NUREG-1619 

Standard Review Plan 

for Physical Protection Plans for the 

Independent Storage of Spent 

Fuel and High-Level Radioactive 

Waste 

U.S. Nuclear Regulatory Commission 

Office of Nuclear Material Safety and Safeguards

P.A. Dwyer
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10018-3308.
NUREG- 1619

Standard Review Plan 

For Physical Protection 

Plans for the Independent Storage of Spent 

Fuel And High-Level Radioactive 

Waste 

Manuscript Completed: July 1998 

Date Published: July 1998 

Prepared by 

P A. Dwyer 

Division of Reactor Program Management 

Office of Nuclear Reactor Regulation 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001
Comments that would make future revisions of this SRP more useful are invited and 

should be directed to: 

Ms. Priscilla A. Dwyer 

Division of Fuel Cycle Safety and Safeguards 

Office of Nuclear Material Safety and Safeguards 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001
ABSTRACT

This document is a standard review plan (SRP) for evaluating plans for the physical 

protection of spent fuel and high-level radioactive wastes stored at (1) independent 

spent fuel storage installations, (2) monitored-retrievable storage installations, and (3) 

the geologic repository operations area. Conducting a review according to an SRP 

ensures that license applicants address every pertinent Nuclear Regulatory 

Commission (NRC) requirement in their NRC-approved physical protection plans and 

ensures consistency and comprehensiveness in the NRC review of the plans. The 

information presented here takes a new matrix or "modular" format to streamline the 

information and facilitate its use.

July 1998 iii NUREG-1619
CONTENTS 

Page 

A bstract . .. . . . .. . . . . . . . . . .. . . . . .. . .. . .. . . . . . . . . . . . . . . . . . . . . . .. . . .. . . iii 

1 Introd uction ............................. ........................... 1 

1.1 Background and Applicability ...................................... 1 

1.2 Purpose of Document ............................................ 1 

1.3 Description of Document .......................................... 1 

1.4 M odular Form at ................................................. 2 

1.5 Protection of Plan ............................................... 2 

2 Basic Steps in the Physical Protection Licensing Process .................... 3 

3 Incorporation by Reference ........................................... 4 

4 Components of Physical Protection Plan ................................. 5 

4.1 Module I - Introduction and Effective Date of Rule ...................... 5 

4.1.1 Introduction ............................................... 5 

4.1.2 Effective Date of Rule ....................................... 5 

4.2 Module II - General Performance Objective and Protection Goal ........... 6 

4.2.1 O bjective ................................................ 6 

4.2.2 Performance Capabilities .................................... 6 

4.2.3 Protection G oal ............................................ 6 

4.3 Module III - Security Organization ............................... 8 

4.3.1 Establishment of Security Organization ......................... 8 

4.3.2 Security A udits ............................................ 8 

4.3.3 Qualifications for Employment in Security ....................... 8 

4.3.4 Security Force Training ...................................... 8 

4.3.5 Records ......................... . 9 

4.4 Module IV - Physical Barrier Systems ............................... 10 

4.4.1 G eneral Layout .......................................... 10 

4.4.2 Physical Barriers .......................................... 10 

4.4.3 Primary Alarm Station and Security Posts ...................... 10 

4 .4.4 Illum ination .............................................. 11 

4.5 Module V - Access Control Subsystems and Procedures ................ 12 

4.5.1 Identification System ....................................... 12 

4.5.2 Access to Protected Areas .................................. 12 

4.5.3 Access Controls at the Protected Area ......................... 12 

4.5.4 Escorts and Escorted Individuals ............................. 12 

4.5.5 Key and Lock Control ...................................... 12 

4.5.6 R ecords ................................................. 12

July 1998 V NUREG-1619
Contents

4.6 Module VI - Detection, Surveillance, and Alarm Subsystems ............. 14 

4.6.1 Isolation Zone Penetration ................................... 14 

4.6.2 Alarm Annunciation at Security Posts ......................... 14 

4.6.3 Power Sources ......................................... 14 

4.6.4 Component Supervision .................................... 14 

4.6.5 Protected Area Monitoring and Assessment ..................... 15 

4.7 Module VII -- Communication Subsystems ........................... 16 

4.7.1 Security Force Communications .............................. 16 

4.7.2 Alarm Station Communications ............................... 16 

4.7.3 Power Sources ........................................... 16 

4.8 Module VIII - Equipment Operability and Compensatory Measures ........ 17 

4.8.1 Equipm ent Operability ...................................... 17 

4.8.2 Compensatory Measures ................................... 17 

4.8.3 Testing and Maintenance ................................... 17 

4.9 Module IX -- Contingency Response Plan and Procedures .............. 18 

4.9.1 Contingency Plan Documentation ............................. 18 

4.9.2 Response Force Liaison .................................... 18 

4.9.3 Response Procedures ...................................... 18 

4 .9.4 R ecords ................................................. 18 

APPENDIX A - RECOMMENDED FORMAT FOR PHYSICAL 

PROTECTIO N PLAN ............................................... 19 

APPENDIX B - GLOSSARY OF TERMS .................................. 22 

APPENDIX C - SAMPLE LICENSE CONDITION ........................... 24

NUREG-1619 Vi July 1998
1 INTRODUCTION

1.1 Background and Applicability 

The U.S. Nuclear Regulatory Commission (NRC) has prepared regulations for the 

physical protection of spent fuel and high-level radioactive waste stored at (1) 

independent spent fuel storage installations (ISFSIs), (2) monitored-retrievable storage 

(MRS) installations, or (3) the future geologic repository operations area codified under 

10 CFR 73.51. These regulations specify the physical protection measures a licensee 

must observe at affected sites and to which a licensee must commit in its NRC

approved physical protection plan. 

1.2 Purpose of Document 

This document is a standard review plan (SRP) for use by NRC license reviewers in 

evaluating physical protection plans prepared pursuant to 10 CFR 60.21(b)(3) (for MRS 

installations and the geologic repository) and 10 CFR 72.24 (for ISFSIs). The SRP 

contains the requirements that a licensee must meet and address in its physical 

protection plan and also contains additional information to be used as guidance in the 

implementation of the regulations. The NRC staff uses the SRP to assure 

comprehensive and consistent license reviews. This document is of use to license 

applicants or licensees seeking an amendment to their license because it presents a 

format acceptable to NRC for the required physical protection plan and concisely 

describes the requirements that the applicant or licensee must meet. This document 

supersedes any interim licensing guidance published before 10 CFR 73.51 was issued. 

1.3 Description of Document 

This document contains nine modules that make up the major elements of physical 

protection plans for meeting the requirements of 10 CFR 73.51. The plans must meet 

the intent of every requirement presented in each module. Following each module is a 

"Guidance" section that contains supplemental information on the NRC's interpretation 

of the regulations, acceptable means for meeting the regulation, and other pertinent 

information. Three appendices contain recommendations on plan format, a user's 

glossary, and a sample license condition. (See Appendices A, B, and C.)

July 1998 1 NUREG-1619
Introduction

1.4 Modular Format 

This SRP has been developed in a new modular format. This effort is part of a new 

initiative by NRC to simplify, and gain efficiencies in, the NRC licensing process by 

presenting information in a user-friendly format. 

1.5 Protection of Plan 

Physical protection plans for the storage of spent fuel and high-level radioactive waste 

should be protected as Safeguards Information in accordance with the provisions of 

10 CFR 73.21.

NUREG-1619 2 July 1998
2 BASIC STEPS IN THE PHYSICAL PROTECTION LICENSING PROCESS 

There are four steps in the NRC evaluation of physical protection plans required to be 

submitted by NRC regulations: submittal, initial review, final review, and issuance of a 

license condition. 

The submittal process can be prompted by the issuance of a new rule or amendments 

to an existing regulation or it can be prompted by a request from the licensee. During 

this process, the applicant or licensee develops its protection strategy for meeting the 

new or amended requirement (or the voluntary request) and documents it in a letter to 

the NRC licensing staff, for review and comment. 

The initial review process is an iterative process in which discussions take place 

between NRC and the licensee or applicant to arrive at a proposal acceptable to NRC. 

A number of proposals may be submitted and evaluated during this process. The 

license reviewer, guided by an SRP, informally ensures that the proposal agreed to is 

adequate and sufficient in meeting NRC requirements. 

The licensee or applicant then makes a formal and final submittal of its proposal. 

License reviewers document their formal review of the proposal in a Safeguards 

Evaluation Report (SER), which is stored and maintained on file for the life of the 

license. 

The physical protection licensing process ends when a license condition is attached to 

the main license. The license condition contains the commitments made by the 

licensee or applicant to meet the new or amended proposal and becomes a permanent 

part of the license, unless it is amended at some future time. Appendix C to this 

document contains a sample license condition that has been attached to a license in 

response to new or amended physical protection requirements or measures.

3 NUREG-1619 July 1998
3 INCORPORATION BY REFERENCE

In addition to the information contained in this SRP, the following documents are 

incorporated by reference, as guidance to support the review process: 

"* Regulatory Guide 5.12, General Use of Locks in the Protection and Control of 

Facilities and Special Nuclear Materials. U.S. Nuclear Regulatory Commission. 

November 1973. 

"* Regulatory Guide 5.44, Perimeter Intrusion Alarm Systems, Rev. 3. U.S. Nuclear 

Regulatory Commission. October 1997. 

"* NUREG-0794, Protection of Unclassified Safeguards Information. U.S. Nuclear 

Regulatory Commission. October 1981.

NUREG-1619 4 July 1998
4 COMPONENTS OF PHYSICAL PROTECTION PLAN

4.1 MODULE I -- INTRODUCTION AND EFFECTIVE DATE OF RULE 

4.1.1 Introduction The licensee should present a general 

description of the facility, including name, 

location, corporation, type of facility, etc. 

4.1.2 Effective date of rule The rule is effective November 12, 1998.

GUIDANCE: 

No additional guidance is provided for this module.

5 NUREG-1619 July 1998
Components of Plan

4.2 MODULE II -- GENERAL PERFORMANCE OBJECTIVE AND PROTECTION 

GOAL

4.2.1 Objective Each licensee shall establish and 

maintain a physical protection system 

with the objective of providing high 

assurance that activities involving special 

nuclear material do not constitute an 

unreasonable risk to public health and 

safety. 10 CFR 73.51(b)(1). 

4.2.2 Performance capabilities To meet the general objective of 

paragraph 73.51 (b)(1), each licensee 

shall meet the following performance 

capabilities: 

(1) Store the spent fuel and high-level 

radioactive waste only within a protected 

area; 

(2) Grant access to the protected area 

only to individuals who are authorized to 

enter the protected area; 

(3) Detect and assess unauthorized 

penetration of or activities within the 

protected area; 

(4) Provide timely communication to a 

designated response force whenever 

necessary; and 

(5) Manage the physical security 

organization in a manner that maintains 

its effectiveness. 10 CFR 73.51 (b)(2). 

4.2.3 Protection goal The physical protection system must be 

designed to protect against loss of 

control of the facility that could be 

sufficient to cause radiation exposure 

exceeding the dose as described in 10 

CFR 72.106. 10 CFR 73.51(b)(3).

NUREG-1619 6 July 1998
Components of Plan

GUIDANCE: 

4.2.3 The design-basis threat for radiological sabotage of power reactors under 

10 CFR 73.1 is not considered appropriate for the types of facilities subject to 

10 CFR 73.51. Hence, a separate protection goal is defined for these facilities.

July 1998 7 NUREG-1619
Components of Plan

4.3 MODULE III -- SECURITY ORGANIZATION 

4.3.1 Establishment of security A security organization with written 

organization procedures must be established. The 

security organization must include 

sufficient personnel per shift to provide 

for monitoring of detection systems and 

the conduct of surveillance, assessment, 

access control, and communications to 

assure adequate response. 10 CFR 

73.51 (d)(5). 

4.3.2 Security audits The physical protection program must be 

reviewed once every 24 months by 

individuals independent of both physical 

protection program management and 

personnel who have direct responsibility 

for implementation of the physical 

protection program. The physical 

protection program review must include 

an evaluation of the effectiveness of the 

physical protection system and a 

verification of the liaison established with 

the designated response force or local 

law enforcement agency. 10 CFR 73.51 

(d)(12). 

4.3.3 Qualifications for employment in Members of the security organization 

security must be ...qualified... to perform assigned 

job duties in accordance with Appendix B 

to Part 73, sections I.A.(1)(a) and (b); 

B(1)(a); and the applicable portions of II. 

10 CFR 73.51(d)(5). 

4.3.4 Security force training Members of the security organization 

must be trained, equipped, qualified, and 

requalified to perform assigned job duties 

in accordance with Appendix B to Part 

73, sections I.A.(1)(a) and (b); B(1)(a); 

and the applicable portions of I1. 10 CFR 

73.51 (d)(5).

NUREG-1619 8 July 1998
Components of Plan

4.3 MODULE III -- SECURITY ORGANIZATION I 

4.3.5 Records The following documentation must be 

retained as a record for three years after 

the record is made or until termination of 

the license. Duplicate records to those 

required under 10 CFR 72.180 and 

10 CFR 73.71 need not be retained. (1) 

A log of individuals granted access to the 

protected area, (2) screening records of 

members of the security organization, 

(3) a log of all patrols, (4) a record of 

each alarm received identifying the type of alarm, location, date and time when 

received, and disposition of the alarm, 

and (5) the physical protection program 

review reports. 10 CFR 73.51(d)(1 3). 

GUIDANCE: 

4.3.3 Appendix B to Part 73, section I.A.(1)(a) requires that the individual possess a 

high school diploma or pass an equivalent performance examination designed 

to measure basic job-related, mathematical, language, and reasoning skills, 

ability, and knowledge required to perform security job duties. 

Appendix B to Part 73, I.A.(1)(b) requires that the individual have no felony 

convictions involving the use of a weapon and no felony convictions that reflect 

on the individual's reliability. 

Appendix B to Part 73, B (1)(a) requires that individuals whose security tasks 

and job duties are directly associated with the effective implementation of the 

licensee physical protection and contingency plans must have no physical 

weakness or abnormalities that would adversely affect their performance of 

assigned security job duties.

9 NUREG-1619 July 1998
Components of Plan

4.4 MODULE IV -- PHYSICAL BARRIER SYSTEMS

4.4.1 General layout Spent nuclear fuel and high-level 

radioactive waste must be stored only 

within a protected area so that access to 

this material requires passage through or 

penetration of two physical barriers, one 

barrier at the perimeter of the protected 

area and one barrier offering substantial 

penetration resistance. 10 CFR 

73.51 (d)(1). 

4.4.2 Physical barriers The physical barrier at the perimeter of 

the protected area must be as defined in 

10 CFR 73.2. Isolation zones, typically 6 

meters [20 feet] wide each, on both sides 

of this barrier, must be provided to 

facilitate assessment. The barrier 

offering substantial resistance to 

penetration may be provided by an 

approved storage cask or building walls 

such as those of a reactor or fuel storage 

building. 10 CFR 73.51 (d)(1). 

4.4.3 Primary alarm station and security The perimeter of the protected area must 

posts be subject to continual surveillance and 

be protected by an active intrusion alarm 

system that is capable of detecting 

penetration through the isolation zone 

and that is monitored in a continually 

staffed primary alarm station and in one 

additional continually staffed location. 

The primary alarm station must be 

located within the protected area; have 

bullet-resisting walls, doors, ceiling, and 

floor; and the interior of the station must 

not be visible from outside the protected 

area. A timely means for assessment of 

alarms must also be provided. 

Regarding alarm monitoring, the 

redundant location need only provide a 

summary indication that an alarm has 

been generated. 10 CFR 73.51(d)(3).

NUREG-1619 10 July 1998
Components of Plan

GUIDANCE: 

4.4.2 A physical barrier means (1) fences constructed of No. 11 American wire gauge 

or heavier wire fabric, topped by three strands or more of barbed wire or similar 

material on brackets angled inward or outward between 30 and 45 degrees from 

the vertical with an overall height of not less than 2.4 meters [8 feet], including 

the barbed topping; (2) building walls, ceilings, and floors constructed of stone, 

brick, cinder block, concrete, steel, or comparable material (openings in which 

are secured by grates, doors, or covers of construction and fastening of 

sufficient strength such that the integrity of the wall is not lessened by any 

opening), or walls of similar construction, not part of a building, provided with a 

barbed topping as described in paragraph (1) of this definition of a height of not 

less than 2.4 meters [8 feet]; or (3) any other physical obstruction constructed in 

a manner and of material suitable for the purpose for which the obstruction is 

intended. 

Vehicle barriers to protect against the malevolent use of a vehicle are not 

presently required at sites subject to 10 CFR 73.51. 

4.4.3 The alternate station may be located at the local law enforcement agency or at 

a commercial alarm monitoring station that has a redundant capability for 

contacting local law enforcement personnel. 

4.4.4 Illumination should be maintained during all periods of darkness (not just during 

periods of assessment). The level of illumination should be sufficient for the 

assessment means used. No required illumination level is specified in 10 CFR 

73.51. It is also recognized that the physical nature of an ISFSI may make it 

difficult to maintain a consistent level of illumination throughout the protected 

area because of obstruction from such structures as storage casks.

NUREG-1619 July 1998

4.4 MODULE IV -- PHYSICAL BARRIER SYSTEMS 

4.4.4 Illumination Illumination must be sufficient to permit 

adequate assessment of unauthorized 

penetration of or activities within the 

protected area. 10 CFR 73.51(d)(2).

11
Components of Plan

4.5 MODULE V -- ACCESS CONTROL SUBSYSTEMS AND PROCEDURES 

4.5.1 Identification system A personnel identification system ... must be established and maintained to 

limit access to authorized individuals. 10 CFR 73.51 (d)(7). 

4.5.2 Access to protected areas All individuals, vehicles, and hand

carried packages entering the protected 

area must be checked for proper 

authorization ... before entry. 10 CFR 73.51 (d)(9). 

4.5.3 Access controls at the protected All individuals, vehicles and hand-carried 

area packages entering the protected area 

must be ... visually searched for 

explosives before entry. 10 CFR 

73.51 (d)(9). 

4.5.4 Escorts and escorted individuals N/A (See Guidance below.) 

4.5.5 Key and lock control A ... controlled lock system must be 

established and maintained to limit 

access to authorized individuals. 10 CFR 73.51 (d)(7). 

4.5.6 Records The following documentation must be 

retained as a record for 3 years after the 

record is made or until termination of the 

license. Duplicate records to those 

required under 10 CFR 72.180 and 10 

CFR 73.71 need not be retained under 

the requirements of this section: (1) a log 

of individuals granted access to the 

protected area; (2) screening records of 

members of the security organization; (3) 

a log of all patrols; (4) a record of each 

alarm received, identifying the type of 

alarm, location, date and time when 

received and disposition of the alarm; 

and (5) the physical protection program I review reports. 10 CFR 73.51 (d)(13).

NUREG-1619

July 1998 12
Components of Plan

GUIDANCE: 

4.5.1 The personnel identification system should provide unique identification of 

individuals granted access to the protected area through such means as a 

picture identification system using a driver's license photograph, a name badge 

system using a badge medium that is difficult to counterfeit, or facial recognition. 

Use of facial recognition should be justified (e.g., long-term employment and 

small site population). 

4.5.4 If an individual can be conclusively identified, is authorized access, and has 

been searched for explosives without positive findings, then no escort is 

required. If the individual cannot meet any one of these three criteria, access to 

the protected area should be denied. 

4.5.5 Regulatory Guide 5.12, General Use of Locks in the Protection and Control of 

Facilities and Special Nuclear Materials (November 1973), should be used as 

guidance in the development of a controlled lock system. 

4.5.6 The applicant or licensee need not describe redundant recordkeeping 

requirements under each module of the plan. Only the records pertinent to the 

particular module need be described.

NUREG-1619

July 1998 13
Components of Plan

4.6 MODULE VI -- DETECTION, SURVEILLANCE, AND ALARM SUBSYSTEMS 

4.6.1 Isolation zone penetration Spent nuclear fuel and high-level 

radioactive waste must be stored only 

within a protected area so that access to 

this material requires passage through or 

penetration of two physical barriers, one 

at the perimeter of the protected area 

and one barrier offering substantial 

penetration resistance. The physical 

barrier at the perimeter of the protected 

area must be as defined in 10 CFR 73.2. 

Isolation zones, typically 6 meters [20 

feet] wide each, on both sides of this 

barrier, must be provided to facilitate 

assessment.... 10 CFR 73.51(d)(1). 

4.6.2 Alarm annunciation at security The perimeter of the protected area must posts be subject to continual surveillance and 

be protected by an active intrusion alarm 

system that is capable of detecting 

penetration through the isolation zone 

and that is monitored in a continually 

staffed primary alarm station and one 

additional continually staffed location... A 

timely means of assessment must also 

be provided. With respect to alarm 

monitoring, the redundant location need 

only provide a summary indication that 

an alarm has been generated. 10 CFR 

73.51 (d)(3). 

4.6.3 Power sources All detection systems and supporting 

subsystems must be tamper indicating 

with line supervision. These systems, as 

well as surveillance/assessment and 

illumination systems, must be maintained 

in operable condition. 10 CFR 

73.51(d)(1 1). 

4.6.4 Component supervision All detection systems and supporting 

subsystems must be tamper indicating 

with line supervision. 10 CFR 

73.51(d)(1 1).

NUREG-1619

July 1998 14
Components of Plan

4.6 MODULE VI -- DETECTION, SURVEILLANCE, AND ALARM SUBSYSTEMS

4.6.5 Protected area monitoring and 

assessment

The perimeter of the protected area must 

be subject to continual surveillance and 

be protected by an active intrusion alarm 

system which is capable of detecting 

penetration through the isolation zone 

and that is monitored in a continually 

staffed primary alarm station and in one 

additional continually staffed location. 10 

CFR 73.51 (d)(3). Isolation zones, 

typically 6 meters [20 feet] wide each on 

both sides of this barrier (the protected 

area barrier) must be provided to 

facilitate assessment. 10 CFR 

73.51(d)(1). The protected area must be 

monitored by daily random patrols. 10 

CFR 73.51(d)(4). A timely means of 

assessment of alarms must also be 

provided. 10 CFR 73.51(d)(3).

I

GUIDANCE: 

4.6.2 The licensee or applicant should follow the guidelines of Regulatory Guide 5.44, 

Perimeter Intrusion Alarm Systems, Rev. 3, regarding alarm annunciation. 

4.6.5 The following factors should be considered in determining frequency of random 

patrols: remoteness of facility, nature of activities located adjacent to the site, 

and size of the storage facility. For example, a minimum of two patrols per day 

should be conducted unless the facility is in a remote area where more patrols 

may be necessary.

NUREG-1619 July 1998 15
Components of Plan

GUIDANCE: 

No additional guidance is provided under this module. 

NUREG-1619 16

4.7 MODULE VII -- COMMUNICATIONS A IJR.•S.,T;M_

4.7.1 Security force communications A security organization with written 

procedures must be established. The 

security organization must include 

sufficient personnel per shift to provide 

for.. .the conduct of...communications to 

assure adequate response. 10 CFR 

73.51 (d)(5).

I

Redundant communications capability 

must be provided between onsite security 

force members and the designated 

response force or local law enforcement 

agency. 10 CFR 73.51(d)(8).

4.7.3 Power sources All detection systems, 

surveillance/assessment systems, and 

supporting subsystems ... as well as 

illumination systems, must be maintained 

in operable condition. 10 CFR 73.51 (d)(11).

July 1998

4.7.2 Alarm station communications
Components of Plan

4.8 MODULE VIII -- EQUIPMENT OPERABILITY AND COMPENSATORY 

MEASURES

4.8.1 Equipment operability 

4.8.2 Compensatory measures 

4.8.3 Testing and maintenance

GUIDANCE: 

4.8.3 The test and maintenance program described in Regulatory Guide 5.44, 

Perimeter Intrusion Alarm Systems, Rev. 3, is an acceptable program for 

maintaining equipment in operable condition. 

July 1998 17 NUREC3-1619

All detection systems and supporting 

subsystems must be tamper indicating 

with line supervision. These systems, as 

well as surveillance/assessment and 

illumination systems, must be maintained 

in operable condition. 10 CFR 

73.51(d)(1 1). 

Timely compensatory measures must be 

taken after discovery of in operability to 

assure that the effectiveness of the 

system is not reduced. 10 CFR 

73.51(d)(1 1). 

All detection systems and supporting 

subsystems must be tamper indicating 

with line supervision. These systems, as 

well as surveillance/assessment and 

illumination systems, must be maintained 

in operable condition. 10 CFR 

73.51(d)(11).
Components of Plan

4.9 MODULE IX -- CONTINGENCY RESPONSE PLAN AND PROCEDURES 

4.9.1 Contingency plan documentation Written response procedures must be 

established and maintained for 

addressing unauthorized penetration of 

or activities within the protected area 

including Category 5, "Procedures," of 

Appendix C to Part 73. 10 CFR 

73.51 (d)(10). 

4.9.2 Response force liaison Documented liaison with a designated 

response force or local law enforcement 

agency must be established to permit 

timely response to unauthorized 

penetrations or activities. 10 CFR 

73.51)(d)(6). 

4.9.3 Response procedures Written response procedures must be 

established and maintained for 

addressing unauthorized penetration of 

or activities within the protected area 

including Category 5, "Procedures," of 

Appendix C to Part 73. 10 CFR 

73.51(d)(10). 

4.9.4 Records The licensee shall retain a copy of 

response procedures as a record for 3 

years or until termination of the license 

for which the procedures were 

developed. 10 CFR 73.51(d)(10). 

GUIDANCE: 

4.9.2 The designated response force could be a privately contracted security force that meets the requirements of Appendix B to Part 73. If the designated 

response force cannot respond in a timely manner, additional protective 

measures may be required, including the use of armed guards. 

4.9.3 It is expected that the contingency plan for the storage of spent fuel and high level radioactive waste will not be as extensive as the plan described for power reactors under Appendix C to Part 73. The contingency plan for the storage of spent fuel and high-level radioactive waste should, as a minimum, include 

Category 5, "Procedures," of Appendix C to Part 73.

NUREG-1619

July 1998 18
APPENDIX A -- RECOMMENDED FORMAT FOR PHYSICAL PROTECTION PLAN 

If the recommended format is used, the applicant should adhere to the numbering 

system of this standard review plan. Under certain circumstances, subsections may not 

be appropriate for a specific application. Clearly state if this is so and give enough 

information to support this conclusion. 

The applicant may wish to submit information in support of an application that is not 

required by regulations and is not essential to the description of the applicant's physical 

protection program. Such information could include, for example, historical data 

submitted in demonstration of certain criteria, discussion of alternatives considered by 

the applicant, or supplementary data regarding assumed models, data, or calculations. 

This information should be provided in an appendix to the plan. 

Upon completion of the plan, the applicant should use the table of contents of this 

document as a checklist to ensure that each subject has been addressed. 

A.1 Style and Composition 

A table of contents should be included in each submittal. 

The applicant should strive for clear, concise presentation of information. Confusing or 

ambiguous statements and general statements of intent should be avoided. Definitions 

and abbreviations should be consistent throughout the submittal, and consistent with 

generally accepted usage. 

Whenever possible, duplication of information should be avoided. The information 

included in other sections of the application may be covered by specific reference to 

those sections. 

Where numerical values are stated, the number of significant figures should reflect the 

accuracy or 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 

should be located in the section in which they are first referenced. Care should be 

taken to ensure that the 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 

people with good vision. 

July 1998 19 NUREG-1619
Recommended Format

A.2 Physical Specifications of Submittal 

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. 

A.2.1 Paper Size 

Text: Paper should measure 21.5 x 28 centimeters [8.5 x 11 inches]. 

Drawings and graphics: 16 x 23 centimeters [6.5 x 9 inches] (to allow for margins) is preferred; however, a larger size is acceptable as long as the finished copy, when folded, does not exceed 21.5 x 28 centimeters [8.5 x 11 inches]. 

A.2.2 Paper Stock and Ink 

Good quality white laser or photocopy paper and consistent ink density for clear 

reproduction by microfilming, photocopying, and printing. 

A.2.3 Paper Margins 

A margin of no less than 2.5 centimeters [1 inch] is to be maintained on the top, bottom, right side, and left side of all pages submitted. 

A.2.4 Printing 

Composition: Text pages should be single spaced. Standard NRC type face and style should be used. 

Reproduction: May be printed or photocopied. Except for an oversized figure, all 

pages of the text will be printed on both sides. 

A.2.5 Binding 

Pages should be punched for a 3-ring loose leaf notebook. 

A.2.6 Page Numbering 

Pages should be numbered consecutively throughout 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, as applicable; and a 

date.

NUREG-1 619 July 1998 20
Recommended Format

A.3 Procedures for Revising Pages 

The updating or revising of data should be on a replacement page basis. The changes 

(revised portion of each page) should be highlighted by a vertical line on the margin opposite the binding margin (outside margin) for each line changed, revised, deleted or 

added. All pages submitted to update, revise, add, or delete pages to the plan shall 

show the date of the change. The transmittal letter should include the index page 

listing the pages to be inserted and the- pages to be removed. When major changes, 

deletions, or additions are made, pages for a revised table of contents should be 

provided. 

A.4 Number of Copies 

The applicant should submit the appropriate number of copies of each requested 

submittal in accordance with 10 CFR 72.16. 

A.5 Public Disclosure 

NRC has determined that it is not in the public interest to disclose the details of physical 

protection programs, and that such details should be protected as Safeguards 

Information pursuant to 10 CFR 73.21 

A.6 Compatibility 

The applicant should ensure that information in the physical protection plan does not 

conflict with the other sections of the application. 

A.7 Schedule for Submittal 

The applicant should contact NRC to determine a schedule for submitting the physical 

protection plan.

July 1998 21 NUREG-1619
APPENDIX B - GLOSSARY OF TERMS

These terms are excerpted from Title 10 of the Code of Federal Regulations (10 CFR 

Parts 72 and 73). 

Independent spent fuel storage installation (ISFSI) - A complex designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage. An ISFSI that is located on the site of another 

facility may share common utilities and services with such a facility and be physically connected to such other facility and still be considered independent, provided that such sharing of utilities and services or physical connections does not (1) increase the probability or consequences of an accident or malfunction of components, structures, or 

systems that are important to safety or (2) reduce the margin of safety as defined in the 

basis for any technical specification of either facility. 

Isolation zone - Any area adjacent to a physical barrier, clear of all objects that could 

conceal or shield an individual. 

Monitored-retrievable storage installation (MRS) - A complex designed, constructed, and operated by the Department of Energy for the receipt, transfer, handling, packaging, possessing, safeguarding, and storage of spent nuclear fuel aged for at least one year and solidified high-level radioactive waste resulting from civilian nuclear activities, pending shipment to a high-level waste repository or other disposal site. 

Physical barrier - (1) Fences constructed of No.11 American wire gauge, or heavier wire fabric, topped by three strands or more of barbed wire (or similar material) on brackets angled inward or outward between 30 degrees and 45 degrees from the vertical, with an overall height of not less than 2.4 meters [8 feet], including the barbed topping; (2) building walls, ceilings, and floors constructed of stone, brick, cinder block, concrete, steel, or comparable materials (openings in which are secured by grates, doors, or covers of construction and fastening of sufficient strength so that the integrity of the wall is not lessened by any opening), or walls of similar construction, not part of a building, provided with a barbed topping (as described in item 1 of this definition) of a height of not less than 2.4 meters [8 feet]; or (3) any other physical obstruction 

constructed in a manner and of materials suitable for the purpose for which the 

obstruction is intended. 

NUREG-1619 22 July 1998
Glossary

Spent nuclear fuel (spent fuel) - Fuel that has been withdrawn from a nuclear reactor 

following irradiation, has undergone at least one year's decay since being used as a 

source of energy in a power reactor, and has not been chemically separated into its 

constituent elements by reprocessing. Spent fuel includes the special nuclear material, 

byproduct material, source material, and other radioactive materials associated with fuel 

assemblies. 

Strategic special nuclear material - Uranium-235 (contained in uranium enriched to 

20 percent or more in the U-235 isotope), uranium-233, or plutonium. 

Watchman - An individual, not necessarily uniformed or armed with a firearm, who 

provides protection for a plant and the special nuclear material therein in the course of 

performing other duties.

23 NUREG-1619 July 1998
APPENDIX C - SAMPLE LICENSE CONDITION

"The licensee shall follow the physical protection plan entitled: '(Insert facility name) 

Independent Spent Fuel Storage Installation Physical Protection Plan,' dated (insert 

date), and as it may be further amended under the provisions of 10 CFR 72.33(e) and 

72.84(d)." 

(The requirements of 10 CFR Part 73, Appendix B, for guard training and qualification, 

are incorporated in Appendix C of the approved physical protection plan. The 

requirements of 10 CFR Part 73, Appendix C, for contingency planning, are 

incorporated into Chapter 1.9 of the physical protection plan.)

NUREG-1619 24 July 1998
NRC FORM 335 U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER 

(2-89) (Assigned by NRC, Add Vol., Supp., Rev., 

NRCM 1102, and Addendum Numbers, If any.) 3201,3202 BIBLIOGRAPHIC DATA SHEET 

(See instructions on the reverse) 

2. TITLE AND SUBTITLE NUREG-1619 

Standard Review Plan for Physical Protection Plans for the Independent Storage of Spent Fuel 

and High-Level Radioactive Waste 3. DATE REPORT PUBLISHED 

MONTH YEAR 

Ju ly 1998 

4. FIN OR GRANT NUMBER 

5. AUTHOR(S) 6. TYPE OF REPORT 

P.A. Dwyer Technical 

7. PERIOD COVERED (inclusive Dates) 

N/A 

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Office or Region, U.S. Nuclear Regulatory Commission, and mailing address; if contractor, 

provide name and mailing address.) 

Division of Fuel Cycle Safety and Safeguards 

Office of Nuclear Material Safety and Safeguards 

US. Nuclear Regulatory Commission 

Washington, D.C. 20555-0001 

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC, type "Same as above'; if contractor, provide NRC Division, Office or Region, U.S. Nuclear Regulatory Commission, 

and mailing address.) 

Same as above

10. SUPPLEMENTARY NOTES 

11. ABSTRACT (200 words or less) 

This document is a standard review plan (SRP) for evaluating plans for the physical protection of spent fuel and high-level 

radioactive waste stored at (1) independent spent fuel storage installations, (2) monitored retrievable storage installations, and 

(3) the geologic repository operations area. Conducting a review according to an SRP ensures that license applicants address 

every pertinent Nuclear Regulatory Commission (NRC) requirement in their NRC-approved physical protection plan and 

ensures consistency and comprehensiveness in the NRC review of the plans. The information here takes a new matrix or "modular" format to streamline the information and facilitates its use.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.) 13. AVAILABILITY STATEMENT 

Standard review plan unlimited 

Physical protection 14. SECURITY CLASSIFICATION 

Spent fuel (This Page) 

Safeguards unclassified 

(This Report) 

unclassified 

15. NUMBER OF PAGES 

16. PRICE

NRC FORM 335 (2-89) This form was electronically produced by Elite Federal Forms, Inc.
Ion recycled 

Federal Recycling Program
STANDARD REVIEW PLAN FOR PHYSICAL PROTECTION PLANS FOR INDEPENDENT 

STORAGE OF SPENT FUEL AHD HIGH-LEVEL RADIOACTIVE WASTE

UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, DC 20555-0001

FIRST CLASS MAIL 

POSTAGE AND FEES PAID 

USNRC 

PERMIT NO. G-67

OFFICIAL BUSINESS 

PENALTY FOR PRIVATE USE, $300

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IV -T UELPR 

sECTVION CH. ICENSING 

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JULY 1998 NUREG- 1619