ML19350C361
| ML19350C361 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse, Erwin, 07000754, 07001113, 07000734, 07000008, 07000036, 07001100, 07001201, 07000398, Framatome ANP Richland, 07000824, 07000135 |
| Issue date: | 03/16/1981 |
| From: | Huff D NRC |
| To: | Partlow J NRC |
| Shared Package | |
| ML19350C362 | List: |
| References | |
| NUDOCS 8104010154 | |
| Download: ML19350C361 (2) | |
Text
q..
q.
D T.-
C r;
ir -
70-11ca 70-36, 70-1201,70-135, 70-824, 70-1257, 3M 16 E 70-754, 70-1113,70-143, DISTRISL' TION :
.Accket files Case files MCL r/f NOTE TO:
J. G. Partlow DHuff RBrightsen FROM:
D. A. Huff JJoyner, Reg. I EMcAlpine, Reg. II THRU:
R. A. Brightsen JHind Reg. III LNorderhaug, Reg. V SU3 JECT: TAMPER-SAFING OF LEU-ADDENDUM This memo is written in order to address those questions and concerns raised as a result of my October 21, 1930 memo regarding the tamper-safing of LEU. These are addressed as follows:
1.
Concerning the conclusion that " theft of significhut quantities of LEU by a single insider is not a credible threat", the coment was made that perhaps numerous trips using a once successful route might present a credible threat. In response to this comment, I make the following observations:
(a) Just because a particular route was once successful, there is no reason to believe that it will be successful again.
Using this route will still involve a degree of risk.
(b)- At 50 lbs/ theft, somewhere between 100 and 180 thef ts would have to be made during a year in order to steal a significant quantity of LEU. In my opinion, increasing the frequency of theft to such a high level would either increase the overall probability of detection or at least not decrease it. There fore,
the multiple theft scenario is in actuality no more credible than the one involving a single large theft.
2.
Concerning the conclusion that "use of the two-man rule at LEU facilities as presently constituted does not provide credible protec-tion from the acts of a single insider", the comment was made that this conclusion was not sufficiently substantiated. However, after
' discussing this with you, it became apparent that the intent of this conclusion was either misunderstood or poorly stated. !!y intent was not to say tbt a two-man rule provides no insider protection but that the two-man rule presently used at LEU facilities is no deterrent to insider theft. A comprehensive two-man rule does indeed provide credible deterrence against insider theft; nevertheless, in the case of LEU facilities where most material in the plant is afforded no protection by a two-man rule, credible deterrence does not exist.
3.
The administrative controls referred to by the comment "What are they?"
are listed in the supporting information for conclusion number one in the October 21 memo. As stated there, these controls include such things as documentation, signa'tures, and the item control program. In fa be consicerec
- C4...........asct, many types of production control records c1 gnt al so part of-these hontrolsv.~..
. - ~ ~ ~... -
~ ~. ~. - ~ ~.
. - ~.. - - -
'""4
=>... 410.4.0.1.0./5.Y...
...d............
,a.,,,.....
an...c nun n--,n, n-nn--
n n n..
I, tr c.
E t
t
-i
(
r 4.
The concern was expressed that eliminating the two-man rule for tamper-safing LEU would decrease the quality of ID at LEU facilities.
It is hereby acknowledged that the accuracy of an individual ID could potentially be compromised by allowing a single individual to tamper-safe containers, if this individual were to falsify tamper-safing records for product or scrap to reflect the existence of material which had been removed. However, one must remember that ID is only a single detection mechanism whereby theft can be discovered which is actually much less sensitive than most other detection mechanisms in an LEU plant (such as item control and tamper-safing records). In addition, when you consider that most tamper-safed LEU has a relatively
. r t residency time (usually no lenger than 2-3 weeks), the fact . an ID might be compromised through the use of tamper-safing does not imply that ones capability for detecting theft is significan'.ly decreased.
Indeed, the above arguments tend to support the conclusion that a one-man rule for tamper-safing LEU pro-vides a detection capability for tamper-safed material which is essentially equivalent to or better than that which exists for untamper-safed material. Therefore, requiring something more for tamper-safed material by necessitating a two-man rule for this activi-ty is neither necessary to the overall objective of timely detection nor is it cost-effective (i.e., doubling the manpower requirement yields little if any safeguards benefit).
5.
Concerning the statement in the previously proposed letter to LEU licensees which indicated that " requiring the second individual for tamper-safing LEU serves no useful purpose relative to effective safeguards", the comment was made that this statement is in error.
Although my opinion continues to be that this s*atement is indeed accurate, I have no objection to changing the letter to read as follows: "We have reevaluated this policy and have determined that tamper-safing of LEU by a single individual does not significantly -
reduce the effectiveness of the current safeguards program for LEU."
Therefore, the new proposed letter to LEU licensees reflects this change.
6.
Due to the fact that some studies indicate that material with greater than 6% enrichment can be used directly in the construction of a
' nuclear explosive, it was recommended that the proposed new tamper-safing policy not be allowed for LEU above this enrichment. There-fore, in response to this recommendation, the proposed letter for implementing this new policy has been modified to make it clear that it applies only to LEU which is less than 6% enriched.
I now believe that all relevant concerns have been addressed. Therefore, I recommend that we send the new proposed letter to all appropriate LEU licensees without delay.
(s\\
emc5 >,SML
,,5 @,L,,h,k,,,,,,,,,,,,,,,,,,,,,,
,,,,,,,,, w,,,,,,,,,,,a. u c
, bb,,/.im.1... 8AS.r.i.9.h,M,e n,,
" "^"*F
^"b
, M.f.W.8.I...... 3,d,W,8,1,,,,,,,,
ec row m ne.semace cuo OFFICIAL RECORD COPY
- '+o-m
-