NUREG-1322, Acceptance Criteria for the Evaluation of Category I Fuel Cycle Facility Physical Security Plans

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NUREG-1322, Acceptance Criteria for the Evaluation of Category I Fuel Cycle Facility Physical Security Plans
ML20085G840
Person / Time
Issue date: 10/31/1991
From: Dwyer P
Office of Nuclear Material Safety and Safeguards
To:
References
NUREG-1322, NUDOCS 9110280054
Download: ML20085G840 (32)
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~ 'j - AVAILABILITY NOTICE Y ? Availability of' Reference Materials Cited in NRC Publications Most documents citefin NRC publications-- wil!-be available from one of the following sources:- m

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. - ~.- . -.--.+.- NUREG-1322 Acceptance Criteria for the Evaluation of Category I Fuel Cycle. Facility Physical Security Plans i Manuscript Completedi September 1991 Date Published: October 1991 - P.- A. Dwyer-Division' or Safeguards and Transportation OITice of Nuclear Material Safety and Safeguards - U.S. Nuclear Regulatory Commission Washington, DC 20555 - ....g t - g a A...../ %*,4 ,m. --,g ,9-43,,-9,,,%.,,,.,y,,,,m,4,_yww.,,-..p,,,,,,4.,w,.,,gg,,,,,v,w,yyyy,,,,,,,,,m, .y.w%%,,..,.,y,,,,,w.,%.,.,,,,,,,,,;,,,,..... ,,m.,-,,,.,w--,

..... -. ~. ~.,. _. i ABSTRACT-This NUREG document presents-criteria developed from U.S. Nuclear Regulatory Commission regulations for the evaluation of physical security plans submitted by Category I-fuel facility licensees. Category I refers to those licensees who use.or possess a formula-quantity of strategic special nuclear material. 1 l l f i l ~ ) I - i iii i ~, -... .--4.,,,,-.~., _.-.--...,,,,,,,.m....,,-r.#. + .-,-r..,,,,,,~ .. - * ~,

CONTENTS Page ABSTRACT.......,.......... iii 1. INTRODUCTION.................................................. 1 2. GENERAL PERFORHANCE OBJECTIVES........................... 2 3. DESIGN BASIS THREAT....................... 3 4. SECURITY ORGANIZATION............................................ 4 4.1 Establishment of Security Organization................... 4 4.2 Security Organization Management.............. 4 4.3 Qualifications for Employment in Security.................... 4 4.4 Guard Force Training................................... 5 4.5 Security Force Armament.......... 5 4.6 Force-on-Force Exercises.................................. 6 4.7 R,3 cords....................... 6 5. PHYSICAL BARRIERS................... 8 5.1 General Layout................... 8 5.E Pratected Area Barriers............ 8 5.3 Vehicle Barriers.......,................................. 8 5.4 Material Access Area Barriers........................... 8 5.5 Security Posts and Structures.......................... 8 5.6 Isolation Zones....... 9 5.7 Illumination............... 9 5.8 Storage of Strategic Special Nuclear Material,......... 9 5.8.1 Vaults........................................... 9 5.8.2 Tamper-Indicating Containers......................... 9 5.8.3 Process Material Access Areas........ 10 5.9 Storage of Enriched Uranium Scrap............... 10 6. ACCESS CONTROL SUBSYSTEMS AND PROCEDURES......................... 11 6.1 Numbered Picture Badge Identification Systems............... 11 6.2 Access to Vital Areas, Material Access Areas, and Controlled Access Areas..................................... 11 6.3 Access Controls at the Protected Area............ 11 6.3.1 Personnel............... 11 6.3.2 Hand-Carried Packages.................... 12 6.3.3 Delivered Packages................. 12 6.3.4 Vehicles................................. 13 6.3.5 Des ignated Licensee Vehicles....................... 13 6.4 Access Controls at Vital Areas, Material Access Areas, and Controlled Access Areas................ 13 6.4.1 Personnel................ 13 6.4.2 Material............ 14 6.4.3 Vehicles............... 14 v

~ CONTENTS _(Continued) .Page,

6. 5 Material Access-Area Exit Search of Contaminated Waste......

11 5 6.6 Shipment of Strategic Special Nuclear Material Offsite...... 15 6.7-Escorts _and Escorted Individuals............................ 15 6.8 Keys, Locks and Combinations................................ 15 6.9. Records..-................................................... 16 7. DETECTION, SURVEILLANCE, AND ALARM SUBSYSTEMS.................... 17 7.1 Isolation Zone Penetration.................................. 17-7.2 Emergency Exits............................................. 17

7. 3 Material Access Area / Vital Area Protection..................

17 7.4 Duress-A1 arms............................................... 17 7.5 Central and Secondary Alarn Stations........................ -18 7.6 Power Sources............................................... 18 7.7 Component Supervision....................................... 18-

7. 8 External Protected Area Monitoring and Assessment...........

19 7.9 Observation Methuds within Material Access Areas............ 19 8. COMMUNICATIONS SUBSYSTEMS........................................ 20 8.1 - Security Force Communications............................... 20 8.2 Alarm Stations Communications............................... 20 8.3 Power Sources............................................... 20 9. TEST AND MAINTENANCE PR0 GRAMS.................................... 21 9.1 ' Installation and Construction Tests......................... 21 9.2 Pre-Operational Tests....................................... 21 9.3 Operational Tests................................... 21 9.4 Preventative Maintenance Programs........................... 22 9.5 Repairs and Maintenance..................................... 22 9.6 Reviews and Audits.......................................... 22 11 0. CONTINGENCY RESPONSE PLANS AND PROCEDURES........................ 23 10.1 Contingency-Plan Documentation.............................. 23 10.2 Local-Law Enforcement Agency Liaison....................... 23 10.3-Tactical Response Force........... 23 10.4 Res",nse Procedui u......................................... 23 10.5 Use of Force................... 24 l-10.6 Protected Area Alarm Assessment.................... 24 10.7 Unoccupied Vault / Material Access Area Alarm Assessment...... 24 r L 10.8 Unoccupied Material Access Area (Alloyed / Encapsulated l Strategic Special Nuclear' Material) Alarr.i Assessment........ 24 l 10.9 Records..................................................... 25 vi a.

__ _. _. ~. _ - ~. _ _. _ _ _ _ _. _. -. _ _ _ 1. _ INTRODUCTION. This document is intended-to be used as a reference manual in evaluating the acceptability of physical security plans submitted by U.S. Nuclear Regulatory Commission (NRC) licensees who possess or use formula quantities of strategic special nuclear material at fixed sites. The document.is composed of criteria .that a licensee should consider in the development of physical security plans designed to meet-NRC physical security regulations. The criteria are presented in a format suitable for security plan development. The source for each cri-terion is listed with each element. The structure of the criteria in this document follows the structure of 673.46 of Title-10 of the Code of Federal Regulations. The content of 673.46 describes an example physical security system that meets the performance capability requirements of S73.45. Measures required by these regulations to potect against theft of strategic special nuclear material are also considered to provide protection against radiological sabotage. A licensee should consult with the NRC physical security plan reviewer for "i guidance on needed physical protection measures for long-term, site-specific, unique situations not treated by this NUREG (e.g. decommissioning activities). Typically, licensees' commitments for physical protection measures imposed during these situations may be documented in an appendix to the physical security plan. i 1

2. -GENERAL PERFORMANCE OBJECTIVES S73.20(a)

The security-plan mus_t commit the licensee to establish and maintain or make arrangements for a physical protection sys-tem which will have as its objective to provide high assurance that activities involving special nuclear material are not inimical to the common defense and security and do not con-- stitute'an unreasonable-risk to the public health and safety. -S73.20(a) The security plan must commit the lictnsee to design.a physical protection system to protect against the design basis threats as described in section 73.1(a) of Title 30 of-the Code of Federal Regulations. 673.20(b)(1) The security plan must commit the licensee to establish and maintain, or arrange for, a physical protection system which provides the performance capabilities outlined in section 73.45 of Title 10 of the Code of Federal Regulations. These performance capabilities are: (1) Detect attempts to gain unauthorized access or introduce unauthorized material into material access areas and vital areas. (2) Permit only authorized activities and conditions within protected areas, material access areas, and vital areas. (3) Permit only authorized placement and movement of strategic special nuclear material within material access areas. (4) Permit removal of only authorized and confirmed forms and amounts of strategic special nuclear material from material access areas. (5) Provide for authorized access and assure detection of and response to unauthorized penetrations of the protected area. (6)- Provide a response capability to assure that the above capabilities are achieved and that adversary forces will be ennaged and impeded until offsite assistance forces arrive. S73.20(b)(2) The security plan must' commit the licensee to design a physical protection system with sufficient redundancy and diversity to assure maintenance of the performance capabilities. described above. S73.20(b)(3) The security plan must commit the licensee to include within the physical. protection program a testing and maintenance program to assure control-over all activities and devices affecting the effectiveness, reliability, and availability of the physical protection system, including a demonstration that any defects of such activities and devices will be promptly detected and corrected for the total period of time they are required as part of the physical protection system. l L L 2

3. DESIGN BASIS THREAT $73.1 The security plan must describe a safeguards system designed to protect against the following dasign basis threat: Theft or diversion of formula quantities of strategic special nuclear material. (1) A determined, violent, external assault, attack by stealth, or deceptive actions by a small group with the following attributes, assistance, and equipment: (a) Well-trained including military training and skills and dedicated individuals; (b) Inside assistance that may include a knowledgeable individual who attempts to participate in a passive role (e.g., provide information), an active role (e.g., facili-tate entrance and exit, disable alarms and communications, participate in violent attack) or both; (c) Suitable weapons up to and including hand-held automatic weapons, equipped with silencers, and having effective long-rangeaccuracyledequipmentincludingincapacitatingagents (d) Hand-carr and explo!ives for use as tools of entry or for otherwise destroying reactor, facility, transport, or container inte-grity or features of the safeguards system; (e) Land vehicles used for transporting personnel and their hand-carried equipment; and the ability to operate as two or more teams. (2) An individual including aa employee in any position; and (3) A conspiracy between individuals in any position who may have: (a) Access to and detailed knowledge of the facilities referred to in S73.20(a) or (b) Items that could facilitate theft of special nuclear material, (e.g., small tools, substitute material, false documents, etc.), or both. 3 e

4. SECURITY ORGANIZATION 4.1 Establishment of Security Organization S73.46(b)(1) The security plan must commit the licensee to establish a security organization including guards. S73.46(b)(1) If a contract security force is used, the security plan must commit the licensee to have written agreements with the contractor. These agreements must clearly show: (1) the licensee is responsible to the Commission for maintaining S safeguards in accordance with Commission regulations and the licensee's security plan; (2) the NRC may inspect, copy, and take away copies of all reports and documents required to be kept by Commission regulations, orderc and applicable license conditions whether such reports or documents are kept by the licensee or the contractor; (3) the requirement that the licensee demonstrate the ability of physical security per-sonnel to perform their assigned duties and responsibilities, including demonstration of the ability of the contractor's physical security personnel to perform their assigned duties and responsibilities in carrying out the provisions of the security plan and section 73.46 of Title 10 of the Code of Federal Regulations; and (4) the contractor will not assign any personnel to the site who have not first been made aware of these responsibilities. 4.' Security Organization Management 673.46(b)(2) The security plan must commit the licensee to have onsite at all times at least one full time member of the security organization with authority to direct the physical protection activities of the security organization. 673.46(b)(3) The security plan must commit the licensee to the establish-ment of a management system to provide for the development, revision, implementation and enforcement of security proce-dures. The security plan must describe a management system which includes (1) written security procedures which document the structure of the security organization and which detail the duties of the guards, watchmen, Tactical Response Team, and other individuals responsible for security; and (2) pro-g visions for written approval of such procedures and any revi-4 sions thereto by the individual with cverall responsibility for the security function. 4.3 Qualifications for Employment in Security S73.46(b)(4) The security plan must commit the licensee not to ;.9rmit an individual to act as a guard, watchman, Tactical Rr<oonse Team member, or other member of the security organi. tion unless the individual has been trained, equipped and qualified in accordance with Appendix B to Part 73, " General Criteria for Security Personnel". N 4

S73.46(b)(4) The security plan must commit the licensee to demonstrate the ability of the physical security personnel, whether licensee or cc.ntractor employees, to carry out their assigned duties or responsibilities upon the request of an authorized member of the Commission. $73.46(b)(5) The security plan must commit the licensee to affirm that, within any given period of time, a member of the security organization will not be assigned to or have direct opera-tional-control over more than one of the redundant elements of a physical protection subsystem if such asalgnment or control could result in the loss of effee iveness of the subsystem. 4.4= Guard Force Training S73.46(b)(4) The security plan murt commit the licensee to train guards, watchme1,-Tactical Response Team members and other members of the security organization to perform each assigned security duty in accordance with Appendix-B to Part 73. S73.46(b)(4) The security plan must commit the licensee to requalify each guard, watchman, and Tactical Response Team member and other members of the security organization, whether a licensee or contractor employee, in accordance with Appendix B to Part 73. App. B to -The security plan must commit the licensee to requalify-Part 73,SII,E security personnel at least every twelve months to aerform assigned security-related job tasks and duties for )oth normal and contingency operations. S73.46(b)(7) The security plan must commit the licensee, in addition to the-qualification requirements of Appendix B to Part 73, to qualify and requalify guards and Tactical Response Team mem-bers annually for night firing with assigned weapons in accordance with Appendix H to Part 73. S73.46(b)(8) The security plan must commit the licensee, in addition to the-training requirement contained in Appendix B to Part 73, to require-Tactical Response Team members to successfully -complete training in response tactics. -4.5-Security Force Armament S73.46(b)(6) The security plan must commit the licensee to arm each guard with a-handgun, as described in Appendix B to Part 73. S73.46(b)(6) The security plan must commit the licensee to arm each Tactical Respor e Team member with a 9mm semiautomatic pistol. S73.46(b)(6) The security plan must commit the licensee to arm all but one member of the Tactical Response Team addit',nally with either a shotgun or a semiautomatic rifle, as described in_ Appendix B 5

a to Part 73. Further, the security plan must commit that the remaining member of the Tactical Response Team carry, as an individually assigned weapon, a rifle of no less caliber than ,30 inches or 7.62 mm. 4.6 Force-on-Force Exercises $73.46(b)(9) The security plan must commit the licensee to conduct Tactical Response Team and guard exercises to demonstrate the overall security system effectiveness and the ability of the security forces to perform response and contingency plan responsibil-ities and to demonstrate individual skills in assigned Team duties. S73.46(b)(9) For licensees possessing a materials license prior to September 1991, the security plan must commit the licensee to carry out, during each twelve month period commencing on the anniversary of 60 days from security plan approval, an exercise at least every four months fcr each shift, one third of which are to be force-on-force. (Licensees granted a materials license after September 1991, should consult with their NRC security plan reviewer for guidance on frequency of exercises.) 673.46(b)(9) The security plan must commit the licensee to demonstrate the capability to respond to attempts to steal strategic special nuclear material. S73.46(b)(9) The security plan must commit the licensee to permit, during each of the twelve month periods specified above, the NRC to observe one of the force-on-force exercises which demonstrates overall security system performance. S73.46(b)(9) The security plan must commit the licensee to notify the NRC of the aforementioned scheduled exercise 60 days prior to that exercise. 4.7 Records 573.46(b)(3)(i) The security plan must commit the licensee to retain a copy of current security procedures as a record until the Cunmis-sion terminates the license for which these procedures were developed, and, if any portion of these procedures is super-ceded, retain the superceded material for three years after the change. S73.46(b)(4) The security plan must commit the licensee to document the results of qualification and requalification for security-force members.and to retain the documentation as a record -for three years after each qualification and requalification. S73.46(b)(7) The. security plan must commit the licensee, or the licensee's agent, to document the results of weapons qualification and requalification for night firieg. This documentation must be 6

y 3 ) retained as a record for three years after each qualification and requalification. -973.46(b)(8) The security plan must commit the licensee to document the . completion of training.in response tactics for members of the Tactical-Response Team. This documentation must be retained as a record for three years.after training is completed.

673.46(b)(9)-

_The security plan must commit the licensee to document the results of Tactical Response Team and guard exercises. This g documentation must-be retained as a recora for three years 'after each exercise is completed, i 1 4 k t a Y 7

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p 5.s PHYSICA1. BARRIERS 15.1-General _ Layout

673.46(c)(1)

The security plan must commit the-licensee to locate vital equipment only within a vital area and to store and process istrategic special nuclear material only within-a material-access area. More--than one vital area or material access-area may be located within a single protected areac $73.46(c)(1) The security plan must commit the licensee to locate both vital areas and material access areas within a protected area -so that access to vital equipment and strategic special nuclear material requires passage through at least three physical barriers (two of which are protected area barriers). - 5. 2 Protected Area Barriers $73.46(c)(1) The security plan must commit the licensee to provide the perimeter of the protected area with two separate physical barriers with an intrusion detection system placed between the two. .S73.46(c)(1) The security plan must commit the licensee to position and construct the inner protected area barrier to enhance assessment of: penetration attempts and to delay attempts at

unauthorized exit from the p_rotected area 573.46(c)(2)

The' security _ plan must commit the licensee to separate the physical barriers at the perimeter of the protected area from any_other barrier designated as a physical barrier for a vital area or material access area within the protected area 5,3 Vehicle Barriers $73.46(c)(1)L The security plan must commit the licensee to incorporate features and structures at the perimeter of the protected area that prevent forcible vehicle entry. 5.4-': Material Access Area Barriers S73.46(c)(5)(iii) The security plan must commit the licensee to process strategic special nuclear material, other than alloys, fuel elements or fuel assemblies only in material access areas constructed with barriers _that provide significant delay to penetration. 5.5 Security Posts'and Structures-S73.46(d)(4)(i) 'The security plan must commit the licensee to-isolate the individual responsible for the last access control function (controlling admission to the protected area) within a_struc-ture with bullet resisting walls, doors, ceiling, floor, and windows. 8

a 5.6 Isolation Zones 573.45(c)(3) The security plan must commit the licensee to maintain-2 isolation zones _in outside areas adjacent to the physical barrier at the perimeter of the protected area. ,S73,46 c) 3( )L _The security nlan must commit the licensee to design ( isolation zones large enough to permit observation of the activities of people on either side of-the barrier at the protected area perimeter in the event of its penetration. S73.46(c)(3) The security plan must commit the licensee to locate parking. facilities outside-of the isolation zone and exterior to the protected area if such facilities _are provided for employees or visitors. 5.-7 Illumination -S73.46(c)(4) The security plan must commit the licensee to provide isolation zones and all exterior areas within the protected area with illumination sufficient for monitoring and observing-i but not'less than 0.2 footcandles measured horizontally at ground level. 5.8' Storage of Strategic Special Nuclear Material 5.8.1-Vaults S73.46(c)(5)(i) The security plan must commit the licensee to store strategic' special nuclear material, other than alloys, fuel elements, or fuel assemblies, in a vault when not undergoing processing if the material can be used directly in the manufacture of a nuclear explosive device. S73.46(c)(5)(i)' The security plan must commit the licensee to design vaults used to protect strategic special nuclear material (other than alloys, fuel elements, and fuel _-assemblies).directly usable in the manufacture of a nuclear explosive device such that the vault is capable of preventing entry to stored stra-tegic special nuclear material by a single action-in a-forced-entry _ attempt, except as such single action would both destroy the barrier and render stored strategic special nuclear mate-rial incapable of being removed. These vaults must provide sufficient delay to prevent removal of stored strategic spe-cial nuclear material prior to arrival of response personnel capable of neutralizing the design basis threat stated in S73.1. 5.8.2. Tamper-Indicating Containers ~ 73.46(c)(5)(ii)

The security plan must commit the licensee to store strategic special-nuclear material (other than alloys, fuel elements, or fuel assemblies) in tamper-indicating containers.

9

5.8.3 Process MaterialLAccess Areas S73,46(c)(5)(iii) __The security plan must commit the licensee to process -strategic special nuclear material (other than alloys, fuel elements, or fuel assemblies) only in material access areas constructed with barriers that provide significant delay to penetration. ! $73.46(c)(5)(iv) The-security plan must commit the licensee to keep strategic special nuclear material (other than alloys, fuel elements or fuel assemblies) in locked compartments or locked process equipment while undergoing p_rocessing except when personally attended. 5.9 Storage of Enriched Uranium Scrap 673.46(c)(6) If desired by the licensee, the security plan may commit the licensee to store enriched uranium scrap (enriched to 20 aer-cent or greater) in the form of small pieces, cuttings, clips, solution or in other forms which result from a manufacturing process, containered in 30 gallon or larger containers with a uranium-235 content of less than 0.25 grams per liter, within a locked and separately fenced area within a larger protected area provided that the storage area fence is no closer than-25 feet to-the perimeter of-the protected area. S73.46(c)(6) If the above described storage area is used, the security plan must commit the licensee to protect the-area, when unoccupied, by a guard or watchman who s1all patrol at intervals not exceeding 4 hours, or by intrusion alarms. L 10

c 6.0L ACCESS CONTROL SUBSYSTEMS ATO PROCEDURES 6.1 Numbered Picture Badge Identification Systems 973.46(d)(1) The security plan must commit the licensee to use a numbered picture badge ident.ification subsystem for all individuals who are authorized access to th'e protected area without escort. - i S73.46(d)(1) For individuals not employed by the licensee but who require frequent'and extended access to protected, material access or vital areas and for whom the licensee wishes to authorize access to such areas without escort, the security plan must commit the licensee to issue a picture badge to the indivi-dual upon entrance to the protected area and retrieve the badge upon exit from the protected area and design the badge such that it indicates (1) non-employee no escort required, (2) areas to which access is authorized and (3) the period for which access has been authorized. S73.46(d)(1) The security plan must commit the licensee to require that badges be displayed by all individuals while inside the protected area. 6.2 Access to Vital Areas, Material Access Areas and Controlled Access Areas i S73.46(d)(2) The security plan must commit the licensee to limit unescorted access to vital areas, material access areas, and controlled access areas to individuals who are authorized access to the material and equipment in such areas-and who require such access to perform their duties. t 1 $73.46(d)(2) The security plan must commit the licensee to affirm that access to material access areas will include at least two individuals. S73.46(d)(2) The security plan must commit the licensee to issue specially coded numbered badges to individuals authorized unescorted access to vital areas, material actess areas, and controlled access areas which indicate the vit, ateas, material access areas,-and controlled access areas to which access is authorized. 673.46(d)(2) The security plan must commit that no activities other than those which require access to strateqle special nuclear mat-erial or to equipment used in the processing, use, or storage of strategic special nuclear material or necessary mainte-nance, will be permitted within a material access area. 6.3 Access Controls at the Protected Area 6.3.1 Personnel S73.46(d)(4)(1) The security plan must commit the licensee to control all points of personnel access into a protected area. I i 11

.$73.46(d)(4)(i) For all--individuals entering the protected area, the security plan must commit the licensee to identify the individuals; search the individuals for firearms, explosives and incendiary devices; and check the individuals' authorizations.

Federal, State,-and local law enforcement personnel on official duty and Ur.ited States Department of Energy couriers engaged in

- the transport of special nuclear material are exempt from this requirement. S73.46(d)(4)(i) The security plan must commit the licensee to accomplish the search function for detection cf firearms, explosives, and incendiary devices through the use of detection equipment capable of detecting both firearms and explosives. S73.46(d)(4)(i) The security plan must commit the licensee to isolate the individual responsible for the last access control function (controlling admission to the protected area) within a struc-ture with bullet-resisting walls, doors, ceiling, floor, and windows. S73.46(d)(4)(ii) The st.curity plan must commit the licensee to conduct a physical pat-down search of an individual when the licensee has cause to suspect that the indiv11ual-is attempting to introduce firearms, explosives, or i cendiary devices into the protected area. S7L46(d)(4)(iii) The security plan must commit the licensee, whenever firearms or explosives detection equipment at a portal is out of ser-vice or not operating satisfactorily, to conduct a abysical pat-down search of all persons who would otherwise nave been subject to search using the equipment. 6.3.2 Hand-Carried Packages S73.46(d)(3) The security plan-must commit the licensee to establish and follow written procedures that will permit access control per-sonnel to identify those materials that are not authorized entry to protected areas. S73.46(d)(5) The security plan must commit the licensee to search for firearms, explosives and incendiary devices all hand-carried packages at the points of personnel and vehicle access into.a protected area, except those carried by individuals exempted from search under paragraph 73.46'd)(4)(i), 6.3.3 Delivered Packages SI3.4C(d)(3) The security plan must commit the licensee to establish and follow written procedures that will permit access control per-sonnel to identify those materials that are not authorized entry to the protected area. S73.46(d)(6) The security plan must commit the licensee to check all packages and material-for delivery into the protected-area for proper identification and authorization and to search for 12

1 l firearms,-explosives, and incendiary devices prior to admittance to the protected area except-those Commission -approved delivery and inspection activities specifically ~ designated by the licensee to be carried out within material

access, vital, or 'rotected areas for reasons of safety, security, or oper.v Conal necessity.

6.3,4 Vehicles S73.46(d)(3)- The security plan must commit the licensee to establish and follow written procedures that will permit access control-personnel to identify those vehicles that are authorized j entry to protected areas. S73.46(d)(4)(i) The security plan must commit the licensee to control all i points of vehicle access into a protected area. l 673.46(d)(7) The security plan must commit the licensee to search all vehicles, except U.S. Department of Energy vehicles engaged in transporting special nuclear material and emergency vehi-cles under emergency conditions, for firearms, explosives and incendiary devices prior to entry into the protected area. -S73.46(d)(7) The security plan must commit the licensee to search the following vehicle areas as part of a required search: -the cab, engine compartment, undercarriage, and cargo area. 673.46(d)(8) .The security plan must commit the licensee to escort all vehicles, except designated licensee vehicles, requiring entry into the protected area by a member of the security organiza-tion while within the protected area, and to the extent pr_ac-ticable,-to off-load the-vehicle in an area that is not adjacenttoavitalarea. ~ 6.3.5 Designated Licensee Vehicles S73.46(d)(8)' The security plan must commit the licensee to limit designated licensee vehicles in their use to onsite plant-functions and -to keep such vehicles within the protected area except for operational, maintenance, security and emergency purposes. S73.46(d)(8)- The security plan must commit the licensee to exercise positive control over all designated licensee vehicles-to assure that they are used'only by_ authorized persons and 'for authorized purposes. 6.4 Access Controls at Vital Areas, Material Access Areas and Controlled Access Areas-6.4.1 Personnel l 573.46(d)(9) The security plan must commit the licensee to control all E points of-personnel Lccess to material access areas, vital areas, and controlled access areas. 673.46(d)(9) The security plan must commit the licensee to post at least 13

l two armed guards trained in accordance with 673.46(b)(7) and Appendix B of Part 73 at each_ material access area control-point whenever in use. -S73.46(d)(9)_ The security plan must commit the licensee to verify the identification and authorization of personnel at material access area-control points. S73.46(d)(9) The security plan must commit the licensee to conduct two separate searches of individuals exiting a material access area for concealed strategic special nuclear material, for individuals exiting an area that'contains only alloyed or encapsulated strategic special nuclear material, the second search may be conducted in a random manner. 6.4.2 Material $73.46(d)(9) The security plan must commit the licensee to search packages -for firearms, explosives and incendiary devices prior to entry into a material access area. S73.46(d)(9) The security plan must commit the licensee to search all material and packages, including trash, wastes, tools, and equipment exiting from a material-access area for concealed strategic special nuclear material by a teem of at least two individuals who are not authorized a cess to that material access area. l l6.4.3 Vehicles-S73.46(d)(3)_ The security. plan must commit the licensee to establish and follow written procedures that will permit access control personnel to identify tMse vehicles that are authorized entry to material accese, and vital areas.. S73.46(d)(9) The security plan must commit the licensee to control all points of vehicle access to material access areas, vital ~L areas, and controlled access areas. S73.46(d)(9) The security plan must commit the licensee to post at least two armed guards trained in accordance with the provisions of S73.46(b)(3) and Appendix B to Part 73 at each material access. area _ control po_ int whenever in use. S73.46(d)(9) The security plan must commit the licensee to verify identification and authorization of vehicles at the material access area control point. S73.46(d)(9) The. security plan must commit che licensee to search all vehicles exiting from a material access area for concealed strategic special nuclear material by a team of at least two -individuals who are not authorized access to that material access area. E 14

I 6.5 Material Access Area Exit Search of Contaminated Waste 673.46(d)(10) The security plan must commit the licensee to drum scan and tamper-scal ctatainers of contaminated wastes befare exiting from a material access arec by at least two individuals, work-ing and recording as a team, who do not have access to the material processing and storage areas. j used for packaging and screening trash and waste as controlled ~ $73.46(d)(12) The security plan must commit the licensee to designate areas ) access areas and separate such areas from processing and storage areas. 6.6 shipment of Strategic Special Nuclear Material Dffsite S73.46(d)(12) The security plan mu.t commit the lio nsee to pack and place in cealed containers strategic spe:iel nuclear material (including produc+., samples and scrap) prepared for shipment offsite. i S73.46(d)(11) The security plan must commit the licensee tc carry out the above procedure in the pre:ence of at lecst two individuals work-ing as a team who will verify and ccitify the content of each i shipping container through the witnessing of gross weight i measurements and nondestructive assay and throur' 'Se inspec-tion of tamper-seal integrity and associa+ed set acords. S73.46(d)(12) The security plan must commit the licensee to designate areas used for preparing strategic special nuclear material for shipment as controlled access areas and to separate these areas from processing and storage areas. 6.7 Escorts and Escorted Individuals 673.46(d)(13) The security plan must commit the licensee to escort individuals not permitted to enter. protected areas without escort by a watchman or other individual desiWated by the j licensee while in a protected area. 673.46(d)(13) The security plan must connit the-licensee to badge individuals recuirir.g escorts with a badge that indicates escort requirec. 673.46(d)(13) The security plan must commit the licensee to register individuals requiring escort in a log that includes the i following information:

1) the individual's name, 2) date,

+

3) time, 4) p!p, and 6) name of individual to be visited.urpose
5) citizensh 6.8 Keys, Locks, and Combinations 973.46(d)(14)

The security plan must commit the licensee to control all keys, locks, combinations, and related equipment used to 15

control access to protected, material access vital, and controlledaccessareastoreducetheprobabIlityof compromise. $73.46( -(14) The security plan must commit the licensee to change keys, locks, combinations, and related equipment whenever there is evidence that the keys, locks, combinations, and related equipment may have been compromited. S73.46(d)(14) The security plan n.ust commit the licensee, upon termination of employment of any employee, to change keys, locks, combin-ations, and related equipment to which that employee had access. 6.9 Records i $73.46(d)(3) The security plan must commit the licensee to retain a copy .of current writtan procedures tht.t permi' access control p(r-sonnel to identify vehicles that are v-rized and those materials that are feat authorized enti, 'o protected, material t access, and vital areas. These procedures must be retairn 1 as a record until the Commission terminates et.ch license for i which the procedures were developed and, if any portion of the procedures is superceded, retain the superceded material for three years after_each change. L 673.46(d)(10) The security plan must commit the licensee to retain as a record the findings of drum scanning and tamper-sealing of containers of contaminated waste exiting from a material access area for a period of three.vears after the record is made. S73.46(d)(13) The security plan must commit the licensee to retain as a record the required log of escorted individuals for a period of three years afte the last entry is made in the log. ( 16

l 7.0 DETECTION, SURVEILLANCE AND ALARM $UBSYSTEMS 7.1 IsolationZonePenetratIon $73.46(e)(1) The security plan must commit the licensee to provide an intrusion alarm subsystem with a capability to detect pene-trations through the isolation zone and to permit response . action. 7.2 Emergency Exits $73.46(e)(2) The security plan must commit the licensee to lock all emergency exits in each pro'.ected, material access, and vital area to prevent entri from the outside. -573.46(e)(2) The security plan must commit the licensee to alarm all emergency exits in each protected, material access and vital area to provide local visible and audible alarm annunciation. S73.46(e)(5) The security plan must commit the license to annunciate emergency exit alarms in a continuously manned central alarm system station and in at least one other continuously manned onsite alarm station. 7.3 Material Access Area / Vital Area Protection S73.46(e)(3) The security plan must commit the licensee to lock and protect by an intrusion alarm subsystem all unoccupied vital areas and meterial access areas. The intrusion alarm subsystem must alarm upon-the entry of a person anywhere into the area u:>on exit from the area and upon movement of an individual wit 11a the area, except that for process material access areas only the location of the strategic special nuclear material within the area is required to be so alarmed. 673.46(e)(3) The security plan must commit the licensee, in addition to locking and protecting by an intrusion alarm subsystem, to keep under the surveillance of closed circuit television, that is monitored in both alarm stations, vaults and process areas that contain strategic special nuclear material that has not been alityed or encapsulated. 973,46(e)(3) The security plan must commit the licensee to employ means which require that an individual other f',an an alarm station operator be present at or have knowledge of access to unoccu-pied-vaults or process areas that contain strategic special nuclear material that has not been alloyed or encapsulated. 7.4 Duress Alarms S73.46(e)(4) The security plan must commit the licensee to provide all manned access control points within the protected area bar-rier, all security patrols and guards stations within the protected area and both alarm stations with duress alanss. i 17

I l 7.5 Central and Secondary Alarm Stations i 573.46(e)(5) The security plan must commit the licensee to annunciate all l alarms required pursuant to $73.46 in a continuously manned central alarm station located within the protected area and at least one other independent, continuously ranned onsite station not necessarily within the protected area so that a j single act.cannot remove the capability of calling for assis-l tance or responding to an alarm. S73.46(e)(5) The security plan must commit the licensee to designate the alarm stations as controlled access areas. $73.46(e)(5) The security plan must commit the liceneee to make bullet.- resisting the walls, doors, ceilings, floors and windows of the alarm stations. S73.46(e)(5) The iecurity plan must commit the licensee to locate the central alarm station within a building so that the interior of the central alarm station is not visible from the perimeter of the protected area. l S73.46(e)(5) The security plan must commit the licensee to affirm that the central alarm station will not contain any operational a tivi-l ties that would interfere with the sxocution of alarm re ponse i functions. i 7.6 Power Sources 573.46(e)(6) The security plan must commit the licensee to keep operable from independent power sources all alarms required by S73.46(e) in the event of loss of normal power. ~S73.46(e)(6)- The security plan must commit the licensee to affirm that switchover to standby power will be automatic and will not cause false alarms on annunciator modules. 7.7 Component Supervision f 673.46(e)(7) The security plan must commit the licensee to affirm that all alarm devices ir.cluding transmission lines to annunciators are tamper-indicating and self-checking e.g., an automatic indica-tion is provided when a failure of the alarm system or.a com-ponent occurs, when there is an attempt to com,r smise the system, or when the system is on standby power. -973.46(e)(7) The security plan must commit the licensee to affirm that the !i annunciation of an alarm at the alarm stations will indicate the type of alarm (e.g., intrusion alarm, emergency exit alarm, etc. ) and ' location. h 18

1 573.46(e)(7) The security plan must commit the licensee to indicate the status of all alarms and alarm zones in the alarm stations. I

7. 8 External Protected Area Monitoring and Assessment 573,46(e)(8)

The security plan must connit the licensee to monitor and periodically check all exterior areas within the protected area to detect the ?resence of unauthorized persons, vehicles, materials, or unaut1orized activities. 7.9 Observation Methods within Material Access Areas ) 973.46(e)(9) The security plan must commit the licensee to provide and use on a continuing basis methods to observe individuals within material access areas to assure that strategic special nuclear material is not moved to unauthorized locations or in ar unauthorizsd manner. i i 4 e i L ? 19

? d 2 ? f 8.0 C0HMUNICATIONS SUBSYSTEMS 8.1 Security force Communications t $73.46(f)(1) The security plan must commit the licensee to sffirm that each guard, watchman, or armed response individual on duty will be capable of maintaining continuous communications with an individual in each continuously manned alarm station who will be capable of calling for assistance from other guards, watchmen, and armed response personnel and from law enforcement authorities. 8.2 Alarm Stations Communications 673.46(f)(2) The security plan must commit the licensee to provide each alarm station with both conventienal telephone service and radio or microwave-transmitted -s -way voice communication, either directly or through an intermediary, for the capabil-ity of connunication with the law enforcement authorities. 8.3 Power Sources 673.46(f)(3) The security plan sust commit the licensee to keep operable from independent power sources non portable communications equipment controlled by the licensee and required by section 73.46(f) in the event of loss of normal power. 9 20

9.0 TEST AND MAINTENANCE PROGRAMS 9.1 Installation and Construction Tests $73.46(g)(1) The security plan must commit the licensee to have a test and maintenance program for intrusion alarms, emergency exit alarms, coamunications equipment, physical barriers, and other physical protection related devices and equipment used pur-suant to 673.46 that will provide for test and inspections during the installation and construction of physical protec-tion subsystems ar,d components to assure that they comply with their respective design criteria and performance specifications. 9.2 Pre-0perational Tests S73.46(g)(2) The security plan must reamit the licensee to have a test and = maintenance nrogram for intrusion alarms, emergency exit alarms, unmunications equipmenc, physical barriers, and other physical protection related devices and equipment used pur-suant to S73.46 that will provide for preoperational tests and inspections of physical protection related subsystems and com-ponents to demonstrate their etfectiveness and availability with respect to their respective design criteria and performance specifications. 9.3 Operational Tests S73.46(g)(3) The security plan must commit the licensee to have a test and maintenance program for intrusion alarms, et.:ergency exit alarms, communications equipment, physical barriers, and other physical protection related devices and equipment used pur-suant to 973.46 that will provide for operational tests and inspections of physical protection related subsystems and components to assure their maintenance in an operable and effective condition. S73.46(g)(3)(1) The security plan must commit the licensee to include as part of operational testing, the testing of each intrusion alarm at the beginning and end of any period that it is used. If the period of continuous use is longer than seven days, the intru-sion alarm must be tested at least once every seven days. S73.4G(g)(3)(ii) The security plan must commit the licensee to include as part of operational testing, the testing of communications equip-ment required for communications onsite, including duress alarms, for performance not less frequently than once at the beginning of each security personnel work shi-lt. S73.46(g)(3)(ii) The security plan must commit the licensee to include as part of operational testing, the testing of communications equip-ment required for ccmmunications offsite. This equipment must be tested for performance not less than once a day. 21

9.4 Preventative Maintenance Programs $73.46(g)(4) The security plan must commit the licensee to establish preventative maintenance programs for physical protection related subsystems and components to assure their continued maintenance in operable and effective condition. S73.46(g)(5) The security plan must commit the licensee to maintain all physical-protection related subsystems and components in operable condition. S73.46(g)(5) The security plan must commit the licensee to develop and employ corrective action procedures and compensatory measures to assure that the effectiveness of the physical protection system is not reduced by failure or other contingencies affecting the operation of the security related equipment or structures. 9.5 Repairs and Maintenance 673.46(g)(5) The security plan must commit the licensee to affirm that repairs and maintenance are performed by at least two indivi-duals working as a team who have been trained in the operation and performance of the equipment. 673.46(g)(5) The security plan must commit that the security organization will be notified before and after repair and maintenance ser-vice is performed and that performance verification tests will be conducted after service has been completed. 9.6 Reviews and Audits 673.46(g)(6) The security plan must commit the licensee to review their security programs at least every twelve months by individuals independent of both security management and security supervision. 673.46(g)(6) The security plan must commit the licensee to include within the security organization review:

a. review and audit of security procedures and practices, evaluation of the effec-tiveness of the physical protection system, an audit of the physical-protection system testing and maintenance program, and an audit of commitments established for response for local law enforcement authorities.

673.46(g)(6) The' security plan must commit the licensee to affirm that the results of the review aud ommendations, corrections,it,andevaluation,alongwithrec-and improvements, if any, will be documented, reported to the licensee's plant _ management, and to corporate management at least one level higher than that-having responsibility for the day to day plant operations. 573.46(g)(6) The security plan must commit the licensee to keep reports of security program reviews available at the plant for inspection for a period of five years. 22 1 ...__J

10.0 CONTINGENCY RESPONSE PLANS AND PROCEDURES 10.1 Contingency Plan Documentation S73.46(h)(1) The security plan must commit the licensee to have a safeguards contingency plan for dealing with threats, thefts, and radiological sabotage related to the strategic special i nuclear material and nuclear facilities subject to 673.46. $73.46(h)(1) The security plan must commit the licensee to develop safeguards contingency plans in accordance with the criteria in Appendix C to Part 73, " Licensee Safeguards Contingency Plans." $73.46(h)(1) The security plan must commit the licensee to include within contingency plans the response requirements of paragraphs (h)(2) through (h)(5) of S73.46. The contingency plans need not be limited to the discussion of these particular 1 requirements. 10.2 Local Law Enforcement Agency Liaison S73.46(h)(2) The security plan must commit the licensee to establish and document response arrangements that have been made with local law enforcement authorities. 10.3 Tactical Response Force 673.46(h)(3) The security plan must commit the licensee to have available at the facility a Tactical Response Team consisting of a min-imum of five (5) members to fulfill assessment and response requirements. S73.46(h)(3) The security plan must commit the licensee to have available a' force of guards or armed response personnel to provide assistance as necessary in addition to the Tactical Response Team. 673.46(h)(3) The security plan must connit the licensee to determine the size and availability of the additional force on the basis of site-specific considerationr that could affect the ability of the total onsite response force to engage and impede the -adversary force until offsite assistance arrives. 673.46(h)(3) The security plan must include the licensee's rationale for the total number and availability of onsite armed response personnel. 10.4 Response Procedures S73.46(h)(4)- The-security plan must commit the licensee to establis,h response procedures for dealing with detection of abnormal presence or activity of persons or vehicles within an isola-L tion zone, a protected area, a material access area, or a 23

3 n vital area or svidence or indication of intrusion into a protected area, a material access area, or a vital area. $73,46(b)(4) for the events described above, the security plan must commit the licensee to affirm that the security crganization will:

1) determine whether or not a threat exie s; 2) assess the extent of the threat, if any; and 3) take immediate concurrent measures to neutralize the threat by a) requiring responding guards or othW armed resoonse personnel to interpose them-selves betweer,vithi creas and ma'.erial access areas and any adversary attempting entry for purposes of theft of strategic special nuclear material and to intercept any person exiting with special nuclear material, and b) infnrming local law enforcement agencies of the threat and requesting assistance.

10.5 Use of Forca $73.46(h)(5) The security plan must commit the licensea to instruct every guard and all response eersonnel to p; event or impede acts of theft of strategic special nuclear material by using force sufficient to counter the force directed at them, iiicluding the u:;e of deadly fnrce, when the guard or other response person has a reasonable belief that it f5 necessary in self-defense or the defen+e nf others. 10.6 Protected Area Alurm Assestment S73.46(h)(6) The security plan must comS t thn licensee to provide a capability of observing is;1r. tion zones and the physical bar-rier at the perimeter of the protected area to facilitate initial response to detection of penetratinn of the orotected area and assessment of the existent.o of a threat. Tais capa-bility shoule preferably be arcvided by aeans of closed circuit television or by other suitule ens which limit exposure of responding perscnnel to possible attack, 10.7 Unoccupied Vault / Material Access Ar4ea Alarm Assessment a $73.46(h)(7) The security plan eurt commit the licenf K to assess alares occurring within unocrapied vau'It.4 and unoccupied material access arcas containing unalloyed or unencapsalated strategic special nuclear materia' by at least two security personnel using closed circuit television or other remote means. 10.8 Unoccupied Material Access Area (Alloyed /Encepsulated Strategic Special Nucitar Material) Alarm Assessment S73.46(h)(8) The ;ecurity alan must comnit the licensee to as?.ess alarms occurring witlin unoccupied material cccess areas that contain only alloyed or encapsulated strategic special-nuclear mater-ial either by at least two security personnel using closed circuit television or other remote means or by at least two security personnel who undergo a search before axiting the material access area. 24 I

) T . 0. 9 Records $73.46(h)(1) The security plan must comit the licensee to retain a copy of j the current safeguards contingency plan as a record until the Comission terminates the license and, if any portion of the i plan is superceded, retain the superceded material for three years after each change. 573.46(h)(2) The security plan must comit the 1;icensee to retain document-ation of current arrangement with the local law enforcement agency as a record until the Comission terminates such lic-ense recuiring the arrangements and, if any errangement is suDeh.eced, retain the superceded material for a period of three years after each change. i a c ? s 1 25

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y. w,- -, u,.... i NUREG-1322 P. Ili tt AND hv81114 t Acceptance Criteria for the Evaluation of Category I fuel Cycle Facility Physical Security Plans i

oAri mi roni ev.ussio n i., j October 1991 4 f IN OH GH ANI NOV91 H b.A ulHUM(51 6 lie't 06 HiPpH1 P.A, Dwyer Technical r n aiuo tovi ni o,,- o.,,,, $. P f HW G ANil AT ION - N AM t AND ADDHi M rn 4 aC,..==* D===m Oaw. me 8,*rea. U S km.* Arvae,*, C.mmece. we, me.me e**eu,, s e=Wo.o. p.tes.se Division of Safeguards and Transportation Office of Nuclear Material Safety and Saf eguards U.S. Nuc19ar Regulatory Commission Washington, DC 20555 a beo.Ns.oniNo on, ow e A noN - N Av t ANo A no a i ss o,..c,,,., w...,,,.....,, ..c v...m o,,,,,,.. v .m.~.. . m Same as above 10 $UPFLtMt N7 A81Y NOil $ ti, ABS 1 R AC f thr ee,m w m.el ~~ This NUREG document presents criteria developed from U.S. Nuclear Regulatory Comission regulations for the evaluation of physical security plans submitted by Category I fuel f acility licensees. Category I refers to those licensees who use or possess a forinula quantity of strateg1c special nuclear material, u ntvwonus.viseneiussa. ....,-o, u....t...oi..i.i i~i unlimited acceptance criteria safeguards ' f '" #'"' Category 1 unclassified physical security fuel facility licensees unclassif.ied Ib NUMBk M 06 FAbib it PHILL NMc 9 omu 3Js 12691

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