ML20297A453

National Organization for Test, Research and Training Reactors 2020 Annual Conference Presentations Made by NRC Staff, Security

ML20297A453
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Issue date:	09/30/2020
From:	Beth Reed NRC/NRR/DANU/UNPL
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ML20297A599	List: ML20297A453 ML20297A470 ML20297A486 ML20297A531 ML20297A595
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Security September 30, 2020 Beth Reed Security Specialist Office of Nuclear Reactor Regulation U.S Nuclear Regulatory Commission 1

Scope

• Access authorization program

- Recent issue

- Elements of a good program

• Security regulations in part 37 and 73 comparison

- What is the difference

- Any exemptions?

• Material control and accounting

- Address a few specific questions from TRTR 2

Access Authorization

• Who can go where and how?

• Who can deem an individual trustworthy and reliable

• Who can give approval for access?

• What should be documented and how long are records retained?

3

Recent Issues

• Physical security plans arent updated to include compensatory measure (CM) commitments nor newer regulations (73.57)

• Reviewing official (RO) retires, or leaves, thus leaving no RO

• Personnel assuming RO responsibilities without being approved by the NRC

• Reason for approval, or denials, not documented in detail 4

NRC-approved Reviewing Official (RO)

• The only person(s) that determines trustworthiness and reliability (T&R)

• Must document how the T&R determination was made

• Responsible for establishing and maintaining records

• Responsible for protecting the personal information collected 5

Who is Granted Unescorted Access?

• Individuals with a need for access

• Access is granted only after the individual is deemed to be T&R based on:

- FBI fingerprint-based criminal history records check

- Favorable background check

• Using elements from security plan or Compensatory Measures Implementation Plan 6

Who Grants Access?

• Could be the RO, or could be the manager/director of the reactor, depending on specifics in security plan

- Sometimes this is the same person

• NOTE - access cannot be granted until after the RO determines T&R

• The T&R decision must be documented - whether access is granted or not, and if access authorization changes 7

Elements of a Good Program

• Specific procedures for the conduct of fingerprinting and collecting background information must be consistent with CM and security plan

• A procedure for correction or completion of criminal record information

• A procedure for protection of information

• A procedure for official review 8

Common Questions

• Can the same fingerprints I sent in for individual access be used to become a RO?

- Answer is No, unless there is a very short period of time between requests

• If Im an RO at one facility, and move to another facility, do I have to resubmit fingerprints?

- Answer is Yes 9

NRC Process

• Determines T&R based on current criminal history

• Passes applicants fingerprints to FBI

- Fingerprints received from licensee along with nomination letter

• Reviews results to determine T&R

• Issues approval letter 10

Where to Send the Information

• Send written requests to:

U.S. Nuclear Regulatory Commission Director, Division of Physical and Cyber Security Policy Attn: Criminal History Program/Mail Stop - T-07D04M 11545 Rockville Pike Rockville, MD 20852

• For more details refer to 10 CFR 73.57(d)

• Information regarding payment and current fees can be found at:

http://www.nrc.gov/site-help/e-submittals.html 11

Key Things to Remember

• Only the NRC-approved reviewing official can grant access to the facility, or access to SGI

- If you are an RO, be sure to nominate someone else before you leave your facility

- Recommended to have at least two ROs at each facility

• Document every decision, keep for 3 years after access is terminated 12

Part 37 Confusion and Questions 13

Whats the Difference?

• Part 37

• Part 73

• Category 1 and 2

• Category I, II, and III Radioactive Material Special Nuclear Material 14

Radioactive Material Radioactive Material Category 1 Category 1 Category 2 Category 2 (TBq) (Ci) (TBq) (Ci)

Americium-241 60 1,620 0.6 16.2 Americium-241/Be 60 1,620 0.6 16.2 Californium-252 20 540 0.2 5.40 Cobalt-60 30 810 0.3 8.10 Curium-244 50 1,350 0.5 13.5 Cesium-137 100 2,700 1 27.0 Gadolinium-153 1,000 27,000 10 270 Iridium-192 80 2,160 0.8 21.6 Plutonium-238 60 1,620 0.6 16.2 Plutonium-239/Be 60 1,620 0.6 16.2 Promethium-147 40,000 1,080,000 400 10,800 Radium-226 40 1,080 0.4 10.8 Selenium-75 200 5,400 2 54.0 Strontium-90 1,000 27,000 10 270 Thulium-170 20,000 540,000 200 5,400 Ytterbium-169 300 8,100 3 81.0 15

SNM Categories MODERATE STRATEGIC LOW STRATEGIC a

MATERIAL ENRICHMENT SIGNIFICANCE SIGNIFICANCE

1. Plutonium Less than 2,000 g but more 500 g or less but more than than 500 g 15 g

2. Uranium-235 20% or more in U-235 Less than 5,000 g but more 1,000 g or less but more isotope than 1,000 g than 15 g 10% or more but less 10,000 g or more Less than 10,000 g but than 20% in U-235 more than 1,000 g isotope Above natural but less -- 10,000 g or more than 10%

3. Uranium-233 -- Less than 2,000 g but more 500 g or less but more than than 500 g 15 g

4. Uranium-235, U-235 portion enriched Less than 5,000 g 1,000 g or less according to uranium-233, to 20% or more. according to the formula: the formula: grams =

and plutonium grams = (grams contained (grams contained U-235) +

in combination U-235) + 2.5 (grams 2.0 (grams U-233 + grams U-233 + grams plutonium) plutonium) but more than but more than 1,000 g 15 g according to the according to the formula: formula: grams = grams, grams = (grams U-235) + contained U-235 + grams 2.0 (grams U-233 + grams U-233 + grams plutonium.

plutonium) 16

Part 37 Differences

• Access Authorization

- Investigations and reinvestigation (10 years)

- More background check elements (37.25)

• Verification of identity, employment history (7 years), education history, character and reputation

- Grandfathering 37.25(b)(2)

• Individuals that have been determined T&R under part 73, or SGI orders, do not require an investigation, but must document

- Access Authorization Program Review 17

Some Differences

• Access Authorization Program

- Reviewing Official vs. NRC-Approved Reviewing Official

• Areas of use or storage

- Security Zones vs. Controlled Access Area

• Monitoring and Detection

- Immediate detection of entry vs. Timely detection of removal 18

Part 37 Nuggets

• Having a part 73 security plan does not exempt a licensee from having to meet part 37 requirements (37.11(b))

- Either develop a separate plan or include part 37 requirements in the part 73 security plan

• Radioactive waste weighing less than 4,409 lbs is not exempt (37.11(c))

• Activated components are not exempt from part 37

- A turn table that contains more than 8.10 Ci must be protected under part 37 19

More Nuggets

• No SGI or SGI-M, but similar protection and access requirements 37.43(d)

• Two NUREGs that are on the public website:

- NUREG-2155 Implementation Guide Rev 1, (Rev 2 is DRAFT)

- NUREG-2166 Best Practices, walks a licensee through the process of developing a security plan 20

Material Control and Accounting 21

What Guidance to Use?

• NUREG/BR-0006 and NUREG/BR-0007

- Provides step-by-step instructions in filling out DOE/NRC forms 740M, 741, 742, 742C

• DOE NMMSS users guide 2.1

- provides the same/similar step-by-step instructions

- NRC inspectors dont review compliance with DOE Users Guide 2.1 22

Updated NUREG/BR-0006 and 0007

• No new requirements were placed on licensees

• All edits to these NUREGs were made to improve, clarify and enhance the existing instructions for reporting to NMMSS 23

Submitting reports to NMMSS

• NUREG/BR-0006, Revision 9

• Section 1.4, Methods for Preparing and Submitting Data to the Nuclear Materials Management and Safeguards System

• NUREG/BR-0007, Revision 8

• Section 1.3, Preparation and Submission of DOE/NRC Forms 742 and 742C in Computer-Readable Format 24

Reporting Requirements?

• What to do for missing SNM?

- 10 CFR 73.71 and Appendix G

• Small quantities (fission chamber)

- 10 CFR 20.2201 reporting requirements depending on the Appendix C values

• 10 times 30 days

• 1000 times immediately after discovery

• Develop corrective actions

• The NRC will follow-up on the event, which may result in an inspection follow-up item or violation 25

Lessons Learned

• Radioactive waste should be secured from unauthorized access

• When discovered to be lost begin survey immediately

- Both visual and radiological survey

• Pull in as many resources as possible 26

Questions 27