ML25260A565

SECY-78-93: Us Position on IAEA Safeguards Effectiveness Principles as Detailed in State Cable 254712 of October 23, 1977

ML25260A565
Person / Time
Issue date:	02/14/1978
From:	James Shea NRC/OIP
To:	Commissioners NRC/OCM
References
SECY-78-93
Download: ML25260A565 (1)

Text

February 14, 1978 S'.:CY-78-93 COMMISSIONER ACTION For:

From:

Thru:

Purpose:

Discussion:

The Commissioners James R. Shea, Director Office of International Programs Clifford V. Smith, Jr., Director Office of Nuclear Material Safety and Safeguards Executive Director for Operations \j_J i)

US POSITION ON IAEA SAFEGUARDS EFFECTIVENESS PRINCIPLES AS DETAILED IN STATE CABLE 254712 OF OCTOBER 23, 1977 To inform the Commission on the background of the above cable, which was issued without NRC clearance, and to request any Commission input to the NRC staff's approach to the Executive Branch on this matter.

The subjects of IAEA safeguards effectiveness principles and the formulation of explicitly quantifiable safeguards criteria to serve as goals in the assessment of IAEA safe-guards performance were discussed periodically last year by members of an informal interagency group convened by DOE.

These principles and criteria were developed for the purpose of providing advice to Dr. Carl Bennett, the US representative to SAGS!.*

The group includes repre-sentatives from ACDA, State, DOE, and NRC (NMSS and IP).

Executive Branch personnel wanted to issue a cable which reflected prevailing US Government views on IAEA safe-guards, particularly as they related to safeguards effec-tiveness criteria, in time for the September 28 SAGSI meeting.

For a variety of reasons ACDA did not get this out in time, thereby missing the SAGSI meeting deadline.

• - -__...~==-----~-* -

--- _~... -:-:... -----*

cable

• One of the main functi ans ~ of:$~GSt:,t 6.tand~ng Advisory Group on Safeguards Implementation) is to advis~ the 'iAEA Inspector General on selected substantive and technical issues related to the development of IAEA's Technical Safegijards Manual.

Contact:

T. Sherr, NMSS (427~4004).

B. Schechter, IP (492-7984)

U.S. NRC Declasslflcatfon Review

Discussion:

{Continued)

-£UNflD.ENTMt 2

Around September 29 ACDA drafted a revised cable and distributed it for interagency comment.

NRC's comments, most of which reflected NMSS views, were received by ACDA around October 4.

While some of NRC's suggestions were accepted and incorporated into a later version of the draft, a number of NRC's major comments were not accepted.

The Interagency Steering Group on International Safeguards met on October 7 for one of its periodic discussions.

At that meeting NMSS suggested that the Executive Branch pre-pare a report to support the safeguards criteria contained in the subject cable. Apparently, this was not considered by the other participants to be compatible with the limited response time available and the Executive Branch's percejved need to go on record at that time with a US Government position paper on IAEA safeguards, particularly in hopes of exerting a positive influence on the impending US-EURATOM and US-IAEA discussions on EURATOM/IAEA safeguards.

The draft cable underwent a number of additional revisions during the succeeding three weeks, without NRC participation.

The cable (Enclosure 17 was eventually sent by State without NRC clearance on October 23, two days before the start of discussions in Europe.

The cable proposed several quantitative effectiveness criteria for international safeguards of plutonium, high and low fissile content uranium, and thorium.

This includes quantities of nuclear material that must be detected through IAEA safeguards in various kinds of facilities, and ranges for detection probabilities and for false alarm rates.

The safeguards criteria proposed in the cable were based primarily on inputs from ACDA.

No formal study or analyses had been conducted, however, to arrive at the technical criteria nor were any rigorous attempts made to check the criteria for internal consistency.

The Executive Branch considers the criteria proposed in the cable only as desirable goals for the international safeguards community, not as currently attainable objectives, and it intends to keep the criteria under continuing review in the future.

In light of the foregoing, the NRC staff proposes to send to Frank Houck of ACDA, the Chairman of a newly-established interagency subgroup on upgrading of IAEA safeguards, by

Discussion:

(Continued)

-tO.iiiDENTlAL 3

February 27 a letter which transmits the staff's comments on the subject cable (Enclosure 2) and calls for early discussion of these comments by the working group.

These colTUllents cover both the conceptual basis of the technical criteria as well as their practicality.

We anticipate that this matter will be discussed at tbe next meeting of the working group (probably in early

• March), -

which was set up to tackle selected aspects of

- th~- US Gcivernment Action Plan for safeguards support to the IAEA.

We will explore with the Group what further efforts might be needed to resolve the issues raised by NRC.

RecolTDllendation:

It is requested that the Commission review the attached material and, if desired, provide us with any further guidance or suggestions not later than COB February 23, 1978.

Enclosures :

l. State Cable 254712

2.

NRC Staff Comments

~:.-C..---V' -~

es R. Shea, Director fice of International Programs a~-Smith, Jr.

Director Office f uclear Material and Sa eguards DISTRIBUTION Commissioners Commission Staff Offices Exec Dir for Operations Secretariat sioners' corrments should be provided directly to the Office of the Secretary by of business Thursday, February 23, 1978. -

sion staff office comments, if any, should be submitted to the Commissioners NLT ry 21, 1978, with an information copy to the Office of the Secretary. If the is of such a nature that it requires additional time for analytical review and t, the Commissioners and the Secretariat should be apprised of when comments expected.

01 *cr &l STATE 254712 fl,i~liA-12 CONflBENnAt OCT-Bl EUR* 12 EA-10 ISO*OO OES-07 SS-I5 Pll-85 10-13 G~C-05 f ~OA-05 SIG*OI FEA-01 CIAE-00 INR-07 L-03 r:SAE-ilO Ell-03 l!B.£.:.Qi DOOE-03 SP-02

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,SH OCT 77

STAT( \/ASIIOC f.SAS!:Y BRUSSELS iSS Y VI EIHIA 1MEr1BASSY BONI!

,SSY LOriDON

,SSY L llXEr.SOURG

.SSY PARIS SSY RQME SSY DUEL IN SSY conr:11AGEN SSY THE HAGUE SSY TOY.YD D OFFICIAL USE STATE. 254712 OR USEEC, ALSO FOR USIAEA 11652: N/A PARM, TECH, EEC, IAEA r:

IAEA SAFEGUARDS EFFECTIVENESS PRINCIPLES: -U~

(Al 5TATE 1674~ (192ii) lT( I 2i!SOl (19 76) 7913 l,.,JLU,t,L

..I t L t. u I { J\ M STAT£ 254712 PROSCRIBED U~ES, AtlD ltl TEfll1S OF TIIE Tlt1E!: REQUIJ;£D TO U~F IIATERIALS FOR PR03CRIBEO PURPOSES; T/1£ DEGREE TO ~HICH THESE 06JECTl 1/ES CR G01lLS CI\U OE ATlHl ll[ O Al f.11'1 1111£ I/Ill BE A FUIJCTIOrl OF SUCH FACTORS A~ T:I E RE~c *_,l'r.Es AvAIU,nLE TO TIIE 11\EA.AHGIIARO:,YST£:: r,;~ 1,,,

STATE OF OEV£L0?I1UIT OF :;.HGIIARUS HCillI!j, U,1.

,,,.f. l

;f PlAII111rlG CF AllY PART ltlt( ~R SAF[GllAHO~ Ct-E,AI IC:, \/Ill PERrORCE TA~E 11110 r,ccouur THESE FACTOR:, lk[ t:.Oi;LS OF THE IAEA $AfEGIJAilOS S'IZTlM SHOULD ~OT BE REDH IIIFO MERELY TO REFLECT CURRErH CltPflOILITY l ltllTATIOIIS.

RATHER, lrl(

,;:__----.QE_GREE TO 1/HI CH GOALS ARE IIOT ACIIIEV£0 WITH CURRENT CAPABILITIES PROVIDES THE BASIS FOR OEFIIIIUG INCREA$Ea RESOUilCE REQUIREMEIITS Allil RESEARC!' AIIO f ' VHOPMEIIT IIEEO:i.

J.

ALTHOUGH -A TT A I fif1EIH OF. SOME OF TIIE GOAl S I H TII[

fOLLOlll~G PAflAGRAPHS I/ILL RCQUIRE I\OOITIOrtAl SAFCGUAROS RESOURCES ~110 FU~THER ADVArlCEMEIITS Ill SAFEGUARD~

TECIIIIOLOGY, \IE BEi. IEVE THAT SIG:IIFICAIH PRO~RESS IS POSS I Cl E ti Oil TOl;ARO A TT~ I 1/tlEIIT OF Al L OF THE GO,~l S.

IIIPEOIMEIIT$ TO THE ACltlEVEI\EIH OF THf!:E GOALS SHOULD BE AVOIOEO.

SUOSIDIARY ARRAUGEH[NTS, THEREFORE, SHOULD HOT CONTAtrl P~OVISIOIIS \ltilCH 1/0ULD PREvrnr ATTAIIIMEtH OF THE GOALS GUT RATHER ~HOULO rROVIDE SUFFICIEIIT FlEXllllllTY FOR THE IAEA TO CO~TINUE PROGR£SSIHG TOI/ARD AiT~l~HEUT OF THESE GOALS AS INCREASED RESOURCES Ar;o 11:t'ROVEt:E:ITS IN TECH~OLOGY ALLOII.

\IE BELIEVE THESE LOALS AHO THEi~

ATTAIIH1EIIT ARE FULLY COIISISTEflf 111TH SAFEGUAr.O~ A~~EEl'.EIITS COIICLUOEO PURSUAHT TO ~RTICLE 111,4 or THE TR~ATY 0~ THE NOIIPROL IFERAT I ON OF 14UCLEAR IJEAPOtlS.

4.

THE SPECIFICATIOII Df TECHIIICAL OBJECTIVES AND rERFORl1A:ICE CRITERIA FOR IAEA SAHCiUlllill!: SijOULD DE lfl TERMS OF THE FOLLOi/lllG MATERIAL CATE,ORIES:

A.

PLUTO~IUM, REGARDLESS or l$CTOPIC COMPO~ITIOrl, THE OllLY EXCEPTIOrt GEING PlUTOl'IIUM 111TH AN I:oiOPIC coucrn-Tr.ATIOI: OF PLIJTOUIU:-1-:33 EXCEEDlfha SO PERCErlT, 1/illCH CAN BE EXEHPTEO FROM SArEGUAROS.

B.

URANIUH, THE FISSILE cornrnT (3UH OF TfiE IS OT~? IC COIICEUTRAilOrtS or llRANIUH 233 ANO 23~1 OF _IIHIClj. (QuALS

,OR EXCEEDS 10 PERCUH, REFERRED TO HE,£I11 A~ HIGll l !HG THE PAST Tl/0 'iEARS THE U. :i. Hl$~I0H TO THE I llEf, flSSILE COt!TE:JT UllAf.!IUM IHf"CU).

11£ 1.'0UIO 6£ PFtl' *F.ED TD rt PROVIDED IJITH GUIUMtCE, RUTEL:i (Ai AIIO <DI, OH

,ITI011 OF Tl!E USG 011 '!!IRIOUS MATTERS \IHICH ~IHCT tlE THE TECHIIICAL EFrECTIVEUE:::i OF THE IA(ll SAFE-SYSTEM.

THE MATERIAL 11-1 THIS TELEGRAM l!UILOS UPON. *** *.

• lllfR GUIDAIICE ArlO IUCLUCES OU~UTllATIVE CRITERIA C.T IVES IIH I CU liE BEL fT1lW!litt1t-O 1k I Rt I,tlAL I OK THE n.sun:: _'ilE""tXPECT TO I\EEP illfSE MATTER'.> UUOER lllG REVI El.'.

THC STATEMEIIT CO,H A 111£0 Ill PARAf.RAPHS GH II TOGEIHER 111TH THl ROTELS, ARE OllR CURRENT 110 ARE TO S&RVE AS GU I o~:tcE FOR USG P[RSOUIIEL I H IONS OU TECHIIICAL HATTERS COUCERNIIIG IAEA SAFE-fYI THIS GUIDAUCE DOES HOT ADDRESS THE QU[STIOrt r,PES OF IIUCLEAR MATERIALS OR FACILITIES~ s*ATE HAVE.

II[ ARE ADOHSSlllG O:!LY TIit MATTER OF, Gl'J!N

[GUARDS 0~ PARTICUL,R MltT[RIAl OR IN PARTICULAR Y TYPES, HOii EFFECTIVE SHOllLD 1/E I/EEK TO MAKE lOS. mo FY I.

TECHUICAL OBJECTIVES OR GOALS OF THE IAEA lOS SYSTEM SHOULO BE DERIVED FROH COUSIO[RATION OF lS OF PROLIFERATIOU DUE TO !HE OIVER~IOII OF IT TYPES, FORMS, AUD 0UAIIT IT I ES or IIUCLEAR

• r11£ RISKS BEIUG ASSESSED IN TERMS OF THE -*

ES OF flUCLEAil MATERIAL 1.'HICH COULD 8£ USEO

• , OR AFTER FURTHER PROCimtlG, fOil PIIOSCIIB£D

, OR IIHICH ltlGHT INDICATE PREPAUTJOll FOR ACCEPT CATEGORIZATIO" BASED ON 20 PERCENl U~ANtun-ZJ5 OUT UrlDER$TAUD THAT THE IAEA HAS PRACT I CAL PRCUL[HS WITH MAKIIIG OISTl11CTIQtlS AT 111£ 20 PERCEUT VALUE.

wE 00 NOT SUPPORl a~ lrtTERHCDIATE CATEGORY FOR 10 TO 2S PEttCEUT URAIIIU11 23S.

C.

URAIIIUM, THE FISSILE CONTENT OF 1/HICH IS LES: THAU HI PERCEflT, (OR 20 PERCEIHl, I. E., LOIi FISSILE co:::rnr UR~NIUH ~FCU).

THIS INCLUDES NATURAL AND OEPLETCO URAII I UM.

D.

THORIUM (THI.

S.

THE A110UIIT OF IIUClEAR MATERIAL IIHICH, IF ttIs:;11IG 1/ITHlrl A STATE OURIUG A OflE-YEJR PERIOD, IS TO BC DETECTED SY THE IAEA SAFEGUARDS ~*;:;rm $HOULO IIOT EXCHO:

A.

EIGHT (8)

KG OF PLUTOIIIUM (PU).

a.

AH AMOUIIT OF HICiH FISSILE COIITENT URA~IUH mFCW COUTAltltrlG EIGHT lal KG OF URAIIIUM 233, T\/£11TT-FtVE * (2S) - --------

KG OF URA/II UH US, OR IN TRE CJIS£ OF r!I XTUUS, All IIMOUNT FOR \IHICH TH( SUM OF THE VEIGHT CF URt.lllU" 133 PtUS 8/25 T IIIH THE ll[IGHT Of URANIUtl 235 IS EIGHT IB) KG.

r.fttllnnt i I rt I,

I f Mrrr: n n f. i; I r. I A I

-I., -:,.~,- ** - '-'. ~ *-

'J J

"'-.J l, \.A, I,,'-

.1 tLL:.liltAM

D:a'OF 02 STATE 2S4712

. iiONflJJOOJAl:

STATE 2S4712 AN At!OllllT OF l.011 FISSILE COIITEtlT URAtl!Ut1 (LFCUl FOil

H THE SUM OF THE II[ IGHT OF UR/\tllUl1 235 PLUS 3 I 111ES

\IE I GIIT OF UR/1111 Ut1 233 IS 75 KG.

(A VALUE OF 1 uO KG, EAD OF 7~, IIOULO Al ~O BE ACCEPT,;BLE. l

!fl EI TflER THE TOT AL MEIG6T OF THE URANIUM SHOULD uor EXCEED 20 IC TO!IS, IIHICII IS ThE AtiOUIIT OF DEPLETED URANIUM THAT BE EXEMPTED FROM SAFEGUARDS..

TIIEIITY (201 METRIC TOtlS OF THORIUM.

ANY COHBINATION OF THE ACOVE.

A AHO B ltlCLUOE QUANTITIES OF OIREC{ UTILITY IN AN o:;1vE DEVICE; C AIIO D ARt OF INDIRECT UTILITY, I.E.,

Q R[QUIRE *FURTHER PROCES~IUI..

E!:D FYI.

ritE Al10Utt T OF UUCLE AR 11A TERI Al 11111 Cll, IF 111 S S IIIG A SIUGLE FACILITY OF AtH TYPE DURltlG A CIIE-YEAR lO, IS TO 8£ DETECTED OY THE IAEA SAFEGUARDS Sl'STEM 0 fXCCEO HEITHER THE ANOU~T SPECIFIED Ill PARAG~APH I 10 rci;crnT OF THE MATERIAL P!.E$EtlT lfj OR PROCESSED IGH BIIIICHEV£R IS GREATER!

THE FACILITY DURIIIG TIIE THE LE:m, OF THESE AllOUIHS

!THAT HI PARA S OR 19 IITlREP~ESEHTS THE UPPER LIMIT FOR THE DETECTION GOAL E IAEA AT ANY FACILITY.

FYI: S0t1E TYPE OF FORMULA*

COHSIHIIIG THESE TMO LINITS MOULD BE USEFUL AIIO OIIE POSSIBILITY IS THE RECIPROCAL OF THE SUN OF THE ROCALS OF THE TUO QUAIITITIES.

Ill ADDITION A LOMER.

ON THE OETECT10ll GOAL SEEMS APPROPRIATE AS A MEAHS.

OIDIIIG UCOUE SAFEGUA~DS EFFORT IN FACILITIES HAVING SNALL AMOUNTS OF NUCLE~R MATCRIAL.

EllD FYI.

kE PROSABILI TY SliOL'LD BE VERY HIGH (9~ TO 99 PERCEIITI OIVERSIOUS DURIIIG AIIY ONE-YEAR PERIOD OF PU AIIO HFCU

AMOUtJTS GIVEN Ill PARAGRAPH 6 IIOULD BE OEiECTED, i011EllitAf LOI/ER PROBABILITY 190 PERCEtiTl FOR LFCU AND

m.

THE PR06A8 IL I rY

(\/HERE TH IS TYf'E OF rROOAB Ill TY

.EVArlTI SIIOULO BE VERY LC\/ II TO 5 PERCE!;!)

THAT A COUCLUSION IS REACHED fHAT DIVERSIOtl HAS OCCURRED 11 FACT IT HAS IIOT, I.E., A FAL$E ALARM.

E TIME! ltlESS 111TH \IHICH DIV[RS!Otl OF A SPECIFIED OF tlllCLEAR MATERIAL SHOULD BE DETECTED IS DIRECTLY D 10 THE TIME REQUIRED TO USE THE MATERIALS FOR IBED PURPOSES.

1110 MEASUWES ARE USED FOR DETECTING 1011, MAHRIAL ACCOUIHAIICY AIID -SURVEILL A!I CE.

HIE

, IIIROUGH COMPLETELY VfRIFIEO PHYSICAL IHVEUTORIES, IHlS IIHETHER THE AMOUNTS OF MATERIAL MHICH ARE ED TD BE PRESENT Ill THIN A FACILITY ARE Ill FACT I.

TIIE LATTER PROVIDES A HEAllS OF DETECTIIIG THE PEMOVAL OF MATERIAL~ DUH!HG PERIODS BETMEE~

,L IIIV£NTORIES.

lllllESS RE~UIRED fOR DETECTING DIVERSIO~S OF LFCU

~1011 CAIi BE ACHIEVED THROU~H IAEA VERIFICATION OF

,L ACCOUIHAIICY 111111 PHY:;ICAL IHVEIHORIES D BY THE IAEA AT ltlTERVALS NOT TO EXCEED OtlE YEAR.

SI/HERE VlRIFl[O MATERIAL ACCOUtlTAtlCY CA~!IOT TIIE DETECTIOU GOALS G!VCH Ill PARAGRl>.PII 6 FOR LFCU RIUH BEC~U~E OF LARGE HEA~UREHEUT ERRORS THE l CET\.'EEN IAEA VERIFIED PHYSICAL IIIVENTORIES SHOULD EEO SIX (6) MOIHHS.

CASE OF FACILITIES FOR IIHICH TH( l~VEIITORY OR ANNUAL THJ;CiUG!ll'UT, \IH ICHEV£R IS GREATER, IS LESS TIIAfl THE Ar:OUIIT

~!\!Erl Ill P1\R1'\GRAPH 5, E.G., 8 KG Or Plll!OIIIUH.

1:1 THIS CASE TIIE IIITERVAL BEl l,'EEII IAEA !/ERIFIEO PHYSICAL lllVtllTOR IEo :H OULO 1101 EY.CHD o:1E Ill YEAR.

ltl CA~ES

\/HERE VER If I ED 11ATER I AL ACCOUIITi<llCY CAIIIIOT ACHIEVE THE OETECTIOll GOALS GIVEH IN PARAG/i.iPH & FOR PLUTO:IIUH AIIO HFCU THE ltHERVAL BETl.'EErl IAEA nillflEO PHYSICAL INVEU-TOR I ES SHOULD ::or EXCEED THREE (JI lfOHTHS.

~........_B.

FOR FACILITIES I/HOSE ltlVEHTO~Y OR AtlllUAL THROUGHPUT

(\/HICHEVER IS GREATER! CF PLUTOIUUM OR HFCU Er;UALS OR EXCCEOS THE AliOU!ITS GIVEtl Ill PARAGRAPH 5 SURVEILLMICE SHOULD. llE El1PLOYEO CAPABLE or DETECT IIIG REMOVAL OF MA-TER I AL OR OTIIER ACTIVITIES 1/IIICII 11AY lt!OICATE 01vrn~101r OF SUCH Alf AllOUrlT IIITHltl OtlE

(!) IIHK, or*THE DIVER'.:1011 FOR MAlERIAL Ill All FORl1$ OTHER Tlf;JI IPIIAOIATEO Fll(L AtlO IIITH.ltl T\10 (21 TO TIIREE (J) MOIITHS, BUT PREFEoABL Y 1110 110tlTH~,

FOil IRRADIATED FUEL.

THE IUTER~~i llET\.'((11 SUCII DEHCT!Otl AMO A REPORT TO THE BOARD OF GOVE~UORS SHOULD UE SHORTER THAN THE OETECT I OII TINES.

THE DETECTION PROBABILITY TO BE ACHIEVED CY lrlESE SURVEILLAlfCl nEASURES WITHIN THESE TIME Ll~ITS CAIi BE LESS THAH THAT GIVEII IN PARAGRArH l AS LO~G AS THE CUMULATIVE PR06ABILITY OVER THE IIITERVAL BETMEEH IAEA VERIFIED PHYSICAL lttV[~TORIES EQUALS THAT IN PARAGRAPH 7.

II.

IN AODITIOU TO THE A60VE F(QUUiEMtllT FOR SURVEILLAIICE THERE ARE T\10 OTHER TYPES OF CIRCUMSTANCES Ill 1/HICH A COIIPREHEUS I VE SYSTEl1 or SUR VE I LL AIICE, BOTH HUl11111 AllO INSTRUMEtHAL, TO COl1PLEMEtlT FACILITY CO!ITAllll-:EIH FEATURES AUD IAEA VERIFIED MATERIAL ACCOUGTAIICY IS REQUIRED.

. A.

SUCH A SYSH:11 IS UEEDED AT POIIU REACTORS, elm I CHt:E!:T PLANTS AIIO REP~OCESSIIIG PLANTS TO E~SURE THAT UIIP[PORTEO NUCLEAR MATERIAL IS HEITHER INTRODUCED INTO HOR REl~VED FROl1 AIIY SUCH FACILITY IIITHOUT TliE ~ilOwl.EDGE OF l~EA ltlSPECTORS.

FYI:

THIS IS TO PROTECT AGAlllST CLANOESllllE USE OF A SAfEGUQROEU FftCILITY TO PRODUCE OR PROCESS UNREPORTED NUCLEAR llilERIAL.

• END FYI.

Ill OPERATIOII/.L TERMS TIIIS SYSTEM NUST PROVIDE ASSURANCE TO THE IAfA THAT (A) All FLOIIS OF NUCLEJI_R MATERlr.l PA:.S TH~OUliH AGREED rKEY"J HEASURIMcUT POIIITS AUD IBI THE IAEA !USPECTORS ARE COGIIIZANT OF All MATERIALS PA:.SIUG lH~OUGH THOSE POINTS Ill SUFFICIEHT TIME FOR !KE IAEA TO SE kBLE TO IDEUTIFY ANO AT THC APPROPRIAlE TIME TO MEA:.URE ACCURATELY SUCH MATERIALS.

THIS REOUIREMEIH ~.LSO APPL lfS TO RESEARCH RHICTORS FOR MHICH THE AIHIUAL PLUTOUIUtf PRODUCTIOII CAPACITY EQUALS OR EXCEEDS OUE (!l KG.

8.

UClt A SYSTlM IS ALSO NEEDED ttl CASES IIHEnC VERIFIED MATERIAL ACCOUKIANCY ALONE IS l~ADEOUATE 10 ACHIEVE THE O[l[~TIOII GOALS SPECIFIED Ill PIRAGRAPK 6 BECAUSE OF THE MEASU~CHEIIT ER~ORS ASSOCIATED UITH L~RLE OUAHIITIE: OF MATERIAL.

THIS REOIJIREl1~NT APPLIES TO fACIL !TIES OF ALL TYPES.

THE USE OF SUfiVEILLAIICE FOR AIIY REASOII DOES IIOT REMOVE THE REOUIREMEHT FOR VERIFICATIOII Of MATERIAL ACCOUIITAllCY I IIVOL VI IIG MEASUREr.C:.TS 1/H I CH COlff CRl1 TO THE LATEST INTERNATIOllAL STANDARDS. VAUCE R PLUTOlllUt1 AIIO HFCU TIMELY DETECTIOII OF DIVERSION EVEO THROUGH A COMBINATION-OF VERIFIED PHYSICAL ---** - -,--------.---.-

~IES AHO SURVEILLA:ICE.

IIITERVAL BfTIIEEli IAEA VERIFIED PHYSICAL iKOULD llOT EXCEED SIX 161 110UTHS, H.CEPT CONADENllAt

µ INVEtl*

IN"1"'L-;-

11i

-wtM-HI frt"EilD18tttF-;-.F-1--f -h--h 41 A.u..l _u.,fl s:~i::..:...* *:}:(~~; :; :::.:., ~* _.-~"

-tiBNfIDfNTIAI:*;

NRC COMMENTS ON ST/.HE DEPARTMENT CABLE CONCERNIMG TECHNICAL 03JECTIVES AND GOALS FOR IAEA SAFEGUARDS tnc1osure L

~RC comments and questions concerning the technical objectives and goals contained in Department of State cable #254712 are listed below.

1. Advantages and Disadvantages of Goal Quantities

2.

The advantages of establishing goal quantities of 11missing 11 nuclear materials which the IAEA safeguards system is designed to detect may not outweigh the disadvantages.

Goal quantities are useful _ to establish the frequency of IAEA inspections and in particular to identify when continuous inspection should be performed.

Goal quantities are also of value to assist the IAEA in identifying countries and facilities which need to be specially reported to the Board of Governors in cases of questionable safeguards performance.

Goal quantities do not appear needed, however, to establish inspection methods for verifying flows of nuclear material and inventory differences (MUFs).

The disadvantages of establishing goal quantities at this time are (1) if the goals prove to be impractical and not thought out, this coul~ create a bias against establishing such goals in the future; and (2) the goals may be interpreted to suggest that thefts of smaller quantities may be diverted without any safe-guards concern.

With regard to the second disadvantage, diversion of such quantities on a continuing basis is believed to be of safeguards concern and such diversion should not be determined to be acceptable. With regard to the first disadvantage, paragraph two states that 11the goals should not be redefined to reflect current capability limitations." While we agree that goals should,.:- L:* ~;;

serve as a target, we believe that any specified goals should be ~'.2u achievable by some perceived means in some reasonable time frame.~~~

-=

It is not evident that the goals expressed in the cable would 8~~<<: ~

satisfy these criteria. In this regard, paragraph three states

~g8g:: ~

that "we believe that significant progress is possible now toward z ~g; *.s attainment of all the goals.

11 However, there is no discussion g~~ ~

of the degree to which they can be attained nor of the means of j;:: d 1

attainment.

~~\:5 Cf) 0 ct I-a

(

~~z Definition of 11High Fissile Content of Uranium HFCU)"

uct-i:

w (\J U')

J

!Dui...J I

• .O <

In paragraph four, section B, HFCU is defined as uranium with

~:::~,

fissile isotopic content equa 1 to or exceeding 10%. Al though

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, ~

some "practical problems" are alluded to, no rationale is given

(.'.)er:~

00;'.J I

l- ~ >-

b

_,t;~~

(.;1ass1iied Y ~

• -:;z-.r..J-;..,d"-~....... =ti'.i_, u ~

'JAL S£CURIT'r1 '

~

~

.. -.J ~EN-,

~ H ORMATION

.nel

~v-c'Mt ~

~ <

~

.. Disclosure Subject To li~MfnFNTIM

-~ I ttitla),

J ' -* ~.J,..-

r *~*-** ***..

for not pursuing a definition consistent with that used for U.S.

domestic safeguards, i.e., 20% fissile isotopic content.

In the absence of any addition~l information, we believe that the value of 20% should be advocated by the U.S.

3.

Goal Quantities for State and Facilities Paragraph five specifies goal quantities of nuclear material to be detected by the IAEA safeguards system if missing within a state during a one-year period.

In paragraph six the goa1 quantities are specifi'ed as app1ying to each facility within a state ~ The limitation in paragraph five is more restrictive than paragraph six, and therefofe, the need for oaragraph six is not evident.

4.

Detection Probabilities Paragraphs five and six, together with paragraph seven attempt to define the detection probabilities.

For Pu and HFCU the probabi1ities of detection are indicated as.95 to.99 with a fa1se alarm rate of.01 to.05.

These ranges of probabilities represent a broad spectrum of power curves, and some combinations may be virtua11y impossib1e whereas other combinations may be practica1.

An analysis is needed which identifies the types of measurement capabi1ities that would be required to satisfy various combinations of detection probabilities and false alarm rates to assure practicality of the combination selected.

In addition, pa.ragraph seven i denti fies a different probabi 1 i ty of detection for LFCU and Thorium (.90) than the probability for Pu and HFCU

(.95 to.99).

The rationale for this difference is not evident considering that the intent of paragraphs five and six was to establish the significant quantities to be detected.

5.

Goal Quantities Should not be Considered as Tolerable Diversion Quantities Paragraph six of the cable is not clear and may suggest that the IAEA safeguards system need not be applied at any facility which possesses less than a goal quantity specified in paragraph five.

6.

Goal Quantities not Achievable if Applied to all Nuclear Facilities Within a State The goal quantities specified in paragraph five would be difficult to achieve for an entire country with a large nuclear industry such as the U.S.

Further, the threshold quantity for plutonium may not be achievable in any country with a reprocessing plant COHFinOOIAJ.

'itt!,M,,i UJ,l!s..~ 'II 11 A., having a capacity of 100 or more metric tons per year.

For the reasons indicated in comment (1) above, the achievability of the goals needs to be demonstrated.

7.

Validity of Goal Quantities Specified The goal quantities for low fissile content uranium (LFCU) seem to be disproportionately small in co~parison with the

- goal quantities for high fissile content uranium (HFCU).

Whereas eight kilograms of plutonium or uranium-223 and 25 kilograms of high enriched uranium-235 can be use~ directly to construct a nuclear explosive device, low fissile content uranium in any quantity (the goal quantity is75-100 kilograms) cannot be used directly for this purpose.

It appears that either the threshold quantities for high fissile content uranium are high or those for low fissile content uranium are low.

8.

Integration of Material Accounting and Surveillance Paragraphs five, six, and seven attempt to set out the detection goals for the IAEA system without regard to the means utilized for achieving the goals.

Paragraphs nine and ten attempt to further define the detection goals through specification of timeli-ness, but in doing so, also identify system reouirements for material accounting and surveillance. These system requirements do not reflect an integrated system that will satisfy the goals established.

Paragraph nine suggests that these goals should be satisfied by material accounting alone for LFCU and Thorium, whereas paragraph ten suggests the goals for Pu and HFCU require a combination of material accounting and surveillance.

The rationale for not allowing latitude with regard to surveillance for LFCU and Thorium is not evident.

In addition, it is not clear why the specific material accounting requirements of paragraph ten, section A would be needed to satisfy the goals identified in paragraphs five, six, and seven.

The specific surveillance require-ments of paragraph ten, section 8, appear to satisfy the goals, and accordingly, assuming that these surveillance provisions are considered practical, the requirements suggested. in the criteria for.material accounting would be unnecessary.

9. Material Accounting and Surveillance Requirements for the State The discussion of material accounting and surveillance requirements in paragraphs nine and ten relate only to the goal quantities of paragraph six; i.e., those pertaining to each facility. There is no similar discussion as related to the goal quantities for the State, i.e., the requirements of paragraph five.

--~DNflD.ENTIAL ~-

'Ul;f't'ff IU,fJI I tJ\L 10.

Timeliness of Detecting a Diversion Paragraph ten states that surveillance methods shall be employed to assure detection within one week of a diversion of goal quantities of plutonium or HFCU.

We question whether an ~ffective survei 11 ance sys tern can be established by the IAEA under the pro-visions of INFCIRC/153 and existing safeguards agreements to achieve this objective.

11.

Surveillance Requirement Paragraph 11 states that an IA~~ surveillance system is needed at certain facilities 11to ensure that unreported nuclear material is neither introduced into nor removed from any such facility without the knowledge of IAE.l\ inspectors."

We do not believe that such a requirement can be effectively implemented by the IAEA under present provisions of INFCIRC/153 and safeguards agreements as stated above.

Effective inspection would require IAEA inspectors to maintain continuous surveillance of all buildings in which nuclear materials are used and stored to detect unauthorized entry or removal of nuclear materials.

We question whether this can be practically attained without establishing protected areas around nuclear operations, employing IAEA inspectors to maintain continuous surveillance of all such areas, and authorizing IAEA inspectors to search all individuals and packages entering or leaving these areas.

While we support this objective, we question its inclusion in the cable on the grounds that it cannot be practically achieved at the present time.

-£0NflUOOIAL