ML20128N799
| ML20128N799 | |
| Person / Time | |
|---|---|
| Site: | Claiborne |
| Issue date: | 02/26/1992 |
| From: | Curran D HARMON, CURRAN, SPIELBERG & EISENBERG, LLP. |
| To: | Brady R NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| FOIA-92-103 NUDOCS 9302230413 | |
| Download: ML20128N799 (14) | |
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- HARMON, CURRAN, GAllAGIIER'& SPIELBERG:
2001' S STREET,-N.W. -
SUITE - 430 ;--
WASHINGTON, D,C.; 20009 1125-P TElulIONE -
GAIL McGRIEVY HARMoN
- (202) 328 3500l DIANE CURAAN '
FAX '---
' ANNE SPIIIEERG
.(202) 528 4918 :
JANNE G. GALLAG!!ER ERIC IL GUTIENSTELN 1992' KATHERINE A. MEYER -
February 26, ERIE 00M 0F INFORMA JES$1CA A. LADD -
30T REQUEST-BY HAND f:oZ4-42H03
^
Raymond J.
Brady, Director NRC' Division of' Security-h h 2-2/
h:
Office of Administration-Washington, D.C.
20555-
SUBJECT:
. Freed _Qm of Information Act and' Declassification D quest re:
Claiborae EnrichmeAt Center. Docket No. 70-3070-ML
Dear Hr. Brady:
On behalf of Citizens-Against Nuclear Trash (" CANT"),.and'pur-suant-to the Freedom of Information Act ( " FOI A), S ' U. S. C. -
552(a)1ea seg., 10-C.F.R 'S 95.45,1 _and Executive. Order:12356 (April 2, is82), I am-writing to request that"the Nuclear:
Regulatory C ommission L(NRC".or " Commission") declassifyand release certain information pertaining to the-proposed-design-of:
the Claiborne Enrichment Center (" CEC")._'This request for:
declassification is supported by the attached affidavit ofL nuclear safeguards consultant. Helen;M. Hunt.
Ir$ particular, CANT requests: declassification of' the diameters Lof1 CEC's_ process piping at potential.online enrichment ~ measurement:
s points.1-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 _-
ports, process valves,'and flanges. : CANT needs this information-in order to meaningfully: challenge the!adequacyiof nuclear:
-Safeguards used to ensure that_the-CEC's.centrifugeLequipment-is not unlawfully diverted _to the surreptitious productioncof.. bomb
~
1-While CANT _would prefer to obtain the exact diameters of CEC process pipes'at. potential online enrichment monitoring-
-points, it would be sufficient for purposes'of: evaluating:the adequacy of _ the plant's safeguards to -know the aooroximate _.
pipe diameters at'these' points, i.e.,
whether they are. greater:
than.110 mm. (inner diameter).
93022304131920226-
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PDR< FDIA ICURRAN92-103.
PDR.
J.. i
e HAHMON, CURRAN, GAU.AGilER & SPIEL.UERG 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, e uranium enrich-ment center, in Homer, Louisiana.
LES is a partnership of five companies which includes Urenco, U.S.A.,
a subsidiary of a Euro-pean consortium known as Urenco, Ltd. ("Uronco").
Urenco is owned by the British and Dutch governments and by NUKEh, a group of German companies.
CANT is a citizens' environmental organization, based in Homer, Louisiana, which has inteivened in the licensing proceeding for the CEC.
On December 19, 1991, the Atomic Safety and-Licensing Board ( " AS LB") admitted, intel Alin, - CANT's contentions L and M, which challengo the effectiveness of the CEC design to provide reasonable assurance that the CEC is not unlawfully divorted to the surr (i.e. bomb grade) uranium.gptitious production of highly enrichedContention L chargos that in order sonable assurance that gas centrifuge equipment at-the CEC is not unlawfully diverted to the production of highly enriched uranium (HEU), LES should require continuous or frequent online enrich-ment ponitoring for all cascades.
To ensure the effectiveness of such monitoring, the plan should stipulato minimum process pipe -
inner diamotors 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 the planncd pipe innor diameter for the CEC is 3.07 inches, which 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 valvec, and/or flanges, IIS' Fundamental Materials control ("FNMC") plan should require effective monitor-ing by reliable technical means which accurately keep-track of employee access to these process connection locaMions.
It is CANT's position that LES should be required to install reliaole tampor-proof monitoring devices for sampling port 9, process 2
The full text of these contentions is attached.
3 Telephone communication:
Potor LeRoy, LES, to Helen M.
Hunt, June 11, 1991.
liAl MON, CUlutAN, GAI.I.AGilElt & SPil:1.nr.itG Raymond J.
Brady rebruary 27, 1992 Page 3 valves, and flanges.
With a cumplete set of tamperproof monitors for process connection locations, utilized with authenticated transmission of data to a contral computet, it would be a simple matter to reliably keep track of times for employee accccs 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 dinmeters and the existence of tamperproof monitoring devices for process connection locations is classified.
According to Lois Telford 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 process connection monitors.
Standard for Classification 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 from disclosure under the Act.
5 U.S.C.
5 552(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 naticnal defense or foreign policy and (B) are in fact properly classified pursuant to such Executive Order.
5 U.S.C.
5 552(b)(1)(A) (emphasic added).
Executive order 12356, which sets forth substantive and procedural criteria for with-holding national security information under Exemption 1,
- permits, jnter p_)ln, 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:
a In no case shall information be classified in order to conceal violations of law, inefficiency, or administra-tive error; to prevent embarrnssment to a person, orya-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.
D l
IIA 1010N, CUlutAN, GALLAGilER & SPIELBERG Raymond J.
Brady February 27, 1992 Page 4 Spqq Algg Carlisle Tirq 3 Rubber Co. v. U.S. Customs Servig.g, 663 F.2d 210, 217 (D.C. Cir. 1980) (af firming requirement for inde-pendent determination of whether national security requires clas-sification requested by a foreign government); Lamont v. Depart-ment of Juqtisa, 475 F. Supp. 761, 772 note 42 (S. D.N. Y.
1979) (Courts "have a duty to look behind any claim of exemption, which all too often in the past has been used'to cover up inef ficency or embarrassment even in foreign policy matters -
which, many tines, are fully known by other countries but not
, gunting-120 Cong. Rec. 36626 (Nov.
printable in our own.
20, 197 4) (Rep. Reid, R-NY).
Information Should be Declassified CANT requests that the NRC reconsider its agreement to provide classification for the requested safeguards information, becaura such classification fails to satisfy the criteria for withholding-under the FOIA and Executive Order 12356.
Classification of approximate process pipe diameters and information regarding the existence of tamporproof monitoring devices is not only unnecessary to protect national security, but it thwarts any pub-lic debate that might result in the stIRD9thCDing of safeguards for the CEC.
Would-be misusers of the CEC already have much of the general information to which CANT seeks access.
The only.
purpose served by classifying it will be to protect Urenco from any public criticism that might lead to stronger safeguards at the CEC.
Process pipe diameters To our knowledge, the CEC is the first plant for which any Euro-pean government has completely classified process pipe diameters.
The approximate, or in some cases, exact, diameters of the pro-cess pipes in Urenco's European facilities have never before been classified; in fact they have been presented freely in open safeguards literature.
In the literature cited below, for exam-ple, exact pipe diameters for Urenco's Almelo~and Capenhurst plants are cited freely.
Approximate diameters are also given.
for Urenco's Gronau plant.
It is also commonly understood that pipe diameters substantially less than 100 mm are "small," and greater than 100 mm are "large."
In addition, many unclassified papers have been published which-discuss the relationship between pipe diameter and feasibility of online enrichment monitoring.
For instance, a brief review of current safeguards literature yielded the following information:
4 n
IlhMMON, CUltitAN, GAllAGilEll & SPIEL.HEltG Raymond J.
Brady February 27, 1992 Page 5 1)
Product pipes in some cascados at the Urenco facility in Almelo, Netherlands, have an outer diameter approximately 42 mm and an inner diameter approximataly 36 mm.
The literature on safeguards for gas centrifuge enrich-ment plants consistently describes those pipes ac "small-diameter pipes."
K. van der Meer, " Enrichment Verification on UF6 in Low Pressure Process Pipes:
An Application of the Two-Geometry Method," Proc. lith ESARDA Cymposium, Luxem-bourg, 1989, ESARDA 22, p.
179.
2)
Product, vaste and dump pipes at the Urenco Capen-hurst f acility in the United Kingdom have inner diametecs of 110 mm.
The saf egua rds 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 Header 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.
- Lauppe, B.
- Richter, G.
Stein, " Assessment of NDA Techniques for the Cascade Areas of Centrifugo Enrichment Plants,"
Proc. 11th ESARDA Symposium, Luxembourg, 1989 ESARDA 22, p.
463.
4)
Product pires in some casc4 les at the Ningyo Toge uranium enrichment pilot plant in Japan are of small to medium diameter (less than 80 nm outer diameter).
M.
- Hori, T.
- Ishiga, M.
- Akiba, A. Tani and M. Oman, "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 onlino 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
pg,1 note 3, p upnl.
IfARMON CURRAN, GAllAGilER & SPIF.UlERG Raymond J.
Brady February 27, 1992 page 6 Brady, et al.,
to Robert M. Born dated Sep-from Raymond J.
Forolyn Trip Travel Report.gro, tember 9, 1991, re:
Thus, general information about the dimensions of Urenco gas centrifugo enrichment facilitics, and even specific information about the pipes at the CEC, in already available to the public through a variety of means.
It is also well known that Urenco florcely opposes any requirement to enlargo CEC pipo diameters at potential measurement points in ordor to utilizo onlino enrich-ment monitoring.
Yet, the inadequacy of CEC pipe diamators for safeguards purposes currently cannot bo litigated in NRC licens-ing hearings for the CEC because the pipo diamotors are clas-sified.
Classification of the information thereby improperly
" thwart (s)" the " sunshine purposon" of the Freedom of Information Act and stiflos in portant public debate about the adequacy of safeguards for the CEC, without serving any national or interna-tional safeguards interests in protecting truly secret informa-tion from discionure.
Iapont1_pepuinen.t_oLJup1193, 475 F.
Supp, at 772.
In fact, it appears that Urenco's ownern, the governments of Germany, Great Britain, and the Netherlands, havo repeatedly sanctioned the release of information regarding process pipe diameters.ht other Urenco plants.
Thus, release of this informa-tion for the CEC would not threaten thcGo foreign governments' security interest in maintaining confidentiality.
The gnly interest which appears to be served by classifying this informa-tion is Urenco's and LES' wish to avoid embarrassing litigation or public debate over the safety of the CEC, or the expense of up3rading the plant's safeguards design and equipment -- c1carly an invalid rationale for classification under Executive Order 12356 and the FOIA.
Description of monitoring devices For the same reasons, CANT also seeks declassification of information pertaining to whether or not the proposed denign of the CEC includes reliable tamper-proof monitoring devices for 5
Three days later, the NRC sent out a replacement page with the pipe diameters deleted.
A cover memorandum requested that the corresponding original page be destroyed, but conveyed no sense of urgency and gave no explanation whateoever for the substitution.
Memorandum f rom Theodore S.
Sherr to Those on attached list, dated September 12, 1991, re:
Replacement Page.
r IIAllMON, CUltilAN, GAI.I.AGilEll & SPillllEltG Raymond J.
Brady February 27, 1992 Pago 7 sampling ports, process valves, and flanges.
As discussed in CAllT's contention M, it is pJrndy publicly known that the design for the CEC does not include such devices.
Thus, naintaining official secrecy regarding the issue does nothing to protect the common defence and security.
In fact, it has the opposito ef fect, by protecting LES and Urenco f rom criticism or challengo in the public hearings regarding their inadequato safeguards sys-tem.
Once again, there are no legitilnato cecurity bases under Execu-tive Order 12356 and the FOIA for withholding this information from the public.
Therefore, CAliT requests that the llRC declas-
,1fy information regarding the existence of reliable tampor-proof monitoring devicou for sampling ports, process valves, and flanges in the applicant'n FHMC.
If, for any reason, you deny this request, please provido a dio-cunnion 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' licence application for the CEC is now underway.
While no hear-ing date has been set, completion of the liRC Staff's Safety Evaluation Report, which would trigger the cummary 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 disecvery as soon as possible.
Pl' ease do not h<mitate to call me if you have any questions about this letter.
Sincerely, (f
u u
Diane Curran Attachments:
1 Af fidavit of lielen M.
Ilunt 2
CAliT's Contentions L and H cc: ASLB Service 1ist (w/o attachment 2) 11RC Commissioners Donnie Grimsley, liRC FOIA Officer
Attechmerit 1 AFFIDAVIT OF IIELEN M. IlUNT IIelen M. Ilunt, 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. Bmdy, 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.
1 d4 Helen M. Hunt Signed and sworn to before me this ? b day of February,1992.
o
,E@l No' tary Public
//
My conunission expires _/19 8' (CN
/
February 26,1992
\\
Statement of Professional Qualifications IIELEN hl. IlUNT P.O. Ilox 530 Princeton, New Jersey 08542 Nuclear Safeguards Positions:
Director, Nuclear Materials Safquards Project,1991 Founder and director of organization dedicated to strengthening national and inter-notional safeguards for the purpose of reducing the likehhood ol unauthorized acquisition of fissile materials for nossible use m nuclear weapons.
Independent Consultant on Nuclear Safeguards,1990 91 Testified before U.S. Department of Energy regarding safeguards issues in DOE nuclear weapons complex; prepared critique of plutonium health hazards study prepared by City of New York for proposed siting of nuclear warheads in New York liarboy at the 1991 European Safeguards Research and Development Association symposmm, proposed a solution to the uranium enrichment measurement problem for gas centnfuge plants.
Consultant to the Nuclear ControlInstitute, Washington, D.C 1958 90 Investigated and reported on critical weaknesses in nuclear safeguards; demonstrated that nondeaructive assay methods are not employed in a way that would allow detection of several kilograms 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 weakner es in Japan's nuclear safeguards program; discovered that current online uranium enrichment measurements are not working for many gas centrifuge enrichment plants.
Edycation:
13.A. in mathematics from Cornell University,1965 M.A. in mathematics from Princeton University,1971 Graduate courses at Princeton University on security and environmentalissues, 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, Los Angeles, California, July 15-18,1990, 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.
- - _ - - - - - ~ _ _. - - ~ _ _ _ _ _ - _ - - - - _ _ _, _,, _ _ _,,. _ _ _. _ _ _ _,, - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _, _ _ _ _ _ _ _ _ _ _ _, _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _, _ _ _ _ _ _ _
Attacle.cnt 2 CANT SAFEGUARDS CONTENTIONS L AND H 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 (llEU), the applicant's fun-damental nuclear material control (FNMC) plan should require con-tinuous or frequent online enrichment monitoring for all cas-cados.
To ensure the effectiveness of such monitoring, the plan chould stipulate minimum process pipe inner diameters of 110 mil-limeters or greater at all potential measurement points.1 The current design of the CEC dono not meet these specifications.2 BASIS:
On December 17, 1990, the NRC published a proposed rule cetting forth "new performance-based material control and dCCounting requirements" to be applied to enrichment facilition.3 1
Minimum precess pipe inner diameter nhould be 110 mm if uranium hexafluoride gas pressure in the pipe is relatively high, an at the Capenhurst plant in the United Kingdom.
Ege T.W. Packer, " Continuous Monitoring of Variations in the U235 Enrichment of Uranium in the lieader 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 muut 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 Capenburst 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 Applicati-on for License, etc., 56 Fed.
Reg. 23,310, 23,313 (May 21, 1990).
detectors can be ovaded too easily.
Because HEU gas could be removed from a centrifuge cascade in a very short time upon a decision to terminate use cf 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 inspectorn 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>
ately high ratio (i.e., at least 1:1) of the amount of U235 in 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 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-agement (May 14-16, 1991) at 363-64. 6.
Ese alng Packer, Attachment 15.
~4~
- diameter, i.e., greater than 110 mm inner diameter.7 Actual recommended pipe diameter at a potential measurement point would depend on gas pressure in the pipe.8 Proposed pipe diameters in the CEC design, however, are significantly smaller.
According to URENCO representative Peter LeRoy, the planned pipe inner diameter for the CEC is 3.07 inches, which is about 78 mm 9 At this pipe diameter, the uranium deposit that would build up on the pipe wall would, within months or a few years, dominate the online enrichnent measurements.
Because of associated large measurement uncertainties, online enrichment measurements would then not be capable of reliably determining whether low enriched or highly enriched uranium hexafluoride gas is present in a pipe.
The CEC design should therefore be modified to increase the pipe size at measurement points to a degree that will permit adequate enrichment monitoring.
M.
Monitoring of Sampling Ports, Process Valves, and Flanges In order to preclude or detect production of HEU by a batch recycling scheme involving misuce of campling ports, process valves, and/or flanges, the applicant's FNMC plan should require effective monitoring by reliable technical means which accurately 7
Communications:
Trevor Packer, Harwell Lab; UK, and Ben Dekker, Uronco, Netherlands, to H64en M. Hunt at ESARDA meat-ing, May 16, 1991.
8 Fee note 41, sunra.
9 Telephone communication:
Peter LeRoy, LES, to Helen M.
I Hunt, June 11, 1991.
-~
keep track of employee access to theco process connection loca-tions.
BASIS:
Compliance with proposed 10 C.F.R. $ 74.33 (c) (5) (1) requires offective monitoring of all product streams.
Production of HEU by a batch recycling scheme involving introduction of feed and withdrawal of product through campling and process valvo ports is a credible scenario in a gas centrifuge enrichment plant.
Misuse of other process valves (not having ports) could be a component of such a scenario.
Onsite production of HEU could be carried out discretely by as few as one or two produc-tion employees.
For this reason, NRC Draft Regulatory Guide DG-5002, 5 12.2, " Monitoring Program for Clandestine Enrichment Scenarios," requires the applicant's FNMC plan to address, intat alla, " 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 flanges."
Use of seals has been only partly reliable, however, because it has been possible for plant production personnel to remove seals from valvo ports -- in order to perform process monitoring -- without promptly replacing coals in a verifiable manner.
Monitoring of such HEU production by human surveillance would not be reliable.
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
6-contrifuges, they might not be soon by an individual who walks the halls.
Moreover, individuals walking huge deserted cascade halls, listening and looking for signs of criminal production activity, could be in great personal danger if d6ch activity were v
9 discovered.
Fearing bodily harm to themselves or loved ones, cascade hall security guards would be strongly motivated not to report such anomallos.
Online enrichment monitoring to defeat such a scenario would not be practical, because of the very great nurber of detectors that would have to be employed.
This scenario could be defeated, however, by the use of reliable tamper-proofed monitoring devices for sampling ports, process valves, and flanges.
Reliable valve monitors, which could be used for these process connection locations, are under development at Sandia National Laboratories and should be avai1~
able in 1992-93.10 With a complete set of tanperproofed 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.11 10 Telephone communication:
Cecil Sonnier, Sandia National Laboratories, to Helen M.
Hunt, July, 1991, 11 yg,
. _ _ _ _ - _ _