AUGUST 2018 ISSUE

On July 5, 2018 the Government introduced amendments to "Rules of Physical Protection of Nuclear Materials, Nuclear Facilities and Storage Sites of Nuclear Materials" approved by the Government Decree N 456 of July 19, 2007 (also known as PP Rules or Government Decree 456).

The PP Rules is a key regulatory document in the area of physical protection applicable to all civil and military nuclear sites. The rules define the structure of the state PP system, roles and responsibilities of all participants including governing bodies in the use of atomic energy that coordinates activities of nuclear sites, security authorities, law enforcement agencies, National Guard of Russia and nuclear sites. The PP Rules also establish general requirements to major elements of the PP system applicable to stationary sites and transportation of nuclear materials.

There were no substantial revisions to PP Rules since the approval of original document in 2007. In May 2017 Rosatom published the draft revision of the document at the Government web-site http://regulation.gov.ru to solicit comments from experts and the general public (for details see the Summer 2017 issue of Russian Nuclear Security Update). A year later the amendments to PP Rules were enacted.

Partially, revisions introduced to the Rules are already captured in multiple government and lower level documents and implemented in practice. Current changes codify these practices in key PP regulation. At the same time, certain new or revised provisions differ from current practices and will likely drive the development and revision of lower level regulations.

Amendments introduced to PP Rules clarify distribution of PP responsibilities between sites and pro-force securing the sites
The amended PP Rules require site management to cooperate with pro-force securing nuclear site while conducting key PP activities, e.g. vulnerability assessment, effectiveness evaluation, and organizing guard systems at a site, regardless of pro-force type – National Guard troops or agency pro-force. Before, cooperation with pro-force was only required at sites secured by National Guard, and not sites secured by agency pro-force. In addition, the amendments explicitly state that pro-force command is liable for violating requirements of PP Rules.
The amendments also transfer responsibility for operating PPS local alarm stations from site security service to the pro-force securing nuclear sites, while central alarm station must still be operated by the site service.

The amendments address authorities related to defining threats and adversary profiles
Revisions introduced to PP Rules provide Federal Security Service (FSB) with explicit authority to define major threats to nuclear sites in cooperation with concerned government agencies, including Rosatom. The revisions also make the FSB responsible for organizing the development of adversary profiles (design basis threats) tailored for specific nuclear sites and communicating the profiles to the sites.

The amendments added requirements to assessing and evaluating PP at sites, including requirements for the establishment of respective agency procedures
Introduced amendments directly require site PP personnel to conduct analytical work to ensure achievement of PP objectives at a site. PP Rules do not define the scope of analytical work, but require government agencies managing nuclear sites, e.g. Rosatom and Minpromtorg, to establish procedures for analytical work. PP Rules also require government agencies managing nuclear sites to establish quantitative criteria for PPS effectiveness, as well as methodology for evaluating PPS effectiveness. This will likely facilitate resolution of longstanding issue with evaluating PPS effectiveness. Federal Norms and Rules NP-083-15 Requirements to PPS require that sites confirm that PPS effectiveness is above minimum acceptable level. However, it was not established what this minimum acceptable effectiveness is and who is in charge of establishing it.

The amendments establish the legal basis for using automated transportation security system created by Rosatom to support PP of category I and II nuclear materials during transportation
A general requirement is added to PP Rules on the use of systems monitoring status of PP during inter-site transportation of category I and II nuclear materials (NM). It is also defined that agency regulations establish requirements to such monitoring systems. We believe that this provides the legal basis for the use of existing automated transportation security system (ATSS) developed and operated by Rosatom to facilitate PP during transportation of category I and II NM by road vehicles and rail.

The amendments define that any irradiated NM is category II NM
The criteria for categorizing NM provided in appendix to PP Rules are revised so that any irradiated NM is now considered category II NM. Before, category II or III could be defined for irradiated NM depending on characteristics that the NM had prior to the irradiation. It will likely lead to toughening requirements to protecting irradiated NM, including low enriched spent nuclear fuel.

The amendments provide additional PP authorities and responsibilities to National Guard and Rostechnadzor
In addition to the recently established responsibility of the National Guard for securing sites defined by the Government, the amended PP Rules require the National Guard to secure areas at sea ports where vessels with nuclear facilities are moored and/or serviced. The amendments also authorize the National Guard to participate in the development of regulations on providing security to nuclear sites.
Amendments introduced to the Rules also specifically define that Rostechnadzor should oversee PP at sites during emergency response. This may require revisions to Rostechnadzor oversight procedures.

The amendments clarify applicability of PP Rules to radioactive waste and NM and facilities involved in military nuclear programs
The amendments specifically state that PP of nuclear facilities, NM and nuclear weapons operated and handled at sites subordinate to Ministry of Defense is governed by federal regulations on military service and MoD regulations, and not PP Rules. PP at sites subordinate to other Government Agencies, e.g. Rosatom and Minpromtorg, handling and operating NM and nuclear facilities involved in military programs is still governed by PP Rules. The amendments also add direct reference to radioactive waste and respective facilities to the list of items protected in accordance with other regulations, not PP Rules.

Certain changes are introduced with regard to PP equipment systems design
The amendments add system for detecting prohibited items (explosives, NM and metal items) to the list of functional sub-systems constituting the PP equipment system. In addition, the amendments require Federal Security Service (FSB) to organize testing explosives detectors to verify their detection capabilities. It is not clear whether this includes organizing regular testing at sites or tests conducted to define suitability of explosive detectors of a specific design for PPS.
The amended PP Rules also directly state that the surveillance system can include various surveillance equipment, and not only equipment for video surveillance.

The approved amendments described above significantly differ from draft amendments discussed with experts and general public in May 2017
In the Summer 2017 issue of Russian Nuclear Security Update we provided an outline of draft amendments to PP Rules published to solicit comments from experts and general public. A number of those changes were not approved:

• explicit definition of terrorist acts as "unauthorized action" against nuclear sites thus requiring the PP system to protect against terrorist acts and eliminating regulatory ambiguity.
• clarifying that in the case if PP Rules require federal agencies managing nuclear sites to define procedures for certain PP activities such as vulnerability analysis, these procedures must be established as a mandatory agency regulation. Currently, the status and form of these documents are not regulated by PP Rules.
• allowing carriers to be responsible for PP of nuclear materials during transportation. Currently, nuclear sites sending or receiving nuclear materials bear responsibility for their physical protection during transportation.
• establishing explicit requirements to design nuclear sites taking into account PP requirements and current threats.

The completion rate for disposal of spent nuclear fuel (SNF) from the storage facility in Andreeva Bay exceeds the plan, according to the report of Anatoly Grigoriev, official in charge of this project in Rosatom.
The shipping process for SNF from Andreeva Bay started on 27 June 2017. The main infrastructure for the unloading and subsequent export of the SNF from nuclear submarines was put into operation in the former naval base at Andreeva Bay, Murmansk region, in April 2017. The project was arranged under the Federal Target Program "Large-Scale Disposal of Armaments and Military Equipment in 2011-2015 and until 2020" within the framework of Northern Dimension Environmental Partnership. This Partnership includes Rosatom companies and contributor-countries – Norway, Italy, Sweden, - as well as the European Bank for Reconstruction and Development.

Nowadays, the storage in Andreeva Bay is the largest storage facility for nuclear submarines with a total current load of 22,000 spent fuel assemblies. For 2018, it was planned to ship off three batches with SNF for further reprocessing to the Mayak processing facility in Ozersk, Chelyabinsk region. However, all work was completed in just six months.
"The progress rate allows us to announce that we are able to ship-off up to eight batches yearly, but there are some difficulties in ensuring this process. We did not think it would go so fast: we do not have enough containers; we were not ready to draw up a timetable for such traffic. However, Mayak is able to reprocess everything that we would ship", - said Anatoly Grigoriev.
Yet, Rosatom keeps the initial frameworks, continuing to declare the completion of SNF disposal from Andreeva Bay in a ten-year period. Also Rosatom plans to conduct work on the rehabilitation of the Bay's territory.

Sources: "The Coordinating Council of Contributing Countries held its Andreeva Bay meeting", April 24, 2017
"Rosatom confirmed its intention to take out spent nuclear fuel from the Andreeva Bay for 10 years", June 7, 2018

Vladimir Putin signed an order for abolishing the status of a closed city (Administrative Formations with Restricted Access, also known as ZATO in Russian abbreviation) of Shikhani, the Russian closed city hosting one of the enterprises involved in Soviet chemical weapons program near Saratov.

Closed cities received such a status in Soviet times, if the objects of critical importance, especially from defense standpoint, were located in these cities. E.g., Rosatom currently controls 10 R&D and industrial enterprises that are anchors for 10 closed cities. The special legal regime of the closed city provides a number of restrictions including entry into the protected area and staying in it, flight restriction over the city area, restrictions on the right to conduct commercial and business activities, etc. However, the status of a closed city gave certain advantages to its residents. The level of social and living conditions was significantly higher than elsewhere in the country. During scarce Soviet times, such cities were very well supplied. The salary premium was added to the basic salaries of residents to compensate for life in closed city, including so called secrecy premium, and the crime rate was close to zero. At present time, Government continues to support closed cities. According to some sources, the Ministry of Finance allocates about RUB 1 billion (up to $ 15 million) for each city to maintain established legal regime.

In April 2018, The Times reported that a laboratory located in Shikhani manufactured the Novichok, nerve agent allegedly used to poison the former Soviet/Russian military intelligence officer Sergey Skripal and his daughter. Mikhail Babich, the former Head of Russia's State Commission on Chemical Weapons, promptly denied the story. "We know where all the bases that stored chemical weapons were, and Shikhani wasn't one of them," Babich said.

When Russia signed the Convention on the Prohibition of Chemical Weapons in the 90s, the government terminated all activities related to designing chemical weapons. The military 'chemical past' of Shikhani was finished over 20 years ago, which was confirmed by Organization for the Prohibition of Chemical Weapons. More details on Shikhani story were presented in the April 2018 issue of Russian Nuclear Security Update.

However, the Skripal case raised an issue on necessity of restricted access of Shikhani, since no high-security objects were left there. On 17 July 2018, the President signed an order for abolishing the status of a closed city from 1st January 2019. The organizational measures should be conducted within the next six months by government and Saratov authorities. Also the city should receive almost RUB 63 million ($1 million) in the following two years to balance the budget.

Minister for Territorial Entities Affairs, Sergey Zyuzin, commented: "The decision to abolish the status of closed city will give an opportunity to develop Shikhani, attract investors and, in fact, improve the life of the region. To date, there have been restrictions on the regime without any real need. It did not allow using to the full capability, an industrial area placed there. And there is a very good industrial area – it has all energy resources and qualified people living in a closed city. I believe this decision will bring positive results. Before, there were always problems - many entrepreneurs wanted to work there, but it was necessary to get approvals even for entry and exit. Now it will not be a problem."

The authorities of the Saratov region confirmed the possibility to establish territory of priority development in Shikhani after the withdrawal of the closed city status. The territory of priority development is an area with favorable tax conditions, simplified administrative procedures and other privileges. Such territories are formed not only for economic development, but also to create comfortable living conditions for the population.
Shikhani example can be applied to other closed cities, including those under Rosatom, and those of them that are no longer involved in the defense programs can be opened as well.

Sources: 1. "Putin liquidates a government 'restricted-access administrative entity' in a town, where British reporters think Novichok may have been manufactured", 18 July 2018
2. "Putin liquidates a government 'restricted-access administrative entity' in a town, where British security services 'found' the secret chemical weapon", 18 July 2018
3. "Deprivation of the status of ZATO will help Shihan to attract investors", 18 July 2018

The process of establishing security areas around Russian NPPs began this year, as it was mentioned in the April 2018 issue of Russian Nuclear Security Update. For Beloyarsk NPP, such a security area is planned to be implemented by August 2018.

In May-June 2017 the Russian Government issued several decrees aimed at enhancing the security of nuclear sites through implementing additional protection measures, and listed nuclear sites, where security areas with restrictions should be implemented. Detailed information on these anti-terrorist protection measures was provided in the Summer 2017 issue of Russian Nuclear Security Update.

The security area was defined to increase the level of anti-terrorist protection in accordance with Article 31 of the Federal Law N170-FZ, "On the Use of Atomic Energy". The special legal regime of the security area provides restrictions on entry into the security area and staying in it, provides a list of grounds for rejecting entry, as well as measures related to these restrictions including the following:

• Flight restriction (including aircraft) over the safety area
• Restrictions on the right to conduct commercial and business activities
• Restrictions on the right of ownership, use and disposal of natural resources and real estate

The RF legislation establishes liability for violations of the special legal regime.

The Beloyarsk NPP press center reported recently: "Measures on antiterrorist protection and maintenance of public order that should be introduced in August 2018 for the establishing security area around Beloyarsk NPP are mostly familiar for the citizens. These include measures on identifying the facts of preparation to commit illegal actions against Beloyarsk NPP, such as verification of the availability of permits to entry on the territory of security area by vehicle, and by air or water vessel".

Currently, the Beloyarsk NPP is working on the installation of information signs and signs for marking the boundaries of the security area. The instruction on the access regime in the security area at the nuclear site was developed in cooperation with law enforcement agencies and local authorities.

Sources: "Antiterrorist security was increased at Beloyarsk NPP in Zarechny", July 12, 2018

A number of projects on modernization of the physical protection system (PPS) is being carried out at Khmelnitsky NPP, Ukraine, with financial support of the Swedish Radiation Safety Authority and the Norwegian Radiation Protection Authority. On 4 July 2018, representatives of the authorities visited the NPP to meet with its management and get acquainted with the progress and further plans for the projects implementation on PPS improvement.

Modernization of PPS is part of the NPP life extension program carrying on in compliance with the requirements on nuclear and radiation safety. "Our challenge is to perform all planned measures for modernization, reconstruction, and replacement of equipment out of the design service life with modern equipment that meets all requirements for safe operation of the unit. To date, 60% of the work has already been completed", - said Nikolai Panashchenko, General Director of Khmelnitsky NPP, at the meeting.

The main projects on modernization of PPS under implementation are:

• modernization of the access control system and physical protection for the first unit
• establishment of a PPS central alarm station at the site

The Deputy General Director for Physical Protection and Regime of Khmelnitsky NPP, Oleg Redzinets, said that these measures should allow minimizing the influence of the human factor on the physical protection, compliance with relevant requirements of the changed legislation, and integrate all engineering and technical means into a single system with central alarm station.

Work on the projects for modernization of the access control system began in 2015, and cost UAH 58 million ($2.21 million). A significant contribution, 22.3% of the total cost, was made by the Swedish Radiation Safety Authority. Currently, the works on equipment installation are proceeding.
The cost of the project on establishment of the PPS central control panel is UAH 45 million ($ 1.71 million), where UAH 35 million ($ 1.33 million) is just equipment cost. The construction and assembly work is completed.

During the meeting, nuclear and radiation safety specialists visited the construction site of the central alarm station for physical protection, and examined the locations of equipment installation at the access control points, supplied under the contract. Summing up the results of the visit, specialists noted that they were satisfied with the results and ready to continue cooperation.

Sources: "Physical protection system is being improved at Khmelnitsky NPP", July 5, 2018

The first production batch of the thermal protection kits was put into operation at the Siberian Chemical Combine (SCC). SCC is a Rosatom fuel company, one of the largest nuclear fuel cycle sites in the world hosting dozens of tons of weapons grade nuclear materials located in Seversk.

According to the changes in RF legislation, nuclear materials should be protected during transportation from heat stress in addition to mechanical damage. SCC collaborated with Atomstroyexport (a foreign trade engineering company of Rosatom for the construction of nuclear power facilities abroad) and CNIITMASH (R&D institute within a machine-building division of Rosatom) to develop a special thermal protection kit for nuclear material packages used for transportation. The goal was to ensure safety of the enterprises' goods during transportation in normal conditions, and in emergency situations as well.

The thermal protection kit was designed especially for packages used by SCC for the transportation of nuclear material. Mainly it is uranium hexafluoride. The designed kit consists of a cylinder-shaped metal cup and a metal conical cap, and together they form a frame "wrapped" in a heat-resistant heat-insulating layer. The design can withstand temperatures of up to 800 degrees for half an hour, required for the arrival of rapid reaction forces, according to the Federal Regulations for Ensuring Safety/Security in the Use of Nuclear Energy.

The first prototypes were tested and improved by CNIITMASH in 2015. SCC purchased 8 samples for industrial testing in transport packages with nuclear material. In May 2018, SCC put into operation the first production batch of the thermal protection kits. By the end of 2018, SCC plans to decide if these kits would be used to protect all goods transported by the enterprise.

Sources: "Siberian Chemical Combine increased the safety of goods transportation", July 19, 2018

A radiation emergency response exercise took place at Chernobyl NPP in July, 2018. Radioactive cesium theft became the theme of the training. According to the scenario, work on the calibration of a gamma spectrometer was held at the plant for processing liquid radioactive waste, when the ionizing radiation source, Cesium-137, was stolen.

The training was aimed to practice actions and interaction between personnel involved in response to such incidents. The following specialists and departments participated the training: the shift supervisors of the site, emergency planning and response team, security service, radiation safety department, department of radioactive waste management, and other specialists. Also servicemen of the military unit were engaged in the training.

The Head of emergency planning and response team, Dmitry Kondratov, commented: "During the training, the "Emergency Response Plan for Emergency Response and Emergency Situations at Chernobyl NPP" was put into effect. All actions of the team were well coordinated, and carried out promptly. The search team worked professionally, interaction with the military unit was also effective. Training was successfully completed".

Sources: "The theft of radioactive cesium was theme of the training at the Chernobyl NPP", July 13, 2018

A man under the influence of alcohol was detained by military servicemen of Sarov, Rosatom's closed city where All-Russian Research Institute of Experimental Physics, leading Russian nuclear research center, is located. Servicemen arrived to the place where the alarm was triggered and found a man trying to enter into the protected area illegally. The intruder explained that he wanted to visit relatives. The man was handed over to the police for further investigation. Later it was found that he was previously convicted.
A similar incident happened in another Rosatom's closed city Zarechny, Penza region, where PO Start, former Russian nuclear weapon complex enterprise, is located. An attempt to cross the fence of the closed city triggered an alarm. The detained intruder was under the influence of alcohol and previously convicted as well.

Sources: "A convict without a pass was caught on the perimeter of Sarov", July 17, 2018

On 17 June 2018, a citizen of the Czech Republic was detained near the Leningrad Nuclear Power Plant. The suspicious foreigner drew the attention of the guard by taking photos of landmarks including Leningrad NPP from an unguarded area 35 kilometers away from the city. Later it was found that the travel destinations of the 35 years-old Czech were Finland and the Baltic countries, and he was transiting Russia.
A detention report was drawn up for the "Violation on restricted access to border areas" with the max penalty in RUB 1000 ($ 16), as defined by Article 18.2 of the Russian Federation Code on Administrative Infractions.

Sources: "Czech tourist detained for taking photos of Leningrad NPP", June 18, 2018