ML20235A165
| ML20235A165 | |
| Person / Time | |
|---|---|
| Issue date: | 01/30/1976 |
| From: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Thornburg H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20234F575 | List:
|
| References | |
| FOIA-86-410 NUDOCS 8707080338 | |
| Download: ML20235A165 (9) | |
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Harold D. Thornburg, Acting Director., Division of Field Operations .
0ffice of Inspection and Enforcement, Headquarters SPECIAL STAFF REVIEWS OF FUEL FACILITY, SAFEGUARDS AND SECURITY PROGRAMS ,
The following is submitted in response to your request of January 28, .
1976.
INTERNAL THREAT A. Question: Are the materials control and the materials -
accountability programs, including containment, confinement and accountability, satisfactory to prevent one employee from removing five formula kilograms of enriched material from a fuel plant at one time or by diverting small amounts of material continuously over the period of one year?
In general, the answer must be "no" because no system has !
been proven to be completely effective and devoid of all risk. However, for each of the fuel facilities considered on an individual basis, the established programs are satisfactory in regard to design, implementation and administration to reduce the risk of diversion by one unassisted employee to a minimum. With varying amounts of assistance which conceivably could be provided through collusion with other employees, the risk of possible diversion is increased.
The following assessment of the effectiveness of physical protection and accountability of materials at the N4 assigned fuel facilities is based on inspection findings and impressions of experienced inspectors familiar with c.~. . - the facilities. Although the inspectors were unable to identify any particular defect which could permit a successful unauthorized removal of material by one ,
employee, positive statements are made with the reserva-tion that some risk exists as previously stated.
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JM 3 01976 Assessment of the effectiveness of the safeguards program of individual fuel facllities to prevent the type of diversion described by the foregoing question is as follows:
FACILITY A: .
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- 1. Five formula kilograms at one time: '.
It is highly unlikely that one unassisted employee ~~.
could remove this quantity of material from the facility:
- a. Material of interest is Pu.
- b. Considerably less than the subject quantity is permitted to be in the processing area at any time in a form that could conceivably be carried out.
- c. Not less than two operators are permitted to be L in a material access area at any time. 4 l
- d. Material in all fonns (cxcept waste) is stored i in a vault which meets GSA specifications, has i access limited to certain authorized operators by the " buddy" system, and is normally locked. ;,
When locked, the intrusion detection systems 'h are activated by the control guard. For access, authorized operators must notify the guard and identify themselves prior to unlocking the door.
- e. The guard response to any alarm associated with the material access areas is imediate - within a minute. Therefore, it would not be possible for an operator to exit undetected through an emergency exit with material and hide it er throw it over the protected area barrier. A., u-s
- f. Material is moved from one area to another only under surveillance.
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- 2. Five formula kilograms by small amounts continuously !
over the period of one year:
It is highly unlikely that one unassisted employee e r' .4 could remove this quantity of material from the facility by small increments.
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Harold D. Thornburg 2- 3 JAN 3 0 1978 -
- a. Only a small quantity of material is permitted to be out of the vault and in process at any one time. '
- b. An item accountability inventory is performed ;-
weekly.
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- c. Physical inventory performed monthly,
- d. Not less than two operators are permitted to be in a material access area at one time or to move material between areas.
- e. If material control and security systems should be defeated and a number of small quantities of material is removed past the detectors, the accountability system would detect diversion within the period of two or three monthly inventories because of limited quantities in process, frequent material balances closed, and a relatively small total inventory at any one time.
FACILITY B:
- 1. Five formula kilograms at one time:
It is highly unlikely that one unassisted employee could remove this quantity of material from the facility.
- a. Material of interest is highly enriched uranium as oxide, carbide er mixture with thorium oxide or carbide, and as metal or alloy.
- b. Normally a discrete item contains significantly less than five kilograms.
- c. Operators in process and storage material balance "D 5 areas (l%A)areundercontinuoussurveillanceby closed circuit TV and at lerst two together.
._%,, d. Material is transported between material balance areas by not less than two employees.
- e. Upon exit from certain material balance and M 'e storage areas not under direct control of a guard, not less than two employees must exit together; prior to exit the control guard must be notified, and employees are required to search each other with hand-held SNM and metal detectors while under l surveillance of a guard by closed circuit TV.
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- f. ' Material being transported between MAA's must be '
. measured, tamper-safed, and accompanied by proper .
m documentation. Each item must be verified upon
, receipt by the receiver. Low level waste is g
measured by nondestructive assay upon exit from '.
an MAA but is not tamper-safed.
- g. It is conceivable that an item or items could be removed from an MAA by an employee during an -
emergency evacuation. However, the possibility of doing so undetected is remote. Also, the evacua-tion route is surveyed for SNM by health physics technicians immediately following the event.
- h. Materials are prepared and packaged for shipping by at least two authorized employees and tamper-safed. Shipments are then transported to the shipping point by et least two employees together.
- 2. Five formula kilograms by small amounts continuously over the period of one year:
l It is highly unlikely that one unassisted employee could I remove this quantity of material fro.n the facility by small increments.
- a. Most of the reasons listed under Part 1. are applicable.
- b. Small sample size quantities could be removed without irmediate detection from one or more of the Research and Development laboratories which are exempt from security requirements of the processing areas. Each laboratory is limited individually 4 to possession of small quantities in no case %.
greater than 350 grams, mostly less. In total, l
for all laboratories, the inventory is less than one kg U-235 and about two kg annual throughput.
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I FACILITY C:
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- 1. Five formula kilograms at one time: .A w It is highly unlikely that one unassisted employee could remove this quantity of material from the facility.
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- a. Materials of interest are highly enriched uranium ,
as metal and metal alloys, and Pu as nitrate, -
oxide and mixed Pu-U oxides. ~@!-
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- b. The same reasons listed for Facility B. are applicable,
- c. Operations with uranium are confined to one relatively small area within a building. MAA's are adjacent to each other so that material movements between MAA's are all within the pro-tected area and under continuous surveillance.
- d. Operations with Pu are confined to a single MAA within a single building at another site. Current operations involve research and development with less than two kilograms Pu in total.
- 2. Five formula kilograms by small amounts continuously over the period of one year.
It is highly unlikely that one unassisted employee could remove this quantity of material from the facility by small increments:
- a. Most of the same reasons listed under Part 1.
are applicable.
- b. It is conceivable that small sample size quantities of uranium could be removed from the facility over a period of time because the laboratories are located outside the protected area. However, such removals would not conceivably escape detection for as long cs a year because of necessary documenta- aa Z tion for accountability, material control measure-ments and surveillance. Also, the laboratories are limited to possession of less than 350 grams and the throughput is less than five kilograms annually.
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- 1. Five formula kilograms at one time: 7 ,-.
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. , It is very unlikely that one unassisted employee could 9e ' -"' ' remove this quantity of material from the facility:
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- a. Materials of interest are Pu and highly enriched uranium. The total Pu is less than ten kilograms
,-and total U-235 is less than two kilograms. Since ,
the facility is engaged primarily in R&D and pilot activities the materials are in a large variety <
of forms and contained in a large number of items each containing a relatively small quantity of material. x
- b. Access to the materials is restricted to a few operators and only under continuous surveillance.
- c. Only less than one kg quantities are permitted to be outside of a locked vault at any one time.
- d. Material balance and item controls in effect would preclude removal of a significant quantity of material at any one time.
- 2. Five formula kilograms by small amounts continuously over the period of one year:
It is very unlikely that one unassisted employee could remove this quantity of material from the facility by small increments:
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- a. Most of the same reasons listed under part 1. are applicable.
- b. It is conceivable that small sample size quantities of uranium could be removed from the facility over a period of time because a number of R&D and analy-tical laboratories which are located outside the WW@
protected areas possess exempt quantities of materials.
Such laboratories would not, in total, possess as much as five kilograms per year. Also, repeated unauthorized removals of small quantities could not escape detection for as long as a year because of accountability and other material control requirements.
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EXTERNAL THREAT /
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. B. Question: Could the aggregate physical protection system -
'@ at each of the facilities being considered, as implemented. #.
7 prevent two or three persons with the equivalent of Vietnam c.- experience and training, from assaulting a facility and successfully removing five formula kilograms of special nuclear material.
The answer must be "no" because physical protection re-quirements were not designed or intended to prevent this type of intrusion.
To qualify the foregoing, it must be assumed that the assault
_. force is adequately equipped with weapons, explosives, tools, knowledge of the security system, fore-knowledge of the loca-tion and identification of the target material, knowledge of the response time and possible strength of Local Law Enforcement Authorities (LLEA), and an assured escdpe plan.
The amount of resistance which could be provided by each of facilities A, B, C and D would not be sufficient to prevent an assault and removal of material. An important variable would be whether the intrusion detection alarm system is inactivated promptly in the central station to prevent annunciation in the secondary manned center and consequent request for outside assistance.
The possible success of assault and removal of material could also be affected at each facility as follows:
FACILITY A:
- 1. The secondary alarm system annunciated in the LLEA TC$
center. Initial response is normally within about eight minutes. Backup response in force could be within a few minutes more depending on availability
- " " " ' and dispersal of personnel.
- 2. Target material is nonna11y stored in a locked vault %' g which meets GSA specifications. It could be opened quickly by knowing the combination or forcing an operator to open it. Forcible entry would be difficult and time consuming.
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- 3. Sufficient material in attractive form is packaged dthin '
the vault in a manner which would permit easy transport. -;
3 4. The facility is sufficiently isolated from a populated 2 area to make escape difficult.
FACILITY 0:
- 1. The central control center is located in the imediate vicinity of the largest portion of the facility's in-ventory of target material. It is sufficiently removed from the nearest vehicle parking to permit observation of approaching individuals. During off shift and weekend hours access from the parking lot is remotely controlled through an additional barrier and CCTV. The possibility of detection of intrusion into the protected area, even through a remote section of barrier, in sufficient time to request assistance is very good. Additional guards and the LLEA could respond within 5 minutes.
- 2. Currently, all except insignificant quantities of target material located at the primary processing and storage area is stored in locked vault type rooms within a pro-tected area at all times.
- 3. A significant quantity of target material is located in a secondary processing and storage area located J within a protected area. When unattended this material e is protected by effective intrusion detectors. It is y
more vulnerable to attack because it is located remote from the nearest guard post and adjacent to open terrain.
However, it can be approached by vehicle only through patrolled areas equipped with intrusion detectors.
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- 4. When manned, ready entry into the building is possible.
However, the processing area and storage areas are equipped with active intrusion detectors and CCTV.
,,,,. The main guard center would have to be neutralized prior to assault on the area. Escape would be complicated.
- 5. Initial LLEA response could be within 5 minutes with M-9 followup in force within a few minutes.
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Harold D. Thornburg JAN 3 0 1976 FACILITY C:
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MA's at the main site are located within a protected 1.
M4 area within an owner controlled area.
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'"_ 2. When the processing areas are in operation, significant quantities of target material could be present at times.
Normally, the bulk of the target material is stored in a locked vault.
- 3. The central alarm and communications center is located within a separate protected area away from the MA areas.
It is highly resistant to intrusion.
- 4. The secondary alarm and communications center is located off-site and is in continuous communication with the central station.
- 5. Initial response by the LLEA could be within E minutes with a backup force within a few minutes.
- 6. The relatively small quantity of material in somewhat unattractive form located at a secondary site remote from the main plant would probably not be susceptible to mass assault for diversion of material at this time.
FACILITY D:
- 1. This facility is located in a remote area and is readily accessible.
- 2. The central alarm and communications center is highly -~
vulnerable to fast and complete neutralization as is #g'eg the secondary center also on site. '
- 3. Although approximately ten kgs of target material is available, it would be unlikely that as much as five
- ~.~ kilograms of material in readily usable form and of a weight and volume which could be carried by two or three individuals could be readily removed from the facility.
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R. H. Engelken Director
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