Protected Area Long-Term Housekeeping (Generic Letter 89-20)

September 26, 1989



This generic letter is being issued because of a growing concern that objects,
materials and general clutter within the protected area (PA) have the 
potential of adversely impacting the capability of guards in assessing and 
responding to alarms.  Specifically, the effectiveness of the Tactical 
Response Teams (TRT), as required by the new comparability rule, may be 
directly impacted by the lack of unrestricted movement throughout the PA.

Current regulations require that each fuel cycle facility subject to the 
requirements of 10 CFR 73.46 perform TRT exercises under 73.46(b)(9); have 
adequate isolation zones for observing activities and people on either side of
the PA barrier under 73.46(c)(3); illuminate the isolation zones and all 
exterior areas within the PA to allow for the monitoring and observation 
requirements under 73.46(c)(4); detect penetration through the isolation zones
to permit response action under 73.46(e)(1); monitor or periodically check all
exterior areas within the PA under 73.46(e)(8); require guards to interpose 
themselves between any adversary attempting entry for purposes of theft of 
special nuclear material under 73.46(h)(4)(iii)(A); and provide assessment 
capabilities either by CCTV or other suitable means which limit exposure of 
responding personnel to possible attack under 73.46(h)(6). 

Recent performance-oriented team inspections at fuel cycle facilities have 
identified PA clutter as having a negative impact on overall security system 
effectiveness.  PA clutter provides potential cover and concealment for adver-
saries, reduces illumination levels and assessment capabilities, and restricts
the movement of responding forces.  We believe that the presence of these 
cluttered areas inside the PA reduces the licensee's ability to meet the 
system performance objectives of 10 CFR 73.20(a). 

In general, the condition of the PA should not provide cover or concealment 
for an adversary, it should not hinder assessment by either CCTV or a 
responding guard, and it should not cause the illumination to fall below the 
0.2 footcandle level required of the exterior portions of the PA and isolation

Concerns and possible corrective actions covered by this letter include:  

o    Construction within the PA     

     -    Physically separate construction activities from the 
          rest of the PA with a temporary barrier. 

     -    Control access to and from the construction site. 
          Upon completion of the construction the area should be 
          immediately cleared. 

o    Previous construction areas 

     -    Clear any lay-down areas leftover from prior 
          construction activities. 

     -    Fill in and grade earthworks.

     -    Remove any temporary fencing or other obstructions. 

o    Scrap and Waste storage areas 

     -    Process promptly if scrap, or move offsite if waste, if 
          these areas interfere with the effectiveness of the 
          security system. 

     -    Any scrap maintained should be in a separately fenced 
          area, no closer than 25 feet to inner PA fence, but 
          within the PA.* 

o    Vehicle storage 

     -    Establish areas within the PA where all designated 
          licensee vehicles are stored and controlled when not 
          in use. 

     -    Establish this area in a manner that does not add 

In response to this letter licensees should provide a report describing site 
conditions relating to isolation zones, protected areas, construction, waste 
and scrap storage, and vehicle storage or other activities that may obstruct 
observation or reduce illumination levels.  The report should include a 
description of the security maintenance program for the prevention of 
obstructions which may degrade security system performance.  

Pursuant to the Commission's authority in 10 CFR 70.22(d), licensees are 
requested to submit this report and a schedule for correcting deficiencies 
within 90 days of the date of this Generic Letter to:

                         Donald J. Kasun
                         Acting Chief Domestic Safeguards 
                           and Regional Oversite Branch
                         Nuclear Regulatory Commission
                         WFN 4-E-4
                         Washington, D.C. 20555

*(Note that scrap storage may have no more that .25 gms. of U-235 per liter in
30 gallon or larger containers (73.46(c)(6)).

This reporting requirement has been approved by the Office of Management and 
Budget under control number 3150-0009 (see 10 CFR 70.8(a)).

If you have any questions about this matter, please contact C. E. Gaskin at 
(301) 492-0649 or Rocio Castaneira at (301) 492-0392. 


                                        George W. McCorkle, Acting Director 
                                        Division of Safeguards 
                                          and Transportation, NMSS

Page Last Reviewed/Updated Thursday, March 25, 2021