ML19242B523

Draft Reg Guide 5.XX, Std Format & Content for Licensee Physical Security Plan for Protection of SNM of Moderate or Low Strategic Significance

ML19242B523
Person / Time
Issue date:	01/16/1979
From:	NRC OFFICE OF STANDARDS DEVELOPMENT
To:
Shared Package
ML19242B477	List: ML19242B476 ML19242B483 ML19242B486 ML19242B489 ML19242B491 ML19242B495 ML19242B502 ML19242B509 ML19242B514 ML19242B518 ML19242B523 ML19242B526
References
REF-10CFR9.7 REGGD-05.XXX, REGGD-5.XXX, NUDOCS 7908080657
Download: ML19242B523 (37)

Text

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ENCLO5URE ' "

REGUL;'ORY OUICE 5. u STANCARD FCRMAT AND CONTENT FC. THE LICENSEE PHYSICAL SECulI"f PLAN FCR THE PROTECTICN CF SPEC!AL NUCLEAR MALAIAL OF TCEDATE CR L a 5TRATEGIC SIGNIF:CANCE INTRCCUCTICN The Atcmic Energy Ac'. of 1954, as amended, directed tre U.S. Atomic Energy Cormission (%EC) to regulate the receipt, manufacture, precuction, transfer, possessicn, use, imocrt, and exccrt of scecial nuclear material (SNM) in crcer to crotect the puolic nellth and ;afety and to provice for tre c: men defense and security. The Eaergy Reorgani:stien Act of 1974 transferred all tn.e licensing and relatea regulatory functions of the AEC to tne Nuclear Regulatory Ccmmission (NRC).

The principal requirements with respect to the pnysical prctection of licensed activities against incustrial sacotage and with respect to the physical protection of special nuclear material in transit are fcund in Title 10, Code of Federal Regulations, Part 50 (10 CF9 Part 50), " Licensing of Precuction and Utilization Facilities"; Part 70, "Scecial Nu" ear Material"; Part 73, " Physical Protection of Plants and Materials"; anc Part 110. "E;c:cet anc Incart of Nuclear Facilities and Materials."

Paragracn 50.34(c) of 10 CFR Part 50 and Paragra:hs 70.20'q), 70.22(h) and 70.22(k) of 1] :F~ Part 70 icentify tre ;nysical :rotection f rformation that must ':e provided in a Mysica!

3ecurity 31an as part of a license acclication. This plan is recuirec in arcer for tne apoli-cant to cemonstrate c;mpliance wit.n the scecific ;nysic31 protection recuirements of 10 CFR Part 73 and 1tust ce suomitted with each acclication for a licensa to possess or use $NM (or f or a license autnorizing trans: ort or celivery of SNM), excect for a licersee possescing, using or transcortirg less than 10 (q of SNM of Icw strategic significance nere sue,itting a :rysical security clan is not recuired.

Mc*ever, in inis case, the licensee is recuirec to meet tre recuirements of 73.47 for the protection of 5NM of Icw strategic significance.

This doct ment (Stancarc Format) cescr%es tne information recuired in ine ;hysical security alan a:mitted as part of an application for a If cense to possess, use, or transcor; $NM of mccerate strategic significance or 10 kg or mere of ShM of low strategic significance and prescrices a stardard format for : resenting the information in an orcerly arrangement. This stancard format will tnus serve as an aid to uniformity anc c:meleteress in tre :recaration anc review of tne anysical protection alan of the license acciicati n.

' Mis :oc. ment can also :e Jsed as guidance l:y licensees possessirg or transportirg less tnan 10 (g 3f $NW of 10w strategic significance in uncerstanding tre intent and imolementing tne recuirements of paragracns 73.47(a),

73.47(f), and 73.47(g) of 10 :FR hrt 73.

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Asice frem aroviding guidance for the stancard 'or at ard c:ntent cf :nysical secu tv Oians, this regulat.ory qu1ur exclains tre intent af tre various ;rovis:ces of the regulation. The 'ntert of eacn requirement is founo in *ne ciscuss en of each se:section and Maliciti is cravicec Oy outlinirg alternative systems that c:uld te uset to fulfil' tne requirements. The :1scussion section and list cf alternatives snould prowice the licensee with the sense or the WC regulatwns This guide is divided irto two parts. Part I, "5NM cf mecerate strategic signi'icanci,"

crescri:es a standard format for precaring tne licentee's security plans anc provices guicance to licensee's.ho possess, use, or transport SNM of mccerate strategic significance. Chacters 1 througn 6 of Part I applies to applications fc a license to possess or use at any fixad site, or at contiguous sites, sucject to control by the licensee, SNM of mecerate strategic signif-icance. Chapters 7 througn 11 of Part I of the Standard Fomat a: plies to a:clications for autnerization to transport or deliver to a carrier for transport SNM of x:cerate stratejic significance.

Part II, "5NM cf L w Strategi: Significance," prescrites a stardard fanat for Ore:aring the licensee's security plan for licensees wnc :ossess, use, or trans:cet more than 10 <g of SNM of Icw strategic significance. It also provides guidance to all licensees.no :cssess, use, or transccc SNM of Icw strategic significance. Cnapters 12 tnreugn 15 of Part II of tne Standard Fomat acclies to a:plications for a license to possess or use at any fixed site, or at contiguous sites, subject to control by ne licansee, more than 10 kg of SNM of 'cw strategic significance. Cha;:ters 16 nrough 20 of Part II of the Standarc Format a; plies to a:alications for authorization to transcort or celiver to a carrier for trans:cr more tnan 10 <g of SNM af Icw strategic significance.

Tacle i snews tre ty:e and amcunt of SNM ::vered in 10 CF1 Part 73.a7.

It sneula :e rotec, as stated in Tacle l's fcotnote, that a) clutonium.itn an isot:cic : rcentratica exceeding 3C*.

or more in Pu-233, b) s;:ecial nuclear material.nicn is cet aeaci'y se:aracle m :trer ancic-active material and nica nas a total external raciation cse rate in excess :-.00 rems per hour at a sistanca of 3 feet from any 3 :essiale sur' ace without intervening sntelcing, and :)

sealec clutonium-ceryllium neutron sources totaling 5C0 grams or 'ess contairec plutonium at any one site or ::ntinuous sites are exemot frem ne recairements of 10 CFP 73.47.

This guice nas teen Ore:arec to minimize 70s; time attricutanle to inc:molete a alicati:ns and to standarci:e One licensing revien ;rocess. The a:alicant is enc:uragec to cre:are nis 3 plication in accorcance with this guice and to provice infonation in eacn section to succort the : rclusien tnat ne nill be acle to ocerate in ac:Orcance with the :ertirent regulations.

Altncugn ::nformance witn this guice is not recuirec, it does recresent a 'crmat 3rd content acceotaole to tne w1C staff As eve!ccments and cnarges in tne auclear incastry ac:ur, tre %mmission's ce;uirementa for infor-'ation may need modification; revisions to inis ;uice will :e 9 ace as recessary to ac::mmecate inese nanges.

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I TA5LE 1 CATECCRIZATICN OF NUCLEAR MATERIAL ACEhTE 274724C s sibitM YATERIAL ENRICHMENT SIGNIFICANCE 5:0NIF!CANCE 1.

Plutonium **

Less than 2000 g but more SCO g or less but more than 500 g than 15 g 2.

Uranium-235 20*. or more in Less than 5000 g but more 10C0 g or less but more U-235 isotope than 1C00 g than 15 g IC*. or more but 10,000 g or more Less than 10,000 g out less than 20*

more than 1CC0 g in U-235 isntoce Above natural 10,000 g or more but less than IC*.

3.

Uranium-233 Less tnan 2000 g out more SCO g or less but more than 500 g than 15 g 4

Uranium-235 U-235 portien Less than 5000 g accorcing 1000 g or less accor ing Uranium-233 enrichec to 20". to the formula: grams =

to the formula: grams =

and Pluton-or more.

(grams contaired U-235) +

(; rams contained U-235) +

iu:n'* in com-2.5 (grams U-233 + grams 2.0 (grams U-233 + grams bination Plutonium'), but mar s than Plutonium'), but more 1000 g according to tre than 15 g according to formula: grams = (grams tne formula: ; rams = grams U-235) + 2.0 (grams U-233 contained U-235 + grims

+ grams Plutonium')

U-233 + grams Plutonium.'

Plutonium with isotocic concentration exceeding 30". or more in Pu-233 is exempt.

'Soecial nuclear material which is not readily separacle from the radioactive material an:

.nicn nas a total external radiation oose rate in excess of 100 rems ;er nour at a distance of 3 feet from any accessible surface witnout intervening snielding is exemot.

0 Sealed clutonium ceryllium reutron sources totaling 500 grams 3r less contained clutoni..,

at any one site or contiguous sites are exemot, k f'*

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• his starcard foa-at cocument has ceen precared as an aid to en1fonity anc c PDleteness in t.ie ;:recaration and review of the physical protection section of license 3;olic3ticEs and to clarify the intant of the regulations. The info natien this c0cument c0ntains will nelp the Iftensee plar. a pnysical protection system cesigned to cetect the theft of SNM of tecerate or icw strategic significance. The ;nysical protect'On sw0 systems icentified are interced to pro-vice a reference pnysical protection,ystem that would r,omally te cacaole of meeting tre performance requirements of paragrace: 73.47(a) of Il CFR Part 73.

However, it is recognized that at any particular site tnere may ce s:me sacsystems and components not neeced or addi-tienal ones needed to meet these performance requirements. In this case the licensee is encouraged to accress in his 14:ense a; plication specific departures frca this guide of sub-systems or c:moonents.

The infor9ation requested in this Standarc Format is the minimum needed for a licease a:pli-cation. Additional info nation may be r uired for completion of the staff review of a : articular acplication and should be incluced as approcriate. It is also the apolicant's risconsioility to te aware of new and revised NRC regulations. The info n ation provided snculd Os co-to-date

- ith res ect to the state of technology for the physical protection tecnniques and systems that n

the acclicant peceaset to use.

Information and procacures delineated in Regulatory Guices in Civision 5, " Materials and Plant Protection," and accrooriate to certain sections of the Physical Security Plan may Oe incorporateo Dy reference.

The acclicant should discuss his olins and programs with tne W C staff :efore prepar bg his a plication. This discussion snould give particular emchasis to the cepth of infor*ation recuired for the clan.

Upon receipt of an a: plication, the NRC staff aill perfora a preliminary review to deter-mire.rether tre acolication provices a reasonaoly c molete presentation of tne inf:rmatten neeced to form a Oasis for tre finoings recuired Oefore issuance of a license. The Stancarc Format will be used by tne !taff as a guiceline for icentifying the type of informati:n neecec.

f an acclication dces not provice a reasonably c:mplete resentation of tre necessary informa-tion, further review of an applicatica will :e sascenc63 antil nis reeced infor9ation is

roviced.

Use of ??e Standard Format The acolicant snould follcw tne numoering system cf 'he Standard F:rmat at least Oc.n to the level of sucsection (e.g., 3.4).

Uncer scme circumstarces :ertain sucsections may ot ce acclicable to a specific application. If so, this snould te clearly stated arc suf" cient infor*ation should te ::r0v1:ec to succort that :cnclusion.

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1 The a;olicant may wisn to sotmit infomati:n in su::crt of nis scalicaron trat is ot required by regulations 2nd is not essential to the :escription of the a;plicant's ;nysical Oro-tection program. $Lcn information c0ule incloce, for example, nistorical cata sotmitted in cemonstration of certain criteria, ciscussion of alternatives consicered by the acclicant, or sLcolementary data regarding assumed icdels, data, or calculations. This infor?ation snoulc te Orovice3 as an 10perdix to the application.

U:on c:mpletion of the applicati:n, the acclicant snould use the Tacle of Ccntents of the Standard Format as a checklist to ensure that eacn sucject has teen addressed.

Stvle ed Comeosition A table of conten:s should be included in eacn sutaittal.

The acclicant snould strive f:r clear, cucise presentation of infomation. Ccnf; sing or amoiqucus statements and gereral statements of intent snould te avoiced. Definitions and accre-viatiens should be consistent througnout the submittal and c:nsistent witn ;enerally ac;ected usage.

'.herever cossible, duolicatico of information should :e avoided. Thus, information already incluced in other sections of the acclications may be coverec by scecific reference to those sections.

' nere numerical values are ststed, the nuccer of significant figures should reflect the accuracy or precisien to.nich the numcer is (newn.

The use of relative values should be clearly indicated.

Drawings, diagrams, and taDies should be used.nen infomation may te presentec more acecuately or conveniently y sucn means. These illustraticas should be located in the section

.nere they are first referenced. Care snould ce taken to ensure tnat all information presented in drawings is legible, that symtals are cefired, anc :nat crawings are not ecuced to tne extent tnat tney cannot te reaa Oy unaidec.or ai eyes.

Physical 5:ecifications of 5ctmittals All material sucmitted in an acclication snould conform to tne f 311cwing ;nysical cimensicns of page si:e, quality of pacer and inns, numcerirg of pages, etc.

1.

Da:er Size Test pages: 3-1/2 x 11 incres.

Cri.ings and ;racnics: 3-1/2 x 11 incnes areferrec; newever, a larger si:e is ac:ectacle reviced the finis *ec c.cy.ren folced :ces not exceed 3-1/2 < 11 incres.

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Pa:er St0ck and ink Suitable quality in sL stance, ;:acer color, and int :'ensity f:r nancling and 'er recroacc-tien by microfilming.

L Page argins A margin of no less than one incn is to te maintained on the tco, cott:m. and inding sice of all pages sucmitted.

4.

Printing Ccmposition: text pages snould be single spaced.

Type face and style: must ce suitable for microfilming.

Recroduction: may be mechanically or phot: graphically recroduced. All pages of tre text may be printed on both sices, and images should be printed head to head.

5.

Sinding Pages snould be punched for looseleaf ring binding.

6.

Page Numoering Pages should be numoered by section and sequentially within the section. Do not num0er the entire recort sequentially. (This entire Standard Format has been numcered sequentially Oecause tre individual cnapters.ere t0o short for secuential numcering ithin each section to e meaningful.)

7.

Format Refererces In the application. references to inis Standard Cormat snould te Dy cna::ter and section numcers.

P-Ocecuras *ar Uccating er ?evisinc Paces The updating or revising of data and text should te on a replacement :: age basis.

The enanged or revised ;;ortion of eacn :: age should :e nignligntea ey a vertical line. The line should te on the margin c;oosite the Dirding margin for each lire cnanged or acced. All

agea su:mitted to uccate, revise, or acd pages to tre aecort are to snow tre date of change.

The transmittal letter snould incluce an incex page listing the :: ages to se inserted and tre

ages to Oe removed.

'ahen major cnanges or additions are mace, pages for a revised Tacle of Contents snould e proviced.

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V :#r of Cccias ire applicant snould sutmit 're !:crocriate numcer of ::cies of eaen requirec su mittal pursuant to 10 CFR i 70.01.

Public Disclosure The NRC had determined that the public disclosure of the details af pnysical protecticn programs is not in the public interest, and sucn details are withheld pursuant to Paragracn 2.790(d) of 10 CFR Part 2.

Thus, the physical protection section of eacn application should te sutaitted as a separate enclosure. Other procrietary and classified information should be clearly identified and submitted in separate enclosures. Eacn sucn submission of pre:riet:ry information should be acc0mcanted by the applicant's cetailed reasons and justifications for requesting exemption from puolic disclosure, as required in Parsgrapn 1.790(b) of 10 CFR Dart 2.

DART I: SNM CF "CCERATE ST;aTGIC S!CN!F!CANCE CHAPTER 1 USE AND STCRAGE AREA CESCRIPT!CN This chapter provides ;uicarce an meeting tre recuirements of paragracns 73.a7(d)(1) anc (d)(2) nich are as fo'lo s:

(d)(1)

Use the material only within a controlled ac:ess area nicn is illuminated sufficiently to allow cetection and surveillance of unauthorized :enetration or activities.

(d)(2)

Store the material only within a controlled access area sucn as a vault-ty:e r00m 3r a: proved security caminet or their ecuivalent.nicn is illuminated sufficiently ta alicw cetection and surveillance of onauthorized peaetration or activities.

A controlled access area (CAA) is cefined in 73.2 caragra:n (:) as, "any tercorarily or aermanently estaclished area.nics is clearly :emarcated, ac:ess to.nicn is controlled md.nic9 af fords isolaticn af tne material, ecu.pment or persens aitnin it " Thus a CAA can :e an accroves security caninet with lock to -nich only autnorized ircivi uals nave tne cor:c1 nation 3r <ey, Or a vault 3r vault-type room.nich uses. cme type of ac:ess ::ntrol system to limit ac:tss to autror-1:ed individual, a lockeo laccratory #ce wnich only autneri:ed indivicuals suct. J arofessors or f a0 instructors nave tne ::maination or aey, or any open ares anose Ocundaries are clearlj defined and into.nien access of personnel is c:ntrolled. Ine regulations as.ritten are cesignec to allow the licensee s great deal af flexibility in ?eeting the recuirements in a :ost ef fect.e manner.

1.1 AREA HE3E WATERIAL !3 USED (73.a7(!M 1))

Intent

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Ie"tCorarily estaDlis9ed CAAs for tFe use of SW aeed act nave :eraanent tj;e :nys' 3 tar *iers at their Ocuncartes.

Cf' ice nartitions, Or:Ons ar strer devicas can :e use to.arn

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,asserscy of the restricted nature of tre area,.nfle uces. control can

e ef f ected inrougn surveillance or supervision of the area cy those using *Se SNH !! tre ti.Te.

Ho.ever, if t e material is to be left unattenced in sucn an area, accitional Orotection must ce previced to control access anc assure a cetection ca;:at"lu in the Josence of autnarizec ::erscnrel. This could be acc:mplished for enamole, through A a stirg of signs and tre use of motion detection ecuipment covering tre i. mediate area in =nich the SNM is locatec. Altrcugn tne material maj te censidered in "use," protection recuirements.ould te the same as inough the material ere in storage, since authorized personnel would not be present.

Permanently designated areas for the use of ShM -ould more closely a;;proximata CAAs intended for the storage of SNM.

In this case, permanent type physical barriers would be a more likely choice, such as would be proviced in t!.e case of a lacoratory or reactor contairment structure, in.htch it was desired to have SNM continually present and in use. kch an area may also serve as a storage area. Although access control and detection capacilities may e proviced througn the use of acnrepriate nare are during 6'e ::eriod when SNM is stored in tnis area, otner ?eans of providing these cacaollities may be required to cerrolement such 9are.are in the case tnat alarms are cesctivated or decrs uniccred, etc.

In sucn cases, licensees may rely u;on nutnori:ed personnel to effect the required protection.

Illumination suf ficient to allow detection and surveillance of unauthori:ed :ecet*-

en or t

activities within the CAA wnere the material is used reed not require the use of nign

15ity lignting througnout the CAA. What is intenced is the use of normal lignting suf ficier.

.niform througnout the CAA so tnat material or unauthorized ;ertonnel cannot te secreted in a carvered area until a time more convenient for the '.nautnorized removal of the material, for ' nose f acil-ities.nere excerit.:ents must be concucted in a dartered room, the lignting recuirement is eucteted for as 1cng as is neeced provided access control is assured and the material is acc:untec fc-at the end of the experi9ent.

Content Cescribe the CAA.rere the material will Ce used. To Oe inc uced in this cescripticn is informatien on the type of barriers surrounding the material, the cortals that allow accass to the material, the size of tne area, the permanence of the CAA, the use of the CAA (e.g.

?aco-ratory, process area, reactor rocm, etc. ), tre 1;gnting level are uniformity ;;roviced that 411' allcw cetectica and surveillance of unauthori:ed penetration or activities and nether tre material will te stored there also.

1. 2 AREA '.HERE *ATERIAL IS 5 3 E0 f73.47(dh21)

Utent CAAs used for t9e stnrage of SNM snould crovice rotection against tseft ecuivalent to a vault-tyce room or an accroved security ca:inet. A vault-tyce room 's defined 'n G :R 3 art 73.0 as, *a roma witn one or fore coors, all moaoie of tetrg icc*ec, ar0tected :y an intrusion alarm.nica creates an alarm con the entry of a :erson anywrere i-to tre Ocm anc v:on cult

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An sc /oved security cacinet is are that is cesigred to afford protection against surreptiticus entry snd locn mani:ulation ara.nien has oeen sporoved Oy the General Services Acministratien or otrer starcarci:ing organi-

stion (e.g., ANSI) as being equivalent to i class 6 GSA rating or tecter.

A sault-t',pe room, by definition, must Oe crotected by motion cetection equicment. This is considered a valid tradeoff far tne physical barrier protection offered by the security caoinet. The vault-type room can be a locked lacoratory, a supply room, or closet equicced with a tamper-resistant motion detector device. The nation detector generally would also satisfy the monitoring requirement addressed in Chapter 2 of this guide, depending upo,; the site-specific considerstions. By " equivalent to a vault-type rocm" it meant that a piece of ecvipment (such as a fission chamcer, reactor core, or storage rack) even though it does not resemble a "roem may meet the storage requirement if there is a means of controlling access to it (e.g.,

d locked grill, inaccessibility beneath water as in a storage pool etc.) and it.: protected with a tamcer-resistant motial cetection system.

The illumination level required for the CAA snould oe sufficiently unifo n and brignt to cetect penetration of or tamcering with the CAA (e.g., eproved security cacinet) or unauthor-i:ed peretration of or activitiet within the CAA (e.g., vault-type room).

Content Cescribe in detail the CAA in wnicn the material will be stored. To be incluced in tnis description is information on the type of barriers surrounding the material, the portals that allow access to the material, the ti:e of the area, the type of CAA (e.g., vault-type rocm,

<sult, security cacinet, etc.), and the location and level of lighting provided tnat aill allcw cetection of unauthorized penetration or activities. If a vault-type room is used to store tre material, cascrite in Chapter 2, Section 1 the type of intrusion alan system used there. :' 1

• ecurity cacinet is used, cescribe in Chapter 3, Section 3, tre type of locking system used.

CNPTER 2 CETECTICN CEVICES CR PCCCECURES This cnacter orovices the following guidance for meeting tre requirement of 73.47(d)(3):

(d)(31 Monitor with an intrusion alarm or other cevice or procedures the controlled access arets to detect unauthorized penetration or activities.

In orcer to help detect unauthori:ed activities or ;enet. stions of CAAs rere the material is used or stored eitner intrusion alarms or otner cevices or security procecures are neeced.

Section 2.1 provices guidance if the licensee cnooses to use intrusion alarm or cevices and Section 2.2 provides guicance if he encoses to use security orocecures.

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2.1 CETECTICN #EV!CES (73.4NdM 31)

Intent For CAAs wnere the material is used, the licer.see will precaoly isn to rely u:en :ersonnel-oriented procedures for assuring that the CAA is not peretrated inacvertently or purposefully by unauthorized personnel. nile the material is in use. However, material left temporarily unattenced should be protec'.ed by a motion cetector (e.g., suspended f rom stove).nich inc0r-p; rates adecuate tamper resistant features. Licensees should cesign their system to minimi:e the rate of spurious or false alarms through proper installation and procedures.

For CAAs where the material is stored, the detection capability will be satisfied througn the use of motion detection eculpment. However, the detection capacility requirement may also be satisfied cy different types of safety cetection devices or security proce:ures. Inf o rmati cn regirding intrusion alar, devices nich could be used is available in MEG 02:0, Interior Intrusion Alar, Systems." However, any choice of detection device, lntrusion or safety, must include tamper-resistant features.

Content Cescribe, if applicable, the tamper-resistant in. Jsion alarm cevices or tamcer-resistant safety devices whicn are used to monitor the CAA.nere u e material is used and stored. Inclucea in this

d. ascription should be:

a.

type of device used with brief theory of operation b.

location of Cetectior device c.

ty;e and location of annunci.ation d.

area of c0verage e.

tamcer-resistant features f.

signal line crotection features emergency power features for cevices h.

c:nditions encer.nicn detection cevice will e used.

2. 2 CE'ECTICN PoCCECUtES (73.4M dM 3))_,

'ntent Licensees may cnocs( to provice the recuired detection cacaoility during certain :eric:s t.mougn reliance en personnel oriented procedures rather than :y the use of detection devices.

This may ue u.siracle during eriods of reavy usage of material nen frecuent traffic into anc out of a CAA may mame the use of an intrusion alarm system inconvenient. Authorized personnei engaged in the use of tne material or otherwise present within :ne CAA or its immeciata vicin1t./

ty satisfy the :etection cacacility recuirement Oroviced they can reasonaoly maintain surveil-lance over the material and c:ntrol ccess to One CAA gr its immeoiste vicinity. nile carey!rg I O.P N rr e s w,

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on.natever otner activities they may :e eagaged in.

At least one lutho-itec :;erson snould ce present at all times in the arsence af cetection cevices.hile the material is in use.

If the material is in storage in 10 3::oroved s+curity crainet or its equivalent, t?e matee'al may be lef t unt.ttended without an intrusion alarm system prsviced some other cetection ::rocecure is employed. 7his may inclu e remote surveillance, usie.g a closed circuit television system or rancomi:ed ;:eriodic ;:atrols by 3 atcnman or ca-'ous police.

Content Cescribe, is' applicabls, the precedures which are used or may be used to monitor the cen-trolled access areas where the material is used or stored. These descriptions should incluce:

the conditions uncer which the prrce*' es would be used; the cms for.nicn the procecures wcula te used; individuals, categoriet Jf ;divicuals or ;erscnnel positions assignec to car *y out procecuras; devices used in coniunction with the precedures; etner assignments or activities to be performed by personnel concurrently with their execution of detection ::cotecur',, provisiens for Jocumentation of inspection procecures teing executed (e.g., log); cescriot.on of the ::roce-dures themselves; and any tecnni:;ues eaoloyed for ranccmization of patrols.

CHAPTER 3 ACCESS : NT:CL This chapter provices guidance on meeting the requirements of paragra::hs 73.47(:)(4), (d)(5),

(d)(S), (d)(7), and (d)(10) wnicn are as follcws:

(d)(4)

Corduct screening prior to graating an individual unescorted access to tre c:ntrolled access area Lere the material is us s or stored, in orcer to octain information :n

.nicn to case a decision to ::er74t sten access, (d)(5)

Develop and maintain a c:ntrolled cacging and lock system to icentify and limit access to controlled access areas to authori:ied individuals, (d)(6)

Limit access to tse controllea access areas to autnori:ed or esc:rtec incivicuals.co recuire suci access in orcer to per'orm their cuties, (c)(7)

Assure that all visitors to the controlled access areas are ancer *?e c:nstant esc:r'.

of an individual.no has teen authori:ec access to the area, (d)(10)

Search on a randem easis vehicles and packages leaving tne c:ntrolled access areas.

o. ; 30E:UTHORIZATICN SCREENING (73.47fdW4 H Intent The intent of the recuirement for ::reauthorization screenirg is to assure tnat &e ticeasee will have sufficient kncwledge of an ircividual to cetermire '.is reli scility arc -aec f:e accast OC h

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prior to ; ranting him authori:ed access to the CAA.nere the material is used or stored. The selection of prececures for conducting this examination and tne criteria he employs to maKe nis judgments are the rescensibility of the licensee, anc of course snould be consistent nita all local, stata and feceral laws and regulations regarding the protection of the privacy and otner rights of the individual. The screening process 9ay te conducted in tne same manner as other investigations custcmarily concucted Oy potential emoloyers for similarly sensitive cositions.

There is no recuirement for the licensee to arrange for an NRC clearance or similar clearance f rom any other government organi:ation. Examples of procedures and critaria wnicn may be employed in the screening process incluce: holding of or having recently neld a government sanc-tioned clearance; examinatien of past employment or educational record (to determine any unsatis-factory employment or school actions or incidents which would indicate any unreliability or previous breaches of trust between the individual and his employer); encorsements or references from previous employers, teachers, or colleagues which would support the need for access, trust-worthiness and reliability of the individual; and consideration of the indivicual's present ecoloyment record indicating demonstrated trustnorthiness and reliaDility over an extenced period of employment with tt; licensee. (This may be c:nsidered in the nature of "grandfathering.")

Centent Cescrite the procedures and criteria that will ce used for ootaining sufficient information needed prior to making a cecision on granting unescorted access er authorization to an indivicual to CAAs =nere the material is used or stored. Icentify the types of individuals =no.ill ce screened (e.g., process engineers, supervisory personnel, professors, instructors, gracuate students, etc.) and who wiil perform the screening process.

3.2 BADGING SYSTEM f 73.a7(dMS))

Intent The purpose of the bacging system is to facilitate access centrol of authori:ed indivicuals into or within the CAA.here the material is used or st: red.

Information on the cacge snoulo be such that i o is possible to clearly distinguisn personnel authori:ea access to tne CAAs from those recuiring an ascort. Information en tne tacge snould also uniquely icentify ne indivicual ossessing the badge. This personalized informaticn can te cotaired througn the use of :noto-gracns, ;ersonal vital statistics, signatures, or any means the licensee may wish to use tnat will uniquely identify the individual.

Centent Jescrite the bacging system used to facilitate c:nt-cces to the CAAs. This descr';-

tion shuuld include 3.

th si:e, snace, co!ce and material c:nstru b.

the distinguisning features of the :acge that m ati'y

.tnori:eo ro:vicuals frem escorted individuals.

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how the bacges will be used for controlling access. (For exanole, will all individuals be checked prior to entering the CAAs or will periodic checxs te made of individuals within a CAA to determine if they are authorized or under escort or mill the bac;e itself permit authori:ed entrance sucn as a card key.)

d.

the system used for issuing, controlling, and accounting for the badges.

3.3 LCCX SYSTEM (73.47(dH51)

Intent Locks used to control access to CAAs should be resistant to manipulation or picking, and should not be mastered. Examples of typical lock systems wnich fit this description are: three-position dial-type comoination locks, six pin key locks, and card-key lock systems. The procedures for assigning keys and combinations to individuals is an integral part of the lock system and should be designed to assure that only authori:ed cersonnel have access to such items. Locks and comoinations should be enanged when information is octained that the lock system may have been compromised. Further information may 5e cotained in Regulatory Guice 5.12, "Ceneral Use of Locks in the Protection and Control of Facilities and Special Nuclear Material."

Content Describe the system for the locking system used to control access to the CAAs wnere material is used and stored. This description should include: locations of all locks incluced in the system by type of lock; the pick-resistant and manipulation-resistant characteristics of each lock type used; personnel responsible for issuing keys or comeinations and changing comoinations or locks; criteria for cnanging comoinations or locks; personnel authori:ed to be given keys or comoinations; and descriptions of types of locks used (references may be mace to Regulatory Guice 5.12 for tnis purpose).

3.4 ACCESS CCNTRCL DESCRIPTION (73.47(d)(61)

Intent The success of other access control system comconents, such as ::reauthorization screen-ing, tacging, and lock control, is cependent upon effective control of ::ersonnel access into the CAA.

Physical access may te controlled in a numcer of dif ferent.ays depending upon the actual configuration of the CAA and other site specific factors. Some examples of these alternatives are:

a.

Control by Authorized Peeson If the area to be controlled is suf ficiently small arc free of ocstructicns, an authorized person performing other activities in a CAA may effect anysical access control by monitoring entry into the area of unauthori:ed ;ersons. A sign ::osted at the entrance.culd nelp ceter casual passers ey.

A typical acclication of this accroach would oe the case of a lacoratory instructor conducting a class in.nich he is familiar nitn each of nis stucents and could aasi b rec 0gni:e unauthori:ed ::ersons not in the class.

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Card dev. Ccmoinatien or <ey Lock Centrol System A more soonisticated, hareware oriented system involves the use of a card key, comoination or key lock system. Physical access control in this case censists of the use of anysical barriers to deter unauthorized persons. A limited numoer of entrances are provided which are controlled by authorized personnel using a card key comoination or key.

This system may be more usefai

-nen larger numbers of authorized personrel, wno nould not necessarily te f amiliar with one another,

.ould need to share the use of tne CAA.

c.

Control by Security Orcanization If security organization personnel are available, physical access control may be accomplished by stationing a person at the entrance to the CAA to check icentification and allow only authorized

ersons into the CAA. This alternative may be unjustifiably expensive unless the security organi-zation memoer's salary can be justified on other grounos as well. A variation of this system requires persons seeking entrance to the CAA to obtain a key from a procerly designated person or security organization for each use.

Content Cescribe the system for limiting physical access to each CAA identified in Sections 1.1 and 1.2 to only authorized personnel or those escorted by authorized personnel. Include in this description the names or titles of individuals granting access authorizations, the criteria to be used in grarting authorizations, the procedures used to assure only authorized or properly escorted persons are allowed access to the CAA. Reference can be mace to Secticns 3.1, 3.C.

3.3, 3.5, and 3.6 of this chacter as they af fect tnis section, to the cescriptions of lock barriers, or other hare.are.nich are usea to control access.

3. 5 ESCCRT SYSTEM CESCRIPTICH (73.a7(d)(7))

Intent The intent of requiring that an escort system be estaclisned is in recognition of the fact that the licensee may wish to allcw access to certain cersons or classes of perscos on a temcorary or infrequent basis, or on short notice, thus maxing the routine crocess for granting access authorizations impractical or inexcedient. Typical arrangements for escorted access may incluce escorts for maintenance or repair personnel, lacoratory classes, puolic tours, guests and visitcrs as required.

Co, tent Describe the system that will be used to escort individuals in the CAAs. In nis security olan, the licensee should assure that only procerly authorized iroivi:uals will ce al!cwed to escort indivicuals. This cescription should include:

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criteria to te used for granting escorted access, c.

criteria to e used for escorting others, c.

procacures for escorting indivicuals into CAAs (e.g., stocents under sucervision of lao instructor, puolic tours, etc.),

d.

the numcer of escorted indivicuals per escort, and e.

the responsibilities of tne escort se.g., periccic surveillance of all indiviacals under escort, accounting for all material prior to leaving tre CAA, remainirg in gererai area during the time unauthoriced individuals are present, etc.).

3.6 SEARCH CESCRIPTICN (73.47(d)(10))

Intent The pri=.ary intent of the searcn requirement is to ceter and pcssibly cetect attempted theft 3 of SNM. The searen prececures ceveloped by the licensee snould take into consiceration the envi-ronment anere *ie material is used or storea, the cnysical characteristics of the 9aterial itself, and the frecuency of accounting for the material. In some cM es, this will require that all venicles and packages leaving the CAAs te seartned in a randem manner. The frecuency of aancom-ness should be determined by the ease with whicn tne material can be stolen and tne length of time it would take to cetect a theft _ In other cases only packages.nicn ecual or exceed tre size of the material teing used or stored would nave to be seirened, taking into consiceration the difficulty with wnich the material could be broken into smaller more easily concealed parts.

Content Cescribe the systen to be used for nncemly seartning venicles or cackages that leave tre CAA.

Incluced in the cescription snould te information as to 1.

the sccce of the se&rch -

the criteria that will be used for searcning venicles and ::ackages (e.g.,.reiner all cacxages and venicles are suoject to search or just tnose packages or senicles nic1 are larger tnan the smallest configuration of material teing used or stored).

2.

the cancomness of the search -

the ranccaness can vary frem suojecting each package or venicle to a search, to using a ranccm numcer generator for cetermining nether a candicate cackage at ve'ticle is to te searched, to searcning a minimum percentage of all packages or venicles leaving encn cay from the CAA.

CHAPTER.1

$ECURITY ORGANIZATICN DESCRIPTICN This chaoter orovices quicance on reeting the recuirements of paragracn 73.a7(c;( 3).nicn states:

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Establish a security organization or modify the current security organization to consist of at least one watenman* per shift able to assess and rescend to any snauthorized pene-trations or activities in the controlled access areas.

4.1 SECURITY ORGANIZAT!CN (73.47(d)(81)

Intent lhe intent of this requirement is to assure that in the event of a security incident someone will be available to assess alarms or other unauthori:ed penetrations or activities and, if warranted, notify the NRC, the local law enforcement authorities, and the responsible person in licensee management. Early detection and notification of any missing material will help facil-itate its prompt recovery. In some cases the licensee may assign additional duties to memoers of the security organization, wnere procedurally oriented options are chosen to satisfy pnysical protection requirements (e.g., periodic patrols and inspections of CAAs for storage of SNM).

Security organi:ation memcers are not required to be fully dedicated, full time employees of the licensee. They may incluce unarmed campus security personnel," contract guards, memoers of the local law enforcement agency (if sufficiently close to the site), etc. No for:nal or com-prenensive. training program is recuirea for security organization personnel. However, under 10 CFR Part 73, Appendix 3, the licensee should be prepared to cemonstrate that each security person understands and is fully qualified and trained to perform those particular duties assigned to him.

Content

escribe the security organization wnich will be rescensible for assessing and resocnding to security incidents. Indicate the other responsibilities of the security organization such as:

a.

conducting periodic physical security cnecks of CAAs, b.

maintaining liaison with the local law enforcement agency, c.

notifying the local law enforceme.t agency of any unauthorized penetrations or activ-ities in the CAAs, and d.

notifying licensee management of any unauthori:ed penetrations or activities in the CAAs.

CHAPTER 5 CC WUNICATIONS This cnacter provides guidance on ?.eeting the requirements of paragraoh 73.47(d)(?.nich states:

(4)(9)

Drovice a communication cacamility cetwe a the security organization and approcriata resconse force.

4 A "watenman is cefined in '.0 CFR Part 73.2 as Sn indivicual, not necessarily unifor :ec or d

imea 4th a firearm, nno orovides protection for a clant and the soecial nuclear material inerein in the course of performing other cuties.

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5.1 C0f*'UNICATICN SYSTEM DESCRIPTION (73.47(dF9))

Intent The intent of this regulation is to assure that a communication capability exists between the licensee and the designated response force. It is imolied that orior to setting up a ccmmuni-cation capaDility, procedures and respon!icilites will have betr. established between the response force and the licensee. (Note: see Chapter 6 aessonse Procecures.) The type of communication system chosen by a licensee should:

a.

provide for a full duplex voice communication capability, b.

De easily accessible to the licensee's securtty organization, and c.

be reliaDie and availacle for immedia' 1 use at any time.

Some communication systems whicn would orovide these capabilities are: dedicated telephone system, non-dedicated pt.blic telephone system, radio, or any ccmbination thereof.

Content Describe the ccmmunication system which is used between the security organization and the appropriate response force. Incluced in this description should be information on:

a.

type of communication system, b.

location of voice terminals in relationship to CAAs, c.

availability of communication system on a 24-hour basis, and d.

reliability of C0mmunication system.

CHAPTER 6 RESPCNSE PROCEDURES This chapter provides guidance on meeting the requirements of paragracn 70.47(d)(11) anich states:

(d)(11)

Establish and maintain respoase procedures for dealing with threats of thefts or thefts of sucn materials.

6.1 RESPONSE PROCEDURES CESCRIPTION (73.47(d)(11))

Intent The intent of this regulation is to help the licensee identify those security incidents wnicn c0uld result in the loss of SNM of mocerate strategic sign:ficance and to cevelco resconse orececures to prevent or reduce the likelihood af sucn a loss. Some types of incicents nicn should te considered and for wnich resconse procecures should te develooed are:

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civil strife such as stucent demonstrations or employ?e strikes, b.

fire, c.

ciscovery that some SNM is missing, and d.

bemo threats.

Content Identify those events for which response peccedures will be developed. Also describe the type of response to be accomplished for each event identified and the ccties and responsibilities of the security organization and management involved in the response. Assure that the NRC will be notified immediately in the event of theft or attempted theft of the material. Describe what local law enforcement assistance is available, their response capabilities, and any agreements made with them to respond in the case of thef t of the material.

CHAPTER 7 W TERI.L TRANSPCRTAT!CN RECUIREMENTS This chapter provides guicance on meeting the requirements of paragraon 73.47(e)(1) wnicn are as follows:

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Eacn licensee wno transports, exports, or delivers to a carrier for transport special nuclear material of moderate strategic significance riiali:

(i) Provide advance notification to the receiver of any planned shipment specifying the mode of tcansport, estimated time of arrival, location of the nuclear material transfer point, name of carrier and transcor, icentification, (ii) Receive confirmation from the receiver criar to the commencemen'. of the lanned shipment tnat the receiver will ::e reaoy to accept the snigment at the plannec time and location and that he acknowledges the scecifiec.moce of transport, (iii) Transport the material in a tancer indicating sealed container, (iv) Check the integrity of the containers and seals prior to snioment, anc (v) Arrange for the in-transit physical protection of the material in accorcance ~ith the requirements of paragrapn 73.47e(3) of this part, unless the receiver is a licensee and has agreed by written contract to arrange for the in-transit physical protection.

7.1 ADVANCE NOTIFICAT!CN CESCRIPT!CN (73.27(eH 1 M il Intent It is tha intant of this section that tne sniocer.ill have preclanned the transportation af the material and informed the receiver of nis clans prior to sii:: ment. This is the first of O

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the several transportation requirements that will allow the receiver to take delivery of the material as slanned or to help assure traceacility of ans missing material that m;nt occur.

Centent The licensee should assure, in his security plan, that prior to eacn shipment of material, notification of the impending shipment will ce given to the receiver provicing him with the f:,i-lowing types of information:

a.

mode of transport (e.g., truck, plane, train or sh g),

b.

estimsted time of arrival, c.

location where material is to be transferred to receiver, d.

name of carrier, and e.

transport identification (e.g., truck, train, or flight numoer, snia name, etc. ).

7. 2 RECEIVER CCNFIRMATICN CESCRIPTION (73.47(e)(1)(ii)

Intent It is the intent of this recuirement that prior to shipment the shipper will be assured that the receiver is ready to accept the shipment at the planned time and location and acknowledges the moce of transport.

Content Describe wnat procedures will be used to assure that shicment of material does not take place until the receiver acknow' edges the planned shipment and moce of trarsport, and that ne will be ready to accept the shipment at the olanned time and location.

7. 3 CCNTAINER CESCRIPTICN (77. 47(e)(1)(:))

Intent The intent of this recuirement is to provide a mechanism or system that will helo the receiver detect any tamcering that may have occurred with the material's container during ship-ment. Regulatory Guice 5.15 entitled, " Security Seals for the Protection and Control of Special Nuclear Material," is available from the NRC for guidance in this area. Recuirements for con-tainers are contained in 10 CFR Part 71 and a smary report of accroved containers is in NUREG-0383.

Content Describe the types of seals that will be used to monitor the material's container during transcort.

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7. 4 IN5DECTICN CESCRIPTICN (73.47)(e)(ivi)

Intent It i? the intent of this requirement that the snipper check the integrity of the material container's seals just prior to shipment, so that he can te assureo tnat they naven't ::een compromised. Then, if upon receipt of the shipment, the receiver discovers the container's integrity has been ccmoromised and the material missing, the sccpe of the recovery operation can focus on the transportation route.

Content Cescribe the procedures to be used to assure

• hat the integrity of the containers or seals is checked just prior to shipment.

7.5 IN-TRANSIT DHYSICAL PROTECTICN (73.47(e)(1)(v))

Intent It is the intent of this requirement that either the shipper or receiver be mace responsible for the chysical protection of the material while it is in transit and that the resconsible licensee has ackowledged this responsibility by written agreement.

Content In his security plan, the ship 0er should either acknowledge responsibility for the in-transit pnysical protection of ShM of moderate strategic s!gnificance, or assure that written agreement from the receiver licensee has been received in wnien the receiver either accents full resoonsi-bility or shared responsibility for the in-transit physical protection of this material accaroing to 10 CFR Part 73.47e(3).

CHAPTER 3 RECEIVER RECUIREMENTS This chapter provides guicance on meeting the recuirements of paragraoh 73.47(e)(2).nich are as follows:

(e)(2)

Each licensee who receives special nuclear material of moderate trategic significance shall:

(i) Check the integrity of the containers and seals ucon receipt of the shicment, and (ii) Notify the shipper of receipt of the material as recuired in 70.54 of Part 70 of this cnacter.

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(iii) Arrange for the in-transit physisal protection of tne matarial in accordance with the requirements of paragraph 73.47e(3) of this part unless the shiccer is a licensee and has agreed in writing to arrange for the in-transit anysical protection.

8.1 INSPECTICN DESCRIPTICN (73.47(e)(2)(i))

Intent This requirement is intended to determine whether t-

.terial's container has been com-promised enroute and whether any material has been removeu so that immediate recovery 7rocedures can be initiated, if required.

Content Describe the procedures to te used to assure that the integrity of the containers and seals will ce checked upon receipt of the shipment of material.

8.2 NOTIFICATICN DESCRIPTICN (73.47(e)(2)(ii))

Intent This recuirement is intended to:

a.

allow that knowledge of the current location of all SNM is availaole, and b.

formally inform the ship;er that the material has teen received.

Content Assure that a comDieted C0py of standard Form NRC-741, " Nuclear Material Transaction Recort,"

will be sent to the shipper <itain (10) days of receiving a snict.ert of material as recuired in j 70.54 of Part 70 of 10 CFR.

S.3 IN-fRANSIT PHYSICAL DQCTECTICN (73.47(31(2)(iii))

Intent It is the intent of this requirement that either the licensee receiver or shipper be made resconsible for tne anysical protection of the material while it is in transit and that the resconsible person has acknowledged this resconsibility by written agreement.

Content In his security plan, the receiver snould either acknowledge resconsibility for the in-transit ohysical protection of SNM of moderate strategic significance or assure that written agreement

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from the shipper nas been received in unich the shipper either accepts full responsibility or snared responsioility for the in transit physical protection of this material according to 10 CFR Part 73.47e(3).

CHAPTER 9 IN-TRANSIT PHYSICAL PROTECTICN RECUIREMENTS This cnacter provides guidance on meeting the reqtitrements of paragrapn 73.47(e)(3).nicn are as follows:

(e)(3)

Each licensee, either shipper or recelser, who arranges for the physical protection

'of special nuclear material of mcderate strategic significance while in transit or wno takes delivery of such material free on board (f.o.b.) the point at which it is delivered to a carrier for transport shall:

(i) Arrange for a telephone or radio communications capability, for notification of any delays in the scheduled shipment, betneen the carrier of the material and the shipper or receiver, (ii) Minimi:e the time that the material is in transit Ly reducing the number and dura-tion of nuclear material transfers and by routing the material in tne most safe and direct manner.

(iii) Oonduct screening of all licensee employees involved in the transportation of the material in order to obtain information on wnich to base a decision to permit them control over the material, (iv) Establisn ind maintain response crocedures for dealing with threats of thef ts or thefts of sucn material.

(v) w ke arrangements to be notified immediately of the arrival rne snipment at a

its destination, or of any such shipment that is lo.t or unaccounted for after the estimated time of arrival at its destination, and (vi) Conduct immediately a trace investigation of any shipment that is Icst or unaccounted for after the estimated arrival time and report to the Nuclear Regulatory Commission as specified in 5 73.71 and to the shipper or receiver as approp riate. The licensee no made the physical protection arrangaments shall also immediately notify the Director of the accroariate Nucleer Regulatory Commission Inspection and Enforcement Regional Office listed in Accendix A of the ar. tion teing tagen to trace the sniement.

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9.1 CCWUNICATICNS CESCRIPTICN (73.37(eM 3 Mi))

Intent The primary intent of this requirement is to as:.re tha: the carrier will notify the snicper or receiver of any changes in plans or delays in the scheculed arrival of a shipment ta its destination due to mechanical breakdown, adverse environmental conditions, public disarcers.

etc. The shipner or receiver can than decice wnether or not to initiate resconse procecures.

The intent of tnis regulation is not to require periodic check-in. Public telepnone or full duplex voice radio are acceptable methods for meeting the intent of this requirement.

Content Describe the type of communication system ard procedures to be used by the carrier of St.M of mode ate strategir significance for notifying the shipper or recei'.er of any change in plans or delays in arrival.

9.2 MINIMjM TRANSIT TIMES CESCRIPTICN (73.47(e)(3)(ii))

Intent This requirement is intended '1 ha"' the snipper or receiver make a rea;onaole effort to ship the material in the fastest and most direct method possible.

• t is not intanced to neces-sarily require exclusive use carriers or expensive modes of travel.

Content Cescribe the procedures and considerations which apply in the transoortation planning process which assure that a determ'aed effort will ce made to minimi:e transit times.

9.3 PCEAUTN RIZATICN SCREENING (73.47(e)(3)(iii))

Intant The intant of the requirement for preauthori:ation screeni g is to assure that the licensee wil have sufficient know1*cge of an individual to cetermine nis eliability and need for access prior to gra.iting him authorized access to tne material in transit. The selection of procedures for conducting this examination and the criteria he employs to make his judgements are the resconsibility of the licensee, and of course snould be consistent with all local, State anc Feceral laws and regulations regarcing the protection of the privacy and cther rignts of :ne indivicual. Tha screening process may oe conducted in the same manner as other investigations custcmarily conw.;ed by potential employers for similarly sensitive positions. There is no requirement for the licensee to arrange for an NRC clearance or simi'ar clearance from any otner government organi:ation. Examoles of procedures and criteria wnich may te emoloyed in tre screening process incluce: holding of or having recently neld a ;pvernment sanctionec clearance

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examination of past s.mplo, ment recorc (to determine any us atisfactory employment or incicents wnicn would indicate ?.ny unreliacility or previous breaches of trust netween the individual and his employer); endorsements or references from previous employers or colleagues wnich would support the need for access, trustworthiness, and reliaoility of the individual; and considera-tion of the individual's present employment record indicating demonstrated trustworthiness and reliability over an extended period of employment with the licensee. (This may be considered in the nature of "grar.dfatherino.")

Content Describe the procedures that will be used for obtaining sufficient information prior to making a decision on gr3nting unescorted access authorization to those licensee employees who will be involved in the transportation of the material. Identify by title or name those employees whn will be screered and those who wil' erform the screening process.

9.4 RESPONSE PROCECURES DESCRIPT e (73.a7(eM 3M iv))

Intent The intent of this regulation is to help the licensee identify those transportation incidents for wnich he might expect to be, otified and which mignt affect the security of the SNM in transit ano to plan response procedures tor such situations. For example, if the shipper is informed by the carrier that :dverse weather conditions nave temporarily prevented further progress of the shipment, the licensee should inform the receiver of a new estimated time of arrival.

Content Identify those events for which response procedures will be developed. Also describe types of response to be accomplished for each event identified and the duties and responsibilities of members of the security organi:ation and management for dealing with the response. Assure that the NRC will be notified immediately in the event of theft or attempted theft of the material.

9.5 NOTIFICATICN DESCRIPTICN (73.47(eM 3H v))

Intent The intent of this requirement is to assure that the licensee responsible for the anysical protection of $hM in transit will have a firm basis for deciding whether or not to initiate response procedures in the event a snigment becomes overdue or is lost.

Content Cescribe the arraagements and procedures.nicn nill oe used for actifying the licensee.no arranges for the physical protection of material in transit of the arrival of the sniement at b '

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Its destination, or of any such snipment that is lost or unaccounted for after the estimated time of arrival at its destination.

9. 6 LOST MATERIAL NOTIFICATION (73.47(e)(3)(vi))

Intent The intent of this requirement is to assure that in case a shipment beccmes overdue, and no reasonable explanation has been received frcm the carrier regarding its status, a trace investigation will be conducted to locate the missing SNM. The NRC is to be notified at this time that the material is missing and informed as to what steps are being taken to recover the missing material. Although the licensee is esponsible for notifying the-NRC of any missing material and to initiate and assist in the.w sequent investigation, the law enforcement agencies bears the responsibility for physically recovering the material.

Content Describe what procedures will be used to trace any shipmment that is lost or has not arrived by the estimated arrival time. Assure that all lost or missing material will be immediately reported to the appropriate NRC Regional Office along with what actions are being taken to trace t:,e snigment, that the NRC will be notified as scecified in 5 73.71 and that the snipper or rsceiver, as appropriate, will also be notified.

CHAPTER 10 EXPCRT nUIREMENTS This chapter provides guidance on meeting the *<cuirements of paragraph 73.47(e)(4) whicn reads as follows:

(e'a 4)

Each licensee wno excorts special nuclear material of moderate strategic significance shall comply with tre requirements specified in $ 73.47(c), (e)(1) and (e)(3).

10.1,5ECURITY DESCRIPTICNS (73.47(e)(3))

apttrs 7 and 3 of this guide to describe the security procecures anich will be used to w

, the material up to the point where the receiver accepts physical protection responsi-bility for the shipment.

CHAPTER 11 IMPORT RECUIREMENTS This chapter provides guidanci on meeting the requirements of paragracn 73.47(e)(5).hich reads as follows:

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Each licensee who imports special nuclear material of mcderate strategic significance shall:

(i) Comply with the requirements specified in 3 73.47(c), (e)(2) and (e)(3), ano (ii) Notify the exporter who delivered the material to a carrier for transport of the arrival of such material.

11.1 SECURITY RECUIREMENTS (73.47(e)(5)(i))

Use Chapters 8 and 9 of this Standard Format to describe the security procedures which will be used to protect the material frota the first point where the shipment is picked up inside the United States, 11.2 NOTIFICATICN (73.47(e)(5)(fi))

Intent The intent of this requirement is to notify the exporter that the material has arrived safely.

Content Describe the procedures to be used for notifying the exporter " the material that the snip-rent has teer, received.

PART II: SNM CF t.CW STRATEGIC SIGNIFICANCE CHAPTER 12 USE AND STCRAGE AREA DESCRIPTICN This cnapter provides guidance on meeting the requirement of paragracn 73.47(f)(1).nich is is follows:

(f)(1)

Store or use sucn material only within a controlled access area.

A controlled access area is defined in 73.2 paragrapn (z) as, "any temcorarily or pernanently establisned clearly demarcated area, access to whicn is controlled and which affords isoiation of the material, equipment or persons within it."

Thus a CAA can te an approved.ecurity caninet with lock to wnicn only authorized individuals nave the camoinaticn or key or a vault or vault-type room which uses some type of act:ss control system to limit access to authorized individual or a locked lacoratory for wnicn only authorized individuals sucn as professors or lab instructors have the comoination or key.

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12.1 AREA WERE MATERIAL IS USED (71.47(f1(1))

Intent Temporarily established CAAs for the use of SNM need not have permanent type physical barriers at their bouncaries. Office partitions, corcons or other devices car, be used to warn cassers-ty of the restricted nature of the area, while tcc".,5 control can be ef fected through sur' eillance or supervision of the area by those usiLg the 5hM at the time. However, if the material is to be left unattenced in such an area, additional protection must be proviced to control access and assure a detection capability 4 the absence of authorized personnel. This could be accom-plished, for example, through the posting of signs and the use of motion detection equipment covering the immediate area in which the SNM is locned. Although the material may ce considered in "use," protection requirements would be the same as thougn the material cere in storage, since authorized personnel wculd not be present.

Permanently designated aceas fcr the use of SNM would more closely aporoximate CAAs intended for the storage of SNM.

In this case, permanent type physical barriers would be a more likely choice, such as would be provided in the case of a laDoratory or reactor containment structure, in which it was cesired to have SNM continually present and in use. Such an area may also serve as a storage area. Although access control and detection capabilities may be proviced through the use of apprenriate harcware during the period when SNM is stored in this area, other means of providing these capabilities may be required to complement such harcware in the case that alarms are deactivated or doors unlocked, etc. In such cases, licensees may rely upon autNr-ized perscanel to effect the required protection.

Content Cescribe the Controlled Access Area (CAA).nere the material will be used. To be incluced in this cescription is information on the type of barriers surrounding the CAA, the portals that allow access to the CAA, and the size of the area. Some typical CAAs where the material may be used are: lacoratories, process areas, reactor reoms, scent fuel pools, or fenced-in areas.

12.2 3REA 'aHERE MATERIAL IS $TCRED (73.47(f)(11)

Intent This area may be similar to that required for the storage of special nuclear material of moderate strategic significance (see Chapter 1, Section 1.2 of this Guice), but does not w es-sarily have to be equivalent to a vault, vault-type room, or accroved security catinet. Examcles of typical CAAs =nere special nuclear material of low strategic significance may te stored are:

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Approved Security Cabinets - cabinets wnicn are GSA accroved, class 6 or greater, or cther testing group approved for protection against surreptitious er..cy and lock manipulation.

3.

Reactor - the reactor is so designed that it does not allow for easy removal of ma N rial.

4 Vault-type Room - some typical vault-tyce rooms where materials are stored and protected with 4. motion detector are storage pools, rooms containing in process storage racks and laboratories where material is lef t unattended. In all cases mevement in the near-vicinity of the material should generate an alarm sign 61.

5.

Locked laboratories or Supply Rocas - these areas must be sufficiently penetration resistant to afford a means of access control and permit the proper functioning of the system for monitoring of the storage area as required under 3 73.47(f)(2) of the rule as described in Chapter 13 of this guide.

Content Describe in detail the CAA in wnich the material will be stored. To be included in this description is information on the type of barriers surrounding the material, the portals that allow access to the material, the size of the area, and the locking mechaaism used to secure the material (see Chapter 3 of this guide for guidance on locking mechanisms).

CHAPTER 13 DETECTION DEVICES OR PRCCEDURES This chapter provides guidance for meeting the requirement of 73.47(d)(3) wnicn is as follews:

(f)(2)

Monitor with an intrusim slarm or otner device or procedures the controlled access areas to detect unauthorized penetration or activities.

In order to help detect unauthorized activities or penetrations of CAAs.here the material is used or stored either intrusion alarms or otner devices or security procedures are needec.

Jection 13.1 provides guidance if the licensee chooses to use intrusion alarms or devices and Section 13.2 provides guidance if he chooses to use security procedures.

13.1 DETECTION DEVICES (73.47(f)(2))

Intent For CAAs wnere the mateilal is used the licensee will precaoly <isn to rely upon personnel-oriented procedures for assuring that the CM is not penetrated inadvertantly or purposefully by unauthorized personnel. However, material left temporarily unattended shculd be protected oy a motion detector (e.g., suspended frem acove) which incorporates adequate tamcer resistant features. Licensees snould design their system to minimize the este of scurious or f alse alarms througr. ;."cer installation and precedures.

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For CAAs wnere the material is stored, the cetection capability will be satisfied through the use of motion detection equicment. However, the detection capacility requirement may also be satisfied by different types of safety detection devices or security procedures. Information re garding intrusion alarm devices wnich could be used is available in NUREC 0320, " Interior Intrusion Alarm Systems." However, any choice of detection device, intrusion or safety, must include tamper-resistant featores.

Content Describe the tamper-resistant intrusion alarm devices or tamper-resistant safety devices which are used to monitor the controlled access areas (CAA) where the material is used and st0 red.

Included in this description should be:

a.

type of davice used with brief theory of operatio1, b.

location of detection device, c.

type and location of annunciation, of coverage, d.

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tamper-resistant features, f.

signal line protection features, g.

emergency pcwer features for devices, and h.

conditions under which detection devices will be use-J 13.2 DETECTICP' PROCEDURES (73.a7(f)(2))

Intent Licansees may choose to provide the required detection capacility during certain periods through reliance on personnel-oriented procedures rather than by the use of detection devices.

This may be desirable during periods of heavy usage of material, wnen frequent traffic into and out of a CAA may make the use of an intrusion alarm system inccnvenient. Authorized personnel engaged in the use of the material or otherwise present within the CAA or its immediate vicinity may satisfy the cetection capaDility requirement provided they can reasonaoly maintain surveil-lance over the material and control access to t9e CAA or its immediate vicinity. nile carrying on the other activities tney may be engaged in.

At least one authorized person snould r.,e present at all tt,es in the acsence of detection devices wnile the material is in use.

If the material is in storage in an approved security cabinet or its ecuivalent, the material may be lef t uni.. ended without an intrusion alarm system provided some other detuction procedure is employed. This may include remota surveillance, using a closed-circuit television systam, or rancomized periodic patrols by a watchman.

Content Cescribe, if acplicable, the procedures <nich are used or may be used to monitor the c:n-trolled access areas.nere the material is used or stored. These descriptions should include:

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the conditions under which the procedures would be t,3ed; the CAAs for anich the procedures would be used; individuals, categories of individuals, or personnel positicns assigned to car / out procedures; devices used in conjunction with the procedures; other assignments or activities to be performed by personnel conturrently with their execution of detection procedures; provisions for documentation of inspection procedures being executed (e.g. log); and cescription of the procedures themselves.

CHAPTER 14 SECURITY RESPONSE This chapter provides guidance on meeting the requirement of paragraph 73.47(f)(3) which is as follows:

(f)(3)

Assure that a watchman or offsite response force will respond to all unauthorized penetrations or activities.

14.1 SECURITY f73.a7(f)(3))

Intent The intent of this requirement is to assure that in the event of a security incident scmeone

. vill be availaole to assess alar s or any unauthorized penetrations or activities and, if warranted, notify the NRC, the local law enforcement authorities, and the responsible person in licensee management. Early detection and notification of a'ay missing material will help facilitate its prompt recovery. For purpose of this regulation, an offsite response force can be a local law enforcement agency or a contract guard service.

Content Describe the security organization which will be responsible for assessing and responding to any unauthorized penetrations or activities. Assure that at least one guard, watenman, or memcer of an of fsite response force will respond to all unauthorized penetrations or security incidents at the CAAs.

CHAPTER 15 RESPONSE PRCCECURES This chaoter provides guidance on meeting the requirements of paragrapn 70.47(f)(4) anicn states:

(f)(4)

Estaolish and maintain response procedures for dealing with threats of tnefts or thef ts of such materials.

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15.1 RESDCNSE PROCECURES CESCRIPTICN (73.47 (f)(4))

Intent The intent of this regulation is to help the licensee identify those security incidents anicn could result in the loss of SNM of low strategic significance ano to develcp resconse pro-cedures to prevent or reduce the likelihoor. e' such a loss. Some types of incidents which should be considered and for which response procedures should be developed are:

a.

civil strife such as student demonstrations or employee strikes, b.

fire, c.

discovery that some SNM is missing, and d.

bomb threats Content Identify those events for which response procedures will be develoDed. Also describe the type of response to be accomplished for each event identified and the duties and responsibilities of the security organization and management involved in the response. Assure that the NRC will be notified immediately in the event of theft or attempted theft of the material. Describe anat local law enforcement assistance is aval.lable, their response capabilities and any agreements made with them to respond in the case of theft of the material.

CHAPTER 16 MATERIAL TRANSPORTATION REQUIREMENTS This chapter provides guidance on meeting the requirements of paragrach 73.47(g)(1) anich are as follcws:

(g)(1)

Each licensee who transports, exports, or ano delivers to a carrier for transport special nuclear material of low strategic significance shall:

(i) Provide advance notifiration to the receiver of any planned snipments scecifying the mode of transport, estimated time of arrival, location of the nuclear material transfer point, name of carrier and transport identification, (ii) Receive confirmation from the receiver prior to the comencement of the planned shipment that the receiver will be ready to accept the snipment at the planned time and location and that he acknowledges 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 shipment, and (v) Arrange for the in-transit physical arctection of the material in accordance nitn the requirements of paragraon 73.47(g)(3) of tais part, unless the receiver is a 31 O Enclosure "C" a

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16.1 ADVANCE NOTIFICATION CESCRIPTION (73.47(c)(1(ii)

Intent It is the intent of this section that the shipper will have preplanned the transportation of the material and informed the receiver of his plans prior to shipment. This is the first of the several transportation requirements that will allow the recei.er to take delivery of the material as planned or to help assure traceaoility of any missing material that might occur.

Content The licensee should assure that prior to each shipment of material, notification of the impending shipment will be given to the receiver giving him the following types of infor' nation:

a.

mode of transport (e.g., truck, plane, train or ship),

b.

estimated time of arrival, c.

location where material is to bo transferred to receiver, d.

name of carrier, and e.

transport identification (e.g., truck, train, or flight number, ship name, etc.).

16.2AECEIVERCCNFIRMATICNDESCRIPTION(73.47(q)(1.Qiy Intent It is the intent of this requirement that orior to shipment the transporter will te assureo that the receiver is ready to accept the shi;; ment at the planned time and location and acknowiecges the mode of transport.

Content Cescribe what procedures will be used to assure that snipment of material cces not take place until the receiver acknowledges the planned sniement and acce of transport, and assures ne will te ready to accept the snipment at the planned time and location.

16.3 CONTAINER DESCRIPTICN (73.47(o)(1)(iiii)

Intent The intent of this requirement is to provide a mechanism or system that will relp the receiver cetect any tampering that may have occurred with the material's container curing snip-ment. Regulatory Guide 5.15 entitled Security Seals for the Protection and Control of Scecial Nuclear Material," is availaole from the NRC for guicance in this area.

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15.4 INSPECTICN DESCRIPTION (73.a7(g)(1)(iv))

Intent The intent of this requirement that the shipper check the integrity of the material con-tainer's seals just prior to shipment, so that ne can be assured that they haven't been ccm-promised. Then if upon reccist of the shipment the receiver discovers the container's integ-rity has been compromised and the material missing, the scope of the recovery operation cL1 focus on the transportation route.

Content Describe the procedures to be used 'A assure that the integrity of the containers or seals is checked just prior to shipment.

16.5 !N-TRANSIT PHYSICAL PROTECTION (73.47(g)(1)(v))

Intent It is the intent of this reouirement that either the shipper or receiver be made responsible for the physical protection of the material while it is in transit and that the responsible person has acknowledged this responsibility by written agreement.

Content In his security plan, the shipper should either m.vwledge responsibility for the in-transit physical orotection of $NM of low strategic significa1ce, or assure that aritten agreement from the rece'ver has been received in which the receiver either accepts full responsibility or snared resconsibility f or the in-transit pnysical protection of this material according to 10 CFR Part 73.47(g)(3).

CHAPTER 17 PECEIVER RECUIREMENTS This chapter provices guidance on ;neeting the requirements of caragraph 73.47(g)(2) which are as follows:

(g)(2)

Each licensee who receives special nuclear material of low strategic significance shall:

(i) Check the integrity of the containers and seals ucon receipt of the shipment,

(ii) :Jotify the shipper of receipt of the materii' as required in j 70.54 of Part 70 of this chapter, and (iii) Arrange for the in-transit physical protection of the material in accordance with the requirements of paragraph 73.47(g)(3) of this part, unless the shipper is a licensee and has agreed in writing to arrange for the in-transit physical protection.

17.1 INSPECTICN DESCRIPTION (73.47(q)(2)(i))

Intent This requirement is intended to determine whether the material's container has been com-promised enroute and whether any material has been removed, so that immediate recovery proce-dures can be initiated, if required.

Content Describe the precedures to be used to assure that the integrity of the containers and seals will be checked upon receipt of the material shipment.

17.2 NOTIFICATION DESCRIPTICN (73.47(q)(2)(ii))

This requirement is intented to:

a.

allow that knowledge of the current location of all 'NM is available, and b.

formally inform the shipper that the material has been received.

Content Assure that a completed copy of standard Form NRC-741, " Nuclear Material Transaction Report,"

will be sent to the shipper within (10) days of receiving a material shiement as required in j 70.54 of Part 70 of 10 CFR. 17.3 INorRANSIT PHYSICAL PROTECT!CN (73.47(q)(2)(iii))

Intent It is the intent of this reoutrement that eithe r the receiver or shipper licensee ce mace responsible for the pnysical protection of the mate si wn a it is in transit and that the responsible licenge has acknowledged this respons

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Content In his security plan, the receiver should either.: knowledge responsibility for the in-transit physical protection of SNM of low str3tegic significance, or assure that written agreement from the shipper has been received in which the shipper either accepts full responsi-bility or sha ed responsibility for the in-transit physical protection of this material according to 10 CFR Part 73.47(g)(3).

CHAPTER 18 IN-TRANSIT PHYSICAL PROTECTICN REQUIREMENTS This chapter provides guidance on meeting the requirements of paragraph 73.47(g)(3) which are as follows:

(g)(3)

Each licensee, either shipper or receiver, wno arrange.s for the pnysical protection of special nuclear material of low strategic significance while in transit or who takes delivery of such material free on board (f.o.b.) the coint at which it is delivered to a carrier for trhnsport shall:

(1) Estaclish and maintain response procedures for dealing with th eats of thefts or thefts of such material, (ii) Make arrangements to be notified immediately of the arrival of the shipment at its destination, or of any such shipment that is lost or unaccounted for after the estimated t.ime of arrival at its destination, and (iii) Conduct immer.fately a trace investigation of any shipment that is lost or unaccounted for after the estimated arrival time and recort to the Nuclear Ragulatory Commission as specified in 3 73.71 and to the shipper or receiver as approp riate. The licensee who made the pnysical protection arrangements shall also immediately notify the Director of the appropriate Nuclear Regulatory Commis-sion Inspection and Enforcement Regional Office listed in Acpen<iix A of the action being taken to trace the shipment.

18.1 RESPCNSE PROCEDURE (73.47(q)(3)(i))

Intent The intent of this regulation is to help the licensee identify those transportatien incidents that could affect the security of the SPM in transit for which he might expect to be notified and for which response procedares should be planned.

Content Identify those events for which response prJcedures will be developed. Also describe type of resconse to be accomplished for each event ide' c.ified and the duties and resconsioilities of 1O9 C9 JL i I /..

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the security organization and management involvad in the response. Assure that the NRC will re notified immediately in the event of theft or attempte.1 cheft of the material.

18.2 NOTIFICATION DESCRIPl!CN (73.47(c)(3)(iii)

Intent The intent of this requirement is to assure that the licensee responsible for the pnysical protection of SNM in transit will have a fir's basis for deciding whether or not to initiate response procedures in the event a shipment becomes overdue or is lost.

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Describe tne arrangements and procedures wnich will be used for notifying the licensee who arranges for the pnysical protection of mate-ial in transit of the arrival of the shipment at its destination, or of any such snipment that is lost or unaccounted for after the estimated time of arrival at its destination.

18.3 LOST MATERIAL NOTIF' CATION (73.47 (c)(3)(iif))

The intent cf this requirement is to assure that in the case a shipment ' ecomes overdue, c

and no reasonable explanation has been received from the carrier regarding its status, a trace investigation wiil be conducted"to locate the missing SNM. The NRC is to be notified at this time that the material is missing and informed as to wnat steps are being taken tr -acover the missing material. Although the licensee is responsible for notifying the NRC of 4 sing material and to initiate and assist in the subsequent investigation, the law enforces agancies bear the responsibility for physically recovering the material.

Content Cescribe wnat procedures will be used to trace any shipment that is lost or has not arrived by the estimated arrival time. Assure that all lost or missing material will it immediatpiv reported to the acpropriate NRC Regional Office along with what actions are being taken to trace the shipment, that the NRC will be notified as specified in S 73.71 and that the shippe or receiver, as appropriate, will also be notified.

CHAPTER 19 EXPORT RECUIRE.uENTS This chapter provides guidance on meeting the requirements of paragrapn 73.47(g)(4) wnich reads as follows:

(g)(4)

Each licensee wno exports special nuclear material of low strategic significance shall comply with the requirements scecified in i 73.47(c), (g)(1) and (g)(3).

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19.1 SECURITY DESCRIPTIONS (73.47(q)(4))

Use Chapters 16 and 18 of tnis Standarc Format to describe the security procedures wnich will be used to protect the material up to the point.nere th1 receiver accepts pnysical protec-tion responsibility fo; the shipment.

CHAntR 20 IMPORT REQU??EMENTS This chapter provides guidance on meeting the requirements of paragrapn 73.47(g)(5) which reads as follows:

(g)(5)

Each licensee who import *, special nuclear material of low strategic significance shall:

(i) Ccmoly with the requirements specified in 5 73.47(c), (g)(2) ano (g)(3), and (ii' Nctify the exporter who delivered the material to a carrier for transport of the arrival o.' such material.

20.1 SECURITY RECifiREMENTS (73.47(q)(5)(i))

Use Chapters 17 and 18 of this 3tandard Format to describe the security procedures wnich will be used to protect the material from the first point where the shipment is picked up.

20.2 NOTIFICATION (73.47(qV5)(ii))

Intent The intent of this regulation is to notify the exporter that the material hat arrived safely.

Content Describe the procedures to be used for notif ng the excorter of the material that the shipment was received.

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ENCLOSURE D VALUE/ IMPACT ASSESSMENT CONTAINING A REPORT JUSTIFICATION ANALYSIS PHYSICAL PROTECTION OF PLANTS AND MATERIALS DD J45