ML19310A814
| ML19310A814 | |
| Person / Time | |
|---|---|
| Issue date: | 04/06/1977 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8006300544 | |
| Download: ML19310A814 (55) | |
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CR 2891 UNITED STATES OF AMERICA TAPES:
2 ro NUCLEAR REGULATORY COMMISSION 3
f 4
5 6
DEVELOPMENT OF. AN EVALUATION ' PROGRAM 7
8 9
10 1717 H Street, N. W.
y; Washington, D. C.
12 Wednesday, 6 April 1977
(
13 14 15 16 17 18 (THIS TRANSCRIPT WAS PREPARED FROM A TAPE RECORDING. )
i 19 PRESENT:
0 Marcus A. Rowden, Chairman Victor Gilinsky, Member 4
21 Richard T. Kennedy, Member 22 Samuel J. Chilk, Secretary 23 K. Chapman E. Volgenau B. Huberman 24 M. Von Ehrenfried w
25 l
l 800830064/f-
2 9
1 PROCEEDINGS 2
MR. CHAPMAN:
The meeting today is basically to 3
respond to the Commission's direction issued on the 18th of 4
5 January telling us to proceed with developing an evaluation Program over the next nine months with particular attention to 6
certain facilities.
7 At the time that direction came to us we had, I guess, g
depending on how finely one divides the line, some number like six different ways that we were considering looking at facilities.
Those have been, between IE and ourselves, have been boiled down to four techniques that we think can be integrated into a very sensible inspection and evaluation program, to give us a high confidence review, if you will, of fuel cycle 14 facilities.
15 And we are here today -- we have sent the paperwork 16 down in early March.
We are here today to describe that program 17 in concept.
18 The implementation, I believe, then, I think, on 19 this taeeting, Commission approval of the general plan, although 20 we have begun already to take some of the steps that are 21 necessary to get that program under way.
22 I think there is a fundamental issue that underlies 23 the subject today, and it has come up in the Congress also, and 24 that is the division between the Licensing Office and the i
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Inspection Office with regard to determinations of facilities 2
and in the reactor case, safety, and in our case, safeguards.
3 In my opinion we must have in the Licensing Offices 4
some authority for field visits to determine the effectiveness 5
of our programs.
6 Where we draw that line is still a bit gray.
7 The briefing here today is an integrated briefing.
O I think we rre all in agreement -- Ernst is in agreement, I 9
believe -- with respect to the briefing: itself, the general 10 approach, and so on.
11 What we have not done is to draw this line and I 12 would recommend, in fact, that we probably not do that unless 13 forced to until we have had more experience with the evaluation 14 program.
15 CHAIRMAN RONDEN:
Do you contenplate the evaluation 16 teams would be a composite of ---
17 MR. CHAPMAN:
The evaluation team will be a composite.
18 It will be an integrated program, but we still have not drawn 19 this fine line that may be forced. upon us by outside advice 20 as to how the Licensing Offices operate with respect to the 21 Inspection Offices.
22 It is still a fundamental question, I think, on 23 both si. des, although probably less in the safety side than it 24 is in the safeguards, simply because safeguarde is a much more 25 subjective subject.
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COMMISSIONER GILINSKY:
Does the evaluation program or 2
plan apply to all fuel cycle facilities?
3 MR. CHAPMAN:
It is our intent that the -- if this 4
nine-month program that you all have asked for proves to be successful in all respects and it so agreed to by the 6
Commission as being successful, we would then carry this 7
program on forever as a way of looking at facilities with 0
respect to their safeguard capability.
9 COMMISSIONER GILINSKY:
This program right here, does 10 that apply to the existing facilities?
11 MR. CHAPMAN:
Yes, sir.
Yes, sir.
It is our intent to 12 start very soon, just as soon as we can get Commission approval 13 and the program organized to start inspection -- or evaluation 14 and inspection.
15 MR. VOLGENAU:
Well, I think we are responding to the 16 Commission request to review the four that fell below ---
17 CHAIRMAN ROWDEN:
There's a priorization aspect to it.
18 MR. VOLGENAU:
Yes.
And that plan concentrates on thos e 19 fodr.
20 I think what Ken is saying is that assuming it works 21 well as a prototype --
22 CHAIRMAN ROWDEN:
Initial kinds of focus.
23 MR. CHAPMAN:
A little bit of both.
24 MR. VOLGENAU:
The latter primarily.
25 MR. CHAPMAN:
Because of scheduling, we may not hit those four plants, one, two, three four.
We may hit them, one,
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two, five, six, or something.
But those four or five plants 2
will be the emphasis of the first part of the program.
And then 3
we will take actio0, of course, based on those evaluations.
4 Following that, there is a continuum there in which 5
you will start going to other plants and so on.
6 What we can do in nine months -- the nine months 7
is the limiting factor.
Not the concept.
Not the thought.
g CHAIRMAN ROWDEN:
Would all facilities be covered within the nine months?
9 MR. CHAPMAN:
No, that's my point.
They will not 10 all be covered.
They will not all be covered in nine months, 11 but they will be all covered in what, about a year and a half, 12 I guess, something like that.
13 COMMISSIONER GILINSKY:
But will you be dealing with 4
any -- but are there some facilities during the first nine months?1 15 MR. CHAPMAN:
As I remember the detail plan, I think there are about seven facilities that one would hope to get to i
the nine months.
8 I think that comes up later in the briefing.
CHAIRMAN ROWDEN:
And what about transportation?
Is that ---
21 MR. CHAPMAN:
Transportation is in this.
22 CHAIRMAN ROWDEN:
And the purpose of this evaluation, 23 as I recall it, is two-fold:
one, to provide a base of the 24 content of the proposed rule-making actions both in regard to 25 I
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interim and longer-term upgrading actions; and at the same time 2
to provide a more definitive evaluation of facilities against 3
the threat level that we presently have established.
Am I 4
correct?
5 MR. CHAPMAN:
No. The current rule-making which you 6
were briefed on yesterday or the day before will proceed 7
probably ahead of this program.
CHAIRMAN ROWDEN:
It will be initiated ---
9 MR. CHAPMAM:
Yes, initiated ahead of.
10 Now, depending on how that rule-making goes with 11 respect to public comments and so on, the various interactions 12 required, this program may catch up with and have an influence 13 on that rule-making activity.
14 CHAIRM.'sN ROWDEN:
I thought it was to give at least 15 a basis for what interim upgrading safeguards --
16 MR. CHAPMAN:
It will, but it will be -- any steps 17 taken as a result of this, I think, will be handled in an ad hoc 18 interim basis and not be picked up in the generic rule-making.
19 I just don't think the timing is right for that 20 although there may be some apsects of this program which will 21 show us some deficiencies that' ought to be picked up in the 22 general ruling.
23 COMMISSIONER GILINSKY:
What is the timing of the rule?
24 MR. CHAPMAN:
The rules will be down here Monday in 25 draft.
We are moving on to the street with those rules
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presumably if the Commission approves.
2 That's why I say, that program is raoving at such a 3
rate that we will be playing catch-up with this program, at 4
least for the first statement.
5 Now, if there is a delay because of public comment 6
or other reasons, then this program might catch up.
7 MR. HUBERMAN:
Or your first inspection shows you 8
that there is a --
9 MR. CHAPMAN:
If there is a major fluw discovered, ther 10 we will have to change that before we go final rules.
11 So I think we are saying the same thing but with a 12 little bit different ---
13 CHAIRMAN ROWDEN:
We are saying it differently.
14 It certainly would be a basis, if any deficiencies 15 were discovered on the basis of more sophisticated techniques 16 for taking action now.
17 MR. CHAPMAN:
Absolutely, absolutely.
And it is our 18 intention to do so, yes, sir.
19 Dutch Von Ehrenfried is going to brief for both IE 20 and NMSS offices. in a single briefing.
21 MR. VON EHRENFRIED:
I will cover all of these points in m re detail.
22 23 We think it is important to start off with these 24 n epts to be sure they are. clear in everybody's mind, including transportation and adversary definitions and then jump 25 m
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into how we plan to execute what we give to them in the plan, 2
including what we have been doing in the meantime and what we 3
will be doing next month as well as in the nine-month period.
4 And, of course, discuss the relationships between 5
evaluation and inspection and then culminate in what we hope 6
to
. get out of this and get your approval on the program.
By way of introduction, we want to empnasize that 8
three of the branches within NMSS with Inspection have worked on this since January 18 and also, it is a 10 joint plan, _ joint presentation.
11 And we are looking to you gentlemen for approval 12 of the approach and any clarifying guidance that you feel we 13 should have.
14 Now, this again, by way of background, almost 15 chronologically.
16 Dr. Volgenau sent you a memo back in December 17 which had the essence of some of these activities that we will 18 talk about in more detail.
19 we later came back on March 9th.
We started 20 selecting teams right after they started training those 21 teams to the plan.
22 And we are here today to discuss it more deeply.
23 Now, I think we should start off here with the 24 baseline of last year and sort of lay a foundation as to what 25 the evaluation process did for us last year.
i
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You remember we did two rounds of what was then i
2 called the adequacy assessments of all of the facilities.
3 We did seven land transportation vulnerability 4
analyses which were the first black-hatting kinds of 5
activities which we got our feet wet in that kind of a 6
methodology.
7 Then later in the year we did three fixed site 8
black-hat operations, General Atomics, GE-Vallecedos where we 9
first look at inside versions with an insider with the facility 10 and we did United Nuclear.
11 Now, the lessons from,all of these, including the 12 physical security, material accounting, the inspection 13 aspects, were that -- we found out that both the NRC needs 14 were evaluated as well as the licensee's capabilities.
15 That is a very fundamental point here, that we have 16 been evaluating NRC's ability to regulate and ability to put 17 license conditions in the field as well as we have been 18 evaluating the in-plant capabilities.
19 Now, we also found that participation of the 20 licensee was crucial to making the teams efficient, to really 21 getting their products out, and we had to give the industry 22 a little bit of credit for last year in that they were quite 23 receptive to the point where we actually were able to, with 24 their permission, do some of the kinds of black-hat operations 25 which showed up some vulnerability.
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about changes for the better.
2 I think we have proven that by one hundred and some 3
license conditions which have definitely improved safeguards 4
in the facilities and in the transportation regimes.
5 We also see that evaluation processes is a resource 6
user.
We have to be organized to do this.
The organizations need to commit to it.
And we will talk about that more as 0
well.
9 So that is the kind of lessons learned from last 10 year.
11 MR. HUBERMAN:
Stretching that a little bit:
have you 12 learned anything about the utilities' role in this type of 13 safeguards approach?
14 You have to get them into this and use some.of 15 their self-inspection -- some self-inspection within this 16 concept to work or do you think leaving them: out is just as 17 good?
18 MR. VON EHRENFRIED:
No.
I think if you're talking 19 about licensee involvement, I think it is very key,that we 20 should have some day this year worked on the licensing self-test 21 program.
22 I think we talked to that very shallowly in the plan 23 because it is a little farther off, but licensing participation 24 is -- you just have to make the opportunity initiate their I
25 own evaluation. programs to keep themselves trained a. up to speed to keep guards motivated, et cetera, i_
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So we are looking for that same kind of 2
participation and cooperation this year.
3 It also came out, as you remember, towards the 4
end of the year, that the adversary definitions played a key 5
role in the team approaches.
6 We will talk about that in more detail later.
We have improved the methodology considerably since 8
~
the early days where we were really forced by the times to 9
mold teams, get them in the field, and try to get the job done.
10 So in that year we have also improved there 11 considerably.
12 Team selection, training, the interdependency of 13 teams between not only organizations but skills we have been 14 improving on, and that has proved to be most important.
15 One of the key areas in evaluation that has given us 16 trouble and also we are giving a lot of attention to again is 17 its measure cf effectiveness.
How we measure assurance?
18 We will talk:.about.that'.later.
19 Certainly assurance is still a subjective thing.
20 We are trying to quantify some of the parameters, but I think 21 we have to realize that a lot of these things are judgment 22 calls based on a lot of experience.
23 We are trying to increase assurance by increasing i
24 experience as well.
25 We have found that the evaluation process does bring l
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1 MR. HUBERMANi:
Will you have that as part of the over-2 all process?
MR. VON EHRENFRIED:
Yes.
4 MR. CHAPMAN:
Let me just stress that.
There are a 5
series of fundamental trade-offs.
6 One is the resource trade-off on our part.
But even 7
if we had all the people, there is a trade-off that says you put 8
all these guys in the plant and it is disruptive of their 9
operation.
Particularly if you look at all the things we 10 like to look at.
11 So you have a trade-off there against what the 12 plant can do.
13 And the other thing is that we can't be out there 14 all the time anyway regardless of how many resources we have.
15 So that you have got to depend on the plant, and 16 the plant management to carry on the effectiveness of the 17 day-to-day plant safeguards program.
18 And so you have to weigh. all these things.
19 One of the things I..have been worried about, and 20 admonishing Dutch, is that we have got to reach some balance 21 on how many people we use on the staff, how long they are out 22 in the field, how disruptive the program is, versus what 23 dependency we want to place on the reliance of the licensing.
24 And we are going to have to evolve that.
I don't 25 think we can just arbitrarily say it is going to be this way.
So part of this program is to try to evolve that
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perspective on the trade-offs.
2 MR. VON EHRENFRIED:
Let's look at the fundamental 3
categories and types in the new lingo here a little bit.
4 Last year I think words were adequacy assessments.
5 We tried to break the evaluation. activity into two maj r categories:
those which truly look at capabilities in 6
place and those which probe for the vulnerabilities no 7
matter where they happened to occur.
g An as year e
a ese two activities.
We 9
will again have them this year.
They will concentrate on 0
capabilities, although it is very difficult sometimes to separate the two.
But this year we want to concentrate on a couple of aspects of the vulnerability appraisals we feel is one of the best, primarily is in the diversion path area and 15 the conspiracy between insiders and exterior groups.
16 We think we have got this exterior self-appraisal 17 thing wired; Jay, and the special forces teams have a lot 18 of experience in that area.
19 We are going to use the same methodologies and 20 techniques except for the fact that we are now going to couple 21 this in conspiracy mode to diversion.
22 Now, let's just briefly look at each one of those 23 four items.
24 Again, emphasis on capabilities under physical 25
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security.
2 We have taken this now and documented a handbook 3
on how to go about doing physical security assessments.
4 It builds on fundamental questions out of the 5
builder-type of last year and takes it right down to what we cal:
third-level criteria, six to seven fundamental kinds of things 7
that need to be examined.
8 This will greatly facilitate training of those 9
teams and to keep the team consistency the same throughout 10 the year and throughout all sites.
l~'
We are then looking, of course, at guard force 12 responses, capabilities to defend, delaying access, that kind 13 of thing, detecting adversaries.
14 very much the same as last year only now better 15 documented, better trained.
16 Material accounting assessments, on the other hand, 17 we have had over the'last year difficulty with this one from 18 the standpoint of evaluation.
But we put together now a team i
19 headed up by IE jointly with NMSS and they have been training to 20 this over the last six to eight weeks now, I guess, whereby 21 they are also trying to get to the same place where we are 22 in physical security, how to do an organized material accounting 23 assessment in an organized fashion.
24 I might point out, too, that we ar capitalizing on 25 some work that IE had Battelle do here, and we are spinning
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off on top of that.
2 MR. CHAPMAN:
I would like to make a comment at 3
the risk of appearing to dangle carrots.
4 I have been reviewing some of the progress in the 5
material accounting area in the last few days and I am 1
6 convinced that within six months or so, when the Commission has 7
a chance to hear thia, we are going to make some really 8
tremendous strides in that area.
9 I think that we are finding a new mathematical base 10 for the whole program.
I think it is going to be very valid.
11 I think it will give us a high assurance that we can track 12 the progress on an accounting basis.
13 And I am very, very excited because I think it 14 not only will fundamentally revise Part 70, but I think it 15 is going to have applications internationally and be of 16 significant help to IE.
17 Unfortunately, it.is not quite ready to come 18 down yet, but I think when it does that you are going to see some 19 real, I hope, good homework that will contribute in the area 20 f material accounting.
COMMISSIONER GILINSKY:
Who put that together?
21 MR. CHAPMAN:
There's a number -- there has been 22 a whole series of efforts, some of which I have referenced 23 ceasionally.
24 U
^ **"
25
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thing.
2 I have had Sid Sid Moglewer -- Stan Dolins was in 3
earlier, but Sid has been the principal mathematician working 4
with Livermore and with SAI.
5 And what they are basically doing is challenging the 6
standard distribution that underlies the MUF concept.
7 And on a plant process basis, looking for skews in 0
the standard distribution, it turns out to be very 9
relevant, because if you can in fact skew the MUF and the 10 LEMUF to a particular plant process and to a particular 11 measurement capability in that plant, you get a hell of a lot 12 closer to the facts than you are if you try to assume a normal 13 distribution.
So all of_this is progressing, plus all of that 14 that Ted Sherr had going.
15 And what we are trying to do now is get it brought 16 together and see how this can all be put together in some kind 17 of a program.
18 I am reasonably excited by the results they get 19 because once you get away from the standard distribution and 20 start understanding what skews that process and where your 21 centerline really ought to be, you begin to mathematically 22 understand what the hell is going on in those plants.
23 And I think it is great.
24 CHAIRMAN ROWDEN:
What is the timing for bringing it 25 together?
l
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MR. CHAPMAN:
Well, some pieces of the work are almost 2
done.
3 As f ar as the Moglewer contract, which-I think is 4
very exciting, is essentially complete.
And they have found 5
some things that we will want to translate into license 6
conditions or rule changes very quickly.
7 A couple of things in regard to how we treat 8
accounting today.
The fundamental program though has got to 9
be integrated was some stuff that Ted Sherr has been doing 10 in a broader context of all of Part 70.
11 I would guess that Ted's work looks about a month from 12 now before we get the total program.
13 CHAIRMAN ROWDEN:
How helpful is that going to be with 14 regard to some of the what we can characterize as " problem 15 facilities"?
16 MR. CHAPMAN:
Well, one of the things that comes out 17 of this -- I'm sorry.
I didn't mean to digress, but it 18 really is a very interesting subject.
19 One of the things that has come out of it is 20 something that we have known, inherently known, but not 21 understood mathematically.
And that is that every plant is different.
22 23 The problem we got into on large throught-put Plants where you have a LEMUF that is based on two sigma -- or 24 a1m a
25 s based on a two sigma distribution
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a very 1srge through-put over 60 day inventory maybe >9veral 2
hundred kilograms, you are using a mean distribution. it 3
really is telling you nothing about that plant.
4 If you get a very small plant, a small through-put, 5
then the LEMUF is narrow enough, you see, that you can get 6
some pretty good understanding of deviations.
7 What we have got to do is go into the large -- what 8
we really have to do is treat each of the plants on a unique 9
basis.
That's what it amounts to.
10 You get into a large plant, there are two ways to 11 change that situation.
You either understand all the skews of 12 the input and output or you can go in and increase the 13 inventory frequency.
So that you don't have such a large 14 underlying data base.
15 COMMISSIONER GILINSKY:
We aren't getting away from a 16 normal distribution?
17 MR. CHAPMAN:
It turns out that the distribution of 13 LEMUF is not normal.
In fact, that is one of the problems.
19 There is a skew because the measuring -- and particularly in 20 these large plants, and that skew gets worse as your total 21 volume, yout total data base gets bigger.
22 In other words, you are taking a very large amount 23 f material over a 60-day period of time and trying to find 24 a line through there on a mean, and it is not a mean in the first place.
And since the damn thing is so broad, it really 25
F 19 1
tells you nothing.
And what you have got to do is either 2
reduce that volume through more frequent inventory, or you 3
have got to understand all the skews in the process.
4 So, to answer your question, is that you will 5
probably end up with something that is uniquely dependent 6
on the type of plant operation that you are running.
7 And in that context, then, MUF can be very 8
meaningful.
9 It would really have a different definition than 10 it has today, but it would be very meaningful.
And that's 11 when we are going to have to come down.
12 It may be in the Commission's interest to look at 13 some of these technical briefings before you look at the 14 total program.
15 I'm not..sure of that.
There has been a whole series 16 of technical studies over the last year which are sort of' feed-17 ing in.
18 If you wait until the whole thing is integrated, it 19 may be harder to understand some of the reasoning than it would 20 be if you.could catch one or two of these ---
'21 CHAIRMAN ROWDEN:
Do you think it is possible to set 22 up some briefings?
23 MR. CHAPMAN:
Yes, sir.
Yes, sir.
Very possible.
24 CHAIRMAN ROWDEN:
Are they classified in the sense that ---
25
20
<s 1
MR. CHAPMAN:
No, no.
They are somewhat technically 2
lacorious, but nonetheless the concepts shine through 3
rather chearly.
And I think as a way of better understanding 4
where we are in Part 70 and why we have been concerned about 5
it and where we might go, it could be useful to hear two or three 6
of those.
CHAIRMAN ROWDEN:
Well, we would like to -- I know I 8
have asked before about putting up some briefings on the 9
materials accounting side.
We have been almost focusing 10 exclusively, as far as our dialogue ---
11 MR. CHAPMAN:
We haven't done our homework.
We had 12 no choice since we couldn't guarantee the MUF was under 13 control, we had to put the physical security under.
So that ---
14 CHAIRMAN ROWDEN:
The offer has been made.
It has been 15 accepted by me.
16 MRs CHAPMAN:
-- Fine.
I'd be delighted.
17 MR. HUBERMAN:
Would there be an appraisa1 in all these 18 briefings as to the applicability for the IAEA?
19 MR. CHAPMAN:
We haven't really thcught about that.
20 All I qun saying is that I am pretty excited about 21 the prospects because it looks like if you can understand the 22 plant, mathematically understand the plant, and model it, 23 then you can get a very, very good handle on diversion, with 24 high confidence.
25 MR. HUBERMAN:
It might be good that when the
21 1
Commission is briefed, then the IAEA ---
2 MR. CHAPMAN:
Well, we have thought about it, but we 3
just haven't gone so far as to get into the IAEA mechanisms.
4 MR. VON EHRENFRIED:
The third type was the 5
external assault which as I mentioned before, we have down to a fine science now. **
g As you know, we have two speicial forces that are 7
NRC employees plus the four on contract.
So with those, say 8
those six, we make up a four-man team that does the surveillance 9
f the plant, the development of the adversary action 10 sequences and the probling for v lunerability which in turn later are pitted against the consistent counter-measures.
So this one is not new, but we feel we have it down now te a science.
14 Now, the one where we feel we have the most to learn this year and the one we feel has the greatest opportunity for true adversary action is in the area of diversion 17 conspiracy.
And we think we found that out only af ter we 18 really had an inside adversary at GE-Vallecedos and had the 19 exterior assault crews give us input as to what kind of inside 20 assistance they need.
21 And so this year we put together again a joint IE 22 team headed up by Dick McCormick from IE with us, and we will 23 have four guys trained to do in-plant diversion path surveys, 24 which is not the same kind of thing that the Bureau of 25 Standards is doing in their diversion path analysis which is
- (Footnote:
Denotes original transcript were pages 15-20.
Due to re-typing of penciled changes these changes extended the pagination to line 6 above.)
22 1
much more comprehensive and tedious.
2 In order to keep the impact ---
COMMISSIONER GILINSKY:
Who is doing that?
aR. VON EHRENFRIED:
Bureau of Standards for ERDA.
However, we have attended those briefings and are 6
familiar with those activities.
7 So again, conspiracy and diversion with this team 8
will be something we are really looking forward to doing.
9 Now, let me be sure that another thing is new that 10 should be clear, all of these kind of evaluation tools now will 11 feed into another team which is really a build up of the same 12 kind of team members which is going to do the synthesis of 13 all the data that is gathered before any declaration of an 14 overall site adequacy, if you will, is declared.
15 In other words, we are not going to do a physical 16 security assessment and say that Site A is adequate.
17 We are going to look at all of these things, 18 including inspection information.
We are going to have those 19 teams send their reports over to the synthesis group who will 20 sit down with all the team members, and we are going to go 21 through this process of trying to determine overall adequacy' 22 and try to figure out what kinds of levels of assurance we are 23 going to get out of it.
24 We need to determine what measures of effectiveness 25 are applicable, which subject judgments we need to keep and so forth.
23 1
So this process is new this year.
Some of these are 2
improvements over last year.
That's the fundamental difference 3
in the evaluation methodology that is new.
4 Now, there has been a lot of discussion as to what 5
is the role of the adversary definitions as it relates to l
6 evaluation.
7 Just as a reminder, there were some statements which went out from NRC to the Federal Register through your Order g
and to the White House and to Udall and to other 9
Congressmen and just as a reminder, we are saying these kinds 10 of things were last year's data.
It is kind of the mind 11 set now of the public.
But that this year what we are going 12 to try to concentrate on is a little bit simpler version 13 plus a different twist here.
4 We are going to say that although we are still interested in the insider in the role of diverter and conspirator, that we are looking at a small terrorist group, or any group with any kind of motivations and capabilities, and we are not going to emphasize that so much as the 19 capability.
20 In other words, if we are going to examine the 21 capabilities, then we are going to backfit and see where in 22 the range of different kinds of threats or adversaries, numbers, that particular site can exhibit countermeasures for, in 24 different categories.
25 So this is a different approach.
It gets away from all
24 1
the numbers games as well as the motivation game which I think 2
gets a lot of people confused.
But it is important that the 3
evaluation teams ---
4 COMMISSIONER GILINSKY:
Could you go through that 5
again?
CHAIRMAN ROWDEN:
Go through that again so we can 7
understand.
l 0
MR. VON EHRENFRIED:
All right.
Last year we had 9
numbers in our minds and we went out and we were conditioned ---
10 CHAIRMAN ROWDEN:
We stated numbers?
11 MR. VON EHRENFRIED:
We stated numbers and we said it 12 that site adequate against one and three.
And even in that 13 discussion we had differences of opinions between team 14 members as to really what is occurring.
We even had hours 15 of discussion of "more than one. "
16 (Laughter.)
17 MR. VON EHRENFRIED:
The thing we want to do, we 18 want to look at the facility and we want to look at its 19 capabilities, and then we want to backfit into a statement of 20 what we think that facility can counter, whether it be three 21 or four or five or whatever th'e numbers are.
22 And we can do that, I think, this year in that first 23 of all we have an evaluation method a little bit better 24 defined.
We have team members who now have spent a lot of time 25 together.
We speak the same jargon, communicate better.
We also-=
I 25 1
COMMISSIONER GILINSKY:
Excuse me.
There's another 2
variable, sort of confidence or something like that.
3 MR. VON EHRENFRIED:
That varies. on the numbers.
4 Soit'sonethingtogiveyouastatementofassurance-f 5
which is a subjective thing anyway -- against one number, and 6
you'll get a different assurance factor against another.
7 MR. HUBERMAN:
Well, you won't have a fixed criteria.
8 MR. VON EHRENFRIED:
Well, no, but we will have data, 9
and we can give you, hopefully by that period of time, 10 relative measures of assurance against a broad spectrum of 11 numbers.
12 COMMISSIONER GILINSKY:
And then what is that going 13 to do for you?
14 MR. VON EHRENFRIED:
Well, that lets you -- us --
know, for example, where the lines can be drawn, where it 15 16 relates to the upgrades project.
It gives you different g
confidence or assurance values for each facility.
And it g
will also probe where the assurance is coming from.
9 In other words, one plant might have high assurance from a material counting area, and another plant might have very little assurance there, but very high physical security.
So it's part of a number of parameters.
it's not just one ---
CHAIRMAN ROWDEN:
How is the determination made as to 23 whether an additicsnal measure is needed?
Whether it would 24 be seen in terms of capability?
26 1
MR. VON EHRENFRIED:
It goes back -- it goes back to 2
the think I mentioned to you where we documented the evaluation 3
criteria a little better this year.
And we now have things 4
like this for physical security whereby we are down now with 67 5
criteria.
And I'm down here now on No.
l',
or 4, and I can tell 6
you very explicitly that we have very low assurance of this 7
one or very high assurance of that.
So we're much deepar now 8
in our understanding of what might be ---
9 MR. CHAPMAN:
For example, what No. 4 might be ---
10 MR. VON 2HRENFRIED:
All right.
For example, here 11 under " access controls," which goes back to this fundamental 12 question, you might have, say, a badging system which is, say, 13 very poor at Plant X.
And it's maybe down at this level, and so l
14 we've now -- we can now pinpoint exactly which safeguard, rhich 15 measure.we're talking about and whether or not we've got a 16 high assurance there or not.
17 So all I am saying here by this process, which is 18 a very tedious thing that has gone on for months to develop 19 this physical security, we now better understand how to 20 evaluate it and we can now give more credible answers, and 21 we can give data to the answers.
S this, again, is a -- I guess -- the reason why 22 23 we needed to have this evaluation and methodology ---
CHAIRMAN ROWDEN:
So you don't have to postulate, for 24 25 example, on physical protection, a certain number of attackers i
o.
27 o
1 out there, in other words ---
2 MR. VON EHRENFRIED:
Last year, of course, we had 3
numbers, but now I can tell you that -- let's say -- responses 4
are extremely high on Plant X.
And I have seen 10 police cars 5
respond in three minutes.
I can maybe attribute that now to 6
higher numbers, if you want to do that.
Or I can give you 7
higher arsurance at a lower number.
8 So now we have an envelope, if you will, that we 9
want to fly in, rather than fly in one particular pattern.
We 10 are trying to understand what this envelope of safeguards is 11 all about.
12 All right.
Now, we are trying to do the same thing 13 in material counting.
We have -- we are starting to develop 14 this now.
And we'll have this in another month or so, and 15 develop it even more through the year.
16 MR. HUBERMAN:
On physical security, is the approach 17 consistent with 73.55; or are you doing anything to make it 18 consistent?
19 MR. VON EHRENFRIED:
Well, a lot of those are quite 20 fundamental in -- and are high of a very high order like that 21 first and second... go much deeper than that now.
We can get 22 traceability through the regulations, as well as the licensing.
23 MR. CHAPMAN:
The answer is some are some aren't.
24 MR. VON EHRENFRIED:
Now, we have been talking mostly 25 about fixed sites, but I think as a result of last year, which
22 1
I guess we briefed you almost a year ago today ---
2 COMMISSIONER GILINSKY:
Let me understand something.
3 This is an evaluation.
You are going to come out with 4
a result which describes the capabilities of the original site?
5 Now, where is it that we're heading for?
6 MR. VON.EHRENFRIED.:
I have got that under "results".
7 Let me keep going through each type, and then I'll 0
wrap it right up and fini,sh it up for you.
9 (Laughter.)
10 Keep in mind that last year we -- a lot of things 11 happened in transportation, and a lot of things changed in 12 transportation.
This year we feel that since the majority of 13 shipments have been taken over -- we will have 15 to 30, we 14 don't really know this year -- that what we need to do is 15 to continue the inspection program on the license conditions 16 that went out May 12th and February lith; but that we should 17 look at some of the new kinds of transportation capabilities 18 that just came in.
19 For example, in the last license condition on 20 transportation we discussed the fact that a lot of these 21 shipments that were terminating at night in Chicago, should 22 probably have two escorts.
Now, if we see another export ship-23 ment going from Piketon to Chicago that requires two escorts, we 24 Will Probably evaluate with the vulnerability or external 25 assault type evaluation.
We don't need to do the internal
29 1
thing anymore.
We've got the internal threat so checked and 2
balanced in transportation that in my estimation, you know, 3
y.ve really got the safeguards there.
So we do want to look 4
at transportation some more in this context.
5
- Now, keep in mind that we also have coming back 6
an option study due on the 20th, I believe
-- yes, that will 7
look at some.of these things we have been talking about, like 8
SECOM, issuing some of the ERDA command center functions, 9
whether or not we go to...
(inaudible).., and so forth.
So 10 this study is underway and Jay Durst is conducting that, and 11 we'll be back to you on that one.
12 Now, before we get to "results," I think there are 13 a few considerations of what you had brought up before, we 14 even stated some of these considerations that we want to factor 15 in.
16 We have to realize that we are starting off in this 17 thing with another process already started.
As the 60-day 18 upgrades, which will be effective here shortly, they are already 19 at the facilities so we need to recognize that that is going on.
20 At the same time ---
21 CHAIRMAN ROWDEN:
Now, those 60-day upgrades relate 22 nly to fixed sites?
MR VON EHRENFRIED: Right.
23 CHAIRMAN ROWDEN:
It doesn't relate to transportation?
24 MR. VON EHRENFRIED: Right.
25
30 1
1 MR. CHAPMAN:
And only to a limited nuder of fixed 2
sites.
3 MR. VON EHRENFRIED:
But it is something that, 4
you know, you can't send one evaluation team out to look at 5
something when they haven't even finished their short-term 6
descriptions.
7 But, at the same time, we have o realize that 8
Erickson's effort on the long-term upgrades, and what we 9
are seeing and may be recommending are hand-in-glove kinds 10 of activities.
Looking at this sort of secondary mode, if you 11
- will, we have direct feedback to this activity, plus the 12 fact that when we know those additional upgrades are in place, 13 we'll have to apply these evaluation tools again next year.
14 Now, I already mentioned the team training.
Ken 15 mentioned the fact that we have got to keep these team 16 sizes down.
Last year we were in the mode where we were 17 learning, we had a lot of trainees, we had a lot of people 18 who were interested in what we were doing, so we had very 19 large teams.
So I think this year we will keep the team sizes 20 down to three or four at a time.
21 There are also other considerations in the inspection l
22 area.
Keep in mind that the inspection, special inspection 23 program for physical security is already complete.
That was 24 completed at the end of the year.
They're still working on the 25 special inspection program for material accounting, which will l
go on while we are doing this evaluation process.
\\
31 1
We have to recognize that che' also have some 2
actions pending for the sites that we are concerned about, B&W, NFS and Wood River.
We want to also say that the Battelle work that IE 5
sponsstad is also going on at Erwin, and so we picked 8.iwin, 6
I guesa, as our first site in that there is so much activity 7
we can spin off on there, plus we can capitalize on the efforts i
8 that have already gone on.
9 Now, we have talked about this separation of 10 evaluation activity and enforcement action, and what 11 that means is that although we have joint IE and NMSS teams 12 we're deep down now into the vulnerabilities of a site, if 13 you will.
It's one thing to try to upgrade safeguards; it's 14 another thing to cite for noncompliance and take enforcement 15 action.
16 So our policy hurc is that we have got to recognize 17 the two activities are going on and that they are things. that 18 you want to try to separate, but that the inspection process 19 will go on, feedback from the evaluations going to the 20 inspection area, but that we'll probably separate ---
21 COMMISSIONER GILINSKY:
What do these inspectors do?
22
? ay are inspecting ---
23 MR. VON 'EHRENFRIED:
Keep in mind that the -- when we 34 say, "IE participates on the team," they are not inspectors --
25 COMMISSIONER GILINSKY:
No, no.
I'm sorry.
I&E's ---
32 1
MR. VON EHRENFREID:
I&E's going to continue their 2
inspection program, but'be aware of our schedules, and 3
schedule their routine inspections at some later time.
4 COMMISSIONER KENNEDY:
I guess I don't understand.
I think I have the same confusion that I think I detected in 6
Commissioner Gilinsky's question.
7 If you evaluate you reach certain conclusions about 8
a site, what's the difference between that and an inspection 9
as to enforcement action?
10 MR. VON EHRENFRIED:
Well, I think the fundamental 11 difference is that we are looking for the effectiveness of c
12 a safeguard.
And, at the same time, one could see a fence 13 that was 7' by 11", which would be a noncompliance kind of 14 thing, but we are really not concerned about that at that time.
15 Maybe the fence is ---
16 COMMISSIONER KENNEDY:
Why not?
It's out of compliance.
17 That's my question.
18 MR. VON EHRENFRIED.:
All right.
To us, we have to 19 separate chose who develop those safeguards and evaluate the 20 effectiveness of safeguards from those who have enforcement 21 action.
22 COMMISSIONER GILINSKY:
Is this due to the cooperation 23 of the licensee?
24 MR. CHAPMAN:
No, I think -- let me see if I can 25 describe this as I understand it.
33 1
We have not been using enforcement as a tool for an 2
evaluation of a base.
We are going to try to bring inspection 3
and evaluation closer together.
That's the intent here, but 4
the evaluation program is as much an inspection of NRC as it 5
is the licensee.
We're out there trying to determine:
do we 6
have an effective safeguard program?
Now, it may be that the licensee is in complete 8
compliance with the regulation, but that the regulations are 9
stupid.
And we will find that out in the evaluation.
10 Obviously, that's not enforcement.
Or it may be that he is in 11 complete compliance, but nonetheless, that particular compliance 12 with respect to how he carries out the badging function, or the 13 distribution of guards, may still not be a satisfactory 14 safeguards posture.
15 COMMISSIONER GILINSKY:
Well, but suppose he's out of 16 compliance and ---
17 MR. CHAPMAN:
If he's out of compliance, then the
.t la IE people on this team will immediately notify the region ---
19 CHAIRMAN RONDEN:
Well, that was my question.
20 MR. CHAPMAN:
Yes, sir.
He will be gigged if he's 21 found significantly out of compliance.
22 COMMISSIONER KENNEDY:
But, now, the evaluation teams 23 will report to the region -- let me be sure I understand what 24 will happen -,the evaluation team would report to the region 25 that this guy's fence is not in compliance with existing
ar-34 1
regulations.
2 MR. VOLGENAU:
That comes back through the 3
headquarters' function.
4 COMMISSIONER KENNEDY:
Well, then what happens?
The 5
region then goes out and looks at it and says, "That's right,"
6 and sends them a noncompliance?
7 MR. VOLGENAU:
Well,'it depends on how bad it is.
8 There will always be a follow-up.
9 COMMISSIONER KENNEDY:
Okay.
10 MR. VOLGENAU:
The case of a fence that is slightly 11 below specifications would be reported back to the regional 12 office.
And that's not a significant item, the way Dutch 13 outlined it.
14 If there was a case where a guard was absent from 15 his post, or a search wasr.'t conducted in the material access 16 area, that is a very significant item, and they would most 17 probably be cited on the spot at the time.
There would probably 18 be an enforcement conference with them and subsequent 19 enforcement action.
It depends on how bad it is.
If it is ---
20 COMMISSIONER KENNEDY:
Now, wait.
Now " cited at the 21 time."
Now, this evaluation time would do that?
22 MR. VOLGENAU:
The inspector -- I don't know precisely 23 how we operate it, but it would depend upon the conditions, 24 but if it's a major item we would be obligated to inform the 25 licensee immediately so that corrective action could be taken.
35 1
more than likely on these And, at the same 2
teams there will be an IE inspector from that region.
Then the 3
regional director would recommend his enforcement action and we 4
would process it in the normal way.
5 It it's a minor point, like a deficiency, we would 6
note it, document it, and it would become a list of deficiencies 7
of other noncompliances that we have, and at some point we 8
document it.
So that on such-and-such a date we'd noted that 9
and recommended that you -- we understand that you are taking 10 corrective action, or we recommend that you do.
11 MR. HUBERMAN:
Ernie, would you say that the only 12 difference between this type of visit by an evaluation team and 13 the normal IE inspection is that there is automatic feedback 14 in this type of visit, they are together and they understand 15 what is right and what is wrong and bring it back to 16 headquarters with them?
17 MR, VOLGENAU:
No, I don' t think that's the only 18 difference.
I think it's a difference.
The whole thrust of 19 this particular exercise is not so much compliance-oriented.
20 MR. HUBERMAN:
I'm talking from an enforcement 21 standpoint; that's a developmental standpoint.
l 22 MR. VOLGENAU:
Oh, okay.
23 MR. HUBERMAN:
I just think the whole philosophy is 24 different.
You want to test and develop NRC's approach.
But 25 from the standpoint of finding things wrong, all the right
36 i
4 9
1 people are there at the same time, and you get this 2
automatic feedback back to headquarters.
3 MR. VOLGENAU:
Sure.
4 MR. CHAPMAN:
Now, back to Mr. Gilinsky's question, 5
which I didn't mean to dismiss out of hand.
Obviously,'one of 6
the benefits of minimizing the enforcement aspect is that you 7
do get good cooperation; much better cooperation.
And we have le'rned that.
9 If one really wants to determine the true condition 10 of safeguards, from either is the regulation sensible, or is it 11 being conducted sensibly, you are better off in that sense to 12 have that cooperation.
But I don't think that's fundamental.
13 It just happens to be a part of the program that falls out.
14 I would think that it is fundamental to minimize 15 the enforaement aspect, at'least in this program, natil we have 16 learned better how to conduct it and how to integrate what 17 I would call the normal inspection program.
And we are not 18 sure yet how they fit together.
19 MR. VON EHRENFRIED:
I have a few last points on the 20 licensees.
21 Although U.S. Nuclear was one of the chosen few 22 there, we have to recognize that they might not be there when 23 we get there.
We will probably just put that off for a while 24 and see what happens.
We have to discuss these Lativities ---
25 CCMMISSIONER GILINSKY:
What are they doing right now?
37 1
Are they in operation?
2 MR. VON'EHERNFRIED:
I understand they have had.it up 3
for sale and tre trying to get -- see what they can do with the 4
material on hand.
5 MR. CHAPMAN:
The plant is not operational but under 6
security at the same level as if the plant were in operation.
7 We have had people down there checking on their 8
shutdown to make sure that they are protected.
9 COMMISSIONER GILINSKY:
Let's see.
If they were shut 10 down, we were counting workers, armed workers in their 11 Protective force.
MR. CHAPMAN:
But they are providing protection.
12 COMMISSIONER GILINSKY:
They're providing protection?
13 MR. CHAPMAN:
Yes, they would like to get rid of the 14 inventory but the inventory is tied up in a Commission 15 decision on an export.
You've had some correspondence on that.
16 CHAIRMAN ROWDEN:
Yes, indeed.
7 COMMISSIONER GILINSKY:
Well, let's see, that's a very g
small Part of their inventory.
19 MR. CHAPMAN:
No, that's most of what they have.
According to Sam Weaver that's his biggest problem:
to get 21 rid of that.
22 COMMISSIONER GILINSKY:
How much material do they have there?
24 MR. CHAPMAN:
I don' t know the number, I'm sorry, 25 offhand, not very much.
It's way down now.
38 1
COMMISSIONER GILINSKY:
You mean like tens of 2
kilograms?
3 MR. CHAPMAN:
It's down on that order. I don't know 4
exactly.
Probably more like 100s or so.
5 MR. DURST:
I can give* you a general answer on that, sir.
7 At the time we were down there in December they were 8
having 10 or 15 kilograms of input raw material.
They had 9
a lot of complicated assemblies which are in storage there.
10 COMMISSIONER GILINSKY:
Yes.
11 MR. DURST:
And I can't tell you the kilogram weight 12 of those.
I think that we are talking something in the range 13 of perhaps 40 kilograms as the very worst cond.. tion.
14 COMMISSIONER GILINSKY:
Total?
15 MR. DURST:
Total, yes.
16 COMMISSIONER GILINSKY:
I see.
17 MR. CHAPMAN:
Weaver has been bringing his inventory 18 down.
I don't know exactly what it is, but it's quite a way 19 down.
The real guarding of the plant now is based on the 20 export.
That's the most material that is there, as I understand 21 it.
22 COMMISSIONER GILINSKY:
Can't that be moved somewhere 23 else?
24 MR. CHAPMAN:
Well, that's -- I guess if it wer9 to 25 be a very long time that would make sense, particularly if ---
39 4
1 COMMISSIONER GILINSKY:
Well, they're right next to ---
2 MR. CHAPMAN:
Well, we're not in trouble because the 3
plant seems to be adequately guarded.
I think Ernie's regional 4
people have been there, and you have looked at it.
5 COMMISSIONER GILINSKY:
Well, it sounds like they 6
want to get out of the necessity of ---
7 MR. CHAPMAN:
Now, depending on how they get out of 8
business, if they sell and the buyer picked up production on 9
that site, which is one possibility, or they sell and the 10 buyer takes some of the equipment and moves it to another 11 site, and we have to decontaminate the closec ut, definitely 12 in the second case we would start moving stuff out of there 13 almost immediately.
14 So it depends on what happens, and nothing has 15 happened really in the last month except we have had people 16 down there talking about ---
17 COMMISSIONER GILINSKY:
Oh, you mean the buyer may 18 not engage in this business?
19 MR. CHAPMAN:
That's right.
20 MR. VON EHRENFRIED:
Okay.
As soon as we get the go 21 on the program we will have to brief the selected sites in 22 that we have to dovete.il into their operations and also. modify 23 other activities surrounding the facility.
So we will be 24 getting them in shortly.
25 Keep in mind now the other sites, the other 10 or
40 1
11 sites that we don't go through this year will still be 2
involved with their routine inspection process.
3 We might brief them later this year in that we might 4
put them up to next January.
But safeguard effectiveness or 5
adequacy for those other sites will be maintained through the 6
inspection of that ---
MR. CHAPMAN:
You may have used the wrong number.
0 You said "other 10 or 11."
There aren't that many.
9 MR. VON EHRENFRIED:
I use " plants."
Some use 10
" facilities."
11 MR. CHAPMAN:
How many do you plan to get to in this 12 time?
13 MR. VON EHRENFRIED:
We should -- depending on --
14 we have planned four as a minimum.
We kind of think we ought 15 to cut our teeth on the first one here this next month or two, 16 and then to try to pick up two, and maybe get two out here.
17 So we should be able to get four or five if things go as well 18 as last year.
19 Now, just to let you know what we have done in the last 20 few months, we have got the teams selected and the training 21 is going.on.
We've finished the physical security assessment 22 handbook.
We have the material accounting one, and we have just 23 started the Battelle work at Erwin.
We've got some briefings 24 on I&E, the material accounting team, the diversion teams are 25 looking at those results.
And, of course, the near-term
41 4
9 1
upgrades are in progress.
The measure of effectiveness, we're 2
trying to get a little contract help there from the mass 3
side from Sandia to help us with that.
4 v'
Now, near future, which is like the rest of this 5
month and next, again brief the sites, firm up the schedule, 6
go ahead and finish up whatever Dr. Tashman needs, and get started.
COMMISSIONER GILINSKY:
Are you going to tell us what this will cost?
10 MR. VON EHRENFRIED:
Excuse me?
1 COMMISSIONER GILINSKY:
Can you tell us what all this 12 costs?
13 CHAIRMAN ROWDEN:
Costs us or costs them?
14 COMMISSIONER GILINSKY:
Cost us.
15 MR. VON EHRENFRIED:
Well, we have no dollars in 16 technical assistance except from this measure of effectiveness, 17 which we are looking at $50,000.
We have the Army contractor 18 which is ongoing, away, ---
19 COMMISSIONER GILINSKY:
No, in terms of our ---
20 MR. CHAPMAN:
Personal costs.
21 MR. VON EHRENFRIED:
Personal Costs?
We have two 22 people from I&E and about six of us, and they will be almost 23 totally absorbed for the year.
24 COMMISSIONER GILINSKY:
I see.
25 MR. CHAPMAN:
It's less than a dozen people, total.
42 1
MR. VON EHRENFRIED:
We will be training another 2
team a little later, so that will bring the numbers up a bit.
3 But it's not large, if we can keep the teams consistent.
If we 4
have to keep swapping out teams, then the numbers begin ---
5 MR. CHAPMAN:
One of the fallacies of some actions 6
taken by the subcommittee in the last few days is that there 7
are a large number of people involved in this thing.
It's 8
been a very, very small operation, numbers maybe four or 9
five people; maybe six at the outset.
The rest of the people 10 in Dutch's shop have been doing the other things I've been 11 talking about, looking at other kinds of techniques and trying 12 to understand the fundamental process and they have not been 13 out black-hatting.
14 Jay Dirsch just had a very small group of guys.
15 So the nocion that we have been on a big inspection program 16 has been improperly conveyed somehow.
Maybe the effect 17 has been high, but the numbers have been very small.
18 CHAIRMAN ROWDEN:
Well, we ought to clarify the record 19 in that regard, then.
20 MR. CHAPMAN:
We're getting some documentation.
21 CHAIRMAN ROWDEN:
We still owe Chairman Udall a 22 response to a part of his inquiry of last September, and I 23 believe part of that response is to describe at least in 24 summary form the comprehensive evaluation program.
That might 25 be one thing ---
43 1
MR. CHAPMAN:
As a matter of fact, the detail 2
breakdown of our budget submission makes that very clear.
3 I guess it wasn't looked at; we only credit some six people in 4
the budget submission, now 31, and the rest of them are laid out 5
almost job-by-job.
Apparently that wasn't considered.
MR. VON EHRENFRIED:
We have discussed this, I think, enough now.
8 Obviously, the inspection process has got to continue.
9 It is just a matter now of trying to separate out what actually 10 happened while the evaluation teams are there.
Now, getting 11 back to results, we see two individual site reports for each 12 facility.
One being the major report, which will be 13 unclassified, although we feel 'se still should have a 14 vulnerability analysis report, which is classified, which will 15 define the adversary action sequences to actually accomplish 16 diversionary conspiracy or theft and we feel we should keep 17 those classified.
18 Now, these reports will always include the funda-19 mental observations as well as recommendations.
And those 20 recommendations then feed that synthesis group I mentioned to 21 you, and it's there where it will be determined as to what 22 implementationandh6ractionsarerequiredbyother 23 organizations, like Commission performance rules, ongoing 24 license conditions, the upgrades project and look to the 25 inspection process; so, fundamentally we hand off the evaluation to other organizations for implementaiton of action.
-- __=
44 1
Now, we feel we should keep you informed of this
~
2 maybe three times out of the year, maybe after one or two sites.
3 We need to feed back the licensee here in that from last year, 4
we learned that they should be totally immersed in the thing; that we feel that it is a participatory kind of a thing and we -
6 feel obligated to keep them informed.
7 Now, what we pass on here to the Congress and the 8
public might be something else to be determined later and it 9
would come from the unclassified.
10 COMMISSIONER GILINSKY:
Let me understand.
You are 11 going to look at a facility and come out with some conclusions 12 like -- how do you express them?
number of attackers; or some 13 other key.
Are you going to say they do pretty well against 14 this kind of a threat, less well against a bigger one, or much 15 better against the smaller one, or ---
16 MR. VON EHRENFRIED:
I think we will start with the 17 details.
18 We will start with the '67 criteria, for example.
And 19 we will build back up fundamental observation statements about l
20 all of those.
Those will then feed over and be brought in to j
i 21 bear with all the vulnerability material accounting, et
)
22 cetera, et cetera.
And then we'll try to derive some expressions 23 of assurances against an enevelope of adversaries.
24 COMMISSIONER GILINSKY:
So you are going to say against 25 a variety of possibilities that is what can be accomplished -- or
45 1
can be counted on?
MR. VON EHRENFRIED:
Let me see if I can give you 3
an example of -- it might be dangerous to give you an 4
example, but --
Let's say if -- we have looked at conspiracy 5
very well, and the things that we are most vulnerable to in 6
conspiracy, let's say, is an access control; that a number of 7
sites were looked at and the fundamental problems, if you 8
related them to conspiracy, so we could probably make a 9
recommendation such as like, "we need to have another 10 countermeasure agains conspiracy to improve access controls 11 at Plant X."
That.should be,one of the ---
12 COMMISSIONER GILINSKY:
How do you know when to stop?
13 I mean, I hate to sort of dwell on the numbers business, and 14 I think that we are all uncomfortable with it to some extent, 15 but are you talking about large conspiracies? or small 16 conspiracies?
17 MR. VON EHRENFRIED:
No.
Keep in mind in conspiracy 18 we. are s t i l'1 down to one insider, thinking about two, 19 but we're down to low numbers.
20 COMMISSIONER GILINSKY:
So when you say " conspiracy,"
21 that one interacting with people outside?
22 MR. VON EHRENFRIED:
Right.
With "N" numbers outside.
23 COMMISSIONER GILINSKY:
Is that what you are talking 24 about?
25 MR.
VON EHRENFRIED:
Right, right.
We are not looking
46 1
at two cleared insiders in conspiracy as much as we are looking 2
at conspiracy. between a cleared guy inside and a control group 3
outside, that kind of thing.
4 COMMISSIONER GILINSKY:
I mean these solid groups 5
outside can be bigger or they can be smaller?
6 MR. VON EHRENFRIED:
Right, right.
We'll look at how 7
sensitive the numbers are.
8 COMMISSIONER GILINSKY:
So you are going to come out 9
with a spectrum of results?
10 MR. VON EHRENFRIED:
Right.
That's what I keep using 11 this flight envelope kind of for balances.
12 COMMISSIONER GILINSKY:
Where does this leave you?
13 I mean that is sort of the end product?
14 MR. VON EHRENFRIED:
Well, that then let's.you 15 know. -- let's say now we have a spectrum of numbers of 16 assultant groups, numbers of insiders, and how they relate, 17 let's say, to a fundamental adversary action.
Then we can 18 draw some conclusions.
19 COMMISSIONER GILINSKY:
How will you know in the 20 meantime whether to recommend an upgrading -- an interim 21 upgrading, or not?
22 CHAIRMAN ROWDEN:
Against what norm do you determine 23 whether you're satisfied?
24 MR. VON EHRENFRIED:
That's a line that we can get the 25 upgrades project to-draw for us in the meantime.
47 Y l COMMISSIONER GILINSKY:
Well, let me ask:
What is 2
the objective of the upgrading project?
MR. VON EHRENFRIED:
The upgrade against some to-be-4 determined threat number.
COMMISSIONER GILINSKY:
But that's the long-term 6
upgrade.
7 MR. VON EHRENFRIED:
Yes, right.
O COMMISSIONER GILINSKY:
What are we doing for the 9
31x ___
10 MR. VON ESRENFRIED:
The near-term is 1 and 3.
11 Still 1 and 3 on that near-term and past year numbers.
12 CHAIRMAN ROWDEN:
When we finish I suggest that 13 we tie all this together.
14 COMMISSIONER GILINSKY:
Well, we had determined 15 violence, and we had well-equipped, well-trained ---
16 MR. CHAPMAN:
Let me see, since I have given Dutch 17 the instructions in this matter, may I 18 We had publicly announced a baseline threat 19 that we used in the past year, and that will remain as a 20 baseline condition throughout whatever we go through.
21 So we are taking off -- anything we do in the future 22 takes off from that point so to speak.
23 We have already communicated with you on the 24 internal matter in regards to clearance rule, and the 25
. application of that to employees in the plant and its relevance.
48 1
So that ground remains the same.
2 Now, what has been at issue here.came up in 3
connection with 73.55 is do we try to pick some specific 4
number for the next round of evaluations or do we broaden 5
this matter and give the review team more latitude in 6
determinations of the capability.
7 Now, what we have decided to do is going from the 8
baseline that was known and publicly stated last year -- we will, in effect, be making a trade-off between the 9
10 component pieces of the safeguards system and a range, 11 essentially unlimited range of capabilities in a threat situation.
12 S
that you would say that no matter whether it 13 is two, three, ten people, if the badging system at that site 4
is no damn good, it is no damn good.
It doesn't matter how many people are involved.
Now, there will be some features of the safeguard system that will only fail because of the preponderance or weight of some kind of an attacking force.
19 We don't know what level that is.
But we would 20 hope these people would make a judgment in that regard.
21 If the total guard system response force breaks 22 down at somewhere like a dozen guys attacking it, then we in 23 the staff, when this information comes back, and assessments 24 wrapped up, and the Commission, if that is appropriate, will 25 have to make a judgment as to whether that facility is okay or not.
49 1
I don't want :hese guys to go out and come back and 2
say, okay, it is exactly this against six/one.
I want to 3
determine what the hell are the failure points in the system ---
4 COMMISSIONER GILINSKY:
Well, ---
5 MR. CHAPMAN:
-- and at what level the threshhold in 6
this business are going to be expected to fail.
7 That's right.
All the way up to the major features 8
of the system.
9 MR. HUBERMAN:
Yeah.
10 MR. CHAPMAN:
So in effect we have shifted gears 11 away from this, you know, this absolute hard number business 12 into a more generic view of the thing, which will try to get thes e
13 people to come back and -- starting with 67 components going 14 up to the next.
You know, where are the failure modes in this 15 thing and at what threshholds of threat would those things 16 fail?
17 We have in the staff then the difficult job of 18 continuing to determine whether or not that is relevant or of 19 immediate concern based on whatever we can know about what we 20 think the threat situation is projected to be.
21 So it will be dynamic as opposed to the static 22 situation it has been in the past year.
I hope, and I think 23 it will be very useful once we can first bring information back.
24 COMMISSIONER GILINSKY:
What is the object of the 25 60-day upgrade?
50 1
MR.. CHAPMAN:
The 60-day upgrade, if you recall, 2
Commissioner, was because when we came to you ---
3 COMMISSICNER GILINSKY:
I recall the background, 4
but ---
5 MR. CHAPMAN:
The background was we did not have the 6
same assurance, the same degree of assurance or confidence 7
with respect to various facilities.
8 We exchanged with the Commission some views on how 9
to get that in the very near-term as opposed to capital 10 investments and the general agreement was that that fundamental 11 approach would be to add some guards, with some other things 12 that could be done.
We have undertaken those.
13 We have instructed each of the licensees -- and I 14 thought you had seen those, because there was a letter that went 15 ut about 30 days ago to each licensee that was affected 16 saying specifically what he was expected to do, with two conditions.
17 18 one is that it is effective the 16th of May.
If he doesn't react, if he has an alternative to what we have directed 19 and there.is one company that claimed they could get better 20 security by some other method than adding guards -- then we 21 want to entertain those no later than the 15th of April and 22 23 So that was all to put this whole thing in the same level of assurance against the threats that we were using in the
51 0
.a 1
past.
2 COMMISSIONER KENNEDY:
Given the time that has expired 3
do you have any indication that there are any:other than that 4
one?
5.
MR. CHAPMAN:
Well, we have the one and there is one 6
that is coming in for a different reason.
The B&W folks are in another matter which I have been 7
w rking with them on where we are going with the licensing of 8
that plant.
9 Ernie, has another action going and they have proposed 10 some alternatives in their case.
But there was only one reactior.
11 fr m the industry with respect to this 60-day effort.
2 COMMIFSIONER GILINSKY:
The view of it that I have is 3
that now we were protecting against.a small group.
4 MR. CHAPMAN:
Yes, sir.
COMMISSIONER GILINSKY: -- with ---
MR. CHAPMAN:
Essentially unlimited.
17 COMMISSIONER GILINSKY: -- essentially unlimited capability -- well trained and I'm not sure where we left the automatic weapons business.
20 MR. CHAPMAN:
We assume it is in.
21 COMMISSIONER GILINSKY:
Okay.
So we have it with 22 automatic weapons.
23 What are we talking about in the longer term is i
24
~
defending against,in effect, a larger group of such people.
25
)
i
52
.i 1
CHAIRMAN ROWDEN:
Or a more talented ---
a more 2
severe threat or something of that character.
3 MR. CHAPMAN:
More severe threat and the thing that 4
makes it more severe, since we have not placed any real 5
restrictions on the dedication or the weaponry, all that makes 6
it more severe probably is a larger size.
Perhaps more help 7
from inside.
8 COMMISSIONER GILINSKY:
Okay.
9 MR. CHAPMAN:
That's really what makes it bigger,or 1*0 more severe.
It is not ---
CHAIRMAN ROWDEN:
The point -- I don't know if Vic was 12 making the point, but I would like to make it.
13 One of the things we ought to do in giving you 14 guidance after this briefing, either in the form of that 15 guidance or a companion piece, is really to tie together all 16 the messages that we have been sending you to make sure there is 17 some consistent thread.
Because the descripters have not 18 always been the same.
And there have been additions to that 19 and I think there ought to be ---
20 COMMISSIONER GILINSKY:
We just went over that.
21 CHAIRMAN ROWDEN:
Oh, you did.
Okay.
22 MR. CHAPMAN:
Generally speaking, I think it is 23 pretty well sorted out in the staff.
But our communication 24 hasn't always been as good as it could have been down here.
25 And I think se are on pretty firm footing and I think the
53
\\
1 evaluation group is on pretty firm footing.
And it is the 2
intent not to force the situation where we have to define very 3
precisely whether the guy is wearing white tennis shoes would 4
be a hell of a lot more use to us than the past year when it was absolutely necessary.
We had to know what was out there and 6
we had to have a baseline to find out.
7 CHAIRMAN ROWDEN:
Whatever we told you ought to make 8
sense.
9 MR. CHAPMAN:
But now we have learned a lot.
10 MR. VOLGNEAU:
I think we need to make very clear 11 what the introduction of this will be, Dutch.
Could you put 12 your chart ---
13 MR. VON EHRENFRIED:
I had this one on results.
14 MR. VOLGENAU:
Tell me where -- relate that to your 15 bag chart and tell me where those individual site reports fit 16 on the bar chart.
17 MR. VON EHRENFRIED:
Okay.
Let me get two charts out 18 here.
Before I give you the bar chart, let me give you this.
19 The product coming out of the evaluation synthesis 20 group, which will be the classified and unclassified reports ---
21 MR. VOLGENAU:
Two reports.
22 MR. VON EHRENFRIED:
Two reports.
Each facility.
23 Will come into both your side and our side of the house for 24 implementation.
25 All right, now, where that will come schedule-wise for i
54
.to 1
a site will be sometime, let's say within a month, after this 2
team has completed, because we have already got to come back 3
and do a debrief, train new teams to get back out to another site.
4 So it will be at least 30 to 45 days for the synthesis groups to take results of this team, to come up with that.
6 MR. VOLGENAU:
So then the rest of NRC, if you 7
will, must make a decision as a result of those evaluations in 8
the two reports, as to what it is going to do with it, 9
whether it is different license conditions ---
10 MR. VON EHRENFRIED:
Right, right.
11 MR. VOLGENAU:
-- different inspection programs.
12 MR. VON EHRENFRIED:
That's the right-hand side of 13 implementation.
14 MR. CHAPMAN:
With one recognition.
That is, if there 15 is anything really abnormal that comes up, we would be back on 16 it imeediately.
17 MR. VOLGENAU:
Right.
18 MR. VON EHRENFRIED:
Okay.
That's it.
We are looking 19 for clarifying guidance, and final approval, and we are ready to 20 hit the road.
21 CHAIRMAN ROWDEN:
Okay.
You are waiting for the 22 message from us then.
23 CHAPMAN:
The only reason we are waiting -- in all 24 honesty, we are not waiting very much, but we were told to 25 bring the plan down here and review it with you, because of'the timing of this thing we have had to move along on some
I 55
',.g r i.
1 assumptions hoping that we weren't too far off base.
2 CEAIRMAN ROWDEN:
Understood.
3 Anything else?
4 (No response.)
5 You will be hearing from us very shortly.
6 MR. CHAPMAN:
Thank you.
CHAIRMAN ROWDEN:
Thank you.
Good briefing.
7 (End of tape recording.)
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