NRC Generic Letter 1989-20
\ ISEP 2 6 798gTO ALL FUEL CYCLE FACILITY LICENSEES WHO POSSESS, USE, OR PROCESS FORMULAQUANTITIES OF STRATEGIC SPECIAL NUCLEAR MATERIALSUBJECT: PROTECTED AREA LONG-TERM HOUSEKEEPING (GENERIC LETTER 89-20)This generic letter is being issued because of a growing concern that objects,materials and general clutter within the protected area (PA) have the potentialof adversely impacting the capability of guards in assessing and responding toalarms. Specifically, the effectiveness of the Tactical Response Teams (TRT),as required by the new comparability rule, may be directly impacted by the lackof unrestricted movement throughout the PA.Current regulations require that each fuel cycle facility subject to therequirements of 10 CFR 73.46 perform TRT exercises under 73.46(b)(9); haveadequate isolation zones for observing activities and people on either sideof the PA barrier under 73.46(c)(3); illuminate the isolation zones and allexterior areas within the PA to allow for-the monitoring and observationrequirements under 73.46(c)(4); detect penetration through the isolationzones to permit response action under 73.46(e)(1); monitor or periodicallycheck all exterior areas within the PA under 73.46(e)(8); require guards *to interpose themselves between any adversary attempting entry for purposes of..-theft of special nuclear material under 73.46(h)(4)(iii)(A); and provide assess-ment capabilities either by CCTV or other suitable means which limit exposure of;responding personnel to possible attack under 73.46(h)(6).Recent performance-oriented team inspections at fuel cycle facilities haveidentified PA clutter as having a negative impact on overall security systemeffectiveness. PA clutter provides potential cover and concealment for adver- ' -saries, reduces illumination levels and assessment capabilities, and restrictsthe movement of responding forces. We believe that the presence of thesecluttered areas inside the PA reduces the licensee's ability to meet the systemperformance objectives of 10 CFR 73.20(a).In general, the condition of the PA should not provide cover or concealmentfor an adversary, it should not hinder assessment by either CCTV or a respondingguard, and it should not cause the illumination to fall below the 0.2 footcandlelevel required of the exterior portions of the PA and isolation zone.Concerns and possible corrective actions covered by this letter include:o Construction within the PA-Physically separate construction activities from therest of the PA with a temporary barrier.-Control access to and from the construction site.Upon completion of the construction the area should beimmediately cleared.09;efo7 ZiK'
o Previous construction areas-Clear any lay-down areas leftover from priorconstruction activities.-- Fill in and grade earthworks.-Remove any temporary fencing or other obstructions.O Scrap and Waste storage areasProcess promptly if scrap, or move offsite if waste, ifthese areas interfere with the effectiveness of thesecurity system.-Any scrap maintained should be in a separately fencedarea, no closer than 25 feet to inner PA fence, butwithin the PA.*o Vehicle storage-Establish areas within the PA where all designatedlicensee vehicles are stored and controlled when notin use.-Establish this area in a manner that does not addclutter.In response to this letter licensees should provide a report describing siteconditions relating to isolation zones, protected areas, construction, waste andscrap storage, and vehicle storage or other activities that may obstruct obser-vation or reduce illumination levels. The report should include a descriptionof the security maintenance program for the prevention of obstructions which maydegrade security system performance.Pursuant to the Commission's authority in 10 CFR 70.22(d), licensees are requestedto submit this report and a schedule for correcting deficiencies within 90 daysof the date of this Generic Letter to:Donald J. KasunActing Chief Domestic Safeguardsand Regional Oversite BranchNuclear Regulatory CommissionWFN 4-E-4Washington, D.C. 20555*(Note that scrap storage may have no more that .25 gms. of U-235 per literin 30 gallon or larger containers (73.46(c)(6).)
-^ TK> K>~This reporting requirement has been approved by the Office of Management andBudget under control number 3150-0009 (see 10 CFR 70.8(a)).If you have any questions about this matter, please contact C. E. Gaskin at(301) 492-0649 or Rocio Castaneira at (301) 492-0392.Sincerely,/S /George W. McCorkle, Acting DirectorDivision of Safeguardsand Transportation, NMSSDistribution:SGDB r/fNMSS r/fRBurnettGMcCorkleDKasunCGaskinRCastaneiraRFonnerZMe~uire-RIIRR.1 14am RLr~l ne RTT_t pl4~RU-~ e e q~f~eOFC :SGDB SGDB *SGDB OGC :SGTF :SGTR IA:_- ------ ---- _~ --------C-------f tL---- --------NAME :RCastaneira :CGaskin :DKasun :RFonner :J0rHches :GMcCorkleDATE :9/AJ/89 :9/A9/89 :9OAR/89 :9 89OFFICIAL RECORD COPY-
This reporting requirement has been approved by the Office of Management andBudget under control number 3150-0009 (see 10 CFR 70.8(a)).If you have any questions about this matter, please contact C. E. Gaskin at FTS492-0649 or Rocio Castaneira at FTS 492-0392.Sincerely,George W. McCorkle, Acting DirectorDivision of Safeguardsand Transportation, NMSSDistribution:SGDB r/fNMSS r/fRBurnettGMcCorkleDKasunCGaskinRCastaneiraRFonnerRKeimig, RIDMcGuire RIIRBellamy RIWCline RII^' in',Al!JOFC :SGDIz'-1{ 2/ :SGDB :SGDBk :OGCL :SGTR 12 :SGTRNAME :RCastaneira:C3 ' in :DKasun nner :JFunches :GMcCorkleDATE :9/4I/89 :9/i7/89 :94?189 :9TIT89 :9/ /89 :9/ /89OFFICIAL RECORD COPY