**CONFIDENTIAL**

**NOTE: WHEN SEPARATED FROM THE APPENDIX, THIS DOCUMENT IS
UNCLASSIFIED**

**NRC INSPECTION MANUAL** NSIR

TEMPORARY INSTRUCTION 2600/009

INSPECTION OF INTERIM COMPENSATORY MEASURES (ICMs) AT

GASEOUS DIFFUSION PLANTS (GDP)

2600/009-01 OBJECTIVE

Provide inspection instructions for determining the status and
effectiveness of licensee actions in response to NRC required interim
compensatory measures (ICMs) for reducing safety and national security
related risks involving malevolent acts at gaseous diffusion plants
licensed by the NRC to possess hazardous material and special nuclear
material (SNM).

2600/009-02 APPLICABILITY

This temporary instruction (TI) is applicable to NRC licensed gaseous
diffusion plant facilities.

2600/009-03 \`BACKGROUND

On May 28, 2002, the Commission issued an Order for the licensees of
GDP's to enhance existing safety and safeguards measures for the
prevention and mitigation of malevolent acts in accordance with NRC
license requirements, comporting with the increased threat environment
following the events of September 11, 2001. The licensees agreed to
complete all of the ICMs by the due date of November 29, 2002, with an
exception for implementing ICM B3 applicable to the Paducah GDP only,
whereby compliance must be completed by March 29, 2003.

**NOTE: WHEN SEPARATED FROM THE APPENDIX, THIS DOCUMENT IS
UNCLASSIFIED**

**CONFIDENTIAL**

In response to the NRC ordered ICMs, licensees committed to actions for
ensuring prevention and mitigation of malevolent acts potentially
involving hazardous materials, SNM, and classified material.

The ICMs and comporting licensee commitments remain in effect pending
notification by the Commission that a significant change in the threat
environment has occurred, or until the Commission determines that other
enhancements are warranted following a more comprehensive evaluation of
existing safety and safeguards measures for preventing and mitigating
malevolent acts.

2600/009-04 RESPONSIBILITIES AND AUTHORITIES

04.01 [Regional Branch Chiefs]{.underline}

a.  Manage TI-related inspection planning, on/offsite inspection, and
    reporting.

b.  Facilitate effective and efficient inspections by coordinating
    inspection related activities with the Security Oversight Section
    Chief, Fuel Cycle & Special Security Programs Section Chief, and
    Information Security Section Chief of the Office of Nuclear Security
    and Incident Response (NSIR) and the Fuel Manufacturing Section
    Chief and Inspection Section Chief of the Office of Nuclear Material
    Safety and Safeguards (NMSS).

c.  Forward a draft report on inspection findings or observations under
    this TI to the Director, Division of Nuclear Security (DNS), NSIR.
    This draft report will be reviewed by a panel to ensure that
    findings and/or observations identified are treated consistently in
    accordance with the enforcement process and to focus early
    management attention on common deficiencies and/or vulnerabilities.
    The review panel will be composed of staff from NSIR, Regions, NMSS,
    Office of Enforcement, and the Office of the General Counsel.

d.  Seek NSIR management concurrence prior to issuing the inspection
    report to the licensee in a timely manner.

e.  Notify the Director, DNS, NSIR and the Fuel Manufacturing Section
    Chief and Inspection Section Chief, NMSS when this TI has been
    completed.

2600/009-05 INSPECTION REQUIREMENTS

The Appendix, which contains "Confidential Information," provides
specific inspection instructions for determining the status and
effectiveness of licensee actions for preventing/mitigating malevolent
acts in accordance with the NRC ordered ICMs and comporting licensee
commitments.

Copies of the Appendix may be obtained from the Security Oversight
Section, DNS, NSIR. Appendix A contains "CONFIDENTIAL INFORMATION" which
must be controlled in accordance with the appropriate Management
Directive governing the NRC Information Security Program.

2600/009-06 INSPECTION GUIDANCE

Preparation for performing the TI requires familiarity with the NRC's
Order requiring licensees to implement safeguards ICMs for GDP
facilities, the licensee's response to the Order, and safeguards
required/implemented in accordance with NRC licensing requirements. The
licensee's responses can be found in the following reference documents:

> **Paducah GDP:** Enclosure #1 to USEC letters to NRC dated January 21,
> 2003 and March 27, 2003.
>
> **Portsmouth GDP:** Enclosure \# 1 to USEC letters to NRC dated July
> 8, 2002 and October 9, 2002.

Inspection activities should be conducted as a team inspection led by
region safeguards inspectors and supplemented by the resident inspector,
emergency preparedness (EP) inspector, and/or other staff necessary for
integrated safety/safeguards inspections.

On-site inspections in accordance with the Appendix should focus on
enhanced safeguards for the materials, site areas, conditions,
activities, system and human performance issues have the potential for
supporting malevolent acts that may cause adverse consequences
involving: a) worker and public health and safety, b) the environment,
c) loss, theft and/or diversion of SNM and hazardous chemicals, and/or
d) unauthorized disclosure, loss, and/or theft of classified material.
In addition to determining the effectiveness of in-situ safeguards, the
effectiveness of the most important management measures for ensuring
safeguards capability, availability, and reliability is to be
determined.

2600/009-07 REPORTING REQUIREMENTS

The results of inspection activities (observations and findings) under
this TI will be documented in an inspection report in accordance with
IMC 610. Inspection report portions associated with the Appendix shall
be subject to CONFIDENTIAL controls in accordance with the appropriate
Management Directive governing the NRC Information Security Program.
Since this is a one-time inspection to determine compliance with the
ICMs, security findings of significance should be discussed with NSIR
prior to their inclusion in the inspection report. To ensure timely
issuance of the inspection report, coordination with NSIR and/or NMSS
(for EP-related issues) should occur as soon as practicable after any
risk significant conditions/activities or potential enforcement issues
are identified.

2600/009-08 COMPLETION SCHEDULE

Inspections of GDP facilities under this TI are to begin commensurate
with, safety and national security related risks involved, GDP licensee
site conditions/activities, and management NSIR/Region management
established priorities. Inspections are to be completed by September 30,
2003. Extension of this date requires approval by the Security Oversight
Section Chief, DNS, NSIR

2600/009-09 EXPIRATION

This TI expires on June 1, 2004.

2600/009-010 CONTACT

Questions regarding the technical aspects of this TI should be directed
to Andrew Rayland, Physical Protection Specialist, Office of Nuclear
Security and Incident Response, Division of Nuclear Security at
301-415-8102. (E-Mail ADR@nrc.gov)

2600/009-11 STATISTICAL DATA REPORTING

For RIT's reporting this inspection will be charged to this TI number.
For inspections completed after this TI has expired the time will be
charged to Development and Maintenance of Safeguards and Security
Inspection Program, RITS Number D91146.

2600/009-12 ORIGINATING ORGANIZATION INFORMATION

12.01 [Organizational Responsibility]{.underline}. This TI was developed
by the Security Oversight Section, DNS, NSIR

12.02 [Resource Estimate]{.underline}. The estimated hours to complete
TI related inspections for each GDP facility are 8 hours for planning,
24 hours for inspecting on-site, and 16 hours for reporting inspection
findings.

12.03 [Training]{.underline}. Inspectors that have been specially
trained in physical protection methods and procedures and qualified
under IMC 1245 "Inspector Qualifications" are required to complete the
inspection. Headquarters Physical Protections Specialists who are not
formally qualified under IMC 1245 will augment the Region Physical
Protection Inspector during the site inspection.

END

Appendix, "Inspection Requirements and Guidance for the Inspection of
Interim Compensatory Measures (ICMs) at Gaseous Diffusion Plants (GDPs)"