ML20092A589

Georgians Against Nuclear Energy Comments on Security at Georgia Tech Reactor Facility Following Georgia Tech Decision to Remove Reactor Fuel Before 1996 Olympic Games.W/ Certificate of Svc

ML20092A589
Person / Time
Site:	Neely Research Reactor
Issue date:	08/31/1995
From:	Carroll G GEORGIANS AGAINST NUCLEAR ENERGY
To:	Neely Research Reactor, ATLANTA, GA
References
CON-#395-17079 95-704-01-REN, 95-704-1-REN, REN, NUDOCS 9509110099
Download: ML20092A589 (19)

Text

,

/ 70 79 00CKETED UNITED STATES OF AMERICA USHRC NUCLEAR REGULATORY COMMISSION 35 SB' -5 A11 :18 ATOMIC SAFETY AND LICENSING BOARD OFFICE OF SECRETAFn(

Before Administrative Judges: ERVICE DOCKETl! { g Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren l GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 GEORGIANS AGAINST NUCLEAR ENERGY (GANE) COMMENTS ON SECURITY AT THE GEORGIA TECH REACTOR FACILITY FOLLOWING GEORGIA TECH'S DECISION '

TO REMOVE THE REACTOR FUEL BEFORE THE 1996 OLYMPIC GAMES GANE respectfully submits the following comments on security of the Georgia Tech reactor facility during the 1996 Olympic Games scheduled to be held in downtown Atlanta in July 1996. The Atomic Safety &

Licensing Board hearing these issues has requested the parties' comments on whether GANE's contention that security is inadequate for the facility during the Games is moot following Georgia Tech's announcement that it will remove all high-enriched uranium fuel prior to the Olympic Games (during February and March 1996). I While GANE is impressed and pleased with Georgia Tech's decision which indeed improves security on the Georgia Tech campus which will house the Olympic Village for 15,000 of the world's athletes during .

the Games - we have contended and continue to contend that all of the radioactive materials at the Neely Nuclear Research Facility pose a security risk. Georgia Tech has also decided to remove another source with which GANE was highly concerned - a 6,000-curie cesium-137 source will be removed from the Cherry Emerson Building near the Neely 9509110099 950831 PDR ADOCK 05000160 PDR

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Nuclear Research Facility before the 1996 Olympics. GANE cannot find our contention that security at the Neely Nuclear Research Facility is inadequate to be moot as long as Georgia Tech plans to retain the

250,000 curies of cobalt-60 on the site.

Attached are materials which will help the parties understand the seriousness of the situation with the cobalt-60. GANE reiterates that cobalt-60 is a highly active gamma emitting source with serious I

consequences to organic life that suffers exposure. Hazardous amounts 1

of cobalt-60 are described in TRILLIONTHS of a curie. It is obvious that 250,000 curies is an awesome amount of radiation which can wreak

much harm if unshielded or spread around in the environment.

GANE asks you to pay particular note to the location of the cobalt-60 within the Neely Nuclear Research Center. The cobalt-60 shielding pool is located'by the outside wall of the facility which faces Atlantic Drive, directly across from where 8th Street terminates on Atlantic. The outside wall is an ordinary brick wall, approximately I four inches thick. Inside the facility, the hot cell which at any l given moment may house any or all of the cobalt-60 (which may also be left in the hot cell overnight and'over the weekends) is located on 3

the other side of a window of the waiting room wall. Apparently realizing that the hot cell was vulnerable, Georgia Tech later added a

" wall" which is concrete blocks stacked without mortar on the other side of the window.

One terrorism scenario of which GANE has been advised is that there may be no alarms or security cameras for the roof over the hot cell and cobalt-60 shielding pool. A " smart guy" could enter the building through the roof undetected. GANE is concerned that the " smart guy" ,

who is too smart to steal the material which would kill him quickly, would drop an explosive with a timer into the area and clear out well before the explosion which would create much harm for residents of the campus, Olympic Village, Atlanta, not too mention, the environment and real estate which would be ruined. GANE is more concerned with harm to the environment and the public health than by the bad press that Georgia Tech, Atlanta, the NRC, the FBI, the State of Georgia, et al.

would receive for allowing such a preventable catastrophe to occur, but global bad press la another likely outcome of radiological sabotage during the Games.

Another scenario that has been described to GANE is of a runaway vehicle rolling down 8th Street, a steep hill that runs down into the low-lying area.where the Neely Nuclear Research Center is situated, crashing through the outside wall of the Neely Nuclear Research Center

and landing in the shielding pool, causing a release of cobalt-60 into the surrounding environment. GANE has heard speculated scenarios of a casually dropped book bag full of explosives and a baby buggy packed with a fertilizer-type explosive such as was used in the Oklahoma City bon 61ng. When you see the damage that a small truckload of explosive did to the large Federal office building in Oklahoma City, it's not too hard to picture a small explosion being able to breach the brick wall of a single-story building and widely dispersing the cobalt-60 on the other side of that wall a great distance.

GANE has also enclosed for your use in studying the severity of the situation at Georgia Tech, a report from The International Task Force on Prevention of Nuclear Terrorism which was published in the Bulletin of Atomic Scientists in 1986. This thoughtful report carries increased significance in the times fol.1.owing the World Trade Center bombing, Oklahoma City bombing and with the Unabomber still at large and holding the world's airports hostage. The study underscores the widely accepted theory that pyschological terror is the main motive behind terrorist acts, not necessarily a body count. The idea of psychological terror as a primary motive for terrorists is also supported by a publication on terrorism Beating International Terrorism by Stephen Sloan (Maxwell Air Force Base, Alabama) which begins its introduction, "The modern age of terrorism was ushered in by the massacre of 11 Israeli athletes at the Olympic Games in Munich in 1972." The first subhead under chapter 1 is Terrorism as a Psychological Weapon. This section begins: "Since terrorism is

' directed toward the creation of a general climate of fear,' it must be stressed that terrorism is first a psychological weapon, for those who use it play on the most elemental fears. As one definition cogently notes, ' Terror is a natural phenomenon, terrorism is the conscious exploitation of it.'"

GANE believes that the cobalt-60 which is licensed by the State of Georgia as an agreement state should be placed immediately under temporary NRC jurisdiction based on the following passage from the Atomic Energy Act:

ATOMIC ENERGY ACT, Chapter 23, 42 S2021 (j) Reserve power to terminate or suspend agreements; emergency situations; State nonaction on causes of danger; authority exercisable only during emergency and commensurate with danger (1) The Commission, upon its own initiative after reasonable notice and opportunity for hearing to the 1

State with which an agreemnt under subsection (b) of this section has become effective . . . finds that (1) such l termination or suspension is required to protect the

public health and safety . . .

(2) The Commission, upon its own motion or upon request of the Governor of any State, may, after notifying the Governor, temporarily suspend all or part of its agreement with the State without notice or hearing if, in the judgment of the Commission:

(A) an emergency situation exists with respect to any materials covered by such an agreement creating danger which requirea immediate action to protect the health or safety of persons either within or outside l l

the State, and (B) the State has failed to take steps necessary to contain or eliminate the cause of the danger within a l reasonable time after the situation arose.

A temporary suspension under this paragraph shall remain in effect only for such time as the emergency situation exists and shall authorize the Commisson to exercise its authority only to the extent necessary to contain or eliminate the danger.

GANE interprets this passage of the Atomic Energy Act to give the NRC authority when it deems necessary to regulate a special situation which is not being appropriately regulated.

Much like the passage from Title 10 -

(f) In addition to the fixed-site requirements set forth in this section and in S73.67, the Commission may require, depending on the individual facility and site conditions, any alternate or additional measures deemed necessary to protect against radiological sabotage at nonpower reactors licensed to operate at or above a power level of 2 megawatts thermal GANE believes that the situation with the 1996 Olympics and the history of terrorism during the Games, the recent outbreak of terrorism and the possible especial attraction of terrorists to radiological sabotage, is that special situation for which both Title i

! 10-and the Atomic Energy Act allow the NRC special authority.

Georgia Tech uses features of the Neely Nuclear Research Center in its operation of the reactor, notably, the cobalt-60 pool is used in i the fuel removal process. It may be useful to divide responsibilities and authorities to some extent, but blind adherence to artificial separations may lead to dangerous oversights and gaps in authority.

GANE notes that the Commission, during its consideration of Georgia Tech's and the NRC Staff's appeal of the Board decision to admit GANE's security contention, requested an inventory of nuclear materials from Georgia Tech. It was following this request for information from the Commission that Georgia Tech announced it would remove all reactor fuel prior to the Olympics. GANE notes that no inventory of nuclear materials has yet been submitted to the Commission or the Atomic Safety & Licensing Board by Georgia Tech.

GANE considers the Commission's interest in a complete inventory healthy given the great risk posed by large inventories of radioactive materials in a large population center on the threshold of hosting an event of global significance.

The reactor is not the only feature of Georgia Tech's nuclear program which poses a security threat. And the actual Olympics is not the only time when the threat of radiological sabotage would be heightened. The psychology of terrorism could be in place well before the Games, possibly influencing other nationalities' sense of security and willingness to participate in the Games or to trust the ability and concern of the United States to mako their citizens safe.

Since Georgia Tech has decided to remove the cesium-137 amd the complete assortment of reactor fuels, the only remaining radiological threat with which GANE is concerned is the inventory of cobalt-60. It is the opinion of GANE that the only sure way to protect Atlanta from the cobalt-60 is to remove it from the site altogether. We do not believe that removal of the cobalt-60 will be as elaborate as removal of the reactor fuel, but we expect that it will take some time to arrange for a home for it and that the packaging wiAl require painstaking process, so we beg for a decision immediately, that the removal work may begin. GANE believes that all the cobalt-60 may not fit into a single standard cask. Since Georgia Tech has not fully embraced the entire task before it that will be required to ensure removal of the threat of radiological sabotage from the Olympic Games, coupled with the fact that none of the current personnel at the Georgia Tech nuclear program have experience with the delicate crocess of removing the spent fuel from the reactor, it is imperative that Georgia Tech receive its mandate quickly and begin the real work of

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removing the dangerous materials.

The fuel removal process involves the cobalt-60 pool, so it is wise to consider all the materials to be removed in one coordinated plan.

GANE encourages the Commission to take its authority from the State of Georgia which has been unresponsive to GANE's concerns with the materials it regulates when it is clear that a special security risk ,

exists because of the Olympics. It is apparent that there is concern with security at the State level that existed prior to GANE's awareness of, or public involvement with, the security risk posed by the cobalt-60. It is also apparent following GANEs effort to work with the State of Georgia on resolving this problem, that there are political barriers within the Georgia Radiation Division which may completely disable Georgia from dealing properly with this security threat. Since the threat from terrorism is imminent and increases as the start of the 1996 Olympic Games approaches an emergency situation now exists with the cobalt-60 and the NRC should step into its authority immediately.

GANE has appreciated the democratic process which has facilitated our bringing these important issues before the authorities in a position to take action. We fervently hope that we can stick to the important issue of protecting the pub]'c health from an unsafe situation such as the cobalt-60 poses by its location in downtown Atlanta. We all must do our part to make the world better for our having lived, and it is within our reach to protect the public from needless harm, while providing the nuclear students and staff at Georgia Tech with a wonderful education in the nuclear industry's most pressing need - the need to properly containerize, and sometimes to transport, extremely hazardous materials. We look forward to the day l when GANE, Georgia Tech and the NRC all shake hands and say, mutually, I l

" Good work, ya'll!" <

Sincerely, enn Carroll Representative for GANE Dated and signed August 31. 1995 in Decatur, Georgia

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NEELY NUCLEAR RESEARCil CENTER AT GEORGIA TECll 900 ATLANTIC ORIVE RADI0 ACTIVE INVENTORY (APPR0XIMATE)

COBALT 60 approx. 250,000 curies

-- 75-80 sources. Some are in wafers, the size of a nickle, stacked in a tube about 12" long. Some are flat (like bacon), approx 10" X 18"

-- All are " doubly encapsulated." The cobalt arrived from the Savannah River Project encapsulated in aluminum. At Georgia Tech they were then welded over with stainless steel. Ilowever, welds were never checked or certified by the American Standard Institute. Strong possibility they could rupture.

-- Stored in open pool, approx. 20' deep X 30' long X 6-8' long. Pool is a few feet away from outside wall of building (concrete block with brick facade),

approx. 40' from Atlantic Drive.

-- If sources were ruptured, very hot particulate matter would give off deadly radiation. Non-soluable particles would lodge in body.

-- Cobalt sources are used in adjacent " hot cells." i

-- Cobalt in pool and in hot cells are extremely vulnerable to terrorism.

-- Cobalt is regulated by the state DNR, Environmental Protection Division.

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Report on nuclear terrorism The International Task Force on Prevention of Nuclear Ter- variant of nuclear proliferation and non-nuclear terrorism.

ransm, thefirst independent group to deal exclusively with While the probability af nuclear terrorism remains low. the the question of nuclear terrorism, was formed in 1985 by consequences for urban and industrial societits could be ,

the Nuclear Controllnstitute, a Washington-based organi- catastrophic. An explosion would breach the critical post-zation concerned with nuclearprohferation problems. The war moratorium on use of nuclear weapons;in a worst-case Task Force and the earlier conference out of which it grew situation it conceivably could spark an inadvertent nuclear were cosponsored by the Institute for Studies in Interna- exchange between the superpours. Thus, the potential for tional Terrorism of the State University of New York. nuclear terrorism poses an exceptional global danger. .

While the Task Force " recognizes there is an element of in the judgment of the Task Force the probability of nu-risk in drawing public attention to the possible means of clear terrorism is increasing. This is due to a confluence nuclear terrorism,"it " considers thefar greater risk to be of factors:

in leaving basic concerns unspoken and needed improve-

• the growing incidence, sophistication, and lethality of ments undone." The report of the Task Force is a consensus conventional forms of terrorism, often to increase shock l document in which all members do not necessarily agree value; -

on every point and all wordings, but in each case a substan-

• apparent evidence of state support, even sponsorship, tial majority of the members do agree. of terrorist groups;

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Thefollowing are two introductory sections of the Task

• the storing and deploying of nuclear weapons in areas / '

Force's report, a sumr.:ary ofits recommendations, and a of intense terrorist activity;

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list ofits members. ' report and some 26 background

• an increasing number of potential targets in civil nu-papers that were cou. nissionedfor use of the Task Force clear programs-in particular facilities and shipments in -

will be published next year by lexington Books. which plutonium and uranium,in forms suitable for use in weapons, are present; l Defining the threat

• potential black and gray markets in nuclear equipment and materials to i At the beginning of the fifth decade of the nuclear age, three '

While as yet there are no public signs that any terrorists vi<

l overriding imperatives dominate efforts to exploit and con-trol the energy of the atom: bve the essential combination of capability and will to no engage in an act of nuclear violence, the psychological and th.

e prevention of nuclear war between the superpowers; politicalimpact of a successful terrorist nuclear threat might a-

• preventjon of the further spread of nuclear weapons; well be exceptional. A plausible threat or hoax involving te' e prevention of catastrophic nuclear accidents.

a miclear device or sabotage could have enormous coercive i ar Now there is a fourth imperative: prevention of nuclear ter-and disruptive results without mass killing or destruction; le.

rorism-nuclear violence by subnational groups-which indeed, we believe this may be the most likely form of im

, should be seen as having an important bearing on the other nuclear terrorism at this time.

three. The public has given little serious attention to the Given the widespread deployment of tactical nuclear in

, possibility of nuclear terrorism, while policy makers devote weapons, the continuing spread of weapon-usable forms ter considerably more attention and resources to the other three of nuclear materiah, and the availability of know-how ap- int imperatives. Yet, the fact that so far there has been no plicable to assembling fission weapons. the interest of ter-

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serious act of nuclear terrorism is no reason for compla- rorists and, as the case may be, their sponsors in acquiring i kn cency. nuclear weapons should be regarded as technically, politi- >

str Terrorists could "go nuclear" in a variety of ways. The cally, and psychologically plausible. There have been pub- of most important of these are stealing a bomb, stealing nu- lished reports of one terrorist group in Europe having tried tet clear materials suitable for weapons and building a bomb unsuccessfully to obtain information on NATO nuclear- '

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with these materials, sabotaging or holding for ransom a weapons storage facilities, and of another having sought ar* l reactor or other nuclear facility or a shipment of reactor unsuccessfully co enlist the help of a nuclear scientist regard- ter fuel or waste, or by credibly claiming to have acquired a ing nuclear weapons they considered stealing. One national os weapon or nuclear material for building r. bomb or a dis- leader, regarded as being engaged in sponsoring terrorism, i ter persal device. Each of these would constitute a form of nu- is reported to have sought unsuccessfully to buy nuclear clear violence, actual or threatened, against society. weapons while pursuing a nuclear research program that pr Terrorists might be more willing than nations to use could be applied in the long term to making bombs. re acquired nuclear weapons. Deterrence may not work Causing or threatening to cause a serious nuclear accident th against terrorists who go to the lengths of" going nuclear." is another potential avenue of nuclear terrorism that should ui In this sense, nuclear terrorism could be the most dangerous be taken seriously. Indeed, according to data made available is December 1986 38 5

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to the Task Force, some 155 bombings, other attacks, and documents are intended to increase public understanding i 3 '

rists violent demonstrations have taken place at the sites of civil of the risks of and the possible countermeasures agains:

I to nuclear installations, mostly power reactors in Europe and nuclear terrorism without providing sensitive details tha and the United States, over the past 20 years. None has caused could prove useful to would-be perpetrators.

ight a serious accident. Most have been the work of nuclear pro- The Task Force, for example, has determined that build ring testers and disaffected employees rather than terrorists. Yet, ing a crude nuclear device, although more difficult that give i a reactor accident brought about by terrorists, even one re- previously suggested by some experts,is within reach o ion; leasing significant amounts of radioactivity,is by no means terrorists having sufficient resources to recruit u team o: i i of implausible and is technically feasible. three or four technically qualified specialists. The team neet The Task Force recognizes that there is an element of risk not have previous experience in building weapons, bu

. lear in drawing public attention to the possible means of nuclear would need chemical high explosives and a sufficient quan lrms terrorism, but we consider the far greater risk to be in leav- tity of weapon-usable nuclear material, most probably in l ap- ing basic concerns unspoken and needed improvements un- metallic form. A special study prepared for the Task Forcs ter- done. Opportunities for nuclear terrorism are likely to be by a team of former U.S. weapons designers has establishet ring , known to sophisticated terrorist organizations and to their that crude nuclear bomb making, while not as simple a-iliti- >

state sponsors. The public should understand the nature once supposed, can be accomplished with a sufficient quan-pub- of the threat. It will then be in a position to decide on pro- tity of reactor-grade plutonium (the kind separated by in ri d tective steps we believe should be taken promptly and the dustry in some countries from the spent fuel of a powe-le:r. . more difficult institutional improvements and international reactor) or highly enriched uranium (the kind used to fue sght arrangements we believe should be pursued over the long many research reactors)in metallic or possibly even in oxid.

ard- term. The near term improvements are feasible and not form. previously, some analysts of this problem believet ontl overly expensive, at least when viewed in national security that a group gaining entry to a civil nuclear fuel fabricatioi ism, i terms, plant could fashion a crude bomb on site simply by wrap

le:r if governments take additional measures now, they may ping some high explosive around a " coffee can" containe thrt prevent nuclear terrorism before it materializes and will be of a few kilograms of plutonium oxide powder and the-ready to respond in the event it materializes. The role of detonating the contraption to obtain a nuclear yield equi dent the media in providing accurate information and dispelhng valent to hundreds, even thousands, of tons of TNT. Th i ould undue fears during the course of a nuclear terrorist incident study found that such a " coffee-can bomb"is not feasible-lable is espccially crucial. The Task Force report and supporting although the use of oxide in a crude nuclear device is possi Bulletin of the Atomic Scientists 39

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ble in a 5,uberantially larger amount-at least many tens of 1 ar kilograms. This information is essential to devising precau- ch tions, restraints, and controls that are adequate to insure ,! fo e'7 ther teirorists do not acquire significant quantities of weap- 1

, sti on-usable nuclear materials. S -

• te At the same time, the Task Force has concluded that '

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/ ta nuclear terrorism is a threat requiring,in addition to tech- ~" "

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nical strategies, en array of political and legal approaches h ' j

) Pt that should be pursued with due recognition of established .

l international norms. Several approaches explored by the T fo Tas5 Force are intended to reduce the threat or to cope with y 7 of the consequences directly-such as those dealing with phys. -

to ical protection, intelligence, and emergency management. th (1 - , .

Other approaches are deemed by a number of the Task ai Force members to be of more limited utility but nevertheless to useful by addressing the threat indirectly and thereby in-  ! es fluencing the climate conducive to nuclear terrorism. Some 1 J ta of the Task Force members assign essential importance to .d m these other approaches: strengthening international law, '

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addressing underlying causes of terrorism, and puruing th arms control, ,

n. m The Task Force agrees that in order to uphold the interna.

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to tional consensus needed for the fight against nuclear ter.

rorism, nations should adhere rigorously to their own obli-4 },

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u-gations under international law as they rightly condemn ,

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terrorists for their violations of international law.

It is beyond the mandate of the Task Force to explore ghf

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' in depth the causes of terrorism generally, including possi- '

ble nuclear terrorism. We recognize, however, that terronsm iw wy. rm c, y th

> de ofrea thrives in an environment where prevailing political, y

economic, and social conditions create anger and despair exist, and these no doubt help to explain why no terrorists, among social, ethnic, religious, or national populations. operating either independently or with state backing, are These conditions serve as a source of popular support for "

known to have attempted major acts of nuclear violence.

terrorist causes and of fresh recruitment for terrorist groups. C' The disincentives for engaging in such heinous acts are still Obviously, addressing grievances will not affect the dedica. high. In a number of nations, we find that protection of i tion and resolve of the most radical terrorists whose objec- the civil and military nuclear sectors has been improved in 4 tive is to destroy the prevailing order. On the o*her hand, recent years. We also find that the push to plutonium fuel t<

we believe it necessary for governments to address underly- in power programs has not proceeded as quickly as project. d<

ing political, economic, and social conditions to the extent ed only a few years ago. Widespread commercial trade in ai possible. This might help dry up fertile ground for terrorists plutonium would require improved controls against terror- m and thereby deprive them of popular support and their re- ism. Due to the adverse economics of using plutonium as cruitraent base. There is little prospect of ending terrorism an energy source over the next several decades, there is a u' in the short term. Several forms of nuclear terrorism, how- window of opportunity to develop improved controls against ,

ir, ever, pose demanding tasks to terrorist groups which could nuclear terrorism if commercial uses are deferred until then. i o' be helped greatly by a broad support base. Thus, the denial in the meantime, weapon-usable forms of uranium are be- m of this base is important for containing the threat of nu. ginning to be phased out of civilian research reactors, espe- in clear terrorism in the long term. cially on university campuses where such fuelis most vul- oi All nations, in striving to deny terrorists nuclear arms, nerable.

should pursue arms control efforts to' help limit the growth Certain paths to bomb making, particularly the seizing o. ,

and the spread of nuclear arsenals. Ouc recommendations and reprocessing of spent fuel, are more difficult and dan. A ,

on a number of relevant arms control measures will be gerous than popularly supposed. Indeed, sabotage of pro- ) e-found further in the report. perly casked spent-fuel shipments is likely to pose little risk ar Finally, the Task Force emphasizes that much can be done except to the perpetrators. Nuclear power plants are de- ti to reduce the dangers; the current situation does not call signed to resist rocket attack from afar and to shut down ci for hopelessness or despair. Nuclear terrorism is possible, safely if powerlines to or from the plant are cut. And the o but not necessarily imminent or inevitable. There is, in fact, risk that nuclear terrorists could trigger inadvertent nuclear l>

some basis for optimism. Obstacles to nuclear terrorism war is being reduced substantially by ongoing diplomatic o December 1986 40 )

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4 and technical cooperation between the superpowers. The Relative vulnerability. In general, civil nuclear installa-challenge is for governments and industry to build on the tions and shipments worldwide have been more vulnerable foundation of these technical, organizational, and political than those in the military sector of countries where nuclear strengths to more effectively counter the threat of nuclear weapons are produced, stored, and deployed. Houver, there 3

terrorism. Effective measures are available and should be may well be exceptions. Limited resources and the more g

j taken to minimize risks of nuclear terrorism without jeo-pardizing development of nuclear energy for peaceful pur-severe social and legal constraints in the private sector of democratic states result in the guard forces, barriers, exclu-

poses. sion zones, and equipment being generally of a lesser order

[ Task Force member Inga Thorsson wishes to add the than those used to protect weapons and military installa-following personal view: No serious discussion of the threat tions and shipments. In particular, civil nuclear materials of nuclear terrorism can disregard the most decisive threat suitable for use in nuclear weapons are not necessarily given i

to our survivah the existence of nuclear weapons. The the same level of protec' tion worldwide as is accorded to threat of nuclear terrorism is due to this fundamental fact weapon materials and to weapons themselves.

and to the production of electrical power by nuclear reac- The nuclear weapons sector is generally less vulnerable tors. Consequently, and aware as I am that knowledge of worldwide, given the substantial resources already applied evil-in this case, the splitting of the atom-can never be to protective measures. Yet, political and budgetary factors taken away from mankind, the political renunciation of ser e unduly to inhibit the upgrading of protective measures nuclear weapons and nuclear-produced electric power is a needed to counter the terroi.st threat against potential mili-

prerequisite to removal of the nuclear terrorist threat. In tary nuclear targets. In particular, upgrading the protection j the final analysis, all states possessing nuclear weapons are of nuclear weapons deployed in Europe and in the Pacific nuclear terrorists, keeping the peoples of the world hostages region, especially in countries where terrorism is intense, to their political aims, to be achieved, if necessary, by the is not proceeding as rapidly as feasible, and military pro-

, use or the threat of use of nuclear weapons.] duction reactors in the United States do not have the costly containment structures required for commercial nuclear p Establishing priorities power plants.

Nature of the adversary. Mass hysteria and social disrup-The Task Force has established an order of priorities as a tion arising from a credible nuclear threat or hoax, rather guide to policy makers and the public for countering the than mass killing and destruction resulting from a nuclear y threat of nuclear terrorism It is based on three basic consi-detonation or sabotage, may be the objective of a group derations: the gravity of the consequences, the vuln. rability attempting nuclear terrorism. Indeed, most terrorists of potential targets, and the nature of the adversary.

operating within their own borders would be inhibited from Gravity of the consequences. Theft and explosion of a engaging in actual nuclear violence out of fear of losing

[ nuclear weapon would likely have the most catastrophic popular support for their cause. However, a single success-j consequences; indeed, the theft and threat of use in and ful theft of a weapon or of weapon-usable material or a r of itself could have severe political and psychological conse- successful penetration of a nuclear-weapons site or a nuclear i

quences. Accordingly, the highest priority should be given reactor would cause severe social, psychological, and poh-to protecting nuclear weapons against theft, preventing the tical disruption-an objective common to most terrorists.

detonation of nuclear weapons in the event they are stolen, The growth of terrorism across borders poses a special i and recovering stolen weapons. Improvements are needed problem because the perpetrators may not be inhibited from l in all three areas, as detailed later in the report. committing nuclear violence against foreign populations. l Theft of nuclear materials and their use or threatened The self-image of some terrorists as being at war with a use in a crude homemade bomb-or, with help from a state, sup power or a military alliance could create incentives in a more sophisticated device-is the second most danger- for a "counterforce" nuclear strike against military installa-l ous possibility. Interest in protecting civil and military tions in which civilian casualties would be regarded as dep-nuclear materials from theft and, at least for the time be- lorable but unavoidable " collateral damage." For example, l ing,in minimizing production and use of materials in weap- a number of NATO installations are far enough from popu-on-usable form should be correspondingly high. lation centers to permit a terrorist nuclear strike with a low-Sabotage or threatened sabotage of a reactor, fuel facility, yield device with relatively few civilian casualties. l or fuel shipment is the third most dangerous possibility. A further consideration is whether terrorists operating A nuclear explosion resulting from such sabotage is all but across borders are operating independently or with state

excluded, but potential contamination to the surrounding support. One view among experts is that the latter are likely

! area could be severe, depending on weather conditions at to have a greater capability and fewer inhibitions. U.S. Sec-the time, on the ability of terrorists to deactivate or cir- retary of State George Shultz, in a speech to the National cumvent fall-back safety mechanisms, and on the ability Defense University, declared: " State support will probably of building structures and shipping containers successful- be the single most important factor in enabling terrorists ly to withstand the consequences and to prevent dispersal to acquire [ advanced) weapons, which may well include of radioactive materials. nuclear devices." But some analysts regard the vulnerabili-Bulletin of the Atomic Scientists i 41

ry of states to retaliation as a major deterrent to state spon- m sorship of nuclear terrorism and regard all but perhaps the International task force di most fanatical regimes as likely to be so inhibited. on prevention of nuclear terrorism A terrorist group's place in the political spectrum is some- pl Co-chairmen:

times seen as being significant in assessing its potential for Rear Adm. Thomas Davies, USN (Ret.), former assistant director nuclear violence. Some obse vers maintain that terrorists of for nonprohferation, U.S. Arms Control and Disarmament Agency fu the "left" tend to regard their cause as designed to better Bernard O'Keefe, chairman, Executive Committee, EG5cG, Inc.

the human condition and thus generally avoid mass casua). Exceutive vice-chairman: )

P*"I I'venthat, president, Nudear Control Institute ties, while terrorists of the "right" tend to be more contemp-tuous of the masses and are more prone to acts that take ('j'Ignew, former director Los Alamos National Laboratory c

relatively large numbers of lives. However, there is an in* Yonah Alexander, director, Institute for Studies in In crnational creasing pattern of random killing among terrorists of all Terrorism, State University of New York l' political persuasions that tends to invalidate this distinction. George Bunn, Stockton Professor of International Law, U.S. Naval

. War College.

Paradox.ically, some analysts believe that if counterterror. Donald De Vito, director, New York State Emergency Manage- ct ism efforts prove generally successful, these efforts could ment Office contribute to the risk of nuclear terrorism. A heightened Hernard Feld, professor of physics, Massachusetts Institute of Technology

" war" against terrorism might lead to an escalation of ter- David Fischer, former assistant director general for external rela-  ;,

rarist violence. According to this view, terrorists often see tiom. International Atomic Energy Agency themselves "on th: defensive," a self-fulfilling image that *'" Gdi"'k Y'"""" """"""mnu, us. Nuclear Regulatmy

. . . Commisuon c!

is confirmed by ever harsher responses to the.ir violent acts. Reinosuke liara, executive vice-president, Seiko Instrument and g it ia also regarded as conceivable that a terrorist group, find- Electronics, Ltd., Japan "

ing itelf in a deadlock situation, blocked in its efforts and Enrico jacchia, former director of EURATOM Safeguards, Euro-

. pean Economic Commumry no longer able to capture headlines, and believing that its ty tiarald Muller, executive director, New Approaches to Non-very enistence is threatened, could resort to nuclear terror- Prohferation: A European Approach, Centre for European Pohcy ism on the basis of having "nothing to lose" and needing S'"d'es, Brussels; Research Fellow, Peace Research Insotute, y

.. . Frank furt a ,' terrorism spectacular,, to regam its prommence. Yuval Ne'eman, director,5ackler Institute, Tel Aviv Umversity, The final consideration is whether terrorists are likely to Israel; formu Israch mimster of science and technology ,o have the combination of motivation and capability needed to d"'""' B'hd*' oral Sciences Defense Systems,

{"ald ""' M D" engage in nuclear violence. There are a number of options John Redick, program officer, W. Alton Jones Foundation ) a for escalating violence before they approach a nuclear thresh- Mohamed Shake , deput> permanent representative of Fsypt to old. Nuclear systems are but one among the high-techno- the United Nations; president,1985 Review Conference of the Nuticar Non-Proliferation Treaty logy options available to terrorists. Chem.ical and biological Claire Staling, journalist I systems, for example, offer terrorists effective methods of Shuraburo Takeda, professor of engineering. Tokai University, 1 threatening to kill or actually killing large numbers of peo- l*Pd"

.. Kenneth Taylor, vice president, government affairs, Nabisco t pie. Further, it is difficult to think of a demand that could Brands, Inc.; former Canadian ambassador to tran '

t be used to justify an act of nuclear violence. For these rea- Theodore Taylor, former deputy director (scientific), U.S. Defeme sons, some analysts discount the possibility of nuclear ter- Atmnic Support Agency

. Inga Thorsson, former Swedish undersecretary of state for dis. a rorism or forecast an increasing number of highly plausible armament; president,1975 Review Conference of the Nuclear a nuclear hoaxes. At the same time, as noted above, acts of nu. Non-Prohferation Treaty p ,

clear sabotage and theft and the technical resources needed 5"' field Turner, former director of the Central Intelligence for construction of a crude nuclear device are within reach k',"[i[ Wahers, director, Nuclear Planning Group, NATO, Brussels C

of modern terrorist groups with sufficient resources. Nu- Mason Willrich, senior vice-president, Pacific Gas & Electric clear terrorism, although it may appear improbable, should C""Pd"Y

. . Bertram Wolfe, vice-president and general manager, Nuclear Fuel .

not be discounted or dismissed. It should be seen as a real and Special Projects Division, General Electric Company threat to civilization. O  ;

h) '

Task force recommendations s

Short-term recommendations The U.S. Nuclear Emergency Search Team should be up- t  !

graded. 1 Protecting nuclear weapons (

Protecting nuclear materials l

Nuclear-weapons states should determine whether their Civil nuclear materials worldwide in forms suitable for f weapons are sufficiently protected to deter or repel terrorists. use in weapons should be given protection equivalent to t All tactical nuclear weapons should be fitted with the government protection of weapons. .

most advanced self-protecting systems. The cost of protecting weapon-usable forms of nuclear  : j December 1986 42 i l l

materials should be factored into private decisions to pro- e duce and use them. j e#

In the meantime, reexamination of civil applications of f plutonium can be conducted on economic grounds. /

Conversion of reactors from weapons-grade uranium / ,'

fuels to lower-enriched uranium not usable in weapons  ;)#

l should be considered at this time.

i d To the extent that civil materials suitable for weapons l l #

are used, extraordinary precautions should be taken to pro- l l

/

tect them from terrorists.

O Protecting nuclear facilities Denial of access to nuclear facilities should be the basic consideration in protecting against sabotage.

^

__f #'pj_ - ~ _.

Thorough vigilance against the insider threat i needed. ea v.a,,,3 w,a c,,,,,,,,

Guard forces should be thoroughly trained and author-ized to use deadly force.

The basis used for designing physical protection of nu-Screening of job applicants and surveillance of employees clear plants should be reviewed to insure that it accurately at nuclear facilities should be conducted in ways to insure

. reflects the current threat.

that employment is not denied for activities that represent Power reactors should be protected against vehicular the exercise of basic rights to free speech and association th reats. rather than pose a security threat.

Research reactors should have adequate security provi-Because of the potential danger of emotionally unstable sions against terrorists. employees and of the insider threat m nuclear plants, em-Reactor safety designs should be reexamined to protect ployees or job applicants who are to have unrestricted ac-agamst an accident caused by terrorists. cess to vital areas of a plant should be subject to psycho-l 1 AEA physical-protection guidelines should be reviewed logical screenir.g and to a check for a national criminal his-and updated. tory, including a check of fingerprint records. Any criminal i l

Pmtection star.dards should be spelled out unambiguously. record found, however, should be available to the subject  !

f r review, c necti n, r appe i before any adverse action l Intelligence programs s taken*

l National authorities should task their intelligence agen-Plant security personnel should be authorized to use j cies to apply sufficient resources to the threat of nuclear deadly force, but the conditions under which the use of l terrorism. deadly force is appropriate and legal should be clearly l 9 "Certed efforts to promote cooperation among nation- spelled out in regulations, taking into consideration the laws al mtelh.gence services, meluding those of the Umted States and customs of particular countries.

and the Soviet Union, should be pursued as part of the ef-In the event of an imminent threat or calamity, national fort to counter the nuclear terrorist threat. . security interests will prevail over individual rights. How-National m.telligence agencies should look for early m. di- ever, wide-ranging searches for nuclear devices or materials, cators of nuclear terrorism' and detention of suspects or witnesso in connection with National intelligence agencies should develop behavioral a nuclear terrorist incident, should -' - undertaken with

', and political profiles of potential nuclear terrorists. maximum restraint.

National intelligence agencies should prepare plans on Controlling nuclear transfers how and when to inform local officials of a credible nuclear No significant nuclear transfers should be made to a na-threat.

tion that is located in a zone of war or that supports or National centers for analyzing intelligence on terrorism Sponsors international terrorism. Such a policy,if adopted should be established and should give high priority to the by all nuclear suppl;iers, would help to deter military attacks nuclear threat. on nuclear installations and to deny to terrorists a potential Civilliberties concerns source of nuclear-weapon material and know-how.

Physical protection and intelligence activities directed at Export controls and customs police practices should be preventing nuclear terrorism always should be exercised reexamined to insure they are adequate to meet the threat with the greatest vigor necessary under the particular cir- of nuclear terrorism.

cumstances, withfull regard to the individual rights of citi- National criminal laws should be amended as necessary zens and employees. to provide for punishment sufficient to work as a true deter-Bulletin of the Atomic Scientists

) 43

rem for violations of nuclear export laws and regulations, in particular, there should be consideration of what ar-There should be prompt and vigorous prosecution of all rangements can be made in advance of a nuclear terrorism persons seeking to smuggle weapons-usable nuclear items crisis to ensure the sharing of information by national intel-out of a country, ligence agencies on a timely basis with selected regional and

. local officials during such a crisis-information needed for U.S.-Soviet cooperation decision making on evacuation and other protective mea-Efforts should be made to promote U.S.-Soviet coopera- sures.

tion on intell;gence-sharing and on responses to threats or The issuance of security clearances to emergency man- )

acts of nuclear terrorism. Consideration should be given agement officials is an essential first step.

as to whether joint action against a nuclear terrorist threat might or might not include the use of force by the super. Role of the media ,

powers. Because of the possibility of widespread panic, injury, and The proposal by Senators Sam Nunn and John Warner death resulting from a credible threat by nuclear terrorists, for establishment of U.S.-U.S.S.R. Nuclear Risk Reduction government officials and media representatives should co-Centers, whose assignments would include principal re- operate in planning how to provide timely and accurate in- i sponsibility for coordinating superpower responses to formation in such a contingency.

nuclear terrorist threats,is a major step in the right direc- To the extent possible, joint videlines should be devel-tion for pursuing these options and should be negotiated oped in anticipation of a crisis by the responsible national pmmptly. government agencies with regard to how and when infor-l Arms controlinitiatives mation will be disseminated during a crisis. The key con- g l The United States and the Soviet Union should pursue sideration should be at what point in a crisis,if the threat l current efforts to negotiate deep cuts in their strategic proves real, there still would be time to order an evacuation in a manner that minimizes injury and death and promotes arsenals with a view toward lessening the threat from nuclear weens by reducing the risk of early use, improv- public order. leading media representatives and state and ing stra;egic stability, and maintaining credible nuclear local officials should be invited to participate in preparation deterrence. of the guidelines.

Ongoing efforts to reduce the size of nuclear arsenals should include the smaller battlefield weapons that are most long-terrn recornrnendations susceptible to attack or theft by terrorists. 8 Additional nuclear-weapon free zones, which would re. International measures duce poten ial access to nuclear weapons, should be nego- All states should embark on outlawing acts of nuclear tiated where it proves consistent with the security interests terrorism by signing and ratifying the Convention on the of the nations concerned. Physical Protection of Nuclear Materials.

In meeting obligations under existing treaties, all nations International agreements in the wake of the Chernobyl '

should examine the antiterrorist benefit which would accrue accident should include measures to deal with the terrorist from a strictly verifiable comprehensive test ban. threat.

Convention on Physical Protection of Nuclear Materials The U.N. Security Council should approve a resolution The Task Force recommends that the Convention on the on nuclear terrorism.

Physical Protection of Nuclear Materials, which has not An agreement specifying additional acts of nuclear terror-come into force for lack of accessions, should be ratified ism is needed, promptly, it is particularly important to secure ratification by the 11 members of the European Economic Community, Emerging nudear tuhnologies  ;

which would provide more than the needed number of Emerging technologies capable of simplifying the pro-accessions. duction of weapon-usable forms of nuclear material should At the same time, urgent steps should be taken bilateral- be foHowed as a possible route for acquisition of such mate-nals by tenonsts.

ly and through the International Atomic Energy Agency to establish more stringent minimum requirements for pro- Advanced enrichment and production technologies should tection of weapon-usable nuclear materials while in domes- be dewtoped with restraint and used only if required to meet l nati nal energy needs.

tic use, storage, or transport worldwide. .g Efforts to develop forms of nuclear fuel less subject to Role of emergency-management programs proliferation should be further encouraged in the interest Emergency management organizations at the regional of lessening the dangers of nuclear terrorism. In particular, and local level should be provided the fiscal and human the development of fuels containing thorium in more pro-resources needed to cope effectively with a threat or act of liferation- and terrorist-resistant fuel cycles should be con-nuclear terrorism. sidered. O 1 December 1986 44

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CERTIFICATE OF SERVICE - Docket No.(s) 50-160-REN S Secretary U.S. Nuclear Regulatory Commission Docketing and Service Branch $$ SU' -5 M1 :18 Washington, DC 20555 0FFICE OF SECRE TARY Office of Commission Appellate Adjudication DOCKETING & SERVlCE U.S. Nuclear Regulatory Commission BRANCH Washington, DC 20555 Administrative Judge Charles Bechhoefer, Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555 Administrative Judge Peter S. Lam Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555 i

Administrative Judge Jerry R. Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555 Sherwin E. Turk, Esq.

Susan S. Chikadel, Esq. I Office of the General Counsel U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Randy A. Nordin Manager - Legal Division E. Gail Gunnells Office of Contract Administration Georgia Tech Atlanta, GA 30332-0420 Ms. Pamela Blockey O'Brien D23 Golden Valley i Douglasville, GA 30134 Ms. Patricia Guilday, Esq.

Assistant Attorney General 40 Capitol Square NW Atlanta, GA 30334-1300

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Bill Ray Manager, Office of Facilities Georgia Tech 225 North Avenue NW Atlanta, GA 30332-0410 The Honorable Zell Miller Governor of Georgia l State Capitol

-Atlanta, GA 30334 The Honorable John Lewis United States Congress 229 Cannon Office Building Wasington, DC 20515 James C. Hardeman, Jr.

Manager Environmental Radiation Program 4244 International Parkway, Suite 114 Atlanta, GA 30354 I

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