ML20235A869

Forwards Partially Withheld Diversion Risk Analysis Prototype.Diversion Risk Analysis Should Be Made for Each Major Fuel Facility to Determine Risk Potential & Type of Response to Threats

ML20235A869
Person / Time
Site:	Framatome ANP Richland
Issue date:	11/27/1974
From:	Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Jennifer Davis US ATOMIC ENERGY COMMISSION (AEC)
Shared Package
ML20234F575	List: IA-86-410, Forwards Partially Withheld Diversion Risk Analysis Prototype.Diversion Risk Analysis Should Be Made for Each Major Fuel Facility to Determine Risk Potential & Type of Response to Threats ML20234F573 ML20235A121 ML20235A147 ML20235A165 ML20235A202 ML20235A227 ML20235A251 ML20235A272 ML20235A375 ML20235A389 ML20235A409 ML20235A430 ML20235A436 ML20235A474 ML20235A630 ML20235A708 ML20235A748 ML20235A799 ML20235A869
References
FOIA-86-410 NUDOCS 8707080560
Download: ML20235A869 (9)

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.n John G. Davis, Deputy Director for Field Operations Q Directorate of Regulatory Operations, BQ .-

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. u ,, , y, TEEUs R. E. Engelken Director, 30 V DIVERSIM RISK ANALYSIS - EXION NUCLEAR CMPANT We agree that a Diversion Risk Analysis should be made for each asjor taal facility to determine the risk potential and the type of response to threats, particularly for risks relating to threats of explosion.

Licensees may be estegorised La order of diminishing risk potential and vulnerability, with only those routinaly possessing significant I quantities of strategic materials in suitable form for fabrication I of a soclear device fneluded in the top category.

Current Regulatory requirements for bimonthly physical inventories and increased physical protection of strategic materials minimism the possibility of diversion of a quantity of such material in sufficient quantity and of a suitable form to permit fabrication of viable device within the two month period. In addition, a number of licensees l possessing the foregoing asterials perform at least an ites accounting

. monthly.

i In event of a threat involving a possible nuclear explosiva device, relatively few licensees need be requested to verify an inventory as an initial response. The request and response could be by predetermined codes. 99,t;,.

In regard to radiological threats, current Reg 21 story requirensets for materials and plant protection are not designed to prevent diversion of a quantity of plutonipes sufficient to be useful as a radiological hasard. In addition, any number of basardous radioactive by prodects such as cobalt 60, are readily available and vulnerable to theft to support a radiological threat.

,@ W[a have selected Exxon Nuclear Company for the prototype Diversion Risk l o n. Analysis because they routinely process plutonium in the manufacture o of mixed oxide reactor fuel. Exxon is permitted by license to possess

,Q 0, not more than 100 kilograms plutonium at any ties and not more than ,

y 10 kilograms may be in unsealed or unencapsulated form. Material not l 8<t o in process, in low-level waste or assembled fuel elements is stored

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! QJ RO:V ltformation in this record was delcted {

S$$ Rissolo:eak in accordance with the Fr 10m of Information

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'E s In event of a timreat requiring a physical inventory, a complete ites acceenting of tamper esfad eestainere, feel bundles, fusi segments. -

r ,y  %.in process,,anterial, and weste eagtainers can be made in appronWastely

, .utwo hours. Weight verificaties of any materials la process would ' '

require addittaamal tima thich would vary with the quantity in procers

, and stage of the process, but ordinarily should be less than one additional hour.

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Vincent !L Risolo 4

7. N. Rissolo, Chief Materials and Plant Protection Branch Enclosures

1. Diversion Risk Analysis - Exxon i 2. Site Plot Plan

3. sketch of Fu Ar ms I.

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ID 'j . ENCLOSUEE DIVERSION RISK ANALYSIS *ii AND RESPONSE PLAN f*

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Exxon Nuclear Company Inc. -

2101 Morn Rapdds Road -

Richtmad, Washingtoa 99352 Docket No.70-129 License No. S h W 1 The plant is located appravimately five miles north of the City of R,ichlan.1 sad about one mile from the closest other industrial facility.

The Hanford AEC reservation is located immediately north of the plant.

The Exxon Puclur Fuels Facilities consist of five buildings an office

, building complex; a uranin = oxide fuels manufacturing ba41d4= ; a mixed l oside (Puoy,2 -UO ) fuels manu accuring building; a radioactive materials

, storage buuding and a warehouse. (See Attachments.)

All plutonium storage and processing operations are restricted to a portion of the Mixed Oxide Building.

MATFETAL POSSESSED

1. Licensed quantities of Matsrial

a. Plutonium - 100 kilograms Not more than 10 Kg permitted to be in dispensable form at any time. Remainder must be in sealed (encapsulated) form. M.*C

b. Uranium as U-235 - 3500 kilograms in uranium enriched in U-235 to not more than 5%.

2. Quantities on inventory as of October 31, 1974

a. Plutonium p,k g,d ams iss11e b.

fi p i U-235 W kilograms in uranium enrichments normal to 5% U-233.

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b. Usual Forms of Material Puo2 feed material Puo2-UO 8 "I*

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Nota: No material as metal or nitrate.

SECURITT PLAN

1. Salient features to prevent diversion

a. All processing and stor 1

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f. See atemehad sketches of facility showing physical features of .

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1. Security Plan hhi?

Implementation of the plan's physical and mA=infatrative features in regard to prevention of diversion of SnDi are considered highly effective within the limitations of 10 CFR 73 requirements.

No partirutar weaknesses have been W reified.

2. Suitability of Haterial

a. Explosive threat Material is unsuitable for fashioning into an amplosive device in the form in which the material is routinely used. The Puo2 , prior to combination with the UO must be converted to  ;

the estal. After combination with UO.,2a complex cha=femi processing would be required to separtes the Fu followed by a y,;;

difficult conversion to meta.1. Pu contained in Ice-level wastes would be extremely difficult to separate and process to a suitable form in sufficient quantity to present a threat.

~ b. Radiological threat

-Puo2 in any quantity in the dispensable forms would present a significant radiological threat. Usefulness of the material *4 as a radiological hazard would diminf eh af tar combining with UO2 and further diminfah in the form of low-level waste and assembled fuel bundias.

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_ RESPONSE PL&M i

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l 1. MUF in excess of LEMUF I

a. Ragional Response If MUF greater than 1.5 LEWUF, direct 14eaa ee to discontinue processing, investigate cause and re-inventory if explanation not found within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of reporting. If diversion suspected, report to Headquarters and appropriate 1mt enforcement agencies, and dispatch Regional inspectors.

If MUF greater than allowed limit but less than 1.5 LEtWF, py' "

advise licenses to re-inventory and investigate to determine cause. Diapatch RO inspector if seems advisable.

b. Licensee Response Make inmediata pra14minan investigation to determina possible cause. If excessive HUF not corrected as a result of pre-liminary investigation, report to AEC Regional Office. Follow " fi with the inventory, review of docuneatation and measurements, and shutdown of all material movements and processing. Report results of investigation to AEC in writing vithin 30 days.

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r==diate moti.ficatios of Headquarters staff aedWpropriate t-I liar enforcasaant aseawy. 'Issoas ar.guitiJe of incident by telephone and diracc licenses accord hgly to determine any

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'9 loss or possible loss of DD(, wheth w sr not incident was ~

diracted toward possible diversick of SAD (, has result of lacident diminf ahd protection ar). how each, aan who hae been -

notified for eaststance.

Dispatch investigative team frca Engica Det"f as no sigai-

.ficance and magnitude of incident, establish commmication centers at 1 site an ilegion. provide coordinatica cf efforts, sacure that licensas and law enforcement personnel are doing oil that is necessary.

! b. Lienasee Response l

Immediata notification of local law enforcement agency Jnui request for assistance. As soon as possible notify AEC Regional Ofa' ice. Provida interim protectica for Stai as

necessary. Determine if any SlDi lost or dispersed and quan-tity. Cooperate with law enforcement forces as required to

, initiate recovery of stolen material.

. 3. Sabotage Threats

a. Ragional Response

_. Obtain all possibis ir., formation to assess the thrsat and risk. . , _ ,

' Notify Headquarters providing all known indoraation. Assuru T' that appropriate law enforcement authorities are notified.

Assist in prev?. ding ==ana or advice for neutralizing the

threat. Kaap Headquarters advised currently. Dispatch RO ,

j o,,, team if seems necesasty. )

b. Licensee Response

. Msq Assess potential of threat and the risk. Hott.fy local law enforcement authorities sad FBI. . Notify AEC Regional Office.

Provide additional protection as possible. Take whatever action possible to neutralize threat. Itsep AEC Regional {

Office advised currently of developments. )

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, , .,Same as for Sabotage Threat.

b. Licensee Response .

Same as for Sabotage Threat.

5. Thefe of Material - known or suspected

a. Regional Response Assure that appropriate law enforcement authorities notified. l i Wotify Headquarters. Determine quantity of material involved I

and reisted information, as known by the lic - er. Dispatch investigative team to licensee site. Assist in deter =<n<ng quantity and form of material by inventory. Analyse possible risk of hazard to public.

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b. L4e-a ee Easponse i

l Notify local law enforcement authorities and FBI. Notify AEC Ragional Office. Determine quantity and form of material, amehanism of thef t, when may have (or did) occur. Assist f authorities in recovery effort by providing all possible in- j formation.

6. Artortion Threat - Facility named in threat

a. Regional Response i

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Analyse nature of threat to determina credibility. Response dependent on basis for extortion threat. Notify Headquarters.

Assure that appropriate law enforcement authorities notified

- by licenses. Advise licensee to increase material protection.

b. Licensee Response ndW$

Analyse the basis and risk of the threat. Notify appropriate l 1 v enforcement authorities and AEC Ragional Office. If threat is based on possible thaft of material, determine immediately whether any not accounted for and form of material. j

!  ! Determine if physical protection may have been defeated in any l  ; vay. Increase protection of material by transferring all l possible to secure storage and increasing guard monitoring, y .. ,

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7. Extortica Threat - General -

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m. Regional Response. .

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Analyse the basia and risk potential. Contact individual Licensees depending on type, gnantity, and form of material *vt~-

involved in the threat, if known, and request inventory check -

of deemed necessary. If extortion is based on a nuclear bomb threat it is not credible that the material may have been diverted from a facility having only material in oxide forms and have been processed to a suitable form within a two month inventory period. Any M- e routinely in possession of 3 stratagic material in a suitable matal form should be requested to make a thorough inventory check of such material immediately.

Materials as scrap, vaste and product where the Stei has been rendered to a form which must be subjected to a 2magthy and l difficult processing operation for recovery in a suitable form I need not be included if all accounted for within the preceding two mont.h period.

If extortion is based on a radiological threat, all 14e=naees possessing plutonium in any form should be requested to inventory all such material in any form. Licensee's possessing only uranh= in any form need not be contacted unless the threat specifically refers to uranium, which would be unlikely.

b. Licensee Responsa

. j Since the reaction to a general extortion threat would usually be initiated by the AEC through Regional Offices, response should be in accordance with AEC instructions.

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