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