ML19259B474

NRC Annual Rept to Congress on Domestic Safeguards (FY78)

ML19259B474
Person / Time
Issue date:	01/31/1979
From:	NRC COMMISSION (OCM)
To:
Shared Package
ML19259B467	List: ML19259B466 ML19259B468 ML19259B469 ML19259B470 ML19259B471 ML19259B472 ML19259B473 ML19259B474
References
NUDOCS 7902150418
Download: ML19259B474 (44)

Text

e DOMESTIC SAFEGUARDS ANNUAL REPORT TO CONGRESS FISCAL YEAR 1978 JANUARY 1979 2072 520 79021so4 \\%

TABLE OF CONTENTS Page Introduction.......

I Scope of NRC Safeguards Activities.....................

1 How NRC Determines Safeguards Adequacy.................

2 Threat Considerations...............................

2 Safeguards Requirements.................................

3 Assessments of Safeguards Adequacy............

3 Safeguards Adequacy in FY 1978............................

7 Fuel Cycle Facilities and Transportation Activities....

7 Power and Non-Power Reactors.............

11 Safeguards Research and Technical Assistance........

13 Future Safeguards Programs................

15 Organization and Management of Safeguards.........

16 Appendio s A.

,eope of NRC Safeguards Act';ities 8.

F(. tors Associated with NRL's Assessment of Safeguards Adequacy C.

Safegaards Research and Technical Assistance D.

Future Safeguards Programs E.

Organization and Management for Safeguards F.

Glossary G.

Classified Appendix (Site-Specific Comprehensive Evaluation Results) 2072 521

9 NRC ANNUAL REPORT TO CONGRESS ON DOMESTIC SAFEGUARDS (Fiscal Year 1978)

INTRODUCTION The U.S. Nuclear Regulatory Commission (NRC) has been directed by Congress (PL 95-601 amending Sec. 209 of the Energy Reorganization Act of 1974) to submit an annual report on NRC's domestic safeguards program.

The law directs the Executive Director for Operations (ED0) of NRC to:

".. prepare and forward to the Commission an annual report (for the fiscal year 1978 and each succeeding fiscal year) on the status of the Commission's programs concerning domestic safeguards matters, including an assessment of the effectiveness and adequacy of safe-guards at facilities and activities licensed by the Commission.

The Commission shall forward to the Congress a report under this section prior to February 1,1979 as a separate document, and prior to February 1 of each succeeding year as a separate chapter of the Commission's annual report (required under section 307 of the Energy Reorganization Act of 1974) following the fiscal year to which such report applies."

This report covers fiscal year 1073.

It focuses on the adequacy of domestic safeguards at facilities and activities licensed by NRC.

Discussions in the report cover:

the scope of NRC safeguards activities; how NRC determines safeguards adequacy; NRC safeguards adequacy in fiscal year 1978; NRC safeguards research and technical assistance; NRC future safeguards programs; and NRC organization and management for safeguards.

Separate appendices provide a detailed discussion for selected topics.

Scope of NRC Safeguards Activities NRC's safeguards responsibilities are set out in the Atomic Energy Act of 1954 and the Energy Reorganization Act of 1974.

Among other thi'.gs, these Acts require NRC to regulate the safeguards of certain nuclear facilities and activities.

NRC safeguards regulatory programs share the common goal of assuring that licensed activities do not pose undue risk to the public health and safety and are not inimical to the common defense and security.

The NRC safeguards measures are designed to deter, prevent, and respond to (1) the unauthorized possession, thef t, diversion or use of special nuclear material, and (2) sabetage of nuclear facilities.

In particular, safeguards for fuel cycle facilities emphasize protection against theft or diversion of strategic special nuclear material, while 20/2 522 safeguards for power reactors emphasize protection against industrial sabotage.

The NRC currently has safeguards regulatory control over 19 fuel cycle facilities which are authorized to possess formula quantities of highly enriched uranium or plutonium,1 transportation activities involving formula quantities of highly enriched uranium or plutonium2 (abo't one shipment per month), 70 operating commercial power reactors, and ~/1 non power reactors.

A more detailed discussion of the scope of NRC safeguards activities is provided in Appendix A.

How NRC Determines Safeguards Adequacy Safeguards at NRC-licensed facilities are in place to protect the public against significant risks associated with possible theft, diversion, or sabotage.

NRC considers safeguards " adequate" if they provide such protection.

Operational use of the term " adequacy" as applied t' safe-guards at NRC-licensed facilities requires a more detailed description of:

1.

NRC's application of the hypothetical design threats and NRC's response to actual threats, should they occur.

2.

Safeguards requirements that NRC imposes on licensees.

3.

Methods NRC uses to assess the adequacy of licensee safeguards.

Threat Considerations.

Information available to NRC does not indicate the existence of a significant near-term threat of theft or diversion involving strategic spacial nuclear material, or sabotage.

NRC's contincing efforts to identify such threats are documented in Appendix B.

Nevertheless, NRC has developed the following hypothetical design threat:

1.

A determined violent external assault, attack by stealth, or deceptive actions, of several persons assisted by an insider, and 2.

An internal threat of an insider, including an employee (in any position).

1Four additional fuel cycle facilities are authorized to possess more than one effective kilogram of low-enriched uranium and are therefore subject to safeguards material control and accounting requireents.

Those fuel cycle facilities iWolved in processing nighly enriched uranium for the manufacture or fuel for the naval propu'.sion program possess rearly all of the highly enriched uranium at fuel cycle facilities.

2 Formula Quartity.

See Glossary (Appendix F).

20/2 523 This hypothetical design threat provides the basis for regulatory requirements that NRC imposes on licensees and provides criteria against which the adequacy of licensee safeguards are judged.3 The current threat characterization used by NRC is essentially the same for power reactors,4 fuel cycle facilities and transportation activities involving strategic special nuclear material (SSNM).

Safeguards Requirements.

NRC imposes safeguards requirements on its licensees in two ways.

First, specific requirements, spelled out in NRC rules and license conditions, detail those protection measures that NRC considers necessary for licensee safeguards. Among other actions, NRC rules require each licensee to submit safeguards plans and a contingency plan that describe the licensee's site-specific implementa-tion of protection measures.

Second, weaknesses that become evident in NRC's routine inspections performed by regional inspectors or NRC's special comprehensive evaluations are corrected by enforcement actions or modification of site specific license conditions.

Assessments of Safeguards Adequacy.

NRC assesses safeguards adequacy at fuel cycle facilities through inspections and comprehensive evaluations.

Safeguards inspections are conducted by NRC safeguards inspectors based in four of the five NRC Regional Offices.

These inspections focus on the licensee's compliance with NRC requirements and the licensee's implementation of safeguards plans.

In addition to performing compliance-type inspections, inspectors also evaluate the effectiveness of licensee-implemented safeguard systems for potential weaknesses not covered by regulations.

Comprehensive evaluations of fuel cycle facilities are conducted by special teams of headquarters staff and regional inspectors.

These evaluations are specifically intended to determine the capability of licensee safeguards to protect egainst the hypothetical design threat.

For each licensee, four separate evaluation te;ms look for external or internal weaknesses that would render a facil ty vulnerable to the i

hypothetical design threat (see Appendix B, pages B-7 to B-11).

After an initial assessment of a fuel cycle facility, follow on comprehensive evaluations may be conducted if a previous assessment is invalidated by a rule change, redefinition of the hypothetical design threat, detection of licensee weakness through an NRC inspection, or other similar circumstances.

3NRC would take an appropriate response to evidence of actual threats.

NRC would notify a licensee of low level threats.

Should it receive evidence of threats considered more serious, NRC could request assistance from the FBI, other federal agencies, and local law enforcement.

Licensees wculd be expected to institute such measures as deploying additional guard forces, curtailing operations, or locking all SSNM in secure vaults.

4The level of protection required for non power ceactor safeguards is currently under study.

20/2 524 The comprehensive evaluation is essentially a two step process.

During the on-site portion of the evaluation, each team determines whether the facility has any emergency safeguards deficiencies that would make the facility so vulnerable to the hypothetical threat that continued operation of the facility would be inimical to the common defense and security or pose undue risk to the public health and safety.

Such emergency safeguards deficiencies would be promptly reported by the teams to NRC management who would take immediate action to correct the deficiencies, employing whatever measures might be necessary.

Upon completion of the on-site assessments, members of the four teams and NRC management conduct a synthesis evaluation that considers the licensee's demonstrated capability to protect nuclear material, the state of safeguards system maintenance, and other safeguards-related factors.

The overall capability of the fuel cycle facility is then judged to provide high, good, fair, or poor assurance of protecting against the hypothetical design threat.

NRC recognizes that its evaluation of fuel cycle facility safeguards capabilities is somewhat imprecise and that licensee safeguards capabilities can change over time.

NRC's assessment that a facility provides a given level of protection against the hypothetical threat does not guarantee:

(1) that the actual level of protection is not somewhat better or worse than the assessment indicates, or (2) that the currently assessed level of protection will continue indefinitely.

Licensee safeguards that are judged to provide high assurance protection against the hypothetical 4 sign threat are considered to possess the desired level of safeguaros capability.

Licensee capabilities judged good or fair can provide adequate safeguards for a limited period, but do not provide the measure of safeguards capability that NRC deems prudent.

Therefore, NRC may make license modifications and will conduct special follow-up inspections to assure that these licensees attain high assurance protection against the hypothetical threat.

NRC maintains confidence in its assessments by requiring facilities to achieve high assurance protection; by inspecting and evaluating safeguards with sufficient frequency, breadth, and depth; and by bringing a variety of individual and organization judgments to bear in the evaluation of safeguards adequacy.

If a licensee's safeguards are judged inadequate (or if NRC inspec-tions identify particularly serious violations of safeguards requirements),

NRC will require immediate improvements to be made, if necessary, by major enforcement action against that licensee.

Major enforcement sanctions available to NRC include Civil Monetary Penalties and Orders.

Civil Monetary Penalties are currently limited to $5,000 per violation and $25,000 for all violations in a thirty-day period.S NRC can impose sNRC has submitted to Congress a proposal to increase penalty limits to $100,000 per violation and $300,000 for all violations in a thirty-day period.

20/2 525

_4_

Orders to modify, suspend, or revoke a license or to makt a licensee

" cease and desist" from certain actions.

Licensee safeguards judged poor are not considered adequate for continued plant operation.

In such cases, NRC would require that operations be stopped unless the observed deficiencies can be immediately corrected.

Licensee safeguards judged fair are considered adequate to permit continued operation only if the observed deficienci~es do not pose an undue risk to the public health and safety or common defense and security during the short term required for their correction.

NRC monitors safeguards adequacy of SSNM transportation activities through its licensing and inspection processes.

NRC regulatory responsi-bilities for transportation include all domestic shipments and the domestic segments of import and export shipments (includirg all storage and transfer points) for formula quantities of SSNM.

Shipments of government-owned SSNM using DOE couriers are a 00E responsibility and are not regulated by NRC.

Shipments are required to be made with an armed escort on primary roads during daylight hours, if possible.

If a trip is scheduled to extend into the night, a second escort vehicle with two adcitional guards is required.

Transfers of highly enriched uranium (HEU) from vehicle to storage, from one vehicle to another, or from storage to vehicle, as well as storage of HEU, must be protected by at least four guards.

The guards are equipped with communications to local police and at least three of them must keep the shipment under continucus surveillance.

All HEU air shipments of more than 350 grams must be made in aircraft dedicated to cargo.

Significant quantities of highly enriched uranium being transferred to or from such aircraft (including periods while in storage) must be protected by at least four guards equipped with a capability for radio communications to either a local law enforcement agency or an air terminal guarti force.

Many other specific requirements, such as requirements for vehicle markings, scheduled check calls which report shipment status 49 hours5.671296e-4 days <br />0.0136 hours <br />8.101852e-5 weeks <br />1.86445e-5 months <br /> of specialized security training with annual requalification for guards, and advance notification of shipments are contained in NRC regulations and license conditions.

NRC's contingency planning rule, which became effective in June 1978, equires that any licensee transporting highly enriched uranium develop and submit to NRC a contingency plan for responding to threats or attempted theft or sabotage which might occur while the shipment is in transit or at transfer points.

All required transportation contingency plans have been received by the NRC.

NRC inspectors monitor each shipment of formula quantities of SSNM during the entire period it is in transit.

Inspection activi.ies cover material control and accounting, physical protection, and health and 20/2 526

_s.

safety.

The inspection activity seeks to assure that the licensee is making the shipment in full compliance with NRC regulations, license conditions, and the NRC approved security plan.

Transportation activities that are conducted in the manner described above are judged to provide adequate public protection.

NRC assesses the adequacy of safeguards at reactors through its licensing review and inspection programs.

.is part of'Its licensing process, NRC examines the physica.1 security mesures p oposed by the licensee in terms of each reactor's vulnerability, inharent protective features, and NRC's regulations.

The bases for this evaluation are:

a)

The facility's security plan b)

An on-site evaluation of site-specific factors influencing safeguards adequacy c)

An analysis of design and operation details from the Final Facility Description and Safety Analysis Report (FSAR).6 This evaluation is performed by a team of licensing staff and regional inspectors.

NRC provides the conclusions of the overall licensing evaluation for each reactor site in a Security Plan Evaluation Report (SPER), the safeguards plan approval document.

A new rule specifying the hypothetical desi earlier) is scheduled to be implemented in 1979.gn threat (discussed At that time, safeguards for power reactors will be judged adequate if they protect against the hypothetical design threat with high assurance.

NRC will approve a reactor operating license when the licensee's security plan contains protective measures that NRC believes will provide this high assurance protection.

NRC inspections at reactors verify the implementation of the safe-guards provisions specified in the regulations, the facility security 6A discussion of facility design features influencing safeguards adequacy is given in Appendix B.

7As of the end of fiscal year 1978, NRC had scheduled a February 23, 1979 implementation of a new rule (10 CFR 73.55) that would require power reactor licensees to protect against the hypothetical design threat.

However, as of late January 1979, the Commission was considering a staff recommendation that would delay the implementation of certain parts of the rule (concerned with measures for protection against the " insider" threat) until May 23, 1979.

The specific measures recommended to be deferred are " pat down" searches, compartmentaliza-tion, and the "two-man" rule.

This delay would provide the Commission time to consider Hearing Board recommendations on the material access authorization program and its implications on these insider threat measures.

The staff believes that delay of these measures for this short period of time will not cause urwarranted safeguards risk.

However, the matter has not been reviewed by the Commission. 2072 427

plan, and the SPER.

If an inspection identifies items of noncompliance, NRC imposes appropriate enforcement sanctions.

Inspections also assess the adequacy of the licensee safeguards.

NRC takes prompt action to correct inadequacies identified in these assessments--either through the enforcement process or (if the inadequacies do not involve noncompliance with NRC requirements) through changes in the licensee's security plan.

The severity of reactor licensee noncompliance dictates the enforcement action taken.

Noncompliances that do not have a substantial potential for harming public health and safety and/or are readily correctable typically form the basis for lower enforcement sanctions, such as letter Notices of Violation.

For those that are more serious, more numerous, deliberate, persistent, or not compensated (by redundant safeguards or inherent pro-tective features of the reactor design), NRC will consider higher sanctions such as Civil Monetary Penalties and Orders (as described previously).

All nuclear power plants in the U.S., with one exception,8 are light water reactors that use low enriched fuel.

Safeguards at these power reactors are designed to protect against radiological sabotage, but do not address theft, because low enriched uranium fuel is not suitable for the manufacture of nuclear explosive devices.

For non power reactors, present regulations require licensees to provide a security program and plan.

In lieu of establishing a hypothetical design threat for all non power reactor licensees, NRC establishes a required level of safeguards protection for each non power reactor commensurate with the safeguards risk posed by that reactor.

Facilities possessing more than formula quantities of SSNM represent a potential theft risk; those operating at relatively high power levels (above 100 Kw) for extended periods of time represent a potential sabotage risk.

However, few non power reactors fall into either of these two risk categories.

For most non power reactors, there is only a small risk of either theft or sabotage.

(NRC is currently re-evaluating the safeguards risk of non power reactors, as discussed on page 12 below).

A more detailed discussion of factors associated with NRC's assess-ment of safeguards adequacy is provided in Appendix B.

Safeguards Adequacy in FY 1978 Fuel Cycle Facilities and Transportation Activities.

In May 1977, NRC initiated a safeguards comprenansive evaluation program expressly designed to assess the adequacy of safeguards at fuel cycle facilities.

As part of this program NRC scheduled visits to 11 fuel cycle facilities.9 8NRC licenses a single high temperature gas-cooled reactor (HTGR).

This reactor uses fuel consisting of a mixture of thorium and highly enriched uranium.

Additionci safeguards measures are employed at this facility to protect against the theft of unirradiated fuel.

90nly 11 of the 19 fuel cycle facilities authorized to possess SSNM and currently operating possess formula quantities in an unitradiated form. 20/2 528

During fiscal year 1977, NRC conducted on-site evaluations at four fuel cycle facilities.

In fiscal year 1978, NRC conducted on-site assessments at five additional fuel cycle facilities.

The results of three of the evaluations conducted during fiscal 1977 have been forwarded to the Congress in detailed classified reports.

Reports on the other facility evaluations are in preparation and will be submitted to the Congress as they are completed.

A summary of completed evaluation results and a schedule of remaining evaluations are contained in classified Appendix G.

Of the four facilities evaluated during fiscal year 1977, none had e"iergency safeguards deficiencies.

One of these facilities provided high assurance protection against both the hypothetical threats of a single insider and a violent assault.

A second facility provided high assurance protection against the hypothetical insider threat and fair to good assurance protection against the hypothetical violent assault threat.

A third facility provided good assurance protection against the hypothetical insider threat and fair to good assurance protection against the hypothetical violent assault threat.

The fourth facility provided fair assurance protection against the hypothetical insider threat and good assurance protection against the hypothetical violent assault threat.

Subsequent improvements have been made at the second and third facilities to upgrace their capabilities against each threat to high assurance.

The fourth facility has ceased strategic special nuclear material production operations and is undergoing a cleanout and recovery operation.

Implementation of the new requirements at the second facility has been verified by a follow-up special inspection.10 A special inspection of the third facility is scheduled for early February 1979, when all of the licensee corrective actions are scheduled to be implemented.

NRC considers the safeguards adequate for the limited period required for these facilities to make corrections and achieve high assurance protection.

Since the synthesis evaluation process has not yet been completed for the five facilities whose on-site assessments were completed during fiscal year 1978, NRC cannot provide ratings for them at this time.

However, NRC did not observe emergency safeguards deficiencies at any of these facilities.

Therefore the evaluation reports are expected to judge safeguards at these five sites to be adequate.it NRC will require toA more recent special safeguards review at the second facility raised questions as to whether the existing safeguards program still provided high assurance.

Although safeguards at this facility are still considered adequate, further upgrades of safeguards at this facility are under consideration.

11 Comprehensive evaluations for the remaining two (of the eleven) fuel cycle facilities will be completed in early fiscal year 1979.

Preliminary evaluation results have not revealed any emergency safe-guards deficiencies.

20/2 529 these licensees to make any improvements necessary to achieve high assurance capabilities against the hypothetical threat which provides the extra measure of safeguards capability that NRC deems prudent.

NRC will verify implementation of these requirements through follow-up special inspections and NRC will forward both the safeguards comprehensive evaluation reports and the special inspection reports to the Congress.

NRC inspection and enforcement activities at fuel cycle facilities during fiscal year 1978 included more than 13,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of on-site safeguards inspections at the 14 fuel cycle facilities of primary interest.12 These inspections revealed 137 items of noncompliance with safeguards requirements.

(See Table 1 for more detail on inspection activities at fuel cycle facilities.) NRC did not impose major enforcement sanctions (i.e., Civil Penalties or Orders) on any of the 14 fuel cycle facilities in fiscal year 1978.

However, several plants were required to shut down for reinventory and NRC sent several Immediate Action Letters identifying additional measures to be taken by the licensees in both material control and accounting and physical protection.

Based on inspection results, NRC has judged that all licensees have responded satis #actorily to identified items of safeguards noncompliance.

However, one c.ae involving possible falsification of guard training records at a fuel facility is currently under investigation.

During fiscal year 1978, inventory differences exceeding regulatory limits were experienced at three fuel cycle facilities.13 NRC examines inventory differences which exceed specific thresholds to try to determine the cause.

During fiscal year 1978, NRC examined inventory differences (which in some instances were associated with reinventory and plant shutdown) in conjunction with material control and physical security measures.

Based on these examinations, NRC did not identify any factual indication (other than the inventory difierences, which are of themselves inconclusive) that SSNM had been stolen or diverted in fiscal year 1978.

In the area of transportation activities, eight shipments of formula quantities of licensed SSNM were made during fiscal year 1978.

All of them were inspected.

NRC detected no items of noncompliance, and all shipments were conducted without significant safeguards incident.

In September 1975, New York City passed a health ordinance virtually banning transportation of radioactive materials through the city.

Similarly, in Chicago there has been a de facto suspension of air shipments of highly enriched uranium chrough O' Hate' airport since December 1977 as a result of concerns expressed by the Major of Chicago on this matter.

12There are 14 fuel cycle facilities authorized to possess formula quantities of unirradiated SSNM in an unsealed configuratic1.

Starting in the fourth quarter of FY 1978 resident inspectors were de,sloyed to fuel cycle facilities at Babcock & Wilcox Co., Apollo and Leechburg, PA and Nuclear Fuci Services, Inc., Erwin, TN.

13NFS Erwin, B&W Apollo, and General Atomic.

2072 530 TABLE 1

SUMMARY

OF SAFEGUARDS INSPECTIONS FOR FISCAL YEAR 1978* AT FUEL CYCLE FACILITIES Number of Number of Number of Percent of Strategic Fuel Facilities Safeguards Manhours of Items of Unannounced Inspections Inspection Onsite Noncompliance Inspections 1.

Babcock & Wilcox, Apollo, Pa.

25(2/23)**

1775(41/1734)**

17(0/17)**

52%

2.

Babcock & Wilcox, Leechburg, Pa.

21(5/16) 1264(158/1046) 10(1/9) 48%

3.

Babcock & Wilcox, LRC, Lynchburg, Va.***

4(2/2) 46(23/23) 1(0/1) 100%

4.

Babcock & Wilcox, NNFD, Lynchburg, Va.

14(5/9) 1177(673/504) 14(11/3) 93%

5.

Exxon Nuclear, Richland, Wa.***

5(2/3) 258(32/226) 0(0/0) 80%

6.

General Atomic, San Diego, Ca.

8(2/6) 825(112/713) 15(6/9) 80%

7.

General Electric, Vallecitos, Ca.

7(4/3) 457(175/282) 12(11/1) 100%

8.

Kerr McGee Nuclear, Crescent, Ok.***4(1/3) 62(42/20) 3(3/0) 100%

9.

Nuclear Fuel Services, Erwin, Tn.

18(5/13) 3987(202/3785) 25(12/13) 33%

10.

Rockwell International, Canoga Park, Ca.

5(2/3) 377(105/272) 10(9/1) 100%

11.

Texas Instruments, North Attleboro, Ma.

10(4/6) 462(101/361) 6(5/1) 80%

12.

United Nuclear, Montville, Cn.

15(1/14) 1037(69/968) 15(6/9) 60%

13.

United Nuclear, Wood River a

cr>

Junction, RI.

17(4/13) 762(153/609) 6(0/6) 59%

'-4 14.

Westinghouse, PFDL, Cheswick, Pa.

14(2/12) 580(90/490) 3(3/0) 43%

N TOTAL 167(41/126) 13,009(1,976/11,033) 137(67/70) 63%

w

~^

^

The summary includes inspections conducted September 1977 through October 1978.

• • For numbers in parentheses, the first number refers to physical security inspection activities, and the second number refers to material control and accounting inspection activities.

• • • These facilities are either not operating or not holding formula quantities in unirradiated form.

In April 1978, the Department of Transportation (00T) rulca that the New York City effective ban on radioactive materials shipment was not preempted by Federal regulation under the Hazardous Materials Transportation Act.

Since the ruling, severa ctates and communities have instituted requirements for permits or aosance notice of shipments.

In its " Final Environmental Statement on the Transportation of Radioactive Material by Air and Other Modes," NUREG-0170, published in December 1977, the NRC staff concluded that the risks were so low that all shipments by all modes could continue under this present regulatory system.

However, the NRC is now extending this work to look more

-losely at transportation of radioactive materials through urban environments.

In addition, NRC has referred to the Executive Branch for analysis the alternative of using military airfields for HEU shipments.

Power and Non power Reactors.

In 1977, NRC published new safeguards regulations for power reactors that include hypothetical design threat requirements.

As required by these regulations (10 CFR Part 73.55),

operating power reactor licensees submitted amended security plans detailing the physical security improvements that they proposed to meet the new requiremNts.

NRC formed eight teams to review and evaluate these security pians for 70 reactors at 55 sites.

Phase I of the review effort consisted of a review of the amended security plans, an onsite evaluation, and one or more meetings with the licensees to discuss any deficiencies of the plan.

This phase was completed in 1977.

The second phase of this review process involves the resolution of outstanding sacurity plan issues and the development of Security Plan Evaluation Reports (SPERs) for each site; this phase was initiated in 1978.

The third phase, inspecting the implementation of Part 73.55, will follow in 1979.

These efforts are discussed further in Appendir. B of this report.

As of the end of fiscal year 1978, NRC had completed the initial review and onsite evaluations of all operating power reactors (Phase I).

By January 1, 1979, about half of the SPERs had been drafted and had been either completed or were under review; the remainder are scheduled to be completed early in 1979.

NRC expec+.s that most (about 75%)

licensees with operating power reactors will have implemented the physical security improvement portion of Part 73.55 by February 23, 1979.

For the remaining licensees, conctruction and installation schedules will extend beyond this deadline, and NRC will require that compensatory measures be in effect by February 23, 1979 to provide a level of physical security equivalent to the permanent measures planned by the licensee.

With these interim measures, NRC expects that all operating power reactors will be capable of providing high assurance protection against the hypothetical external assault threat by February 23, 1979.

In fiscal year 1978, prior to implementation of Part 73.55, power reactor licensees were not required to protect against a specific hypothetical design threat, and NRC inspections did not assess licensee capabilities against such a threat.

Therefore, NRC did not evaluate the adequacy of power reactor safeguards in terms of providing 2072 532 protection against particular threats.

However, al' power reactor licensees were in substantial compliance with existing require-ments during fiscal year 1978 and all licensees were responsive in correcting identified items of noncompliance.

By these standards, NRC judges the fiscal year 1978 power reactor safeguards adequate.

In addition, parts of the new rule (relating to physical security organization, access, communication, testing and maintenance, and response) were fully implemented by all operating power reactor licensees during fiscal year 1978.

In fiscal year 1978, 71 non power reactors held operating licenses.

As discussed above, the adequacy of safeguards at non power reactors is evaluated on a case-by case basis.

Safeguards requirements for each non power reactor are commensurate with the safeguards risk arising from its operation.

Different requirements are established for reactors possessing Category I, Category II and Category III material, Table 2 shows the numbers of non power reactors using each of these materials.

TABLE 2 NON-POWER REACTORS CATEGORY 14 I

II III OTHER TOTALS Test Reactors 1

1 0

0 2

Critical Experiments 1

1 0

0 2

Research Reactors 1

32 24 10 67 TOTALS 3

34 24 10 71 In fiscal year 1978, NRC continued its evaluation of non power reactor safeguard risk arising from potential theft and sabotage.

Preliminary results of this evaluation indicate that:

1)

The potential for endangering the health and safety of the public by a release of radioactivity due to sabotage of a non pow facility exists only at a small number of reactors which can be operated at relatively high power levels.

NRC is continuing to investigate the level of risk in actual operating conditions.

2)

Only three licensees actually possess an inventory of unirradiated strategic special nuclear material (SSNM) in excess of a formula quantity, and these facilities have implemented the protective measures against theft specified in their approved security plans.

14 Categories I, II, and III.

See Glossary (Appendix F).

"Other" refers to those reactors covered for physical protection by 10 CFR 73.40. 2072 533

3)

Physical protection measurec at licensed non power reactors are needed to prevent theft of special nuclear material that is not self protecting and is present in quantities and enrichments less than those presently covered by Part 73.

The safeguards theft risk for these reactor; is small because multiple thef ts at several facilities would be needed to obtain a formula quantity of SSNM.

Nonetheless, NRC is considering additional regulations to improve the physical protection measures at these facilities.

NRC also recognizes a need for compatibility between US and international physical security guidelines.

The new non power reactor regulations and associated guidance to licensees, if approved, will provide a standard of adequacy compatible with international guidelines.

NRC inspection and enforcement activities at reactors also provided a means of judging the effectiveness of safeguards.

During fiscal year 1978, N.1C expended nearly 6500 hours0.0752 days <br />1.806 hours <br />0.0107 weeks <br />0.00247 months <br /> in on-site safeguards inspections at power reactors and 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> at non power reactors.15 These inspections revealed 468 items of noncompliance with safeguards require-ments.

(See Table 3 for more detail on inspection activities at reactors.) NRC has issued a number of Immediate Action Letters that identified measures to be taker by the licensees

'.o improve their safeguards systems, but no safeguards events warranted major enforcement actions (Orders or Civil Penalties) against reacto' licensees during the year.

Recent physical protection inspections and invi stigations of allegations have disc:osed evidence of improper guard training records and possible falsification of training records.

Licensee management audits of guard training have also been found, in some cases, to be either nonexistent or seve?ely deficient.

In IE Circular 78-17,

" Inadequate Guard Training / Qualification and Falsified Training Records,"

NRC informed all licenses of these situations and advised that NRC would be evaluating each licensee's program for guaro qualification and training.

NRC will take necessary corrective actions.

Safeguards Research and Technical Assistance The NRC safeguards program includes both research (long term, comprehensive efforts) and technical assistance (short term efforts in support of operational assignments).

In fiscal year 1978, about

$10 million was spent on safeguards research and technical assistance, divided about equally between these two categories.

During this period, the major efforts of the safeguards research program were directed to development of methods for evaluation of safeguards effectiveness.

Technical assistance was provided to major program offices to support their current safeguards 158y the end of fiscal year 1978, about 20 resident inspectors were deployed at power reactor sites.

A portion of each resident inspector's time is spent inspecting safeguards. 2072 534

TABLE 3

SUMMARY

OF SAFEGUARDS INSPECTIONS FOR FISCAL YEAR 1978* AT REACTORS Facility Number of Safeguards Number of Manhours Number of Items Percent of Inspections of Inspection Onsite of Noncompliance Unannounced Inspections Power Reactors 219(167/52)**

6470(5400/1070)**

4?8(405/23)**

90%

Non power Reactors 96(56/40) 1201(701/500) 40(33/7) 95%

I Tne summary includes inspections conducted September 1977 through October 1978.

For numbers in parentheses, the first number refers to physical security inspection activities, and the second number refers to material control and accounting inspection activities.

rs; CD w

N bw

activities projects ranged from aiding in the development of NRC's physical security upgrade rule to making improvements in nuclear measurement standardt A more detailed description of NRC's Research and Technical Assistance programs is provided in Appendix C.

Further discussion of NRC safeguards research activities may be found in NRC's 1978 Annual Report, Chapter 11.

Future Safeguards Programs To improve the safeguards protection at facilities and activities under the regulatory authority of HRC, the staff is currently undertaking additional safeguards projects.

Tnese projects are summarized below:

A new guard training upgrade rule (for fuel cycle facilities, transportation activities, and power reactors) became effective in early fiscal year 1979, and implementation, which will take two years, is underway.

This rule provides for an upgrade of qualification, training, and equipment requirements for security personnel at fuel cycle and power reactor facilities and for escort guards who accompany domestic shipments of strategic quantities of SSNM.

The NRC staff has proposed a physical security upgrade rule for fuel cycle facilities that would increase the required level of protection against theft of SSNM by increasing the postulated threat (including emphasis oa internal conspiracies).16 This proposed rule would also require increased protection for SSNM shipments and certain non power reactors.

This rule is currently scheduled to become effective in fiscal year 1979.

The results of hearings on a proposed Material Access Authorization Program requirement will be studied during FY 1979 to help NRC decide whether such an effort would enhance safeguards protectior, in a cost effective manner.

As stated earlier, NRC is currently considering the development of a new rule for non power reactor safeguards.

This rule would cover non power reactors not included in the fuel c,'le facility upgrade rule mentioned above.

The NRC has also developed a proposed rule, tc be implemented in fiscal year 1979, that would specify physical protection mea 3ures for facilities possessing less than formula quai;tities of highly enriched uranium and plutcnium or certain specific quantities of low-enriched uranium.

These materials are of moderate or low 16 Threat studies conducted by NRC have generally supported the judgment that it would be prudent to adopt a higher threat level for fuei cycle facilities.

A major classified study of the characteristics and capabilities of terrorists and other criminals was submitted to the Commission in September 1978.

An unclassified version of this report should be available in fiscal year 1979. 2072 536

safeguards significance, and the increased protection conforms with international guidelines.

The staff is also evaluating recommendations of an internal Task Force studying the role of material control ar.d accounting in NRC's safeguards program.

A material control and accounting development plan has been prepared to analyze recommendations and alternatives and to implement improvements judged to be cost-effective.

Those improvements involving state-of-the-art te:.hnology will be included in a proposed rule scheduled for public comment in fiscal year 1980.

Those recommendations requiring further research and development are to be considered for later implementation.

A more detailed discussion of NRC's future safeguards programs and their status is provided in Appendix 0.

Organization and Management of Safeguards Each of the major program offices has a role in the planning and implementing of NRC's domestic safeguards program.

Inter-office coordina-tion of tne NRC contracted safeguards activities is provided by the Safeguards Technical Assistance and Research Coordinating Group (STAR),

with participation by the major program offices.

An Integrated Safeguards Program Plan is currently under development to aid in the coordination of the various NRC safeguards activities.

The entire NRC safeguards program is reviewed and approved annually by the Budget Review Group, the Executive Director for Operations, and the Commission during the NRC budget review process.

More detailed descriptions of the safeguards responsibilities of individual NRC program offices and of the Safeguards Integrated Program Plan are provided in Appendix E.

20/2 537 APPENDIX A SCOPE OF NRC SAFEGUARDS ACTIVITIES A.

NRC Responsibilities in Safegeards 1.

Legislative Assignments of Responsibility The origins of NRC safeguards responsibilities can be traced to the Atomic Energy Act of 1954.

These responsibilities were augmented in the Energy Reorganization Act of 1974, which assigned safeguards responsibility for licensed activities tu the NRC.

The Atomic Energy Act of 1954, in Section 2(d), mandates the regulation of processing and utilization of source, byproduct and special nuclear material (SNM) in the national interest in order to (1) " provide for tne common defense and security" and (2) " protect the public health and safety." To implement these policies, Section 3(c) of the Act provides for "a program for Government control of the possession, use and production of atomic energy and special nuclear material so directed as to make the maximum contribution to the common defense and security and to the national welfare..."

Finally, the Act recognizes the poten-tially serious consequences of SNM loss or diversion, for it requires the Commission (Section 161i) to " prescribe such regulations... it may deem necessary... to guard against the loss or diversion of any special nuclear material..." and "to govern any activity authorized pursuant to this Act... to protect health and to minimize danger to life and property."

Substantially increased attention to the area of domestic nuclear safeguards was mandated by the Energy Reorganization Act of 1974 (ERA), which created the Nuclear Regulatory Commission.

The ERA created the Office of Nuclear Material Safety and Safeguards (NMSS) and charged it with licensing and regulating all facilities and materials associated with processing, transport and handling of nuclear material, including (Sec. 204(b)(1)) "the provision and maintenance of safeguards against threats, thefts, and sabotage of such licensed facilities and materials." The ERA also mandated (Sec. 204(b)(2)) reviews of safeguards by NRC to include:

"(A) monitoring, testing and recommenaing upgrading of internal accounting systems for special nuclear material and other nuclear material licensed under the Atomic Energy Act of 1954, as amended; (B) developing... contingency plans for dealing with threats, thefts, and sabotage relating to special nuclear material, high-level radioactive wastes, and nuclear facilities resulting from all activities licensed under the Atomic Energy Act of 1954, as amended; 2072 538 A-1

(C) assessing the need for, and the feasibility of, establishing a security agency within the office for the performance of the safeguards functions,... a report with recommendations on this matter shall be prepared within one year of the effective date of this Act and promptly transmitted to the Congress by the Commission."

The ERA also established an Office of Nuclear Reactor Regulation (NRR), assigning it responsibility for licensing and regulation of nuclear reactors and requiring the Director of NRR (Sec. 203(b)(2)) to

" review the safety and safeguards of all such facilities...", and the Office of Nuclear Regulatory Research (RES) to develop recommendations for research and to engage in or contract for research.

2.

The NRC Safeguards Mission In 1976, the NRC formally adopted the following statement:

" Safeguards measures are designed to deter, prevent, or respond to (1) the unauthorized possession or use of significant quantities of nuclear material through theft or diversion; ar.d (2) sabotage of nuclear facilities.

The safeguards program has as its mission achieving a level of protection against such acts to insure against significant increase in the overall risk of death, injury, or property damage to the public from other causes beyond the control of the individual."

The following guidelines were established in 1976 to define the adequacy, effectiveness, and acceptability cf safeguards.

First, to be effective, safeguards must be capable of:

"... preventing, with high confidence, a civil disaster; providing substantial protection against serious civil damage; and providing timely and accurate information on the status of nuclear material and facilities."

Second, to be acceptable, safeguards must

"...take realistic account of the risks involved, and of burdens on the public, in terms of civil liberties, institutional, economic, and environmental impacts."

8.

Affected Facilities and Activities The Nuclear Regulatory Commission domestic safeguards program is applied to all licensed nuclear facilities and activities authorized to receive title to, own, acquire, deliver, receive, possess, use, transfer, import and export special nuclear material.

Import and export activities are generally considered within the realm of international safeguards and will be discussed here only to the extent necessary to fully describe the facilities and activities subject to domestic safeguards.

2072 339 A-2

The NRC currently has safeguards regulatory control over 19 fuel cycle facilities which are authorized to possess significant quantities of highly enriched uranium or plutonium,1 transportation activities involving highly enriched uranium or plutonium (about one shipment per month), 70 operating commercial power reactors, and 71 non power reactors.

The safeguards requirements for licensed facilities and activities are tailored to the quantities of special nuclear materials (SNM) authorized for possession or actually possessed.

Those facilities authorized to possess and use more than one effective kilogram2 of SNM are subject to detailed requirements for the material control and accounting of all material received, shipped, discarded, or in inventory.

These facilities include fuel conversion and fabrication plants, those engaged in special service (e.g., production of isotopes for medical purposes), power reactors, test reactors and research reactors.

Physical protection is required if the licensee possesses formula quantities of strategic special nuclear material (SSNM)--that is, uranium-235 (contained in uranium enriched to 20 percent or more in the U-235 isotope), uranium-233, or plutonium alone or in any combina-tion in a quantity of 5000 grams or more computed by the formula, grams =

(grams contained U-235) + 2.5 (grams U-233 + grams plutonium).

Physical protection of the facility and niaterial is also required in the operation of a nuclear power reactor, and attendant activities.

These physical protection measures are intended to prevent the thef t of highly enriched uranium, uranium-233 or plutonium which could be used to make a nuclear bomb, and the sabotage of the licensed facilities which would significantly increase the risk to the public of radioactive release.

Formula quantitiesa of strategic special nuclear material must also be safeguarded while in transit.

Transportation of SSNM takes place between different licensees, between licensees and Department of Erergy (D0E) facilities and between licensed cr government facilities and a terminus for export or import shipments under NRC license.

Such IFour additional fuel cycle facilities possess more than one effective kilogram of low-enriched uranium.

Those fuel cycle facilities involved in processing highly enriched uranium for the manufacture of fuel for the Naval Propulsion Program possess nearly all of the highly-enriched uranium at fuel cycle facilities.

2 Effective kilograms of SNM means:

(1) for plutonium and uranium-233 their weight in kilograms; (2) for uranium with an enrichment in the isotope U-235 of 0.01 and above, its element weight in kilograms multiplied by the square of its enrichment expressed as a decimal weight fraction; ar.d (3) for uranium with an enrichment in the isotope U-235 below 0.01 by its element weight in kilograms multiplied by 0.0001.

3Sce Glossary, Appendix F.

20/2 540 A-3

material is measured and packaged, transfer documents are prepared, and after the required physical protection arrangements are made, the material is shipped to the recipient.

00E provides for physical protection of all DOE-owned shipments of formula quantities of SSNM.

Licensed ship-ments are protected under NRC safeguards requirements.

2072 541 A-4

APPENDIX B FACTORS ASSOCIATED WITH NRC'S ASSESSMENT OF SAFEGUARDS ADEQUACY A.

Threat Considerations Information available to the NRC does not indicate the existence of a significant near-term threat of theft or diversion involving strategic special nuclear material, or sabotage.

The NRC itself does not engage in intelligence gathering or collection.

To ensure the timely flow of data necessary to assess an actual or potential threat to the domest;c nuclear industry, the NRC relies upon the existing efforts within the Intelligence Community to collect and report back information.

Over the past three years, the NRC has actively pursued the development of interfaces with 82 organizational elements of over 28 agencies that could provide response support and threat information.

Formal and informal interface anreements have been established and frequent contact is maintained with the Intelligence Community to obtain threat informati These agencies provide NRC:

(1) reports dealing with threats to nuclear facilities and (2) collateral information of an analogous nature such as adversary characteristics, previous acts of violence, bombing incidents and other data useful to threat assessment. Means of communication include secure telephone, teletype, routine distribution channels, and regular informal meetings.

The NRC plans to develop and negotiate a series of formal safe-guards interagency agreements with thirteen key agencies.

A draft agreement with the Federal Bureau of Investigation is currently in negotiation.

These formal agreements would be in addition to functional working arrangements already in existence, such as with the National Foreign Intelligence Board and the National Foreign Intelligence Assessment Center that provide guidance to the Community for use in assuring appropriate and timely dissemination of information relevant to NRC's mission.

The NRC is also a member of the NSC/ SCC interagency working group on terrorism.

The current threat characterization for industrial sabotage against nuclear power reactors, contained in 10 CFR Part 73.55, is as follows:

(1) A determined violent external assault, attack by stealth, or deceptive actions, of several persons with the following attributes, assistance and equipment:

(a) well-trained (including military training and skills) and dedicated individuals, (b) inside assistance which may include a knowledgeable individual who attempts to participate in both a passive role (e.g., provide information) and in an active role (e.g.,

facilitate entrance and exit, disable alarms and communications, participate in violent attack), (c) suitable weapons, up to and including hand-held automatic weapons, equipped with silencers and having effective long range accuracy, and (d) hand-carried equipment, including incapacitating B-1 20/2 542

agents and explosives for use as tools of entry or otherwise destroying the reactor integrity, and (2) An internal threat of an insider, including an employee (in any position).

The threat characterization presently used in the determination of adequacy of nuclear fuel cycle facilities and transportation activities is the same as the one for power reactors specified above except that the equipment the adversary may employ would be used to destroy " features of the safeguaro:, system," rather than "the reactor integrity.nl NRC has not established a hypothetical design threat for non power reactors.

The level of protection required for these facilities is currently under study.

B.

Current Regulatory Requirements

===1.

Background===

Many current safeguards regulatory requirements were imposed some time before the current hypothetical design threat level was postu-lated.

In the years 1969-1974, the Atomic Energy Commission developed physical security and material control regulations that were set forth in the Code of Federal Regulations, 10 CFR Parts 70 and 73.

In 1975, NRC assumed responsibility for application and administration of these regulations.

Part 70 specifies the regulations for the domestic licensing, accounting, and controlling of special nuclear material (SNM).

In 1977, Part 73.55 was issued; this regulation added a substantial number of new safeguards requirements for the operation of nuclear reactors and charac-terized for the first time in NRC regulations the hypothetical design threat. These requirements are to be fully implemented in 1979.

Additional proposed changes to Part 73 would upgrade safeguards requirements and would increase the hypothetical design threat for SSNM.

2.

Physical Protection, 10 CFR 50, 70, and 73 The physical security requirements for fixed sites and materials in transit are addressed in Parts 50, 70, and 73 of Title 10 of the Code of Federal Regulations.

Under these regulations, all licensed production facilities, power and non power reactors, and carriers that transport formula quantities of SSNM are required to submit, for NRC review and approval, a plan describing the physical security measures proposed to protect the facility, material, or shipment.

Specific requirements for fixed sites licensed to possess or use formula quantities of SSNM include the following:

(a) A physical security organization including armed guards.

IComprehensive Evaluation Plan (for fuel cycle facilities with SSNM)

NRC, NMSS, May 1, 1977.

2072 543 B-2

(b) Physical barriers such that vital equipment and SSNM are protected by two security barriers.

(c) Access restrictions to control the movement of personnel, vehicles, and materials.

(d) Detection aids, including alarms which must annunciate in central and secondary alarm station manned and operated by the facility security force.

(e) A requirement for testing and maintenance of all security related equipment.

(f) A response requirement by facility guards and, as provided by prior liaison, by the Local Law Enforcement Agencies (LLEAs)

Section 73.55 describes similar requirements for power reactors.

A performance requirement is also included that specifies the hypothetical design threat (as described in Section A above), to be used in the evaluation of the effectiveness of safeguards for power reactors.

3.

Material Control and Accouating 10 CFR Part 70 The current material control and accounting system for nuclear materials, as required by 10 CFR Part 70, was designed to:

(a) provide knowledge of the identity, quantity, and location, based upon actual measurements, of material present at a fixed site and in transit; (b) detect the loss of material from discrete items, containers, or process-ing operations; and (c) provide checks and balances for physical security measures.

Each applicant for a license (to possess or use SNM in a quantity exceeding one effective kilogram in unsealed form) is required to submit for NRC approval a description (plan) of his material control and accounting system in sufficient detail to show that the system fulfills the requirements of 10 CFR Part 70.

For licensees authorized to possess more than one effective kilogram of special nuclear material, the rule provides specific requirements for:

(a) A management system to implement the licensee's material control and accounting plan.

(b) Written policies, instructions, procedures, and other documenta-tion necessary for the implementation of the material control and an accounting plan.

(c) Audits to assure compliance with procedures.

20/2 544 B-3

(d) An SNM measurement and record system.

(e) Periodic physical inventories.

(f) Evaluations of inventory and shipper / receiver differences.

(g) A measurement quality control program.

(h) Audits to ensure that the program is functioning effectively.

C.

Licensing Review NRC performs licensing reviews (on-site in many cases) to evaluate licensee safeguards plans covering physical security and material control and accounting.

The approval of apprcpriate accountability and protection plans is a prerequisite for the issuance of a license for the manufacture, possession, and use of special nuclear material.

1.

Fuel Cycle Facilities and Transportation During 1978, the staff reviewed requirements for measurement control program plans.

The required plans will specify measurement systems for mass and volume determination, sampling errors, and analytical errors.

Licensee plans for the material control and accounting and physical protection of SNM at fixed facilities and of SSNM in transit are submitted for review and approval in support of license applications.

NRC reviews these plans to determine whether they conform with regulations.

Also, NRC has published additional guidance to licensees in the form of NUREG reports.

Certain additional conditions have been imposed in 1978 as a result of the findings of the comprehensive evaluation review teams (discussed in Section D, below).

2.

Reactqrs Parts 50, 70 and 73 of Title 10 of the Code of Federal Regula-tions require the submittal of a security plan for each power reactor.

As discussed above, the requirements for power reactors (10 CFR Part 73) have recently been upgraded, and a performance criterion for protection against the hypothetical design threat has been incorporated in 10 CFR 73.55.

In addition to regulations, NRC has published additional guidance to licensees in the form of NUREG reports providing details of the " Standard Format and Content" of power reactor security plans, and the " Acceptance Criteria" to be used by the staff as an aid in determining the adequacy of these plans.

20/2 345 B-4

As required by the revised 10 CFR Part 73, all operating power reactor licensees had submitted amended security plans in May of 1977.

NRR formed eight review teams to review and evaluate these security plans for 70 reactors at 55 sites.

Phase I of the review effort (consist-ing of a review of the plan, an on-site evaluation, and o e or more meetings with the licensees to discuss any deficiencies of the plan) was completed in 1977.

The second phase of the review process (involving the resolution of outstanding security plan issues) was initiated in 1978, and is currently nearing completion.

The third phase (inspecting the implementation of Part 73.55) will follow.

D.

Comprehensive Evaluation Program for Fuel Cycle Facilities In April of 1977, the Commission directed the Office of Nuclear Material Safety and Safeguards and the Office of Inspection and Enforce-ment to conduct a comprehensive program of safeguards evaluations at fuel cycle facilities.

The actual safeguarcs evaluations began during May 1977 and have continued throughout 1977 and 1978.

The primary purpose oi the safeguards comprehensive evaluation program has been to assess J'e fuel cycle facility licensees' capability to protect against the hypottetical design threat identified earlier.

A secondary purpose of the evaluation program was to provide to the Commission a preliminary estimate of the licensees' capability to meet more demanding safeguards requirements under consideration by the Commission.

The comprehensive evaluation process employs four separate NRC teams.

Each team visits the facility to examine a different facet of its overall safeguards system.

Team findings are then synthesized and documented in a single report evaluating the adequacy of the facility's safeguards program.

The four teams are:

1.

Divercian Path Survey The purpose of the Diversion Path Survey portion of the compre-hensive evaluation program is to determine where in the production process there are points that might be vulnerable to internal diversion of SSNM.

To make this evaluation, the team examines the processing operations of the facility to identify locations where special nuclear materials are accessible, to determine their form at these points, and to determine whether any diversion paths exist that would allow removal of SSNM from the facility.

The evaluation considers all process locatiuns where nuclear material is accessible, but emphasizes those paths vulnerable to a single facility employee in any position or a single authorized visitor.

2.

External Assault Survey The purpose of the external assault survey is to obtain an external adversary-oriented view of the facility.

The individuals involved in conducting this portion of the evaluations have extensive B-5 2072 346

experience in covert military operations.

The survey places particular emphasis upon finding possible safeguards vulnerabilities that a potential adversary might exploit for theft or sabotage.

The survey identifies facility safeguards vulnerabilities through the use of remote observa-tion and close surveillance of the site and monitoring facility guard force and local law enforcement radio communications.

Later in the evaluation, survey team members are escorted through the facility to obtain a first hand view of the safeguards system from an insider's perspective.

Actual plans for theft of SSNM or radiological sabo+.ge may be developed by the team to illustrate identified vulnerabil es and to evaluate their usefulness to a potential adversary.

3.

Physical Security Assessment This portion of the assessment process is designed to determine those capabilities which provide protection against:

(1) Theft by a Lone Insider Are present material control procedures sufficient to deter or detect the theft of 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 the theft of SSNM by means of a well planned and coordinated assault by several outsiders assisted by an insider?

In contrast to the adversary-oriented external assault team, which operates mostly outside the facility, the physical security assessment team performs a detailed review of safeguard capabilities from within the facility.

In assessing capabilities against the lone insider, this portion of the evaluation considers access controls, including: measures to prevent the introduction of contraband, measures to allow only authorized personnel access, and detection of unauthorized access.

Containment control (which includes measures against unauthorized removal of SSNM),

assurance of integrity of containment, and detection of unauthorized conditions are also evaluated.

In assessing the facility's capability for protecting against external assault with insider assistance, this portion of the evaluation considers detection and delay of adversaries; deployment and communication of response forces; and motivation, training, and reliability of response forces.

4.

Material Control and Accounting Assessment The purpose of the material control and accounting assessment is to determine:

(a) whether the licensee's material control system is capable of detecting a loss of five formula kilograms of SSNM during the inventory period in which such a loss might occur, (b) whether the 0/2

$47 B-6

e licensee's material accounting system was capable of detecting, after the fact, a loss of five formula kilograms of SSNM occurring during a prior two month inventory period or during a prior period of up to twelve months, and (c) whether the material control and accounting systems could determine quickly, in respcnse to an external stimulus (such as an alleged theft), whether or not a five formula kilogram loss of SSNM had, in fact, occurred.

The material control and accounting assessment involves an in-depth examination of the record system, the item control system, process controls, measurements and measurement controls, the inaterial balance, shipper-receiver controls, and the statistical program.

The final part of the comprehensive evaluation is the synthesis of the results of the Diversion Path Survey, External Assault Survey, Physical Security Assessment, and Material Control and Accounting Assess-ment into a conclusion concerning the adequacy of facility safeguards.

This is accomplished L, careful consideration of the specific observa-tions developed during each portion of the assessment to determine whether the safeguards strengths observed counterbalance any vulnera-bilities that might also have been observed.

These results are summarized, along with the specific observations made during each portion of the evaluation, in a safeguards comprehensive evaluation report.

After appropriate coordination, these reports are trans.'itted to the Commissicaers and Congress.

In reaching their judgment, both the assessment teams and the synthesis group use the following rating scheme:

1.

Poor No evidence of capability Obsolete Not yet implemented Not yet operable Poor maintenance Easily compromised 2.

Fair Stated capability but not verified Fair maintenance Implemented but not completely operational Fair records and history Could be compromised 3.

Good Limited demonstration of capability Good maintenance Good records / history Not easily compromised 20/2 548 B-7

4.

High Several operational demonstrations High state of maintenance Records and history provide high support of performance Very difficult to compromise When the safeguards comprehensive evaluation of a licensed facility uncovers a weakness in its safeguards progra,1, NRC requires that the licensee take appropriate remedial action.

The schedule for remedial action depends upon the severity of the vulnerability discovered.

If an emergency safeguards program deficiency is discovered, immediate action is required.

For deficiencies of less severity, the licensee is required to take prompt action.

Remedial action on minor safeguards program deficiencies is usually scheduled to be completed within a reasonable length of time.

A summary of the comprehensive evaluations is provided in classified Appendix G.

E.

Inspection and Enforcement The in section and enforcement program is designed:

(1) to verify that licensees perform in accordance with applicable sections of the Federal statutes, Commission regulations, and Commission-issued licenses and permits; and (2) to inspect the licensee safeguards program for overall adequacy. When licensees are not adhering to these requirements or are conducting operations that might endanger the public health and safety, or might adversely affect the common defense and security, NRC takes appropriate enforcement action or takes steps to change the requirements.

NRC also investigates incidents, accidents, allegations and other unusual circumstances involving matters that may be subject to NRC jurisdiction.

The two types of safeguards inspections--material control and accounting and physical protection--are conducted at nuclear reactors, fuel cycle facilities, and at the other facilities that are licensed to possess or ship special nuclear materials.

The activities inspected include those measures that:

(1) assure physical protection of nuclear reactors and fuel cycle facilities against theft of nuclear material or the creation of a radiological hazard through sabotage; (2) control and account for special nuclear material; and (3) protect both domestic traasport and import and export of special nuclear material.

Material accounting inspections are conducted to determine whether the licensee's program assures adequate control and accounting of special nuclear material.

In addition, the NRC inspects certain licensed export and import shipments of special nuclear material to review material control and independently verify the quantity and type of material shipped.

2072 549 B-8

Both destructive and nondestructive assay techniques are used to monitor special nuclear material inventories.

Three NRC regionai offices have nondestructive assay vans that provide a capability for conducting onsite measurement of licensee material.

Physical protection inspections review the level of protection provided by the licensee against theft, diversion and sabotage at fixed licensee sites and for special nuclear.naterial in transit.

NRC inspectors examine each licensee's security program to assure both effectiveness and conformance to license specifications.

Materials in transit are also subject to NRC monitoring.

This includes inspections at the points of origin, destination, or transfer, and cbservation or surveillance by NRC inspectors along the shipment route.

F.

Assessment cf Reactors There are currently 70 power reactors and 71 non power reactors licensed to operate in the U.S.

In addition, 88 construction permits for nuclear power reactors have been issued.

The safeguards concern for reactors includes consideration of possible theft and sabotage.

For power

reactors, he primary concern is the potential for sabotage, while theft is a concern primarily for those non power reactors possessing formula quantities of highly enriched fuel.

1.

Power R actors The primary concern of power reactor safeguards is to prevent a release of radioactivity which could harm the health and safety of the public as a result of industrial sabotage.

Power reactors, by nature of their design, have a relatively high level of intrinsic sabotage resistance compared to fuel cycle facilities.

Nevertheless, independent backup systems are installed to assure safe shutdown of the facility in the event of a failure of the primary system.

The design principle of separation of redundant emergency systems, with the capability to tolerate an additional single failure, provides a further measure of protection by increasing the number of steps a saboteur would have to follow to achieve successful sabotage.

Another design principle which increases the difficulty of achieving a significant release of radioactivity is the arrangement of multiple barriers against the release of fission products.

(These barriers include the reactor containment, which in most cases is a massive reinforced concrete structure.) In addition, protection of other vital systems is provided at a result of the design of structures against violent natural phenomena, such as earthquakes, tornados, etc.

In addition, NRC requires physical protection measures for adequate safeguarding of power reactors.

NRC is currently reviewing the adequacy of safeguards at all operating power reactors, based on 10 CFR 73.55.

Phase I of this effort has been completed and is discussed in Section C.2 of this Appendix.

In 1978, NRC continued to place primary emphasis on completion of the review and evaluation in Phase II of the 20/2 550

review.

This includes a review of the licensee's response to questions and comments from NRC, further meetings with the licensees to attempt a resolution of any differences or outstanding issues, and the preparation of a Security Plan Evaluation Report for each site.

The third and last phase of the implementation of 10 CFR 73.55 at all operating power reactors will consist of an inspection by the Office of Inspection and Enforcement to verify the completion and operability o# all physcial security systems and procedures described in the security plans.

Completion of the review and implementation of all provisions of all three phases of this regulation was originally scheduled for August 24, 1978.

However, many licensees indicated that they could not achieve this implementation time because of construction de'ays caused by severe winter weather conditions, delays in delivery scredules for some highly specialized security systems of limited availcaility, and other factors.

On August 7, 1978, the Commission published in the Federal Register an extensic, af the deadline for final implementation of Part 73.55 from August 24, 1978 to February 23, 1979.

This extension permits completion of construction an1 equipment installation at most sites.

In a few cases, however, the completion schedules extend beyond this deadline.

In those situations, NRC will require compensatory measures (which, in most cases, are heavily manpower intensive) to be in effect by February 23, 1979, which provides an equivalent level of security agair.A the external assault threat.

These compensatory measures will be docum'.:nted in the security plan, and will have received prior review and approval by the NRC staff.

In January 1979 the NRC staff recommended to the Commission that the implementation of certain parts of Part 73.55 be deferred until May 23, 1979.

The Commission is currently considering the staff recommenda-tion for deferral.

The specific measures recommended for deferral are " pat down" searches, compartmentalization, and the "two-man" rule; these measures would provide additional protection against the " insider" threat.

A February 1979 implementation of pat-down searches, two man-rule procedures, and compartmentalization could preempt Commission consideration of Hearing Board recommendations concerning the proposed material access authorization program.

The material access authorization program (or an equivalent clearance program) would provide substantial protection against the insider threat.

The staff believes that delay of these measures will not cause an unwarrarced safeguards risk against sabotage by an insider for the additictal three month period because licensees presently use interim search procedures and they will have implemented other requirements of Section 73.55 by February 1979.

20/2 551 B-10

Thur

'ar, the NRC staff has reviewed ohysical security plans for all of the,0 operating reactors.

When the plans are fully implemented, these power reactors should provide an adequate level of safeprds protection.

Continuing assessment of safeguaros adequacy will b' made through an inspection and enforcement program.

2.

Non-Power Reactors In contrast to power reactors, where sabotage is the primary concern, the safeguards concern for some non power reactors also includes the potential for theft of SNM, particularly for those facilities which are authorized to possess more than formula quantities of highly enriched uranium and plutonium.

(At this time, no non power reactor licensee is in possession of formula quantities of plutonium, although one facilty is authorized to do so.)

The NRC is currently evaluating non power reactor safeguards adequacy.

This evaluation includes an assessment cf the target attractive-ness for theft or diversion of several types of fuel elements, the potential of various protection measures, and the physical security effectiveness at the various non power reactor installations.

In addition, the staff is also currently performing an in depth evaluation of the sabotage potential of non power reactors, particularly those reactors operating at the higher end of the range of power levels (i.e., above 100 kW).

G.

Safeguards Continaency Planning The development of safeguards contingency plans was mandated by Congress in the Energy Reorganization Act of 1974.

These plans set forth operational schemes and response activities for dealing with threats, thefts, and sabotage relating to SSNM and nuclear facilities resulting from activities licensed under the Atomic Energy Act of 1954, as amended.

The safeguards contingency plans under development include planning at the licensee level and at the national level.

A licensee safeguards contingency plan relates to a specific licensed nuclear facility or transportation activity.

The plan assigns responsi-bilities and identifies procedures for the licensee's security organization to effect timely co rdinated response actions in the event an adversary threat or attempt occurs against the facility or activity.

A rule requiring licensees to prepare safeguards contingency plans became effective on July 6, 1978.

NRC safeguards contingency planning at the national level is intended to accomplish r.ecessary rapid information exchange about threats and criminal acts against licensed nuclear facilities, activities, and material, and to cooperate with the FBI and other agencies.

An NRC incident Response Organization has been established to assure that proper actions are taken to protect the public health and safety in the event of an incident subject to NRC jurisdiction.

It includes an Executive B-u 20/2 552

Management Team (EMT), the Information Assessment Team (IAT), an Incident Responce Action Coordination Team (IRACT), and necessary supporting sta'f to implement IRACT directed actions.

An NRC Incident Response Center, including facilities, communica-tions, operational readiness data, and operating procedures is operational and is currently being further developed.

Alerting and recall procedures to initiate operations from the Incident Response Center by the Incident Response Organization are being exercised to evaluate the NRC response procedures and to train appropriate staff.

20/2 553 B-12

APPENDIX C SAFEGUARDS RESEARCH AND TECHNICAL ASSISTANCE A.

Nature and Scope The NRC safeguards contractual program includes both research and technical assistance projects.

Research projects are planned and managed by the Office of Nuclear Regulatory Research (RES).

They are usually long-term, comprehensive efforts, conducted for the most part in response to specific user requirements generated by the other program offices.

Technical assistance projects, on the other hand, are normally short-term efforts managed directly by the program offices and oriented toward providing the specific technical and analytical support necessary to fulfill operational assignments and responsibilities.

For FY 78, the total safeguards contractural program was about 10.5 million dollars, divided about equally between research and technical assistance projects.

B.

FY 1978 Projects During FY 78, the major efforts of the safeguards research program were directed to the development of methods for performance evaluation of safeguards effectiveness.

The methods being developed include various computerized models applicable to a broad spectrum of safeguards scenarios.

Five evaluation models were provided to user offices for suitability testing.

These tests began in March 1978.

Earlier suitability testing has confirmed the applicability of two of these models to power reactor evaluation even though they were initially developed for fuel cycle evaluation.

The nature of technical assistance projects varies in accordance with the assigned functions and responsibilities of the sponsoring offices.

In FY 78, the major emphases in technical assistance prmjects, by office, were as follows:

for NMSS, the physical security upgrade rule, field adequacy evaluations, and identification of safeguards requirements for the nuclear industry; for NRR, the implementation of new physical protection requirements in reactor facilities; for IE, analytical and technical nuclear measurement services for regional inspectors; and for SD, the improvement of nuclear measurement standards and the development, in both physical protection and material control and acccunting, of NUREG documents and guides for dissemination and use throughout the government and the nuclear industry.

2072 554 C-1

C.

Utilization of Contractual Program Results During FY 78, centractual projects were conducted in all major safeguards areas, which include material control and accounting, physical protection of facilities and SNM in transit, threat analysis, contingency planning, and information systems.

Primary emphasis was placed on efforts in material control and accounting and physical protection, which together accounted for approximately 80 percent of the safeguards contractural funds.

Results from contractual projects have been used to assess and improve the effectiveness of nuclear safeguards for both current and proposed facilities, and to provide specialized technical and analytical support to the program offices in the performance of their assigned responsibilities.

Examples of application include the following:

Use of event tree modeling to identify reactor vital areas.

Use of Bayesian statistical logic to assist in the comprehen-sive field evaluations program.

Application of route selection logic to determine the least vulnerable route for a 1300 mile SNM shipment.

Publication of numerous documents to provide licensee guidance.

20/2 355 C-2

APPENDIX D FUTURE SAFEGUARDS PROGRAM To improve the safeguards protection at facilities and activities under the regulatory authority of HRC, the staff is currently undertaking additional safeguards projects.

These projects are summarized below:

A.

Guard Training In response to public comments on the proposed rule published in the Federal Register in July 1977, to upgrade qualification, training, and equipment requirements for security personnel at fuel cycle and power reactor facilities and for escort guards who accompany domestic shipments of SSNM, the rule was extensively revised to specify performance-oriented requirements instead of the detailed training requirements originally proposed.

The rule was approved for publication as a final rule by the NRC on May 17, 1978.

At that time, the NRC decided that all of the required guidance to licensees necessary to implement the rule should be available in final form before the rule is published.

This guidance:

NUREG-0464, " Site Security Personnel Training Manual"; NUREG-0465,

" Transportation Security Personnel Training Manual"; and revised chapters to Regulatory Guide 5.52, " Standard Format and Content for the Physical Protection Section of a Licensee Application (For Facilities other than Nuclear Power Plants)" was made available for comment on August 9, 1978.

The final rule was published co August 23, 1978, and became effective October 23, 1978, concurrent with final publication of all guidance documents.

Implementation, which will take two years, is underway.

B.

Physical Protection Upgrade Rule - Fuel Facilities Based, among other things, on the findings of a joint ERDA-NRC1 task force on fuel cycle site assessments, and on a need to give licensees more flexibility in fulfilling protection requirements, the NRC in 1976 initiated a physical security upgrade program for fuel cycle facilities that possess formula quantities of strategic special nuclear material (SSNM).

As a part uf this program, a proposed physical security upgrade rule was published in the Federal Register on July 5, 1977. The rule is designed to provide safeguards protection against a threat level higher than the one currently used.2 Following receipt and evaluation of public comments, the proposed IERDA is now in the Department of Energy (DOE).

2 Threat studies conducted by NRC have generally supported the judgment that it would be prudent to adopt a higher threat level for fuel cycle facilities.

A major classified study of the characteristics and capabilities of terrorists and other. criminals was submitted to the Commission in September 1978.

An unclassified version of this report should be available in fiscal year 1979.

o-20/2

$56

e rule was modified and republished for public comment on August 9, 1978.

One of the main features of the proposed rule is its emphasis on performance requirements that allow licensees greater flexibility in carrying out their physical security responsibilities.

The proposed rule also sets forth requirements for certain protection systems and subsystems.

At the time the upgrade rule becomes effective, the NRC will provide additional guidance in the form of descriptions for alternative protection systems and design methods for these systems.

The proposed physical security upgrade rule would also provide for strengthening of protection for nuclear shipments.

Again, performance requirements supplemented by requirements for certain protection systems and subsystems would be used. When compared to current measures, additional guards and escort vehicles and additional hardening of transport vehicles would be required.

This rule is currently scheduled to become effective in FY 1979.

In a separate program, the NRC is conducting tests of a radio communication system designed to more reliably transmit essentially continuous location and status information from nuclear transport vehicles to a control point.

C.

Material Access Authorization Program In March 1977, the NRC published for comment proposed regulations (10 CFR Part 11) that would requira certain individuals involved in licensed nuclear activities to receive NRC authorization before being granted access to or control over special nuclear material (SNM) or vital and protected areas at reactors, fuel cycle facilities and in transporta-tion activities.

NRC authority to require such authorization was acquired in 1974 by enactment of Public Law 93-377, which amended the Atomic Energy Act (section 161i). A staff proposal for a personnel access program in which background investigations would be conducted by the Civil Service Commission was forwarded to the Commission in late 1976.

This proposed program would be administered by the NRC, utilizing procedures similar to those presently applied in the security clearance program for NRC employees, contractors, and others having access to NRC classified information.

The results of hearings on the staff proposal, which were held in the summer of 1978, will be studied during fiscr.1 year 1979 to help NRC assess this program.

D.

Non-Power Reactors NRC is currently conside'-ing the development of a new rule for non power reactor safeguards.

This rule would cover non power reactors not included in the fuel cycle facility upgrade rule mentioned above.

20/2 557 D-2

E.

Physical Protection of Category II and Category III Materials During 1978 NRC published proposed rules that would require protection of Category II material (special nuclear material of moderate strategic significance) and Category III materials (special nuclear material of low strategic significance).

The proposed measures are designed to provide a level of protection equivalent to that suggested in Information Circular /225 published by the International Atomic Energy Agency (IAEA).

They require physical protection at fixed sites, including non power reactors, and for nuclear materials in transit.

The proposed rule was published for public comment on May 24, 1978, and will be published for implementation during fiscal year 1979.

F.

Material Control and Accounting In September 1977, a Task Force was established to study the role of material control and accounting in the NRC's safeguards program.

The study considered domestic nuclear facilities possessing one effective kilogram or more of SSNM.

Low-enriched uranium and international safeguards were not included in the study except that some consideration was given to the role of the NRC safeguards program in supporting international safeguards.

In its report, issued in April 1978, the Task Force concluded that the current regulatory base is fundamentally sound and rigorous implementation of its requirements should provide a substantial level of safeguards protection, but that there are some areas in which strengthening is appro-priate.

The report sets forth several findings and recommends that the NRC develop and issue a material control and accounting upgrade rule to implement the findings.

The rule would be issued in two phases:

the first would be implemented in 18 to 24 months following a Commission decision to proceed with the rulemaking effort; the second would be implemented within five years as technology under development is proven.

The Task Force recommended that NRC require licensees to use existing or available process monitoring data in their safeguards programs, maintain shift inventory controls over items and containers, provide for certifi-cation or overcheck of waste discards and intraplant transfers, improve traceability of records, develop response plans for performing special physical inventories on demand, upgrade custodian and scrap controls, reconcile shipper / receiver differences in a more timely manner, perform random audits three times per year, and select and train key material control and accounting personnel in accordance with specified criteria.

The Task Force also recommended improvement in NRC operations, revitali-zation of the regulatory guide program, specific studies to support a goal-oriented safeguards programs, and priorities for NRC's research and technical assistance programs.

The Task Force recommendations were sub-sequently reviewed by NRC staff.

A material control and accounting develop-ment plan has been prepared to implement those recommendations that are determined to be cost-effective.

20/2

$58 0-3

L G.

Classification of Safeguards Information The classification of safeguards information within NRC was, in fiscal year 1978, based on Executive Order 11652, " Classification and Declassification of National Security Information and Material," dated March 8,1972, as amended, and the Atomic Energy Act of 1954, as amended.

The application of the Executive Order to specific categories of safeguards information has been an evolutionary process which began with the reports generated by the Special Safeguards Study Group and continued with the reports generated in support of the Safeguards Supplement to the Draft Generic Environmental Statement on Use of Mixed Oxide Fuel ic Light Water Reactors.

This evolutionary process was reinforced by studit:s and decisions on the part of the National Security Council concerning the safeguarding of those categories of information and materials that could be most directly useful in the construction of nuclear explosive devices.

In fiscal year 1978, NRC classified safeguards information only if it fell within the below-listed five categories and if its disclosure would significantly assist a malevolent individual or group in acquiring or using special nuclear material.

The categories are:

a.

Certain information on material control and accountability.

b.

Information on physical protection at fixed sites.

c.

Certain information on in-transit protection of special nuclear material.

d.

Safeguards analyses that indicate vulnerabilities and plans for protecting certain types and quantities of special nuclear material.

e.

Certain safeguards communications related information and procedures.

It should be clearly noted that most of the information within the above five categories was not classified and that classification was used only when essential to the national security.

Effective December 1,1978, Executive Order 11652 was replaced by Executive Order 12065, " National Security Information," dated June 28, 1978. This new Executive Order specifically identifies information con-cerning United States Government Programs for safeguarding nuclear materials or facilities as one criterion for classification of information.

It does not, however, substantially modify the safeguards categories of information classified by the NRC.

Through its requirement for the issuance of classifi-cation guidance, implementation of this new Executive Order should result in a more clearly codified set of classification standards for use by NRC personnel in the safeguards area.

2072 559 D-4

APPENDIX E ORGANIZATION AND MANAGEMENT FOR SAFEGUARDS A.

.m.uional Responsibilities - Lead and Support Offices Each of the major program offices has a role in planning and implementing the NRC domestic safeguards program.

The Office of Nuclear Material Safety and Safeguards (NMSS) has lead responsibilities for safeguards activities in the areas of fuel cycle facilities and material transportation.

This office formulates safeguards policy and develops new and revised regulatory approaches and requirements for fuel cycle facilities and material tranportation.

It reviews, evaluates and approves safeguards elements of licensee applications and amended physical security plans.

It also develops contingency plans, interagency agreements, and threat assessment capabilities.

It maintains safeguards information gathering and retrieval systems.

This office is also responsible for conducting assessments of advanced safeguards measures and, with the Office of Inspection and Enforcement, evaluates adequacy of safeguards as implemented by fuel cycle licensees.

The Office of Nuclear Reactor Regulation (NRR) has lead responsi-bilities with respect to safeguards for reactors.

This office formulates safeguards policy and develops new and revised regulatory requirements for safeguarding power and non power reactors.

It reviews, evaluates and approves safeguards elements of license applications and amended physical security plans for upgrading power reactor physical security.

It supports reactor licensee contingency planning.

This office, with the Office of Inspection and Enforcement, evaluates the adeqt.acy of safeguards as imple-mented by reactor licensees.

The Oflice of Standards Development (SD) develops and maintains standards and guides clarifying the objectives and performance criteria of the evolving safeguards.

It is also responsible for developing standards and guides for assessing licensee safeguards systems.

The Office of Inspection and Enforcement (IE) conducts inspections and investigations to (1) monitor licensees' compliance with all safeguards regulatory requirements, (2) assess the adequacy and effectiveness of licensee-implemented safeguards programs, and (3) determine the necessary enforcement actions to ensure that the proper corrective action is taken by licensees to protect the public health and safety.

It advises other program offices on inspectability, enforcement and adecuacy of proposed safeguards regulatory changes, and it provides inputs ragarding adequacy of licensee plans.

This office provides overall coordination of the NRC incident response program.

20/2 560 E-1

Q)

• • +A>gr9

/g, h

\\

' I 4 + f7e (4,4NN

)

////p

/

4$ 'I

'4 N

IMAGE EVALUATION TEST TARGET (MT-3) 1.0 l# EM EA

= s @ I!L23 u L" E l.8 1.25 1.4 1.6

=

c si si

<>+sA A

4///

+

e,3>f>g>//

<$.s zy4,$

e[lv>

y 4

0

$s&#>&9

/s

1. e 0

~$

hh,

$3f>

/f<4,4

~

V' IMAGE EVALUATION TEST TARGET (MT-3) 1.0 l9 m E24 i2 EE Imlzs.2 2

u i!ii, :2 g3 l

l,l h,

bN l 1.8_

' l.25 1.4 1.6 4

6"

• I>'//f'

'S 4

I

4 g

M[?'

dI.k TEST TARGET (MT-3) 1.0 502 EM l# !!3 ll!!!E

!EE lillM I ll l

1.8 1.25 1.4 1.6

• r %

+ ///p

• d"/s>bybe

+

R>gy@

n ///

,,,,,

2 I

1. hk.$#)'I{4' TEST TARGET (MT-3) 1.0

'! DE E4 6 m Bl\\\\=n a

=

m l,l

$I# ll!!!_N_

2 1.25 1.4 1.6 6,,

=

th,f*e?>,*/

[.4,&

'4 [' S i

4, o

I

b The Office of Nuclear Regulatory Research GES) provides research support to the lead offices.

It conducts programs to aid the establishment of NRC safeguards regulatory policies.

This office is also resrcnsible for the development of evaluation techniques for assessing the effective-ness of reactor, fuel cycle facility, and transportation safeguards, for the development of the Integrated Safeguards Information System (ISIS),

and for research to develop improved metheds for assas W a protection levels.

Inter-office integration of the NRC safeguards research program is provided by the Safeguards Technical Assistance and Research Coordinating Group (STAR), under the lead of NMSS with participation by the other program offices.

811 safeguards contractual projects are reviewed by the Coordinating Group and the Group conducts followup reviews of each cc.. trac-tual project.

In addition, the Coordinating Group maintains contact wit".

NRC representatives on the DOE /NRC,afeguards Liaison Board to assure that NRC safeguards projects do not unnecessarily duplicate or overlap DOE safeguards projects.

The NRC safeguards program.

• eviewed and approved annually by the Budget Review Group, the Executive director of Operations, and the Commission during the budget process.

B.

Integrated Safeguards Plan The development of a formal Integrated Safeguards Plan was initiated in August 1977.

When completed it will provide a formal, long-term plan which, in its first phase, defined the current safeguards acti"ities of all NRC offices that are engaged in the NRC safeguards program.

In its second phase, the plan will specify the goals and objectives of the total NRC safeguards program, delineate office responsibilities for achieving the safeguards goals and objectives of NRC, and assure overall coordination of NRC safeguards efforts.

Phase I was completed in March of 1978.

Phase II of the Integrated Safeguard, Plan is scheduled to be completed in 1979.

C.

Coordination With Other Federal Agencies In its role as a regulatory agency, NRC has no response forces for responding to safeguards contingencies. Therefore, NRC must rely on those Federal a;encies that have authority, responsibility, knowledge, expertise, and capability for providing an active and timely response.

To date, the NRC has contacted 82 organizational elements of 28 Federal agencies and three national associations.

These contacts were made to determine what resources are available and of use to NRC, and what agreements would be needed for NRC to request any desired essistance.

NRC is preparing to negotiate " Memoranda of Understanding" with those agencies that ccn provide meaningful assistance to NRC.

J2073 001 E-2

APPENDIX F GLOSSARY TERMS AND ABBREVIATIONS USED IN SAFEGUARDS ANNUAL REPORT Category I Equivalent to Formula Quantities of SSNM Material Category II Special nuclear material of moderate strategic Material significance:

(1) Less than formula quantities of strategic special nuclear material, but in a quantity of more than 1,000 grams of uranium-235 (contained in uranium enriched to 20 pervent or more in the U-235 isotope) or more than 500 grams of uranium-233 or plutonium or in a combined quantity of more than 1,000 grams when computed by the equation, grams =(grams contained U-235)+2(grams U-233+ grams plutonium), or (2) 10,000 grams or more of uranium-235 (contained in uranium enriched to 10 percent or more but less than 20 percent in the U-235 isotope).

Category III Special nuclear material of low strategic significance:

Material (1) Less than an amount of strategic special nuclear material of moderate strategic significance, but more than 15 grams of uranium-235 (contained in uranium enriched to 20 percent or more in the U-235 isotope) or 15 grams of uranium-233 or 15 grams of plutonium or the combination of 15 grams when computed by the equation, grams = grams contained U-235+ grams plutonium +

grams U-233, or (2) Less than 10,000 grams but more than 1,000 grams of uranium-235 (contained in uranium enrictad to 10 percent or more but less than 20 percent in the U-235 isotope), or (3) 10,000 grams or more of uranium-235 contained in uranium enriched above natural but less than 10 percent in the U-235 isotope.

CFR Code of Federal Regulations DOE Department of Energy DOT Department of Transportation Effective (1) For plutonium and U-233 their weight in kilograms Kilograms (2) For uranium with an enrichment in the isotope of SNM U-235 of 0.01 and above, its element weight in kilograms multiplied by the square of its enrichment expressed as a decimal weight fraction.

2073 002 F-1

s Effective (3) For uranium with an enrichment in the isotope Kilograms U-235 below.01 by its element weight in kilo-of SNM, cont'd.

grams multiplied by 0.0001 EIS Environmental Impact Statement EMT Executive Management Team ERA Energy Reorganization Act of 1974 ERDA Energy Research and Development Administration

(,ow part of 00E)

Formula Strategic special nuclear material in any combination Quantity in a quantity of 5,000 grams or more computed by the formula, grams =(grams contained U-235+2.5(grams U-233

+ grams plutonium))

FY Fiscal Year HEU High Enriched Uranium IAEA International Atomic Energy Agency IAT Information Assessment Team ID Inventory Difference IE Office of Inspection and Enforcement IRACT Incident Response Action Coordination Team ISIS Integrated Safeguards Information System LLEA Local Law Enforcement Agencies LWR Light Water Reactor NMSS Office of Nuclear Material Safety and Safeguards Non-Power Reactors used for research, training, testing, or Reactors the production of radioisotopes NRC Nuclear Regulatory Commisssion NRR Office of Nuclear Reactor Regulation 200/3 003 F-2

OSHA Occupational Safety and Health Administritior g

PWR Pressurized Water Reactor RES Office of Nuclear Regulatory Research SD Office of Standards Development SNM Special Nuclear Material SPER Security Plan Evaluation Report SSNM Strategic Special Nuclear Material STAR Safeguards Technical Assistance and Research Coordinating Group Strategic Uranium-235 (contained in uranium enriched to 20 Special percent or more in the U-235 isotope), uranium-233, Nuclear or plutonium Material 20/3 J04 F-3

APPENDIX G SITE-SPECIFIC COMPREHENSIVE EVALUATION RESULTS (FY 1978)

CLASSIFIED This Classified Appendix contains schedules and Summary Evaluations based on comprehensive evaluations at fuel cycle facilities.

2073 005 G-1