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Draft Physical Security Plan
for Sea Shipment of Category II Quantities

• Preparation an EM-62 initiative following 9/96 shipments
  
  
• Security Plan a contractual requirement in RFP for DOE shipping contractor
  
  
• DOE contractor ships fuel from developing countries calendar 1997
  
  

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Sierra Club vs James D. Watkins, Secretary of
U.S. Department of Energy, et.al.
(December 9, 1991)

• Federal Court found inadequate a DOE Environmental Assessment re: impact of shipping Taiwanese spent fuel to Savannah River
  
  
• Department has to consider possibility of human intervention and attendant risks of low probability event
  
  
  - even though police might escort shipments, risk of low probability event can't be ignored
  

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Infcirc/225/Rev. 3

• Is material self-protecting?
  
  
  - 100 rads/hr. at one meter unshielded
  - if not, treat as unirradiated, not self-protecting
  
  
• Cat I unirradiated 5 kg U-235 or more
  
  
• Cat II unirradiated
  
  - less than 5 kg but more than 1 kg if enrichment is 20% or higher
  - 10 kg U-235 or more if enrichment is 10% - 20%
  
  
• Reduce Cat I or II quantity one category level if self-protecting
  

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DOE Order 5633.3B
Control & Accountability of Nuclear Material

• Moderately irradiated >15r/hr.
  
  - Category II Attractiveness Level D U-235>50 kg.
  - Category III Attractiveness Level D U-235>8<50 kg.
  
  
• Highly irradiated>100r
  
  - Reportable Quantities
  

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Fuel Categorization Critical

• Security for Category I quantity significantly higher than for IAEA Category II or lower
  
  
• If Category II under DOE Order 5633.3B, protect as if Category I
  

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Stages of Transport

• Reactor to Port of Embarkation
  
  
• Port of Embarkation
  
  
• At Sea
  
  
• U.S. Territorial Limits to Charleston or Concord NWS
  
  
• U.S. Port to Savannah River or Idaho
  
  

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Scope of Category II Plan

• Focus from reactor to U.S. port
  
  
• Host country regulations (if any) apply from reactor to port of embarkation
  
  - Do national regulations incorporate Infcirc/225/Rev.3?
  
  
• IAEA Guidelines on Physical Protection of Nuclear Material (Infcirc/225/Rev. 3) while at sea
  
  - satisfy requirements of Convention on Physical Protection of Nuclear Material (Infcirc/274/Rev. 1)
  
  
• 10 CFR 73.37 for spent fuel applies to NRC licensee while in US. territorial waters
  
  
• DOE Order 5632.1C-1, Protection & Control of Safeguards and Security Interests, requirements for sea shipment of irradiated fuel
  

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Clarify Who Does What

• Designation of U.S. and shipper country government POCs under Physical Security Convention
  
  
• Designation of emergency response agency in host country and while at sea
  
  
• Shipper 24-hour communications center
  
  
• Cognizant DOE operations center
  

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Draft Category II Plan

• Shipper fills in summary matrix and plan text on how shipper fulfills all applicable elements of Infcirc/225/Rev. 3
  
  
• Several stages
  
  - how fuel gets to exit port
  - security at exit port
  - security at sea
  - entry into US territorial waters
  

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Information Which Plan Will Generate

• Security capability for transport to port
  
  - route, stop-overs, hand-overs, etc.
  - guard and response force
  - who is in charge
  - with whom is security plan on file
  - load vehicle check, locks and seals
  
  
• At sea
  
  - who has advance knowledge of route
  - escort(s)
  - communications, monitoring cargo, emergency response
  
  
• At receiving Port
  
  - hand-over arrangements
  

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Some Key Issues

• Current threat assessment of the route and its alternatives
  
  
• How the security plan addresses the assessed threat
  
  
• Who is responsible for doing what
  
  - capability to carry out the responsibility
  
  
• Use of "need to know" principle and tight information security to protect access to sensitive route and security information
  
  
• Language barrier
  

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Need for:

• Early communications with DOE on security
  
  
• Planning for security
  

DOE ready to help

POC EM Safeguards and Security Team

Tel.: (301) 903-9977
Fax : (301) 903-9980