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 1980U.S. NUCLEAR REGULATORY COMMISSIONREGULATORY GUIDEOFFICE OF STANDARDS DEVELOPMENTREGULATORY GUIDE 5.14(Task SG 910-4)\JJUSE OF OBSERVATION (VISUAL SURVEILLANCE) TECHNIQUESIN MATERIAL ACCESS AREASA. INTRODUCTIONPart 73, "Physical Protection of Plants and Materials,"of Title 10, Code of Federal Regulations, specifies perform-ance requirements for the physical protection of specialnuclear materials and associated facilities. Section 73.20,"General Performance Requirements," describes the generalperformance objective and requirements that must be metthrough the establishment of a physical protection system.Performance capabilities necessary to meet the requirementsof § 73.20 are described in § 73.45, "Performance Capabil-ities for Fixed Site Physical Protection." While detectionand assessment requirements are specified throughout thecapability statements, specific surveillance and monitoringtechniques are required under two capability statements of§ 73.45. Paragraph 73.45(c) permits only authorizedactivities and conditions within protected areas, materialaccess areas, and vital areas. A physical protection systemmust achieve this by detecting unauthorized activities orconditions within these areas through detection and surveil-lance subsystems. Paragraph 73.45(d) permits only autho-rized placement and movement of strategic special nuclearmaterial within material access areas. This must be accom-plished through the use of detection and monitoringsubsystems and procedures to discover and assess unautho-rized placement and movement of strategic special nuclearmaterial. Finally, § 73.46, "Fixed Site Physical ProtectionSystems, Subsystems, Components and Procedures,"outlines typical specific safeguards measures that will oftenbe included in an overall system that meets the generalrequirements of Sections 73.20 and 73.45.Paragraph (e)(3) of § 73.46 provides for the use ofclosed-circuit television (CCTV) as a means of surveillancein all vaults and process areas that contain unalloyed orunencapsulated strategic special nuclear material (SSNM).The substantial number of changes in this revision has made itimpractical to indicate the changes with lines in the margin.Paragraph (e)(9) of § 73.46 provides for observation ofindividuals within material access areas (MAAs) to ensurethat SSNM is not moved to unauthorized locations or in anunauthorized manner. Paragraph (h)(7) provides for remotealarm assessment by at least two security personnel usingCCTV or other means for assessing alarms occurring inunoccupied vaults and process areas. The value of theobservation (visual surveillance) techniques used to meetthese provisions can be enhanced by careful considerationof surveillance needs both in the design phase of plantconstruction and in the continuing development of opera-tional procedures and controls.For the purposes of this guide, visual surveillance andobservation are used interchangeably to mean direct orindirect visual monitoring of an area for the purpose ofdetecting or assessing the activities occurring therein.This guide describes measures the NRC staff considersacceptable for implementing the requirements of surveillanceor observation within material access areas to ensuresafeguarding of strategic special nuclear material.B. DISCUSSION1. OBJECTIVE OF VISUAL SURVEILLANCEThe objective of visual surveillance (observation) inMAAs is the detection or assessment of activities that couldadversely affect the safeguarding of SSNM. This couldinclude, among other things, the direct observation ofindividuals' normal work functions within MAAs and theremote monitoring of unoccupied areas, e.g., vaults orautomated process areas, within MAAs. The physicalprotection benefits to be derived from visual surveillanceinclude the following:a. The likelihood that insider considerations of theft ordiversion would be reduced because of an awareness of theincreased risk of detection,USNRC REGULATORY GUIDESRegulatory Guides are issued to describe and make available to thepublic methods acceptable to the NRC staff of implementingspecific parts of the Commission's regulations, to delineate tech-niques used by the staff In evaluating specific problems or postu-lated accidents or to provide guidance to applicants. RegulatoryGuides are no( substitutes for regulations, and compliance withthem is not required. Methods and solutions different from those setout in the guides will be acceptable if they provide a basis for thefindings requisite to the issuance or continuance of a permit orlicense by the Commission.Comments and suggestions for Improvements In these guides areencouraged at all times, and guides will be revised, as appropriate,to accommodate comments and to reflect new information orexperience. This guide was revised as a result of substantive com-ments received from the public and additional staff review.Comments should be sent to the Secretary of the Commission,U.S. Nuclear Regulatory Commission Washington, D.C. 20555,Attention: Docketing and Service Branch.The guides are issued in the following ten broad divisions:1. Power Reactors 6. Products2. Research and Test Reactors 7. Transportation3. Fuels and Materials Facilities 8. Occupational Health4. Environmental and Siting 9. Antitrust and Financial Review5. Materials and Plant Protection 10. GeneralCopies of issued guides may be purchased at the current GovernmentPrinting Office price. A subscription service for future guides in spe-cific divisions is available through the Government Printing Office.Information on the subscription service and current GPO Prices maybe obtained by writing the U.S. Nuclear Regulatory Commission,Washington, D.C. 20555, Attention: Publications Sales Manage b. The probability that attempts at theft or diversionwould be detected in a more timely manner,c. The capability to more effectively reconstruct theevents of an act of theft or diversion and thus enhanceefforts to recover missing material,d. Continuous verification of the identity of individualswithin MAAs and the increased ability to determine whethernonessential activities are occurring within MAAs.2. SCOPE OF VISUAL SURVEILLANCEVisual surveillance of SSNM, unoccupied MAAs, areas orequipment within MAAs, or individuals in MAAs may allbe of value from a safeguards standpoint.Visual surveillance may be one of a number of alternativemethods that can detect access into an area (authorized orunauthorized). When used in conjunction with otherdetection methods, it can also serve as a means to verifyaccess, to assess such access, and to determine whether ornot a threat exists and how severe it may be Therefore,visual surveillance can be an effective means of eitherdetecting or assessing personnel access.Similarly, visual surveillance may be used to detect orassess the position or movement of SSNM itself. In certain cir-cumstances, it may be useful as a means of verifying thatonly authorized activities occur during processing operations.Thus, visual surveillance can be useful in detecting or assess-ing the movement of SSNM both within and out of an MAA.The use of direct observation should be planned so thatthere is reasonable assurance that the activities to be observedare in fact observable and that the individual acting as anobserver is able to recognize and assess a potential problemas such. The use of indirect observation such as CCTV shouldalso include consideration of what is observable, how accu-rately it can be interpreted, and by whom.In some special instances, visual surveillance may not benecessary. For example, when SSNM is contained in specialpackages or automated processes, removal of SSNM couldbe detected by means other than visual surveillance andcommunicated to the alarm stations for initiation ofresponse to a theft or diversion attempt.Further, different visual surveillance methods may beappropriate to specific parts of a particular facility and forspecific purposes. While direct observation may be moresuitable for some areas, CCTV may be more appropriate forothers. Visual surveillance may itself serve as a primarydetection or assessment method or may better serve as abackup to some other primary detection or assessmentcomponent or subsystem.3. MANAGEMENT SUPPORTA well planned visual surveillance system requiresadequate management support for optimum operation.Without proper attention to administrative and operatingprocedures, theft or diversion may be difficult to detect orassess, and the possibility of recovery may be decreased.4. SURVEILLANCE PERSONNELSurveillance personnel may include guards, watchmen,management personnel, or fellow workers positionedlocally or remotely. To be effective, the observer must befamiliar enough with the operation he or she is witness-ing to be able to recognize activities that are not authorizedor are not consistent with established safeguards procedures.Also for visual surveillance to be effective, a sufficientnumber of observers must be available to provide consistentdetection and assessment capability. Consideration shouldbe given to the changing numbers of observers who mightbe necessary for different situations, such as shift change,shutdown, inventory, or emergency.Visual surveillance can be subject to certain inherentproblems. The use of pairs of workers to observe each othercould be susceptible to collusion. While this susceptibilitycan be reduced by rotating pair assignments so as not tohave set pairs, any surveillance system or procedure thatrelies on fellow worker surveillance must recognize thereluctance of most workers to report a fellow worker. Thistype of system may also be of limited effectiveness whenworkers, in the course of their normal functioning, arelocated out of view of each other or must place all theirattention on a competing task. In addition, a surveillancesystem that relies extensively on watchmen or remoteviewing devices can adversely affect employee morale. Asafeguards awareness program (similar to traditional safetyawareness campaigns) that emphasizes the importance ofvisual surveillance procedures to overall employee interestscan serve to counteract these disadvantages.5. SURVEILLANCE INSTRUMENTATIONThe visual surveillance function can be significantlyaided by the proper use of optical or electronic devices suchas mirrors, periscopes, or CCTV. Closed circuit televisionsystems offer greater area coverage per observer and can bepositioned and equipped with remotely operated controlsso that large areas may be scanned or specific sections maybe concentrated on. One-way viewing enclosures for thecameras may be useful in concealing the panning positionand field of view of CCTV. This may be desirable so thatcamera scanning time and position cannot be easily antici-pated by an individual attempting to circumvent thesystem.The use of CCTV systems for visual surveillance thatinclude a motion detector may also prove useful. Permanentrecords may be kept by the use of video tape recording. Apermanent recording system could also be activated byan associated video motion detection CCTV system orseparate intrusion alarm system to automatically provide arecord of any action or activity occurring in the area ofconcern. However, the use of CCTV should not be considereda satisfactory substitute for the two-man rule.5.14-2 6. PHYSICAL CHARACTERISTICSb. Operating ProceduresThe physical characteristics of an area can substantiallyaffect the capability to effectively observe those activitiesoccurring within it. Where interior partitions, equipment,material, or shielding obstruct the view, elevated viewinglocations may be used.C. REGULATORY POSITIONVisual surveillance techniques can be useful in meetingsome of the performance capability statements of § 73.45.Examples of specific visual surveillance techniques forMAAs and vaults and process areas containing unalloyedand unencapsulated SSNM that are typically included in alicensee physical protection system are provided in para-graphs 73.46(e)(3), (e)(9), and (h)(7) of 10 CFR Part 73.This section describes operational measures and physicalfeatures that will aid the use of visual surveillance for theprotection of strategic special nuclear material.1. OPERATIONAL MEASURESThe following sections describe features and characteristicsof visual surveillance measures acceptable to the Commissionfor ensuring that satisfactory observation can be maintained.a. Administrative ControlsAll facility personnel should be instructed in theobjectives of the surveillance system and how it operates.Individuals, whose primary responsibility is surveillance(e.g., authorized individuals, watchmen, or guards) shouldbe trained' in the use of surveillance devices and systemsand should be sufficiently familiar with both routine andspecial plant operations to be able to recognize unauthorizedactivity.A surveillance system relying on fellow workersurveillance must recognize the reluctance of most employeesto report the misdeeds of fellow workers to management.When such a system is used, special attention should begiven to a program aimed at instilling in each employee asense of personal responsibility for prevention of a theft ordiversion of SSNM by a fellow worker.Surveillance policies for emergency situations shouldprovide, if at all possible, for continued surveillance ofpersonnel evacuating a material access area until they havebeen checked for concealed SSNM, for remote surveil-lance of the evacuated area while not compromising thesurveillance of other areas that may not have been evacuated,and for temporarily assigning special surveillance activitiesas may be required."Training requirements for guards and watchmen may be found inAppendix B,"General Criteria for Security Personnel," to 10 CFRPart 73 and NURFGA0464, "Site Security Personnel Trifung-Manual,'Volumes 1, 2, 3, and 4. Copies of NUREG-0464 may be obtainedfrom the National Technical Information Service, Springfield,ViFginia-22161.The surveillance system should be tested periodicallyand the results of these tests documented. The range andclarity of fields of view, including the vulnerability ofhardware components to interference from fluorescentlighting or sources of vibration, heat, or electric fields,should be checked. The adherence to the reporting proce-dures required by paragraphs 73.45(g) and 73.71(b) of10 CFR Part 73 should be verified.Visual surveillance procedures for the purpose ofobserving individuals in MAAs should provide assurancesthat an individual is always in the field of view of anobserver. Where an independent means of monitoring thelocation or manner of movement of SSNM is used, the useof visual surveillance procedures should be available as anassessment tool in the event of an alarm or other indicationof abnormal occurrence.When CCTV is used to observe vaults and 'processareas containing unalloyed or unencapsulated SSNM, itshould, as a minimum, provide a field of view that coversthe total area occupied by the SSNM. The use of automaticpanning cameras to provide this field of view is acceptable.In cases where SSNM is stored in multiple locations, makingit impractical to provide total CCTV coverage, an acceptablealternative is a field of view that covers doors and normalapproaches to material.Visual surveillance as used to assess alarms in unoccu-pied vaults or process areas containing unalloyed or un-encapsulated SSNM should be accomplished by two indi-viduals using CCTV or other remote means. Where the fieldof view does not provide complete assurance of the natureof the alarm, direct observation of the exterior roof andwalls may be necessary for adequate assessment.Equipment, supplies, and byproducts that are used orare produced in the material access area should be kept indesignated storage locations when not in use and should notbe allowed to accumulate where they can interfere withsurveillance.All aisles and passageways through a material accessarea should. be kept free of temporarily stored processmaterials, scrap, and trash so as not to interfere withsurveillance of the area.2. AIDS TO EFFECTIVE SURVEILLANCEWhether direct or indirect visual observation techniquesare used, the following physical features are acceptable tothe Commission for ensuring a capability for effective visualsurveillance.a. Area CharacteristicsAn area where SSNM is processed or stored should beprovided with lighting sufficient to provide adequate visualdetection and assessment of the activities occurring within5.14-3 the area. The actual amount of lighting necessary is depend-ent on the purpose of the area; its size, configuration, andreflective characteristics; and the illumination requirementsof any equipment used, such as CCTV cameras.If obstructions (e.g., room partitions, screen panels,radiation shielding, and safety barricades) interfere withdirect surveillance of process aisles, process equipment, oroperators; special vantage points, mirrors, or remote viewingdevices should be provided.Storage areas for in-process, feed, product, scrap, andwaste materials containing SSNM should have sufficientcapacity that material can be stored in designated locationsin a manner that will not interfere with lighting or thefield of view of surveillance devices. If storage is above floorlevel, the areas should be arranged with clearly definedaisles betweein storage racks and shelves. Each aisle thatprovides access to SSNM should be capable of being monitoredby direct or indirect visual surveillance. If storage is belowfloor level (e.g., in trenches or individual pits), the areashould be free of partitions, obstructions, or structuresabove floor level that could conceal an individual from view.Containers of SSNM in storage should be arranged sothat covers and seals are visible from adjacent aisles orpassageways and from a distance of at least 5 feet.Shipping and receiving areas should be arranged withsufficient clear space that movement of an individualaround vehicles in the area can be observed. The dock areaadjacent to the cargo portal of a vehicle being loaded orunloaded should be kept clear of objects that could obstructobservation of activities within 20 feet of the portal.b. Process Equipment CharacteristicsSurveillance devices, if used, should be located so that'access ports (covered or in use) or bag-out stations ofenclosed process lines (glove boxes or hoods) will not beobscured from view.Where possible, detection or monitoring devices on,or associated with, process equipment, including remotesurveillance devices or associated equipment, should beequipped with tamper alarms. Where CCTV with video taperecording is used, the recording function should be activatedas an indication of alarm. Such use does not serve as asubstitute for the use of the two-man rule to observeindividuals.Surveillance devices or stations should be located sothat heating and ventilating ducts, utility piping, conduit,or other items providing services to process equipment orequipment enclosures do not block observation of workareas.Piping, ducts, or conveyor systems used to move SSNMwithin a process, or from one process to another process,and to or from storage should be distinctly marked (e.g.,color coded) to enhance identification of contents andfunction.All SSNM containers should be designed so as to havecharacteristic markings to identify whether the SSNM isbuffer storage, final product scrap for recycle, scrap forrecovery, or waste. These containers should also be dis-tinguishable from all other containers in the area.5.14-4 VALUE/IMPACT STATEMENTA separate value/impact analysis has not been preparedfor the revision to this regulatory guide. The changes weremade to make the guide consistent with the upgradedphysical protection amendments to the regulations publishedin final form in the Federal Register of November 28, 1979(44 FR 68184). A value/impact analysis prepared for theproposed amendments was made available in the Commis-sion's Public Document Room, 1717 H Street, NW., Washing-ton, D.C., at the time the proposed amendments werepublished. This analysis is appropriate for the final amend-ments as well as for the regulatory guide revisions appro-priate to those amendments.5.14-5 UNITED STATESNUCLEAR REGULATORY COMMISSIONWASHINGTON, D. C. 20555OFFICIAL BUSINESSPENALTY FOR PRIVATE USE. $300POSTAGE AND FEES PAIDU.S. NUCLEAR REGULATORYCOMMISSION119496002001 I1 DAD5QAQ5US NRC REGIONI IOFFICE OF INS3EU'TION & ENFORCER J BORES631 PARK AVENJEREGION IKING OF PRUSSIA PA 19406