Regulatory Guide 5.30

Materials Protection Contingency Measures for Uranium and Plutonium Fuel Manufacturing Plants. Label as Withdrawn 01/15/98

ML003740078
Person / Time
Issue date:	06/30/1974
From:	Office of Nuclear Regulatory Research
To:
References
RG-5.30
Download: ML003740078 (8)

June 1974 U.S. ATONMC ENERGY COMMISSION

REGULATORY GUIIDE

DIRECTORATE OF REGULATORY lTAN*ARD8 REGULATORY GUIDE 5.30

MATERIALS PROTECTION CONTINGENCY MEASURES FOR URANIUM

AND PLUTONIUM FUEL MANUFACTURING PLANTS

A. INTRODUCTION

Sections 73.40, "Physical Protection: General Re 1. Scope of Materials Protection Contingency Mesures quirements at Fixed Sites," and 73.50, "Requirements for Physical Protection of Licensed Activities," of 10 The basic philosophy of this guide to the establish CFR Part 73, "Physical Protection of Plants and ment of design and operational measures for the Materials," prescribe requirements for the physical pro protection of SNM under nonroutine conditions is that, tection of special nuclear materials (SNM) and the plants since no system is immune to malfunction, backup in which they are used or stored. Section 70.22, measures should be- provided to maintain the level of

"Contents of Applications," of 10 CFR Part 70, protection afforded by each of the normal materials

"Special Nuclear Material," requires, among other protection systems. Further, since emergencies or non things, that each application for a license to possess routine situations may not follow anticipated patterns, certain quantities of special nuclear material (SNM) such backup measures should provide flexibility to contain a full description of the applicant's program for accommodate a variety of possible failure modes. For control of and accounting for SNM which will be in his example, to provide adequate protection capability in possession under license and a physical security plan for the event of power failure, equipment malfunction, or meeting the physical protection requirements of 10 C'.;, guard incapacitation, the contingency measures should Part 73. Section 70.51, "Material Balance, Inventory, include, respectively, an alternative source of power, redundant hardware, and additional support personnel.

and Records Requirements," requires, among other things, that certain licensees establish, maintain, and follow written material control and accounting proce Protection of the plant against industrial sabotage that could endanger the public health and safety by dures which are sufficient to enable the licensee to account for the SNM in his possession under license. exposure to radiation is beyond the scope of this guide, Proposed §70.58, "Fundamental Nuclear Material Con although some of the measres identified herein may provide protection against such acts as well. In addition, trols," would require, if adopted, that each licensee who emergencies that may pose a threat to plant security or is authorized to possess certain quantities of SNM

establish material balance areas or item control areas for personnel health and safety but not to the protection of the physical and administrative control of nuclear SNM are also beyond the scope of this guide. Emer material. gencies that may be caused or utilized by a thief to conceal the removal (either previous or concomitant) of Essential to the protection of special nuclear material SNM, however, are considered.

against theft are proper planning, implementation, and testing of measures designed to provide protection of 2. Objectives of Emergency Materials Protection Mea special nuclear material even under emergency or other sures nonroutine conditions. This guide describes measures acceptable to the Regulatory staff for assuring continued During emergencies, the effectiveness of normal protection of special nuclear material in such instances. security measures for protecting SNM may be reduced.

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- emergency that requires complete or partial evacua equipment malfunction, guard incapacitation, or a

.. n of --aterial access area because of health and change in equipment and plant structure that leads to a safetw ,"-'iderations may result in a necessary relaxa reduction in the capability to protect SNM can each tion of exit control requirements. The possibility of represent a functional loss of part of the required evacuation procedures deleteriously affecting the protec materials protection system.

tion of SNM can be minimized by proper planning and posting of emergency procedures and by a program of b. EMERGENCY MEASURES are those provisions instruction and drills for personnel at the facility. that are taken to protect SNM in response to a nonroutine event. In addition, emergency measures It also is possible that routine accountability mea include nonroutine measures taken to prevent the sures for protecting SNM may be co~npromised by the degradation of conditions that could result in a reduc sudden and unexpected movement, removal, or altera tion or loss of materials protection if not controlled or if tion of SNM or SNM records. E~fective emergency left untreated. Postemergency measures are taken to measures that replace or supplement routine materials protect and account for SNM following events during protection measures and are implemdnted in accordance which its protection may have been compromised.

with established emergency plannihg procedures can enhance the protection of materials in the following c. NATURAL EVENT means a condition that results manner: from natural causes such as severe weather conditions, floods, and earthquakes.

a. The likelihood of theft will b* reduced. Measures taken io limit access to SNM and tof provide surveillance d. NUCLEAR EVENT means a condition resulting over an area in which an emergenc* situation exists will from a nuclear accident such as the sudden release of tend to deter an individual from ngaging in unautho radiatic" 'As in a criticality incident).

rized or illegal acts.

'0- IONAL EVENT means a condition re b. Theft of special nuclear material can be detected. s11' fire, equipment failure, injury to personnel, Emergency and postemergency measures can control and oi and contamination from SNM or other document the movement, removal,! or alteration of SNM raujsoactive material following a spill or process mal and the quantities involved. function, false alarm, or the functional loss of part of the materials protection system.

c. The amount of damage to or accidental loss of SNM may be reduced, thereby frther improving the 4. Emergency Materials Protection System likelihood that a theft will be detected. Emergency materials protection measures for locating and identify An emergency materials protection system, as with ing an emergency condition, tr~nsmitting emergency any security system, consists of detection, communica information to responsible individuals, and taking tion, and response elements (human or automatic),

actions necessary to protect material can minimize the which together constitute a workable system. The failure extent of damage to or accidental loss of SNM. or any one of these elements to function constitutes a system failure.

d. The capability for recovering stolen material is improved. Emergency monitoring and postemergency Warning of an impending or imminent emergency can assay and accountability measures can help to recon be obtained from (1) detection measures based on struct the event, thereby aiding recovery of material. sensors that automatically activate alarms or otherwise alert individuals that an emergency exists, (2) instru e. If potential nonroutine conditions are thoroughly ments that monitor normally varying conditions, and (3)

considered in the initial planning and established emer surveillance of emergency indicators by either remote gency operating measures are followed, a facility can be devices or direct observation. Such warning could operated under certain nonroutine conditions without include indications of severe weather conditions, pro jeopardizing the -protection of SNM. cesses that are out of control with respect to tempera ture or pressure, buildup of SNM approaching criticality

3. Definitions limits, or the release of radioactive materials. Appro priate sensors may detect among other things, radiation, For the purpose of this guide, the following defini temperature changes, motion, interruption or alteration tions are provided: of an electric current, and electromagnetic changes. An emergency also may be detected by remote observation a. NONROUTINE EVENT means any condition that with the aid of closed-circuit television (CCTV) monitors

.*ters the approved features of a facility, the equipment, or by direct observation by an individual at the scene.

or the method of operation such that the requirements for materials protectiun are threatened or are not being When an existing or imminent emergency condition is met. For example, a powei outage, damage to records, detected, individuals responsible for taking appropriate

5.30-2

actions must be notified. The actions taken by security bility to protect SNM requires immediate remedial personnel, plant management, and employees at the time measures if the materials are to be provided with of an emergency depend on the alarms and information continued protection.

that are transmitted to them. Emergency instructions and actions usually are based on signal transmissions by Identification of appropriate contingency measures wire or radio to visible and audible annunciating can be aided by consideration of the following non (warning) devices. Warnings and instructions also may be routine conditions:

relayed during an emergency by direct voice communica tion. a. Functional loss of SNM isolation measures such as access control devices for materials processing or storage The objectives of the response or emergency actions areas or remotely operated process or storage handling taken by individuals to deal with an emergency are, in equipment.

order of priority, (I) to protect the health and safety of the general public and of individuals at the plant, (2) to b. Need for access by maintenance, installation, or assure overall security and protection of materials, (3) to construction personnel not authorized to have access to assure that all SNM is accounted for, and (4) to SNM and not normally permitted to work in a materials reestablish routine materials protection procedures as access area.

soon as possible.

c. Reduced capability to inspect or test for com In protecting the safety and lives of individuals, pliance with requirements for processing, storing, trans measures taken to evacuate personnel, administer first ferring, measuring, or protecting SNM. This could be a aid, and protect personnel from radiation hazards also result, for example, of process or equipment changes or can help to protect SNM. The rapid deployment of the relocation.

guard force and other emergency security personnel can assure continued materials protection during and follow d. Compromise of keys, locks, or combinations to ing an emergency. Emergency actions by an emergency locks that are used to secure SNM or SNM account supervisor and by trained technical support personnel ability records.

can assure a rapid assessment of the location, condition, and amount of SNM affected by the emergency, thereby e. Functional loss of personnel or package searching aiding postemergency actions and the resumption of devices installed at passage points in the physical routine materials protection-procedures.

barriers.

5. Temporary Operation Under Nonroutine Conditions f. Failure of remote surveillance equipment.

Following a natural, operational, or nuclear event that results in a temporary loss of part of a materials g. Unavailability of dock facilities normally used for protection system, it may be desirable to continue isolating shipments and receipts of SNM or for isolating operation (cleanup, production in unaffected areas, etc.) SNM from other materials.

of the facility on a temporary basis, provided the facility or equipment is properly designed to accommodate h. Failure of the intrusion alarm protection system.

emergency measures adequate for the protection of material during such periods. Operating in such a i. Loss of offsite communication capability at the condition also might be desirable during periods of plant central alarm station.

construction, alteration, or equipment changes.

j. Commingling of SNM assigned to different mate Whenever a system functions under conditions for rial balance areas (MBAs) as a result of loss of which it was not designed, the possibility of component identification or undocumented movement of SNM

malfunction increases. In such cases a system failure can bearing materials.

be averted by a fail-safe design and by proper action of individuals. k. Loss of automatic data processing capability for control and accounting of SNM:

Nonroutine conditions may occur as a result of modification of process equipment and plant design, 1. Reduced vault storage capacity that may be caused, changes in operating or maintenance procedures, or the for example, by a spill of radioactive material.

temporary loss of portions of the materials protection system (detection, communication, or response ele The materials protection measures that would apply ment). to nonroutine operations are emergency substitutes for normal requirements. Operation under these measures Some nonroutine operating conditions may not be are intended to proceed only during a temporary loss of recognized as emergencies. However, any loss of capa- routine protection capability.

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C. REGULATORY POSITION

c. In the event of failure of a sensor :r other instrumentation, parameters that had been monitored by k.a,*uip or special measures and actions that can be the failed device should be visually monitored ;,)y direct taken to help assure the continued protection of SNM

or remote means unless a redundant sensor is available to during an emergency or threatened emergency are monitor the parameter.

described below. For each component of the normal materials protection system the failure mode that may

2. Communication Measures result from fire, explosion, criticality, or contamination (either accidental or deliberate) should be identified. To The following guidelines constitute emergency mea provide protection, the backup measure for each system sures that are acceptable to the Regulatory ;taff for component should be invulnerable to the event that transmitting warning or alert signals and for communi caused the failure of that component. cating during and after a reported emergency.

Emergency materials protection measures that affect a. Signals that indicate when and where an emer activities in material access areas may, in some, cases, gency condition exists should be a fail-safe, tamper impact on necessary safety measures. If prescribed resistant design and should include both visible and emergency materials protection measures (e.g., evacua. audible annunciating devices. Transmission and annun tion to a supervised assembly area or surveillance of ciator equipment should conform to Interim Federal rescue vehicles) would place individuals in further Specification W-A-00450B(GSA-FSS) dated February jeopardy, health and safety considerations1 take prece 16, 1973, entitled "Alarm Systems, Interior, Security, dence. Further, if prescribed materials protection mea 3 Components For."

sures are less stringent than other requirements (as, for example, health and safety requirements or local build b. Tamper-resistant annunciators should be located in ing codes) the more stringent requirements should apply. at 'I two places within a material access area such that th, -an be seen and heard by supervisory and operating

1. Detection Aids personini whose actions may be needed to protect

.i or to avert an imminent emergency that could The following guidelines constitute measures accept .ompromise the protection of material. Additional able to the Regulatory staff for detecting actual or annunciators for all emergency signals should be located potential conditions that would compromise routine at the continuously manned central alarm station.

materials protection measures.

c. Onsite one-way communications consisting of a a. Reports from offsite severe-weather warning or plant-wide public-address system and portable battery meteorological services should be used for predicting powered megaphones should by available for relaying adverse weather conditions that could compromise instructions to evacuating and evacuated personnel.

materials protection. If a natural event that can jeopar dize the protection of SNM is predicted, all SNM in d. At the time of an emergency, telephone usage process, to the extent practicable, should be placed in should be restricted to essential messages having to do containers, sealed and locked in vaults, or located in with the emergency.

other areas that will provide protection from theft and from physical damage that could reduce the effective e. In addition to systems required for communica ness of postemergency procedures. (See also Regulation tion with local law enforcement authorities, 4 communi Position C.5, "Postemergency Materials Accountability cation by telephone or radio should be available to Measures.") notify key off-duty company personnel (to provide additional security, supervisory, technical support, or

.b. Sensors should be installed to detect conditions of cleanup personnel, as needed to protect or account for temperature, pressure, shock, release of radioactive SNM). A backup communication capability, e.g., desig materials, and interruption of vital services and equip nation of an offsite, duty officer (supplied with company ment that could precipitate an emergency with a transportation) who would be contacted by the law potential effect on the protection of SNM. (Although enforcement agency, should be available for contacting written for a different purpose, IEEE Standard key individuals in the event of a general telephone

279-19712 contains useful guidance for the installation outage.

of sensorsin Section 3, Items 3-6.)

f. Security plans with local law enforcement agency

1Other regulatory guides that deal with emergency plans to authorities should provide for periodic "check-in" pro protect the health and safety of workers and the general public from accidental radioactivity releases are under development. cedures and should assure that an inability of the

2 3 IEEE Standard 279-1971, "Criteria for Protection Systems for Copies may be obtained from the Standardization Nuclear Power Ge'"-rating Stations." Copies may be obtained Division, Federal Supply Service, General Services Administration, from the Institute of Electrical and Electronics Engineers, Inc.. Washington, D.C. 20406.

345 East 47th Street, New York, New York 10017 4 Paragraph 7 3.50(e)(3) of 10 CFR

Part 73.

5.30-4

authorities to communicate with the continuously State, or Federal agencies. Offsite organizations may manned central alarm station will be treated by the include local law enforcement authorities, fire depart authorities as a call for assistance. Contacts or liaison meats, AEC personnel, State health departments, hospi with local law enforcement authorities should include tals, and ambulance and rescue services.

utilization of intelligence-gathering groups for possible warning or to aid in the recovery of stolen material. b. Emergency Access Control

(1) Records of persons granted access to material

3. Personnel Control access areas prior to, during, and after an emergency should be secured and maintained for later analysis.

The following guidelines constitute emergency mea (2) Measures should be taken to protect or pro surFs that are acceptable to the Regulatory staff for vide backup for required intrusion detectors 6 so that all controlling access to SNM during or following an exits from and entrances to an evacuated material access emergency. area can be closed, locked, and alarmed. If not alarmed, such areas should be kept under continuous direct or a. Evacuation remote visual surveillance.

(1) All personnel should be instructed and drilled (3) Construction materials should be available on in the salient features of the emergency materials site for making emergency repairs to breaks in the protection plan. Since the plan may be quite complex physical barriers.

and repetitive, an abstract, memo, manual, or list of (4) Access to evacuated material access areas rules should be published and distributed to all em should be restricted to authorize security, supervisory, ployees and visitors. In addition, key instructions for emergency materials protection, and rescue personnel in individual areas within the plant should be posted in accordance with established emergency procedures.

conspicuous locations. (5) Emergency keys or lock combinations neces

(2) If consistent with personnel health and safety sary for emergency personnel should be stored in considerations, emergency rendezvous areas shouldkbe/ tamper-resistant, alarmed enclosures and should be located within the protected area. changed whenever there is reason to believe such an

(3) Personnel who are evacuated from a facility enclosure may have been compromised. (Disadvantages because of an emergency should leave according to of master keyed. locks is discussed in another regulatory established plans and routes with a minimum of travel guide. 7 )

througK material access areas. Emergency exit routes from a Material access area'should avoid passage through c. Surveillance other material access areas.

(4)i Personnel evacuated from or through a mate (1) Emergency lighting from an alternative or rial access area should be under surveillance wherever secondary power source should be provided to all material access areas to provide illumination sufficient possible is they are being evacuated, should be kept under surveillance after they are evacuated, and should for surveillanceg during periods when the normal light ing system -is inoperative. If an area-wide power failure rendezvous at a single predetermined location until would disrupt the secondary power supply, battery dismissed or instructed to return to work. Such person powered floodlights designed to activate automatically if nel should be identified from area access control records and accounted for.

5 the normal lighting system fails should be installed throughout the material access area in a manner that

(5) Emergency exits from the protected area provides general illumination of not less than 0.2 should be designed to allow continuous visual surveil foot-candle. 9 In addition, all security personnel should lance of evacuating personnel during evacuation.

be provided with portable battery-powered spotlights.

(6) Areas where individuals assemble following an evacuation should be clear of obstructions that would All battery-powered lights should be provided with a provide concealment such as buildings, fences, trees, or signal light to warn of weak batteries.

shrubbery and should be restricted from public access. (2) Planning should include, as appropriate, the use of portable CCTV equipment to survey and to

(7) All persons and vehicles leaving a protected monitor activites in a material access area following an area or emergency rendezvous area should be assumed to emergency in which sensors or other monitoring equip bear concealed SNM and should be accompanied by ment have become inoperative and conditions exist that supervisory or security personnel until circumstances make extended occupancy hazardous.

allow a search to be conducted. 5 Personnel requiring offsite medical attention should not be exempted.

6

(8) If an emergency situation cannot be con Paragraph 73.60(c) of 10 CFR Part 73.

trolled adequately with the available onsite manpower, 7 Regulatory Guide 5.12, "General Use of Locks in the Protec additional off-duty company personnel should be called tion and Control of Facilities and Special Nudear Material."

in or support should be obtained from offsite local, 8 Regulatory Guide 5.14, "Visual Surveillance of Individuals in Material Access Areas."

5 9 See also Regulatory Guide 5.7, "'Control of Personnel Access to Local safety codes may require higher levels of illumination to Protected Areas. Vital Areas. and Material Access Areas." assure safe evacuation.

5.30-5

(3) Additional security or guard personnel should ware and tools removed from a material access area be called in or other qualified plant personnel should be should be examined for SNM. and all personnel should designated to support the regular security personnel as be searched for concealed SNM. 13 ,k needed for performing backup guard functions, surveil (4) To provide for temporary handling of both lance, and materials protection for a material access area shipments and receipts of SNM in the same dock area, that is threatened or affected by an emergency. physical separation should be provided between the

(4) All emergency vehicles (company-owned or dock platforms and material storage areas at the dock.

owned by an offsite organization) that are brought into Storage areas should be designed with clear space a protected area and are used for the transfer of sufficient to accommodate operations normally done on equipment or personnel to or from a material access area the dock e.g., removal of outer packaging, gross measure during or following an emergency should be under ment check, seal verification. etc.

continuous surveillance by supervisory or security per (5) Process equipment in which in situ measure sonnel while within the protected area. If surveillance ments or in situ calibration of instruments is normally has not been continuous, exiting vehicles and any performed should be designed with provisions for individuals therein should be accompanied until both emergency access and working space to utilize alterna can be searched for concealed SNM. tive or duplicate sampling, measuring, and calibrating equipment or devices.

4. Nonroutine Operation b. Protection System Component Failure The following guidelines constitute measures that are acceptable to the Regulatory staff for assuring continued Continuous direct visual surveillance by security or protection of SNM while a plant or process is tempo supervisory personnel or other backup measures should rarily operating under nonroutine conditions which be provided for all materials security devices, the could otherwise reduce the protection afforded by operability or required level of performance of which routine materials protection measures. cannot be verified.

(1) Whenever changes in process operations, a. Necessary Nonroutine Operation equipment design, or equipment location can reduce normal inspection and testing capability, special design While certain nonroutine operations may be desir features and operating procedures implemented must be able (particulary cleanup after a natural or nuclear consistent with approved license amendments. 14 To aid emergency), extensive use of emergency measures can implementation and approval, duplicate or equivalent not justify long-term operation in noncompliance with backup measuring and testing devices may be provided.

10

AEC rules, regulations, license conditions, or orders. Also, use of calibrated nondestructive assay equipment,

(1) The design of automated or remotely operated or procedures which call for a partial shutdown for equipment for processing, transporting, or storing SNM sampling, special calibration of instruments, or obtaining should provide for access to equipment, as allowed by physical measurements, may be substituted for normal safety considerations, to facilitate removal or draindown in-line or dynamic inventory measurements. Equipment of SNM. Manual operations or maintenance to equip also may be designed with supplemental viewing and ment that may permit access to SNM should be inspection ports or openings that can take the place of performed within controlled material access areas by primary access ports blocked owing to changes in individuals authorized to have access to SNM. equipment design or location.

(2) Material access areas should be designed with (2) Provisions for manual searches or backup sufficient clearance to permit the installation of tempo monitoring equipment should be available in the event rary physical barriers to isolate areas that might require of temporary malfunction of equipment routinely used postemergency cleanup or other nonroutine activities by to search individuals, packages, and vehicles exiting from personnel who are not authorized access to SNM. If material access areas. Equipment normally in use at two deductive surveillanceI I is to be utilized for activities in different control points may serve as backup for one such "isolated" areas, the area should be separated from another, provided either control point can be deacti other areas by barriers equivalent to those normally vated (blocked, locked, and alarmed) when not properly

12 required for material access areas. equipped.

(3) Where possible, SNM should be removed from (3) Backup equipment should be available for process equipment and accounted for before any non monitoring all waste streams for SNM. When not in use, routine activites are undertaken in that area. All hard this equipment should be stored in an area physically separated from primary monitoring equipment.

0

lpagraphs 70.32(c) and 70.32(t) of 10 CFR Part 70. (4) Backup capability for surveillance of material I lSee Regulatory Guide 5.14, "Visal Surveillance of Indivi processing or storage areas should be provided in the duals in Material Acces Areas." event of failure of an intrusion alarm or remote visual

12 parapgaph 73.2(0 of 10 CFR Part 73. (Standards for Barrier 13 pa:fiqraph 73.60(b) of 10 CFR Part 73.

Construction are the subject of a regulatory guide under development.) 14Paragraph 70.32(b) of 10 CFR Part 70.

5.30-6

surveillance system. This backup may be a redundant remote surveillance until needed for inventory and SNM

intrusion alarm system and/or a capability for con accountability.

tinuous on-location visual surveillance by security or b. Control and Docutmentation supervisory personnel who can communicate with the (1) Emergency exits should be designed so that continuously manned ceniral alarm station. they may be used temporarily to replace normal access

(5) Security, supervisory, or authorized operating or exit control points. Inoperative access points should personnel such as storage or vault custodians should be barricaded or locked and, in either case, they should provide continuous direct surveillance of any normally be alarmed consistently with requirements for material locked or secured process or storage area for periods acces areas. 16 Direct visual surveillance should be when keys are lost or unaccounted for, locks are maintained over any unalarmed, though inoperative or damaged, or lock combinations are compromised. This unused, access points (emergency as well as normal surveillance should be continued until all affected locks access points).

are replaced or until lock combinations are changed by (2) Solid, liquid, and gaseous effluents from a

7 authorized security or management personnel. material access area normally must be monitored to

17 detect and measure SNM that may be released.

5. Postemergency Materials Accountability Measures Retention ponds and tanks should be provided as necessary to allow monitoring of liquid effluents from emergency-related activities such as fire fighting and The following guidelines constitute actions that are decontamination.

acceptable to the Regulatory staff for assuring continued (3) The location of all SNM in a facility should be materials control and accounting following an emer determined as soon as possible after an emergency to gency. assure continued surveillance and access control of such material. Temporary material access areas or boundaries should be established in the event that SNM must be a. Accounting moved or barriers removed during or as a result of an

(1) Emergency measures should assure the integ emergency.

rity of material accountability records so that a valid (4) Nondestructive assay equipment should be postemergency material balance can be made following available to assist in timely verification of SNM content conditions in which the identification of SNM items may of materials that may have been spilled, moved, or have been lost or obliterated, SNM may have been altered during an emergency.

relocated to another material balance area (MBA) (5) If SNM that is not in process cannot be without adequate transfer records, or equipment that protected because of temporary loss of normal vault or may have contained SNM has been removed. storage capability, emergency measures should be taken When SNM has been relocated to another area, a to assure that security and accountability requirements temporary MBA should be established that encompasses are met. Temporary storage areas should be designated both the original area and the new area. This temporary and should be physically separated from process or other MBA should be physically identified with suitable material access areas with a temporary isolation barrier markings or barriers. All SNM within the temporary that can be kept under continuous direct surveillance by MBA should be physically inventoried and new records security personnel or by an authorized vault custodian.

obtained and reconciled with the preemergency records. If other areas approved for SNM storage are available, Measurements should be of sufficient quality that the material should be relocated to these areas and afforded uncertainty of the postemergency inventory is no greater the full protection routinely required of SNM (access than the uncertainty of the preemergency records. New control, intrusion alarms, surveillance, etc.). While SNM

separate MBAs with material transfer stations, custo is being relocated to temporary storage, sealed con dians, and records may be necessary for SNM (or tainers should not be opened unless there is reason to equipment containing SNM) that is relocated for post suspect that seals have been compromised. Unsealed emergency cleanup or recovery. containers of SNM should be identified, sealed, and

(2) If electronic data processing is used for SNM listed before beinf relocated. All relocated containers control and accounting. a master file should be main should be locked7 (either individually or in a larger tained which can be updated from a log of transactions container with others) to physically isolate them from processed subsequent to the last updating of the file. A individuals who are authorized to have access to mate capability for the manual recording of data 15 normally rials normally assigned to the temporary storage area.

entered automatically may also be desirable. Similarly, SNM normally assigned to the area should be

(3) As soon as possible after an emergency all locked or otherwise protected from individuals who are SNM control records should be accounted for and placed authorized to have access to the relocated material.

in locked storage or kept under continuous direct or

16 paragraph 73.60(c) of 10 CFR Part 73.

15 Regulatory guides dealing with material control and account 1

7Paragraph 70.22(b)(1) of 10 CFR Part 70.

ing records are under development.

5.30-7

When normal vault or other storag capability has been illicitly truasferred to another container to aid laser restored and the material is returned from temnporar removal.

storage, the integrity of each seal should be verified.l 8 (7) ADl Mesureos taken to protect SNM during an

(6) lIn the event the relocated SNM has not been emtergency, whether In accordance with established conatin uously isolated while in temporary storap or if there is reason -to suspect that a meal has been corn emergecy -b or a departure forom such plans, sbouM

be documented. This should include, where fwbe", a promised., all suspect and unsealed packages at that record of instructions &me and actions taken and storage location, whether believed to contain SNM or should include interviews with individuals who wee in not. should be opened if necessary and the contents the material access area immlediately prior to the remeasured to verify that no SN&4 has been stolen or emergency. These records should be reviewed for post.

accident or postemrgerncy anabysis of posible dehlberte

18 Regulatory Guide 5.15, "Sectutty Seal for the Protection and cause and for modifying emnergecy procedures as Control or Specia Nuclear Matmial." appropriate.

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