Regulatory Guide 5.59

Standard Format and Content for a Licensee Physical Security Plan for the Protection of Special Nuclear Material of Moderate or Low Strategic Significance

ML12187A706
Person / Time
Issue date:	01/10/1980
From:	Minogue R B Office of Nuclear Regulatory Research
To:
References
DG MP 711-4 RG-5.059
Download: ML12187A706 (65)

0, UNITED STATESNUCLEAR REGULATORY COMMISSIONWASHINGTON, D. C. 20555January 10, 1980REGULATORY GUIDE SUBSCRIPTION LIST (DIVISION 5)Draft Regulatory Guide MP 711-4, "Standard Format and Content for a Licensee PhysicalSecurity Plan for the Protection of Special Nuclear Material of Moderate or LowStrategic Significance," was issued for public comment in July 1979. The purpose,of the guide is to identify the information needed by the staff in its review oflicensees' physical security plans for protection of special nuclear material ofmoderate or low strategic significance and to provide an acceptable format for itssubmission. In addition, the guide provides information on the intent of the variousprovisions of amendments to Part 73 of the Commission's regulations published July 24,1979, as an aid to the licensee in developing the plan.Since the draft guide was issued for public comment, the Commission has identifieda need for additional clarification of the intent of portions of these amendments.Accordingly, some changes were made in Chapters 1 and 2 of Parts I and II of thisguide to fulfill this need. Chapter 1 was expanded to better define the controlledaccess areas where the material will be used or stored. Chapter 2 was revised toclearly explain what is meant by 73.67(a)(2) "... early detection and assessment ofunauthorized access or activities by an external adversary within the controlledaccess area..." and "... early detection of removal of special nuclear material byan external adversary from a controlled access area." The section in Chapter 2 onintent was expanded to explain how detection devices or procedures could be used toprovide early detection against theft of various types of SNM of moderate or lowstrategic significance.Comments on regulatory guides are encouraged at all times, but comments on the abovechanges in Chapters 1 and 2 of Parts I and II will be particularly helpful to theNRC staff in evaluating the need for an early revision to this guide.Robert B. Minogue, DirectorOffice of Standards Development January 1980U.S. NUCLEAR REGULATORY COMMISSIONREGULATORY GUIDEOFFICE OF STANDARDS DEVELOPMENTTask MP 711-4REGULATORY GUIDE 5.59STANDARD FORMAT AND CONTENTFOR A LICENSEE PHYSICAL SECURITY PLANFOR THE PROTECTION OF SPECIAL NUCLEAR MATERIALOF MODERATE OR LOW STRATEGIC SIGNIFICANCEUSNRC REGULATORY GUIDESRegulatory Guides are issued to describe and make available to thepublic methods acceptable to the NRC staff of implementingspecific parts of the Commission's regulations, to delineate tech-niques used by the staff in evaluating specific problems or postu-lated accidents or to provide guidance to applicants. RegulatoryGuides are not substitutes for regulations, and compliance withthem Is not required. Methods and solutions different from those setout in the guides will be acceptable if they provide a basis for thefindings requisite to the issuance or continuance of a permit orlicense by the Commission.Comments and suggestions for improvements in these guides areencouraged at all times, and guides will be revised, as appropriate,to accommodate comments and to reflect new information orexperience. This guide was revised as a result of substantive com-ments received from the public and additional staff review.Comments should be sent to the Secretary of the Commission;U.S. Nuclear Regulatory Commission, Washington, D.C. 20555,Attention: Docketing and Service Branch.The guides are issued in the following ten broad divisions:1. Power Reactors 6. Products2. Research and Test Reactors 7. Transportation3. Fuels and Materials Facilities 8. Occupational Health4. Environmental and Siting 9. Antitrust and Financial Review5. Materials and Plant Protection 10. GeneralCopies of issued guides may be purchased at the current GovernmentPrinting Office price. A subscription service for future guides in spe-cific divisions Is available through the Government Printing Office.Information on the subscription service and current GPO prices maybe obtained by writing the U.S. Nuclear Regulatory Commission,Washington, D.C. 20555, Attention: Publications Sales Manage TABLE OF CONTENT

S. INTRODUCTION

..........................................................PART I SPECIAL NUCLEAR MATERIAL OF MODERATE STRATEGICSIGNIFICANCE ................................................Chapter 1 USE AND STORAGE AREA AT A FIXED SITE .......................1.1 Area Where Material Is Used ............................1.2 Area Where Material Is Stored ..........................Chapter 2 DETECTION DEVICES AND PROCEDURES AT A FIXED SITE ...........2.1 Earliness of Detection ...................... ..........2.2 Detection Through Monitoring of Controlled AccessA reas ................................................Chapter 3 ACCESS CONTROL AT A FIXED SITE .............................3.1 Preauthorization Screening .............................3.2 Badging System .........................................3.3 Lock System ............................................3.4 Personnel Entry Control System .........................3.5 Escort System ..........................................3.6 Search .................................................Chapter 4 SECURITY ORGANIZATION AT A FIXED SITE ......................Chapter 5 COMMUNICATIONS AT A FIXED SITE .........................Chapter 6 RESPONSE PROCEDURES AT A FIXED SITE ........................Chapter 7 MATERIAL TRANSPORTATION REQUIREMENTS .......................7.1 Advance Notification ................................7.2 Receiver Confirmation ..................................7.3 Container ..............................................Page17881114141517171818192020222324252526267.4 Inspection .................................... 26Chapter 8Chapter 97.5 Responsibility for In-Transit Physical Protection..RECEIVER REQUIREMENTS--TRANSPORTATION ..................8.1 Inspection .........................................8.2 Notification .......................................8.3 Responsibility for In-Transit Physical Protection..IN-TRANSIT PHYSICAL PROTECTION REQUIREMENTS ............9.1 Communications .....................................9.2 Minimum Transit Times ..............................2728282829303031-Iii TABLE OF CONTENTS9.3 Preauthorization Screening .............................9.4 Response Procedures ....................................9.5 Notification ..... .............................9.6 Lost Material Notification .............................Chapter 10 EXPORT REQUIREMENTS .......................................Chapter 11 IMPORT REQUIREMENTS .......................................11.1 Security Requirements ...............................11.2 Notification ........................................PART II -SPECIAL NUCLEAR MATERIAL OF LOW STRATEGIC SIGNIFICANCE .......Chapter 1 USE AND STORAGE AREA AT A FIXED SITE .......................1.1 Areas for Use and Temporary Storage ....................1.2 Areas for Permanent Storage ............................Chapter 2 DETECTION DEVICES AND PROCEDURES AT A FIXED SITE ...........2.1 Earliness of Detection............................2.2 Monitoring of Controlled Access Areas ..................Chapter 3 SECURITY RESPONSE AT A FIXED SITE ..........................Chapter 4 RESPONSE PROCEDURES AT A FIXED SITE ........................Chapter 5 MATERIAL TRANSPORTATION REQUIREMENTS .......................5.1 Advance Notification ...................................5.2 Receiver Confirmation ..................................5.3 Container ..............................................5.4 Inspection ............................. ...............5.5 Responsibility for In-Transit Physical Protection ......Chapter 6 RECEIVER REQUIREMENTS--TRANSPORTATION ......................6.1 Inspection .............................................6.2 Notification ...........................................6.3 Responsibility for In-Transit Physical Protection ......Chapter 7 IN-TRANSIT PHYSICAL PROTECTION REQUIREMENTS ................7.1 Response Procedure .....................................7.2 Notification ........... .......................7.3 Lost Material Notification .............................Page31323232343535353637373942424348495050515151515353535355555556iii TABLE OF CONTENTSPageChapter 8Chapter 9EXPORT REQUIREMENTS ........................................IMPORT REQUIREMENTS ........................................9.1 Security Requirements ...........................9.2 Notification ...........................................57585858iv INTRODUCTIONThe Atomic Energy Act of 1954, as amended, directed the U.S. AtomicEnergy Commission (AEC) to regulate the receipt, manufacture, production,transfer, possession, use, import, and export of special nuclear material(SNM) in order to protect the public health and safety and to provide forthe common defense and security. The Energy Reorganization Act of 1974transferred all the licensing and related regulatory functions of the AECto the Nuclear Regulatory Commission (NRC).The principal requirements with respect to the physical protection oflicensed activities against industrial sabotage and with respect to the phys-ical protection of special nuclear material in transit are found in 10 CFRPart 50, "Domestic Licensing of Production and Utilization Facilities,"Part 70, "Domestic Licensing of Special Nuclear Material," Part 73, "Phys-ical Protection of Plants and Materials," and Part 110, "Export and Importof Nuclear Equipment and Materials."Paragraph 50.34(c) of.lO CFR Part 50 and paragraphs 70.22(g), 70.22(h),and 70.22(k) of 10 CFR Part 70 identify the physical protection informationthat must be provided in a Physical Security Plan as part of a license appli-cation. This plan is required in order for the applicant to demonstratecompliance with the specific physical protection requirements of 10 CFRPart 73 and must be submitted with each application for a license to possessor use SNM (or for a license authorizing transport or delivery of SNM), exceptfor a license to possess, use, or transport less than 10 kg of SNM of lowstrategic significance, in which case a physical security plan is not required.However, for the protection of SNM of low strategic significance, the licenseeis required to meet the requirements of §73.67, "Licensee Fixed Site andIn-Transit Requirements for the Physical Protection of Special Nuclear Mate-rial of Moderate and Low Strategic Significance," of 10 CFR Part 73.This regulatory guide describes the information required in the physicalsecurity plan submitted as part of an application for a license to possess,use, or transport SNM of moderate strategic significance or 10 kg or moreof SNM of low strategic significance and recommends a standard format forpresenting the information in an orderly arrangement. This standard formatwill thus serve as an aid to uniformity and completeness in the preparationand review of the physical protection plan of the license application. Thisdocument can also be used as guidance by licensees possessing or transportingless than 10 kg of SNM of low strategic significance in understanding theintent and implementing the requirements of paragraphs 73.67(a), 73.67(f),and 73.67(g) of 10 CFR Part 73.Aside from providing guidance for the standard format and content ofphysical security plans, this regulatory guide explains the intent of thevarious provisions of the regulation. The intent of each requirement isfound in the discussion of each subsection and is implicitly provided byoutlining alternative systems that could be used to fulfill the requirements.The discussion section and list of alternatives should provide the licenseewith the sense of the NRC regulations.This guide is divided into two parts. Part I, "Special Nuclear Materialof Moderate Strategic Significance," provides a standard format for preparingthe licensee's security plans and provides guidance to licensees who possess,1 use, or transport SNM of moderate strategic significance. Chapters 1 through6 of Part I apply to applications for a license to possess or use at anyfixed site, or at contiguous sites subject to contrQl by the licensee, SNMof moderate strategic significance. Chapters 7 through 11 of Part I applyto applications for authorization to transport or deliver to a carrier fortransport SNM of moderate strategic significance.Part II, "Special Nuclear Material of Low Strategic Significance," pro-vides a standard format for preparing the licensee's security plan for licenseeswho possess, use, or transport more than 10 kg of SNM of low strategic signif-icance. It also provides guidance to all licensees who possess, use, ortransport SNM of low strategic significance. Chapters I through 4 of PartII apply to applications for a license to possess or use at any fixed site,or at contiguous sites subject to control by the licensee, more than 10 kgof SNM of low strategic significance. Included in this category are licenseeswho have nuclear power reactors under construction and are seeking a licenseto possess nuclear fuel onsite prior to obtaining their operating license.Chapters 5 through 9 of Part II apply to applications for authorization totransport or deliver to a carrier for transport more than 10 kg of SNM oflow strategic significance.Table 1 shows the type and amount of SNM covered in §73.67 of 10 CFRPart 73. It should be noted, as stated in the footnote to Table 1, that(1) plutonium with an isotopic concentration exceeding 80% or more in Pu-238,(2) special nuclear material'that is not readily separable from other radio-active material and that has a total external radiation dose rate in excessof 100 rems per hour at a distance of 3 feet from any accessible surfacewithout intervening shielding, and (3) sealed plutonium-beryllium neutronsources totaling 500 grams or less of contained plutonium at any one siteor contiguous sites are exempt from the requirements of §73.67 of 10 CFRPart 73.This guide has been prepared to minimize lost time attributable toincomplete physical security plans and to standardize the review process.The applicant is encouraged to prepare his physical security plan in accord-ance with this guide and to provide information in each section to supportthe conclusion that he will be able to operate in accordance with the perti-nent regulations. Although conformance with this guide is not required,the format and content presented are acceptable to the NRC staff.As developments and changes in the nuclear industry occur, the Commis-sion's requirements for information may need modification; revisions to thisguide will be made as necessary to accommodate these changes.Purpose and ApplicabilityThis standard format has been prepared as an aid to uniformity and com-pleteness in the preparation and review of the physical protection sectionof license applications and to clarify the intent of the regulations. Theinformation this guide contains will help the licensee plan a physical pro-tection system designed to detect the theft of SNM of moderate or low strat-egic significance. The physical protection subsystems identified are thosewhich will usually be included in a protection system that would normallybe capable of meeting the performance requirements of paragraph 73.67(a) of2 TABLE 1CATEGORIES OF SPECIAL NUCLEAR MATERIALMODERATE STRATEGIC LOW STRATEGICMATERIAL* ENRICHMENT SIGNIFICANCE SIGNIFICANCE1. Plutonium2. Uranium-235Less than 2,000 g but morethan 500 gLess than 5,000 g but morethan 1,000 g20% or more inU-235 isotope10% or more butless than 20%in U-235 isotopeAbove naturalbut less than10%500 g or less but morethan 15 g1,000 g or less butmore than 15 gLess than 10,000 g butmore than 1,000 g10,000 g or more10,000 g or more3. Uranium-2334. Uranium-235,uranium-233,and pluton-ium in 'com-binationU-235 portionenriched to 20%or more.Less than 2,000 g but morethan 500 gLess than 5,000 g accordingto the formula: grams =(grams contained U-235) +2.5 (grams U-233 + gramsplutonium) but more than1,000 g according to theformula: grams = (gramsU-235) + 2.0 (grams U-233+ grams plutonium)500 g or less but morethan 15 g1,000 g or less accordingto the formula: grams =(grams contained U-235) +2.0 (grams U-233 + gramsplutonium) but morethan 15 g according tothe formula: grams =grams contained U-235 +grams U-233 + gramsDlutonium.*The following materials are exempt:1. Special nuclear material that is not readily separable from the radioactive material andthat has a total external radiation dose rate in excess of 100 rems per hour at a distanceof 3 feet from any accessible surface without intervening shielding,2. Plutonium with an isotopic concentration of 80% or more in Pu-238, and3. Sealed plutonium-beryllium neutron sources totaling 500 grams or less of contained plutoniumat any one site or contiguous site CFR Part 73. However, it is recognized that at any particular site theremay be some subsystems and components not needed or additional ones neededto meet these performance requirements. In these cases, the applicant isencouraged to address in the license application specific departures of sub-systems or components from this guide.The information requested in this guide is the minimum needed for thereview of a physical security plan. Additional information may be requiredfor completing the staff review of a particular plan and should be includedas appropriate. It is also the applicant's responsibility to be aware ofnew and revised NRC regulations. The information provided should be up todate with respect to the state of technology for the physical protectiontechniques and systems that the applicant proposes to use.In cases where NRC-approved security plans are already in existenceand where the measures included therein meet or exceed the requirements of§73.67 of 10 CFR Part 73, the licensee may reference in his proposed securityplan those sections of the NRC-approved security plan that are applicable.Information and procedures delineated in the regulatory guides in Divi-sion 5, "Materials and Plant Protection," that are appropriate to certainsections of the physical security plan may be incorporated by reference.The applicant should discuss his plans and programs with the NRC staffbefore preparing the application. This discussion should give particularemphasis to the depth of information required for the plan.Upon receipt of an application, the NRC staff will perform a preliminaryreview to determine whether the application provides a reasonably completepresentation of the information needed to form a basis for the findingsrequired before issuance of a license. The standard format will be used bythe staff as a guideline for identifying the type of information needed.If an application does not provide a reasonably complete presentation ofthe necessary information, further review of an application will be suspendeduntil this needed information is provided.Use of the Standard FormatThe applicant should follow the numbering system of the Standard Formatdown to the level of section (e.g., 3.4). Under some circumstances, certainsections may not be applicable to a specific application. If so, this shouldbe clearly stated and sufficient information should be provided to supportthat conclusion.The applicant may wish to submit in support of his application informa-tion that is not required by regulations and is not essential to the descrip-tion of the applicant's physical protection program. Such information couldinclude, for example, historical data submitted in demonstration of certaincriteria, discussion of alternatives considered by the applicant, or supple-mentary data regarding assumed models, data, or calculations. This informa-tion should be provided as an appendix to the application.Upon completion of the application, the applicant should use the Tableof Contents of the Standard Format as a checklist to ensure that each subjecthas been addresse Style and CompositionA table of contents should be included in each. submittal.The applicant should strive for clear, concise presentation of informa-tion. Confusing or ambiguous statements and general statements of intentshould be avoided. Definitions and abbreviations should be consistent through-out the submittal and consistent with generally accepted usage.Wherever possible, duplication of information should be avoided. Thus,information already included in other- sections of the applications may becovered by specific reference to those sections.Where numerical values are stated, the number of significant figuresshould reflect the accuracy or precision to which the number is known. Theuse of relative values should be clearly indicated.Drawings, diagrams, and tables should be used when information may bepresented more adequately or conveniently by such means. These illustrationsshould be located in the section where they are first referenced. Care shouldbe taken to ensure that all information presented in drawings is legible,that symbols are defined, and that drawings are not reduced to the extentthat they cannot be read by unaided normal eyes.Physical Specifications of SubmittalsAll material submitted in an application should conform to the followingphysical dimensions of page size, quality of paper and inks, numbering ofpages, etc.:1. Paper SizeText pages: 8-1/2 x 11 inches.Drawings and graphics: 8-1/2 x 11 inches preferred; however, a largersize is acceptable provided the finished copy when folded does not exceed8-1/2 x 11 inches.2. Paper Stock and InkSuitable quality in substance, paper color, and ink density for handlingand for reproduction by microfilming.3. Page MarginsA margin of no less than one inch is to be maintained on the top, bottom,and binding side of all pages submitted.4. PrintingComposition: text pages should be single spaced.Type face and style: must be suitable for microfilmin Reproduction: may be mechanically or photographically reproduced.All pages of the text may be printed on both sides, and images shouldbe printed head to head.5. BindingPages should be punched for looseleaf ring binding.6. Page NumberingPages should be numbered by section and sequentially within the section.Do not number the entire report sequentially. (This entire'StandardFormat has been numbered sequentially because the individual chapterswere too short for sequential numbering within each section to bemeaningful.)7. Format ReferencesIn the application, references to this Standard Format should be bypart, chapter, and section numbers.Procedures for Updating or Revising PagesThe updating or revising of data and text should be on a replacementpage basis.The changed or revised portion of each page should be highlighted by avertical line in the margin opposite the binding margin for each line changedor added. All pages submitted to update, revise, or add pages to the reportshould show the date of the change. The transmittal letter should includean index page listing the pages to be inserted and the pages to be removed.When major changes or additions are made, pages for a revised table of contentsshould be provided.Number of CopiesThe applicant should submit the appropriate number of copies of eachrequired submittal pursuant to §70.21, "Filing," of 10 CFR Part 70.Public DisclosureThe NRC has determined that the public disclosure of the details ofphysical protection programs is not in the public interest, and such detailsare withheld pursuant to paragraph 2.790(d) of 10 CFR Part 2. Thus the phys-ical protection section of each application should be submitted as a separateenclosure. Other proprietary and classified information should be clearlyidentified and submitted in separate enclosures. Each such submission ofproprietary information should be accompanied by the applicant's detailedreasons and justifications for requesting exemption from public disclosureas required in paragraph 2.790(b) of 10 CFR Part PART ISPECIAL NUCLEAR MATERIALOF MODERATE STRATEGIC SIGNIFICANCE7 1. USE AND STORAGE AREA AT A FIXED SITEThis chapter provides guidance on meeting the requirements of paragraphs73.67(d)(1) and (d)(2), which are as follows:(d)(1) Use the material only within a controlled access area which isilluminated sufficiently to allow detection and surveillance ofunauthorized penetration or activities.*(d)(2) Store the material only within a controlled access area such as avault-type room or approved security cabinet or their equivalentwhich is illuminated sufficiently to allow detection and surveil-lance of unauthorized penetration or activities.*A controlled access area (CAA) is defined in paragraph 73.2(z) as "anytemporarily or permanently established area which is clearly demarcated,access to which is controlled and which affords isolation of the materialor persons within it." "Access control" means measures used to allow onlyspecified personnel, materials, and vehicles ingress into and egress from agiven area, while "isolation" refers to measures taken to deter persons,materials, or vehicles from entering or leaving a given area through otherthan established access control points. Thus, a controlled access areaincludes provisions for both isolation and access control. In some cases,isolation or access control systems may also serve the purpose of aiding inthe detection of unauthorized penetration or activities* within the CAA.Therefore these detection-related considerations are alluded to in thischapter.In the discussion that follows, CAAs intended for use and the possiblestorage of SNM of moderate strategic significance are discussed separatelyfrom those intended solely for the storage of such SNM. Although the require-ments for these two different applications of CAA are in most respects similar,it is recognized that the means used to isolate the material and controlaccess may differ markedly *for use areas compared with storage areas andtherefore warrant separate discussion.1.1 Area Where Material Is Used [73.67(d)(1)]IntentThis section discusses CAAs intended primarily for the use bf SNM ofmoderate strategic significance. These may be temporarily established tomeet transitory or intermittent SNM use requirements or they may be perma-nently established. Permanently established CAAs for use of SNM may alsobe suitable for storage. "Use" means that the material is undergoing pro-cessing (e.g. fuel fabrication, irradiation in a reactor, etc.) or utiliza-tion of its properties in conjunction with experimental equipment (e.g.,research or educational laboratory experiments). Different isolation/accesscontrol measures may be used for periods during which the area is occupiedversus unoccupied.Unauthorized activities are those activities deemed by the licensee to beindicative of or contributory to the possible theft of SN Illumination sufficient to allow detection and surveillance of unauthor-ized penetration or activities within the CAA where the material is usedneed not require the use of high-intensity lightiog throughout the CAA.What is intended is the use of normal lighting sufficiently uniform through-out the CAA to ensure that material or unauthorized personnel cannot besecreted in a darkened area until a time more convenient for the unauthorizedremoval of the material. For those facilities where experiments must beconducted in a darkened room, the lighting requirement is exempted for aslong as is needed provided access control is ensured and the material isaccounted for at the end of the experiment.a. Temporarily Established CAAsTemporarily established CAAs for the use of SNM need not have permanentbarriers at their boundaries. Isolation of the material and persons usingthe material may be provided by office partitions, cordons, or other devicesused to warn passersby of the restricted nature of the area. Access controlcan be effected through surveillance or supervision of the area by thosewho are using the SNM and who are responsible for the material. However,the provision of access control through personal supervision is suitableonly for those situations in which the size of the CAA and the number ofpersons to be admitted are sufficiently small and in which the CAA issuitably configured to make such procedures practical.When material located in a temporarily established CAA is to be leftunattended (i.e., because it is impractical to replace the material in aCAA designed for long-term storage of the material), access control andimproved isolation for the temporary CAA may be provided to substitute forthe discontinued personal supervision over the material. (In addition, pro-visions must be made for satisfying the monitoring requirement of paragraph73.67(d)(3).) Improved isolation can sometimes be provided by increasingthe penetration resistance of existing barriers (e.g. , locking doors andwindows, placing the material in a locked drawer or supply room, etc.).Access control may be provided by any of the measures suggested below forpermanently established CAAs left unattended; some of these suggestions maybe more suitable for temporary use than others. If no suitable barrier isavailable to provide isolation, material left unattended can be protectedby a motion alarm covering the area immediately surrounding the material.This improved detection capability would be considered an acceptable sub-stitute for the rudimentary isolation provided by temporary barricades,cordons, signs, and other less substantial means of isolation that may beused on a temporary basis.b. Permanently Established CAAsPermanently established CAAs for the use and temporary storage of SNMof moderate strategic significance would most likely provide isolation forthe SNM through the use of permanent barriers. These could consist of fences;gates or freestanding walls for exterior areas; or exterior or interior build-ing walls, locked doors, windows, bars, grillwork; or other barriers forinterior areas. Such barriers are not required to meet the more stringentcriteria for physical barriers used for the protection of formula quantities9 of strategic special nuclear material (SSNM).* However, good security manage-ment practice would dictate that the barrier be substantial enough to-detercasual passersby from unauthorized penetration. If the barriers are alsodesigned to aid in detection, the criteria for penetration resistance ortamper-indication in accordance with the specific monitoring procedures tobe used also apply.Access control for permanently established CAAs during periods theyare occupied can be provided by personal supervision. However, when theseareas are unoccupied or when the size, configuration, or numbers of personsintended to be admitted to the area make personal supervision impractical,other means of access control may be called for. Some of the additionalaccess control measures that may be used for permanently established CAAs**in these situations are:* Stationing of a watchman at CAA access control points,Limiting distribution of keys, keycards, or combinations to doorsand gates,Using a coded badging system to identify authorized personnel atCAA access control points,Controlling locked CAA doors and gates by use of remote surveillance(e.g., via intercom or CCTV) by personnel stationed at a centrallylocated access control facility, orControlling access of personnel, material, and vehicles into CAAsby other means.It is expected that large facilities will have more complex isolationand access control systems than small facilities in order to achieve compar-able levels of protection.Content(This section needs to be completed only for CAAs designated exclusivelyfor use of SNM. CAAs designated for both use and storage are to be describedas recommended in Section 1.2 of this Standard Format.)Describe the CAAs designated exclusively for use of the material. Indi-cate under what conditions CAAs will be established on a temporary basis.For each CAA identified, provide the following information:1. A description of the area and its features relative to other facil-ity features, showing the normal routes of ingress to each CAA (including ascale diagram)."Strategic special nuclear material" means uranium-235 (contained in uraniumenriched to 20 percent or more in the U-235 isotope), uranium-233, or plutonium.Access control requirements for CAAs for the use or storage of SNM of moderatestrategic significance are discussed in Chapter 3 of Part I of this guide.10 2. Descriptions of physical barriers, cordons, walls, partitions, orother means of providing isolation of the CAA and channelling entry throughestablished access control points into the CAA.3. The means and criteria used for controlling access into the CAAat established access control points.4. If more than one CAA is designated, indicate the types of materialnormally used in each CAA; for temporarily established CAAs, indicate thetypes of activities normally performed within each area.5. The lighting level and uniformity of lighting provided to allowdetection and surveillance of unauthorized penetration or activities withinthe CAA or in the immediate vicinity of the CAA.1.2 Area Where Material Is Stored [73.67(d)(2)]IntentControlled access areas normally used only for storage of SNM are describedin this section. Such CAAs may be very limited in size, since they needonly contain the material itself, and access to them is expected to be infre-quent. Where small amounts of material are involved, the CAA may consistof relatively small containers such as security cabinets, safes, and lockedclosets or supply rooms.The same basic isolation and access control* capabilities that applyto CAAs for the use of SNM of moderate strategic significance also apply toCAAs for the storage of this material. However, the CAA for storage is, inaddition, specifically required to be equivalent to either an approved securitycabinet or a vault-type room. This additional requirement embodies a tradeoffdecision to be made by the licensee between the capability for immediatedetection of penetration attempts into a vault-type room and the improvedpenetration resistance likely to be provided by an approved security cabinet.A vault-type room is defined in paragraph 73.2(o) of 10 CFR Part 73 as"a room with one or more doors, all capable of being locked, protected byan intrusion alarm which creates an alarm upon the entry of a person anywhereinto the room and upon exit from the room or upon movement of an individualwithin the room." The vault-type room can be a locked laboratory, supplyroom, closet, or other room equipped with a tamper-resistant motion detectoralarm system. The motion detector would simultaneously satisfy the monitor-ing requirement of paragraph 73.67(d)(3) addressed in the next chapter.The expression "equivalent to a vault-type room" means that a piece of equip-ment (such as a fission chamber, reactor core, or storage rack), even thoughit does not resemble a "room," may meet the requirement for a storage-typeCAA if there is a means of isolation (e.g., a locked grill, inaccessibilitybeneath water as in a storage pool, intricate and time-consuming proceduresrequired for removal) and it is protected with a tamper-resistant motiondetection system. Note that in some cases, material located in such piecesof equipment may be considered in use rather than in storage. In this case,Access control requirements for CAAs for the use or storage of SNM of moderatestrategic significance are discussed in Chapter 3 of Part I of this guide.11 whether the material is being personally supervised or not, the requirementfor use of a motion detection system to satisfy the monitoring requirementis removed, and other monitoring devices or procedures may be used instead.When a container equivalent to an approved security cabinet is chosento satisfy paragraph 73.67(d)(2), the equivalency is based upon the penetra-tion resistance of the container and the difficulty associated with manipula-tion of the lock. The basic premise used to determine whether such a con-tainer may be monitored by procedures or devices other than a motion detectoris whether it is unreasonable to expect that an external adversary couldpenetrate the container in a reasonable amount of time without leaving anindi'cation of the penetration. The amount of time that would be requiredfor penetration without such an indication may be used to govern the fre-quency of patrols when monitoring procedures are used. An approved securitycabinet or its equivalent is one whose design has been certified by theGeneral Services Administration or other nationally recognized standardsorganization (e.g., ANSI) to afford protection against surreptitious entryand lock manipulation equivalent to that provided by a Class-6 GSA ratingor better.Isolation for CAAs intended only for storage usually will be providedby the penetration resistant features of the perimeter barriers or containerwalls of the CAA. The level of penetration resistance of such barriers isnot required to meet the more stringent criteria for physical barriers usedto protect formula quantities of strategic special nuclear material (SSNM).Rather, the physical barriers or container walls of the CAA are intendedonly to deter penetration by unauthorized persons and to aid detection byproviding an indication of forced penetration.In determining the level of isolation/access control required for suchCAAs, the time required for extricating SNM from its storage location inrelationship to the licensee's time of detection and assessment may be takeninto account (e.g., spent fuel assemblies stored in spent fuel storage poolsor fuel residing in nonpower reactor cores).Examples of typical CAAs where special nuclear material of moderatestrategic significance may be stored are:1. Vault. A structure that satisfies the definition for a vault asstated in paragraph 73.2(n) would provide more than adequate isolationprotection.2. Approved Security Cabinets. Those cabinets that are designed toprovide delay and resistance against surreptitious entry and lock manipulation.3. Reactor. Reactors that are so designed that removal of materialis difficult.4. Vault-Type Room. Some typical vault-type rooms where materialsare stored and protected with a motion detector are storage pools, a roomcontaining in-process storage racks, and laboratories where material is leftunattended. In all cases, movement in the near vicinity of the material orof the material itself generates an alarm signal.12 5. Locked Laboratories, Supply Rooms. These areas must be sufficientlypenetration resistant to afford a means of isolation/access control and permitthe proper functioning of the system for monitoring the storage area asrequired by paragraph 73.67(d)(3) of the rule as described in Part I, Chapter 2.The illumination level required for the CAA should be sufficiently uniformand bright (a) in the case of a security cabinet, to detect penetration ofor tampering with the CAA containment or (b) in the case of a vault-typeroom or its equivalent, to detect unauthorized penetration of or activitieswithin the CAAContentDescribe the CAAs where the material will be stored and, in some cases,used. For each such CAA, provide the following information:1. A description of the area and its features relative to other facil-ity features showing the access control points for the CAA (including a scalediagram).2. The isolation system such as physical barriers, container walls,or other features which demarcate the perimeter of the CAA and channel entryonly through established access control points.3. The means and criteria used for controlling access to the CAA atestablished access control points.4. If more than one CAA is designated for the storage of the material,the types of material normally to be stored in each area.5. The lighting level and uniformity of lighting provided to allowdetection and surveillance of unauthorized penetration or activities withinthe CAA, or in the immediate vicinity of the CAA (where security cabinetsare used).13

-~ nrTl-PTTALI r~rir,'rr AkIfl nnAf'rniInr~- AT A rr~,rr, CTT~e. UAVNDE3 PlIU rMIUEUUEI- l1 +/-AEU 31IEThis chapter provides guidance for meeting the.requirement of paragraph73.67(d)(3), which is as follows:(d)(3) Monitor with an intrusion alarm or other device or procedures thecontrolled access areas to detect unauthorized penetrations oractivities.The purpose of this monitoring activity as stated in paragraph 73.67(a)(2)is to provide "early detection and assessment of unauthorized access or activ-ities by an external adversary within the controlled access area..." andearly detection of removal of special nuclear material by an external adversaryfrom a controlled access area." This should be done to achieve the objectiveof minimizing the possibilities for unauthorized removal of special nuclearmaterial "consistent with the consequences of such actions," as stated inparagraph 73.67(a) of the effective rule. Thus the earliness of detection-afforded by the licensee's physical protection system may vary dependingupon the nature and quantity of the material susceptible to unauthorizedremoval. Further discussion of the earliness of detection required forpossible thefts of different types and quantities of special nuclear materialof moderate strategic significance is provided in Section 2.1.2.1 Earliness of Detection [73.67(a)]Determination of early detection of unauthorized access, activities,or removal of special nuclear material.from controlled access areas will bebased on an assessment of the magnitude of the consequences associated withpossible misuse of the type and quantity of material that could be removedin a given theft attempt. For special nuclear material of moderate strategicsignificance, two distinct cases are considered:1. Theft of strategic special nuclear material (SSNM).*2. Theft of low-enriched uranium (LEU).**Thefts from a single facility of SSNM in quantities of moderate strategicsignificance are limited by definition to quantities that could not be usedto construct a nuclear explosive device; thefts of similar quantities ofmaterial from several different facilities could, however, lead to the accu-mulation of an aggregate quantity that would permit such illicit use. (Theconsequences of a single theft of such material would have minimal impacton the public health and safety). Therefore, detection of such thefts isrequired sufficiently early to ensure early notification to the NRC so thatthe NRC in turn can notify other licensees of the need to implement appro-priate responses to prevent the accumulation by a single adversary of aformula quantity of material through multiple thefts from different facil-ities. The NRC believes that there are detection systems and proceduresIn this case, Strategic Special Nuclear Material means all SNM of moderatestrategic significance other than low-enriched uranium.Low-enriched uranium is.uranium enriched above natural percentages but lessthan 20% in the U-235 isotope.14 that would allow the licensee to detect a theft of SSNM within approximatelytwo hours.The criteria for early detection of thefts of LEU enriched to more than10%, but less than 20%, in the isotope U-235 are the same as for thefts ofLEU in quantities comprising SNM of low strategic significance. The readershould refer to Part II of this guide for information regarding appropriatemonitoring procedures to achieve early detection for such material.2.2 Detection Through Monitoring of Controlled Access Areas [73.67(d)(3)]IntentLicensees possessing quantities of SNM of moderate strategic significancecan provide a monitoring system capable of detecting a theft of materialwithin approximately two hours of the actual removal of the material. Eitherdetection devices or security procedures may be used to help detect unauthor-ized activities or penetration of CAAs. Most of the sites at which thismaterial is stored or used are likely to be small research-oriented facilitiessuch as non-power reactors and educational institutions. At such facilitiesthere are likely to be relatively small quantities of SNM available, andauthorized access to it may be infrequent.Detection devices such as interior motion detector systems, balancedmagnetic switches, etc. could be used to monitor such relatively small CAAs,where the number of established access control points is very limited.Security procedures may also be used to protect against thefts of quanti-ties of SNM of moderate strategic significance because watchman patrolsinherently allow unguarded intervals during which an external adversary couldconceivably obtain access to the CAA, remove a small quantity of material,and leave before being discovered. The inspection procedure may (a) be suffi-ciently frequent to ensure that an external adversary could not complete asuccessful theft of the material during the unguarded intervals, (b) providefor an indication of the CAA barrier having been tampered with (as with aseal or by observation of damage done to the barrier), or (c) provide foran item count inventory or other accounting for the material as part of theinspection. Some examples are given below:After having left material unattended in an experimental setup ina classroom used as a temporary CAA, the instructor returns afterseveral hours and verifies that the material is still in place.A small quantity of material is stored in a security cabinet forseveral months at a time without authorized access. Every twohours a watchman comes around to inspect the cabinet to ensurethat the lock is secure and the cabinet has not been tampered with.If a lockois used that is not designed to be resistant to surrepti-tious and forced entry, the watchman also inspects a tamper-indicatingseal to verify that the container has not been tampered with.During times a non-power reactor is left unattended, a watchmancomes around every two hours and checks that none of the fuel elementshave been removed by unauthorized persons. If he encounters a15 person working during off-hours in the vicinity of the non-reactor,he asks for appropriate identification.While a non-power reactor is being used, the supervisor ensuresthat he or his designee is not away from the reactor for a periodlonger than thirty minutes or a period he estimates would beminimally required for a person to obtain fuel elements in thecore that are not self-protecting by virtue of their having beensufficiently irradiated.During periods when excess fuel is left unattended in a storagecloset at a non-power reactor facility, an alarm system is activ-ated that would annunciate if anybody tried to penetrate thecloset without proper authorization.During periods when the material is being used under the direct supervi-sion of authorized personnel, the monitoring requirement may be satisfiedby virtue of the continuous surveillance exercised by such personnel.ContentFor each of the CAAs designated for the protection of SNM of moderatestrategic significance, provide the following information regarding the meas-ures taken to fulfill the monitoring requirement of paragraph 73.67(d)(3):1. Describe any devices employed by specifying the type of device,its installed location, the type and location of annunciation, the intendedarea of coverage, and the tamper-resistant features. Refer, if desired, toexisting filed security plans or NRC-published guidance or NUREG seriesdocuments.2. Describe any procedures employed to monitor the CAA or portionsthereof, including the categories of persons who will execute the procedures,the frequency of inspections or rounds of patrol, the basis for the determina-tion of such frequencies, and the occasions when the procedures are intendedto be implemented. Indicate, also, the features of the CAA (e.g. barriers,locks, seals, etc.) that will affect the way the procedures are used.3. Explain how the combination of procedures and devices used tomonitor each CAA meets the criteria for early detection of theft by anexternal adversary relative to the type of material found in each CAA.16 3. ACCESS CONTROL AT A FIXED SITEThis chapter provides guidance on meeting the requirements of paragraphs73.67(d)(4), (d)(5), (d)(6), (d)(7), and (d)(1O), which are as follows:(d)(4) Conduct screening prior to granting an individual unescorted accessto the controlled access area where the material is used or stored,in order to obtain information on which to base a decision to permitsuch access,(d)(5) Develop and maintain a controlled badging and lock system toidentify and limit access to the controlled access areas toauthorized individuals,(d)(6) Limit access to the controlled access areas to authorized orescorted individuals who require such access in order to performtheir duties,(d)(7) Assure that all visitors to the controlled access areas are underthe constant escort of an individual who has been authorizedaccess to the area,(d)(1O) Search on a random basis vehicles and packages leaving the con-trolled access areas.An access control system is one that controls access to or egress froma CAA through normal routes for personnel, materials, or vehicles.3.1 Preauthorization Screening [73.67(d)(4)]IntentThe intent of the requirement for preauthorization screening is toensure that the licensee will have sufficient knowledge of an individual todetermine his reliability and need for access prior to granting him authorizedaccess to the CAA where the material is used or stored. The selection ofprocedures for conducting this examination and the criteria he employs tomake his judgments are the responsibility of the licensee and, of course,should be consistent with all local, State, and Federal laws and regulationsregarding the protection of the privacy and other rights of the individual.The screening process may be conducted in the same manner as other investiga-tions customarily conducted by potential employers for similarly sensitivepositions. There is no requirement for the licensee to arrange for an NRCclearance or similar clearance from any other government organization.Examples of procedures and criteria that may be employed in the screeningprocess include holding or having recently held a government-sanctionedclearance; examination of past employment or educational records (to deter-mine any unsatisfactory employment or school actions or incidents that wouldindicate any unreliability or previous breaches of trust between the indi-vidual and his employer); endorsements or references from previous employers,teachers, or colleagues that would support *a decision for granting accessor that would attest to the trustworthiness and reliability of the individual;and consideration of the individual's present employment record indicatingdemonstrated trustworthiness and reliability over an extended period of17 employment with the licensee. (This may be considered in the nature of"grandfathering.")ContentDescribe the procedures and criteria that will be used for obtainingsufficient information prior to making a decision on granting unescortedaccess authorization to an individual to CAAs where the material is used orstored. Identify the types of individuals who will be screened (e.g., pro-cess engineers, supervisory personnel, professors, instructors, graduatestudents) and who will perform the screening process.3.2 Badging System [73.67(d)(5)]IntentThe purpose of the badging system is to facilitate the identificationof authorized individuals and the control of access to or within the CAAwhere the material is used or stored. Information on the badge should besuch that it is possible to clearly distinguish personnel authorized foraccess to the CAAs from those requiring an escort. Information on the badgeshould also uniquely identify the individual possessing the badge. Thispersonalized information can be obtained through the use of photographs,personal vital statistics, signatures, or any means the licensee may wishto use that will uniquely identify the individual.ContentDescribe the badging system used to facilitate control of access tothe CAAs. This description should include:1. The size, shape, color, material, and construction of badges.2. The distinguishing features of the badge that identify authorizedindividuals from escorted individuals.3. How the badges will be used for controlling access. (For example,will all individuals be checked prior to entering the CAAs, will periodicchecks be made of individuals within a CAA to determine if they are author-ized or under escort, or will the badge itself permit authorized entrance,e.g., a card key.)4. The system used for issuing, controlling, and accounting for thebadges.3.3 Lock System [73.67(d)(5)]IntentLocks used to control access to CAAs should be resistant to manipulationor picking and should not be mastered. Examples of typical lock systemsthat fit this description are three-position dial-type combination locks,six-pin key locks, and card-key lock systems. The procedures for assigningkeys and combinations to individuals is an integral part of the lock systemand should be designed to ensure that only authorized personnel have access18 to such items. Locks and combinations should be changed when informationis obtained that the lock system may have been compromised. Further informa-tion may be obtained in Regulatory Guide 5.12, "General Use of Locks in theProtection and Control of Facilities and Special Nuclear Material."ContentDescribe the locking system used to control access to the CAAs wherematerial is used and stored. This description should include locations ofall locks included in the system by type of lock, the pick-resistant andmanipulation-resistant characteristics of each lock type used, personnelresponsible for issuing keys or combinations and changing combinations orlocks, criteria for changing combinations or locks, personnel authorized tobe given keys or combinations, and descriptions of types of locks used(references may be made to Regulatory Guide 5.12 for this purpose).3.4 Personnel Entry Control System [73.67(d)(6)]IntentThe success of other access control system components, such as preauthori-zation screening, badging, and lock control, is dependent upon effectivecontrol of personnel access into the CAA. Physical access may be controlledin a number of different ways depending upon the actual configuration ofthe CAA and other site specific factors. Some examples of these alternativesare:1. Control by Authorized Person. If the area to be controlled issufficiently small and free of obstructions, an authorized person performingother activities in a CAA may effect physical access control by monitoringentry of unauthorized persons into the area. A sign posted at the entrancewould help deter casual passersby. A typical application of this approachwould be the case of a laboratory instructor conducting a class in which heis familiar with each of his students and could easily recognize unauthorizedpersons not in the class.2. Card-Key, Cipher, Combination, or Key-Lock Control System. A moresophisticated hardware-oriented system involves the use of a card-key, cipher,combination, or key-lock system. Physical access control *in this case consistsof the use of physical barriers to deter unauthorized persons. A limitednumber of entrances that are controlled by authorized personnel using a cardkey, cipher, combination, or key are provided. This system may be more usefulwhen larger numbers of authorized personnel who would not necessarily befamiliar with one another need to share the use of the CAA.3. Control by Security Organization. If security organization personnelare available, physical access control may be accomplished by stationing aperson at the entrance to the CAA to check identification and allow onlyauthorized persons into the CAA. This alternative may be unjustifiablyexpensive unless the security organization member's salary can be justifiedon other grounds as well. A variation of this system requires persons seekingentrance to the CAA to obtain a key from a properly designated person orsecurity organization for each use.19 ContentDescribe the system for limiting physical access to each CAA identifiedin Sections 1.1 and 1.2 of Part I to authorized personnel or those escortedby authorized personnel. Include in this description the names or titlesof individuals granting access authorizations, the criteria to be used ingranting authorizations, and the procedures used to ensure that only author-ized or properly escorted persons are allowed access to the CAA. Referencecan be made to Sections 3.1, 3.2, 3.3, 3.5, and 3.6 of this chapter as theyapply to this section for the description of locks, barriers, or otherhardware that are used to control access.3.5 Escort System [73.67(d)(7)]IntentThe requirement that an escort system be established is in recognitionof the fact that the licensee may wish to allow access to certain personsor classes of persons on a temporary or infrequent basis or on short notice,thus making the routine process for granting access authorizations impracticalor inexpedient. Typical arrangements for escorted access may include escortsfor maintenance or repair personnel, laboratory classes, public tours, guests,and visitors as required.ContentDescribe the system that will be used to escort individuals in the CAAs.In his security plan, the licensee should ensure that only properly authorizedindividuals will be allowed to escort individuals. This description shouldinclude:1. Criteria to be used for granting escorted access,2. Criteria to be used for escorting others,3. Procedures for escorting individuals into CAAs (e.g., studentsunder supervision of lab instructor, public tours),4. The number of escorted individuals per escort, and5. The responsibilities of the escort (e.g. , periodic surveillanceof all individuals under escort, accounting for all material prior to leavingthe CAA, remaining in general area during the time unauthorized individualsare present).3.6 Search [73.67(d)(10)]IntentThe primary intent of the search requirement is to deter and possiblydetect attempted thefts of SNM. The search procedures developed by thelicensee should take into consideration the environs where the material isused or stored, the physical characteristics of the material itself, andthe frequency of accounting for the material. In some cases, this will20 require that all vehicles and packages leaving the CAAs be searched in arandom manner. The frequency of random searches should be determined bythe ease with which the material can be stolen and.the length of time itwould take to detect a theft. In other cases, only packages that equal orexceed the size of the material being used or stored would have to besearched, taking into consideration the difficulty with which the materialcould be broken into smaller more easily concealed parts.ContentDescribe the system to be used for randomly searching vehicles orpackages that leave the CAA. Include in the description information as to:1. The scope of the search. This should identify the criteria thatwill be used for searching vehicles and packages (e.g., whether all packagesand vehicles are subject to search or just those packages or vehicles thatare larger than the smallest configuration of material being used or stored).2. The randomness of the search. The scheme for selecting the packagesor vehicles to be searched should be identified (e.g., subjecting each packageor vehicle to a search, using a random number generator for determining whethera candidate package or vehicle is to be searched, searching a minimum percentageof all packages or vehicles leaving the CAA each day).21 4. SECURITY ORGANIZATION AT A FIXED SITEThis chapter provides guidance on meeting the requirements of paragraph73.67(d)(8), which states:(d)(8) Establish a security organization or modify the current securityorganization to consist of at least one watchman* per shift ableto assess and respond to any unauthorized penetrations or activ-ities in the controlled access areas.IntentThe intent of this requirement is to ensure that, in the event of asecurity incident, someone will be available to assess alarms or otherunauthorized penetrations or activities and, if warranted, notify the NRC,the local law enforcement authorities, and the responsible person in licenseemanagement. Early detection and notification of any missing material willhelp facilitate its prompt recovery. In some cases, the licensee may assignadditional duties to members of the security organization where procedure-oriented options are chosen to satisfy physical protection requirements (e.g.,periodic patrols and inspections of CAAs for storage of SNM). Security organ-ization members are not required to be fully dedicated full-time employeesof the licensee. They may include unarmed campus security personnel (watchmen),contract guards, members of the local law enforcement agency (if sufficientlyclose to the site), etc. No formal or comprehensive training program isrequired for security organization personnel. However, the licensee shouldbe prepared to demonstrate that each security person understands the particularduties assigned to him and is fully qualified and trained to perform them.ContentDescribe the security organization that will be responsible for assessingand responding to security incidents. Indicate the other responsibilitiesof the security organization such as:1. Conducting periodic physical security checks of CAAs,2. Maintaining liaison with the local law enforcement agency,3. Notifying the local law enforcement agency of any unauthorizedpenetrations or activities in the CAAs, and4. Notifying licensee management of any unauthorized penetrations oractivities in the CAAs.A "watchman" is defined in paragraph 73.2(d) of 10 CFR Part 73 as "an indi-vidual, not necessarily uniformed or armed with a firearm, who provides protec-tion for a plant and the special nuclear material therein in the course ofperforming other duties."'22 5. COMMUNICATIONS AT A FIXED SITEThis chapter provides guidance on meeting the requirements of paragraph73.67(d)(9), which states:(d)(9) Provide a communication capability between the security organiza-tion and appropriate response force.IntentThe intent of this regulation is to ensure that a communication capabil-ity exists between the licensee and the designated response force. It isimplied that, prior to setting up a communication capability, proceduresand responsibilities will have been established between the response forceand the licensee. (See Chapter 6, "Response Procedures," of Part 1.) Thetype of communication system chosen by a licensee should:1. Provide for full duplex voice communication capability,2. Be easily accessible to the licensee's security organization, and3. Be reliable and available for immediate use at any time.Some communication systems that would provide these capabilities are adedicated telephone system, a non-dedicated public telephone system, radio,or any combination thereof.Content/Describe the communication system that is used between the securityorganization and the appropriate response force. This description shouldinclude information on:1. Type of communication system,2. Location of voice terminals in relationship to CAAs,3. Availability of communication system on a 24-hour basis, and4. Reliability of communication system.23 6. RESPONSE PROCEDURES AT A FIXED SITEThis chapter provides guidance on meeting the requirements of paragraph70.67(d)(11), which states:(d)(11) Establish and maintain response procedures for dealing with threatsof thefts or thefts of such materials.IntentThe intent of this regulation is to help the licensee to identify thosesecurity incidents that could result in the loss of SNM of moderate strategicsignificance and to develop response procedures to prevent or reduce thelikelihood of such a loss. Some types of incidents that should be consideredand for which response procedures should be developed are:1. Situations that could possibly lead to theft of SNM (e.g., civilstrife),2. Discovery that the security system has been breached, and3. Discovery that some SNM is missing.ContentIdentify those events for which response procedures will be developed.Also, describe the type of response to be accomplished for each event identi-fied and the duties and responsibilities of the security organization andmanagement involved in the response. Ensure that the NRC will be notifiedimmediately in the event of theft or attempted theft of the material. Describewhat local law enforcement assistance is available, their response capabil-ities, and any agreements made with them to respond in the case of theft ofthe material.24 7. MATERIAL TRANSPORTATION REQUIREMENTSThis chapter provides guidance on meeting the requirements of paragraph73.67(e)(1), which are as follows:(e)(1) Each licensee who transports, exports, or delivers to a carrierfor transport special nuclear material of moderate strategic signif-icance shall:(i) Provide advance notification to the receiver of any plannedshipments specifying the mode of transport, estimated timeof arrival, location of the nuclear material transfer point,name of carrier and transport identification,(ii) Receive confirmation from the receiver prior to the commence-ment of the planned shipment that the receiver will be readyto accept the shipment at the planned time and location andacknowledges the specified mode of transport,(iii) Transport the material in a tamper-indicating sealed container,(iv) Check the integrity of the containers and seals prior to ship-ment, and(v) Arrange for the in-transit physical protection of the materialin accordance with the requirements of paragraph 73.67(e)(3)of this part unless the receiver is a licensee and has agreedin writing to arrange for the in-transit physical protection.7.1 Advance Notification [73.67(e)(1)(i)]IntentThe intent of this paragraph is to require the shipper to preplan thetransportation of material and inform the receiver of his plans prior toshipment. This is the first of the several transportation requirements thatwill allow the receiver to take delivery of the material as planned or tohelp ensure traceability of any missing material.ContentThe licensee should ensure in his security plan that, prior to eachshipment of material, the receiver will be notified of the impending shipmentand provided the following types of information:1. Mode of transport (e.g., truck, plane, train, or ship),2. Estimated time of arrival,3. Location where material is to be transferred to receiver,4., Name of carrier, and25 5. Transport identification (e.g., truck, train, or flight number;ship name).7.2 Receiver Confirmation [73.67(e)(1)(ii)]Intent,The intent of this requirement is that, prior to shipment, the shipperwill be assured that the receiver is ready to accept the shipment at theplanned time and location and has acknowledged the mode of transport.ContentDescribe what procedures will be used to ensure that shipment of mate-rial does not take place until the receiver acknowledges the planned shipmentand mode of transport and states that he will be ready to accept the shipmentat the planned time and location.7.3 Container [73.67(e)(1)(iii)]IntentThe intent of this requirement is to provide a mechanism or system thatwill help the receiver detect any tampering with the material's containerthat may have occurred during shipment. Regulatory Guide 5.15, "SecuritySeals for the Protection and Control of Special Nuclear Material," providesguidance in this area. Requirements for containers are contained in 10 CFRPart 71, and a summary report on approved containers is contained in NUREG-0383.*If the material is shipped in an exclusive-use carrier, it is acceptable toseal the carrier itself rather than each individual SNM container.ContentDescribe the types of seals that will be used to monitor the material'scontainer during transport.7.4 Inspection [73.67(e)(1)(iv)]IntentThe intent of this paragraph is to require the shipper to check theintegrity of the material container's seals just prior to shipment so thathe can be assured that they have not been compromised. Then, upon receiptof the shipment, if the receiver discovers that the container's integrityhas been compromised and the material is missing, the scope of the recoveryoperation can focus on the transportation route.ContentDescribe the procedures to be used to ensure that the integrity of thecontainers or seals is checked just prior to shipment.Copies of NUREG-0383, "Directory of Certificates of Compliance for Radio-active Materials Packages," may be obtained from the National TechnicalInformation Service, Springfield, Virginia 22161.26 7.5 Responsibility for In-Transit Physical Protection [73.67(a)(1)(v)]IntentThe intent of this paragraph is to make clear that the licensee shippingthe material is responsible for arranging for the physical protection ofthe material in transit if the receiver is not a licensee. If both the shipperand receiver are licensees, the shipper may allow the receiver to acceptthis responsibility wholly or in part, provided there is appropriate documen-tation specifying their respective responsibilities. Where no such documenta-tion exists, both the shipper and receiver are held jointly responsible.(See Section 8.3 in the next chapter.)ContentIn his security plan, the shipper should either acknowledge responsibil-ity for the in-transit physical protection of SNM of moderate strategic signif-icance or ensure that a written agreement from the receiver licensee hasbeen received in which the receiver accepts either full responsibility orshared responsibility for the in-transit physical protection of this materialin accordance with paragraph 73.67(e)(3) of 10 CFR Part 73.27 8. RECEIVER REQUIREMENTS--TRANSPORTATIONThis chapter provides guidance on meeting the requirements of paragraph73.67(e)(2), which are as follows:(e)(2) Each licensee who receives special nuclear material of moderatestrategic significance shall:(i) Check the integrity of the containers and seals upon receiptof the shipment,(ii) Notify the shipper of receipt of the material as required inSection 70.54 of Part 70 of this chapter, and(iii) Arrange for the in-transit physical protection of the materialin accordance with the requirements of paragraph 73.67(e)(3)of this part unless the shipper is a licensee and has agreedin writing to arrange for the in-transit physical protection.8.1 Inspection [73.67(e)(2)(i)]IntentThis requirement is intended to determine whether the material's con-tainer has been compromised enroute and whether any material has been removedso that immediate recovery procedures can be initiated if required.ContentDescribe the procedures to be used to ensure that the integrity of thecontainers and seals will be checked upon receipt of the shipment of material.8.2 Notification [73.67(e)(2)(ii)]IntentThis requirement is intended to:1. Ensure that knowledge of the current location of all SNM is avail-able, and2. Formally inform the shipper that the material has been received.ContentEnsure that a completed copy of standard-lorm NRC-741, "Nuclear MaterialTransaction Report," will be sent to the shipper within 10 days of receivinga shipment of material as required in §70.54 of 10 CFR Part 70.28'

8.3 Responsibility for In-Transit Physical Protection [73.67(e)(2)(iii)]IntentThe intent of this paragraph is to make clear that the licensee receiv-ing the material is responsible for arranging for the physical protectionof the material in transit if the shipper is not a licensee. If both theshipper and receiver are licensees, the receiver may allow the shipper toaccept this responsibility either wholly or in part provided there is appro-priate documentation specifying their respective responsibilities. Whereno such documentation exists, both the shipper and receiver are held jointlyresponsible. (See Section 7.5 in the preceding chapter.)ContentIn his security plan, the receiver should either acknowledge responsibil-ity for the in-transit physical protection of SNM of moderate strategic signif-icance or ensure that a written agreement from the shipper has been receivedin which the shipper accepts either full responsibility or shared responsibilityfor the in-transit physical protection of this material in accordance withparagraph 73.67(e)(3) of 10 CFR Part 73.29 9. IN-TRANSIT PHYSICAL PROTECTION REQUIREMENTSThis chapter provides guidance on meeting the requirements of paragraph73.67(e)(3), which are as follows:(e)(3) Each licensee, either shipper or receiver, who arranges for thephysical protection of special nuclear material of moderate strategicsignificance while in transit or who takes delivery of such materialfree on board (f.o.b.) the point at which it is delivered to acarrier for transport shall:(i) Arrange for a telephone or radio communications capability,for notification of any delays in the scheduled shipment,between the carrier and the shipper or receiver,(ii) Minimize the time that the material is in transit by reducingthe number and duration of nuclear material transfers and byrouting the material in *the most safe and direct manner,(iii) Conduct screening of all licensee employees involved in thetransportation of the material in order to obtain informationon which to base a decision to permit them control over thematerial,(iv) Establish and maintain response procedures for dealing withthreats of thefts or thefts of such material,(v) Make arrangements to be notified immediately of the arrivalof the shipment at its destination, or of any such shipmentthat is lost or unaccounted for after the estimated time ofarrival at its destination, and(vi) Conduct immediately a trace investigation of any shipmentthat is lost or unaccounted for after the estimated arrivaltime and report to the Nuclear Regulatory Commission asspecified in §73.71 and to the shipper or receiver as appro-priate. The licensee who made the physical protection arrange-ments shall also immediately notify the Director of the appro-priate Nuclear Regulatory Commission Inspection and EnforcementRegional Office listed in Appendix A of the action being takento trace the shipment.It is not the intent of these paragraphs to require that the responsiblelicensee for shipping SNM of moderate strategic significance ship the materialunder armed escort or in a specially designed carrier.9.1 Communications [73.67(e)(3)(i)]IntentThe primary intent Df this requirement is to ensure that the carrierwill notify the shipper or receiver of any changes in plans or delays inthe scheduled arrival of a shipment to its destination due to mechanicalbreakdown, adverse environmental conditions, public disorders, etc. The30 shipper or receiver can then decide whether or not to initiate response pro-cedures. It is not the intent of this regulation to require periodic check-in.Public telephone or full duplex voice radio are acceptable methods for meetingthe intent of this requirement.ContentDescribe the type of communication system and procedures to be used bythe carrier of SNM of moderate strategic significance for notifying the shipperor receiver of any change in plans or delays in arrival.9.2 Minimum Transit Times [73.67(e)(3)(ii)]IntentThis requirement is intended to have the shipper or receiver make areasonable effort to ship the material by the fastest and most direct methodpossible. It is not intended to require exclusive-use carriers or expensivemodes of travel.ContentDescribe the procedures and considerations that apply in the transporta-tion planning process to ensure that a determined effort will be made tominimize transit times.9.3 Preauthorization Screening [73.67(e)(3)(iii)]IntentThe intent of the requirement for preauthorization screening is to ensurethat the licensee will have sufficient knowledge of an individual to determinehis reliability and need for access prior to granting him authorized accessto the material in transit. The selection of procedures for conducting thisexamination and the criteria he employs to make his judgements are the respon-sibility of the licensee and, of course, should be consistent with all local,State, and Federal laws and regulations regarding the protection of the privacyand other rights of the individual. The screening process may be conductedin the same manner as are other investigations customarily conducted by poten-tial employers for similarly sensitive positions. There is no requirementfor the licensee to arrange for an NRC clearance or similar clearance fromany other government organization. Examples of procedures and criteria thatmay be employed in the screening process include holding or having recentlyheld a government-sanctioned clearance; examination of past employment records(to determine any unsatisfactory employment or incidents that would indicateany unreliability or previous breaches of trust between the individual andhis employer); endorsements or references from previous employers or colleaguesthat would support a decision for granting access or that would attest tothe trustworthiness and reliability of the individual; and consideration ofthe individual's present employment record indicating demonstrated trust-worthiness and reliability over an extended period of employment with thelicensee. (This may be considered in the nature of "grandfathering.")31 ContentDescribe the procedures that will be used for obtaining sufficientinformation prior to making a decision on granting unescorted access authoriza-tion to those licensee employees who will be directly involved in the transporta-tion or in the planning and movement control of the material. Identify bytitle or name those employees who will be screened and those who will performthe screening process.9.4 Response Procedures [73.67(e)(3)(iv)]IntentThe intent of this regulation is to help the licensee to identify thosetransportation incidents for Which he might expect to be notified and thatmight affect the security of the SNM in transit and to plan response proceduresfor such situations. For example, if the shipper is informed by the carrierthat adverse weather conditions have temporarily prevented further progressof the shipment, the licensee should inform the receiver of a new estimatedtime of arrival.ContentIdentify those events for which response procedures will be developed.Also, describe types of response to be accomplished for each event identifiedand the duties and responsibilities of members of the security organizationand management for dealing with the response. Ensure that the NRC will benotified immediately in the event of theft or attempted theft of the material.9.5 Notification [73.67(e)(3)(v)]IntentThe intent of this requirement is to ensure that the licensee responsiblefor the physical protection of SNM in transit will have a firm basis fordeciding whether or not to initiate response procedures in the event a shipmentbecomes overdue or is lost.ContentDescribe the arrangements and procedures that will be used for notifyingthe licensee who arranges for the physical protection of material in transitof the arrival of the shipment at its destination or of any such shipmentthat is lost or unaccounted for after the estimated time of arrival at itsdestination.9.6 Lost Material Notification [73.67(e)(3)(vi)]IntentThe intent of this requirement is to ensure that, in the event a ship-ment becomes overdue and no reasonable explanation has been received fromthe carrier regarding its status, a trace investigation will be conductedto locate the missing SNM. At this time, the NRC must be notified that theI32 material is missing and informed as to what steps are being taken to recoverthe missing material. Although the licensee is responsible for notifyingthe NRC of any missing material and to initiate and assist in the subsequentinvestigation, the law enforcement agencies bear 'the responsibility forphysically recovering the material.ContentDescribe what procedures will be used to trace any shipment that is.lost or has not arrived by the estimated arrival time. Ensure that all lo.stor missing material will be immediately reported to the appropriate NRCRegional Office along with what actions are being taken to trace the shipment,that the NRC will be notified as specified in § 73.71, "Reports of Unaccounted-for Shipments, Suspected Theft, Unlawful Diversion, or Industrial Sabotage,"and that the shipper or receiver, as appropriate, will also be notified.33 10 EXPORT REQUIREMENTSThis chapter provides guidance on meeting the requirements of paragraph73.67(e)(4), which reads as follows:(e)(4) Each licensee who exports special nuclear material of moderatestrategic significance shall comply with the requirements speci-fied in § 73.67(c), (e)(1) and (e)(3).Use Chapters 7 and 9 of this part to describe the security proceduresthat will be used to protect the material up to the point where the receiveraccepts physical protection responsibility for the shipment.34 11. IMPORT REQUIREMENTSThis chapter provides guidance on meeting the requirements of paragraph73.67(e)(5), which reads as follows:(e)(5) Each licensee who imports special nuclear material of moderatestrategic significance shall:(i) Comply with the requirements specified in § 73.67(c), (e)(2)and (e)(3), and(ii) Notify the exporter who delivered the material to a carrierfor transport of the arrival of such material.11.1 Security Requirements [73.67(e)(5)(i)]Use Chapters 8 and 9 of Part I of this Standard Format to describe thesecurity procedures that will be used to protect the material from the firstpoint where the shipment is picked up inside the United States.11.2 Notification [73.67(e)(5)(ii)]IntentThe intent of this requirement is to ensure that the exporter is noti-fied that the material has arrived safely.ContentDescribe the procedures to be used for notifying the exporter of thematerial that the shipment has been received.35 PART IISPECIAL NUCLEAR MATERIALOF LOW STRATEGIC SIGNIFICANCEI36 1. USE AND STORAGE AREA AT A FIXED SITEThis chapter provides guidance on meeting the requirement of paragraph73.67(f)(1), which is as follows:(f)(1) Store or use such material only within a controlled access area.A controlled access area (CAA) is defined in paragraph 73.2(z) as "anytemporarily or permanently established area which is clearly demarcated,access to which is controlled and which affords isolation of the materialor persons within it." "Access control" means measures used to allow onlyspecified personnel, materials, and vehicles ingress into and egress from agiven area, while "isolation" refers to measures taken to deter persons,materials, or vehicles from entering or leaving a given area through otherthan established access control points. Thus, a controlled access area includesprovisions for both isolation and access control. In some cases, isolationor access control systems may also serve the purpose of aiding in the detectionof unauthorized penetration or activities* within the CAA. Therefore, thesedetection-related considerations are also alluded to in this chapter.In the discussion that follows, CAAs intended for the use and possiblestorage of SNM of low strategic significance are discussed separately fromthose intended solely for the storage of such SNM. Although there is nodifference in the requirements for these two different applications of theCAA, it is recognized that the means used to isolate the material and tocontrol access may differ markedly for use areas compared with storage areasand therefore warrant separate discussion.1.1 Areas for Use and Temporary Storage [73.67(f)(1)]This section discusses CAAs intended primarily for the use and temporarystorage of SNM of low strategic significance. These may be temporarily estab-lished to meet transitory or intermittent SNM use requirements or they maybe permanently established. Permanently established CAAs for use of SNMmay also be used for storage for short intervals between periods of usage."Use" means that the material is undergoing processing (e.g. fuel fabrication,irradiation in a reactor, etc.) or utilization of its properties in conjunc-tion with experimental equipment (e.g., research or educational laboratoryexperiments). Different isolation/access control measures may be used forperiods during which the area is occupied versus unoccupied.a. Temporarily Established CAAsTemporarily established CAAs for the use of SNM need not have permanentbarriers at their boundaries. Isolation of the material and persons usingthe material may be provided by office partitions, cordons, or other devicesused to warn passersby of the restricted nature of the area. Access controlcan be effected through surveillance or supervision of the area by thosewho are using the SNM and who are responsible for the material. However,Unauthorized activities are those activities deemed by the licensee to beindicative of or contributory to the possible theft of SNM.37 Sthe provision of access control through personal supervision is suitableonly for those situations in which the size of the CAA and the number ofpersons to be admitted are sufficiently small and in which the CAA is suitablyconfigured to make such procedures practical.When material located in a temporarily established CAA is to be leftunattended (i.e. , because it is impractical to replace the material in aCAA designed for long-term storage of the material), access control andimproved isolation for the temporary CAA may be provided to substitute forthe discontinued personal supervision over the material. (In addition,provisions must also be made for satisfying the monitoring requirement ofparagraph 73.67(f)(2).) Improved isolation can sometimes be provided byincreasing the penetration resistance of existing barriers (e.g. , lockingdoors and windows, placing the material in a locked drawer or supply room,etc.). Access control may be provided by any of the measures suggested belowfor permanently established CAAs left unattended; some of these suggestionsmay be more suitable for temporary use than others. If no suitable barrieris available to provide isolation, material left unattended can be protectedby a motion alarm covering the area immediately surrounding the material.This improved detection capability would be considered an acceptable sub-stitute for the rudimentary isolation provided by temporary barricades,cordons, signs, and other less substantial means of isolation that may beused on a temporary basis.b. Permanently Established CAAsPermanently established CAAs for the use and temporary storage of SNMof low strategic significance would most likely provide isolation for theSNM through the use of permanent barriers. These could consist of fences;gates or freestanding walls for exterior areas; or exterior or interiorbuilding walls, locked doors, windows, bars, grillwork; or other barriersfor interior areas. Such barriers are not required to meet the more stringentcriteria for physical barriers used for the protection of formula quantitiesof strategic special nuclear material (SSNM).* However, good security manage-ment practice would dictate that the barrier be substantial enough to detercasual passersby from unauthorized penetration. If the barriers are alsodesigned to aid in detection, the criteria for penetration resistance ortamper-indication in accordance with the specific monitoring procedures tobe used also apply.Access control for permanently established CAAs during periods theyare occupied can be provided by personal supervision. However, when theseareas are unoccupied or when the size, configuration, or numbers of personsintended to be admitted to the area make personal supervision impractical,other means of access control may be called for. Some of the additionalaccess control measures that may be used for permanently established CAAsin these situations are:"Strategic special nuclear material" means uranium-235 (contained in uraniumenriched to 20 percent or more in the U-235 isotope), uranium-233, or plutonium.38 Stationing of a watchman at CAA access control points,Limiting distribution of keys, keycards, or combinations to lockson doors and gates,Using a coded badging system to identify authorized personnel atCAA access control points,Controlling locked CAA doors and gates by use of remote surveillance(e.g., via intercom or CCTV) by personnel stationed at a centrallylocated access control facility, orControlling access of personnel, material, and vehicles into CAAsby other means.It is expected that large facilities (e.g., fuel processing facilities)will have more complex isolation and access control systems than small facil-ities (e.g. , research facilities) in order to achieve comparable levels ofprotection.ContentDescribe the CAAs where the material will be used. Indicate under whatconditions CAAs will be. established on a temporary basis. State whethereach CAA will also be used for storage. For each CAA identified, providethe following information:.1. A description of the area and its features relative to other facil-ity features, showing the normal routes of ingress to each CAA (including ascale diagram).2. Descriptions of physical barriers, cordons, walls, partitions, orother means of providing isolation of the CAA, and channelling entry throughestablished access control points into the CAA.3. The means and criteria used for controlling access into the CAAat established access control points.4. If more than one CAA is designated, indicate the types of materialnormally used in each CAA; for temporarily established CAAs, indicate thetypes of activities normally performed within each area.1.2 Areas for Permanent Storage [73.67(f)(1)]IntentControlled access areas normally used only for storage of SNM aredescribed in this section. Such CAAs may be very limited in size, sincethey need only contain the material itself, and access to them is expectedto be infrequent. Where small amounts of material are involved, the CAAmay consist of relatively small containers such as security cabinets, safes,and locked closets or supply rooms.39 Isolation for CAAs intended only for storage usually will be providedby the penetration-resistant features of the perimeter barriers or containerwalls of the CAA. Such barriers and container walls are not required tomeet the more stringent criteria for physical barriers used for the protec-tion of formula quantities of SSNM. However, good security management prac-tice would dictate that the barrier be substantial enough to deter casualpassersby from unauthorized penetration. If the barriers are also designedto aid in detection, the criteria for penetration resistance or tamper-indicationin accordance with the specific monitoring procedures to be used alsoapply.In determining the level of isolation and access control for such CAAs,the minimum time required for extricating SNM from its storage location inrelationship to the licensee's time of detection and assessment may need tobe taken into account (e.g. , fuel assemblies stored in shipping casks ornon-selfprotecting fuel residing in non-power reactor cores). The bulkiness,massiveness, and difficulty of movement or disassembly of fresh fuel elementsor other fArms of low-enriched uranium (LEU) in large quantities such asshipping casks or assemblies may pose sufficient difficulty to persons attempt-ing unauthorized removal within a reasonable time period (relative to CAAmonitoring procedures) that they can be considered to provide isolation.Control of access to special equipment and vehicles capable of handling andtransporting such items may also be included as integral elements of theaccess control program for the CAA.Access control procedures for CAAs designated exclusively for storageare expected to be similar to those described in the previous section forperiods when use-type CAAs are unoccupied.It is expected that large facilities (e.g. fuel processing facilities)will have more complex isolation and access control systems than small facil-ities (e.g. , research reactors) in order to achieve comparable levels ofprotection.An illumination level is recommended for the CAA that is sufficientlyuniform and bright to detect penetration of or tampering with the CAA contain-ment (in the case of a security cabinet) or unauthorized penetration of oractivities within the CAA (in the case of a vault-type room or its equivalent).Content(This section needs to be completed only for CAAs designated exclusivelyfor storage of SNM. CAAs designated for both use and storage are to bedescribed as recommended in Section 1.1 of Part II of this Standard Format.)Describe the CAAs where the material will be stored, if different fromthose previously described for use. For each such CAA, provide the followinginformation:1. A description of the area and its features relative to other facil-ity features showing the access control points for the CAA (including a scalediagram).40 2. The physical barriers, container walls, or other features thatdemarcate the perimeter of the CAA and channel entry through only estab-lished access control points. If access control is provided by virtue ofthe bulkiness, massiveness, and difficulty of disassembly of a container orobject serving as a CAA, describe the facts relied upon to support such adetermination.3. The means and criteria used for controlling access to the CAA atestablished access control points.4. If more than one CAA is designated for the storage of the mate-rial, indicate the types of material normally to be stored in each area.41 2. DETECTION DEVICES AND PROCEDURES AT A FIXED SITEThis chapter provides guidance for meeting the requirement of paragraph73.67(f)(2), which is as follows:(f)(2) Monitor with an intrusion alarm or other device or procedures thecontrolled access areas to detect unauthorized penetrations oractivities.The purpose of this monitoring activity as stated in paragraph 73.67(a)(2)is to provide "early detection and assessment of unauthorized access or activ-ities by an external adversary within the controlled access area..." and"early detection of removal of special nuclear material by an externaladversary from a controlled access area." This should be done to achievethe objective of minimizing the possibilities for unauthorized removal ofspecial nuclear material "consistent with the consequences of such actions,"as stated in paragraph 73.67(a) of the effective rule. Thus the earlinessof detection afforded by the licensee's physical protection system may varydepending upon the nature and quantity of the material susceptible to unauthor-ized removal. Further discussion of the earliness of detection requiredfor possible thefts of different types and quantities of special nuclearmaterial of low strategic significance is provided in Section 2.1.2.1 Earliness of Detection [73.67(a)]The criteria used for determining the earliness of detection for unautho-rized access, activities, or removal of special nuclear material from controlledaccess areas will depend upon an assessment of the magnitude of the consequencesassociated with possible misuse of the type and quantity of material thatcould be removed in a given theft attempt. For special nuclear material oflow strategic significance, three distinct cases are considered:1. Gross theft of low-enriched uranium (LEU)*2. Minor theft of low-enriched uranium (LEU)3. Theft of strategic special nuclear material (SSNM) (i.e., SNM oflow strategic significance other than LEU.)Gross theft of LEU refers to the theft of LEU in a sufficiently largequantity that it could yield upon further enrichment or other processingenough material of the type and quantity needed to construct a clandestinefission explosive (CFE) device. This quantity may vary depending on theenrichment and physical and chemical form of the feed material but mayroughly be estimated as an amount containing about 75 kilograms of theisotope U-235. Because the most serious consequences to the public healthand safety could occur from a theft of this magnitude, a system that woulddetect a theft sufficiently early to allow for prompt recovery is called for.The NRC believes that, because of the large quantity of material involved andwith proper detection systems and procedures, the licensee would be capable ofLow-enriched uranium is uranium enriched above natural but less than20% in the U-235 isotope.42 detecting a gross theft of LEU between the time of the actual theft and thetime it is transported off site.Minor theft of LEU refers to thefts involving much smaller quantities ofLEU such as could be removed by one or two persons in a private vehicle oron one's person. These minor thefts are significant only to the extent thatthey could be repeated periodically to eventually accumulate an aggregatequantity similar to that which might be obtained in a gross theft. Therequired degree of earliness of detection of such thefts is related to thetime that would be needed by the adversary to obtain a gross amount throughrepeated thefts. If the amount taken in each of a series of daily theftsis very small, the ultimate time of detection could be as long as six months--the interval between material inventories as required by Part 70. For largerquantities that could be removed in a single theft, but still much less thanwould constitute a gross theft, it would be reasonable to expect that onein a series of such thefts would be detected before a gross amount could beremoved.Licensees who possess less than gross quantities of LEU need not providefor early detection of a single theft of a gross quantity, but the capabilityfor detecting multiple thefts is as important as it is for those licenseespossessing gross quantities.Thefts from a single facility of SSNM (SNM of low strategic significanceother than LEU) are limited by definition to quantities that could not beused to construct a nuclear explosive device; thefts of similar quantitiesof SSNM from several different facilities could, however, lead to the accumu-lation of an aggregate quantity that would permit such illicit use. (Theconsequences of a single theft of such material would have minimal impacton the public health and safety.) Therefore, detection of such thefts isrequired sufficiently early to ensure early notification to the NRC. TheNRC in turn can then notify other licensees of the need to implement appro-priate response measures to prevent the accumulation by a single adversaryof a formula quantity of material through multiple thefts from differentfacilities. The NRC believes that there are detection systems and proceduresthat would allow the licensee to detect a theft of SSNM within approximatelytwo hours.2.2 Monitoring of Controlled Access Areas [73.67(f)(2)]IntentMonitoring of CAAs where the material is used will require a capabilityfor early detection of (a) unauthorized penetration of the CAA perimeter,(b) unauthorized activities within the CAA, (c) unauthorized removal of SNMfrom the CAA, or (d) some combination of these, by an external adversary.For purposes of this guidance, an external adversary is any person no temployed by the licensee or one of his contractors to report for work on aregular basis at the licensee's site and who is not directly involved inthe processing or other authorized use of the material in connection withhis assigned duties. For purposes of this definition, graduate and otherstudents assigned by the licensee at an educational or research institutionto assume responsibility for the regular handling of the material would notbe considered an external adversary.43 The choice of particular safeguards measures to be included in the CAAmonitoring system will depend upon a number of different site specific factorssuch as whether the measure is to function while the area is occupied orunoccupied, the size of the area, the types of functions performed in thearea, the level of traffic into and out of the area, etc. Many of the avail-able safeguards measures which may be employed in the CAA monitoring systemare described in various regulatory guides and NUREG series documents issuedby the Commission. Specifically, the Fixed Site Physical Protection UpgradeRule Guidance Compendium* provides guidance on selection, installation, andimplementation of monitoring devices and procedures relative to physicalprotection of formula quantities of SSNM. This guidance is also applicableto monitoring equipment and procedures for CAAs at fixed sites having lessthan formula quantities of SNM with regard to individual physical protectionmeasures. It is recognized, however, that from a systems point of view,this body of guidance intended to support the Upgrade Rule may emphasize amuch greater level of redundancy and diversity than would be required forthe protection of SNM of moderate and low strategic significance.** Thefollowing paragraphs give illustrations of various monitoring systems thatcan be used to provide the earliness of detection discussed in Section 2.1.a. Early Detection of Gross Theft of LEUEarly detection of gross theft of LEU means detection during the attemptedtheft. This may be accomplished by using intrusion alarms or other monitoringdevices in the following applications:Fence or buried line perimeter detection systems at the CAA boundaries.Door and window alarms (e.g., balanced magnetic switches) for CAAs withinbuildings and alarms on emergency exit doors equipped with crash bars.Volumetric interior motion detection systems for unoccupied CAAs orportions of CAAs within buildings.In many cases, security procedures may be employed as substitutes forsome or all of the devices that could be employed to fulfill the monitoringrequirement for the CAA. Security procedures may be especially attractiveThe compendium was issued for public comment in conjunction with the pro-posed Physical Protection Upgrade Rule (42 FR 34310, 7/5/77). It isintended to assist the licensee in the development and implementation ofsafeguards physical protection and transportation protection plans. Copiesare available for inspection at the Commission's Public Document Room,1717 H Street NW., Washington, D.C.Tamper-safing of devices intended for use at facilities having less thanformula quantities of strategic special nuclear material need protect onlyagainst the external adversary; to the extent such a distinction can be madefor a given device, this represents a relaxation in tamper-safing requirementsrelative to protection of formula quantities.44I in protecting against the theft of gross quantities of LEU located outsidebuildings, where intrusion alarms may more easily be circumvented by'anexternal adversary. Typical security procedures that may be employed fordetection of attempts at unauthorized removal of gross quantities of LEUinclude the following:Periodic patrols of CAA perimeters and areas within the CAA bywatchmen.Surveillance (escorting) of non-licensee vehicles capable of trans-porting gross quantities of LEU away from the site.Continuous (without interruption) or continual (intermittent)surveillance of the CAA, or a given portion of the CAA which con-tains a gross quantity of LEU, by designated supervisory or otherlicensee employees. (These surveillance responsibilities couldbe undertaken in addition to the employee's normal functionsprovided they can both be discharged adequately.)Periodic inspections to confirm continued integrity of barriers,gates, loading bay doors, etc., through which unauthorized removalof gross quantities of LEU could be effected.Inspection of large vehicles leaving CAAs to ensure they are notused for unauthorized removal of a gross quantity of LEU.Where procedures involve periodic patrols or inspections, the amountof time that would be required for an adversary to complete the removal ofa gross quantity of LEU may be used to govern the interval between inspec-tions. For example, if a given number of a certain type of container ofLEU would have to be individually loaded onto a truck in order to effectremoval of a gross quantity of LEU and the time required for such loadingis determined to be in excess of two hours, then a two-hour guard patrol ofthe given area would be considered to meet the earliness-of-detection guide-line for the subject material.A combination of these and perhaps other measures could satisfy theearly detection criterion for gross theft of LEU if it could be shown thatan external adversary could not obtain unauthorized access to the SNM withoutbeing detected by at least one intrusion alarm component.b. Early Detection of Minor Theft of LEUThe criteria for early detection of minor theft of LEU can be satisfiedby a monitoring program that provides a sufficiently high probability ofdetection of one in a series of minor thefts so it is implausible that anadversary would be able to obtain in the aggregate a gross quantity of LEU.Such a capability could beeprovided in whole, or in part, by the samemonitoring program designed to detect gross theft. Additional measures thatmight be included in the monitoring program to protect against minor theftinclude the following:Exit searches of non-licensee vehicles capable of transportinghand-carried quantities of LEU (on random or general basis).45 0 Administrative control of materials removed from controlled areaswhere easily concealed or hand-carried items containing LEU areavailable.Item count inventories more frequent than those currently requiredunder Part 70.Procedures directing regular employees to be aware of unauthorizedpersons in their work areas and to report the presence of suchpersons to supervisory or security personnel. (A coded badgingprogram would support this measure.)* Escorting of visitors and other unauthorized persons entering CAA.* Watchman patrols to detect unauthorized persons within the CAA.* SNM doorway monitors at all personnel access control points.These are not required measures, but illustrations of how the monitoringprogram for detecting gross theft of LEU may be extended to include the capa-bility for early detection of minor theft of LEU. One or more of these meas-ures may be, employed, but probably not all of them would be needed for anyone installation.c. Early Detection of Theft of SSNM (SNM of low strategic significanceother than LEU)For facilities where it is necessary to protect against thefts of SNMof low strategic significance other than LEU (SSNM), earliness of detectionis discussed in Section 2.1 of this chapter. The physical protection systemin this case may differ considerably from that designed to protect LEU.The sites are likely to be small research-oriented facilities such as non-powerreactors and educational institutions. Also, there is likely to be muchless material available, and authorized access to i't may be less frequent.Detection devices such as interior motion detector systems, balanced magneticswitches, etc. could be used to monitor relatively small CAAs where thenumber of established access control points is very limited.Procedures may also be used to protect against thefts of SSNM in thissubcategory. Since watchman patrols inherently allow unguarded intervalsduring which an external adversary could conceivably obtain access to theCAA, remove a small amount of material, and leave before being discovered,the inspection procedure may (a) be sufficiently frequent to ensure anexternal adversary could not complete a successful theft of the materialduring the unguarded intervals, (b) provide for an irrevocable indicationof the CAA barrier having been tampered with (as with a seal or by observa-tion of damage done to the barrier), or (c) provide for an item countinventory or other accounting for the material *s part of the inspection.Some examples are given below:After having left material unattended in an experimental setup ina classroom used as a temporary CAA, the instructor returns aftertwo hours and verifies that the material is still in place.46 A small quantity of material is stored in a security cabinet forseveral months at a time without authorized access. Every twohours a watchman comes around to inspect the cabinet to ensurethat the lock is secure and the cabinet has not been tampered with.If a suitable combination or other pick-resistant lock is not used,the watchman also inspects a tamper-indicating seal to verify thattde container has not been tampered with.During times when a non-power reactor is left unattended, a watch-man comes around every two hours and checks that none of the fuelelements have been removed by unauthorized persons. If he encountersa person working during off-hours in the vicinity of the reactor,he asks for appropriate identification.While a non-power reactor is being utilized, the supervisor ensuresthat he or his designee is not away from the reactor for a periodlonger than thirty minutes, a period he estimates would be minimallyrequired for a person to secure fuel elements in the core thatwere not self-protecting by virtue of their having been sufficientlyirradiated.During periods when excess fuel is left unattended in a storagecloset at a non-power reactor facility, an alarm system is activatedthat would annunciate if anybody tried to penetrate the closetwithout proper authorization.During periods when the material is being used under the direct supervi-sion of authorized personnel, the monitoring requirement is satisfied byvirtue of the continuous surveillance by the authorized personnel.ContentFor each of the CAAs described previously (see Part II, Chapter 1, ofthis guide), provide the following information regarding the measures takento fulfill the monitoring requirement of paragraph 73.67(f)(2):1. Describe any devices employed by specifying the type of device,its installed location, the type and location of annunciation, its intendedarea of coverage, and its tamper-resistant features. Refer, if desired, toexisting filed security plans or NRC-published guidance or NUREG seriesdocuments.2. Describe any procedures employed to monitor the CAA or portionsthereof, including the categories of persons who will execute the procedures,the frequency of inspections or rounds of patrol, the basis for the determina-tion of such frequencies, and the occasions upon which the procedures areintended to be implemented. Indicate, also, the features of the CAA (e.g.barriers, locks, seals, etc.) that will play a role in the way the proceduresare used.3. Explain how the combination of procedures and devices used tomonitor each CAA meets the criteria for early detection of theft by an externaladversary relative to the type of material found in each CAA.47 03. SECURITY RESPONSE AT A FIXED SITEThis chapter provides guidance on meeting the requirement of paragraph73.67(f)(3), which is as follows:01(f)(3) Assure that a watchman or offsite response force will respond toall unauthorized penetrations or activities.IntentThe intent of this requirement is to ensure that, in the event of asecurity incident, someone will be available to assess alarms or any unauthor-ized penetrations or activities and, if warranted, notify the NRC, the locallaw enforcement authorities, and the responsible person in licensee management.Early detection and notification of any missing material will help facilitateits prompt recovery. For the purpose of this regulation, an offsite responseforce can be a local law enforcement agency or a contract guard service.ContentDescribe the security organization that will be responsible for assessingand responding to any unauthorized penetrations or activities. Ensure thatat least one guard, watchman, or member of an offsite response force willrespond to all unauthorized penetrations or security incidents at the CAAs.48 4. RESPONSE PROCEDURES AT A FIXED SITEThis chapter provides guidance on meeting the requirements of para-graph 70.67(f)(4), which states:(f)(4) Establish and maintain response procedures for dealing withthreats of thefts or thefts of such material.IntentThe intent of this regulation is to help the licensee to identifythose security incidents that could result in the loss of SNM of low strat-egic significance and to develop response procedures to prevent or reducethe likelihood of such a loss. Some types of incidents that should be con-sidered and for which response procedures should be developed are:1. Situations that could possibly lead to theft of SNM (e.g. civildisturbance).2. Discovery that the security system has been breached.3. Discovery that some SNM is missing.ContentIdentify those events for which response procedures will be developed.Also describe the type of response to be accomplished for each event identi-fied and the duties and responsibilities of the security organization andmanagement involved in the response. Ensure that the NRC will be notifiedimmediately in the event of theft or attempted theft of the material.Describe what local law enforcement assistance is available, their responsecapabilities, and any agreements made with them to respond in the case oftheft of the material.49 5. MATERIAL TRANSPORTATION REQUIREMENTSThis chapter provides guidance on meeting the requirements of paragraph73.67(g)(1), which are as follows:(g)(1) Each licensee who transports or who delivers to a carrier fortransport special nuclear material of low, strategic significanceshall:(i) Provide advance notification to the receiver of any plannedshipments specifying the mode of transport, estimated timeof arrival, location of the nuclear material transfer point,name of carrier and transport identification,(ii) Receive confirmation from the receiver prior to commencementof the planned shipment that the receiver will be. ready toaccept the shipment at the planned time and location andacknowledges the specified mode of transport,(iii) Transport the material in a tamper-indicating sealed container,(iv) Check the integrity of the containers and seals prior to ship-ment, and(v) Arrange for the in-transit physical protection of the materialin accordance with the requirements of §73.67(g)(3) of thispart, unless the receiver is a licensee and has agreed inwriting to arrange for the in-transit physical protection.5.1 Advance Notification [73.67(g)(1)(i)]IntentThe intent of this paragraph is to require the shipper to preplan thetransportation of the material and inform the receiver of his plans priorto shipment. This is the first of several transportation requirements thatwill allow the receiver to take delivery of the material as planned or tohelp ensure traceability of any missing material.ContentThe licensee should ensure that, prior to each shipment of material,the receiver will be notified of the impending shipment and provided thefollowing types of information:1. Mode of transport (e.g., truck, plane, train, or ship),2. Estimated time of arrival,3. Location where material is to be transferred to receiver,4. Name of carrier, and50 5. Transport identification (e.g., truck, train, or flight number;ship name).5.2 Receiver Confirmation [73.67(g)(1)(ii)]IntentThe intent of this requirement is that, prior to shipment, the trans-porter will be assured that the receiver is ready to accept the shipment atthe planned time and location and has acknowledged the mode of transport.ContentDescribe what procedures will beused to ensure that shipment of mate-rial does not take place until the receiver acknowledges the planned shipmentand mode of transport and states that he will be ready to accept the shipmentat the planned time and location.5.3 Container [73.67(g)(1)(iii)]IntentThe intent of this requirement is to provide a mechanism or system thatwill help the receiver detect any tampering with the material's containerthat may have occurred during shipment. Regulatory Guide 5.15, "SecuritySeals for the Protection and Control of Special Nuclear Material," providesguidance in this area. If the material is shipped in an exclusive-usecarrier, it is acceptable to tamper-seal the carrier itself rather than eachindividual SNM container.ContentDescribe the types of seals that will be used to secure the material'scontainer during transport.5.4 Inspection [73.67(g)(1)(iv)]IntentThe intent of this paragraph is to require the shipper to check theintegrity of the material container's seals just prior to shipment so thathe can be assured that they have not been compromised. Then, upon receiptof the shipment, if the receiver discovers the container's integrity hasbeen compromised and the material is missing, the scope of the recoveryoperation can focus on the transportation route.ContentDescribe the procedures to be used to ensure that the integrity of thecontainers or seals is checked just prior to shipment.51 5.5 Responsibility for In-Transit Physical Protection [73.67(g)(1)(v)]IntentThe intent of this paragraph is to make clear that the licensee shippingthe material is responsible for arranging for the physical protection ofthe material in transit if the receiver is not a licensee. If both theshipper and receiver are licensees, the shipper may allow the receiver toaccept this responsibility wholly or in part provided there is appropriatedocumentation specifying their respective responsibilities. Where no suchdocumentation exists, both the shipper and receiver are held jointly respon-sible. (See Section 6.3 in the next chapter.)ContentIn his security plan, the shipper should either acknowledge responsibil-ity for the in-transit physical protection of SNM of low strategic signif-icance .or ensure that a written agreement from the receiver has been receivedin which the receiver accepts either full responsibility or shared respon-sibility for the in-transit physical protection of this material in accordancewith paragraph 73.67(g)(3) of 10 CFR Part 73.052 6. RECEIVER REQUIREMENTS--TRANSPORTATIONThis chapter provides guidance on meeting the requirements of paragraph73.67(g)(2), which are as follows:(g)(2) Each licensee who receives quantities and types of special nuclearmaterial of low strategic significance shall:(i) Check the integrity of the containers and seals upon receiptof the shipment,(ii) Notify the shipper of receipt of the material as required in§70.54 of Part 70 of this chapter, and(iii) Arrange for the in-transit physical protection of the materialin accordance with the requirements of paragraph 73.67(g)(3)of this part, unless the shipper is a licensee and has agreedin writing to arrange for the in-transit physical protection.6.1 Inspection [73.67(g)(2)(i)]IntentThis requirement is intended to determine whether the material's con-tainer has been compromised enroute and whether any material has been removedso that immediate recovery procedures can be initiated if required.ContentDescribe the procedures to be used to ensure that the integrity of thecontainers and seals will be checked upon receipt of- the material shipment.6.2 Notification [73.67(g)(2)(ii)]This requirement is intended to:1. Ensure that knowledge of the current location of all SNM is avail-able, and2. Formally inform the shipper that the material has been received.ContentEnsure that a completed copy of Form NRC-741, "Nuclear Material Transac-tion Report," will be sent to the shipper within 10 days after a materialshipment has been received as required in §70.54 of 10 CFR Part 70.6.3 Responsibility for In-Transit Physical Protection [73.67(g)(2)(iii)]IntentThe intent of this paragraph is to make clear that the licensee receivingthe material is responsible for arranging for the physical protection ofthe material in transit if the shipper is not a licensee. If both the shipper53 and receiver are licensees, the receiver may allow the shipper to acceptthis responsibility either wholly or in part provided there is appropriatedocumentation specifying their respective responsibilities. Where no suchdocumentation exists, both the shipper and receiver-are held jointly respon-sible. (See Section 5.5 in the preceding chapter).ContentIn his security plan, the receiver should either acknowledge responsibil-ity for the in-transit physical protection of SNM of low strategic significanceor ensure that a written agreement from the shipper has been received inwhich the shipper accepts either full responsibility or shared responsibilityfor the in-transit physical protection of this material in accordance withparagraph 73.67(g)(3) of 10 CFR Part 73.54 7. IN-TRANSIT PHYSICAL PROTECTION REQUIREMENTSThis chapter provides guidance on meeting the requirements of paragraph73.67(g)(3), which are as follows:(g)(3) Each licensee, either shipper or receiver, who arranges for thephysical protection of special nuclear material of low strategicsignificance while in transit or who takes delivery of such mate-rial free on board (f.o.b.) the point at which it is delivered toa carrier for transport shall:(i) Establish and maintain response procedures for dealing withthreats of thefts or thefts of such material,(ii) Make arrangements to be notified immediately of the arrivalof the shipment at its destination, or of any such shipmentthat is lost or unaccounted for after the estimated time ofarrival at its destination, and(iii) Conduct immediately a trace investigation of any shipmentthat is lost or unaccounted for after the estimated arrivaltime and report to the Nuclear Regulatory Commission asspecified in §73.71 and to the shipper or receiver as appro-priate. The licensee who made the physical protectionarrangements shall also immediately notify the Director ofthe appropriate Nuclear Regulatory Commission Inspection andEnforcement Regional Office listed in Appendix A of the actionbeing taken to trace the shipment.7.1 Response Procedures [73.67(g)(3)(i)]IntentThe intent of this regulation is to help the licensee identify thosetransportation incidents that could affect the security of the SNM in transitfor which he might expect to be notified and for which response proceduresshould be planned.ContentIdentify those events for which response procedures will be developed.Also describe the type of response to be accomplished for each event identi-fied and the duties and responsibilities of the security organization andmanagement involved in the response. Ensure that the NRC will be notifiedimmediately in the event of theft or attempted theft of the material.7.2 Notification [73.67(g)(3)(ii)]IntentThe intent of this requirement is to ensure that the licensee respon-sible for the physical protection of SNM in transit will have a firm basisfor deciding whether or not to initiate response procedures in the event ashipment becomes overdue or is lost.55 ContentDescribe the arrangements and procedures that will be used for notifyingthe licensee who arranges for the physical protection of material in transit(1) of the arrival of the shipment at its destination or (2) of any suchshipment that is lost or unaccounted for after the estimated time of arrivalat its destination.7.3 Lost Material Notification [73.67(g)(3)(iii)]The intent of this requirement is to ensure that, in the event a ship-ment becomes overdue and no reasonable explanation has been received fromthe carrier regarding its status, a trace investigation will be conductedto locate the missing SNM. At this time, the NRC should be notified thatthe material is missing and informed as to what steps are being taken torecover it. Although the licensee is responsible for notifying the NRC ofany missing material and for initiating and assisting in the subsequentinvestigation, the law enforcement agencies bear the responsibility forphysically recovering the material.ContentDescribe what procedures will be used to trace any shipment that islost or has not arrived by the estimated arrival time. Ensure that all lostor missing material will be immediately reported to the appropriate NRCRegional Office along with what actions are being taken to trace the shipment,that the NRC will be notified as specified in §73.71, and that the shipperor receiver, as appropriate, will also be notified.56 8. EXPORT REQUIREMENTSThis chapter provides guidance on meeting the'requirements of paragraph73.67(g)(4), which reads as follows:(g)(4) Each licensee who exports special nuclear material of low strategicsignificance shall comply with the appropriate requirements speci-fied in §73.67(c), (g)(1) and (g)(3).Use Chapters 5 and 7 of Part II of this Standard Format to describethe security procedures that will be used to protect the material up to thepoint where the receiver accepts physical protection responsibility for theshipment.57 9. IMPORT REQUIREMENTSThis chapter provides guidance on meeting the requirements of paragraph73.67(g)(5), which reads as follows:(g)(5) Each licensee who imports special nuclear material of low strategicsignificance shall:(i) Comply with the requirements specified in §73.67(c), (g)(2)and (g)(3), and(ii) Notify the person who delivered the material to a carrierfor transport of the arrival of such material.9.1 Security Requirements [73.67(g)(5)(i)]Use Chapters 6 and 7 of Part II of this Standard Format to describethe security procedures that will be used to protect the material from thefirst point where the shipment is picked up.9.2 Notification [73.67(g)(5)(ii)]IntentThe intent of this regulation is tothat the material has arrived safely.ensure that the exporter is notifiedContentDescribe the procedures to be usedmaterial that the shipment was received.for notifying the exporter of the58 VALUE/IMPACT ASSESSMENTA separate value/impact analysis has not been prepared for this regula-tory guide. The guide was developed to provide a standard format and contentfor the physical protection plans that licensees authorized to possess ortransport special nuclear material of moderate strategic significance or 10kilograms or more of material of low strategic significance are required tosubmit by amendments to Part 73 of the Commission's regulations publishedJuly 24, 1979 (44 FR 43280). A value/impact analysis prepared for theamendments was made available in the Commission's Public Document Room atthe time the amendments were published. This analysis is also appropriateto this regulatory guide.59 UNITED STATESNUCLEAR REGULATORY COMMISSIONWASHINGTON, D. C. 20555OFFICIAL BUSINESSPENALTY FOR PRIVATE USE, $300POSTAGE AND FEES PAIDU.S. NUCLEAR REGULATORYCOMMISSION119406002001a I D5DAQ5QABJS NRC REGION IFFICE OF INSPECTION & ENFORCEU3J BORESEGION PARK AVENUEIING OF PRUSSIA PA 19406