKET 70-1201 SECURITY PLAN 1

i TABLE OF CONTENTS Definitions / Acronyms 1

1.0 Site and Facility i

1.1 Location 1.2 Control led Access Area 1.2.1 Lynchburg Manufacturing Facility Site Description 1.2.2 Material Usage j

1.2.3 Material Storage I

2.0 Detection Devices and Procedigas 2.1 Entrance To Controlled Access Areas 2.2 Normal Working Day i

2.3 Off-Hours 2.4 Security Force 3.0 Security Resoonse j

3.1 Security Organization 3.2 Security Force 4.0 Resoonse Procedures 4.1 Response Action and Capabilities 5.0 Material Transportation Requirements. Shioner l

5.1 Notification of Receiver 5.2 Receiver's Information 5.3 Tampersafing 5.4 Shipment Inspection 5.5 In-Transit Physical Protection 6.0 Material Transportation Requirements. Receiver 6.1 Receipt inspection 6.2 Shipper Notification 6.3 In-Transit Physical Protection i

Page 1 of 15 DATE: 6-10-98 REV.3 l

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FRAMATOME COGEMA FUELS, LYNCHBURG MANUFACTURING FACILITY USNRC LICENSE SNM-1168, DOCKET 70-1201 SECURITY PLAN l

l 7.0 In-Transit Physical Protection Requirement

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7.1 Notification Criteria 7.2 Response to Notification 8.0 Exoort Requirements 9.0 Imoort Requirements I

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FRAMATOME COGEMA FUELS, LYNCHBURG MANUFACTURING FACILliY USNRC LICENSE SNM-1168, DOCKET 70-1201 SECURITY PLAN -

DEFINITIONS Controlled Access Area A temporarily or permanently established, clearly demarcated area, with specified and restricted access points.

Framatome Cogema Fuels A company of which the Lynchburg Manufacturing Facility is a part.

Lynchburg Manufacturing Facility Framatome Cogema Fuels manufacturing plant for nuclear fuel.

Local Law Enforcement Agencies The law enforcement agencies of the Lynchburg Police Department, the Campbell County Sheriffs Office, and the Virginia State Police.

Low Enriched Uranium Uranium enriched above natural but less than 10% in the U-235 isotope.

Special Nuclear Materials As defined in 10 CFR 70.4.

Clock Key Stations Electronic means to document areas observed by Security.

Acronyms CAA Controlled Access Area j

FCF Framatome Cogema Fuels LMF Lynchburg Manufacturing Facility LEU Low Enriched Uranium LLEA Local Law Enforcement Agency l

SNM Special Nuclear Material I

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FRAMATOME COGEMA FUELS, LYNCHBURG MANUFACTURING FACILITY USNRC LICENSE SNM-1168, DOCKET 70-1201 o

l SECURITY PLAN 1.0 Site and Facility Description 1.1 Location The Lynchburg Manufacturing Facility (LMF)is part of Framatome Cogema Fuels and is located in Campbell County, Virginia, along Route 726. The total site consists of approximately 76 acres of Framatome Cogema Fuels property.

1.2 Controlled Access Area (CAA)

The LMF is encompassed by a fence (See Figure 1) which constitutes the physical barrier for the CAA. The fence is constructed of No. 9 W&M gauge copper-bearing steel wire fencing fabric (chain link) topped by 3 strands of barbed wire angled outward. The area within the fence is approximately 17 acres.

Several structures exist within the CAA. Ingress and egress via the gates is controlled and a minimum of two (2) security officers are on site continuously to assure only authorized personnel and vehicles enter the CAA. Vehicles are permitted within the CAA only for special purposes when approved and under escort by a security officer. Visual searches of vehicles leaving the CAA will be conducted by a security officer prior to exit, unless continuously monitored by security during the access period.

There are 9 gates along the perimeter fence (See Figure 1).

Personnel access to the CAA is obtained through a personnel gate located between Gate 1 and the security post. The personnel gate is electronically operated and entry is controlled from inside the security house. Commercial vehicle entrance is accomplished through the gate located adjacent to the security house (Gate 1).

Gate 1 is electronically operated from within the FCF security house and will remain closed at all times other than admittance of i

approved vehicles and in the event of a plant evacuation. Gates 3, 7, and 8 are bolt locked from inside the CAA. There are security seals on these gates. The seal would need to be broken to open the gate. There is no key lock on those gates because of their use for emergency evacuations of the CAA. The other Gates,4,5,6, and 9 on the perimeter are used by Framatome employees whi;e conducting their normal work functions, but remain closed and locked except when attended or in use. The personnel authorized to use these gates are responsible for their control while using the gate. These functions include but are not limited to environmental sampling and service meter recording.

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FRAMATOME COGEMA FUELS, LYNCHBURG MANUFACTURING FACILITY USNRC LICENSE SNM-1168, DOCKET 70-1201 SECURITY PLAN All personnel within th' CAA must wear an access badge denoting e

if they are Framatome personnel or visitors requiring an escort except when the efficient handling of emergencies precludes this.

Escorts are only required in the manufacturing area of the plant.

The badging system is under the direction of the Manager, Safety and Licensing.

- The gates are locked with padlocks when not in use. The locks and keys for them are under the control of personnel authorized by the Manager, LMF Facilities.

An exception to gate usage describad above may occur when there is an emergency situation at any of BWX's neighboring facilities and their normal access road is blocked. In these cases, evacuation and/or emergency vehicle traffic to or from BWX may occur through perimeter Gates 5 and 1. Watchmen will be located along the evacuat.or, oath to observe evacuation activity and to assure that all traffic flows directly through the LMF without unnecessary stopping, in a manner consistent with safe handling of emergencies.

1.2.2 License SNM-1168 limits enrichment level of SNM at the LMF to <

5.1% (Category lli). Usage of material consists primarily of fabricating fuel bundles. This primary usage of material at the LMF occurs w: thin the main building within the CAA.

1.2.3 Material at the LMF is stored at various locations within the main building. The following material may be stored outside of the building, but within the CAA.

1.2.3.1 Fuel assemblies in tampersafed shipping containers are stored outside. The size and weight, about 7200 lbs., of these shipping containers precludes an undetected removal of them.

1.2.3.2 Low-level waste may be stored outside the building. This waste consists of but is not limited to; LSA, oily rags, filter media, and contaminated oil. The nature of the material significantly lessens its desirability for theft..

1.2.3.3 UFe may be stored in UFe ylinders which shall be c

located in designated UFs torage areas. The size and s

weight of the cylinders predudes an undetected removal

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of them.

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FRAMATOME COGEMA FUELS, LYNCHBURG MANUFACTURING FACILITY j

USNRC LICENSE SNM-1168, DOCKET 70-1201 l

SECURITY PLAN i

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2.0 Detection Devices and Procedures 2.1 The controlled access area (CAA) is contained by a perimeter i

fence. Entrance by non-Framatome employees is restricted. Two

. (2) security officers are on site 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. The other points of

. ingress and egress are restricted to Framatome authorized personnel as noted in Section 1.2.1. Unauthorized personnel in the CAA are reported to the security officer for response.

2.2 During the course of the normal working day, employee activity within the CAA provides positive means to mitigate material theft by an extemal adversary. This is accomplished via the badging system in use at the LMF. Unauthorized activities involving SNM can be easily detected by Framatome employees. Personal vehicles are not permitted within the CAA without authorization by management and will be under escort by a security officer.

Commercial vehicles will be escorted by designated LMF employees or a security officer except as specifically authorized by.

the Manager, LMF Facilities or designated altemate.

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1 2.3 During off hours, holidays and weekends, a security officer tours the CAA to detect unauthorized activity. Tours will be conducted per each of the three 8-hour shifts starting and ending at 0800.

Tours will ba made at random times.

During these rounds, appropriate locks of the structure within the CAA are checked for compromise. Clock Key Stations are set up within the CAA to document that the tour is made within the CAA as required.

2.4 The security force may be contracted from a private security service company or Framatome. These officers may be trained by outside organizations. Detailed instructions specific to the site will be provided from the Manager of LMF Facilities or the LMF security officer.

l The LMF Security Operating Manual describes security measures in detail, includ!r.g visitor admittance, vehicle admittance, sign-in/ sign-out guidelines, etc. A Security Procedure Outline delir.eates l

the areas of the LMF Security Operating Manual which m subject

. to NRC inspection for compliance with 10 CFR 73.67. The Security l

Procedure Outline highlights those areas described in this plan and areas required by Part 73 that have been incorporated into the LMF l

Security Operating Manual.

I Page 6 of 15 DATE: 6-10-98 REV.3 l

FRAMATOME COGEMA FUELS, LYNCHBURG MANUFACTURING FACILITY USNRC LICENSE SNM-1168, DOCKET 70-1201 SECURITY PLAN 3.0 Security Resoonse 3.1 The security of LMF is the responsibility of the Manager, LMF Facilities. Officers at the LMF are provideu either by a private

- security service company or employed by Framatome. While on duty, those officers are responsible to the Manager, LMF Faci'ities.

3.2 While only two officers are normally stationed at the LMF, additional personnel can be called upon as needed.

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FRAMATOME COGEMA FUELS, LYNCHBURG MANUFACTURING FACILITY USNRC LICENSE SNM-1168, DOCKET 70-1201 SECURITY PLAN.

4.0

' Resoonse Procedures The Emergency Procedure defines the security officer's roles and responsibilities for civil disturbances, bomb threats and other site emergencies. The LMF security operating manual provides guidelines defining security's role concerning theft of company property. The NRC Regional Office will be notified by the Manager, Safety & Licensing of any apparent theft of SNM.

Local law enforcement agencies will be contacted to provide backup assistance for the security force if it is needed at LMF.

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FRAMATOME COGEMA FUELS, LYNCHBURG MANUFACTURING FACILITY USNRC LICENSE SNM-1168, DOCKET 70-1201 SECURITY PLAN l

5.0 Material Transportation Requirements. Shicoer

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The provisions of this chapter apply to only those shipments of 10 kg U-1 235 or more; shipments under 10 kgs U-235 are exempt from these i

requirements.

j 5.1 Prior to shipment of SNM, LMF will provide to the receiver the following:

1.

Mode of transportation 2.

Estimated time of arrival 3.

Location where receiver takes responsibility for physical protection.

4.

Name of carrier 5.

Name and/or number of transport.

5.2 The shipper will confirm that the receiver has a license to handle i

the material being shipped, and will be ready to accept the shipment as planned.

5.3 As a minimum, the outermost container bearing SNM will be sealed. A Type E button seal will be used for this purpose. The intent of seal usage is to enable the receiver to immediately verify the integrity of the shipment upon receipt.

5.4 Shipments will be inspected prior to release from the LMF to assure that the seals that were applied were not compromised in any way.

5.5 The responsibility for in-transit physical protection will be designated on a case by case basis to either the shipper or receiver.

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FRAMATOME COGEMA FUELS, LYNCHBURG MANUFACTURING FACILITY USNRC LICENSE SNM-1168, DOCKET 70-1201 SECURITY PLAN l

6.0 Material Transportation Reautrements. Receiver The provisions of this chapter apply to only those receipts of 10 kgs U-235 or more; shipments under 10 kgs U-235 are exempted from these requirements.

6.1 Upon receipt of a shipment, the LMF will inspect all tramperseals To check the integrity of the shipment. If a seal has been compromised, the appropriate in-plant investigation will be undertaken.

6.1.1 Fuel assemblies identification number will be verified. If -

Problems arise, the shipper will be notified and appropriate investigative action will be undertaken.

6.1.2 Other containers of SNM will be gross weighed to verify shipper's gross weight. Upon discovery of large gross weight discrepancies, the shipper will be notified and appropriate investigative action will be undertaken.

6.2 Upon receipt of material, the receiver will notify the shipper that the material has been received in accordance with 10 CFR 70.54 or as otherwise authorized in specific conditions of license.

6 6.3 The responsibility for in-transit physical protection will be designated on a case by case basis.

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FRAMATOME COGEMA FUELS, LYNCHBURG MANUFACTURING FACILITY USNRC LICENSE SNM-1168, DOCKET 70-1201 l

SECURITY PLAN i

7.0 In-Transit Physical Protection Requirements 7.1 For shipments which Framatome Cogema Fuels has accepted physical protection requirements, the carrier shall be instructed to notify.the LMF immediately if any of the following events occurs:

i a.

Transport vehicle accident.

b.

Unexpected delays affecting a reasonable estimated time of

arrival, c.

Theft or attempted theft of SNM.

7.2 Upon notification of any of the above events, the LMF shall initiate the following response measures:

a.

Transoort vehicle accident affecting cargo 1.

Notify NRC.

2.

Assure that the regional law enforcement agencies are cognizant of the accident, material being carried, and that necessary protection steps have been initiated.

3.

Make any necessary arrangements to correct problems.

i 4.

Notify shipper or receiver.

1 b.

Unexoected delav i

1.

Assure shipper and receiver are cognizant of the delay.

2.

Establish if the reason for the delay constitutes a threat to the security of the Special Nuclear Material.

a.

If no perceived threat exists, establish new estimated time of arrival and assure receiver is notified ofit, b.

If a threat is perceived '.o exist, request additional protection via local law enforcement agencies, and notify the NRC.

c.

Theft or attemoted theft of SNM 1.

Assure local law enforcement in the vicinity of the I-incident is notified.

' 2.

Notify the NRC of ir.cident and actions being taken.

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FRAMATOME COGEMA FUELS, LYNCHBURG MANUFACTURING FACILITY USNRC LICENSE SNM-1168, DOCKET 70-1201 SECURITY PLAN 3.

Provide support as appropriate to aid in correcting situation.

4.

Notify shipper / receiver.

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FRAMATOME COGEMA FUELS, LYNCHBURG MANUFACTURING FACILITY USNRC LICENSE SNM-1168, DOCKET 70-1201 SECURITY PLAN 8.0 Exoort Requirements I

For the export of SNM, the criteria established in Chapter 5.0 and 7.0 will be adhered to until such time that the receiver accepts physical protection responsibility for the shipment.

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FRAMATOME COGEMA FUEL S, LYNCHBURG MANUFACTURING FACILITY USNRC LICENSE SNM-1168, DOCKET 70-1201 SECURITY PLAN 9.0 Imoort Requirements 1

9.1 When the responsibility for the physical protection of the SNM shipment is assumed, the criteria established in Chapter 6.0 and 7.0 will be followed.

9.2 Shipper will be notified of receipt in accord with the provisions of the import license.

Pege 14 of 15 DATE: 6-10-98 REV. 3

FRAMATOME COGEMA FUELS, LYNCHBURG MANUFACTURING FACILITY USNRC LICENSE SNM-1168, DOCKET 70-1201 SECURITY PLAN l

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