Publication Date: 5/1/80
    Pages: 5
    Date Entered: 2/22/84
    Title: USE OF OBSERVATION (VISUAL SURVEILLANCE) TECHNIQUES IN MATERIAL ACCESS AREAS (11/73)
    Revision 1(*)
    May 1980
    U.S. NUCLEAR REGULATORY COMMISSION
    REGULATORY GUIDE
    OFFICE OF STANDARDS DEVELOPMENT
    REGULATORY GUIDE 5.14
    (Task SG 910-4) USE OF OBSERVATION (VISUAL SURVEILLANCE) TECHNIQUES
    IN MATERIAL ACCESS AREAS
A. INTRODUCTION
    Part 73, "Physical Protection of Plants and Materials," of Title
    10, Code of Federal Regulations, specifies performance requirements for
    the physical protection of special nuclear materials and associated
    facilities. Section 73.20, "General Performance Requirements,"
    describes the general performance objective and requirements that must
    be met through the establishment of a physical protection system.
    Performance capabilities necessary to meet the requirements of section
    73.20 are described in section 73.45, "Performance Capabilities for
    Fixed Site Physical Protection." While detection and assessment
    requirements are specified throughout the capability statements,
    specific surveillance and monitoring techniques are required under two
    capability statements of section 73.45. Paragraph 73.45(c) permits only
    authorized activities and conditions within protected areas, material
    access areas, and vital areas. A physical protection system must
    achieve this by detecting unauthorized activities or conditions within
    these areas through detection and surveillance subsystems. Paragraph
    73.45(d) permits only authorized placement and movement of strategic
    special nuclear material within material access areas. This must be
    accomplished through the use of detection and monitoring subsystems and
    procedures to discover and assess unauthorized placement and movement of
    strategic special nuclear material. Finally, section 73.46, "Fixed Site
    Physical Protection Systems, Subsystems, Components and Procedures,"
    outlines typical specific safeguards measures that will often be
    included in an overall system that meets the general requirements of
    Sections 73.20 and 73.45.
    Paragraph (e)(3) of section 73.46 provides for the use of
    closed-circuit television (CCTV) as a means of surveillance in all
    vaults and process areas that contain unalloyed or unencapsulated
    strategic special nuclear material (SSNM).
    ----------
    (*) The substantial number of changes in this revision has made it
    impractical to indicate the changes with lines in the margin.
    ----------
    Paragraph (e)(9) of section 73.46 provides for observation of
    individuals within material access areas (MAAs) to ensure that SSNM is
    not moved to unauthorized locations or in an unauthorized manner.
    Paragraph (h)(7) provides for remote alarm assessment by at least two
    security personnel using CCTV or other means for assessing alarms
    occurring in unoccupied vaults and process areas. The value of the
    observation (visual surveillance) techniques used to meet these
    provisions can be enhanced by careful consideration of surveillance
    needs both in the design phase of plant construction and in the
    continuing development of operational procedures and controls.
    For the purposes of this guide, visual surveillance and
    observation are used interchangeably to mean direct or indirect visual
    monitoring of an area for the purpose of detecting or assessing the
    activities occurring therein.
    This guide describes measures the NRC staff considers acceptable
    for implementing the requirements of surveillance or observation within
    material access areas to ensure safeguarding of strategic special
    nuclear material.
B. DISCUSSION
1. OBJECTIVE OF VISUAL SURVEILLANCE
    The objective of visual surveillance (observation) in MAAs is the
    detection or assessment of activities that could adversely affect the
    safeguarding of SSNM. This could include, among other things, the
    direct observation of individuals' normal work functions within MAAs and
    the remote monitoring of unoccupied areas, e.g., vaults or automated
    process areas, within MAAs. The physical protection benefits to be
    derived from visual surveillance include the following:
    a. The likelihood that insider considerations of theft or
    diversion would be reduced because of an awareness of the increased risk
    of detection,
    b. The probability that attempts at theft or diversion would be
    detected in a more timely manner,
    c. The capability to more effectively reconstruct the events of
    an act of theft or diversion and thus enhance efforts to recover missing
    material,
    d. Continuous verification of the identity of individuals
    within MAAs and the increased ability to determine whether nonessential
    activities are occurring within MAAs.
2. SCOPE OF VISUAL SURVEILLANCE
    Visual surveillance of SSNM, unoccupied MAAs, areas or equipment
    within MAAs, or individuals in MAAs may all be of value from a
    safeguards standpoint.
    Visual surveillance may be one of a number of alternative methods
    that can detect access into an area (authorized or unauthorized). When
    used in conjunction with other detection methods, it can also serve as a
    means to verify access, to assess such access, and to determine whether
    or not a threat exists and how severe it may be Therefore, visual
    surveillance can be an effective means of either detecting or assessing
    personnel access.
    Similarly, visual surveillance may be used to detect or assess the
    position or movement of SSNM itself. In certain circumstances, it may
    be useful as a means of verifying that only authorized activities occur
    during processing operations. Thus, visual surveillance can be useful in
    detecting or assessing the movement of SSNM both within and out of an
    MAA.
    The use of direct observation should be planned so that there is
    reasonable assurance that the activities to be observed are in fact
    observable and that the individual acting as an observer is able to
    recognize and assess a potential problem as such. The use of indirect
    observation such as CCTV should also include consideration of what is
    observable, how accurately it can be interpreted, and by whom.
    In some special instances, visual surveillance may not be
    necessary. For example, when SSNM is contained in special packages or
    automated processes, removal of SSNM could be detected by means other
    than visual surveillance and communicated to the alarm stations for
    initiation of response to a theft or diversion attempt.
    Further, different visual surveillance methods may be appropriate
    to specific parts of a particular facility and for specific purposes.
    While direct observation may be more suitable for some areas, CCTV may
    be more appropriate for others. Visual surveillance may itself serve as
    a primary detection or assessment method or may better serve as a backup
    to some other primary detection or assessment component or subsystem.
3. MANAGEMENT SUPPORT
    A well planned visual surveillance system requires adequate
    management support for optimum operation. Without proper attention to
    administrative and operating procedures, theft or diversion may be
    difficult to detect or assess, and the possibility of recovery may be
    decreased.
4. SURVEILLANCE PERSONNEL
    Surveillance personnel may include guards, watchmen, management
    personnel, or fellow workers positioned locally or remotely. To be
    effective, the observer must be familiar enough with the operation he or
    she is witnessing to be able to recognize activities that are not
    authorized or are not consistent with established safeguards procedures.
    Also for visual surveillance to be effective, a sufficient number of
    observers must be available to provide consistent detection and
    assessment capability. Consideration should be given to the changing
    numbers of observers who might be necessary for different situations,
    such as shift change, shutdown, inventory, or emergency.
    Visual surveillance can be subject to certain inherent problems.
    The use of pairs of workers to observe each other could be susceptible
    to collusion. While this susceptibility can be reduced by rotating pair
    assignments so as not to have set pairs, any surveillance system or
    procedure that relies on fellow worker surveillance must recognize the
    reluctance of most workers to report a fellow worker. This type of
    system may also be of limited effectiveness when workers, in the course
    of their normal functioning, are located out of view of each other or
    must place all their attention on a competing task. In addition, a
    surveillance system that relies extensively on watchmen or remote
    viewing devices can adversely affect employee morale. A safeguards
    awareness program (similar to traditional safety awareness campaigns)
    that emphasizes the importance of visual surveillance procedures to
    overall employee interests can serve to counteract these disadvantages.
5. SURVEILLANCE INSTRUMENTATION
    The visual surveillance function can be significantly aided by the
    proper use of optical or electronic devices such as mirrors, periscopes,
    or CCTV. Closed circuit television systems offer greater area coverage
    per observer and can be positioned and equipped with remotely operated
    controls so that large areas may be scanned or specific sections may be
    concentrated on. One-way viewing enclosures for the cameras may be
    useful in concealing the panning position and field of view of CCTV.
    This may be desirable so that camera scanning time and position cannot
    be easily anticipated by an individual attempting to circumvent the
    system.
    The use of CCTV systems for visual surveillance that include a
    motion detector may also prove useful. Permanent records may be kept by
    the use of video tape recording. A permanent recording system could
    also be activated by an associated video motion detection CCTV system or
    separate intrusion alarm system to automatically provide a record of any
    action or activity occurring in the area of concern. However, the use
    of CCTV should not be considered a satisfactory substitute for the
    two-man rule.
6. PHYSICAL CHARACTERISTICS
    The physical characteristics of an area can substantially affect
    the capability to effectively observe those activities occurring within
    it. Where interior partitions, equipment, material, or shielding
    obstruct the view, elevated viewing locations may be used.
C. REGULATORY POSITION
    Visual surveillance techniques can be useful in meeting some of
    the performance capability statements of section 73.45. Examples of
    specific visual surveillance techniques for MAAs and vaults and process
    areas containing unalloyed and unencapsulated SSNM that are typically
    included in a licensee physical protection system are provided in
    paragraphs 73.46(e)(3), (e)(9), and (h)(7) of 10 CFR Part 73. This
    section describes operational measures and physical features that will
    aid the use of visual surveillance for the protection of strategic
    special nuclear material.
1. OPERATIONAL MEASURES
    The following sections describe features and characteristics of
    visual surveillance measures acceptable to the Commission for ensuring
    that satisfactory observation can be maintained.
    a. Administrative Controls
    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., authorized individuals, watchmen,
    or guards) should be trained(1) in the use of surveillance devices and
    systems and should be sufficiently familiar with both routine and
    special plant operations to be able to recognize unauthorized activity.
    A surveillance system relying on fellow worker surveillance must
    recognize the reluctance of most employees to report the misdeeds of
    fellow workers to management. When such a system is used, special
    attention should be given to a program aimed at instilling in each
    employee a sense of personal responsibility for prevention of a theft or
    diversion of SSNM by a fellow worker.
    Surveillance policies for emergency situations should provide, if
    at all possible, for continued surveillance of personnel evacuating a
    material access area until they have been checked for concealed SSNM,
    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.
    ----------
    (1) Training requirements for guards and watchmen may be found in
    Appendix B, "General Criteria for Security Personnel," to 10 CFR Part 73
    and NUREG-0464, "Site Security Personnel Training Manual," Volumes 1, 2,
    3, and 4. Copies of NUREG-0464 may be obtained from the National
    Technical Information Service, Springfield, Virginia 22161.
    ----------
    b. Operating Procedures
    The surveillance system should be tested periodically and the
    results of these tests documented. The range and clarity of fields of
    view, including the vulnerability of hardware components to interference
    from fluorescent lighting or sources of vibration, heat, or electric
    fields, should be checked. The adherence to the reporting procedures
    required by paragraphs 73.45(g) and 73.71(b) of 10 CFR Part 73 should be
    verified.
    Visual surveillance procedures for the purpose of observing
    individuals in MAAs should provide assurances that an individual is
    always in the field of view of an observer. Where an independent means
    of monitoring the location or manner of movement of SSNM is used, the
    use of visual surveillance procedures should be available as an
    assessment tool in the event of an alarm or other indication of abnormal
    occurrence.
    When CCTV is used to observe vaults and process areas containing
    unalloyed or unencapsulated SSNM, it should, as a minimum, provide a
    field of view that covers the total area occupied by the SSNM. The use
    of automatic panning cameras to provide this field of view is
    acceptable. In cases where SSNM is stored in multiple locations, making
    it impractical to provide total CCTV coverage, an acceptable alternative
    is a field of view that covers doors and normal approaches to material.
    Visual surveillance as used to assess alarms in unoccupied vaults
    or process areas containing unalloyed or unencapsulated SSNM should be
    accomplished by two individuals using CCTV or other remote means. Where
    the field of view does not provide complete assurance of the nature of
    the alarm, direct observation of the exterior roof and walls may be
    necessary for adequate assessment.
    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.
    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.
2. AIDS TO EFFECTIVE SURVEILLANCE
    Whether direct or indirect visual observation techniques are used,
    the following physical features are acceptable to the Commission for
    ensuring a capability for effective visual surveillance.
    a. Area Characteristics
    An area where SSNM is processed or stored should be provided with
    lighting sufficient to provide adequate visual detection and assessment
    of the activities occurring within the area. The actual amount of
    lighting necessary is dependent on the purpose of the area; its size,
    configuration, and reflective characteristics; and the illumination
    requirements of any equipment used, such as CCTV cameras.
    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.
    Storage areas for in-process, feed, product, scrap, and waste
    materials containing SSNM 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 areas should be arranged with
    clearly defined aisles between storage racks and shelves. Each aisle
    that provides access to SSNM 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.
    Containers of SSNM 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.
    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 that
    could obstruct observation of activities within 20 feet of the portal.
    b. Process Equipment Characteristics
    Surveillance devices, if used, 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.
    Where possible, detection or monitoring devices on, or associated
    with, process equipment, including remote surveillance devices or
    associated equipment, should be equipped with tamper alarms. Where CCTV
    with video tape recording is used, the recording function should be
    activated as an indication of alarm. Such use does not serve as a
    substitute for the use of the two-man rule to observe individuals.
    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.
    Piping, ducts, or conveyor systems used to move SSNM within a
    process, or from one process to another process, and to or from storage
    should be distinctly marked (e.g., color coded) to enhance
    identification of contents and function.
    All SSNM containers should be designed so as to have
    characteristic markings to identify whether the SSNM 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.
    VALUE/IMPACT STATEMENT
    A separate value/impact analysis has not been prepared for the
    revision to this regulatory guide. The changes were made to make the
    guide consistent with the upgraded physical protection amendments to the
    regulations published in final form in the Federal Register of November
    28, 1979 (44 FR 68184). A value/impact analysis prepared for the
    proposed amendments was made available in the Commission's Public
    Document Room, 1717 H Street, NW., Washington, D.C., at the time the
    proposed amendments were published. This analysis is appropriate for
    the final amendments as well as for the regulatory guide revisions
    appropriate to those amendments.
    2