ML003739369

Regulatory Guide 5.67 (Draft Issued as DG-5002) Material Control & Accounting for Uranium Enrichment Facilities Authorized to Produce Special Nuclear Material of Low Strategic Significance

ML003739369
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Issue date:	12/31/1993
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RG-5.67
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U.S. NUCLEAR REGULATORY COMMISSION December 1993 REGULATORY GUIDE OFFICE OF NUCLEAR REGULATORY RESEARCH REGULATORY GUIDE 5.67 (Draft was Issud as DG-5002)

MATERIAL CONTROL AND ACCOUNTING FOR URANIUM ENRICHMENT FACILmES AUTHORIZED TO PRODUCE SPECIAL NUCLEAR MATERIAL OF LOW STRATEGIC SIGNIFICANCE USNMC REGUIATORY GUIDES The guldes are Issued In the following ten broad divisions:

Regulatory Guides are Issued todescribe and make available to the pubilc methods acceptable to the NRC staff of implementing specific parts of 1. Power Reactors 6. Products the Cormnmission's regulations, to delineate techniques used by the staff 2. Research and Test Reactors 7. Transportation in evaluating specific problems or postulated accidents, or to provide 3. Fuels and Materials Facilities 8. Occupational Health guidance to applicants. Regulatory Guides are not substitutes for regula- 4. Environmental and Siting 9. Antitrust end Financial Review tions. and compliance with them Is not required. Methods and solutions 6. Materials and Plant Protection 10. General different from those set out In the guides will be acceptable If they provide a basis for the findings requisite to the Issuance or continuance of a per-mit or license by the Commission. Copies of issued guides may be purchased from the Government Printing Office at the current GPO price. inforrnation on current GPO prices may This guide was issued after consideration of comrnents received from the be obtained by contacting the Superintendent of Documents, U.S.

public. Comments and suggestions for Improvements In these guldes are Government Printing Office, Mali Stop SSOP, Washington, DC encouraged at all times, and guldes will be revised, as appropriate, to 20402-32, telephone (202)512-2249 or (202)512-2171.

accommodate comnnents and to reflect naw information or experlence.

Written comments may be submitted to the Rules Review and Directives Issued guides may also be purchased from the National Technical infor-Branch, DFIPS, ADM, U.S. Nuclear Regulatory Comnission, Washing- mation Service on a standing order basis. Details on this service may be ton, DC 20668-0001. obtained by writing NTIS, 5285 Port Royal Road, Springfield, VA 22161.

I I  : 1I Ii

CONTENTS Page A. INTRODUCTION .................................................................. 1 B. DISCUSSION ....................................................................... 1 C. REGULATORY POSITION .......................................................... 2

1. Performance Objectives .......................................................... 2

2. Organization ................................................................... 4

3. MC&A Procedures .............................................................. 5

4. Measurements . ................................................................ 5

5. Measurement Control Program .................................................... 6

6. Statistics . ..................................................................... 9

7. Physical Inventories ............................................................. 10

8. Item Control . .................................................................. 12

9. Shipper-Receiver Comparisons .................................................... 13

10. Assessment of the MC&A Program ................................................ 14

11. Resolving Indications of Unauthorized Production of Enriched Uranium and Missing Uranium 15

12. Program for Precluding and Detecting Unauthorized Production of Enriched Uranium .... ... 17

13. Recordkeeping . ................................................................ 19 D. IMPLEMENTATION ............................................................... 20 REGULATORY ANALYSIS .............................. ................................ 21 iii II

A. INTRODUCTION 6. Resolve indications of unauthorized produc-tion of uranium of low strategic significance; Section 74.33, "Material Control and Accountin g 7. Provide information to aid in the investigation for Uranium Enrichment Facilities Authorized TiD of missing uranium; Produce Special Nuclear Material of Low Strategi C Significance," of 10 CFR Part 74, 'Material Contrc 8. Provide information to aid in the investigation and Accounting for Special Nuclear Material," con of the production of uranium enriched to 10 tains the material control and accounting (MC&A ,) percent or more in the isotope U-235; and requirements applicable to enrichment facilitie S 9. Provide information to aid in the investigation authorized to produce and possess more than 1 effec of unauthorized production of uranium of low tive kilogram of special nuclear material (SNM) of loxIV strategic significance.

strategic significance.

This regulatory guide describes methods accept-Section 74.33 establishes MC&A performanc e able to the NRC staff for achieving the general per-objectives to protect against, detect, and respond tio formance objectives in 10 CFR 74.33. This regulatory the use of uranium enrichment equipment for the unL- guide discusses each important component of a licen-authorized production of SNM of moderate or higiFh see's MC&A program and describes methods that may strategic significance or the introduction of undeclaredd be used to satisfy the rule.

source material (SM) into the process equipment fo ir the unauthorized production of uranium of low strate Any information collection activities mentioned in gic significance. In addition, 10 CFR 74.33 require,s this regulatory guide are contained as requirements in licensees to provide information that will aid in the in 10 CFR Part 74, which provides the regulatory basis vestigation of missing uranium or unauthorized enrich for this guide. The information collection require-ment of uranium. Section 74.33 also specifies pet r- ments in 10 CFR Part 74 have been approved by the formance objectives and required system features an' ad Office of Management and Budget, Approval No.

capabilities that are consistent with MC&A require 3150-0123.

ments applicable to other NRC-licensed activities in volving the possession and use of more than 1 effectiv e B. DISCUSSION kilogram of SNM of low strategic significance. Licen sees and applicants are required by 10 CF]R The MC&A requirements for uranium enrich-74.33(b) (1) to submit a fundamental nuclear materikal ment facilities specified in 10 CFR 74.33 have been control plan describing how the performance objec established to provide adequate safeguards for NRC-tives, system features and capabilities, and record I- licensed materials at such plants. The basis for such keeping requirements will be met. The general pet r- requirements is that the safeguards must be at least formance objectives, set forth in 10 CFR 74.33(a) equivalent to those required for plants possessing ma-that must be met by the licensee's MC&A prograr n terial of equivalent safeguards significance. Since the are: requirements set forth in 10 CFR 74.33 are perform-ance-based, this regulatory guide has been developed

1. Maintain accurate, current, and reliable infoi r- to describe one approach to meeting those require-mation of and periodically confirm the quanti ments. The rationale for the approach is that the en-ties and locations of source material and spe richment levels that are authorized for NRC-licensed cial nuclear material in the licensee' S enrichment plants will be the same general level as for possession; licensees authorized to fabricate low enriched uranium fuel. However, enrichment facilities differ from fabri-

2. Protect against and detect production of ura cation facilities in that they possess equipment that nium enriched to 10 percent* or more in the could be used to produce SNM of moderate or high isotope U-235; strategic significance. For this reason, the MC&A sys-tem for enrichment facilities must contain additional

3. Protect against and detect unauthorized prc safeguards features to protect against and detect such duction of uranium of low strategic signifi '~ activities.

cance; Since 10 CFR 74.33 is a performance-based regu-

4. Resolve indications of missing uranium; lation, it is the objectives rather than the means for achieving them that are defined in 10 CFR 74.33(a).

5. Resolve indications of production of uraniur n Thus, applicants or licensees are free to decide how to enriched'to 10 percent or more in the isotop e design, manage, and operate their MC&A systems.

U-235 (for centrifuge enrichment facilities This regulatory guide is not intended to be an exhaus-this requirement does not apply to each cai s- tive description of all possible methods a licensee cade during its start-up process, not to excee' d might use to achieve the desired objectives. Instead, the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />); this regulatory guide provides guidance on an accept-able approach for achieving the objectives in 10 CFR

'AU enrichment levels specified in this guide should be treated aLS 74.33(a). Other alternatives are acceptable provided weight percent and not atom percent. they satisfy the requirements of 10 CFR 74.33.

5.67-1 I I

C. REGULATORY POSITION 74.33(c) (4) (i)). This inventory provides a snapshot of the amount of material in process at a given time.

1. PERFORMANCE OBJECTIVES Regulatory Position 7 provides guidance on the con-duct of dynamic physical inventories.

Each licensee subject to 10 CFR 74.33 is required to implement and maintain an MC&A system that is 1.1.4 Yearly Plant Physical Inventory capable of achieving the performance objectives of 10 CFR 74.33(a). Once a year, at intervals not to exceed 370 days (10 CFR 74.33(c) (4) (i)), the licensee must conduct a total plant inventory and must be able to detect, with 1.1 Maintain Accurate, Current, and Reliable at least a 90 percent power of detection, an actual loss Information of and Periodically Confirm or theft of a detection quantity (DQ) that may have the Quantities and Locations of Source occurred since the last yearly inventory. DQ is a site-Material and Special Nuclear Material in specific parameter that depends upon the amount of the Licensee's Possession material processed annually at each facility. To satisfy the requirement in 10 CFR 74.33(c) (4) (i) to confirm As used in this guide, accurate information means the quantity and location of all SNM and SM currently that the amounts and locations of the material in ques- possessed by the enrichment facility, the licensee must tion are based on records and measurements; current conduct both a dynamic (nonshutdown) physical in-information means that the licensee knows, through ventory of the uranium and U-235 contained within MC&A records, how much of this material is pos- the enrichment processing equipment and a static sessed at any given time and its location (i.e., in proc- physical inventory of all other uranium and U-235 ess or in storage); and reliable information means that that is not within the processing equipment. Criteria the quantities and locations of all classes of material pertaining to physical inventories are discussed in and items listed in the accounting records are, in fact, Regulatory Position 7. The performance of a total correct and verifiable. plant inventory should include:

1.1.1 Shipments and Receipts 1. Measuring (or, when direct measurement is not feasible, using indirect measurements) all The licensee must account for all $NM and SM SNM and SM quandties on hand that have received or shipped. This should be accomplished by not previously been measured in their current maintaining reliable records that are based on meas- form, ured values (10 CFR 74.33(c)(2)). Guidance- on shipper-receiver procedures and the analysis of 2. Verifying the physical presence of all uniquely shipper-receiver data is provided in Regulatory Posi- identified SNM and SM items that the ac-tion 9 of this regulatory guide. counting records indicate are on hand,

3. Measuring a sample of randomly selected un-1.1.2 Monitoring Material Movements encapsulated and unsealed items, based on a The monitoring program must include the use of statistical sampling plan, to confirm the previ-item control procedures to monitor the location and ous measurements of SNM and SM contained integrity of items and ensure that all SM and SNM in each of these items, which in turn will be quantities of record associated with receipts, ship- used as the basis for accepting or rejecting the ments, discards, and ending inventory are based on total SNM and SM contained in all such measurements (10 CFR 74.33(c) (6)). The monitoring items, and program should also include process-monitoring pro- 4. Verifying the integrity of all encapsulated cedures to maintain current knowledge of the total items and all tamper-safed' items.

uranium and U-235 within the enrichment process.

Guidance on the item control program is provided in Regulatory Position 8 of this regulatory guide, while 1.2 Protect Against and Detect Production of guidance on measurements and measurement control Uranium Enriched to 10 Percent or More programs are in Regulatory Positions 4 and 5, respec- in the Isotope U-235 tively. Monitoring the quantity of material in process The licensee should have a program for monitor-may involve the use of production and quality control ing the isotopic composition of product and depleted data. A detailed and accurate recordkeeping system uranium streams, independent of operations, that pro-for MC&A and production data must be maintained to vides high assurance of timely detection of production provide knowledge of the quantity of material on a of uranium enriched to 10 percent or more in the iso-timely basis (10 CFR 74.33(d)). tope U-235 before SNM of moderate strategic signifi-cance could be produced if such production could be 1.1.3 Dynamic Physical Inventories achieved within 370 days. The licensee may also want In order to verify that the controls descn1bed in "Tamper-safing" Is defined in1O CFR 74.4 as the use of de-Regulatory Position 1.1.2 have been effective, the vices on containers or vaults In a manner and at a time that ensures a clear indication of any violation of the Integrity of licensee must perform a dynamic physical inventory at previously made measurements of SNM within the container intervals not to exceed 65 days (10 CFR or vault.

5.67-2

to consider monitoring other parameters besides en cators means that the licensee has investigated all in-richment levels and instituting a personnel monitorin g formation relevant to the cause of the indicator and program to observe activities in the process areas tiD has concluded that a theft or loss of SNM or SM has protect against the production of uranium enriched tiD not occurred. As stated in 10 CFR 74.33(c) (6), only 10 percent or more in the isotope U-235. The enrich indications that suggest a possible loss of items or of ment technology used may determine the extent of th e material from items involving 500 grams or more of program. For example, a limited program for a gase U-235 need be investigated.

ous diffusion technology plant would be appropriat e because it is difficult for a few people to recon- figur e The procedures that the licensee should under-the equipment to produce higher enrichments in a take to resolve an indication of missing uranium de-short time, while a more extensive program for a cen l- pend on the nature of the indicator. In some cases, the trifuge technology plant would be appropriate becaus e resolution process would begin with a thorough review of the ease of reconfiguring the machines to produc e of the MC&A records to locate blatant errors such as higher enrichments in a short period of time. The pro omissions of entire items, data entry errors in com-gram can use nondestructive assay with fixed detec puter programs or on records, incorrect entries, tran-tors, portable detectors, or UFO samples taken antd scription errors, errors in estimating the amount of ma-analyzed for U-235 concentration. terial holdup in equipment, or calculational errors. A detailed examination of the MC&A records for the ap-The program must be managed and maintainedd plicable material type should identify gross errors. The independent of the operations (production) unit or r- next stage in the resolution process could be to isolate ganization (10 CFR 74.33(c) (1) (ii)), but it may mak e the storage area or the portions of the process that ap-use of production and quality control data that ar e pear to be involved. Once this is accomplished, all the normally generated and used by production personI- information that contributed to the determination of nel. Additional guidance for this program is provide' d the SM and SNM quantities for that storage location in Regulatory Position 12 of this regulatory guide. or process stream should be verified. If there is still no resolution, the licensee should consider sampling and The NRC Operations Center must be notifie' d remeasuring the applicable material in the applicable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of discovery of any actual production cif storage area or process stream to verify the quantities.

uranium enriched to 10 percent or more in the isotop e If the investigation of an indication results in a deter-U-235 as required by 10 CFR 74.11. For centrifug e mination that an actual loss or theft has occurred, the enrichment facilities, this requirement does not appi y loss or theft must be reported to the NRC in accor-to each cascade during its start-up process, not to e), dance with 10 CFR 74.11. Additional guidance on ceed the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. resolution of indications of missing uranium is pre-sented in Regulatory Position 11.

1.3 Protect Against and Detect Unauthorized Production of Uranium of Low Strategic 1.5 Resolve Indications of Production of Significance Uranium Enriched to 10 Percent or More h in the Isotope U-235 A program must be implemented that will, wit high assurance, protect against and detect the urk- A formalized program designed to resolve indica-authorized production of uranium of low strategi ic tions of the production of uranium enriched to 10 per-significance that is not included in the facility' s cent or more in the isotope U-235 must be developed accounting records (10 CFR 74.33(a)(3)). The prcD- (10 CFR 74.33(a) (5)). Resolution of such indications gram should be capable of detecting the introductio n means that the licensee has investigated all informa-of feed material not declared or recorded in the faci il- tion relevant to the cause of the indicator and has con-ity MC&A records. The program must be manage d cluded that enrichment of uranium to 10 percent or and maintained independently of the production cor more in the isotope U-235 has not occurred. Since operations organizational unit (10 CF.R unauthorized enrichment might not be detected on a 74.33(c) (1) (ii)), but should not be excluded from u!5- timely basis through the conduct of the static physical ing process monitoring or production control data an d inventories or periodic dynamic physical inventories, equipment. Additional guidance, for this program is the resolution process should include investigating all provided in Regulatory Position 12. the information that contributed to the indication of unauthorized enrichment. Upon receipt of an indica-Pursuant to 10 CFR 74.11, discovery of actual urn- tion that uranium may have been or is being enriched authorized production of uranium of low strategic silI~ to 10 percent or more, the licensee is required by 10 nificance must be reported to the NRC Operatior 's CFR 74.33(a) (5) to take appropriate actions to inves-Center within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. tigate and resolve the indicator. Material contained in any suspect process equipment or piping or in a sus-1.4 Resolve Indications of Missing Uranium pect container should be measured to determine its U-235 concentration. If the indication was generated A formalized program to resolve any indicatio n by instrumentation or measurements, the instruments that uranium SM or SNM is missing must be deve I- or measurement systems used for monitoring should oped (10 CFR 74.33(a) (4)). Resolution of such ind i- be examined to determine whether they are calibrated 5.67-3 II

and functioning properly. An examination of the proc- indications of unauthorized production of uranium of essing equipment should be performed to ensure that low strategic significance is included in Regulatory Po-unauthorized modifications have not been made. The sition 11.

presence of uranium enriched to 10 percent or more should be verified through remeasuring the material 1.7 Provide Information To Aid in the in question, whether in item form or in process Investigation of Missing Uranium, the equipment. Production of Uranium Enriched to 10 Percent or More in the Isotope U-235, or If the resolution process results in a determination the Unauthorized Production of Uranium that unauthorized enrichment of uranium to 10 per- of Low Strategic Significance cent or more in the isotope U-235 has actually oc-curred, this condition must be reported to the NRC As previously noted, the detection of any actual according to 10 CFR 74.11. For centrifuge enrich- loss or theft of SNM, or any actual unauthorized pro-ment facilities, this requirement does not apply to each duction of enriched uranium, is reportable under 10 cascade during the start-up process, not to exceed the CFR 74.11. Such reports, depending upon the serious-first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ness of the material facts, may result in investigations by the NRC or other government agencies. The pur-Guidance on resolution of indications of uranium poses of such investigations would be to recover any enriched to 10 percent or more is presented in Regula- lost or stolen material, to secure and control any unau-tory Position 11. thorized material produced, and to identify and bring to justice the individuals involved. NRC licensees are 1.6 Resolve Indications of Unauthorized required by 10 CFR 74.33(a)(7), (a)(8), and (a)(9)

Production of Uranium of Low Strategic to provide any information, particularly the relevant Significance information contained in the MC&A records, to assist the NRC or other government agencies in their investi-A formalized program designed to resolve indica- gations.

tions of the production of unauthorized uranium enriched to less than 10 percent in the isotope U-235 2. ORGANIZATION must be developed and followed (10 CFR 74.33 (a) (6)). Resolution of such indicators means that the 2.1 Corporate Organization licensee has investigated all information relevant to the At least one corporate-level official should have cause of the indicator and has concluded that un- responsibilities pertaining to the control and account-authorized (i.e., undeclared and clandestine) produc- ing of all SM and SNM possessed by the licensee (10 tion of uranium enriched to less than 10 percent in the CFR 74.33(c)(1)(i)).

isotope U-235 has not occurred.

Indicators of unauthorized production of uranium 2.2 Facility Organization of low strategic significance can come from many dif- A comprehensive facility management structure ferent sources, some of which are listed in Regulatory should be developed (10 CFR 74.33(c)(1)). This Position 11.2. Therefore, the resolution process will structure should clearly establish where the responsi-be dictated by the type of indicator that occurs. For bility lies for the (1) overall MC&A program, (2) SM example, if an employee reports that there appears to and SNM custodianship, (3) receiving and shipping of be an excess of UFe feed cylinders in a storage area, SM and SNM, (4) analytical laboratories, (5) physical the resolution process might include verifying the re- inventories, (6) monitoring programs to protect port and making a detailed analysis of shipping and against and detect unauthorized enrichment activities, receiving records as well as production records. On the and (7) onsite nuclear material handling operations.

other hand, if it is discovered that the rate of enriched uranium production differs from scheduled produc- The interrelationships of facility positions outside tion, it may be appropriate to sample and measure de- the MC&A organization that have responsibilities re-pleted UFO containers to determine whether the lating to MC&A activities (such as sampling, bulk U-235 concentration of the depleted uranium is con- measurements, analytical measurements) should be sistent with the authorized and declared production of identified within the management structure.

enriched uranium.

2.3 MC&A Organization In the event of any of these or other indications of unauthorized production of uranium enriched to less A single individual should be designated as the than 10 percent in the isotope U-235, the licensee overall manager of the MC&A program. In order to should determine the cause of the indicator and con- ensure independence of action and objectivity of deci-clude whether or not unauthorized production has oc- sion making, the MC&A manager should either report curred or is under way. A licensee determination that directly to the facility manager or report to an indi-unauthorized production of uranium of low strategic vidual with no production responsibilities who reports significance has taken place is reportable according to directly to the facility manager (10 CFR 10 CFR 74.11. Additional guidance on resolution of 74.33(c)(1)(ii)).

5.67-4

The responsibilities and authority of each supen vi- 3. MC&A PROCEDURES sor and manager should be established for the varioiLIS Approved written MC&A procedures must be de-functions within the MC&A organization (10 CF~R veloped and periodically reviewed (10 CFR 74.33(c)(1)(iii)). Careful consideration should Ibe 74.33(c) (1) (iv). These procedures should address the given to how the activities of one functional unit iDr following topics:

individual serve as a control over or check the actih ties of other units or individuals. The MC&A manage er

• Accountability record system, should have the responsibility for reviewing and aj proving all written MC&A procedures, both with in 0 Sampling and measurements, and outside his organization. MC&A managers shou.Id 0 Measurement control program, be appointed to oversee (1) the nuclear material a counting program, (2) the measurement control pri D-

• Item control program, gram, (3) the item control program, (4) the monito ing programs, and (5) the statistical program.

• Static and dynamic physical inventories, Whenever more than one key MC&A function is

• Investigation and resolution of loss indicators, assigned to the same person, specific procedureDs 0 Investigation and resolution of indicators sug-should be developed to preclude such things ,as gesting possible unauthorized enrichment ac-(1) performance of accounting or record control fun Lc- tivities, tions by persons who also generate the associateId source data and (2) any person having sole authori ty 0 Monitoring program to detect unauthorized to evaluate or audit information for which he or she is enrichment activities, responsible (10 CFR 74.33(c)(1)(iii)).

• Determination of the standard error of the in-ventory difference (SEID), active inventory, 2.4 MC&A System and inventory difference (ID),

In order to maintain clear overall responsibility f<or 0 MC&A recordkeeping system, and MC&A functions (10 CFR 74.33(c)(1)(i)), respons1i-

• Independent assessment of the effectiveness bility for the following MC&A activities should be e:s- of the MC&A program.

tablished:

1. Overall MC&A program management, 4. MEASUREMENTS

2. Measurements, 4.1 Measurement Systems

3. Accountability records, Measurement systems and measurement proced-ures must be developed in order to meet the systems

4. Measurement control and statistics, features and capabilities of 10 CFR 74.33(c)(2) and (3). A measurement system can be defined as any in-

5. Item control, strument or device, or combination of devices, used to derive a mass, volume, uranium element concentra-

6. Physical inventories, tion, U-235 isotopic concentration, or U-235 con-tent. Parameters that are important to most measure-

7. Custodial responsibilities (SM and SNM sto r- ment systems include the measurement device or age and movement controls), equipment used, standards used for calibration, and standards used for control. For analytical laboratory

8. Monitoring program for detecting unautho r- measurements, sampling equipment and technique ized enrichment activities, used, sample aliquoting technique, and sample pretreatment methodology are often important pa-

9. Investigation and resolution of indicators (sul 9- rameters.

gesting possible loss or possible unauthorize d enrichment activities),

4.1.1 Bulk Measurement Systems

10. Receiving and shipping of SM and SNM, For each mass (weight) measurement system, a decision should be made as to the weighing device, the

11. Analytical laboratories, and type of containers weighed, the material within the containers being weighed, the capacity of the weighing

12. MC&A recordkeeping system and controls. device, the range to be utilized, and the sensitivity of the device.

Policies, instructions, procedures, duties, respor sibilities, and delegations of authority should be deve1- For each volume measurement system, the vessel oped to ensure that separation and overchecks a!re (tank, column, etc.) to which the measurement built into the MC&A system (10 CF R applies, the capacity of the vessel, the material being 74.33(c) (1) (iii)). measured (including uranium and U-235 5.67-5 II

concentrations), the volume-measuring devices, and 74.33(c) (1) (iv)). The organizational units responsible the sensitivity and range of operation of the system for the preparation, revision, and approval of the should be considered. measurement procedures should be clearly identified.

A periodic review of the measurement procedures 4.1.2 Analytical Measurement Systems must be conducted (10 CFR 74.33(c)(1)(iv)). Meas-For each analytical (laboratory) measurement sys- urement procedures should be approved by the overall tem to be used, the following should be considered: MC&A manager and by the manager of the organiza-tional unit responsible for performing the measure-

1. Type of material or chemical compound (e.g., ment. Measurement procedures should also be ap-UF 6 , uranium alloy, U3 08 , uranyl nitrate solu- proved by the measurement control program manager.

tion) being measured,

5. MEASUREMENT CONTROL PROGRAM

2. Characteristics to be measured (e.g., grams uranium per gram sample, U-235 isotopic 5.1 Organization and Management concentration),

3. Analytical method used, The organization and management of the meas-urement control program should contain a measure-

4. Sampling technique, ment quality assurance function. Independence from the analytical laboratory and from other units per-

5. Sample handling (i.e., pre-analysis sample forming either sample taking or measurements should storage and treatment), be maintained (10 CPR 74.33(c)(1)(iii)). The meas-

6. Measurement interferences (e.g., impurities), urement control program manager should be at a man-and agement level that is sufficient to ensure objectivity and independence of action. Thus, the measurement

7. Expected measurement uncertainty. control program manager should either report directly to the overall MC&A manager or, if in a different or-4.1.3 NDA Measurement Systems ganizational unit, be on the same level as the MC&A manager.

For each nondestructive assay (NDA) measure-ment system to be used, the following should be con- The measurement control program must be man-sidered: aged to ensure adequate calibration frequencies, suffi-cient control of biases, and sufficient measurement

1. The NDA equipment package (detector and precision to achieve the capability required in 10 CFR electronics), 74.33(c) (3).

2. The type of container being measured, 5.1.1 Functional Relationship

3. SM or SNM material type within the con-tainer, The relationship and coordination among the measurement control program manager, the analytical

4. Characteristics being measured, laboratory, and any other groups performing measure-ments should be defined clearly (10 CFR

5. Measurement configuration (e.g., source to 74.33(c) (1)(i)). There should be adequate assurance detector distance, collimation, and shielding), that the measurement control program manager has

6. Calculational method, and the authority to enforce all applicable measurement control requirements.

7. Expected measurement uncertainty.

5.1.2 Procedures 4.2 Measurement Uncertainties The measurement control program procedures must be established and maintained (10 CFR 74.33(c)

Special attention should be given to the expected measurement uncertainties for each measurement sys- (1) (iv)). All the currently applicable written proced-tem, for example, the variance from calibration, the ures pertaining to measurement control and measure-ment quality assurance should be reviewed annually.

variance from sampling, and the random error compo-nents. The smaller each of these components can be Responsibility for preparation, revision, and approval made, the greater the likelihood that the performance of the procedures should be assigned. Individual objectives of 10 CFR 74.33 will be met. The units in measurement control program procedures should be documented and approved by the measurement con-which errors are expressed should be consistent with other sources of uncertainty. trol manager (10 CFR 74.33(c)(1)(iv)). At a mini-mum, the procedures should address:

4.3 Measurement Procedures 1. Calibration frequencies and methods, A set of approved written measurement proce- 2. Standards used for calibration (description dures must be developed and followed (10 CFR and storage controls),

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3. Standards used for control (obtaining or pre. 3. Protection and control of calibration stan-paring standards and traceability of stan- dards to maintain the validity of their certified dards), or assigned values, and

4. Control standard measurements, 4. The range of calibration for each measure-ment device or system and the minimum num-

5. Replicate sampling and replicate measure. ber of calibration runs (observations) needed ments, to establish a calibration.

In general, there are two types of measurement

6. Control limits and control responses, systems-those that are recalibrated periodically and

7. Generation and collection of control data, those that are calibrated each time the system is used, and based on one or a few measurements of representative standards. The latter type of calibration is often re-

8. Recordkeeping controls and requirements. ferred to as "point-calibration" and is regarded as be-ing bias-free. In the former case, the calibration stan-dards need not be representative because system bias 5.1.3 Contractor Program Reviews is estimated from the periodic measurement of repre-If measurement services are provided by an out, sentative control standards. For point-calibrated side contractor or company offsite laboratory, a review measurement systems, the following calibration proce-program should be developed to monitor the offsitt dures should be followed.

measurements (10 CFR 74.33(c) (3) (iii)). The pur 1. The standard or set of standards used to cali-pose of such a program is to ensure that the contractor brate the measurement system should be rep-or offsite laboratory has an acceptable measuremen resentative of the process unknowns that are control program to the extent that use of the contrac measured by the system. That is, the repre-tor's measurements will not compromise the licensee' s sentative calibration standard should undergo ability to meet any measurement or measurement con all the measurement steps in the same manner trol requirement contained in 10 CFR 74.33(c). Ar that the unknowns do.

initial review of the contractor's measurement contro program should be conducted prior to licensee use o f 2. One or more calibration standards should be measurements performed by the contractor or offsitA processed (measured) along with each un-laboratory. known or set of unknowns measured. That is, both the standard and the unknown are meas-All contractor or offsite laboratory review finding ,s ured at the same time with the same person and recommendations should be documented an( measuring both the standard and the un-submitted to both the measurement control progran known.

manager and the overall MC&A manager in a timeld fashion. The two managers should arrive at an agree 3. The measurement values assigned to the proc-ment as to what corrective actions, if any, need to be ess unknowns are derived from the measure-taken, based on their evaluation of the report, an( ment response observed for the standard that transmit these findings to the contractor or offsiti was measured along with the unknowns.

laboratory in writing. Measurements performed b:

4. The measurement response for each unknown such contractors or offsite laboratories should not be used until the licensee has verified that the corrective should fail within plus or minus 10 percent of actions have been instituted. the response for a standard measured at the same time as the unknown. For unknowns of The persons who conduct a contractor reviei w very low concentration, the measurement re-need not be employed by the licensee, but they shoul(d sponse should fall within plus or minus 4 stan-not be employed by, or in any way be associated with dard deviations of the response for a standard the contractor or offsite laboratory so that the inde measured at the same time as the unknown.

pendence of the conclusions may be maintained. For systems that are range-calibrated, SM or SNM accountability values should not be based on 5.2 Calibrations measurements that fall outside the range of calibra-tion. The calibration standards for range-calibrated A calibration program that contains approved pro systems need not be representative of the process ma-cedures for the following should be developed: terial or items to be measured by the calibrated device or system. It is the primary measurement device, not

1. Calibration frequency for each measuremelnIt necessarily the entire measurement system, that needs device or system, to be calibrated. This is particularly true when the pri-mary measurement device is common to two or more

2. Identification of the reference standards use, d measurement systems. For example, the Davies &

for calibration of each measurement device oir Gray titration method is often used to analyze samples system, of different uranium materials to determine uranium 5.67-7 I

concentration. In this case, two or more measurement

• Is a particular bias likely to be long term, short systems involving different sampling methods, differ- term, or cyclic in nature?

ent sample pretreatment methods, and different con-trol standards are being utilized. The potassium di-

• Is bias a function of the process measurement chromate titrant is, however, common to all systems, values over the range of calibration? That is, and it is the titrant that is calibrated (or standardized) does the relative percent bias vary over the with a reference standard such as certified U3 08 or range of calibration?

certified uranium metal.

• What controls or procedures are needed to In the case of nonconsumable calibration stan- ensure that sampling or aliquoting of the dards such as weight standards, the frequency of control standard is representative of the sam-recertification should be given special consideration. pling or aliquoting of the process material?

The recertification frequency should depend on how

• How similar, in terms of chemical composi-often the standards are handled, the standards' stabil- tion, uranium concentration, density, homo-ity, and the adequacy of the controls used to maintain geneity, and impurity content, should the con-the integrity of the standards. Biannual recertification trol standards be relative to the process of such standards is usually acceptable. unknowns?

5.3 Control Standard Program 5.4 Replicate Program For those measurement systems that are not In order to estimate the combined analytical and point-calibrated, a defined program for the periodic sampling random error variance, measurements of measurement of control standards should be estab- replicate (duplicate) samples should be performed.

lished and followed. Control standard measurements Although it is not necessary to estimate how much of are performed to (1) monitor the stability of a previ- the total random error is due to sampling and how ously established calibration factor and (2) estimate much is due to analysis, an estimate of the random the bias of the measurement system over a specified analytical error variance can be obtained by perform-period (e.g., an inventory period). The calibration ing replicate measurements on single samples. For factor is the numerical relationship between the ob- nonsampling measurement systems such as NDA and served output of a measurement system and the actual weight-measurement systems, the random error vari-value of the characteristic being measured, as based ance can be derived from either replicate measure-on a traceable standard. If there is a possibility of a ments performed on the process items or the replicate change in the standard's true value from factors such data generated from the measurement of control stan-as evaporation, moisture pickup, or oxidation, the dards.

value of the standard should be checked periodically. For each measurement system involving sampling and analysis, the following should be considered: (a)

To be representative of the process materials be- the number of samples to be taken and measured and ing measured, a control standard need not always be (b) the number of analyses to be performed on each identical to the process unknowns, but any constituent sample. Replicate samples should be independent of of the process material or any factor associated with a one another. The minimum number of replicate sam-process item that potentially could produce a bias ef- ples measured for each analytical measurement system fect on the measurement should be present to the depends upon the number of batches processed dur-same degree in the control standards. For scales used ing the inventory period. If there are very few batches to weigh very large items such as UFO cylinders, the processed during the inventory period, replicate sam-control standard weights should be artifact cylinders ple measurements on all the batches may be needed.

(both empty and full) of certified mass to avoid a bias If the process in question produces a large number of effect caused by buoyancy or point loading. batches during an inventory period, each batch need In addition to material composition and matrix not be subjected to replicate sampling. If 14 or fewer factors, biases can be induced by changes in tempera- batches are processed during an inventory period, rep-ture, humidity, line voltage, and background radia- licate samples from each batch should be measured.

tion, or they may be operator-induced. Therefore, in Otherwise, the minimum number of replicate samples scheduling control standard measurements, the fol- to be measured should be the greater of 15 or 15 per-lowing questions should be addressed: cent of the batches generated, unless 15 percent ex-ceeds 50, in which case the measurement of more than

• Does operator-to-operator variation need to 50 replicate samples is not necessary.

be considered and hence monitored?

• Can environmental or other variables contrib- "Batch" is defined in 10 CFR 74.4 as a portion of source mate-ute to measurement bias? rial or SNM handled as a unit for accounting purposes at a key measurement point and for which the composition and quantity

• Is bias likely to vary with respect to the time of are defined by a single set of measurements. A batch may be in bulk SM or SNM form or contained in a number of separate day? items.

5.67-8

5.5 Warning and Out-of-Control Limits nee any control measurement that exceeds an out-of-control limit and for taking the system out of service Both warning and out-of-control limits should be with respect to accountability measurements. Re-established and used for both control standard anc d sponse and corrective action requirements should be replicate measurements for those measurement sys developed and documented. As a minimum, response tems used for nuclear material accountability. Foi r to a reported incident of a control measurement ex-point-calibrated systems, the assigned value of th( ceeding an out-of-control limit should consist of:

standards measured along with the unknowns is as sumed to be valid. Control limits for the verificatior 1 1. Verifying that the measurement system in measurements associated with such standards shoulc question has been taken out of service with respect to accountability measurements, be established. This is particularly applicable to those point-calibrated systems that use a single standard, o:r 2. Documenting the occurrence of the event, aliquots from a single standard, over any extended pe riod of time. 3. Performing at least two additional control standard measurements, and The warning and out-of-control limits are nor maily set based on a tradeoff between the cost of inves 4. If results of 3, above, do not show the system tigating and resolving incidents when limits are ex to be back in control, performing additional ceeded and the consequences of accepting g control measurements using a different con-measurements of poor quality. Warning limits shouh d trol standard or different replicate sample (as be set at the 0.05 level of significance and out-of appropriate), recalibrating the measurement control limits should be set at the 0.00 1 level of signifi system, or, if necessary, making system re-cance. This means that 95 percent of the time th4 pairs.

measurement response of the standard is expected to For those measurement systems that make a sig-be within the warning limits and 99.9 percent of thi e nificant contribution to the magnitude of the standard time it is expected to be within the out-of-control lim 1 error of the inventory difference (SEID), the response its. When a measurement system generates a contro*I to an out-of-control condition should also include measurement response that falls beyond an out-of remeasurement of any samples (items) that were control limit, the system should not be used for ac measured prior to the out-of-control condition but af-counting purposes until it has been brought back int4° ter the last within-control measurement. The validity control below the warning limit. At regular interval Is of the prior measurements can be established without determined in advance by the licensee, control stan a complete remeasurement of all the samples (items) dard measurements should be made and the dat a involved if remeasurement on a "last in, first out" ba-

-should be analyzed to determine whether control lim sis is used. That is, the last sample (item) measured its should be modified. prior to the out-of-control measurement should be the first to be remeasured, and in reverse order continued 5.5.1 Control Charts until two consecutive remeasurements are found to be not statistically different from their initial measure-Measurement control data, such as control stann ments at the 95 percent confidence level. In other dard measurerinent results and the differences betweei words, for two consecutive remeasurements, the statis-measurement values of replicate pairs, may be anad tical test of the null hypothesis that the difference be-lyzed by automated techniques but should be plotter tween the measured and remeasured value is zero is on graphs. All control charts should be reviewed aLt not rejected.

least once every 2 weeks unless the measurement syi tem in question was not used during that period. Th e 6. STATISTICS purpose of this review is to ensure that all occurrence of standards measurements falling outside the warnin g In order to achieve the objectives and capabilities and out-of-control limits are documented and apprc I- of 10 CFR 74.33, a statistical program must be insti-priate action has been taken. This review is also irk- tuted to evaluate the measurement control data, en-tended to detect situations in which the limits are ncAt sure that measurements are accurate and precise, en-exceeded but there are problems that would indicat e sure that measurement data are analyzed in a rigorous that recalibration or other corrective action should b e manner, and ensure that hypotheses concerning the taken. The review should address the frequency th. at status of the nuclear material possessed are appropri-control data exceed either the warning or the out-o]f- ately tested. The NRC has sponsored the development control limits and should evaluate for any significar it of a comprehensive reference that specifically ad-trends. dresses the statistical treatment of SM and SNM meas-urement data. The statistical methods described in

'Statistical Methods for Nuclear Material Manage-5.5.2 Response Actions ment," NUREG/CR-4604, are acceptable to the The analyst or operator performing a contra measurement, or the applicable supervisor, shoul d 'W. M. Bowen and C. A. Bennett, NUREG/CR-4604, De-cember 1988. Copies may be purchased from the U.S. Govern-have the responsibility for promptly reporting to thLe ment Printing Office, P.O. Box 37082, Washington, DC measurement control program manager or the desil 20013-7082.

5.67-9 I I fI I!

NRC staff for satisfying. the requirements of 10 CFR comprehensively reviewed with all persons involved 74.33. before the start of each dynamic and static physical inventory.

At a minimum, the statistical program should ad-dress the following topics: For inventorying the SM and SNM that does not reside in the enrichment processing equipment, a

1. Procedures and methods for estimating meas- book inventory listing derived from the MC&A re-urement variance components, cords should be generated just prior to the actual start

2. Procedures and methods for determining and of the inventory. This listing should include afl SM and applying bias correction, including: SNM that the records indicate should be possessed by the licensee at the cut-off time, except for material to

• Frequency of bias estimates, be covered by the dynamic physical inventory that is to be conducted in conjunction with the static inventory.

• Method of determining the effect of a bias on the measured quantity of material in in- For dynamic physical inventories, a book inven-dividual SM or SNM items, tory quantity, to which the results of the dynamic physical inventory will be compared, is needed. One

• Method for bias corrections to items and approach to estimating the in-process inventory is to conditions under which they will be made, calculate a quantity known as the "running book in-

• Method for determining the effect of biases process inventory" (RBIPI). Essentially, this calcula-on inventory difference, and tion is analogous to determining one's checkbook bal-ance. First, the amount of SM and SNM introduced

• Method for applying bias corrections to the into the process since the last dynamic physical inven-inventory difference and the conditions un- tory is added to the amount that was in the process at der which they will be applied, that time. Then the amount of material removed from

3. Procedures and methods for determining ac- the process in the same time span is subtracted. The RBIPI is the quantity of uranium and U-235 calcu-tive inventory, lated as follows:

4. Procedures and methods for determining RBIPI = BI + CI - CO SEID,

5. Where: BI = Beginning in-process inventory (at the Procedures and methods for determining the DQ,* and start of the current inventory period) as determined from the previous dy-

6. Procedures and methods for determining the namic physical inventory.

detection threshold (DI) values to be used to provide a 90 percent power of detecting a loss CI = Cumulative measured input to the en-richment process for the current dy-of a DQ amount of material, as required by 10 namic physical inventory period.

CFR 74.33(c)(4).

At least two individuals should independently ver- CO = Cumulative measured output from the ify the correctness of the SEID calculation for each enrichment process for the current total plant material balance. If the SEID value is calcu- dynamic physical inventory period.

lated using a computer, verification may be accom- Hence, the inventory difference associated with plished during each physical inventory reconciliation the dynamic physical inventory is calculated as fol-process by two or more persons checking for correct- lows:

ness of the input data used by the computer to calcu-late SEID and checking the correctness of a sample ID = RBIPI - EI = (BI+CI) - (CO+EI) calculation used to verify the computer program. Where: EI = Ending in-process inventory as deter-mined from the dynamic physical in-

7. PHYSICAL INVENTORIES ventory.

7.1 General Description 7.2 Organization, Procedures, and Schedules Detailed procedures should be developed for the conduct of both dynamic physical inventories of the The composition and duties of the organization enrichment processing equipment and static physical for the typical physical inventories, both dynamic and inventories of the balance of the plant (10 CFR static, should be established in advance of the invento-74.33(c)(1)(iv)). The physical inventory functions ries. The individual having responsibility for the and responsibilities should be clearly defined and coordination of the physical inventory effort shouli be identified. Written procedures for both dynamic and static physical inventories should be developed and

'DQ should not exceed 1.3 percent of the annual U-235 quan- approved by the MC&A manager and no revisions tiy introduced Into the enrichment process except when the 1.3 percent Is less than 25 kg U-235, in which case the DO should be made to these procedures without his or her need not be less than 25 kg U-235. approval (10 CFR 74.33(c) (1) (iv)). Specific inven-5.67-10

tory instructions should be prepared and issued for tory has started for nonenrichment processes each dynamic and static physical inventory. such as scrap recovery.

Procedures should be developed for item storage 7.3 Inventory Composition and handling or tamper-indicating methods that are used to ensure that prior measurements are valid and The quantity of material within the enrichment may be used for inventory purposes (10 CFR equipment for both uranium and U-235 at the time of 74.33(c)(1)(iv)). Also, inventory procedures should dynamic physical inventory should be accounted for. address how item identities are verified and how tam-UFO cylinders connected (valved in) to the enrich- pering with the contents of items will be detected.

ment process system should be included as part of the dynamic physical inventory. For static physical inven- For items that are not encapsulated, affixed with a tories, the item composition should be categorized as tamper-indicating seal, or otherwise protected to en-depleted uranium, natural uranium, or enriched ura- sure the validity of prior measurements, procedures nium. If different size cylinders or other containers are should be developed for determining which items are used within one of the three UFO categories, they to be measured at physical inventory time. Criteria should be treated as different item strata. should be developed for the justification of any pro-posed alternatives to measurement of any SM and SNM included in the inventory. A statistical sampling 7.4 Conducting Dynamic Physical Inventories plan for determining how many and which items are to be randomly selected for remeasurement may be an The licensee is required by 10 CFR 74.33(c) (4) to alternative method to 100 percent verification of prior perform a dynamic physical inventory, which involves measurements. Such a plan should address the follow-striking a material balance around the processing ing:

equipment as described in Regulatory Position 7.1. In-direct measurements and production parameters (as

• The method of classifying into several strata well as the analysis of process samples) to determine the types of items to be sampled;:

the quantity of material within the enrichment process

• The method for calculating the sample size for may be used. The estimate of the amount of material within the process should be compared to that shown each stratum; by the MC&A records to provide an indication as to

• The quality of the measurement methods used whether or not a loss or theft has occurred. The loss to verify original measurement values; detection sensitivity associated with the bimonthly dy-namic inventories should be sufficient to detect a loss

• The procedure for reconciling discrepancies or theft of DQ or greater over a 12-month period with between original and remeasured values, in-at least a 90 percent power of detection. A DQ is a cluding when additional tests and remeasure-site-specific quantity of U-235, the value of which is ments would be performed; and discussed in Regulatory Position 6 of this regulatory

• The basis for discarding the value of a previ-guide. ous measurement of SM or SNM value and replacing it with a remeasured value.

7.5 Conducting Static Physical Inventories One acceptable means for establishing the number Detailed written procedures and methods associ- of items to be randomly selected for remeasurement ated with performing static physical inventories should from a given material type is given by the following be developed (10 CFR 74.33(c)(1) (iv)). These proce- equation, which calculates the number of items that dures should address the following: would need to be remeasured to give a 90 percent probability of detecting the loss of DQ kilograms of

• The organization and independence of inven- U-235 from the given material stratum:*

tory functions, n = N [ 1 -( 0 .1 0 )x/g1

• Assignment of inventory teams and the in-structions given to each team, Where: n = number of items to be remeasured N = total number of items in the stratum

• The processes of obtaining, verifying, and re-cording source data, x = maximum U-235 content per item (kilograms)

• Control of inventory forms, g = DO (kilograms U-235)

• The process for verifying the presence of each item while preventing multiple counting of any item, and 'G.F. Piepel and R. J. Brouns, Statistical Sampling Plans for Prior Measurement Verification and Determination of the SNM Content of Inventories,' prepared for the NRC by Pacific

• The procedures for halting processing and Northwest Laboratory, NUREG/CR-2466 (PNL-4057).

material movement after the physical inven- March 1982.

5.67-11 I II I

Any items on ending inventory that have not been 8. ITEM CONTROL previously measured must be measured for inventory purposes (10 CFR 74.33(c)(2)). 8.1 Organization Procedures should be developed for determining The person to be responsible for overseeing the when the element and isotope factors for items, ob- item control program and the persons who have signifi-jects, or containers will be measured directly for inven- cant item control program responsibilities should be tory and when they may be based on other measure- identified in the applicable MC&A procedures.

ments. These procedures should clarify the conditions under which it is permissible to apply an average en- 8.2 General Description richment factor to the measured uranium element content and the method used to determine the factor. The MC&A system must maintain records of all SM and SNM items, regardless of quantity or duration If the content of items is established through prior of existence (10 CFR 74.33 (c) (6) (i)). In addition, the measurements and those items are tamper-safed or ac- item control program should provide current informa-cess to them is controlled, the current SM or SNM tion about the location, identity, and uranium and quantity in those items may be based on those meas- U-235 quantity of all nonexempt SM and SNM items ured values. Otherwise, verification of SM or SNM (10 CFR 74.33(c)(6)(i)). Items that can be exempt content can be achieved by reweighing either (1) all from item control program coverage are:

the items within a given stratum or (2) randomly se- 1. Items that exist for less than 14 calendar days, lected items from the stratum based on a statistical and sampling plan. A statistical sampling plan will not be acceptable if there is any likelihood of a significant 2. Any licensee-identified items containing less change in the uranium concentration (or weight frac- than 500 grams U-235 provided the cumula-tion) or in the uranium isotopic composition. For ex- tive total of such exempted items does not ex-ample, oxidation or change in moisture content will ceed 50 kilograms U-235.

alter the uranium concentration.

All items, whether or not they are subject to the item control program, should have a unique identity.

7.6 Inventory Difference Limits and Response For items subject to the item control program, the fol-Actions lowing are acceptable means for providing a unique identity:

A well-defined system for evaluating total plant in-

• A unique alpha-numeric identification on a ventory differences (IDs) and taking action when IDs tamper-safe seal that has been applied to a exceed certain predetermined thresholds should be es- container of SM or SNM, tablished and followed. As a minimum, there should be a response level if the U-235 ID is equal to or ex-

• A unique alpha-numeric identification perma-ceeds the detection threshold (DT). The DT for such nently inscribed, embossed, or stamped on an ID problem (DT = DQ - 1.3 SEID) may be inter- the container or item itself, or preted in the following manner. If an actual loss or theft of a DQ amount or more occurred since the last

• A uniquely prenumbered (or bar coded) label static physical inventory, there is at least a 90 percent applied to each item; the label has adhesive probability that the inventory difference will exceed qualities such that its removal from an item the detection threshold. The above limit is expressed. would preclude its reuse.

in terms of absolute values of ID (i.e., no regard for Locations of items shown by the item control pro-algebraic sign). gram records need not be unique, but location desig-nations should be specific enough so that any item can For any unresolved ID that remains greater than be located in a timely fashion. The MC&A record sys-or equal to DT (even if the ID is negative), the licensee tem must be tamper-proof and controlled in such a may need to take steps for scheduling a plant-wide manner that the record of an item's existence cannot reinventory and investigation. Intermediate-level be destroyed or falsified without a high probability of thresholds may be useful in order to provide a timely detection (10 CFR 74.33(d)(3)).

mechanism for detection of losses that are less than a DQ so that the occurrence of an ID greater than or Each nonexempt item should be stored and han-equal to DT may be avoided in future physical dled in a manner that enables detection of, and pro-inventories. vides protection against, unauthorized or unrecorded removals of SM and SNM.

The regulation in 10 CFR 74.33(c) (4) (i) requires 1 1

static and dynamic physical inventories for both ura- 8.3 Item Identity Controls nium element and U-235, and 10 CFR 74.33 (c)(4)(ii) requires the reconciliation and adjustment Tamper-safe seals or other tamper-indicating de-of the book inventory for the results of the static physi- vices may be used to provide unique item identity.

cal inventory for both uranium element and U-235. Procedures should be developed for:

5.67-12

1. The type of seals utilized for the various types The actual frequency of the above checks and the of containers stored, size of the random sample should be a function of an expected discrepancy rate based on prior observa-

2. The method of seal procurement and meas- tions. Items that cannot be located are not discrepan-ures taken to ensure that duplicate (counter- cies but indications of possible loss or theft. On the feit) seals are not manufactured, contrary, discrepancies are inadvertent conditions such as items not in assigned locations and incorrect

3. Seal storage, control, distribution, destruc- entries in item control program records.

tion, and accounting, and

4. Maintenance and control of seal usage and 8.6 Investigation and Resolution of Loss disposal records. Indicators Procedures and controls should be developed to 8.4 Storage Controls ensure that all incidents involving missing or compro-mised items or falsified item records will be investi-Storage areas and controls for items are important gated. A compromised item is one with evidence of elements in the item control program because they tampering or an unsealed and unencapsulated item form the basis for accepting prior measurements of that has been assigned to a limited access, controlled items, as opposed to remeasuring the item at inventory storage area, but is found elsewhere. If any unencap-time. Any controls used to ensure the validity of prior sulated and unsealed item is located after it has been measurements should be equivalent to the protection determined that it is missing or if an item is found to be provided by tamper-safing seals. Both administrative compromised, the contents should be verified by controls (such as custodian assignments and limiting measurement. Additional guidance on resolution of authorized access to storage areas) and physical con- item discrepancies is included in Regulatory Position trols (e.g., locked and alarmed doors) may be used. 11.

8.5 Item-Monitoring Methodology and 9. SHIPPER-RECEIVER COMPARISONS Procedures 9.1 Receiving Procedures As part of the item control program, a system of The first action to be taken by the licensee upon item monitoring that includes the following should be receipt of SM or SNM should be verification of the maintained: correct number of items, the correct identity of the

1. Verification that items shown in the MC&A items, and the integrity of the tamper-indicating seals.

records are actually stored and identified in The maximum elapsed time for determining whether the manner indicated in the records, or not a significant shipper-receiver difference (SRD) exists should be established by the licensee and should

2. Verification that generated items and changes not exceed 30 calendar days.

in item locations are properly recorded in the MC&A record system in a timely manner, and 9.2 Determination of Receiver's Values For natural UF6 , the licensee may establish the

3. Detection, with high probability, of a real loss receiver's values by measuring U-235 concentration of items (or uranium from items) amounting (either by NDA or by sampling and analysis), weighing to 500 grams or more of U-235. each cylinder, and using a nominal percent uranium factor. All SNM receipts, and any SM receipts not in The item-monitoring system should periodically the form of UFO, should be measured for uranium and include: U-235 content.

• Checking the actual storage status of a suffi-cient sample of randomly selected items from 9.3 Evaluation of SRDs the item control program records from each SRDs greater than 500 grams of U-235 are evalu-stratum to confirm that the recorded informa- ated by testing the hypothesis that the SRD equals tion is correct, zero. NUREG/CR-4604, 'Statistical Methods for Nu-

• Checking the accuracy of the item control clear Material Management,"

• in the chapter on hy-program records for a sufficient sample of ran- pothesis testing, provides methods that are acceptable domly selected items from each storage area to the NRC.

to ensure that all items are being properly en-tered into the records, and

• Checking the accuracy of a sufficient sample W.M. Bowen and C. A. Bennett, NUREG/CR-4604, Decem-ber 1988. Copiesmay be purchased fromthe U.S. Government of randomly selected production records of Printing Office, P. 0. Box 37082, Washington, DC created and consumed items. 20013-7082.

5.67-13 I I TI

9.4 Resolution of Significant SRDs individual member should not participate in the assess-ment of the parts of the MC&A system for which that Resolution of a significant SRD usually involves an person has direct responsibility. Hence, the MC&A independent measurement of retainer samples. A re- manager can not be a team member. Also, to guard tainer sample is one taken prior to shipment of the against collusion, no pair of team members should per-material and kept until shipper-receiver comparisons form assessments of each other's area of responsibil-are resolved and it is determined that there is no dis- ity. The leader of the assessment team should have no pute concerning the amount shipped. Resolution of responsibilities for managing any of the MC&A ele-such SRDs could involve testing three hypotheses. The ments being assessed.

first hypothesis is that the difference between the ship-per's weight and the receiver's weight is zero. The The minimum number of individuals on any given second hypothesis is that the difference between the assessment team should depend on the knowledge and shipper's percent uranium element measurement and expertise of the team relative to MC&A activities and the receiver's percent uranium element measurement on their experience in conducting reviews.

is zero. The third hypothesis is that the difference be-tween the shipper's U-235 measurement value and Personnel assigned to the assessment team should the receiver's U-235 measurement value is zero. have a good understanding of the objectives and the requirements of the MC&A program and should have If an SRD is statistically significant and it is 500 or sufficient knowledge and experience to be able to more grams of U-235, it must be resolved (10 CFR judge the adequacy of the parts of the system they re-74.33(c) (7)). In the event that such an SRD occurs, view. The team should have authority to investigate all the first thing to resolve is any significant difference aspects of the MC&A system and should be given ac-between the shipper's and receiver's net weights of the cess to all necessary information.

material shipped (e.g., kilograms UFO). Since the shipper will not be able to repeat the measurements In order to provide a meaningful and timely as-upon which his net weights will be based, the licensee's sessment, the review and evaluation process should resolution procedure should specify how the net not be protracted. The actual review and investigation weight value to which both the shipper and receiver activities should be completed in 30 calendar days, agree is to be determined. When the shipper's and re- with an additional 15 calendar days allowed for com-ceiver's net weights are in statistical agreement with pleting and issuing a final team report.

one another, the receiver can proceed to resolve the differences in elemental and isotopic measurements of 10.2 Report of Findings and Recommendations the material in question, including, if necessary, remeasurement by the shipper using the retained The areas to be reviewed must encompass the en-samples. tire MC&A system, and the level of detail of the re-views should be sufficient to ensure that the assess-

10. ASSESSMENT OF THE MC&A PROGRAM ment team has adequate information to make meaningful judgments of the MC&A program's effec-tiveness (10 CFR 74.33(c)(8)(i)). The report should 10.1 General Description provide findings pertaining to:

The capabilities, performance, and overall effec- 1. Organizational effectiveness to manage and tiveness of the licensee's MC&A program must be in- execute MC&A activities, dependently reviewed and assessed at least every 24 months as required by 10 CFR 74.33(c) (8). This inde- 2. Management responsiveness to indications of pendence should be established by ensuring that the possible losses of uranium and of possible un-individual responsible for assessing each portion of the authorized enrichment activities, MC&A program does not have routine responsibilities within that program element. It is preferred that the 3. Staff training and competency to carry out entire MC&A program be reviewed and evaluated MC&A functions, during each assessment. If so, intervals between as-sessments can be as long as 24 months. If individual 4. Reliability and accuracy of accountability assessments do not cover the entire MC&A system, measurements made on SM and SNM, the intervals should be no longer than 12 months. 'In- 5. Effectiveness of the measurement control pro-terval' means the elapsed time between either the gram in monitoring measurement systems and start of or termination of successive assessments. its sufficiency to meet the requirements for controlling and estimating both bias and The responsibility and authority in the licensee's organizational structure for the assessment program SEID, should be at least one level higher than that of the 6. Accuracy of the material accounting records, MC&A manager. Such responsibility should include the selection of the assessment team leader and the 7. Effectiveness of the item control program to initiation of corrective actions. Team members may be track and provide current knowledge of items, selected from the facility staff or from outside, but an 5.67-14

8. Capability to promptly locate items and effec- three types of indications above should be made, and tiveness in doing so, appropriate resolution procedures for each postulated indicator should be identified. In addition, the time

9. Timeliness and effectiveness of SRD evalu- limits within which resolution of indicators must be ac-ations and resolution of excessive SRDs, complished and the actions to be taken if resolution has not occurred within that time should be specified.

10. Reliability and effectiveness of the inventory-taking procedures, 11.1 Indicators of Missing Uranium

11. Capability to confirm the quantities and loca-tions of SM and SNM, Possible indicators of missing uranium include:

12. Capability to detect and resolve indications of

• Determination through the item control pro-unauthorized enrichment activities and the ef- gram that a specific item is not in its author-fectiveness of doing so, and ized location and its actual location is not known,

13. Capability to detect and resolve indications of missing uranium and the effectiveness of do-

• Discovery of tampering with the MC&A re-ing so. cords, On completion of each assessment, the findings

• Discovery that an item's integrity or its and recommendations for corrective action, if any, tamper-indicating seal has been compro-must be documented (10 CFR 74.33(c)(8)(ii)). The mised, written report should be distributed to the plant man-ager, the MC&A manager, and other managers af-

• A significantly lower remeasured value on any fected by the assessment. item, batch, or lot of measured material in which the difference between the original and remeasured values exceeds twice the standard 10.3 Management Review and Response to error plus 500 grams or more U-235, Report Findings and Recommendations

• Discovery of unauthorized feed or withdrawal Management should review the assessment report equipment in the processing area, and take the necessary actions to correct any MC&A system deficiencies. The management review must be

• Information from the process control system documented (10 CFR 74.33(c) (8) (iii)), and it should indicating a potential loss of material from the include a schedule for the correction of deficiencies. process system.

Corrective actions, if any, that pertain to daily or weekly activities should be initiated promptly after the Resolution of an indication means that the licen-submittal of the final assessment report. see has concluded that a loss or theft of more than 500 grams of U-235 has not occurred. For each antici-

11. RESOLVING INDICATIONS OF pated type of loss indicator, a detailed resolution pro-UNAUTHORIZED PRODUCTION OF cedure should be developed.

ENRICHED URANIUM AND MISSING When appropriate, the resolution process may in-URANIUM clude (1) a thorough check of the accountability Procedures must be developed for resolving indi- records and source information, (2) locating and iso-cators of either missing uranium involving 500 or more lating the source of the problem, (3) isolating the exact grams U-235 or of indicators of unauthorized enrich- reason for the problem within the area or processing ment (10 CFR 74.33(a)(4), (5), (6), and 10 CFR unit, (4) determining the amounts of uranium and

• 74.33(c)(1) (iv) and (c)(5)). The three generic types U-235 involved, and (5) making a determination that of indications are: the indication is or is not resolved. The resolution pro-cedures should be implemented in such a manner that

1. Indications that either uranium source mate- no individual who could have been responsible for the rial or enriched uranium is missing, potential loss could also be responsible for resolution.

2. Indications that unauthorized production of uranium of low strategic significance has been 11.2 Indications of Unauthorized Production of or is occurring, and Uranium Enriched to Less Than 10 Percent in the Isotope U-235

3. Indications that the enrichment equipment has been or is being used to produce enriched Possible indicators of unauthorized production of uranium with an enrichment of 10 percent or uranium enriched to less than 10 percent in the iso-more in the isotope U-235. tope U-235 include:

The resolution program should address the possi-

• Presence of unauthorized product, feed, or ble indicators of missing uranium. A determination of depleted uranium cylinders in the processing potential indicators that can be postulated for the area, 5.67-15 I

• Presence of UFO cylinders that have not been

• An allegation that unauthorized production of entered into the MC&A record system, uranium enriched to 10 percent or more in the isotope U-235 has occurred or is occur-

• Variations from planned production sched- ring, and ules,

• Higher than normal nuclear signal, caused by

• A change in the enrichment assay of UFO tails the presence of uranium enriched to 10 per-from that specified by production schedules, cent or more, from a container or process e An excess amount of depleted uranium or an system.

excess rate of depleted uranium production, Resolution of an indication means that the licen-see has concluded that unauthorized production of

• Incorrectly identified cylinders, such as de- uranium enriched to 10 percent or greater in the iso-pleted uranium or feed identified as enriched tope U-235 has not occurred and is not occurring. For product material, each anticipated type of indicator, detailed resolution

• Discovery of tampering with the MC&A rec- procedures should be developed.

ords, Since unauthorized enrichment might not be de-tected through the conduct of static physical invento-

• Discovery of unauthorized feed or withdrawal ries or dynamic physical inventories, the resolution equipment in the processing area, process should include the investigation of all the in-

• An allegation that unauthorized enrichment formation that contributed to the indication of un-of uranium to 9.9 percent or less in the isotope authorized enrichment. On receipt of an indication U-235 is or has been occurring, and that uranium enriched to 10 percent or more may have been or is taking place, the licensee should verify, by

• Reconfiguration of the enrichment equipment remeasuring, whether material enriched to greater to permit unauthorized operation. than 9.99 percent is present in the process equipment or items. Depending on the type of indicator, immedi-Resolution of an indication means that the licen- ate isolation of the process area or storage area from see has concluded that unauthorized production of which the indication was received may be needed until uranium enriched to less than 10 percent in the iso- the indication is resolved. The instruments and meas-tope U-235 has not occurred and is not occurring. For urement systems used for monitoring should be exam-each anticipated type of indicator, detailed resolution ined to determine whether they are functioning prop-procedures should be developed. erly. The processing equipment should be thoroughly examined to ensure that unauthorized modifications In the event of any of these or other indicators of have not been made. The presence of uranium en-possible unauthorized production of uranium enriched riched to 10 percent or more should be verified by to less than 10 percent in the isotope U-235, the licen- remeasuring the material in question, whether in item see should determine the indicator's cause and come form or in the process equipment. If this investigation to a conclusion as to whether or not unauthorized pro- determines that an indication of unauthorized enrich-duction has occurred or is occurring. If an indication ment to 10 percent or more is true, the NRC must be of unauthorized production is determined to be true, notified within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of such determination pursuant the NRC must be notified within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> pursuant to to 10 CFR 74.11.

10 CFR 74.11.

If the investigation conducted to resolve the indi-11.3 Indications of Unauthorized Production of cation is inconclusive, further measures are needed Uranium Enriched to 10 Percent or More before the licensee may conclude that the indication is in the Isotope U-235 resolved. To protect against the relocation and con-cealment of the enriched uranium, a thorough investi-Possible indicators of unauthorized production of gation of the entire facility should be performed by uranium enriched to 10 percent or greater in the iso- persons independent of the processing organization.

tope U-235 include:

12. PROGRAM FOR PRECLUDING OR

• Any measurement from a process stream DETECTING UNAUTHORIZED PRODUC-monitoring program that indicates out-of- TION OF ENRICHED URANIUM specification enrichment concentrations, There are several alternative approaches available

• Unauthorized withdrawal equipment in the to protect against and detect unauthorized production enrichment processing area, of enriched uranium. The licensee may perform an analysis to identify and evaluate all credible scenarios

• Unauthorized reconfiguration of enrichment through which clandestine enrichment could occur equipment, and provide a monitoring program to protect against and detect each scenario. One approach for detecting

• Discovery that enrichment-level monitoring unauthorized production of uranium enriched to 10 equipment has been compromised, percent or more in the isotope U-235 would be a pro-5.67-16

gram to monitor the enrichment level of the uranium fore 10,000 grams of U-235 contained in such materi-in all process streams and all possible withdrawal paths al is produced. For unauthorized production of ura-so that SNM of moderate strategic significance could nium enriched to 20 percent or more, regardless of the not be produced within any period of 370 calendar production rate, detection is to occur before 1000 days and any uranium enriched to 20 percent or more grams of U-235 contained in HEU is produced.

in the isotope U-235 would be detected. Detecting production from undeclared feed of enrichment levels These scenarios for production of uranium en-that are within the limits authorized by license must riched to 10 percent or more in the isotope U-235 rely on measures other than monitoring of enrichment should include process system adjustments, batch re-levels. cycle processing, cascade interconnections, cascade isolation, and cascade reconfiguration.

12.1 Organization To preclude unauthorized production of uranium enriched to 10 percent or more in the isotope U-235, The person responsible for executing the program the following types of measures should be considered:

for precluding or detecting unauthorized production of enriched uranium should be identified by title or posi-

• Process design features that preclude un-tion in the organization. This person need not be part authorized enrichment to be conducted simul-of the MC&A organization, but must be independent taneously with normal (authorized) produc-of the production organization. Personnel who are as- tion, signed program responsibilities should also be inde-

• Personnel access controls that limit the num-pendent of production supervision (10 CFR ber of individuals who could gain access to the 74.33 (c) (1) (ii)). This program should be well coordi- enrichment processing equipment or its con-nated with both MC&A and production management. trol mechanisms, The program director should have the necessary authority to carry out all aspects of the program.

• Physical security controls such as locked and alarmed doors or TV monitors that would de-12.2 Monitoring Program for Clandestine tect unauthorized access to processing equip-Enrichment Scenarios ment or product material,

• Process control systems that could detect un-12.2.1 General Description of Program authorized use of production equipment, The overall design of this program should be

• Production control and process monitoring based, at least in part, on a clandestine enrichment activities that could contribute to the detec-path analysis. That is, for each credible scenario for tion of the unauthorized production of ura-clandestine enrichment, there should be a monitoring nium enriched to 10 percent or more in the system for the timely detection of that scenario. isotope U-235, and With respect to the monitoring program for de-

• Use of tamper-indicating seals on process tecting unauthorized production of uranium enriched valves and flanges.

to 10 percent or more, one acceptable approach would be to monitor the enrichment level in all process For the program to protect against and detect streams and all possible withdrawal paths, at adequate unauthorized production of uranium enriched to less frequencies, so that (1) 10,000 grams or more of than 10 percent in the isotope U-235, the following U-235 contained in uranium enriched between 10 topics should be considered:

and 20 percent (which would be SNM of moderately strategic significance) could not be produced within

• The type of monitoring and surveillance, and any period of 370 calendar days, and (2) any produc- its frequency, to be applied to the processing tion of uranium enriched to 20 percent or more (i.e., areas; HEU) would be detected before the production of

• The type of monitoring and surveillance, and HEU containing 1000 grams of U-235 could occur. its frequency, to be applied to the process con-That is to say, regardless of monitoring methodology, trol room and other areas where operation of if unauthorized production of uranium enriched be- processing equipment can be controlled or tween 10 and 20 percent in U-235 occurs at such a modified; slow rate that production of a quantity representing SNM of moderate strategic significance (i.e., 10,000

• The type of monitoring and surveillance, and grams of U-235) would take more than 370 calendar its frequency, to be applied to potential feed days, it is not necessary that such production be de- and withdrawal areas; tected by the monitoring program. However, if SNM of moderate strategic significance (involving uranium

• Process monitoring activities (e.g., radiation enriched between 10 and 20 percent) can result from and flow metering) other than process sam-unauthorized enrichment activities within 370 days or pling that could contribute to the detection of less, the monitoring is to detect such production be- unauthorized production; 5.67-17 I I I I 1

• Use of tamper-indicating seals on process

• Independent weighing, sampling, and isotopic valves and flanges; assay of material withdrawn at the product and tails withdrawal stations,

• Personnel access controls that limit the num-ber of individuals who could gain access to the

• Independent sampling and isotopic assay of enrichment processing equipment or its con- in-process material at randomly selected trol mechanisms; points, and

• Physical security controls such as locked and

• Verification that the quantity of U-235 inde-alarmed doors, closed circuit television moni- pendently determined to be in the product tors, etc., that would detect unauthorized ac- and tails is consistent with the independently cess to processing equipment or product mate- determined feed input.

rial; For gaseous diffusion and gas centrifuge facilities,

• Production control activities that could con- the licensee or applicant should consider monitoring tribute to the detection of unauthorized pro- such process parameters as UFg gas pressures, flow duction; rates, enrichments, valve positions, operating parame-ters, cascade configuration and connections, and

• Employee education to increase the probabil- tracking all potential UFP containers in the process ity of reporting of potential unauthorized ac- area. The purpose is to ensure that the amount of en-tivities by facility personnel; and riched uranium being produced agrees with produc-tion schedules.

• Notification of appropriate MC&A personnel by operations organizations of the operating status of the cascades, especially when a cas- 12.3 Program for Monitoring Output Streams cade is isolated from the process stream.

The overall design of the program should include analysis of all processing and product streams to deter-12.2.2 Program Sensitivity mine where uranium isotopic measurements should be While any actual enrichment of uranium to 10 made and at what frequency to preclude clandestine percent or more in the isotope U-235 is prohibited enrichment activities. That is, for each identified sce-(except for cascade start-up in centrifuge facilities as nario for clandestine enrichment, there should be a noted in Regulatory Position 1.2), the detection sensi- monitoring system for the timely detection of any im-plementation of that scenario. Since NDA measure-tivity need not be absolute. Since large quantities of uranium enriched to between 10 and 20 percent in the ment techniques can be useful for detecting the pres-ence of uranium enriched to unauthorized levels, the isotope U-235 would be required for a meaningful ma-levolent activity, 10 CFR 74.33(c)(5) requires that use of such techniques, either by manual measure--

ments using portable NDA instruments or instruments production of uranium in this enrichment range be de- that are permanently affixed to the process equip-tected before SNM of a moderate strategic signifi- ment, should be considered. In the former case, ad-cance could be produced within a 370 day period. ministrative controls should be used to detect or pre-That is to say, there should be a high assurance of de- clude collusion of the measurement personnel with a tecting the production of 10,000 grams or more of U-235 in the form of uranium enriched to between 10 potential clandestine perpetrator. In the latter case, frequent inspection and testing of the instruments and 20 percent in the isotope U-235. Production of uranium to greater than 20 percent in the isotope should be performed to detect or preclude tampering U-235 should be .detected soon enough to preclude or disabling of the NDA measurement system.

the actual production of 1 kilogram of U-235 con- The scenario analysis should address each prod-tained in HEU. uct stream regardless of material type or composition and should be conducted by persons that have a thor-12.2.3 Data, Information, and Activities ough knowledge of the processing equipment and To Be Monitored enrichment technology. All conceptual means for pro-duction of uranium of enrichment levels equal to or The means for independently verifying that the greater than 10 percent in the isotope U-235 should actual enrichment levels in the various process streams be identified. These approaches should include are consistent with design enrichment parameters process system adjustments, batch recycle processing, should be developed. In developing the monitoring cascade interconnections, and cascade reconfigura-program, activities such as the following should be tion (e.g., increasing the number of stages).

considered:

The extent of the monitoring program should de-

• Independent weighing, sampling, and isotopic pend on the same types of measures as those identified assay of material introduced at the feed addi- in Regulatory Position 12.2.1 for monitoring clandes-tion stations, tine enrichment scenarios.

5.67-18

12.4 Decision Criteria for Declaring

• Ledgers (journals, computer printout sheets, Unauthorized Production etc.) associated with the accountability sys-tem, An MC&A procedure that defines the basis for (a) declaring that unauthorized production of uranium

• Ledgers (journals, computer printout sheets, enriched to 10 percent or more in the isotope U-235 etc.) associated with the item control pro-has taken place and (b) declaring that unauthorized gram, including seal usage and "attesting to" production of uranium enriched to less than 10 per- records, cent in the isotope U-235 has taken place should be

• Completed DOE/NRC-742 and NRC-327 developed. Forms and incoming and outgoing DOE/

NRC-741 Forms, Whenever there is an indication that unauthorized enrichment is or may be occurring, that indication

• Forms (memos, reports, etc.) associated with must be subject to the investigation and resolution re- identification of, investigation of, and resolu-quirements of 10 CFR 74.33(c)(5), which are dis- tion of significant shipper-receiver differ-cussed in Regulatory Position 11 of this regulatory ences, guide. If actual unauthorized production of enriched uranium is discovered, that discovery must be re-

• Loss indication and alleged theft investigation ported to the NRC within one hour as required by 10 reports, CFR 74.11.

• Investigation reports pertaining to indications of unauthorized enrichment activities,

13. RECORDKEEPING

• Investigation reports pertaining to excessive inventory differences, 13.1 Description of Records

• Reports containing the findings and recom-The MC&A program must utilize and retain all mendations of MC&A system assessments as records, forms, reports, and standard operating proce- well as any letters or memos pertaining to ac-dures pursuant to 10 CFR 74.33(d). Such records tions in response to assessment team recom-should include, but are not limited to, the following: mendations,

• Documents recording changes in the MC&A e Forms used for recording data associated with management structure or changes in responsi- the monitoring program, bilities relating to MC&A positions,

• Records and forms used to document author-ized reconfiguration of enrichment equip-

• Any procedures pertaining to accountability ment, measurements (including sampling) and measurements related to the requirements of

• Status reports or summary reports pertaining 10 CFR 74.33(c)(5), to the monitoring for unauthorized enrich-ment and item monitoring programs, and

• Forms used to record or report measurement data and measurement results, including

• Training, qualification, and requalification source data, reports or records.

All retained records and reports must contain suf-

• Forms (notebooks, etc.) used to record cali- ficient detail to enable NRC inspectors to determine bration data associated with any accountabil- that the licensee has attained the system features and ity measurement system, capabilities and has met the general performance ob-

• Forms (notebooks, etc.) used to record quan- jectives (10 CFR 74.33(d)(1)).

tities, volumes, and other data associated with the preparation of standards (both calibration 13.2 Program for Ensuring an Accurate and and control) used in connection with account- Reliable Record System ability measurement systems, Controls to ensure that records are highly accurate

• Forms used to record or report measurement and reliable should be developed. Specific MC&A control program data, control limit calcula- procedures dealing with record protection should be tions, out-of-control investigations, developed and followed. The record system should also provide a capability for easy traceability of all SM

• Forms (listings, instructions, etc.) associated and SNM transactions from the point at which the with a physical inventory (both dynamic and data is generated to the final accounting records.

static), This program should address the following topics:

• Forms (worksheets, etc.) used in the calcula-

• The auditing system or program to verify the tion of SEID, ID, and active inventory values, correctness and completeness of records, 5.67-19 II I fI

• The procedures designed to prevent or detect D. IMPLEMENTATION the falsification or destruction of data or re-cords by an individual.

The purpose of this section is to provide informa-

• The plan for reconstructing lost or destroyed tion to applicants regarding the NRC staff's plans for SM or SNM records, using this regulatory guide.

• Access controls used to ensure that only authorized persons can update and correct re- Except in those cases in which an applicant pro-cords, and poses an acceptable alternative method for complying with specified portions of the Commission's regula-

• The protection and redundancy of the record tions, the methods described in this guide will be used system so that any act of record alteration or in the evaluation of Fundamental Nuclear Material destruction will not eliminate the ability to Control Plans submitted by applicants or licensees pur-provide complete MC&A information. suant to 10 CFR 74.33.

K 5.67-20

REGULATORY ANALYSIS A separate regulatory analysis was not prepared rulemaking in this instance are slightly higher than the for this regulatory guide. The regulatory analysis pre- costs of imposing license conditions, the advantages of pared for 10 CFR 74.33, 'Nuclear Material Control promulgation by rulemaking include the opportunity and Accounting for Uranium Enrichment Facilities for public comment, which better assures that all ap-Authorized To Produce Special Nuclear Material of propriate issues are raised prior to the imposition of Low Strategic Significance," provides the regulatory these requirements.

basis for this guide and examines the cost and benefits A copy of the regulatory analysis is available for of the rule as implemented by the guide. The rule sets inspection and copying for a fee at the NRC Public forth the NRC staff position on MC&A at licensed en- Document Room, 2120 L Street NW., Washington, richment plants and provides safeguards to protect the DC, as part of the file on the Federal Register Notice health and safety of the public. While the costs of dated October 31, 1991 (56 FR 55991).

5.67-21 II I l

Federal Recycling Program

. I I I 1 ii1

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UNITED STATES FIRST CLASS MAIL NUCLEAR REGULATORY COMMISSION POSTAGE AND FEES PAID WASHINGTON, D.C. 20555-0001 USNRC PERMIT NO. G-67 OFFICIAL BUSINESS PENALTY FOR PRIVATE USE, $300