ML20134L159
| ML20134L159 | |
| Person / Time | |
|---|---|
| Issue date: | 06/04/1975 |
| From: | Gossick L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Lyon H ENERGY RESEARCH & DEVELOPMENT ADMIN.(PRESENTLY DOE) |
| Shared Package | |
| ML20134L162 | List: |
| References | |
| NUDOCS 9611200177 | |
| Download: ML20134L159 (6) | |
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^ "i lir.11. E. Lyon, Director Division of Safeguards and Security Energy Research & Development Administration Washington, D.C. 20545
Dear fir. Lyon:
We have reviewed the draft " Annual Report to the National Security Council on the Status of Domestic Safeguards" enclosed with the memo-randum of P.ay 20,1975, from fir. Robert E. Tharp, and offer the fol-lowing suggestions for revision of the draft. -
We believe that in the transmittal letter the second sentence in the second paragraph should be changed to read as follows: "This report has been coordinated with t.M Nuclear Regulatory Comnission." We also reco: mund deleting the lnt sentence of the second paragraph which indi-cates a separate report Lay be submitted by the Nuclear Regulatory Coanission.
On page 13 of the draft report, we strongly disagree with the suggestion that "... the liational Security Council seek Congressional support for JW directing the liuclear Regulatory Comission to accept the major features of ERDA-developed safeguards and security measures and principles for new reactor concepts and related fuel cycles." We feel that this pro-posal is definitely contrary to the intent of the Congress that the liuclear Regulatory Com:nission function as an indapendent regulatory acency.
As hn indapendent agency, the !!uclear Reculatory Comission provides a much needed " check and calance" function which can definitely strengthen our Nation's safeguards system by developing regulations independent of the research and development phases. Accordingly, if the suggesti.on is included, it should be made clear that (1) the suggestion expresses only an ERDA view and (2) the Huclear Regulatory Connission does not agree with that view.
The rationale for classifying the report is not clear to us. He feel consideration should be given to publishing the report as unclassified.
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6 Mr. II. E. Lyon, Director Division of Safeguards and Security Energy Research & Development Administration Washington, D.C. 20545
Dear (4r. Lyon:
We have reviewed the draft " Annual Report to the National Security Council on the Status of Dorastic Safeguards" enclosed with the rumo-randum of--May 20, 1975, from Mr. Robert E. Tharp, and offer the fol-lexing suggestions for revision of the draft. -
We believe that in the transmittal letter the second sentence in the second paragraph should be changed to read as follows: "This report has been coordinated with the Nuclear Regulatory Ccamission." We also reconi:end daleting the lest sentence of the second paragraph which indi-cates a sepsrate report uay be submitted by the Huclear Regulatory Co=iissi on.
On paga 13 of the draft report, we strongly disagree with the suggestion ;
that "... the National Security Council seek Congressional support for '
directing the Nuclear Regulatory Connaission to accept the major features Wii of ERDA-developed safeguards and security measures and principles for new reactor concepts and related fuel cycles." We feel that this pro-posal is definitely contrary to the intent of the Congress that the '
liuclear Regulatory Comission function as an independent regulatory agency.
As an independent agency, the Hac1 car Ragulatory Comission provides a much needed " check and oalance" function which can definitely strengthen our Nation's safeguards system by developing ragulations independent of the research and development phases. Accordingly, if the suggestion is included, it should be made clear that (1) the suggestion expresses only an ERDA view and (2) the Huclear Regulatory Connission does not agree with -
that view.
The rationale for classifying the report is not clear-to us. We feel consideration should be given to publishing the report as unclassified.
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Mr. H. E.1, yon Addjtional comments are set forth in the enclosure to this lettar.
f ..e We would expect a final draft to be returned for Cor.raission review.
Sincerely.
lS hn.wiu Leo V. Gossick Executive Director for Operations
Enclosure:
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i Enclosure 1 i
Page 4, top paragraph: i 1
Add the thought that (1) the NRC is conducting a security agency
- 73;
' ' ' study as mandated by the Energy Reorganization Act and (2) the types of questions raised in this paragraph are being considered as part of that study.
Page 5, bottom paragraph: t As an editorial comment, it appears that the reference to Exhibit 2 may be ambiguous; i.e., Exhibit 2 to this report vis-a-vis Exhibit 2 to the Lynn letter.
Page 8, item 2:
This item should state that similar links will be established between the FBI and the NRC and between the CIA and the NRC.
Page 8:
In the pa"agraph preceding the heading " Improvements in Safeguards" add a sentence such as the following:
"The NRC prepared a detailed description of significant events in the 1RC safeguards program for special nuclear material
- q' *;, and related facilities for the year 1974 which is contained in Enclosure 2."
The above referenced enclosure was transmitted to the Office of Safeguards and Security on March 5,1975. An additional copy is enclosed as Enclosure 2 to this letter.
Page 9, bottom line:
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Change " Commission" to " Atomic Energy Commission."
Page 10, line 5:
4 Change the phrase "... five kilograms of contained fissile material" '
to ".. 2 kilograms of Pu as U-233 or 5 kilograms of U-235 contained in uranium enriched to 20% or more in the U-235 isotope."
Page 10, bottom paragraph:
Add the thoughts (1) that the purpose of the entrance search is to ,
deny introduction of firearms, explosives, incendiary devices, and other !
things which could be used to sabotage the facility or aid in the theft of 1 t Q:b%
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1 SNM; (2) that the purpose of the exit search is to deny exit of unauthorized l SNM; and (3) that, as will be noted subsequently, the NRC is developing a clearance program for access to unclassified SNM. l 9 Page 11, last sentence: i 1
Make clear that the purpose of the October 1974 amendments was to further strengthen the regulations for the control and accounting of SNM.
Page 12, first sentence:
Consider revising the sentence to read:
"The protection measures which were discussed in Section 3 above and which are intended to deny forced access-also protect against forced removal ."
Page 12, third paragraph:
Add the following statement:
"The NRC is commencing a concerted effort to develop stronger liaison with the FBI and other appropriate agencies in an attempt to develop pertinent contingency plans designed to guide government action in the event WM ' of special nuclear material removal and/or emergencies at licensee facilities."
Page 13, last paragraph:
Substitute the following material for this paragraph:
" Legal authority has been obtained for requiring that access to SNM or to SNM accountability records be limited to persons with clearances (PL 93-377). Methods of implementation are under study. Duplicate record systems, local and central, and shipper-receiver measurements also reduce the risk of deceit.. Requi re-ments for control and accounting of SNM were revised to provide greater sensitivity and timeliness for de-tecting theft or diversion. NRC initiated and is developing a program whose goal is the control of and accounting for material on a real-time basis. NRC also is undertaking the application of diversion-path analysis in order to (a) identify weaknesses in material control systems and (b) develop methods for detecting possible or attempted diversion of special nuclear material."
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Page 14, second paragraph: I Revise the first sentence to read as follows:
"During 1974, new rules for protection of SNM in transit were applied to all licensees and transportation companies (10 licensees and 5 transportation companies) which are authorized to protect transport shipments of more than 2000 grans of Pu or U-233 or more than 5000 grams of U-235 contained in uranium enriched to 20% or more in the U-235 isotope."
Page 15, Section 8 and 9:
Add the following at the end of this paragraph: .
"The NRC plans to establish similar li ia son."
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