APPENDIX I Thomas J. McTiernan APPENDIX I equipment not already in place, the staff believes that the necessary action has been taken. We have no information from any intelligence or investigative arm of the government of known groups in this country having the combination of motivation, skill, and resources to attack a nuclear power reactor, and physical security upgrading is underway. Therefore, publication of this rule is, in the staff's view, appropriate interim action and results in the appropriate increased awareness of physical security at nuclear power plants. The second area concerns statements made on page iii and elsewhere in the document which indicate that GAO believes the level of inspection varied from plant to plant. Variations observed by GAO could have arisen from three basic causes: (1) different commitments and levels of details in each licensee's approved security plan; (2) the fact that only portions of the annual inspection are covered during any one visit and the tasks of successive visits are not required to be repeated except to verify corrective action taken by the licensee; and (3) human factors, which we have attempted to minimize by the establishment of standard inspection procedures. As described above, the program that will be used to review the licensee's amended security plans will solve the problems associated with different commitments and levels of details. The GAO has suggested that changes are appropriate to minimize the other two causes of variation in the level of inspection. We are continuing to review our inspection program and procedures for upgrading as necessary. The third area concerns the directive relating to inadequacies of locks. GAO points out that the directive has not yet been issued. A circular addressing locks was forwarded on 17 March 1977 to the regional offices for distribution to licensees. As you know, the staff has met with GAO staff to discuss several specific points of the report. Several changes were discussed. In addition, GAO staff and Division of Security staff have met to discuss areas which caused some classification concern. I understand that changes have been made in the report and that the Division of Security recommends that the report be published as not classified. Lee V. Gossick Office of the Executive Director An Unclassified Digest Of Nuclear Regulatory Commission Energy Research and Development Administration EMD-77-40a MAY 2 19 REPORT OF THE COMPTROLLER COMMERCIAL NUCLEAR FUEL DIGEST The development and expanded use of nuclear energy in the United States has resulted in increasingly large amounts of highly dangerous "special nuclear material" being processed by the Government and private industry. The most dangerous of these materials are plutonium and highly enriched uranium. In addition to being used in the fabrication of bombs, plutonium is an extremely toxic substance, with the potential of causing cancer if inhaled, or exposed to an open wound. Such materials, therefore, are potential targets of terrorist groups, criminals, or agents of foreign countries. The potentially catastrophic consequences of even a single theft of significant quantities of such material and the possible impact such an occurrence could have on the development of nuclear-generated energy makes it essential that special nuclear material be adequately protected. Two Federal agencies are responsible for properly safeguarding nuclear materials: --The Energy Research and Development Administration for nuclear materials held by its research and development facilities; and --The Nuclear Regulatory Commission for establishing and enforcing nuclear materials safeguard requirements at commercial facilities. This report deals with weaknesses in the nuclear material accountability and physical security systems at commercial fuel fabrication and processing facilities. Unlike commercial nuclear power reactors which use low enriched uranium in the production of electricity, the fabrication and processing facilities employ large quantities of plutonium and highly enriched uranium, consequently these facilities are attractive targets. The basic systems used at facilities licensed by the Nuclear Regulatory Commission to prevent special nuclear material from being lost or stolen are (1) material control and accountability for detecting and deterring thefts and (2) physical security to prevent or respond to thefts. ACCOUNTING FOR SPECIAL Accounting for special nuclear materials is extremely complex and is based on physical, chemical, and radiometric measurements. Current state-of-the-art limitations in measurement instruments and the difficulties in measuring nuclear materials held up in pipes, machinery, and filters preclude accurate measurements. The accuracy ranges from as high as plus or minus 0.1 percent to as low as plus or minus 80 percent. The former Atomic Energy Commission and its successor agencies have recognized the uncertainties and limitations of the accountability systems. Since 1968, the Energy Research and Development Administration has had an ongoing research and development program aimed at improving the state of the art of the instruments used to measure and record nuclear materials. Also both agencies are developing a computerized measurement and accountability system that may permit continuous control of such material through automated recording and measurement techniques resulting in more timely special nuclear material data. Discrepancies normally occur between physical and book inventories. Discrepancies which cannot be reconciled have been termed "material unaccounted for" (MUF), which is a prime indicator of the effectiveness of nuclear materials accountability and control systems. Since licensed facilities began operating in 1955, the MUF at major commercial facilities has amounted to thousands of kilograms of special nuclear materials. Although these quantities do not necessarily denote lost or stolen material, the fact that it is missing greatly detracts from the integrity of the safeguards system. In addition, the accountability systems do not provide timely information on possible thefts so that prompt response and recovery actions can be undertaken. Frequently, quantities of material large enough to make a weapon go unaccounted for from 1 to 2 months. At one of the commercial nuclear fuel fabricators GAO visited, significant quantities of plutonium had gone unaccounted for for about 1-1/2 months. Although physical security procedures such as access and exit controls helped assure that material was not removed from the plant, the licensee and the Commission could not be certain whether the loss was due to clerical error, to measurement inaccuracies or to actual theft. The Commission ultimately attributed the incident to plutonium within the plant piping and machinery that was previously unmeasured. |