ML20235A799
| ML20235A799 | |
| Person / Time | |
|---|---|
| Site: | 07001193 |
| Issue date: | 02/03/1978 |
| From: | Hind J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Trubatch S NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| Shared Package | |
| ML20234F575 | List:
|
| References | |
| FOIA-86-410 NUDOCS 8707080541 | |
| Download: ML20235A799 (2) | |
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jf \; . NUCLEAR REGULATORY COMMISSION REGloN lit S
- February 3, 1978 Docket No. 70-1193 I
MEMORANDUM FOR: Sheldon L. Trubatch,-Office of the. General Counsel, Headquarters FROM: J. A. Hind, Chief, Safeguards Branch
SUBJECT:
REGION Ill DIVERSION RISK ANALYSIS STUDY ON ,
KERR-MCGEE PLUTONIUM FACILITY (10 CFR 2.790(d)
INFORMATION)
As you requested during your telephone call of February 2, 1978 to me, here are my reasons why the subject study which was forwarded on December 9,1974 to John Davis, Deputy Director for Field Operations, Directorate of Regulatory Operations should not be released to the parties involved.in the present legal action with Kerr-McGee concerning the Karen Silkwood incident:
A. This Region III study was a prototype Diversion Risk Analysis and was submitted to Headquarters for review and consideration before a standard analysis format was established. A standard analysis format was never established. Therefore, since this study has not been formally analyzed and commented on, it still represents a "best-effort" endeavor and we could possibly be questioned or even criticized on the use and derivation of some of our more subjective comments and assumptions.
B. The study details the features of the facility physical security programs of which many are still in effect.
C. The study points outs weaknesses and vulnerabilities in the facility's physical security and material control and accounting systems that could also be applicable to other similar sites. Some are still applicable to the Kerr-McGee facility.
1 41 870701 0 PD" 97070%s^6-41 P%gNER g
l lhI0flMll0h In thil f000rd W3s deleted h accordance with th freedom of Information Act,IXinj
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f Sheldon L. Trubatch February 3, 1978 D. The report details chemical processing steps required to develop an explosive threat from the common material form at Kerr-McGee.
These types of material are presently at other sites.
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, . fiknI, Chief j Safeguards Branch cc: N. Haller, IE
DEC 9 1974 l
I John C. Davis, Deputy Director for Field Operations Directorate of Regulatory Operations, Headquarters I DIVERSION RISK ANALYSIS - HAJOR FUEL FR0 CESSING FACILTIES DOCKET 50. 70-1193 As requested in your memo of November 18, 1974, sa=* anMeet, enclosed is our prototype diversion risk analysis for the irr-HeGe lutonium Facility. Our evaluation contains relative fact'bts (co 111ty, availability, etc.) which have been estimated for this study.
! The final format of the Response Flans will most likely require
.j licensees to take certain actions presently not required by regulation.
i If these actions are that important, strong consideration should be given to amanding appropriate licenses or additional reguistions.
James C. Keppler Regional Director
Enclosure:
As stated above (10 CPR 2.790 Information) ec: C. W. Kuhlman, RO, w/anci
+ J. C. Whitaker, 10, w/enci l RO Files DR Central Files Sam Bryan, RO:III Coordinator ,
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.u....., Donahue/ Ridp a Hin D h ,
o.v. , 12/9/74 12]9/74 12/9/k 3 Form AEC 31s (Rev. S$3) ABCM 0340 W u. s. oovannuswv raiwrime orricas seva. masses
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l DIVERSION RISK ANALYSIS AND RESPONSE PLAN i.
I Kerr-McGee' Nuclear Corporation Kerr-McGee Center Oklahoma City, Oklahoma Facility:
Kerr-McGee Nuclear Corporation Cimarron Facility Plutonium Fuel Plant Crescent, Oklahoma Docket No. 70-1193 License No. SNM-1174 Prepared By: Regulatory Operations Region III h terials and Plant Protection Branch l
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d Location of Facility, Physical Layout of Plant and Access Controls The Kerr-McGee Plutonium Plant is situated in a rural area of Logan i
County, Oklahoma about four miles south of Crescent, ten miles vest of Guthrie and twenty-eight miles north of Oklahoma City. The site i is one-half mile north of State Highway 33 and is bordered on the vest by State Highway 74.
The Plutonium Plant shares the same land tract as the Uranium Plant and the entire site is commonly identified as the Cimarron Facility.
(See Exhibit No. 1) Encompassing the company-owned land is a peri-meter fence which deters the entry on company property by unauthorized persons. (See Exhibit No. 2) Employees enter the site proper through an outer vehicle gate either controlled by card key or by surveillance of a guard. Employees park their vehicles nearby the plant in which they work. Visitors are not permitted to park within the outer fence line. They are allcwed entry on foot af ter co=municating via intercom with the guard at Post #2 in the Uranium Plant. Identification and initial registration is accomplished at Post #2.
A separate security fence surrounds the Plutonium Plant. This barrier forms the erimeter of the rotected area and this barrier is protected by a ystem. (See Exhibit No. 3) The fence has emergency exit gates and a vehttular gate, all of which are locked and not operable from outside the fence line. The presence of private vehicles within the protected area fence is prohibited.
The main entrance for the Pu Plant is on the south wal behind the security fence. The fence entr ate is uate (See it No. 4 r to entrance to t y, t e employees' snd visitors pass through a If the earch is negative, the guard '
the entry door'. Once in the oxes, cases an packages are ;
by the guard. Employees leave their lunch boxes n t e lunch room.
Visitors are identified, the visitee is contacted and escort is pro-vided.
Within an leading from the guard post to the office section are a are conducted of each individual as be enters or leaves the bu ing through this corridor. Physical inspection cf lunch boxes and handc.arried articles is accomplished by a guard on egress from the building through guard post #1.
The general office area for the Pu Plant is in the southwest secti of the building. The material access area (MAA) perimeter is i 1
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M respec-t weay. These doors are ei;10, *ed with ose combination is limited to employees who arc authorize access to within the MAA.
The plant internals are separated as material balance areas (MEA) and accountability records are maintained for each MBA. (See Exhibit No. 9) j Oa the perimeter of the Pu Plant there are xits and I one material and man door all of which are i g% On the there is a door leading to an air lock which is adjacent to the@
all of the plant l
Immediately outside this door is an ecause this % monitor is remote, a as been positioned in the air lock to view he swellasthegf leading to the dock. The guard at Post #1 has ic: mediate visual survei lance c abili in the event of an which 1 leads to th dock.
There is one other opening in t e Pu Plant on the % all. This con-sists of a tn permit the introduction of Uranium Plant sam les into the Pu uilding for spectrographic analysis. This g tarou ,
is within the rotected area fence access is controlled by activisted by the uard at Post fl. License Condition 9.3.2 (b) permits the use of this The opening has been modified by a series of baffle ates which reclude. tb i.rt.asfer of material to the outside. In addition, an is used to assure that SNM is not diverted through this opening.
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MATERIAL POSSESSED Licensed Possession Licensed Limit Usual Usual Material and Form Inventory Forms Plutonium 360 kgs 300 kgs Plutonium Nitrate as oxide (PN) e 200 g/l !
(239 principal isotope) or other maximum. Plutonium compounds and Uranyl nitrate (MN). Plutoniur.-
uranium diurantte Pu-U dioxide (MO)
MO pellets M0 pins Plutonium-238 2 gs 2 gs sealed source sealed source Enriched Uranium 1050 g, U-235 0.0>20Wt.%
Uranium-233 100 mg --
Plutonium-242 5 mg --
Uranium, natural 3200 kgs Uranyl nitrate Mixed nitrate MO powders MO pellets MO pins
Security plan Salient Features to prevent diversion: f l 1. Outer perimeter fence to protect owner-controlled area.
l 2. Access controls at outer fence line to preclude unauthorized entry to the general site.
- 3. Identification and registration of non-employees at Post #2 (Uranium Plant Guard Office) prior to permitting further move-ment toward the Pu Plant.
- 4. SecurityfencesurroundingPuPlantprotectegareawhosegates
- 5. protecting rimeter of Pu P1 rotected area.
- 6. ate monitored by Guard at Post #1 in Pu Plant to control personnel access to protected area.
- 7. Protective lighting of protected area fence meets or exceedo 0.2 foot candle illumination levels.
- 8. Access controlled by Guard at of Pu Plant.
of handcarried articles ptior to permitting urt er movement into the building proper.
- 9. searches of individuals as th roceed into ding
- 10. n entry portals of the material access a a.
scor itors while within the area.
- 11. on all emergency exits of the material access
- 12. larm annunciation s ions for alarmsf
- 13. rovide uard surveillance a exit door in event of or M7 a tivation.
- 14. monitor at M xit door. 1
- 15. on pass-throu .a ir-1 pek . Baffle plates !
within t o preclude movement of material to the outside.
- 16. Personnel searches by on leavi the materia access area.
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- 17. of all materials leaving the material access area for the office, shipment or burial are conducted by Health Physics personnel for contamination clearance. No package is permitted to exit the area without investigation of the contents.
Tool boxes required for maintenance are given piece by piece mination b both Health Physics and the uard.
- 18. are located in the
- 19. Emergency power provided for alarm system, i
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uards and an armed supervisor are assigned to the
- 20. % rme site
- 21. means of communication exist between guards and he site and local law enf orcement agency.
- 22. Procedures devel d for res dins; to alarms of intrusion devices or devices.
- 23. Tests of system within specified time imit. I Tests of are con-ducted daily. Physica arr ers o protecte area nspected daily.
- 24. Lists of personnel authorized entry into the material access and vital areas is maintained by guards and supervisors. List is dated and revised each time a r.hange occurs.
- 25. Identification badges issued to authorized personnel, S
% o distinguish degree of access.
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Assessment of Risk Security Plan - Description and analysis of effectiveness of features -
Weaknesses identified.
1 The licensee security plan has been strengthened by imposition of l
License Conditions by Licensing. During calendar year 1974, three l physical protection inspections were conducted by RO:III. An in-spection of May 6-9, 1974, disclosed violations resulting; mainly from the transition to Part 73 regulations and failure to meet licensing - prescribed dates for equipoent installation and oper-ation. The most recent follow-up inspection conducted on September 11, 1974, disclosed that considerable progress had been made in implement-ing corrective actions. Two violations, relating to License Con-ditions, were disclosed during this inspection. According to the licensee, the noted violations have been corrected.
The security plan and license conditions providt. for an increcsing degree of otection as one approaches or enters the material access area. control points are provided to deter ready access to In addition, the physical barriers presented by the construction of the Pu Plant and the system on the perimeter doors of the building provide acc table deterrents to forced entry. This, along with the presence of armed security force personnel on !
the site at all times provides in our opinion, an adequate degree of l
' I protection against undetected intrusion.
l Other features of the security plan provide for control cf persons l
within the Pu Plant and strategically placed j M upplement ee and exit searches conduct e guard.
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! The availability of t the and the are intended to eter ivers on of S!Of a%t t ose points.
l k ness in the A we,Ji is presented ht the has its tat ons. Although t 4 o assur onformance to Regulatory Guide there is the probability that ould not be detectable if carried f out in It would be a time consuming feat to carry out a sufficient quantity of S!Of usable as an. explosives threat and in all probability, accountability records maintained in the Material Balance Areas Vould detect appreci-able shortages because of the frequency of inventories. It is pointed out, however, that an employee could obtain and carry out small sample quantities that are highly contaminating and a radiological 1 l
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threat could result.
Recently, RO:III was a ised by. the 1,1censee Security Of ficer that tests were made of th_e on ed in plastic. These samples consisted of The unshielded sa les were carried through the
' porta monitors The results o e tests were:
Alarm Frequency Quantity 25%
E 75%
95%
Verification of these reported test results has not been made by RO:III through independent testing.
area Another potential weakness is presented in the , pass which leads to the Was barrels are taken rom t proceed into the and th nee through the A through the material-man oor leadi to the t th s portal. The is not used in conjunction vi variably creates a larm movement of vaste throu.h the and the Guard at Post can view the area nt e The individual involve g o determine the alarm cause. taking movement of waste could conceivably conceal ShH aused by advantage of the M eaused by the vaste to possible diversion. In the Myard adjacent to the dock are three The west immobile vans, one of which is used for storage of waste. alarm and a security ;
side of the yard is protected by an l fence. About 20 feet outside this vest fence is another fence pro- !
On the north and east fence peri-tecting the owner-controlled land. The meters there is no " buffer" fence for the owner-controlled area.
north and east barriers are formed by the protected area It is fence and both possible l sections are protected by active intrusion alarms. '
that an individual could throw a small container of SLH over the north or east fence sections and return later to recover it from out-side of the fence.
the final product, fuel Also, with respect to the .
pine..are in sealed shipping boxes in bird-cages which measure about On movement of the material through a roll-up door nine feet long.
into the air-leck toward the material-man door leading to the dock, the " shine" of the ShN creates ersonnel even though the material is not directly moved t roug involved in product movement could conceivably take advantage of the
ttempt diversion from the plant to the outer oc or yard area which are within the protected area alarm-pro-tected perimeter fence. If an opportunity presented itself, material could be thrown over the north or east fence sections for possible pick up from outside these fence lines.
i With further respect to waste or product retraval through thM l it is established procedure that all material exiting the ant e checked for contamination by Health Physics personnel. While this procedure may tend to deter diversion of items hidden in waste drums or shi in containers, there are no provisions for involved in material movement, et er than those who may have to exit through the to reach the work area. Normally, several individuals are involved in each move-ment of final product so personnel mobility may be limited by personal surveillance of each other. If diversion of material thrown over the fence is made, collusion between employees would be required. On occasion, however, only one single individual may be involved in vaste removal and his movements outside the plant building within the pro-tected area fence would not normally be observed.
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M LESSMENT OF M Q Suitability and availability of materials. (See Exhibit No. 6)
. Material Forms Available A list of material forms available at the K-M Plutonium Plant are listed below with the normal location within plant material balance areas.
The license permits plutonium oxides and other compounds and there-fore excludes plutonium as metal. The license also permits 1050 grams of enriched uranium and this limit was included to cover analytical samples received from the Uranium Plant nearby and ether analytical programs. The Uranium Plant license permits only 350 gr of uranium of enrichment greater than 20Wt.% and at present there is essentially none of this material on hand. Therefore, the evaluation of U-235 threat has been excluded in this study.
K-M receives plutonium nitrate in L-10 shipping containers. After receipt these containers are stored in the vault until they are needed for production. Average shipment is 40 Kgs Pa in about 23 containers of about 1700 g Pu each. Along with each shipment is a 3L container with 3g samples of each Pu nitrete lot.
The L-10 containers are coved to Room 128 and the 10 liter bottle re-moved and weighed in GB 3A, a sample taken and contents transferred to GB 3B. The bottle is rinsed and dried to obtain a tare weight and net weight to determine any shipper-receiver difference. l The Pu nitrate is then blended and cress blended with natural uranyl nitrate to give a 3 to 1 U/Pu ratio and crossblended to give a uni-form mixture. The blend is stored in wall storage tanks encased in the east wall of the vault.
Mixed nitrate is then coprecipitated continuously in GB 5A, Room 128, and filtered in an open pan filter. The filtrate is caught in a receiver tank, pumped through a second filter to receiver tanks in GB SB. The filtrate is sampled and discarded by mixing with cement 0.01 in 55-gallon drums. The liquid waste prior to cementing average grams per liter Pu.
The coprecipitated cake is transferred by hand from the panisfilter intro-to calciner boats, moved through a tunnel to GB 6A where it duced into the inert gas calciner. Calcined mixed oxide is removed from the calciner in GB 6B and allowed to cool. The MO is then milled and blended in adjacent GB 5 in 10 Kg batches. Two samples are taken from each batch. Blended M0 powder is charged in 2 liter
' or 3 liter cans, placed in the portable glovebox (GB) and the GE j moved to Room 124 for pelleting or in the vault for temporary
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storage. These operations are all carried out in an enert atmos- {
phere. z In Room 124 the 2 or 3 liter cans moved from the portable GD into the room GB. The M0 powder is slugged into pellets, granulated.
to 20 mee h and collected in 2 liter cans and calcined again to adjust the 0/M ration, j l
The reduced M0 powder is then pressed into pellets, sintered, ground to size, 6pd inspected. The certified pellets are placed in one-half liter cans, moved through a tunnel into GB 18 located in Roou 123 J and stored there in vertical tubes located in the concrete base of !
the GB. The average pellet weight (s 1.2 g and contains 0.3 g Pu.
Each can of pellets containe about 1400 g Pu. Rejected pellets are put into 1 liter cans and transferred to the vault or Room 127 for i recovery. The cans average 2800 g Pu.
1 Certified pellets are loaded into the cladding (110 in each pin) and the cladding tubes welded closed. Each completed pin contains about 42 g Pu. The 7 foot long pins are moved through x-ray into Room 121 where they are cleaned, inspected and stored in vertical pipes buried in the concrete floor of the room.
One-hundred-1.senty certified pins are placed in each Model 60 shipping container, 5040 g Pu, for shipment to the customer. The loaded Model 60 container weighs about 800 pounds.
Along with the numerous samples taken, many different types of wastes are also generated during the processing. These will mainly contain various quantities and purities of the 3/1 uranium-plutonium mix.
Some MO wastes can be recovered and recycled directly to the recycle feed tank. Most must be processed to purify them. Combustible wastes are burned and the ash collected in 220 gram batches and stored in 1-2 liter cans in the vault or dissolved along with other impure MO wastes. The dissolved wastes are stored in vall storage tanks until sufficient inventory has been collected to economically operate the solvent extration system (SX). The dissolved waste is fed to the SX battery with pure mixed nitrate solution collected in wall storage tanks. The vaste solutions are processed through an ion exchanged system to remove almost all the plutonium and sent to the waste solid-ification process. The dilute plutonium vastes, 0.0? g/l Pu, is mixed with cement in lined 55-gallon drums and these are stored in the locked waste trailer located at the west side of the Plutonium Facility. The drums weigh about 800 pounds and generally contain less than 2 g Pu.
Other slightly contaminated dry wastes i.e. wipes, gloves, swabs, empty containers, etc. , are also collected in 55-gallon drums and placed in the trailer for storage until a shipment to burial is scheduled. These waste drums usually contain an average of 2 g Pu.
Occasionally spent resin from the ion exchange must be disposed of and cemented drums of this material may contain up to 30 g Pu but weigh 800-1100 pounds.
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l The larce size and weight of the 55-gallon drums and the sus 11 quantity of contained and difficu)c to recover plutonium make the theft risk of these materia)6 so low as to be ignored in this study. However, the dry easte drums could be employed to move other plutonium materir,is through the SNM detectors to get ther outside of the facility.
Containers Normally Used and Average Contents L-10 Shipping container and 10 liter bottle 1900 g Fu as Pu nitrate (pun)
L-3 or 6M Shipping Container (samples) 20 g Pc as Pu nitrate (pun)
Model 60 Shipping Container (FFTF Pins) 5040 g Pu es M0 Pins (Lab Waste) 2 g Fu - any Gallon Bottle 3 liter cans 2600 g Fu as MO Powder 2 liter cans 1730 g Pu as MO Powder 1 liter cans 850 g Pu as MO Powder 1 liter cans 2600 g Pu as M0 Pellets 1/2 liter cans 1400 g Pu as MO Pellets 1 liter bottle (Lab Recycle) 200 g Pu as pun 25 m1 bottle (samples) 50 g Fu as pun 25 m1 bottle (samples) 70 g Pu MO Powder 5 m1 bottle (samples) 10 g Pu as pun Material Balance Aress and Estimated Inventories Est. Inv.,* g Pu MBA-11 Scrap Recovering, Room 127 11,800 ry 600 183,600
-13 Wet Ceramic, Room 128 60,000 MBA-21 Pe. net Fabricatica 5,000 East Storage 200 MBA-22 MEA-23 West Storage 23,000 MBA-31 Fuel Pin Storage 16.000 300,000
- Considerable variance could be expected between the MBA iventories at different times.
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Suitability of Material for Explosive Threat It is assumed that a trigger quantity of 2 Kgs Pu metal would be required to pose an explosive threat. It is assumed that mixed oxide and solution would also require refining and processing to metal to provide an explosion. After diversion the following chemical processing steps would be required to develope an explosive threat from the common material forms at K-M.
Plutonium Mixed Oxides H1xed Nitrate Solution Nitrate Solution
- 1. Dissolution 1. Pu-U Separation 1. Precipitation
- 2. Pu-U Separation a. Solvent Ext. 2. Calcination
- a. Solvent Extratien b. Ion Exchange 3. Fluorination
- b. Ion Exchange 2. Precipitation 4. Reduction
- 3. Precipitation 3. Calcination 5. Casting
- 4. Calcination 4. Fluorination
- 5. Fluorination 5. Reduction to metal
- 6. Reduction to Metal 6. Casting
- 7. Casting Each of the processing steps would result in some loss cf ' plutonium so the following explosive suitability factors are based upon the number of steps required in processing to an explosive device.
Explosive Suitability Factor Plutonium Nitrate Solutions 1.2 Mixed Nitrates Solutions 1.25 Mixed Oxides 1.3 :
1 Two other elements not included in the suitability factors are time )
I and complexity. The more steps required to f abricate an explosive device would take time and also lead to the possible early detection because of contamination spread. An undetected diversion by individuals outside the K-M organizatica is improbable, therefore, the individuals doing the processing would be reporting to work as scheduled and the detection of any contamination spread could eventually be discovered. 4 The above suitability factore are used to iperease the amount of 1 plutonium required for a trigger quantity. l 1
Explosive Threat The explosive threat is based upon the suitability of the material, the quantity of plutonium in each container, the conteiner size, the container weight, and the possibility of detection during a diversion.
The container concealability factor is based upon the volume of each container as follows:
Container Concealability Factor Greater than 20 liters volume 10.0 Four liters to 20 liters volume 4.0 Three to four liters volume 3.0 Two to three liters volume 2.0 One to two liters volume 1.0 Less than one liter 0.1 The higher the factor, the more difficult to conceal.
The container handling factor is based upon the total container weight and factors in the requirement that the large heavy containers would require more than one individual to handle.
Container Handling Factor Greater than 50 pounds container weight"-50x2 Ten pounds to 50 pounds 2.0 One pound to ten pounds 1.5 {
Less than one pound 1.0 (
The higher the factor, the more difficult to carry.
The container detectability f actor is based upon the quantity of contained plutonium and the resultant possibilities of detection by i I
the SNM counters.
Container Detectability Factor Greater than 10 grams Pu 5.0 One to 10 grams Pu 2.0 One-half to 1 gram Pu 1.0 Less than one-half gram 0.5 The hig'her the f actor, the higher the possibility of being detected.
The concealability, handleability, and detectability factors are summed for each container giving the diversion risk f actor for that particular container. The higher the factor, the more difficult to divert the container.
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1 Not included in the risk factor is the plent location of the con- l tainer, it would be more difficult to remove a container from l storage wells, some glove boxes or the vault without detection, j However, all the containers are at some time in transit within the l plant and during this operation the containers are considered equally accessable.
The threat from a critical device fabricated from the contents of each container is based upon the number of thefts required to ob- l tain the modified trigger quantity and the detectability factor of the container and is given as the inverse ratio in the table In other rds, the table indicates that th as the highest diversion rating for an explosive t rea .
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Suitability of Material Forms for Radio 1cgical Threat Criticality Threat The material suitability for a radiological threat has been divided into two categories, criticality and contraination. The threat of a criticality would require a finite quantity; the amount depending upon the SNM composition, configuration and surroundings. The mini-I mum critical masses for the various SNM forms available at the normal isotopic content and optimum moderation and configuration is shown below.
l Material Forms Critical Mass, g Pu Mixed oxide powders as slurry 770 Plutonium nitrate solutions 790 Mixed nitrate solutions 830 M0 Pins 6300 150 pins M0 Pellets 6300 (2) 21,900 The physiological threat from a criticality burst would be limited to a small area and therefore would harm only a small population.
The criticality would be of limited physiological effect as compared to an explosive device and the main threat would probably be loss of property through contamination.
The threat from a critical device is then based upon the number of thef ts required to obtain enough plutonium and the diversion risk factor for each container. In other words, the table indicates the 1-liter can of MO oxide powder has the highest diversion rating for a criticality radiological threat.
Radiological Contamination The suitability of plutonium or mixture of plutonium and uranium for posing a radiological contamination threat is based upon the threat to human life from inhalation or ingestion and the loss or damage to property by contamination. The largest property damage and possibly the greatest human threat would be caused by dispersing a fine powder from a tall building upwind of a large population center. A release of this type would be similar to a stack release and the distribution of plutonium can be estimated.
The distribution from such a release would vary with particle size, shape and density, release rate, windspeed, and spread of the result-ing cloud. The threat to human life would be greater near the release point where concentrations are higher, while the loss of property or cost of decontamination would not vary significantly. The threat
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1 varies.with the quantity of plutonium released and the form in which it is released. For instance, the release of pins or pellets would not pose a significant threat and the release of liquids would not pose as significant a probletn as fine powder unless it was released by some type of atomizing equipment. ,
i In the case of soluable plutonium nitrate for instance, being put into a water supply, the plutonium would be diluted, polymerized and settle out on the bottom of the reservoir as would insoluable j mixed oxide powders. 'The small amount of plutonium carried in the water supply would depend again upon the reservoir size, particle j sizes, etc. Such an instance would not be of a significant death !
threat, however, the reservoir and possibly all the mains and piping would eventually have to be replaced.
In either of the cases above, airborne dispersed or dispersal in the water supply would give. only a limited threat to human life but the property loss or damage could be very large.
The suitability of material for a contamination threat depends upon material type and is categorized in the following table:
Suitability for Contamination M0 Powders 5.0 Pu Nitrate 3.0 M0 Pellets 1.5 M0 Fuel Pins 1.0 The higher the factor, the more suitable for contamination.
One hundred grams Pu is arbitrarily taken as the radiological mass and the radiological threat then becomes the ratio of the radiological mass times material suitability to the diversion risk.
The table indicates that the 3-liter can of M0 powder (13.0) has the highest rating for a radiological contamination threat.
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. _ Response Plan l
(1) MUF in excess of LEMUF Licensee Response:
(a) Advise RO:III of excessive MUF as stipulated in Part 70 or License Conditions.
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(b) Re-evaluate all components of the material balance con-tributing to the MUF and review security program for deviations. '
(c) Conduct investigation and report in accordance with 10 CFR l 70.53.
(d) If MUF >2.0 LEMUF, suspend operations and take a new inventory. ;
l (e) Restart operations after approval of AEC.
(2) Security Incidents - Including Actual Sabotage Licensee Response:
(a) Advise RO:III imediately - provide ascessment of dac. age or potential threat to health and safety of public.
(b) Institute imediate fact gathering investigation.
(c) Nctify LLEA - request assistance if required.
(d) Increase guard force size to cope with situation.
(e) Increase in-plant surveillance measures.
RO:III Response:
j (a) Advise RO:HQ and FBI of incident (b) Dispatch inspector to site. l l
(c) Keep RO:HQ apprised of developments.
(3) Sabotage Threats l
Licensee Response:
(a) Institute emergency plan.
(b) Advise RO:III of threat.
(c) Notify LLEA and request assistance if required.
(d) Incr. ease oize of guard force.
(e) Conduct foot and vehicular patrols of site.
RO:III Re.sponse:
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(a) Advise RO:HQ and FBI of threat.
(b) Assess the adequacy of the licensee actions to cope with the threat.
(c) If determined necessary, dispatch inspectors to the site.
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c (d) Keep R0:HQ advised of situation. ,
I (4) Civil or Labor Strife Licensee Response:
(a) Advise RO:III of situation.
(b) Determine need for strengthening security force.
(c) Request support from LLEA if deemed necessary.
(d) Increase in-plant surveillance.
RO:III Response:
(a) Advise R0:HQ of situation.
(b) Ascertain adequacy of licensee actions to cope with the situation.
(c) If deemed necessary, dispatch inspector to site.
(d) Keep RO:HQ apprised of developments.
1 (5) Theft of Material - Known or Suspected Licensee Response:
(a) Notify RO:III, FBI, and LLEA of incident.
(b) If possible, ascertain form and quantity of missing material.
(c) If theft involves trigger quantity of material institute immediate inventory first of items of highest diversion ratings. Complete remaining parts of inventory.
(d) If less than trigger quantities, institute immediate in-ventory of all items.
(e) Interview supervisors, workers, etc., who would be involved with the theft.
(f) Review security program implementation with particular attention to checking of personnel monitors.
RO:III Response:
(a) Notify RO:HQ of incident. {
(b) Dispatch Investigation / Inspection team to site. ]
(c) Interview persons knowledgeable of event. l (d) Assure adequacy of actions taken by licensee. )
(e) Keep K0:HQ epprised of developments. i
)
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4
- 1 1
I
M Extortion Threat - Facility Named in Threat t
(6) ;
I 1
Licensee Response:
\
(a) Notify RO:III of threat, f (b) Notify LLEA - request assistance if required by nature of )
threat.
(c) Increase security force size.
(d) Step up protective patrol frequency.
(e) Increase in-plant surveillance.
(f) Conduct inventory if threat implies possible theft of material according to highest diversion rating and type of threat.
(g) If less than eight hours, inventory and check material of 1
highest diversion rating.
(h) If time permits, continue to inventory and check material of lower diversion rating.
RO:III Response:
(a) Advise RO:HQ of threat.
(b) Evaluate licensee's actions to assure their adequacy.
(c) If substantive threat is posed, dispatch inspector to site.
(d) Keep R0:HQ advised of developments.
(7) Extortion Threat - General 1 Licensee Response:
(a) Respond to requests from RO:III for information.
(b) Conduct it:ventories by diversion rating as time allowed to determine if any material is missing, j RO:III Response:
(a) Upon receipt of Extortion threat notification f rom RO:HQ, telephonically contact all ef fected licensees and request:
(1) Information regatding any missing material according to diversion rating.
(2) Information regarding any SNM in transit.
(3) Inventory by diversion rating to determine if any l material is missing.
(b) Keep RO:HQ advised of findings.
OR l (c) If extortion threat information it received from source i l
4 1
b
other than RO:HQ:
(1) Advise RO:HQ of threat.
(2) Contact affected licensees by phone to inquire regarding missing material according to diversion rating.
(3) Request information regarding SNM shipments in transit.
(4) Request inventory by diversion rating as time allows.
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E Cross Section fg u 96 he or j, ,3 eo Diameter Beight Volume Weight "U ggu Inches Inches Litera Pounds S $0 '
CONTAINER Model 60 shipping MO 18 x18 113 600 800 5040 10 Container Pins 32 Room 121 L-10 Shipping pun 23.5 67 416 500 Container 1700 10 20 'ault v
Room 128 L-3 or 6M Shipping pun 23.5 33 208 Container 400 20 10 16 Vaul t samples 55-Callon Waste Any 23.5 33 208 Drum 50 2 10 2 BO-1 Hallwsys Trailer 10 Liter Bottle pun 5 72 14 36 1700 4 2 vault I Room'128 1-Gallon Waste pun 6.3 Jugs 9 4.5 6 2 4 MN 1,5 Laboratory FFTF Pins (62) H.O. 3 102 12 50 2604 4 2 Room ' 21 Room 123 j 3 Liter Can Ho 5 9 3 26 2600 3 Powder 2 Room 128 Room 124 Vault 2 Liter Can Ho 4 11 2 17 1730 Powder 2 Poj,t.CB 2
1 Liter can MO 4 5.5 1 8.5 850 1 u Powder 3,3 l 1 Liter Can Ho 4 5.5 1 28 2800 1 j Pellets 2 vault l
Room 124 Room 127 1 Liter Bottle pun 3 8 3.5 1 200 1 1,5 Vault Laboratory 1/2 Liter can Ho 3 4 .5 14 1400 1 2 Room 123 Pellets Room 124 25 ML Bottles MO Powder 1 2 .025 .5 70 .1 !1 Laboratory Y""
25 ML Bottles pun 1 2 .025 .3 50 .1 '1 Laboratory Vault
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, vault 1/2 Gram Pu .5 .1 1 Laboratory Vault 1/4 Gram Pu .25 .1 1 Laboratory Vault 1 Milligram Pu
.001 .1 1 Laboratory Vault L .. ,