ML19256E668
| ML19256E668 | |
| Person / Time | |
|---|---|
| Issue date: | 04/30/1978 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| References | |
| FRN-52FR10033 AA50-2-002, AA50-2-2, NUREG-0450, NUREG-0450-V01, NUREG-450, NUREG-450-V1, NUDOCS 7911140410 | |
| Download: ML19256E668 (40) | |
Text
NUREG-0450 Vol.1 REPORT OF THE MATERIAL CONTROL AND MATERIAL ACCOUNTING TASK FORCE Summary 0hhh s..;hp*
l 1714 160 Office of Nuclear Material Safety and Safeguards U. S. Nuclear Regulatory Commission
)D**}D *F'9fV J2o oJu o
Sb _2 NOTICE The members of the Material Control and Material Accounting Task Force, who are all NRC staff members, are solely responsible for this report.
The views expressed herein are those of the Task Force. The Nuclear Regulatory Commission is reviewing this report and has taken no position on the conclusions or reconinendations.
Available from National Technical Information Service Springfield, V'.rginia 22161 Price: Printed Copy $4.50; Microfiche $3.00 The price of this document for requesters outside of the North American Continent can be obtained from the National Technical Information Service.
1714 161
N U R EG-0450 Vol.1 REPORT OF THE MATERIAL CONTROL AND MATERIAL ACCOUNTING TASK FORCE Summary Manuscript Completed: March 1978 Date Published: April 1978 Division of Safeguards Office of Nuclear Materials Safety and Safeguards U. S. Nuclear Regulatory Commission Washington, D. C. 20555 1714 162
CONTENTS Page EXECUTIVE
SUMMARY
1 VOLUME I, Summary B a c k g ro u n d....................................................... S-1 Definitions......................................................S-2 Scope............................................................S-3 Task Fo rc e F i n d i n g s.............................................. S-4 C o n c l u s i o n s...................................................... S - 16 R e c o mm e n d a t i o n s.................................................. S - 2 5 VOLUME II Foreword.........................................................i Chapter One -Introduction P u rpo se o f the R e po r t............................................ I-1 H i s t o ry.......................................................... I - l Definitions......................................................I-3 S c o p e o f t h e S t u dy............................................... I - 6 Approach.........................................................I-7 Organi za ti on o f the Report....................................... I-11 Chapter Two - Safeguards Objectives and Functions I n t ro d u c ti o n.................................................... 1 1 - 1 Th e NRC Sa fegua rds 0bj ec ti ve.................................... 11-2 Gui delines to Sa feguards Purpose and Ef fecti veness............... II-2 S a f e gu a rd s F u n c ti o n s............................................ 11-4 C o n c l u s i o n s..................................................... 1 1 - 13 Chapter Three - The Role of Material Control in Fulfilling the Safeguards Objective I n t r o d u c ti o n.................................................... 1 1 1 - 1 De scripti on of a Ma teri al Control Sy s tem......................... I I I-2 The Role of Material Control in Fulfilling the Safeguards F u n c ti o n s................................................... 1 1 1 - 11 System Obj ectives and Goal s for Material Control................. III-17 The Current Ma teri al Control Prog ram............................. III-36 S u m m a ry......................................................... 1 1 1 - 5 0 S-i 1714 163
CONTENTS (continued)
Page Chapter Four - The Role of Material Accounting in Fulfilling the Safeguards Objective I n t r o d u c ti o n.................................................... I V-1 De sc ri ption o f a Materi al Accounti ng System..................... IV-2 The Role of Material Accounting in Fulfilling the Safeguards F u n c t i o n s................................................. I V - 12 System Objec tives and Goal s for Material Accounti ng............. IV-17 Th e Curren t Ma teri al Accounti ng P rogram......................... IV-35 S u mm a ry......................................................... I V - 5 7 Glossary VOLUME III Chapter Five - Proposed Regulatory Upgrades and Supporting Programs I n t r o d u c ti o n.................................................... V - 1 I n te g ra te d S a f e gu a rd s........................................... V -2 U p g ra d e s, H e a r-T e rm a n d L o n g-T e rm............................... V -10 Cu rren t Devel opmen t P rog ram.....................................V-33 S u m m a ry......................................................... V - 5 2 Chapter Six - Special Issues I n t r o d u c ti o n.................................................... V I - 1 Ac ti on Cri teri a for Inventory Di f ferences.......................VI-4 Ma terial Ba l ance Area Accounti ng................................VI-13 The Analysi s o f I nventory Di f ferences...........................VI-20 Ra pi d Ma te ri al Co n trol..........................................V I-35 Collusion and Material Control and Material Accounting..........VI-49 I n fo rma ti o n Fl ow a nd An aly si s.................................. V I-61 Glos sary VOLUME IV Appendix A:
Chronological Development of Material Control and Material Accounting Requirements Appendix B:
Current Requirements and Practices Appendix C:
Measurement and Measurement Quality Control Programs Appendix 0:
Special Inventory Difference Considerations Appendix E:
Evaluation Methodologies S-ii 1714 16,4
CONTENTS
SUMMARY
Page B a c k g ro u n d.....................................................
5 - 1 Definitions.....................................................S-2 Scope........................................................... S-3 T a s k Fo rc e Fi n d i n g s............................................. S-4 T h e Sa f e gu a rd s P rog ran..................................... S-4 Roles of Material Control and Material Ac c o u n t i n g Sy s t en s....................................... S - 7 Object ves for 'iaterial Control and Material Accounting...............................................S-9 Goals for Material Control and Material A c c o u n t i n g............................................... S-1 1 C o n c l u s i o n s..................................................... S-16 R e c omme n d a t i o n s................................................. S-2 5 R e fe r e n c e s...................................................... S - 3 4 S iii 1714 16~b
S-1
Background
Early in 1976, NRC conducted a special review (Reference S-1) of the safeguards maintained by those licensces that possessed significant*
amounts of strategic special nuclear material (SSNM),
i.e., plutonium, uranium-233, or uranium enriched in the uraniun-235 isotope to 20%
or more. One result of the review was the fornation of a Task Force to study the roles of material control and material accounting in the safeguards program.
This study culminated in September 1977, in the formation of a dedicated team to prepare a formal report of the findings.
Specifically, the Task Force was asked to:
1.
Define the roles and objectives of material control and material accounting in the NRC safeguards program; 2.
Recommend goals for material control and material accounting systems based on their roles and objectives; 3.
Assess the extent to which the existing regulatory base meets or provides the capability to meet the recommended goals; 4.
Provide direction for material control and mat ' rial accounting development, including both near-term and long-term upgrades.
This report constitutes the findings of the Task Force.
Five formula kilograms or more.
See Glossary at end of Volume II or III.
1714 166
S-2 Defi ni_tions Before delineating roles, objectives, and goals, it was necessary for the Task Force to develop definitions for material control, material accounting, and physical protection, so that the distinctions among the three systems would be clear.
Clarity of function was essential to the development of descriptions of roles and, subsequently, to the development of objectives for material control and material account.ng.
The definitions used in this report are:
Material Control is that part of the safeguards program encompassf6fnianagement and process controls to:
(1) assign and exercise responsibility for nuclear material, (2) maintain vigilance over the material, (3) govern its internal novement, location, and utiliation, and (4) monitor the inventory and process status of all nuclear material.
Material Accounting is that part of the safeguards program encompassing the procedures and systems to:
(1) perform nuclear material measurements, (2) maintain records, (3) provide reports, and (4) perform data analysis to account for nuclear material.
Physical Protection is that part of the safeguards program encompassing the equipment, procedures, and physical controls to:
(1) protect nuclear materials from thef t or diversion through the use of access and egress controls anc physical barriers, (2) detect attempts at thef t or diversion through the use of surveillance measures and alarm systems, and (3) respond to attempts at thef t or diversion through the use of on-site security personnel and off-site law enforcement assistance.
There are certain safeguards activities and responsibilities that are not covered by one of the systems defined above.
These activities and responsibilities generally pertain to the fuel cycle 171,a 147
S-3 as a whole rather than to site-specific practices.
The Task Force called the collection of these activities " Safeguards fianagement,"
and defined this term as follows:
Safeguards Management is that part of the safeguards program encompassing those NRC activities necessary to assure the ef fectiveness and efficiency of the safeguards prog.-am.
It entails such supportive functions as proposing safeguards legislation, pronulgating regulations, providing regulatory guides, disseminating information concerning penalties for thef t ana rewards for information about potential or actual thef ts, assisting in the analysis of intelligence information, conducting a safeguards research program, and assessing the effectiveness of safeguards across the licensed nuclear industry.
These definitions formed the basis for the Task Force deliberations on material control and material accounting systems.
Scope The Task F)rce limited its considerations to donestic safeguards involving SSNM and to the type of fi.cilities that can possess and use, at any time, more than one effective kilogram
- of such materials.
These materials have a special importance in NRC's safeguards program oecause, in proper form and in sufficient amount, they could be used directly in the construction of a clandestine fission explosive (CFE).
Analysis of the physical protection system was not within the purview of the Task Force and was discussed in the report only where there was obvious overlap of responsibilities between systems. The focus of a
See Glossary for definitions of terms.
1714 168
S-4 the Task Force's deliberations was on existing types of facilities; however, possible impacts of new fuel cycles were considered to the extent time allowed. Consistent with the December 30, 1977, Commission Order on Mixed-Oxide Fuel (Reference S-2), goals specific to possible future facilities for plutonium recycle were not developed.
Task Force Findings The Task Force study evolved in three distinct phases.
In phase one, the functions and objectives of the NRC safeguards program as a whole were defined.
These provided a basis for the description of the roles of the material control and material accounting systems within that overall program. The description of roles and the develop-ment of objectives and specific goals for each system constituted phase two of the study. The third phase consisted of the generation of a
" blueprint" for those future upgrades of material control and material accounting systems needed to implement the goal-oriented approach. The results of the first two phases of the study will be summarized in this section.
The results of phase three, the " blueprint," will be covered in the final section of this summary under " Recommendations."
The Safeguards Program A heirarchical structure (Figure S-1) was developed for.\\c s.!?eguards program based on NRC policy statements (Reference M u t irding 1714 169
FIGURE S-1 NRC SAFEGUARDS PROGR AM N RC SAFEGU ARDS l
PROGRAM l
_i l
I-INTERN ATION AL 7 DOMESTIC l
SAFEGUARDS SAFEGUARDS l_ _ _ _ _ _ J SAFEGUARDS OllJ2CTIVE
-.L 3
p SABOTAGE THEFT OR DIVERSION HOAXES l
g
_J
_ _ L_ _
l 5,
w OTHER SPECI AL STR ATE GlC SPECI AL I NUCLE AR M ATERI AL l NUCLE AR M ATERI AL gL____J SG Functions DETERRENCE PREVENTION
RESPONSE
ASSU R ANCE Demonstration of etfective Impeding adversary actions Loss detection Establishing regulations systems Detection Assusrnent of lossu Ucensing raiew and nafuation S'.:'asares Penalties and rewards Alarm assessment Response plans Demonstration of capabilities Dissemination of information Defeat of attempts Determination of compliance Validation of capabilities Confirmation of material status N
b r- ~ m i
Subjects m dashed bones are not directly addressed in this report.
-g q
CD
S-6 safeguards objectives and functions. Such statements specify three primary safeguards functions:
deterrence, prevention, and response.
The Task Force developed working definitions for the functions in order to to determine how material control and material accounting contributed to them.
Deterrence is the safeguards function that incorporates neasures intended to discourage a potential adversary from attempting a male-volent act. Prevention is the safeguards function that consists of measures to impede or stop an adversary fro;n successfully completing a nalevolent act or successfully perpetrating a hoax. Response is the safeguards function that provides for loss detection and assessment and for a predetermined course of action in response to an actual or alleged theft.
One other function, Assurance, can be inferred from the HRC safeguards objective statements. Assurance is the safeguards function that incorporates nieasures to satisfy the NRC and the public that the safeguards program is in place, that it can respond effectively to a threat or an atteilsted malevolent act, and that nuclear materials are present in assigned locations and accountei for. For the purposes of this report, detection was considered to be aspect of safeguards contributing to all four of the safeguards functions, in varying degrees.
1714 171
S-7 Supporting each of these functions is a set of safeguards measures as shown i n Fi gure 1.
These measures provide the capability to perform the functions.
Roles of Material Control and flaterial Accounting Systems Having structured the safeguards program into four major functions, the roles that material control and material accounting systems should perform were described with respect to their contributions to these functions. The material control system should contribute to Deterrence by providing a means of readily detecting unauthorized removals of SSNM and tracing and identifying suspects, thus deterring those who fear exposure. By maintaining continuous vigilance over material, monitoring process operations, and establishing cross-checks over material movements, material transactions, and administrative controls, the material control system can provide early warning of attempts at thef t or diversion. Full use of process monitoring information can provide additional safeguard alarms and can improve data analysis capabilities.
Thus, the material control system should contribute to the Prevention function by providing timely information to improve material loss alarm responsiveness, leading to the interruption of attempts to steal or divert material.
The material control system, by continuous monitoring and vigilance, should play a major Response role in the rapid discovery of a loss of material.
The material control system should have the primary safeguards role of rapid assessment of losses or alleged losses. Material 1714 172
S-8 control should play an important short-tern Assurance role by providing continuous indication of effective system operation and by confirming material status between physical inventories.
The material accounting system should contribute to Deterrence by providing an af ter-the-fact detection capability for significant material loss and by discouraging those who desire anonymity af ter committing in-transit thef t or falsifying shipping data to disguise theft from a plant.
In the case of a hoax, the material accounting system plays an important Prevention role in combating the alieged thef t by providing records of material quantities and locations to assist in the v >rification of plant holdings. With respect to the Response function, the material accounting system, especially the records, can contribute in a major way to af ter-the-f act loss detection, to the precise assessment of losses or alleged losses, and to the identification of suspects in case of a thef t or diversion.
However, it is in the area of Assurance that material accounting makes its greatest contribution to safeguards. The primary role of material accounting is to provide long-term assurance, through records of holdings verified by physical invento. ies, that material is present in assigned locations and in correct amounts.
In addition, shipper-receiver comparisons provide assuraim' that material has not been lost or stolen in-transit and that overstatements of a plant's shipments or understatements of receipts are not being used to disguise a material loss, thef t, or diversion.
1714 173
S-9 Objectives for Material Control and Material Accounting Systems Once the roles, highlighted above, of material control and material accounting were determined, objectives were written for each system.
Thirteen objectives were developed for the material control system and sixteen objectives were developed for the material accounting
~
system.
The objectives are provided individually in Chapters Three and Four of the second volume of this report, but for this summary have been combined and summarized below.
The Task Force believes that the material control and material accounting systems should maintain cognizance of the status of SSNM through inventory control and process monitoring procedures, periodic material balances, and effective measurement, measurement control, and statistical data analysis programs. Knowledge about SSNM status should be maintained for material within facilities, being transferred between facili-ties, and being discarded as waste. Cognizance of SSNM status should be maintained that is sufficient to provide timely detection of the loss of a significant quantity of SSNM and to assure that physical protection and custodial control programs have been effective.
Cognizance of material status should be maintained that is sufficient to detect:
o Diversion or removal of a significant quantity of material to an unauthorized location within a f acility (detection should occur prior to possible removal of the material from a facility); and 1714 174
S-10 o A single significant loss or a series of small losses of SSNM within a facility, during transfers between facilities, or through waste discards (detection of a series of small losses should occur prior to their accumulation into a significant loss).
The Task Force believes that the material control and material account-ing systems should contain checks and balances to ensure that the systems have not been compromised or circumvented. These checks and balances should be incorporated in procedures and capabilities to:
o Confine the use and internal movement of SSNM to authorized locations and operations through confirmation of authorizations, through deter-mination of types and quantities of SSNM added to or removed from process and storage, and through controls over material transactions to protect against unauthorized transfers of SSNM.
The Task Force believes that the material control and material account-ing systems should have the capability to assess actual or alleged losses and to provide information to law enforcement authorities which will assist in the assessment of such incidents, in the identification of those having had access to any missing material, in the timely apprehension of thieves, and in the recovery of stolen SSNM. This requires the following:
o A capability to provide timely evaluation of external or internal detection alarms from any part of the safeguards system; o An analytical capability for the timely evaluation, localization, and accurate assessment of losses, including characterization of missing material; o A capability to contribute to the identification of individuals with responsibility for, or access to, any missing material; and o A system of records with sufficient security and redundancy to detect attempted record falsification or destruction.
1714 175
S-11 The Task Force believes that NRC has safeguards management responsibili-ties in the area of material control and material accounting, which include the following:
1.
Ensuring licensee compliance with material control and material accounting regulations and periodically evaluating system capabilities; 2.
Monitoring the safeguards status of all facilities licensed to handle strategic special nuclear material capabilities; and 3.
Providing a public record to demonstrate the capabilities and effectivenes of the nuclear material safeguards program.
Goals for Material Control and Material Accounting Based on the general objectives established for material control and material accounting, the Task Force derived a set of specific goals for each system.
Sixteen goals were developed for the material control system, and twenty-two goals were developed for the material accounting system.
The NRC " Operating Assumption on Clandestine Fission Explosives" (CFE)
(Reference S-4) provided a basis for establishing quantitative goals.
Some members of the Task Force had reservations about translating the operating assumption directly.into safeguards criteria because no credit is given in the assumption for a graded approach to safeguards.
If approval were granted for safeguards graded on the basis of material form and material location within a facility, several of the Task Force's goals most likely would be expanded into a number of goals, corresponding to the graded material forms.
1714 176
S-12 The goals for material control and material accounting have been combined in this summary and are presented below in abbreviated form.
Intent statements for each goal appear in Chapters Three and Four.
In support of the objectives related to cognizance of material status, the Task Force believes that material control and material accounting systems should be maintained sufficient to detect, with high assurance *,
the loss of five formula kilograms of SSNM:
1.
In the form of items or sealed containers, accessible to theft, during any single shif t (detection should occur within the shif t during which the loss takes place);
2.
From any controllable unit of a facility within any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period (detection should occur within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the loss);
3.
In a single loss or a combination of small losses f rom any controllable unit of a facility within the interval between physical inventories; 4.
From an entire facility or from smaller accounting units comprising the entire facility on the basis of a periodic measured physical inventory (if accounting units are required, controls should be established to preclude:
i)
Unauthorized removal by an adversary from two or more accounting units; and ii) Falsification of records of one or more accounting units by any adversary having access to material);
5.
From any single shipment (the presence and integrity of all items and containers of SSNM should be verified within one working day of receipt.
Detection of a five formula kilogram loss should occur within 10 days of receipt); and 6.
Fron any combination of shipments over any period of twelve con-secutive months.
- Detection with high assurance is defined to mean a detection probability of 90% or more.
See Glossary for definitions of other terms.
'74
,77
S-13 In further support of the objectives related to cognizance of material status, the Task Force believes that material control and material accounting systems should include:
1.
Bimonthly measured physical inventories; 2.
Procedures to reconcile and adjust book inventory to physical inventory results within 30 days from its beginning; 3.
Procedures to identify, establish cause, and take corrective action for bimonthly and cumulative inventory differences that exceed their associated limits of error, and procedures to ensure that the longer term trend of inventory dif ferences is toward zero; 4.
Identification and reconciliation of shipper-receiver differences statistically significant at the 95% confidence level (statistically significant differences should be resolved during the inventory interval in which they are identified); and 5.
Procedures and measurements, of a quality necessary to achieve the other goals, to substantiate the quantities of all SSNM received, shipped, transferred between control areas, on inventory, or discarded, including:
i)
A rigorous measurement quality control program to calibrate measurement systems and to monitor and control measurement performance within statistical bounds; ii)
Procedures to accurately measure scrap or capability to recover scrap during the inventory period in which it is generated; iii)
Procedures to verify that measurements of liquid and solid waste disca-ds accurately reflect nuclear material content; and iv)
Facilities to provide for and procedures to require that as much material as is practicable is in item form, in calibrated process systems, or in otherwise measureable, verifiable, and controllable form.
1714 178
S-14 In support of the objectives related to establishing checks and balances to protect against compromise or circumvention of the safeguards program, the Task Force believes that the material control and material accounting systems should contain:
1.
Procedures for maintaining continual vigilance over SSNM and cognizance of its status, including:
i)
Qualification and training to ensure that key employees are knowledgeable and maintain safeguards awareness; ii)
Shif t monitoring of process operations and associated records to ensure that all uses, movements, and locations of SSNM are in accordance with a set of written procedures and authorizations; and iii) Assignment of direct responsibility and accountability for all SSNil in a facility to designated custodians who are required to maintain effective stewardship over the material charged to them; and 2.
Provisions for a separation of functions so the activities of one individual or organizational unit serve to check the activities of other individuals or organizational units, including:
i)
Separation of functional duties and responsibilities so that checks are made for authorization of material movement and verification of contents of receipts, intraplant material transfers, and shipments; and ii)
At least three random audits per year to review and appraise the soundness, adequacy, and application of accounting practices, to determine the extent of compliance with procedures, to test the reliability of data and information, and to appraise the quality of performance in meeting assigned responsibilities.
1714
'79
S-15 In support of the objectives related to assessing actual or alleged losses and to providing safeguards information to law enforcement authorities, the Task Force believes that the material control and material accounting systems should have:
1.
The ability, when a loss is detected, to rapidly estimate the size of the loss, identify the loss mechanism, characterize any missing material, and identify those having access to or responsibility for the missing material, including:
1)
Procedures and information sufficient to evaluate process conditions and material records to assess alarms within one hour; ii)
Procedures and capability to conduct, on a demand basis, physical inventories based on measurements to provide a record of quantities of SSNM at a facility and to provide results as soon as possible but no later than 20 days from the day on which the demand was made; and iii) Ready traceability of all transactions from source data to final accounting records.
2.
A system of records with redundancy and security sufficient to:
i)
Limit access to SSNM accounting records to those with a need to know; s
ii)
Secure from falsification or destruction those records that could be used to identify individuals responsible for unauthorized removal; and iii) f asure that an act of record alteration or destruction will not eliminate the capability to provide a complete and vtlid set of SSNM materiai accounting information.
1714 180
S-16 In support of the objectives related to NRC's safeguards management responsibilities needed to monitor safeguards across the nuclear fuel cycle, the Task Force believes that NRC should:
1.
Confirm on a periodic basis that a licensee's material control and material accounting systems are meeting specific material control and material accounting objectives and goals as expressed in the regulations; 2.
Provide a monitoring capability for in-depth data analyses to measure licensee performance against NRC objectives and goals and to assess short and long-term inventory differences, shipper-receiver differences, and other material accounting data of SSNM licensees; and 3.
Generate on a regular basis, public material accounting reports containing accurate, concise interpretations and evaluations to assure the public of the capabilities and effectiveness of the safeguards program.
The Task Force feels that achievement of the specific goals in this report for material control and material accounting will upgrade these systems sufficiently for them to fulfill their defined roles in LRC's safeguards program.
Conclusions During the course of thir study, the Task Force evaluated most of the significant aspects of material control and material accounting. As one result of these evaluations the Task Force drew definite conclusions about the effectiveness, the utility, or the status of current safeguards projects and/or practices. These conclusions are presented in this section.
1714 181
S-17 General The Task Force believes that the current regulatory base is fundamentally sound and that rigorous implementation of its requirements by licensees should provide a substantial level of safeguards protection. However, based on the goals for material control and material accounting developed in this study, the Task Force believes that there are some areas in which strengthening of safaguards is appropriate. The following conclusions high-light these areas, and the subsequent recocinendations address the question of strengthening them.
Integrated Safeguards The Task Force believes that the development of specific goals is needed for an integrated safeguards program to provide in-depth pro-tection against theft, unauthorized removals, and diversion of SSNM.
The proposed goals for material control and material accounting were developed in recognition of an integrated safeguards concept, although specific goals were not available nor developed for an overall program.
Material Accounting The major contribution of material accounting to the safeguards program is to support the assurance function, discussed previously. Material accounting also can contribute to the prevention, response, and 1714 182
S-18 deterrence functions but assurance is its primary role. With respect to the important response measure of loss detection, the Task Force believes that the lack of timeliness of material accounting limits the system's capability to rapidly detect a significant loss with high assurance.
However, material accounting should act as a backup loss detection systen.
Physical security and material control must be designed to make the primary con-tributions to the prevention or the rapid detection of thef t.
Material Control The Task Force finds that material control can nake a significant con-tribution to the prevention of unauthorized removal of SSNM and to the assessment of material losses. Material control can serve a primary role in the safeguards program by providing an ongoing loss detection capability between physical inventories. Al though many licensed operations are not currently meeting many of the goals developed for the material control syciem because there are no NRC requirements to do so, the Task Force feels that the potential capabilities of licensees to meet them generally is high.
Rapid Material Control The conclusions reached in NRC's Special Safeguards Study on Rapid Material Control are supported by the Task For.:e. The use of frequent item checks and electronic sensing systems fo container status 1714 183
S-19 monitoring can be effectively utilized in current safeguards programs.
The concepts in this report involving process monitoring for material control purposes can be designed to provide rapid or timely response capabilities. The Controllable Unit approach to material control shows potential as one means of obtaining the timely process monitoring capability envisioned by the Task Force.
Some licensees currently are accumulating process and production data by computerized systems although at present few are utilizing the information for safeguards purposes.
Computer programs could be designed to use such information for safeguards process monitoring. The NRC should continue to monitor closely the develop-ment of rapid material control systems that are being designed under DOE sponsorship to provide near real-time measurement and analysis of information on material status. At this time the Task Force does not feel that this development work has progressed to a point where a specific recomendation can be made for application.
Action Criteria for Inventory Differences The current regulatory base could be substantially strengthened by specifying actions that should be taken in response to an indicated loss of a significant amount of SSNM. When such an indication is based on material control and material accounting information, the "true" status of the material is not known but is inferred from records and measurement data.
Indicated losses must be investigated to determine, if possible, the actual status of the material in question. Action criteria are needed on 1714 184
S-20 which to base the initiation of the investigations and the conditions under which they should be conducted.
The Task Force believes that action criteria should be based on the detection with high assurance of a loss of five formula kilograms of SSNM. To achieve this capability will require setting a detection alarm threshold at approximately three formula kilograms in order to maintain a reasonable false alarm rate.
The false alarm rate should not be prescribcd by regulation. Rather, NRC should focus on specifying the loss detection requirements. The action criteria of five formula kilograms is based on current NRC policy as expressed in the Operating Assumption on CFEs and on the goals proposed in this report.
The Task Force developed the action criteria shown in Table S-1 as appropriate for response to an indicated loss of SSNM.
Inventory Difference Analysis The primary data analysis in support of material accounting is the comparison of ids with the limit of error on their associated measurements.
This comparison should center on providing assurance that a significant loss of material has not occurred by focusing on the probability of detecting a significant material loss. Al though material accounting by itself cannot provide absolute assurance that a loss has not occurred, small inventory differences (ID) do provide a high level of assurance that a significant loss has not occurred.
The Task Force finds that additional analysis, in the form of a cumulative ID (CUSUM) approach and long-term trend analysis would strengthen the loss detection capability and the assurance provided by ID/LEID comparisons.
1714 185
S-21 TABLE S-1 1
ACTION CRITERIA FOR INVENTORY DIFFERENCES CRITERIA BIMONTHLY BIMONTHLY l
INVENTORY LIMITS OF CUMULATIV[
ACTION TAKEN ICURRENT/ PROPOSED DIFFERENCES (ID)2 ERRORS ON ID (LEID)
ID (CID)
Current IIDl> LEID LEID>.5% T None and Investigate lIDl<0.75% T Proposed lIDl> LEID LEID > 3 Fkg ICIDi> LECID and Or long term trend IIDl< 3 Fkg in ICIDI is signifi.
cantly greater than 0.
Investigate and begin reinventory Current 0.75%T < $0l< l.0%T N/A N/A immediately Investigate and begin reinventory Proposed 3 Fkg <lIDl< 5 Fkg N/A N/A within 3 days Shutdown and inves-tigate. Reinventory within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Current lIDl>l.01 T N/A N/A Resume operations when
[TDl<.75% T or when NRC approves Shutdown and inves-ti gate. Begin clean-out inventory within Proposed ID> 5 Fkg N/A N/A 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Resume operations when ID < 3 Fkg or when NRC approves
- 1. T = throughput, Fkg = formula kilograms (see glossary in Volume II),
l jindicates an absolute value, and h/A = not applicable.
- 2. Minimum thresholds of 200 grams of Pu or U-233 grams of HEU must be exceeded before. any action is required.
- 3. Consideration should be given to a shutdown-cleanout inventory if the investigation fails to reveal the cause of the problem.
1714 186
S-22 Material Balance Area Accounting Accounting on a Material Balance Area (MBA) basis should enable licensees, who cannot do so on a facility basis, to detect with high assurance a five formula kilogram loss of SSNM.
In addition, MBA accounting provides an improved ability to localize losses and a means for identification of suspects in the event of thef t.
Evaluation Methods Evaluation methods will be needed to determine if licensees are meeting the goal-oriented material control and material accounting systems the Task Force proposes. The attributes needed for these evaluation methods were identified in the report. The techniques used in NRC's Comprehensive Evaluation Program (CEP) will be valuable for future assessments. The National Bureau of Standards' " Diversion Path Analysis",
the Lawrence Livermore Laboratory's " Material Control System Assessment Procedures", and the Science Applications, Inc.
" Security Force Collusion" techniques provide important complementary capabilities.
Regulatory Upgrades The contribution of the material control and material accounting systems to safeguards can and should be increased.
This can be done by means of a time phased amendment to the regulations. Phase One of the new 1714 187
S-23 regulation would provide for implementation of short-term upgrades (18 to 24 months) while Phase Two would cover those upgrades that would require more significant system changes or development of new techniques (within five years).
High priority upgrades should be made in material control prac cices (specifically in process monitoring, item control, and custodial control) to strengthen their safeguards capabilities, and in measurement verification practices to guard against the mis-statement of material quantities. Priority upgrades should be made in material balance accounting, in the handling of shipper / receiver differences, in scrap control, in measurements, in management control, and in record security. Several upgrades call for the development of regulatory guides to provide licensees with specific guidance regarding implementation of the goals in this report. This action will require revitalization of NRC's regulatory guide program in the area of fuel cycle safeguards.
NRC Program Upgrades Several goals developed by the Task Force directly involve HRC activities. These can be grouped into three areas; NRC monitoring, public reporting about the safeguards program effectiveness, and IAEA support. The primary upgrades needed to support the NRC program 1714 188
S-24 envisioned by the Task Force are in the monitoring area, a Congressionally mandated measure in support of the assurance function.
NRC Technical Assistance Program Based on a review of the current NRC safeguards technical assistance activities, the Task Force finds that (a) the Controllable Unit Accounting (CUA) program, (b) NRC's efforts to provide a base to improve measurement and measurement quality control, and (c) the use of NRC Inspection and Enforcement assay vans and outside laboratories to test licensee inventory quantities are activities that have considerable potential for application in the safeguards program envisioned by the Task Force.
The Nuclear Materials Management and Safeguards System (NMMSS), the infor-mation system supported jointly by NRC and DOE to receive data on nuclear materials and to report on material status, neither receives nor provides all the data and infornation needed to meet the goals in thic report per-taining to NRC monitoring responsibilities. The Task Force goals envision a routine and improved data collection processing and analyzing capability within NRC to support its policy making functions and to carry out the monitoring responsibility as assigned in the Energy Reorganization Act of 1974.
1714 189
S-25 Collusion and Material Control and Material Accounting There appears to be a " conspiracy" size at which " optimum" safeguards would change from primary reliance on procedural and technical safe-guards against collusion to primary reliance on a clearance program.
There appears to be a rational basis for developing and evaluating material control and material accounting measures against collusion.
Information about the effectiveness of these measures currently is lacking and should be developed.
Recommendati ons The Task Force's recommendations follow from the goals developed for material control and material accounting systems and the assessed capability of the current regulatory base to meet them. Al though the recommendations were based on the conclusions in the previous section, they are grouped here for programmatic convenience as follows:
Material Control and Accounting Upgrade Rule; NRC Operations; Regulatory Guides; Supporting Studies; and Research and Technical Assistance.
The recommendations provide a " blueprint" for the development of future material control and material accounting systems.
Before action is taken to implement these recommendations, particularly those requiring rule making, a value-input analysis of the suggested actions should be prepared. This analysis will influence the way 1714 190
S-26 that these Task Force reccamendations actually are implemented.
Development of regulations and value-impact analyses were beyond the scope of this report.
Material Control and Material Accounting Upgrade Rule The Task Force recommends that NRC promulgate a material control and material accounting upgrad? rule, following appropriate value-impact analysis, to implement the goals contained in this report.
The rule should be issued in two phases; the first to be implemented in 18 to 24 months from NRC approval of the goals as acceptable targets for the safeguards program for SSNM; the second to be implemented within five years as technology under development is proven.
To implement Phase One, NRC should require licensees to:
1.
Incorporate existing or available process monitoring techniques into their safeguards programs; 2.
Maintain shif t inventury controls over items and containers; 3.
Have an independent observer attest to the validity of quantities of SSNM discarded; 4.
Have an independent verification measurement on intra-plant material transfers, or have an independent observer or the second party to the transfer attest to the validity of the original measurement; 5.
Improve procedures to provide ready traceability and information throughout the accounting process, including a technical review of source data for errors and irregularities and overchecks to ensure the accuracy of the bookkeeping process; 1714 191
S-27 6.
Develop facility specific plans to respond to NRC requests to perform' special physical inventories (on demand) in a timely manner; 7.
Where appropriate, upgrade plant custodial practices and improve pro-cedures for addressing scrap recovery problems to the extent necessary to meet current material accounting requirements; 8.
Reconcile statistically significant shipper / receiver differences within 30 days of their detection; 9.
Conduct rar dom audits of their material control and material accounting programs three times per year;
- 10. Select, train, and qualify key material control and material accounting personnel in accordance with specified criteria; To implement Phase Two of the Upgrade rule, flRC should require licensees to:
1.
Maintain a record system meeting designated minimum specifications or performance criteria; 2.
Maintain daily controls over the status of bulk quantitites of SSNM; 3.
Provide NRC with the material accounting data which NRC requires to make use of applicable sophisticated data analysis techniques for monitoring material status; 4.
Provide NRC with data on shipped quantities and associated measurement errors for all interplant transactions involving more than 50 grams of SNM; 5.
Establish control limits for measurement uncertainties and inventory differences at the individual MBA level if required to insure the desired detection sensitivity and loss assessment capabilities required by the goals, and take specific actions if these control limits are exceeded (see Table S-1).
1714 192
S-28 6.
Take prescribed investigative and corrective actions in response to inventory differences that exceed the recommended control limits in this report (see summary of Action Criteria for Inventory Dif ferences, Table S-1);
7.
Compute cumulative inventory differences and take prescribed investigative and corrective actions if they exceed the recommended control limits in Table S-1; 8.
Process SSNM containing scrap or characterize it sufficiently well, within the inventory period in which it is generated, to meet the proposed material accounting goals; and 9.
Conduct vulnerability analyses of the material control and material accounting systems.
NRC Operations To assure a cost-effective safeguards program designed to protect SSNM against thef t or diversion, the Task Force recommends that NRC:
1.
Develop specific goals and objectives for an integrated safeguards program; 2.
Continuously monitor safeguards programs in terms of these goals; 3.
Develop an evaluation program encompassing a broad set of evaluative techniques with the goal of incorporating, in a consistent manner, the evaluation attributes defined in this report (see Appendix E); and 4.
Develop techniques for protecting against collusion, giving specific consideration to the contributions of material control and material accounting.
To improve NRC's monitoring responsibility assigned to NMSS in the Energy Reorganization Act of 1974, the Task Force recommends that a 1714 193
S-29 program of routine analysis and evaluation of material accounting data be established to:
1-Analyze cumulative inventory differences and shipper /
receiver differences, and evaluate incidents in which licensees fail to meet the goals proposed in this report; 2.
Assess trends, biases, cumulative effects, and inter-plant relationships in licensee material accounting data; and 3.
Review position descriptions and training programs for key material control and materiai accounting personnel, requiring improvements if appropriate.
To improve the bases for monitoring material control and material accounting performance across the nuclear industry, the Task Force recommends:
1.
The expeditious implementation of licensee plans for measurement control programs submitted in response to Section 70.57(c) of Title 10 of the Code of Federal Regulations; 2.
The review and upgrading, as necessary, of measurement error propagation models used by each licensee; 3.
Revision of Nuclear Materials Management and Safeguards System (NMMSS) reporting entities for SSNM licensees to be consistent with the partitioning of facilities into plants or, if appropriate, accounting units; 4.
Review of NMMSS reporting entities for SSNM licensees to assure that data for high enriched uranium operations are clearly separated from low enriched uranium operations; 5.
Upgrade the edit;ng by NMMSS of reported licensee safeguards data for accuracy and consistency; and 1714 194
S-30 6.
The acquisition of a) a secure interactive computer capability for use in collecting, storing, sorting, and analyzing special nuclear material accounting data, and b) associated flexible computer sof tware that presents safeguards information in a succinct and omprehensive manner.
The Task Force recommends that NRC provide greater visibility to the assurance provided by the overall safeguards program by:
1.
Continuing to provide the public with periodic reports containing information on the status of special nuclear material; 2.
Developing an increased capability to respond to public inquiries concerning safeguards; and 3.
Improving the NRC public reporting system by including assessments of the effectiveness of the overall safeguards program instead of limiting reporting to material balance resul ts.
In the area of international safeguards, the Task Force recommends that:
NRC continue to assist the IAEA in the preparation of subsidiary arrangements and facility attachments, the collection of design information, and the development of appropriate information reporting systems.
Regulatory Guides and NUREG Reports To assist licensees in designing capabilities to upgrade their material control and material accounting systems to fulfill goal-oriented requirements as proposed in this report, the Task Force recommends the revitalization of the Regulatory Guide program in the area of nuclear material safeguards. Specifically, the Task Force recommends that NRC develop and publish Regulatory Guides and NUREG Reports on:
1714 195
S-31 1.
Performance standards for effective custodial control and for maintaining vigilance over material; 2.
Techniques for the propagation of measurement errors, including illustrative examples; 3.
Design of material accounting systems to meet Task Force goal s; 4.
Evaluation and reconciliation of shipper / receiver differences, including review and upgrading of Regulatory Guide 5.28,
" Evaluation of Shipper / Receiver Differences in the Transfer of Special Nuclear fiaterials; 5.
Standards for organizational plans and procedures for delegation of authority; 6.
Specifications for licensee personnel selection, training, and qualification programs; and 7.
Design of material control and material accounting prograns to meet the requirements of a proposed rule to implement the pending US/I AEA agreement.
Supporting Studies The Task Force recommends that studies be initiated or continued, as appropriate, to support the goal-oriented safeguards program.
Specifically, studies are needed to:
1.
Develop objectives and goals for the total safeguards program in the same degree of detail and specificity as those proposed for material control and material accounting in this report; 2.
Determine a quantitative measure or at least a figare of merit for the effectiveness of a security clearance program, based upon full-field background investigations, in protecting against malevolent conspiracies involving two or more security cleared individuals; and 1714 196
S-32 3.
Support the development of the proposed Material Control and Material Accounting Upgrade rule by a) determining the best me3ns to rrovide independent verification of the quantities of SSNM discarded as waste, b) determining an appropriate absolute quantitative action limit, in addition to its limit of error, for cumulative inventory differences, and the optimum number of successive inventory periods to be included in the cumulative inventory difference test, c) developing a comprehensive characterization of the accounting problems associated with the
.'.ccumulation of scrap materials in various portions of the fuel cycle and suggestions to resolve these problems cost-effectively, and d) establishing performance criteria or minimum specifications necessary to meet the proposed goals for records,ystems and for the requisite safeguards against their falsification and destruction.
Research and Technical Assistance The Task Force reviewed or had direct knowledge of the majority of research and technical assistance programs being conducted for NRC in the areas of material control and material accounting.
On that foundation, the Task Force feels that substantial technical support is being generated to provide the basis for goal-oriented requirements.
The Task Force recommends that NRC give priority, within its research and technical assistance programs for:
1.
Evaluation and testing of concepts, technology, and capabilitiet for ar, plying process monitoring techniques to material contrsl systems for the timely detection and assessment of actual or alleged material losses; 2.
Implementation of secure and automated storage of item; and containers of SSNM, and the associated continuous monitoring of their presence and integrity; 3.
Programs for development and publication of NUREG documents to assist licensees in improving measurement systems and measurement controls including:
(a) supporting the National Bureau of Standards program for development of reference standards and reference measurement techniques, (b) evaluating techniques for estimating quantities of SS&1 1714 197 3
S-33 held-up in process equipment, piping, and work stations, (c) evaluating and demonstrating NDA and on-line measurement equipment applicable to process monitoring within the nuclear fuel cycle (d) disseminating methodology for calibrating and monitoring measurement systems, and (e) obtaining concensus on statistical techniques, for (i) characterization and treatment of systematic errors, (ii) refinement of error propagation techniques, and (iii) establishment of the statistical base for controlling measurement performance; and 4.
Development and publication of NUREG documents to assist licensees in the use of evaluative methods for assessing inventory differences and in developing investigative techniques and strategies to resolve excessive inventory differences.
There was one significant area of current technical assistance effort that the Task Force did not have the time to evaluate as to its applicability to the goal-oriented program described in this report.
This technical assistance effort is concerned with the game-theoretical approach to analysis of material accounting data.
The Task Force recommends that:
HRC establish a peer review consisting of covernment, academic, or industrial professionals knowledgable about game theory and about safeguards, to assess the utility of strategic analysis for safeguards in general and for analyzing inventory difference and other material accounting data in particular.
Chapters One through Six of the report discuss the concepts, objectives, goals, conclusions, and recommendations in this summary. Appendices A through E present detailed technical discussions and explanations to support the main body of the report.
1714 198
S-34 References - Sunnary S-1
" Joint ERDA-NRC Task Force on Safeguards Final Report,"
(Unclassified Version), NUREG-0095, ERDA 77-34, U.S.
Nuclear Regulatory Conmission and U.S. Energy Research and Development Administration, July 1976.
S-2 U.S. Nuclear Regulatory Cornission Order, " Mixed-0xide Fuel," Federal Register, Vol. 42, No. 251, December 30, 1977.
S-3 Chilk, Samuel J., Secretary of the Connission, memorandum for Lee V. Gossick, Executive Director for Operations, SECY-75-729A,
" Safeguards Objectives," May 21, 1976.
S-4 Gossick, Lee V., NRC Executive Director for Operations, memorandum of August 8,1977, " Operating Assumption on Clandestine Fission Explosives."
1714 199
UNf f E D STATES I
NUCLE AR RE GULA TORY COMMISSION W ASHINGT ON, D. C. 2056S U S. NUC LE A R OS GUL A TOM %
OF FICI AL SUSINESS cow MesseoN PEN ALTY FOR PRIVATE USE, $300 tJ 1714 200