Regulatory Guide 5.52

(Proposed Revision 3 Issued as DG-5004) Standard Format & Content of Licensee Physical Protection Plan for Strategic Special Nuclear Material at Fixed Sites (Other than Nuclear Power Plants)

ML003739235
Person / Time
Issue date:	12/31/1994
From:	Office of Nuclear Regulatory Research
To:
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RG-5.052 Rev 3
Download: ML003739235 (12)

EOU

U.S. NUCLEAR REGULATORY COMMISSION

Revi Decembe SREGULATORY GUIC

OFFICE OF NUCLEAR REGULATORY RESEARCH

REGULATORY GUIDE 5.52 (Proposed Revision 3 was issued as DG-5004)

STANDARD FORMAT AND CONTENT OF A LICENSEE

PHYSICAL PROTECTION PLAN FOR STRATEGIC SPECIAL NUCLEAR MATERIAL

AT FIXED SITES (OTHER THAN NUCLEAR POWER PLANTS)

ision 3 r 1994 PE

A. INTRODUCTION

This regulatory guide describes the standard for mat recommended by the Nuclear Regulatory Com mission (NRC) for preparing physical protection plans for formula quantities of strategic special nuclear mate rial (SSNM) at fixed sites other than nuclear power plants. Formula quantities are sometimes referred to as category I quantities of material. Guidance on the content of physical protection plans is also provided in this regulatory guide.

The requirement for a physical protection plan is included in the regulations for physical protection of licensed activities against theft and radiological sabo tage of formula quantities of SSNM, which are in

10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities"; Part 70, "Domestic Licens ing of Special Nuclear Material"; and Part 73, "Physi cal Protection of Plants and Materials." Specific re quirements for licensees possessing formula quantities of SSNM are found in 10 CFR 73.20, 73.45, and

73.46.

Conformance to the format and content of the physical protection plan presented in this guide is not required by the NRC. The physical protection plan may be submitted for NRC review and approval in an alternative format that provides an equal level of com- USNRC REGUIATORY GUIDES

Regulatory Guides are Issued to describe and make available to the public such information as methods acceptable to the NRC staff for implement ing specific parts of the Commission's regulations, techniques used by the staff in evaluating specific problems or postulated accidents, and data needed by the NRC staff in Its review of applications for permits and licenses. Regulatory Guides are not substitutes for regulations, and corn pliance 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 findings 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 public. 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 information or experience.

Written comments may be submitted to the Rules Review and Directives Branch, DFIPS, ADM, U.S. Nuclear Regulatory Commission, Washing ton, DC 20555-0001.

pleteness and detail if it addresses every applicable sec tion of 10 CFR Part 73, as does this regulatory guide.

Any information collection activities mentioned in this regulatory guide are contained as requirements in

10 CFR Part 73. The information collection require ments in 10 CFR Part 73 have been approved by the Office of Management and Budget, Approval No.

3150-0002.

B.

FORMAT OF THE PHYSICAL

PROTECTION PLAN

This document is divided into two major parts.

The first part describes the physical protection plan format, and the second part outlines the elements of a physical protection program that should be described in the physical protection plan.

If the format in this guide is used, the applicant should follow the numbering system used in Section C,

"Physical Protection Plan Contents." Under some cir cumstances, certain subsections 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 information in support of an application that is not required by the regulations and is not essential to the description of the applicant's physical protection program. This informa tion, which should be relative to the plan, could The guides are Issued In the following ten broad divisions:

1. Power Reactors

2. Research and Test Reactors

3. Fuels and Materials Facilities

4. Environmental and Siting

5. Materials and Plant Protection

8. Occupational Health

9. Antitrust and Financial Review

10. General Copies of issued guides may be purchased from the Government Printing Office at the current GPO price, Information on current GPO prices may be obtained by contacting the Superintendent of Documents, U.S.

Government Printing Office, Mail Stop SSOP, Washington, DC

20402-9328, telephone (202)512-2249.

Issued guides may also be purchased from the National Technical Infor mation Service on a standing order basis. Details on this service may be obtained by writing NTIS, 5285 Port Royal Road, Springfield, VA 22161.

include, for example, historical data submitted in dem onstration of certain criteria, a discussion of alterna tives considered by the applicant, or supplementary data regarding assumed models, data, or calculations.

It should be provided in an appendix to the plan.

STYLE AND COMPOSITION

A table of contents should be included for each submittal.

The applicant should strive for clear, concise pre sentation of information.

Confusing or ambiguous statements and general statements of intent should be avoided. Definitions and abbreviations should be con sistent throughout the submittal and consistent with generally accepted usage.

Whenever possible, duplication of information should be avoided. Information included in other sec tions of the application may be covered by specific ref erence to those sections.

Where numerical values are stated, the number of significant figures should reflect the 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 shbuld be located in the sections in which 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 conform to the following physical dimensions of page size, quality of papers and inks, numbering of pages, etc.

Paper Size Text pages: Either the metric standard A4, which is 210 mm by 297 mm, or the customary 8-1/2 x 11 inches.

Drawings and graphics: The metric A4 size or

8-1/2 x 11 inches is preferred; however, a larger size is acceptable provided the finished copy, when folded, does not exceed the A4 size or 8-1/2 x 11 inches.

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

Paper Margins A margin of no less than 2.5 cm or 1 inch is to be maintained on the top, bottom, and binding side of all pages submitted.

Printing Composition: text pages should be single-spaced.

Type face and style: must be suitable for micro filming.

Reproduction: may be mechanically or photo graphically reproduced. All pages of the text may be printed on both sides, and images should be printed head to head.

Binding Pages should be punched for standard loose-leaf

3-ring binders.

Page Numbering Pages should be numbered sequentially through out the main part of the document. Any appendices may be numbered separately if desired. Each page of the physical protection plan should contain a page number, a revision number if applicable, and a date.

PROCEDURES FOR UPDATING OR REVISING

PAGES

The updating or revising of data and text should be on a replacement-page basis.

The changes or revised portions of each page should be highlighted by a vertical line. The line should be on the margin opposite the binding margin for each line changed or added. All pages submitted to update, revise, or add pages to the report are to 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 addi tions are made, pages for a revised table of contents should be provided.

NUMBER OF COPIES

The applicant should submit the appropriate num ber of copies of each required submittal in accordance with 10 CFR 50.4(b)(2)(ii) and 10 CFR 70.21.

PUBLIC DISCLOSURE

The NRC has determined that public disclosure of the details of physical protection programs is not in the public interest, and such details are withheld in accor dance with 10 CFR 2.790(d). Thus, the physical pro tection section of each application should be submitted as a separate enclosure. Other proprietary or classified information, for example, clarifying correspondence between reviewer and licensee, should be clearly iden tified and submitted in separate enclosures. Each such submittal of proprietary information should request ex-

5.52-2 L1

emption from public disclosure as required in 10 CFR

2.790(b).

COMPATIBILITY

The applicant should ensure that the physical pro tection plan is compatible with the other sections of the application.

SCHEDULE FOR SUBMITTAL

The applicant should contact the NRC to deter mine a schedule for the submittal of the physical pro tection plan.

C. PHYSICAL PROTECTION PLAN

CONTENTS

The following sections describe, in general terms, the material and level of detail that should be included within a physical protection plan. The applicant's physical protection plan should follow the organization and numbering system used in this Section C. The applicable sections of the regulations are cited for each section of the physical protection plan. Upon comple tion of the plan, the applicant should use this regulato ry guide as a checklist to ensure that each subject has been addressed.

1. INTRODUCTION AND SCHEDULE FOR

IMPLEMENTATION

This section should state the corporate name of the applicant, the facility name, and the location of the facility. The applicant should describe the type of facil ity to be operated and the general layout of the facility and its surrounding area. This section should include a map of the entire facility and other maps and illustra tions as appropriate. The applicant should indicate on these maps the locations of physical protection sys tems, subsystems, and major components; all material access areas; vital areas; vaults; entry/exit control points; and alarm stations.

This section should also describe the schedule for implementing the physical protection plan, with special attention to those portions involving new construction, significant physical modification of existing structures, or major equipment installation that may require ex tensions of time. For approved plans, the scheduling of upgrades or new construction should be addressed in this section on a case-by-case basis.

2.

GENERAL PERFORMANCE OBJECTIVES

(10 CFR 73.20(a) and 73.20(b)(1), (2), (3),

and (4))

This section should describe, in general terms, how the physical protection program will have, as its objective, high assurance that activities involving spe cial nuclear material are not inimical to the common defense and security and do not constitute an unrea sonable risk to the public health and safety.

This section should also describe how the perform ance capabilities outlined in 10 CFR 73.45 will be met through the establishment, maintenance, and arrange ment for a physical protection system.

Further, this section should identify those portions of the facility physical protection system for which re dundant and diverse components are necessary in or der to ensure adequate performance, as required by 10

CFR 73.20(b)(2). In general terms, the applicant should describe the subsystems and components to be used to provide this redundancy and diversity and the ways in which these subsystems and components are redundant and diverse.

Finally, this section should describe how the physi cal protection system is designed to ensure that the in tegrity of the system is maintained at all times.

3.

DESIGN BASIS THREAT (10 CFR 73.1)

This section should affirm the intent to prevent, with high assurance, the theft of special nuclear mate rial by the threats described in 10 CFR 73. 1. The plan should also describe how measures used to protect against theft of special nuclear material also provide protection against radiological sabotage.

4.

SECURITY ORGANIZATION

4.1 Establishment of Security Organization (10

CFR 73.46(b) (1))

This section should state whether the security organization is private or contract. If contract, this sec tion should briefly describe the written agreements between the licensee and contract guard force man agement that pertain to how the guard force will meet the requirements of Appendix B, "General Criteria for Security Personnel," and Appendix H, "Weapons Qualification Criteria," to 10 CFR Part 73.

4.2 Security Organization Management (10 CFR

73.46(b)(2) and (3))

This section should describe the structure and management of the security organization, including uniformed security personnel and other persons re sponsible for security-related functions. This section should contain a description of each supervisory and management position, including responsibilities and how lines of authority extend up to facility and corpo rate management.

This section should affirm that written security procedures will be used and that provisions for written approval of such procedures and any revision thereto will be developed and used.

This section should also affirm that at least one full-time member of the security organization with the authority to direct the physical protection activities of the security organization will be on site at all times.

5.52-3

4.3 Qualification for Employment in Security

(10 CFR 73.46(b)(4) and (5))

This section should affirm that an approved guard force training plan in accordance with Appendices B

and H to Part 73 is in effect.

In addition, the plan should describe how the li censee will demonstrate the ability of physical security personnel, whether licensee or contractor employees, to carry out their assigned duties or responsibilities upon the request of an authorized member of the NRC. The plan should also affirm that, within any giv en period of time (at least 1 work shift or 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />), a member of the security organization will not be as signed to or have direct operational control over more than one of the redundant elements of a physical pro tection subsystem, if such assignment or control could result in the loss of effectiveness of the subsystem.

4.4 Guard Force Training (10 CFR 73.46(b)(4),

(7), and (8); II.E of Appendix B to 10 CFR

Part 73; and Appendix H to 10 CFR Part 73)

In addition to the affirmation that an approved guard force training plan is in effect (see Section 4.3 above), this section should include a description of the qualification and requalification program for guards and tactical response team (TRT) members in firing with assigned weapons. For TRT members only, in clude a description of the training program in response tactics.

4.5 Security Force Armament and Equipment

(10 CFR 73.45(g)(3) and 73.46(b)(6))

This section should affirm that every guard and tactical response team member will be armed and should describe the armament assigned to members of the security force by position title. In addition, equip ment to be used by members of the security force in providing effective response capabilities should also be described.

4.6 Force-on-Force Exercises (10 CFR

73.46(b) (9))

This section should describe how scenarios for force-on-force exercises are developed, the design goals for conducting such exercises, and the frequency of such exercises. This section should affirm that the NRC will receive a 60-day notice of one force-on-force exercise each year so that the NRC may observe the exercise.

4.7 Records (10 CFR 73.46(b)(3)(i), (4), (7),

(8), and (9))

This section should affirm that the following records will be maintained and retained and should de scribe how they will be maintained and retained:

"* Current security procedures until the NRC termi nates the license for which these procedures were developed; if any portion of these procedures is superseded, the superseded material should be re tained for 3 years after the change.

"* Results of qualification and requalification for se curity force members; the documentation should be retained as a record for 3 years after each quali fication and requalification.

"* Results of weapons qualification and requalifica tion for firing; the results should be retained as a record for 3 years after each qualification and re qualification.

"* Documentation of completion of training in re sponse tactics by members of the tactical response team; the documentation should be retained as a record for 3 years after the training is completed.

"* Results of tactical response team and guard exer cises; such records should be retained for 3 years after each exercise is completed.

5.

PHYSICAL BARRIERS

5.1 General Layout (10 CFR 73.46(c)(1))

This section should describe facility material ac cess areas (and vital areas, if applicable) with regard to their locations and functions and, in general terms, should describe the spatial relationship between re quired barriers at the protected area and material ac cess areas.

5.2 Protected Area Barriers (10 CFR

73.45(f)(1)(i), 73.46(c)(1) and (2))

This section should identify the physical barriers (including entry/exit points during both opened and closed conditions) at the protected area boundary.

This should include a physical description of the barri ers and a discussion of the purpose of each barrier.

5.3 Vehicle Barriers (10 CFR 73.45(O(1)(i) and

73.46(c) (1))

This section should describe the location and placement of vehicle barriers about the protected area.

A physical description of the barrier system should be included, along with information that substantiates that the barrier can adequately counter the design basis ve hicle. Vehicle control at entry/exit points should also be described.

5.4 Material Access Area Barriers (10 CFR

73.45(b)(1)(i) and 73.46(c) (5) (iii))

This section should describe the level of physical hardening for the walls, floors, and ceilings of the dif ferent types of material access areas at the site, for ex ample, materials used and Underwriter's Laboratory hardening level, if appropriate. The number, location,

-5.52-4 I

and type of entry/exit portals should be described.

Methods used to provide hardening of the portals (during opened and closed conditions) should be de scribed. Hardening of ventilation ducts or other open ings should also be described.

5.5 Security Posts and Structures (10 CFR

73.46(d) (4) (i))

This section should describe the location and pur pose of all permanent security posts and structures.

The physical construction of structures used as security posts should be described.

5.6 Isolation Zones (10 CFR 73.46(c)(3))

This section should describe the location and size of all isolation zones at the facility. The section should affirm that the zones will be maintained clear of ob stacles or structures.

5.7 Illumination (10 CFR 73.46(c)(4))

This section should describe the lighting system at the facility that ensures necessary illumination for all required monitoring, observation, and assessment activities.

5.8 Storage of Strategic Special Nuclear Material

5.8.1 Vaults (10 CFR 73.46(c)(5)(i))

This section should describe the purpose of each vault located within the facility and the wall, floor, and ceiling construction of each vault. The location and type of entry portal to the vault should be described.

5.8.2 Tamper-Indicating Containers (10

CFR 73.46(c) (5) (ii))

This section should describe the construction and use of tamper-indicating containers in the storage of SSNM other than alloys, fuel elements, or fuel assemblies.

5.8.3 Process Material Access Areas (10

CFR 73.46(c)(5)(iii) and (iv))

This section should describe the purpose of each process material access area at the site and the pro tection afforded SSNM (other than alloys, fuel ele ments, or fuel assemblies) while within these material access areas. Both physical and procedural protective measures should be described.

5.9 Storage of Enriched Uranium Scrap (10 CFR

73.46(c) (6))

This section should describe the locations used for storage of enriched uranium scrap and the protection (physical and procedural) afforded these locations.

6.

ACCESS CONTROL SUBSYSTEMS AND

PROCEDURES

6.1 Numbered Picture Badge Identification Systems (10 CFR 73.46(d)(1))

This section should describe the numbered picture badge identification system used at the facility. This description should include a discussion of procedures used for badging individuals with authorized unes corted access to the protected area and for individuals not employed by the licensee but who require frequent and extended access to the protected area. Instruc tions that badged individuals receive in proper badge procedures should also be described, along with proce dures for control of nonbadged emergency response individuals during emergency situations.

6.2 Access to Vital Areas, Material Access Areas, and Controlled Access Areas (10 CFR

73.45(b)(2) and 73.46(d)(2))

This section should describe procedures for deter mining an individual's need for access to a vital area, material access area, or controlled access area; proce dures for the distribution and maintenance of lists of authorized individuals; procedures for ensuring the maintenance of the two-man rule within material ac cess areas; and procedures for ensuring that no activi ties other than those that require access to strategic special nuclear material or necessary maintenance are permitted within material access areas. This section should also describe methods used to visually identify individuals who have authorized unescorted access to vital areas, material access areas, or controlled access areas. This description should note differences in pro cedures, if any, between working and nonworking hours (i.e., nights, weekends, and holidays) and nor mal versus emergency conditions.

6.3 Access Controls at the Protected Area

6.3.1 Personnel (10 CFR 73.45(f)(1) and

(2), 73.46(d)(4)(i) and (ii))

This section should describe how the licensee will control all points of personnel access into the pro tected area, under both normal and emergency condi tions. This description should include the methods used to identify individuals, methods used to verify in dividuals' authorizations, methods used to verify emer gency conditions, and procedures for conducting searches of individuals for firearms, explosives, and in cendiary devices. Individuals exempted from any of the aforementioned access controls should be de scribed. The distribution and maintenance of authori zation lists should also be described.

5.52-5

6.3.2 Hand-Carried Packages (10 CFR

73.45(f)(1) and (2), 73.46(d)(3) and

(5))

This section should affirm that the licensee will establish and follow written procedures that will permit access-control personnel to identify materials in hand carried packages that are not authorized entry to the protected area, during both normal and emergency conditions. Further, this section should describe procedures for searching hand-carried packages at personnel and vehicle access points for firearms, ex plosives, and incendiary devices. The development, distribution, and maintenance of lists of authorized (or unauthorized) materials should be described.

6.3.3 Delivered Packages (10 CFR

73.45(f)(1) and (2), 73.46(d)(3)

and (6))

This section should affirm that the licensee will es tablish and follow written procedures that will permit access-control personnel to identify materials in deliv ered packages that are not authorized entry to the protected area during both normal and emergency conditions. Further, methods used to check for proper identification and authorization should be described along with search procedures for firearms, explosives, and incendiary devices. Any activities exempted from the above procedures should be described. The devel opment, distribution, and maintenance of authorized (or unauthorized) materials lists should be described.

6.3.4 Vehicles (10 CFR 73.45(f)(1) and (2),

73.46(d)(3), 73.46(d)(4)(i),

73.46(d) (7), and 73.46(d) (8))

This section should describe procedures used for controlling all points of vehicle access (nonemergency and emergency) into the protected area and should de scribe how written procedures are established and fol lowed that will permit access-control personnel to identify vehicles that are authorized entry to the pro tected area. The distribution and maintenance of these procedures should be described. Search procedures of all vehicles requiring entry to the protected area for firearms, explosives, and incendiary devices should also be described. Any vehicles exempted from the aforementioned procedures should be described. Pro cedures used for escorting vehicles within the pro tected area and areas where vehicles may have access, along with the purpose for the access, should be de scribed.

6.3.5 Designated Licensee Vehicle (10 CFR

73.46 (d) (8))

This section should describe the control and use of designated licensee vehicles within the protected area.

6.4 Access Controls at Vital Areas, Material Access Areas, and Controlled Access Areas

6.4.1 Personnel (10 CFR 73.45(b)(2) and

73.46(d) (9))

This section should describe the methods used by the licensee to control all points of personnel access to material access areas, vital areas, and controlled ac cess areas, including methods used to verify identifica tion and authorization. Personnel exit searches from material access areas should also be described.

6.4.2 Material (10 CFR 73.45(b)(2) and

73.46(d) (9))

This section should describe procedures for verify ing material entry authorizations and procedures for verifying quantity and type of material. This section should describe the procedures and equipment used to detect unauthorized materials that are hand-carried by authorized individuals or mailed or otherwise shipped as part of an authorized shipment. Describe how con ditions differ between regular working hours and non working hours (i.e., nights, weekends, and holidays).

6.4.3 Vehicles (10 CFR 73.45(b)(2);

73.46(d)(3) and (9))

This section should describe methods used to con trol all points of vehicle access (e.g., under both non emergency and emergency conditions) to material access areas, vital areas, and controlled access areas, including the establishment and maintenance of written procedures that will permit access control per sonnel to identify those vehicles that are authorized entry to material access and vital areas. Vehicle exit searches should-also be described.

6.5 Material Access Area Exit Search of Contaminated Waste (10 CFR

73.46(d)(10) and (12))

This section should describe procedures and areas used for searching contaminated wastes coming from a material access area.

6.6 Shipment of Strategic Special Nuclear Material Offsite (10 CFR 73.46(d) (11)

and (12))

This section should describe containers and areas, as well as procedures, used for shipping strategic spe cial nuclear material offsite.

6.7 Escorts and Escorted Individuals (10 CFR

73.46(d) (13))

This section should identify, by job function, those individuals who may be designated as escorts and de scribe procedures used for escorting individuals during both routine and emergency situations. Such proce dures should describe individuals requiring escort,

5.52-6

badging procedures, training that escorts receive, and recordkeeping.

6.8 Keys, Locks, and Combinations (10 CFR

73.46(d) (14))

This section should describe licensee procedures for controlling all keys, locks, combinations, and re lated equipment used to control access to protected, material access, vital, and controlled access areas.

The description should include the circumstances un der which such keys, locks, etc., are changed and pro cedures followed when an employee with access to such keys, locks, etc., terminates employment.

6.9 Records (10 CFR 73.46(d)(3), (10), and

(13))

This section should describe recordkeeping proce dures for (1) current written procedures that permit access-control personnel to identify vehicles that are authorized and identify materials that are not autho rized entry to protected, material access, and vital ar eas, (2) findings of drum-scanning and tamper-sealing of containers of contaminated wastes coming from ma terial access areas, and (3) the required log of escorted individuals.

7.

DETECTION, SURVEILLANCE, AND

ALARM SUBSYSTEMS

7.1 Isolation Zone Penetration (10 CFR

73.45(f)(1)(ii) and 73.46(e)(1))

This section should describe licensee commit ments for capabilities to detect penetration through re quired isolation zones. Generic equipment types, along with associated detection capabilities, should be de scribed.

7.2 Emergency Exits (10 CFR 73.46(e)(2) and

(5))

This section should describe the location of all emergency exits and describe the protection afforded them.

7.3 Material Access Area and Vital Area Protec tion (10 CFR 73.45(b)(1)(ii) and 73.46(e)(3))

This section should describe protection afforded

(1) unoccupied vital and material access areas, (2) the location of strategic special nuclear material within process material access areas, and (3) vaults and pro cess areas that contain strategic special nuclear materi al that has not been alloyed or encapsulated, including a description of procedures for access to these particu lar vaults and process areas. Generic equipment types used to provide this protection, along with associated detection capabilities, should be described.

7.4 Duress Alarms (10 CFR 73.46(e)(4))

This section should describe the security stations and individuals that are provided with duress alarms.

The type of duress alarms used should be described.

7.5 Central and Secondary Alarm Stations (10

CFR 73.45(g) (5) and 73.46(e) (5))

This section should describe the location and con struction of the central and secondary alarm stations.

Methods used for annunciation of required alarms should be described, along with protection afforded the stations, both procedural and physical, so that a single act cannot remove the capability of calling for assistance or responding to an alarm. The licensee should affirm that the central alarm station will not contain any operational activities that would interfere with the execution of alarm response functions.

7.6 Power Sources (10 CFR 73.46(e)(6))

This section should describe types of security equipment, including alarms, capable of being oper ated from independent power sources, the duration of operation in the event of loss of normal power, and the indications given upon loss of normal power and switchover to standby power. This section should also affirm that switchover to standby power will be auto matic and will not cause false alarms.

7.7 Component Supervision (10 CFR

73.46(e) (7))

This section should describe the physical protec tion afforded to alarm systems, including transmission media, to ensure that the system is not being tampered with, compromised, or on standby power without the knowledge of the licensee. This section should de scribe the annunciation systems at the alarm stations and commit the licensee to indicate the status of all alarms and alarm zones in the alarm stations.

7.8 External Protected Area Monitoring and Assessment (10 CFR 73.45(c) and

73.46(e) (8))

This section should describe methods used to monitor all exterior areas within the protected area and the duration or periodicity of such monitoring.

Criteria used in defining authorized and unauthorized activities and conditions within the protected area should be described, along with methods for develop ing, maintaining, and distributing lists of authorized ac tivities and conditions.

7.9 Observation Methods within Material Access Areas (10 CFR 73.46(e)(9))

This section should describe methods used to ob serve individuals within material access areas to ensure that strategic special nuclear material is not moved to unauthorized locations or moved in an unauthorized

5.52-7

manner. The duration or periodicity of such monitor ing should be described along with criteria used in defining authorized and unauthorized activities and conditions within the material access area. Methods for developing, maintaining, and distributing lists of authorized activities and conditions should be described.

8.

COMMUNICATIONS SUBSYSTEMS

8.1 Security Force Communications (10 CFR

73.45(g) (4) and 73.46(f) (1))

This section should describe how each guard, watchman, or armed response individual on duty will be capable of maintaining continuous communications with the individual in each continuously manned alarm station. This section should also describe how the indi vidual in each continuously manned alarm station will be capable of calling for assistance from other guards, watchmen, and armed response personnel and from law enforcement authorities.

8.2 Alarm Station Communications (10 CFR

73.46(f) (2))

This section should describe the redundant sys tems used to ensure the capability of communications with the local law enforcement authority.

8.3 Power Sources (10 CFR 73.46(0(3))

This section should describe methods used by the licensee to keep nonportable communications equip ment controlled by the licensee operable in the event of loss of normal power.

9.

TEST AND MAINTENANCE PROGRAMS

9.1 Installation and Construction Tests (10 CFR

73.46(g) (1))

This section should describe the testing and in spection program for (1) intrusion alarms, (2) emer gency exit alarms, (3) communications equipment, (4)

physical barriers, and (5) other physical-protection related devices and equipment, used pursuant to 10

CFR 73.46, during the installation and construction of the physical protection subsystems and components.

This description should also include the purpose for and the intended level of the testing and inspection program.

9.2 Pre-Operational Tests (10 CFR 73.46(g)(2))

This section should describe the testing and in spection program for (1) intrusion alarms, (2) emer gency exit alarms, (3) communications equipment, (4)

physical barriers, and (5) other physical-protection related devices and equipment, used pursuant to 10

CFR 73.46, within the pre-operational time frame (af- ter initial installation, but before full-time operation).

This description should include the purpose for and the intended level of the testing and inspection pro gram.

9.3 Operational Tests (10 CFR 73.46(g)(3))

This section should describe the testing and main tenance program for (1) intrusion alarms, (2) emer gency exit alarms, (3) communications equipment, (4)

physical barriers, and (5) other physical-protection related devices and equipment, used pursuant to 10

CFR 73.46, during routine operation. This description should include the purpose for and the intended level of the testing and maintenance program. In addition, specific methods for testing each type of equipment should be included in the description, along with perio dicity of testing.

9.4 Preventive Maintenance Programs (10 CFR

73.46(g)(4) and (5))

This section should describe the preventive main tenance program established to ensure that all physical-protection-related subsystems and compo nents are maintained in operable and effective condi tion. This section should also describe corrective ac tions or compensatory measures used in the event of component failure within physical protection systems.

9.5 Repairs and Maintenance (10 CFR

73.46(g) (5))

This section should describe procedures used in performing repairs and maintenance of physical pro tection systems.

9.6 Reviews and Audits (10 CFR 73.46(g)(6))

This section should describe the applicant's review and audit of the security program. This description should include the periodicity of the review and audit, a description of who will conduct the review and audit, items covered by the review and audit, how the review and audit will be documented, to whom the review and audit documentation will be provided for review, and the recordkeeping associated with the review and audit.

10. CONTINGENCY RESPONSE PLANS AND

PROCEDURES

10.1 Contingency Plan Documentation (10 CFR

73.45(g)(2) and 73.46(h)(1))

This section should affirm that the licensee will have an approved safeguards contingency plan for dealing with threats, thefts, and radiological sabotage related to the strategic special nuclear material and nu clear facilities subject to 10 CFR 73.46. These plans should be developed in accordance with the criteria in Appendix C to Part 73 and should cover, but not nec-

5.52-8 L1

essarily be limited to, the response requirements of 10

CFR 73.46(h) (2) through (h)(5).

10.2 Local Law Enforcement Agency Liaison (10

CFR 73.46(h)(2))

This section should describe the documented re sponse arrangements that the applicant has made with local law enforcement agencies. It should also include estimated response times.

10.3 Tactical Response Force (10 CFR

73.46(h) (3))

This section should describe the number of tacti cal response team members immediately available for response and the duties they will be assigned. In addi tion, the required force of guards or armed responders available to assist the tactical response team should be described, along with a discussion of the rationale for determining the number of individuals in this force of guards or armed responders and the availability of this force.

10.4 Response Procedures (10 CFR 73.45(g)(1)

and 73.46(h) (4))

This section should describe the applicant's re sponse procedures for dealing with detection of abnor mal presence or activity of persons or vehicles within an isolation zone, a protected area, a material access area, or a vital area or evidence or indication of intru sion into a protected area, a material access area, or a vital area. Methods for assessing the threat and neu tralizing the threat should be described.

10.5 Use of Force (10 CFR 73.46(h)(5))

This section should describe the instructions that guards and armed responders will receive in the use of force in the prevention or impeding of theft of strategic special nuclear material.

10.6 Protected Area Alarm Assessment (10 CFR

73.46(h) (6)

This section should describe methods used for providing assessment of all protected area alarms.

10.7 Unoccupied Vault and Material Access Area Alarm Assessment (10 CFR

173.46(h) (7))

This section should describe methods used for as sessing alarms occurring within unoccupied vaults and unoccupied material access areas containing unalloyed or unencapsulated strategic special nuclear material.

10.8 Unoccupied Material Access Area (Alloyed/

Encapsulated Strategic Special Nuclear Material) Alarm Assessment (10 CFR

73.46(h) (8))

This section should describe methods used for as sessing alarms occurring within unoccupied material access areas that contain only alloyed or encapsulated strategic special nuclear material.

10.9 Records (10 CFR 73.46(h)(1) and (2))

This section should describe how the licensee will establish, maintain, and retain as a record the current safeguards contingency plan. Until the Commission terminates the license, if any portion of the plan is su perseded, the licensee should retain the superseded portion for 3 years after the date of the change. This section should also describe the licensee's records of agreements with local law enforcement agencies.

11. AUTHORIZED PLACEMENT AND

MOVEMENT OF STRATEGIC SPECIAL

NUCLEAR MATERIAL WITHIN

MATERIAL ACCESS AREAS

11.1 General (10 CFR 73.45(d))

This section should describe the purpose and ob jective of the measures used to control movement and placement of strategic special nuclear material.

11.2 Establishment of Authorized Placement and Movement of Strategic Special Nuclear Material (10 CFR 73.45(d) (1) (i) and (iii))

This section should describe the criteria to be used to delineate the authorized placement and movement of strategic special nuclear material within each materi al access area. For each material access area, the loca tions within the material access area for which the placement and movement of the strategic special nu clear material are to be authorized should be provided.

The development, maintenance, and distribution of schedules of authorized placement and movement of strategic special nuclear material should also be de scribed.

11.3 Establishment of Current Knowledge of Strategic Special Nuclear Material (10 CFR

73.45(d)(1)(i) and (ii))

This section should describe, for each material ac cess area, the components to be used to verify the type, quantity, and location of strategic special nuclear material within the material access area. Procedures and frequency of activities used to monitor or verify the location of strategic special nuclear material should be described.

11.4 Prevention of Unauthorized Placement and Movement of Strategic Special Nuclear Material (10 CFR 73.45(c) and

73.45 (d) (1) (iv))

This section should describe the measures to be used to detect the unauthorized placement and move-

5.52-9

ment of strategic special nuclear material within each material access area. Also, the containment of strate gic special nuclear material, when the material is be tween the vault and process machinery, should be de scribed.

12. REMOVAL OF STRATEGIC SPECIAL

NUCLEAR MATERIAL THROUGH

MATERIAL ACCESS AREA PORTALS

12.1 Development of Authorization Procedures for Removal (10 CFR 73.45(e)(2)(i) and

(0))

This section should describe how authorization procedures for removal are developed. It should also describe how lists of authorized personnel are to be developed, distributed, and maintained.

12.2 Procedures and Controls for Strategic Special Nuclear Material Removal (Including Scrap and Waste) (10 CFR

73.45 (e) (2))

This section should describe how the identification and authorization of each person presenting strategic special nuclear material for removal from a material access area are to be verified. The confirmation of ver ification of authorization, type, and quantity of strate gic special nuclear material should also be described.

Further, this section should describe the components to be used to detect unauthorized removal of strategic special nuclear material. The components to be used to deter unauthorized attempts to remove strategic spe cial nuclear material from material access areas should be described. Procedures and controls should be dis cussed for both normal conditions (e.g., regular work ing hours and nonworking hours) and emergency con ditions. Procedures used to verify that an emergency condition exists should be described.

13. COMPENSATORY MEASURES FOR

PHYSICAL PROTECTION COMPONENTS

(APPENDIX A)

This section should describe (in generic terms)

compensatory measures to be taken in the event of a failed or degraded component of the physical protec tion system. (This section may be an appendix to the physical protection plan, if desired.)

14. SPECIAL SITUATIONS OR CONDITIONS

AFFECTING PHYSICAL PROTECTION

(APPENDIX B)

This section should describe long-term, site specific unique situations not covered by the main body of the physical protection plan (e.g., decommis sioning activities). (This section may be an appendix to the physical protection plan, if desired.)

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REGULATORY ANALYSIS

A separate regulatory analysis was not performed for this regulatory guide. The regulatory analysis prepared for amendments to 10 CFR 73.46 in 1988 provides the regulatory basis for this guide and examines the costs and benefits of the rule (as implemented by the guide.) A copy of this regulatory analysis is available for inspection and copying for a fee at the NRC Public Docu ment Room, 2120 L Street NW., Washington DC, as Enclosure E to Secy 88-250.

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