**NRC INSPECTION MANUAL**NSIR/DSO

INSPECTION PROCEDURE 81200.06

(U) INSPECTABLE AREA:		PROTECTION OF SAFEGUARDS INFORMATION FOR DECOMMISSIONING NUCLEAR POWER REACTORS 

PROGRAM APPLICABILITY:	IMC 2202 Appendix A

81200.06-01	INSPECTION OBJECTIVES

01.01	To determine if the licensee's information protection system effectively protects safeguards information (SGI), as defined in accordance with Title 10 of the *Code of Federal Regulations* (10 CFR) 10 CFR 73.21, and 10 CFR 73.22.

01.02	To verify that the licensee’s program for the protection of SGI is designed and implemented in a manner that protects this information against unauthorized disclosure.

81200.06-02	INSPECTION REQUIREMENTS

General Guidance

The inspection activity outlined within this procedure is intended to be implemented at the discretion of regional management on an "As Needed" basis, when inspector(s) identify degraded licensee performance within the protection of SGI program area.  The risk significance of identified compliance issues or compliance issues indicative of programmatic deficiencies associated with this program area should be the focus of evaluation and the basis for the determination to implement this inspection activity.

Through verification of the inspection requirements within this inspection procedure, the inspector(s) shall ensure that the licensee’s security program associated with this sample provides assurance that the licensee’s program is designed and implemented in a manner that protects against the design basis threat (DBT) of radiological sabotage.

In preparing to complete this procedure, the inspector(s) should familiarize themselves with relevant documentation which may include, but is not limited to, the licensee's physical security plan, site-specific and/or corporate implementing procedures, security post orders; all U.S. Nuclear Regulatory Commission (NRC)-approved licensing actions (i.e., exemptions, license amendments, alternative measures) and security program reviews and audits.  The inspector(s) should consider conducting a review of past security inspection reports for the facility.

The inspector(s) are responsible for ensuring the inspection procedure is completed and evaluated to a level which provides assurance that licensees are meeting the NRC requirements within the security program area being inspected.

This guidance is being provided as a tool which:  (1) recommends to the inspector(s) certain methods and techniques for determining licensee security program compliance and 

effectiveness related to an inspection requirement or; (2) clarifies certain aspects of a regulatory requirement associated with a particular inspection requirement.  Where minimum sampling numbers are indicated (i.e., at least three intrusion detection system zones shall be tested, or at least 20 percent of the total personnel on a shift will be selected for weapons firing etc.), the inspector(s) should adhere as closely as possible to the numbers identified in the guidance.  The inspector(s) may expand the minimum number to aid in determining the extent of the condition, should compliance concerns arise.  Completion of other recommended actions contained in this guidance should not be viewed as mandatory; prior to the inspector determining whether an inspection sample has been adequately addressed.  Should questions arise regarding procedural requirements or guidance, the inspector(s) should consult with regional management or the Office of Nuclear Security and Incident Response, the program office, for clarification.

The inspector(s) should coordinate the conduct of the inspection with the licensee's staff before the inspection.  Key areas of coordination would be scheduling dates and times to conduct observations of areas where SGI is stored and requesting that the licensee's SGI program procedures be made available for the inspector(s) to review.

The following types of non-public security-related information that are not classified as Restricted Data or National Security Information related to physical protection are considered SGI:

a.	The composite physical security plan for the facility or site.

b.	Site-specific drawings, diagrams, sketches, or maps that substantially represent the final design features of the physical security system not easily discernible by members of the public. 

c.	Alarm systems layouts showing the location of intrusion detection devices, alarm assessment equipment, alarm system wiring, emergency power sources for security equipment, and duress alarms not easily discernible by member of the public.

d.	Physical security orders and procedures issued by the licensee for members of the security organization detailing duress codes, patrol routes and schedules, and responses to contingency events. 

	e.	Site-specific design features of plant security communication systems.

f.	Lock combinations, mechanical key design, or passwords integral to the physical security system.

g. Documents and other matter that contain lists or locations of certain 	safety-related equipment explicitly identified in the document or other matter as vital for purposes of physical protection, as contained in security plans, contingency measures, or plant-specific safeguards analyses.

h.	The composite safeguards contingency plan/measures for the facility or site.

i.	The composite facility officer training and qualification plan/measures disclosing features of the physical security system or response procedures.

j.	Information relating to on-site or off-site response forces, including size, armament of response forces, communications systems used for security purposes, and arrival times of such forces committed to respond to security contingency events.

k.	Information that reflects characteristics and attributes of the DBT of radiological sabotage.

l.	Engineering and safety analyses, security-related procedures or scenarios, and other information revealing site-specific details of the facility or materials if the unauthorized disclosure of such analyses, procedures, scenarios, or other information could reasonably be expected to have a significant adverse effect on the health and safety of the public or the common defense and security by significantly increasing the likelihood of theft, diversion, or sabotage of source, byproducts, or special nuclear material.

m.	Information related to the transportation of, or delivery to a carrier for transportation of a formula quantity of strategic special nuclear material or more than 100 grams of irradiated reactor fuel, including:

1.	The composite physical security plan for transportation;

2.	schedules and itineraries for specific shipments of source material, byproduct material, high-level nuclear waste, or irradiated reactor fuel;

3.	arrangements with and capabilities of local police response forces;

4.	locations of safe havens identified along the transportation route;

5.	limitation of communications during transport;

6.	procedures for response to security contingency events;

7.	information concerning tactics and capabilities required to defend against attempted sabotage, or theft and diversion of formula quantities of special nuclear material irradiated reactor fuel, or related information; and 

8.	engineering or safety analyses, security-related procedures or scenarios and other information related to the protection of the transported material if the unauthorized disclosure of such analyses, procedures, scenarios, or other information could reasonably be expected to have a significant adverse effect on the health and safety of the public or the common defense and security by significantly increasing the likelihood of theft, diversion, or sabotage of source, byproduct or special nuclear material.

n.	Information pertaining to safeguards and security inspections and reports, including:

1.	portions of inspections reports; and

2.	evaluation, audits, or investigations that contain details of a licensee’s physical security system or that disclose uncorrected defects, weaknesses, or vulnerabilities in the system.

o.	Portions of correspondence that contain SGI as set forth in 10 CFR 73.22(a)(1) through (a)(3).

One hour has been allocated within the resource estimate of this inspection procedure for the inspector(s) to conduct physical protection program status verifications.  The purpose of the status verification is to ensure that the implementation of the licensee's physical protection program is maintained in accordance with regulations, licensee security plans and implementing procedures.  The inspector(s) should conduct observations of physical protection program elements other than those inspected within this procedure.

02.01	Information Protection System

Verify that the licensee, has established, implemented, and maintains an information protection system that includes the applicable measures for SGI as specified in             10 CFR 73.22 and subsequently published NRC Orders.  (10 CFR 73.21(a)(1)(i) and 73.21(b)(2))

Specific Guidance

For the inspection of this requirement, the inspector(s) should verify that the licensee has developed a program to address the control, protection and designation of SGI and that the implementing measures are documented in procedures.

02.02	Access to SGI

Verify that only authorized personnel are provided access to SGI and that the licensee's process for authorizing access to SGI is based on the criteria listed below.   

(10 CFR 73.22 (b))

a. Personnel must have an established need to know.  (10 CFR 73.22(b)(1))

b. Personnel must have a completed Federal Bureau of Investigation criminal history records check in accordance with 10 CFR 73.57 that is favorably adjudicated.  (10 CFR 73.22(b)(1)) 

c. Personnel must be deemed trustworthy and reliable based upon a background check or other means approved by the Commission (10 CFR 73.22(b)(2)).  The background check, at a minimum, must include:

	1.	verification of identity, based upon a fingerprint check;

	2.	employment history;

	3. 	education; and 

	4.	personal references.

d. Personnel must meet the exemption criteria of the category of individuals specified in 10 CFR 73.59 as exempt from the criminal history records check and background check requirements and have an established need to know. 	(10 CFR 73.22(b)(3))

Specific Guidance

For the inspection of this requirement, the inspector(s) should review the licensee's implementing procedures for the control, protection, and designation of SGI to verify that the licensee screens and provides access to SGI only to personnel who have met the requirements for access to SGI in accordance with the regulations.  The inspector(s) may request that the licensee provide a listing of personnel who have been authorized access to SGI and query licensee security management pertaining to the job description of these personnel which requires that they maintain access to SGI.

02.03	Protection of SGI

a. Verify that the licensee stores unattended SGI in storage containers with locks that possess the characteristics identified in 10 CFR 73.2, “Definitions,” under "Security Storage Container" and "Lock."  (10 CFR 73.22(c)(2))

Specific Guidance

For the inspection of this requirement, the inspector(s) should request that the licensee provide a tour of all areas that SGI is either stored, used, or developed to ensure that all areas have been provided a means to properly protect SGI that is unattended.  The inspector(s) should compare the security storage containers and locks that the licensee 

uses for the protection of SGI to the criteria in 10 CFR 73.2 to ensure that the containers provide the required level of protection.

b.	 Verify that access to the combination to security storage containers, used to store SGI, is controlled to preclude access to individuals not authorized access to SGI.               (10 CFR 73.22(c)(2))

Specific Guidance

For the inspection of this requirement, the inspector(s) should query licensee security management regarding the personnel who have access to SGI security storage containers in each area to ensure that lock combinations, keys, etc., are provided only to those personnel designated for access to these storage containers to preclude unauthorized access to SGI.  Not every individual authorized access to SGI should be provided access to security storage containers that contain SGI.  Restricting access to security storage containers to only designated personnel reduces the potential for the compromise of SGI.

c. Verify that the licensee implements measures for the control of SGI while in use or outside of a locked security storage container and that the measures require SGI to remain under the control of an individual who is authorized access to SGI.

(10 CFR 73.22(c)(1))

Specific Guidance

For the inspection of this requirement, the inspector(s) should review the licensee's implementing procedures for the control, protection and designation of SGI to ensure the licensee addresses the control of SGI when in use or located outside of a security 

storage container.  Whenever possible, the inspector(s) should observe the implementation of these measures to verify that the implementation is consistent with the regulations and licensee procedures.  SGI within alarm stations or rooms continuously manned by authorized individuals need not be stored in a locked security storage container.

d. Verify that the licensee reviews security-related information against the criteria for SGI and properly designates, protects and controls SGI in accordance with regulations and site procedures.  (10 CFR 73.21 & .22)

Specific Guidance

For the inspection of this requirement, the inspector(s) should review the licensee's implementing procedures for the control, protection and designation of SGI to verify that the procedures address the review, screening and evaluation of security-related information to ensure proper designation.  The inspector(s) should also verify that these designation processes are conducted at each location that security-related information is processed or developed to ensure the proper protection of information designated SGI.  

e. Verify that the licensee’s security storage containers used to store SGI do not bear identifying marks that indicate or identify the sensitivity of the information contained within.  (10 CFR 73.22(c)(2))

Specific Guidance

No inspection guidance.

02.04    Processing, Reproducing, and Transmitting SGI

a. Verify that the licensee’s stand-alone computers or computer systems used to process SGI are not connected to a network that is accessible by users not authorized access to SGI.  (10 CFR 73.22(g)(1))

Specific Guidance

For the inspection of this requirement, the inspector(s) should observe computer systems that the licensee uses for the development and processing of SGI.  The inspector(s) should request that the licensee demonstrate the isolation of these systems from accessible operational networks to verify that these systems and the information they possess are not accessible to unauthorized users.

b. Verify that the licensee’s computers used to process SGI that are not located within an approved security storage container have a removable information storage medium that contains a bootable operating system (used to initialize the computer).

(10 CFR 73.22(g)(2))

Specific Guidance

For the inspection of this requirement, the inspector(s) should ensure that computers used to process SGI that are not located within an approved security storage container have removable storage medium that contain bootable operating systems and software application programs.  Data may be saved on the removable storage medium used to boot the operating system or a different removable storage medium.

c. Verify that the licensee locks removable storage mediums from SGI computers in a security storage container when not in use.  (10 CFR 73.22(g)(2))

Specific Guidance

No inspection guidance.

d. Verify that equipment used by the licensee to reproduce SGI does not allow unauthorized access to SGI by means of retained memory or network connectivity.

(10 CFR 73.22(e))

Specific Guidance

When inspecting this requirement, the inspector(s) should review licensee procedures for the reproduction or transmission of SGI utilizing technology such as copy machines or facsimile (FAX) machines to ensure that the licensee has established processes to protect the information such as memory purging and encryption.  The inspector(s) should request to observe the copy machines and FAX machines used for SGI to verify that these machines are capable of the protection as stated in licensee procedures and do not allow unauthorized access and reproduction.

e.  Verify that the licensee’s processes for transporting SGI outside of an authorized place of use or storage include the following measures:  (1) documents are packaged in two sealed envelopes or wrappers to conceal the presence of SGI; (2) the inner envelope or wrapper contains the name and address of the intended recipient and is marked on both sides, top, and bottom with the words “Safeguards Information”; and (3) the outer envelope or wrapper is opaque, addressed to the recipient, contains the address of sender, bearing no markings or indication of the SGI contained within.

(10 CFR 73.22(f)(1)).

Specific Guidance

No inspection guidance.

f. Except under emergency or extraordinary conditions, verify that the licensee’s processes for the electronic transmission of SGI outside of an authorized place of use or storage include the use of NRC approved secure electronic devices, such as FAX or telephone devices or electronic mail that is encrypted by (Federal Information Processing Standard 140-2 or later) a method that has been approved by the NRC.  

(10 CFR 73.22(f)(3))

Specific Guidance

For the inspection of this requirement, the inspector(s) should observe all of the electronic devices used for the transmission, and preparation for transmission, of SGI to ensure that these devices either have the capability to encrypt and/or transmit SGI in accordance with regulatory requirements.  The information is produced by a self-contained secure automated data processing system and transmitters and receivers implement the information handling processes that provide assurance that SGI is protected before and after transmission.  Physical security events required to be reported under 10 CFR 73.71 are considered to be extraordinary conditions.

02.05	Marking of SGI

a. Verify that the licensee implements a process to ensure that documents or other matter,

containing SGI, are conspicuously marked on the top and bottom of each page; i.e., “Safeguards Information.”  (10 CFR 73.22 (d)(1))

b. Verify that the licensee’s processes used to prepare documents containing SGI for delivery to the NRC include marking of transmittal letters or memoranda to indicate that attachments or enclosures contain SGI but that the transmittal document or other matter does not (i.e., “when separated from SGI attachment or enclosure, this document is decontrolled.”).  (10 CFR 73.22(d)(2))

c.	 Verify that the licensee implements a process to ensure that the first page of documents containing SGI bear the name, title, and organization of the individual authorized to make an SGI determination, and who has determined that the document or other matter contains SGI; the date the determination was made; and indicates that unauthorized disclosure will be subject to civil and criminal sanctions.  (10 CFR 73.22(d)(1))

d. Verify that the licensee’s processes used to prepare documents containing SGI for delivery to the NRC include portion marking for the transmittal document, but not the attachment, in accordance with the regulation.  (10 CFR 73.22(d)(3))

Specific Guidance

Documents need not be designated and marked as SGI, top and bottom, if they are already marked and protected as classified information.  Portions of the document containing SGI however must be properly marked to indicate the designation of the information contained therein.

02.06	Removal from SGI Category and SGI Destruction

a. Verify that the licensee implements a process for the removal of documents, or other matter from the SGI category when the information no longer meets the criteria of SGI. (10 CFR 73.22(h))

Specific Guidance

For the inspection of this requirement, inspector(s) should review recently decontrolled documents or other matter to ensure that they do not disclose SGI in another form or when combined with other unprotected information, do not disclose SGI.

b. Verify that the licensee's processes for decontrolling SGI include measures to obtain the authority to remove the information from the SGI category through NRC approval or through consultation with the organization or individual who made the original SGI determination.  (10 CFR 73.22(h))

Specific Guidance

For the inspection of this requirement, the inspector(s) should review the licensee’s procedures for decontrolling SGI to ensure that they include a review by the appropriate entity (usually the agency, department, or personnel who made the original designation) before decontrolling the information.  

c.    Verify that the licensee has established a process for the destruction of SGI and that its method of destruction precludes reconstruction by means available to the public at large.  (10 CFR 73.22(i))

Specific Guidance

For the inspection of this requirement, the inspector(s) should review licensee procedures to verify that the licensee has established measures for the destruction of SGI when the information is no longer needed and that the methodologies (burning, shredding, etc.) prevent reconstruction of the SGI media through any means of reconstruction available to the public at large.  Piece sizes no wider than one quarter inch composed of several pages or documents thoroughly mixed are considered destroyed.

02.07	Reviews

Events and Logs:  Review licensee event reports, safeguards log entries and corrective action program entries for the previous 12 months (or since the last inspection) that concern the protection of SGI program, and follow up, if appropriate.

Security Program Reviews:  Verify that the licensee is conducting security 

program reviews in accordance with 10 CFR 73.55(m) and that the licensee's program for the protection of SGI was included in a review as required by the regulation.  

(10 CFR 73.55(m), Security Plan)

Identification and Resolution of Problems:  Verify that the licensee identifies problems with its SGI protection program at an appropriate threshold and enters problems in the corrective action program.  Verify that the licensee has appropriately resolved the regulatory requirement issue for a selected sample of problems with protection of SGI.  (10 CFR 73.55 (b)(10))

Specific Guidance

The inspector(s) should review safeguards log entries, licensee condition reports, licensee corrective action program entries, etc., for the previous 12 months to determine whether the licensee has experienced issues with the implementation of its SGI program.  The inspector(s) should follow-up on issues identified to ensure the licensee has taken appropriate corrective actions to prevent a re-occurrence of issues identified.  For the inspection of this requirement the inspector(s) should review the documented results of security program reviews or audits performed by the licensee to ensure the continued effectiveness of its SGI program.  The inspector(s) should ensure that the reviews have been conducted in accordance with the requirements of 

10 CFR 73.55(m).  The inspector(s) should also request that the licensee provide a 

copy of the report that was developed and provided to licensee management for review.  The inspector(s) should review the report to identify findings that were identified via the review or audit to ensure that the findings were entered in the licensee's corrective action program.

81200.06-03	PROCEDURE COMPLETION

The decommissioning security inspection program for nuclear power reactor facilities that have permanently shut down emphasizes a balanced look at a cross section of licensee activities important to the conduct of safety and security at decommissioning sites.  Licensee decommissioning security programs and procedures should be assessed to ensure that they afford a comparable level of quality, rigor, and effectiveness as those in existence during reactor power operations.  The decommissioning security inspection program also provides Regional Administrators flexibility in the application of inspection resources to deal with issues and problems at specific plants.  Therefore, all inspection requirements need not be completed for every particular inspection.  However, the inspector(s) should perform a minimum of 50-percent of the applicable inspection requirements within this inspection procedure to ensure the objectives of this inspection procedure are met.

81200.06-04	RESOURCE ESTIMATE

The resource estimate for this inspection procedure is approximately 6 hours of direct on-site inspection effort every 3 years.  These hours of inspection effort are allocated every 3 years or as needed.  Inspection hour estimates are based on current experience and will be reviewed and revised periodically.  It is expected that actual inspection hours will vary from site to site and from the estimate depending on the level of security at decommissioning sites.  Inspection hours shall be pre-planned, tailored to the particular licensee, and scheduled.  The sample size for this procedure is 1.

END

Attachment 1:  Revision History for IP 81200.06

Issue Date:  01/05/21	11	81200.06

Attachment 1 - Revision History for IP 81200.06

Issue Date:  01/05/21	Att1-1	81200.06