ML20058B411
| ML20058B411 | |
| Person / Time | |
|---|---|
| Issue date: | 10/26/1990 |
| From: | Haugnhey C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Johnson T CITIZENS AGAINST NUCLEAR TRASH |
| References | |
| REF-PROJ-M-45 NUDOCS 9010300182 | |
| Download: ML20058B411 (14) | |
Text
OCT I 61990 Mr. Toney Johnson Citizens Against Nuclear Trash c/o P.O. Box 195 Homer, Louisiana 71040
Dear Mr. Johnson:
Thank you for your letter dated October 1,1990, in which you indicated that we have properly (LES),
summarized your concerns related to ownership of Louisiana Energy Services Because your concerns pertain to entities which are not Nuclear Regulatory Commission (NRC) licensees or applicants and to other matters most of which are not regulated by the NRC, we have only limited jurisdiction at this time.
We are reviewing your concerns in anticipation of the prospective application for licenses by LES. The nature and scope of the review depends on the specific issues under consideration.
There is no intervention or hearing in connection with this review.
However, once LES submits an application for licenses, a notice will be published in the Federal Register announcing its receipt and opportunity for leave to intervene in the proceeding, according to the appropriate procedures in Title 10 Code of Federal Regulations, Part 2.
I want to assure you that we do not intend to sweep your concerns under the rug. We take very seriously our responsibility to review matters which involve protection of public health and safety and the common defense and security.
We will advise you of the results of our review of your concerns when it is completed.
Separately, in response to your telephone request to Mr. Loysen of nty staff for a copy of our trip report to the Urtnco plants in Europe last June, a copy of the report is enclosed.
Sincerely.
Onfmal,$17,0e11h)
Charles J. Haughney, Chief Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards
Enclosure:
Trip report Distribution:
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TRIP REPORT l
VISITS TO URENCO GAS CENTRIFUGE URANIUM ENRICHMENT PLANTS i
l ALMELO, THE NETHERLANDS f
GRONAU, FEDERAL REPUBLIC 0F GERMANY CAPENHURST, ENGLAND JUNE S-8, 1990
SUMMARY
l During the period of June S-8, 1990, an NRC team visited the gas centrifuge uranium enrichment plants opt ited by Urenco in Europe. They were accompanied by representatives of the U.S. Department of Energy, Louisiana Energy Services I
(LES), Urenco, Inc, and Urenco, Ltd.
The purpose of the visits was to gain more detailed safety, environmental, safeguards, and security information, about the plants' design, construction, and operation in preparation for reviewing a license application by LES for a similar plant in the United States.
The visits included two days at Urenco Nederland in Almelo, the l'
Netherlands, one day at Urenco Deutschland in Gronau, Federal Republic of Germany, and one day at Urenco (UK) in Capenhurst, England.
The discussions focused on safety and environmental considerations involving UF handling, safeguards in place at the plants, and classification and g
control of sensitive information.
Site visits included plant tours of operating fee,d, cascade, and take-off halls, research facilities - and the centrifuge machine assembly building at Gronau.
Much of the information l
disclosed was classified, proprietary, or provided in confidence.
The objectives of the visits - familiarization with gas centrifuge enrichment operations and identification of issues that might impact licensing - were completely satisfied.
Urenco personnel were open and frank in discussions, and the NRC team was given access to the most sensitive portions of the facilities. While the principles of operation of the Urerco plants are the same, significant technical differences exist among them, and Urenco expects to provide the most modern, safe, and secure features for the LES plant.
With the possible exception of UF tails (tisposition, there do not appear to be any g
unresolvable safety or envir5nmental issues based on the demonstrated operation of the Urenco plants.
In regard to nuclear material safeguards, the systems installed in the Urenco plants would provide a good start in satisfying NRC requirements, but additional positive measures to protect against and detect. unauthorized production and enrichment will be necessary.
Security, and especially classification, procedures of the Tripartite governments, which are followed by Urenco, differ from those that will be required for LES.
A series of actions involving Urenco, LES, NRC, and DOE will be necessary to provide appropriate security-classification measures for classified information and material in the United States.
.g.
BACKGROUND In mid-1989, LES announced that it was proceeding with plans to develop the first commercial uranium enrichment plant in the United States, to be located at Homer Louisiana.
LES, a partnership comprising components of Urenco Inc.
(a wholly-owned subsidiary of Urenco, Ltd.), Fluor Daniel, Inc., Duke Power Company, Louisiana Power & Light Company, and Northern States Power Company, would employ the gas centrifuge technology and equipment provided by Urenco, Ltd.
Urenco has successfully operated gas centrifuge uranium enrichment plants in Europe for many years, and currently has facilities in Almelo, the Netherlands, Gronau, Federal Republic of Germany, and Capenhurst, England.
The U.S. plant, to be known as the Claiborne Enrichment Center (CEC), would be modelled after the latest Urenco designs in service, and would have a capacity of 1.5 million separative work units (SWU) per year.
The NRC staff, having little experience with gas centrifuge uranium enrichment technology, immediately embarked on a familiarization program which began with a brief visit in September 1989 to Urenco's Almelo and Gronau plants by R.M. Bernaro, R.E. Cunningham, and P. Loysen.
The program also included a visit to 00E uranium enrichment facilities, award of a technical assistance contract to a 00E laboratory for development of specifications for material control and accounting, and initiation of a rulemaking for uranium enrichment safeguards (presently not covered in NRC regulations).
The initial visit to the Urenco plants pointed out the need for more detailed visits, particularly by NRC l
Safeguards staff, to the plants prior to receipt of an application for licenses by LES.
Accordingly, arrangements were made through the Netherlands Embassy and the U.S. Department of State, and later with LES, Urenco, Inc.,
and Urenco Ltd., for classified visits to the three plants.
The objective was to gain insights on safety, environmental, safeguards, and security matters t
l_
related to gas centrifuge uranium enrichment, and to identify potential issues L
that could impact licensing of the proposed LES plant in the United States.
THE NRC TEAM VISITS The NRC team consisted of R.J. Brady, Director, Division of Security, ADM, i
l R.F. Burnett, Director, Division of Safeguards and Transportatlon, NMSS, C.J.
Haughney, Chief, Fuel Cycle Safety Branch, Division of Industrial and Medical Nuclear Safety, NMSS, 0.J. Kasun, Acting Chief, Domestic Safeguards and i
Regional Oversight Branch, Division of Safeguards and Transportation, NMSS, and P. Loysen, Licensing Project Manager, Fuel Cycle Safety Branch, Division of Industrial and Medical Nuclear Safety, NMSS.
The team was accompanied throughout the visits by W. Shepard, Office of Classificatio; fechnology and Policy 00E, P.G. LeRoy, LES Licensing Manager, Duke Engineering & Services, Inc., E.F. Kraska, Senior Technical Manager, Vrenco, Inc., M.B. Kratzer, Board Member, Urenco, Inc., A.J. Lorimer, Project Director, Vrenco Ltd., and O.
Aston, Company Scretary, Vrenco Ltd.
A list of the many other individuals l
with whom the team interacted at the threo sites is attached at the end of the report.
The Urenco plant visits included two days at Urenco Nederland in Almelo, one day at Urenco Deutschland in Gronau, and one day at Urenco (UK) in Capenburst.
The overall agenda provided for extensive briefings by the Almelo plant experts in the principal' areas of interest, followed by an overall plant tour, detailed discussions on individual topics, and additional plant observations.
The pattern was repeated at the other plants, but without extensive briefings
l..
3 e
and with emphasis placed on differences among the plants.
Of special interest was a detailed tour through the centrifuge machine assembly building at the Gronau site.
Prior to the Capenhurst plant visit, the UK government hosted a dinner in Chester, providing the opportunity for informal exchanges with Urenco (UK), British Nuclear Fuels Limited, and UK Department of Energy safety, safeguards, and security personnel.
The remainder of the report is separated into individual sections dealing with safety and environmental, safeguards, and security and classification matters.
SAFETY AND ENVIRONMENTAJ Introductions were made all around at the beginning of the vists at Almelo, and welcoming talks given by Dr. H. Rakhorst, Mr. D. Aston, and Mr. A.
Lorimer, with remarks being made by Messrs. Haughney, Burnett, and Brady, as well as Mr. P. Verbeek of the Netherlands Ministry af Foreign Affairs.
Mr. N.
Hootsmans provided a detailed explanation of the or{gnization and management of Urenco Ltd., Ultra-Centrifuge Nederland, and Urenco Nederland, and the development of gas centrifuge uranium enrichment technology.
He stressed the importance of quality assurance throughout plant activities and its main cbjective to ensure reliability for economic success.
In that regard, he stated thtt in 1988 overall Urenco production since inception was 95 percent l
of installd capacity.
Attainment of a high degree of safety is an important benefit of t,'e Qv program as well.
Mr. B. Dekker delivered an extensive briefing on the safety and environmental aspects of the Almelo plants, including the design and operating philosophy, i
features for worker and environmental protection, and licensing.
The NRC team l
asked about the company's position on disposition of UF tails, noting the g
interest on that issue in the United States and the visTt by Mr. Haughney and Mr. Loysen to the Cogema tails defluorination plant at Pierrelatte, France.
Mr. Larimer stated that the policy of the Troika countries is to store UF tailsasanasset,withchecksandmonitoringofstoragecylinderstoensbre their integrity.
Urenco offers to return tails to its customers, and some accept the offer.
At Almelo, for example, only about 50 percent of the tails generated have been retained onsite.
This may explain Mr. Bernero's otservation last fall that there seemed an inordinately small number of tails cylinders at the plants.
Mr. Dekker mentioned that a risk analysis performed in the UK concluded that outside storage in cylinders was acceptable.
After touring the plant and receiving additional briefings on safeguards and security-classification matters, discussions were held with plant engi.pers to get a better understanding of how material flows through the plant and where potential problem areas might be.
In addition to the known situation related to feed, take-off, homogenization, and blending stations; feed purification (essentially desublimers), contingency and crash dump systems, and flow control-systems may provide points for system upset and will need to be examined in connection with the LES application.
Apparently, during normal operation, the plant is easily controlled and runs without significant process flow perturbation.
No accidents involving releases of UF have been reported.
6 One Urenco manager indicated that running the plant, per 5e, was boring!
At Gronau, the newest of the three plants, Urenco Deutschland is in the process of adding 600,000 SWUs to bring the total capacity to one million SWUs
s
. e in 1991.
The centrifuge machines for the addition ce of the TC-12 type, the same as will be used at LES.
Dr. G. Meyer-Kretchmen and Mr. J. Pokar provided most of the briefing on the Gronau plant, which was SM rt because of the interest by the NRC team in visiting the centrifuge machine assembly building, and the need to leave in time to fly to England in the early evening.
One interesting difference among the plants and discussed here is the methods in which UF product and tails are collected to the take-off stations.
At Gronau g
and largGly at Almelo, UF is collected in desublimers, which are essentially 6
large cold traps, isolatea from the main process flow stream, and then reheated and sent to the product and tails cylinders.
At Capenhurst UF is c
compressed (still at subatmospheric pressure) and sent directly to the pFoduct and tails ev!1nders.
The former method involves an extra step and a significLnt accumulation of UF. outside of cylinders, which is problematical, while the latter method is morI continuous, but involves compressors and their attendant leakage potential.
The LES plant would use three stages of compression, two at the exit from the cascades, and one adjacent to the take-off stations.
This final compression is done as close to take-off as possible to minimize the amount of heat tracing required to keep the UF I
l gaseous at the pressure extant.
6 l
For over a year, classified details of the gas centrifuge machines developed i
l by Urenco have been unavailable to the NRC staff.
Urenco has maintained that NRC should not care about the details because the machines contain so little i
l uranium and their failure is inconsequential.
The staff has stated that it needs to understand the machines to reach or agree with Urenco's conclusions.
It was with this background that Urenco permitted the NRC team to tour the centrifuge assembly building at Gronau, and in fact, explained all facets of machine construction and assembly.
A cutaway of a current model machine was of great value in the explanation.
Most of the information obtained on this tour was classified, some aspects of which are discussed in the Security and i
I Classification section of this report.
The information and the results of i
actual centrifuge machine failures in the plants help the NRC team to understand why Urenco believes that machine failures have little or no safety I
implications.
l BNFL's Capenburst. Works, which contains the oldest operating centrifuge machines in the Urenco enterprise, is not being expanded beyond its 800,000.
l SWUs per year capacity.
In addition to the distinction of using compressors, rather than desublimers, for collection of UF from the cascades, Capenhurst I
heatsfeedcylindersinsteamcheststosublikesolidUF directly to gas, without going through the liquid phase.
Thenewerplanth(andthepropoo LES plant) heat feed cylinders in autoclaves with either electrically heated l
or steam-heated air.
This also permits the reduction to subatmospheric pressure for feeding to the cascades to be taken withiri the autoclaves, a safety feature that will be incorporated at LES, but not used at Almelo or Gronau.
It is not clear, however, whetner feed purification would occur l
before or after pressure reduction.
L The Capenburst plant radiation protection manager' explained his practices for control of worker and public exposure to uranium and HF.
Combined internal and external doses to workers are very low, averaging some 55 millirems per 1
year in 1989, and arise mostly from maintenance and waste processing activities.
In the UK, acute exposures to HF are based on a concept called toxic load, which is expressed as (concentration)2 x time, so as to limit
l exposures to very high concentrations, if even for short times.
For the times of interest, the numerical value of the HF toxic load is similar to that used by the NRC.
The plant manager mentioned that the old gaseous diffusion plants at Capenhurst were being decommissioned, and that the high assay plant has been decommissioned.
However, there are no specific arrIngements for decommissioning the gas centrifuge plant in the future, inasmuch as it would be but a small part of the total BNFL site.
In connection with current i
decommissioning, BNFL has large amounts of uranium-contaminated aluminum which is is easily cleaned and recycled for unrestricted use.
A limit equivalent to 10 pCi/gm is used for this purpose.
The NRC team asked if Urenco could provide a listing of the national release or discharge limits that are applicable in the Troika countries.
Urenco agreed to compile them and send them at a later date.
SAFEGUARDS On June 5 at Almelo, the briefings covered primarily plant operations, plant j
safety and environmental considerations, and current regulations.
Several parts of the Almelo complex were visited, including the original buildings now l
decommissioned, the laboratory areas, and the operating cascade halls. On the following day, June 6, discussions focused on IAEA/ EURATOM safeguards implementation and inspections.
Site personnel demonstrated a typical IAEA inspection visit, including the photo-matching of valves and piping in the cascade hall.
On June 7, the NRC team visited the Gronau complex for discussions concerning plant operations, safeguards, and centrifuge design and manufacture.
The afternoon tour was highlighted by demonstrations of machine assembly techniques and quality control testing.
On June 8, the team visited the Capenhurst complex for final talks on plant operations and safeguards, as implemented in the U.K.
Urenco personnel were open and frank, answering all questions asked.
Access was provided to the sensitive areas in both the production halls and manufacturing plants.
There seemed to be a sincere desire on the part of Urenco personnel to satisfy the team's information needs. -Many of the details i
of centrifuge design, fabrication, installation, and operation are considered to be classified by the Urenco companies and the tripartite governments.
All three plants have been placed under IAEA/ EURATOM safeguards, there being no national safeguards programs in the three countries.
Joint team inspections are conducted monthly, with an additional 6-8 Limited Frequency Unannounced Access inspections per year.
Notification is provided to IAEA four days in advance of all product shipments.
An annual physical inventory (off-line) is conducted at each plant and the inventory differences (MUF) are provided to IAEA and EURATOM.
Historically, the MUFs have averaged about 0.1 percent of feed the first year of operation (plate out losses) and about 0.01 percent thereafter.
Allowable limits are 0.2 percent.
The installed material control and accounting systems include all normal functions such as sampling,
-measurements and assays, bookkeeping, item tracking, use of seals, etc.
i 6-o l
a l
1 The safeguards findings and conclusions resulting from the visits include:
t The Urtnco and foreign government personnel were very responsive to l
l the NRC team's inquiries.
Briefings were well prepared, l
comprehensive, and complete.
Plant tours included access to areas l
normally embargoed to all but certain Urenco personnel.
The objectives of the trip were completely satisfied, and the l
information gathered will significantly aid in preparation for review of an application for licenses by LES.
l t
The safeguards systems in use at the Urenco plants would provide a t
good start toward satisfying NRC requirements.
Additional measures l
will be required to protect against and detect any unauthorized i
enrichments.
SECURITY AND CLASSIFICATION From June 5-8, 1990, Raymond Brady, the NRC Director of Security (0/SEC) and William Shepard of DOE's Office of Classification and Technology Policy, were members of the NRC team that visited Urenco's three gas centrifuge uranium enrichment plants in Europe.
The following unclassified narrative reflects the results of D/SEC's discussions and observations.
Since some subject areas were discussed at all three plants, they will be discussed only once for sake i
of brevity where discussions were essentially the same.
The classified visits and discussions were extremely valuable since 0/SEC is responsible for the overall NRC security-classification program at LES.
Almelo Plant l
l~
After a general site orientation session conducted by senior officials of I-Ulta-Centrifuge Nederland (UCN), the shareholder, and Urenco Nederland, the production enterprise, the NRC team visited specific areas of the plant, including the separation buildings (e.g., cascade halls, and central control room), office areas, and related support areas.
The security classification implications of each were discussed while at the plant.
The team also received a short orientation on the plant's security and classification program (except that applicable to the centrifuge assembly area, which was subsequently covered during the Gronau plant visit).
Almelo's program is based on a classified " Tripartite Handbook of Security and Classification Procedures," dated 1985, and a related " Centrifuge Classification Guide," dated 1987.
l D/SEC had detailed discussions on June 5 and 6, 1990, with Roelof Gerritsen,-
Head of Security and General Affairs for Urenco Nederland, and Erich Kraska, l-Senior Technical Manager (formerly associated with the Gronau plant) of l
Urenco, Inc.
Discussions centered on security-classification topics l-applicable to the Almelo plant and their possible implications to the LES E
plant.
The Almelo plant's_ security program consists of physical barriers (e.g.,
fences and watchmen), intrusion detection equipment (e.g., CCTV), personnel i
l l
7 security clearances, classified document and material control procedures, and visitor controls.
During discussions, Messrs. Gerritsen and Kraska indicated that tne classification guide was prepared and approved in 1987 to cover all information concerning gas cent-ifuge development and application.
There has been no subsequent change notic e or interpretative documents.
Based upon an initial review of the guide items (topics), it was obvious that some of the items concerned research and development work (e.g. Item 3.10) which were not relevant to LES activities.
Subsequent discussions with Mr. David Aston, who is Chairman of the Security and Classification Working Group as well as the Urenco Ltd. Company Secretary, confirmed this fact.
He agreed to provide us with (1) an annotated version of the guide which will focus on LES activities, and (2) a component drawing of the TC-12 machine which will be installed at LES' Claiborne Enrichment Center.
This annotated guide and component drawing will be very helpful since NRC/00E needs to provide LES, e.g., Fluor Daniel, current / applicable classification guidance.
No terms, phrases, words or components, per se, are classified because of their association with the l
Tripartite gas centrifuge program.
Currently, throughputs and inventory differences (10) at the Urenco plants are unclassified.
In fact, the guide doesn't really address insterial control and accounting (MC&A), and the MC&A l
plan for the LES plant may need to be classified.
Also, an inventory i
difference in any amount may need to be classified and then declassified after l
a period of six months from date of inventory assessment, providing (a) any resulting investigation is completed and (b) the initial classification I
determination was not due to extenuating circumstances.
10 data would remain classified for the duration of an investigation.
Mr. Aston said that Urenco Ltd. has filed / searched U.S. pattnt records, and he did not foresee any cla:sified LES patent applications.
During a general discussion of Almelo's safety and environmental systems, including autoclaves, waste treatment facilities, and air handling systems, i
UCN said that none, per se, had any classification implications.
LES I
personnel should, however, carefully' review any safety analysis reports to assure that no classified information is inadvertantly included when describing plant or centrifuge operational characteristics, since some information is classified.
The Tripartite classification guide contains a number of items which are classified RESTRICTED, which is the lowest of four classification levels used by the Tripartite Governments to protect classified information.
The U.S. ha, i
agreed to protect RESTRICTED information as CONFIDENTIAL, which is the lowest classification level used by the U.S. Government to protect classified t
information.
Urenco personnel were informed of this fact and advised that any classified information transferred to LES, as previously agreed upon by the respective governments, will be protected as classified, consistent with 10 CFR Parts 25 and 95.
Also, another area that needs further discussion is the marking of Urenco documents - the U.S. portion marks documents, while the Tripartite Governments do not.
While at Almelo, the team also saw how Urenco destroyed classified centrifuges which had crashed or became technologically obsolete.
Since a complete centrifuge is classified Secret (external visual access to a complete
8-centrifuge and assembled units are not classified), it must be destroyed by 1
pulverizing, shredding, etc. to preclude access to classified information.
Gronau Plant Senior personnel of Uranit GmbH, the shareholder, and Urenco Deutschland, the i
production enterprise, gave the NRC team a short briefing on the plant's security-classification program and a comprehensive briefing / tour of the classified centrifuge assembly area (CAA).
Gronau's security classification program is also based on the aforementioned Tripartite security and classification procedures.
The plant's security measures includes armed guards, dogs, double fences, badges, clearances, and security containers.
0/SEC had specific discussions on June 7, 1990 with Ernst Steinebach, Manager of Security and Safeguards for Urenco Deutschland, Franz Fischer, Uranit Assembly Plant Manager and other personnel involved with CAA activities.
Urenco considers the following centrifuge design expertise and manufacturing know-how to be extremely sensitive and important:
Design Expertise Manufacturing-Know-How Metallurgy Machining Composite Technology Flowturning Mechanics Welding Tribology Bonding Gasdynamics Assembling Electric Driwe Composite Manufacturing Vacuum Technology Quality Control Classified centrifuge components and related classified support equipment are manuf actured at cleared government, plant, or contractor sites.
The centrifuge assembly process consists of removing the classified components /sub-assemblies from an adjacent storage area and assembling them through a series of manual and automated steps emphasizing quality control.
Automated functions include a CAA self-contained, x-ray system which inoicates classified information (e.g. diameter of a centrifuge) and a DEC VAX computer system with remote terminals containing product inventory data which also processes classified information.
Classified documents (e.g., engineering specifications) are handled by CAA personnel.
No classified radiographs are taken.
Once the centrifuges are assembled and tested, they are moved into a cascade hall on small transports (carts), bolted to the floor, connected to plant systems, and brought on-line.
The cascade hall contains a number of centrifuge cascades which operate in series and parallel to enrich uranium.
Within the cascade hall are cabinets housing the controls for the cascades and the electrical supply required to drive the motort of the centrifuges. While on the plant tour, the team sau a classified cutaway model of a centrifuge which showed its components /subassem911es.
LES said it plans no such model at its plant.
Information on cascade performance and operating characteristics is classified.
Thus, each cascade hall contain numerous automated information systems (i.e,, process control and data acquisition systems) handling classified data which are displayed / monitored in a control room which is
-9o manned around the clock.
Computer programs are used to supervise plant functions, and both the programs and the related data (e.g., centrifuge frequency) are classified.
No matter (e.g., printouts or centrifuge components) was seen to be marked with its assigned classification level.
Centrifuge plants can be expanded on a modular basis, and therefore it is possible to add capacity to 3 plant consistent with market demand.
In each plant visited, we s w Urenco expanding its enrichment capacity through either contruction of new u :Jes or installation of more effective / efficient machines.
In fact.
ike Gronau plant there were additional guards on duty to escort construction workers, since classified work was being performed in an adjacent area.
Large movable physical barriers in the cascade halls were used to preclude visual access to classified matter.
Urenco Ltd. has advised the U.S. Government (e.g., NRC/ DOE) of the need to receive LES plant operating data in order to review warranty claims and to provide technical assistance for the safe and efficient operation of the LES plant.
Broadly speaking, three categories of information need to be made available to Urenco, viz: information on plant operations, information to satisfy warranties, and information from centrifuge autopsies.
The reverse flow of information is a controversial and major topic of discussion between the U.S. and Tripartite Governments because of its Atomic Energy Act Restricted Data implications, as well as its Urenco-LES Juint Venture implications.
00E is currently assessing the legal implications of such a transfer of operating data and will be advising interested parties of its decision.
Capenburst Plant Senior personnel of British Nuclear Fuels Limited (BNFL), the shareholder and Urence (UK), the production enterprise, gave the team a general site orientation briefing and tour.
The plant's security-classification program is also based on the previously mentioned Tripartite security and classification procedures.
Capenhurst's security program included watchmen, fences, badges, clearances, security containers, visitor control, and prohibition of articles (e.g., camera and sound recording equipment).
0/SEC had specific discussions on June B, 1990 with BNFL's Colin Scane, Plant Manager, and Mike Olney-Smith, Security Of ficer, as well as with Chris Price.
United Kingdom Atomic Energy Authority Security Branch representative.
The team visited certain areas of the plant, including the cascade halls, where several generations of machines, ranging from LECs, 3LCs to TC-11s were in use, and their safeguards / security features were discussed.
At each plant, the security-classification aspects of IAEA and EURATOM safeguards system visits and inspections were discussed.
Based on these discussions, it was determined that each plant has:
1.
Established procedures to handle IAEA/ EURATOM visits and inspections, which include procedures to protect commercially sensitive information and classified information.
e
- 0 2.
Negotiated its own Facility Attachment (FA) which contains, for example, a short description of the facility, accounting measures for the facility, provisions for surveillance measures, and a detailed description of the mode and scope of IAEA routine inspections.
This FA is considered extremely sensitive and is protected accordingly by the plants and their respective governments.
Based on the discussions, Vrenco Ltd. agreed to clarify IAEA/ EURATOM access to commercially sensitive / classified information, especially that contained in IAEA/ EURATOM notebooks (e.g., photographs).
This is of interest, since 10 CFR Part 95 covers access by IAEA representatives to classified information.
The team also discussed the plant's classified document control program (e.g.,
marking and handling of classified documents) with regard to Control Room activities and to office procedures.
The plant manager's secretary discussed BNFL's program which included per'. anal computers, document registers, security containers, and the preparation of monthly plant performance progress reports.
[
i l
From a security-classificatfor perspective, Capenhurst plant personnel are very concerned about protecting the pipe arrays and the height of centrifuges in the cascade halls.
Another major area of concern is uncleared construction / maintenance workers and visitors.
Uncleared visitors are only taken on preplanned, unclassified routes to minimize their amount of time in the plant for security reasons.
Plant personnel said that security, safeguards, safety, installation, and production people must work closely during the design, installation, and production stages to help assure respective concerns are addressed, and to minimize future problem areas.
LES Plant LES' CEC in Homer, Louisiana will consist of separation halls; a centrifuge assembly building; office buildings; guard house; feed, product, and tails storage areas; and related support facilities.
l Based upon discussions during the trip with various personnel, especially Messrs. LeRoy, Kraska and Kratzer, some preliminary comments / perspectives can L
be made regarding the proposed low enriched uranium enrichment plant.
l LES has already done some initial building / process drawings which have not been submitted to NRC for review / comment.
LES should plan to receive 5 sea / land containers of the 36-foot type every three weeks for three years by NL, FRG or UK ships under_the control of foreign government' cleared personnel.
For security reasons, no I
containers / shipments will have parts for an entire centrifuge machine.
LES needs to prepare and submit for NRC approval a Transportation / Facility Security Plan for these classified shipments, which includes where they will I-be off-loaded from the ship and subsequently stored before actually assembled.
SEC is currently discussing with U.S. Customs personnel the security-classification implications of these shipments.
The actual assembly work is expected to start in January 1995 by European / United States personnel in LES' Centrifuge Assembly Building (CAB),
which is one of the most highly sensitive / classified areas of the plant.
I T
.s t Urenco Ltd. will retain ownership of the assembled centrifuges until they are actually bolted to the floor in the cascade halls for warranty and other reasons.
The 60 person assembly shop team will initially be comprised of 20 European and 40 U.S. personnel, all of whom will be at least "L" type cleared by their respective governments.
Based on the sensitivity of these assembly activities, according to Gronau plant personnel, LES should determine whether or not the U.5. personnel should be "0" rather than "L" cleared.
Foreign nationals will be permanently assigned to the CAB area for three to four years.
Over time, fewer Europeans and more Americans will be in this area as the Americans acquire the necessary skill / experience, f.Gording to Mr. LeRoy, all permanent LES piant personnel (about 200) will be at least "L" cleared.
LES also needs to consider clearances for their joint venture partners, such as senior Louisiana Power and Light Company personnel, in addition, it is estimated that SEC will have to process about twenty LES related foreign security assurances a year for personnel (e.g., visitors).
LES will receive classified assembly books / manuals / procedures from Urenco Ltd.
Gronau plant personnel also thought they would need, on occasion, access to some engineering / manufacturing specifications.
LES, tfrough NRC, has already received a classified Urenco design package which was addressed to Urenco, Inc., Fluor Daniel and Duke Engineering and Services personnel, some of whom were not NRC cleared.
SEC marked the package consistent with U.S. security classification requirements.
LES and NRC recognize the need to have current classification guidance for this project and to handle classified matter consistent with 10 CFR Part 95.
SEC is focusing on certain information security issues as noted in this report.
LES will probably need several security containers to store classified documents and to establish security areas to store classified parts.
LES said it will establish and implement a security program consistent with 10 CFR Parts 25.and 95 NRC security policies and procedures to protect classified matter (i.e., documents, information and material).
Thus it will implement various physical security measures (e.g., use personnel identification badges, watchmen and security containers), information security measures (e.g., mark classified documents), personnel security measures (e.g., use clearance and visitor control procedures), and automated information system security measures.
LES did not foresee any need for communication security measures (e.g., a secure telephone system) between the various partners in the U.S. or in Europe.
LES_will need to establish NRC exclusion and limited security areas at its plant.
Exclusion areas (where mere access to the area will result in accets to classified matter) will include the centrifuge assembly / storage areas and the cascade halls, including the control room.
These areas will contain classified information (such as centrifuges, pipework and gauges).
Limited areas (a security area where watchmen or other internal control can prevent access by unauthorized persons to classified matter) will include the office building and the auxiliary areas containing support services, such as health physics functions.
Classified matter in limited area will include monthly reports and computer _ media.
Based on this visit and related discussions, LES needs to:
u
- 12
- 1.
Submit preliminary plant architect / engineering /contruction/ pro:ess drawings to NRC safety, safeguards and security personnel to assure adequate consideration of their respective areas of concern.
2.
Decide whether or not U.S. personnel in the centrifuge assembly area will need NRC "Q" clearances because they will have access to either sensitive / classified (1) engineering or renufacturing specifications or (2) complete centrifuge machines / components and sub-assemblies.
3.
Receive and comply with updated specific centrifuge classification guidance, since the 1987 Centrifuge Classification Guide is not focused on TC-12 machines nor LES activities.
(The Chairman of the Security and Classification Working Group has agreed to furnish NRC/00E such guidance.)
4.
Establish positive procedures to assure that LES (including Fluor Daniel) generated matter is reviewed and marked by an authorized classifier.
5.
Receive guidance from the U.S. Government (based on DOE input) on the transfer of U.S.-origin operating information from LES to Urenco Ltd.,
concerning information on plant operations, information to satisfy warranties, and information from centrifuge autopsies.
(00E is preparing a legal opinion on the reverse flow of information from U.S. to Europe).
6.
Receive clarification on the portion marking of foreign government information.
7.
Submit a security plan and otherwise meet the requirements of 10 CFR Part 25 and 95 to protect classified documents, information, and material.
This will involve, for example, using security containers to store. classified documents; establishing security areas to protect classified centrifuge machines / components /sub-assemblies in use and storage; providing adequate security for centrifuges during shipment; using protective personnel; and processing classified data /information on 1
automated information systems in office, assembly and opePational areas.
8.
Inform NRC on the security classification implications s _IAEA visits / inspection especially what types / levels of inforaetion they may have access to at LES.
Conclusions The visits and related discussions at the three Urenco enrichment plants were very informative from a security-classification perspective since 0/SEC developed a deeper appreciation and understanding of the plants' overall security programs, discussed matters of mutual interest with plant and Triparitite Government. personnel, and identified some areas of future concern.
At the conclusion of the Capenhurst plant visit, the NRC team telephoned GPA/IP to advise that the results of the trip had been eminently successful in every way, and that this information should be conveyed to Carlton Stoiber at the Department of State.
Mr. Stoiber was en route to Vienna to participate in the initial discussions on the Phase III Agreement for transfer of classified information from the tripartite governments to the United States, and he wished to know the outcome of the NRC team visits prior to the discussions.
a
. i LIST OF PERSONNEL CONTACTED Almelo Hubert Rakhorst UCN Commercial Manager Norbert Hootsmans UCN Managing Director Claus Joseph UCN Safeguards Consultant Ben Oekker Urenco Security and Safeguards Manager Pieter Verbeek Netherlands Ministry of Foreign Af fairs Gronau Gustav Meyer-Kretchmer Head, Urenco Plants Division Ernst Steinebach Urenco Security and Safeguards Manager Jochim Pokar Uranit Licensing Manager Franz Fischer Uranit Assembly Plant Manager Martin Fleischer FRG Ministry of Foreign Affairs Hans Ren.c;an BMFT Safeguards Office Capenburst Colin Scane Urenco Plant Manager Peter Friend Urenco Safeguards Officer Timothy Moore BNFL Chief Design Engineer Robert Foulkes BNFL Safeguards Officer David Sedgwick BNFL Health Physics Manager 51chael Olney-Smith BNFL Site Classification Officer Peter Agrell UK Department of Energy - International Safeguards Graham Andrew UK Department of Energy Safeguards Office Christopher Price UKAEA Security Branch t
9 l
3 CITIZENS AGAINST NUCLEAR TRASH C/O P. O. COX 195 HOMER, LOUISIANA 71040 318/927-6942 October 1, 1990 I
Mr. Charles J.
Haughney, Chief Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards U.
r Nuclear Regulatory Commission Washington, D. C.
20555 RE:
Project No. M45
Dear Mr. Haughney:
Thank you for your letter dated September 26, 1990.
In this
- letter, you asked that we notify you of our other concerns.
Please be advised that we have many other concerns, but for the time being, we are limiting our questions to just those you have listed in this letter.
We would like to have a very thorough understanding of your review process and just what goes into a review.
Please remember that we asked for a " thor-ough and complete" investigation and not just a review.
So thot-we might understand this process, please answer the following questions.
What forma ; does a review follow:
A)
Is it an adjudicatory type hearing?
B)
Is it a simple review by NRC Staff members only?
C)
Is it a meeting between NRC personnel, LES personnel, and intervonors making the allegations?
D)
May we attend the review meetings and present our information and comment or give testimony?
Describe the investigation efforts that will be made by the NRC to-determine the validity of the allegations made.
A)
Will you call, write, or conduct investigations with the appropriato European government officials with regulatory authority over Urenco companies?
B)
Will you interview, under oath, Urenco officials and question them thoroughly as to the allegations?
C)
Will you question Peter Jelinek personally and if necessary I
have.a hearing where re can be placed under oath and j
questioned?
D)
What are our legal rights, as interveners, to participate in any and all reviews end investigations?
wwmvo{h os N'i PDC
a Considering the number and complexity of the allegations already listed and the fact that Urenco is a foreign entity doing business in three (3) toreign countrier how long and how many NRC employees do you expect it to take t'. do a thorough investi-gation? Please keep in mind that the allegations which we sent to you came from major news sources all over the world.
CNN News recently ran a
news clip in which they stated that Iraq was in possession of gas centrifuges. These are serious allegations and we expect you to make a concerted effort to determine that there have been no violations by any of the L.E.S.
consortium members their personnel. We are especially concerned by two incidents or that seem to indicate that the NRC is in fact rushing L.E.S.'s application through in great haste. In the 1990 first quarter issue of " Nuclear Industry" Mr. Rick Priory senior vice president of Duke Power is quoted as saying the following:
" Priory adds that the NRC has been "very cooperative" and has given LES reason to believe its proposed plant will receive expeditious review.
"Over the past year we've had numerous meetings with the NRC," he notes.
"We think we've seen eye to eye with them on a set of licensing requirements.
We're favorably," he says." pleased the NRC has responded so And in yet another incident of apparent biased pro-approval tendencies, Mr.
Bill Spell, of the Louisiana Energy Division of
- DEQ, faxed Mr.
Charles Hackney of the NRC-Region IV Office, a copy of an anti-LES editorial from the local Guardian Journal Paper in which he states:
"We Need Help!
This thing is getting like that 25 cent piece of steak - the more you chew it, the bigger it
.gets!"
Why is Mr.
Bill Spell asking Mr. Hackney of the NRC for help?
Is it not the NRC's responsibility to maintain a totally
" arms length" objective stance that is devoid of even the hint of a
conflict-of interest?
Remarks such as the above appear to clearly indicate an aggressive pro-approval LES stance by your agency.
Such tendencies can totally destroy public confidence in your agency and in the licensing process of such dangerous facilities.
We will be closely monitoring your investigations of these allegations to assure that they are not
" SWEPT UNDER THE RUG".
I have attached copies of those comments for your convenience.
i
f'..
h.
Please get this information back to us as quickly as poss-it'e, as we are also sending information to several other Federal 4:
Ager.'ies and Congressional Committees that are interested in these allegations.
We certainly want to get this information t
where it will do the most good as_quickly as possible.
Sincerely, s
b' Toney Johnson TJ/ebg Enclosure i
Michael McDaniels, DEQ-Baton Rouge, LA
[
cc Honorable. George Miller Rick Priory i
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mayor of Ilomer, la., (pop. 4600), the county seit at:d Claiborne Parish's largest town. *lt's succeed in today's convoluted, cut-throat going to raise the standard of living for all our enrichment market, one must look beneath geople. Our mWor concern was that they the surface and examine the complexities of were going to locate in another parish."Ihe the business as it exists today. With sales of plant's construction is expected to employ approximately $1.5 billion annually, the DOE thout 400 workers at peak. Once operational, remains the world's leading supplier of it will employ about 200 workers, the majority enrichment services. Ilut its share of the of whom IIS promises to hire and train local-worldwide market has dropped to 46 percent i
I ly. Another 60N100 jobs will be created indi-today and its share of the domestic rectly.
market-currently around 110 percent --could Travis Tinsley, chairman of the contact plummet precipitously in the mid 1990s.
committee for the Claiborne Parish Industrial Today, DGE says,it runs the risk of a whole.
Development Foundation, says the project sale defection of its domestic customers to will
- add tremendously" to the local economy overseas competitors.
and provide the community with high caliber, it wasn't that way 15 years ago. Then, the well paying jobs. "We've been exporting the DOE supplied virtually all of the free world's
! better products of our schools from this uranium enrichment needs. But the Atomic
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parish for the last 35 to 40 years. This allows Energy Commission, DOE's predecessor us to keep some of them home," he says.
t.gency, lost the monopoly on enrichment the And Tom Crocker, mayor of Haynesville U.S. had held ever since the wartime (pop. 3400), Claiborne Parish's other mWor Manhattan Project a half century ago. When town, explains,"We're an old-time 1920+ type the AEC discovered in the early 1970s that its oil boom parish...We're 99.99 percent in favor enrichment capacity was fully booked,it sim-of this.*
ply stopped writing new orders.1he result?
To understand why IIS is cominced it can in a classic example of a free market at work,
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