Publication Date: 11/1/73 Pages: 4 Date Entered: 1/5/93 Title: Visual Surveillance of Individuals in Material Access Areas November 1973 U.S. ATOMIC ENERGY COMMISSION REGULATORY GUIDE DIRECTORATE OF REGULATORY STANDARDS REGULATORY GUIDE 5.14 VISUAL SURVEILLANCE OF INDIVIDUALS IN MATERIAL ACCESS AREAS A. INTRODUCTION Title 10 CFR, Part 73, "Physical Protection of Plants and Materials," delineates requirements for the physical protection of licensee plants and the special nuclear materials used, stored, or processed therein. Paragraph (a)(7) of section 73.60,(1) "Physical Protection of Special Nuclear Material at Fixed Sites," specifically requires that the licensee provide and use on a continuing basis methods to observe individuals within the material access areas to assure that special nuclear material is not diverted. Visual surveillance techniques (e.g., closed-circuit television, observation galleries, or direct visual observation by fellow workers or special surveillants), if used to meet this requirement, can be aided by proper consideration of surveillance requirements both in the initial phases of plant construction and the installation of process equipment and in the continuing development of operating procedures and administrative controls. This guide describes operational measures and physical features which the AEC Regulatory staff considers to be adequate for the implementation of visual surveillance. Such measures are generally not dependent on the nature of the process operations planned for a particular plant. However, specific physical features (for example, glove box enclosures) may not be applicable to all plants. B. DISCUSSION 1. Objective of Surveillance Effective surveillance of individuals having access to special nuclear material (SNM) can enhance the protection and/or probability of recovery of such material in the following manner: ---------- (1) 38 F.R. 30537, 11/6/73. ---------- a. The likelihood of diversion will be reduced. An individual who is aware that his actions are being monitored will tend to be deterred from illegal acts. b. Diversion can be detected. Information can be obtained about the identities and activities of individuals suspected of diverting or attempting to divert SNM from a specific unit process or location in the material access area. c. The capability of recovering diverted material is enhanced. When material is discovered to be missing, reconstruction of the diversion event may be possible from routine surveillance information. d. Surveillance can provide a backup to access control. The presence of unauthorized individuals in a material access area or the nonessential presence of personnel normally authorized access can be observed and documented. 2. Scope of Surveillance As used herein, visual surveillance means the direct or indirect observation of individuals to detect activities potentially involving access to special nuclear material for diversion. In some special cases, visual surveillance (observation) may be replaced by deductive surveillance to assure that special nuclear material is not diverted. For example, if the only special nuclear material allowed in a particular material access area is of a size, weight, or form such that unauthorized removal would be readily detected and this material cannot be clandestinely subdivided into concealable size, weight, or shape, then visual surveillance of individuals in that material access area may be unnecessary. Similarly, if the only SNM in an area is contained in instrumented packages (e.g., a specially designed vault or automated or remotely controlled process equipment) so that any attempt to surreptitiously remove the SNM (such as by attempted bypassing of protective devices or use of manual override options) will be indicated at a manned control console and the individual manning the console will interpret the indication as a potential theft attempt and annunicator systems will assure his cognizance of such an indication, then visual surveillance may not be necessary. Further, different visual surveillance methods may be appropriate to specific parts of a particular facility and for specific purposes. While direct observation may be required for high-risk areas, closed-circuit television may be suitable for others. Information obtained and analyzed immediately could be used to prevent a diversion while information suited to later analysis could be used to identify and apprehend the diverter who may have eluded initial detection. 3. Management Support A well-designed or well-equipped surveillance system will not function satisfactorily without a company-backed policy for proper utilization of the system. Without proper attention to operating procedures, a diversion may be difficult to detect and diverted material much more difficult to recover. If a surveillance system is to be effective, a sufficient number of surveillants must be available to observe processes and individuals during normal operation, during shift change, when the process is shut down such as at night or on weekends, and when conditions are not normal such as during a physical inventory or during an emergency. 4. Surveillance Personnel Surveillance personnel may include guards, watchmen, management personnel, remotely located surveillants and/or fellow workers. To be effective, the surveillant must be familiar enough with the operation he is witnessing to be capable of detecting activities that are not authorized or are inconsistent with established materials protection procedures. Surveillance, whether by fellow workers or others, is subject to certain inherent problems. The use of pairs of workers to observe each other is susceptible to collusion between the two. While this susceptibility can be reduced by rotating the activity assignments of individuals so as not to have set pairs, any surveillance system that relies heavily on fellow worker surveillance must recognize the inherent reluctance of most employees to report a fellow worker. On the other hand, a surveillance system that relies extensively on watchmen, uniformed guards, and remote viewing devices can adversely affect employee morale. A concerted effort by management to instill in its employees a sense of mutual responsibility for the protection of SNM (similar to current safety awareness campaigns which usually combine features of both "fellow worker" and "outsider" surveillance) can serve to counteract these disadvantages. 5. Surveillance Instrumentation The surveillance function can be aided by either optical (mirrors, periscopes, etc.) or electronic (closed-circuit television) hardware systems. Closed-circuit television cameras offer greater operational freedom since they can be mounted on a remotely positioned base and can be equipped with remotely operated pan, tilt, and zoom controls. In either case, the system can be augmented by photography or video tape to provide permanent records for later use. The recording system can also be activated by a command signal from an intrusion alarm to automatically provide a record of any action or irregularity following the indication of intrusion. 6. Physical Characteristics Any interference in the capability to monitor the activities of an individual presents a problem for effective surveillance. This interference may result from unnecessarily complex operating procedures or from inherent physical limitations such as inadequate visibility resulting from poor lighting or the presence of smoke, steam, or fumes or the presence of partitions, physical obstructions, or shielding. To reduce the effect of floor level obstructions, elevated viewing galleries have been used. C. REGULATORY POSITION In addition to the immediate area where SNM is processed or stored (which must be in a material access area(2)), all areas accessible from an SNM process or storage area without a check of individuals and packages for concealed SNM(3) are considered a part of a material access area and when occupied must be provided with a means of observing individuals therein. While visual surveillance techniques are generally applicable to all SNM processing or storage activities, proper attention to SNM storage restrictions (size, weight, form) and protective instrumentation can, in lieu of visual observation, deductively provide assurance that SNM cannot be diverted from or through the area. This section describes operational measures and physical features which will aid the use of visual surveillance for the protection of special nuclear material. ---------- (2) Section 73.60(a)(1) of 10 CFR Part 73. (3) See Regulatory Guide 5.7, "Control of Personnel Access to Protected Areas, Vital Areas, and Material Access Areas. ---------- 1. Operational Measures The following guidelines set forth features and characteristics of administrative and procedural measures acceptable to the Regulatory staff for assuring that satisfactory visual surveillance can be maintained. a. Administrative Controls (1) All facility personnel should be instructed in the objectives of the surveillance system and how it operates. Individuals whose primary responsibility is surveillance (e.g., escorts, watchmen, or guards should be trained(4) in the use of surveillance aids and should be sufficiently familiar with routine plant operations and special purpose activities to be able to recognize irregular procedures. (2) A surveillance system relying on fellow worker surveillance must recognize the reluctance of most employees to inform authorities on the misdeeds of their companions. If utilized, special attention should be given to a program aimed at instilling in each employee a sense of personal jeopardy as a result of a theft of SNM by a fellow worker. (3) Surveillance policies for emergency situations should provide for continued surveillance of personnel evacuating the material access area until they have been checked for concealed SNM, for remote surveillance of the evacuated area while not compromising the surveillance of other areas that may not have been evacuated, and for temporarily assigning special surveillance activities as may be required. (A more detailed description of emergency measures is to be included in another regulatory guide dealing with materials protection under emergency conditions.) b. Operating Procedures (1) The surveillance system should be tested periodically and the results of those tests documented. (a) The range and clarity of fields of view, including the vulnerability of hardware components to interferences from fluorescent lighting or sources of vibration, heat, or electric fields, should be checked. (b) The adherence to required reporting procedures(5) should be verified. (2) Equipment, supplies, and byproducts that are used or are produced in the material access area should be kept in designated storage locations when not in use and should not be allowed to accumulate where they can interfere with surveillance. (3) All aisles and passageways through a material access area should be kept free of temporarily stored process materials, scrap, and trash so as not to interfere with surveillance of the area. ---------- (4) A regulatory guide on the training, equipping, and qualifying of guards and watchman is under development. (5) Includes reports to the AEC and the facility security organization as necessary pursuant to sections 73.71(b) and 73.50(g), respectively, of 10 CFR Part 73. ---------- 2. Aids to Effective Surveillance Whether direct or indirect visual observation techniques are used, the following physical features are acceptable to Regulatory staff to assure a capability for effective visual surveillance. Dimensional guidance is based on generally accepted industrial practice. a. Area Characteristics (1) An area where SNM is processed or stored should be provided with lighting capable of illuminating equipment and working surfaces with no less than 50 ft-candles during normal working hours or when otherwise occupied.(6)(7) (2) Support areas or other "nonprocess or nonstorage" locations within a material access area should be provided with lighting capable of illuminating the area with no less than 30 ft-candles during normal working hours or when otherwise occupied.(6)(7) (3) If obstructions (e.g., room partitions, screen panels, radiation shielding, and safety barricades) interfere with direct surveillance of process aisles, process equipment, or operators, special vantage points, mirrors, or remote viewing devices should be provided. (4) Storage areas for in-process, feed, product, scrap, and waste materials containing SNM should have sufficient capacity that material can be stored in designated locations in a manner that will not interfere with lighting or the field of view of surveillance devices. If storage is above floor level, the area should be arranged with clearly defined aisles between storage racks and shelves. Each aisle that provides access to SNM should be capable of being monitored by direct or indirect visual surveillance. If storage is below floor level (e.g., in trenches or individual pits) the area should be free of partitions, obstructions, or structures above floor level that could conceal an individual from view. (5) Containers of SNM in storage should be arranged so that covers and seals are visible from adjacent aisles or passageways and from a distance of at least 5 feet. (6) Shipping and receiving areas should be arranged with sufficient clear space that movement of an individual around vehicles in the area can be observed. The dock area adjacent to the cargo portal of a vehicle being loaded or unloaded should be kept clear of objects which could obstruct observation of activities within 20 feet of the portal. ---------- (6) Intrusion alarms are required for such areas when unoccupied pursuant to section 73.60(c) of 10 CFR Part 73. (7) ANSI Standard A11.1-1973, "American National Standard Practice for Industrial Lighting." Copies may be obtained from the Illuminating Engineering Society, 345 East 47th Street, New York, New York 10017. ---------- b. Process Equipment Characteristics (1) Surveillance devices or stations should be located so that access ports (covered or in use) or bag out stations of enclosed process lines (glove boxes or hoods) will not be obscured from view. (2) Where possible, material protection devices on, or associated with, process equipment and including auxiliary surveillance equipment itself should be equipped with alarms to signal the surveillant of tampering. Where closed-circuit television with video tape recording is used, it should be coupled to the intrusion alarm system so that an indication of an intrusion will automatically actuate recording equipment. (3) Surveillance devices or stations should be located so that heating and ventilating ducts, utility piping, conduit, or other items providing services to process equipment or equipment enclosures do not block observation of work areas. (4) Process equipment that normally contains SNM should be so arranged (or designed) that openings and drains used to remove liquids, slurries, and dry materials (including samples) from the equipment operate in either a fully open or fully closed mode which is determinable (verifiable) from a distance of at least 10 feet.(8) (5) The boundaries of areas dedicated to a particular process or, in the case of parallel process lines, to a particular line should be clearly marked (e.g., with colored floor tile, painted lines). Clearly marked aisles not less than 8 feet in width should be located between equipment or equipment enclosures that constitute separate process lines or functions. (6) Piping, ducts, or conveyor systems used to move SNM within a process, from one process to another process, and to or from storage should be distinctly marked (e.g., color coded) to identify the contents. (7) All containers for SNM should be designed so as to have characteristic markings and characteristic colors or shapes to identify whether the SNM is buffer storage, final product, scrap for recycle, scrap for recovery, or waste. These containers should also be distinguishable from all other containers in the area. ---------- (8) See also other regulatory guides dealing with the design of process equipment (e.g., Regulatory Guide 5.6, "Design Considerations for Minimizing Residual Holdup of Special Nuclear Material in Drying and Fluidized Bed Operations"). ---------- 1