MATERIAL PROTECTION, CONTROL AND ACCOUNTING (MPC&A) AT THE U.S. MOX FUEL FABRICATION PLANT: MERELY AN AFTERTHOUGHT?

Full consideration of safeguards and physical protection issues early in the design of nuclear facilities is a fundamental principle of good engineering. It is widely recognized that careful planning and integration of material protection control and accounting (MPC&A) systems into plant design can greatly facilitate application of effective safeguards and robust physical protection. On the other hand, a lack of attention to such considerations during facility design can lead to significant problems later requiring expensive retrofits, a good example being the design flaws that caused severe plutonium holdup problems at the Plutonium Fuel Production Facility in Japan. These lessons, based on decades of experience in nuclear material processing, apparently have been ignored by DOE/NNSA and consortium Duke Cogema Stone and Webster (DCS), the contractor hired to construct a mixed-oxide fuel fabrication facility (MFFF) at the Savannah River Site (SRS). In February 2001, DCS submitted an application to the Nuclear Regulatory Commission (NRC) for authorization to begin construction of the MFFF. The application, called a Construction Authorization Request (CAR), contains general design information but virtually no detail about MPC&A systems for the facility. DCS has argued that it need only supply such information when it applies for a license to operate the MFFF. The CAR has not had the benefit of IAEA review because the U.S. government has not yet decided whether to place the MFFF on the list of facilities eligible for IAEA safeguards. Last year, the group Georgians Against Nuclear Energy (GANE) intervened in the CAR licensing proceeding, proffering more than a dozen contentions highlighting inadequacies in the CAR. An NRC Atomic Safety and Licensing Board (ASLB) panel accepted several of GANE’s contentions for litigation, including those that question the CAR’s lack of information about MPC&A systems. In a separate filing after the September 11 terrorist attacks, GANE requested that the Commission suspend the CAR proceeding until the MFFF can be redesigned to withstand a post-Sept. 11 design basis threat that includes jet aircraft attack. This paper will provide an overview and update of the CAR adjudicative proceeding, with an emphasis on the admitted safeguards and physical protection contentions.