ML20028F428

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Eden Radioisotopes, LLC January 21, 2020 Meeting Presentation
ML20028F428
Person / Time
Site: 99902077
Issue date: 01/28/2020
From: Beth Reed, Charles Teal
Office of Nuclear Reactor Regulation, Office of Nuclear Security and Incident Response
To:
Shared Package
ML20028E698 List:
References
Download: ML20028F428 (15)
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Potential Security Measures Beth Reed, NRR Chuck Teal, NSIR January 21, 2020

Commission Direction

  • Use supplemental security measures

- Measures to supplement the regulation

- Measures in past Orders apply

- Apply as license conditions

  • Site specific

- Dependent on design, use, product, etc

  • Graded approach

- Accounts for type and quantity of material used 2

Approach

  • Regulatory Basis for Rulemaking to Enhance Security of SNM

- In ADAMS under ML14321A007

  • Rule was discontinued, but approach remains

- Graded approach

- Risk informed

- Based on the attractiveness of the material

- Driven by the dilution of the material 3

Dilution Factor

  • The weight of uranium-235, uranium-233 and plutonium divided by the total weight of the SNM material and non-SNM materials which are not mechanically separable from the SNM) for solids.
  • Three Levels

- Non-dilute

- Moderately dilute

- Highly dilute

Non-dilute

  • Material with a dilution factor equal to or greater than 20 percent for uranium-235 and equal to or greater than 10 percent for uranium-233 and plutonium.

Moderately Dilute

  • Material with a dilution factor equal to or greater than 1 percent but less than 20 percent for uranium-235 and equal to or greater than 1 percent but less than 10 percent for uranium-233 and plutonium.
  • MOX and certain non power reactor fuels, for example, can be considered moderately dilute SNM.

Highly Dilute

  • HEU-contaminated processing waste, for which the recovery of SNM is uneconomic, is an example of highly dilute materials.

Material Attractiveness - U-235 Uranium-235 Nuclear Material Attractiveness Cat I Cat II Cat III Level High-Grade Materials A 5 kg 1 kg RQ Metals and compounds (20 wt %), solutions (25 g/l) <5 kg <1 kg Low-Grade Materials B N/A 25 kg? RQ Metals and compounds (1 wt % and <20 wt %); <25 kg?

solutions (1 g/l and <25 g/l)

All Other Materials C N/A N/A RQ Uranium (<10% U-235); highly irradiated material (1000 R/h @ 1 m); metals and compounds (<1 wt

%); solutions (<1 g/l) 8

Material Attractiveness - Pu & U-233 Plutonium and Uranium-233 Nuclear Material Attractiveness Cat I Cat II Cat III Level High-Grade Materials A 2 kg 0.4 kg RQ Metals and compounds (20 wt %); solutions (25 <2 kg <0.4 kg g/l)

Low-Grade Materials B N/A 10 kg? RQ Metals and compounds (1 wt % and <20 wt %); <10 kg?

solutions (1 g/l and <25 g/l); Pu (80 % Pu-238)

All Other Materials C N/A N/A RQ Uranium (<6% U-233); highly irradiated material (1000 R/h @ 1 m); metals and compounds (<1 wt

%); solutions (<1 g/l) 9

Potential Security Measures Cat I Cat I Mod Dilute Cat II Mod Dilute Cat I Highly Dilute Cat II Cat III Protective Strategy Protect against DBT Immediately detect Promptly detect Timely detect of theft and diversion attempts to remove attempts to remove attempts to remove and radiological of SNM and provide of SNM and notify of SNM and notify sabotage sufficient delay local law LLEA to recovery through the use of enforcement SNM Prevent the removal barriers and/or agencies to allow of SNM and other armed responders to recovery of SNM.

unauthorized allow LLEA to activities involving promptly recover SNM SNM Diversion Path Analysis Security Plan Physical Security Physical Security Physical Security Physical Security Plan Plan Plan Plan Safeguards Cont. Safeguards Cont.

Plan Plan Training & Qual. Training & Qual.

Plan Plan 10

Cat I Cat I Mod Dilute Cat II Mod Dilute Cat I Highly Dilute Cat II Cat III Security Implement Program Implement Program Implement Program Implement Program Organization Management Management Management Management System System System System Part 26 - except Subpart I & K Part 26, Subpart I -

Manage Fatigue Physical Barrier OCA Vehicle Barrier Vehicle Barrier System/blast System analysis Isolation Zone Isolation Zone Protected Area Protected Area Vital Area Material Access Controlled Access Controlled Access Controlled Access Area Area Area Area Locked Processes Locked Processes Locked Processes Vault Vault-type room Vault-type room Hardened CAS Hardened CAS 11

Cat I Cat I Mod Dilute Cat II Mod Dilute Cat I Highly Dilute Cat II Cat III Access Controls Protected & Material Protected Area & Controlled Access Controlled Access Access Area Access Controlled Access Area Access Portals Area Access Portals Portals Area Access Portals Limit unescorted Limit unescorted Limit unescorted Limit unescorted access access access access Part 11 73.57 73.57 73.57 Photo Badges Photo Badges Photo Badges Photo Badges Escort Requirements Escort Requirements Escort Requirements Escort Requirements Search Programs OCA - vehicles None Protected Area - Protected Area -

entry (contraband) & entry (contraband) &

exit (SNM - exit (SNM &

shielding) shielding)

Material Access Controlled Access Controlled Access Area - entry and exit Area - exit (SNM & Area - entry (SNM - shielding) shielding) (contraband) random exit (SNM &

Vault (weapons) shielding) 12

Cat I Cat I Mod Dilute Cat II Mod Dilute Cat I Highly Dilute Cat II Cat III Detection and Protected Area & Protected Area & Vault type room Assessment Material Access Vault type room Intrusion Detection Area Intrusion Intrusion Detection System with UPS Detection System System with UPS with UPS Video Capture Video Capture Central Alarm Central Alarm Central Alarm Station Station Station Secondary Alarm Secondary Alarm Secondary Alarm Station (on-site or Station (on-site or Station off-site) off-site)

Surveillance Surveillance Surveillance Surveillance Program - Program Program Program Protected Area &

unoccupied Material Access Area Periodic Patrols of Periodic Patrols of Periodic Patrols of Periodic Patrols of outside areas outside areas outside areas outside areas Two person rule in MAA Three person rule in Vault Illumination Illumination 13

Cat I Cat I Mod Dilute Cat II Mod Dilute Cat I Highly Dilute Cat II Cat III Communication CAS/SAS two-way CAS/SAS two-way CAS/SAS two-way Two-way redundant redundant redundant redundant communication with communication with communication with communication with LLEA LLEA LLEA LLEA Continuous Continuous Continuous Continuous communication communication communication communication between CAS/SAS between CAS/SAS between CAS and among security force and on-site and off- and on-site and off- on-site and off-site site response force site response force response force Non-portable Non-portable Non-portable Non-portable equipment on UPS equipment on UPS equipment on UPS equipment on UPS Response 10 Tactical Response Team -

interrupt and neutralize Deadly Force Deadly Force Armed Security Armed Security Officers Officers - interrupt LLEA Liaison LLEA Liaison LLEA Liaison LLEA Liaison Heightened Security Heightened Security Heightened Security 14

Cat I Cat I Mod Dilute Cat II Mod Dilute Cat I Highly Dilute Cat II Cat III Security Program Annually Bi-annually Bi-annually Bi-annually Review Management Management Management Management Review Review Review Review CAP or event log CAP or event log CAP or event log CAP or event log Maintenance & Required Required Required None Testing Compensatory In PSP In PSP In PSP In PSP Measures Suspension of Allowed Allowed Allowed Allowed Security Measures Records Required Required Required Required Alternative Allowed Allowed Allowed Allowed Measures 15

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