Mr. Dillon is an independent consultant formerly with the International Atomic Energy Agency

May 16, 2006
AUTHOR: Garry Dillon
Wide Area Environmental Sampling in Iran (PDF) 67.13 KB

Wide Area Environmental Sampling in Iran

Any meaningful negotiated agreement with Iran must, at the very minimum, require Iran to:

1. Unconditionally agree not to acquire or develop nuclear weapons or weapons useable nuclear material or any subsystems or components or any research, development, support or manufacturing facilities related thereto;
2. Submit to the Secretary General and to the Director General of the IAEA a declaration containing complete details of its past activities to produce or acquire special nuclear materials (plutonium and enriched uranium) and nuclear weapons technology, including complete details of external assistance, both offered and provided, as well as related procurement activities.
3. Immediately enter into force the “Additional Protocol” and actively co-operate with the IAEA in its robust implementation for the purpose of verifying the accuracy and completeness of the information provided in respect of Iran’s past nuclear activities and in building ongoing confidence that Iran’s present and future nuclear activities are confined to exclusively peaceful uses.

The IAEA is very well experienced in the verification of the accuracy and completeness of declarations defined in item 2 above and whilst significant uncertainties remain, has already gained considerable knowledge of Iran’s past nuclear activities.

The IAEA has also gained much experience in Wide Area Environmental Sampling (WAES) both through its field and laboratory work in laying the technical groundwork for the Additional Protocol and from the implementation of its plan for the Ongoing Monitoring and Verification (OMV)1 of Iraq’s undertaking in compliance with paragraph 12 of UNSC resolution 687 (1991). This paper addresses the viability of WAES – as defined in Article 18.g of the Additional Protocol -as a means of gaining assurance that all nuclear activities in Iran are known to the IAEA and are subject to routine verification in accordance with Iran’s safeguards agreement with the IAEA.

The context for the implementation of WAES in Iran would be twofold:

1. IRAN is already a potential nuclear weapons state and should Iran so choose, it would be merely a matter of time until it fully developed a production capability for weapons usable nuclear material and its subsequent weaponisation.
2. Iran’s oft declared peaceful nuclear undertakings might well be genuine but pragmatism requires that comprehensive verification measures be implemented, over a substantial period of time, to build the necessary level of international confidence of Iran’s compliance with those undertakings.

The locations and scope of monitoring activities prescribed by the Additional Protocol

The Additional Protocol defines, inter alia, the locations to which the IAEA may gain “Complementary Access2” and specifies the verification measures the IAEA may implement to gain assurance of the absence of nuclear material or nuclear-related activities. The locations fall into three specific categories:

1. Locations not holding, or no longer holding, nuclear material
2. Locations holding material that has not been processed to a level of purity for it to be suitable for fuel fabrication or isotopic enrichment, or holding material that has been exempted from safeguards verification measures by virtue of its non-nuclear use or nuclear material (typically in the form of waste) judged to be unrecoverable.
3. Locations hosting nuclear-related activities but not holding nuclear material.

The verification measures for the three categories comprise a sub-set of the following:

1. Visual observation (common to all three categories)
2. Collection of environmental samples (common to all three categories)
3. Radiation detection and measurement (common to all three categories)
4. Non-destructive measurements and sampling
5. Item counting
6. Application of seals … and other tamper indicating devices
7. Examination of records … of [nuclear] material
8. Other objective measures … agreed by the [IAEA] Board

These locations and verification activities are summarized in Table 1.

It is clear that, under the Additional Protocol, the IAEA’s right of (complementary) access and freedom of choice of verification activities are considerably less than was provided in the case of its OMV plan, implemented in Iraq. Nonetheless, given Iran’s active co-operation, there is enough flexibility in the text of the protocol for the IAEA to be able to implement a verification process that would provide substantial assurance of Iran’s compliance with its undertakings.

In the special context of this paper two Articles of the Additional Protocol are of fundamental importance:

Article 5.c which would require Iran to “… provide the Agency [IAEA] with access to any location specified by the Agency … to carry out location-specific environmental sampling …” and

Article 9 which would require Iran to “… provide the Agency with access to locations specified by the Agency to carry out wide-area environmental sampling …”

Article 9, however, goes on to state that “The Agency shall not seek such access until the use of wide-area environmental sampling and the procedural arrangements therefore have been approved by the Board and following consultations between the Agency and” [the state]

Wide-area environmental sampling is defined in Article 18.g as meaning the collection of environmental samples (e.g., air, water, vegetation, soil, smears) at a set of locations specified by the Agency for the purpose of assisting the Agency to draw conclusions about the absence of undeclared nuclear material or nuclear activities over a wide area. Location-specific environmental sampling differs only in its application being confined “… at, and in the immediate vicinity of a location …” and that the Agency’s conclusions are drawn with respect to that “… specific location …”.

It is clear from the foregoing that a legal basis for the implementation of WAES in Iran exists and with the approval of the IAEA Board of Governors and the co-operation of Iran could be implemented. Furthermore, the text of the Additional Protocol underwrites the fundamental value of environmental sampling as a contributing technology to the IAEA’s ability to draw conclusions regarding the absence of undeclared nuclear material or nuclear activities. However, it is clear that a pre-requisite to the implementation of WAES is a reasonable understanding of the costs involved and the technical resource requirements.

A notional plan for the implementation of WAES in Iran

There is no particular complication to the “front-end” of environmental sampling, it is simply a matter of determining what kind of sample is most appropriate and at which and how many locations the samples should be taken. The premise on which WAES is based is that any significant activities related to the processing of nuclear material would result in a detectable impact on the environment – either from chronic low-level releases or an acute high-level release following a processing malfunction.

In the context of a clandestine enrichment facility WAES would be focused mainly on the detection of uranium but also on related processing elements such as fluorine. Due to its ubiquity, the mere detection of uranium is of little significance unless it is detected in concentrations markedly different from those occurring naturally in the area sampled or the relative abundance of the U235 isotope is greater than .71%.

WAES is further complicated by the fact that in a state such as Iran with a history of uranium processing activities, analysis of deposition samples (such as surface smears or vegetation) would not be able to readily distinguish whether the material deposited was a result of current nuclear activities or originated from past activities. Although vulnerable to re-suspension complications, it is now widely accepted that the sampling of air for the collection of particulate and gaseous matter is the most reliable and unambiguous means of detection of current nuclear activities. A variety of designs of air-samplers exist ranging from those little more sophisticated than a domestic vacuum cleaner to those capable of continuous analysis of the collected matter combined with the capability to transmit the results of that analysis to an headquarters control room.

However, the IAEA’s experience, in Iraq, shows that simplicity of design and robustness of construction are likely to provide the most reliable performance. Ideally, the air-sampling equipment would be housed within a small trailer or road vehicle and would have battery back-up and the capability to transmit alarm annunciations to an appropriate IAEA control and supervision location in the event of loss of power supplies or tampering. The transportability of the air-sampling station enables the grid to be readily adjusted or, if appropriate, completely redesigned.

Nuclear forensics have achieved such extraordinary sensitivities that it virtually impossible to sanitize radioactively contaminated surfaces or to avoid the detection of leakages of radioactive gaseous or liquid effluents. For example analysis of environmental samples – airborne particulate matter, water, deposited or sedimented materials – is capable of detecting the presence of uranium down to a few millionth, billionth, billionth parts of a gram. However, even with such sensitivities it has to be recognized that the concentration of any environmental contamination reduces inversely and non-linearly with the distance from the point of release. The actual reduction would be a function of terrain and the prevailing meteorological conditions.

A detailed topographical / meteorological study would thus be required to determine a practical detection range based on an assessed notional release and the practical limits of sample analysis. It is, of course this “detection range -R” that will determine the grid array of the air sampling stations and thus the related capital equipment costs, in-field service personnel resources costs and analytical costs.

For purposes of this notional plan, it is assumed that air-sampling stations would be set up on a regular square grid with the diagonal separation of the air-sampling stations equal to the detection range. It follows that the grid would be of side R/√2 with a corresponding grid-element area of R2/2. As a first approximation the number of air-sampling stations could be calculated by dividing Iran’s superficial area by the area of a single grid element. However, it would also be necessary to recognize the need for additional sampling stations to cover the perimeter of the grid. Again for purposes of illustration, the number of additional air-sampling stations is derived from the state’s land boundary divided by R/√2.

Iran is not a small country and covers an area of some 1.65 million square kilometers with a land boundary of 5,400km. Based on the foregoing assumptions a sampling network designed around a detection range of 10km would require an unmanageable 33,764 air-sampling stations and even stretching the detection range to 100 kilometres would still require some 400 air sampling stations. As was the case in Iraq it is likely that the relatively high levels of atmospheric dust would require frequent sample changing to avoid blockage of the collecting media. Assuming, therefore, that samples were changed on a bi-weekly basis a 400 station network would generate some 10,400 samples per year.

A cost assessment of 400 station network is shown in Table 2

The data in Table 2 is produced simply to illustrate operational costs and should not be interpreted to suggest that the exampled network is capable of providing meaningful detection sensitivities. Indeed, the mountainous nature of much of the Iranian terrain will complicate the country specific topographical and meteorological study and is likely to indicate the need for a non-uniform grid including areas requiring a more closely spaced grid.

Regardless of these complications, the table does show that the most critical component of overall cost is sample analysis, contributing, as it does, to more than 60% of the costs in the illustrative model. Furthermore, the data do not include the complementary environmental samples (herbage, smears, water etc.) that should be collected. Although these samples could be collected without additional labor or equipment costs they could potentially more than double the analytical load, pushing the total annual cost towards $30 million. Even without this extra burden the number of samples generated, in the Table 2 example, far exceeds the currently available international analytical resources, at the very highest level of sensitivity.

It should also be recognized that at $30 million these notional costs represent about 25% of the total annual operating budget of the IAEA Department of Safeguards, including voluntary contributions from motivated member states. At first glance such costs seem inordinately high. However, it is merely necessary to change the comparator to, for example, the annual cost of the military action in Iraq or the “replacement costs” of Manhattan following the explosion of a 50 kiloton device to make the costs appear to be an entirely worthwhile investment.

The notional case outlined in Table 2 will clearly contain inaccuracies and is presented merely to arrive at an “order of magnitude” costing of WAES in the Iran context. However, many obvious refinements are available:

One such refinement would be to carry out a detailed analysis of Iran, on the basis of a 10km grid, and to weight each grid section with respect to any attributes therein which could contribute to sustaining clandestine nuclear activities. Such attributes would include, for example, access to power and water supplies, population centers, road and rail transport and geological conditions compatible with under-grounding. On the basis of this analysis it would be possible to determine those “high-potential” areas of the country worthy of continuous and intensive monitoring activities – probably less than 10% of the total area. Within the so-termed high-potential areas air-sampling stations would be positioned in conformity with location-specific detection range calculations. Areas of significantly lesser potential would be subject to less intensive sampling and analysis.

Another simple refinement is available in the analytical process in that portions of samples from contiguous locations could be blended and analysed as a composite batch sample. Should analytical results from the composite sample so indicate the individual sample-portions could then be analyzed. It should also be recognized that WAES serves, at least in part, as a deterrent and provided the “target” is unaware, its effectiveness is undiminished regardless of whether all or only a fraction of the samples collected are actually analyzed.

Yet another refinement would be to either complement or entirely replace WAES by multiple location-specific environmental sampling wherein the locations would be chosen of the basis of its high-potential to support undeclared nuclear activities or on the basis of information provided to or independently developed by the IAEA. It is clear that motivated member states should be investing considerable resources in gathering information relevant to Iran’s professed peaceful uses of nuclear energy for example by aerial/satellite surveillance, telecommunications monitoring and export / import monitoring. It is equally clear that those states should be in a position to provide “cues” to the IAEA to identify locations worthy of location-specific environmental sampling and as appropriate complementary access.

Recommendations

1. If not already “work in progress” the IAEA should commission a working group, of internal and external experts, to design a plan for the implementation of WAES in Iran based on a detailed analysis of the topographical and meteorological characteristics of its various regions. The plan should include realistic cost analyses and address the various options available between full-scope WAES and the targeted/cued implementation of multiple location-specific environmental sampling campaigns

2. Motivated IAEA member states should re-evaluate their relevant information gathering system and establish formal pathways for the prompt transmission of information to the IAEA.

3. Those states having high sensitivity analytical capability – principally USA, UK and France -should invest significantly in the expansion and further development of those capabilities to ensure that the international community will be in a position to satisfy the demand in the event that it becomes necessary/appropriate to implement WAES in Iran or elsewhere.

4. The IAEA Board of Governors should address the question of funding for the implementation, as necessary, of WAES. Too often in the past too many IAEA member states have been more focused on the financial savings that could result from the evolution of safeguards technologies and approaches. It is time to recognize that the cost of international nuclear material safeguards is trivial when compared to the financial burden of pragmatic “worst case scenarios” that might result from failure to implement robust safeguards measures at the leading edge of technological excellence.

Table 2 – Notional cost assessment of a 400 air-sampling station network

Detection range (km)	100
Number of air sampling stations	400
Equipment and installation cost per unit	$10,000
Amortization period (years)	3
Equipment and installation costs per year	$1,333,000
Number of service visits/year per installation	26
Servicing capacity (units/day – 2 person team)	3
Servicing resources required (person-years3)	40
Field Office resource requirements (person-years)	4
Personnel costs including travel and accommodation	$5,000,000
Number of samples collected for analysis	10,400
Cost per analysis	$1,000
Total analytical costs	$10,400,000
Total annual costs including equipment amortization	$16,733,000
Notional overall annual cost/ air-sampling station	$41,833
Notional overall cost per analytical result	$1,610

The above data do not include the complementary environmental samples (herbage, smears, water etc.) that should be collected. Although these samples could be collected without additional labor or equipment costs they could potentially more than double the analytical load, pushing the total annual cost towards $30 million. Even without this extra burden the number of samples generated, in the above example, far exceeds the currently available international analytical resources, at the very highest level of sensitivity.

Endnotes

1. As approved in Security Council resolution 715 (11 October 1991)

2. Access to locations other than those containing declared nuclear materials

3. Assuming a 3 month tour of duty and a 6 day working week and taking into account annual leave, official holidays and compensatory time off week 1 person year equates to 170 inspection days

TABLE 1

SUMMARY OF LOCATIONS SUBJECT TO COMPLEMENTARY ACCESS AND PERMITTED VERIFICATION MEASURES