ML25261A124

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SECY-78-202: Comprehensive Evaluation of Safeguards at the Nuclear Fuel Services (NFS) Facility, Erwin, Tennessee
ML25261A124
Person / Time
Issue date: 04/10/1978
From: Casey Smith, Volgenau E
Office of Nuclear Material Safety and Safeguards, NRC/OE
To: Commissioners
NRC/OCM
References
SECY-78-202
Download: ML25261A124 (1)
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Text

i I SECY-78-202 Ao ril 1 O, 19 78 For:

COMMLS~IQNER ACTION Fl"om:

Thru:

Subject:

Purpose:

iscussion:

Clifford V. Smith. Jr.* Director Office of Nuclear Material Safety and Safeguards Ernst Vplgenau, Director Office of Inspection and Enforcement Executive Director for Operations COMPREHENSIVE EVALUATION OF SAFEGUARDS AT THE NUCLEAR FUEL SERVICES (NFS) FACILITY. ERWIN, TENNESSEE To forward the comprehensive evaluation report on safeguards at the NFS, Erwin, facility and to obtain Commission approval of proposed letters for trans-mitting the report to Congress. This is a Conmiss;on Action Item.

Background

In May 1977, the Commission appl"oved a comprehensive plan for evaluating safeguards at licensed fuel cycle facilities which contain significant quantities of strategic special nuclear mat~rials. The first comprehensive evaluation report (on United Nuclear's Wood River Junction fad 1 i ty) was sent to the Congress in February 1378.

In hfs covering letters, the Chainnan promfsed to forward other evaluation reports to Congress, as they became available. The first report was sent to the following:

o The Honorable Gary Hart, Chairman Subcommfttee on Nuclear Regul3tfon Senate Committee on Environment and Pub 1 i c: Wor!< s a The Honorable Morris K. Udall, Chairman Subcommittee on Energy and the Enviror.mer.t House Cormiittee on Interior and Insular Affairs o The Honorable John O. Dingell, Chairman Subcommittee on Energy and Power House Committee on Interstate and Foreign Commerce Erickson, SG/~MSS

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~he Cor.mfssioners Primary Evaluation Criteria The staff evaluated safeguards at the NFS, E~Nin, facility in terms of capability to protect against nuclear theft or sabotage involving the following:

l.

An insider acting alone, or

z. A violent assault by several outsiders wfth assistance from an fnsider.

Results of Primarx Evaluation at NFS, E""in fs a comprehensive evaluation report on safeguards at NFS, Erwin consolidating the findings of four separate evaluation teams whfch vfsfted the facility.

Personnel from the Office of Inspection and Enforcment and from the Division of Safeguards participated in this evaluation effort.

  • Ori the basis of this report, the staff concluded that safeguards at NFS, Erwin protect with good assurance against theft or sabotage by a single insider acting alone, and *good to fair assurance against a violent assa*ult by several outsiders assisted by an insider.

Actions to Attain High Assurance Protection at NFS, Erwin The comprehensive evaluation did not disclose any emergency safeguards deficiencies requiring,. irrmediate correction.

However, on the basis of the report, the NRC staff is preparing to irr,plement a number *or short term actions and some of a lass urgent nature to achieve high assurance protection at NFS, Erwin. 1 They are as follows:

Protection Against an rnsidar An action recommended to achieve high assurance

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protection agains~ nuclear theft by a single insider is to improve promptly the conditions under which.

access controls are operated and searches conducted.

In particular, personnel congestion pre~ently compli-cates the work of security guards at an access control point.

ihe cc,m,iss1oners

-~4tWetl:im.. Protection Against External Assault--Wjth Insfde Assistance Following are short term actions recolffllended by the staff to improve NFS, Erwin protection against external assault:

Secondary Evaluation Durir,g the evaluation of HFS, Erwin, secondary consideration was also given to the licensees' capability to satisfy mere demand;ng safeguards requirements which were publfshed for comment

n the Federal Register on July 5, 1977 (42 FR 34310).

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On the basis of the evaluation repor~. the staff ~oncludes that ex1st1ng safeguards at NFS, -Erwrn would requ1re considerable modification to satisft NRC 1s proposed new requirements. Following are thv types of actions which would be required:

0 Increase surveillance of persons having access to materl al access areas o Establish dual manning of material access control points.-*---

b(3) USC 1 O o Improve protected area lighting.

This is not an exhaustive list of actions which would be required at ~IFS, Erwin. Rather, it is indicative of the kinds of actions required to satisfy proposed new safeguards requirements currently being considered by the Commission.

Furthermore, the list is generally consistent with that shown in the statement of consider-tions published with the proposad new rule in July. 1977

( 42 FR ~_4l!.Q_l_.;

Summary The comprehensive evaluation at NFS. Erwin did not disclose any problems warranting emergency remedial action. However. the staff is translating its recommendations into licensing *actions to provide high assurance safeguards for strategic special nuclear materi~ls_~t ~f.S, Er~in.

('in NRC ~eam will visit NFS, __

Erwin soon to deliver the evafuat,on report and

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managem~n_t... __... _

Recommendation:

That the Commission:

l. Note the contents of the enclosed evaluation report.
2.

Approve 1de-~_ticaf-le~terstransriiitting the-

  • report to Congressional oversight Conmittees (enclosure 2 is draft letter).

ihe con1111ssfoners Coordination:

The Office of the Executive Legal Director has no legal objections. OCA concurs.

Enclosures:

~~

Clifford v. Smith, Jr., Director

~~ Office of Nuclear Material Safety

~ and Safeguards ector Office of Inspection and Enforcement

1. Evaluation Report (Confidential-Restricted Data)
2. Draft letter to Congress fm Chairman Hendrie lssfoners' cotrrnents should be provided directly to the Office of the Secretary
  • ose of business Friday, April 21, 1978.

ission staff office co~ments, if any, should be submitted to the issioners NLT April 14, 1978, with an information copy to the Office he Secretary.

If the paper is of such a nature that it requires additional for analytical review and cornnent, the Commissioners and the Secretariat ld be apprised of when comments may be expected.

~!BUTION 1ss1oners ission Staff Offices Dir for Operations

~tariat

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COMPREHENSIVE EVALUATION REPORT ON THE NUCLEAR SAFEGUARDS AT THE NUCLEAR FUEL SERVICES (NFS) FACILITY, ERWIN, TENNESSEE APRIL 7, 1978

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COMPREHE~SIVE EVALUATIOij REPORT OH THE NUCLEAR SAFEGUARDS AT THE NUCLEAR FUEL SERVICES (NFS) FACILITY, ERWIN, TENNESSEE 1.0 Introduction This comprehensive eva1uatfon report on safeguards is based upon data collected by NRC field evaluation teams which visited the NFS, Erwin facility during August and September 1977.

1.1 Facility Description The NFS-Erwin plant is in a rural isolated area south of the town of Er"Wfn, Tennessee (4-5000 population).

The terra1n is rugged. and the plant is immediately adjacent to the Nolichucky River, and the Clfnchffeld Railroad, which parallels the river. Highway fngress into the area fs by US 23W. which also parallels the river valley.

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This plant processes high enriched uranium into a form suitable for use f n the naval reactor program.

Employees have "L" or "Q" clearances from DOE.

High quality standards and the complexity of this process generate s1gnificant amounts of scrap. Thfs scrap is then recovere1 for reintroduction into the production process.

Thus, there are two major productive operations at the plant.

In previous times. this plant also enqaqed in plutonium fabrication.

. 2 Existino Security System

.. 2.1 Contract Guards and LLEA ~esoonsa Forces The present Contract guards and supervis9!~_!'~v~ now been on site

  • for ~_pproximate1y 10 months.

_ _____ _J B~th the contract guaras and Fie NFS shf1£.:._* __,

supervisors have oeen sworn l n as deputy sheriff's.

..... _.,., ~**_.!I tQtiWWllRL There fs good interdepartment cooperation between the pol fee agencies plus a very positive attitude in supporting NFS in their safeguards program. Police departments were familiarized with the facility 1 ayout.

1.2.2 Communications 1.2.3 Primary Central Alarm Station (PCAS) 1,2.4 Secondary Alarm Station (SAS) 1.2.5 Lighting Perimeter lighting is supplied by several dozen mercury vapor lamps mounted on posts approximately30 feet high.

1.2.6 Perimeter Barriers The facility nerime~er is protected by a ch~~n 11nk fenc, top~-~twith barbed wire. f J

1.2.7 £QY 1.2.a Access Control and Search -- Mate~ial Access Areas (MAA's)

A member of the security force has direct control of all entrances into an MAA.

The identity of individuals wishing to enter the MAA is

_checked again~t ~n ~uthorized access log which is continually updated.

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Packages *are searched when entering the MAA for counterfef t SNM and or shielding material.

A search for metal and SHM is performed by a member of the security force when materials and personnel exit the MAA.

A "two man rule" is observed when working in an i*\\I\\A.

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1.3 Evaluation Criteria The primary purpose of the evaluation was to examine licensee capabilities and vulnerabilities against the threat of theft or sabotage by (1) a single insider acting alone, or (2) a violent assault of several well trained and dedicated persons with military training and skills assisted by a knowledgeable insider.

In reaching Judgments about security, NRC evaluation teams used these er f terfa:

2. Fair
3.

Good *

4.

High No evidence of capability Obsolete Not yet implemented Not yet operable Poor maintenance Easily compromised Stated capability but not verified Fair maintenance Implemented but not completely op~ratfonal Fair records and history Could be compromised Limited demonstration of capability Good maintenance Good records/~1story Not easily compromised Several operational demonstrations High state of maintenance Records and history provide high support of performance Very difficult to compromise The above categories provide a key to the relative adequacy of safeguards at different facilities.

2.0 The Evaluation Process The comprehensive evaluation process involved four separate NRC teams.

Each of them exam1_ned a different facet of the overall safeguards system. Their separate findings were then distilled into a single comprehensive evaluation report. The four teams performed the following in the field:

Diversion Path Survey External Assault Survey Physical Security Assessment Material Control and Accounting Assessment 2.1 Diversion Path Survey 2.1.1 Purpose The purpose of the Diversion Path Survey was to determine where in the production process the site might be vulnerable to internal diversion of strategic special nuclear materials.

2.:.2 Method The facility strategic special nuclear material processing operations were examined to determine the process locations where nuclear material was accessible, its form at that point, and whether any diversion paths exist that would allow removal of SNM from the fac;lity. All process locations where nuclear material was acces-sible were considered.

Primary consideration was given to those paths fnvolv1ng a single facility employee in any position or a single authori2ed visitor.

The Diversion Path Survey specifically excluded assessment of physical security procedures or equipment in either the mater1al access area or the protected area since these were to be covered by the Physical Security Assessment Team.

2.2 External Assault Survey 2.2.1 Purpose The purpose of the external assault survey was to obtain an external adversary-oriented view of the facility.

The survey placed partic-ular emphasis upon finding possible safeguards vulnerabilities which a potential adversary might exploit for purposes of theft or sabotage.

2.2.2 Method The External Assault Team used remote observation, close surveil-lance, and communications monitoring of NFS and LLEA frequencies to identify vulnerabilities of the NFS Safeguards systems. Later in the assessment specific team members were escorted through the facility to get a first hand vfew of the safeguards system from an insider's perspective. Plans of attack were then developed by the team to exploit identfffed vulnerabflfttes and to evaluate their usefulness to a potential adversary.

2.3 Physical Security Assessment 2.3.l Purpose The assessment process was designed to answer the following basic questions:

1. Theft by a Lone Insider Are present material control procedures sufficient to prevent, with high assurance, the theft of more than five formula kilograms of strategic special nuclear material (SSNM) by an employee in any position in any single theft or in any continuing series of thefts over a period of up to one year?
2. Theft by External Assault Are present physical protection procedures sufficient to prevent, with high assurance, the theft of more than five formula kilograms of SSNM by means of a well-planned and coordinated assault by several outsiders assisted by an insider?

2.3.2 Method In contrast to the adversary-oriented exterior assault team, which operated mostly outside the facility, the physical security assessment team did a detailed review of safeguard capabilities from within the facility.

The following factors were considered:

Strategic special nuclear material is uranium-235 (contained in uranium i h d 0

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b(3) USC 10 Protection Against Lone Insider*

Access Controls 0 Measures to prevent introduction of contraband CONflDEtffiit:-

0 Measures to allow only authorized personnel access o Detection of unauthorized access Containment Controls o Measures against unauthorized removal of SNM o Integrity of containment o Detection of unauthorized conditions Protection Against External Assault (with inside assistance) o Detection and delay of adversaries o Deployment and communication of response forces o Motivation, training and reliability of response forces o Condition, equipment and numbers of response forces 2.4 Material Control and Accounting Assessment 2.4.1 Purpose The purpose of the material control and accounting assessment was to determine whether the licensees' material control and accounting system would indicate significant theft or diversion, after the fact.

2.4.2 Method In making its assessment of licensee material control and accounting capabilities, the NRC team measured time responsiveness of the system to verify after the fact, whether a theft had occurred, This objective is expanded ;n the following quest;on:

Can the material control and accounting system substan-tiate if more than five kilograms of high enriched uranium were illicitly removed during previous inventory periods, and can it perform this verification during the current inventory period?

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3.0 seecif1c 0bservat;ons 3.1 Observations Concerning Material Accessibility 3.1.1 Fuel Production (MBA-6) -- Accessibility of SNM SNM is.accessible in several places fn the fuel production process.

For this process step. the two-man rule seems to ooerate more eff~ctively than it does for the end of the At this stage of fuel production, the process controls and super-v1s_1on become more strfngen_t since the material is nearer to

.brnQ a finished producti I On the other hand, process controls are even tiqhter at this staqe of fabrication. 1 ji Supervisory and QC personne I a I so pay very close attention to all the production steps throughout this stage of the process.

3.1.2 HEU Laboratory (MBA-6) -- Accessibility of SNM Access to SNM in the laboratory is limited to samples.

Individual samples can be quite large {uQ to 500 gms) and the total lab inventory may be several kQ.

The laboratory is within the MAA, however, and all personnel are subject to MAA search procedures.

I This stream is sampled daily, by arab s~mole technique, from ins1de the protected area.

Sinks in the MBA-6 portion of the laboratory are tied into the plant contaminated waste stream. The waste stream is collected in large holding tanks where it is sampled and the sample analyzed for uranium content before disposal to the recovery fac11fty or waste treatment facility.

The laboratory also contained a ladies restroom t1ed 1nto the city sewer systems which could be used as a means of diverting easily accessible sample quantities of SNM from the labs.

3.1.4 Warehouses -- Accessibility of SNM Building is used for stored scrap generated in MBA's 5 and 6.

Containers_are all sealed, and identified by quantity and type of material.

.J Waste cori-tai ners scheduled for burial are also stored in this building and may be shipped from this building to burial.

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\\ -- Accessibi 1 ity of SNM type room within

-~OMFIDtNTIAb ICA-1, Bldg.

-- Accessfbflity of SNM is a general receiving ar ioactfve and non-radioactive.

The nature of the material stored in the warehouses, its packaging and the procedures and controls in effect. limits the material aecessi b; lf ty for diversion.

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3.2 Soecific Observations--Div~rsion Path Survey 3.2.l Emergency Safeguards Deficiencies Requiring Immediate Correction The Diversion Path Survey did not disclose any emergency def1c1en-cies requiring imnediate correction.

J.2.2 Sfgnfficant Safeguards Program Deficiencies Requiring Short Term Correction The Diversion Path Survey did not disclose any sfgnfffcant safe-guards program deficfencfes requiring short term corrrection.

3.2.3 Minor Safeguards Program Deficiencies of a Less Urgent Nature Drains Tied to Sanitary Sewer A ladies restroom and some sink drains in the laboratory MAA were tied

nto the plant sanitary sewer system.

They offered a possible path for diversion of accessible quantities of-SNM contained in the laboratory.

Perhaps, more importantly, they also offered an opportunity for a disgruntled or careless employee to adversely affect the fac11;ty's material balance and possibly contaminate the city sewer system.

(These conditions have since been corrected.)

Waste not Scanned for Metal Non-combustible waste from the laboratory, particularly _full plastic bags of empty contaminated sample vials. could conceivably house shielded quantities of SNM.

This material was not scanned for metal prior to being placed into a 55-gallon drum.

When this drum was full, it was tamper-safed and removed from the building for scanning.

(Th1s condition has since been corrected.)

Congested Access Control.Point The personnel access control point located is very congested. Three streams of traffic simultaneously converge upon this access control point.

This could confuse the guard as to who is leaving the MAA.

Thfs condition should be called to management's attention.

3.2.4 Items of Noncompliance The Diversion Path Survey did not disclose any items of noncompli-ance with existing regulatory requirements.

J.3 Specific Observations--External Assault Survey 3.3.1 Emergency Safeguards Deficiencies Requiring Immediate Correction The External Assault Appraisal did not disclose any emergency deficiencies requiring immediate correction.

3~3.2 Significant Safeguards Program Deficiencies Requiring Short Term Correction 3.3.3 Minor Safeguards Program Deficiencies of A Less Urgent Nature The External Assault Survey did not disclosure any minor safeguards nroaram deficiencies of a loss UrQent nature.

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3.3.4 Negative Factors 1n the Local Environment The exterior assault appra i sa 1 team made some observatf ons of a safeguard related nature involving matters generally outside the control of the licensee. These are noted below:

Adversary Escape Potential Since there are only two roads accessing Erwin, Tennessee, they can easily be interdicted to l!revent rapid response fro.!!'__police a_ge~_cies outsf de of Unicoi County,/

Interdiction of roads would also 1nhfbft StJM recove~y operat;ons. ~

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3.3.5 Positfve Factors fn the Local Environment The exterior assault appraisal team noted a number of factors peculiar to NFS, Erwin, which support the safeguards system.

These are enumerated below.

Adversary Movements Might be Hampered During Extended Reconnaissance Free movement by potential adversaries is restricted to the outlying areas because of the sensitivity to strangers fn the small towns and settlements.

Even the heavy traffic which moves through the moun-tains in the summer is subject to this local interest. The sensitivity and awareness to strangers provides a unique and effective asset to NFS safeguards by endangering any lengthy reconnaissance effort by an adversary group.

Some daylight operations co~ld be conducted on the western and northern boundaries, but at risk of possible detection by the local cfttzens and/or patrolling railroad detectives.

Road Escape Routes Can be Blocked Two major roads lead into the town of Erwin.

They are well maintained and easily travelled during normal weather, but are hazardous during periods of fog, rafn, snow, or fee.

These roads are not an effective route for adversary escape from the Erwin area since they can be easily controlled and blocked by the LLEA assets in the immediate area.

Illumination of Storage Areas is Good Illumination of SNM storage area entrances is good.

Securfty Force Personnel are Deputy Sheriffs The security force and plant security supervisors are deputy sheriffs. Security force members are deputy sheriffs. Auxiliary deputy sheriffs are also available for SNM recovery operations ana/or adversary containment within NFS site boundaries. All security personnel on the contract guard force are local citizens and are familar with the surrounding terrain and indigenous population.

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~** **sf:Q.., ***- Local Police Provide Effective Support Law enforcem~nt response ~vailabl!_to NFSr l

provide arf etn-ct1-ve backup to the site.

The randomness of patrols-;-

low communications profiles, and lack of established routines make law enforcement activities difficult for an adversary to evaluate. Officers' knowledge of the area plus an inter-department mutual aid plan of the n.verlapping jurisdictions are an asset to NFS security.

The LLEA have a cooperative attitude and an interest in supportil)S NFS in th~ Safeguard~ Program.

Add.1tiona1 assets to LLEA are 1 that can be utilized depending-apo-n their avail ab1 11 r.~.

_,Would Hamper Adversary Operatio_ns w -

An additional. not presently coordinated asset for NFS are the 1 I( Note:

Tennessee-State fish and Game officers, State Forestry pe1sonnel plus State and Federal Alcohol control agents are also active in this area and could pose difficulties for potential adversaries.)

Police Have Good Access to the NFS Facility Law Enforcement Agencies have multiple avenues of approach to the NFS facility ttJjt would be difficult to interdict or block.

The random patrols/

Jmake these routine patrols very difficult to fix and monitor.

3.4 Specific Obse~vations -- Physical Security Assessment 3.4.l Emergency Safeguards Deficiencies Requiring Immediate Correction The Physical Security Assessment did not disclose any emergency safe-guard deficiencies requiring fmmediate correction.

3.4.2 Significant Safeguards Program Deficiencies Requiring Short-Term Correction Alarm Condition Override Possibility

--if the SAS operator was inattentive, distracted or not at his position, the occurrence could 90 unnoticed.

(The licensee was made aware of this condition prior to the evaluation and it was subsequently corrected).

Secondary Alann Station Manning/Operating Practices From 7:00 p.m. to 7:00 a.m.* the secondary station operator 1s required to reconcile all alanns with the primary station and to log the alarm reconciliations. However, during main shift operations (7:00 a.m. to 7:00 p.m.) the secondary station attendant is not required to reconcile all alanns with the primary station. (Recently he has been given the job of "silencing" alarms by pushing a button which stops the status light from blinking.)

Activities in this area should be closely monitored by management security personnel as well as NRC inspectors to ensure that secondary functions are being properly performed.

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Protected Area Searches Vehicles coming onsite are searched for people and exolosives.

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I Alarm System Integrity Maint"enan,e or modi.fication of intrusion alarm system '?'!'P5Jn~~~~

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No maintenance is performed on any part of the security system without the knowledge cf the secur1ty officer. Furthermore, c1rcuit(s) officially logged as modified or repaired are function-ally tested by security personnel at the time of repair.

I Dependence [

also j eopa rdi zes the tota 1 system dur1n9,.any per1o~ of unplanned a7 sence, although provisions are made for

  • for anticipated absences.

Detection at the Protected Area Boundary I

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I 3.4.3 Minor Safeguards Program Deficiencies of a Less Urgent Nature Narrow Clear Zones at the Site Perimeter As an item of special attention, licensee management should expand the area external to the fence by cutting vegetation. Also, inside the perimeter of the fence, 11censee management should conduct a general clean-up campaign to remove unnecessary items which would provide natural cover or concealment.

Manning of Primary Central Alann Station The number of people located within the station, the diversity of activities and the demands p1aced upon the station operator present a potential for the operator to be distracted from performing hfs duties. It is_ a1soconcehable that the statfon operator would

. _.be _ VJJlne rab 1 e _j:o

'were the insfde adversary: This should be-subject to close management evaluation to determine if there is any indication that the situation within the station actually degrades the level of operator performance.

Congestion at Access Control Points

.J During shift changes, activity is accelerated and waiting 11 nes are formed.

Under such co.nd1t1ons>>

search procedures have a potential for being hurried and less inclusive than those conducted under low volume periods. Manage-ment should closely examine the situation to see if alternative procedures could be worked out along with structural modifications.

Management personnel should pursue the adequacy of searches conducted at this point. (This condft1on was also noted by the Diversion Path Survey Team.)

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3.4.4 Notable Safeguards Strengths The Physical Security Assessment Team also noted a number of safeguards system strengths peculiar to NFS, Erwin, as listed below:

Loca1 Law Enforcement Support f s Good Supervisors and line personnel ;nJ-

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were interviewed. They infonnally

--- --d-iscussed past operational experiences which were relevant to an assessment of their capability to support the NFS, Erwin facility.

In particular. however. the interviews focused upon periodic "no notice" dl"'ills al"'ranged by NFS Erwfn managment in coordfnation with Intel"'vfewees were asked about conduct

--or su*cfi tests. Regardingthese tests, they were ask,ed about inftfal dispositfon of response forces. personnel reactions, response times.

functions perfonned and thefr personal attitudes toward such exerc1 ses.

  • There appeared to be a good exchange of information and good coordfnatfon between LLEA elements and NFS, Erwin management.

(For example, almost every sworn officer ~ho was interviewed had been on a conducted tour of the NFS facility and was familar with the site layout and function.)

f It was concluded that the attitude and relations between the LLEA and NFS Erwin managment was good. Furthermore, LLEA personnel recognize a* special responsibility to protect against theft of the nuclear material at the NFS site.

Employees are Onsite 24 Hours a Oay The process areas operate continuously except for an annual two week shutdown for equipment repair. Because of this there is considerable movement in and around most of the buildings throughout a 24 nour.

period.

Guard Force Shift Supervisors are All Experienced Al 1. supervi SO:S r

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, have pol1,;e or military exper1ence. The NFS shift supervlsors are of particularly high quality and capability.

They are also relatively young, dynamic and intelligent. Coupling the two sets of superv;sors should prov;de good flexibil;ty for command and control of emergency situations.

Al arm Systems are E ffecthe 3.5 Specific Observations -- Material Control and Accounting Assessment 3.5.1 Emergency Safeguards Deficiencies Regufr;ng Immediate Correction The material control and accounting assessment did not disclose any emergency safeguards deficfencies requiring fmmedfate correction.

3.5.2 Signfffcant Safeguards Program Deficiencies Requiring Short Term Correction The material control and accounting assessment did not disclose any safeguards program deficiencies requiring short term correction.

I 3.5.3 Minor Program Oeffciencies of A Less Urgent Nature CONf!DOOtAI:::,-

Measurement of Of scard Stream A discard stream was identified in MBA-6 in which process liquid discharged to the sewer was based on zero (0) uranium values if composite liquid samples were assayed to contain less than 0.0001 g U/1.

Volume measurements for the discards were not made.

Based on preliminary findings, the loss stream amounted to less than 30 g uranium per inventory period which complies with existing NRC license conditions. However, since volume measurements were not being performed accurately, corrective action ought to be taken to assure that total volume multiplied by 1fqufd concentration does not exceed acceptable 1 imits.

Reliability of Hondestructfve Assay (NOA) Equipment NFS's NOA system (segmented gamma scanner) for assaying incinerator ash had been independently tested and found to be unsatisfactory.

NFS management acknowledged that the system had been experiencing drift problems and an outside consultant had been hired to correct the problem. Until the problem is resolved, NFS plans to run additional standards in order to correct for significant biases. At the closeout meeting, NFS personnel noted that the NOA system in question was shutdown due to operational problems similar to those found by the NRC team.

Scrap Recovery Pl ant The scrap recovery plant (t-'BA-5) was designed and built fn the 1950's when safeguards considerations were not emphasized as much as today.

It lacks capabiity to measure in-process SHM and the physical ability to retrofit fs quest A me f o her c ncerns with the scrap plant include:

4.0 Conclusions and Recommendations 4.1 Assurance Against a Single Insider The NRC staff concluded that the safeguards system at NFS, Erwfn provided good assurance of protection against nuclear theft by a single insider.

4.1.1 Recommended Actions to Achieve High Assurance Protection Against a Single Insider The only actions necessary.. to achieve high assurance _protection aqai nst" nuclear tliift-*by a -sing.le insider. is to. improve the condftf ons under which afcess_controls ar~ operated ~nd_increased management attention to

  • searches. As noted elsewhere il'l._t_t:1.i.1._report. personnel.conQesJ:ion oresent*

- ~-""soffepffiates _the_work_ of securi~y g~ards at an access control point.

4.2 Assurance Against External Assault The NRC staff concluded that the safeguards system at NFS, Erwin provided good to fair assurance of protection against nuclear theft by several ext~rnal-armed assaflants aided by an insider:***-- *. - *

4. 2.1
  • Recommended Act ions to Achieve High Assurance Protection Aga ins*t

- External Assault The NRC.staff identified a number of deficiencies requiring short term actions and some deficiencies of less urgent nature which also need correction to achieve a high level of assurance against external assault. Recommended actions are listed below:

  • Recommended Short=re*rm Actions -- Externar Assault Protection Following are short term actions recorrmended by the NRC staff to improve nuclear safeguards agafnst external assault at NFS, Erwin:

Recommended Actf ons of Less Urgent Nature -- External Assault Protection Following are less urgent actions recommended by the NRC staff.to improve nuclearsafeguardsagainst external assault at NFS, Erw1n:

4.2 Capability of Accounting System to Substantiate Theft The NRC staff concluded that the control _and accountina orocedures

_£J currently fol lowed at NFS, E.-win p.-ovide to.-detec:t f

either a single theft or a series of smah scale diversions as indicated below:

criterion o Capability to substantiate if more than five formula kilograms of SNM were illicitly removed from the facility during previous inventory periods.

o Capabi l ity to substantiate if more than five formula kilograms of SNM were illicitly removed from the facility during current inventory p,eriod.

Rating 4.3. 1 Reco~.mended Ac ti ons to Impr ove -- Material Accounting Capability The NRC staff did not see the need for any emergency or short term actions to im?rove material accounting capability at NFS, Erwin.

However, the following acti ons could improve SNM ~c.co,untability:

4. 4.

Sabotage Considerat.ions 4.~.1 Recommendations Concerning Potential Sabotage Sabotage potent;41 associated with Building should be the subject of a separate review by NRC and the licensee.

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5.0 Secondary Evalution During the site evaluation, secondary consideration was also given to the licensee's capability to meet more demanding safeguards require-ments published for comment in the Federal Register on July 5, 1977 (42 FR 34310). These are also described in detail 1n Appendix B to this report. Based upon field observations the NRC staff concludes that safeguards at NFS, Erwin would require considerable modification to satisfy future requirements in the proposed new rule.

5.1 Specfffc Observations Related to NRC's Proposed Future Safeguards Regui ~ements 5.1.l Accessfbflfty to SNM Although SNM is accessible within the process area, the problem of accessfbflfty especially in the early stages

  • 1s not peculiar to NFS. Erwin. While more process control and/or surveil-lance within the process area should be encouraged, it must be under-stood that the process requires a high degree of material accessibility.

Moreover, as long as the MAA control points are being operated correctly, access to the material does not imply that successful diversion may be carried out.

The proposed procedures and controls that work against one insider would also work to some extent against a conspiracy. However, additional safeguards measures related to process monitoring, surveillance and material control procedures. would be requ;red to protect against a threat of diversion involving conspiracy.

5.1.2 Hardness of SNM Storage Areas Based on surveillance, PDR infonnation and insider information, the walls, doors, windows, ceiling and other ooeninas of SNM storage buildings we,-e.assessed for vulnerability.

-co*JIM.='

-l1mFWERTrAL 5.1.3 Secondary Alarm Survivability

-H is anticipated that fu-riner fiar<lerifng of the s-econdar;-a1arm station would be required* to meet proposed safeguards upgrading requirements now being cons;dered by the NRC.

5.1.4 False Criticality Alarm Potential The control panel for criticality alarm sensors is located in the Health and Safety lab area ~of bldg. 105.

False alanns can be

-* ~HAI;-- --

c::~cqwNFPffllntt'tFPmmnt1at-.;;

5.1.5 Parts of Protected Area Are Not Illuminated The lighting system of NFS effectively illuminates the fences and clear ;ones,;-

  • 5.2 Satisfying Proposed Future Requirements of NRC's Upgrade Rule The NRC staff concluded that safeguards at NFS, Erwin would require.

considerable modifications to satisfy proposed new requirements of NRC's upgrade rule. Following are the types of actions which would be required:

o Provide increased surveillance of persons having access to material access areas.

o Provide dual manning of material access control points.

o Harden SNM storage vaults.

o Improve protected area lighting.

Th1s 1s not an exhaustive list of actions which would be required at NFS, Erwin. Rather, it is indicative of the kinds of actions required to satisfy proposed new safeguards requirements currently being consfdered by the Commission. Furthermore, this list is generally consistent with that shown in the statement of considerations published with the proposed new rule in July 1977 (42 FR 34310).

APPENDIX A PHOTOGRAPHS OF NFS. ERWIN AND SURROUNDINGS

9-1 APP:NOIX 3 I.

EVALUAiICN AOVERS~~y CEFiN!i!ONS A. Generai ihe pur;ose of this appendix is t~ d~sc~ss hypothetical adversary characteristics wnfcn w111 be used to assess safe9uards during implementation of. t?te 1977 Comprehensive E*1aluation Plan for SSNM facf11t1es.

a.

ihe Sasaline for Prfmar1 ~'laluation During 1977, primary evaluations will measure safeguar~s capabflit1es against the hypothetical threat give~ below. It should be noted that !~is requfremtn~ fs similar tJ the requir~~er.t for physical protection of nuclear power react~rs agafnst ir.dust~1ai sabotage specified in 10 C~

73. :5 (a).

ihe licen_se-e shal1 es:aolfsh ar.d mafntafn an or?site physical protection syst=~ and sec~rity or;anf:at1on against t~eft by bo;h the follcwing:

{l) A detar.nined v~o1e~! ex~~rr.al assau1t, a::.ac~ by staalt~.

0r deceptive ac~icns, 0f several :ersons wi:h the fo11owing at~ributes, assistance, and equi;men::

(i) well ~rained (includ~ng ~ili:ary tn.~nir.; and skil~s) and dedicat~d i~d~vi~uals, (ii) inside assistanc~ whfc~

may inc1ude a knowied;eable indivicual ~ho attempts tc part1cipate in co.:., a ;,assiye roie {e.g., provide infor:na-t1on) and an active r,le (e.;., facili~ate ent~ance and

. I I

F

  • 8*2 exit. d1sable alarms and c:r.:::unicaticns. par:icipata fn vfolent at"tac!c), (iii) su_itable weacons, up to and including hand-held auta~a~ic we1p0ns, equipped wit~

silencers and havfng effectfve long*rsnge accuracy

  • .(iv) _hand-c&l"1"ied equip~~nt, fncludfng fncapac1tatfng agents ~nd explosives far use as t~als of entry or otherwise destroying features of the safeguards systsm, (2)

An inte~nat threat of an insider, 1nclud1ng an em~loyee (in any posttfon).

Each component tn,e of evaluation, e.g., ::Xtarior Assaul~ Acoraisal, Oiven1on Path Survev, ~aterfai Acc~un~in~ Assess~e~t, and Physical Se~~rity Assess~ent will use relevant por~ians or this acversary base*

line as evaluation cr1tar!a and w~il measure safe~uar1 ca:ab11ft1e5 and vulner!bflities agafnst ft.

C.

rne Baseline for Sec~ndar;, :vaiua:i::ns Curing fmplemertt!:ian of the !Si7 C:imprehensive :'.n1ua:1on P1an seconcar, consideration dl1 also :::ie g1ve:, ::i 1~ce?tsee :?!3aci1i:~es t~

meet t~e more demanding perforn:ance re~u~r~en:s which Nf11 ~e :~e subject or safeguards upgrace rulemaking durin~ the same t1we period.

'.valuat~on
  • results Hill provide input to :he rul;~akfng ~~cess.

ihe hy~othet1c!1 t~reat for the seeon~arl evaluat~ons fs as follows:

(l) A deter.:iined violent external assau1:, at~ack ~Y s:aalth, or decspt1ve ac~1ons, by a s~ail group wi:h the fo11owing at~ribu:es, F

,ss1stance, and equipment:

(f) weil tr11ned (1ncludfng m11ftar; tr!ining and skitls) and dedfca~ad fndivicuats, (ff) inside assistznce which ~~Y ir.cluce a knowledgeable 1ndiv1~ua1 who at!~~pts to part1cipate in both a passfv9 role (e.g.,.prcvide infcn:iatfon) and an active roJe (e.g.,

facilit!ta en"t:-!nce and exit, disable alarms an~ e::miun1ca-

.tions, par~icfpate 1n violent a:~ack), (iii) suitable wea~ons, up to and fnc1ud1ng hand-neld autcmatic we!pons, equ~pped wti h s'fl ence!"S ar:d having effec!ive i ong-ranga ac::.iracy, and e.x;,tosives for use as t::ols for en~ry ar.d othe,r,1isa (v) the ability to operate as two or more teams, and

2.

The threat pos*ed by a conspiracy of insiders or employees fn any posit ion.

,t

~

~ '

?',

' i.

i

' (

The Honorable Morr1s K. Udall, Chairman Subcommittee on Energy and the.Environment Committee on Interior and Insular Affairs United States House of Representatives Washington, D. c.

20515

Dear Mr. Chairman:

Enclosed is a comprehensive evaluation report on nuclear safeguards at the Nuclear Fuel Services (NFS) facility, Erwin, Tennessee.

It is the second report in a series now in preparation reevaluating safeguards at fuel cycle *facilities in accordance with a comprehensive evaluation plan which the Comm1ss1on endorsed in May 1977.

As stated in our letter of March 30, 1978, these reports disclose weaknesses for which we will require corrective actions.

On the basis of this report, the NRC staff concluded that safeguards at NFS, Erwin protect with good assurance against theft or sabotage by a single insider acting alone, and with good to fair assurance against a violent assault by several outsiders assisted_ by.an insider.

The comp~ehensive evaluation did not disclose any emergency safeguards deficiencies requiring immediate correction.

On, the basis of the report, the NRC staff has recorm1ended a number of actions to improve nuclear safeguards at NFS, Enlin.

The staff is translating its recommendations into licensing actions to provide high assurance safeguards for strategic special nuclear materials at NFS, Erwin.

During the evaluation of NFS, secondary consideration was also given to the licensee's capability to satisfy more demanding safeguards requirements published for comment on July S, 1977 in the Federal Register

The Honorable Morris (42 FR 34310).

On the basis of the evaluation report, the staff concludes that safeguards at NFS, Erwin would require considerable modification to satisfy future requirements fn the proposed new rule.

An NRC team will visit NFS, Erwin soon to deliver the evaluation report and discuss licensing and inspection actions with licensee manage-ment.

Following corrective actions, the 11censee w111 be reinspected by our staff to verify comp11ance.

The refnspection report will be reviewed by the Commission which will take whatever corrective action is indicated, including. if necessary, license suspension.

Th;s report_ is classified Confidential-Restricted Data-National Security Information because it contains information that could assist a potential adversary intent on theft or sabotage involving strategic nuclear materials.

Enclosure:

Sincerely, Joseph M. Hendrie Chairman E-val uation Report (Confidentia 1-Res tri cted Oa ta)

Similar letters to:

The Honorable Gary Hart, Chairman Subcommittee on Nuclear Regulation Committee on Environment and Public Works United States Senate Washington, D. C.

20510

{Additional addressees on next page)

-3*

The Honorable John D. Dingell, Chairman Subcommfttee on Energy and Power Conmfttee on Interstate and Foreign Conmerce United States House of Representatives Washfngton, D. C.

20515 The norabl~ John Glenn Chairman Subcom ittee o Energy, N clear Proliferation and F eral S vices Committee on.Gove ment Affa rs United Sta s Senat Washington/ o. C.

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