A
CRITIQUE OF PHYSICAL PROTECTION STANDARDS FOR
TRANSPORT
OF IRRADIATED MATERIALS
Edwin
S. Lyman, Nuclear Control Institute
1000 Connecticut Ave. NW,
Washington, DC 20036 USA (202) 822-8444
Presented at the 40th Annual Meeting of the Institute of
Nuclear Materials Management,
Phoenix, AZ, July 1999
Abstract
The Clinton Administration has
proposed a $10 billion program to counter the growing threat of terrorism. However, it is paying little attention to
the risk of radiological sabotage, even though shipments of spent nuclear fuel
(SNF) are projected to increase dramatically within the next decade, and
current U.S. standards for the physical protection of SNF transports have not
changed substantially since the early 1980s.
In 1979, as a result of a Sandia
National Laboratories (SNL) study that predicted serious radiological
consequences from SNF transport cask sabotage in a densely populated urban
area, the Nuclear Regulatory Commission issued an interim rule (10 CFR 73.37)
which specified that SNF transport routes should avoid such areas "where
practicable." In 1980, the rule was amended to permit transit of SNF
through heavily populated areas with an armed escort. This change was informed by research which showed that the
releases of material resulting from a design-basis shaped charge attack on a
SNF cask would be smaller than originally thought. In 1984, NRC issued a proposed rule that would have weakened the
regulation further by removing the requirement for an armed escort through
heavily populated areas. However, the
proposal received severe criticism and the rulemaking was never completed.
A recent study by SNL describes
two-stage attacks on transport casks which, with certain modifications, could
lead to much larger radionuclide releases.
A review should be conducted to assess whether the current regulations
provide adequate protection against the threat of such attacks.
Introduction
The Clinton Administration has
recently announced major new initiatives to combat the threat of terrorism
utilizing weapons of mass destruction (WMD).
However, the emphasis has been on the use of biological and chemical
agents. There has been no visible
effort to review and upgrade existing measures aimed at preventing the occurrence
of a terrorist attack resulting in a radiological release. In fact, with regard to the risk of
radiological sabotage, the bureaucracy seems to be moving in the opposite
direction.
Late in 1998, as a result of
pressure from the nuclear industry, Nuclear Regulatory Commission (NRC) staff
terminated a program known as the Operational Safeguards Response Evaluation
(OSRE), which tested the abilities of nuclear power plant security forces to
repel terrorist assaults aimed at core damage and radiological release. Although the program was quickly reinstated
by former NRC Chairman Shirley Jackson following reports in the media of the
termination, the industry and NRC staff have continued their efforts to relax
physical protection requirements which they view as excessively burdensome.[1]
Given these circumstances, the
public has legitimate reason to be concerned about the depth of the commitment
of NRC and the nuclear industry to maintaining a rigorous regime for protection
of potential targets for radiological sabotage, which include both operating
nuclear plants and highly radioactive materials in transit or storage. At the same time that nuclear plant
operators are under unprecedented pressure to reduce costs, including the cost
of security and safeguards, the terrorist threat appears to be expanding in
breadth and lethality.
Physical protection programs are
nominally designed to protect against "design basis" threats
(DBT). A credible security plan depends
critically on selection of a DBT that is sufficiently realistic and
conservative to represent a wide range of contemporary threats. However, it is not clear that this is the
case for the DBTs in current use by NRC.
While sensitive details of DBTs are not available to the public for
security reasons, those details that are publicly available lead one to
question their adequacy. For instance,
it is known that the size of the attacking force specified in the DBT for
sabotage of a nuclear power plant is smaller than that specified in the DBT for
a Category I facility containing special nuclear material (SNM). While theft of SNM could potentially be more
catastrophic than sabotage of a nuclear facility, both types of event could
have devastating physical and psychological impacts on the public.
Physical Protection
Regulations for Transport of Irradiated Materials
On June 24, 1999, the Attorney
General for the State of Nevada sent a petition to NRC requesting a rulemaking
to review and strengthen the regulations for physical protection of spent nuclear
fuel (SNF) contained in 10 CFR Part 73.[2] This petition was based largely on an
extensive and generally excellent analysis commissioned by Nevada in 1997.[3] Given Nevada's interest in making the
transport of SNF to an interim storage or geologic disposal site at Yucca
Mountain as difficult and costly as possible, the political motivations for
this action are apparent. Nonetheless,
the petition raises serious issues concerning the adequacy of the current regulations
and has considerable merit.
The current NRC regulations for
physical protection of SNF transport originated in 1979 as "interim"
measures and have never been finalized.[4] They were instituted in response to the
results of a 1978 Sandia National Laboratory draft study ("The 1978 Urban
Study"), which estimated the consequences of a successful sabotage attack
on a truck cask containing 3 pressurized-water reactor (PWR) spent fuel
assemblies in a densely populated urban area.
The 1978 Urban Study projected that tens of early fatalities (EF) (from
acute radiation exposure) and hundreds to thousands of latent cancer fatalities
(LCFs) could result from such an attack.
These projections were sufficiently severe that NRC decided to
immediately implement an interim rule without first soliciting public comment,
pending the results of further confirmatory research.
The "interim final rule"
established in 1979 included requirements such as advance NRC notification and
approval of spent fuel shipment routes, coordination with local law enforcement
on emergency plans, specifications for the number and training of (unarmed)
escorts and an immobilization capability for vehicles carrying spent fuel by
road. Of particular note was a
requirement that the shipment route should be "planned to avoid, where
practicable, heavily populated areas."
NRC considered this statement to be an effective embargo on shipments of
spent fuel through densely populated urban areas.
In 1980, NRC published amendments to
the 10 CFR 73 interim final rule which "reduced the stringency of the
required physical protection measures," according to a 1982 SNL report.[5] These were issued in response to public
comments and to a revised version of the SNL 1978 Urban Study ("The 1980
Urban Study") which projected consequences of an urban sabotage incident
that were about a factor of ten lower than those in the first version,
primarily as a result of assuming a 14-fold smaller release fraction of
respirable particulates from the cask (0.07% instead of 1%).[6] As a result, NRC removed the effective
embargo on SNF shipments through heavily populated areas, but required that
such shipments be accompanied by an armed escort.
In 1984, NRC attempted to weaken
physical protection regulations even further by issuing a proposed rule that
would have removed the armed-escort requirement for SNF shipments through
heavily populated areas.[7] The basis for this was "research
recently completed [that] has shown that the likely respirable release from
sabotage and the resulting consequences are but a tiny percentage of the
estimated values which originally prompted issuance of the rule." The research referred to was a series of
tests in the early 1980s undertaken by SNL of the effect of shaped charge
attacks on typical SNF truck casks at that time.[8]
The 1984 proposed rule received a
great deal of negative comment and the rulemaking was ultimately suspended,
leaving the interim final rule in place.[9] However, the claims underlying the proposal
--- that spent fuel casks are relatively invulnerable to terrorist attack and
that consequences of such an attack would be extremely limited, even in densely
populated urban areas --- has become established wisdom. This situation, unfortunately, may be
contributing to unjustified complacency about the potential threat posed by SNF
shipments. The State of Nevada's call
for a full reevaluation of the technical basis for the existing regulations is
clearly warranted.
The threat evaluated by SNL and NRC
in the early 1980s involved a single shaped charge attack on a spent fuel
shipping cask containing a surrogate SNF assembly composed of depleted
uranium. The shaped charge jet
penetrated the wall (4.5 cm of stainless steel and 21.3 cm of lead), perforated
50% of the fuel rods and shattered the solid fuel in its path. In addition, it caused the temperature of
the fuel mass to rise to greater than 1744C.
The basis for the NRC's contention
that the consequences of such an attack are limited stems from the observation
that although the cask was penetrated and the SNF was damaged, only a
relatively small amount of fuel was actually shattered by the jet, and only a
small fraction of the material that was released was small enough to be
respirable (less than 10 microns in diameter).
The experiments showed that only 4.3x10-6 of the solid fuel
was released in the form of respirable aerosol, corresponding to a release of
only 6 grams of depleted uranium oxide from a truck cask containing three SNF
assemblies (1.4 tonnes heavy metal). This
quantity was then multiplied by 5.6 to adjust for the fact that the experiments
used fresh fuel and not spent fuel, based on small-scale correlation
experiments. The peak consequences of
this release in a densely populated urban area like New York City were found to
be zero EFs and seven LCFs.
The question of whether the scenario
outlined above is a realistic representation of the contemporary sabotage
threat has been the focus of much criticism and is one of the chief concerns
raised in the State of Nevada's petition.
Here we will focus on two of the many technical issues.
a) The source term extrapolated from the SNL
experiments is inaccurate and non-conservative.
The derivation of the single
shaped-charge attack source term from the SNL experiments is inaccurate. SNL assumed, in extrapolating from results
for fresh fuel to those for spent fuel, that the source term would consist only
of two components: the noble gas
inventory of the breached fuel rods and the fraction of the solid fuel observed
to form a respirable aerosol. Sandia,
however, neglected to consider the fuel-cladding gap fraction of semivolatile
radionuclides such as tellurium (Te), antimony (Sb) and cesium (Cs), even
though at the elevated temperature that was observed one would expect the
entire gap inventory of Cs and most of that for Te and Sb to be released in
gaseous form from breached fuel rods.
In addition, the high temperature would likely have caused further
releases of cesium trapped on grain boundaries.
Although SNL acknowledged that
enhanced releases of semivolatiles would occur at that temperature, it argued
that "these radionuclides are less biologically significant than the
actinides and the resultant calculated dose increase would not affect the
overall risk estimate." We have
conducted an analysis (see below) that shows this is not the case. The gap fraction of Cs isotopes is on the
order of 1% of the total fuel rod inventory.
In addition, gap releases from spent fuel irradiated to the high burnups
experienced today exhibit greater gap releases when punctured. A recent Brookhaven National Laboratory
(BNL) study evaluated the consequences of spent fuel pool accidents in which
releases of semivolatiles in the gap took place.[10] The Cs gap release fraction from overheated
high-burnup fuel in the absence of fire was estimated as 3%.
b) Sabotage scenarios which could lead to a
significant enhancement of the release of respirable particles were not
adequately considered.
The sabotage scenario which NRC
considered in its original rulemaking for the physical protection of SNT
transports involved only a one-stage attack using a single shaped charge. The radionuclide release resulting from this
scenario was therefore limited to that caused by the initial cask breach and
fuel rod damage. However, they did not
carry out an adequate assessment of relatively simple measures that an attacker
might use to greatly enhance the respirable release from the cask once
breached.
NRC stated in its 1984 proposed rule
that it considered the possibility that "an adversary could use more than
one shaped charge in attacking the cask" and concluded that "the
likely result is that the release would be in proportion to the charges
used." It said further that
"there is no known technology that would allow a disproportionately large
increase in production of respirable particles with credible increase in a
saboteur's explosive resources."
Even if the amount of radionuclide
release were linearly proportional to the number of shaped charges, it is clear
from the calculation below that a doubling or tripling of the release could
result in additional thousands of LCFs in densely populated areas. However, there are, without a doubt,
credible means by which a terrorist could cause an increase in respirable
release by an order of magnitude or more.
It is not hard to envision ways to
do this. A good example is derived from
a 1996 SNL study (the "Red Team Report"), which describes a scenario
by which terrorists intercept a shipping cask containing canisters of vitrified
high-level waste which themselves contain small cans of immobilized plutonium.[11] The report describes a two-stage attack in
which terrorists use a shaped charge to penetrate the lid of the shipping cask,
and then inject a low-explosive charge to blow off the lid and facilitate the
theft of the canisters within without damaging them. This was intended as a credible theft scenario. However,
the same analysis suggests a credible sabotage
scenario in which high explosive instead of low explosive is injected, with the
objective of causing maximum (rather than minimum) damage to the cask contents.
It is certainly straightforward to conclude that a two-stage attack, as
outlined above, could be devised to cause the generation and release of a
considerably larger amount of respirable material than a one-stage attack
utilizing only a single shaped charge.
This issue was raised by the Nuclear
Control Institute when a sea shipment of vitrified high-level waste en route
from France to Japan traversed the Panama Canal in 1998. (The ship was boarded by Greenpeace at one
end of the Canal, demonstrating that the shipment's security arrangements were
not adequate even to protect against interception by non-violent activists.) Subsequently, one of the authors of the Red
Team Report, John Hinton, testified for a lawsuit in Puerto Rico that the
observation in the Red Team Report "does not support and was not meant to
support a conclusion" that storage and transport casks for vitrified
high-level waste "were vulnerable to credible threats of radiological
sabotage."[12]
However, such a statement violates
common sense. If SNL concluded that a
shipment could be intercepted, a cask could be penetrated, the lid could be
removed with low explosive and the canisters could be safety retrieved, then
one is led to conclude that sabotage scenarios are also plausible, especially
since they can be simpler (for instance, an escape plan would be unnecessary on
a suicide mission).
There does not appear to be data in
the open literature regarding the fragmentation behavior of spent fuel to which
high explosives have been directly applied.
It is well known that direct application of explosives to ceramic
fragments generally cause a reduction in the average particle size of the
fragments. However, the heating that
occurs during the explosion can cause sintering and an increase in particle
size as well, depending on the properties of the ceramic. Such information is clearly relevant to an
assessment of the consequences of such an action. Therefore, there is a need for experiments of this type, and SNL
should be tasked to do them.
A less sophisticated but also
effective approach to increasing radionuclide release from a breached SNF cask
would be to inject fuel into the cavity and start a fire. This would cause ignition of the Zircaloy
cladding, and at a minimum would greatly enhance the release of cesium and
other semivolatile elements that remain in the fuel pellets. The BNL spent fuel pool study assumed that
100% of the fuel Cs inventory would be released. Recent results from France indicate that heating at 1500C of high-burnup
spent fuel for one hour caused the release of 26% of the Cs inventory.[13]
We performed a consequence
assessment using the MACCS2 code[14]
for the three source terms given in Table I.
TABLE
I Source Terms For Consequence Calculations
source term |
Radionuclide release fractions |
|||||||
|
Kr |
I |
Cs |
Te |
Sr/Ba |
Ru |
La |
Ce |
S1: no Cs,Te gap release S2: low Cs,Te gap release S3: high Cs,Te gap release |
0.34 0.34 1.0 |
2.4E-5 1.0E-2 1.0 |
2.4E-5 1.0E-2 2.5E-1 |
2.4E-5 3.6E-4 2.0E-2 |
2.4E-5 2.4E-5 2.0E-3 |
2.4E-5 2.4E-5 8.0E-5 |
2.4E-5 2.4E-5 2.4E-5 |
2.4E-5 2.4E-5 2.4E-5 |
The first source term in Table I is
the one used by Sandoval, et al. (1983). The second is the same source term with an
additional contribution from the semivolatile gap fraction released from the
fraction of the fuel rods SNL expected would be breached (to take cesium as an
example, a 3% gap fraction multiplied by 0.34 yields 0.0102). The third source term represents the
releases caused by a high-temperature fire following the initial explosion, and
is based on BNL fire release estimates (except for Cs, for which we judged a
lower release fraction to be appropriate).
The cask inventory was based on a
truck cask carrying 4 ten-year-old PWR assemblies, each with a burnup of 50,000
MWD/t. The inventory was generated
using the ORIGEN-S module of the SCALE 4.3 code.
The consequences of a successful
attack in an urban area of very high population density were estimated for the
three source terms in Table I.
Statistical sampling of atmospheric conditions was used in the MACCS
calculations. The population
distribution was the same as that used by SNL in Sandoval, et al. (1983), which is meant to be representative of a densely
populated urban area like New York City (39,000 persons/km2 within
10 km of the accident, steadily decreasing to 380 persons/km2
between 50 and 88 km from the accident).
Results of the calculations are presented in Table II.
TABLE
II
Consequences of Sabotage Events
|
LCFs within 80 km (mean/max) |
Economic Costs (million US$) |
Source term: S1 S2 S3 |
34 / 77 1,480 / 3,880 7,120 / 15,500 |
30 5000 51,000 |
The calculations indicated that for
the source term with no semivolatile gap fraction, about 35 latent cancer
fatalities (LCFs) would result among the population within 80 km of the
accident, which is consistent with the estimate of 4 LCFs (mean) given by
Sandoval, et al. (1983), considering
the former result is twenty years old and used a now-obsolete code based on
radiation risk estimates that have been since revised upward. However, when the gap release source term is
considered, the estimate jumps to nearly 1,500 LCFs, which is on the order of
the results which led NRC to issue the interim embargo against SNF shipments
through urban areas in 1979. Therefore,
the original neglect of the semivolatile gap fraction resulted in an
underestimate of the consequences of the shaped-charge attack by a factor of
40.
The calculated consequences of the
S3 source term show that casualties can be further increased by a factor of
five by relatively simple means, such as setting a fire.
No early fatalities from acute
radiation exposure were predicted for any of the source terms. This was expected because most of the
radionuclides associated with high acute exposures would have decayed to very
low concentrations in 10-year-old SNF.
Conclusions
The apparent lack of concern among
government authorities regarding the threat of radiological sabotage of
transports of highly irradiated materials is unwarranted. A new analysis of the radiological releases
resulting from the breaching of a SNF truck cask with a shaped charge
demonstrates that the original consequence predictions that led NRC to impose
an embargo on SNF shipments in 1979 --- hundreds to thousands of latent cancer
fatalities --- are indeed valid.
Moreover, even greater consequences can be engineered by determined
terrorists without expending significantly greater effort. Consequently, the petition of the State of
Nevada to re-examine the physical protection regulations for SNF transports
should be favorably regarded, and NRC should consider reimposing the embargo on
SNF shipments through urban areas or substantially increasing the protection
requirements for such shipments.
To support this effort, Sandia
National Laboratories should undertake a new research effort to develop more
accurate and realistic release fractions from cask sabotage events. These experiments should be based on
credible terrorist attacks with the goal of maximizing respirable particle
release.
The Nuclear Control Institute will
continue to work vigorously to ensure that stringent physical protection
measures are maintained (or strengthened where appropriate) on all nuclear
facilities and transports that could serve as targets of radiological
sabotage. Otherwise, the current
exclusive emphasis on chemical and biological attack may well invite terrorist
attacks on nuclear materials or facilities as a result of a perception that
they are "soft" targets.
References
[1]. Testimony of Paul Leventhal (President,
Nuclear Control Institute) on the Recommendations of the NRC Safeguards
Assessment Task Force," presented to the U.S. Nuclear Regulatory
Commission, Washington, DC, May 5, 1999.
[2]. State of Nevada, Office of the Attorney
General, "Petition to Institute Rulemaking to Amend Regulations Governing
Safeguards for Shipments of Spent Nuclear Fuel (SNF) Against Sabotage and
Terrorism and To Initiate a Comprehensive Assessment," June 22, 1999.
[3]. Robert J. Halstead and James David Ballard,
"Nuclear Waste Transportation and Security Issues: The Risk of Terrorism and Sabotage Against
Repository Shipments," report prepared for The Nevada Agency for Nuclear
Projects, Carson City, NV, 89710, October 1997.
[4]. U.S. Nuclear Regulatory Commission, "10
CFR Part 73, Physical Protection of Irradiated Reactor Fuel in Transit: Interim
Final Rule," 44 FR 117 (4466), June 15, 1979.
[5]. R.P. Sandoval et al., "An Assessment of the Safety of Spent Fuel
Transportation in Urban Environs," SAND--82-2365, Sandia National
Laboratories, June 1983.
[6]. Finley, N.C. et al., "Transportation of Radionuclides in Urban
Environs: Draft Environmental
Assessment," NUREG/CR-0743 (SAND79-0369), Prepared for the U.S. Nuclear
Regulatory Commission by Sandia National Laboratories, July 1980.
[7]. U.S. Nuclear Regulatory Commission, 10 CFR
Part 73, "Modification of Protection Requirements for Spent Fuel
Shipments," proposed rule, 49 FR 112 (23867), June 8, 1984.
[8]. Sandoval, et al. (1983), op cit.
[9]. Halstead and Ballard, op cit.
[10]. R.J. Travis et al., "A Safety and Regulatory Assessment of Generic BWR and
PWR Permanently Shutdown Nuclear Power Plants," NUREG/CR-6451, prepared
for the U.S. NRC by Brookhaven National Laboratory, August 1997.
[11]. J.P. Hinton et al., "Proliferation Vulnerability Red Team Report,"
SAND97-8203, Sandia National Laboratories, October 1996.
[12]. Declaration of John P. Hinton, Sandia
National Laboratories, Livermore, California, Mayaguezanos Por La Salud Y El Ambiente et al. v. United States of
America et al., March 12, 1998
[13]. U.S. Nuclear Regulatory Commission, Advisory
Committee on Reactor Safeguards, public meeting, April 9, 1999.
[14]. D.L. Chanin and
M.L. Young, Code Manual for MACCS2: Volume I, User's Guide, SAND97-0594,
Sandia National Laboratories, March 1997 (unofficial corrected version)