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{{Adams
{{Adams
| number = ML12187A706
| number = ML003739253
| issue date = 01/10/1980
| issue date = 02/28/1983
| title = Standard Format and Content for a Licensee Physical Security Plan for the Protection of Special Nuclear Material of Moderate or Low Strategic Significance
| title = Rev 1, (Task SG 229-4) Standard Format and Content for a Licensee Physical Security Plan for the Protection of Special Nuclear Material of Moderate or Low Strategic Significance
| author name = Minogue R
| author name =  
| author affiliation = NRC/RES
| author affiliation = NRC/RES
| addressee name =  
| addressee name =  
Line 10: Line 10:
| license number =  
| license number =  
| contact person =  
| contact person =  
| case reference number = DG MP 711-4
| document report number = RG-5.59
| document report number = RG-5.059
| document type = Regulatory Guide
| document type = Regulatory Guide, Memoranda
| page count = 69
| page count = 65
}}
}}
{{#Wiki_filter:0,                        UNITED STATES
{{#Wiki_filter:U.S. NUCLEAR REGULATORY COMMISSION
                          NUCLEAR REGULATORY COMMISSION
Revision 1 February 1983 REGULATORY GUIDE
                                WASHINGTON, D. C. 20555 January 10, 1980
OFFICE OF NUCLEAR REGULATORY RESEARCH
REGULATORY GUIDE SUBSCRIPTION LIST (DIVISION 5)
REGULATORY GUIDE 5.59 (Task SG 2294)  
Draft Regulatory Guide MP 711-4, "Standard Format and Content for a Licensee Physical Security Plan for the Protection of Special Nuclear Material of Moderate or Low Strategic Significance," was issued for public comment in July 197
STANDARD FORMAT AND CONTENT
FOR A'LICENSEE PHYSICAL SECURITY PLAN
FOR THE PROTECTION OF SPECIAL NUCLEAR MATERIAL
OF MODERATE OR LOW STRATEGIC SIGNIFICANCE
USNRC REGULATORY GUIDES
Regulatory Guides are issued to describe and maie available to the public methods acceptable to the NRC staff of Implementing specific parts of the Commission's regulations, to delineate tech niques used by the stiff in evaluating specific problems or 'postu lated accidents or to provide guidance to app Icants. Regu*atory Guides are noQ substitutes for regulations, and aompllance with them Is not required. Methods and solutions different from those set out In the guides will be acceptable If they Provide a basis for the indings requisite to the Issuance or continuance of a permit or license by the Commission.


===9. The purpose===
This guide was Issued after consideration of comments received from the pubiic. Comments and suggestions for Improvements In these guides are encouraged at all times, and guides will be revised, as appropriate, to accommodate comments and to reflect new Informa tion or experience.
,of the guide is to identify the information needed by the staff in its review of licensees' physical security plans for protection of special nuclear material of moderate or low strategic significance and to provide an acceptable format for its submission.  In addition, the guide provides information on the intent of the various provisions of amendments to Part 73 of the Commission's regulations published July 24,
1979, as an aid to the licensee in developing the plan.


Since the draft guide was issued for public comment, the Commission has identified a need for additional clarification of the intent of portions of these amendments.
Comments should be sent to the Secretary of the Commision, U.S. Nuclear Regulatory Commission Washington, D.C. 2055n, Attentlon: Docketing and Service BraIncn.


Accordingly, some changes were made in Chapters 1 and 2 of Parts I and II of this guide to fulfill this need. Chapter 1 was expanded to better define the controlled access areas where the material will be used or stored. Chapter 2 was revised to clearly explain what is meant by 73.67(a)(2) "... early detection and assessment of unauthorized access or activities by an external adversary within the controlled access area..." and "... early detection of removal of special nuclear material by an external adversary from a controlled access area." The section in Chapter 2 on intent was expanded to explain how detection devices or procedures could be used to provide early detection against theft of various types of SNM of moderate or low strategic significance.
The guides are Issued In the following ten broad divisions:


Comments on regulatory guides are encouraged at all times, but comments on the above changes in Chapters 1 and 2 of Parts I and II will be particularly helpful to the NRC staff in evaluating the need for an early revision to this guide.
===2. Power Reactors ===
6. Products L Research and Test Reactors


Robert B. Minogue, Director Office of Standards Development
===7. Transportation ===
3. Fuels and Materials Facilities IL Occupational Health
4. Environmental and Siting
9. Antitrust and Financial Review
5. Materials and Plant Protection 20. General Copies of issued guides may be Purchased at the current Government Printing Office price" A subscription service for future guides In spe cific divisions Is available through the Government Printing Office.


COMMISSION                                            January 1980
Information on the subscription service and current GPO prices may be obtained by writing the U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, Attentiont Publications Sales Manager.
                        U.S. NUCLEAR REGULATORY
                        REGULATORY GUIDE
                        OFFICE OF STANDARDS DEVELOPMENT
                                                                                                                          Task MP 711-4 REGULATORY GUIDE 5.59 STANDARD FORMAT AND CONTENT
                                      FOR A LICENSEE PHYSICAL SECURITY PLAN
                            FOR THE PROTECTION OF SPECIAL NUCLEAR MATERIAL
                                OF MODERATE OR LOW STRATEGIC SIGNIFICANCE
                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:
TABLE OF CONTENTS
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 not 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.
INTRODUCTION .......................................................... 
PART I
SPECIAL NUCLEAR MATERIAL OF MODERATE STRATEGIC
SIGNIFICANCE ....................................... 
Chapter 1 USE AND STORAGE AREA AT A FIXED SITE ....................... 
1.1 Area Where Material Is Used
...................... 
1.2 Area Where Material Is Stored ..................... 
Chapter 2 DETECTION DEVICES AND PROCEDURES AT A FIXED SITE.......... 
2.1 Earliness of Detection........................ 
2.2 Detection Through Monitoring Controlled Access Areas... 
Chapter 3 ACCESS CONTROL AT A FIXED SITE .............................. 
3.1 Preauthorization Screening .......................... 
3.2 Badging System ..................................... 
3.3 Lock System............... 
3.4 Personnel EntryControlSystem.
 
3.5 Escort System .................
................. 
3.6-Search ........
.............................. 
Chapter 4 SECURITY ORGANIZATION AT A FIXED SITE................. 
Chapter 5 COMMUNICATIONS AT A FIXED SITE
....................... 
Chapter 6 RESPONSE PROCEDURES AT A FIXED SITE ........................ 
-.Chapter 7 MATERIAL TRANSPORTATION REQUIREMENTS ....................... 
7.1 Advance Notification to Receiver ....................... 
7.2 Receiver Confirmation.. 
7.3 Inspection .............
....................... 
7.4 Responsibility for In-Transit Physical Protection ...... 
Chapter 8 RECEIVER REQUIREMENTS--TRANSPORTATION ...................... 
.8.1 Inspection .............................................. 
8.2 Notification to Shipper.......................... 
8.3 Responsibility for In-Transit Physical Protection ......
iii Pane vii
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TABLE OF CONTENTS (Continued)
Chapter 9 Chapter I
Chapter Chapter
1 I
Chapter 1 PART II
Chapter 1 Chapter 2 Chapter 3 Chapter 4 Chapter IN-TRANSIT PHYSICAL PROTECTION REQUIREMENTS ................ 
9.1 Communications ....................
...................   
9.2 Minimum Transit Times .................................. 
9.3 Preauthorization Screening ............................. 
9.4 Response Procedures
.............................. 
9.5 Notification ...................................
........ 
9.6 Lost Material Notification ...... , ................... 
9.7 NRC Notification ................
................. 
0, TRANSFER AND CONTROL REQUIREMENTS... .......... 
10.1 Carrier Transfers .......
...................... 
10.2 Control of Shipments ............................... 
1 EXPORT REQUIREMENTS ....................................... 
2 IMPORT.REQUIREMENTS ...............
................ 
12.1 Security Requirements ................. 
12.2 Notification .........................
....... 
.3 ORDERS TO DELAY SSNM SHIPMENTS ............................. 
13.1 Notification of Receipt of SSNM ..................... 
SPECIAL NUCLEAR MATERIAL OF LOW STRATEGIC SIGNIFICANCE ....... 
USE AND STORAGE AREA AT A FIXED SITE....................... 
1.1 Areas for Use and Temporary Storage .................... 
1.2 Areas for Permanent Storage ............................ 
DETECTION DEVICES AND PROCEDURES AT A FIXED SITE ........... 
2.1 Earliness of Detection...................... 
2.2 Monitoring Controlled AccessAreas. ............... 
3 SECURITY RESPONSE AT A FIXED SITE
............... 
RESPONSE PROCEDURES AT A FIXED SITE............. 
5 MATERIAL TRANSPORTATION REQUIREMENTS ...................... 
5.1 Advance Notification ............................... 
5.2 Receiver Confirmation ................
.................. 
5.3 Container ..........................
.
................ 
5.4 Inspection .........................................
... 
5.5 Responsibility for In-Transit Physical Protection.....
iv Page
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5.59-53
 
TABLE OF CONTENTS (Continued)
Chapter 6 Chapter 7 Chapter 8 Chapter 9 RECEIVER REQUIREMENTS--TRANSPORTATION ...................... 
6.1 Inspection .................................... 
6.2 Notification .................... 
6.3 Responsibility for In-Transit Physical Protection ......   
IN-TRANSIT PHYSICAL PROTECTION REQUIREMENTS................ 
7.1 Response Procedures .................................... 
7.2 Notificatipn.................................
.......... 
7.3 Lost Material Notification ............................. 
EXPORT REQUIREMENTS ........................................   
IMPORT REQUIREMENTS ........................
............... 
9.1 Security Requirements ..................................  
9.2 Notification ...........................................
VALUE/IMPACT STATEMENT ................................................
V
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INTRODUCTION
The Atomic Energy Act of 1954, as amended, directed the U.S. Atomic Energy Commission (AEC)*to regulate the receipt, manufacture, production, transfer.
 
possession, use, import, and export of special nuclear material (SNM)
in order to protect the public health and safety and to provide for the common defense and security.
 
The Energy Reorganization Act of 1974 transferred all thd licensing and related regulatory functions of the AEC to the Nuclear Regulatory Commission (NRC).   
The principal requirements with'respect to the physical protection of licensed activities against industrial sabotage and with respect to the phys ical protection of special nuclear material in transit are found in 10 CFR
Part 50, "Domestic Licensing of Production and Utilization Facilities"; Part
70, "Domestic Licensing of Special Nuclear Material"; Part 73, "Physical Protection of Plants and Materials"; and Part 110, "Export and Import of Nuclear Equipment and Materials."
Paragraph 50.34(c) of 10 CFR Part 50 and paragraphs 70.22(g), 70.22(h),
and 70.22(k) of 10 CFR Part 70 identify the physical protection information that must be provided in a physical security plan as part of a license appli cation.
 
This plan is required in Order for the applicant to demonstrate compliance with the specific physical protection requirements of 10 CFR Part 73 and must be submitted with each application for a license to possess or use SIM
(or for a license authorizing transport or delivery of SNM), except for a license to possess, use, or transport less than 10 kg of SiM of low strategic significance, in which case a physical security plan is not required.
 
However, for the protection of SNM of low strategic significance, the licensee is required to meet the requirements of § 73.67, "Licensee Fixed Site and In-Transit Requirements for the Physical Protection of Special Nuclear Material
*of Moderate and Low Strategic Significance," of 10 CFR Part 73.


Copies of issued guides may be purchased at the current Government Comments and suggestions for improvements in these guides are        Printing Office price. A subscription service for future guides in spe- encouraged at all times, and guides will be revised, as appropriate, cific divisions Is available through the Government Printing Office.
Any guidance in this document related to information collection activities has been cleared under OMB Clearance Nos. 3150-0002, 3150-0009, and 3150-0011.


to accommodate comments and to reflect new information or            Information on the subscription service and current GPO prices may experience. This guide was revised as a result of substantive com-  be obtained by writing the U.S. Nuclear Regulatory Commission, ments received from the public and additional staff review.          Washington, D.C. 20555, Attention: Publications Sales Manager.
This regulatory guide describes the information required in the physical security plan submitted as part of an application .for a license to possess, use, or transport SNM of moderate strategic significance or 10 kg or more of SNM of low strategic significance and recommends a standard format for presenting the information in an orderly arrangement.


TABLE OF CONTENTS
This standard format will thus serve as an aid to uniformity and completeness in the preparation and review of the physical security plan of the license application.
                                                                                                                Page INTRODUCTION ..........................................................                                          1 PART I  SPECIAL NUCLEAR MATERIAL OF MODERATE STRATEGIC
 
          SIGNIFICANCE ................................................                                          7 Chapter 1  USE AND STORAGE AREA AT A FIXED SITE .......................                                          8
This document can also be.used as guidance by licensees possessing or transporting less than
            1.1 Area Where Material Is Used ............................                                         8
10 kg of SNM of low strategic significance in understanding the Intent and implementing the requirements of paragraphs 73.67(a), 73.67(f), and 73.67(g) of  
            1.2 Area Where Material Is Stored ..........................                                        11 Chapter 2  DETECTION DEVICES AND PROCEDURES AT A FIXED SITE ...........                                        14
10 CFR Part 73.
            2.1 Earliness of Detection ......................                                        .......... 14
 
            2.2 Detection Through Monitoring of Controlled Access Areas ................................................                                    15 Chapter 3  ACCESS CONTROL AT A FIXED SITE .............................                                        17
Aside from providing guidance for the standard format and content of physical security plans, this regulatory guide explains the intent of the various provisions of the regulation.
            3.1    Preauthorization Screening .............................                                      17
            3.2    Badging System .........................................                                      18
            3.3    Lock System ............................................                                      18
            3.4    Personnel Entry Control System .........................                                      19
            3.5    Escort System ..........................................                                      20
            3.6    Search .................................................                                      20
Chapter 4  SECURITY ORGANIZATION AT A FIXED SITE ......................                                        22 Chapter 5 COMMUNICATIONS AT A FIXED SITE .........................                                              23 Chapter 6  RESPONSE PROCEDURES AT A FIXED SITE ........................                                        24 Chapter 7 MATERIAL TRANSPORTATION REQUIREMENTS .......................                                          25
            7.1    Advance Notification ................................                                        25
            7.2    Receiver Confirmation ..................................                                      26
            7.3    Container ..............................................                                      26
            7.4    Inspection .......                                  .............................            26
            7.5    Responsibility for In-Transit Physical Protection..                                          27 Chapter 8  RECEIVER REQUIREMENTS--TRANSPORTATION ..................                                            28  -I
            8.1 Inspection .........................................                                            28
            8.2 Notification .......................................                                            28
            8.3 Responsibility for In-Transit Physical Protection..                                              29 Chapter 9  IN-TRANSIT PHYSICAL PROTECTION REQUIREMENTS ............                                            30
            9.1 Communications .....................................                                            30
            9.2 Minimum Transit Times ..............................                                             31 ii


TABLE OF CONTENTS
The intent of each requirement is found in the discussion of each subsection and is implicitly provided by outlining alternative systems that could be used to fulfill the requirements.
                                                                                                          Page
            9.3 Preauthorization Screening .............................                                  31
            9.4 Response Procedures ....................................                                  32
            9.5 Notification .....                  .............................                        32
            9.6 Lost Material Notification .............................                                  32 Chapter 10  EXPORT REQUIREMENTS .......................................                                  34 Chapter 11  IMPORT REQUIREMENTS .......................................                                  35
            11.1  Security Requirements ...............................                                35
            11.2  Notification ........................................                                35 PART II  -SPECIAL NUCLEAR MATERIAL OF LOW STRATEGIC SIGNIFICANCE .......                                  36 Chapter 1 USE AND STORAGE AREA AT A FIXED SITE .......................                                    37
            1.1 Areas for Use and Temporary Storage ....................                                  37
            1.2 Areas for Permanent Storage ............................                                  39 Chapter 2  DETECTION DEVICES AND PROCEDURES AT A FIXED SITE ...........                                  42
            2.1 Earliness of Detection............................
                                                                                                          42
            2.2 Monitoring of Controlled Access Areas ..................                                  43 Chapter 3  SECURITY RESPONSE AT A FIXED SITE ..........................                                  48 Chapter 4  RESPONSE PROCEDURES AT A FIXED SITE ........................                                  49 Chapter 5  MATERIAL TRANSPORTATION REQUIREMENTS .......................                                  50
            5.1 Advance Notification ...................................                                  50
            5.2 Receiver Confirmation ..................................                                  51
            5.3 Container ..............................................                                  51
            5.4  Inspection .............................                                ............... 51
            5.5 Responsibility for In-Transit Physical Protection ......                                  51 Chapter 6  RECEIVER REQUIREMENTS--TRANSPORTATION ......................                                  53
            6.1 Inspection .............................................                                  53
            6.2 Notification ...........................................                                  53
            6.3 Responsibility for In-Transit Physical Protection ......                                  53 Chapter 7  IN-TRANSIT PHYSICAL PROTECTION REQUIREMENTS ................                                  55
            7.1 Response Procedure .....................................                                  55
            7.2 Notification ...........                          .......................                55
            7.3 Lost Material Notification .............................                                 56 iii


TABLE OF CONTENTS
The vii
                                                                      Page Chapter 8 EXPORT REQUIREMENTS ........................................ 57 Chapter 9 IMPORT REQUIREMENTS ........................................ 58
          9.1 Security Requirements ...........................        58
          9.2 Notification ........................................... 58 iv


INTRODUCTION
discussion section and list of alternatives should provide the licensee with the sense of the NRC regulations.
      The Atomic Energy Act of 1954, as amended, directed the U.S. Atomic Energy Commission (AEC) to regulate the receipt, manufacture, production, transfer, possession, use, import, and export of special nuclear material (SNM) in order to protect the public health and safety and to provide for the common defense and security. The Energy Reorganization Act of 1974 transferred all the licensing and related regulatory functions of the AEC
to the Nuclear Regulatory Commission (NRC).
      The principal requirements with respect to the physical protection of licensed activities against industrial sabotage and with respect to the phys- ical protection of special nuclear material in transit are found in 10 CFR
Part 50, "Domestic Licensing of Production and Utilization Facilities,"
Part 70, "Domestic Licensing of Special Nuclear Material," Part 73, "Phys- ical Protection of Plants and Materials," and Part 110, "Export and Import of Nuclear Equipment and Materials."
      Paragraph 50.34(c) of.lO CFR Part 50 and paragraphs 70.22(g), 70.22(h),
and 70.22(k) of 10 CFR Part 70 identify the physical protection information that must be provided in a Physical Security Plan as part of a license appli- cation.    This plan is required in order for the applicant to demonstrate compliance with the specific physical protection requirements of 10 CFR
Part 73 and must be submitted with each application for a license to possess or use SNM (or for a license authorizing transport or delivery of SNM), except for a license to possess, use, or transport less than 10 kg of SNM of low strategic significance, in which case a physical security plan is not required.


However, for the protection of SNM of low strategic significance, the licensee is required to meet the requirements of §73.67, "Licensee Fixed Site and In-Transit Requirements for the Physical Protection of Special Nuclear Mate- rial of Moderate and Low Strategic Significance," of 10 CFR Part 73.
This guide is divided into two parts.


This regulatory guide describes the information required in the physical security plan submitted as part of an application for a license to possess, use, or transport SNM of moderate strategic significance or 10 kg or more of SNM of low strategic significance and recommends a standard format for presenting the information in an orderly arrangement. This standard format will thus serve as an aid to uniformity and completeness in the preparation and review of the physical protection plan of the license application. This document can also be used as guidance by licensees possessing or transporting less than 10 kg of SNM of low strategic significance in understanding the intent and implementing the requirements of paragraphs 73.67(a), 73.67(f),
Part I,-"Special Nuclear Material of Moderate Strategic Significance," provides a standard format for preparing the licensee's security plans and provides guidance to licensees who possess, use, or transport SNM of moderate strategic significance.
and 73.67(g) of 10 CFR Part 73.


Aside from providing guidance for the standard format and content of physical security plans, this regulatory guide explains the intent of the various provisions of the regulation. The intent of each requirement is found in the discussion of each subsection and is implicitly provided by outlining alternative systems that could be used to fulfill the requirements.
Chapters 1 through 6 of Part I apply to applications for a license to possess or use at any'fixed site, or at contiguous sites subject to control by the licensee, SNM of moderate strategic significance.-
Chapters'7 through 13 of Part I apply to applications for authorization to transport or deliver to a carrier for transport SN! of moderate strategic significance.


The discussion section and list of alternatives should provide the licensee with the sense of the NRC regulations.
Part 1I, "Special Nuclear Material of Low Strategic Significance," pro vides a standard format for preparing the licensee's security plan for licensees who possess, use, or transport more than 10 kg of SNM of low strategic significance.


This guide is divided into two parts. Part I, "Special Nuclear Material of Moderate Strategic Significance," provides a standard format for preparing the licensee's security plans and provides guidance to licensees who possess,
It also provides guidance to all licensees who possess, use, or transport SNM of low strategic significance.
                                      1


use, or transport SNM of moderate strategic significance. Chapters 1 through
Chapters 1 through 4 of Part II apply to applications for a license to possess or use at any fixed-site, or at contiguous sites subject to control by the licensee, more than 10 kg of SNM of low strategic significance.
6 of Part I apply to applications for a license to possess or use at any fixed site, or at contiguous sites subject to contrQl by the licensee, SNM
of moderate strategic significance. Chapters 7 through 11 of Part I apply to applications for authorization to transport or deliver to a carrier for transport SNM of moderate strategic significance.


Part II, "Special Nuclear Material of Low Strategic Significance," pro- vides a standard format for preparing the licensee's security plan for licensees who possess, use, or transport more than 10 kg of SNM of low strategic signif- icance.    It also provides guidance to all licensees who possess, use, or transport SNM of low strategic significance. Chapters I through 4 of Part II apply to applications for a license to possess or use at any fixed site, or at contiguous sites subject to control by the licensee, more than 10 kg of SNM of low strategic significance. Included in this category are licensees who have nuclear power reactors under construction and are seeking a license to possess nuclear fuel onsite prior to obtaining their operating license.
Included in this category are licensees who have nuclear power reactors under construction and are seeking a license to possess nuclear fuel onsite prior to obtaining their operating license.


Chapters 5 through 9 of Part II apply to applications for authorization to transport or deliver to a carrier for transport more than 10 kg of SNM of low strategic significance.
Chapters 5 through 9 of Part II apply to applications for authorization to transport or deliver to a carrier for transport more than  
10 kg of SNH of low strategic significance.


Table 1 shows the type and amount of SNM covered in §73.67 of 10 CFR
Table 1 shows the type and amount of SN4 covered in § 73.67 of 10 CFR  
Part 73.    It should be noted, as stated in the footnote to Table 1, that
(1) plutonium with an isotopic concentration exceeding 80% or more in Pu-238,
(2) special nuclear material'that is not readily separable from other radio- active material and that has a total external radiation dose rate in excess of 100 rems per hour at a distance of 3 feet from any accessible surface without intervening shielding, and (3) sealed plutonium-beryllium neutron sources totaling 500 grams or less of contained plutonium at any one site or contiguous sites are exempt from the requirements of §73.67 of 10 CFR
Part 73.
Part 73.


This guide has been prepared to minimize lost time attributable to incomplete physical security plans and to standardize the review process.
It should be noted, as stated in the footnote to Table 1, that (1)
plutonium with an isotopic concentration exceeding 80 percent or more in Pu-238, (2) special ndulear material that is not readily separable from other radioactive material and that has a total external radiation dose rate in excess of 100 rems per hour at a distance of 3 feet from any accessible surface without intervening shielding, and (3) sealed plutonium-beryllium neutron sources totaling 500 grams or less of contained plutonium at any one site or contiguous sites are exempt from the requirements of S 73.67 of 10 CFR Part-73.
 
This guide has been prepared to minimize time lost because of incomplete physical security plans and to standardize the review process.


The applicant is encouraged to prepare his physical security plan in accord- ance with this guide and to provide information in each section to support the conclusion that he will be able to operate in accordance with the perti- nent regulations.    Although conformance with this guide is not required, the format and content presented are acceptable to the NRC staff.
Applicants are encouraged to prepare their physical security plans in accordance with this guide and to provide information in each section to support the conclusion that they will be able to operate in accordance with the pertinent regulations.


As developments and changes in the nuclear industry occur, the Commis- sion's requirements for information may need modification; revisions to this guide will be made as necessary to accommodate these changes.
Although conformance with this guide is not required, the format and content presented are acceptable to the NRC staff.


Purpose and Applicability This standard format has been prepared as an aid to uniformity and com- pleteness in the preparation and review of the physical protection section of license applications and to clarify the intent of the regulations. The information this guide contains will help the licensee plan a physical pro- tection system designed to detect the theft of SNM of moderate or low strat- egic significance. The physical protection subsystems identified are those which will usually be included in a protection system that would normally be capable of meeting the performance requirements of paragraph 73.67(a) of
As developments and changes in the nuclear industry, 9ccur, the Commis sion's requirements for information may need modification; revisions to this guide will be made as necessary to accommodate these changes.
                                        2


TABLE 1 CATEGORIES OF SPECIAL NUCLEAR MATERIAL
Purpose and Applicability This standard format has been prepared as an aid to uniformity and com pleteness in the preparation and review of the physical protection section of license applications and to clarify the Intent of the regulations.
                                          MODERATE STRATEGIC                      LOW STRATEGIC
  MATERIAL*          ENRICHMENT              SIGNIFICANCE                        SIGNIFICANCE
1. Plutonium                              Less than 2,000 g but more      500 g or less but more than 500 g                      than 15 g
2.  Uranium-235    20% or more in       Less than 5,000 g but more      1,000 g or less but U-235 isotope        than 1,000 g                    more than 15 g
                    10% or more but      10,000 g or more                Less than 10,000 g but less than 20%                                        more than 1,000 g in U-235 isotope Above natural                                        10,000 g or more but less than
                    10%
3.  Uranium-233                          Less than 2,000 g but more      500 g or less but more than 500 g                      than 15 g
4.  Uranium-235,    U-235 portion        Less than 5,000 g according    1,000 g or less according uranium-233,    enriched to 20%      to the formula:  grams =      to the formula: grams =
    and pluton-    or more.            (grams contained U-235) +      (grams contained U-235) +
    ium in 'com-                        2.5 (grams U-233 + grams        2.0 (grams U-233 + grams bination                            plutonium) but more than        plutonium) but more
                                          1,000 g according to the       than 15 g according to formula: grams = (grams        the formula: grams =
                                          U-235) + 2.0 (grams U-233      grams contained U-235 +
                                          + grams plutonium)              grams U-233 + grams Dlutonium.


*The following materials are exempt:
The viii
1.   Special nuclear material that is not readily separable from the radioactive material and that has a total external radiation dose rate in excess of 100 rems per hour at a distance of 3 feet from any accessible surface without intervening shielding,
 
2.   Plutonium with an isotopic concentration of 80% or more in Pu-238, and
Table 1 CATEGORIES OF SPECIAL NUCLEAR MATERIAL
MODERATE STRATEGIC
Low STRATEGIC
MATERIAL*
ENRICHMENT
SIGNIFICANCE
SIGNIFICANCE
1.
 
Plutonium
2.
 
Uranium,235
20% or more in U-235 isotope
10% or more but less than 20%
in U-235 isotope Above natural but less than
10%
Less than 2,000 g but more than-500 g Less than 5,000 g but more than 1,000 g
10,000 g or more
500 g or less but more than 15 g
1,000 g or less but more than 15 g Less than 10,000 g but more than 1,000 g
10,000 g or more
3.
 
Uranium-233
4.
 
Uranium-235, uranium-233, and pluton ium in com bination U-235 portion enriched to 20%
or more.
 
Less than 2,000 g but more than 500 g Less than 5,000 g according to the formula:
grams =
(grams contained U-235) +
2.5 (grams U-233 + grams plutonium) but more than
1,000 g according to the formula:
grams = (grams U-235) + 2.0 (grams U-233
+ grams plutonium)
500 g or less but more than 15 g
1,000 g or less according to the formula:
grams =
(grams contained U-235)-+
2.0 (grams U-233 + grams plutonium) but more than 15 g according to the formula:
grams =
grams, contained U-235 +
grams U-233 + grams olutonium.
 
*The following materials are exempt:  
1.
 
Special nuclear material that is not readily separable from the radioactive material and that has a total external radiation dose rate in excess of 10Q rems per hour at a distance of 3 feet from any accessible surface without intervening shielding,  
2. Plutonium with an isotopic concentration of 80 percent or more in Pu-238, and  
3. Sealed plutonium-beryllium neutron sources totaling 500 grams or less of contained plutonium at any one site or contiguous sites.
3. Sealed plutonium-beryllium neutron sources totaling 500 grams or less of contained plutonium at any one site or contiguous sites.


10 CFR Part 73. However, it is recognized that at any particular site there may be some subsystems and components not needed or additional ones needed to meet these performance requirements.   In these cases, the applicant is encouraged to address in the license application specific departures of sub- systems or components from this guide.
;t
 
information this guide contains will help the licensee plan a physical pro tection system designed to detect the theft of SNM of moderate or low strategic significance.
 
The physical protection subsystems identified are those that will usually be included in a protection system that would normally be capable of meeting the performance requirements of paragraph 73.67(a) of 10 CFR  
Part 73. However, it is recognized that at any particular site there may be some subsystems and components not needed or additional ones needed to meet these performance requirements.
 
In these cases, applicants are encouraged to address in the license application specific departures of subsystems or components from this guide.
 
The information requested in this guide is the minimum needed for the review of a physical security plan.
 
Additional information may be required for completing the staff review of a particular plan and should be included as appropriate.


The information requested in this guide is the minimum needed for the review of a physical security plan. Additional information may be required for completing the staff review of a particular plan and should be included as appropriate.    It is also the applicant's responsibility to be aware of new and revised NRC regulations. The information provided should be up to date with respect to the state of technology for the physical protection techniques and systems that the applicant proposes to use.
It is also the applicant's responsibility'to be aware of new and revised NRC regullations.


In cases where NRC-approved security plans are already in existence and where the measures included therein meet or exceed the requirements of
The information provided should be up to date with respect to the state of technology for the physical protection techniques and systems that the applicant proposes to use.
§73.67 of 10 CFR Part 73, the licensee may reference in his proposed security plan those sections of the NRC-approved security plan that are applicable.


Information and procedures delineated in the regulatory guides in Divi- sion 5, "Materials and Plant Protection," that are appropriate to certain sections of the physical security plan may be incorporated by reference.
In cases where NRC-approved security plans are already in existence and where the measures included therein meet or exceed the requirements of § 73.67 of 10 CFR Part 73, licensees may reference in their proposed security plans those sections of the NRC-approved security plans that are applicable.


The applicant should discuss his plans and programs with the NRC staff before preparing the application. This discussion should give particular emphasis to the depth of information required for the plan.
Information and procedures delineated in the regulatory guides in Divi sion 5, "Materials and Plant Protection," that are appropriate to certain sec tions of the physical security plan may be incorporated by reference.


Upon receipt of an application, the NRC staff will perform a preliminary review to determine whether the application provides a reasonably complete presentation of the information needed to form a basis for the findings required before issuance of a license. The standard format will be used by the staff as a guideline for identifying the type of information needed.
Applicants should discuss their plans and programs with the NRC staff before preparing the applications.
 
These discussions should give particular emphasis to the depth of infoimation required for the plans.. 
.Upon receipt of an application, the NRC staff will perform a preliminary review to determine whether the application provides a reasonably complete presentation of the information needed to form a basis for the findings required before issuance of a license.
 
The standard format will be used by the staff, as a guideline for identifying the type of information needed.


If an application does not provide a reasonably complete presentation of the necessary information, further review of an application will be suspended until this needed information is provided.
If an application does not provide a reasonably complete presentation of the necessary information, further review of an application will be suspended until this needed information is provided.


Use of the Standard Format The applicant should follow the numbering system of the Standard Format down to the level of section (e.g., 3.4). Under some circumstances, certain sections may not be applicable to a specific application. If so, this should be clearly stated and sufficient information should be provided to support that conclusion.
Use of Standard Format The applicant should follow the numbering system of the Standard Format down to the'level of section (e.g., 3.4).  
Under some circumstances, certain sections may not be applicable to a specific application.
 
If so, this should be clearly stated and sufficient information should be provided to support that conclusion.
 
The applicant may wish to submit in support of the application information that is not required by regulations and is not essential to the description of the applicant's physical protection program.
 
Such information could include, for example, historical data submitted in demonstration of certain criteria, discussion of alternatives considered by the applicant, or supplementary data x
 
regarding assumed models, data, or calculations.


The applicant may wish to submit in support of his application informa- tion that is not required by regulations and is not essential to the descrip- tion of the applicant's physical protection program. Such information could include, for example, historical data submitted in demonstration of certain criteria, discussion of alternatives considered by the applicant, or supple- mentary data regarding assumed models, data, or calculations. This informa- tion should be provided as an appendix to the application.
This information should be provided as an appendix to the application.


Upon completion of the application, the applicant should use the Table of Contents of the Standard Format as a checklist to ensure that each subject has been addressed.
Upon completion of the application, the applicant should use the Table of Contents of the Standard Format as a checklist to ensure that each subject has been addressed.


4
Style and Composition A table of contents should be included in each submittal.
 
The applicant should strive for clear, concise presentation of informa tion.


Style and Composition A table of contents should be included in each. submittal.
Confusing or ambiguous statements and general statements of intent should be avoided.


The applicant should strive for clear, concise presentation of informa- tion. Confusing or ambiguous statements and general statements of intent should be avoided. Definitions and abbreviations should be consistent through- out the submittal and consistent with generally accepted usage.
Definitions and abbreviations should be consistent through out the submittal and consistent with generally accepted usage.


Wherever possible, duplication of information should be avoided. Thus, information already included in other- sections of the applications may be covered by specific reference to those sections.
Wherever possible, duplication of information should be avoided.


Where numerical values are stated, the number of significant figures should reflect the accuracy or precision to which the number is known. The use of relative values should be clearly indicated.
Thus, information already included in other sections of the applications may be covered by specific reference to those sections.


Drawings, diagrams, and tables should be used when information may be presented more adequately or conveniently by such means. These illustrations should be located in the section where they are first referenced. Care should be taken to ensure that all information presented in drawings is legible, that symbols are defined, and that drawings are not reduced to the extent that they cannot be read by unaided normal eyes.
Where numerical values are stated, the number of significant figures should reflect the accuracy or precision to which the number is known.


Physical Specifications of Submittals All material submitted in an application should conform to the following physical dimensions of page size, quality of paper and inks, numbering of pages, etc.:
The use of relative values should be clearly Indicated.
1.    Paper Size Text pages:  8-1/2 x 11 inches.


Drawings and graphics: 8-1/2 x 11 inches preferred; however, a larger size is acceptable provided the finished copy when folded does not exceed
Drawings, diagrams, and tables should be used when information may be presented more adequately or conveniently by such means.
      8-1/2 x 11 inches.


2.    Paper Stock and Ink Suitable quality in substance, paper color, and ink density for handling and for reproduction by microfilming.
These illustrations should be located in the section where they are first referenced.


3.    Page Margins A margin of no less than one inch is to be maintained on the top, bottom, and binding side of all pages submitted.
Care should be taken to ensure that all information presented in-drawings is legible, that symbols are defined, and that drawings are not reduced to the extent that they cannot be read by unaided normal eyes.


4.   Printing Composition:   text pages should be single spaced.
Physical Specifications of Submittals All material submitted in an application should conformnto the following physical dimensions of page size, quality of paper and inks, numbering of pages, etc.:  
1.


Type face and style:   must be suitable for microfilming.
Paper Size Text pages:  
8-1/2 x 11 inches.


5
Drawings and graphics:
8-1/2 x 11 inches preferred; however, a larger size is acceptable provided the finished copy when folded does not exceed
8-1/2 x 11 Inches.


Reproduction:   may be mechanically or photographically reproduced.
2.
 
Paper Stock and Ink Suitable quality in substance, paper color, and ink density for handling and for reproduction by microfilming.
 
3.
 
Page Margins A margin of no less than 1 inch is to be maintained on the top, bottom, and binding side of all pages submitted.
 
xi
 
4.
 
Printing Composition:
text pages should be single spaced.
 
Type face and style:
must be suitable for microfilming.
 
Reproduction:  
may be mechanically or photographically reproduced.


All pages of the text may be printed on both sides, and images should be printed head to head.
All pages of the text may be printed on both sides, and images should be printed head to head.


5.  Binding Pages should be punched for looseleaf ring binding.
5.


6.  Page Numbering Pages should be numbered by section and sequentially within the section.
Binding Pages should be punched for looseleaf ring binding.


Do not number the entire report sequentially. (This entire'Standard Format has been numbered sequentially because the individual chapters were too short for sequential numbering within each section to be meaningful.)
6.
7.   Format References In the application, references to this Standard Format should be by part, chapter, and section numbers.
 
Page Numbering Pages should be numbered by section and sequentially within the section.
 
Do not number the entire report sequentially.
 
(This entire Standard Format has been numbered sequentially because the Individual chapters were too short for sequential numbering within each section to be meaningful.)  
7.
 
Format References In the application, references to this Standard Format should be by part, chapter, and section numbers.


Procedures for Updating or Revising Pages The updating or revising of data and text should be on a replacement page basis.
Procedures for Updating or Revising Pages The updating or revising of data and text should be on a replacement page basis.


The changed or revised portion of each page should be highlighted by a vertical line in the margin opposite the binding margin for each line changed or added. All pages submitted to update, revise, or add pages to the report should show the date of the change. The transmittal letter should include an index page listing the pages to be inserted and the pages to be removed.
The changed or revised portion of each page should be highlighted by a vertical line in the margin opposite the binding margin for each line changed or added.
 
All pages submitted to update, revise, or add pages to the report should show the date of the change.
 
The transmittal letter should include an index page listing the pages to be inserted and the pages to be removed.


When major changes or additions are made, pages for a revised table of contents should be provided.
When major changes or additions are made, pages for a revised table of contents should be provided.


Number of Copies The applicant should submit the appropriate number of copies of each required submittal pursuant to §70.21, "Filing," of 10 CFR Part 70.
Number of Copies The applicant should submit the appropriate~number of copies of each required submittal pursuant to § 70.21, "Filing," of 10 CFR Part 70.
 
Public Disclosure The NRC has determined that the public disclosure of the details of physical protection programs is not in the public interest, and such details are withheld pursuant to paragraph 2.790(d) of 10 CFR Part 2, "Rules of Practice for Domestic Licensing Proceedings."
Thus the physical protection section of each application should be submitted as a separate enclosure.


Public Disclosure The NRC has determined that the public disclosure of the details of physical protection programs is not in the public interest, and such details are withheld pursuant to paragraph 2.790(d) of 10 CFR Part 2. Thus the phys- ical protection section of each application should be submitted as a separate enclosure. Other proprietary and classified information should be clearly identified and submitted in separate enclosures. Each such submission of proprietary information should be accompanied by the applicant's detailed reasons and justifications for requesting exemption from public disclosure as required in paragraph 2.790(b) of 10 CFR Part 2.
Other proprietary and classified information should be clearly identified and submitted in separate enclosures.


6
Each such submittal of proprietary information should be accompanied by the applicant's detailed reasons and justifications for requesting exemption from public disclosure as required in paragraph 2.790(b) of 10 CFR Part 2.


PART I
xti
    SPECIAL NUCLEAR MATERIAL
 
PART I  
SPECIAL NUCLEAR MATERIAL  
OF MODERATE STRATEGIC SIGNIFICANCE
OF MODERATE STRATEGIC SIGNIFICANCE
                  7
5.59-1
 
1.
 
USE AND STORAGE AREA AT A FIXED SITE
This chapter provides guidance on meeting the requirements of paragraphs
73.67(d)(1) and (d)(2),.which are as follows:
(d)(1)
Use the material only within a controlled access area which is illuminated sufficiently to allow detection and surveillance of unauthorized penetration or activities.*
(d)(2)
Store the material only within a controlled access area such as a vault-type room or approved security cabinet or their equivalent which is illuminated sufficiently to allow detection and surveillance of unauthorized penetration or activities.*
A controlled access area (CAA)
is defined in paragraph 73.2(z) as "any temporarily or permanently established area which is clearly demarcated, access to which is controlled and which affords isolation of the material or persons within it." "Access control" means measures used to allow only specified personnel, materials, and vehicles ingress into and egress from a given area, while "isolation" refers to measures taken to deter persons, materials, or vehicles from entering or leaving a given area through other than established access control points.
 
Thus, a CAA Includes provisions for both isolation and access control.
 
In some cases, isolation or access control systems may also serve the purpose of aiding in the detection of unauthorized penetration or activities* within the CAA.
 
Therefore, these detection-related considerations are alluded tQ in this chapter.
 
In the discussion that follows, CAAs intended for use and the possible storage of SNM of moderate strategic significance are discussed separately from those intended solely for the storage of such SNM.
 
Although the requirements for these two different applibations of CAA are in most respects similar', it is recognized that the means used to isolate the material and control access may differ markedly for use areas compared with storage areas and therefore warrant separate discussion.
 
1.1 Area Where Material Is Used [73.67(d)(1)]
Intent This section discusses CAAs intended primarily for the use of SNM of moderate strategic significance.
 
These may be temporarily established to meet transitory or intermittent SKM use requirements or they may be permanently established.
 
Permanently established CAAs for use of SNM may also be suitable for st6rage.
 
"Use" means that the material is undergoing processing (e.g.,
fuel fabrication, irradiation in a reactor) or utilization of its properties in conjunction with experimental equipment (e.g., equipment used for research or educational laboratory experiments).
Different isolation/access control measures may be used for periods during whicht the area is occupied versus unoccupied.


1.  USE AND STORAGE AREA AT A FIXED SITE
SUnauthorized activities are those activities deemed by the licensee to be indicative of or contributory to the possible theft of SNM.
      This chapter provides guidance on meeting the requirements of paragraphs
73.67(d)(1) and (d)(2), which are as follows:
(d)(1)    Use the material only within a controlled access area which is illuminated sufficiently to allow detection and surveillance of unauthorized penetration or activities.*
(d)(2)    Store the material only within a controlled access area such as a vault-type room or approved security cabinet or their equivalent which is illuminated sufficiently to allow detection and surveil- lance of unauthorized penetration or activities.*
      A controlled access area (CAA) is defined in paragraph 73.2(z) as "any temporarily or permanently established area which is clearly demarcated, access to which is controlled and which affords isolation of the material or persons within it." "Access control" means measures used to allow only specified personnel, materials, and vehicles ingress into and egress from a given area, while "isolation" refers to measures taken to deter persons, materials, or vehicles from entering or leaving a given area through other than established access control points.        Thus, a controlled access area includes provisions for both isolation and access control.        In some cases, isolation or access control systems may also serve the purpose of aiding in the detection of unauthorized penetration or activities* within the CAA.


Therefore these detection-related considerations are alluded to in this chapter.
5.59-3


In the discussion that follows, CAAs intended for use and the possible storage of SNM of moderate strategic significance are discussed separately from those intended solely for the storage of such SNM.        Although the require- ments for these two different applications of CAA are in most respects similar, it is recognized that the means used to isolate the material and control access may differ markedly *for use areas compared with storage areas and therefore warrant separate discussion.
Illumination sufficient to allow detection and surveillance of unauthor Ized penetration or activities within the CAA where the material is used need not require the use of high-Intensity lighting throughout the CAA.


1.1    Area Where Material Is Used [73.67(d)(1)]
What is intended is the use of normal lighting sufficiently uniform throughout the CAA
Intent This section discusses CAAs intended primarily for the use bf SNM of moderate strategic significance.        These may be temporarily established to meet transitory or intermittent SNM use requirements or they may be perma- nently established.        Permanently established CAAs for use of SNM may also be suitable for storage.        "Use" means that the material is undergoing pro- cessing (e.g. fuel fabrication, irradiation in a reactor, etc.) or utiliza- tion of its properties in conjunction with experimental equipment (e.g.,
to ensure that material or unauthorized personnel cannot be secreted in a darkened area until a time more convenientfor the unauthorized removal of the material.
research or educational laboratory experiments).        Different isolation/access control measures may be used for periods during which the area is occupied versus unoccupied.


Unauthorized activities are those activities deemed by the licensee to be indicative of or contributory to the possible theft of SNM.
For those facilities where experiments must be conducted in a darkened room, the lighting requirement is exempted for as long as is needed provided access control is ensured and the material is accounted for at the end of the experiment.


8
1.


Illumination sufficient to allow detection and surveillance of unauthor- ized penetration or activities within the CAA where the material is used need not require the use of high-intensity lightiog throughout the CAA.
Temporarily Established CAAs Temporarily established CAAs for the use of SNM need not have permanent barriers at their boundaries.


What is intended is the use of normal lighting sufficiently uniform through- out the CAA to ensure that material or unauthorized personnel cannot be secreted in a darkened area until a time more convenient for the unauthorized removal of the material.    For those facilities where experiments must be conducted in a darkened room, the lighting requirement is exempted for as long as is needed provided access control is ensured and the material is accounted for at the end of the experiment.
Isolation of the material and persons using the material may be provided by office partitions, cordons, or other devices used to warn passersby of the restricted nature of the area.


a.    Temporarily Established CAAs Temporarily established CAAs for the use of SNM need not have permanent barriers at their boundaries.    Isolation of the material and persons using the material may be provided by office partitions, cordons, or other devices used to warn passersby of the restricted nature of the area. Access control can be effected through surveillance or supervision of the area by those who are using the SNM and who are responsible for the material. However, the provision of access control through personal supervision is suitable only for those situations in which the size of the CAA and the number of persons to be admitted are sufficiently small and in which the CAA is suitably configured to make such procedures practical.
Access control can be effected through surveillance or supervision of the area by those-who are using the SNN and who are responsible for the material.


When material located in a temporarily established CAA is to be left unattended (i.e., because it is impractical to replace the material in a CAA designed for long-term storage of the material), access control and improved isolation for the temporary CAA may be provided to substitute for the discontinued personal supervision over the material.    (In addition, pro- visions must be made for satisfying the monitoring requirement of paragraph
However, the provision of access control through personal supervision is suitable only for those situations in which the size of the CAA and the number of persons to be admitted are sufficiently small and in which the CAA is suitably configured to make such-procedures practical.
73.67(d)(3).)    Improved isolation can sometimes be provided by increasing the penetration resistance of existing barriers (e.g. , locking doors and windows, placing the material in a locked drawer or supply room, etc.).
Access control may be provided by any of the measures suggested below for permanently established CAAs left unattended; some of these suggestions may be more suitable for temporary use than others. If no suitable barrier is available to provide isolation, material left unattended can be protected by a motion alarm covering the area immediately surrounding the material.


This improved detection capability would be considered an acceptable sub- stitute for the rudimentary isolation provided by temporary barricades, cordons, signs, and other less substantial means of isolation that may be used on a temporary basis.
When material located in a temporarily established CAA is to be left unattended (i.e., because it is impractical to replace the material in a CAA
designed for long-term storage of the material), access control and improved isolation for the temporary CAA may be provided to substitute for the discontinued personal supervision over .the material.


b.    Permanently Established CAAs Permanently established CAAs for the use and temporary storage of SNM
(In addition, provisions must be made for satisfying the monitoring requirement of paragraph
of moderate strategic significance would most likely provide isolation for the SNM through the use of permanent barriers. These could consist of fences;
73.67(d)(3).)
gates or freestanding walls for exterior areas; or exterior or interior build- ing walls, locked doors, windows, bars, grillwork; or other barriers for interior areas.   Such barriers are not required to meet the more stringent criteria for physical barriers used for the protection of formula quantities
Improved isolationdcan sometimes be provided by increasing the penetration resistance of existing barriers (e.g., locking doors andwindows, placing the material in a locked drawer or supply room).  
                                        9
Access control may be provided by any of the measures suggested below for permanently established CAAs left unattended; some of these suggestions may be more suitable for temporary use than others.


of strategic special nuclear material (SSNM).*    However, good security manage- ment practice would dictate that the barrier be substantial enough to-deter casual passersby from unauthorized penetration.    If the barriers are also designed to aid in detection, the criteria for penetration resistance or tamper-indication in accordance with the specific monitoring procedures to be used also apply.
If no suitable barrier is available to provide isolation, material left unattended may be protected by a motion alarm covering the area immediately surrounding the material.


Access control for permanently established CAAs during periods they are occupied can be provided by personal supervision. However, when these areas are unoccupied or when the size, configuration, or numbers of persons intended to be admitted to the area make personal supervision impractical, other means of access control may be called for. Some of the additional access control measures that may be used for permanently established CAAs**
This improved detection capability would be considered an acceptable substitute for the rudimentary isolation provided by temporary barricades, cordons, signs, and other less substantial means of isolation that may be used on a temporary basis.
in these situations are:
      *    Stationing of a watchman at CAA access control points, Limiting distribution of keys, keycards, or combinations to doors and gates, Using a coded badging system to identify authorized personnel at CAA access control points, Controlling locked CAA doors and gates by use of remote surveillance (e.g., via intercom or CCTV) by personnel stationed at a centrally located access control facility, or Controlling access of personnel, material,  and vehicles into CAAs by other means.


It is expected that large facilities will have more complex isolation and access control systems than small facilities in order to achieve compar- able levels of protection.
2.


Content (This section needs to be completed only for CAAs designated exclusively for use of SNM. CAAs designated for both use and storage are to be described as recommended in Section 1.2 of this Standard Format.)
Permanently Established CAAs Permanentiy established CAAs for the use and temporary storage of SNM of moderate strategic significance would most likely provide isolation for the SNM
      Describe the CAAs designated exclusively for use of the material.  Indi- cate under what conditions CAAs will be established on a temporary basis.
through the use of permanent barriers.


For each CAA identified, provide the following information:
These could consist of fences; gates or freestanding walls for exterior areas; or exterior or interior building walls, locked doors, windows, bars, grillwork; or other barriers for interior areas.
      1.  A description of the area and its features relative to other facil- ity features, showing the normal routes of ingress to each CAA (including a scale diagram).
  "Strategic special nuclear material" means uranium-235 (contained in uranium enriched to 20 percent or more in the U-235 isotope), uranium-233, or plutonium.


Access control requirements for CAAs for the use or storage of SNM of moderate strategic significance are discussed in Chapter 3 of Part I of this guide.
Such barriers are not required to meet the more stringent criteria for physical barriers used for the protection of formula quantities of strategic special
5.59-4


10
nuclear material (SSNM).*
However, good security management practice would dictate that the barrier be substantial enough to deter casual passersby from unauthorized penetration.


2.  Descriptions of physical barriers, cordons, walls, partitions, or other means of providing isolation of the CAA and channelling entry through established access control points into the CAA.
If the barriers are also designed to aid in detec tion, the criteria for penetration resistance or tamper indication In accordance with the specific monitoring procedures to be used also apply.


3.  The means and criteria used for controlling access into the CAA
Access control for permanently established CAAs during periods they are occupied can be provided by personal supervision.
at established access control points.


4.  If more than one CAA is designated, indicate the types of material normally used in each CAA; for temporarily established CAAs, indicate the types of activities normally performed within each area.
However, when these areas are unoccupied or when the size, configuration, or numbers of persons intended to be admitted to the area make personal supervision Impractical, other means of access control may be called for.


5.   The lighting level and uniformity of lighting provided to allow detection and surveillance of unauthorized penetration or activities within the CAA or in the immediate vicinity of the CAA.
Some of the additional access control measures that may be used for permanently established CAAs** in these situa tions are:
Stationing a watchman at CAA access control points, Limiting distribution of keys, keycards, or combinations to doors and gates, Using a coded badging system to identify authorized personnel at CAA
access control points,
.
Controlling locked CAA doors and gates by use of remote surveillance (e.g., intercom or CCTV) by personnel stationed at a centrally located access control facility, or  
.
Controlling access of personnel, material, and vehicles into CAs by other means.


1.2  Area Where Material Is Stored [73.67(d)(2)]
It is expected that large facilities will have more complex Isolation and access control systems than small facilities in order to achieve comparable levels of protection.
Intent Controlled access areas normally used only for storage of SNM are described in this section. Such CAAs may be very limited in size, since they need only contain the material itself, and access to them is expected to be infre- quent. Where small amounts of material are involved, the CAA may consist of relatively small containers such as security cabinets, safes, and locked closets or supply rooms.


The same basic isolation and access control* capabilities that apply to CAAs for the use of SNM of moderate strategic significance also apply to CAAs for the storage of this material. However, the CAA for storage is, in addition, specifically required to be equivalent to either an approved security cabinet or a vault-type room. This additional requirement embodies a tradeoff decision to be made by the licensee between the capability for immediate detection of penetration attempts into a vault-type room and the improved penetration resistance likely to be provided by an approved security cabinet.
Content (This section needs to-be completed only for CA*s designated exclusively for use of SNM.


A vault-type room is defined in paragraph 73.2(o) of 10 CFR Part 73 as
CAAs designated for both use and storage are to be described as recommended in Section 1.2 of Part I of this Standard Format.)
"a room with one or more doors, all capable of being locked, protected by an intrusion alarm which creates an alarm upon the entry of a person anywhere into the room and upon exit from the room or upon movement of an individual within the room."    The vault-type room can be a locked laboratory, supply room, closet, or other room equipped with a tamper-resistant motion detector alarm system. The motion detector would simultaneously satisfy the monitor- ing requirement of paragraph 73.67(d)(3) addressed in the next chapter.
Describe the CAAs designated exclusively for use of the material.


The expression "equivalent to a vault-type room" means that a piece of equip- ment (such as a fission chamber, reactor core, or storage rack), even though it does not resemble a "room," may meet the requirement for a storage-type CAA if there is a means of isolation (e.g., a locked grill, inaccessibility beneath water as in a storage pool, intricate and time-consuming procedures required for removal) and it is protected with a tamper-resistant motion detection system. Note that in some cases, material located in such pieces of equipment may be considered in use rather than in storage.    In this case, Access control requirements for CAAs for the use or storage of SNM of moderate strategic significance are discussed in Chapter 3 of Part I of this guide.
Indi-"  
cate under what conditions CAAs will be established on a temporary basis.


11
For each CAA identified, provide the following information:
1.


whether the material is being personally supervised or not, the requirement for use of a motion detection system to satisfy the monitoring requirement is removed, and other monitoring devices or procedures may be used instead.
"A description of the area and its features relative to other facility features, showing the normal routes of ingress to each CAA (including a scale diagram). 
"Strategic special nuclear material" means uranium-235 (contained in uranium enriched to 20 percent or more in the U-235 isotope), uranium-233, or plutonium.


When a container equivalent to an approved security cabinet is chosen to satisfy paragraph 73.67(d)(2), the equivalency is based upon the penetra- tion resistance of the container and the difficulty associated with manipula- tion of the lock. The basic premise used to determine whether such a con- tainer may be monitored by procedures or devices other than a motion detector is whether it is unreasonable to expect that an external adversary could penetrate the container in a reasonable amount of time without leaving an indi'cation of the penetration.   The amount of time that would be required for penetration without such an indication may be used to govern the fre- quency of patrols when monitoring procedures are used. An approved security cabinet or its equivalent is one whose design has been certified by the General Services Administration or other nationally recognized standards organization (e.g., ANSI) to afford protection against surreptitious entry and lock manipulation equivalent to that provided by a Class-6 GSA rating or better.
Access control requirements for CAAs for the use or storage of SNM of moderate strategic significance are discussed in Chapter 3, "Access Control at a Fixed Site," of Part I of this guide.
 
5.59-5
 
Note that, in some cases, material located in such pieces of equipment may be considered in use rather than in storage.
 
In this case, whether the material is being personally supervised or not, the requirement for use of a motion detection system to satisfy the monitoring requirement isiremoved, and other monitoring devices or procedures may be used instead.
 
When a container equivalent to an approved security cabinet is chosen to satisfy paragraph 73.67(d)(2), the equivalency is based on the penetration resistance of the container and the difficulty associated with manipulating the lock.
 
The basic premise used to determine whether such a container may be monitored by procedures or devices other than a motion detector is whether it is unreasonable to expect that an external adversary could penetrate the container in a reasonable amount of time without leaving an indication of the penetration.
 
The amount of time that would be required for penetration without such an indication may be used to govern the frequency of patrols when monitoring procedures are used.
 
An approved security cabinet or its equivalent is one whose design has been certified by the General Services Administration or other nationally recognized standards organization (e.g., ANSI) to afford protection against surreptitious entry and lock manipulation equivalent to that provided by a Class-6 GSA rating or better.
 
Isolation for CAAs intended only for storage usually will be provided by the penetration-resistant features of the perimeter barriers or container walls of the CAA.
 
The level of penetration resistance of such barriers is not required to meet the more stringent criteria for physical barriers used to protect formula quantities of SSNM.


Isolation for CAAs intended only for storage usually will be provided by the penetration resistant features of the perimeter barriers or container walls of the CAA. The level of penetration resistance of such barriers is not required to meet the more stringent criteria for physical barriers used to protect formula quantities of strategic special nuclear material (SSNM).
Rather, the physical barriers or container walls of the CAA are intended only to deter penetration by unauthorized persons and to aid detection by providing an indication of forced penetration.
Rather, the physical barriers or container walls of the CAA are intended only to deter penetration by unauthorized persons and to aid detection by providing an indication of forced penetration.


In determining the level of isolation/access control required for such CAAs, the time required for extricating SNM from its storage location   in relationship to the licensee's time of detection and assessment may be taken into account (e.g., spent fuel assemblies stored in spent fuel storage pools or fuel residing in nonpower reactor cores).
In determining the level of isolation/access control required'for such CAAs, the time required for extricating SNM from its storage location in relationship to the licensee's time of detection and assessment may be taken into account (e.g., spent fuel:assemblies stored in spent fuel storage pools or fuel residing in nonpower reactor cores).
      Examples of typical CAAs where special nuclear material of moderate strategic significance may be stored are:
Examples of typical CAAswhere special nuclear material of moderate strategic significance may be stored are:  
      1. Vault. A structure that satisfies the definition for a vault as stated in paragraph 73.2(n) would provide more than adequate isolation protection.
1.
 
Vault.
 
A structure that satisfies the definition for a vault as stated in paragraph 73.2(n) would provide more than adequate isolation protection.
 
2.
 
Approved Security Cabinets.
 
Those cabinets that are designed to provide delay and resistance against surreptitious entry and lock manipulation.
 
3.
 
Reactor.
 
Reactors that are sodesigned that removal of material is difficult.
 
4.
 
Vault-Type Room.
 
Some typical vault-type rooms where materials are stored and protected with a motion detector are storage pools, a room containing in-process storage racks, and laboratories where material is left unattended.
 
In all cases, movement in the near vicinity of the material or of the material itself generates an alarm signal.
 
5.59-7
 
5.
 
Locked Laboratories, Supply Rooms.
 
These areas must be sufficiently penetration resistant to afford a means of isolation/access control and permit the proper functioning of the system for monitoring the storage area as required by paragraph 73.67(d)(3) of the rule and as described in Chapter,2,
"Detection Devices and Procedures at a Fixed Site," of Part I of this guide.
 
The Illumination level required for the CAA should be sufficiently uniform and bright (a) in the case of a security cabinet, to detect penetration of or tampering with the CAA containment or (b) in the case of a vault-type room or its equivalent, to detect unauthorized penetration of or activities within the CAA.
 
Content Describe the CAMs wheirethe material will be stored and, in some cases, used.


2.  Approved Security Cabinets. Those cabinets that are designed to provide delay and resistance against surreptitious entry and lock manipulation.
For each such CAM,
provide the following information:
1.


3.   Reactor.  Reactors that are so designed that removal of material is difficult.
features, diagram).
A description of the area and its features relative to other facility showing the access control points for the CAM (including a scale
2.


4.  Vault-Type Room.  Some typical vault-type rooms where materials are stored and protected with a motion detector are storage pools, a room containing in-process storage racks, and laboratories where material is left unattended. In all cases, movement in the near vicinity of the material or of the material itself generates an alarm signal.
The isolation system such as physical barriers, container walls, or other features that demarcate the perimeter of the CAM and channel entry only through established access control points.


12
3.


5.    Locked Laboratories, Supply Rooms.  These areas must be sufficiently penetration resistant to afford a means of isolation/access control and permit the proper functioning of the system for monitoring the storage area as required by paragraph 73.67(d)(3) of the rule as described in Part I, Chapter 2.
The means and criteria used for controlling access to the CAA at established access control points.


The illumination level  required for the CAA should be sufficiently uniform and bright (a) in the case    of a security cabinet, to detect penetration of or tampering with the CAA    containment or (b) in the case of a vault-type room or its equivalent, to  detect unauthorized penetration of or activities within the CAA
4.
Content Describe the CAAs where the material will be stored and, in some cases, used.    For each such CAA, provide the following information:
      1.    A description of the area and its features relative to other facil- ity features showing the access control points for the CAA (including a scale diagram).
      2.    The isolation system such as physical barriers, container walls, or other features which demarcate the perimeter of the CAA and channel entry only through established access control points.


3.    The means and criteria used for controlling access to the CAA at established access control points.
the types
5.


4.    If more than one CAA is designated for the storage of the material, the types of material normally to be stored in each area.
detection CAM or in If more than one CAM is designated for the storage of the material, of material normally to be stored in, each area.


5.    The lighting level and uniformity of lighting provided to allow detection and surveillance of unauthorized penetration or activities within the CAA, or in the immediate vicinity of the CAA (where security cabinets are used).
The lighting level and uniformity of lighting provided to allow and surveillance of unauthorized penetration or activities within the the immediate vicinity of the CAM (where-security cabinets are used).
                                        13
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      This chapter provides guidance for meeting the.requirement of paragraph
73.67(d)(3), which is as follows:
(d)(3)      Monitor with an intrusion alarm or other device or procedures the controlled access areas to detect unauthorized penetrations or activities.


The purpose of this monitoring activity as stated in paragraph 73.67(a)(2)
DETECTION DEVICES AND PROCEDURES AT A FIXED SITE
is to provide "early detection and assessment of unauthorized access or activ- ities by an external adversary within the controlled access area..." and
This chapter provides guidance for meeting the requirement of paragraph  
''early detection of removal of special nuclear material by an external adversary from a controlled access area." This should be done to achieve the objective of minimizing the possibilities for unauthorized removal of special nuclear material "consistent with the consequences of such actions," as stated in paragraph 73.67(a) of the effective rule. Thus the earliness of detection- afforded by the licensee's physical protection system may vary depending upon the nature and quantity of the material susceptible to unauthorized removal.    Further discussion of the earliness of detection required for possible thefts of different types and quantities of special nuclear material of moderate strategic significance is provided in Section 2.1.
73.67(d)(3), which is as follows:
(d)(3)  
Monitor with an intrusion alarm or other device or procedures the controlled access areas to detect unauthorized penetrations or activities.


2.1  Earliness of Detection [73.67(a)]
The purpose of this monitoring activity as stated in paragraph 73.67(a)(2)
      Determination of early detection of unauthorized access, activities, or removal of special nuclear material.from controlled access areas will be based on an assessment of the magnitude of the consequences associated with possible misuse of the type and quantity of material that could be removed in a given theft attempt. For special nuclear material of moderate strategic significance, two distinct cases are considered:
is to provide "early detection and assessment of unauthorized access or activ ities'by an external adversary within the controlled access area..." and "early detection of removal of special nuclear material by an external adversary from a controlled access area.". This should be done to achieve the objective of minimizing the possibilities for unauthorized removal of special nuclear material "consistent with the consequences of such actions," as stated in paragraph 73.67(a) of the effective rule.
      1.  Theft of strategic special nuclear material (SSNM).*
      2.  Theft of low-enriched uranium (LEU).**
Thefts from a single facility of SSNM in quantities of moderate strategic significance are limited by definition to quantities that could not be used to construct a nuclear explosive device; thefts of similar quantities of material from several different facilities could, however, lead to the accu- mulation of an aggregate quantity that would permit such illicit use. (The consequences of a single theft of such material would have minimal impact on the public health and safety). Therefore, detection of such thefts is required sufficiently early to ensure early notification to the NRC so that the NRC in turn can notify other licensees of the need to implement appro- priate responses to prevent the accumulation by a single adversary of a formula quantity of material through multiple thefts from different facil- ities. The NRC believes that there are detection systems and procedures In this case, Strategic Special Nuclear Material means all SNM of moderate strategic significance other than low-enriched uranium.


Low-enriched uranium is.uranium enriched above natural percentages but less than 20% in the U-235 isotope.
Thus, the earliness of detection afforded by the licensee's physical protection system may vary depending on the nature and quantity of the material susceptible to unauthorized removal.


14
Further discussion of the earliness of detection required for possible thefts of different types and quantities of special nuclear material of moderate strategic significance is provided in Section 2.1 of Part I of this guide.


that would allow the licensee to detect a theft of SSNM within approximately two hours.
2.1 Earliness of Detection [73.67(a)]
Determination of early detection of unauthorized access, activities, or removal of SNM from CAAs will be based on an assessment of the magnitude of the consequences associated with possible misuse of the type and quantity of material that could be removed in a given theft attempt.


The criteria for early detection of thefts of LEU enriched to more than
For SNM of moderate strategic significance, two distinct cases are considered:
10%, but less than 20%, in the isotope U-235 are the same as for thefts of LEU in quantities comprising SNM of low strategic significance. The reader should refer to Part II of this guide for information regarding appropriate monitoring procedures to achieve early detection for such material.
1.


2.2  Detection Through Monitoring of Controlled Access Areas [73.67(d)(3)]
Theft of strategic special nuclear material (SSNM).*
Intent Licensees possessing quantities of SNM of moderate strategic significance can provide a monitoring system capable of detecting a theft of material within approximately two hours of the actual removal of the material.    Either detection devices or security procedures may be used to help detect unauthor- ized activities or penetration of CAAs.    Most of the sites at which this material is stored or used are likely to be small research-oriented facilities such as non-power reactors and educational institutions. At such facilities there are likely to be relatively small quantities of SNM available, and authorized access to it may be infrequent.
2.


Detection devices such as interior motion detector systems, balanced magnetic switches, etc. could be used to monitor such relatively small CAAs, where the number of established access control points is very limited.
Theft of low-enriched uranium (LEU).**
Thefts from a single facility of SSNM in quantities of moderate strategic significance are limited by definition to quantities that could not be used to construct a nuclear explosive device;.thefts of similar quantities of material from several different facilities could, however, lead to the accumulation of an aggregate quantity that would permit such illicit use.


Security procedures may also be used to protect against thefts of quanti- ties of SNM of moderate strategic significance because watchman patrols inherently allow unguarded intervals during which an external adversary could conceivably obtain access to the CAA, remove a small quantity of material, and leave before being discovered. The inspection procedure may (a) be suffi- ciently frequent to ensure that an external adversary could not complete a successful theft of the material during the unguarded intervals, (b) provide for an indication of the CAA barrier having been tampered with (as with a seal or by observation of damage done to the barrier), or (c) provide for an item count inventory or other accounting for the material as part of the inspection. Some examples are given below:
(The consequences of a single theft of such material would have minimal impact on the public health and safety.)  
            After having left material unattended in an experimental setup in a classroom used as a temporary CAA, the instructor returns after several hours and verifies that the material is still in place.
Therefore, detection of such thefts is required sufficiently early to ensure early notification to the NRC so thatthe NRC in turn can notify other licensees of the need to implement appropriate responses to prevent the accumulation by a single adversary of a formula quantity of material through multiple thefts from different facilities.


A small quantity of material is stored in a security cabinet for several months at a time without authorized access. Every two hours a watchman comes around to inspect the cabinet to ensure that the lock is secure and the cabinet has not been tampered with.
The NRC believes that there are detection systems and procedures that would allow the licensee to detect a theft of SSNM within approximately 2 hours.


If a lockois used that is not designed to be resistant to surrepti- tious and forced entry, the watchman also inspects a tamper-indicating seal to verify that the container has not been tampered with.
In this case, strategic special nuclear material means all SHM of moderate strategic significance other than low-enriched uranium.


During times a non-power reactor is left unattended, a watchman comes around every two hours and checks that none of the fuel elements have been removed by unauthorized person
Low-enriched'uranium is uranium enriched above natural percentages but less than 20 percent in the U-235 isotope.


====s. If he encounters a====
5.59-9
                                        15


person working during off-hours in the vicinity of the non-reactor, he asks for appropriate identification.
The criteria for early detection of thefts of LEU enriched to more than
10 percent, but less than 20 percent, in the isotope U-235 are the same as for thefts of LEU in quantities comprising SNM of low strategic significance.


While a non-power reactor is being used, the supervisor ensures that he or his designee is not away from the reactor for a period longer than thirty minutes or a period he estimates would be minimally required for a person to obtain fuel elements in the core that are not self-protecting by virtue of their having been sufficiently irradiated.
The reader should refer to Part II of this guide for information regarding appropriate monitoring procedures to achieve early detection for such material.


During periods when excess fuel is left unattended in a storage closet at a non-power reactor facility, an alarm system is activ- ated that would annunciate if anybody tried to penetrate the closet without proper authorization.
2.2 Detection Through Monitoring-Controlled Access Areas [73.67(d)(3)]
Intent Licensees possessing quantities of SNM of moderate strategic significance can provide amonitoring system capable of detecting a theft of material within approximately 2 hours of the actual removal of the material.


During periods when the material is being used under the direct supervi- sion of authorized personnel, the monitoring requirement may be satisfied by virtue of the continuous surveillance exercised by such personnel.
Either detection devices or security procedures may be used to help detect unauthorized activities or penetration of CAAs.


Content For each of the CAAs designated for the protection of SNM of moderate strategic significance, provide the following information regarding the meas- ures taken to fulfill the monitoring requirement of paragraph 73.67(d)(3):
Most of the sites at which this material is stored or used are likely to be small research-oriented facilities such as nonpower reactors and educational institutions.
      1.  Describe any devices employed by specifying the type of device, its installed location, the type and location of annunciation, the intended area of coverage, and the tamper-resistant features. Refer, if desired, to existing filed security plans or NRC-published guidance or NUREG series documents.


2.  Describe any procedures employed to monitor the CAA or portions thereof, including the categories of persons who will execute the procedures, the frequency of inspections or rounds of patrol, the basis for the determina- tion of such frequencies, and the occasions when the procedures are intended to be implemented. Indicate, also, the features of the CAA (e.g. barriers, locks, seals, etc.) that will affect the way the procedures are used.
At such facilities there are likely to be relatively small quantities of SNM available, and authorized access to it may be infrequent.


3.   Explain how the combination of procedures and devices used to monitor each CAA meets the criteria for early detection of theft by an external adversary relative to the type of material found in each CAA.
Detection devices such as interior motion detector systems, balanced magnetic switches, etc., could be used to monitor such relatively small CAAs where the number-of established access control points Is very limited.


16
Security procedures may also be used to protect against thefts of quanti ties of SNM of moderate strategic significance because watchman patrols inherently allow unguarded Intervals during which an external adversary could conceivably obtain access to the CA, remove a small quantity of material, and leave before being discovered.


3.  ACCESS CONTROL AT A FIXED SITE
The inspection procedure may,(1) be suffi ciently frequent to ensure that an external adversary could not complete a successful theft of the material during the unguarded intervals,,(2) provide for an indication of the CAA barrier having been tampered with (as with a seal or by observation of damage done to the barrier), or (3) provide for an item count inventory or other accounting for the material as part of the inspection.
      This chapter provides guidance on meeting the requirements of paragraphs
73.67(d)(4), (d)(5), (d)(6), (d)(7), and (d)(1O), which are as follows:
(d)(4)    Conduct screening prior to granting an individual unescorted access to the controlled access area where the material is used or stored, in order to obtain information on which to base a decision to permit such access, (d)(5)    Develop and maintain a controlled badging and lock system to identify and limit access to the controlled access areas to authorized individuals, (d)(6)    Limit access to the controlled access areas to authorized or escorted individuals who require such access in order to perform their duties, (d)(7)    Assure that all visitors to the controlled access areas are under the constant escort of an individual who has been authorized access to the area, (d)(1O)    Search on a random basis vehicles and packages leaving the con- trolled access areas.


An access control system is one that controls access to or egress from a CAA through normal routes for personnel, materials, or vehicles.
Some examples are given below:
After having left material unattended in an experimental setup in a classroom used as a temporary CM, the instructor returns after several hours and verifies that the material is still in place.


3.1  Preauthorization Screening [73.67(d)(4)]
A small quantity of material-is stored in a security cabinet for several months at a time without authorized access.
Intent The intent of the requirement for preauthorization screening is to ensure that the licensee will have sufficient knowledge of an individual to determine his reliability and need for access prior to granting him authorized access to the CAA where the material is used or stored.      The selection of procedures for conducting this examination and the criteria he employs to make his judgments are the responsibility of the licensee and, of course, should be consistent with all local, State, and Federal laws and regulations regarding the protection of the privacy and other rights of the individual.


The screening process may be conducted in the same manner as other investiga- tions customarily conducted by potential employers for similarly sensitive positions.    There is no requirement for the licensee to arrange for an NRC
Every 2 hours a watchman comes around to inspect the cabinet to ensure that the lock is secure and the cabinet has not been tampered with.
clearance or similar clearance from any other government organization.


Examples of procedures and criteria that may be employed in the screening process include holding or having recently held a government-sanctioned clearance; examination of past employment or educational records (to deter- mine any unsatisfactory employment or school actions or incidents that would indicate any unreliability or previous breaches of trust between the indi- vidual and his employer); endorsements or references from previous employers, teachers, or colleagues that would support *adecision for granting access or that would attest to the trustworthiness and reliability of the individual;
If a lock is used that is not designed to be resistant to surreptitious and forced entry, the watchman also inspects a tamper-indicating seal to verify that the container has*not been tampered with.
and consideration of the individual's present employment record indicating demonstrated trustworthiness and reliability over an extended period of
                                        17


employment with the licensee.      (This may be considered in the nature of
During periods when a nonpower reactor is left unattended, a watchman comes around every 2 h6urs and checks that none of the fuel elements
"grandfathering.")
5.59-10
Content Describe the procedures and criteria that will be used for obtaining sufficient information prior to making a decision on granting unescorted access authorization to an individual to CAAs where the material is used or stored. Identify the types of individuals who will be screened (e.g., pro- cess engineers, supervisory personnel, professors, instructors, graduate students) and who will perform the screening process.


3.2  Badging System [73.67(d)(5)]
have been removed by unauthorized persons.
Intent The purpose of the badging system is to facilitate the identification of authorized individuals and the control of access to or within the CAA
where the material is used or stored. Information on the badge should be such that it is possible to clearly distinguish personnel authorized for access to the CAAs from those requiring an escort. Information on the badge should also uniquely identify the individual possessing the badge. This personalized information can be obtained through the use of photographs, personal vital statistics, signatures, or any means the licensee may wish to use that will uniquely identify the individual.


Content Describe the badging system used to facilitate control of access to the CAAs. This description should include:
If a person working during off-hours in the vicinity of the nonpower reactor is encountered, appropriate identification is requested.
      1.  The size, shape,  color, material,  and construction of badges.


2.  The distinguishing features of the badge that identify authorized individuals from escorted individuals.
*
While a nonpower reactor is being used, the supervisor ensures that he/she or his/her designee is not away from the reactor for a period longer than 30 minutes or a period he/she estimates would be minimally required for a person to obtain fuel elements in the core that are not self-protecting by virtue of their having been sufficiently irradiated.


3. How the badges will be used for controlling access. (For example, will all individuals be checked prior to entering the CAAs, will periodic checks be made of individuals within a CAA to determine if they are author- ized or under escort, or will the badge itself permit authorized entrance, e.g., a card key.)
*
      4.  The system used for issuing, controlling, and accounting for the badges.
During periods when excess fuel is left unattended-in a. storage closet at a nonpower reactor facility, an alarm system is activated that would annunciate if anybody tried to penetrate the closet without proper authorization.


3.3  Lock System [73.67(d)(5)]
During periods when the material is being used under the direct supervi sion of authorized personnel, the monitoring requirement may be satisfied by virtue of the continuous surveillance exercised by such personnel.
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 that fit this description are three-position dial-type combination 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 ensure that only authorized personnel have access
                                        18


to such items.    Locks and combinations should be changed when information is obtained that the lock system may have been compromised. Further informa- tion may be obtained in Regulatory Guide 5.12, "General Use of Locks in the Protection and Control of Facilities and Special Nuclear Material."
Content For each of the CAAs designated for the protection of SM4 of moderate strategic significance, provide the following information regarding the meas ures taken to fulfill the monitoring requirement of paragraph 73.67(d)(3):  
Content Describe the locking system used to control access to the CAAs where material is used and stored. This description should include locations of all locks included 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 combinations and changing combinations or locks, criteria for changing combinations or locks, personnel authorized to be given keys or combinations, and descriptions of types of locks used (references may be made to Regulatory Guide 5.12 for this purpose).
1.
                  3.4  Personnel Entry Control System [73.67(d)(6)]
Intent The success of other access control system components, such as preauthori- zation screening, badging, and lock control, is dependent upon effective control of personnel access into the CAA. Physical access may be controlled in a number of different ways depending upon the actual configuration of the CAA and other site specific factors. Some examples of these alternatives are:
      1.  Control by Authorized Person.    If the area to be controlled is sufficiently small and free of obstructions, an authorized person performing other activities in a CAA may effect physical access control by monitoring entry of unauthorized persons into the area. A sign posted at the entrance would help deter casual passersby. A typical application of this approach would be the case of a laboratory instructor conducting a class in which he is familiar with each of his students and could easily recognize unauthorized persons not in the class.


2.  Card-Key, Cipher, Combination, or Key-Lock Control System. A more sophisticated hardware-oriented system involves the use of a card-key, cipher, combination, or key-lock system. Physical access control *inthis case consists of the use of physical barriers to deter unauthorized persons. A limited number of entrances that are controlled by authorized personnel using a card key, cipher, combination, or key are provided. This system may be more useful when larger numbers of authorized personnel who would not necessarily be familiar with one another need to share the use of the CAA.
Describe any devices employed by specifying the type of device, its installed location, the type and location of annunciation, the intended area of coverage, and-the tamper-resistant features.


3.  Control by Security Organization.    If security organization personnel are available, physical access control may be accomplished by stationing a person at the entrance to the CAA to check identification and allow only authorized persons into the CAA.      This alternative may be unjustifiably expensive unless the security organization member's salary can be justified on other grounds as well.    A variation of this system requires persons seeking entrance to the CAA to obtain a key from a properly designated person or security organization for each use.
Refer, if desired, to existing filed security plans, regulatory guides, or NUREG documents.


19
2.


Content Describe the system for limiting physical access to each CAA identified in Sections 1.1 and 1.2 of Part I to 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 granting authorizations, and the procedures used to ensure that only author- ized or properly escorted persons are allowed access to the CAA. Reference can be made to Sections 3.1, 3.2, 3.3, 3.5, and 3.6 of this chapter as they apply to this section for the description of locks, barriers, or other hardware that are used to control access.
Describe any procedures employed to monitor the CAA or portions thereof, including the categories of persons who will execute the procedures, the frequency of inspections or rounds of patrol, the basis for the determina tion of such frequencies, and the occasions when the procedures are intended to be implemented.


3.5   Escort System [73.67(d)(7)]
Also indicate the features of the CAA (e.g., barriers, locks, seals) that will affect the way the procedures are used.
Intent The requirement that an escort system be established is in recognition of the fact that the licensee may wish to allow access to certain persons or classes of persons on a temporary or infrequent basis or on short notice, thus making the routine process for granting access authorizations impractical or inexpedient. Typical arrangements for escorted access may include escorts for maintenance or repair personnel, laboratory classes, public tours, guests, and visitors as required.
 
3.
 
Explain how the combination of procedures and devices used to monitor each CAA meets the criteria for early detection of theft by an external adversary relative to the type of material found in each CAA.
 
5.59-11
 
3.
 
ACCESS CONTROL AT A FIXED SITE
This chapter provides guidance on meeting the requirements of paragraphs
73.67(d)(4), (d)(5), (d)(6), (d)(7), and (d)(1O), which are as follows:
(d)(4)
Conduct screening prior to granting an individual unelcorted access to the controlled access area where the material is used or stored, in order to obtain information on which to base a decision to permit such access, (d)(5)
Develop and maintain a controlled badging and lock system to identify and limit access to the controlled access areas to authorized Individuals, (d)(6)
Limit access to the controlled access areas to authorized or escorted individuals who require such access in order to perform their duties, (d)(7)
Assure that all visitors to the controlled access areas are under the constant escort of an individual who has been authorized acceig to the area, (d)(1O)
Search on a random basis vehicles and packages leaving the controlled access areas.
 
An. access control system is one that controls access to or egress from a CAA through normal routes for personnel, materials, or vehicles.
 
3.1 Preauthorization Screening [73.67(d)(4)]
Intent The Intent of the requirement for preauthorization screening is to ensure that the licensee will have sufficient knowledge of an individual to determine his/her reliability and need for access prior to. granting him/her authorized access to the CAA where the material is used or stored.
 
The selection of procedures for conducting this examination and the criteria employed to make these judgments are the responsibility of the licensee and, of course, should be consistent with all local, State, and Federal laws and regulations regarding the protection of the privacy and other rights of the individual.
 
The screening process may be conducted in the same manner as other investigations customarily conducted by potential employers for similarly sensitive positions.
 
There is no requirement for the licensee to arrange for an NRC clearance or similar clearance from any other government organization.
 
Examples of procedures and criteria that may be employed in the screening process .include holding or having recently held a government-sanctioned clearance; examination of past employment or educational records (to determine any unsatisfactory employment or school actions or incidents that would indicate any unreliability or previous breaches of trust between the individual and his/her employer);
endorsements or references from previous employers, teachers, or colleagues that would support a decision for granting access or that would attest to the trustworthiness and reliability of the individual; and consideration of the individual's present employment record indicating demonstrated trustworthiness
5.59-12
 
and reliability over an extended period of employment with the licensee.
 
(This may be considered in the nature of "grandfathering.")
Content Describe the procedures and criteria that will be used for obtaining sufficient information prior to making a decision on granting unescorted access authorization to an individual to CAAs where the material is used or stored.
 
Identify the types of individuals who will be screened (e*.g.,
process engineers, supervisory personnel, professors, instructors, graduate students)
and who will perform the screening process.
 
3.2 Badging System [73.67(d)(5)]
Intent The purpose of the badging system is to facilitate the identification of authorized individuals and the control of access to or within the CAA where the material is used or stored.
 
Information on the badge should be such that it is possible to clearly distinguish personnel authorized for access to the CAAs from those requiring an escort.
 
Information on the badge should also uniquely identify the individualpossessing the badge.
 
This personalized information can be obtained through the use of photographs, personal vital statistics, signatures, or any means the licensee may wish to use that will uniquely identify the Individual.
 
Content Describe the badging system used to facilitate control of access to the CAAs.
 
This description should include:
1.
 
The size, shape, color, material, and construction of badges.
 
2.
 
The'distinguishing features of the badge that identify authorized individuals from escorted individuals.
 
3.
 
How the badges will be used for controlling access.
 
(For example, will all individuals be checked prior to entering the CAAs, will periodic "
checks be made of individuals within a CAA to determine if they are authorized or underescort, or will the badge itself permit authorized entrance, e.g., a card key'.)
4.
 
The system used for issuing, controlling, and accounting for the badges.
 
3.3 Lock System
[73.67(d)(5)]
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 that fit this description are three-position dial-type combination 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
5.59-13
 
be designed to ensure that only authorized personnel have access to such items.
 
Locks and combinations should be changed when information is obtained that the lock system may have been compromised.
 
Further information may be obtained in Regulatory Guide 5.12, "General Use of Locks in the Protection and Control of Facilities and Special Nuclear Materials."
Content Describe the locking system used to control access to the CAAs where material is used and stored.
 
This description should include locations of all locks included 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 combinations and changing combinations or locks, criteria for changing combinations or locks, personnel authorized to be given keys or combinations, and descriptions of types of locks used (references may be made to Regulatory Guide 5.12 for this purpose). 
3.4 Personnel Entry Control System [73.67(d)(6)]
Intent The success of other access control system components such as preauthori zation screening, badging, and lock control is dependent upon effective control of personnel access into the CAA.
 
Physical access may be controlled in a number of different ways depending on the actual configuration of the CAA and other site-specific factors.
 
Some examples of these alternatives are:
1.
 
Control by Authorized Person.
 
If the area to be controlled is sufficiently small and free of obstructions, an authorized person performing other activities in a CAA may effect physical access control by monitoring entry of unauthorized persons into the area.
 
A sign posted at the entrance would help deter casual passersby.
 
An example of this approach would be when laboratory instructors are conducting classes and, because they are familiar with each of their students, they could easily recognize unauthorized persons not belonging in the classes.
 
2, Card-Key, Cipher, Combination, or Key-Lock Control System.
 
A more sophisticated hardware-oriented system involves the use of a card-key, cipher, combination, or key-lock system.
 
Physical access control in this case consists of the use of physical barriers to deter unauthorized persons.
 
A limited number of entrances that are controlled by authorized personnel using a card, key, cipher, combination, or key are provided.
 
This system may be more useful when larger numbers of authorized personnel who would not necessarily be familiar with one another need to share the use of the CAA.'
3.
 
Control b Security Organization.
 
If security organization personnel are availablephysical access control may be accomplished by stationing a person at the entrance to the CAA to check Identification and allow only authorized persons into the CAA.
 
This alternative may be unjustifiably expensive unless the security organization member's salary can be justified on other grounds as well.
 
A variation of this-system requires persons seeking entrance to the CAA to obtain a key from a properly designated person or security organization for each use..
5.59-14
 
Content Describe the system for limiting physical access to each CAA identified in Sections 1.1 and 1.2:of Part I to 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 granting authorizations, and the procedures used to ensure that only authorized or.
 
properly escortedpersons are allowed access to the CAA.
 
Reference may~be made to Sections 3.1, 3.2, 3.3, 3.5, and 3.6 of this chapter as they apply to this section for the description of locks, barriers, or other hardware that are used to control access.
 
3.5 Escort System [73.67(d)(7)]  
Intent The requirement that an escort system be established is in recognition of the fact that the licensee may wish to allow access to certain persons or classes of persons on a temporary or infrequent basis or on short notice, thus making the routine process for granting access authorizations impractical or inexpedient.
 
Typical arrangements for escorted access may include escorts for maintenance or repair personnel, laboratory classes, public tours, guests, and visitors as required.


Content Describe the system that will be used to escort individuals in the CAAs.
Content Describe the system that will be used to escort individuals in the CAAs.


In his security plan, the licensee should ensure that only properly authorized individuals will be allowed to escort individuals. This description should include:
In its security plan, the licensee should ensure that only properly authorized individuals will be allowed to escort individuals.
      1.  Criteria to be used for granting escorted access,
      2.  Criteria to be used for escorting others,
      3.  Procedures for escorting individuals into CAAs (e.g.,    students under supervision of lab instructor, public tours),
      4.  The number of escorted individuals per escort, and
      5.  The responsibilities of the escort (e.g. , periodic surveillance of all individuals under escort, accounting for all material prior to leaving the CAA, remaining in general area during the time unauthorized individuals are present).
                            3.6  Search [73.67(d)(10)]
Intent The primary intent of the search requirement is to deter and possibly detect attempted thefts of SNM. The search procedures developed by the licensee should take into consideration the environs where the material is used or stored, the physical characteristics of the material itself, and the frequency of accounting for the material.      In some cases, this will
                                      20


require that all vehicles and packages leaving the CAAs be searched in a random manner. The frequency of random searches should be determined by the ease with which the material can be stolen and.the length of time it would take to detect a theft. In other cases, only packages that equal or exceed the size of the material being used or stored would have to be searched, taking into consideration the difficulty with which the material could be broken into smaller more easily concealed parts.
This description should include:
1.


Content Describe the system to be used for randomly searching vehicles or packages that leave the CAA.  Include in the description information as to:
Criteria to be used for granting escorted access,  
    1. The scope of the search. This should identify the criteria that will be used for searching vehicles and packages (e.g., whether all packages and vehicles are subject to search or just those packages or vehicles that are larger than the smallest configuration of material being used or stored).
2.
    2.   The randomness of the search. The scheme for selecting the packages or vehicles to be searched should be identified (e.g., subjecting each package or vehicle to a search, using a random number generator for determining whether a candidate package or vehicle is to be searched, searching a minimum percentage of all packages or vehicles leaving the CAA each day).
                                      21


4. SECURITY ORGANIZATION AT A FIXED SITE
Criteria to be used for escorting others,  
      This chapter provides guidance on meeting the requirements of paragraph
3.
73.67(d)(8), which states:
(d)(8)    Establish a security organization or modify the current security organization to consist of at least one watchman* per shift able to assess and respond to any unauthorized penetrations or activ- ities in the controlled access areas.


Intent The intent of this requirement is to ensure that, in the event of a security incident, someone will be available to assess alarms or other unauthorized penetrations or activities and, if warranted, notify the NRC,
Procedures for escorting individuals into CAAs (e.g., students under the supervision of laboratory instructor, public tours),  
the local law enforcement authorities, and the responsible person in licensee management.    Early detection and notification of any missing material will help facilitate its prompt recovery. In some cases, the licensee may assign additional duties to members of the security organization where procedure- oriented options are chosen to satisfy physical protection requirements (e.g.,
4.
periodic patrols and inspections of CAAs for storage of SNM).    Security organ- ization members are not required to be fully dedicated full-time employees of the licensee. They may include unarmed campus security personnel (watchmen),
contract guards, members of the local law enforcement agency (if sufficiently close to the site), etc.    No formal or comprehensive training program is required for security organization personnel.    However, the licensee should be prepared to demonstrate that each security person understands the particular duties assigned to him and is fully qualified and trained to perform them.


Content Describe the security organization that will be responsible for assessing and responding to security incidents. Indicate the other responsibilities of the security organization such as:
The number of escorted Individuals per escort, and  
      1.  Conducting periodic physical security checks of CAAs,
5.
      2.  Maintaining liaison with the local law enforcement agency,
      3.  Notifying the local law enforcement agency of any unauthorized penetrations or activities in the CAAs, and
      4.  Notifying licensee management of any unauthorized penetrations or activities in the CAAs.


A "watchman" is defined in paragraph 73.2(d) of 10 CFR Part 73 as "an indi- vidual, not necessarily uniformed or armed with a firearm, who provides protec- tion for a plant and the special nuclear material therein in the course of performing other duties."'
The responsibilities of the escort (e.g., periodic surveillance of all individuals under escort, accounting for all material prior to leaving the CAA, remaining in general area during the time unauthorized individuals are present).. 
                                      22
3.6 Search [73.67(d)(10)]
Intent The primary intent of the search requirement is to deter and possibly detect attempted thefts of SNM.


5.  COMMUNICATIONS AT A FIXED SITE
The search procedures developed by the licensee should take into consideration the environs where the material is used
    This chapter provides guidance on meeting the requirements of paragraph
5.59-15
73.67(d)(9), which states:
(d)(9)    Provide a communication capability between the security organiza- tion and appropriate response force.


Intent The intent of this regulation is to ensure that a communication capabil- ity exists between the licensee and the designated response force. It is implied that, prior to setting up a communication capability, procedures and responsibilities will have been established between the response force and the licensee. (See Chapter 6, "Response Procedures," of Part 1.) The type of communication system chosen by a licensee should:
or stored, the physical characteristics of the material itself, and the frequency of accounting for the material.
      1.  Provide for full duplex voice communication capability,
      2.  Be easily accessible to the licensee's security organization, and
      3.  Be reliable and available for immediate use at any time.


Some communication systems that would provide these capabilities are a dedicated telephone system, a non-dedicated public telephone system, radio, or any combination thereof.
In some cases, this will require that all vehicles and packages leaving the CAAs be searched in a random manner.


Content
The frequency of random searches should be determined by the ease with which the material can be stolen and the length of time it would take to detect a theft.
                                                                  /
      Describe the communication system that is used between the security organization and the appropriate response force. This description should include information on:
      1.  Type of communication system,
      2.  Location of voice terminals in relationship to CAAs,
      3.  Availability of communication system on a 24-hour basis,    and
      4.  Reliability of communication system.


23
In other cases, only packages that equal or exceed the size of the material being used or stored would have to be searched, taking into consideration the difficulty with which the material could be broken into smaller, more easily concealed parts.


6. RESPONSE PROCEDURES AT A FIXED SITE
Content Describe the system to be used for randomly searching vehicles or packages that leave the CAA.
      This chapter provides guidance on meeting the requirements of paragraph
70.67(d)(11), which states:
(d)(11)    Establish and maintain response procedures for dealing with threats of thefts or thefts of such materials.


Intent The intent of this regulation is to help the licensee to identify those security incidents that could result in the loss of SNM of moderate strategic significance and to develop response procedures to prevent or reduce the likelihood of such a loss. Some types of incidents that should be considered and for which response procedures should be developed are:
Include in the description information as to:
      1.   Situations that could possibly lead to theft of SNM (e.g., civil strife),
1.
      2.   Discovery that the security system has been breached, and
 
      3.   Discovery that some SNM is missing.
The scope of the search.
 
This should identify the criteria that will be used for searching vehicles and packages (e.g., whether all packages and vehicles are subject to search or just those packages or vehicles that are larger than the smallest configuration of material being used or stored). 
2.
 
The randomness of the search.
 
The scheme for selecting the packages or vehicles to be searched should be identified (e.g., subjecting each package or vehicle to a search, using a random number generator for determining whether a candidate package or vehicle is to be searched, searching a minimum percentage of all packages or vehicles.l.eaving the CAA each day).
5.59-16
 
4.
 
SECURITY ORGANIZATION AT A FIXED SITE
This chapter provides guidance on meeting the requirements of paragraph
73.67(d)(8), which states:
(d)(8)
Establish a security organization or modify the current security organization to consist of at least one watchman* per shift able to assess and respond to any unauthorized penetrations or activities in the controlled access areas.
 
Intent The intent of this requirement is to ensure that, in the event of a security incident, someone will be available to assess alarms or other 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 any missing material will help facilitate its prompt recovery.
 
In some cases, the licensee may assign additional duties to members of the security organization where procedure oriented options are chosen to satisfy physical protection requirements (e.g.,
periodic patrols and inspections of CAAs for storage of SNM).
Security organ ization members are not required to be fully dedicated full-time employees of the licensee.
 
They may include unarmed campus security personnel (watchmen),
contract guards, members of the local law enforcement agency (if sufficiently close to the site), etc.
 
No formal or comprehensive training program is required for security organization personnel.
 
However, the licensee should be prepared to demonstrate that each security person understands the particular duties assigned to him/her and is fully qualified and trained to perform them.
 
Content Describe the security organization-that will be responsible for. assessing and responding to security incidents.
 
Indicate the other responsibilities of the security organization such as:
1.
 
Conducting periodic physical security checks of CAAs,
2.
 
Maintaining liaison with the local law enforcement agency,
3.
 
Notifying the local law enforcement agency bf any unauthorized penetrations or activities in the CAAs,, and
4.
 
Notifying licensee management of any unauthorized penetrations or activities in the CAAs.
 
A "watchman" is defined in paragraph 73.2(d) of 10 CFR Part 73 as "an indi vidual, not necessarily uniformed or armed with a firearm, who provides protec tion for a plant and the special nuclear material therein in the course of performing other duties."
5.59-17
 
5.
 
COMMUNICATIONS AT A FIXED SITE
This chapter provides guidance on meeting the requirements of paragraph
73.67(d)(9), which states:
(d)(9)
Provide a communication capability between the security organization and appropriate response force.
 
Intent The intent of this regulation is to ensure that a communication capability exists between the licensee and the designated response force.
 
It is implied that, prior to setting up a communication capability, procedures and responsibilities will have been established between the response force and the licensee.
 
(See Chapter 6, "Response Procedures at a Fixed Site," of Part I.)
The type of communication system chosen by a licensee should:
1.
 
Provide for full duplex voice communication capability,
2.
 
Be easily accessible to the licensee's security organization, and
3.
 
Be reliable and available for immediate use at any time.
 
Some communication systems that would provide these capabilities Include a dedicated telephone system, a nondedicated public telephone system, radio, or any combination thereof.
 
Content Describe the communication system that is used between the security organization and the appropriatd response force.
 
This description shoulNd include information on:
1.
 
Type of communication system,
2.
 
Location of voice terminals in relationship to CAAs,
3.
 
Availability of communication system on a 24-hour basis, and
4.
 
Reliability of communication system.
 
5.59-18
 
6.
 
RESPONSE PROCEDURES AT A FIXED SITE
This chapter provides guidance on meeting the requirements of paragraph
73.67(d)(11), which states:
(d)(11)
Establish and maintain response procedures for dealing with threats of thefts or thefts of such materials.
 
Intent The intent of this regulation is to help the licensee to identify those security Incidents that could result in the loss of SNM of moderate strategic significance and to develop response procedures to prevent or reduce the likelihood of such a loss.
 
Some types of incidents that should be considered and for which response procedures should be developed are:  
1.
 
Situations that could possibly lead to theft of SNM (e.g., civil strife),  
2.
 
Discovery that the security system has been breached, and  
3.
 
Discovery that some SM is missing.


Content Identify those events for which response procedures will be developed.
Content Identify those events for which response procedures will be developed.


Also, describe the type of response to be accomplished for each event identi- fied and the duties and responsibilities of the security organization and management involved in the response. Ensure 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 capabil- ities, and any agreements made with them to respond in the case of theft of the material.
Also, describe the type of response to be accomplished for each event identi fied and the duties and responsibilities of the security organization and management involved in the response.


24
Ensure that the NRC will be notified immediately in the event of theft or attempted theft of the material.


7.  MATERIAL TRANSPORTATION REQUIREMENTS
Describe what local law enforcement assistance is available, their response capabil ities, and any agreements made with them to respond in the case of theft of the material.
      This chapter provides guidance on meeting the requirements of paragraph
73.67(e)(1), which are as follows:
(e)(1)    Each licensee who transports, exports, or delivers to a carrier for transport special nuclear material of moderate strategic signif- icance shall:
          (i)  Provide advance notification to the receiver of any planned shipments specifying 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 commence- ment of the planned shipment that the receiver will be ready to accept the shipment at the planned time and location and 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 ship- ment, and (v)  Arrange for the in-transit physical protection of the material in accordance with the requirements of paragraph 73.67(e)(3)
                of this part unless the receiver is a licensee and has agreed in writing to arrange for the in-transit physical protection.


7.1  Advance Notification [73.67(e)(1)(i)]
5.59-19
Intent The intent of this paragraph is to require the shipper to preplan the transportation of material and inform the receiver of his plans prior to shipment. This is the first of the several transportation requirements that will allow the receiver to take delivery of the material as planned or to help ensure traceability of any missing material.


Content The licensee should ensure in his security plan that, prior to each shipment of material, the receiver will be notified of the impending shipment and provided the following types of information:
7.
      1.   Mode of transport (e.g.,  truck, plane, train, or ship),
      2.  Estimated time of arrival,
      3.  Location where material is to be transferred to receiver,
      4.,  Name of carrier, and
                                        25


5.    Transport identification (e.g.,  truck, train, or flight number;
MATERIAL TRANSPORTATION REQUIREMENTS
            ship name).
This chapter provides guidance on meeting the requirements of paragraph
                  7.2  Receiver Confirmation [73.67(e)(1)(ii)]
73.67(e)(1),-which are as follows:
Intent, The intent of this requirement is 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 has acknowledged the mode of transport.
(e)(1)  
Each licensee who transports, exports, or delivers to a carrier for transport special nuclear material of moderate strategic significance shall:
(i) Provide advance notification to the receiver of any planned shipments specifying 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 commencement of the planned shipment that the receiver will be ready to accept the shipment at the planned time and location and acknowledges the specified mode of transport, (iii)
Check the integrity of the container and locks or seals prior to shipment, and (iv)
Arrange for the in-transit physical protection of the material in accordance with the requirements of paragraph 73.67(e)(3) of this part unless the receiver is a licensee and has agreed in writing to arrange for the in-transit physical protection.


Content Describe what procedures will be used to ensure that shipment of mate- rial does not take place until the receiver acknowledges the planned shipment and mode of transport and states that he will be ready to accept the shipment at the planned time and location.
7.1 Advance Notification to Receiver [73.67(e)(11(1)]
Intent The intent of this paragraph is to require the shipper to preplan the transportation of material and inform the receiver of his plans prior to shipment.


7.3  Container [73.67(e)(1)(iii)]
This is the first of the several transportation requirements that will allow the receiver to take delivery of the material as planned or to help ensure traceability of any missing material.
Intent The intent of this requirement is to provide a mechanism or system that will help the receiver detect any tampering with the material's container that may have occurred during shipment. Regulatory Guide 5.15, "Security Seals for the Protection and Control of Special Nuclear Material," provides guidance in this area. Requirements for containers are contained in 10 CFR
Part 71, and a summary report on approved containers is contained in NUREG-0383.*
If the material is shipped in an exclusive-use carrier, it is acceptable to seal the carrier itself rather than each individual SNM container.


Content Describe the types of seals that will be used to monitor the material's container during transport.
Content The licensee should ensure in his security plan that, prior to each shipment of material, the receiver will be notified of the impending shipment and provided the following types of information:
1.


7.4  Inspection [73.67(e)(1)(iv)]
Mode of transport (e.g., truck, plane, train, or ship),  
Intent The intent of this paragraph is to require the shipper to check the integrity of the material container's seals just prior to shipment so that he can be assured that they have not been compromised. Then, upon receipt of the shipment, if the receiver discovers that the container's integrity has been compromised and the material is missing, the scope of the recovery operation can focus on the transportation route.
2.


Content Describe the procedures to be used to ensure that the integrity of the containers or seals is checked just prior to shipment.
Estimated time of arrival,
3.


Copies of NUREG-0383, "Directory of Certificates of Compliance for Radio- active Materials Packages," may be obtained from the National Technical Information Service, Springfield, Virginia 22161.
Location where custody of the material will be transferred to the receiver,  
4.


26
Name of carrier, and
5.59-20


7.5   Responsibility for In-Transit Physical Protection [73.67(a)(1)(v)]
5.
Intent The intent of this paragraph is to make clear that the licensee shipping the material is responsible for arranging for the physical protection of the material in transit if the receiver is not a licensee. If both the shipper and receiver are licensees, the shipper may allow the receiver to accept this responsibility wholly or in part, provided there is appropriate documen- tation specifying their respective responsibilities. Where no such documenta- tion exists, both the shipper and receiver are held jointly responsible.


(See Section 8.3 in the next chapter.)
Transport identification (e.g., truck, train, or flight number; ship name). 
Content In his security plan, the shipper should either acknowledge responsibil- ity for the in-transit physical protection of SNM of moderate strategic signif- icance or ensure that a written agreement from the receiver licensee has been received in which the receiver accepts either full responsibility or shared responsibility for the in-transit physical protection of this material in accordance with paragraph 73.67(e)(3) of 10 CFR Part 73.
7.2 Receiver Confirmation [73.67(e)(1)(ii)]
Intent The intent of this requirement is 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 has acknowledged the mode of transport.


27
Content Describe what procedures will be used to ensure that shipment of material does not take place urt'il the receiver acknowledges the planned shipment and mode of transport and states that he will be ready to accept the shipment at the planned time and location.


8. RECEIVER REQUIREMENTS--TRANSPORTATION
7.3 Inspection [73.67(e)(1)(iil)]
    This chapter provides guidance on meeting the requirements of paragraph
Intent The intent of this paragraph is to provide a means for confirming the integrity of a shipment through inspections just prior to commencement and during the shipment by ensuring that the material containers and any associated locks or seals are intact at the time the shipment commences.
73.67(e)(2), which are as follows:
(e)(2)     Each licensee who receives special nuclear material of moderate strategic significance shall:
          (i)  Check the integrity of the containers and seals upon receipt of the shipment, (ii)  Notify the shipper of receipt of the material as required in Section 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 73.67(e)(3)
                of this part unless the shipper is a licensee and has agreed in writing to arrange for the in-transit physical protection.


8.1  Inspection [73.67(e)(2)(i)]
Content Describe the procedures to be used to ensure that the integrity of the shipment containers and associated locks or seals is checked just prior to shipment.
Intent This requirement is intended to determine whether the material's con- tainer has been compromised enroute and whether any material has been removed so that immediate recovery procedures can be initiated if required.


Content Describe the procedures to be used to ensure that the integrity of the containers and seals will be checked upon receipt of the shipment of material.
7.4 Responsibility for In-Transit Physical Protection Intent The intent of this paragraph is to make clear that the licensee shipping the materialtis responsible for arranging for the physical protection of the material in transit if the receiver is not a licensee.


8.2  Notification [73.67(e)(2)(ii)]
If both the shipper and receiver are licensees, the-shipper may allow the receiver to accept this responsibility wholly or in part, provided there is appropriate documentation specifying their respective responsibilities.
Intent This requirement is intended to:
      1.  Ensure that knowledge of the current location of all SNM is avail- able, and
      2.  Formally inform the shipper that the material has been received.


Content Ensure that a completed copy of standard-lorm NRC-741, "Nuclear Material Transaction Report," will be sent to the shipper within 10 days of receiving a shipment of material as required in §70.54 of 10 CFR Part 70.
Where no such documentation exists, both the shipper and receiver are held jointly responsible.


28'
(See Section gi3 of Part I of this guide.)
Content In its security plan, the shipper should either acknowledge responsibility for the in-transit physical protection of SNM of moderate strategic signif icance or ensure that a written agreement from the receiver licensee has been received in which the receiver accepts either full-responsibility or shared responsibility for the in-transit physical protection of this material in accordance with paragraph 73.67(e)(3) of 10 CFR Part 73.


8.3    Responsibility for In-Transit Physical Protection [73.67(e)(2)(iii)]
5.59-21
Intent The intent of this paragraph is to make clear that the licensee receiv- ing the material is responsible for arranging for the physical protection of the material in transit if the shipper is not a licensee. If both the shipper and receiver are licensees, the receiver may allow the shipper to accept this responsibility either wholly or in part provided there is appro- priate documentation specifying their respective responsibilities. Where no such documentation exists, both the shipper and receiver are held jointly responsible.  (See Section 7.5 in the preceding chapter.)
Content In his security plan, the receiver should either acknowledge responsibil- ity for the in-transit physical protection of SNM of moderate strategic signif- icance or ensure that a written agreement from the shipper has been received in which the shipper accepts either full responsibility or shared responsibility for the in-transit physical protection of this material in accordance with paragraph 73.67(e)(3) of 10 CFR Part 73.


29
8.


9.  IN-TRANSIT PHYSICAL PROTECTION REQUIREMENTS
RECEIVER REQUIREMENTS--TRANSPORTATION
      This chapter provides guidance on meeting the requirements of paragraph
This chapter provides guidance on meeting the requirements of paragraph  
73.67(e)(3), which are as follows:
73.67(e)(2), which are as follows:  
(e)(3)       Each licensee, either shipper or receiver, who arranges for the physical protection of special nuclear material of moderate strategic significance while in transit or who takes delivery of such material free on board (f.o.b.) the point at which it is delivered to a carrier for transport shall:
(e)(2)  
            (i) Arrange for a telephone or radio communications capability, for notification of any delays in the scheduled shipment, between the carrier and the shipper or receiver, (ii)   Minimize the time that the material is in transit by reducing the number and duration of nuclear material transfers and by routing the material in *the most safe and direct manner, (iii)    Conduct screening of all licensee employees involved in the transportation of the material in order to obtain information on which to base a decision to permit them control over the material, (iv)  Establish and maintain response procedures for dealing with threats of thefts or thefts of such material, (v)  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 time of arrival at its destination, and (vi)  Conduct immediately a trace investigation of any shipment that is lost or unaccounted for after the estimated arrival time and report to the Nuclear Regulatory Commission as specified in §73.71 and to the shipper or receiver as appro- priate. The licensee who made the physical protection arrange- ments shall also immediately notify the Director of the appro- priate Nuclear Regulatory Commission Inspection and Enforcement Regional Office listed in Appendix A of the action being taken to trace the shipment.
Each licensee who receives special nuclear material of moderate strategic significance shall:  
(i) Check the integrity of the containers and seals upon receipt of the shipment, (ii) Notify the shipper of receipt of the material as required in Section 70.54 of Part 70 of this chapter, and.


It is not the intent of these paragraphs to require that the responsible licensee for shipping SNM of moderate strategic significance ship the material under armed escort or in a specially designed carrier.
(iii) Arrange for the in-transit physical protection of the material in accordance with the requirements of paragraph 73.67(e)(3) of this part unless the shipper is a licensee and has agreed in writing to arrange for the in-transit physical protection.


9.1 Communications [73.67(e)(3)(i)]
8.1 Inspection [73.67(e)(2)(i)]  
Intent The primary intent Df this requirement is to ensure that the carrier will notify the shipper or receiver of any changes in plans or delays in the scheduled arrival of a shipment to its destination due to mechanical breakdown, adverse environmental conditions, public disorders, et
Intent This requirement is intended to determine whether the material's container has been compromised en route and whether any material has been removed so that immediate recovery procedures may be initiated if required.


====c.   The====
Content Describe the procedures to be used to ensure that the integrity of the.
                                        30


shipper or receiver can then decide whether or not to initiate response pro- cedures.  It is not the intent of this regulation to require periodic check-in.
containers and seals will be checked upon receipt of the shipment of material.


Public telephone or full duplex voice radio are acceptable methods for meeting the intent of this requirement.
8.2 Notification to Shipper [73.67(e)(2)(ii)]
Intent This requirement is intended to provide the shipper with knowledge of when responsibility for the shipment has been assumed by the receiver and when the shipper's responsibility is ended.


Content Describe the type of communication system and procedures to be used by the carrier of SNM of moderate strategic significance for notifying the shipper or receiver of any change in plans or delays in arrival.
Content Ensure that the receiver will send a completed copy of standard Form NRC-741, "Nuclear Material Transaction Report," to the shipper within 10 days of receiving a shipment of material as required in § 70.54 of 10 CFR Part 70.


9.2  Minimum Transit Times [73.67(e)(3)(ii)]
8.3 Responsibiltl for In-Transit Physical Protection
Intent This requirement is intended to have the shipper or receiver make a reasonable effort to ship the material by the fastest and most direct method possible. It is not intended to require exclusive-use carriers or expensive modes of travel.
[73.57(e)(2)(Mt)],
Intent The intent of this paragraph is to make clear that the licensee receiving the material is responsible for arranging for the physical protection of the
5.59-22


Content Describe the procedures and considerations that apply in the transporta- tion planning process to ensure that a determined effort will be made to minimize transit times.
material in transit if the shipper is not a licensee.


9.3  Preauthorization Screening [73.67(e)(3)(iii)]
If both the shipper and receiver are licensees, the receiver may allow the shipper to accept this responsibility either wholly or in part provided there is appropriate documentation specifying their respective responsibilities.
Intent The intent of the requirement for preauthorization screening is to ensure that the licensee will have sufficient knowledge of an individual to determine his reliability and need for access prior to granting him authorized access to the material in transit. The selection of procedures for conducting this examination and the criteria he employs to make his judgements are the respon- sibility of the licensee and, of course, should be consistent with all local, State, and Federal laws and regulations regarding the protection of the privacy and other rights of the individual. The screening process may be conducted in the same manner as are other investigations customarily conducted by poten- tial employers for similarly sensitive positions. There is no requirement for the licensee to arrange for an NRC clearance or similar clearance from any other government organization.    Examples of procedures and criteria that may be employed in the screening process include holding or having recently held a government-sanctioned clearance; examination of past employment records (to determine any unsatisfactory employment or incidents that would indicate any unreliability or previous breaches of trust between the individual and his employer); endorsements or references from previous employers or colleagues that would support a decision for granting access or that would attest to the trustworthiness and reliability of the individual; and consideration of the individual's present employment record indicating demonstrated trust- worthiness and reliability over an extended period of employment with the licensee.  (This may be considered in the nature of "grandfathering.")
                                        31


Content Describe the procedures that will be used for obtaining sufficient information prior to making a decision on granting unescorted access authoriza- tion to those licensee employees who will be directly involved in the transporta- tion or in the planning and movement control of the material.    Identify by title or name those employees who will be screened and those who will perform the screening process.
Where no such documentation exists, both the shipper and receiver are held jointly responsible.


9.4  Response Procedures [73.67(e)(3)(iv)]
(See Section 7.5 of Part lof this guide.)  
Intent The intent of this regulation is to help the licensee to identify those transportation incidents for Which he might expect to be notified and that might affect the security of the SNM in transit and to plan response procedures for such situations. For example, if the shipper is informed by the carrier that adverse weather conditions have temporarily prevented further progress of the shipment, the licensee should inform the receiver of a new estimated time of arrival.
Content In its security plan, the receiver should either acknowledge responsibil ity for the in-transit physical protection of SNM of moderate strategic signif icance or ensure that a written agreement from the shipper has been received in which the shipper accepts either full responsibility or shared responsibility for the in-transit physical protection of this material in accordance with paragraph 73.67(e)(3) of 10 CFR Part 73.


Content Identify those events for which response procedures will be developed.
5.59-23
 
9.
 
IN-TRANSIT PHYSICAL PROTECTION REQUIREMENTS
This chapter provides guidance on meeting the requirements of paragraph
73.67(e)(3), which are as follows:
(e)(3)
Each licensee who arranges for the in-transit physical protection of special nuclear material of moderate strategic significance or who takes delivery of this material free on board (f.o.b.) the pointtat which it is delivered to a carrier for transport shall:
(i)
Arrange for telephone or radio communications between the transport and the licensee or its designee:
(A) to periodically confirm the status of the shipment, (B) for notification of any delays in the scheduled shipment, and (C) to request appropriate local law enforcement agency response in the event of an emergency.
 
(ii)
Minimize the time that the material is in transit by reducing the number and duration of nuclear material transfers and by routing the material in the most safe and direct manner, (iii) Conduct screening of all licensee employees involved in the transportation of the material in order to obtain information on which to base a decision to permit them control over the material, (iv) Establish and maintain response procedures for dealing with threats of thefts or thefts of such material, (v)
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 time of arrival at its destination, (vi)
Initiate immediately a trace investigation of any shipment that is determined to be lost or unaccounted for after a reasonable time beyond the estimated arrival time.
 
(vii) Notify immediately the Director of the appropriate Nuclear Regulatory Commission Regional Office listed in Appendix A to this part of the action being taken to trace the shipment.
 
9.1 Communications [73.67(e)(3)(03I
Intent The primary intent of this requirement Is to ensure that procedures are established or facilities made available to permit communications to take place between the transport and the licensee or its designee for the purposes of
(1) periodically confirming the status of the shipment while it is in progress,
(2) notifying the licensee of delays along the shipment route that may affect the shipment's established schedule, and (3) requesting assistance from local
5.59-24
 
law enforcement authorities (LLEAs).
These communications need not be direct between the licensee and the transport.
 
1.
 
Confirmation of Shipment Status Communications for confirming the status of a shipment should be timed to reflect the expected changes in shipment status indicated by the shipment's scheduled itinerary.
 
For general motor freight (involving less-than-truckload quantities), direct communications between the transport and the licensee may be impractical.
 
This requirement may then be satisfied by periodically telephoning the carrier to obtain updated reports on the shipment's progress based on calls the carrier receives from drivers on a regular basis.
 
The frequency with which the licensee should check the status of a shipment should normally be at least every 10 to 14 hours.
 
This corresponds to the frequency with which the drivers normally would call in.
 
Similar indirect communications may be used to satisfy this requirement in the case of air shipments, but they should be more frequent to reflect the shorter air travel times between terminals.
 
When direct radio or telephone communications are practical between the licensee and the transport, the frequency of calls should normally be approximately every 12 hours.
 
2.
 
Notification of Shipment Delays Notifications to-the licensee should be made by the carrier or transport personnel whenever unforeseen conditions arise that threaten to delay the shipment significantly beyond the estimated arrival time at the next point on the shipment's itinerary.
 
This notification may be made by conventional telephone lines or by radio.
 
Installation ofradiotelephone lines or comparable equipment is not required.
 
These communications need not be direct between the transport. and the licensee or its designee.
 
The transport personnel may relay the information to the licensee through the carrier's offices.
 
3.
 
Requests for LLEA Assistance SProcedures or facilities are also required to facilitate the transport personnel in obtaining assistance from LLEAs.
 
Use of radiotelephone or citizens' band radio equipment for this-purpose is acceptable but not required.
 
The transport personnel may alternatively use conventional telephone lines.
 
Requests for assistance should be in accordancemwith the response procedures developed to comply with paragraph 73.67(e)(3)(iv). 
Content Describe the communications facilities and procedures to be used to ensure that communications are established to achieve the three purposes enumerated in paragraph 73.67(e)(3)(i).
The names and telephone numbers of responsible individuals should be given where appropriate.
 
Refer to established response procedures (Section 9.4 of Part I of this guide) as necessary.
 
5.59-25
 
9.2 Minimum Transit Times [73.67(e)(3)(ii)]
Intent This requirement is intended to have the shipper or receiver make a reasonable effort to ship the material by the fastest and most direct method possible.
 
It is not intended to require use of dedicated transports or other expensive modes of travel.
 
Content Describe the procedures and considerations that apply in the transporta tion planning process to ensure that a determined effort will be made to minimize transit times.
 
9.3 Preauthorization Screening [73.67(e)(3)(iii)]
Intent The intent of the requirement for preauthorization screening is to ensure that the licensee will have sufficient knowledge of an individual to determine his/her reliability and need for access prior to granting him/her authorized access to the material in transit.
 
The selection of procedures for conducting this examination and the criteria employed to make judgments are the responsibility of the licensee and, of course, should be consistent with all local, State, and Federal laws and regulations regarding the protection of the privacy and other rights of the individual.
 
The screening process may be conducted in the same manner as are other investigations customarily conducted by potential employers for similarly sensitive positions.
 
There is no requirement for the licensee to arrange for an. NRC clearance or similar clearance from any other government organization.
 
Examples of procedures and criteria that may be employed in the screening process include holding or having recently held a government-sanctioned clearance; examination of past employment records (to determine any unsatisfactory employment or incidents that would indicate any unreliability or previous breaches of trust between the individual and his/her employer); endorsements or references from previous employers or colleagues that would support a decision for granting access or that would attest to the trustworthiness and reliability, of the individual; and consideration of the individual's present employment record indicating demon strated-trustworthiness and reliability over an extended period of employment.
 
with the licensee.
 
(This may be considered in the nature of "grandfathering.")
Content Describe the procedures that will be used for obtaining sufficient information prior to making a decision on granting unescorted access authorization to those licensee employees who will be directly involved in the transportation or in the planning and movement control of the material.
 
Identify by title or name those employees who will be screened and those who will perform the screening process.
 
5.59-26
 
9.4 Response Procedures [73.67(e)(3)(iv)]
Intent The intent of this regulation is to help the licensee to identify those transportation incidents for which notification might be expected and that might affect the security of the SNM in transit and to plan response procedures for such situations.
 
For example, if the shipper is informed by the carrier that adverse weather conditions have 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 organization and management for dealing-with the response.


Also, describe types of response to be accomplished for each event identified and the duties and responsibilities of members of the security organization and management for dealing with the response. Ensure that the NRC will be notified immediately in the event of theft or attempted theft of the material.
Ensure that the NRC will be notified immediately in the event of theft or attempted theft of the material.


9.5 Notification [73.67(e)(3)(v)]
9.5 Notification [73.67(e)(3)(v))
Intent The intent of this requirement is to ensure that the licensee responsible for the physical protection of SNM in transit will have a firm basis for deciding whether or not to initiate response procedures in the event a shipment becomes overdue or is lost.
Intent The intent of this requirement is to ensure that the licensee responsible for the physical protection of SNM in transit will have a firm basis for deciding whether or not to initiate response procedures in the event a shipment becomes overdue or is lost.


Content Describe the arrangements and procedures that will be used for notifying the licensee who arranges for the physical protection of material in transit of the arrival of the shipment at its destination or of any such shipment that is lost or unaccounted for after the estimated time of arrival at its destination.
Content Describe the arrangements and procedures that will be used for notifying the licensee who arranges for the physical protection of material. in transit of the arrival of the shipment at its destination or of any such shipment that is lost or unaccounted for after the estimated time of arrival at its'destination.
 
9.6 Lost Material Notification [73.67(e)(3)(vi)]
Intent The intent of this requirement is to ensure that, in the event a shipment becomes overdue at its destination or at a scheduled stop on its itinerary and no reasonable explanation has been received by the licensee from the carrier regarding.its status, a trace investigation will be initiated.
 
Content Describe what procedures will be used to trace any shipment that is lost or has not arrived at a particular point on the shipment's itinerary or at its final destination by the estimated arrival time.
 
5.59-27
 
9.7 NRC Notification [73.67(e)(3)(vll))
Intent The intent of this requirement is-to ensure that after a reasonable amount of time has elapsed with no explanation of the cause for the shipment's being.
 
overdue, the NRC will be immediately notified that the shipment is missing or unaccounted for and advised of the actions being taken to locate the missing shipment.
 
The amount of time considered reasonable before these tracing and notification procedures are initiated should not exceed I hour In any case.
 
Content Ensure that all material determined to be lost or unaccounted for will be reported immediately-to the appropriate NRC Regional Office in accordance with S 73.71.
 
Ensure that notification includes specifying what actions are being taken to trace the shipment and that the shipper or receiver, as appropriate, will also be notified.
 
5.59-28
 
10.
 
TRANSFER AND CONTROL REQUIREMENTS
This chapter provides guidance on meeting the requirements of paragraph 73.67(e)(4), which reads as follows:
(e)(4)
Each licensee who arranges the physical protection of strategic special nuclear material in quantities of moderate strategic signif icance while in transit or who takes delivery of this material free on board (f.o.b.) the point at which it is delivered to a carrier for transport, shall, in addition to the requirements of (e)(1),
(e)(2) and (e)(3) above:
(1) Make all shipments of the material either (A) in dedicated transports with no intermediate stops to load or unload other cargo and with no carrier or vehicle transfers or temporary storage in transit, or (B) under arrangements whereby the custody of the shipment and all custody transfers are acknowledged by signature, and (ii)
Maintain the material under lock, or under the control of an Individual who has acknowledged acceptance of custody of the material by signature.
 
10.1 Carrier Transfers (73.67(e)(4)(i))
Intent The intent of this requirement is to ensure continuity in the assignment
'and acceptance of personal responsibility for shipments of strategic special nuclear material (high-enriched uranium and plutonium).
The requirements of paragraph 73.67(e)(4) do not apply to LEU.
 
This continuity may be provided by
(1) shipping the material in a dedicated transport vehicle so-that the material would be under the continuous control of the same individual(s),for the duration of the shipment or. (2) arranging for each individual who. assumes custody of the shipment to indicate acceptance of personal responsibility for the material by signature.
 
Shipment of the material in a dedicated transport means there should .be no intermediate stops to load or unload other cargo and no carrier or vehicle transfers or. temporary storage en route.
 
However, material other than the SNM
being shipped may be carried in the transport's cargo compartment provided it does not detract from the security of the shipment.
 
For shipments by general freight, this requirement may be satisfied by arranging for "signature security service" with a high surveillance feature, which is provided by many air and motor freight carriers.,
Content Indicate how this requirement would be met for each of the modes of shipment to be employed.
 
Indicate how this requirement would continue to be met in emergency situations by reference to the emergency response plans
5.59-29
 
included in Section 9.4 of the plan.
 
If signature serviceis to be employed, describe the type of service that will be provided by the particular carrier chosen for the shipment.
 
If a dedicated transport is to be used to satisfy.


9.6  Lost Material Notification [73.67(e)(3)(vi)]
this requirement, affirm that the same individual(s) will maintain respon sibility for the shipment from the point of origin to its destination.
Intent The intent of this requirement is to ensure that, in the event a ship- ment becomes overdue and no reasonable explanation has been received from the carrier regarding its status, a trace investigation will be conducted to locate the missing SNM. At this time, the NRC must be notified that the I
                                      32


material is missing and informed as to what steps are being taken to recover the missing material.  Although the licensee is responsible for notifying the NRC of any missing material and to initiate and assist in the subsequent investigation, the law enforcement agencies bear 'the responsibility for physically recovering the material.
10.2 Control of Shipments (73.67(e)(4)(ii))
Intent The intent of this requirement is to ensure that SSNM is not misrouted or mishandled by unauthorized individuals during the course of a shipment and to facilitate early detection and recovery of the material in case of loss or theft.


Content Describe what procedures will be used to trace any shipment that is
This can be achieved by maintaining the material under lock or under the control of a responsible individual whenever the material is not secured in a locked compartment.
.lost or has not arrived by the estimated arrival time. Ensure that all lo.st or missing material will be immediately reported to the appropriate NRC
Regional Office along with what actions are being taken to trace the shipment, that the NRC will be notified as specified in § 73.71, "Reports of Unaccounted- for Shipments, Suspected Theft, Unlawful Diversion, or Industrial Sabotage,"
and that the shipper or receiver, as appropriate, will also be notified.


33
Maintaining the shipment in a locked compartment would normally be possible only for shipments in dedicated transports.


10  EXPORT REQUIREMENTS
In this case, the cargo compartment should be locked upon embarkation and unlocked only after arrival at the shipment's destination.
      This chapter provides guidance on meeting the requirements of paragraph
73.67(e)(4), which reads as follows:
(e)(4)    Each licensee who exports special nuclear material of moderate strategic significance shall comply with the requirements speci- fied in § 73.67(c), (e)(1) and (e)(3).
      Use Chapters 7 and 9 of this part to describe the security procedures that will be used to protect the material up to the point where the receiver accepts physical protection responsibility for the shipment.


34
If the locked cargo compartment is left unattended for an extended period that might allow the unauthorized removal of the material, the Individual(s) responsible for the shipment should establish upon returning to the transport that the compartment has remained continuously under lock.


1
This can be done by examiningthe cargo compartment lock for signs of tampering, examining seals on the cargo compartment, or opening the compartment and ensuring that the material is intact.


===1. IMPORT REQUIREMENTS===
For general freight shipments, during which the cargo compartment -may be opened frequently to load or unload other cargo, locking of the compartment may not be practical on a continuous basis.
    This chapter provides guidance on meeting the requirements of paragraph
73.67(e)(5), which reads as follows:
(e)(5)    Each licensee who imports special nuclear material of moderate strategic significance shall:
            (i)  Comply with the requirements specified in § 73.67(c), (e)(2)
                and (e)(3), and (ii)  Notify the exporter who delivered the material to a carrier for transport of the arrival of such material.


11.1  Security Requirements [73.67(e)(5)(i)]
When the shipment is not maintained under lock, the material is required to be in a sealed cargo compartment or maintained under the control of an individual who has indicated by signature his/her acceptance of responsibility for the shipment.
      Use Chapters 8 and 9 of Part I of this Standard Format to describe the security procedures that will be used to protect the material from the first point where the shipment is picked up inside the United States.


11.2  Notification [73.67(e)(5)(ii)]
This individual should
Intent The intent of this requirement is to ensure that the exporter is noti- fied that the material has arrived safely.
.be the same person who has stgned for custody of the shipment in compliance wtth paragraph.73.67(e)(4)(i).
For air shipments in which the cargo compart ments are not locked, an individual responsible for the shipment is not required to accompany the shipment during flight provided a responsible individual main tains control of the shipment during the entire time the shipment remains at each air terminal.


Content Describe the procedures to be used for notifying the exporter of the material that the shipment has been received.
During unscheduled stops at air terminals not. on the ship ment's itinerary, the shipment may be considered to be under the control of the flight crew provided the shipment is not offloaded and a member of the flight crew remains with- the aircraft at all times.


35
Maintaining the shipment under control means (1) ensuring the shipment is properly routed at transfer points, (2) keeping the material under lock or under surveillance, which would include periodically (normally at least every
2 hours) checking the shipment to ensure it has not been misplaced or tampered with, and (3) ensuring that the licensee or its designee is notified immediately if the shipment is determined to be missing., The licensee should ensure that the signature security service or other service provided by.the
5. 59-30


PART II
carrier under normal or special arrangements includes all three of the these elements of control.
  SPECIAL NUCLEAR MATERIAL
 
Content Indicate the periods during which the shipment will be maintained under lock and those during which it will be maintained under the control of a responsible individual.
 
Describe the instruments to be -used for documenting acknowledgment of custody of the material by individuals assigned respon sibility for controlling the shipment.
 
Also, describe the arrangements made with carriers to ensure that the individuals they assign to maintain control of the material do so in accordance with the three elements of control described above.
 
Refer to -the emergency response procedures developed in accordance with paragraph 73.67(e)(3)(iv) as necessary.
 
5.59-31
 
11.
 
EXPORT REQUIREMENTS
This chapter provides guidance on meeting the requirements of paragraph
73.67(e)(5), which reads as follows:
(e)(5)
Each licensee who exports special nuclear material of moderate strategic significance shall comply with the requirements specified in § 73.67(c), (e)(1) and (e)(3) and.(e)(4). 
Use Chapters 7, "Material Transportation Requirements," 9, "In-Transit Physical Protection Requirements," and 10, "Transfer and Control Requirements,"
of Part I of this guide to describe the security procedures that will be used to protect the material up to the point where the receiver accepts physical protection responsibility for the shipment.
 
5.59-32
 
12.
 
IMPORT REQUIREMENTS
This chapter provides guidance on meeting the requirements of paragraph
73.67(e)(6), which reads as follows:
(e)(6)
Each licensee who imports special nuclear material of moderate strategic significance shall:
(1) Complywith the requirements specified in § 73.67(c), (e)(2),
(e)(3) and (e)(4), and (ii)
Notify the exporter who delivered the material to a carrier for transport of the arrival of such material.
 
12.1 Security Requirements [73.67(e)(6)(i)]
Use Chapters 8, "Receiver Requirements--Transportation," and 9,
"In-Transit Physical Protection Requirements," of Part I of this guide to describe the security procedures that will be used to protect the material from the first point at which the shipment is picked up inside the United States.
 
12.2 Notification [73.67(e)(6)(tt))
Intent The intent of this requirement is to ensure that the exporter is notified that the material has arrived safely.
 
Content Describe the procedures to be used for notifying the exporter of the material that the-shipment has been received.
 
5.59-33
 
13.
 
ORDERS TO DELAY SSN4 SHIPMENTS
This chapter provides guidance on meeting the requirements of paragraph
73.67(e)(7) and S 73.72 (as it may apply to shipments of special nuclear material of moderate strategic significance).
These requirements read as follows:
(e)(7)
If, after receiving advance notice pursuant to S 73.72 from a licensee planning to import, export, transport, deliver to a carrier for transport in a single shipment, or take delivery at the point where it is delivered to a carrier, special nuclear material of moderate strategic significance containing in any part strategic special nuclear material, it appears to the Commission that two or more shipments of special nuclear material of moderate'strategic significance, constituting in the aggregate an amount equal to or greater than a formula quantity of strategic special nuclear material, may be en route at the same time, the Commission may order one or more of the shippers to delay shipment according to the following provisions:
(i)
The shipper shall provide to the Commission, upon request, such additional information regarding a planned shipment as the Commission considers pertinent to the decision on whether to delay such shipment.
 
(0i) The receiver of each shipment, or the shipper if the receiver is not a licensee, shall notify the Director of the appropriate Nuclear Regulatory Commission Regional Office listed in Appendix A by telephone, no later than 24 hours after arrival of such shipment at its final destination, or after such shipment has left the United States as an export, to confirm the integrity of the shipment at the time of receipt or exit from.
 
the United States.
 
(iii) The Commission shall notify the affected shippers no later than two days before the scheduled shipment date that a given shipment is to be delayed.
 
(iv) Shipments of special nuclear material of moderate strategic significance which are protected in accordance with the provisions of §§ 73.20, 73.25, and 73.26 shall not be subject to orders to delay shipment nor considered to constitute a portion of an aggregate formula quantity of strategic special nuclear
.material for the purposes of determining whether any shipments must be delayed.
 
§ 73.72 Requirement for advance notice of shipment of special nuclear material.
 
(a)
Each licehsee who plans to import, export, transport, deliver to a carrier for transport in a single shipment, or take delivery, at the point where it is delivered to a carrier, the following materials, shall notify the
5.59-34
 
Director of the appropriate Nuclear Regulatory Commission Regional Office listed in Appendix A by U.S. Mail, postmarked at least 7 days in advance of the shipping date:
(1) formula quantities of strategic special nuclear material, or (2) special nuclear material of moderate strategic significance containing in any part strategic special nuclear material.
 
(b)
The following information shall be furnished in the advance notice:
shipper, receiver, carrier(s), estimated dates and time of departure and arrival, transfer point(s), and mode(s) of shipment.
 
(c)
The Director of the appropriate Nuclear Regulatory Commission Regional Office shall also be notified by telephone 7 days in advance of the shipping date that an advance shipping notice has been sent by mail, and of any changes to the shipment itinerary prior to the shipment date.
 
Road shipments or transfers with one-way transit lines of 1 hour or less in duration between installations of a licensee are exempt from the requirements of this section.
 
It is noted.that shipments of SNM of moderate strategic significance consisting entirely of uranium enriched in the isotope U-235 to 10 percent or more but less than 20 percent are not subject to these requirements.
 
Of the requirements detailed-above, only paragraph 73.67(e)(7)(ii) and
§ 73.72 should be addressed in the licensee's physical security plan.
 
This is discussed in Section 13.1.
 
1.
 
Criteria for Delaying Shipments Under the provisions of paragraph 73.67(e)(7) of the regulations, the NRC
has authority to order delays in certain shipments of SNM.of moderate strategic significance.
 
It is the intention of the NRC to exercise this authority only when necessary to protect the public health and safety from the possible consequences of the theft of a formula quantity of SSNM.
 
Since the number of affected shipments expected annually is quite low, shipment delays are expected to be ordered very rarely.
 
In most cases, licensees will be able to clear shipment dates with the NRC staff far in advance so that potential conflicts in the scheduling of shipments can be avoided.
 
However, shipment delays may be required on an emergency basis if a previous shipment is determined to be missing and cannot be accounted for before the next scheduled shipment is to depart.
 
When a'scheduling conflict that cannot be resolved voluntarily arises, the following criteria will be applied to determine which shipments will be delayed:
a.
 
Total time needed to complete the shipment, b.
 
The impact of a schedule delay on the use of the SNM at the delivery site, c.
 
Planned routing of the material, d.
 
The relationship of the material to the national defense or to other essential programs in the nation's interest,
5.59-35
 
e.-
The possible impacts on the shipper/carrier relationship with regard to availability of shipment vehicles and other special arrangements that would be difficult to reschedule, and f.
 
How far in advance of the proposed shipment date the NRC was notified of the intent to make the shipment.
 
2.
 
NRC Requests for Additional Shipment Information In order to apply the decision criteria listed above, the NRC has the authority under paragraph 73.67(e)(7)(i) to request additional information from licensees regarding a planned shipment of SSNM that may be subject to a possible delay order.
 
Such information requests may be made at any time prior to a scheduled shipment ei~ther by telephone or in writing.
 
3.
 
NRC Notification of Shipment Delay Orders to Licensees Under paragraph 73.67(e)(7)(lii), the NRC will normally notify licensees that a shipment is to be delayed no later than 2 days before a shipment is scheduled to depart.
 
In practice, it is expected that potential conflicts will be resolved much before the date of a planned shipment after appropriate NRC
consultations with the prospective shippers.
 
However, in an emergency the NRC
may order delays in shipments or other responsible action at any time it may deem necessary or desirable to promote the common defense and security, protect health, or minimize danger to life or property.
 
13.1 Notification of Receipt of SSNM (73.67(e)(7)(ii))
Intent The intent of this notification requirement is to ensure that the NRCtis promptly informed of the receipt of a shipment of SSNM subject to para graph 73.67(e)(7) or, in the case of export shipments, informed that the ship ment has left the United States safely.
 
Based on this information, the NRC can permit subsequent shipments subject to paragraph 73.67(e)(7)(ii) to commence with the knowledge that a formula quantity of SSNM will not be at risk "In a.
 
small number of simultaneous shipments.
 
This will also ensure that shipment delay orders will not have to be imposed unnecessarily for failure to confirm that a previous shipment is no longer at risk.
 
Compliance with this requirement is not a substitute for compliance with other notification requirements under paragraph 73.67(e)(2)(Ii). 
Content Affirm that, in the case of a shipment of SNM of moderate strategic significance containing in any part SSNM, arrangements are made to obtain confirmation of the integrity of the shipment at the point where the material leaves the United States as an export or at its final destination.
 
Describe the procedures for accomplishing this and notifying the NRC of the shipment's status at the time of receipt or exit from the United States.
 
Include the names or titles of individuals who will be responsible for ensuring that the required confirmation is made and the proper notification is provided to the NRC.
 
5.59-36
 
PART II  
SPECIAL NUCLEAR MATERIAL  
OF LOW STRATEGIC SIGNIFICANCE
OF LOW STRATEGIC SIGNIFICANCE
                              I
5.59-37
              36
 
1.
 
USE AND STORAGE AREA AT A FIXED SITE
This chapter provides guidance on meeting the requirement of paragraph
73.67(f)(1), which is as follows:
if)(1)
Store or use such material only within a controlled access area.
 
A controlled access area (CAA)
is defined in paragraph 73.2(z) as "any temporarily or permanently established area which is clearly demarcated, access towhich is controlled and which affords isolation of the material or persons within it."
"Access control" means measures used to allow only specified personnel, materials, and vehicles ingress into and egress from a given area, while "isolation"' refers to measures taken to deter persons, materials, or vehicles from entering or leaving a given area through other than established access control points.
 
Thus, a CAA includes provisions for both isolation and access control.
 
In some cases, isolation or access control systems may also serve the purpose of aiding in the detection of unauthorized penetration or activities* within the CAA.
 
Therefore, these detection-related considerations are also alluded to in this chapter.
 
In the discussion that follows, CAAs intended for the use and possible storage of SNM of low strategic significance are discussed separately from those intended solely for the storage of such SNM.
 
Although there is no difference in the requirements for these two different applications of the CAA,
it is recognized that the means used to isolate the material and to control access may differ markedly for use areas compared with storage areas and therefore warrant separate discussion.
 
1.1 Areas for Use and Temporary Storage [73.67(f)(1)3 This section discusses CAAs intended primarily for the use and temporary storage of SNM of low strategic significance.
 
These may be temporarily estab lished to meet transitory or intermittent SNM use requirements or they may be permanently established.
 
Permanently established CAAs for use of SNM may also be used for storage for short intervals between periods of usage.
 
"Use" means that the material is undergoing processing (e.g., fuel fabrication, irradiation in a reactor) or utilization of its properties in conjunction with experimental equipment (e.g., equipment used for research or educational laboratory experiments).
Different isolation/access control measures may be used for periods during which the area is occupied versus unoccupied.
 
1.
 
Temporarily Established CAAs Temporarily established CAAs for the use of SNM need not have permanent barriers at their boundaries.
 
Isolation of the material and persons using the material may be provided by office partitions, cordons, or other devices used to warn passersby of the restricted-nature of the area.
 
Access control can be effected through surveillance or supervision of the area by those who are using the SNM and who are responsible for the material.
 
However, the provision of Unauthorized activities are those activities deemed by the licensee to be indicative of or contributory to the possible theft of SNM.
 
5.59-39
 
access control through personal supervision is suitable only for those situations in which the size of the CAA and the number of persons to be admitted are sufficiently small and in which the CAA is suitably configured to make such procedures practical.
 
When material located in a temporarily established CAA is to be left unattended (i.e., because it is impractical to replace the material in a CAA
designed for long-term storage of the material), access control and improved Isolation for the temporary CAA may be provided to substitute for the discon tinued personal supervision over the material.
 
(In addition, provisions must also be made for satisfying the monitoring requirement of paragraph 73.67(f)(2).)
Improved isolation can sometimes be provided by increasing the penetration resistance of existing barriers (e.g., locking doors and windows, placing the material in a locked drawer or supply room).
Access control may be provided by any of the measures suggested below for permanently established CAAs left unattended; some of these suggestions may be more suitable for temporary use than others.
 
If no suitable barrier is available to provide isolation, material left unattended may be protected by a motion alarm covering the area immediately surrounding the material.


1.  USE AND STORAGE AREA AT A FIXED SITE
This improved detection capability would be con sidered an acceptable substitute for the rudimentary isolation provided by temporary barricades, cordons, signs, and other less substantial means of isolation that may be used on a temporary basis.
      This chapter provides guidance on meeting the requirement of paragraph
73.67(f)(1), which is as follows:
(f)(1)    Store or use such material only within a controlled access area.


A controlled access area (CAA) is defined in paragraph 73.2(z) as "any temporarily or permanently established area which is clearly demarcated, access to which is controlled and which affords isolation of the material or persons within it." "Access control" means measures used to allow only specified personnel, materials, and vehicles ingress into and egress from a given area, while "isolation" refers to measures taken to deter persons, materials, or vehicles from entering or leaving a given area through other than established access control points. Thus, a controlled access area includes provisions for both isolation and access control.    In some cases, isolation or access control systems may also serve the purpose of aiding in the detection of unauthorized penetration or activities* within the CAA. Therefore, these detection-related considerations are also alluded to in this chapter.
2. Permanently Established CAAs Permanently established CAAs for the use and temporary storage of SNM of low strategic significance would most likely provide isolation for the SNM
through the use of permanent barriers.


In the discussion that follows, CAAs intended for the use and possible storage of SNM of low strategic significance are discussed separately from those intended solely for the storage of such SNM. Although there is no difference in the requirements for these two different applications of the CAA, it is recognized that the means used to isolate the material and to control access may differ markedly for use areas compared with storage areas and therefore warrant separate discussion.
These could consist of fences; gates or freestanding walls for exterior areas; or exterior or interior building walls, locked doors, windows, bars, grillwork; or other barriers for interior areas.


1.1  Areas for Use and Temporary Storage [73.67(f)(1)]
Such barriers are not required to meet the more stringent criteria for physical barriers used for the protection of formula quantities of strategic special nuclear material (SSNM).*
      This section discusses CAAs intended primarily for the use and temporary storage of SNM of low strategic significance. These may be temporarily estab- lished to meet transitory or intermittent SNM use requirements or they may be permanently established.    Permanently established CAAs for use of SNM
However, good security management practice would, dictate that the barrier be substantial enough to deter casual passersby from unauthorized penetration.
may also be used for storage for short intervals between periods of usage.


"Use" means that the material is undergoing processing (e.g. fuel fabrication, irradiation in a reactor, etc.) or utilization of its properties in conjunc- tion with experimental equipment (e.g., research or educational laboratory experiments).    Different isolation/access control measures may be used for periods during which the area is occupied versus unoccupied.
If the barriers are also designed to aid in detec tion, the criteria for penetration resistance or tamper indication in accor-. 
dance with the specific monitoring procedures to be used also apply.


a.    Temporarily Established CAAs Temporarily established CAAs for the use of SNM need not have permanent barriers at their boundaries.    Isolation of the material and persons using the material may be provided by office partitions, cordons, or other devices used to warn passersby of the restricted nature of the area. Access control can be effected through surveillance or supervision of the area by those who are using the SNM and who are responsible for the material.      However, Unauthorized activities are those activities deemed by the licensee to be indicative of or contributory to the possible theft of SNM.
Access control for permanently established CAs during periods they are occupied can be provided by personal supervision.


37
However, when these areas are unoccupied or when the size, configuration, or numbers of persons intended to be admitted to the area make personal supervision Impractical, other means of access control may be called for.


S
Some of the additional access control measures that may be used for permanently established CAMs in these situations are:
the provision of access control through personal supervision is suitable only for those situations in which the size of the CAA and the number of persons to be admitted are sufficiently small and in which the CAA is suitably configured to make such procedures practical.
Stationing a watchman at CAA access control points, Limiting distribution of keys,. keycards, or combinations to locks on doors and gates,
*"Strategic special nuclear material" means uranium-235 (contained in uranium enriched to 20 percent or more in the U-235 isotope), uranium-233, or plutonium.


When material located in a temporarily established CAA is to be left unattended (i.e. , because it is impractical to replace the material in a CAA designed for long-term storage of the material), access control and improved isolation for the temporary CAA may be provided to substitute for the discontinued personal supervision over the material.      (In addition, provisions must also be made for satisfying the monitoring requirement of paragraph 73.67(f)(2).)    Improved isolation can sometimes be provided by increasing the penetration resistance of existing barriers (e.g. , locking doors and windows, placing the material in a locked drawer or supply room, etc.). Access control may be provided by any of the measures suggested below for permanently established CAAs left unattended; some of these suggestions may be more suitable for temporary use than others. If no suitable barrier is available to provide isolation, material left unattended can be protected by a motion alarm covering the area immediately surrounding the material.
5.59-40


This improved detection capability would be considered an acceptable sub- stitute for the rudimentary isolation provided by temporary barricades, cordons, signs, and other less substantial means of isolation that may be used on a temporary basis.
Using a coded badging system to identify authorized personnel at CAA
access control points, Controlling locked CAA doors and gates by use of remote surveillance (e.g.,  
intercom or CCTV) by personnel stationed at a centrally located access control facility, or
.
Controlling access of personnel, material, and vehicles into CAAs by other means.


b.     Permanently Established CAAs Permanently established CAAs for the use and temporary storage of SNM
It is expected that large facilities (e.g., fuel processing facilities)
of low strategic significance would most likely provide isolation for the SNM through the use of permanent barriers. These could consist of fences;
will have more complex isolation and access control systems than small facil ities (e.g., research facilities) in order to achieve comparable levels of protection.
gates or freestanding walls for exterior areas; or exterior or interior building walls, locked doors, windows, bars, grillwork; or other barriers for interior areas. Such barriers are not required to meet the more stringent criteria for physical barriers used for the protection of formula quantities of strategic special nuclear material (SSNM).*    However, good security manage- ment practice would dictate that the barrier be substantial enough to deter casual passersby from unauthorized penetration.     If the barriers are also designed to aid in detection, the criteria for penetration resistance or tamper-indication in accordance with the specific monitoring procedures to be used also apply.


Access control for permanently established CAAs during periods they are occupied can be provided by personal supervision. However, when these areas are unoccupied or when the size, configuration, or numbers of persons intended to be admitted to the area make personal supervision impractical, other means of access control may be called for. Some of the additional access control measures that may be used for permanently established CAAs in these situations are:
Content Describe the CAAs where the material will be used.
  "Strategic special nuclear material" means uranium-235 (contained in uranium enriched to 20 percent or more in the U-235 isotope), uranium-233, or plutonium.


38
Indicate under what conditions CAAs will be established on a temporary basis.


Stationing of a watchman at CAA access control points, Limiting distribution of keys, keycards,  or combinations to locks on doors and gates, Using a coded badging system to identify authorized personnel at CAA access control points, Controlling locked CAA doors and gates by use of remote surveillance (e.g., via intercom or CCTV) by personnel stationed at a centrally located access control facility, or Controlling access of personnel,  material, and vehicles into CAAs by other means.
State whether each CAA will also be used for storage.


It is expected that large facilities (e.g., fuel processing facilities)
For each CAA identified, provide the following information:
will have more complex isolation and access control systems than small facil- ities (e.g. , research facilities) in order to achieve comparable levels of protection.
1.


Content Describe the CAAs where the material will be used. Indicate under what conditions CAAs will be. established on a temporary basis. State whether each CAA will also be used for storage. For each CAA identified, provide the following information:
A description of the area and its features relative to other facility features, showing the normaliroutes of ingress to each CAA (Including a scale diagram).
    .1. A description of the area and its features relative to other facil- ity features, showing the normal routes of ingress to each CAA (including a scale diagram).
2.
      2.  Descriptions of physical barriers, cordons, walls, partitions, or other means of providing isolation of the CAA, and channelling entry through established access control points into the CAA.


3.  The means and criteria used for controlling access into the CAA
Descriptions of physical barriers, cordons, walls, partitions, or other means of providing isolation of the CAA,
at established access control points.
and channelling entry through established access control points into the CAA.


4.    If more than one CAA is designated, indicate the types of material normally used in each CAA; for temporarily established CAAs, indicate the types of activities normally performed within each area.
3.


1.2  Areas for Permanent Storage [73.67(f)(1)]
The means and criteria used for controlling access into the CM at established access control'points.
Intent Controlled access areas normally used only for storage of SNM are described in this section.    Such CAAs may be very limited in size, since they need only contain the material itself, and access to them is expected to be infrequent. Where small amounts of material are involved, the CAA
may consist of relatively small containers such as security cabinets, safes, and locked closets or supply rooms.


39
4.


Isolation for CAAs intended only for storage usually will be provided by the penetration-resistant features of the perimeter barriers or container walls of the CAA.    Such barriers and container walls are not required to meet the more stringent criteria for physical barriers used for the protec- tion of formula quantities of SSNM. However, good security management prac- tice would dictate that the barrier be substantial enough to deter casual passersby from unauthorized penetration. If the barriers are also designed to aid in detection, the criteria for penetration resistance or tamper-indication in accordance with the specific monitoring procedures to be used also apply.
If more than one CAA is designated, the types of material normally used in each CAA; for temporarily established CAAs, the types of activities normally performed within each area.


In determining the level of isolation and access control for such CAAs, the minimum time required for extricating SNM from its storage location in relationship to the licensee's time of detection and assessment may need to be taken into account (e.g. , fuel assemblies stored in shipping casks or non-selfprotecting fuel residing in non-power reactor cores). The bulkiness, massiveness, and difficulty of movement or disassembly of fresh fuel elements or other fArms of low-enriched uranium (LEU) in large quantities such as shipping casks or assemblies may pose sufficient difficulty to persons attempt- ing unauthorized removal within a reasonable time period (relative to CAA
1.2 Areas for Permanent Storage [73.67(f)(1)]
monitoring procedures) that they can be considered to provide isolation.
Intent CAAs normally used only for storage of SNM are described in this section.
 
SuchCAAs may be very limited in size since they need only contain the material itself, and access to them is expected to be infrequent.
 
Where small amounts of material are involved, the CAA may consist of relatively small containers such as security cabinets, safes, and locked closets or supply rooms.
 
Isolation for CAAs intended only for storage usually will be provided by the penetration-resistant features of the perimeter barriers or container walls of the CAAM Such barriers and container walls are not required to meet the more stringent criteria for physical barriers used for the protection of formula quantities of SSNM.
 
However, good security management practice would
5.59-41
 
dictate that the barrier be substantial enough to deter casual passersby from unauthorized penetration.
 
If the barriers are also designed to aid in detection, the criteria for penetration resistance or, tamper indication in accordance with the specific monitoring procedures to be used also apply.
 
In determining the level of isolation and access control for such CAAs, the minimum time required for extricating SNM from Its storage location in relationshipto the licensee's time of detection and assessment may need to be taken into account (e.g., fuel assemblies stored in shipping casks or non-self-protecting fuel residing in nonpower reactor cores).  
The bulkiness, massiveness, and difficulty of movement or disassembly of fresh fuel elements or other forms of low-enriched uranium (LEU)  
in large quantities such as shipping casks or assemblies may pose sufficient difficulty to persons attempt ing unauthorized removal within a reasonable time period (relative to CAA  
monitoring procedures) that they may be considered to provide isolation.


Control of access to special equipment and vehicles capable of handling and transporting such items may also be included as integral elements of the access control program for the CAA.
Control of access to special equipment and vehicles capable of handling and transporting such items may also be included as integral elements of the access control program for the CAA.
Line 775: Line 1,671:
Access control procedures for CAAs designated exclusively for storage are expected to be similar to those described in the previous section for periods when use-type CAAs are unoccupied.
Access control procedures for CAAs designated exclusively for storage are expected to be similar to those described in the previous section for periods when use-type CAAs are unoccupied.


It is expected that large facilities (e.g. fuel processing facilities)
It is expected that large facilities (e.g., fuel processing facilities)  
will have more complex isolation and access control systems than small facil- ities (e.g. , research reactors) in order to achieve comparable levels of protection.
will have more complex isolation and access control systems than small facil ities (e.g., research reactors) in order to achieve comparable levels of protection.
 
An illumination level is recommended for the CAA that is sufficiently uniform and bright to'detect penetration of or tampering with the CAA contain ment (In the case of a security cabinet) or Unauthorized penetration of or activities within the CAA (in the case of a vault-type room or its equivalent). 
Content (This section needs to be completed only for CAAs designatedexclusively for storage of SNM.
 
CAAs designated for both use and storage are to be described as recommended in Section 1.1 of Part II of this Standard Format.)
Describe the CAs where the material will be stored, if different from those previously described for use.
 
For each such CAA, provide the following information:
1.
 
A description of the area and its features relative to other facility features showing the access control points for the CAA (including a scale diagram). 
2.
 
The physical barriers, container walls, or other features, that demarcate the perimeter of the CAA and channel entry through only established access control points.
 
If access control is provided by virtue of the bulkiness, massiveness, and difficulty of disassembly of a container or object
5.59-42
 
serving as a CAA, describe the facts relied upon to support such a determination.
 
3.
 
The means and criteria used for controlling access to the CAA'at established access control points.
 
4.
 
If more than one CA
is designated for the storage of the material, the types of material normally to be stored in each area.
 
5.59-43
 
2.
 
DETECTION DEVICES AND PROCEDURES AT A FIXED SITE
This chapter provides guidance for meeting the requirement of paragraph
73.67(f)(2), which is as follows:
(f)(2)
Monitor with an intrusion alarm or other device or procedures the controlled access areas to detect unauthorized penetrations or activities.
 
The purpose of this monitoring activity as stated in paragraph 73.67(a)(2)
is to provide "early detection and assessment of unauthorized access or activ ities by an external adversary within the controlled access area..." and "early detection of removal of special nuclear material by an external adversary from a controlled access area."
This should be done to achieve the objective of minimizing the possibilities for unauthorized removal of special nuclear material "consistent with the consequences of such actions," as stated in paragraph 73.67(a) of the effective rule.
 
Thus, the earliness of detection afforded by the licensee's physical protection system may vary depending on the nature and quantity of the material susceptible to unauthorized removal.
 
Further discussion of the earliness of detection required for possible thefts of different types and quantities of special nuclear material of low strategic significance is provided in Section 2.1 of Part II of this guide.
 
2.1 Earliness of Detection [73.67(a)]
The criteria used for determining the earliness of detection for unauthor ized access, activities, or removal of SNM from CAAs will depend on an assess ment of the magnitude of the consequences associated with possible misuse of the type and quantity of material that could be removed in a given theft attempt.
 
For SNM of low strategic significance, three distinct cases are considered:
1.
 
Gross theft of low-enriched uranium (LEU)*
S2.


An illumination  level is recommended for the CAA that is sufficiently uniform and bright to    detect penetration of or tampering with the CAA contain- ment (in the case of    a security cabinet) or unauthorized penetration of or activities within the    CAA (in the case of a vault-type room or its equivalent).
Minor theft of LEU.
Content (This section needs to be completed only for CAAs designated exclusively for storage of SNM.      CAAs designated for both use and storage are to be described as recommended in Section 1.1 of Part II of this Standard Format.)
      Describe the CAAs where the material will be stored, if different from those previously described for use. For each such CAA, provide the following information:
      1.    A description of the area and its features relative to other facil- ity features showing the access control points for the CAA (including a scale diagram).
                                        40


2.    The physical barriers, container walls, or other features that demarcate the perimeter of the CAA and channel entry through only estab- lished access control points. If access control is provided by virtue of the bulkiness, massiveness, and difficulty of disassembly of a container or object serving as a CAA, describe the facts relied upon to support such a determination.
3.


3.     The means and criteria used for controlling access to the CAA at established access control points.
Theft of strategic special nuclear material (SSNM)
(i.e., SNM of low strategic significance other than LEU). 
Gross theft. of LEU refers to the theft of LEU in a sufficiently large quantity that it could yield upon further enrichment or other processing enough material of the type and quantity needed to construct a clandestine fission explosive (CFE)
device.


4.    If more than one CAA is designated for the storage of the mate- rial,    indicate the types of material normally to be stored in each area.
This quantity may vary depending on the enrichment and physical and chemical form of the feed material but may roughly be estimated as an amount containing about 75 kilograms of the isotope U-235.


41
Because the most serious consequences to the public health and safety could occur from a theft of this magnitude, a system that would detect a theft sufficiently early to allow for prompt recovery is called for.


2.  DETECTION DEVICES AND PROCEDURES AT A FIXED SITE
The NRC believes that, because of the Low-enriched'uranium is uranium enriched above natural but less than 20 percent in the U-235 isotope.
      This chapter provides guidance for meeting the requirement of paragraph
73.67(f)(2), which is as follows:
(f)(2)    Monitor with an intrusion alarm or other device or procedures the controlled access areas to detect unauthorized penetrations or activities.


The purpose of this monitoring activity as stated in paragraph 73.67(a)(2)
5.59-44
is to provide "early detection and assessment of unauthorized access or activ- ities by an external adversary within the controlled access area..." and
"early detection of removal of special nuclear material by an external adversary from a controlled access area." This should be done to achieve the objective of minimizing the possibilities for unauthorized removal of special nuclear material "consistent with the consequences of such actions,"
as stated in paragraph 73.67(a) of the effective rule. Thus the earliness of detection afforded by the licensee's physical protection system may vary depending upon the nature and quantity of the material susceptible to unauthor- ized removal.    Further discussion of the earliness of detection required for possible thefts of different types and quantities of special nuclear material of low strategic significance is provided in Section 2.1.


2.1  Earliness of Detection [73.67(a)]
large quantity of material involved and with proper detection systems and procedures, the licensee would be capable of detecting a gross theft of LEU  
      The criteria used for determining the earliness of detection for unautho- rized access, activities, or removal of special nuclear material from controlled access areas will depend upon an assessment of the magnitude of the consequences associated with possible misuse of the type and quantity of material that could be removed in a given theft attempt. For special nuclear material of low strategic significance, three distinct cases are considered:
between the time of the actual theft and the time it is transported off site.
      1.  Gross theft of low-enriched uranium (LEU)*
      2.  Minor theft of low-enriched uranium (LEU)
      3.  Theft of strategic special nuclear material (SSNM)  (i.e., SNM of low strategic significance other than LEU.)
      Gross theft of LEU refers to the theft of LEU in a sufficiently large quantity that it could yield upon further enrichment or other processing enough material of the type and quantity needed to construct a clandestine fission explosive (CFE) device. This quantity may vary depending on the enrichment and physical and chemical form of the feed material but may roughly be estimated as an amount containing about 75 kilograms of the isotope U-235.    Because the most serious consequences to the public health and safety could occur from a theft of this magnitude, a system that would detect a theft sufficiently early to allow for prompt recovery is called for.


The NRC believes that, because of the large quantity of material involved and with proper detection systems and procedures, the licensee would be capable of Low-enriched uranium is uranium enriched above natural but less than
Minor theft of LEU refers to thefts involving much smaller quantities of LEU such as could be removed by one or two persons in a private vehicle or on one's person.
  20% in the U-235 isotope.


42
These minor thefts are significant only to the extent that they could be repeated periodically to eventually accumulate an aggregate quantity similar to that which might be obtained in a gross theft.


detecting a gross theft of LEU between the time of the actual theft and the time it is transported off site.
The required'degree of earliness of detection of such thefts is related to the time that would be needed by the adversary to obtain a gross amount through repeated thefts.


Minor theft of LEU refers to thefts involving much smaller quantities of LEU such as could be removed by one or two persons in a private vehicle or on one's person. These minor thefts are significant only to the extent that they could be repeated periodically to eventually accumulate an aggregate quantity similar to that which might be obtained in a gross theft. The required degree of earliness of detection of such thefts is related to the time that would be needed by the adversary to obtain a gross amount through repeated thefts. If the amount taken in each of a series of daily thefts is very small, the ultimate time of detection could be as long as six months--
If the amount taken in each of a series of daily thefts is very small, the ultimate time of detection could be as long as 6 months--the interval between material inventories as required by Part 70.
the interval between material inventories as required by Part 70. For larger quantities that could be removed in a single theft, but still much less than would constitute a gross theft, it would be reasonable to expect that one in a series of such thefts would be detected before a gross amount could be removed.


Licensees who possess less than gross quantities of LEU need not provide for early detection of a single theft of a gross quantity, but the capability for detecting multiple thefts is as important as it is for those licensees possessing gross quantities.
For larger-quantities that could be removed in a single theft, but still much less than would constitute a gross theft, it-would be reasonable to expect thatone in a series of such thefts would be detected before a gross amount could be removed.


Thefts from a single facility of SSNM (SNM of low strategic significance other than LEU) are limited by definition to quantities that could not be used to construct a nuclear explosive device; thefts of similar quantities of SSNM from several different facilities could, however, lead to the accumu- lation of an aggregate quantity that would permit such illicit use. (The consequences of a single theft of such material would have minimal impact on the public health and safety.) Therefore, detection of such thefts is required sufficiently early to ensure early notification to the NRC. The NRC in turn can then notify other licensees of the need to implement appro- priate response measures to prevent the accumulation by a single adversary of a formula quantity of material through multiple thefts from different facilities. The NRC believes that there are detection systems and procedures that would allow the licensee to detect a theft of SSNM within approximately two hours.
Licensees who possess less than gross quantities of LEU need not provide for early detection of-a single theft of a gross quantity, but the capability for detecting multiple thefts is as important as it isfor those licensees possessing gross quantities.


2.2  Monitoring of Controlled Access Areas [73.67(f)(2)]
Thefts from a single facility of SSNM (SNM of low strategic significance other than LEU) are limited by definition to quantities that could not be used to construct a nuclear explosive device; thefts of similar quantities of SSNM
Intent Monitoring of CAAs where the material is used will require a capability for early detection of (a) unauthorized penetration of the CAA perimeter, (b) unauthorized activities within the CAA, (c) unauthorized removal of SNM
from several different facilities could, however, lead to the accumulation of an aggregate quantity that would permit such illicit use.
from the CAA, or (d) some combination of these, by an external adversary.


For purposes of this guidance, an external adversary is any person no t employed by the licensee or one of his contractors to report for work on a regular basis at the licensee's site and who is not directly involved in the processing or other authorized use of the material in connection with his assigned duties.   For purposes of this definition, graduate and other students assigned by the licensee at an educational or research institution to assume responsibility for the regular handling of the material would not be considered an external adversary.
(The consequences of a single theft of such material would have minimal impact on the public health and safety.)
Therefore, detection of such thefts is required sufficiently early to ensure early notification to the NRC.


43
The NRC in turn can then notify other licensees of the need to implement appropriate response measures to prevent the accumulation by a single adversary of a formula quantity of material through multiple thefts from different facilities.


The choice of particular safeguards measures to be included in the CAA
The NRC believes that there are detection systems and procedures that would allow the licensee to detect a theft of SSNM within approximately 2 hours.
monitoring system will depend upon a number of different site specific factors such as whether the measure is to function while the area is occupied or unoccupied, the size of the area, the types of functions performed in the area, the level of traffic into and out of the area, etc. Many of the avail- able safeguards measures which may be employed in the CAA monitoring system are described in various regulatory guides and NUREG series documents issued by the Commission. Specifically, the Fixed Site Physical Protection Upgrade Rule Guidance Compendium* provides guidance on selection, installation, and implementation of monitoring devices and procedures relative to physical protection of formula quantities of SSNM. This guidance is also applicable to monitoring equipment and procedures for CAAs at fixed sites having less than formula quantities of SNM with regard to individual physical protection measures.    It is recognized, however, that from a systems point of view, this body of guidance intended to support the Upgrade Rule may emphasize a much greater level of redundancy and diversity than would be required for the protection of SNM of moderate and low strategic significance.** The following paragraphs give illustrations of various monitoring systems that can be used to provide the earliness of detection discussed in Section 2.1.


a.     Early Detection of Gross Theft of LEU
2.2 Monitoring Controlled Access Areas [73.67(f)(2)]
      Early detection of gross theft of LEU means detection during the attempted theft. This may be accomplished by using intrusion alarms or other monitoring devices in the following applications:
Intent Monitoring CAAs where the material is used will require a capability for early detection of (1) unauthorized penetration of the CAA perimeter, (2).
      Fence or buried line perimeter detection systems at the CAA boundaries.
unauthorized activities within the CAA,(3) unauthorized removal of SNM from the CAA, or (4) some combination of these, by an external adversary.


Door and window alarms (e.g., balanced magnetic switches) for CAAs within buildings and alarms on emergency exit doors equipped with crash bars.
For purposes of this guidance, an external adversary is any person not employed by the licensee or one of its contractors to report for work on a regular basis at the licensee's slte-and who is not directly involved in the processing or other authorized use of the material in connection with his/her assigned duties.
 
For purposes of this definition, graduate and other students assigned by the licensee at an educational or research institution to assume responsibility for
5.59-45
 
the regular handling of the material would not be considered an external adversary.
 
The choice of particular safeguards measures to be included in the CAA
monitoring system will depend on a number of different site-specific factors such as.whether the measure is to function while the area Is occupied or unoccupied, the size of the area, the types of functions performed in the area, the level of traffic into and~out of the area, etc.
 
Many of the available safeguards measures that may be employed in the CAA monitoring system are described in various regulatory guides and NUREG documents issued by the NRC.
 
Specifically, the Fixed Site Physical Protection Upgrade Rule Guidance Com pendium* provides guidance on selection, installation, and implementation of monitoring devices and procedures relative to physical protection of formula quantities of SSNM.
 
This guidance is also applicable to monitoring equipment and procedures for CAAs at fixed sites having less than formula quantities of SNM with regard to individual physical protection measures.
 
It is recognized, however, that from a systems point of view, this body of guidance intended to support the Upgrade Rule may emphasize a much greater level of redundancy and diversity than would be requiredifor the protection of SNI of moderate and low strategic significance.**
The following paragraphs give Illustrations of various monitoring systems that can be used to provide the earliness of detec tion discussed in Section 2.1 of Part II of this guide.
 
1.
 
Early Detection of Gross Theft of LEU
Early detection of gross theft of LEU means detection during the attempted theft.
 
This may be accomplished by using intrusion alarms or other monitoring devices in the following applications:
*
Fence or buried line perimeter detection.systems at the CAA boundaries.
 
Door and window alarms (e.g., balanced magnetic switches) for CAAS with in buildings and alarms on emergency exit doors equipped with crash bars.


Volumetric interior motion detection systems for unoccupied CAAs or portions of CAAs within buildings.
Volumetric interior motion detection systems for unoccupied CAAs or portions of CAAs within buildings.


In many cases, security procedures may be employed as substitutes for some or all of the devices that could be employed to fulfill the monitoring requirement for the CAA.    Security procedures may be especially attractive The compendium was issued for public comment in conjunction with the pro- posed Physical Protection Upgrade Rule (42 FR 34310, 7/5/77). It is intended to assist the licensee in the development and implementation of safeguards physical protection and transportation protection plans. Copies are available for inspection at the Commission's Public Document Room,
In many cases, security-procedures may be employed as substitutes for some or all of the devices that could be employed to fulfill the monitoring requirement for the CAA.
  1717 H Street NW., Washington, D.C.


Tamper-safing of devices intended for use at facilities having less than formula quantities of strategic special nuclear material need protect only against the external adversary; to the extent such a distinction can be made for a given device, this represents a relaxation in tamper-safing requirements relative to protection of formula quantities.
Security procedures may be especially attractive in protecting against the theft of gross quantities of LEU located outside The c6mpendlum was issued in conjunction with the Physical Protection Upgrade Rule.


44 I
It is Intended to assist the licensee in the development and implementa tion of safeguards physical protection and transportation protection plans.


in protecting against the theft of gross quantities of LEU located outside buildings, where intrusion alarms may more easily be circumvented by'an external adversary. Typical security procedures that may be employed for detection of attempts at unauthorized removal of gross quantities of LEU
Copies are available for inspection at the Commission's Public Document Room,
include the following:
1717 H Street NW., Washington, D.C.
          Periodic patrols of CAA perimeters and areas within the CAA by watchmen.


Surveillance (escorting) of non-licensee vehicles capable of trans- porting gross quantities of LEU away from the site.
Tamper-safing of devices intended for use at facilities having less than formula quantities of SSNM need protect only against the external adversary;
to the extent such a distinction can be made for a given device, this represents a relaxation in tamper-safing requirements relative to protection of formula quantities.


Continuous (without interruption) or continual (intermittent)
5.59-46
          surveillance of the CAA, or a given portion of the CAA which con- tains a gross quantity of LEU, by designated supervisory or other licensee employees.   (These surveillance responsibilities could be undertaken in addition to the employee's normal functions provided they can both be discharged adequately.)
 
          Periodic inspections to confirm continued integrity of barriers, gates, loading bay doors, etc., through which unauthorized removal of gross quantities of LEU could be effected.
buildings where intrusion alarms may more easily be circumvented by an external adversary.
 
Typical security procedures that may be employed for detection of attempts at unauthorized removal of gross quantities of LEU include the following:
*
Periodic patrols of CAA perimeters and areas within the CAA by watchmen.
 
Surveillance (escorting) of nonlicensee vehicles capable of trans porting gross quantities of LEU away from the site.
 
Continuous (without interruption) or continual (intermittent)  
surveillance of the CAA, or a given portion of the CAA that contains a gross quantity of LEU,  
by designated supervisory or other licensee employees.
 
(These surveillance responsibilities could be undertaken in addition to the employee's normal functions provided they can both be discharged adequately.)  
Periodic inspections to confirm continued integrity of barriers, gates, loading bay doors, etc., through which unauthorized removal of gross quantities of LEU could be effected.


Inspection of large vehicles leaving CAAs to ensure they are not used for unauthorized removal of a gross quantity of LEU.
Inspection of large vehicles leaving CAAs to ensure they are not used for unauthorized removal of a gross quantity of LEU.


Where procedures involve periodic patrols or inspections, the amount of time that would be required for an adversary to complete the removal of a gross quantity of LEU may be used to govern the interval between inspec- tions. For example, if a given number of a certain type of container of LEU would have to be individually loaded onto a truck in order to effect removal of a gross quantity of LEU and the time required for such loading is determined to be in excess of two hours, then a two-hour guard patrol of the given area would be considered to meet the earliness-of-detection guide- line for the subject material.
Where procedures involve periodic patrols or inspections, the amount of time that would be required for an adversary to complete the removal of a gross quantity of LEU may be used to govern the interval between inspections.
 
For example, if a given number of a certain type of container of LEU would have to be individually loaded onto a truck in order to effect removal of a gross quantity of LEU and the time required for such loading is determined to be in excess of 2 hours, then a 2-hour guard patrol of the given area would be considered to meet the earliness-of-detection guideline for the subject material.


A combination of these and perhaps other measures could satisfy the early detection criterion for gross theft of LEU if it could be shown that an external adversary could not obtain unauthorized access to the SNM without being detected by at least one intrusion alarm component.
A combination of these and perhaps other measures could satisfy the early detection criterion for gross theft of LEU if it could be shown that an external adversary could not obtain unauthorized access to the SNM without being detected by at least one intrusion alarm component.


b.  Early Detection of Minor Theft of LEU
2.
      The criteria for early detection of minor theft of LEU can be satisfied by a monitoring program that provides a sufficiently high probability of detection of one in a series of minor thefts so it is implausible that an adversary would be able to obtain in the aggregate a gross quantity of LEU.


Such a capability could beeprovided in whole, or in part, by the same monitoring program designed to detect gross theft. Additional measures that might be included in the monitoring program to protect against minor theft include the following:
Early Detection of Minor Theft of LEU
          Exit searches of non-licensee vehicles capable of transporting hand-carried quantities of LEU (on random or general basis).
The criteria for early detection of minor theft of LEU can be satisfied by a monitorihg program that provides a sufficiently high probability of detection of one in a series of minor thefts so it is implausible that an adversary would be able to obtain in the aggregate a gross quantity of LEU.'
                                      45                      0
Such a capability could be provided in whole, or in part; by the same monitoring program designed to detect gross theft.
 
Additional measures that might be included in the monitoring program to protect against minor theft include the following:  
Exit searches of nonlicensee vehicles capable of transporting hand-carried quantities of LEU (on a random or general basis).
5.59-47


Administrative control of materials removed from controlled areas where easily concealed or hand-carried items containing LEU are available.
Administrative control of materials removed from controlled areas where easily concealed or hand-carried items containing LEU are available.
Line 876: Line 1,858:
Item count inventories more frequent than those currently required under Part 70.
Item count inventories more frequent than those currently required under Part 70.


Procedures directing regular employees to be aware of unauthorized persons in their work areas and to report the presence of such persons to supervisory or security personnel.   (A coded badging program would support this measure.)
Procedures directing regular employees to be aware of unauthorized persons in their work areas and to report. the presence of such persons to supervisory or security personnel.
      *   Escorting of visitors and other unauthorized persons entering CAA.
 
(A coded badging program would support this measure.)  
*  
Escorting of visitors and other unauthorized persons entering CAAs.
 
*
Watchman patrols to detect unauthorized persons within the CAA.
 
*
SNM doorway monitors at all personnel access control points.
 
These are not required measures but illustrations of how the monitoring program for detecting gross theft of LEU may be extended to include the capa bility for early detection of minor theft of LEU.
 
One or more of these meas ures may be employed, but probably not all of them would be needed for any one installation.
 
3.
 
Early Detection of Theft of SSNM (SNM of low strategic significance other than LEU)
For facilities where it is necessary to protect against thefts of S[N4 of low strategic significance other than LEU (SSN!4),
earliness of detection is discussed in Section 2.1 of this chapter.
 
The physical protection system in this case may differ considerably from that designed to protect LEU.
 
The sites are likely to be small research-oriented facilities such as nonpower reactors and educational institutions.


*    Watchman patrols to detect unauthorized persons within the CAA.
Also, there is likely to be much less material available, and authorized access to it may be less frequent.


*    SNM doorway monitors at all personnel access control     points.
Detection devices such, as interior motion detector systems, balanced magnetic switches, etc.,
could be used to monitor relatively small CAAs where the number of established access control points is very limited.


These are not required measures, but illustrations of how the monitoring program for detecting gross theft of LEU may be extended to include the capa- bility for early detection of minor theft of LEU.    One or more of these meas- ures may be, employed, but probably not all of them would be needed for any one installation.
Procedures may also be used to protect against thefts of SS*M in this subcategory.


c.   Early Detection of Theft of SSNM (SNM of low strategic significance other than LEU)
Since watchman patrols inherently allow unguarded intervals during which an external adversary could conceivably obtain access to the CAA,
      For facilities where it is necessary to protect against thefts of SNM
remove a small amount of material, and leave before being discovered, the inspection procedure may (a) be sufficiently frequent to ensure an external adversary could. not complete a successful theft of the material during the unguarded intervals, (b) provide for an irrevocable indication of the CAA
of low strategic significance other than LEU (SSNM), earliness of detection is discussed in Section 2.1 of this chapter.    The physical protection system in this case may differ considerably from that designed to protect LEU.
barrier having been tampered with (as with a seal or by observation of damage done to the barrier), or (c) provide for an item count inventory or other accounting for the material as part of the inspection.


The sites are likely to be small research-oriented facilities such as non-power reactors and educational institutions.    Also, there is likely to be much less material available, and authorized access to i't may be less frequent.
Some examples are given below:
After having left material unattended in an experimental setup in a classroom used as a temporary CAA, the instructor returns after
2 hours and verifies that the material is still in place.


Detection devices such as interior motion detector systems, balanced magnetic switches, etc. could be used to monitor relatively small CAAs where the number of established access control points is very limited.
5.59-48


Procedures may also be used to protect against thefts of SSNM in this subcategory.    Since watchman patrols inherently allow unguarded intervals during which an external adversary could conceivably obtain access to the CAA, remove a small amount of material, and leave before being discovered, the inspection procedure may (a) be sufficiently frequent to ensure an external adversary could not complete a successful theft of the material during the unguarded intervals, (b) provide for an irrevocable indication of the CAA barrier having been tampered with (as with a seal or by observa- tion of damage done to the barrier), or (c) provide for an item count inventory or other accounting for the material *s part of the inspection.
A small quantity of material is stored in a security cabinet for several months at a time without authorized access.


Some examples are given below:
Every 2 hours a watchman comes around to inspect the cabinet to ensure that the lock is secure and the cabinet has not been tampered with.
          After having left material unattended in an experimental setup in a classroom used as a temporary CAA, the instructor returns after two hours and verifies that the material is still in place.


46
If a suitable combination or other pick-resistant lock is not used, the watchman also inspects a tamper-indicating seal to verify that the container, has not been tampered with.


A small quantity of material is stored in a security cabinet for several months at a time without authorized access. Every two hours a watchman comes around to inspect the cabinet to ensure that the lock is secure and the cabinet has not been tampered with.
During periods when a nonpower reactor is left unattended, a watchman.


If a suitable combination or other pick-resistant lock is not used, the watchman also inspects a tamper-indicating seal to verify that tde container has not been tampered with.
comes around every 2 hours and checks that none of the fuel elements have been removed by unauthorized persons.


During times when a non-power reactor is left unattended, a watch- man comes around every two hours and checks that none of the fuel elements have been removed by unauthorized persons. If he encounters a person working during off-hours in the vicinity of the reactor, he asks for appropriate identification.
If a person working during off-hours in the vicinity of the reactor is encountered, appropriate identification is requested.


While a non-power reactor is being utilized, the supervisor ensures that he or his designee is not away from the reactor for a period longer than thirty minutes, a period he estimates would be minimally required for a person to secure fuel elements in the core that were not self-protecting by virtue of their having been sufficiently irradiated.
While a nonpower reactor is being used, the supervisor ensures that he/she or his/her designee is not away from the reactor for a period longer than 30 minutes, a period he/she estimates would be minimally required for a person to secure fuel elements in the core that were not self-protecting by virtue of their having been sufficiently irradiated.


During periods when excess fuel is left unattended in a storage closet at a non-power reactor facility, an alarm system is activated that would annunciate if anybody tried to penetrate the closet without proper authorization.
During periods when excess fuel is left unattended in a storage closet at a nonpower reactor facility, an alarm system is activated that would annunciate if anybody tried to penetrate the closet without proper authorization.


During periods when the material is being used under the direct supervi- sion of authorized personnel, the monitoring requirement is satisfied by virtue of the continuous surveillance by the authorized personnel.
During periods when the material is being used under the direct supervi sion of authorized personnel, the monitoring requirement is satisfied by virtue of the continuous surveillance by the authorized personnel.


Content For each of the CAAs described previously (see Part II, Chapter 1, of this guide), provide the following information regarding the measures taken to fulfill the monitoring requirement of paragraph 73.67(f)(2):
Content For each of the CAAs described previously (see Chapter I of Part II of this guide), provide the following lnformatibn regarding the measures taken to fulfill the monitoring requirement of paragraph 73.67(f)(2):  
      1.    Describe any devices employed by specifying the type of device, its installed location, the type and location of annunciation, its intended area of coverage, and its tamper-resistant features.    Refer, if desired, to existing filed security plans or NRC-published guidance or NUREG series documents.
1.


2.    Describe any procedures employed to monitor the CAA or portions thereof, including the categories of persons who will execute the procedures, the frequency of inspections or rounds of patrol, the basis for the determina- tion of such frequencies, and the occasions upon which the procedures are intended to be implemented. Indicate, also, the features of the CAA (e.g.
Describe any devices employed by specifying the type of device, its installed location, the type and location of annunciation, its intended area of coverage, and its tamper-resistant features.


barriers, locks, seals, etc.) that will play a role in the way the procedures are used.
Refer, if desired, to existing.


3.    Explain how the combination of procedures and devices used to monitor each CAA meets the criteria for early detection of theft by an external adversary relative to the type of material found in each CAA.
filed security plans, regulatory guides, or NUREG documents.


47
2.


0
Describe any procedures employed to monitor the CAA or portions thereof, including the categories of persons who will execute the procedures,. 
                    3. SECURITY RESPONSE AT A FIXED SITE
the frequency of inspections or rounds of patrol, the basis for the determina tion of such frequencies, and the occasions upon which the procedures are intended to be implemented.
      This chapter provides guidance on meeting the requirement of paragraph
 
73.67(f)(3), which is as follows:
Also indicate the features of the CAA (e.g.,
                                                                01 (f)(3)     Assure that a watchman or offsite response force will respond to all unauthorized penetrations or activities.
barriers, locks, seals) that will play a role in the way the procedures are used.
 
3.
 
Explain how the combination of procedures and devices used to monitor each CAA meets the criteria for early detection of theft by an external adversary relative to the type of material found in each CAA.
 
5.59-49
 
3.
 
SECURITY RESPONSE AT A FIXED SITE
This chapter provides guidance on meeting the requirement of paragraph  
73.67(f)(3), which is as follows:  
(f)(3)  
Assure that a watchman or offsite response force will respond to all unauthorized penetrations or activities.
 
Intent The intent of this requirement is to ensure that, in the event of a security incident, someone will be available to assess alarms or any unauthor ized 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 facilitate its prompt recovery.
 
For the 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 that will be responsible. for assessing and responding to any unauthorized penetrations or activities.
 
Ensure that at least one guard, watchman, or member of an offsite response force will respond to all unauthorized penetrations or security Incidents at the CAAs.
 
5.59-50
 
4.
 
RESPONSE PROCEDURES AT A FIXED SITE
This chapter provides guidance on meeting the requirements of para graph 73.67(f)(4), which states:
if)(4)
Establish and maintain response procedures for dealing with threats of thefts or thefts of such material.


Intent The intent of this requirement is to ensure that, in the event of a security incident, someone will be available to assess alarms or any unauthor- ized penetrations or activities and, if warranted, notify the NRC, the local law enforcement authorities, and the responsible person in licensee management.
Intent The intent of this regulation is to help the licensee to identify those security incidents that could result in the loss of SNM of low strategic significance and to develop response procedures to prevent or reduce the likelihood of such a loss.


Early detection and notification of any missing material will help facilitate its prompt recovery. For the purpose of this regulation, an offsite response force can be a local law enforcement agency or a contract guard service.
Some types of incidents that should be considered and for which response procedures should be developed are:
1.


Content Describe the security organization that will be responsible for assessing and responding to any unauthorized penetrations or activities. Ensure that at least one guard, watchman, or member of an offsite response force will respond to all unauthorized penetrations or security incidents at the CAAs.
Situations that could possibly lead to theft of SNM (e.g., civil disturbance). 
2.


48
Discovery that the security system has been breached.


4.  RESPONSE PROCEDURES AT A FIXED SITE
3.
      This chapter provides guidance on meeting the requirements of para- graph 70.67(f)(4), which states:
(f)(4)    Establish and maintain response procedures for dealing with threats of thefts or thefts of such material.


Intent The intent of this regulation is to help the licensee to identify those security incidents that could result in the loss of SNM of low strat- egic significance and to develop response procedures to prevent or reduce the likelihood of such a loss. Some types of incidents that should be con- sidered and for which response procedures should be developed are:
Discovery that some SNM is missing.
      1.  Situations that could possibly lead to theft of SNM (e.g. civil disturbance).
      2.  Discovery that the security system has been breached.


3.  Discovery that some SNM is missing.
-Content Identify those events for which response procedures will be developed.


Content Identify those events for which response procedures will be developed.
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.


Also describe the type of response to be accomplished for each event identi- fied and the duties and responsibilities of the security organization and management involved in the response.    Ensure that the NRC will be notified immediately in the event of theft or attempted theft of the material.
Ensure 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 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 theft of the material.


49
5.59-51


5.  MATERIAL TRANSPORTATION REQUIREMENTS
5.
    This chapter provides guidance on meeting the requirements of paragraph
73.67(g)(1), which are as follows:
(g)(1)    Each licensee who transports or who delivers to a carrier for transport special nuclear material of low, strategic significance shall:
            (i)  Provide advance notification to the receiver of any planned shipments specifying 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 commencement of the planned shipment that the receiver will be. ready to accept the shipment at the planned time and location and 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 ship- ment, and (v)  Arrange for the in-transit physical protection of the material in accordance with the requirements of §73.67(g)(3) of this part, unless the receiver is a licensee and has agreed in writing to arrange for the in-transit physical protection.


5.1  Advance Notification [73.67(g)(1)(i)]
MATERIAL TRANSPORTATION REQUIREMENTS
Intent The intent of this paragraph is to require the shipper to preplan the transportation of the material and inform the receiver of his plans prior to shipment. This is the first of several transportation requirements that will allow the receiver to take delivery of the material as planned or to help ensure traceability of any missing material.
This chapter provides guidance on meeting the requirements of paragraph
73.67(g)(1), which are as follows:
(g)(1)  
Each licensee who transports or who delivers to a carrier for transport special nuclear material of low strategic significance shall:
(i) Provide advance notification to the receiver of any planned shipments specifying 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 commencement of the planned shipment that the receiver will be ready to accept the shipment at the planned time and location and acknowledges the specified mode of transport, (lii)
Transport the material in a tamper-indicating sealed container, (iv)
Check the integrity of the containers and seals prior to ship ment, and (v)
Arrange for the in-transit physical protection of the material in accordance with the requirements of S 73.67(g)(3) of this part, unless the receiver is a licensee and has agreed in writing to arrange for the in-transit physical protection.


Content The licensee should ensure that, prior to each shipment of material, the receiver will be notified of the impending shipment and provided the following types of information:
5.1 Advance Notification [73.67(g)(1)(i)]
      1.   Mode of transport (e.g.,  truck, plane, train, or ship),
Intent The intent of this paragraph is to require the shipper to preplan the transportation of the material and inform the receiver of his plans prior to shipment.
      2.    Estimated time of arrival,
      3.    Location where material is to be transferred to receiver,
      4.   Name of carrier, and
                                        50


5.   Transport identification (e.g.,  truck, train, or flight number;
This is the first of several transportation requirements that will..
          ship name).
allow the receiver to take delivery of the material as planned or to help ensure traceability of any missing material.
                5.2    Receiver Confirmation [73.67(g)(1)(ii)]
Intent The intent of this requirement is that, prior to shipment, the trans- porter will be assured that the receiver is ready to accept the shipment at the planned time and location and has acknowledged the mode of transport.


Content Describe what procedures will beused to ensure that shipment of mate- rial does not take place until the receiver acknowledges the planned shipment and mode of transport and states that he will be ready to accept the shipment at the planned time and location.
Content The licensee should ensure that, prior to each shipment of material, the receiver will be notified of the impending shipment and provided the following types of information:
1.


5.3 Container [73.67(g)(1)(iii)]
Mode of transport (e.g., truck, plane, train, or.ship),
Intent The intent of this requirement is to provide a mechanism or system that will help the receiver detect any tampering with the material's container that may have occurred during shipment.     Regulatory Guide 5.15, "Security Seals for the Protection and Control of Special Nuclear Material," provides guidance in this area.     If the material is shipped in an exclusive-use carrier, it is acceptable to tamper-seal the carrier itself rather than each individual SNM container.
2.
 
Estimated time of arrival,
3.
 
Location where material is to be transferred to receiver,
4.
 
Name of carrier, and
5.
 
Transport identification (e.g., truck, train, or flight number; ship name).
5.59-52
 
5.2 Receiver Confirmation [73.67(g)(1)(ii))
Intent The intent of this requirement is that, prior to shipment, the transporter will be assured that the receiver is ready to accept the shipment at the planned time and location and has acknowledged the mode of transport.. 
Content Describe what procedures will be used to ensure that shipment of material does not take place until the receiver acknowledges the planned shipment and mode of transport and readiness to accept the shipment at the planned time and location.
 
5.3 Container [73.67(g)(1)(iii)]  
Intent The intent of this requirement is to provide a mechanism or system that will help the receiver detect any tampering with the material's container that may have occurred during shipment.
 
Regulatory Guide 5.15, "Security Seals for the Protection and Control of Special Nuclear Material," provides guidance in this area.
 
If the material is shipped in an exclusive-use carrier, it is acceptable to tamper-seal the carrier itself rather than each individual SN5 container.


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


5.4 Inspection [73.67(g)(1)(iv)]
5.4 Inspection [73.67(g)(1)(iv))
Intent The intent of this paragraph is to require the shipper to check the integrity of the material container's seals just prior to shipment so that he can be assured that they have not been compromised. Then, upon receipt of the shipment, if the receiver discovers the container's integrity has been compromised and the material is missing, the scope of the recovery operation can focus on the transportation route.
Intent The intent of this paragraph is to require the shipper to check the integrity of the material container's seals just prior to shipment so as to be assured that they have not been compromised.
 
Then, upon receipt of the shipment, if the receiver discovers the container's integrity has been compromised and the material is missing, the scope of the recovery operation can focus on the transportation route.
 
Content
. 
Describe the procedures to be used to ensure that the integrity of the containers or seals is checked just prior to shipment.
 
5.59-53
 
5.5 Responsibility for In-Transit Physical Protection [73.67(g)(1)(v)]
Intent The intent of this paragraph is to make clear that the licensee'shipping the material is responsible for arranging for the physical protection of the material in transit if the receiver is not a licensee.
 
If both the shipper and receiver are licensees, the shipper may allow the receiver to accept this responsibility wholly or in part provided there is appropriate documentation specifying their respective responsibilities.
 
Where no such documentation exists, both the shipper and receiver are held jointly responsible.
 
(See Section 6.3 of PartlII of this guide.)
Content In its security plan, the shipper should either acknowledge responsibility for the in-transit physical protection of SNM of low strategic significance or ensure that a written agreement from the receiver has been received in which the receiver accepts either full responsibility or shared responsibility for the in-transit physical protection of this material in accordance with paragraph 73.67(g)(3) of 10 CFR Part,73.
 
5.59-54
 
6.


Content Describe the procedures to be used to ensure that the integrity of the containers or seals is checked just prior to shipment.
RECEIVER REqUIREMENTS--TRANSPORTATION
This chapter, provides guidance on meeting the requirements of paragraph
73.67(g)(2), which are as follows:
(g)(2)
Each licensee who receives quantities and types of special nuclear material of low strategic significance shall:
(i)
Check the integrity of the containers and seals upon receipt of the shipment, (ii)
Notify the shipper of receipt of the material as required in'
§ 70.54 of Part 70 of this chapter, and (iii) Arrange for the in-transit physical protection of the material in accordance with the requirements of paragraph 73.67(g)(3) of this part, unless the shipper is a licensee and has agreed in writing to arrange for the in-transit physical protection.


51
6.1 Inspection [73.67(g)(2)(i)]
Intent This requirement is intended to determine whether the material's container has been compromised en route and whether any material has been removed so that immediate recovery procedures can be initiated if required.


5.5    Responsibility for In-Transit Physical Protection [73.67(g)(1)(v)]
Content Describe the procedures to be used to ensure that the integrity of the containers and seals will be checked upon receipt of the material shipment.
Intent The intent of this paragraph is to make clear that the licensee shipping the material is responsible for arranging for the physical protection of the material in transit if the receiver is not a licensee.      If both the shipper and receiver are licensees, the shipper may allow the receiver to accept this responsibility wholly or in part provided there is appropriate documentation specifying their respective responsibilities. Where no such documentation exists, both the shipper and receiver are held jointly respon- sible. (See Section 6.3 in the next chapter.)
Content In his security plan, the shipper should either acknowledge responsibil- ity for the in-transit physical protection of SNM of low strategic signif- icance .or ensure that a written agreement from the receiver has been received in which the receiver accepts either full responsibility or shared respon- sibility for the in-transit physical protection of this material in accordance with paragraph 73.67(g)(3) of 10 CFR Part 73.


0
6.2 Notification [73.67(g)(2)(ii)]
                                      52
Intent This requirement is intended to ensure that knowledge of the current location of all SNM is available and to formally inform the shipper that the material has been received.


6.  RECEIVER REQUIREMENTS--TRANSPORTATION
Content Ensure that a completed copy of Form NRC-741, "Nuclear Material Transac tion Report," will be sent to the shipper within 10 days after a material shipment has been received as required in § 70.54 of 10 CFR Part 70.
    This chapter provides guidance on meeting the requirements of paragraph
73.67(g)(2), which are as follows:
(g)(2)      Each licensee who receives quantities and types of special nuclear material of low strategic significance shall:
            (i)  Check the integrity of the containers and seals upon receipt of the shipment, (ii)  Notify the shipper of receipt of the material as required in
                §70.54 of Part 70 of this chapter, and (iii)  Arrange for the in-transit physical protection of the material in accordance with the requirements of paragraph 73.67(g)(3)
                of this part, unless the shipper is a licensee and has agreed in writing to arrange for the in-transit physical protection.


6.1  Inspection [73.67(g)(2)(i)]
6.3 Responsibilit for In-Transit Physical Protection L73.67(g)2)ttt)  
Intent This requirement is intended to determine whether the material's con- tainer has been compromised enroute and whether any material has been removed so that immediate recovery procedures can be initiated if required.
Intent The intent of this paragraph is to make clear that the licensee receiving the material is responsible for arranging for the physical protection of the
5.59-55


Content Describe the procedures to be used to ensure that the integrity of the containers and seals will be checked upon receipt of- the material shipment.
material in transit if the shipper is not a licensee.


6.2  Notification [73.67(g)(2)(ii)]
If both the shipper and receiver are licensees, the receiver may allow the shipper to accept.thls respon sibility either wholly or in part provided there is appropriate documentation specifying their respective responsibilities.
      This requirement is intended to:
      1.    Ensure that knowledge of the current location of all SNM is avail- able, and
      2.    Formally inform the shipper that the material has been received.


Content Ensure that a completed copy of Form NRC-741, "Nuclear Material Transac- tion Report," will be sent to the shipper within 10 days after a material shipment has been received as required in §70.54 of 10 CFR Part 70.
Where no such-documentation exists, both the shipper and receiver are held jointly responsible.


6.3    Responsibility for In-Transit Physical Protection [73.67(g)(2)(iii)]
(See Section 5.5 of Part II of this guide.)  
Intent The intent of this paragraph is to make clear that the licensee receiving the material is responsible for arranging for the physical protection of the material in transit if the shipper is not a license
Content In its security plan, the receiver should either acknowledge responsibil ity for the in-transit physical protection of SNM of low strategic significance or ensure that a written agreement from the shipper has been received in which the shipper accepts either full responsibility or shared responsibility for the in-transit physical protection of this material in accordance with paragraph
73.67(g)(3) of 10 CFR Part 73.


====e. If both the shipper====
5.59-56
                                          53


and receiver are licensees, the receiver may allow the shipper to accept this responsibility either wholly or in part provided there is appropriate documentation specifying their respective responsibilities. Where no such documentation exists, both the shipper and receiver-are held jointly respon- sible. (See Section 5.5 in the preceding chapter).
7.
Content In his security plan, the receiver should either acknowledge responsibil- ity for the in-transit physical protection of SNM of low strategic significance or ensure that a written agreement from the shipper has been received in which the shipper accepts either full responsibility or shared responsibility for the in-transit physical protection of this material in accordance with paragraph 73.67(g)(3) of 10 CFR Part 73.


54
IN-TRANSIT PHYSICAL PROTECTION REQUIREMENTS
This chapter provides guidance on meeting the requirements of paragraph
73.67(g)(3), which are'as follows:
(g)(3)
Each licensee, either shipper or receiver, who arranges for the physical 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 point at which ItAis delivered to a carrier for transport shall:
(i)
Establish and maintain response procedures for dealing with threats 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 time of arrival at its destination, and (iii) Conduct immediately a trace investigation of any shipment that is lost or unaccounted for after the estimated arrival time and report to the Nuclear Regulatory Commission as specified in
§ 73.71 and to the shipper or receiver as appropriate.


7.  IN-TRANSIT PHYSICAL PROTECTION REQUIREMENTS
The licensee who made theiphysical protection arrangements shall also immediately notify the Director of the appropriate Nuclear Regulatory Commission Regional Office listed in Appendix A of the action being taken to trace the shipment.
      This chapter provides guidance on meeting the requirements of paragraph
73.67(g)(3), which are as follows:
(g)(3)      Each licensee, either shipper or receiver, who arranges for the physical protection of special nuclear material of low strategic significance while in transit or who takes delivery of such mate- rial free on board (f.o.b.) the point at which it is delivered to a carrier for transport shall:
            (i)  Establish and maintain response procedures for dealing with threats 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 time of arrival at its destination, and (iii)  Conduct immediately a trace investigation of any shipment that is lost or unaccounted for after the estimated arrival time and report to the Nuclear Regulatory Commission as specified in §73.71 and to the shipper or receiver as appro- priate.    The licensee who made the physical protection arrangements shall also immediately notify the Director of the appropriate Nuclear Regulatory Commission Inspection and Enforcement Regional Office listed in Appendix A of the action being taken to trace the shipment.


7.1   Response Procedures [73.67(g)(3)(i)]
7.1 Response Procedures [73.67(g)(3)(i)]  
Intent The intent of this regulation is to help the licensee identify those transportation incidents that could affect the security of the SNM in transit for which he might expect to be notified and for which response procedures should be planned.
Intent The intent of this regulation is to help the licensee identify those transportation incidents that could affect the security of the SNM in transit for which notification might be expected and for which response procedures should be. planned.


Content Identify those events for which response procedures will be developed.
Content Identify those events for which response procedures will be developed.


Also describe the type of response to be accomplished for each event identi- fied and the duties and responsibilities of the security organization and management involved in the response. Ensure that the NRC will be notified immediately in the event of theft or attempted theft of the material.
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.


7.2  Notification [73.67(g)(3)(ii)]
Ensure that the NRC will be notified immediately in the event-pf theft or attempted theft of the material.
Intent The intent of this requirement is to ensure that the licensee respon- sible for the physical protection of SNM in transit will have a firm basis for deciding whether or not to initiate response procedures in the event a shipment becomes overdue or is lost.


55
7.2 Notification t73.67(g)(3)(ii)]
Intent The intent of this requirement is to ensure that the licensee responsible for the physical protection of SNM in transit will have a firm basis for deciding whether or not to initiate response procedures in the event a shipment becomes overdue or is lost.


Content Describe the arrangements and procedures that will be used for notifying the licensee who arranges for the physical protection of material in transit
5.59-57
 
Content Describe the arrangements and procedures that will be used for notifying the licensee who arranges for the physical protection of material in transit  
(1) of the arrival of the shipment at its destination or (2) of any such shipment that is lost or unaccounted for after the estimated time of arrival at its destination.
(1) of the arrival of the shipment at its destination or (2) of any such shipment that is lost or unaccounted for after the estimated time of arrival at its destination.


7.3   Lost Material Notification [73.67(g)(3)(iii)]
7.3 Lost Material Notification [73.67(g)(3)(iii)]  
      The intent of this requirement is to ensure that, in the event a ship- ment becomes overdue and no reasonable explanation has been received from the carrier regarding its status, a trace investigation will be conducted to locate the missing SNM. At this time, the NRC should be notified that the material is missing and informed as to what steps are being taken to recover it.    Although the licensee is responsible for notifying the NRC of any missing material and for initiating and assisting in the subsequent investigation, the law enforcement agencies bear the responsibility for physically recovering the material.
The intent of this requirement is to ensure that, in the event a shipment becomes overdue and no reasonable explanation has been received from the carrier regarding its status, a trace investigation will be conducted to locate the missing SN4.


Content Describe what procedures will be used to trace any shipment that is lost or has not arrived by the estimated arrival time. Ensure that all lost or missing material will be immediately reported to the appropriate NRC
At this time, the NRC should be notified that the material is missing and informed as to what steps are being taken to recover it. Although the licensee is responsible for notifying the NRC of any missing material and for initiating and assisting in the subsequent investigation, the law enforcement agencies bear the responsibility for physically recovering the material.
Regional Office along with what actions are being taken to trace the shipment, that the NRC will be notified as specified in §73.71, and that the shipper or receiver, as appropriate, will also be notified.


56
Content Describe what procedures will be used to trace any shipment that is lost or has not arrived by the estimated arrival time.


===8. EXPORT REQUIREMENTS===
Ensure 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 the shipment, that the NRC will be notified as-specified in S 73.71, and that the shipper or receiver, as appropriate, will also be notified.
    This chapter provides guidance on meeting the'requirements of paragraph
73.67(g)(4), which reads as follows:
(g)(4)    Each licensee who exports special nuclear material of low strategic significance shall comply with the appropriate requirements speci- fied in §73.67(c), (g)(1) and (g)(3).
      Use Chapters 5 and 7 of Part II of this Standard Format to describe the security procedures that will be used to protect the material up to the point where the receiver accepts physical protection responsibility for the shipment.


57
5.59-58


===9. IMPORT REQUIREMENTS===
8.
      This chapter provides guidance on meeting the requirements of paragraph
73.67(g)(5), which reads as follows:
(g)(5)      Each licensee who imports special nuclear material of low strategic significance shall:
            (i)  Comply with the requirements specified in §73.67(c), (g)(2)
                and (g)(3), and (ii)  Notify the person who delivered the material to a carrier for transport of the arrival of such material.


9.1  Security Requirements [73.67(g)(5)(i)]
EXPORT REQUIREMENTS
      Use Chapters 6 and 7 of Part II of this Standard Format to describe the security procedures that will be used to protect the material from the first point where the shipment is picked up.
This chapter provides guidance on meeting the requirements of paragraph
73.67(g)(4), which reads as follows:
(g)(4)
Each licensee who exports special nuclear material of low strategic significance shall comply with the appropriate requirements specified in § 73.67(c), (g)(1) and (g)(3). 
Using Chapters 5, "Material Transportation Requirements," and 7,
"In-Transit Physical Protection Requirements," of Part II of this Standard Format, describe the security procedures that will be used to protect the material up to the point where the receiver accepts physical protection responsibility for the shipment.


9.2 Notification [73.67(g)(5)(ii)]
5.59-59
 
9.
 
IMPORT REQUIREMENTS
This chapter provides guidance on meeting the requirements of paragraph
73.67(g)(5), which reads as follows:
(g)(5)
Each licensee who imports special nuclear material of low strategic significance shall:
(i)
Comply with the requirements specified in § 73.67(c), (g)(2) and (g)(3), and (ii) Notify the person who delivered the material to a carrier for transport of the arrival of such material.
 
9.1 Security Requirements [73.67(q)(5)(l)1 Using Chapters 6, "Receiver Requirements--Transportation," and 7,
"In-Transit Physical Protection Requirements," of Part II of this.Standard Format, describe the security procedures that will be used to protect the material from the first point where the shipment is picked up.
 
9.2 Notification [73.67(g)(5)(ii)]  
Intent The intent of this regulation is to ensure that the exporter is notified that the material has arrived safely.
Intent The intent of this regulation is to ensure that the exporter is notified that the material has arrived safely.


Content Describe the procedures to be used for notifying the exporter of the material that the shipment was received.
Content Describe the procedures to'be used for notifying the exporter of the material that the shipment was received.
 
5.59-60


58
VALUE/IMPACT STATEMENT
A separate value/impact analysis has not been prepared for this regulatory guide.


VALUE/IMPACT ASSESSMENT
The guide was developed to provide a standard format and content for the physical security plans that licensees authorized to possess or transport special nuclear material of moderate strategic significance or 10 kilograms or more of material of low strategic significance are required to submit by amendments to Part 73 of the Commission's regulations published July 24, 1979  
      A separate value/impact analysis has not been prepared for this regula- tory guide. The guide was developed to provide a standard format and content for the physical protection plans that licensees authorized to possess or transport special nuclear material of moderate strategic significance or 10
(44 FR 43280).  
kilograms or more of material of low strategic significance are required to submit by amendments to Part 73 of the Commission's regulations published July 24, 1979 (44 FR 43280).   A value/impact analysis prepared for the amendments was made available in the Commission's Public Document Room at the time the amendments were published. This analysis is also appropriate to this regulatory guide.
A value/impact analysis prepared for the amendments was made available in the Commission's Public Document Room at the time the amendments were published.


59
This analysis is also appropriate to this regulatory guide.
 
59-61
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Latest revision as of 02:11, 17 January 2025

Rev 1, (Task SG 229-4) Standard Format and Content for a Licensee Physical Security Plan for the Protection of Special Nuclear Material of Moderate or Low Strategic Significance
ML003739253
Person / Time
Issue date: 02/28/1983
From:
Office of Nuclear Regulatory Research
To:
References
RG-5.59
Download: ML003739253 (69)
v • d • e


U.S. NUCLEAR REGULATORY COMMISSION

Revision 1 February 1983 REGULATORY GUIDE

OFFICE OF NUCLEAR REGULATORY RESEARCH

REGULATORY GUIDE 5.59 (Task SG 2294)

STANDARD FORMAT AND CONTENT

FOR A'LICENSEE PHYSICAL SECURITY PLAN

FOR THE PROTECTION OF SPECIAL NUCLEAR MATERIAL

OF MODERATE OR LOW STRATEGIC SIGNIFICANCE

USNRC REGULATORY GUIDES

Regulatory Guides are issued to describe and maie available to the public methods acceptable to the NRC staff of Implementing specific parts of the Commission's regulations, to delineate tech niques used by the stiff in evaluating specific problems or 'postu lated accidents or to provide guidance to app Icants. Regu*atory Guides are noQ substitutes for regulations, and aompllance with them Is not required. Methods and solutions different from those set out In the guides will be acceptable If they Provide a basis for the indings requisite to the Issuance or continuance of a permit or license by the Commission.

This guide was Issued after consideration of comments received from the pubiic. Comments and suggestions for Improvements In these guides are encouraged at all times, and guides will be revised, as appropriate, to accommodate comments and to reflect new Informa tion or experience.

Comments should be sent to the Secretary of the Commision, U.S. Nuclear Regulatory Commission Washington, D.C. 2055n, Attentlon: Docketing and Service BraIncn.

The guides are Issued In the following ten broad divisions:

2. Power Reactors

6. Products L Research and Test Reactors

7. Transportation

3. Fuels and Materials Facilities IL Occupational Health

4. Environmental and Siting

9. Antitrust and Financial Review

5. Materials and Plant Protection 20. General Copies of issued guides may be Purchased at the current Government Printing 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 may be obtained by writing the U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, Attentiont Publications Sales Manager.

TABLE OF CONTENTS

INTRODUCTION ..........................................................

PART I

SPECIAL NUCLEAR MATERIAL OF MODERATE STRATEGIC

SIGNIFICANCE .......................................

Chapter 1 USE AND STORAGE AREA AT A FIXED SITE .......................

1.1 Area Where Material Is Used

......................

1.2 Area Where Material Is Stored .....................

Chapter 2 DETECTION DEVICES AND PROCEDURES AT A FIXED SITE..........

2.1 Earliness of Detection........................

2.2 Detection Through Monitoring Controlled Access Areas...

Chapter 3 ACCESS CONTROL AT A FIXED SITE ..............................

3.1 Preauthorization Screening ..........................

3.2 Badging System .....................................

3.3 Lock System...............

3.4 Personnel EntryControlSystem.

3.5 Escort System .................

.................

3.6-Search ........

..............................

Chapter 4 SECURITY ORGANIZATION AT A FIXED SITE.................

Chapter 5 COMMUNICATIONS AT A FIXED SITE

.......................

Chapter 6 RESPONSE PROCEDURES AT A FIXED SITE ........................

-.Chapter 7 MATERIAL TRANSPORTATION REQUIREMENTS .......................

7.1 Advance Notification to Receiver .......................

7.2 Receiver Confirmation..

7.3 Inspection .............

.......................

7.4 Responsibility for In-Transit Physical Protection ......

Chapter 8 RECEIVER REQUIREMENTS--TRANSPORTATION ......................

.8.1 Inspection ..............................................

8.2 Notification to Shipper..........................

8.3 Responsibility for In-Transit Physical Protection ......

iii Pane vii

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TABLE OF CONTENTS (Continued)

Chapter 9 Chapter I

Chapter Chapter

1 I

Chapter 1 PART II

Chapter 1 Chapter 2 Chapter 3 Chapter 4 Chapter IN-TRANSIT PHYSICAL PROTECTION REQUIREMENTS ................

9.1 Communications ....................

...................

9.2 Minimum Transit Times ..................................

9.3 Preauthorization Screening .............................

9.4 Response Procedures

..............................

9.5 Notification ...................................

........

9.6 Lost Material Notification ...... , ...................

9.7 NRC Notification ................

.................

0, TRANSFER AND CONTROL REQUIREMENTS... ..........

10.1 Carrier Transfers .......

......................

10.2 Control of Shipments ...............................

1 EXPORT REQUIREMENTS .......................................

2 IMPORT.REQUIREMENTS ...............

................

12.1 Security Requirements .................

12.2 Notification .........................

.......

.3 ORDERS TO DELAY SSNM SHIPMENTS .............................

13.1 Notification of Receipt of SSNM .....................

SPECIAL NUCLEAR MATERIAL OF LOW STRATEGIC SIGNIFICANCE .......

USE AND STORAGE AREA AT A FIXED SITE.......................

1.1 Areas for Use and Temporary Storage ....................

1.2 Areas for Permanent Storage ............................

DETECTION DEVICES AND PROCEDURES AT A FIXED SITE ...........

2.1 Earliness of Detection......................

2.2 Monitoring Controlled AccessAreas. ...............

3 SECURITY RESPONSE AT A FIXED SITE

...............

RESPONSE PROCEDURES AT A FIXED SITE.............

5 MATERIAL TRANSPORTATION REQUIREMENTS ......................

5.1 Advance Notification ...............................

5.2 Receiver Confirmation ................

..................

5.3 Container ..........................

.

................

5.4 Inspection .........................................

...

5.5 Responsibility for In-Transit Physical Protection.....

iv Page

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TABLE OF CONTENTS (Continued)

Chapter 6 Chapter 7 Chapter 8 Chapter 9 RECEIVER REQUIREMENTS--TRANSPORTATION ......................

6.1 Inspection ....................................

6.2 Notification ....................

6.3 Responsibility for In-Transit Physical Protection ......

IN-TRANSIT PHYSICAL PROTECTION REQUIREMENTS................

7.1 Response Procedures ....................................

7.2 Notificatipn.................................

..........

7.3 Lost Material Notification .............................

EXPORT REQUIREMENTS ........................................

IMPORT REQUIREMENTS ........................

...............

9.1 Security Requirements ..................................

9.2 Notification ...........................................

VALUE/IMPACT STATEMENT ................................................

V

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INTRODUCTION

The Atomic Energy Act of 1954, as amended, directed the U.S. Atomic Energy Commission (AEC)*to regulate the receipt, manufacture, production, transfer.

possession, use, import, and export of special nuclear material (SNM)

in order to protect the public health and safety and to provide for the common defense and security.

The Energy Reorganization Act of 1974 transferred all thd licensing and related regulatory functions of the AEC to the Nuclear Regulatory Commission (NRC).

The principal requirements with'respect to the physical protection of licensed activities against industrial sabotage and with respect to the phys ical protection of special nuclear material in transit are found in 10 CFR

Part 50, "Domestic Licensing of Production and Utilization Facilities"; Part

70, "Domestic Licensing of Special Nuclear Material"; Part 73, "Physical Protection of Plants and Materials"; and Part 110, "Export and Import of Nuclear Equipment and Materials."

Paragraph 50.34(c) of 10 CFR Part 50 and paragraphs 70.22(g), 70.22(h),

and 70.22(k) of 10 CFR Part 70 identify the physical protection information that must be provided in a physical security plan as part of a license appli cation.

This plan is required in Order for the applicant to demonstrate compliance with the specific physical protection requirements of 10 CFR Part 73 and must be submitted with each application for a license to possess or use SIM

(or for a license authorizing transport or delivery of SNM), except for a license to possess, use, or transport less than 10 kg of SiM of low strategic significance, in which case a physical security plan is not required.

However, for the protection of SNM of low strategic significance, the licensee is required to meet the requirements of § 73.67, "Licensee Fixed Site and In-Transit Requirements for the Physical Protection of Special Nuclear Material

Any guidance in this document related to information collection activities has been cleared under OMB Clearance Nos. 3150-0002, 3150-0009, and 3150-0011.

This regulatory guide describes the information required in the physical security plan submitted as part of an application .for a license to possess, use, or transport SNM of moderate strategic significance or 10 kg or more of SNM of low strategic significance and recommends a standard format for presenting the information in an orderly arrangement.

This standard format will thus serve as an aid to uniformity and completeness in the preparation and review of the physical security plan of the license application.

This document can also be.used as guidance by licensees possessing or transporting less than

10 kg of SNM of low strategic significance in understanding the Intent and implementing the requirements of paragraphs 73.67(a), 73.67(f), and 73.67(g) of

10 CFR Part 73.

Aside from providing guidance for the standard format and content of physical security plans, this regulatory guide explains the intent of the various provisions of the regulation.

The intent of each requirement is found in the discussion of each subsection and is implicitly provided by outlining alternative systems that could be used to fulfill the requirements.

The vii

discussion section and list of alternatives should provide the licensee with the sense of the NRC regulations.

This guide is divided into two parts.

Part I,-"Special Nuclear Material of Moderate Strategic Significance," provides a standard format for preparing the licensee's security plans and provides guidance to licensees who possess, use, or transport SNM of moderate strategic significance.

Chapters 1 through 6 of Part I apply to applications for a license to possess or use at any'fixed site, or at contiguous sites subject to control by the licensee, SNM of moderate strategic significance.-

Chapters'7 through 13 of Part I apply to applications for authorization to transport or deliver to a carrier for transport SN! of moderate strategic significance.

Part 1I, "Special Nuclear Material of Low Strategic Significance," pro vides a standard format for preparing the licensee's security plan for licensees who possess, use, or transport more than 10 kg of SNM of low strategic significance.

It also provides guidance to all licensees who possess, use, or transport SNM of low strategic significance.

Chapters 1 through 4 of Part II apply to applications for a license to possess or use at any fixed-site, or at contiguous sites subject to control by the licensee, more than 10 kg of SNM of low strategic significance.

Included in this category are licensees who have nuclear power reactors under construction and are seeking a license to possess nuclear fuel onsite prior to obtaining their operating license.

Chapters 5 through 9 of Part II apply to applications for authorization to transport or deliver to a carrier for transport more than

10 kg of SNH of low strategic significance.

Table 1 shows the type and amount of SN4 covered in § 73.67 of 10 CFR

Part 73.

It should be noted, as stated in the footnote to Table 1, that (1)

plutonium with an isotopic concentration exceeding 80 percent or more in Pu-238, (2) special ndulear material that is not readily separable from other radioactive material and that has a total external radiation dose rate in excess of 100 rems per hour at a distance of 3 feet from any accessible surface without intervening shielding, and (3) sealed plutonium-beryllium neutron sources totaling 500 grams or less of contained plutonium at any one site or contiguous sites are exempt from the requirements of S 73.67 of 10 CFR Part-73.

This guide has been prepared to minimize time lost because of incomplete physical security plans and to standardize the review process.

Applicants are encouraged to prepare their physical security plans in accordance with this guide and to provide information in each section to support the conclusion that they will be able to operate in accordance with the pertinent regulations.

Although conformance with this guide is not required, the format and content presented are acceptable to the NRC staff.

As developments and changes in the nuclear industry, 9ccur, the Commis sion's requirements for information may need modification; revisions to this guide will be made as necessary to accommodate these changes.

Purpose and Applicability This standard format has been prepared as an aid to uniformity and com pleteness in the preparation and review of the physical protection section of license applications and to clarify the Intent of the regulations.

The viii

Table 1 CATEGORIES OF SPECIAL NUCLEAR MATERIAL

MODERATE STRATEGIC

Low STRATEGIC

MATERIAL*

ENRICHMENT

SIGNIFICANCE

SIGNIFICANCE

1.

Plutonium

2.

Uranium,235

20% or more in U-235 isotope

10% or more but less than 20%

in U-235 isotope Above natural but less than

10%

Less than 2,000 g but more than-500 g Less than 5,000 g but more than 1,000 g

10,000 g or more

500 g or less but more than 15 g

1,000 g or less but more than 15 g Less than 10,000 g but more than 1,000 g

10,000 g or more

3.

Uranium-233

4.

Uranium-235, uranium-233, and pluton ium in com bination U-235 portion enriched to 20%

or more.

Less than 2,000 g but more than 500 g Less than 5,000 g according to the formula:

grams =

(grams contained U-235) +

2.5 (grams U-233 + grams plutonium) but more than

1,000 g according to the formula:

grams = (grams U-235) + 2.0 (grams U-233

+ grams plutonium)

500 g or less but more than 15 g

1,000 g or less according to the formula:

grams =

(grams contained U-235)-+

2.0 (grams U-233 + grams plutonium) but more than 15 g according to the formula:

grams =

grams, contained U-235 +

grams U-233 + grams olutonium.

  • The following materials are exempt:

1.

Special nuclear material that is not readily separable from the radioactive material and that has a total external radiation dose rate in excess of 10Q rems per hour at a distance of 3 feet from any accessible surface without intervening shielding,

2. Plutonium with an isotopic concentration of 80 percent or more in Pu-238, and

3. Sealed plutonium-beryllium neutron sources totaling 500 grams or less of contained plutonium at any one site or contiguous sites.

t

information this guide contains will help the licensee plan a physical pro tection system designed to detect the theft of SNM of moderate or low strategic significance.

The physical protection subsystems identified are those that will usually be included in a protection system that would normally be capable of meeting the performance requirements of paragraph 73.67(a) of 10 CFR

Part 73. However, it is recognized that at any particular site there may be some subsystems and components not needed or additional ones needed to meet these performance requirements.

In these cases, applicants are encouraged to address in the license application specific departures of subsystems or components from this guide.

The information requested in this guide is the minimum needed for the review of a physical security plan.

Additional information may be required for completing the staff review of a particular plan and should be included as appropriate.

It is also the applicant's responsibility'to be aware of new and revised NRC regullations.

The information provided should be up to date with respect to the state of technology for the physical protection techniques and systems that the applicant proposes to use.

In cases where NRC-approved security plans are already in existence and where the measures included therein meet or exceed the requirements of § 73.67 of 10 CFR Part 73, licensees may reference in their proposed security plans those sections of the NRC-approved security plans that are applicable.

Information and procedures delineated in the regulatory guides in Divi sion 5, "Materials and Plant Protection," that are appropriate to certain sec tions of the physical security plan may be incorporated by reference.

Applicants should discuss their plans and programs with the NRC staff before preparing the applications.

These discussions should give particular emphasis to the depth of infoimation required for the plans..

.Upon receipt of an application, the NRC staff will perform a preliminary review to determine whether the application provides a reasonably complete presentation of the information needed to form a basis for the findings required before issuance of a license.

The standard format will be used by the staff, as a guideline for identifying the type of information needed.

If an application does not provide a reasonably complete presentation of the necessary information, further review of an application will be suspended until this needed information is provided.

Use of Standard Format The applicant should follow the numbering system of the Standard Format down to the'level of section (e.g., 3.4).

Under some circumstances, certain sections may not be applicable to a specific application.

If so, this should be clearly stated and sufficient information should be provided to support that conclusion.

The applicant may wish to submit in support of the application information that is not required by regulations and is not essential to the description of the applicant's physical protection program.

Such information could include, for example, historical data submitted in demonstration of certain criteria, discussion of alternatives considered by the applicant, or supplementary data x

regarding assumed models, data, or calculations.

This information should be provided as an appendix to the application.

Upon completion of the application, the applicant should use the Table of Contents of the Standard Format as a checklist to ensure that each subject has been addressed.

Style and Composition A table of contents should be included in each submittal.

The applicant should strive for clear, concise presentation of informa tion.

Confusing or ambiguous statements and general statements of intent should be avoided.

Definitions and abbreviations should be consistent through out the submittal and consistent with generally accepted usage.

Wherever possible, duplication of information should be avoided.

Thus, information already included in other sections of the applications may be covered by specific reference to those sections.

Where numerical values are stated, the number of significant figures should reflect the accuracy or precision to which the number is known.

The use of relative values should be clearly Indicated.

Drawings, diagrams, and tables should be used when information may be presented more adequately or conveniently by such means.

These illustrations should be located in the section where they are first referenced.

Care should be taken to ensure that all information presented in-drawings is legible, that symbols are defined, and that drawings are not reduced to the extent that they cannot be read by unaided normal eyes.

Physical Specifications of Submittals All material submitted in an application should conformnto the following physical dimensions of page size, quality of paper and inks, numbering of pages, etc.:

1.

Paper Size Text pages:

8-1/2 x 11 inches.

Drawings and graphics:

8-1/2 x 11 inches preferred; however, a larger size is acceptable provided the finished copy when folded does not exceed

8-1/2 x 11 Inches.

2.

Paper Stock and Ink Suitable quality in substance, paper color, and ink density for handling and for reproduction by microfilming.

3.

Page Margins A margin of no less than 1 inch is to be maintained on the top, bottom, and binding side of all pages submitted.

xi

4.

Printing Composition:

text pages should be single spaced.

Type face and style:

must be suitable for microfilming.

Reproduction:

may be mechanically or photographically reproduced.

All pages of the text may be printed on both sides, and images should be printed head to head.

5.

Binding Pages should be punched for looseleaf ring binding.

6.

Page Numbering Pages should be numbered by section and sequentially within the section.

Do not number the entire report sequentially.

(This entire Standard Format has been numbered sequentially because the Individual chapters were too short for sequential numbering within each section to be meaningful.)

7.

Format References In the application, references to this Standard Format should be by part, chapter, and section numbers.

Procedures for Updating or Revising Pages The updating or revising of data and text should be on a replacement page basis.

The changed or revised portion of each page should be highlighted by a vertical line in the margin opposite the binding margin for each line changed or added.

All pages submitted to update, revise, or add pages to the report should show the date of the change.

The transmittal letter should include an index page listing the pages to be inserted and the pages to be removed.

When major changes or additions are made, pages for a revised table of contents should be provided.

Number of Copies The applicant should submit the appropriate~number of copies of each required submittal pursuant to § 70.21, "Filing," of 10 CFR Part 70.

Public Disclosure The NRC has determined that the public disclosure of the details of physical protection programs is not in the public interest, and such details are withheld pursuant to paragraph 2.790(d) of 10 CFR Part 2, "Rules of Practice for Domestic Licensing Proceedings."

Thus the physical protection section of each application should be submitted as a separate enclosure.

Other proprietary and classified information should be clearly identified and submitted in separate enclosures.

Each such submittal of proprietary information should be accompanied by the applicant's detailed reasons and justifications for requesting exemption from public disclosure as required in paragraph 2.790(b) of 10 CFR Part 2.

xti

PART I

SPECIAL NUCLEAR MATERIAL

OF MODERATE STRATEGIC SIGNIFICANCE

5.59-1

1.

USE AND STORAGE AREA AT A FIXED SITE

This chapter provides guidance on meeting the requirements of paragraphs

73.67(d)(1) and (d)(2),.which are as follows:

(d)(1)

Use the material only within a controlled access area which is illuminated sufficiently to allow detection and surveillance of unauthorized penetration or activities.*

(d)(2)

Store the material only within a controlled access area such as a vault-type room or approved security cabinet or their equivalent which is illuminated sufficiently to allow detection and surveillance of unauthorized penetration or activities.*

A controlled access area (CAA)

is defined in paragraph 73.2(z) as "any temporarily or permanently established area which is clearly demarcated, access to which is controlled and which affords isolation of the material or persons within it." "Access control" means measures used to allow only specified personnel, materials, and vehicles ingress into and egress from a given area, while "isolation" refers to measures taken to deter persons, materials, or vehicles from entering or leaving a given area through other than established access control points.

Thus, a CAA Includes provisions for both isolation and access control.

In some cases, isolation or access control systems may also serve the purpose of aiding in the detection of unauthorized penetration or activities* within the CAA.

Therefore, these detection-related considerations are alluded tQ in this chapter.

In the discussion that follows, CAAs intended for use and the possible storage of SNM of moderate strategic significance are discussed separately from those intended solely for the storage of such SNM.

Although the requirements for these two different applibations of CAA are in most respects similar', it is recognized that the means used to isolate the material and control access may differ markedly for use areas compared with storage areas and therefore warrant separate discussion.

1.1 Area Where Material Is Used [73.67(d)(1)]

Intent This section discusses CAAs intended primarily for the use of SNM of moderate strategic significance.

These may be temporarily established to meet transitory or intermittent SKM use requirements or they may be permanently established.

Permanently established CAAs for use of SNM may also be suitable for st6rage.

"Use" means that the material is undergoing processing (e.g.,

fuel fabrication, irradiation in a reactor) or utilization of its properties in conjunction with experimental equipment (e.g., equipment used for research or educational laboratory experiments).

Different isolation/access control measures may be used for periods during whicht the area is occupied versus unoccupied.

SUnauthorized activities are those activities deemed by the licensee to be indicative of or contributory to the possible theft of SNM.

5.59-3

Illumination sufficient to allow detection and surveillance of unauthor Ized penetration or activities within the CAA where the material is used need not require the use of high-Intensity lighting throughout the CAA.

What is intended is the use of normal lighting sufficiently uniform throughout the CAA

to ensure that material or unauthorized personnel cannot be secreted in a darkened area until a time more convenientfor the unauthorized removal of the material.

For those facilities where experiments must be conducted in a darkened room, the lighting requirement is exempted for as long as is needed provided access control is ensured and the material is accounted for at the end of the experiment.

1.

Temporarily Established CAAs Temporarily established CAAs for the use of SNM need not have permanent barriers at their boundaries.

Isolation of the material and persons using the material may be provided by office partitions, cordons, or other devices used to warn passersby of the restricted nature of the area.

Access control can be effected through surveillance or supervision of the area by those-who are using the SNN and who are responsible for the material.

However, the provision of access control through personal supervision is suitable only for those situations in which the size of the CAA and the number of persons to be admitted are sufficiently small and in which the CAA is suitably configured to make such-procedures practical.

When material located in a temporarily established CAA is to be left unattended (i.e., because it is impractical to replace the material in a CAA

designed for long-term storage of the material), access control and improved isolation for the temporary CAA may be provided to substitute for the discontinued personal supervision over .the material.

(In addition, provisions must be made for satisfying the monitoring requirement of paragraph

73.67(d)(3).)

Improved isolationdcan sometimes be provided by increasing the penetration resistance of existing barriers (e.g., locking doors andwindows, placing the material in a locked drawer or supply room).

Access control may be provided by any of the measures suggested below for permanently established CAAs left unattended; some of these suggestions may be more suitable for temporary use than others.

If no suitable barrier is available to provide isolation, material left unattended may be protected by a motion alarm covering the area immediately surrounding the material.

This improved detection capability would be considered an acceptable substitute for the rudimentary isolation provided by temporary barricades, cordons, signs, and other less substantial means of isolation that may be used on a temporary basis.

2.

Permanently Established CAAs Permanentiy established CAAs for the use and temporary storage of SNM of moderate strategic significance would most likely provide isolation for the SNM

through the use of permanent barriers.

These could consist of fences; gates or freestanding walls for exterior areas; or exterior or interior building walls, locked doors, windows, bars, grillwork; or other barriers for interior areas.

Such barriers are not required to meet the more stringent criteria for physical barriers used for the protection of formula quantities of strategic special

5.59-4

nuclear material (SSNM).*

However, good security management practice would dictate that the barrier be substantial enough to deter casual passersby from unauthorized penetration.

If the barriers are also designed to aid in detec tion, the criteria for penetration resistance or tamper indication In accordance with the specific monitoring procedures to be used also apply.

Access control for permanently established CAAs during periods they are occupied can be provided by personal supervision.

However, when these areas are unoccupied or when the size, configuration, or numbers of persons intended to be admitted to the area make personal supervision Impractical, other means of access control may be called for.

Some of the additional access control measures that may be used for permanently established CAAs** in these situa tions are:

Stationing a watchman at CAA access control points, Limiting distribution of keys, keycards, or combinations to doors and gates, Using a coded badging system to identify authorized personnel at CAA

access control points,

.

Controlling locked CAA doors and gates by use of remote surveillance (e.g., intercom or CCTV) by personnel stationed at a centrally located access control facility, or

.

Controlling access of personnel, material, and vehicles into CAs by other means.

It is expected that large facilities will have more complex Isolation and access control systems than small facilities in order to achieve comparable levels of protection.

Content (This section needs to-be completed only for CA*s designated exclusively for use of SNM.

CAAs designated for both use and storage are to be described as recommended in Section 1.2 of Part I of this Standard Format.)

Describe the CAAs designated exclusively for use of the material.

Indi-"

cate under what conditions CAAs will be established on a temporary basis.

For each CAA identified, provide the following information:

1.

"A description of the area and its features relative to other facility features, showing the normal routes of ingress to each CAA (including a scale diagram).

"Strategic special nuclear material" means uranium-235 (contained in uranium enriched to 20 percent or more in the U-235 isotope), uranium-233, or plutonium.

Access control requirements for CAAs for the use or storage of SNM of moderate strategic significance are discussed in Chapter 3, "Access Control at a Fixed Site," of Part I of this guide.

5.59-5

Note that, in some cases, material located in such pieces of equipment may be considered in use rather than in storage.

In this case, whether the material is being personally supervised or not, the requirement for use of a motion detection system to satisfy the monitoring requirement isiremoved, and other monitoring devices or procedures may be used instead.

When a container equivalent to an approved security cabinet is chosen to satisfy paragraph 73.67(d)(2), the equivalency is based on the penetration resistance of the container and the difficulty associated with manipulating the lock.

The basic premise used to determine whether such a container may be monitored by procedures or devices other than a motion detector is whether it is unreasonable to expect that an external adversary could penetrate the container in a reasonable amount of time without leaving an indication of the penetration.

The amount of time that would be required for penetration without such an indication may be used to govern the frequency of patrols when monitoring procedures are used.

An approved security cabinet or its equivalent is one whose design has been certified by the General Services Administration or other nationally recognized standards organization (e.g., ANSI) to afford protection against surreptitious entry and lock manipulation equivalent to that provided by a Class-6 GSA rating or better.

Isolation for CAAs intended only for storage usually will be provided by the penetration-resistant features of the perimeter barriers or container walls of the CAA.

The level of penetration resistance of such barriers is not required to meet the more stringent criteria for physical barriers used to protect formula quantities of SSNM.

Rather, the physical barriers or container walls of the CAA are intended only to deter penetration by unauthorized persons and to aid detection by providing an indication of forced penetration.

In determining the level of isolation/access control required'for such CAAs, the time required for extricating SNM from its storage location in relationship to the licensee's time of detection and assessment may be taken into account (e.g., spent fuel:assemblies stored in spent fuel storage pools or fuel residing in nonpower reactor cores).

Examples of typical CAAswhere special nuclear material of moderate strategic significance may be stored are:

1.

Vault.

A structure that satisfies the definition for a vault as stated in paragraph 73.2(n) would provide more than adequate isolation protection.

2.

Approved Security Cabinets.

Those cabinets that are designed to provide delay and resistance against surreptitious entry and lock manipulation.

3.

Reactor.

Reactors that are sodesigned that removal of material is difficult.

4.

Vault-Type Room.

Some typical vault-type rooms where materials are stored and protected with a motion detector are storage pools, a room containing in-process storage racks, and laboratories where material is left unattended.

In all cases, movement in the near vicinity of the material or of the material itself generates an alarm signal.

5.59-7

5.

Locked Laboratories, Supply Rooms.

These areas must be sufficiently penetration resistant to afford a means of isolation/access control and permit the proper functioning of the system for monitoring the storage area as required by paragraph 73.67(d)(3) of the rule and as described in Chapter,2,

"Detection Devices and Procedures at a Fixed Site," of Part I of this guide.

The Illumination level required for the CAA should be sufficiently uniform and bright (a) in the case of a security cabinet, to detect penetration of or tampering with the CAA containment or (b) in the case of a vault-type room or its equivalent, to detect unauthorized penetration of or activities within the CAA.

Content Describe the CAMs wheirethe material will be stored and, in some cases, used.

For each such CAM,

provide the following information:

1.

features, diagram).

A description of the area and its features relative to other facility showing the access control points for the CAM (including a scale

2.

The isolation system such as physical barriers, container walls, or other features that demarcate the perimeter of the CAM and channel entry only through established access control points.

3.

The means and criteria used for controlling access to the CAA at established access control points.

4.

the types

5.

detection CAM or in If more than one CAM is designated for the storage of the material, of material normally to be stored in, each area.

The lighting level and uniformity of lighting provided to allow and surveillance of unauthorized penetration or activities within the the immediate vicinity of the CAM (where-security cabinets are used).

5.59-8

2.

DETECTION DEVICES AND PROCEDURES AT A FIXED SITE

This chapter provides guidance for meeting the requirement of paragraph

73.67(d)(3), which is as follows:

(d)(3)

Monitor with an intrusion alarm or other device or procedures the controlled access areas to detect unauthorized penetrations or activities.

The purpose of this monitoring activity as stated in paragraph 73.67(a)(2)

is to provide "early detection and assessment of unauthorized access or activ ities'by an external adversary within the controlled access area..." and "early detection of removal of special nuclear material by an external adversary from a controlled access area.". This should be done to achieve the objective of minimizing the possibilities for unauthorized removal of special nuclear material "consistent with the consequences of such actions," as stated in paragraph 73.67(a) of the effective rule.

Thus, the earliness of detection afforded by the licensee's physical protection system may vary depending on the nature and quantity of the material susceptible to unauthorized removal.

Further discussion of the earliness of detection required for possible thefts of different types and quantities of special nuclear material of moderate strategic significance is provided in Section 2.1 of Part I of this guide.

2.1 Earliness of Detection [73.67(a)]

Determination of early detection of unauthorized access, activities, or removal of SNM from CAAs will be based on an assessment of the magnitude of the consequences associated with possible misuse of the type and quantity of material that could be removed in a given theft attempt.

For SNM of moderate strategic significance, two distinct cases are considered:

1.

Theft of strategic special nuclear material (SSNM).*

2.

Theft of low-enriched uranium (LEU).**

Thefts from a single facility of SSNM in quantities of moderate strategic significance are limited by definition to quantities that could not be used to construct a nuclear explosive device;.thefts of similar quantities of material from several different facilities could, however, lead to the accumulation of an aggregate quantity that would permit such illicit use.

(The consequences of a single theft of such material would have minimal impact on the public health and safety.)

Therefore, detection of such thefts is required sufficiently early to ensure early notification to the NRC so thatthe NRC in turn can notify other licensees of the need to implement appropriate responses to prevent the accumulation by a single adversary of a formula quantity of material through multiple thefts from different facilities.

The NRC believes that there are detection systems and procedures that would allow the licensee to detect a theft of SSNM within approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

In this case, strategic special nuclear material means all SHM of moderate strategic significance other than low-enriched uranium.

Low-enriched'uranium is uranium enriched above natural percentages but less than 20 percent in the U-235 isotope.

5.59-9

The criteria for early detection of thefts of LEU enriched to more than

10 percent, but less than 20 percent, in the isotope U-235 are the same as for thefts of LEU in quantities comprising SNM of low strategic significance.

The reader should refer to Part II of this guide for information regarding appropriate monitoring procedures to achieve early detection for such material.

2.2 Detection Through Monitoring-Controlled Access Areas [73.67(d)(3)]

Intent Licensees possessing quantities of SNM of moderate strategic significance can provide amonitoring system capable of detecting a theft of material within approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the actual removal of the material.

Either detection devices or security procedures may be used to help detect unauthorized activities or penetration of CAAs.

Most of the sites at which this material is stored or used are likely to be small research-oriented facilities such as nonpower reactors and educational institutions.

At such facilities there are likely to be relatively small quantities of SNM available, and authorized access to it may be infrequent.

Detection devices such as interior motion detector systems, balanced magnetic switches, etc., could be used to monitor such relatively small CAAs where the number-of established access control points Is very limited.

Security procedures may also be used to protect against thefts of quanti ties of SNM of moderate strategic significance because watchman patrols inherently allow unguarded Intervals during which an external adversary could conceivably obtain access to the CA, remove a small quantity of material, and leave before being discovered.

The inspection procedure may,(1) be suffi ciently frequent to ensure that an external adversary could not complete a successful theft of the material during the unguarded intervals,,(2) provide for an indication of the CAA barrier having been tampered with (as with a seal or by observation of damage done to the barrier), or (3) provide for an item count inventory or other accounting for the material as part of the inspection.

Some examples are given below:

After having left material unattended in an experimental setup in a classroom used as a temporary CM, the instructor returns after several hours and verifies that the material is still in place.

A small quantity of material-is stored in a security cabinet for several months at a time without authorized access.

Every 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> a watchman comes around to inspect the cabinet to ensure that the lock is secure and the cabinet has not been tampered with.

If a lock is used that is not designed to be resistant to surreptitious and forced entry, the watchman also inspects a tamper-indicating seal to verify that the container has*not been tampered with.

During periods when a nonpower reactor is left unattended, a watchman comes around every 2 h6urs and checks that none of the fuel elements

5.59-10

have been removed by unauthorized persons.

If a person working during off-hours in the vicinity of the nonpower reactor is encountered, appropriate identification is requested.

While a nonpower reactor is being used, the supervisor ensures that he/she or his/her designee is not away from the reactor for a period longer than 30 minutes or a period he/she estimates would be minimally required for a person to obtain fuel elements in the core that are not self-protecting by virtue of their having been sufficiently irradiated.

During periods when excess fuel is left unattended-in a. storage closet at a nonpower reactor facility, an alarm system is activated that would annunciate if anybody tried to penetrate the closet without proper authorization.

During periods when the material is being used under the direct supervi sion of authorized personnel, the monitoring requirement may be satisfied by virtue of the continuous surveillance exercised by such personnel.

Content For each of the CAAs designated for the protection of SM4 of moderate strategic significance, provide the following information regarding the meas ures taken to fulfill the monitoring requirement of paragraph 73.67(d)(3):

1.

Describe any devices employed by specifying the type of device, its installed location, the type and location of annunciation, the intended area of coverage, and-the tamper-resistant features.

Refer, if desired, to existing filed security plans, regulatory guides, or NUREG documents.

2.

Describe any procedures employed to monitor the CAA or portions thereof, including the categories of persons who will execute the procedures, the frequency of inspections or rounds of patrol, the basis for the determina tion of such frequencies, and the occasions when the procedures are intended to be implemented.

Also indicate the features of the CAA (e.g., barriers, locks, seals) that will affect the way the procedures are used.

3.

Explain how the combination of procedures and devices used to monitor each CAA meets the criteria for early detection of theft by an external adversary relative to the type of material found in each CAA.

5.59-11

3.

ACCESS CONTROL AT A FIXED SITE

This chapter provides guidance on meeting the requirements of paragraphs

73.67(d)(4), (d)(5), (d)(6), (d)(7), and (d)(1O), which are as follows:

(d)(4)

Conduct screening prior to granting an individual unelcorted access to the controlled access area where the material is used or stored, in order to obtain information on which to base a decision to permit such access, (d)(5)

Develop and maintain a controlled badging and lock system to identify and limit access to the controlled access areas to authorized Individuals, (d)(6)

Limit access to the controlled access areas to authorized or escorted individuals who require such access in order to perform their duties, (d)(7)

Assure that all visitors to the controlled access areas are under the constant escort of an individual who has been authorized acceig to the area, (d)(1O)

Search on a random basis vehicles and packages leaving the controlled access areas.

An. access control system is one that controls access to or egress from a CAA through normal routes for personnel, materials, or vehicles.

3.1 Preauthorization Screening [73.67(d)(4)]

Intent The Intent of the requirement for preauthorization screening is to ensure that the licensee will have sufficient knowledge of an individual to determine his/her reliability and need for access prior to. granting him/her authorized access to the CAA where the material is used or stored.

The selection of procedures for conducting this examination and the criteria employed to make these judgments are the responsibility of the licensee and, of course, should be consistent with all local, State, and Federal laws and regulations regarding the protection of the privacy and other rights of the individual.

The screening process may be conducted in the same manner as other investigations customarily conducted by potential employers for similarly sensitive positions.

There is no requirement for the licensee to arrange for an NRC clearance or similar clearance from any other government organization.

Examples of procedures and criteria that may be employed in the screening process .include holding or having recently held a government-sanctioned clearance; examination of past employment or educational records (to determine any unsatisfactory employment or school actions or incidents that would indicate any unreliability or previous breaches of trust between the individual and his/her employer);

endorsements or references from previous employers, teachers, or colleagues that would support a decision for granting access or that would attest to the trustworthiness and reliability of the individual; and consideration of the individual's present employment record indicating demonstrated trustworthiness

5.59-12

and reliability over an extended period of employment with the licensee.

(This may be considered in the nature of "grandfathering.")

Content Describe the procedures and criteria that will be used for obtaining sufficient information prior to making a decision on granting unescorted access authorization to an individual to CAAs where the material is used or stored.

Identify the types of individuals who will be screened (e*.g.,

process engineers, supervisory personnel, professors, instructors, graduate students)

and who will perform the screening process.

3.2 Badging System [73.67(d)(5)]

Intent The purpose of the badging system is to facilitate the identification of authorized individuals and the control of access to or within the CAA where the material is used or stored.

Information on the badge should be such that it is possible to clearly distinguish personnel authorized for access to the CAAs from those requiring an escort.

Information on the badge should also uniquely identify the individualpossessing the badge.

This personalized information can be obtained through the use of photographs, personal vital statistics, signatures, or any means the licensee may wish to use that will uniquely identify the Individual.

Content Describe the badging system used to facilitate control of access to the CAAs.

This description should include:

1.

The size, shape, color, material, and construction of badges.

2.

The'distinguishing features of the badge that identify authorized individuals from escorted individuals.

3.

How the badges will be used for controlling access.

(For example, will all individuals be checked prior to entering the CAAs, will periodic "

checks be made of individuals within a CAA to determine if they are authorized or underescort, or will the badge itself permit authorized entrance, e.g., a card key'.)

4.

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

3.3 Lock System

[73.67(d)(5)]

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 that fit this description are three-position dial-type combination 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

5.59-13

be designed to ensure that only authorized personnel have access to such items.

Locks and combinations should be changed when information is obtained that the lock system may have been compromised.

Further information may be obtained in Regulatory Guide 5.12, "General Use of Locks in the Protection and Control of Facilities and Special Nuclear Materials."

Content Describe the locking system used to control access to the CAAs where material is used and stored.

This description should include locations of all locks included 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 combinations and changing combinations or locks, criteria for changing combinations or locks, personnel authorized to be given keys or combinations, and descriptions of types of locks used (references may be made to Regulatory Guide 5.12 for this purpose).

3.4 Personnel Entry Control System [73.67(d)(6)]

Intent The success of other access control system components such as preauthori zation screening, badging, and lock control is dependent upon effective control of personnel access into the CAA.

Physical access may be controlled in a number of different ways depending on the actual configuration of the CAA and other site-specific factors.

Some examples of these alternatives are:

1.

Control by Authorized Person.

If the area to be controlled is sufficiently small and free of obstructions, an authorized person performing other activities in a CAA may effect physical access control by monitoring entry of unauthorized persons into the area.

A sign posted at the entrance would help deter casual passersby.

An example of this approach would be when laboratory instructors are conducting classes and, because they are familiar with each of their students, they could easily recognize unauthorized persons not belonging in the classes.

2, Card-Key, Cipher, Combination, or Key-Lock Control System.

A more sophisticated hardware-oriented system involves the use of a card-key, cipher, combination, or key-lock system.

Physical access control in this case consists of the use of physical barriers to deter unauthorized persons.

A limited number of entrances that are controlled by authorized personnel using a card, key, cipher, combination, or key are provided.

This system may be more useful when larger numbers of authorized personnel who would not necessarily be familiar with one another need to share the use of the CAA.'

3.

Control b Security Organization.

If security organization personnel are availablephysical access control may be accomplished by stationing a person at the entrance to the CAA to check Identification and allow only authorized persons into the CAA.

This alternative may be unjustifiably expensive unless the security organization member's salary can be justified on other grounds as well.

A variation of this-system requires persons seeking entrance to the CAA to obtain a key from a properly designated person or security organization for each use..

5.59-14

Content Describe the system for limiting physical access to each CAA identified in Sections 1.1 and 1.2:of Part I to 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 granting authorizations, and the procedures used to ensure that only authorized or.

properly escortedpersons are allowed access to the CAA.

Reference may~be made to Sections 3.1, 3.2, 3.3, 3.5, and 3.6 of this chapter as they apply to this section for the description of locks, barriers, or other hardware that are used to control access.

3.5 Escort System [73.67(d)(7)]

Intent The requirement that an escort system be established is in recognition of the fact that the licensee may wish to allow access to certain persons or classes of persons on a temporary or infrequent basis or on short notice, thus making the routine process for granting access authorizations impractical or inexpedient.

Typical arrangements for escorted access may include escorts for maintenance or repair personnel, laboratory classes, public tours, guests, and visitors as required.

Content Describe the system that will be used to escort individuals in the CAAs.

In its security plan, the licensee should ensure that only properly authorized individuals will be allowed to escort individuals.

This description should include:

1.

Criteria to be used for granting escorted access,

2.

Criteria to be used for escorting others,

3.

Procedures for escorting individuals into CAAs (e.g., students under the supervision of laboratory instructor, public tours),

4.

The number of escorted Individuals per escort, and

5.

The responsibilities of the escort (e.g., periodic surveillance of all individuals under escort, accounting for all material prior to leaving the CAA, remaining in general area during the time unauthorized individuals are present)..

3.6 Search [73.67(d)(10)]

Intent The primary intent of the search requirement is to deter and possibly detect attempted thefts of SNM.

The search procedures developed by the licensee should take into consideration the environs where the material is used

5.59-15

or stored, the physical characteristics of the material itself, and the frequency of accounting for the material.

In some cases, this will require that all vehicles and packages leaving the CAAs be searched in a random manner.

The frequency of random searches should be determined by the ease with which the material can be stolen and the length of time it would take to detect a theft.

In other cases, only packages that equal or exceed the size of the material being used or stored would have to be searched, taking into consideration the difficulty with which the material could be broken into smaller, more easily concealed parts.

Content Describe the system to be used for randomly searching vehicles or packages that leave the CAA.

Include in the description information as to:

1.

The scope of the search.

This should identify the criteria that will be used for searching vehicles and packages (e.g., whether all packages and vehicles are subject to search or just those packages or vehicles that are larger than the smallest configuration of material being used or stored).

2.

The randomness of the search.

The scheme for selecting the packages or vehicles to be searched should be identified (e.g., subjecting each package or vehicle to a search, using a random number generator for determining whether a candidate package or vehicle is to be searched, searching a minimum percentage of all packages or vehicles.l.eaving the CAA each day).

5.59-16

4.

SECURITY ORGANIZATION AT A FIXED SITE

This chapter provides guidance on meeting the requirements of paragraph

73.67(d)(8), which states:

(d)(8)

Establish a security organization or modify the current security organization to consist of at least one watchman* per shift able to assess and respond to any unauthorized penetrations or activities in the controlled access areas.

Intent The intent of this requirement is to ensure that, in the event of a security incident, someone will be available to assess alarms or other 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 any missing material will help facilitate its prompt recovery.

In some cases, the licensee may assign additional duties to members of the security organization where procedure oriented options are chosen to satisfy physical protection requirements (e.g.,

periodic patrols and inspections of CAAs for storage of SNM).

Security organ ization members are not required to be fully dedicated full-time employees of the licensee.

They may include unarmed campus security personnel (watchmen),

contract guards, members of the local law enforcement agency (if sufficiently close to the site), etc.

No formal or comprehensive training program is required for security organization personnel.

However, the licensee should be prepared to demonstrate that each security person understands the particular duties assigned to him/her and is fully qualified and trained to perform them.

Content Describe the security organization-that will be responsible for. assessing and responding to security incidents.

Indicate the other responsibilities of the security organization such as:

1.

Conducting periodic physical security checks of CAAs,

2.

Maintaining liaison with the local law enforcement agency,

3.

Notifying the local law enforcement agency bf any unauthorized penetrations or activities in the CAAs,, and

4.

Notifying licensee management of any unauthorized penetrations or activities in the CAAs.

A "watchman" is defined in paragraph 73.2(d) of 10 CFR Part 73 as "an indi vidual, not necessarily uniformed or armed with a firearm, who provides protec tion for a plant and the special nuclear material therein in the course of performing other duties."

5.59-17

5.

COMMUNICATIONS AT A FIXED SITE

This chapter provides guidance on meeting the requirements of paragraph

73.67(d)(9), which states:

(d)(9)

Provide a communication capability between the security organization and appropriate response force.

Intent The intent of this regulation is to ensure that a communication capability exists between the licensee and the designated response force.

It is implied that, prior to setting up a communication capability, procedures and responsibilities will have been established between the response force and the licensee.

(See Chapter 6, "Response Procedures at a Fixed Site," of Part I.)

The type of communication system chosen by a licensee should:

1.

Provide for full duplex voice communication capability,

2.

Be easily accessible to the licensee's security organization, and

3.

Be reliable and available for immediate use at any time.

Some communication systems that would provide these capabilities Include a dedicated telephone system, a nondedicated public telephone system, radio, or any combination thereof.

Content Describe the communication system that is used between the security organization and the appropriatd response force.

This description shoulNd include information on:

1.

Type of communication system,

2.

Location of voice terminals in relationship to CAAs,

3.

Availability of communication system on a 24-hour basis, and

4.

Reliability of communication system.

5.59-18

6.

RESPONSE PROCEDURES AT A FIXED SITE

This chapter provides guidance on meeting the requirements of paragraph

73.67(d)(11), which states:

(d)(11)

Establish and maintain response procedures for dealing with threats of thefts or thefts of such materials.

Intent The intent of this regulation is to help the licensee to identify those security Incidents that could result in the loss of SNM of moderate strategic significance and to develop response procedures to prevent or reduce the likelihood of such a loss.

Some types of incidents that should be considered and for which response procedures should be developed are:

1.

Situations that could possibly lead to theft of SNM (e.g., civil strife),

2.

Discovery that the security system has been breached, and

3.

Discovery that some SM is missing.

Content Identify those events for which response procedures will be developed.

Also, describe the type of response to be accomplished for each event identi fied and the duties and responsibilities of the security organization and management involved in the response.

Ensure 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 capabil ities, and any agreements made with them to respond in the case of theft of the material.

5.59-19

7.

MATERIAL TRANSPORTATION REQUIREMENTS

This chapter provides guidance on meeting the requirements of paragraph

73.67(e)(1),-which are as follows:

(e)(1)

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

(i) Provide advance notification to the receiver of any planned shipments specifying 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 commencement of the planned shipment that the receiver will be ready to accept the shipment at the planned time and location and acknowledges the specified mode of transport, (iii)

Check the integrity of the container and locks or seals prior to shipment, and (iv)

Arrange for the in-transit physical protection of the material in accordance with the requirements of paragraph 73.67(e)(3) of this part unless the receiver is a licensee and has agreed in writing to arrange for the in-transit physical protection.

7.1 Advance Notification to Receiver [73.67(e)(11(1)]

Intent The intent of this paragraph is to require the shipper to preplan the transportation of material and inform the receiver of his plans prior to shipment.

This is the first of the several transportation requirements that will allow the receiver to take delivery of the material as planned or to help ensure traceability of any missing material.

Content The licensee should ensure in his security plan that, prior to each shipment of material, the receiver will be notified of the impending shipment and provided the following types of information:

1.

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

2.

Estimated time of arrival,

3.

Location where custody of the material will be transferred to the receiver,

4.

Name of carrier, and

5.59-20

5.

Transport identification (e.g., truck, train, or flight number; ship name).

7.2 Receiver Confirmation [73.67(e)(1)(ii)]

Intent The intent of this requirement is that, prior to shipment, the shipper will be assured that the receiver is ready to accept the shipment at the planned time and location and has acknowledged the mode of transport.

Content Describe what procedures will be used to ensure that shipment of material does not take place urt'il the receiver acknowledges the planned shipment and mode of transport and states that he will be ready to accept the shipment at the planned time and location.

7.3 Inspection [73.67(e)(1)(iil)]

Intent The intent of this paragraph is to provide a means for confirming the integrity of a shipment through inspections just prior to commencement and during the shipment by ensuring that the material containers and any associated locks or seals are intact at the time the shipment commences.

Content Describe the procedures to be used to ensure that the integrity of the shipment containers and associated locks or seals is checked just prior to shipment.

7.4 Responsibility for In-Transit Physical Protection Intent The intent of this paragraph is to make clear that the licensee shipping the materialtis responsible for arranging for the physical protection of the material in transit if the receiver is not a licensee.

If both the shipper and receiver are licensees, the-shipper may allow the receiver to accept this responsibility wholly or in part, provided there is appropriate documentation specifying their respective responsibilities.

Where no such documentation exists, both the shipper and receiver are held jointly responsible.

(See Section gi3 of Part I of this guide.)

Content In its security plan, the shipper should either acknowledge responsibility for the in-transit physical protection of SNM of moderate strategic signif icance or ensure that a written agreement from the receiver licensee has been received in which the receiver accepts either full-responsibility or shared responsibility for the in-transit physical protection of this material in accordance with paragraph 73.67(e)(3) of 10 CFR Part 73.

5.59-21

8.

RECEIVER REQUIREMENTS--TRANSPORTATION

This chapter provides guidance on meeting the requirements of paragraph

73.67(e)(2), which are as follows:

(e)(2)

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

(i) Check the integrity of the containers and seals upon receipt of the shipment, (ii) Notify the shipper of receipt of the material as required in Section 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 73.67(e)(3) of this part unless the shipper is a licensee and has agreed in writing to arrange for the in-transit physical protection.

8.1 Inspection [73.67(e)(2)(i)]

Intent This requirement is intended to determine whether the material's container has been compromised en route and whether any material has been removed so that immediate recovery procedures may be initiated if required.

Content Describe the procedures to be used to ensure that the integrity of the.

containers and seals will be checked upon receipt of the shipment of material.

8.2 Notification to Shipper [73.67(e)(2)(ii)]

Intent This requirement is intended to provide the shipper with knowledge of when responsibility for the shipment has been assumed by the receiver and when the shipper's responsibility is ended.

Content Ensure that the receiver will send a completed copy of standard Form NRC-741, "Nuclear Material Transaction Report," to the shipper within 10 days of receiving a shipment of material as required in § 70.54 of 10 CFR Part 70.

8.3 Responsibiltl for In-Transit Physical Protection

[73.57(e)(2)(Mt)],

Intent The intent of this paragraph is to make clear that the licensee receiving the material is responsible for arranging for the physical protection of the

5.59-22

material in transit if the shipper is not a licensee.

If both the shipper and receiver are licensees, the receiver may allow the shipper to accept this responsibility either wholly or in part provided there is appropriate documentation specifying their respective responsibilities.

Where no such documentation exists, both the shipper and receiver are held jointly responsible.

(See Section 7.5 of Part lof this guide.)

Content In its security plan, the receiver should either acknowledge responsibil ity for the in-transit physical protection of SNM of moderate strategic signif icance or ensure that a written agreement from the shipper has been received in which the shipper accepts either full responsibility or shared responsibility for the in-transit physical protection of this material in accordance with paragraph 73.67(e)(3) of 10 CFR Part 73.

5.59-23

9.

IN-TRANSIT PHYSICAL PROTECTION REQUIREMENTS

This chapter provides guidance on meeting the requirements of paragraph

73.67(e)(3), which are as follows:

(e)(3)

Each licensee who arranges for the in-transit physical protection of special nuclear material of moderate strategic significance or who takes delivery of this material free on board (f.o.b.) the pointtat which it is delivered to a carrier for transport shall:

(i)

Arrange for telephone or radio communications between the transport and the licensee or its designee:

(A) to periodically confirm the status of the shipment, (B) for notification of any delays in the scheduled shipment, and (C) to request appropriate local law enforcement agency response in the event of an emergency.

(ii)

Minimize the time that the material is in transit by reducing the number and duration of nuclear material transfers and by routing the material in the most safe and direct manner, (iii) Conduct screening of all licensee employees involved in the transportation of the material in order to obtain information on which to base a decision to permit them control over the material, (iv) Establish and maintain response procedures for dealing with threats of thefts or thefts of such material, (v)

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 time of arrival at its destination, (vi)

Initiate immediately a trace investigation of any shipment that is determined to be lost or unaccounted for after a reasonable time beyond the estimated arrival time.

(vii) Notify immediately the Director of the appropriate Nuclear Regulatory Commission Regional Office listed in Appendix A to this part of the action being taken to trace the shipment.

9.1 Communications [73.67(e)(3)(03I

Intent The primary intent of this requirement Is to ensure that procedures are established or facilities made available to permit communications to take place between the transport and the licensee or its designee for the purposes of

(1) periodically confirming the status of the shipment while it is in progress,

(2) notifying the licensee of delays along the shipment route that may affect the shipment's established schedule, and (3) requesting assistance from local

5.59-24

law enforcement authorities (LLEAs).

These communications need not be direct between the licensee and the transport.

1.

Confirmation of Shipment Status Communications for confirming the status of a shipment should be timed to reflect the expected changes in shipment status indicated by the shipment's scheduled itinerary.

For general motor freight (involving less-than-truckload quantities), direct communications between the transport and the licensee may be impractical.

This requirement may then be satisfied by periodically telephoning the carrier to obtain updated reports on the shipment's progress based on calls the carrier receives from drivers on a regular basis.

The frequency with which the licensee should check the status of a shipment should normally be at least every 10 to 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />.

This corresponds to the frequency with which the drivers normally would call in.

Similar indirect communications may be used to satisfy this requirement in the case of air shipments, but they should be more frequent to reflect the shorter air travel times between terminals.

When direct radio or telephone communications are practical between the licensee and the transport, the frequency of calls should normally be approximately every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

2.

Notification of Shipment Delays Notifications to-the licensee should be made by the carrier or transport personnel whenever unforeseen conditions arise that threaten to delay the shipment significantly beyond the estimated arrival time at the next point on the shipment's itinerary.

This notification may be made by conventional telephone lines or by radio.

Installation ofradiotelephone lines or comparable equipment is not required.

These communications need not be direct between the transport. and the licensee or its designee.

The transport personnel may relay the information to the licensee through the carrier's offices.

3.

Requests for LLEA Assistance SProcedures or facilities are also required to facilitate the transport personnel in obtaining assistance from LLEAs.

Use of radiotelephone or citizens' band radio equipment for this-purpose is acceptable but not required.

The transport personnel may alternatively use conventional telephone lines.

Requests for assistance should be in accordancemwith the response procedures developed to comply with paragraph 73.67(e)(3)(iv).

Content Describe the communications facilities and procedures to be used to ensure that communications are established to achieve the three purposes enumerated in paragraph 73.67(e)(3)(i).

The names and telephone numbers of responsible individuals should be given where appropriate.

Refer to established response procedures (Section 9.4 of Part I of this guide) as necessary.

5.59-25

9.2 Minimum Transit Times [73.67(e)(3)(ii)]

Intent This requirement is intended to have the shipper or receiver make a reasonable effort to ship the material by the fastest and most direct method possible.

It is not intended to require use of dedicated transports or other expensive modes of travel.

Content Describe the procedures and considerations that apply in the transporta tion planning process to ensure that a determined effort will be made to minimize transit times.

9.3 Preauthorization Screening [73.67(e)(3)(iii)]

Intent The intent of the requirement for preauthorization screening is to ensure that the licensee will have sufficient knowledge of an individual to determine his/her reliability and need for access prior to granting him/her authorized access to the material in transit.

The selection of procedures for conducting this examination and the criteria employed to make judgments are the responsibility of the licensee and, of course, should be consistent with all local, State, and Federal laws and regulations regarding the protection of the privacy and other rights of the individual.

The screening process may be conducted in the same manner as are other investigations customarily conducted by potential employers for similarly sensitive positions.

There is no requirement for the licensee to arrange for an. NRC clearance or similar clearance from any other government organization.

Examples of procedures and criteria that may be employed in the screening process include holding or having recently held a government-sanctioned clearance; examination of past employment records (to determine any unsatisfactory employment or incidents that would indicate any unreliability or previous breaches of trust between the individual and his/her employer); endorsements or references from previous employers or colleagues that would support a decision for granting access or that would attest to the trustworthiness and reliability, of the individual; and consideration of the individual's present employment record indicating demon strated-trustworthiness and reliability over an extended period of employment.

with the licensee.

(This may be considered in the nature of "grandfathering.")

Content Describe the procedures that will be used for obtaining sufficient information prior to making a decision on granting unescorted access authorization to those licensee employees who will be directly involved in the transportation or in the planning and movement control of the material.

Identify by title or name those employees who will be screened and those who will perform the screening process.

5.59-26

9.4 Response Procedures [73.67(e)(3)(iv)]

Intent The intent of this regulation is to help the licensee to identify those transportation incidents for which notification might be expected and that might affect the security of the SNM in transit and to plan response procedures for such situations.

For example, if the shipper is informed by the carrier that adverse weather conditions have 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 organization and management for dealing-with the response.

Ensure that the NRC will be notified immediately in the event of theft or attempted theft of the material.

9.5 Notification [73.67(e)(3)(v))

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

Content Describe the arrangements and procedures that will be used for notifying the licensee who arranges for the physical protection of material. in transit of the arrival of the shipment at its destination or of any such shipment that is lost or unaccounted for after the estimated time of arrival at its'destination.

9.6 Lost Material Notification [73.67(e)(3)(vi)]

Intent The intent of this requirement is to ensure that, in the event a shipment becomes overdue at its destination or at a scheduled stop on its itinerary and no reasonable explanation has been received by the licensee from the carrier regarding.its status, a trace investigation will be initiated.

Content Describe what procedures will be used to trace any shipment that is lost or has not arrived at a particular point on the shipment's itinerary or at its final destination by the estimated arrival time.

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9.7 NRC Notification [73.67(e)(3)(vll))

Intent The intent of this requirement is-to ensure that after a reasonable amount of time has elapsed with no explanation of the cause for the shipment's being.

overdue, the NRC will be immediately notified that the shipment is missing or unaccounted for and advised of the actions being taken to locate the missing shipment.

The amount of time considered reasonable before these tracing and notification procedures are initiated should not exceed I hour In any case.

Content Ensure that all material determined to be lost or unaccounted for will be reported immediately-to the appropriate NRC Regional Office in accordance with S 73.71.

Ensure that notification includes specifying what actions are being taken to trace the shipment and that the shipper or receiver, as appropriate, will also be notified.

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10.

TRANSFER AND CONTROL REQUIREMENTS

This chapter provides guidance on meeting the requirements of paragraph 73.67(e)(4), which reads as follows:

(e)(4)

Each licensee who arranges the physical protection of strategic special nuclear material in quantities of moderate strategic signif icance while in transit or who takes delivery of this material free on board (f.o.b.) the point at which it is delivered to a carrier for transport, shall, in addition to the requirements of (e)(1),

(e)(2) and (e)(3) above:

(1) Make all shipments of the material either (A) in dedicated transports with no intermediate stops to load or unload other cargo and with no carrier or vehicle transfers or temporary storage in transit, or (B) under arrangements whereby the custody of the shipment and all custody transfers are acknowledged by signature, and (ii)

Maintain the material under lock, or under the control of an Individual who has acknowledged acceptance of custody of the material by signature.

10.1 Carrier Transfers (73.67(e)(4)(i))

Intent The intent of this requirement is to ensure continuity in the assignment

'and acceptance of personal responsibility for shipments of strategic special nuclear material (high-enriched uranium and plutonium).

The requirements of paragraph 73.67(e)(4) do not apply to LEU.

This continuity may be provided by

(1) shipping the material in a dedicated transport vehicle so-that the material would be under the continuous control of the same individual(s),for the duration of the shipment or. (2) arranging for each individual who. assumes custody of the shipment to indicate acceptance of personal responsibility for the material by signature.

Shipment of the material in a dedicated transport means there should .be no intermediate stops to load or unload other cargo and no carrier or vehicle transfers or. temporary storage en route.

However, material other than the SNM

being shipped may be carried in the transport's cargo compartment provided it does not detract from the security of the shipment.

For shipments by general freight, this requirement may be satisfied by arranging for "signature security service" with a high surveillance feature, which is provided by many air and motor freight carriers.,

Content Indicate how this requirement would be met for each of the modes of shipment to be employed.

Indicate how this requirement would continue to be met in emergency situations by reference to the emergency response plans

5.59-29

included in Section 9.4 of the plan.

If signature serviceis to be employed, describe the type of service that will be provided by the particular carrier chosen for the shipment.

If a dedicated transport is to be used to satisfy.

this requirement, affirm that the same individual(s) will maintain respon sibility for the shipment from the point of origin to its destination.

10.2 Control of Shipments (73.67(e)(4)(ii))

Intent The intent of this requirement is to ensure that SSNM is not misrouted or mishandled by unauthorized individuals during the course of a shipment and to facilitate early detection and recovery of the material in case of loss or theft.

This can be achieved by maintaining the material under lock or under the control of a responsible individual whenever the material is not secured in a locked compartment.

Maintaining the shipment in a locked compartment would normally be possible only for shipments in dedicated transports.

In this case, the cargo compartment should be locked upon embarkation and unlocked only after arrival at the shipment's destination.

If the locked cargo compartment is left unattended for an extended period that might allow the unauthorized removal of the material, the Individual(s) responsible for the shipment should establish upon returning to the transport that the compartment has remained continuously under lock.

This can be done by examiningthe cargo compartment lock for signs of tampering, examining seals on the cargo compartment, or opening the compartment and ensuring that the material is intact.

For general freight shipments, during which the cargo compartment -may be opened frequently to load or unload other cargo, locking of the compartment may not be practical on a continuous basis.

When the shipment is not maintained under lock, the material is required to be in a sealed cargo compartment or maintained under the control of an individual who has indicated by signature his/her acceptance of responsibility for the shipment.

This individual should

.be the same person who has stgned for custody of the shipment in compliance wtth paragraph.73.67(e)(4)(i).

For air shipments in which the cargo compart ments are not locked, an individual responsible for the shipment is not required to accompany the shipment during flight provided a responsible individual main tains control of the shipment during the entire time the shipment remains at each air terminal.

During unscheduled stops at air terminals not. on the ship ment's itinerary, the shipment may be considered to be under the control of the flight crew provided the shipment is not offloaded and a member of the flight crew remains with- the aircraft at all times.

Maintaining the shipment under control means (1) ensuring the shipment is properly routed at transfer points, (2) keeping the material under lock or under surveillance, which would include periodically (normally at least every

2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) checking the shipment to ensure it has not been misplaced or tampered with, and (3) ensuring that the licensee or its designee is notified immediately if the shipment is determined to be missing., The licensee should ensure that the signature security service or other service provided by.the

5. 59-30

carrier under normal or special arrangements includes all three of the these elements of control.

Content Indicate the periods during which the shipment will be maintained under lock and those during which it will be maintained under the control of a responsible individual.

Describe the instruments to be -used for documenting acknowledgment of custody of the material by individuals assigned respon sibility for controlling the shipment.

Also, describe the arrangements made with carriers to ensure that the individuals they assign to maintain control of the material do so in accordance with the three elements of control described above.

Refer to -the emergency response procedures developed in accordance with paragraph 73.67(e)(3)(iv) as necessary.

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11.

EXPORT REQUIREMENTS

This chapter provides guidance on meeting the requirements of paragraph

73.67(e)(5), which reads as follows:

(e)(5)

Each licensee who exports special nuclear material of moderate strategic significance shall comply with the requirements specified in § 73.67(c), (e)(1) and (e)(3) and.(e)(4).

Use Chapters 7, "Material Transportation Requirements," 9, "In-Transit Physical Protection Requirements," and 10, "Transfer and Control Requirements,"

of Part I of this guide to describe the security procedures that will be used to protect the material up to the point where the receiver accepts physical protection responsibility for the shipment.

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12.

IMPORT REQUIREMENTS

This chapter provides guidance on meeting the requirements of paragraph

73.67(e)(6), which reads as follows:

(e)(6)

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

(1) Complywith the requirements specified in § 73.67(c), (e)(2),

(e)(3) and (e)(4), and (ii)

Notify the exporter who delivered the material to a carrier for transport of the arrival of such material.

12.1 Security Requirements [73.67(e)(6)(i)]

Use Chapters 8, "Receiver Requirements--Transportation," and 9,

"In-Transit Physical Protection Requirements," of Part I of this guide to describe the security procedures that will be used to protect the material from the first point at which the shipment is picked up inside the United States.

12.2 Notification [73.67(e)(6)(tt))

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

Content Describe the procedures to be used for notifying the exporter of the material that the-shipment has been received.

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13.

ORDERS TO DELAY SSN4 SHIPMENTS

This chapter provides guidance on meeting the requirements of paragraph

73.67(e)(7) and S 73.72 (as it may apply to shipments of special nuclear material of moderate strategic significance).

These requirements read as follows:

(e)(7)

If, after receiving advance notice pursuant to S 73.72 from a licensee planning to import, export, transport, deliver to a carrier for transport in a single shipment, or take delivery at the point where it is delivered to a carrier, special nuclear material of moderate strategic significance containing in any part strategic special nuclear material, it appears to the Commission that two or more shipments of special nuclear material of moderate'strategic significance, constituting in the aggregate an amount equal to or greater than a formula quantity of strategic special nuclear material, may be en route at the same time, the Commission may order one or more of the shippers to delay shipment according to the following provisions:

(i)

The shipper shall provide to the Commission, upon request, such additional information regarding a planned shipment as the Commission considers pertinent to the decision on whether to delay such shipment.

(0i) The receiver of each shipment, or the shipper if the receiver is not a licensee, shall notify the Director of the appropriate Nuclear Regulatory Commission Regional Office listed in Appendix A by telephone, no later than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after arrival of such shipment at its final destination, or after such shipment has left the United States as an export, to confirm the integrity of the shipment at the time of receipt or exit from.

the United States.

(iii) The Commission shall notify the affected shippers no later than two days before the scheduled shipment date that a given shipment is to be delayed.

(iv) Shipments of special nuclear material of moderate strategic significance which are protected in accordance with the provisions of §§ 73.20, 73.25, and 73.26 shall not be subject to orders to delay shipment nor considered to constitute a portion of an aggregate formula quantity of strategic special nuclear

.material for the purposes of determining whether any shipments must be delayed.

§ 73.72 Requirement for advance notice of shipment of special nuclear material.

(a)

Each licehsee who plans to import, export, transport, deliver to a carrier for transport in a single shipment, or take delivery, at the point where it is delivered to a carrier, the following materials, shall notify the

5.59-34

Director of the appropriate Nuclear Regulatory Commission Regional Office listed in Appendix A by U.S. Mail, postmarked at least 7 days in advance of the shipping date:

(1) formula quantities of strategic special nuclear material, or (2) special nuclear material of moderate strategic significance containing in any part strategic special nuclear material.

(b)

The following information shall be furnished in the advance notice:

shipper, receiver, carrier(s), estimated dates and time of departure and arrival, transfer point(s), and mode(s) of shipment.

(c)

The Director of the appropriate Nuclear Regulatory Commission Regional Office shall also be notified by telephone 7 days in advance of the shipping date that an advance shipping notice has been sent by mail, and of any changes to the shipment itinerary prior to the shipment date.

Road shipments or transfers with one-way transit lines of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or less in duration between installations of a licensee are exempt from the requirements of this section.

It is noted.that shipments of SNM of moderate strategic significance consisting entirely of uranium enriched in the isotope U-235 to 10 percent or more but less than 20 percent are not subject to these requirements.

Of the requirements detailed-above, only paragraph 73.67(e)(7)(ii) and

§ 73.72 should be addressed in the licensee's physical security plan.

This is discussed in Section 13.1.

1.

Criteria for Delaying Shipments Under the provisions of paragraph 73.67(e)(7) of the regulations, the NRC

has authority to order delays in certain shipments of SNM.of moderate strategic significance.

It is the intention of the NRC to exercise this authority only when necessary to protect the public health and safety from the possible consequences of the theft of a formula quantity of SSNM.

Since the number of affected shipments expected annually is quite low, shipment delays are expected to be ordered very rarely.

In most cases, licensees will be able to clear shipment dates with the NRC staff far in advance so that potential conflicts in the scheduling of shipments can be avoided.

However, shipment delays may be required on an emergency basis if a previous shipment is determined to be missing and cannot be accounted for before the next scheduled shipment is to depart.

When a'scheduling conflict that cannot be resolved voluntarily arises, the following criteria will be applied to determine which shipments will be delayed:

a.

Total time needed to complete the shipment, b.

The impact of a schedule delay on the use of the SNM at the delivery site, c.

Planned routing of the material, d.

The relationship of the material to the national defense or to other essential programs in the nation's interest,

5.59-35

e.-

The possible impacts on the shipper/carrier relationship with regard to availability of shipment vehicles and other special arrangements that would be difficult to reschedule, and f.

How far in advance of the proposed shipment date the NRC was notified of the intent to make the shipment.

2.

NRC Requests for Additional Shipment Information In order to apply the decision criteria listed above, the NRC has the authority under paragraph 73.67(e)(7)(i) to request additional information from licensees regarding a planned shipment of SSNM that may be subject to a possible delay order.

Such information requests may be made at any time prior to a scheduled shipment ei~ther by telephone or in writing.

3.

NRC Notification of Shipment Delay Orders to Licensees Under paragraph 73.67(e)(7)(lii), the NRC will normally notify licensees that a shipment is to be delayed no later than 2 days before a shipment is scheduled to depart.

In practice, it is expected that potential conflicts will be resolved much before the date of a planned shipment after appropriate NRC

consultations with the prospective shippers.

However, in an emergency the NRC

may order delays in shipments or other responsible action at any time it may deem necessary or desirable to promote the common defense and security, protect health, or minimize danger to life or property.

13.1 Notification of Receipt of SSNM (73.67(e)(7)(ii))

Intent The intent of this notification requirement is to ensure that the NRCtis promptly informed of the receipt of a shipment of SSNM subject to para graph 73.67(e)(7) or, in the case of export shipments, informed that the ship ment has left the United States safely.

Based on this information, the NRC can permit subsequent shipments subject to paragraph 73.67(e)(7)(ii) to commence with the knowledge that a formula quantity of SSNM will not be at risk "In a.

small number of simultaneous shipments.

This will also ensure that shipment delay orders will not have to be imposed unnecessarily for failure to confirm that a previous shipment is no longer at risk.

Compliance with this requirement is not a substitute for compliance with other notification requirements under paragraph 73.67(e)(2)(Ii).

Content Affirm that, in the case of a shipment of SNM of moderate strategic significance containing in any part SSNM, arrangements are made to obtain confirmation of the integrity of the shipment at the point where the material leaves the United States as an export or at its final destination.

Describe the procedures for accomplishing this and notifying the NRC of the shipment's status at the time of receipt or exit from the United States.

Include the names or titles of individuals who will be responsible for ensuring that the required confirmation is made and the proper notification is provided to the NRC.

5.59-36

PART II

SPECIAL NUCLEAR MATERIAL

OF LOW STRATEGIC SIGNIFICANCE

5.59-37

1.

USE AND STORAGE AREA AT A FIXED SITE

This chapter provides guidance on meeting the requirement of paragraph

73.67(f)(1), which is as follows:

if)(1)

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

A controlled access area (CAA)

is defined in paragraph 73.2(z) as "any temporarily or permanently established area which is clearly demarcated, access towhich is controlled and which affords isolation of the material or persons within it."

"Access control" means measures used to allow only specified personnel, materials, and vehicles ingress into and egress from a given area, while "isolation"' refers to measures taken to deter persons, materials, or vehicles from entering or leaving a given area through other than established access control points.

Thus, a CAA includes provisions for both isolation and access control.

In some cases, isolation or access control systems may also serve the purpose of aiding in the detection of unauthorized penetration or activities* within the CAA.

Therefore, these detection-related considerations are also alluded to in this chapter.

In the discussion that follows, CAAs intended for the use and possible storage of SNM of low strategic significance are discussed separately from those intended solely for the storage of such SNM.

Although there is no difference in the requirements for these two different applications of the CAA,

it is recognized that the means used to isolate the material and to control access may differ markedly for use areas compared with storage areas and therefore warrant separate discussion.

1.1 Areas for Use and Temporary Storage [73.67(f)(1)3 This section discusses CAAs intended primarily for the use and temporary storage of SNM of low strategic significance.

These may be temporarily estab lished to meet transitory or intermittent SNM use requirements or they may be permanently established.

Permanently established CAAs for use of SNM may also be used for storage for short intervals between periods of usage.

"Use" means that the material is undergoing processing (e.g., fuel fabrication, irradiation in a reactor) or utilization of its properties in conjunction with experimental equipment (e.g., equipment used for research or educational laboratory experiments).

Different isolation/access control measures may be used for periods during which the area is occupied versus unoccupied.

1.

Temporarily Established CAAs Temporarily established CAAs for the use of SNM need not have permanent barriers at their boundaries.

Isolation of the material and persons using the material may be provided by office partitions, cordons, or other devices used to warn passersby of the restricted-nature of the area.

Access control can be effected through surveillance or supervision of the area by those who are using the SNM and who are responsible for the material.

However, the provision of Unauthorized activities are those activities deemed by the licensee to be indicative of or contributory to the possible theft of SNM.

5.59-39

access control through personal supervision is suitable only for those situations in which the size of the CAA and the number of persons to be admitted are sufficiently small and in which the CAA is suitably configured to make such procedures practical.

When material located in a temporarily established CAA is to be left unattended (i.e., because it is impractical to replace the material in a CAA

designed for long-term storage of the material), access control and improved Isolation for the temporary CAA may be provided to substitute for the discon tinued personal supervision over the material.

(In addition, provisions must also be made for satisfying the monitoring requirement of paragraph 73.67(f)(2).)

Improved isolation can sometimes be provided by increasing the penetration resistance of existing barriers (e.g., locking doors and windows, placing the material in a locked drawer or supply room).

Access control may be provided by any of the measures suggested below for permanently established CAAs left unattended; some of these suggestions may be more suitable for temporary use than others.

If no suitable barrier is available to provide isolation, material left unattended may be protected by a motion alarm covering the area immediately surrounding the material.

This improved detection capability would be con sidered an acceptable substitute for the rudimentary isolation provided by temporary barricades, cordons, signs, and other less substantial means of isolation that may be used on a temporary basis.

2. Permanently Established CAAs Permanently established CAAs for the use and temporary storage of SNM of low strategic significance would most likely provide isolation for the SNM

through the use of permanent barriers.

These could consist of fences; gates or freestanding walls for exterior areas; or exterior or interior building walls, locked doors, windows, bars, grillwork; or other barriers for interior areas.

Such barriers are not required to meet the more stringent criteria for physical barriers used for the protection of formula quantities of strategic special nuclear material (SSNM).*

However, good security management practice would, dictate that the barrier be substantial enough to deter casual passersby from unauthorized penetration.

If the barriers are also designed to aid in detec tion, the criteria for penetration resistance or tamper indication in accor-.

dance with the specific monitoring procedures to be used also apply.

Access control for permanently established CAs during periods they are occupied can be provided by personal supervision.

However, when these areas are unoccupied or when the size, configuration, or numbers of persons intended to be admitted to the area make personal supervision Impractical, other means of access control may be called for.

Some of the additional access control measures that may be used for permanently established CAMs in these situations are:

Stationing a watchman at CAA access control points, Limiting distribution of keys,. keycards, or combinations to locks on doors and gates,

5.59-40

Using a coded badging system to identify authorized personnel at CAA

access control points, Controlling locked CAA doors and gates by use of remote surveillance (e.g.,

intercom or CCTV) by personnel stationed at a centrally located access control facility, or

.

Controlling access of personnel, material, and vehicles into CAAs by other means.

It is expected that large facilities (e.g., fuel processing facilities)

will have more complex isolation and access control systems than small facil ities (e.g., research facilities) in order to achieve comparable levels of protection.

Content Describe the CAAs where the material will be used.

Indicate under what conditions CAAs will be established on a temporary basis.

State whether each CAA will also be used for storage.

For each CAA identified, provide the following information:

1.

A description of the area and its features relative to other facility features, showing the normaliroutes of ingress to each CAA (Including a scale diagram).

2.

Descriptions of physical barriers, cordons, walls, partitions, or other means of providing isolation of the CAA,

and channelling entry through established access control points into the CAA.

3.

The means and criteria used for controlling access into the CM at established access control'points.

4.

If more than one CAA is designated, the types of material normally used in each CAA; for temporarily established CAAs, the types of activities normally performed within each area.

1.2 Areas for Permanent Storage [73.67(f)(1)]

Intent CAAs normally used only for storage of SNM are described in this section.

SuchCAAs may be very limited in size since they need only contain the material itself, and access to them is expected to be infrequent.

Where small amounts of material are involved, the CAA may consist of relatively small containers such as security cabinets, safes, and locked closets or supply rooms.

Isolation for CAAs intended only for storage usually will be provided by the penetration-resistant features of the perimeter barriers or container walls of the CAAM Such barriers and container walls are not required to meet the more stringent criteria for physical barriers used for the protection of formula quantities of SSNM.

However, good security management practice would

5.59-41

dictate that the barrier be substantial enough to deter casual passersby from unauthorized penetration.

If the barriers are also designed to aid in detection, the criteria for penetration resistance or, tamper indication in accordance with the specific monitoring procedures to be used also apply.

In determining the level of isolation and access control for such CAAs, the minimum time required for extricating SNM from Its storage location in relationshipto the licensee's time of detection and assessment may need to be taken into account (e.g., fuel assemblies stored in shipping casks or non-self-protecting fuel residing in nonpower reactor cores).

The bulkiness, massiveness, and difficulty of movement or disassembly of fresh fuel elements or other forms of low-enriched uranium (LEU)

in large quantities such as shipping casks or assemblies may pose sufficient difficulty to persons attempt ing unauthorized removal within a reasonable time period (relative to CAA

monitoring procedures) that they may be considered to provide isolation.

Control of access to special equipment and vehicles capable of handling and transporting such items may also be included as integral elements of the access control program for the CAA.

Access control procedures for CAAs designated exclusively for storage are expected to be similar to those described in the previous section for periods when use-type CAAs are unoccupied.

It is expected that large facilities (e.g., fuel processing facilities)

will have more complex isolation and access control systems than small facil ities (e.g., research reactors) in order to achieve comparable levels of protection.

An illumination level is recommended for the CAA that is sufficiently uniform and bright to'detect penetration of or tampering with the CAA contain ment (In the case of a security cabinet) or Unauthorized penetration of or activities within the CAA (in the case of a vault-type room or its equivalent).

Content (This section needs to be completed only for CAAs designatedexclusively for storage of SNM.

CAAs designated for both use and storage are to be described as recommended in Section 1.1 of Part II of this Standard Format.)

Describe the CAs where the material will be stored, if different from those previously described for use.

For each such CAA, provide the following information:

1.

A description of the area and its features relative to other facility features showing the access control points for the CAA (including a scale diagram).

2.

The physical barriers, container walls, or other features, that demarcate the perimeter of the CAA and channel entry through only established access control points.

If access control is provided by virtue of the bulkiness, massiveness, and difficulty of disassembly of a container or object

5.59-42

serving as a CAA, describe the facts relied upon to support such a determination.

3.

The means and criteria used for controlling access to the CAA'at established access control points.

4.

If more than one CA

is designated for the storage of the material, the types of material normally to be stored in each area.

5.59-43

2.

DETECTION DEVICES AND PROCEDURES AT A FIXED SITE

This chapter provides guidance for meeting the requirement of paragraph

73.67(f)(2), which is as follows:

(f)(2)

Monitor with an intrusion alarm or other device or procedures the controlled access areas to detect unauthorized penetrations or activities.

The purpose of this monitoring activity as stated in paragraph 73.67(a)(2)

is to provide "early detection and assessment of unauthorized access or activ ities by an external adversary within the controlled access area..." and "early detection of removal of special nuclear material by an external adversary from a controlled access area."

This should be done to achieve the objective of minimizing the possibilities for unauthorized removal of special nuclear material "consistent with the consequences of such actions," as stated in paragraph 73.67(a) of the effective rule.

Thus, the earliness of detection afforded by the licensee's physical protection system may vary depending on the nature and quantity of the material susceptible to unauthorized removal.

Further discussion of the earliness of detection required for possible thefts of different types and quantities of special nuclear material of low strategic significance is provided in Section 2.1 of Part II of this guide.

2.1 Earliness of Detection [73.67(a)]

The criteria used for determining the earliness of detection for unauthor ized access, activities, or removal of SNM from CAAs will depend on an assess ment of the magnitude of the consequences associated with possible misuse of the type and quantity of material that could be removed in a given theft attempt.

For SNM of low strategic significance, three distinct cases are considered:

1.

Gross theft of low-enriched uranium (LEU)*

S2.

Minor theft of LEU.

3.

Theft of strategic special nuclear material (SSNM)

(i.e., SNM of low strategic significance other than LEU).

Gross theft. of LEU refers to the theft of LEU in a sufficiently large quantity that it could yield upon further enrichment or other processing enough material of the type and quantity needed to construct a clandestine fission explosive (CFE)

device.

This quantity may vary depending on the enrichment and physical and chemical form of the feed material but may roughly be estimated as an amount containing about 75 kilograms of the isotope U-235.

Because the most serious consequences to the public health and safety could occur from a theft of this magnitude, a system that would detect a theft sufficiently early to allow for prompt recovery is called for.

The NRC believes that, because of the Low-enriched'uranium is uranium enriched above natural but less than 20 percent in the U-235 isotope.

5.59-44

large quantity of material involved and with proper detection systems and procedures, the licensee would be capable of detecting a gross theft of LEU

between the time of the actual theft and the time it is transported off site.

Minor theft of LEU refers to thefts involving much smaller quantities of LEU such as could be removed by one or two persons in a private vehicle or on one's person.

These minor thefts are significant only to the extent that they could be repeated periodically to eventually accumulate an aggregate quantity similar to that which might be obtained in a gross theft.

The required'degree of earliness of detection of such thefts is related to the time that would be needed by the adversary to obtain a gross amount through repeated thefts.

If the amount taken in each of a series of daily thefts is very small, the ultimate time of detection could be as long as 6 months--the interval between material inventories as required by Part 70.

For larger-quantities that could be removed in a single theft, but still much less than would constitute a gross theft, it-would be reasonable to expect thatone in a series of such thefts would be detected before a gross amount could be removed.

Licensees who possess less than gross quantities of LEU need not provide for early detection of-a single theft of a gross quantity, but the capability for detecting multiple thefts is as important as it isfor those licensees possessing gross quantities.

Thefts from a single facility of SSNM (SNM of low strategic significance other than LEU) are limited by definition to quantities that could not be used to construct a nuclear explosive device; thefts of similar quantities of SSNM

from several different facilities could, however, lead to the accumulation of an aggregate quantity that would permit such illicit use.

(The consequences of a single theft of such material would have minimal impact on the public health and safety.)

Therefore, detection of such thefts is required sufficiently early to ensure early notification to the NRC.

The NRC in turn can then notify other licensees of the need to implement appropriate response measures to prevent the accumulation by a single adversary of a formula quantity of material through multiple thefts from different facilities.

The NRC believes that there are detection systems and procedures that would allow the licensee to detect a theft of SSNM within approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

2.2 Monitoring Controlled Access Areas [73.67(f)(2)]

Intent Monitoring CAAs where the material is used will require a capability for early detection of (1) unauthorized penetration of the CAA perimeter, (2).

unauthorized activities within the CAA,(3) unauthorized removal of SNM from the CAA, or (4) some combination of these, by an external adversary.

For purposes of this guidance, an external adversary is any person not employed by the licensee or one of its contractors to report for work on a regular basis at the licensee's slte-and who is not directly involved in the processing or other authorized use of the material in connection with his/her assigned duties.

For purposes of this definition, graduate and other students assigned by the licensee at an educational or research institution to assume responsibility for

5.59-45

the regular handling of the material would not be considered an external adversary.

The choice of particular safeguards measures to be included in the CAA

monitoring system will depend on a number of different site-specific factors such as.whether the measure is to function while the area Is occupied or unoccupied, the size of the area, the types of functions performed in the area, the level of traffic into and~out of the area, etc.

Many of the available safeguards measures that may be employed in the CAA monitoring system are described in various regulatory guides and NUREG documents issued by the NRC.

Specifically, the Fixed Site Physical Protection Upgrade Rule Guidance Com pendium* provides guidance on selection, installation, and implementation of monitoring devices and procedures relative to physical protection of formula quantities of SSNM.

This guidance is also applicable to monitoring equipment and procedures for CAAs at fixed sites having less than formula quantities of SNM with regard to individual physical protection measures.

It is recognized, however, that from a systems point of view, this body of guidance intended to support the Upgrade Rule may emphasize a much greater level of redundancy and diversity than would be requiredifor the protection of SNI of moderate and low strategic significance.**

The following paragraphs give Illustrations of various monitoring systems that can be used to provide the earliness of detec tion discussed in Section 2.1 of Part II of this guide.

1.

Early Detection of Gross Theft of LEU

Early detection of gross theft of LEU means detection during the attempted theft.

This may be accomplished by using intrusion alarms or other monitoring devices in the following applications:

Fence or buried line perimeter detection.systems at the CAA boundaries.

Door and window alarms (e.g., balanced magnetic switches) for CAAS with in buildings and alarms on emergency exit doors equipped with crash bars.

Volumetric interior motion detection systems for unoccupied CAAs or portions of CAAs within buildings.

In many cases, security-procedures may be employed as substitutes for some or all of the devices that could be employed to fulfill the monitoring requirement for the CAA.

Security procedures may be especially attractive in protecting against the theft of gross quantities of LEU located outside The c6mpendlum was issued in conjunction with the Physical Protection Upgrade Rule.

It is Intended to assist the licensee in the development and implementa tion of safeguards physical protection and transportation protection plans.

Copies are available for inspection at the Commission's Public Document Room,

1717 H Street NW., Washington, D.C.

Tamper-safing of devices intended for use at facilities having less than formula quantities of SSNM need protect only against the external adversary;

to the extent such a distinction can be made for a given device, this represents a relaxation in tamper-safing requirements relative to protection of formula quantities.

5.59-46

buildings where intrusion alarms may more easily be circumvented by an external adversary.

Typical security procedures that may be employed for detection of attempts at unauthorized removal of gross quantities of LEU include the following:

Periodic patrols of CAA perimeters and areas within the CAA by watchmen.

Surveillance (escorting) of nonlicensee vehicles capable of trans porting gross quantities of LEU away from the site.

Continuous (without interruption) or continual (intermittent)

surveillance of the CAA, or a given portion of the CAA that contains a gross quantity of LEU,

by designated supervisory or other licensee employees.

(These surveillance responsibilities could be undertaken in addition to the employee's normal functions provided they can both be discharged adequately.)

Periodic inspections to confirm continued integrity of barriers, gates, loading bay doors, etc., through which unauthorized removal of gross quantities of LEU could be effected.

Inspection of large vehicles leaving CAAs to ensure they are not used for unauthorized removal of a gross quantity of LEU.

Where procedures involve periodic patrols or inspections, the amount of time that would be required for an adversary to complete the removal of a gross quantity of LEU may be used to govern the interval between inspections.

For example, if a given number of a certain type of container of LEU would have to be individually loaded onto a truck in order to effect removal of a gross quantity of LEU and the time required for such loading is determined to be in excess of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then a 2-hour guard patrol of the given area would be considered to meet the earliness-of-detection guideline for the subject material.

A combination of these and perhaps other measures could satisfy the early detection criterion for gross theft of LEU if it could be shown that an external adversary could not obtain unauthorized access to the SNM without being detected by at least one intrusion alarm component.

2.

Early Detection of Minor Theft of LEU

The criteria for early detection of minor theft of LEU can be satisfied by a monitorihg program that provides a sufficiently high probability of detection of one in a series of minor thefts so it is implausible that an adversary would be able to obtain in the aggregate a gross quantity of LEU.'

Such a capability could be provided in whole, or in part; by the same monitoring program designed to detect gross theft.

Additional measures that might be included in the monitoring program to protect against minor theft include the following:

Exit searches of nonlicensee vehicles capable of transporting hand-carried quantities of LEU (on a random or general basis).

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Administrative control of materials removed from controlled areas where easily concealed or hand-carried items containing LEU are available.

Item count inventories more frequent than those currently required under Part 70.

Procedures directing regular employees to be aware of unauthorized persons in their work areas and to report. the presence of such persons to supervisory or security personnel.

(A coded badging program would support this measure.)

Escorting of visitors and other unauthorized persons entering CAAs.

Watchman patrols to detect unauthorized persons within the CAA.

SNM doorway monitors at all personnel access control points.

These are not required measures but illustrations of how the monitoring program for detecting gross theft of LEU may be extended to include the capa bility for early detection of minor theft of LEU.

One or more of these meas ures may be employed, but probably not all of them would be needed for any one installation.

3.

Early Detection of Theft of SSNM (SNM of low strategic significance other than LEU)

For facilities where it is necessary to protect against thefts of S[N4 of low strategic significance other than LEU (SSN!4),

earliness of detection is discussed in Section 2.1 of this chapter.

The physical protection system in this case may differ considerably from that designed to protect LEU.

The sites are likely to be small research-oriented facilities such as nonpower reactors and educational institutions.

Also, there is likely to be much less material available, and authorized access to it may be less frequent.

Detection devices such, as interior motion detector systems, balanced magnetic switches, etc.,

could be used to monitor relatively small CAAs where the number of established access control points is very limited.

Procedures may also be used to protect against thefts of SS*M in this subcategory.

Since watchman patrols inherently allow unguarded intervals during which an external adversary could conceivably obtain access to the CAA,

remove a small amount of material, and leave before being discovered, the inspection procedure may (a) be sufficiently frequent to ensure an external adversary could. not complete a successful theft of the material during the unguarded intervals, (b) provide for an irrevocable indication of the CAA

barrier having been tampered with (as with a seal or by observation of damage done to the barrier), or (c) provide for an item count inventory or other accounting for the material as part of the inspection.

Some examples are given below:

After having left material unattended in an experimental setup in a classroom used as a temporary CAA, the instructor returns after

2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and verifies that the material is still in place.

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A small quantity of material is stored in a security cabinet for several months at a time without authorized access.

Every 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> a watchman comes around to inspect the cabinet to ensure that the lock is secure and the cabinet has not been tampered with.

If a suitable combination or other pick-resistant lock is not used, the watchman also inspects a tamper-indicating seal to verify that the container, has not been tampered with.

During periods when a nonpower reactor is left unattended, a watchman.

comes around every 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and checks that none of the fuel elements have been removed by unauthorized persons.

If a person working during off-hours in the vicinity of the reactor is encountered, appropriate identification is requested.

While a nonpower reactor is being used, the supervisor ensures that he/she or his/her designee is not away from the reactor for a period longer than 30 minutes, a period he/she estimates would be minimally required for a person to secure fuel elements in the core that were not self-protecting by virtue of their having been sufficiently irradiated.

During periods when excess fuel is left unattended in a storage closet at a nonpower reactor facility, an alarm system is activated that would annunciate if anybody tried to penetrate the closet without proper authorization.

During periods when the material is being used under the direct supervi sion of authorized personnel, the monitoring requirement is satisfied by virtue of the continuous surveillance by the authorized personnel.

Content For each of the CAAs described previously (see Chapter I of Part II of this guide), provide the following lnformatibn regarding the measures taken to fulfill the monitoring requirement of paragraph 73.67(f)(2):

1.

Describe any devices employed by specifying the type of device, its installed location, the type and location of annunciation, its intended area of coverage, and its tamper-resistant features.

Refer, if desired, to existing.

filed security plans, regulatory guides, or NUREG documents.

2.

Describe any procedures employed to monitor the CAA or portions thereof, including the categories of persons who will execute the procedures,.

the frequency of inspections or rounds of patrol, the basis for the determina tion of such frequencies, and the occasions upon which the procedures are intended to be implemented.

Also indicate the features of the CAA (e.g.,

barriers, locks, seals) that will play a role in the way the procedures are used.

3.

Explain how the combination of procedures and devices used to monitor each CAA meets the criteria for early detection of theft by an external adversary relative to the type of material found in each CAA.

5.59-49

3.

SECURITY RESPONSE AT A FIXED SITE

This chapter provides guidance on meeting the requirement of paragraph

73.67(f)(3), which is as follows:

(f)(3)

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

Intent The intent of this requirement is to ensure that, in the event of a security incident, someone will be available to assess alarms or any unauthor ized 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 facilitate its prompt recovery.

For the 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 that will be responsible. for assessing and responding to any unauthorized penetrations or activities.

Ensure that at least one guard, watchman, or member of an offsite response force will respond to all unauthorized penetrations or security Incidents at the CAAs.

5.59-50

4.

RESPONSE PROCEDURES AT A FIXED SITE

This chapter provides guidance on meeting the requirements of para graph 73.67(f)(4), which states:

if)(4)

Establish and maintain response procedures for dealing with threats of thefts or thefts of such material.

Intent The intent of this regulation is to help the licensee to identify those security incidents that could result in the loss of SNM of low strategic significance and to develop response procedures to prevent or reduce the likelihood of such a loss.

Some types of incidents that should be considered and for which response procedures should be developed are:

1.

Situations that could possibly lead to theft of SNM (e.g., civil disturbance).

2.

Discovery that the security system has been breached.

3.

Discovery that some SNM is missing.

-Content Identify those events for which response procedures will be developed.

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.

Ensure 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 theft of the material.

5.59-51

5.

MATERIAL TRANSPORTATION REQUIREMENTS

This chapter provides guidance on meeting the requirements of paragraph

73.67(g)(1), which are as follows:

(g)(1)

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

(i) Provide advance notification to the receiver of any planned shipments specifying 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 commencement of the planned shipment that the receiver will be ready to accept the shipment at the planned time and location and acknowledges the specified mode of transport, (lii)

Transport the material in a tamper-indicating sealed container, (iv)

Check the integrity of the containers and seals prior to ship ment, and (v)

Arrange for the in-transit physical protection of the material in accordance with the requirements of S 73.67(g)(3) of this part, unless the receiver is a licensee and has agreed in writing to arrange for the in-transit physical protection.

5.1 Advance Notification [73.67(g)(1)(i)]

Intent The intent of this paragraph is to require the shipper to preplan the transportation of the material and inform the receiver of his plans prior to shipment.

This is the first of several transportation requirements that will..

allow the receiver to take delivery of the material as planned or to help ensure traceability of any missing material.

Content The licensee should ensure that, prior to each shipment of material, the receiver will be notified of the impending shipment and provided the following types of information:

1.

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

2.

Estimated time of arrival,

3.

Location where material is to be transferred to receiver,

4.

Name of carrier, and

5.

Transport identification (e.g., truck, train, or flight number; ship name).

5.59-52

5.2 Receiver Confirmation [73.67(g)(1)(ii))

Intent The intent of this requirement is that, prior to shipment, the transporter will be assured that the receiver is ready to accept the shipment at the planned time and location and has acknowledged the mode of transport..

Content Describe what procedures will be used to ensure that shipment of material does not take place until the receiver acknowledges the planned shipment and mode of transport and readiness to accept the shipment at the planned time and location.

5.3 Container [73.67(g)(1)(iii)]

Intent The intent of this requirement is to provide a mechanism or system that will help the receiver detect any tampering with the material's container that may have occurred during shipment.

Regulatory Guide 5.15, "Security Seals for the Protection and Control of Special Nuclear Material," provides guidance in this area.

If the material is shipped in an exclusive-use carrier, it is acceptable to tamper-seal the carrier itself rather than each individual SN5 container.

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

5.4 Inspection [73.67(g)(1)(iv))

Intent The intent of this paragraph is to require the shipper to check the integrity of the material container's seals just prior to shipment so as to be assured that they have not been compromised.

Then, upon receipt of the shipment, if the receiver discovers the container's integrity has been compromised and the material is missing, the scope of the recovery operation can focus on the transportation route.

Content

.

Describe the procedures to be used to ensure that the integrity of the containers or seals is checked just prior to shipment.

5.59-53

5.5 Responsibility for In-Transit Physical Protection [73.67(g)(1)(v)]

Intent The intent of this paragraph is to make clear that the licensee'shipping the material is responsible for arranging for the physical protection of the material in transit if the receiver is not a licensee.

If both the shipper and receiver are licensees, the shipper may allow the receiver to accept this responsibility wholly or in part provided there is appropriate documentation specifying their respective responsibilities.

Where no such documentation exists, both the shipper and receiver are held jointly responsible.

(See Section 6.3 of PartlII of this guide.)

Content In its security plan, the shipper should either acknowledge responsibility for the in-transit physical protection of SNM of low strategic significance or ensure that a written agreement from the receiver has been received in which the receiver accepts either full responsibility or shared responsibility for the in-transit physical protection of this material in accordance with paragraph 73.67(g)(3) of 10 CFR Part,73.

5.59-54

6.

RECEIVER REqUIREMENTS--TRANSPORTATION

This chapter, provides guidance on meeting the requirements of paragraph

73.67(g)(2), which are as follows:

(g)(2)

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

(i)

Check the integrity of the containers and seals upon receipt of the shipment, (ii)

Notify the shipper of receipt of the material as required in'

§ 70.54 of Part 70 of this chapter, and (iii) Arrange for the in-transit physical protection of the material in accordance with the requirements of paragraph 73.67(g)(3) of this part, unless the shipper is a licensee and has agreed in writing to arrange for the in-transit physical protection.

6.1 Inspection [73.67(g)(2)(i)]

Intent This requirement is intended to determine whether the material's container has been compromised en route and whether any material has been removed so that immediate recovery procedures can be initiated if required.

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

6.2 Notification [73.67(g)(2)(ii)]

Intent This requirement is intended to ensure that knowledge of the current location of all SNM is available and to formally inform the shipper that the material has been received.

Content Ensure that a completed copy of Form NRC-741, "Nuclear Material Transac tion Report," will be sent to the shipper within 10 days after a material shipment has been received as required in § 70.54 of 10 CFR Part 70.

6.3 Responsibilit for In-Transit Physical Protection L73.67(g)2)ttt)

Intent The intent of this paragraph is to make clear that the licensee receiving the material is responsible for arranging for the physical protection of the

5.59-55

material in transit if the shipper is not a licensee.

If both the shipper and receiver are licensees, the receiver may allow the shipper to accept.thls respon sibility either wholly or in part provided there is appropriate documentation specifying their respective responsibilities.

Where no such-documentation exists, both the shipper and receiver are held jointly responsible.

(See Section 5.5 of Part II of this guide.)

Content In its security plan, the receiver should either acknowledge responsibil ity for the in-transit physical protection of SNM of low strategic significance or ensure that a written agreement from the shipper has been received in which the shipper accepts either full responsibility or shared responsibility for the in-transit physical protection of this material in accordance with paragraph

73.67(g)(3) of 10 CFR Part 73.

5.59-56

7.

IN-TRANSIT PHYSICAL PROTECTION REQUIREMENTS

This chapter provides guidance on meeting the requirements of paragraph

73.67(g)(3), which are'as follows:

(g)(3)

Each licensee, either shipper or receiver, who arranges for the physical 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 point at which ItAis delivered to a carrier for transport shall:

(i)

Establish and maintain response procedures for dealing with threats 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 time of arrival at its destination, and (iii) Conduct immediately a trace investigation of any shipment that is lost or unaccounted for after the estimated arrival time and report to the Nuclear Regulatory Commission as specified in

§ 73.71 and to the shipper or receiver as appropriate.

The licensee who made theiphysical protection arrangements shall also immediately notify the Director of the appropriate Nuclear Regulatory Commission Regional Office listed in Appendix A of the action being taken to trace the shipment.

7.1 Response Procedures [73.67(g)(3)(i)]

Intent The intent of this regulation is to help the licensee identify those transportation incidents that could affect the security of the SNM in transit for which notification might be expected and for which response procedures should be. planned.

Content Identify those events for which response procedures will be developed.

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.

Ensure that the NRC will be notified immediately in the event-pf theft or attempted theft of the material.

7.2 Notification t73.67(g)(3)(ii)]

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

5.59-57

Content Describe the arrangements and procedures that will be used for notifying the licensee who arranges for the physical protection of material in transit

(1) of the arrival of the shipment at its destination or (2) of any such shipment that is lost or unaccounted for after the estimated time of arrival at its destination.

7.3 Lost Material Notification [73.67(g)(3)(iii)]

The intent of this requirement is to ensure that, in the event a shipment becomes overdue and no reasonable explanation has been received from the carrier regarding its status, a trace investigation will be conducted to locate the missing SN4.

At this time, the NRC should be notified that the material is missing and informed as to what steps are being taken to recover it. Although the licensee is responsible for notifying the NRC of any missing material and for initiating and assisting in the subsequent investigation, the law enforcement agencies bear the responsibility for physically recovering the material.

Content Describe what procedures will be used to trace any shipment that is lost or has not arrived by the estimated arrival time.

Ensure 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 the shipment, that the NRC will be notified as-specified in S 73.71, and that the shipper or receiver, as appropriate, will also be notified.

5.59-58

8.

EXPORT REQUIREMENTS

This chapter provides guidance on meeting the requirements of paragraph

73.67(g)(4), which reads as follows:

(g)(4)

Each licensee who exports special nuclear material of low strategic significance shall comply with the appropriate requirements specified in § 73.67(c), (g)(1) and (g)(3).

Using Chapters 5, "Material Transportation Requirements," and 7,

"In-Transit Physical Protection Requirements," of Part II of this Standard Format, describe the security procedures that will be used to protect the material up to the point where the receiver accepts physical protection responsibility for the shipment.

5.59-59

9.

IMPORT REQUIREMENTS

This chapter provides guidance on meeting the requirements of paragraph

73.67(g)(5), which reads as follows:

(g)(5)

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

(i)

Comply with the requirements specified in § 73.67(c), (g)(2) and (g)(3), and (ii) Notify the person who delivered the material to a carrier for transport of the arrival of such material.

9.1 Security Requirements [73.67(q)(5)(l)1 Using Chapters 6, "Receiver Requirements--Transportation," and 7,

"In-Transit Physical Protection Requirements," of Part II of this.Standard Format, describe the security procedures that will be used to protect the material from the first point where the shipment is picked up.

9.2 Notification [73.67(g)(5)(ii)]

Intent The intent of this regulation is to ensure that the exporter is notified that the material has arrived safely.

Content Describe the procedures to'be used for notifying the exporter of the material that the shipment was received.

5.59-60

VALUE/IMPACT STATEMENT

A separate value/impact analysis has not been prepared for this regulatory guide.

The guide was developed to provide a standard format and content for the physical security plans that licensees authorized to possess or transport special nuclear material of moderate strategic significance or 10 kilograms or more of material of low strategic significance are required to submit by amendments to Part 73 of the Commission's regulations published July 24, 1979

(44 FR 43280).

A value/impact analysis prepared for the amendments was made available in the Commission's Public Document Room at the time the amendments were published.

This analysis is also appropriate to this regulatory guide.

59-61

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