ML20052C474
| ML20052C474 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 04/30/1982 |
| From: | Gilbert F, Hartman W, Isaacs T JOINT APPLICANTS - CLINCH RIVER BREEDER REACTOR |
| To: | National Resources Defense Council, Sierra Club |
| References | |
| NUDOCS 8205050021 | |
| Download: ML20052C474 (29) | |
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NATURAL RESOURCES DEFENSE COUNCIL, IN
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Pursuant to 10 C.F.R. 5 2.742, and in accordance with the Board's Prehearing Conference Order of February 11, 1982, the Department of Energy, Project Management Corpora-tion, and the Tennessee Valley Authority (the Applicants),
hereby submit their Updated Responses to Intervenors',
Natural Resources Defense Council, Inc. and the Sierra Club, August 13, 1976 Request to Applicants for Admissions (1-1/
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cants responded to Admissions 1-38 on August 26, l
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ADMISSION.
1.
For a nominal or baseline threat with respect to safeguards, it is reasonable to assume that the internal and external threats are two and six persons, respec-tively.
The range of numbers suggested by threat researchers, expert opinion, and partisan comments generally lie within a factor of two, up and down, from this baseline specification.
RESPONSE.
1.
The Applicants deny this statement.
This statement assumes that a design basis threat has been selected.
The dynamic nature of safeguards requires that the concept of a " design basis threat" be placed in the proper context.
To the highest degree possible, the Applicants' approach to safeguards is to make the protection of the CRBRP and special nuclear material threat-independent.
This is due to the recognition of the fact that the definition of what may be treated as a nominal
" baseline threat" or credible threat is a continuing process which must take into account changing societal situations and advances in technology.
A better understanding of potential safeguards threats is evolving as a result of research into the moti-vations and capabilities of persons and groups who could pose threats to nuclear plants and special nuclear materials
. (see discussion DOE /EIS-0085-D,Section VI A.2).
It is recognized, for example, that size of the adversary force is but one of a number of characteristics and not necessarily the predominant one.
Perhaps the single most important conclusion that has been reached to date as a result of this research is that an effective safeguards system must respond to a spectrum of threats.
ADMISSION.
2.
The lowest level of design threat for safeguards is an internal threat, one person, and an external threat, three persons.
No one has seriously suggested that these levels are too high and that we should consider even lower as design threats for adequate safe guards.
RESPONSE.
2.
The Applicants deny this statement for the reasone stated in their response to No. 1.
ADMISSION.
3.
To estimate the credible threat, the Office of Nuclear Materials Safety and Safeguards researched 19 relevant studies and conducted nine (9) interviews with individuals and groups of professional analysts from the FBI, the intelligence [ community), the Department of Defense and State and local law enforcement agencies.
s 4-RESPONSE.
3.
The Applicants cannot truthfully admit or deny this statement.
The Applicants do not possess sufficient information concerning NRC's internal deliberative processes and the parameters of the inquiry conducted by NRC with regard to this topic to make such a determination.
ADMISSION.
4.
From this there was a consensus estimate that an external threat group will probably number about 6-8 persons and very likely not exceed 12 persons.
RESPONSE.
4.
The Applicants cannot truthfully admit or deny this statement for the reasons stated in their response to No. 3.
ADMISSION.
5.
This estimate is consistent with estimates that might be drawn from historical data alone.
RESPONSE.
5.
The Applicants cannot truthfully admit or deny this statement (See Applicants' response to No. 3) with regard to the consistency between this estimate and the estimate that might be drawn from historical data alone.
See the Applicants' response to No. 1.
' ADMISSION.
I 6.
With respect to the armaments that might be used in an external threat, the intelligence and police communities a'cknowledge that automatic weapons, machine guns, plastic explosives and shaped charges could be accumulated in a private arsenal.
RESPONSE,.
6.
The Applicants admit that the weapons and devices cited could be accumulated in private hands to the extent that "could" implies only that such an accumulation would not be impossible.
ADMISSION.
7.
Heavier weapons like mortars and hand-held air defense weapons might also be available but these would be detected more easily during movement so they are less likely to be employed than lighter weapons.
RESPONSE.
7.
The Applicants admit that the weapons cited would be more easily detected during movement, and less likely to be employed than lighter weapons.
The Applicants admit that these weapons might be available only to the extent that "might" implies that it would not be impossible.
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6-ADMISSION.
8.
In general, the internal threat to nuclear facilities is:
One person operating alone will probably remain undecected.
Instance of collusion involving 2-3 persons have been encountered in industry.
Most hijackings involve internal collusion.
Key internal persons can be influenced by threats against their families or other forms of blackmail.
RESPONSE.
8.
The Applicants cannot truthfully admit or deny this statement.
It is not clear what relationship exists between the initial phrase and the four sentences which follow.
ADMISSION.
9.
A credible internal threat, for safeguards purposes consists of 2-3 persons in collusion.
RESPONSE.
9.
The Applicants deny this statement for the reasons stated in their response to No. 1.
1 ADMISSION.
10.
Factors such as worldwide terrorism affect intelligence estimates of credible threat.
i RESPONSE.
10.
The Applicants cannot truthfully admit or deny this statement.
The Applicant is unable to respond since it is not involved in any intelligence gathering activities.
ADMISSION.
11.
In light of current conditions, the credible external threat is about 7 well-trained and equipped persons bent on theft of SNM or sabotage.
RESPONSE.
11.
The Applicants deny this statement for the reasons stated in their response to No. 1.
ADMISSION.
12.
The current credible internal threat is about 2 knowledgeable persons with access to SNM and facilities.
RESPONSE.
12.
The Applicants deny this statement for the reasons stated in their response to No. 1.
ADMISSION.
13.
The NRC Staff does not attempt to quantify a confidence level with respect to protection against theft of special nuclear material.
. l RESPONSE.
13.
The Applicants cannot truthfully admit or deny this statement.
See Applicants' response to No. 3.
ADMISSION.
14.
The adequacy of the CRBRP security program is judged against regulatory requirements, rather than threat capabilities or a range of threat capabilities.
RESPONSE.
14 The Applicants cannot truthfully admit or deny this statement.
The Applicants do not possess sufficient information concerning the entire basis upon which NRC will render its judgment of CRBRP safeguards and security systems.
ADMISSION.
15.
The nature of the internal (diversion) threat considered in establishing current licensing requirements is the diversion of special nuclear material (SNM) by one person.
RESPONSE.
15.
The Applicants cannot truthfully admit or deny this statement.
See Applicants' response to No. 3.
. ADMISSION.
16.
The nature of external (assault) threats considered in development of current licensing requirements was the prevention of theft or sabotage by one or two armed individuals or a group of unarmed individuals.
RESPONSE.
16.
The Applicants cannot truthfully admit or deny this statement.
See Applicants' response to No. 3.
ADMISSION.
17.
Physical protection requirements cannot be separated from credible threats.
RESPONSE.
17.
The Applicants deny this statement for the reasons stated in their response to No.
1.
ADMISSION.
18.
The Staff does not evaluate security programs for specific threat scenarios or threat capabilities.
RESPONSE.
18.
The Applicants canot truthfully admit or deny this statement.
See Applicants' response to No. 3.
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ADMISSION.
19.
The adequacy of the CRBRP security program is being judged against the existing regulatory requirements and guidance.
RESPONSE.
19.
The Applicants cannot truthfully admit or deny this statement.
See Applicants' response to No. 14.
ADMISSION.
20.
It is possible that a CDA could be initiated by sabotage conducted by one or two insiders who could gain access to vital equipment.
RESPONSE.
20.
The Applicants admit this statement to the extent that it is not impossible that a CDA could be initiated by sabotage conducted by one or two specially trained insiders who could gain access to vital equipment.
However, as discussed in detail in the Applicants' response to Interrogatory Set Eight (question IV) it is highly improbable that this could occur.
ADMISSION.
21.
It is possible that a CDA could be initiated by sabotage conducted by a group of outsiders aided by one or two insiders.
11 -
RESPONSE.
21.
See Applicants' response to No. 20.
ADMISSION.
22.
It is possible that insiders, whose families were held hostage, could be coerced into aiding a group of outsiders.
RESPONSE.
22.
The Applicants admit this statement to the extent that it is possible that insiders could be coerced into aiding a group of outsiders.
ADMISSION.
23.
Former Chairman Ray cited "a theoretical standard involving an attack by 10 terrorists armed with light weapons." The 10 cited by Chairman Ray may now be more appropriately described as a threat of a smaller group of well-trained outsiders armed with automatic weapons and assisted by a single insider.
RESPONSE.
23.
The Applicants admit this statement to the extent that this is an accurate quotation of. Chairman Ray, I
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. but it has bearing on CRBRP only to the extent discussed in the Applicants' response to No. 1.
ADMISSION.
24.
The CRBR will be subject to NRC license and construction requirements.
RESPONSE.
24.
The Applicants admit this statement.
ADMISSION.
25.
The fuel fabrication facility for CRBR, presently not designated, will also in all probability be subject to NRC license and inspection requirements.
RESPONSE.
25.
The Applicants deny this statement.
The probable fabrication facility for CRBR fuel is the Secure Automated Fabrication Line in Richland, Washington, which is not subject to NRC license and inspection requirements.
ADMISSION.
26.
The present location of plutonium for incorporation in CRBR fuel is at Hanford (Richland, Washington) which, as an ERDA facility, is exempt from licensing.
. RESPONSE.
26.
The Applicants can neither admit nor deny this statement, since the location is not presently known.
t (See Interrogatory Set 8, Updated Answer III, 5(a).
ADMISSION.
27.
The Applicant has not defined the " design basis threat" with respect to safeguards.
RESPONSE.
27.
The Applicants deny this statement.
A design basis threat for CRBR is defined in 10 C.F.R. Part 73.
DOE fuel cycle facilities are to be comparably effective.
ADMISSION.
28.
Guard forces should be engineered to meet the credible external / internal threats.
RESPONSE.
28.
The Applicants deny this statement for the reasons stated in their response to No. 1.
The guards forces are but one element of the Applicants' safeguards and security sy stems, and, therefore, are not necessarily engineered around a given threat.
For further discussion, t
refer to Applicants' answer to V - XIII of the Eighth Set of Interrogatories propounded by NRDC.
. ADMISSION.
29.
During recovery operations following a successful thef t of plutonium, a situation might arise wherein appropriate search warrants could not be obtained (e.g., on a timely basis) and as a consequence search without warrant would occur.
RESPONSE.
29.
The Applicants admit this statement, although DOE has no reason to believe that this will be the case.
ADMISSION.
30.
The recovery operations following a successful theft of plutonium might involve area-wide searches in which regions might be cordoned off and roadblocks set up.
In such cases all vehicles, buildings and other property might be searched.
Such search might be aided by detection equipment.
RESPONS E.
30.
The Applicants admit this statement, although DOE has no reason to believe that this will be the case.
ADMISSION.
31.
The recovery operations following a successful theft of plutonium might involve dentention and interrogation without warrant.
15 -
RESPONSE.
31.
The Applicants admit this statement.
ADMISSION.
32.
Following the successful theft of a sufficient amount of plutonium, a credible atom bomb blackmail threat would be possible.
RESPONSE.
32.
The Applicants cannot truthfully admit or deny this statement.
Knowledge that "a sufficient amount of plutonium" has been stolen does not provide sufficient l
information to assess the credibility of an atom bomb blackmail threat.
Credibility would depend upon many factors, including circumstances of the theft and the form of plutonium stolen.
See response to question VIII.5 of the Applicants' answers to Eighth Set of Interrogatories propounded by NRDC.
ADMISSION.
33.
In the presence of an atomic bomb blackmail threat, martial law may be required.
RESPONSE.
33.
The Applicants admit this statement although DOE has'no reason to believe that this will be the case.
16 -
ADMISSION.
34.
Following the successful theft of sufficient plutonium, an atomic bomb explosion with a yield of 100 tons (TNT equivalent) would be a possibility.
4 RESPONSE.
34.
The Applicants cannot truthfully admit or deny this statement.
There is insufficient information to make a determination.
Theft of nuclear material does not alone make an atomic bomb explosion a credible event.
Such a determination would require information concerning circumstances surrounding the thef t and the form of stolen plutoniuc.
ADMISSION.
35.
Following the successful thef t of sufficient plutonium, an atomic bomb explosion with a yield of 1000 tons (TNT equivalent) would be a possibility.
RESPONSE.
35.
The Applicants cannot truthfully admit or deny this statement.
See Applicants' response to No. 34.
O ADMISSION.
i 36.
The plutonium composition of the initial core j
loadings for the CRBR and that extracted from fuel removed from the reactor core represent preferred material for the
i 17 -
construction of atomic bombs as opposed to that form extracted from high burn up of LWR fuel.
RESPONSE.
36.
The Applicants admit this statement to the extent that the Pu composition alone is considered.
How-ever, in reality, preferred material for " atomic bombs" is a complex issue that cannot be addressed simply by examining the chemical and isotopic compositions of the various classes of reactor fuels cited.
Other factors in such a definition would include, but not be limited to, material form or availability, radiological hazards posed in clandestine operations, and time, equipment, knowledge, and resources required between acquisition of the fuel in its processing.
ADMISSION.
37.
The plutonium extracted from the blanket of the CRBR would be a more preferred atomic bomb material than the initial core loadings or that extracted from fuel removed from the reactor core.
RESPONSE.
37.
The Applicants admit this statement.
See Applicants' response to No. 36.
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. ADMISSION.
38.
Plutonium in the initial core loading, the plutonium extracted from fuel removed from the reactor core, and plutonium extracted from the blar. set of the CRBR would be weapons-grade plutonium.
RESPONSE.
38.
The Applicants deny this statement.
The plutonium in the initial core loading and the plutonium extracted from fuel removed from the reactor core is not
" weapons grade" plutonium.
The Applicants admit that the plutonium which could be extracted from the blanket is
" weapons grade" plutonium.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of
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Department of Energy
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DOCKET NO. 50-537 PROJECT MANAGEMENT CORPORATION and,)
TENNESSEE VALLEY AUTHORITY
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AFFIDAVIT OF Dr. F. C. Gilbert, being duly sworn, deposes and says as follows:
1.
That he is employed as Deputy Assistant Secretary for Nuclear Materials, Defense Programs, U.S. Department of Energy, and that he is duty authorized to update the replies to Item 26 and Items 36-38 in the Natural Resources Defense Council's August 13, 1976 request for Admission concerning Contention 5.
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That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.
signature SUBSCRIBED and SWORN to before me this / 4 day of Ape,L,1982.
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In the matter of
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DOCKET NO. 50-537 PROJECT MANAGEMENT CORPORATION and,)
TENNESSEE VALLEY AUTHORITY
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AFFIDAVIT OF William M. Hartman, being duly sworn, deposes and says as follows:
1.
That he is employed as Nuclear Engineer, Office of Reactor Research and Technology, U.S. Department of Energy, and that he is duty authorized to execute the responses on behalf of the Applicants to the NRDC's August 17, 1976, request for Admission Centention 9, number 9; and NRDC's August 13, 1976, request for Admission Contention 5, number 25.
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That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.
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29 SUBSCRIBED and SWORN to before me this /.f day of dre/ C,1982.
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NUCLEAR RFGULATORY COMMISSION In the matter of
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DOCKET NO. 50-537 PROJECT MANAGEMENT CORPORATION and,)
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AFFIDAVIT OF John R. Longenecker, being duly sworn, deposes and says as follows:
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That he is employed as Manager, Licensing and Environmental Coordination, Office of Nuclear Energy, U.S. Department of Energy, and that he is duly authorized to update the replies to Item 24 in the Natural Resources Defense Council's August 13, 1976 request for Admission concerning Contention 5.
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That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.
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AFFIDAVIT OF Major General William W. Hoover, USAF, being duly sworn, 1
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DOCKET N0. 50-537 PROJECT MANAGEMENT CORPORATION and,'
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AFFIDAVIT OF John Stewart, being duly sworn, deposet and says as follows:
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That he is employed as Program Analyst, Office of Safeguards and Security, U.S. Department of Energy, and that he is duly authorized to answer 8/13/76 Admissions numbers 3, 4, 6-10, 13-16, 18, 19, and 22.
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That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.
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DOCKET NO. 50-537 PR(kIECT MANAGEMENT CORPORATION and,)
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- 4 Robert L. Woolley, being duly sworn, deposes and says AFFIDAVIT OF I
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That he is employed as Licensing Manager, Plant Development Division, Office of Nuclear Energy, U.S. Department of Energy, and that he is duly authorized to update the replies to Item 78 l
29, 31, and 33 in the Natural Resources Def'ense Council's August 13, 1976 request for Admission concerning Contention 5.
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That the above-mentioned and attached answers are true and
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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In the Matter of
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UNITED STATES DEPARTMENT OF ENERGY
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PROJECT MANAGEMENT CORPORATION
)
Docket No. 50-537
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TENNESSEE VALLEY AUTHORITY
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(Clinch River Breeder Reactor Plant)
)
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CERTIFICATE OF SERVICE Service has been effected on this date by personal delivery or first-class mail to the following:
- Marshall E. Miller, Esquire Chairman Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C.
20545 Dr. Cadet H. Hand, Jr.
Director Bodega M rine Laboratory a
University of California P. O. Box 247 4
Bodega Bay, California 94923
- Mr. Gustave A. Linenberger Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C.
20545
- Daniel Swanson, Esquire
- Stuart Treby, Esquire Office of Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C.
20545 (2 copies)
-2.
- Atomic Safety & Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D. C.
20545
- Atomic Safety & Licensing Board Panel U. S. Nuclear Regulatory Com=ission Washington, D. C.
20545
- Docketing & Service Section Office of the Secretary i
U. S. Nuclear Regulatory Commission Washington, D. C.
20545 (3 copies)
William M. Leech, Jr., Attorney General William B. Hubbard, Chief Deputy Attorney General Lee Breckenridge, Assistant Attorney General State of Tennessee Office of the Attorney General 450 James Robertson Parkway Nashville, Tennessee 37219 Oak Ridge Public Library Civic Center Oak Ridge, Tennessee 37820 Herbert S. Sanger, Jr., Esquire Lewis E. Wallace, Esquire W. Walter LaRoche, Esquire James F. Burger, Esquire Edward J. Vigluicci, Esquire Office of the General Counsel Tennessee Valley Authority 400 Commerce Avenue Knoxville, Tennessee 37902 (2 copies)
- Dr. Thomas Cochran Barbara A. Finamore, Esquire Natural Resources Defense Council 1725 Eye Street, N. W., Suite 600 Washington, D. C.
20006 (2 copies)
Mr. Joe H. Walker 401 Roane Street Harriman, Tennessee 37748 Ellyn R. Weiss Harmon & Weiss 1725 Eye Street, N. W.,
Suite 506 Washington, D. C.
20006
l l Lawson McGhee Public Library 500 West Church Street Knoxville, Tennessee 37902 I
William E. Lantrip, Esq.
Attorney for the City of Oak Ridge Municipal Building P. O. Box 1 Oak Ridge, Tennessee 37830 1
l Leon Silverstrom, Esq.
Warren E. Bergholz, Jr., Esq.
l U. S. Department of Energy 1000 Independence Ave., S. W.
t Room 6-B-256, Forrestal Building i
Washington, D. C.
20585 (2 copies)
- Eldon V. C. Greenberg Tuttle & Taylor i
1901 L Street, N. W.,
Suite 805 Washington, D. C.
20036 l
Commissioner James Cotham r
Tennessee Department of Economic and Community Development I
Andrew Jackson Building, Suite 1007 l
Nashville, Tennessee 37219 i
i GeorgVL. EdgF Attorney for Project Management Corporation DATED: April 30, 1982 1
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Denotes hand delivery to 1717 "H" Street, N.W., Washington, D. C.
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- / Denotes hand delivery to indicated address.
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