Regulatory Guide 5.14

Use of Observation (Visual Surveillance) Techniques in Material Access Areas

ML12191A017
Person / Time
Issue date:	05/31/1980
From:	Office of Nuclear Regulatory Research
To:
References
SG 910-4 RG-5.014, Rev. 1
Download: ML12191A017 (6)

Revision 1*

May 1980

U.S. NUCLEAR REGULATORY COMMISSION

REGULATORY GUIDE

OFFICE OF STANDARDS DEVELOPMENT

REGULATORY GUIDE 5.14 (Task SG 910-4) \JJ

USE OF OBSERVATION (VISUAL SURVEILLANCE) TECHNIQUES

IN MATERIAL ACCESS AREAS

A. INTRODUCTION

Paragraph (e)(9) of § 73.46 provides for observation of individuals within material access areas (MAAs) to ensure Part 73, "Physical Protection of Plants and Materials," that SSNM is not moved to unauthorized locations or in an of Title 10, Code of Federal Regulations, specifies perform- unauthorized manner. Paragraph (h)(7) provides for remote ance requirements for the physical protection of special alarm assessment by at least two security personnel using nuclear materials and associated facilities. Section 73.20, CCTV or other means for assessing alarms occurring in

"General Performance Requirements," describes the general unoccupied vaults and process areas. The value of the performance objective and requirements that must be met observation (visual surveillance) techniques used to meet through the establishment of a physical protection system. these provisions can be enhanced by careful consideration Performance capabilities necessary to meet the requirements of surveillance needs both in the design phase of plant of § 73.20 are described in § 73.45, "Performance Capabil- construction and in the continuing development of opera- ities for Fixed Site Physical Protection." While detection tional procedures and controls.

and assessment requirements are specified throughout the capability statements, specific surveillance and monitoring For the purposes of this guide, visual surveillance and techniques are required under two capability statements of observation are used interchangeably to mean direct or

§ 73.45. Paragraph 73.45(c) permits only authorized indirect visual monitoring of an area for the purpose of activities and conditions within protected areas, material detecting or assessing the activities occurring therein.

access areas, and vital areas. A physical protection system must achieve this by detecting unauthorized activities or This guide describes measures the NRC staff considers conditions within these areas through detection and surveil- acceptable for implementing the requirements of surveillance lance subsystems. Paragraph 73.45(d) permits only autho- or observation within material access areas to ensure rized placement and movement of strategic special nuclear safeguarding of strategic special nuclear material.

material within material access areas. This must be accom- plished through the use of detection and monitoring

B. DISCUSSION

subsystems and procedures to discover and assess unautho- rized placement and movement of strategic special nuclear 1. OBJECTIVE OF VISUAL SURVEILLANCE

material. Finally, § 73.46, "Fixed Site Physical Protection Systems, Subsystems, Components and Procedures," The objective of visual surveillance (observation) in outlines typical specific safeguards measures that will often MAAs is the detection or assessment of activities that could be included in an overall system that meets the general adversely affect the safeguarding of SSNM. This could requirements of Sections 73.20 and 73.45. include, among other things, the direct observation of individuals' normal work functions within MAAs and the Paragraph (e)(3) of § 73.46 provides for the use of remote monitoring of unoccupied areas, e.g., vaults or closed-circuit television (CCTV) as a means of surveillance automated process areas, within MAAs. The physical in all vaults and process areas that contain unalloyed or protection benefits to be derived from visual surveillance unencapsulated strategic special nuclear material (SSNM). include the following:

a. The likelihood that insider considerations of theft or The substantial number of changes in this revision has made it diversion would be reduced because of an awareness of the impractical to indicate the changes with lines in the margin. increased risk of detection, USNRC REGULATORY GUIDES Comments should be sent to the Secretary of the Commission, U.S. Nuclear Regulatory Commission Washington, D.C. 20555, Regulatory Guides are issued to describe and make available to the Attention: Docketing and Service Branch.

public methods acceptable to the NRC staff of implementing specific parts of the Commission's regulations, to delineate tech- The guides are issued in the following ten broad divisions:

niques used by the staff In evaluating specific problems or postu- lated accidents or to provide guidance to applicants. Regulatory 1. Power Reactors 6. Products Guides are no( substitutes for regulations, and compliance with 2. Research and Test Reactors 7. Transportation them is not required. Methods and solutions different from those set 3. Fuels and Materials Facilities 8. Occupational Health out in the guides will be acceptable if they provide a basis for the 4. Environmental and Siting 9. Antitrust and Financial Review findings requisite to the issuance or continuance of a permit or 5. Materials and Plant Protection 10. General license by the Commission.

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b. The probability that attempts at theft or diversion Without proper attention to administrative and operating would be detected in a more timely manner, procedures, theft or diversion may be difficult to detect or assess, and the possibility of recovery may be decreased.

c. The capability to more effectively reconstruct the events of an act of theft or diversion and thus enhance 4. SURVEILLANCE PERSONNEL

efforts to recover missing material, Surveillance personnel may include guards, watchmen, d. Continuous verification of the identity of individuals management personnel, or fellow workers positioned within MAAs and the increased ability to determine whether locally or remotely. To be effective, the observer must be nonessential activities are occurring within MAAs. familiar enough with the operation he or she is witness- ing to be able to recognize activities that are not authorized

2. SCOPE OF VISUAL SURVEILLANCE or are not consistent with established safeguards procedures.

Also for visual surveillance to be effective, a sufficient Visual surveillance of SSNM, unoccupied MAAs, areas or number of observers must be available to provide consistent equipment within MAAs, or individuals in MAAs may all detection and assessment capability. Consideration should be of value from a safeguards standpoint. be given to the changing numbers of observers who might be necessary for different situations, such as shift change, Visual surveillance may be one of a number of alternative shutdown, inventory, or emergency.

methods that can detect access into an area (authorized or unauthorized). When used in conjunction with other Visual surveillance can be subject to certain inherent detection methods, it can also serve as a means to verify problems. The use of pairs of workers to observe each other access, to assess such access, and to determine whether or could be susceptible to collusion. While this susceptibility not a threat exists and how severe it may be Therefore, can be reduced by rotating pair assignments so as not to visual surveillance can be an effective means of either have set pairs, any surveillance system or procedure that detecting or assessing personnel access. relies on fellow worker surveillance must recognize the reluctance of most workers to report a fellow worker. This Similarly, visual surveillance may be used to detect or type of system may also be of limited effectiveness when assess the position or movement of SSNM itself. In certain cir- workers, in the course of their normal functioning, are cumstances, it may be useful as a means of verifying that located out of view of each other or must place all their only authorized activities occur during processing operations. attention on a competing task. In addition, a surveillance Thus, visual surveillance can be useful in detecting or assess- system that relies extensively on watchmen or remote ing the movement of SSNM both within and out of an MAA. viewing devices can adversely affect employee morale. A

safeguards awareness program (similar to traditional safety The use of direct observation should be planned so that awareness campaigns) that emphasizes the importance of there is reasonable assurance that the activities to be observed visual surveillance procedures to overall employee interests are in fact observable and that the individual acting as an can serve to counteract these disadvantages.

observer is able to recognize and assess a potential problem as such. The use of indirect observation such as CCTV should 5. SURVEILLANCE INSTRUMENTATION

also include consideration of what is observable, how accu- rately it can be interpreted, and by whom. The visual surveillance function can be significantly aided by the proper use of optical or electronic devices such In some special instances, visual surveillance may not be as mirrors, periscopes, or CCTV. Closed circuit television necessary. For example, when SSNM is contained in special systems offer greater area coverage per observer and can be packages or automated processes, removal of SSNM could positioned and equipped with remotely operated controls be detected by means other than visual surveillance and so that large areas may be scanned or specific sections may communicated to the alarm stations for initiation of be concentrated on. One-way viewing enclosures for the response to a theft or diversion attempt. cameras may be useful in concealing the panning position and field of view of CCTV. This may be desirable so that Further, different visual surveillance methods may be camera scanning time and position cannot be easily antici- appropriate to specific parts of a particular facility and for pated by an individual attempting to circumvent the specific purposes. While direct observation may be more system.

suitable for some areas, CCTV may be more appropriate for others. Visual surveillance may itself serve as a primary The use of CCTV systems for visual surveillance that detection or assessment method or may better serve as a include a motion detector may also prove useful. Permanent backup to some other primary detection or assessment records may be kept by the use of video tape recording. A

component or subsystem. permanent recording system could also be activated by an associated video motion detection CCTV system or

3. MANAGEMENT SUPPORT separate intrusion alarm system to automatically provide a record of any action or activity occurring in the area of A well planned visual surveillance system requires concern. However, the use of CCTV should not be considered adequate management support for optimum operation. a satisfactory substitute for the two-man rule.

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6. PHYSICAL CHARACTERISTICS b. OperatingProcedures The physical characteristics of an area can substantially The surveillance system should be tested periodically affect the capability to effectively observe those activities and the results of these tests documented. The range and occurring within it. Where interior partitions, equipment, clarity of fields of view, including the vulnerability of material, or shielding obstruct the view, elevated viewing hardware components to interference from fluorescent locations may be used. lighting or sources of vibration, heat, or electric fields, should be checked. The adherence to the reporting proce-

C. REGULATORY POSITION

dures required by paragraphs 73.45(g) and 73.71(b) of

10 CFR Part 73 should be verified.

Visual surveillance techniques can be useful in meeting some of the performance capability statements of § 73.45. Visual surveillance procedures for the purpose of Examples of specific visual surveillance techniques for observing individuals in MAAs should provide assurances MAAs and vaults and process areas containing unalloyed that an individual is always in the field of view of an and unencapsulated SSNM that are typically included in a observer. Where an independent means of monitoring the licensee physical protection system are provided in para- location or manner of movement of SSNM is used, the use graphs 73.46(e)(3), (e)(9), and (h)(7) of 10 CFR Part 73. of visual surveillance procedures should be available as an This section describes operational measures and physical assessment tool in the event of an alarm or other indication features that will aid the use of visual surveillance for the of abnormal occurrence.

protection of strategic special nuclear material.

When CCTV is used to observe vaults and 'process

1. OPERATIONAL MEASURES areas containing unalloyed or unencapsulated SSNM, it should, as a minimum, provide a field of view that covers The following sections describe features and characteristics the total area occupied by the SSNM. The use of automatic of visual surveillance measures acceptable to the Commission panning cameras to provide this field of view is acceptable.

for ensuring that satisfactory observation can be maintained. In cases where SSNM is stored in multiple locations, making it impractical to provide total CCTV coverage, an acceptable a. Administrative Controls alternative is a field of view that covers doors and normal approaches to material.

All facility personnel should be instructed in the objectives of the surveillance system and how it operates. Visual surveillance as used to assess alarms in unoccu- Individuals, whose primary responsibility is surveillance pied vaults or process areas containing unalloyed or un- (e.g., authorized individuals, watchmen, or guards) should encapsulated SSNM should be accomplished by two indi- be trained' in the use of surveillance devices and systems viduals using CCTV or other remote means. Where the field and should be sufficiently familiar with both routine and of view does not provide complete assurance of the nature special plant operations to be able to recognize unauthorized of the alarm, direct observation of the exterior roof and activity. walls may be necessary for adequate assessment.

A surveillance system relying on fellow worker Equipment, supplies, and byproducts that are used or surveillance must recognize the reluctance of most employees are produced in the material access area should be kept in to report the misdeeds of fellow workers to management. designated storage locations when not in use and should not When such a system is used, special attention should be be allowed to accumulate where they can interfere with given to a program aimed at instilling in each employee a surveillance.

sense of personal responsibility for prevention of a theft or diversion of SSNM by a fellow worker. All aisles and passageways through a material access area should. be kept free of temporarily stored process Surveillance policies for emergency situations should materials, scrap, and trash so as not to interfere with provide, if at all possible, for continued surveillance of surveillance of the area.

personnel evacuating a material access area until they have been checked for concealed SSNM, for remote surveil- 2. AIDS TO EFFECTIVE SURVEILLANCE

lance of the evacuated area while not compromising the surveillance of other areas that may not have been evacuated, Whether direct or indirect visual observation techniques and for temporarily assigning special surveillance activities are used, the following physical features are acceptable to as may be required. the Commission for ensuring a capability for effective visual surveillance.

a. Area Characteristics

"Training requirements for guards and watchmen may be found in Appendix B,"General Criteria for Security Personnel," to 10 CFR Part 73 and NURFGA0464, "Site Security PersonnelTrifung-Manual,' An area where SSNM is processed or stored should be Volumes 1, 2, 3, and 4. Copies of NUREG-0464 may be obtained from the National Technical Information Service, Springfield, provided with lighting sufficient to provide adequate visual ViFginia-22161. detection and assessment of the activities occurring within

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the area. The actual amount of lighting necessary is depend- b. Process Equipment Characteristics ent on the purpose of the area; its size, configuration, and reflective characteristics; and the illumination requirements Surveillance devices, if used, should be located so that'

of any equipment used, such as CCTV cameras. access ports (covered or in use) or bag-out stations of enclosed process lines (glove boxes or hoods) will not be If obstructions (e.g., room partitions, screen panels, obscured from view.

radiation shielding, and safety barricades) interfere with direct surveillance of process aisles, process equipment, or Where possible, detection or monitoring devices on, operators; special vantage points, mirrors, or remote viewing or associated with, process equipment, including remote devices should be provided. surveillance devices or associated equipment, should be equipped with tamper alarms. Where CCTV with video tape Storage areas for in-process, feed, product, scrap, and recording is used, the recording function should be activated waste materials containing SSNM should have sufficient as an indication of alarm. Such use does not serve as a capacity that material can be stored in designated locations substitute for the use of the two-man rule to observe in a manner that will not interfere with lighting or the individuals.

field of view of surveillance devices. If storage is above floor level, the areas should be arranged with clearly defined Surveillance devices or stations should be located so aisles betweein storage racks and shelves. Each aisle that that heating and ventilating ducts, utility piping, conduit, provides access to SSNM should be capable of being monitored or other items providing services to process equipment or by direct or indirect visual surveillance. If storage is below equipment enclosures do not block observation of work floor level (e.g., in trenches or individual pits), the area areas.

should be free of partitions, obstructions, or structures above floor level that could conceal an individual from view.

Piping, ducts, or conveyor systems used to move SSNM

Containers of SSNM in storage should be arranged so within a process, or from one process to another process, that covers and seals are visible from adjacent aisles or and to or from storage should be distinctly marked (e.g.,

passageways and from a distance of at least 5 feet. color coded) to enhance identification of contents and function.

Shipping and receiving areas should be arranged with sufficient clear space that movement of an individual All SSNM containers should be designed so as to have around vehicles in the area can be observed. The dock area characteristic markings to identify whether the SSNM is adjacent to the cargo portal of a vehicle being loaded or buffer storage, final product scrap for recycle, scrap for unloaded should be kept clear of objects that could obstruct recovery, or waste. These containers should also be dis- observation of activities within 20 feet of the portal. tinguishable from all other containers in the area.

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VALUE/IMPACT STATEMENT

A separate value/impact analysis has not been prepared proposed amendments was made available in the Commis- for the revision to this regulatory guide. The changes were sion's Public Document Room, 1717 H Street, NW., Washing- made to make the guide consistent with the upgraded ton, D.C., at the time the proposed amendments were physical protection amendments to the regulations published published. This analysis is appropriate for the final amend- in final form in the Federal Register of November 28, 1979 ments as well as for the regulatory guide revisions appro-

(44 FR 68184). A value/impact analysis prepared for the priate to those amendments.

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