ML20205J022
| ML20205J022 | |
| Person / Time | |
|---|---|
| Site: | 07000008 |
| Issue date: | 01/19/1976 |
| From: | Builder C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Brightsen R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20205H965 | List: |
| References | |
| NUDOCS 9904090142 | |
| Download: ML20205J022 (4) | |
Text
I'
, s .
l k f', UNI fl.t) S T A 11,5 NUCLE An ut. Gill ATONY COMMISSION l
- p. E WASHINGTON. O C. 20'45 5 '- l
's, . . . . . / ATTACHMENT B January 19, 1976 Ronald A. Drightsen. Assistant Director for Licensing, MEH0RAf100M FOR:
Division of Safeguards FROM:
Carl H. Builder, Director, Division of Safeguards
~
l
SUBJECT:
ADEQUACY OF CURREilf SAFEGUARDS l
The adequacy of safeguards is the central question that we have been struggling to approach in our GESl10-related activitics over the past What is six months. The orientation of GESMO is toward the future:
an adequate safeguards posture if the nation embarks upon the wide-scale use of mixed oxide (recycled plutonium) fuel in light water reactors? The draft safeguards supplement to GCSMO, scheduled for i
publication in March, should provide the analytical As theseand tedhnical frame-frameworks
! works within which that question can be judged.
emerge, however, it becomes apparcut that they are not limited to future safeguards; they may be equally suited to judge the adequacy of current
- ' safeguards.
Over the past six months,
' We recognized this eventuality some time ago.
I have been questioned several times as to the adequacy of current safcguards. I have replied that I was not in a position to judge current safeguards as adequate or inadequato until we had logically structured both the safeguards problem and our approach to solutions.
4 Only then, 1 argued, would we In understand response to the measures the question by which of when we we judge the adequacy of safeguards.
would be in a position to make such judgments, I have stated that the safeguards portion of GCSMO could not be completed until we possesse
! . these logical structures or frameworks.
Fortunately, the logic has been found and tite structures have beenThe assembled by some very r.apabic people who have werhed very hard.
i safeguards supplement to the GCSMO is now being drafLed around th
- - framcuorks, as are interim licensing rules.
will see the dennuement of our six-month struggle to gain a position 3 where the adequacy of safeguards might be rationally judged.
9904090142 760202 PDR ADOCK 07000008 PDR C
. . _d
F January 19, 1976 Ponald A. Orightsen l
Thus, the time is almost upon us now, where we shall not nnly want to l
make judgments about future safeguards for mixed oxide fuel cycles, but be compelled by our public obligations to make judgments about the The moment such judg-adequacy or inadequacy of current safeguards.
ments are possible, we must be prepared to mcyc promptly to advise the Commissioners of any apparent inadequacies. We must be prepared to support such judgments with the available facts, but we should not allow fact-finding activitics to become an excuse for delaying reasonable I am soliciting
- judgments where public safety and security are involved.
your assistance in preparation for the eventuality that we may judge current safcguards to be inadequate at one or more licensed facilities.
The analytical and technical Nmeworks developed for GESrio focus on the thef t of nuclear materials, suitable in quantity and form for the illicit manufacture of nuclear explosives, as the overriding concern of safeguards. We must have a safeguards posture that provides high confidence ia cur ability to prevent the theft of significant quar,titics of special nuclear materials (SUM). Significant quantitic,s have been
- established at five formula kilograms [as defined in 10 CFR Section l
73.l(b)],abouthalftheminimumrequiredforthemanufactureofanillicit nuclear explosivo. Thus, physical protection measures and material con-trols (i.e., containment, access, and accounting procedures) must be deemed adequate to prevent (not just dctcct) the thef t of five formula i kilograms of SUM.
l He have tried to avoid the specifics of potential threats in developing l the analytical framework for GESh0 because such specifics are fraught Out we have not succeeded, l with uncertainty and are invitations to argument. !
there does not appear to be any way that we can analytically divorce the design bilities. of adequate safeguards from the specification of threat
' capabilitics, we have been forced to design safeguards across a range of l threat levels, recognizing that the final choice of design threat is a '
judgment' call. We have varied the design threat from lowest to the In between these extremes, we i highest lovcis that have been suggested.
must admit that there is- room for opinion as to where the design threat should be set and, hence, what constitutes adequate saicguards.
Dut at the lowest levels of design threat, we have the opportunity to L
define what have been called " insufficiency criteria," to define how much l
safeguards are not enough. If safcguards are not adequato against the
' lowest levels of design threat that have been suggested, then we must logically conclude that such saferuards are inadequate, quite apart from
- the uncertainty we may accept abnt t what consistutes adequate safeguards.
I am concerned that some or even many of our currently licensed facilitics may not have safeguards which arc ancquate against the lowest levels of design threat we are considering n GESMO.
J
r l
l lonald A. Brightsen January 19, 1976 The design threats in the safeguards supplement to GESMO are diviced Many l into an internal (diversion) and an external (assault) threat.
parameters or considerations iuust be taken into account in-describing or specifying such threats. To simplify these descriptions, we have assumed that all of these parameters (e.g. , motivation, training, arms, equipment, employment position, etc.) are fixed at worst-case values with respect to safeguards, and that the only remaining variabic is the number of peopic involved in the threat. For a nominal or base-line threat, as a point of departure, we have assumed that the internal and external threats are two and six persons, respectively. The range of numbers suggested by thrcat researchers, expert opinion, and partisan conments generally lie within a factor of two, up and down, from this baseline specification. Thus, the lowest levels of design threat i
being considered in Gl'Sf40 arc, for an internal threat, one person and, for an external threat, three persons. I don't know of any serious suggestion that these levels are too high and that'uc should consider even lower levels as design threats for adequate safeguards.
l The logical conclusion from all this is that current safeguards must be l presumed inadequate if they cannot effectively counter internal It does not,threats of.
of one person or external threats of three persons.
course, say that they are adequate if they can cf fcctively counter these same threats. Dut there should be a higher urgency to correct what is clearly inadequate, even before finally dcLermining what is adequate. Thus, while we are cuattiag further judgments about what may be a prudent design threat level,1 '.hink we are obliged to act promptly where safeguards are insufficient against threat levels that are at the lower extreme of what may be judgpd prudent. -
Thetoughquestionswemaysoonhhvctoanswerforourselvesabout currently licensed facilitics (and associated transportation) are these:
- 1. Are present material control procedures sufficient to prevent, with a high degree of assurance, the theft of more than five formula kilograms of Sl!M hy any single employee .in any position in any single thef t or in any continuing series of thof ts over a period of ,up to one year?
- 2. Arc present' physical protection procedurcs sufficient to prevent, with a high degree of assurance, the theft of more than five formula kilograns of SilM by means of a well-planned and coordinated assault by three persons, one of whom may be an employee in collusion, having the equivalent of military .
training and equipment?
im\ .
E I e . . .
l l
January 19, i m Ronald A. Drightsen If a high degree of a*surance needs to be quantified, I would sugges that something like 99-percent confidence should be invoked.
Iftheanswerstothencquestionsredilydependuponfurther definition _or explanation of the qocctions, we should engage in that If the answers are '"no," we should move dialogue inmediately.
promptly to establish why and, I think youin general can help us get terms, these what would
- to change the answer to "ycs."
answers soon.
In the weeks just ahead, we must act wif.h due care toward ou responsibilitics to the public, the Comr.iissioners, and the licensec We'should not be precipitous, for there Cut cautionis potential should notfor great har we rush to or act on erroncous conclusions.
paralyze and security.
us in view of our enormous responsibilitic I would urge that we act with both the there may be no cosy avenues.
care and courage that these times deserve, now and when we upon wilat we did at this important juncture.
c.'. /
Carl 11. Builder, Director Division of Safeguards l
l 1
3.
~
s 1
)
i g . ,
~
g s <
- . .. . a i ,
L