ML20127B760

FOIA Request for Documents Re Declassification of Info Re Proposed Design of Claiborne Enrichment Ctr.Affidavit of Hm Hunt & Related Info Encl

ML20127B760
Person / Time
Site:	Claiborne
Issue date:	02/26/1992
From:	Curran D CITIZENS AGAINST NUCLEAR TRASH, HARMON, CURRAN, SPIELBERG & EISENBERG, LLP.
To:	Brady R NRC OFFICE OF ADMINISTRATION (ADM)
References
FOIA-92-103 NUDOCS 9301130106
Download: ML20127B760 (17)

Text

_

4 IIARMON, CURRAN, GALLAGIIER & SPIELBERG 2001 S STREET, N.W.

SUITE 430 WASlHNGTON, D.C 200091125 numoNE GArt McGREYY RUWoN (202) 328-3500 DLANE CURRAN FAX ANNE $PIElBEJtG (202) 328 6918 JA.N?iE G GALLAGHER ERJC R GUTZLNSTILN February 26, 1992 KATHERNE A. MWEA EREEDOM OF INFOWATIO JE551CA A LAprs

~

ACT REQUEST fo7A42-/03 BY HAND Raymond J.

Brady, Director h / M/ -k 2' NRC Division of Security Office of Administration

',iashington, D. C.

20555 SUBJ ECT:

freedom of_Information Act and Declassification Recruest re:

Claiborne Enrichment Center, Jocket No. 70-3070-ML

Dear Mr. Brady:

On behalf of Citizens Against Nuclear Trash (" CANT"), and pur-suant to the Freedom of Information Act ("FOIA"), 5 U.S.C.

5 552(a) et seq., 10 C.F.R. $ 95.45, and Executive Order 12356 (April 2, 1982), I am. writing to request that the Nuclear Regulatory Commission ("NRC" or " Commission") declassify and release certain information pertaining to the proposed design of the Claiborne Enrichment Center (" CEC").

This request for declassification is supported by the attached affidavit of-nuclear safeguards conse' tant Helen M.

Hunt.

In particular, CANT requests declassification of the diameters of CEC's p{ocess piping at potential online enrichment measurement points.

CANT also seeks declassification of information pertaining to whether or not the proposed design of the CEC includes reliable tamper-proof monitoring devices for sampling process valves, and flanges.

CANT needs this information

ports, in order to meaningfully challenge the adequacy of nuclear safeguards used to ensure that the CEC's centrifuge equipment is not unlawfully diverted to the surreptitious production of-bomb While CANT would prefer to obtain the exact diameters of CEC 1

process pipes at potential online enrichment monitoring it would be sufficient for purposes of evaluating the

points, adequacy of the plant's safeguards to know the approximate pipe diameters at these points, i.e.,

whether they are greater than 110 mm (inner diameter).

9301130106 920226 PDR FOIA CURRAN 92-103 PDR 930/00 (O V

E o

hap 10N, CURRAN, GAILAGIIER & SPIELBERG Raymond J.

Brady February 27, 1992 Page 2 grade uranium.

As discussed below, classification of this information serves no legitimate security purpose, and even defeats the goal of maintaining security at the plant.

Background

Louisiana Energy Services ("LES") has applied to the NRC for a combined license to build and operate the CEC, a uranium enrich-ment center, in Homer, Lcuisiana.

LES is a partnership of five companies which includes Urenco, U.S. A., a subsidiary of a Euro-pean consortium known as Urenco, Ltd. ("Urenco").

Urenco is owned by the British and Dutch governments and by NUKEM, a group of German companies.

CANT is a citizens' environmental organization, based in Homer, Louisiana, which has intervened in the licensing proceeding for the CEC.

On December 19, 1991, the Atomic Safety and Licensing Board ("ASLB") admitted, int _qr alla, CANT's contentions L and M, which challenge the ef fectiveness of the CEC design to provide reasonable assurance that the CEC is not unlawfully diverted to i

d (i. e. l>omb grade) uranium.gptitious_ production of highly enr che the surr Contention L charges that in order to provide rea-sonable assurance that gas centrifuge equipment at the CEC is not unlawfully diverted to the production of highly enriched uranium LES should require continuous or f requent online enrich-(HEU),

ment monitoring for all cascades.

To ensure the effectiveness of such monitoring, the plan should stipulate minimum process pipe inner diameters of 110 millimeters or greater at all: potential measurement points.

CANT has been informed by a representative of the license applicant, Louisiana Energy Services ( " LES " ), that which the planned pipe inner diameter for the CEC is 3.07 inches, is about 78 mm.3 CANT's Contention M asserts that in order to preclude or detect production of HEU by a batch recycling scheme involving misuse of sampling ports, process valves, and/or flanges, LES' Fundamental Materials Control ("FNMC") plan should require ef fective monitor-ing by reliable technical means which accurately keep track of It is employee access to these process connection locations.

CANT's position that LES should be required to install reliable tamper-proof monitoring devices for campling ports, process 2

The full text of these contentions is attached.

3 Telephone communication:

poter I4Roy, LES, to Helen M.

Hunt, June 11,_1991.

~

~

+

HdijMON, CUlutAN, GA1.LAGilER & SPIELIIERG Raymond J. Brady February 27, 1992 page 3 valves, and flanges.

With a complete set of tamperproof monitors for process connection locations, utilized with authenticated transmission of data to a central computer, it would be a simple matter to reliably keep track of times for employee access to process connection locations, and to compare cumulative access times with data in the applicant's FNMC plan.

It is our understanding, based on statements made by NRC counsel at a January 21, 1992, prehearing conference on the admissibility of CANT's contentions, that information regarding product pipe diameters and the existence of tamperproof monitoring devices for process connection locations is classified.

According to Lois Teiford of your office, the pipe diameters were classified at the request of the British, French and Dutch governments.

We do not know the basis for classifying the information regarding procese connection monitors.

Standard for Clannification of Information The Freedom of Information Act requires the NRC to make avail-able, upon public request, any agency documents that are not spe-cifically exempted f rm.a disclosure under the Act.

5 U.S.C.

552(a),(b).

Exemption 1 of the FOIA permits the NRC to withhold documents that are (A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of-national defense or foreign policy and (B) are in f act properly classified pursuant to such Executive Order.

5 U.S.C. 5 552 (b) (1) ( A) (emphasis added).

Executive Order 12356, which sets forth substantive and procedural criteria for with-holding national security information under Exemption 1, permits, inter alia, classification of " foreign government information."

5 1. 3 (a) (3) _ However, 5.1.6 of the Executive Order also requires that the foreign classification request must be for a legitimate security purpose:

In no case shall ir formation be classified in order to conceal violatione of law, inefficiency, or administra-tive error; to prevent embarrassment to a person, orga-nization, or agency; to restrain competition; or to prevent or delay the release of information that does not require protection in the interest of national security.

r

likitMON, CUlutAN, GAu.Acitut & Splituw.RG Raymond J.

Brady February 27, 1992 Page 4 Dre A109 C4r1inlo_TiteAIWbbet_Cou.tJ4_01rd 9P9_licrXics, 663 v

F.2d 210, 217 (D.C. Cir. 1980) (af firming requiremont for indo-pendent determination of whether national security requires clan-sification reguented by a foreign governmor.t); Lomont__LJspJir;t-MOD L0f luntign, 475 F. Supp. 7 61, 7 7 2 note 42 (S.D.N.Y.

1979)(Courts "have a duty to look behind any clairn of exernption, which all too of ten in the past has boon uced to cover up inef ficancy or embarrannment even in foreign policy mattern fully known by other countrica but not which, many timen, are printable in our own.

..", quotdng 120 Cong. Roc. 36626 (Nov.

20, 197 4 ) (Rep. Reid, R-fiY).

Information Should be Declannified CA11T requesto that the ilRC roconnider itn agreement to provido clannification for the requented safeguards information, becauno such clanuificaticn falln to natisfy the criteria for withholding under the Foi A and Executive Order 12356.

Clannification of approxinato proccus pipo diametern and information regarding the existence of tamporproof monitoring devices is not only unnocemary to protect national security, but it thwart.n any pub-Itc debate that might renult in the str.ongt.bening of nafeguards for the CEC.

Would-be minunern of the CEC already have much of the general information to which cat 4T necks accens.

The only purpose cerved by clannif ying it will be to protect Urenco from any public criticinm that might lead to ntronger safeguards at the CEC.

procenn pipe diana' tern To our knowledge, the CEC in the first plant for which any Euro-pean government han completely clannified procena pipe diamotorn.

The approximate, or in uomo canen, exact, diameters of the pro-cena pipen in Urenco'n European f teilitien have never bef ore been clannified; in fact they have been prenented freoly in open nafeguards 1iterature.

In the literaturo cited below, for exam-plc, exact pipe diametern for Urenco'n Almolo and Capenhurst plants are cited freely.

Approximato diamotern are alno given f or Urenco's Cronau plant.

It in also commonly underntood that pipe diametoru cutstantially lenn than 100 mm are "umall," and greater than 100 mm are "large."

In addition, many unclannified papern have been publinhed which discunn the relationship between pipo diameter and foanibility of-on1ine enrichment monitoring.

For innlanco, a brief review of current nafeguarda literaturo yielded the following information:

b.pHMON, CURRAN, GAI.LAGilER & SPIELBERG Raymond J.

Brady February 27, 1992 Page 5 1)

Product pipes in some cascades at the Urenco facility in Almelo, Netherlands, have an outer diameter approximately 42 mm and an inner diameter approximately 36 The literature on safeguards for gas centrifuge enrich-mm.

ment plants consistently describes those pipes-as "small-diameter pipes."

K. van der Meer, " Enrichment Verification on UF6 in Low Pressure Process Pipos:

An Application of the Two-Geometry Method," Proc. lith ESARDA Symposium, Luxem-bourg, 1989, ESARDA 22, p. 179.

2)

Product, waste and dump pipes at the Urenco Capen-hurst f acility in the United Kingdom have inner diameters of 110 mm.

The safeguards literature consistently describes gas centrifuge process pipes having an inner diameter greater than about 100 mm as "large-diameter pipes."

T.W.

Packer, " Continuous Monitoring of Variations in the U235 Enrichment of Uranium in the !!cader Pipework of a Centrifuge Enrichment Plant," Proc. 13th ESARDA Symposium, Avignon, France, 1991.

ESARDA 24, p.

372.

3)

Product pipes in some cascades at the Urenco facility in Gronau, Germany, are of small diameter.

W.D.

Iauppe,

B.

Richter, G. Stein, " Assessment of NDA Techniques for the Cascade Areas of Centrifuge Enrichment Plants,"

Proc. lith ESARDA Syn.posium, Luxembourg, 1989 ESARDA 22, p.-

483.

4)

Product pipes in some cascades at the Ningyo Toge uranium enrichment pilot plant in Japan are of-small to medium diameter (less than 80 mm outer diameter).

M. Hori, T. Ishiga, M. Akiba, A. Tani and M. Omae, "NDA Measurement of the Enrichment of Uranium in the Pipe for a Gas Centrifuge Enrichment Plant," Proc. 27th Annual Meeting, Institute of Nuclear Materials Management, New Orleans, 1986, p.

649, diagram.

It is also publicly known that like some of Urenco's European plants, the CEC is being designed with small process pipe-diameters that are not conducive to online enrichment monitoring.

In fact, a LES representative provided process pipe dimensions to a member of the public over the telephone.4 In addition, the NRC published them in a trip report that was circulated widely within the NRC and sent to various members of the public.

Memorandum 4

See note 3, puprji.

l IIAllMON, CUlut AN, G AI.IAG11En & SPIEL. HERG l

Raymond J.

Brady February 27, 1992 Page 6 Brady, et al.,

to Robert M.

Dern dated Sep-Foreign Trip Travel Report.gro, from Raymond J.

tomber 9, 1991, re:

Thus, general information about the dimensions of Urenco gas centrifuge enrichment facilities, and even specific information about the pipes at the CEC, is already available to the public through a variety of means.

It is also well known that Urenco fiercely opposes any requirement to enlarge CEC pipe diameters at potential measurement points in order to utilize online enrich-ment monitoring.

Yet, the inadequacy of CEC pipe diameters for saf eguards purposes current ly cannot be litigated in NRC licens-ing hearings for the CEC because the pipe diameters are clas-sified.

Classification of the information thereby improperly

" thwart [s)" the " sunshine purpocos" of the Freedom of Information Act and stifles important public debate about the adequacy of nafeguards for the CEC, without serving any national or interna-tional safeguards intererts in protecting truly secret informa-t ion f rom disclosure.

Lamont v._De p.a r t y nt _o LJ u s Re c, 4 7 5 F.

Supp. at 772.

In fact, it appears that Urenco's owners, the governments of Germany, Great Britain, and the Netherlands, have repeatedly canctioned the release of information regarding process pipe diameters at other Urenco plant s.

Thus, release of this informa-tion for the CEC would not threaten these foreign governments' cecurity interest in maintaining confidentiality.

The orlly interest which appears to be served by classi f ying this informa-tion is Urenco's and IES' wish to avoid embarrassing litigation or public debate over the safety of the CEC, or the expense of upgrading the plant's safeguards design and equipment -- clearly an invalid rationale for classification under Executive Order 12356 and the FOIA.

De ieript ion of monitoring devices CANT also seeks declassification of for the same reasons, infornation portaining to whether or not the proposed design of the CEC includes reliable tamper-proof ronitoring devices for 5

Three days later, the NRC sont out a replacement page with the pipe diameters deleted.

A cover memorandum requesteo that the corresponding original page be destroyed, but conveyed no sense of urgency and gave no explanation whatsoever for the substitution.

Memorandum from Theodore S.

Sherr to Those on attached liut, dated September 12, 1991, re:

Replacement Page.

A IIIRMON, CURRAN, GAllAGilER & SPIElllERG Raymond J.

Brady February 27, 1992 Page 7 campling ports, process valves, and flanges.

As discussed in CANT's contention M, it is DJIensk publicly known that the design for the CEC does not include such devices.

Thus, maintaining official secrecy regarding the issue does nothing to protect the common defense and security.

In fact, it has the opposite effect, by protecting LES and Urenco from criticism or challenge in the public hearings regarding their inadequate safeguards sys-tem.

Once again, there are no legitimate security bases under Execu-tive Order 12356 and the FOIA for withholding this information from the public.

Therefore, CANT requests that the NRC declas-sify information regarding the existence of reliable tamper-proof monitoring devices for campling ports, process valves, and flanges in the applicant's FNMC.

If, for any reason, you deny this request, please provide a dis-eusnion of the reasons for your decision and the legal authority upon which you rely.

Request for expedited treatment Litigation of CANT's contentions challenging the adequacy of LES' license application for the CEC is now underway.

While no hear-ing date has been set, completion of the NRC Staff's Safety Evaluation Report, which would trigger the summary judgment and hearing processes, is expected to occur in early 1993.

Thus, CANT respectfully requests that you give immediate attention to this matter, so that we may begin discovery as soon as possible.

Pl' ease do not hesitate to call me if you have any questions about this letter.

Sincerely,

~

b ~ a_

Diane Curran Attachments:

1 Affidavit of Helen M.

liunt 2

CANT's Contentions L and M cc: ASLB Service list (w/o attachment 2)

NRC Commissioners Donnie Grimsley, NRC FOIA Officer 1

Attacionent 1 AFFIDAVIT OF llELEN M. IIUNT Helen M. Hunt, being duly sworn, deposes and says:

1) I am an independent consultant on nuclear safeguards A statement of my professional qualifications is attached.

2) I assisted in the preparation of Citizens Against Nuclear Trash's safeguards contentions L and M in the NRC licencing proceeding for the Claiborne Enrichment Center.

3) I have also reviewed the foregoing letter from Diane Curran to Raymond J. Brady, dated February 26,1992, re: Claiborne Enrichment Center, Docket No.

70-3070-ML.

4) The information contained in CANT's contentions and in the letter from Ms. Curran to Mr. Brady is true and correct to the best of my knowledge.

14#1/W Helen M. Hunt Signed and sworn to before me thisc2b_ day of February,1992.

_B.

7874

/D 4

Nbtary Public

//

My conunission expires./O /@

/

I February 26,1992

Statement of Professional Qualifications IIELEN M.11UNT P.O. Box 530 Princeton, New Jersey 08542 Nuclear Safeguards Positions:

Director, Nuclear Materials Safeguards Project,1991 Founder and director of organization dedicated to strengthening national and inter-national safeguards for the purpose of reducing the likehhood oT unauthorized acquisition of fissile materials for possible use m nuclear weapons, independent Conndtant on Nuclear Safeguards, 1990 91 Testified before U.S. Department of Energy r arding safeguards issues in DOE nuclear weapons complex; prepared critique o lutomum health hazards study prepared by City of bew York for proposed siting of nuclear warheads in New York liarbor; at the 1991 European Safeguards Research and Development Association symposium, proposed a solution to the uranium enrichment measurement problem for gas centnfuge plants.

Considiant to the Nuclear ControlInstitute, Washington, D.C.1988 90 investigated and reported on critical weaknesses in nuclear safeguards; demonstrated that nondestructive assay methods are not employed in a way that would allow detection of several kilograrns of shielded plutomum or highly enriched uranium in a standard waste disposal container, and proposed a solution to the problem at the 1990 annual meeting of the Institute of Nuclear Materials Manage.

ment; assessed and reported on weaknesses in Japan's nuclear safeguards program; discovered that current online uranium enrichment measurements are not working.

for many gas centrifuge enrichment plants.

Edycatiom B.A. in mathematics from Cornell University,1965 M.A. in mathematics from Princeton University,1971 Graduate courses at Princeton University on security and environmental issues, 1987-88 Principal Nuclear Safeguards Presentations and Publications:

" Detection of Attempted Diversion in Waste Containers," paper presented at the -

annual meeting of the Institute of Nuclear Materials Management,IAs Angeles, California, July 1518,1990, and published in the conference Proceedings.

" Effective Go/No Go Enrichment Measurements," paper presented at the Euro-pean Safeguards Research and Development Association Symposium on Safeguards and Nuclear Material Management, Avignon, France, May 14 16,1991, and pub.

lished in the conference Proceedings.

,---=--_:,_.

+

CANT SAFEGUARDS CONTENTIONS L AND M L.

Online Enrichment Monitoring In order to provide reasonable assurance that gas centrifuge equipment at the CEC is not unlawfully diverted to the production of highly enriched uranium (HEU), the applicant's fun-damental nuclear material control (FNMC) plan should require con-tinuous or frequent online enrichment monitoring for all cas-cades.

To ensure the effectiveness of-such monitoring, the plan should stipulate minimum process pipe inner diameters of 110 mil-limeters or greater at all potential measurement points.1 The current design of the CEC does not meet those specifications.2 BASIS:

On December 17, 1990, the NRC published a proposed rule setting forth "new performance-based material control and accounting requirements" to be applied to enrichment facilitics.3 Minimum process pipe inner diameter should be 110 mm if 1

uranium hexafluoride gas pressure in the pipe is relatively high, as at the Capenhurst plant in the United Kingdom.

See T.W. Packer, " Continuous Monitoring of Variations in the U235 Jnrichment of Uranium in the Header Pipework of a Centrifuge-Enrichment Plant," Proceedings of the 13th ESARDA Symposium on Safeguards and Nuclear Material Management, 14-16 May 1991. 5.

(This article and all other articles referenced in the following four safeguards contentions are attached and incorporated by reference into this contention.)

Minimum process pipe inner diameters must be larger than-110 mm for pipes in which the uranium hexafluoride gas pressure is moderate or low.

For example, if the-gas pressure were one-half that in a typical corresponding pipe at the Capenhurst plant, then the minimum process pipe inner diameter should be the square root of two times 110 mm, or 155 mm.

2 The safeguards issues addressed in the following four con-tentions will also be raised in CANT's comments to the Commis-sion regarding the proposed standards for the CEC.

3 The Commission has directed that if this proposed rule is not final by the time of licensing of the CEC, the CEC license is to be amended, as necessary, to conform to the regulations.

Notice of Receipt of Application for License, etc., 56 Fed.

I Reg. 23,310, 23,313 (May 21, 1990).

l

.g.

55 Fed. Reg. 51,726.

Pursuant to proposed 5 74.33 (c) (5) (i),

material control and accounting systems for uranium enrichment facilities must include a " detection program, independent of pro-duction", that provides "high assurance" of " detection of any production of uranium enriched to 10 percent or more in the U235 isotope in any product stream."

NRC Draf t Regulatory Guide DG-which describes methods acceptable to the NRC for achieving

5002, the performance objectives in 10 C.F.R. 5 74.33, specifies that The licensee should have a program for monitoring the isotopic composition of product and tail streams, inde-pendent of operations, that provides high assurance of timely detection of any production of uranium enriched (A)n to 10 percent or more in the isotope U-235.

extensive program for the centrifuge technology would be appropriate because of the case of reconfiguring the machines to produce higher enrichments in a short period of time.

The program can use nondestructive assay with fixed detectors, portable detectors, or UF6 samples taken and analyzed for U-235 concentration.

Reg. Guide DG-5002, 5 1.2.

For several reasons, the most practical and effective means of meeting this requirement is to employ frequent or continuous use of fixed detectors for monitoring gas-enrichment in-all pro-duct, waste, and dump pipes, rather than the more established practice of occasional intermittent use of portable detectors.4 First, continuous or frequent enrichment monitoring allows more-constant and comprehensive surveillance over-the uranium enrich-ment process than does occasional intermittent enrichment monitoring.

Second, detection of HEU production by portable 4

S.cn Packer, Attachment 15.

bu u tuuk u uuupu o

en e

-3 detectors can be evaded too easily.

Because HEU gas could be removed from a centrifuge cascade in a very short time upon a decision to terminate use of the cascade (or a portion of the cascade) for HEU production, it would be possible for plant pro-duction personnel to take actions so that HEU production would not be detected by means of a portable detector technique; indeed, the high visibility of inspectors carrying detectors would serve as a signal to production personnel to promptly cease HEU production.

Extensive sampling of process gas would not be a practical alternative to online enrichment monitoring, because it would involve excessive risk of leakage of air into the pipes.5 For all online enrichment monitoring techniques presently known, it is well established that effectiveness of monitoring requires that at measurement points there be at least a moder-in ately high ratio (i.e., at least 1:1) of the amount of U235 in the pipe deposit.6 The most the gas to the amount of U235 practical means of assuring that this condition exists throughout the life of the enrichment equipment is to install process pipe sections at potential measurement points which are of a large l

5 Communications:

Trevor Packer, Harwell Lab, United Kingdom and Ben Dekker, URENCO, Netherlands, to Helen-M. Hunt at ESARDA meeting, May 16, 1991.

6 Helen M. Hunt, " Effective Go/No Go Enrichment Measures,"

13th ESARDA Symposium on Safeguards and Nuclear Material Man-i agement (May 14-16, 1991) at 363-64. 6. 'See also Packer,-Attachment 15.

f

~~

e

E t

-4_

diameter, 1.o., greator than 110 mm Inner diamotor.7 Actual 1

recommended pipe diameter at a potential measurement point would depend on gas pressure in the pipo.0 Proposed pipo diamotors in l

the CEC design, however, are significantly smaller.

According_to URENCO representativo Potor LeRoy, the planned pipe inner diamotor for the CEC in 3.07 inches, which j a about 78 mm.9 At this pipo diameter, the uranium deposit that sould build up on the pipe wall would, within months or a few yaars, dominate the online enrichment measurements.

Because of associated large measurement uncertainties, onlino enrichment measurements would then not be capable of reliably determining whether low enriched or higV ' enriched uranium hexafluoride gas is present in a pipe.

The CEt isign should therefore be. modi fied to increase the pipo

+

size at measurement points to a degree that will permit adequato enrichment monitoring.

M.

Monitoring of Sampling Ports, Process Valves, and Flanges In order to preclude or detect production of HEU by a batch recycling ccheme involving misuso of sampling ports, process valves, and/or flanges, the applicant's FNMC plan should require ofrectivo monitoring by reliable technical means which accurately 7

Communications:

Trevor Packer, Harwell Lab, UK, and Ben Dekker, Urenco, Netherlands, to Hc:an M. Hunt at ESARDA moot-ing, May 16, 1991.

8 San noto 41, supta.

I 9

Telephone communication:

Potor LeRoy, LES, to Helen M.

Hunt, June 11, 1991.

i

. _.. ~ _. _ - - _. _ _.. -., _. _ _ _,. -..., -. _ _ _..., - - -.. _ ~.. -...,. -, _. _, _.. _ _. - -

koop track of employce access to these process connection loca-tions.

BASISt Compliance with proposed 10 C.F.R.

$ - 74. 3 3 (c) (5) (i) requires effective monitoring of all product streams.

Production of HEU by a batch recycling scheme involving intreduction of feed and withdrawal of product through sampling and process valve ports is a credible scenario in a gas centrifuge enrichmant plant.

Hisuse of other proccas valves (not having ports) could be a component of such a scenario.

Onsite production of HEU could be carried out d.iscretely by as few as one or two produc-tion employees.

For this reason, NRC Draft Regulatory Guide DG-5002, $ 12.2, " Monitoring Program for-alandestine Enrichment Scenarios," requires the applicant's FNMC plan to address, inLqr a.11.n, " Sampling ports and frequency of sampling to be used for monitoring of product streams,' and "The use of tamper-indicating seals on process valves and flangac."

Use of seals has_been only partly reliable, however, because it has been possible for plant production personnel to remove seals from valve ports -- in order to perform process monitoring -- without promptly replacing seals in a verifiable manner.

Monitoring of ruch HEU production by human surveillance would not be rollable.

It would be difficult to detect and assure the reporting of small feed and withdrawal containers that would serve as "possible indicators of unauthorized production."

DG-5002, 5 11.3.

Hidden in the forest of tens of thousands of

I L

contrifuges, they might not bo scen by an individual who walks the halls.

Moreover, individuals walking huge deserted cascade j

halls, listening and looking for signs of criminal production activity, could bo in great personal dangor if such activity wore t

d'scovered.

Tearing bodily harm to themselves or loved ones, cascado hall security guards would be strongly motivated not to report such anomalion.

Onlino enrichment monitoring to dofoat nuch a scenario would not be practical, because of the very great number of detectors that would have to be employed.

This scenario could bo defeated, however, by the use of reliable tarper-proofed monitoring devices for sampling ports, procens valves, and flanges.

Rollable valve monitors, which could be used for those process connection locations, are under development at Sandia National Laboratories and should be avail-able in 1992-93.10 With a complete set of tamporproofed monitors for process connection locations, utilized with authenticated transmission of data to a central computer, it would be a simple matter to rollably keep track of timos for employee access to process connection locations, and to compare cumulativo access times with data in the applicant's FNMC plan.Il l

10 Telephone communication:

Cecil sonnier, Sandia National Laboratories, to Helen M. Hunt, July, 1991, 11 Id.

as4r-'7v4[

-m virvv y'wer -Www' - -W7w77-sw.yw

-yve'>+r-my er 1ew-per"4 w&e?

v*ecr--=e-e**=mp,u-en-e-++r--er-'g+n"re*.-N=e-w-e-ei-e+em+ev--wu-wrww-wte-

-