ML20148M759
| ML20148M759 | |
| Person / Time | |
|---|---|
| Issue date: | 07/31/1977 |
| From: | NRC OFFICE OF POLICY EVALUATIONS (OPE) |
| To: | |
| Shared Package | |
| ML20148M724 | List: |
| References | |
| NUDOCS 8012240028 | |
| Download: ML20148M759 (86) | |
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.i g;g)j NRC BREFING-BOOK -- TABLE OF CO.VTENTS qq V. p.
Volume II p~
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' VI . [.. 5.i DGESTIC SAFEGUARDS E :
- 1. Domestic Safeguards
- 2. General Safeguards Activities =,
- 3. . Major Safeguards Accomplishments since November 1976
' 4. hhfor; Safeguards Objectives for FY 1977 E g
- 5. Vil Liberties Implications of Nuclear Safeguards '
T >2 guards Backup Information. ' VII. . INTERNATIONAL '
- 1. U.S; Government Nuclear Export Functions "i
- 2. NRC's Export Licensing Functions
- 3. Export-Import Licensing Regulations ..
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- 4. Internhtional Reach of NEPA and Public Health and Safety '1
'5. Nonproliferation Legislation 6.. Intervention Petitions ..l T. ASCO.II Spanish Reactor
- 8. IAEA Safeguards and Physical Security , :
9.. Worldwide Nuclear Safety
'10. International Regulatory Cooperation SEPARATE CLASSIFIED SECTION, PROVIDED UPON REQUE,..
_ 11. Suppliers' Conference G 5 12s Yugoslavia .
'13. Continuing Discussions with India :
- i VIII'. RADIOACTIVE NASTE biANAGE>EhT 1.. Radioactive Waste h!anagement
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- 2. ERDA Role in Radioactive Waste bhnagement
- 3. Radioactive Wastes and Associated hhnagement Technologies
'4 S-3: Environmental Impact of the LKR Fuel Cycle
- 5. Uraniua Mill Tailings 1
- 6. Spent (Irradiated) Fuel Storage
- 7. Low Level Waste hhnagement :
- 8. Decommissioned Nuclear Facilities :
- 9. Article, "Tne Disposal of Radioactive Wastes from Fission Reactors."
- 10. ACRS Report on Management of High Level Radioactive Wasto ,
IX. NRC/5 FATE: RELATIONS
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- 1. General Statement concerning State ivolvement in Nuclerv Issues
- 2. NRC and the States -- Partnership in Regulation ;
- 3. Section 102 Study
- 4. Agreement States . .a
- 5. Memorandum of Understanding Concerning Water Quality *
- 6. Scheduling of Joint Hearings with 3ew York State
'7. Infomation on SINB and WGREPO
- 8. Information on Nuclear-Related State Initiatives i..
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. AMI} Voltrae II (Continued) s v;
X. CONGRESSIONAL / LEGISLATIVE
- 1. Congressional Comittees with Jurisdiction over NRC
- 2. NRC Authorization and Appropriation Bills for FY 78 3 1.R.18 - Legislation to Streamline the Licensing Process XiC Memorandum on NRC Legislative Proposals i
,egislative Status Report on Energy Facility Siting Legislation vtary List of NRC Appearances at Congressional Hearings XI. ;RRENT ISSUES !
- 1. Clinch River Breeder Reactor l;
- 2. The Price-Anderson Act
- 3. S.M
\ -- Public Reporting of Inventory Differences #
- 4. Radiography Overexposures i
- 5. Increasing Public Participation '
- 6. Seabrook Nuclear Power Plant
- 7. Diablo Canyon Nuclear Power Plant
- 8. Conran Allegations Concerning NRC Safeguards
- 9. Current Litigation i ;
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DOMESTIC SAFEGUARDS TABLE OF CONTENTS E
- 1. Domestic Safeguards
- 2. General Safeguards Activities
- 3. Major Safeguards' Accomplishments Since November 1976
- 4. Major Safeguards Objectives for FY 1977
- 5. Civil Liberties Ino,lications of Nuclear Safeguards
- 6. Safeguards Backup Information I
- a. Detailed history, sumary, and overview of NRC safeguards activities
- b. Projected tasks and scheduling for safeguards upgrades.
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;. 9 6.. g f.- D2IESTIC SAFEGUARDS v i The Atomic Energy Act, as amended, recogni::ed the need for nuclear .
safeguards, and in 1974 the Congress underscored the importance of this activity in the Energy Reorganization Act, which provided for the establishment in the new h2C of an Office of Nuclear Material Safety and Safeguards. The Federal Government, industry, and the general public have come tc, focus sharply on the safeguards issue. The need to develop and inplement adequate safeguards for the varicus , civilian uses of nuclear power has grown substantially, not only in correspondence with the increasing use of nuclear power but also because of public concerns stemming from the escalating number of terrorist-type incidents in the United Stites and E abroad. Tne Administration and the public are also concerned about the potential proliferation of nuclear weapons among present non-weapons countries. In the pasc two-and-a-half years, NP.C has built and staffed a rather substantial safeguards organization, laid the foundation for near and long-term policies on safeguards, and has begun to implement these policia. In this effort, we have been guided by our statutory mandates to:
-- provide and maintain safeguards against threats, thefts, and sabotage;
-- conduct a continual review of safeguards at all regulated facilities, including but not being limited to ronitoring, testing, and recommending upgrading; and
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-- reco=aending and coordinating necessary research. !,
Over the past year and a half, NRC has directed an intensive I inspection and evaluation program aimed at detecting safeguards problems at fuel cycle facilities nuclear power reactors, and during transport of weapons-usa,ble nuclear caterials. Our various evaluations de'termined that specific improvements ' were needed both in terms pf physical security and in material ' control and accounting. In February 1977, firal rules for upgraded physical security requirements at power reactors were published. In July 1977, proposed rules involving safeguards of SSN'4 at licensed activities (fuel cycle facilities, transportation, and some research reactors) were published.
'. Domestic Safeguards - 2 (ti i;;.
Fuel Cycle Facilities i;;
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hRC currently licenses 12 fuel cycle facilities which possess b significant qt.antities of special nuclear material (greater i than 5 kg of uranium enriched to at least 20 percent U-235, ' or greater than 2 kilograms of plutonium or U-233). E Protection against theft, diversion, or sabotage of S21 ' at fuel cycle facilities such as fabrication plants involves both physical security and material control and accolating. However, significant improvements in material control and c
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accounting are difficult to achiave, in many caras requiring more advanced technology. Facing the fact that existing material accounting procedures for SDI could not guarantee that the material unaccounted for was still in plar.t, ARC decided that rigorous physical security and access control , over SSI was the most positive way to provide assurance that diversion had not occurred. _- Therefore, ARC concentrated on strengthening physical security , through changes in license conditions. Among the new requirements at fixed sites were:
-- increased nudaers of guards and weapons;
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-- expanded use of intrusion alarms in SM! p' rocess areas, h and improved tamper-resistance of alarm circuits; I
-- additional protection of central alarm s cations against unauthorized access and small arms fire;
-- improved capabilities of secondary alam stations;
-- specific guideliner on use of deadly force by guards;
-- more stringent controls over acces.; to S2i;
-- more stringent searches of personnel, packages, and vehicles;
-- strengthening of barriers containing SE!;
-- improved liaison and communications between the facilitics and local law enforcement officials. ,
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l 1 Domestic Safeguards - 3 I' [.. i..: Transport of Soecial Nuclear Material h Three companies currently have NRC-approved transportation plans for shipments of significant quantities of special nuclear material. A special evaltution of transport of special nuclear material 7. , includ.d, with the cooperation of the Department of Defense, ~ simulated attacks on transport as well as intensive study of routes and conr.anications. As a result, NRC imposed new license conditions, including: -
-- a ninimum of five amed guards accompanying the shipment;
-- shipment of the SL! in either an amored vehicle, or a vehicle of speial design with an amored cab and penetration-resistant cargo compartment;
-- additional communications equipment; -
-- all shipments to be made on primary highways only;
-- if the shipment cannot be completed during daylight hours, a second esccrt vehicle and two additional guards must
( accompany it;
-- any transfer from road to air transport must be monitored by four guards in co cunication with either the local police or the air teminal guard forces.
Nuclear Power Reactors There are presently 64 NRC-licensed nuclear power reactors which are subject to safeguards rules. . Nuclear reactor facilities present different safeguards problems than those connected with fuel cycle facilit.ies and transportation. Reactor safeguards are aimed at preventi g acts of sabotage which could endanger the public health and safety through releases of radioactivity to the environment. - NRC's regulatory approach has been a conservative one -- although there is no conclusive evidence that acts of sabotage would be attempted, NRC has elected to require improved physical security at licensed nuclear power plants. '
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t.. if Domestic Safeguards - 4 (s.. i Newly imposed regulations utilize a phased approach to implementation . da of the new requirements. Some security program features were required to be in place by May 25, 1977, while others are to be y(; , completed as soon as poss N e, but no later than August 24, 1978.
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The May 25 requirements dealt with the organization and procedures ; of the total security progren, such as: '
-- operation, t*aining, and supervision of the security force;
-- search of incoming persons, packages, material, and vehicles;
-- use of security. badges; h Y
-- visitor control; in 0
-- liaison with local law enforcement officials; '
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-- response to security contingencies; .
- presence of a noainal 10 armed, trained individuals, with at least five armed, trained guards on each shift with p primary responsibility for responding to security problems. -
Also on May 25, each power reactor licensee and applicant had to submit an amended physical security plan for NRC evaluation and , approval. The improvements to be completed as soon as possible, but no later than August 1978 involve procurement and installation of major equipment items and construction of buildings. These ' features include:
-- security intrusion detection systems; ,
-- reduadant comunications with law enforcement authorities;
-- incorporation of dedicated alann stations; m
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-- installation of such surveillance aids as upgraded lighting and closed circuit television. '
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t a ( _ GENERAL SAFEGUARDS ACTIVITIES, The Comission intends to continue its efforts to provide b high assurance protection against therts of St! by internal : conspiracies and violent assaults by detemined individuals or groups. This involves both short-range and long-range = regulatory activities. E As part of IGC's long-range activities, a proposed safeguards- ie upgrade rule was recently published idtich will strengthen is. safeguards for all licensed SS.41 activities,' including fuel ! cycle facilities, transportation activities, and research M reactors. In contrast to earlier safeguards improvements, the Comission intends to implement these further upgradings
.through public rulemaking.
The safeguards revisions which were proposed define systems and subsystems required for both fixed site and transport physical protection programs. They m uld also define design . , basis-events against which the licensee should protect, and the ' perfomance capabilities which the physical security program must possess. t. 4 iz The systems and subsystems defined in the proposed revisions k are, in general, required at present, b2t in the context of the F new regulations they will be subjected to evaluation of - perfomance capability, Considerable flexibility is afforded each licensee to meet the stated perfomance objectives, thus . allowing the rust cost-beneficial choices for each site. Thus, although some hardware changes would probably be required, ; high costs to the licensees from the proposed revisions are not anticipated. Among the chief improvements proposed are the numbers, quality, and equipment of the gum;d forces. l As with the previous regulation, implementation of the improved safeguards m uld occur in two phases. , r The first phase, or " interim upgrade" would require licensees L to. submit modified physical security plans for increasing if their physical protection against theft and radiological sabotage, either by an external terrorist group or by acts of an insider. F The second phtse, or " final upgrade," calls for further modifications by the licensee describing added physical security and material control measures they would implement to protect against theft or radiological sabotage by internal conspiracies. o - l l l ! I l' o b
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General Safeguards Activities - 2 )y::q pb... s .. r a yj Tne Comission recently issued for public coment a proposed <1 rule which.would require a security clearance for all individuals 0 involved in the operation of nuclear power reactors and fuel k {p reprocessing facilities, in the licensed use, processing, or storage of certain quantities of S?ct, and in the private sector y transportation of certain quantities of S01. This clearance _ Fi requirement should provide substantial additional protection e against an insider attempting sabotage. '" In an additional effort to' improve licensees' security organizations, the NRC has issued for public coment a proposed '". regulation covering the qualifications, training, and equipping , of guards and other security personnel.
.A comprehensive safeguards evaluation program nas been initiated for licensed SSSI fuel facilities and transportation activities. .
Tne Commission approved the program earlier this year, and , site evaluations are under way at selected locations. Evaluations are being made against perfor ance-oriented requirements which will provide an assessaent of safeguards as against current and proposed requirements. Input from these evaluations, which include " black hat" assessments, will be i-reflected in a final version of the proposed safeguards upgrade rule. 4 5 F- [ f [ a 4 k
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r- htOOR SAFEGUARDS ACCOMPLIS!NENTS SINCII Nom!BER 1976 g ..
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- 1. Published for public coment a proposed rule for physical security L.
F upgrade of fuel cycle plants, transportation, and research reactors. 5 2 m Published for public coment a proposed rule on the use of force E by licensee guards.
- 3. Published a final rule on safeguards at nuclear power reactors.
- 4. Published for public comment a proposed rule for safeguards I
contingency planning. .
- 5. Published for public connent a proposed rule regarding qualifications, training, and equipping of guards.
- 6. Published for public coment a proposed rule requiring security clearances for certain licensee personnel.
- 7. Developed prototype safeguards contingency plans for typical operations! - ~
- 8. Initiated steps to require classification of security plans at licensed facilities.
- 9. Initiated development of NRC headquarters safeguards contingency
, plan.
- 10. Strengthened license conditions for protection of SSDi. ,
- 11. Generated framework for evaluation of research and technical assistance efforts.
- 12. Established new policy for regulatory guides on safeguards.
- 13. Developed comprehensive evaluation plan for facility / transportation safeguards, and initiated evaluations of SS21 facilities.
- 14. Prepared inventory difference data for pending release, in b j
cooperation with ERDA and with guidance from the National Security Council. '
- 15. Assisted in developing technical support plan for IAFA. !
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- 16. Drafted provisional list of facilities eligible for IAEA safeguards. l
- 17. Initiated negotiations with IAEA to develop subsidiary arrangements for U.S.-IAEA agreements. ,
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hf MAJOR' SAFEGUARDS OBJECTIVES FOR FY 1977
- 1. Upgrade physical protection for SS.NM in fuel facilities, in transit, P,.
and at research reactors. E ..."
- 2. Implement rule on safeguards 'at power reactors. y*
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- 3. Complete a' major study of role of material accounting. ~
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.4. Release of inventory difference (material unaccounted for) to public. .
- 5. Implement contingency plans through rulemaking. :
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- 6. Implement National Security Council decision to classify inventory w difference information and security plans of fuel cycle facilities .j and reactors. 7
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- 7. Restructure present low enriched uranium regulations. '
- 8. Provide direction for NRC safeguards research i
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- 9. Develop systems for trend analysis and early warning. -
- 10. Continue safeguards evaluations. n j :. .
W 11. Prepare for implementation of U.S.-IAEA safeguards agreement.
- 12. Develop NRC-wide safeguards program plan. ,
- 13. Improve communications with the U.S. intelligence community.
- 14. Complete first round of comprehensive safeguards assessments of fuel facilities and transportation. '~
- 15. Initiate comprehensive safeguards assessments at power reactors. ,
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k g CIVIL LIBERTIES D TLICATIONS OF NUCLEAR SAFEGUARDS E5 {. 2
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;:r ml The possible impact on civil liberties are acong the matters considered f
in assessment of proposed safeguards systems. As port of that E consideration, the NRC comissioned five reports on the civil liberties - R implications of nuclear safeguards, in order to obtain a broad range ! of non government opinion on tne questions involved. ,
.a The five reports, which have been made public, explore a relatively new '~
area of social concern and provide valuable infomation for considering " civil 3iberties matters ar, an aspect of NRC's GESMO (Pu recycle) '~ proceedings, for existing and the>m are considered e,mlicable to safeguards upgradings facilities. The consultants generally agree on the importance of minimizing the potentLa impacts of safeguards activities on civil liberties guarantees, as contained in the Constitution and defined by the Courts. The reports also note hat civil liberties questions associated ', ; with nuclear safeguards must be weighed against the impacts on civil liberties resulting from possible energy shortages if nuclear power is removed as a possible source of energy or if nuclear materials are stolen, t The consultants recontended certain actions to ninimize civil liberties impacts, including:
-- appropriate safeguards procedures; .
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-- advanced contingency planning
-- strict NRC control over personnel clearance and information classification systems;
-- strict linitations to prevent abuses in infonnation gathering activities.
Many of the consultants' reco=endations are extensions of considerations already applied to the current safeguards program. , Tne of reports civil recomend liberties full public participation in the consideration , questions. The NRC wholeheartedly agrees. This will be achieved through a public coment process and public hearings, as considered appropriate. i i i i i
DETAILED HISERY,'SUMRY, AND OVERVHM OF NRC SAFEGU.\RDS ACTIVITIES Y_ I. THE SAFEGUARDS PROBLEM A. Definition and Backgrrond . ii2 ' The development of the nuclear industry as part of the nation's energy E supply system presents a potential for increasir.g the risk of harm to the general public from: (1) theft or diversion of strategic special nuclear material (SS :tl) which can be fabricated into a nuclear explosive device or used for dispersal of radioactivity; and (2) sabotage of nuclear material. or faciliti^s leading to dispersal or radioactivity. Actions of either type may appeal to dangerous elements in society. Such elements could include criminak, motivated by personal gain (from sale of SS!!M or by extortion); extremists, exerting pressure for socio-political or economic change; and disoriented persons seeking revenge for some perceived wrong. While no antisocial incidents involving theft or sabotage are known to have occurred within the nuclear power indus,try in this country, there have been several in other nations with minor s consequences. There have also been an increasing number of nonnuclear - incidents of terrorism in this and other countries ever the past several years. .. Groups that could in theory take malevolent action against nuclear plants or naterials occupy a wide spectrum; however, there is no current or historical evidence that any orgc sized or known groups presently intend to commit such acts of sabotage, theft, or diversion. For purposes of establishing security controls, two categbries of groups are considered most likely to constitute a threat in the future. These are: (1) a small group of individuals possessing the highest motivation and skill needed to achieve their goals, including a willingness to receive and inflict casualties, and equipped with hand-held automatic weapons; and (2) disgruntled employees with access to nuclear fuel industry operations and thus capable of acting covertly. B. Purpose of Safeguards Safeguards are defined as those measures employed to deter, prevent, or l respond to (1) the unauthorized possession or use of significant ; quantities of nuclear materials throuch thef t or diversion; and (2) the l sabotage of nuclear materials and facilities. The !!RC safeguardsiprogram l has the gentral objective of providing a level of protection against such l acts that will insure Gainst significant increase in the overall risk of 3 n death, injury, and property damage to the public from other causes beyond the control of the individual. To te acceptable, safeguards must take [c -1 realistic account of the risks involved and of burdens on the public in L terms of civil liberties, institutional, economic, and environmental impacts. E L:
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2 C. Importance of fluclear Safeguards The nature of special nuclear material with its potentially high risk The to ' the public denands that proper security precautions be observed. general increase in terrorism has heightened concern overSuch the possibility of attempted sabotage or seizure of materials for illicit use. _ E that, although no actual attempts are known to have occurr#, in the U.S., public awareness and concern is growing because of this in publicity . concern liferation. from the standpoint of limiting worldwide nuclear weap enacting the Energy Reorganization Act of 1974 (ERA) assigned the Nuclear Regulatory Commission increasing responsibilities for safeguards. II. IIRC SAFEGUARDS RESPONSIGIt.ITIES AMD ORGANIZATION Mithin the HRC, the Office of Nuclear Material Safety and Safeguards (ONMSS is charged by the Energy Reorganization Act of 1974 with responsibility for licensing and regulation of all nuclear facilities and. materials associatedTh with reprocessing, handling and transport. for upgrading, testing, and monitoring nuclear material accounting systems ONMSS per-and developing contingency plans to deal with emergency and its Director acts as spokesman for the Commission on safeguards matters. Uithin ONMSS, the Division of Safeguards is immediately responsible for program The OUMSS organization is shown on Chart 1. development and implementation. These dutiesInspection, are performedresearch, and standards in other major the NRC safeguards functions. programmatic offices as indicated on the overall NRC organi (Chart 2). In addition to these directly budgeted resources, NRC obtains on Chart 3. assistan-e fron, and works in close coordination with, other Federal, state, and local agencies. III. URC SAFEGUARDS PROGRAMS Current programs are directed at protecting against thef t or diversion of cer-tain types and quantities of nuclear materials that could be used for nuclear explosives or contaminants and protecting against the sabotage of facilities and materials. requires a license in order to own, acquire, deliver, receive, possess, use,The NR transport, import or export special nuclear materials. , H safeguards requirements for materials and plant pro If items of noncompliance or deficiencies are found in the implementation o saf eguards requiremer.ts by the licensee, the licensee is instructed The flRC has the to take prompt corrective action to inform the URC of 'the results. a on licensees for noncompliance with the items and conditions of the license. l
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.m .A. Safeguards Responsibilities ,z ,,
llRC exercises safeguards oversight by a series of rulemaking, licens'ing, and operations monitoring activities.
- 1. Rulemaking g; ,
M .. ..i The !!RC sets forth, .via a public r.ulemaking procest. , safeguards practices b which the industry must follow. Such regulatory guidance is then used - l by llRC staff to determine if plant designs, SNil shipments, or other e R 9
. materials handling operations proposed by commercial groups are acceptable. Industry, intervenors, and members of the public partici-pate in the rulemaking process.
- 2. Licensing When a company desires to build a plant or utilize special nuclear a material, an application is made to the .MRC. The licensing staff reviews such proposals against the rules and developed guides. The ,
safeguards review, conducted separately from the safety and environ-mental analysis, is an integral part of the llRC's evaluation. If the K . proposal clearly meets fiRC's rules for safeguarding nuclear operations, the finding is positive. In cases where more stringent safeguards are needed, .but are not clearly specified by the regulations, the license , may be approved subject to additional license conditions. Such add-on conditions become legally binding as long as the license is in
. effect. Also, if i!RC finds a licensee's material control and accounting or physical security deficient af ter operation has begun, license con-ditions, specific te a particular plant, may be imposed to correct specific deficiencies. ,
- 3. Operations Monitoring The NRC inspects licensee operations periodically to assure that effective safeguards measures are being followed. The inspectors review activities against overall safeguards rules and the operator's license conditions; and also assures the adequacy of the prograra's overall effectiveness. Inspection frequency varies with the type of operations (degree of safeguards risk). At highly enriched uranium and plutonium fuel plants, for example, more frequent inspections are made to revie.! j the operator's material control and verification methods and to check [. ,
his physical protection measures. Both announced and unannounced I t inspections are employed to audit the licensee's compliance with Federal F requirements. Finally, inspections are made periodically to establish that materials shipments are being conducted according to established , security procedures and '. hat proper accountabili ty . controls are maintai bq 7
- 4. Contingency Planning The Energy Reorganization Act of 1974 charges llRC with the responsibility for developing ". . . contingency plans for dealing with threats, thef ts, f
- and sabotage relating to special nuclear materials, high-level radio- (;
active wastes and nuclear facilities resulting from all activities E licensed under the Atomic Energy Act oi 1954, as amended." l 5 i y 't v l
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Al methodology has been developed that 'provides for the systematic ' development of safeguards contingency plans which will give guidance, y for licensees 'and NRC staff, in the event of threats, thefts, and M
, sabotage. -
j4 A safeguards contingency is ' defined as any unuwal or nonroutine event Q $ that ' requires the execution of security plans and procedures not k W normally performed on a day-to-day basis. The safeguards staff at.the W d licensed facility is responsible for anticipating .and dealing with them 5 effectively. E A safeguards contingency plan is a documented plan developed to respond to threats, thefts or sabotage in connection with SNM of nuclear facilities licensed by the URC, in such a way that, if normal safeguards , fail, SNM will be held secure or recovered and/or nuclear facilities will be kept secure or restored to a protected condition. Contingency plans contain: (1) a predetermined set of decisions and actions re-quired to satisfy stated objectives; (2) an identification of data, criteria, procedures, and mechanisms necessary to make and carry out the decisions and actions efficiently; and (3) a specification of the individual, group or organizational entity . responsible for each decision and action. The HRC has developed a methodology for determining when a . given threat or situation should be perceived as serious; and has focused efforts on constructing a base for the assessment nf information from other Federal agencies. ,
. Interagency Agreements. An important aspect of contingency planning is a knowledge of all available resources and of the means to mobilize them should they be needed. To obtain this knowledge, the HRC staff has established contact with 60 organizational elements of 23 Federal agencies and two national associations. Interagency agreements, in which the~ .
procedurcs will be clearly defined in writing and the options and resources identified, are being drafted with those agencies and organizations that have been found of potential help in responding to safeguards contingencies. These agencies include the Energy Research and Development Administration, the Federal Bureau of Investigation, the Central Intelligence Agency, the Secret Service, the Department of State, components of the Department of Defense, the Coast Guard, the Federal Aviation Administration, and others. Incident Response Center. URC has established an Incident Response Center (IRC), with on-call duty officers available for responding to events arising outside of normal working
- hours. Its facilities and ,
procedures are currently being upgraded. Information Assessment Team. To ensure prompt, coordinated action on all information regarding threats to licensed nuclear facilities and materials, the NRC has also established an Information Assessment Team (IAT). The team is responsible for rapidly reviewing the authenticity of sources and data on each reported threat and determining the .q
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seriousness of the threat. It then recommends a course of action to be taken by MRC management. _.) [
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A prototype licensee safeguards contingency plan was prepared by !!RC for the Plutonium Fuels Developmant Laboratory of the Westinghouse .... Corporation, and a plan for safeguarcfing highway transportation of S: lit p was developed with the cooperation of Tristater iotor Transit Co. , in ' order to verify and demonstrate the llRC methodology in actual appli-cation. A regulation has been drafted which would require licensees authorized to possess significant quantities of S:;M to develop and use i safeguarcis contingency plans.
- 5. Research A high priority was placed by Congress on the ability of the hRC to obtain the research necessary to discharge its regulatory responsibility with regard to nuclear safeguards. Following the impetus established by the ERA, l'RC initiated a strong safeguards confirmatory research effort.
In addition to obtaining research services through its own budgetary process, iiRC draws heavily upon nuclear safeguards research conddcte;d s by the Energy Research and Development Administration and the Defense ' fluclear Agency. The t'RC safeguards research program supports the decision-making process involved in ru'lemaking, licensing, operations monitoring and contingency planning. -
- 6. International Safeguards flRC is responsible for licensing the export of nuclear materials. In discharging this responsibility the iiRC utilizes information provided by the Executive Branch agencies, and cooperates with those agencies on export control matters. Additionally, i1RC works with the international atomic energy agencies and other nations to strengthen the international safeguards regime.
B. Overall Sa feguards Delgations i The specific responsibilities for implementing portions of the ilRC safeguards l program are as follows- ' 1 The Commission nahes overall policy determina tions. j; The Office of iluclear flaterial Safety and Safeguards is responsible [ for: i-Identification of safeguards policy or program weakness; [ Overall safeguards progran development; h Recomaending safeguards research and technical assistance efforts; F All safeguards licensing except for reactors; P Analysis of safeguards related informtion; and E Coordination with ERDA on common safeguards programs and policy [ matters.
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The Office of Standards Development is responsible for: Standards and codes; and - Recom.nending safeguards research needed for standards development. The Office of lluclear P,eactor Regulation is responsible for: Development of safeguards evaluation plans for reviert of reactor license applications; Safeguards licensing of reactors; and Recommending reactor safeguards research. The Office of Inspection and Enforcement is responsible for: - Development of detailed inspection programs; Inspection of licensees for compliance vlith regulations and license conditions; Enforcement of requirements; Investigation of abnonaal occurrences ini.ading theft or diversion of S lil; and .- Recomending safeguards research based on inspection results. The Offict of Nuclear Regulatory Research is responsible for: Detecining jointly with HilSS and others the safeguards research requirements; Planning and implementina the safeguards research pregram; Coordinating the safeguar6s researcn work with the cognizant fiRC technical staff; Assuring appropriate dissemination within NRC of the results of safeguards research; and Coordination with ERDA and other government agencies on safeguards research. ( C. Relationships With Other Agencies
- l. Responsibility for implementation of the nation's nuclear safeguards system is spread among several agencies and organizations. For example:
Energy Research and Development Administration (ERDA) implements safeguards in nuclear activities in ERDA license-exempt operations and conducts research related to safeguards technology. Defense Nuclear Agency (DNA) implements safeguards for the protection of nuclear weapons and conducts research related to safeguards technology.
I 7_ y 5.. q Intelligence gathering responsibilities are shared by: Federal,,. - state and local. law enforcement agencies. The repelling of an initial overt
- action is currently the responsi-bility of the licensee supported by the local law e.iforcement 3.
I. , agency. k The responsibility for recovery of stolen material is assigned to E the Federal Bureau of Investigation assisted by the Emargency
. Action and Coordination Teams of the Energy Research and Develop-ment Administration. flRC would, of course, work closely with the agencies involved in recovery operations -to supply pertinent information needed by the recovery teams.
- 2. NRC/ERDA Cooperation The Energy Research and Development Administration, which is rcsponsible for researching and developing alternate energy resources, including-nuclear energy, has authority over certain nuclear facilities of'the; e' U.S. Government. The !!RC is concerned with regulation for safety,-- '
environment and safeguards primarily in civilian nuclear activities, but also including certain of ERDA's operations. It is desirable that nuclear safeguards applied by flRC and ERDA be consistent, since the - purpose for safeguards is the same in both areas. In order to maintain comparability and encourage mutual reinforcement in their respective safeguards programs, flRC and EP,DA adopted, in 1976, a working agreement committing both staffs to close and continuing cooperation. The agreement encompasses conu ngency planning, safeguards measures for facilities and transport. evaluative methodology and , criteria, long range planning, research requirements, technical assistance studies, and international programs. Also in 1976, the tuo agencies collaborated in a joint report to the flational Security Council on the status of domestic nuclear safeguards, making recommendations for the strengthenirig of both of their programs. A significant area of IIRC/ERDA cooperation was launched on f4 arch 12, 1976, when the llRC Chairman and tha ERDA Acministrator met with top officials of the two agencies to review the safeguards status of nuclear ((.
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fuel cycle facilities licensed by l!RC and processing fuel under ERDA h -1 contracts. A joint action plan was adopted to detornine the overall
}L status- of..present safeguards ccntrols at these so-called mixed f acilitics i.:
(involved with both NRC and ERDA), which handle significant amounts of y 1 high-enriched uranium or plutonium, and to recommend any necessary irgreva p. . ments. As a result of tast force findings, the team recommended that di "q measures be taken to improve the security of future operations. The NRC' W is developing a timetable to provide for such an upgrading of safeguards.
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IV. SAFEGUARDS PROGRAM ACTIVITIES
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A. Concerns During the Past Year . The area of nuclear safeguards--those . measures used to prevent the theft h or diversion of nuclear materials or the sabotage of nuclear facilities-- Z was one of intense study. evaluation and activity during the past year. P This section will cover significant developments and decisions related to E dcastic safeguerds. Domestic safeguards for licensed nuclear materials and facilities are an increasingly important element in the overall llRC guidance and standards program, as well as the research needed to confirm or revise them. Safe-guards are an important aspect of MRC's review of license applications fur reactor and fuel cycle operations and a major concern in HRC's inspection and enforcement activity. Regulations related to safegua.ds are primarily set forth in 10 CFR Part 73, " Physical Pr otection of Plants anc' Materials," and 10 CFR Part 70, "Special Nuclear ilaterial." The protection of special nuclear material (SiM), whether in use, in trunsit or in stonge, is the principal objective of safegu6rds. SN:-) means (1) plutonium, uranium-233, uraniume ' nriched in the isotope 233 or in the isotope 235, and any ottier material which the Coalission, pursuant to the provisions of section 51 of the Act, determines to be special nuclear material, but does not include source material; or (2) any nieterial artificially enriched by any of the foregoing but does not include source. material. The continuing development and expansion of the nuclear power industry has prompted continual review and upgrading of safeguard.; requirements. B. Developing Safeguards Policy The Commission's continuing assessmtnt of licensee perfernance in the 1 safeguards area during 1976 proceeded fro:. two basic questions: Are , present-day safeguards satisfactory in terms of present needs? and, What ' new or augmented measures will be necessary to protect in the future? More specifically, the Commission focused on the following kinds of critical safe-guards questions:
- Unat are the crucial securi'.y problems facing nuclear licensees?
- What are the highest priority safeguards .research needs?
- What level of protection is adequate?
- What are the surest and most efficient means by which to enhance (1) transportation security, (2) fuel plant protection, (3) reactor protecti_a, and (4) material control and accounting?
- Should current " systems-oriented" regulations, whicn specify how a re-quired objective is to be met, be. supplemented with " performance-oriented" regulations, which focus on the goal and allow a licensee flexibility in going about meeting it?
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- What kinds of tests are demanded to provide assurance that industry security systems are affording the necessary degree of protection?
- Are workable contingency plans in place to guide response to any .
attempted thefts or attacks? Are safeguards early warning systems s'ufficiently fast and reliabic p to thuart overt or covert attacks against nuclear plans and materials? In seeking a resolution of these quest' ions, the NRC made three fundamental policy determinations from which to approach all safeguards issues. Fi rs t , ' while NRC must define the levels of safeguards protection needed and incorporate them into performance oriented regulc tions, the licensees them-selves will have primary responsibility for designing safeguards systems, making security improvements, and maintaining the capability to assure that nuclear plants and special nuclear materials were ef fectively protected. NRC will continue, through inspection and enforcement, to assure that licensees are complying with applicable requirements and performance criteria for implementing safeguards. Second, NRC would establish, with a high degree of confidence, that safeguards systems were satisfactory by use of such improved techniques as on-site validations and operational readiness tests 9 to probe for weaknesses in the system, or the revamping of data systems to speed the flow of vital security information to the. proper licensee personnel and to the NRC. The third policy"oetermination was that nuclear safeguards will be tailored to the degree of risk associated with particular materials and facilities. For example, low-enriched uranium does not pose the same security problems that high-enriched uranium or plutonium does, and safe-guards prescribed for their protection snould differ accordingly, C. Safeguards Upgrading Over the past year, improvements have been made at all fuel cycle facilities to assure protection against hypothetical threats of determined, violent assaults by highly motivated and skillful assailants, willing to receive and inflict casualties, and actively aided by a facility employee in any position, including that of guard. The N.C considered protection against a insider participation in an attack, a vitally important element of its pro-tective program. These improvements followed a series of on-site assess-ments at each facility by NRC staff teams including visits by a specially constituted NRC-ERDA task force. The improvements made include: additional guards; greater capabilities for communicating offsite in an emergency; inproved capabilities of a:larm systems; better search and surveillance procedures; formalized procedures for support fro:n local lau enforcement agencies; and strengthened controls over access to nuclear materials. Similar assessments and upgrading of transportation safeguards also were made. Upgrading was accomplished by increasing the number and tra" ling of escort guards and the installation of a backup communications capability. Additional measures in the transportation area will be implemented shortly. Four companies are now authorized to transport strategic quantities of plutonium and high enriched uranium.
1lhile noting that the available evidence, including communications from cognizant Federal aoencies, does not indicate that an attack on licensees. is likely, the liRC considers such an attack cannot be wholly discounted and prudence dictates that protection should be increased. In this re-gard, the NRC will conduct a rulemaking to establish, through public P proceedings, upgraded interim safeguards reovirements and proposed longer term upgrading actions. The objective cf the rulemaking is to consider additional safeguards measures to counter the hypothetical threats of internal conspiracies among licensee employees and determined violent assaults which would be more severe than those postulated in evaluating the adequacy of current safeguards. Interim actions to be considere! in the rulemaking include: (1) increasing the capability of weapons supplied to guards; (P) improving guard training; (3) requiring strategic special nuclear materials (SSNM) licensees te employ additional safeguards measures, as the staff determines necessary at each facility or for each transport company, to defend against an external threat having the capability of a determined assault more severe than that currently postulated; (4) a security clearance program for employees with access to SSNM; and (5) other measures which may, for the ir.terim, be utilized to increase protection against internal threats of theft or diversion of SSNM. D. Material Control and Accounting Systems L Material control and accounting measures can be categorized according to their purposes into three groups as follows:
- 1. Access controls which restrict access to sensitive materials or records to those individuals who need such access in the performance of their job functions.
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- 2. Containment mechanisms which protect against removal of SSMM from its ;
authorized location. I i
- 3. Accounting systems which provide assurance that no significant quantities of material have been misdirected.
These approach:s are mutually reinforcing; no one of them can be fully effective alone. Various combinations of the three approaches are employed j to provide the levels of protection against diversion required for specific j plaats and materials, and some physical security measures act to reinforce i material controls. In 1976, the r'aterial control and accounting systems at licensed fuel cycle plants were significantly upgraded through implementation of improved fundamental nuclear material controls. Additional checks and balances were built into the controls and accounting systems, new controls were established within plants to localize losses and to provide increased
. i:;:i custodial controls, validation procedures for material shipments were in-
' proved, the accumulation of scrap was limited and regular recovery was .
provided, and procedures were established to provide current knowledge of the location and quantities of-items and containers of special nuclear material, expand repo,0n 23, 1976, a proposed amendment to the regulation to August m rting requirements for accounting information was issued for G public comment, but this amendment has not as yet been made effective. g During the year occurrences of inventory discrepancies at the Nucibar Fuel Services plant located near Erwin, Tennessee, and the Babcock and Wilcox plant at Apollo, Pennsylvania, were comprehensively investigated to determine causes for the nonrandomness of these events. Significant im-provement in performance was achieved at the Erwin plant through improved measurement and control procedures. ~ While NRC investigation has not been completed at the Apollo plant, some improvements in accounting and control procedures have already been - implemented. - gq A senicr NRC task force was estab.lished on April 27., 1976, toprovideI comprehensive review of the role of material control and accounting in safe-guards. Within URC there has never been an overall review of the functions ' of these activities and an assessment of the best methods for implementing
. these programs. The purpose of the study is to (1) identify the functions ,
and capabilities of material control and accountina, (2) assess current license requirements in the light of these, and (3) establish the framework and path for future programs. . Site Evaluations J E. In January 1976, the NRC began a special review of safeguards which focused on fuel cycle facilities possessing strategic quantities of highly enriched i uranium or plutonium. Evaluations were made at 15 facilities to assess the b l: ef fectiveness of their physical protection and material control programs. I; J The review teams studied the licensees' ability to meet current regulations [ and judged their safeguards capabilities against specified threat levels. [ Although there are no specific threat levels defined in the MC regulations, -{' p-the levels used for this review consisted of an internal threat involving one employee, occupying any position, and an external threat coriprising, at f. a minimum, three well armed, well trained persons who might have ,inside F i knowledge or assistance. Safeguards em?loyed by licensees were expected f to le sufficient to defeat these threats. - l Heaknesses were found at each of the 15 facilities, the most prevalent re- p , lated to. control of access to strategic quantities of SUM (both stored and ~ d in process), exit search procedures, and adequate of renponse by orsite and n rb_ i 1 ___ _=
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and offsite security forces. The review teams were satisfied that short - tern measures could correct most of the deficiencies and that some couid be a resolved by procedural changes alone. During their initial review, the =d teams found that the guard forces of some licensees were reluctant to engage L... . an attacking force, due in part to a' lack of strength in numbers. ['Q R -- Of the 15 facilities involved in the review, eight were judged adequate to 31 withstand both the postulated external and internal- threats. Of the re- M maining'seven, one was judged adequate to protect against the external threat i only, and four were judged adequate to deal with the internal threat only, while two were inadequate to deal with either threat. Correction of these . safeguards deficiencies was monitored by !!RC staff using existing inspection, enforcement and licensing procedures and including the imposition of plant- , specific license conditions All fuel cycle ~ licensees were required to achieve the capability by the end of August 1976 to withstand, at a minimum, the' internal and external threats postulated above. To confirm that this -
' capability was achieved, NRC a".sessment/ evaluation teams again visited all fuel cycle operations involved during September and October 1976 and-found that the safeguard capability at all facilities was sufficient to meet the ;
design threats under the evaluation. criteria applied. The " safeguards upgrading" previously discussed reflects these actions toward continued im-provement of the safeguards posture. t
.. F. Safeguarding Power Reactors tiRC continued to emphasize safeguards'for nuclear power plants during 1976, and initiated major efforts to evaluate current physical security at operating plants and the need for new regulations. At the end of the fiscal year these efforts were nearing completion. In February 1977, the !!uclear Regulatory Com1ission amended its regulations to specify detailed require- -
ments for the protection of nuclear power plants apinst industrial sabotage. Adoption of these measures--to protect the public health and safety--followed , the intensive staff review of the entire regulatory approach to safeguards over the past two years. , The new provisions spell out flRC requirements for the physical security organization which must be maintained, including the size of the on-site i response force, and for the control of access to and within the nuclear power ' plant. Other security provisions relate to communications, alarw stations, searches, liaison with local law enforcement. authorities, visitor controls, : 3 monitored isolation zones around physical barriers, and bullet-resistant construction for vital areas such as central alarm stations. and reactor control rooms. Regulations established in December 1973 require licensees to submit plans 9 for protecting nuclear power plants against sabotage, but those regulations did not specify particular requirements for such plans. Those plans, re- - t, viewed and approved by the regulatory staff of the former Atomic Energy - Com1ission and now in effect, include seme of the provisions contained in , the new amendments. I
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( While no such threats have occurred, the ilRC determined that, both as a 3 matter of prudence and to serve as a basis for judging the adequacy of safeguards system designs, physical security programs should be able to. protect against:
- 1. a determined violent external assault, by stealth, or deceptive actions, by several persons who are well-trained (including military training and skills) and dedicated; these persons could have the assistance of a knowledgeable insider and be armed with automatic weapons equipped with silencers; they also could have incapacitating agents and explosives to gain entry or otherwise destroy reactor integrity; and
- 2. a threat of an irisider in any position, including a guard, i_
In conforming to these general requirenents, the physical security system ) J
'must meet specific requirements in the areas of security organizatio6 3 q !
(including size of response force), physical barriers, access requirements, j i alarm systems, and cercaunication testing and maintenance. In addition to U O several changes in these specific reqirements, the new rule clarifies re- B R quirements for actions by a qualified guard force and for the nominal size -
- i of a well-trained on-site response force. I I
Licensees must implement requirements concerning security organization, i i access, communications, and testing and maintenance, as well as the require- I ments for on-site response force capability, within 90 days of publication l in the Federal Reaister. They also must submit amended security plans for [ llRC approval within 90 days, and will be required to implement these amended j' plans as soon as practical after approval; for some measures (for example, I those requiring construction), licensees will be given up to a year and a half to comply with all provisions of this anendment. The amendments permit [L-the llRC staff to approve alternatives to the rau requirements if they are l found to be equally effective in providing protection. fr l G. Vulnerability Analysis of Land Transport t. L i It has been widely believed, though unsubstantiated, that transportation is the weakest link in the safeguards system; however, moving security p vehicles have, almost uniquely, been excluded as targets of terrorism in h the last decade. In the spring of 197G, the ilRC conducted a series of P field tests of transportation vulnerability, with tha assistance of the U.S. Army Special Forces that evaluated the road transportation systea on routes which had carried more than 75 percent of the special nuc1 car naterial O( transported by truck in 1975. The joint test team observed shipments, h evaluating the routes, equipment cnd procedures employed, communications, and the availability of police response in case of erargency. The test ( b identified arcas where vulnerability could be reduced. Resultant imposition p of new license conditions materially improved the security of truck transport. 4 The most important of the new requirements were the addition of an armed k q-f aa,_ra.
;; E escort in a separate vehicle for all shipments, the addition of -
appropriate communication equipment (including Citizen Band Radio), and the provision of supplementary training for security personnel. All of [ .. these actions were implemented by llay 1976, and ilRC-monitored shiprents E since then have used the improved systems. i N The route vulnerability assessment also demonstrated the desirability of f y increasing the awareness of local law enforcement authorities of their i role as response forces in the national nuclear safeguards effort. This was H partially accomplished, relative to the highway transport of Silli, dtring S police interviews, in one phase of the route vulnerability assessment. The C llRC effort to develop strong ties with local law enforcement agencies will f continua in the form of llRC-developed programs which increase their awareness of the role of law enforcement in safeguards, close staff liaison, improved cross-coimunications systems and other cooperation.
'In February 1977, specific license conditions were issued to further upgrade the level of protection afforded to shipments of strategic quantities of ST M. These new requirements included the use of an armored transport vehicle, a significant increase in the number of armed guards used to escort the shipment and monitor transfers, restricting travel to daylight hours on major highways (a second escort vehicle required when night travel is performed) and improved communications capability. The present level of protection is considered to be comparably effective to that required by ERDA.
H. Vulnerability Analysis of Fixed Sites After the general results of the vulnerability analysis of transportation were released several licensed nuclear facilities volunteered to cooperate in similar assessments of the vulnerabilities at their sites. During the year vulnerability appraisals were made at three sites. The vulnerability analysis methodology included observations of plant activity; discussions with guards, facility security management, other facility employees, and police; and a detailed appraisal of the methods and equipment which hypothetical adversaries could be expected to employ in the thef t of SD1. The results of these analyses have been used to increase ' the security awarenes's of facility management and assist l!RC in its con- ' tinuing evaluation of safeguards at licensed nuclear facilities. ' Unile emphasizing current safeguards considerations, tiie vulnerability b analysis program also considered potential systems and procedural changes F for the long-term and provided useful data upon which decisions about the , safeguarding of nuclear material have been based. In the coming year data from this program will continue to be a part of a comprehensive evaluation effort directed toward assisting the program of safeguards upgrades. p i 1 9n-......._..__ _.
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b I. Security Agency Ltudy Findings The third fiRC undertaking mandated by the. Energy Reorganization Act was the deternination of whether a Federal security agency was needed to safe-guard commercial nuclear operations, and if it was feasible to create suca F an agency within the i!RC. Of concern in this regard were nuclear power reactors, certain fuel plants, and special nuclear materials. The basic question was whether the licensees, in concert with local law-enforcement bodies, could prov;de adequate armed security personnel with appropriate back-up resources, or if Federal guards were called for. Sixteen criteria, based mainly on consultants' reports, were used by URC to compare the effectiveness of private and Federal guard forces. The criteria included: general and local security knowledge; mental and physical fitness; alertness; motivation; arrest power; authority to use deadly force; chain of command and controllability during crisis; compatibility in normal
' operations; liaison with offsite forces; and weapons. Other issues cortsidered in the study included the role of offsite reaction forces; administrative implications for licensees and imC; and the possible use of Federal security forces from other agencies, fiore. than 300 persons contributed to the study, including special contractors to report on soecific aspects of the issue, '
and consultants frcm the Federal Cureau of Investigation, the Department of Defense, the Department of the Treasury, the U.S. llarshals Service, and the
. Energy Research and Development Administratiin.
As a result of the study, the flRC conclud'ed, and reported to the Congress on , September 7,1976, that there is no need at this time to create a Federal i Security agency within the NRC to protect commercial nuclear facilities frcm !' sabotage and nuclear materials from theft or diversion. The creation of l a special security force within flRC would not result in a higher degree of t guard force effectiveness than can be achieved through the use of private I guards who have been properly trained and certified by f1RC. The study identifies means by !hich guard forces could be upgraded through the im-position of new requirements under current authority. The study also con- l cluded that new legislative authority would be necessary for the creation or y a guard force within ilRC. { A salient finding of the security agency study was that no difference in h potential impact on civil liberties could be discerned between the use of !' Federal and the use of private guard forces. p J. Research h p The development and initiation of i:RC's Safeguards Research Program has as E its major goal the initial development of methods for evcluating tha h effectiveness of safeguards systems in early 1978 with further developn.;nt b and improvement during FY 1973 and 1979. Therefore, with few exceptions, F .; results from the major safeguards research projects are not capected in q FY 1977. However, some near-term efforts have produced the follouing [i accomplishments related to the shorter term needs of the fiRC Safeguards f P rogram. j
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In FC 1976, a review of regulations concerning the control 'and accounting l of. Siti, to identify the manner of. immediate changes that could be made to' l . improve the effectiveness and efficiency bf the material control and - accounting systems, was . completed. It was concluded that the most . h;E Ei effective and efficient way of improvi.ng the material. control and accounting b system in the near-tera was to place more-reliance on. material controls and
- less on currently used techniques for. material accounting. One related x.y .
recommendation would require licensees to analyze their material control y system to: identify the possible existence of credible diversion routes.- . A report'on."Tha While Collar Challenge to fluclear Safeguards" was completed y in December 1976. The study defined the characteristics of white 1 collar crime that require consideration in the design and evaluation of safeguards. l systems; and concluded that the achievement of safeguards' objectives with j respect to the white-collar adversary may not be. completely. assured by 0 achievina conpliance with existing safeguards procedures. The report is g;
' being _used to evaluate potential diversion and theft of Sill 4 by employees at t:j licensed. facilities. '"
' An assessnent' of mathematical models for evaluating mixed-oxide interim safeguard rules was completed. The report concluded that, while there are l some evaluation models of limited utility available, there were no _,
techniques sufficiently developed, in scope or detail, to fully test safe- .i guards for compliance to performance requirements. 3
.j Sabotage vulnerability studies of existing light water reactors were ' {
completed, and concluded that nuclear power plants have inherent resistance i to sabotage due to their safety-based designs and construction. The j complete, classified reports were used in the preparation of (1RC's new , 1 regulations (10 CFR 73.55) concerning physical security at nuclear reactors , and continues to be used by the Office of Huclear Reactor Regulation (tiRR) : as an aid to evaluation of reactor designs and security systems. Finally, the research on methoos to evaluate effectiveness of' fixed site . physical protection have produced some simple methods for relating the l ability to detect an adversary attempting to gain unauthorized access to the time required for guard response. ~j d K. Progress (liilestones and Accomplishments) Summary , In 1976, staff work focused on defining the safeguards task expressed in the i Energy Reorganization Act and taking prelirnary actions to reduce the risk _j of illicit use of special nuclear material. 3 H
- dorked with other government and nongovernment agencies to ascertain d most probable threat. y
- Deterained adequacy of licensee's physical protection measures through 6 field assessment of all major facilities, a j
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' Required licensees to take ircediate improvement action where ,
evaluations showed weakness. 7 Identified safeguards issues of most inrnediate concern to public
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- Strengthened material controls to prevent loss or theft that would g endanger the public. '
- h Developed a model . contingency plan to minimize risk to the public that could~ arise in connection with threats, thef ts, or sabotage at nuclear facilities.
-- P.oviesed material accounting problems at two nuclear facilities and required corrective actions to be taken.
Developed t'achniques for probing licensee safeguards systems for
. weaknesses outside normal inspection methods.
Assessed the vulnerability of nuclear material shipments. Major security improvements resulted from changes initiated as a result of the assessments. Completed a mjor policy study for Congress. , u, .
- Isactivi a federal guard force necessary to protect commercial nuclear 4' ' N ty? Security Agency Study" (T!ct at this time.)
Assessed the safeguards implications of using ' recycled plutoniu.i in 'LURs (GES!!0 Supplement). :
- Completed a Special Safec;uards Study and a joint ERDA/ftRC review of safeguards associated with fuel plants . handling large amounts of SiiM.
V. OTHER ACTIVITIES A. f!RDC Petition During the year, the Commission denied a petition by the flational Resources Defense Council to take " emergency" action to close doun certain nuclear fuel plants or order immediate changes. In denying the ;etition, ilRC
. stated that a significant upgrading of safeguards had aiready taken place and that additional measures were under implementation. Thus, while recognizing the need to continually improve security, the f!RC denied that an emergency situation existed. IIRC continued to implement mtasures to improve safe- ...
guards systems, and moved toward the development of performance-oriented regulations that wot.'d establish higher protection levels which the nuclear
'(h industry would have to achieve, based on specific threat levels. L p
B. Plutonium Study ex To aid in reaching a decision on the proposed widescale use of mixed oxide p (H0X) fuel in light water nuclear reactot 3, the llRC continued througi:out ;f the year to develop an environmental impact statement in accordance with p the flatinnal Environmental Policy Act of 1969. The Cor.:nission had describ2d R the scope, procedures, and schedule for completing that statement and I'j.! Hp. E U sc , p )
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g;. e indicated that, before it reaches a decision on the wides: ale use of liOX fuel, it would make a full assessmant of safeguards issues. Accordingly, the Commission directed its . staff to prepare and circulate for written coment a draft safeguards supplement to the former Atomic Energy Coamission's draft " Generic Environmental Statement en the Use of Recycle Plutonium in Mixed 0xide Fuel in Light Water Cooled - Reactors." However, the Prtsidentiai Muclear Policy Statement of October 28, 1976, and the new administration's emphasis on the non-proliferatf ori aspects of recycle have addad imponderables yet to be fully addressed. Though a draf t environmental statement Safeguards Supplement is expected to be published in late spring, the impact on the Cost Benefit Analysis and the International Implications sections may delay these for an indeterminate period of time. C. Safeguards Infor; ration System NRC began development of a comprehensive information system to collect, process and disseninate safeguards-related information. The Integrated ,N Safeguards In' rnation System (ISIS) will be utilized to anticipate and-meet safegua' ; information requirements into the mid-1980's and beyond. Although detailed information requirements have not been drawn up, it is evident that certain basic data related to physical security, material , control and accounting, contingency planning, inspection records, and vulnerability test results co1 be usefully consolidated. D. The Use of Force . I As a consequence of contacts with the nuclear industry concerning the frG- L tection of special nuclear material, the HRC determined that the matter of guard responsibility was one that required more positive definition. It was clear that a commitment from industry would be needed to assure th?t j' s their guards would take appropriate response action--including the use cf force as circumstances dictated to protect the material. { t In November 1975, the NRC informed fuel cycle licensees of the full intent l j of MRC regulations concerning guard response, following up with addi;'o.ul clarification in direct discussions during site visits. Frem these L discussions it becaue strparent that there were wide variations in pre- [. scribed guard response actions and procedures amono the licensed plants. [ To remedy this situation, a massane was sent to licensee:; in [brch 196 which further defined and clarified the URC's policy in this regard. This (~ policy has currently been issued as a proposed rule chang. f L E li L I L
L VI. PLA"S AND PRIORITIES t During FY 1977 the staff will concentrate on the following specific safeguards goals: Enhance the capabilities of material control and accounting systems. Begin steps to implement US/IAEA Agreement on safeguards at U.S. facilities. ' Reevaluate selected licensees' capability to protect special nuclear material:
- Over shipping routes.
- At the facility.
Complete contingency plans for the fuel cycle:
- To ensure protection of material. -
- To ensure pronpt recovery of material.
- To keep the public informed.
- Take other actions to minimize risk.
Identify research effort necessary to support the NRC nucle safeguards effort. Develop computerized nuclear material data systems which wi' give early trend analysis or warning signals. Develop a personnel clearance program for persons with access to special nuclear material to reduce dangers of internal theft or sabotage.
- Upgrade guard efficiency (through training and clarification of weapons policy) to strengthen protection of facilities and ship;aents.
In FY 1978, the following activities will be given priority by the staff: Contingency plans to cope riith emergency situations will be completed and tested; approved by NRC; implemented by licen7ees. Field tests and evaluations of tne vulnerability of nuclear fuel plants will be conducted twice a year at each site to ensure strong protection over all nuclear activities. Complete implementation of US/IAEA Agreement. This effort should result in stronger international safeguards. Full scale tests and evaluation of security over nuclear material in-transit will be made, with identification and correction of weaknesses. Findings of the nateri~al accounting task force to further strengthen pro-tection of nuclear materials will be implemented. . Continued effort in the interest of public protection will be applied by means of these program improvements: Methods to guide licensees in meeting the tougher " performance type" safe- i' guards regulations will be specified. Ir: proved assessment techniques by which to judge licensees' compliance will ! be developed. i a
W: Inspection and licensing review procedures will be developed to guide the staff in reviewing license applications.
- Cost / benefit analyses will be required pri-or to adoption of any new regu-latory requirement.
Programs wil1 be reevaluated to stress licensee initiative. I!RC will specify goals. Industry will propose methods.
- Safeguards program effectiveness will be increased via:
[
- Tailoring safeguards to degree of risk. h
- Deregulating where possible.
Incorporating advanced technology into the regulatory process.
- Streamlining standards and guides.
- Overhauling regulations to stress performance capability of licensees.
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I y C CHART(A I OFFICE OF NUCLEAR MATEMAAL SAFETY & SAFEGUARDS-l ' DIRECTOR (CHAPMAN) DEPUTY DIRECTOR FOR i OPERATIONS (VACANT) DEPUTY DIRECTOR FOR TECHNICAL PROGRAMS (SMILEY) ASST.TO THE DIRECTOR
& CHIEF PROGRAM SUPPORT (BROWN) i I I DIVISION OF SAFEGUARDS DIV.0F FUEL CYCLE & WASTE SAFEGUARDS PLANS AND MATERIAL SAFETY
~
~ MANAGEMENT I (VACANT - DIR ECTOR) POLICY STAFF (SMITH - DIRECTOR) STAFF (PAGE - DEPUTY DIR.) (PERCHONOK) (CUNNINGHAM - DEPUTY DIR.)
(BISHUP) I I ' I I I I I I I A/D REQUIREMENTS A/D FOR LICENSING A/D FOR A/D FOR FUEL ~ A/O FOR MATL. A/DFOR AND TECHNOLOGY (BRIGHTSEN) OERATIONS & CYCLE SAFETY ' SAFETY & LICEN. OPERATIONS AND [ (POWERS - ACTING) EVALUATION & LICENSING " ' (NUSSBAUMER) TECHNOLOGY l3 (THAYER) (MARTIN) (LOWENBERG) i REOUIREMENTS PHYSICAL CONTINGENCY FUEL PROCESSING RADIOISOTOPES OPERATIONS ANALYSIS SECURITY PLANNING
" ~ ~ ~ & FABRICATION LICENSING AND PLANNING BRANCH LICENSING BRANCH BRANCH
~ ~
BRANCH BRANCH BRANCH ,
, (EVANS) (McCORKLE) (CARTER)
(ROUSE) (SINGER) (SMITH) TECHNOLOGY M ATL. CONTROL TEST & l FUEL REPRO-TRANSPORTATION TECHNOLOGY _ ASSESSMENT _ LICENSING _ EVALUATION CESSING AND
. BRANCH _ ASSESSMENT BRANCH BRANCH BRANCH RECYC LE BRANCH (MACDONALD) BRANCH
($HE RR) (McALPINE. ACTIN G) (VON EHRENFRIED) (]/fRNERO) (LEROHL) JAN 19H i i
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( NRC SAFE.- ( :3 BUDGET CHART 3 b, y (Dollars'in'inousands) FY 1976 FY 1976T FY 1977 FY 1978 Safeguards Safeguards Safeguards ' Safeguards People Dollars People Dollars People Dollars People Dollars Research (10) $ 2,831 (10) $3,048 $ 9,455 (12) (15) $10,936 Huclear Reactor Regulation (6) 33 (22) 0 (24) 767 (22) 600 Inspection and Enforcement (60) 1,316 932 1,445 (60) (79) (96) 1,291 Standards (16) 1,050 (16) 329 1,555 (17) (17) 1,500 Nuclear Material Safety and Safeguards (71) 2,085 (71) 1,154 3,627 (104) (124) 4,744 Staff Support (8) 65 (8) 16 65 (11') (12) 76 TOTAL (171) $ 7,380 (187) $5,479 (247) 16,914 $19,147 (286) rmr; .;
'~-'
PROJECT: PHYSICAL SECURITY UPGRADE ,.., SCHED FY 1977 FY 1978
-TASKS COMP.
- DATE ..
O N D J, F M A M J J A S O N D J F M A M J J A S Performance Rules ^ May 77 O
- Draft proposed rule ,
O .
- Publish proposed rule Jul 77 Nov 77 d
Ui- - Issue 'inal ruic
~ O-
- Initial licensec plans submitted - Feb 78 O ~
Jul 78
, - Plans approved Sunport for Implementation .
- Develop Standard Format and Content g ,
Guide Dec 77 . _ - . , O=
- Devcicp Standard Review Plan Feb 78 ,
g
- Determine Safeguard Performance -
Inspection Approach Mar 78 MANPOWER FUNDING PROBLEMS / COMMENTS: 5
,m -
- 9 e e continue:d on next page
. : M* ; -7.; "
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i 4 PROJ.ECT: PHYS! CAL SECUR!TY UPGRADE
~
(Page 2) SCHED~ TASKS COMP. FY 1977 FY 1978 DATE ONDJFMAMJJASONDJFMAMJJAS Action Plan for Protection of Transient inter national Shipments , Jtir. 77 g , Recommeml.itions to Commission on Physical _l Security licquirements for Small Amounts A - aLSNh1 - Feb 77 i MANPOWER ~UNDING PROBLEMS / COMMENTS: f ' i:Y 77 CUOGET 1C 701 K i Y 77 ACTUAL 12 591 K . 720 K i:YgMI'.U f )G E T
'2 1G D _
t .
~
PiiOJECT: IMPROVENiENTS IN MATER!AL CONTROL
~
AND ACOOUNTING ~ d ,; a SCllED~ TASKS COMP. FY 1977 FY 1978 DATE .. ONQJFMAMJJASONDJFMAMJJAS Material Control and Accounting Task Force - i i
- Brief Commission Jun 77
- Draft Report Jun 77
'A .
- Final Report Jul 77 Pacommentiatico to the Commission for '
, , MCS A (future directions) Sep 77 Devcico MC & A Upr:ratic Rule -
- Test concepts and assess implications of various perfor uance units Jul 78 A
- Publish propored rule Sep 78
' MANPOWER FUNDING PROBLEMS / COMMENTS:
<_ . . ~ . _
+
__ _ _ .1 $ ._ _ _ _ _ _ m. [ _i'_i_s._
- _ . _ . _ _.__E_E_.u * , . -_ . ,_ . 4 s. . ma 'w_ . . ,. 4 a m_. i. ' . ,,_[.' _
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t . ? u PROJECT: 2MPROVEMENTS IN - MATERIAL CONTROL AND ACCOUNT!NG (Page Z SCllED*
- b FY 1977 FY 1978 TASKS '
COMP. DATE . O N D J ,F M A M J J A' S O N D J F M A M J J A S Revise Regulations - LEU ,
- Draft proposed rule Jul77
- Publish proposed rule Oct 77 -
A ,
- Issue ef fective rule ,
Jun 78 - 1 !- MANPOWER FUNDING PROBLEMS / COMMENTS:
. FY 77 DUDGET "FY 77 tasks were not specifically identified FY 77 ACTUAL 4 -
in the FY 77 hudget.
'"' 78 UUDGET G 150 K L (,) -
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s PROJECT: GESMO DRAFT SAFEGUARDS SUPPLEMENT i!P ' l'ij., _ SCHED' FY 1977 FY 1978
' TASKS COMP. -
DATE
,' ONDJFMAMJJASONDJFMAMJJAS Reancement of Comminion Policy
- Public response closure date Jun 77 -
O a - New Commission Policy Statement Jul 77 -- b 1 4 . Draft Safeguards Suppicment , { 3
- Chapters 5 & G revisions comp!cted May 77 O -
, , ~
- Draf t comple:cd Jul 77 O -
" - Document availabic for public release Jul 77 .a.
-=
MANPOWER FUNDING PROBLEMS / COMMENTS:
- 1. Impact of President Carter's proliferation GG9 K statement being assess:d.
FY 77 BilDGET 7.0 45G K 2. Resulting changes to drait not yet defined. FY 77 ACTUAL G.7
' - h FY 70 BUDGET -
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PROJECT: SAFEGUARDS CONTINGENCY PLANN!NG .. SCllED' TASKS COrv1P. FY 1977 FY 1978 DATE O N D J F M A M J J A'S O N D J F M A M J.J A S LICENSEE APPLICATION Pronmed Rule .
- Write propesed regulations Feb 77 -- - b
- Publish in Federal Register Jun 77 s- --
b Effective Role
! - Evaluate comments;draf t final ^
rule (SD) Nov 77 ------- A
- Ef fcctive rule sent to Commission Feb 78 _d
- Publi:h ef fective rule and regulatory guides Apr 78 6 '
- Licensee plans submitted for NRC approval Aug 78 _ _ _ _ _d MANPOWER FUNDING PROBLEMS / COMMENTS:
' A COMPLETED
@ DELAYED -
A SCHEDULED i e
- a ~
e _ _ _ _ o_;
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'SCHED TASKS COMP.' FY 1977 FY 1978 DATE ~
ONDJFMAMJJASONDJFMAMJJAS NATIONAL APPLICATION Draf t of interagency Agreements l
- FBI Jan 78 O
- ERDA Apr 78 -
O '
- Alcohol, Tobacco & Fircarms Jul 78 - - - - -
O
- Customs Oct 78 O Ocrefop NRC HO Contingency Plan
- Develop NRC HQ planning perspcctivc Mar 77 - --
'A
- Summarize HQ proccclurcs Aug 77 - - -
O
-~
- Craf t " Straw man HQ contingency q plan with appenclices Nov 77 -
---- ~
6 l MANPOWER FUNDING PROBLEMS / COMMENTS: j e- -- -
^t ' , -continucri un tier,t page mr- r:r ;p*!,-.
m.
0 PilOJECT: SAFEGUARDS CONTONGENCY PLANN!NG (Page 3) .. f SCllED FY 1977 FY 1978 l TASKS COMP. . DATE . ONDJFMAMJJASONDJFMAMJJAS O
- Complete final draf t Jun 78 j
TilREAT ASSESSMENT SUPPORT Define requirements for Threat Assessment Jul 77 Dat3 Ha:e ll O Feb 78 __ 1 pctine Threat inclicators O Design Software for Support System Oct 78 ll - u I FUNDING PROGLEMS/ COMMENTS: MANPOWER
- Incit.Jes 2 professionals and 1 intern 17.0* 323.5 K Positions in freeze status FY 77 GUDGET 322.2 K 7.G
. FY 77 ACTUAL 7!i0.0 K FY 78 GUDGET 13.0 .
9 m.>. _ o
. .m
r m ,' & t% PilOJECT: INFORMAi[GN ANALYSIS & EVALUATION , l SCllED* TASKS COMP. FY 1977 FY 1978 DATE . 0NDJFMAMJJASONDJFMAMJJAS Facility]rramportation Analysis and
- E_yaluation
- Comprehensive Evaluation Plan May 77
- Develop Evaluation Techniques (l) Jan 78 "- -
12/78
- Fictd Assessments (2) Dec 78 O
- Component Performance Tests (1)(3) Nov 77 b .
- Imprcve Methottology for Evaluation g SG Effectiveness (l) Oct 77 --
4 Information Operation
- Upgrade NMMSS Operatiensil) Sep 77 -
- ISIS Development
- General Design Mar 78 --
g 10/79
- Program & Start Up Sep 79 O _
MANPOWER FUNDING PROBLEMS / COMMENTS: - (1) FY'78 Effort Contingent on FY 77 CUDGET 19 1,160 i< FY 77 Result: FY 77 ACTUAL 11 733 K " " $_
- FY 73 CUDGET 22 1,304 K Y 7 -
- 3) Alm & hm b FY U D ( *
. . . . ; . : :'i:NT- ?!?r ?!M:
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c. 9 PROJECT: SAFEGUARDS L!CENS!NG SCHiiD~ FY 1977 FY 1973 TASKS COMP. . DATE .. O N D J F M A M J J A S O N D 'J F M A M J J A 5 Material Control Upgrade - B&W Jul 77 - _ . _ _ _ . _ _
- -_--_A .
- icasurement Control Plans .
- Develop Review Criteria Jul 77 .w---- A -
Dec 77 A
- Review and Approval ,
Strengthcocd Safer;iraids License Conditions
- Trant.portation Feb 77 - b ,
- Fixed Sites
- 2nd Round Site Assessments Dec 76 -b
- Orders for additional protection Mar 77 . 8 MANPOWER FUNDING PROGLEMS/ COMMENTS:
Review of Mcar.urement control plans has been dlaYeti into the first quarter of FY 78 due to FY 77 CUDGET 5.0 MCL personnel .hortanc. For FY 77, availabic , FY 77 ACTUAL 1.5 . branch inanpow'a' diH be about G MY less than 1Y - budsted (15 MY). {} 70IIUDGET v,-~~~; n~: -:.**~. h525 i- ...
' 2 _- _ ___ -__ _ _ _ _ :_; . _ , ; :;, ;1_ ;_. _ ._ _
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t Mr:N i Ai!ON US/iA:- ;A AGR...!:f:M~i:N~i . l SCilED* FY 1977 FY 1978 TASKS COMP. DATE . ONDJFMAMJJASONDJFMAMJJAS Dec 76 ---- A A J pr;n Responsibilitics Develop Rule Chang Jul 77 O
- Publish proposed rule --
Oct 77 ---- O
- Issue cf fcctive rule O
Complete Eligihte Facility Listing Mar 78 , 4 '
' Oct 77 O a -
Reviv Reports Data Procc sing System Devhlop Subsidiary Arrangements Oct 77 -- -- b , l MANPOWER FUNDING PROBLt-MS/ COMMENTS: . FY 77 UllDGET 3.0 150 K
. FY 77 ACTUAL 1.2 35 K .
5.0 150 K sg FY 78 BUDGET *
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1 4
. (, 0 IhTERNATIC'RL TABLE OF CONTEVIS
- 1. U.S. Government Nuclear Export Functions
- 2. NRC's Export Licensing Functions
[- p
-[3. Export-Inport Licensing Regulations
{.
.4.- International Reach of NEPA and Public Health and Safety ,',
- 5. -Nonproliferation Legislation .
- 6. Intervention Petitions:
-- India
-- South Africa
-- West Gemany - Burgeraktion Opinion
-- Others listed, t
- 7. ASCO II Spanish Reactor Decision
- 8. IAEA Safeguards and Physical Security
; i ,
- 9. Worldwide Nuclear Safety
- 10. International Regulatory Cooperation SEPARATE CLESIFIED SECTION, PROVIDED UPON REQUEST
- 11. Suppliers' Conference ~
- 12. Yugoslavia
- 13. Continuing Discussions with India a
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((r; U.S. GOVEPMiE.NT NUCLEAR EXPORT FUN'CTIONS hhile the NRC is respons.tble for licensing nuclear exports, many other Federal agencies are involved in various aspects of the nuclear export program. Agreements for Cooperation between the U.S. and other nations under Section 123 of the Atomic hergy Act are the basis for nuclear sales abroad. The Department of State and ERDA are jointly responsible for negotiating such agreements. Major expnrts of facilities and materials undet such agreements are licensed by the NRC. However, exports of nuclear components and certain materials, such as heavy water, are made under a Commerce Derartment license. ERDA may, in unusual circumstances, prov2de certain minor nuclear exports to other countries without a license, in what is called a " government-to-government" transfer. FRDA is also responsible for the export of non-hardware items (technology transfer). Our agreements for cooperation give the United States varying degrees of control over the recipient's subsequent actions with regard to U.S.-supplied material and facilities. In general, the recipient must have U.S. permission to retransfer U.S.-
- supplied exports to a third country, or to reprocess U.S.-supplied nuclear fuel. ERDA is responsible for approving these subsequent arrangements.
NRC's involvement in these lanctions is basically one of consultation, as follows: Activity Resoonsible Agency Negotiation of Department of State and Agreements for Cooperation ERDA Foreign Distribution of ERDA Nuclear Material Export of Nuclear Facility Department of Comerce Components , i i Export of Nuclear-Related Department of Commerce ! Civil Comodities i Exports of Nuclear ERDA . Technology l
1
. I s.v..i J
'!.'t Export functions - 2
~ D(i Activity. Responsible Agency ""
Foreign Retransfers of ERDA-Nuclear Material '
!=
' Approval of Reprocessing ERDA I ...'~"t .! .
' Request involving U.S.
Origin Material t M Export-Import Bank Export-Import Bank ' Financing of Foreign Nuclear Projects
=
In general, the NRC's consultative role is such that the Cor.cission has ample opportunity to express its views prior to Exccutive Branch action. However, the consultative arrangements are still ' relatively new, and in some cases the action has proceeded .. without NRC. coordination. NRC does not consult with the Executive Branch on the following -
,y. nuclear export functions: ,
Activity Responsible Agency ; Negotiation of. ~ ERDA Enrichtent Contracts . Negotiation of Nuclear ERDA t. Material Sales Contracts Export of C0CCN-Controlled Department of State . Nuclear Comodities to the Comunist bloc The NRC staff has felt no need for involvement with respect to the negotiation of enrichment and sale contracts, for these are ,. largely technical negotiations implementing the provi.sions of i agreements for cocoperation. ' C P N j '.
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k.l; Export functions - 3 NRC is consulted on the negotiations for agreements for cooperation, and tTiese are the key to implementing U.S. enrichment and materials supply policy. The pending export licensing legislation would require ERDA to consult with NRC on enrichment contracts, however, and NRC has not opposed this provision. COCG! is an international comittee that controls exports of strategic c. .raodities to comunist countries; its members are the United States, Canada, Japan, and the Western European nations. ;;. COCOM-controlled nuclear exports fall into the category of East-West trade issues which are outside the statutory authority of the NRC. Any export of nuclear-related commodities that would involve NRC ju-isdiction would be handled by the usual Executive Brnch agency, and NRC would consult through the establi1hed interagency review procedures. j 4m t b I
- 7. NRC's EXPORT LICENSING FUNCTIONS C..
vy Among the licensing functions assumed by the NRC in January 1975 was the responsibility for issuing export licenses for nuclear 9 materials and facilities. Prior to creation of the KRC, the General Manager's side of the AEC had made the substantive decisions on export licenses, and hence the regulatory staff -- which became the NRC staff -- had no experience in the policy aspects of export licensing. [j: The Comission's authority to issue export licenses is independent of the Executive Branch. However, the Comission recognized imediately that it was essential to involve certain Executive Branch agencies in the export review process, since they possess the expertise, information, and assements which can assist in the Comission's detemination that issuance of an export license a would not be " inimical to the common defense and security." (In the early months of the Comission's existence, there was " some concern expressed by the Congress that the NRC's independence , might somehow be compromised if the Comission called upon the Executive Branch for infomation on exports. However, it is now generally recognized that the Comission must rely heavily on Executive Branch input in order to perfom its export licensing function responsibly.) fu VTnen the NRC receives an export license application, it is distributed to relevant NRC staff, and at the same time, it is forwarded to the State Department. NRC requ3sts the State Department to provide the background data which NRC requires, as well as the fomal views of the Executive Branch on the given license application. In Executive Order 11902, President Ford designated the State Department as the lead agency within the Executive Branch for developing views on export license applications. State consults other agencies, such as ERDA, DoD, and the Arms Control and Disamament Agency (ACDA), to collate all the relevant i infomation existing within the Executive Branch. To assure that the nuclear export will be used exclusively for peaceful purposes and will meet the "comon defense and - security" requirement of the Atomic Energy Act, the State Dept etment assessment seeks to answer, among others, the following main questions:
-- UTnat is the purpose of the export?
e i !
- 5 l
) ( Export Licensing Functions - 2 (5 -
-- Does the recipient country have an Agreement for Cooperation with the United States (cf. Section 123 of the Atomic Energy Act), and if so, is the export in question covered by the Agreement?
-- Has the recipient country accepted and implemented IAEA safeguards and/or other appropriate supplementary bilateral conditions (including, where applicable, understandings regarding re-export) imposed by the United States?
-- In cases where the recipient country is not required by the Non-Proliferation Treaty (NFT) to accept IAFA safeguards, does the recipient country or organization have accounting and inspection procedures that will assure compliance with the requirements of the relevant U.S. Agreement?
-- Does the recipient country have adequate physical security arrangements to prevent sub-national diversion of significant quantities of nuclear weapons materials (plutonium or highly enriched uranium)?
-- What is the position of the recipient country with regard
(' to nuclear nonproliferation -- party to NPT, Latin American Nuclear Fuel Zone, Inc., or public statements?
-- hhat understandings does the United States have with the -
recipient country with respect to the use of U.S.-supplied . material or equipment to acquire or develop nuclear explosive devices for any pugose? hhat are the recipient country's policies and actions as to such development using equipment and material from any source?
-- What other factors exist which bear on issuance of the export license -- e.g. further U.S. understandings with the recipient country, other supplier countries, or interested neighbor countries?
hhile the NRC does not directly participate in the Executive Branch agencies' development and evaluation of this information, there is regular staff level commtnication with the Executive - Branch so that its review can take into account particular 1 Comission concerns. In practice, the staff and the Commission frequently ask the Executive Branch for additional information, particularly in the rore difficult cases. i l
Export Licensing Functions - 3 The State Department sends the NRC an analysis of the relevant information, as well as a coordinated Executive Branch view on the license application. If the involved Execn+ive Branch agencies are unable to resolve any internal differences, these differences are resolved by the National Security Council, or by the President himself, if necessary. Tne NRC is infomed of c such situations by the Executive Branch. For general assistance in performing its export licensing functions, the Cor:lission receives a regular flow of State Department ;
~
telegraphic traffic on export issues, and relevant Executive Branch agencies provide intelligence su:rtaries and intelligence and foreign relations briefings. The Commission considers the formal and informal Executive Branch presentations prior to making the NRC detemination on the license. The Comission also takes into account all other matters of record in the licensing proceeding, including , contributions of NRC staff, the applicant, and others who may - be participating in the proceeding. In the end, the final deternination on the export license is made independently by the Conrtission. ( There are two general categories of export licenses. The Cor=tissioners rast examine and concur in any license involving:
-- more than one effective kilogram of spec,ial nuclear -
material, as defined in 10 CFR Part 70;
-- 10,000 kilograms or more of source material;
-- a production or utilization facility or major component thereof; i
- policy implications.
Routine license applications not falling within the foregoing categorical criteria are acted upon by WC staff. j
)
All licenses, major and minor, are signed by the Comission's Office of International Programs. (..
( EXFORT-IMPORT LICENSING REGULATIONS h After experience with its export licensing activities, the Comission realized that there was a need for codified export-import licensing regulations. The need arose because , l;:
-- References to export licenses were scattered throughout E the domestic rules, and were, in many cases, outmoded; m
-- The criteria and procedures for export licensing were different than those for domestic licensing; *
-- The hearing requirement under domestic rules was not suitable for application to export license cases.
After an extensive study on export licensing regulations, the Corraission published for public comment on June 30, 1977 a proposed new part to its regulations (10 CFR Part 110), " Export and Import of Nuclear Facilities and Materials." After the 45-day coment period the new rule can formally enter into effect. In the interim, the , Commission can use it as guidance. The proposed new rule codifies in one location standards, procedures, and rules of practice for licensing the export and import of
- - utilization facilities, source, byproduct, and special nuclear materials. It includes
-- standards for granting or denying license applications;
-- information required to be included in the license application; .
-- general proceduras utilized in Comission review and in !
obtaining Executive Branch views on license applications;
-- public notification of applications;
-- conduct of public proceedings, including oral hearings
modelled on a legislative format;
-- rulemaking and enforcement actions relating to licenses.
The proposed new rule does not contain the substantive criteria - utilized to determine whether a proposed export is or is not inimical to the co mon defense and security because such criteria are presently being developed by Congress, the NRC and the Executive Branch in legislation in the Congress. t
O , c INTERNATIONAL REACH OF NEPA AND PUBLIC HEALTH AND SAFETY r..; W
'Iko issues which arise with respect to the Comission's responsibilities in export licensing are the application of the health and safety finding from the Atomic Energy Act, and the extent of any environmental impact analysis required by NEPA. E A
Tne Coraission has taken the position in all its export licensing $ decisions that the health and safety detemination applies only , to the United States. Tnis position has not been challenged by . the Congress or in the courts. i;; it However, the NEPA issue has been challenged in the courts in cases relating to the foreign activities of other Federal government agencies. NEPA states that environmental assessments must be made for major Federal decisions, but there are no ~ bounds placed on the definition of "the environment," and hence the issue remains unclear. A specific provision oi NEFA calls for the responsible agency ' to aid any foreign nation in environmental deteminations, - with due consideration to foreign policy.
,The Comaission was specifically challenged on this point in n'
the Burgeraktion case; the foreign intervenors petitioned the Co=nission to prepare an environmental impact statement on the site in West Germany where the proposed reactor export would be located. The Comission determined that the international reach of NEPA did include global impacts which might arise from its decisions, but that this did not include site-specific impacts. Global impacts were defined as those which would extend substantially beyond the recipient country, e.g. those arising from ocean > dumping of radioactive wastes, or krypton releases from foreign reprocessing of spent fuel derived from U.S.-supplied materials. .y The Comission thus denied the Burgeraktion petition on June 28, 1977. In reaching its decision on Durgeraktion, the Comission relied heavily on a staff report which addressed the question of , t/nat kind of environmental analysis, if any, in the nuclear cxport licensing process would comply with current legal ' requirements, advance U.S. nonproliferation goals, and assist decisionmakers in recipient nations and the U.S.
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(, .:. International NEPA - 2 :.; t;:; a
- p The Staff report concluded that: .
if.i NEPA requires only an assessment of domestic impacts :;. 'D a (impacts on the U.S.) and, to the extent feasible, I;4 glooal impacts (those extending substantially beyond ' the recipient country); E y At present, no compelling legal argument can be made . on either ' side of the question of whether foreign impacts (site-specific and local to the recipient country and possibly neighboring areas) should be assessed, because the law is still under development; ,
-- hTtC's decision regarding its NEPA responsibility for assessment of foreign impacts should be guided largely by. sound policy considerations. These policy considerations establish that assessments of foreign ,
impacts of U.S. nuclear export licensing activities should not be made; The U.S. should encourage, and if reques;;d, assist recipient nations in environmental impact analysis; p -- " Consultations should be undertaken with Executive Branch staff to discuss whether the ERDA Environmental Impact Statement on U.S. Nuclear Power Export Activities requires supplementation, , u [ l
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9' .( NONPROLIFERATION LEGISLATION se Rising concern in the U.S. and throughout the world over the [i proliferation of nuclear weapons has stifaulated the Congress f;[ to work.on legislative guidelines for the NRC and Executive 9;
- Branch agencies having nuclear export responsibilities. As *
- more and more nations develop nuclear power for peaceful uses, '
their ease in obtaining access to weapons materials increases, a and the Congress therefore wishes to impose controls on the 5 U.S. nuclear export program to-safeguard against further g
- proliferation. 4:
The Energy Reorganization Act gave the NRC responsibility p~ for licensing nuclear exports'in accordance with three determining factors found in the Atomic Energy Act: ~
-- whether an agreement for cooperation would apply;
-- whether the export would be inimical to the health and safety of the American public;
-- whether the export would be inimical to the common defense and security of the United States.
The first two factors are easy to determine; it is the third factor which has been the focus of two years of congressional - hearings and numerous legislative proposals. !a b The problem is that the Atomic Energy Act gives no detailed guidance on how to apply the standard of inimicality to the common defense and security. The Congress, Executive Branch, - and the NRC have been working to develop a set of criteria which all agree would aid the NRC in making its inimicality determination. " There are currently before the Congress four bills dealing with this issue:
-- S. 897, sponsored by Senators Percy and Glenn;
-- H.R. 4409, sponsored by Congressman Bingham;
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-- S.1432 and H.R. 6910 -- identical Administration bills, q which NRC has fully supported, i h
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, Nonproliferation Legislation - 2 k
The Administration bills propose the following six export criteria: 1. IAEA sagds as required by Article III(2) of the treaty [::
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shall be applied with respect to such material or facilities proposed to be exported, to any material or facilities previously exported by the United States and subject to the applicable agreement for cooperation, and to any special nuclear material used in or produced through the use thereof. 2. No such material, facilities, or sensitive nuclear techno1cgy iu proposed to be exported, no material or sensitive nuclear technology previously exported by the U.S. and subject to the applicable b~ agreement for cooperation, and no special nuclear material produced through the use of such materials, facilities, or sensitive nuclear technology will be used for anquelear device or for research on or development of any nuclear explosive device. 3. Adequate physical security measures will be maintained with respect to such material or facuities proposed to be exported , and to any special nuclear material used in or produced through the use thereof. 4. ( No such materials, facilities, or sensitive nuclear technology proposed to be exported, and no special nuclear material produced through the use of such matcrial will be retransferred to the jurisdiction of any other nation or group'of nations ~unless the prior approval of the United States is obtained for such retransfer. The United States shall not approve such retransfer unless the , nation or group of nations designated to receive such retransfer agrees that it shall be subject to the conditions required by this subsection. o 5. No such material proposed to be exported and no special nuclear material produced through the use of such raterial will be gocessed, and no irradiated fuel elements containing such material removed from a reactor shall be altered in form or content, unless the prior approval of the United States is obtained for such reprocessing or alteration. 6. No s g sensitive nuclear technolore shall be exported unless the foregoing conditions snail be appiied to any nuclear material or equipment which is produced or constructed in the recipient nation or group of nations by or through the use of any such exported sensitive nuclear technology.
{ Nonproliferation Legislation - 3 k.. In the Administration bill, criteria 4 and 5 may be waived in certain cases if the recipient country agrees to participate in the President's International Fuel Cycle Evaluation.
'lhe bill also contains a set of negotiation goals for new agreements for cooperation and any renegotiation of existing agreements.
In addition, the President is given the authority to override a negative licensing decision by the h1C. Tne President's decision is subject to congressional approval. The Senate in several and House important ways: bills differ from the Adninistration all
-- the criteria dealing with retransfer and reprocessing controls call for U.S. control over non-U.S.-supplied -
fuel irradiated in U.S.-supplied reactors (as opposed to the Administration bill which covers only U.S.- supplied fuel); L -- the negotiation goals listed automatically become new criteria after an 18-month negotiating period (the Administration bill puts no time limits on negotiations);
-- neither bill has a Presidential override clause which would apply in the event that the h2C denies issuance of a license which the Executive Branch favors;
-- the Senate bill would transfer to the h2C the responsibility for making the retransfer and reprocessing determinations now made by ERDA, while the House bill would give only bill calls for NRC to consult on these determinations, but does not relocate any of these functions). !
All of the bills call for NRC licensing of certain nuclear-related exports now licensed by the Commerce Department. - 1 Former subcommitteesChairman Rowdenlegislation. on the proposed testified before a House and two Senate \ out the Commission's need for definitive criteria, and the factEach time, he pointe-l' that the Corcnission believes that the Administration bill contains the needed criteria and represents the proper approach for dealing with other countries in the export licensing process.
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[ l a v IhTERVENTION PETITIONS D-c India : Tne first petition for intervention and request for hearing on an export license application ever submitted to the NRC (or the AEC) was received on March 2, 1976. , Tnree environmental and public interest organizations sought to ; challenge applications for two licenses for fuel to be used in the two U.S.-supplied Tarapur reactors in India. Although the Commission concluded that the petitioners were not entitled to an on-the-record adjudicatory hearing, it decided as a matter cf discretion (and in view of congressional interest) to hold a legislative-type public hearing on the issues presented
-by the two license applications.
The hearing was considered as an experiment in deternining the , need for or value of public trticipation in export licensing proceedings. Interest-' , outside the government.were invited to participat. 't their views and information. The Tarapur hearing was held on vuly 20 and 21,1976, and the witnesses included a Member of Congress, several former government (5 officials, members of the academic community, representatives for the petitioners, the NRC staff, and a representative of the State Department. > The witnesses presented prepared statements, were questioned by the Commissioners, and were alloted time to rebut other witnesses' testimony. The Department of State witness was cuestioned for five hours by the Commissioners. Issues covered in the hearings included:
-- requiring India to ratify the NPT or at least to accept full fuel cycle safeguards;
-- buyback of spent fuel from the Tarapur reactors;
-- the volatile political situation on the Indian subcontinent; ' :1
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-- India's nuclear explosives program. ~~
Tne format developed for the Tarapur hearing was used as the basis for the hearing procedures described in the Commission's proposed export-import licensing regulations. E M,.
r { Intervention Petitions - 2 r 3 Despite the holding of the public hearing, the petitioners were
,.l not satisfied, as they were not granted the right to intervene.
They appealed the Comissioners' denial of intervention to the $ U.S. Court of Appeals for the District of Columbia. . R [;1 ; On December 8,1976, the Court heard oral arguments on the w intervenors' petition for Court review of the Comission decision. [h S The Court has not yet issued an opinion. (il; Prior to the Comission Tarapur hearing, the petitioners had p reached agreement with the Department of State that they would W raise no objections to issuance of one of the pending fuel licenses in advance of the hearing. A majority of the Comissioners then determined that all required statutory standards had been s met, Gilinskyanddissented. directed that the license be granted. Comissioner Comissioner Gilinsky dissented because he lacked confidence in the effectiveness of the safeguards to be applied to the plutonium produced in the Tarapur fuel. He felt that since
- India has an operating reprocessing facility at Tarapur,
] has not renounced its nuclear explosives program and has not 4 i ratified the NPT, further safeguards assurances w,ere necessary before the license should be issued. i After the hearing, another license application for fuel for i Tarapur was filed with the Comission. Tne same intervenors ' 3 filed a petition requesting that the Comission not issue the license until the Court of Appeals case was decided, and that the new license pending license. proceeding be consolidated with the already the actions so that it could act on the old application andThe Commiss . { at thethe same Court time preserve the issues under consideration by of Appeals. ^ Even though all the Tarapur issues had not been resolved, - on June 28, 1977, the Comission unanimously approved the second Tarapur fuel application. 4 In approving the license, the Comission relied heavily on the r State Department's recomendation that the license be issued m as the need for the fuel was urgent and issuance of the license would represent an act of good faith toward the Government , of India which would help U.S. negotiations with that { _ nation. (See classified materials on Continued Negotiations { o with the Indian Governm:nt.)
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Intervention Petitions - 3 G Petitioners were not satisfied with the Comission's handling of # the matter, and on June 29 tequested a court injunction against shipment of the fuel to India. On June 30, the Court ordered the NRC to suspend the license pending further action and ordered NRC to submit briefs to it on issues raised by the petitioners. , On July 6, after review of briefs submitted by NRC and the p Executive Branch, the Court vacated the stay, pemitting reinstatement " of the license. South Africa Two petitions were filed t intervene against an application to export two nuclear reactors and low enriched fuel to South Africa. ~ However, the export license applications were subsequently withdrawn by the reactor vendor, who noted that South Africa had withdrawn , its letter of intent and awar6ed the reactor orders to another L supplier. Therefore, the Comission dismissed the petitions to intervene. ' A second license application for an export to South Africa has L been filed with the Commission, this time for highly enriched [ g' uranium for a U.S.-supplied research reactor. A petition to intervene was filed, and that petition has not been acted upon by the Commission. Executive Branch views on the merits of issuing this license have not yet been received, as the State Department is conducting a comprehensive review of overall U.S. policy toward South Africa, and no views on this particular license may be expected prior to completion of the policy review. West Gemsny - Burgeraktion Decision On February 16, 1977, a West Geman public interest group, Burgeraktion Atomschutz Mittelrhein, filed a petition with the Commission for leave to intervene and for a hearing on an - application for export of a utilization facility (component parts of a reactor) to West Germany. The petition raised the issue of whether the Comission should prepare an c. assessment of the impact of the proposed export on the West " Geman environment before acting on the export application. The Commission detemined that NEPA does not require it to prepare an individual environmental statement assessing the site-specific impacts of a particular proposed reactor export when the impact was on territory within the sovereign jurisdiction ' of a foreign government. D Y
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, Intervention Petitions - 4' .1 4 :l c: The Commission also determined that the.irgacts of the export [Q) on the United States and globally were satisfied by the p'"n . previously-prepared ERDA EIS on nuclear power exports. Tne Commission thus determined that issuance of the export p= license met all applicable licensing requirements contained in the Atomic Energy Act, and directed that the license be issued. g
'Other Intervention Petitions ..
Petitlens to intervene have been filed against the following export license applications: Country Material Status
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West Geminy 16.01 Kg IEU Awaiting Executive Branch views ) West Germany low enriched fuel Awalting Executive Branch views (!. Netherlands low enriched fuel Awaiting Executive Branch views W st Germany 9.4 Kg U-235 in Petition received June.24, 1977 , 10 Kg of U38 0 e t 1 - s
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ASCO II - SPANISH REACTCR DECISION F'(... The first Comissioner dissent on an export license ap occurred on the application to export a PR (ASCO II)to plication Spain. As a result of the dissent, the first written Comission opinion on an export license was published. Since 1965, the AEC had licensed the export of eight power reactors to Spain, all under terms of a US-Spain Agreement for Cooperation and subject to IAEA safeguards. ' The ASCO II request was the first export license for a power $ reactor to Spain submitted to the NRC. Tne Cortission received an Executive Branch analysis favoring issuance of the license, and then undertook analysis of the issues involved, beginning in August 1975. In June 1976, the Commission issued its decision favoring issuance of the license, with Comissioner Gilinsky dissenting. Comissioner Gilinsky dissented on the grounds that non-U.S. fuel could be used in the reactor. He argued that the U.S. does not g have reprocessing controls over non-U.S. supplied fuel, and if the irradiated fuel were to be reprocessed the only safeguards .. b would be those of the IAEA, and he does not b:lieve that IAEA
~"f_ safquards are adequate for safeguarding separated plutonium. F He also noted that Spain is not a party to the NPT and has existing contracts for the purchase of fuel from non-U.S. sources.
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7: Comtissioner Gilinsky offered a remedy: condition the license to require that the Spanish use only U.S.-supplied fuel in L I the ASCO II reactor. The majority opinion expressed concern over the desirability of stringent safeguards for fuel reprocessing, but concluded that in this particular situation, the considerable safeguards franework contained in the existing agreements were an adequate basis for supporting issuance of the license. The najority concluded that the license condition proposed by Co=tissioner Gilinsky would not be effectiva in achieving the safeguards objective because the AEC had c1 ready licensed export of eight power reactors to Spain, all of which could ' be supplied with non-U.S. origin fuel. Spain has acquired reactors from other suppliers, and will be able to do so in the future. -
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'ir Thus,'even if it could be assured that the export of ASCO-II coulci.
be tied to the use of U.S.-supplied fuel, the overall safeguards problem would continue to exist as regards Spain, p;4 m Since the ASCO II Opinion, all commissioners have favored controls {plh i < .:.i over non-U.S. fuel irradiated in U.S.-supplied reactors, to the f i extent that such controls are attainable fron the recipient fh i country and are not in conflict with overall foreign policy $~ considerations. p::: ii n
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r b::. t IAEA SAFEGUARDS AND INTERNATIONAL PHYSICAL SE3JRITY STANDARDS [g. ~, LAEA Safeguards 1 The International Atomic Energy Agency (IAEA) is responsible for c the administration of an international safeguards program and for " providing assistance to developing countries which wish to initiate nuclear power programs. The safeguards function of IAEA is of great importance to E supplier countries such as the United States, whereas the technical assistance program is of greater interest to the developing countries. Hence, the IAEA represents a delicate political bargain between those countries primarily interested in safeguards against nuclear weapons proliferation and those countries interested in obtaining the economic benefits of peacefd nuclear energy. The IAEA safeguards system seeks to verify that civil nuclear materials and facilities have not been diverted to any military , use. The system is based principally on measurement checks, and the IAEA uses travelling inspectors, radiation monitoring equipment, and tamper proof seals and cameras to monitor. the nuclear facilities under its supervision. IAEA safeguards are applied t. C1 the nuclear programs of nations which have signed the Non-Proliferation Treaty (NPT) . In countries which have not signed the N?r, IAEA safeguards are . applied to all facilities and materials furnishbd by outside suppliers which are Nur parties (basically, all suppliers except France). Tnus, for example, IAEA safeguards in India apply to the Tarapur reactor supplied by the U.S. and the RAPP reactors supplied by Canada, but not to India's indigenous nuclear facilities. The IAEA inspection program is generally acknowledged to be effective in the area of light water reactors ad low enriched uranium fuel. However, considerable concern has been expressed over the ability of the IAEA to safeguard future nuclear programs which may involve breeder reactors and substantial quantities of plutonium. Three major areas of concern are involved: '
-- PERSONNEL: verification of controls on plutonium would probably require pemanent resident inspectors, thereby increasing considerably the number of inspectors needed by the IAEA.
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-- MEASUREMENT CO.VfROL: measurement accuracy required to detect diversion of weapons-significant quantities of 2 plutonium would have to be much greater than that presently used to control low enriched uranium. There !
- is some question whether the technology needed for such accuracy is available. E E
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-- TIMELINESS OF DETECTION: it would take some months to f construct a nuclear weapon from diverted low enriched uranium, but it would-take only hours or days to ,y achieve a weapons _ capability with diverted plutonium. "
Tne Carter Administration believes that the problems of
& . trolling weapons proliferation resulting from large national breeder and reprocessing programs are too great to justify the t economic benefits such programs might offer. Hence the U.S. -
has tried to get the IAEA and interested nations in general ' to focus on multinational fuel cycle centers and spent fuel storage regimes, rather than an expansion of IAEA capability + to inspect large-scale national breeder or reprocessing programs. ii;i The NRC is a inember of the interagency group that coordinates U.S. activities in the IAEA and sends technical and safeguards personnel to assist the IAEA in Vienna and part;icipate in its - conferences. . Physical Security . t The IAEA statute does not give it responsibility for protecting nuclear materials and facilities against theft or sabotage. A At the United Statea' insistence, the IAEA has developed guidelines (INFCIRC-225) for physical protection. However, *j the implementation of these guidelines is the responibility of each individual country. Since November 1974 the United States has required assurancos from recipient countries that adequate physical security will ' 1 be applied to exports of significant quantities of weapons-grade material. Other suppliers have also adopted this requirement as a condition of supply. g f:: 4 i e. D 6
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L hDRLDhTIDE NUCLEAR SAFETY
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$ t Although the NRC does not assess foreign health and safety impacts - g.; in specific export licensing cases, NRC is the lead government p. agency responsible for cooperating with other countries on d nuclear' safety issues related to public health and safety. E D NRC utilizes a number of mechanisms for nuclear safety cooperation: E
-- IAEA: NRC plays a very strong role in helping IAEA draft standards for nuclear plant safety and environmental protection. These standards are of particular ' assistance to developing nations which wish to establish safe nuclear power programs. In addition, the NRC staff attends many IAEA conferences and symposiums on safety-related subjects.
-- Bilateral infomation exchange arrangements: NRC has agreements to exchange regulatory information and cooperate in standards development with Brazil, Denmark, the Federal ,
Republic of Gemany, South Korea, France, Italy, Japan, - g;. Spain, Sweden, Switzerland, and Iran. NRC has also ~ discussed such arrangements with Belgium, Canada, the USSR, Mexico, the Netherlands, Israel, Finland, Greece, Turkey, and Romania.
-- Research cooperation agreements: NRC has bilateral safety research agreements with Brazil, Denmark, Finland, France, Germany, Italy, Japan, South Korea, Norway, .
Sweden, the United Kingdom,.and the IAEA. Gemany, Japan, and the Nordic countries are partu_ipating in the HEC's Loss-of-Fluid Test (LOFT) program, and a number of IAEA member nations participate in the Power Burst Facility (PBF) and Heavy Section Steel Technology (HSST) programs. E
-- Multinational projects: ARC is a member of the nultinationally-supported Halden nuclear fuel perfomance project in Noreay, and in the Matviken containment response project in Sweden.
-- Foreign visitor.;: during fiscal'1976, NRC received 510 visitors frem 32 countries and international organizations for discussions on technical and policy concerns related -
to nuclear regulation and safety. An importans ae has arisen relating to the non-disclosure of foreign safet) .tnformation provided to the NRC through the H a H aforementioned channels. I a
- p. h'orldwide Nuclear Safety - 2 E
Many foreign countries do not follow a policy of providing the public openly with infomation on nuclear safety. However, nuch of the information they can provide NRC is of value to n. this agency in providing effective protection and regulation !i within the United States. Therefore, in order to obtain this needed information., NRC has agreed with foreign regulatory authorities not to release any infomation they have provided without their permission. In some cases, the NRC is able to withhold the foreign infomation under the Freedom of Information Act, because it is proprietary in nature. In other cases, with the agreement of the State Department, NRC classifies the infomation under Executive Order 11902 on the grounds that its disclosure would damage foreign relations. (. Thus far, the NRC has been successful in maintaining a steady flow of useful information from other countries, and in honoring their desire for confidentiality. 9 e i .. s e
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-INTERNATIONAL REGULATORY COOPERATION-NRC maintains close relations with foreign nuclear regulatory 'j; authorities in' order to assist them with problems of nuclear "
health, safety, and environmental issues. This cooperation takes place through the following mechanisms: . H
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- 1. Bilateral Information Arrangements: NRC has agreements for the exchange of regulatory and sarety information with Brazil, _
Denmark, the Federal Republic of Germany, South Korea, France, E Italy, Japan, Spain, Sweden, Switzerland, and the United Kingdom. F5 The primary objectives of these arrangements are:
-- to facilitate prompt and reciprocal notification of safety problems;
-- to exchange regulatory information; c .
-- to foster an expert consensus on regulatory and safety standards. [=
NRC is discussing establishment of similar airangements with Belgium, Canada, Mexico, the Netherlands, and the USSR. I 2. Research Cocoeration Agreements: NRC has bilateral reactor safety research agreements with 11 countries and one multinational organization. They are: Brazil, Denmark, Finland, France, West
- Germany, Italy, Japan, South Korea, Norway, Sweden, the United Kingdom, and the IAEA. Under the terms of these agreements, NRC and other countries exchange reports, computer codes, research results of specific programs, and in certain cases, personnel on extended assignments. IAEA countries also participate in the NRC research programs on LOFT, PBF, and HSST.
- 3. Multinational Projects: NRC also participates in the multinationally supported Halden nuclear fuel perfomance project in Norway and in the Marviken containment response project in Sweden.
- 4. IAEA: NRC represents the U.S. government on a number of ,
IAF_A-sponsored international committees which develop regulatory guides and standards, primarily to assist ccuntries which are initiating nuclear power programs so that they can proceed on a L safe and environmentally sound basis. ~ 5 . c ?
I i i y[. International Regulatory Cooperation - 2 - I::) 6 .B k- \.)
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Foreign Visitors: In fiscal 1976, NRC received 510 visitors F from 32 countries and three international organizations, to I:? discuss safety and regulatory problems. , H . S
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9 RADIOACTIVE EASTE MANAGBIENT
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Considerable public concern has been expressed over what'some .j perceive as the lack of a firm national policy for the " management of radioactive wastes. Some argue that the Federal Government has, in the past, been dilatory in its treatment of the issue. g. c=
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E. The Energy Reorganization Act of 1974, which created the NRC, [{[{: splits responsibility for radioactive waste management: ~
-- ERDA is to_ develop the technology and operate high level waste disposal facilities; ~
-- NRC is to license and regulate commercial and certain ERDA-owned waste storage facilities.
To implement its waste management responsibilities, NRC created a Waste Management Branch within the Division of Fuel Cycle and g - Material Safety, Office of Nuclear Material Safety and Safeguards. Early in 1977, NRC placed further emphasis on its waste '_ e" ' management activities by creating an Assistant Director for Waste Management to oversee newly-created High Level Waste Management and Low Level Waste Management Branches. From its inception, the Nuclear Regulatory Comission's waste canagement program has been designed to achieve four major goals: P
-- to provide objective performance goals (technical, social, economic, and environmental) against which nuclear waste management programs and strategies -
can be evaluated.
-- to provide a framework of regulations, standards, and guides for management of nuclear wastes within which NRC can effectively and efficiently carry out the ,
functions dictated by its role to protect the public health and safety. This framework will be supported by a comprehensive series of environmental impact statements.
-- to develop a methodology for implementing its goals and regulations, and the data base needed to make .;
1 effective use of this methodology; W
-- to be capable of performing licensing reviews on proposed waste management systems as required to meet P our mandate to protect health, safety, and the environment.
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c t-Radioactive Waste Management - 2 To achieve these goals, NRC is working with other Federal agencies 5 an accelerated effort to ensure that the necessary facilities , and regulatory framework will be in place when they are needed to , deal eith nuclear wastes in a safe and environmentally acceptable - manner. For its part, the NRC has taken the following steps: 1 Participated in an interagen y task force program to review activities of all Federal agencies concerning high-level g radioactive waste management and develop a schedu]e for an E integrated Federal effort on waste management. 2 bgun development of perfomance criteria for solidified high level wastes. These criteria are being developed based on a systems analysis model which considers the nomal and potential accident environments to which high-level solid matrices could be exposed during interim storage, transportation, handling, emplacement, and post-emplacement.
- 3. h gun scheduling of standards r^ quired to regulate all licensed waste categories, p~ 4. hogun development of licensing procedures to provide for an independent assessment of high-level waste repositories preposed by HWA. Repository site selection criteria are -
being developed and will encompass a broad spectrum of concerns, including earth science, geographic, democraphic, and socioeconomic factors. A study to determine the design and operating requirements for high level waste repositories will provide a basis for development of standards and staff review methodologies.
- 5. Cenducted workshops to assist in considering the partitioning of racioactive wastes, the formulation of a waste classification system, and factors that might affect the long-tem perfomance of gcclogical repositories for high level wastes.
- 6. Preparation of a draft envircunental impact statement on uranitra mill operations, with particular emphasis on mill '
tailia',s as a fom of radioactive waste requiring regulatory managc~.ent . i
- 7. :bassessed the technical and regulatory bases for the cperation of existing shallow land burial sites for low level wastes, and initiated an interagency study of needs for in.provement in this area now and in the future.
Radioactive Waste Management - 3
- 8. Carried out a thorough survey of data on the environmental impacts of nuclear fuel reprocessing and waste management which will be the basis for new rulemaking proceedings on such impacts in the licensing of nuclear power plants (S-3).
hRC's regulatory mandate requires the Comtission to ensure that licensed waste runagement facilities will adequately protect public health and safety. . But implementation of a national waste management program involves more than technological and regulatory achievement. It is equally important to establish public trust in the decisionmaking processes, and to establish this trust in the near future. i' Hence NRC must undertake an approach in regulatory implementation ; which focuses on achieving public participation in our i decisionmaking processes and subsequent public acceptance of ' the regulatory outcome. Moreover, NRC's regulatory process must therefore provide an ongoing forum for all parties concerned ! with all aspects of the waste management system. p
ERDA ROLE-IN RADI0 ACTIVE WASTE MANAGB Efr (':. s Under the Energy Reorganization Act, ERDA is to develop the R technology for radioactive waste management, and to operate disposal facilities for high level waste (EW). ERDA is pursuing a research anI development program designed (=: to acconodate the anticipated need for disposal of EW, which [5 may include the spent fuel accumulating at nuclear power 6 2 plants if a decision against reprocessing is made. !ii-L~ ERDA's primary goal is to have operable the first demonstration EW disposal facility by 1985, and President Carter's nuclear m. energy message reemphasized this goal. ERDA recently published a technical alternatives document (ERDA 76-43) setting forth various technologies for the handling and disposal of wastes from reactors and post-fis: ion operations in the LhR fuel cycle. E Basicany, ERDA believes that, after solidification or EW, emplacement in stable geological famations is the most feasible technology for these wastes. ERDA is now examining ' four basic types of geological emplacement:
-- ice sheets
-- sea floor formations
-- shallow continental geological fomations
-- deep continental geological formations.'
The latter type appears most promising because it offers }ll the best possibility of isolating radioactive wastes from the e k biosphere for the millenia needed for them to become inert. Development of a deep geological disposal facility would serve to demonstrate the accept &bility of a specific geological fomation for permanent disposal of high level and transuranic wastes. Because of the present uncertainty over reprocessing of spent fuel, ERDA is also exploring the concept of a Retrievable Surface Storage Facility * (RSSF), in which spent fuel could be placed for eventual retrieval if, in the future, a decision ' is made to reprocess such fuel. ERDA is presently preparing a generic environmental impact statement on high level waste disposal, with a draft ~r.gf .? expected to be issued this fall. ' d h
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I RADI0 ACTIVE WASTES AND ASSOCIATED MANAGE'ENT TECHNOLOGIES *
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e' Radioactive materials which result from the nuclear fuel cycle. , can be separated into two main categories: effluents, and wastes. , d Effluents are th6se materials discharged to the environment in gaseous or liquid form, and which must fall within NRC and EPA limits. . f Wastes' are those materials which are of sufficient potential ~ radiological hazard that they require special care.. Sources of wastes and the associated disposal technologies are as
-follows:
- 1. IRRADIATED FUEL: if irradiated fuel becomes a waste, i.e.
if reprocessing does not occur, then the fuel assemblies can be stored or managed as a waste, c g. by placing them in containers and filling the void space with metal. Such technology is available but has not been used.
- 2. .CH0P-LEACH FUEL BUNDLE RESIDUES: these are solid wastes '
comprising short lengths of fuel cladding, fuel bundle support rods, poison rods, massive end fittings, fuel support grids, ~ assorted springs, and spacer elements. The available technology is to store these wastes without treatment. The small amount c". of chop-leach fuel bundle residue wastes generated in the U.S. ' to date, at the NFS plant, was packaged in steel containers and placed in shallow burial grounds.
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ERDA is developing advanced technology to deconraminate and/or consolidate these wastes by mechanical compactica, melting, or. - by chemical reaction. .
- 3. HIGH LEVEL LIQUID WASTE: HLLW is generated in the first solvent extraction cycle of nuclear fuel reprocessing facilities.
No.LhR fuel cycle HLLW has yet been generated in the U.S. except for a small amount generated at NFS. That waste is now in storage. Present NRC regulations require that if more commercial .., HLLW is generated in the U.S. , it must be converted to a stable, q dry solid within five years after fuel reprocessing. i
- Surr:r.ary excerpts taken from ERDA-76-43, Alternatives ' '
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S.Ii g- Wastes and Technologies - 2 _ b.... . Technology exists to convert the HLLW to a calcine powder or a glass. ERDA wastes, which differ chemically from thR fuel cycle wastes _ and have lower levels of radioactivity, have been calcined routinely at the Idaho National Engineering Laboratory since 1963. g A production-scale facility for converting HLLW to glass, under p - construction at Marcoule, France, is scheduled to begin operation this. year. ERDA is also working on several alternative methods f for converting HLLW to a glass.
- 4. NON-HIGH-LEVEL LIQUID HASTES: this category encompasses a broad spectrum of radioactive liquid wastes varying widely in chenical and radioactive content. Some plant wastes, such as laundry and decontamination solutions, are representative; also included are wastes specific to certain plants, such as acid etch solutions from MOX fuel fabrication plants, or alkaline solvent wash solutions from a fuel reprocessing plant. In addition to evaporation, which is the most comonly used treatment technology, treatments can include reverse osmosis, fidcculation, precipitation, filtration, and ion exchange.
The technologies are all availabic and most are currently being used in the nuclear industry, w
- 5. c CO'BUSTIBLE SOLID WASTES: these include a large variety of items, such as paper, rags, plastic sheeting, protective clothing, gloves, rubber shoes, wood, organic ion exchange resins, filter aids, etc. Much of the waste material is .,
collected as general trash, which usually consists of a mixture . l of combustib;e and noncombustible items. Therefore, treatment options generally include sorting prior to treatment of the F wastes. q Various treatment technologies are available for combustible wastes. They range from simple storage in boxes or steel b drums to compaction, encapsulatier. in concrete, and incineration. i The incineration of combustible waste is simple in principle, but requires special considerations when applied to radioactive materials. The most important of these considerations have been associated with the off-gas cleanup system. A number of ' alternative incineration systems are being developed and evaluated in the U.S. ,
- 6. NONCO.\BUSTIBLE SOLID WASTES: the primary constituent of these solid wastes is metal, but other noncombustibles such as glass and concrete are also present.
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h'astes and Technologies - 3 :: Noncombustible wastes may include inoperable and obsolete process equipment.such as pumps, process vessels, piping, and laboratory or process glove boxes. The steps-in management of large noncombustible waste items are deconi nination, disassembling, and packaging. Comercialized technology is available for these steps. Decontamination'usually includes chemical flushing with several different reagents, but may also include mechanical _. d activities. Disassembling may be done by sawing or mechanical cutting or tearing, as well as cutting with torches or electric arc. Packaging can be done either with or without crushing or mechanical compaction. 3 Q
- 7. GASEOUS EFFLUENTS: these include radioactive noble gases, iodine, tritium, and carbon-14. Treatment technology is available for the noble gases and iodine, and is being developed for tritium and carbon-14.
Two technologies are available to collect noble gases from ;7 off-gas effluents. .One is the cryogenic treatment of the entire T off-gas stream, followed by distillation of the resultant liquified-air for purification of the noble gas fraction. This technology is currently used at the Idaho Chemical Processing Plant. The second technique is collection by liquid fluorocarbon 0, absorption. Tnis technology is presently being offered commercially for capture of noble gases released from DlRs. . 5 i
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'S-3: ENVIRO.9IEhTAL DIPACT OF TIE LhR FUEL CYCLE L
In November 3972, the AEC published an " Environmental Suney of the Uranium Fuel Cycle" (h' ASH-1248) . After consideration of public coments and hearings, the AEC issued a rule in 1974 calling for use of the Survey results as the technical basis for informed consideration of environmental effects of the uranium fuel cycle in the environmental impact statements for individual LhRs proposed for licensing. The Survey treated the nuclear fuel cycle generically, pemitting an overview of the entire industry without the need to evaluate particular plants. Table S-3 of the Survey presented the summary of the environmental impacts of the fuel cycle attributable to one 1,000 MNe LhR, to be used in the cost / benefit analysis for the plant. S-3 had as its base a r,dification of the uranium-only recycle process, in which separated plutonium was stored for possible later use, rather than being recycled or treated as a waste stream. To , compensate for the lack of specific site and design detail, - it made estimates of effluent concentration, radiation dose rates, and hu .an population densities appropriate to the model fuel-cycle o facilities. ' On July 21, 1976, the U.S. Court of Appeals for the District of Columbia, in the " Vermont Yankee" case, handed down a decision which held that: .
-- the rule for considering the environmental effects of the uranium fuel cycle for individual thRs (i.e. S-3, was inadequately supported in the areas of reprocessing L
of used fuel and the management of radioactive wastes;
-- before the NRC can license a nuclear power plant, the NEPA requires that the environmental effects of fuel reprocessing and waste management be considered through rulemaking or in individual licensing actions.
On August 13, 1976, the Comission issued a General Statement of Policy with regard to the Court decision. Tne principal elements of the Statement were: '
-- hRC would reopen the rulemaking proceeding on the environmental effects of the uraniu . fuel cycle t s:
-- supplement the record on reprocessing and waste management;
-- detemine, on the basis of the supplemented record, if the existing rule should be amended.
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-- the staff was directed to review the existing literature and ;;.
produce a revised and adequately documented environmental !i survey on the probable environmental costs of reprocessing p and waste management in licensing a nuclear power reactor. .
-- The Comission temporarily suspended the issuance of new '
full power reactor licenses, cps and UMs. The temporary suspension would remain in effect until completion of the revised environmental survey, at which time the Commission - would detemine if it could be used to justify the development of an interim rule to serve as the basis for restmting licensing activities by mid-December.
~i On October 8,1976, the Court delayed the effectiveness of its decis._ n regarding the environmental effects of the uranium fuel cycle and further indicated in its view that the Commission could
- continue issuing licenses on a conditional basis.
In October 1976, the Commission announced a proposed interim rule dealing with the environmental effects of fuel reprocessing and waste management in licensing nuclear power plants. The proposed rule incorporated a revised S-3 table. The Commission noted that, if warranted, an effective interim rule could'be in place by mid-January. The proposed interim rule was based on the newly-completed evaluation of the environmental impacts of nuclear fuel reprocessing and waste management (hUREG-D116, Supplement 1 to 1%SH-1248) . Tne evaluation found that environmental impacts of fuel reproce sing j, and waste management, as they relate to individual nuclear plants, a continue to be small, even when bpacts not completely evaluated in the past are considered. j On November 11, 1976, the NRC resumed licensing of nuclear power ;- plants and outlined its plans for considering the environmental impact of waste management and fuel reprocessing in licensing [ 1-proceedings. Licenses were authorized to be issued on the basis of the ' currently effective fuel reprocessing and waste storage values contained in Table S-3. Tne Commission directed that such licenses be issued only if the revised values of the proposed rule were specifically analyzed to determine if they would tilt the cost / benefit analysis against issuanca of the license.
S 3 If it appeared that the cost / benefit analysis would be tilted against issuance of the license, the proceeding would be suspended with respect by to waste and fuel reprocessing issues until further action the Ccmmission. Under this approach, the accuracy of the revised values was not ' to be at issue in the proceeding; rather, the issue would be the detemination of whether the cost / benefit balance would be tilted if the revised values were used. U In October 1976, Supplement 1 to KASH-1248 (NUREG-0116) was published in response to the July 21 Court decision remanding the reprocessing and waste managemert portions of the fuel cycle rule. The Supplement presents a discussion of spent fuel reprocessing and waste management impacts, and is based on a thorough survey of the available data. It indicates that the available data are adequate for a quantitative assessment of impacts from nomal operations of all parts of the reprocessing and waste management systems. On March 14, 1977, Supplement 2 to WASH-1248 (NUREG-0216) ( was published. It contained public comments on hUREG-0116 and the NRC responses to those comments. In March 1977, NRC published an effective interim rule and in May 1977 announced procedures for c final rulemaking on S-3. The announcement named a hearing board chaired by Michael Glaser, and called for public participation. Hearings are likely L; to start in Fall 1977. Meanwhile, NRC is appealing the ' Vermont Yankee" decision which initiated these proceedings to the Supreme Court. Tne NRC brief was filed June 27, 1977, and the case is expected to be heard in October 1977. s I 5 i I
i HRANIUM MILL TAILINGS p;: Uranium mill tailings contain radium, which has a 1600-year half-life. They present a health hazard to the public, the degree of which depends on how long its short-lived daughter product, radon gas, is delayed in escaping to the atmosphere by a barrier layer on top of the tailings. The tailings are sandlike and may be blown around by the wind. They are also structurally suitable for use in concrete r=. and also as landfill material. Mill tailings are a highly visible problem of concern to the public and Congress. Tailings are present at both active uranium mills and inactive or abandoned mills. The amount of tailings continues to grow in both categories. NRC regulates tailings at active mills, but not at inactive or abandoned mills, so the amount of unregulated tailings will continue to increase as mills are shut down. Twenty-two uranium mills in eight western states have ceased operating, leaving behind about 26 million tons of tailings. ; In one instance, these tailings were used extensively for construction purposes, resulting in Congress enacting a law to provide remedial action to protect the public affected against radiation overexposure. ERDA is the lead agency with regard to assessment of the health (j impact of mill tailings at inactive sites, and for developing - plans and recommendations for remedial actions for these sites.
-- October 1974, ERDA issued preliminary report on 22 inactive sites.
-- May 1976, ERDA reported on first of 22 sites assessed, providing estimates of stabilization costs. R6D work on other sites continues.
As NRC is responsible for regulating uranium mill teilings at active and future sites, the Comission has established a ; regulatory program to avoid the problems associated with abandoned tailings in the future. On June 3, 1976, NRC announced its intention to prepare a generic environmental impact statement on uraniuta milling: -
-- to assess the environmental impact of uranium milling operations, including the management of mill tailings; g
-- to present alternative solutions to the tailings problem H H
-- to provide for public participation in regulatory decisions
- on mill tailings. ,
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j Uranium Mill Tailings - 2 .( [. E The. draft environmental impact statement is currently scheduled for publication in August 1978. In the interim, NRC is requiring a tailings stabilization and control program at all uranium mills, as part of the license if review for new mills or applications for license renewals. b (5
-- individual environmental impact' statements must be-submitted for each site; 7.:;
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-- specific requirements for tailings stabilization as part of the license conditions;
-- financial security arragements, through bonding or other methods, to ensure reclamation and stabilization of tailings.
-- license conditioned such that mill tailings management C practices will be subject to roview in accordance with ,
the conclusions of the EIS and any related rulemaking, y '- , Many current and future uranium mills are located in hRQ Agreement States, and therefore licensed by them, hTC's EIS on uranium. nilling will include activities in the Agreement States. In H addition, hRC periodically reviews the regulatory programs of the Agreement States to ensure compatibility with hRC regulatory programs. In March 1977, the IRC staff conducted a workshop for the Agreement States on regulatory programs for uranium mills. . It should also be noted that NRC staf-f is presently studying whether, and to what extent, hRC should regulate Naturally - F_. Occurring and Accelerator Produced Radioactive Material (NAtM). If hRC did possess authority to regulate NARM, this authority would encompass all uranium mill tailings, whether at active q or abandoned sites. f
f.I.If h SPENT (IRRADIATED) FUEL STORAGE k=I w The fuel assemblies used to generate heat in a nuclear power reactor ijj, have a finite life and must be replaced periodically, due to depletion of fissile fuel material and accumulation of fission [ products. : i Each' year a typical large power reactor will discharge from 25 to 40 tons of spent fuel in 60 to 200 fuel assemblies. These f$ . 6 W spent fuel assemblies are placed in an onsite spent fuel storage pool pending either shipment to a reprocessing facility or disposal as radioactive waste. For single-unit facilities, the practice is that the spent fuel storage pool accomodate the spent fuel assemblies associated with a normal refueling, plus additional space to safely store an entire reactor core -- i.e. a total spent fuel storage capacity of one and one-third cores. is y For multi-unit facilities the utility generally increases the ~ storage pool capacity by the incremental refueling load for the additional plants, so that the capacity for storing one 'ftd1 - core is retained. p
' The design capacity for spent fuel storage at the plant site has developed as an industry practice, not as an NRC requirement. ?
There is no regulatory requirement for providing or retaining available storage space in onsite storage pools. g i Because the decision on plutonium recycle (reprocessing of spent fuel) has been substantially delayed, many utilities d l have found their spent fuel storage capacity would soon , become inadequate. NRC has approved expansion of storage $ capacity at several facilities already, and has pending before it a number of expansion applications.
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( LOW LEVEL WASTE MANAGBETT
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E Radioactive wastes with a low level of radiation contamination < are presently disposed of by shallow land burial, usually in . the containers in which they are shipped. j... There are six commercial land burial' sites in the United States authorized to receive and bury low level wastes (LLW). These are: '
-- Beatty, Nevada
-- Hanford, Washington
-- Barnwell, South Cr e ina -
-- Maxey Flats. - .c .y L ....
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-- West Valley, new fork ~
-- Sheffield, Illinois. J All but the Sheffield site are located in NRC Agreement States and are regulated by the States. The States have assumed responsibility for long-term care of the sites. F Public interest in management of low-level wastes has been stimulated by reports of leakage from the Maxey Flats site, and pilferage from the Beatty, Nevada site. .
Last year, NRC began a major reevaluation of its program for licensing the disposal of low level wastes. Tnis reevaluation was partially in response to public concerns, and partially in response to a congressional recommendation that the Federal
- govern ent move promptly to develop a coordinated program for the safe management of low level radioactive wastes, and consider assertion of Federal control over regulation and ownership of the commercial burial grounds.
NRC conducted an in-house task force study, which was published in March 1977 as NUREG-0217, "NRC Task Force Report on Review .z. of the Federal / State Program for Regulation of Commercial , 1 Low-Level Radioactive Waste Burial Grounds." (Executive Summary and background infomation appended.) ei a d w$. .
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I=s~.. . l i Among the issues considered in the Task Force Report were: E
-- appropriate Federal / State roles in licensing and [.T...
regulation of comercial LLW disposal; * - se >
-- establishnent of a Federally-administered perpetual care fund; :
-- the need for an accelerated NRC program to establish a s comprehensive set of unifom national standards and criteria for LLW disposal;
-- initiation of a study on alternatives to the disposal of wastes by shallow land burial.
Early in 1977, the newly-created Low Level Waste Management Branch began preparation of an Action Plan to develop and implement a = comprehensive regulatory program for the management of LLW. The plan will stress early results to the extent possible, systematically capitalize on existing information, and draw E upon the work of outside agencies such as ERDA, EPA, USGS, CEQ, the States, and the National Laboratories. In addition, the LLW Branch has under way a aries of studies , to develop the regulatory data base necessary to prepare standards, criteria and regulations governing LLW disposal. Tnese studies cover,the following topics:
-- the chemical toxicity of LLW;
-- the country's LLW disposal needs through the year 2000;
-- criteria for LLW disposal;
-- criteria for radioactive waste threshholds;
-- alternative methods for disposal of LLW.
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