ML20097G994
| ML20097G994 | |
| Person / Time | |
|---|---|
| Issue date: | 12/31/1995 |
| From: | Joy D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| References | |
| NUREG-1065, NUREG-1065-R02, NUREG-1065-R2, NUDOCS 9601290207 | |
| Download: ML20097G994 (62) | |
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,P AVAILABILITY NOTICE
< Availability of Reference Materials Cited in NRC Publications Most documents cited in NRC publications will be available from one of the following sources:
1.
- The NRC Public Document Room, 2120 L Street, NW., Lower Level, Washington, DC r
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t NUREG-1065 Rev.2 Acceptable Standard Format and Content for the Fundamental Nuclear Material Control (FNMC) Plan Required for Low-Enriched Uranium Facilities 1
I Manuscript Completed: November 1995 Date Published: December 1995 i
i D. R. Joy Division of Fuel Cycle Safety and Safeguards Omce of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission j
Washington, DC 20555-0001 e%.,,
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Abstract This document provides a revised structure for tion or utilization facilities licensed pursuant to NUREG-1065, Revision 1, dated 1985, which 10 CFR Part 50 or Part 70 and waste disposal contains information that the licensee or applicant facilities) that are authorized to possess and use j
should provide in its fundamental nuclear material more than one effective kilogram of unencapsulated control (FNMC) plan. The revised structure has SNM of low strategic significance. Unlike the been patterned after the acceptable standard format structure of the enrichment guide, however, this and content for the FNMC plan required for low revision for NUREG-1065 includes a complete set enriched uranium enrichment facilities, of affirmations required from licensees. R ese are NUREG/CR-5734, K/ITP-415, dated 1991. That the same affirmations that appeared in Revision 1 of document was structured in a manner to serve as a NUREG-1065 but in some instances the language direct outline for licensees preparation of their has been modified to clarify intent.
FNMC plan while NUREG-1065 was structured to more closely follow and elaborate on the contents All other modifications involve format and editorial j
of 10 CFR 74.31.
changes designed to provide clarifications and j
facilitate preparation or revision of the required i
This revised structure for NUREG-1065 continues FNMC plan.
to implement the requirements of 10 CFR 74.31.
It applies to NRC licensees (other than produc-l J
iii NUREG-1065 Rev. 2
4
.i Contents Page 1
iii i
Abstract........................................................................
4 A c ronyms........................................................................ ix 1
Int rod uc t ion..................................................................... 1
. Performance Objectiws, System Features and Capabilitics, and Affirmat6ns..................... 3 4
j Performance O bjectives........................................................ 3 e
Affirmations Pertaining to Performance Objectiws.................................... 5 Affirmations Pertaining to System Capabilities....................................... 5 1 Organization.................................................................
11'
~ 1.0 Re gula tory la tent...................................................... 11 4
1.1 Corporate O rganization.................................................. 11 1
12 Plant or Site O rganization................................................ 11 13 MC& A O rganization.................................................... 1 1 13.1 Responsibilities and Authority........................................ 11 13 2 MC& A Procedures................................................ 12 j-Training and Qualification Requirements..................................... 12 1.4 4
j 1.5 MC& A System Description............................................... 12 1.6 Acceptance Criteria..................................................... 13 j
1.7 A ffirma t ions.......................................................... 14 i
2 Mea sure me nt s................................................................ 15 2.0 Regulatory Intent....................................................... 15 2.1 M easure ment Points.................................................... 15 22 Measurement Systems................................................... 15 I
22.1 Bulk Measurement Systems........................................... 15 I
222 Analytical Measurement Systems....................................... 16 223 ND A Measurement Systems.......................................... 16 2.2.4 Other Measurement Systems.......................................... 16 23 Measure ment U ncertainties............................................... 16 4
2.4 Measurement Procedures................................................. 16 1
2.5 A cceptance Criteria..................................................... 17 2.6 Affirmations.......................................................... 17 q
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3 Measurement Control Program.................................................... 19 1
4 1
3.0 R e gula tory Intent........................................................ 19 i
a-3.1 O rganization and Management............................................. 19 l
3.1.1 Functional Relationships............................................. 19 l
3.12 Procedures....................................................... 19 3.13 Contractor Program Audits and Reviews................................. 19 i
32 Calibrat ions........................................................... 20 33 Control Standard Program................................................ 21 3.4 Replicate Program...................................................... 22 3.5 Control Limits......................................................... 22 3.5.1 Measurement Control Data Analysis.................................... 23 i
3.5 2 Response Actions.................................................. 23 3.6 - Acceptance Criteria..................................................... 23 t
3.7 A ffirmations.......................................................... 25 i
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NUREG-1065 Rev.2 1
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1 4 Sta tist ic s..................................................................... 2 7 4.1 Determination of Measurement Uncertainties.................................. 27 4.2 Determination of SEID.................................................. 27 43 B ias Corrections....................................................... 28 5 Physical In ventories............................................................ 29 t
5.0 Re gulatory latent....................................................... 29 i
5.1 G eneral Description..................................................... 29 52 Organization, Procedures, and Schedules..................................... 29 53 Typical Inventory Composition............................................. 29 i
5.4 Description of Typical item Strata.......................................... 30 i
5.5 Conducting Physical inwntories............................................ 30 l
5.6 Inventory Difference Limits and Response Actions.............................. 32 5.7 Acceptance Criteria...................................................... 32 5.8 A ffirmat ions.......................................................... 33 t
6 I te m Control................................................................. 35 6.0 Regulatory latent....................................................... 35 i
6.1 O rganizat ion.......................................................... 35 62 G eneral Description..................................................... 35 63 Item Identity Cont rols................................................... 35 6.4 Storage Con trols....................................................... 36 l
6.5 Item Monitoring Methodology and Procedures................................. 36 36 6.6 Investigation and Resolution of Item Discrepancies...............................
6.7 Acceptance C rite ria..................................................... 36 6.8 A ffirma t ion s......................................................... 37 i
7 Shippe r-Receiwr Comparisons.................................................... 39 l
r 7.0 R e gula tory Inten t....................................................... 39 7.1 Receiving Procedures.................................................... 39 72 Determination of Receiver's Values......................................... 39 73 Evaluation of Shipper-Receiwr Differences.................................... 39 7.4 Resolution of Significant Shipper-Recciwr Differences........................... 40 l
7.5 Acceptance Crite ria.................................................... 40 7.6 A ffirma tions.......................................................... 40 i
8 Assessment and Review of the Material Control and Accounting Program.................... 41 t
41 1
8.0 Re gulatory Intent..............................
8.1 General Description.................
................ 41 82 Report of Findings and Recommendations.................................... 42 l
i 83 Management Review and Response to Report Findings and Recommendations......... 42 l
8.4 Acceptance Crite ria..................................................... 42 8.5 A ffirma t ions.......................................................... 43 4
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9 Resolving Indications of Missing Uranium........................................... 45 j
9.0 Regulatory latent...................................................... 45 9.1. Methods and Procedures for Identifying Indicators.............................. 45 92 System and Procedures for Inwstigating and Resolving Indicators................... 45 l
93 Response Actions for Unresolved Indicators................................... 45 9.4 Documentation Requirements............................................. 46 9.5 Acceptance Criteria.................................................... 46 9.6 A ffirma t ions.......................................................... 46 1
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NUREO.1065 ' Rev. 2 vi
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r 10 Informational Aid for Assisting in the Investigation and Recovery of Missing Uranium..........
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a 10.0 Regulatory latent..................................
............47 10.1 Information Aid
..............................................47 10.2 Acceptance Criteria............................................. 48 10.3 Affirmations
.................................48 11 Recordkeeping
......................................................49
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11.0 Regulatory latent...............................................49
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11.1 Description of Records............................................. 49 11.2 Program and Controls for Ensuring an Accurate and Reliable Record System.......... 50 11.3 Acceptance Criteria.............
................................50 1 1.4 Affirmations................................
.................51 G lossary............................................................. 5 3 l
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vii NUREG-1065 Rev. 2
i Acronyms
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CFR Code of Federal Regulations NRC U. S. Nuclear Regulatory Commission DQ Detection quantity SEID Standard error of the inventory l
DT Detection threshold difference l
FKG Formula kilogram SNM Special nuclear material FNMC Fundamental nuclear material control SRD Shipper-receiver difference s
Uranium IAEA International Atomic Energy Agency U-233 Uranium-233 J
ICA Item control area U-234 Uranium-234
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ID Inventory difference U-235 Uranium-235 LEU loweriched uranium U-238 Uranium-238 l
MBA Material balance aren UO Uranium dioxide 2
4 MC&A Material control and accounting U,0, Urano-uranic oxide NDA Nondestructive assay UF.
Uranium hexafluoride NMMSS Nuclear Materials Management and wt %
Weight percent i
Safeguards System l
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ix NUREG-1065 Rev. 2 i
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Introduction An applicant's fundamental nuclear material control objectives of 10 CFR 74.31 and the MC&A system (FNMC) plan must demonstrate how the basic features and capabilities needed to meet the capabilities specified in 10 CFR 74.31(c) are objectives. The chapters that follow incorporate achieved and maintained and how such capabilities and expand on (1) the general performance are used to achieve the performance objectives objectives, and (2) the system features and listed in 10 CFR 74.31(a). After acceptmg an capabilities. The first eight chapters are arranged FNMC plan and imposing it as a condition of in a sequence corresponding to the system license, the IJ.S. Nuclear Regulatory Commission capabilities required by 10 CFR 74.31(c)(1) through (NRC) willjudge the adequacy of a licensee's (8), of which (c)(5), and hence chapter 5, deals materials control and accountability (MC&A) with the first performance objective of confirming performance by inspecting for compliance with the presence of SNM. Chapters 9 and 10 address commitments and practices described in the plan.
the second and third performance objectives -
' resolving indications of missing uranium" and " aid Because 10 CFR 74.31 is, for the most part, a in the investigation and recovery of missing performance-oriented regulation, the emphasis is on material". Chapter 11 deals with the record defining objectives rather than the means for keeping requirements of 10 CFR 74.31(d).
achieving them. Thus, applicants and licensees Together these 1I chapters provide applicants or have many alternatives with regard to how their licensees an outline for an FNMC plan.
MC&A system and program are designed, managed, and operated. IIence, this document ne body of an FNMC plan, corresponding to cannot begin to cover all possible methodologies Chapters I through 11, shall be a condition of that a licensee might use to achieve the desired license, and compliance with the FNMC plan objectives. Instead, this document provides commitments, the required affirmations, and related examples of acceptable MC&A approaches procedures will be inspectable. Explanations and commonly or typically used by low enriched discussions appearing in the body of the plan should uranium fuel fabricators. His document is be detailed and precise, as opposed to general and intended for use by applicants, licensees, and NRC vague, so that all parties concerned (i.e., NRC safeguards licensing reviewers. For the most part, licensing reviewers, NRC inspectors, and licensee recommended criteria are not to be regarded as personnel responsible for plan execution) have a rigid, fixed standards. That is, a lower clear and nonconflicting understanding of the what, elfectiveness of one feature relative to a particular how, and when aspects of each plan commitment.
aspect can be tolerated if there is a compensating feature, or combination of features, that provides an ne annex (or appendix) of an FNMC plan should overall effective safeguards system. Although not provide supplementary and general information likely, a licensee could fail to meet most of the about the facility and the MC&A system [e.g.,
criteria recommended in this document and still copies of blank record forms, site map, process achieve the regulatory objectives. In the final diagrams, an example standard error of the analysis, an NRC reviewer must make a judgment inventory difference (SEID) calculation, etc.]. The as to whether the applicant or licensee can achieve annex will not be incorporated as a condition of with high probability, without going beyond its license and wi!! not be the basis for inspection.
FNMC plan commitments, the objectives stated in Thus, descriptions presented by the applicant or 10 CFR 74.31(a). He recommendations provided licensee to satisfy regulatory intent must be in the herein pertain to both applicant submitted FNMC plan itself, rather than the annex, and must provide plans and any revisions made to existing approved adequate detail so as not to be largely dependent on plans.
examples or supplementary information in the annex for proper understanding.
Pages 3 through 10 of this intnxluction section desenbe the basis of the three general performance 1
NUREG-1065 Rev. 2
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Performance Objectives, System Features and Capabilities, and Affirmations i
Performance Obj*ectives matarial within the facility using itaan control
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integrity of items until they are intral-8 to
. De general performance objectives and the system the process and (2) to ensure all SNM capabilities to be addressed by the FNMC plan are quantities of record associated with receipts, i
set forth in 10 CFR 74.31. De basis on which shipments, discards, and ending inventory each of the three general performance objectives are based on measurements.
and eight system capabilities were fonned is Recommendations for meeting the described in the following paragraphs of this section performance objectives for the item centrol together with identification of the related required program are provided in Chapter 6 of this i
licensee affirmations.
document, and for measurements and measurement control programs are provided General Performance Objectives in Chapters 2 and 3, repectively.
Monitoring the material in process may l
involve the use of process or material control i
data. A detailed and accumte recordkeeping l
1.
Confirin the m of special maclear system for the generated data that provides r
unaterial knowledge of the material's location on a l
timely basis should be maintained to support ne purpose of this objective is to verify the this function.
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presence of or to detect the occurrence of any significant loss or theft of special nuclear The licensee should conduct total plant material (SNM). To maintain current physical inventories at an average interval of information of the SNM in their possession, no more than 12 months, with no single licensees should have in place a program that interval (between any two consecutive l
provides timely, accurate, reliable physical inventories) being greater than 13 information about the quantity and location of calendar months. Each physicalinventory materials in their possession. Accurate must be conducted in a manner that provides information means that item quantities for at least a 90 percent power of detecting any i
both the element uranium and the isotope U-actual loss or theft of a detection quantity i
235 are based on measured values or on (DQ) that may have occurred since the last reliable factors. Reliable information means yearly inventory. A DQ is a site-specific that the quantity of material in an item and quantity of U-235, the magnitude of which is the location of all items is known (with the discussed in Chapter 4 of this document.
possible exception of items that have been created, transferred, or consumed within the The licensee should verify the presence of all past 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) and that the k> cation SNM currently possessed by the facility, as designations are specific enough to provide stated in its accounting records. His for the retrieval of the items in a pmmpt verification is normally accomplished by a manner. Reliable information also means shutdown and cleanout of processing i
that the quantities and locations of all classes equipment, measurement of cleanout of material and items listed in the accounting materials and measurement of any materials I
records are correct and verifiable (with the not previously measured in their existing possible exception of items that have been form, visual verification (on a 100 percent created, transferred, or consumed within the basis) of the presence of all possessed SNM l
past 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />).
items (by means of unique item identities),
and confirming the SNM quantities De licensee or applicant should accurately associated with unencapsulated and unsealed I
account for all SNM that is received and items on ending inventory. However, a l
shipped by maintaining reliable records based dynamic (i.e., nonshutdowa) inventory of on accurate measurements. When a shipment some or all processing equipment may be l
is received, the licensee should begin utilized if the mea,urement uncertainty monitoring movement and kication of the associated with the total material balance (for 3
NUREG-1065 Rev. 2 eI f
4
c.
Objectives and Capabilities the inventory period) is within the 0.25 Multiple loss indications from items and/or percent of active inventory constraint process equipment within a material balance specified in 10 CFR 74.31(c)(4).
period must be resolved even though the loss Recommendations pertaining to physical from each event is less than 500 grams of inventories are detailed in Chapter 5 of this U-235. This resolution need not occur until document. In summary, a total plant the total potential loss equals or exceeds 500 physical inventory involves:
grams of U-235.
(1) verifying the presence, on a 100 Resolution of an indicator depends on the percent basis, of all uniquely identified type of indicator. Anomalies at plants can SNM items listed in the accounting indicate a number of scenarios from simple records theft to complex diversions. The resolution process in some cases should begin with a (2) measuring (by direct measurement or, thorough review of the MC&A records to if direct measurement is not feasible, locate blatant errors. These errors might by indirect measurement) all bulk include omissions of entire items, incorrect SNM quantities on hand (i.e., all entries to computer programs or records, SNM not in item form) transcription errors, incorrect estimates of the amount of holdup in equipment, or (3) measuring any items not previously calculational errors. A detailed examination measured of the MC&A records for each material type should identify gross errors. The next stage (4) verifying the identity and integrity of in the resolution process would be to isolate all encapsulated items and items the process or storage area that appears to be affixed with tamper-indicating seals causing the anomaly. Once this is accomplished, all of the information that (5) measuring a SNM related parameter contributed to the SNM quantities for that for a sample of randomly selected location should be verified. If resolution still unencapsulated and unsealed items, is not accomplished, the licensee should based on a statistical sampling plan, to remeasure and sample material in the process verify the previously measured or storage areas to verify quantities. If the quantities of SNM ccmtained in such investigation of an indicator results in a items detennination that an actual loss or theft has occurred, the loss or theft must be reported The physical inventory program should be to NRC pursuant to 10 CFR 74.11.
managed and maintained independent of the production or operations organization but 3.
Aid in the Investigation and Recovery of should not be excluded from using process Missing Material monitoring and production control data.
If the NRC and/or other government agencies 2.
Resolve Indications of Missing Uranium deem it necessary to conduct an investigation relating to actual (or highly suspected) events The licensee or applicant should have a pertaining to missing material, the licensee is formalized program to resolve any indication to provide, without specifically being asked, that SNM is missing. Resolution of such any information deemed relevant to the indicators means that the licensee has made a recovery of material involved in a loss, theft, determination that a theft or loss of SNM has or diversion. The burden shall be on the not occurred. Only indications that suggest a licensee to provide (without being asked) all possible loss of items or material from items information that it recognizes as being equal to or greater than 500 grams of U-235 relevant, as opposed to providing only need be investigated; a possible loss of a informaticn that the investigators request.
detection quantity detected during a material Additional information and recommendations balance closure needs to be investigated and pertaining to providing information to aid in resolved in accordance with 74.31(c)(5).
NUREG-1065 Rev. 2 4
r Objectives and Capabilities investigations are provided in Chapter 10 of To meet the three general objectives, the MC&A this document.
system depends on features and capabilities as required by 10 CFR 74.31(c)(1) through (c)(8) and 74.31(d). These system capabilities and their The licensee is required to make affirmations related affirmation statements are identified below,
)
with respect to these three pesformance and are discussed in Chapters I through 8 and 11 of objectives and the eight systesu capabilities, and this document.
these must be stated (without any noodification) in the FNMC plan. The affirmations are listed (1)
Establish, document and maintain a heloW*
management structure which assures clear overnil responsibility for material control and Affinitiations Pertaining to Performance accounting functions, independence of Objectives MC&A managernent from production responsibilities, separation of key An MC&A system will be maintained that is resp nsibilities and adequate review and use capable of confirming, at least annually, the of critical material control and accounting presence of all SNM expected to be present procedures.
(at a given time) based on the accounting Islgers, with the possible exception of wate in its FNMC plan, the licensee must make
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materials transferred to (via DOE /NRC Form the followmg affirmahons with respect to j
741 transactions) and stored in holding management structure:
accounts.
Responsibility for the overall MC&A system
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An expeditious investigation will be promptly management is assigned to a position that is initiated for all indications of significant separate from production responsibilities or losses (2500 grams of U-235) of SNM and any other responsibilities that may give rise 1
each allegation or indication of SNM theft.
to conflict of interest.
Information will be provided to appropriate The responsibility for each MC&A function Federal Authorities to aid in their investiga-i8 assigned to a specific position in the r
tion of indications of missing material and in organization, and the organization is the recovery of SNM in the event of a loss, structured in a way that the key functions are theft, or unauthorized diversion.
separated or overcheck one another. The position descriptions are available in writing A cause or probable cause that is based on to the personnel affected.
objective evidence will be assigned :o each The facility organization and the MC&A indication of possible loss that is investigated.
policies and procedures are documented.
The results of all investigations of alleged All critical MC&A procedures, and any thefts, and any mdications of a sigmficant revisions thereto, are reviewed and approved loss (d500 grams U-235) which remain prior to their implementation.
unresolved after 30 calendar days shall be Management policies are established, reported to the appropriate NRC MC&A documented and maintained to ensure that all licensing authority.
critical MC&A procedures are adherex! to including measurement procedures used for l
accountability purposes.
Affirmations Pertaining to System Capabilities (2)
Establish and maintain a measurement system which ensures all quantities in the material accounting records are based on measured values.
5 NUREG-1065 Rev. 2 4
Objectives and Capabilities The licensee must make the following utilized contractor to assure that the quality amtmations with repect to the of the measurements is maintained on a level accountability measurement system:
consistent with the regulatory requirements.
A program of measurement procedures and methods is maintained for all SNM receipts, (4)
In each inventory period, control total removals and inventory items, and all material control and accounting measurement quantities of SNM in the material accountmg uncertainty so that twice its standard error records are based on measured values.
is less than the greater of 9,000 grams of U-235 or 0.25 % of the U-235 active inven-Measurement systems that are the key tory, and assure that any measurement contributors to the total measurement standard error will be identified. The list Performed under contract are controlled so will be reviewed annually and updated as that the licensee can satisfy the requirements.
necessary. These are considered as key measurement systems and their standard (5)
Unless otherwise required to satisfy 10 CFR deviations are monitored and controlled by Part 75, perform physical inventories at least the measurement control program.
every 12 months (with no more than 13 calendar months between any two consec-(3)
Follow a measurement control progra,m utive physical inventories): and, within 60 which assures that, measurement bias is days after the start of the inventory, reconcile estimated and sigmficant biases are and adjust the book inventory to the results eliminated from inventory difference values of the physical inventory, and resolve, or of record.
report an inability to resolve, any inventory The licensee must make the following difference which is rejected by a statistical amnnations with respect to measurement test which has a 90% power of detecting a quality:
discrepancy of a quantity of U-235 established by NRC on a site specific basis.
A measurement control program is followed by which all measurement biases associated The licensee must make the following with key measurement systems, are estimated affirmations with respect to physical and any significant biases are eliminated inventories:
from inventory difference (ID) values and shipper / receiver differences.
An MC&A system will be maintained that is capable of confirming, at least annually, the The calculation of the measurement contributions to SEID are traceable to the presence of all SNM expected to be present appropriate measurement error data and to (at a given time) based on the accounting the calibration standards used.
ledgers, with the possible exception of waste materials transferred to (via DOE /NRC The total measurement uncertainty is Form 741 transactions) and stored in holding controlled so that twice its standard error for accounts.
each material balance period will be less than the greater of 9,000 grams of U-235 or 0.25 Unless otherwise required by Facility percent of the active U-235 inventory for the Attachments that satisfy 10 CFR Part 75, inventory period. (NOTE: "Twice the physical inventories will, on the average, be standard error associated with total performed at least every 12 morths (with no measurement uncertainty" can also be more than a 13 calendar month interval denoted as "LEID", i.e., "the limit of error between consecutive physical inventory dates) of the inventory difference").
and will be used as the basis for reconciling and adjusting the book inventory which is The measurement systems have adequate done within 60 days after the start of each calibration frequencies, sufficient control of physical inventory.
biases, and sufficiently small standard deviations to achieve the requirements of For each physicalinventory, inventory 74.31(c)(4). A measurement control procedures are clearly written and are program is used by both in-house and by any reviewed and approved by the individual NUREG-1065 Rev. 2 6
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Objectives and Capabilities t
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responsible for the conduct of the physical U-235 detection threshold (DT) W is not
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inventory.
resolved within the 60-day reconanation period, all SNM processing will be halted De individual responsible for the conduct of unless otherwise authorized by the NRC.
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the physical inventory is either free from
[ NOTE: his applies to both positive and
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potential conflicts of interest or is negative ID values.]
)
overchecked sufficiently to prevent I
The results of all physical inventories and of j
compromising the validity of the physical inventory.
investigations and resolution actions follow-j ing any excessive U-235 ID are recorded and i
Each physical inventory listing will include auditable. An excessive ID is one (regard-all SNM possessed (on the inventory date),
less of the algebraic sign) that exceeds both 4
1 with the possible exception of waste materials 3.00 times SEID and 9,000 grams U-235.
assigned to holding accounts (in accordance with DOE /NRC Form-741 instructions) and (6)
Maintain current knowledge of items when residual holdup that can be regarded as zero the sum of the time of existence of an item, by definition, and that all such listed SNM the time to make a record of the item, and i
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quantities shall be based on measurements the time necessary to locate the item exceeds i
(for SNM quantity).
14 days. Store and handle, or subsequently 1
1 measure, items in a manner so that Within 60 days after the start of each unauthorized removals of substantial l
physical inventory, the inventory difference quantities of material from items will be will be determined. Any inventory detected. Exempted are items individually difference, which is rejected by a statistical containing less than 500 grams of U-235 up test that has a 90% power of detecting a to a total of 50 kilograms of U-235, solutions discrepancy of a quantity of U-235
%u a concentration of less than 5 grams of established by the NRC on a site-specific U-235 per liter, and items of waste destined
}
basis, will be reported to the appropriate for burial or incineration.
?
MC&A licensing and MC&A inspection i
organizational units at NRC Headquarters.
The licensee must make the following affirmations with respect to maintaining i
Discrepancies in the identity, quantity or current knowledge of items and detecting i
location of items, objects or containers of unauthorized removals:
l SNM that are detected during a physical For items not exempted from item control j
inventory will be corrected.
program coverage, a record system is Inventory difference values will be corrected maintained to provide a knowledge of the j
for (1) accounting adjustments resulting from current status of such items for which the t
prior period activity, and (2) significant sum of the elapsed time from initial j
biases that have not been previously taken generation of the item plus the time required into account. (NOT81: See the definition of to locate the item, including any time
'significant bias" in Chapter 4 of this Plan).
required to complete or update item records, would exceed 14 calendar days. For items Adjustments made to reconcile the book subject to this commitment, the item control inventory to the physical inventory are in and records system provides the capability to accordance with standard accounting promptly locate and confirm the existence of practices and are traceable and auditable in any specific item or group of items upon a
j the MC&A records.
demand. The item record system is secured in such a manner that the record of an item's Whenever a finalized U-235 ID (after existence cannot be destroyed or falsified by applying any appropriate bias corrections and a single individual without a very high prior period adjustments) is greater than the probability of detection.
i 7
NUREG-1065 Rev. 2 1
1 w
Objectives and Capabilities For SNM received, shipper / receiver Each item (unless it is an exempted item) is stored and handled in a manner that enables differences that are statistically significant detection of or provides protection against and also greater tht.g 90 erams U-235, on a unauthorized or unrecorded removals of total shipment basis (and also on a batch SNM; otherwise knowledge of the SNM basis when subject to 10 CFR Part 75), are content is assured by seals or maintaining the detected within 30 days of receipt except for item as a sealed source (i.e., as encapsulated those materials specifically identifialin material).
Chapter 7 of this FNMC plan as being exempted from shipper / receiver evaluations.
All incidents involving missing or Measurement results for shipments and comfromised items or falsified item records are investigated. (A compromised item is receipts are corrected for biases that are one for which there is evidence of tampering significant at the 0.05 Imi O.e., for any bias or which is found outside its assigned that exceeds two times the standard error controlled access area.)
associated with a mean), and which impact individual items by more than their rounding The contenta of a compromised item or an error in terms of U-235 and/or uranium unsealed, unencapsulated item kicated after it content.
has been missing will be redetermined by A significant shipper / receiver difference, measurements (i.e., by NDA or by weighing.
sampling and analysis).
e.g., one that exceeds both twice the combined measurement standard deviation (7)
Resolve on a shipment basis and, when for that shipment (and also any batch when required to satisfy Part 75 of this chapter, subject to Part 75) and 500 grams of U-235, also on a batch basis, shipper / receiver is promptly investigated and resolved on a differences that exceed both twice the shipment basis and also on a batch basis combined measurement standard error for when required to satisfy 10 CFR 75.4(d).
that shipment (and/or batch) and 500 grams Significant shipper / receiver differences, as of U-235.
defined above, are reported to the The licensee must make the following appropriate NRC safeguards licensing affirmations with respect to resolving organizational unit by telephone or facsimile shipper / receiver differences:
within 5 calendar days of determining such significant difference.
Each shipment received is inspected for loss or damage to the container or seals to (8)
Independently assess the effectiveness of the determine if SNM could have been removed.
material control and accounting system at.
If the integrity of the shipping container is least every 24 months, and document questionable, the presence of all items that management's action on prior assessment were packaged in the container will be recommendations.
verified.
The licensee must make the following Except for those materials specifically affirmations with respect to independent identified as exempted in Chapter 7 of this assessment and evaluation of the MC&A I
FNMC plan, measurements of the quantity of system effectiveness:
SNM received in each shipment are The capabilities and performance of the performed and the shipper / receiver difference is tested for statistical significance.
MC&A system will be reviewed and its Occurrences of significant shipper / receiver effectiveness will be independently assessed differences in excess of 500 grams U-235 at least every 24 months. That is, the and missing items are reported to the shipper nominal elapsed time from the completion of promptly.
one review / assessment to the completion of the next will not exceed 24 calendar months.
NUREG-1065 Rev. 2 8
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Objectives and Capabilities l
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Reviews and assessments are performed The MC&A recordkeeping requirements of 10 CFR cither by qualified individuals from outside 74.31(d) are as follows:
or qualified individuals from inside the j
facility organization whose work assignments (1)
Each licensee shall establish records that will and positions within the organization will not demonstrate that the system capabilities impair their ability to make objective requirements have been met and maintain judgements of the MC&A system capabilities these records for at least three years, unless a and performance, longer retention time is required by Part 75 l
3 of this chapter.
t Each overall review and assessment will be conducted and completed in a time frame that (2)
Records which must be maintained pursuant is short with respect to the time for changes to 10 CFR Part 74 may be the original or a to have o: curred in the MC&A system and reproduced copy or a microform, if such willinclude any such changes made during reproduced copy or microform is duly I
the time the review / assessment is being authenticated by authorized personnel ar.1 the i
l conducted, microform is capable of producing a clear and legible copy after storage for the period The completion date for any specified by Commission regulations. The review / assessment is defined as the date record also may be stored in electronic media l
when the team submits its final written report with the capability for producing legible, (of findings and recommendations) to plant accurate, and complete records during the t
1 management. The start date is the first day required retention period. Records such as l
j in which one or more team members actually letters, drawings, and specifications must j
inspect records and/or interview MC&A include all pertinent information such as personnel, and such start date will be stamps, initials, and signatures.
1 documented.
(3)
The licensee shall maintain adequate The assessment team leador will have no safeguards against tampering with and loss of responsibility for managing or performing records.
any of the MC&A functions.
1 The licensee must make the following The results of the assessment and affirmations with respect to recordkeeping:
l recommendations for corrective action, if A record retention system is maintained for any, will be documented and reported to the plant manager and other managers affected those records necessary to show that the i
by the assessment. Management will review MC&A system requirements of 10 CFR the assessment report and take the necessary 74.31(c) have been met. Such records are t
actions to correct MC&A system retained for at least three years. The records deficiencies. Such corrective actions (if any) referred to in 10 CFR 75.22 and 75.23 and that pertain to daily or weekly activities will generated during any period that the facility be initiated within 40 calendar days following is under International Atomic Energy Agency the submittal of the review / assessment final (IAEA) safeguards will be retained for at report.
least five years. Records of the following will be maintained current and will be Management's response to recommendations retained for at least three years:
from the review and assessment, including Management structure MC&A job any corrective actions ordered by management and the expected time frame for descriptions, and MC&A policies and completing such actions, will be documented procedures; l
within 30 days following the submittal of the team's report.
Accounting source data records (accounting source data normally 9
NUREG-1065 Rev. 2 1
_ - ~. -. -.
~ _ - - - - - -. -
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i Objectives and Capabilities
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I Sufficient protection and redundancy of the j
l-consist of shipping and receiving j
forms, physical inventory forms, and record system is provided so that an act of the forms used for initially recording record alteration or destruction will not l
l measurement and measurement control eliminate the capability to provide a complete j
data. After an item is destroyed, the and correct set of SNM control and f
j item location record needs to be accounting information that could be used to l
retained for an additional 14 days but confirm the presence of SNM resolve then may be destroyed);
indications of missing material, or aid in the investigation and recovery of missing d
Records of shipments and receipts and
- material, j
i investigations of significant l
Ready traceability will be provided for all shipper / receiver differences plus the information used to resolve them; SNM transactions from source data to final i
accounting records.
I Measurement data for receipts, l
l shipments, discards, and inventory; The followmg chapters of this document incorporate l
i and expand on the performance objectives and on f
Calibration of measurement systems, the system features and capabilities of 10 CFR j
measurement control data, bias 74.31. The chapters are arranged in a format and t
j
- estimates, and the statistical analyses sequence to provide applicants and licensees an
[
of the measurement control data; outline for the FNMC plan.
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Data used to denonstrate that the measurement system performance l
achieves the standard deviation limits required by 10 CFR 74.31(c)(4);
Physical inventory listings and inventory work sheets; t
Calculations of detection thresholds for excessive ids of a safeguards significance (i.e., ID alarm point for detecting a loss equal to or greater than DQ);
Calculations of the standard error of the estimated ID and information used to reconcile an excessive ID (i.e., an t
ID that is > 3.00 times SEID)-
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Reports of investigations and resolution of indications of loss of SNM; and
'Ihe eesults of independent assessments and management action taken to correct any deficiencies identified.
NUREG-1065 Rev. 2 10
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1 Organization 1.0 Regulatory Intent (6) sampling operations i
(7) measurement control program The intent of 10 CFR 74.31(c)(1) is to reqmre licensees to implement a management structure that (8) physical inventories permits effective functioning of the MC&A system, and assures that the MC&A program performance (9) on-site SNM handling operations will not he adversely affected by the plant management structure. Documentatbn, review and A brief description should be provided for each f
approval of the procedures, and the assignment of site-level position, outside of the MC&A the key functions to specific positions eliminates organization, that has responsibilities relating to ambiguities about what is to be done by whom.
MC&A activities (e.g., sampling, mass The management structure is meant to separate key measurements, analytical measurements, and MC&A functions from each other in order to measurement control). For each position, the provide overchecks that increase MC&A system functions, responsibilities, and authorities should be reliability and counter defeat of the system through clearly described.
deceit and falsification. It is also meant to free MC&A managemeat from conflicts of interest with 1.3 MC&A Organization other major functions such as productmn.
1.1 Corporate Organization An organizationa chart r.nd position-by-position desenption of the entire MC&A orgamzation should be provided. An individual should be designated as The corporate stmeture should be described, and all the overall manager of the MC&A program and the corporate organization positions that have responsi-FNMC plan must demonstrate the assurance of bilities related to MCAA at the licensee's site independence of action and objectivity of decision should be identified. A description of the for the MC&A manager. Two options for meeting corporate-level functions, responsibilities, and the orFanizational independence are (1) report authorities for MC&A program oversight and directly to the plant or site manager or (2) report to assessments should be provided. At least one an individual who reports directly to the plant or corporate official should have responsibilities site manager and who has no production pertaining to the control and accounting of all SNM responsibilities.
possessed by the licensee.
1.2 Plant or Site Organization 1.3.1 Responsibilities and Authority A description of the site's management structure A description that clearly indicates the emphasizing MC&A should be provided. The site responsibilities and authority of each supervisor and management structure should be described to the manager should be provided for the various extent that it can be clearly shown that the MC&A functions within the MC&A organization. The organization is independent of potentially description should indicate how the activities of one conflicting responsibilities. This description should functional unit or individual serve as a control over, also indicate how responsibilities are assigned for or checks on, the activities of other units or the following functions:
individuals. The FNMC plan should explain how coordination is achieved and maintained between (1) overall MC&A program or system the MC&A organization and other plant organizational groups that perform MC&A-related (2)
SNM custodianship activities. A definitive statement should be made specifying how the MC&A manager assures (3). receiving and shipping of SNM appropriate review and approval for all written pro-cedures pertaining to MC&A-related activities, and (4) analytical laboratories to any future revisions thereto, that are issued both within and outside of the MC&A organization. In (5) bulk and NDA measurements 11 NUREG-1065 Rev. 2
1 Organization addition to the MC&A manager function, the (7) determination of SEID, active inventory, and functions to be addressed should include, as a inventory difference minimum, the following:
(1) nuclear material accounting (9) MC&A recordkeeping system (2) measurement control program (10) independent assessment of the effectiveness (3) item control program of the MC&A program (4) statistical applications 1.4 Training and Qualification Requiretrients Whenever more than one key MC&A function is assigned to the same person, the FNMC plan should clearly describe the checks and balances that This section of the FNMC plan should describe the preclude the following:
training programs to be established and maintained to provide qualified personnel and to provide for (1) performance of accounting or record control the continuing level of qualification with respect to functions by individuals who also generate personnel assigned to MC&A responsibilities.
source data Training procedures and qualification criteria should be discussed in definitive statements.
(2) assignment of sole authority to any individual Minimum qualification requirements should be to overcheck, evaluate, or audit information stated for each key MC&A position.
for which he or she is responsible 1.3.2 MC&A Procedures The length of this section and its level of detail will Critical MC&A procedures to be described are be dependent on the information provided in the those written pmcedures which, if not performed previous sections of this chapter. The overall correctly, could result in a failure to achieve one or MC&A organization should be described in a more of the performance objectives of 10 CFR manner that explains how the general performance 74.31(a) and the system capabilities of 10 CFR objectives of 10 CFR 74.31(a) and the capabilities 74.31(c). All critical MC&A procedures should be of 10 CFR 74.31(c) will be effectively achieved.
identified in the body of the FNMC plan. The FNMC plan also should contain a definitive The individual who has responsibility for each of statement that the procedures will be followed.
the following MC&A-related functions should be This set of critical MC&A procedures should, as a specified by title:
minimum, adequately address the following topics, regardless of which facility organizational group is (1) overall MC&A program management (Note:
responsible for the particular topic:
This individual should have no major non (1) accountability record system (2) measurements (Note: Respcmsibility may be (2) sampling and measurements divided on the basis of type of measurements (e.g., analytical laboratory measurements, (3) measurement control program NDA measurements, bulk measurements, and
'"*I E
(4) item control program (3) measurement control and statistics (5) physical inventories 7 "'"
(6) investigation and resolution of loss indicators NUREG-1065 Rev. 2 12 i
Organization (5) item control control requirements, and conduct data analysis) are clearly defmed in a written (6) physical inventories position description that defines the responsibilities for that position.
(7) custadial responsibilities (e.g., SNM storage ne qualifications and experience required and movement controls) e for each position assigned an SNM control (8) investigation and resolution of indicators that and accounting function will be sufficient to suggest possible loss of SNM (9) receiving and shipping of SNM permit adequate performance of the duties required of that position.
(10) analytical laboratories ne descriptions (in the FNMC plan) of the e
(11) MC&A recordkeeping system and controls management structure and assignment of duties and authorities show that those ne information in this chapter should include a responsible for each MC&A function will description of the policies, instructions, procedures, have sufficient authority to perform the duties, responsibilities, and delegation of authority function in the intended manner.
in sufficient detail to demonstrate the separation of De MC&A organization is separate from the duties or overchecks built into the MC&A system.
production organization and is also separate his section should also include a discussion from organizations that generate source data, relating to critical MC&A procedures including a if practical; otherwise, independence of the summary of the review, approval, and functions is attained by suitable controls and implementation control and requirements. Critical overchecks.
MC&A procedures and all changes to them should ne responsibility for MC&A program undergo technical review by cognizant members of a
the staff and be approved by line management management is designated to an individual at directly affected and by a level of management an organizational level sufficient to assure above the level responsible for executing the independence of action and objectiveness of pmcedures (but not beyond on site plant decisions.
management).
No two key MC&A functions are assigned to 1.6 dCCeptance criteria the same peram unless adequate checks and balances are provided. As a consequence of this criterion:
A judgment that the applicant's or licensee's approach for establishing and documenting an Individuals who generate source data, effective MC&A program that will be maintained such as performing measurements, or by an acceptable organizational (management) perform shipping and receiving structure, as described in the FNMC plan, will be activities, do not perform any based on (but not limited to) the following criteria 7 accounting or record control functions unless suitable overchecks are ne authorship, approval authorizations, and p ovided to prevent falsification of effective dates of MC&A policies and both source data and accounting procedures will be documented, and will records, and involve appropriate management and technical staff.
No individual has the sole authority to overcheck, evaluate performance, or He resp (msibilities and authorities for each audit information for which he/she is position assigned a function having a responsible.
significant impact on SNM control and accounting (including all positions authorized Critical MC&A procedures and all changes to control SNM movement, generate source to them which directly affect the licensee's data, define and/or implement measurement ability to detect the loss of SNM or to 13 NUREG-1065 Rev. 2 1
f Organization resolve indications of missing SNM, as per 10 CFR 74.31(a), undergo technical review by cognizant members of the staff and will he approved by line management directly affected and by a level of management above the level respcmsible for executing the critical procedures (but not beyond on-site management).
All current critical MC&A procedures are made easily accessible to all affected individuals, and are maintained to show for each procedure (1) the revision number, (2) date issued, (3) who prepared the procedure, and (4) who approved the procedure (as indicated by signature and date signed).
1.7 Affirmations The five affirmation statements related to MC&A management stmeture, given on page 5 under section (1), must be stated (without nxxiifcation) in the FNMC plan.
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i NUREG 1065 Rev. 2 14
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2 Measurements 2.0 Regulatory Intent 2.2 Measurement Systems 4
The intent of 10 CFR 74.31(c)(2) is that licensees ne FNMC plan should describe in detail each must maintain a system of measurements to assure masurement system used for nuclear material l
that all quantities of SNM (both element and fissile accountmg purposes. The principal elements and isotope) in the accounting records are oased on operations involved in the measurement systems for t
reliable measurements. The measurement MC&A encompass mass (or weight) or volume 4
uncertainty associated with the values entered into determination; sampling; chemical analyses for the accounting records must be sufficiently small so element and isotope; and nondestructive assay as to assure that the limit specified in 10 CFR (NDA). Each measurement system should also be I
74.31(c)(4), for the total MC&A measurement defined or identified by its unique set of the uncertainty (associated with a physical inventory following parameters: (1) measurement device or s
material balance), is not exceeded. Except for equipment used, (2) standards used for calibration, sealed sources, samples, and other certain and (3) standards used for control. Additionally, materials, all SNM receipts are to be measured for for analytical laboratory measurements, the the purpose of performing shipper-receiver following also should be identified: (1) sampling evaluations. In the absence of any significant technique and equipment used, (2) sample shipper-receiver difference, a licensee may book aliquoting tech-nique, and (3) sample pretreatment either its measured values or the shipper's measured methodology. Elements of the measurement control values. When recording shipper's values (for SNM Program (e.g., standards traceable to a national receipts), the measurement uncertainty associated system) used for validating and determining control with the shipper's values needs to be known and limits, precision, and accuracy levels for each used in the determination of SEID. It is also measure-ment system used for accountability are intended that a licensee's measurement program described in Chapter 3.
provide bias estimates to be used in correcting inventory difference values and shipper-receiver The FNMC plan should provide descriptions for a
differences for significant measurement biases. The each measurement system associated with bulk, j
estimation of measurement bias is discussed in analytical, and NDA measurements, and should Chapter 3 (Measurement Control Program).
identify, where applicable, any other measurement systems used for accounting purposes that do not i
2.1 Measurement Points fall within these categories. Then descriptions should provide sufficient information to demonstrate
~-
how the systems are implemented to ' ensure the The FNMC plan should identify and describe each capability to meet the precision and accuracy limits.
1 measurement that is used for accountmg purposes.
The following sections provide examples of the Measurements (1) establish the quantities in each types of information necessary for selected custodial area, material balance area (MBA), or measurement systems.
j item control area (ICA) and in the facility as a j
whole, and (2) contribute to the desired capahdity 2.2.1 Bulk Measurement Systems to localize losses and to generate and to assess alarms. Measurement points and/or sampling For each weighing system, the applicant or licensee stations should be selected to provide quantitative information about material flows and inventories should specify the type of weighmg device, the type that will permit detection and localization of any of container (s) weighed, matenal withm the loss or diversion, or to confirm that no diversion containers being weighed, capacity of the weighing has occurred. Typically, three functional types of device, range to be used, sensitivity of the device, and the calibratmn frequency. The description MBAs and ICAs are present: (1) pmcessing, (2) storage, and (3) receiving and shipping. The should include the capacity and the sensitivity of the identification and definition of measurement points "C"N f*:g., capacity not to exceed X kilograms, and j
for processing MBAs are necessary because of the sensitivity to be at least as good as Y grams).
physical or chemical changes of the nuclear materials that occur in these MBAs. The storage For each volume measurement system, the FNMC plan should identify the vessel (e.g., tank, column, and the receiving and shipping areas are typically ICAs. Typical processing MBAs include (1) etc.), capacity of the vessel to which the 1
processing areas, (2) decontamination and recovery measurement applies, the material being measured, areas, (3) laboratory areas, and (4) feed and the volume measunng device and instrumentation, product sampling and transfer areas.
the sensitivity of each device and system, the ranFe 15 NUREG-1065 Rev. 2
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Measurements of operation and/or calibration, and the calibration 2.2.4 Other Measurement Systems frequency.
If applicable, the FNMC plan also should identify 2.2.2 Analytical Measurement Systems any other measurement ystems used for accounting purposes that do not fall within the three categories For each analytical measurement system, the covered by subsections 2.2.1, 2.2.2, and 2.2.3.
FNMC plan thould specify the following:
2.3 Measurement Uncertainties (1) type of material or chemical compound (e.g.,
UP., uranium alloy, UO,, uranyl nitrate The expected measurement uncertainties of the solution) being sampled and measured desenbed measurement systems should be provided.
Variance components for calibration, sampling, (2) sampling technique random, and systematic error for each measurement system should be stated. The units in which the (3) sample handling (i.e., pre-analysis sample errors are expressed should be clearly identified.
storage and treatment) 1 (4) analytical method used 2.4 Measurement Procedures (5) characteristics measured (e.g., grams of The licensee or applicant should define how uranium per gram sample, U-235 isotopic assurance is demonstrated that measurement concentration) procedures (i.e., methods) are established, i
approved, and maintained. This can be (6) measurement interferences accomplished by (1) making a definitive statement that an approved measurement procedures (i.e.,
j (7) expected measurement uncertainty methods) manual, or set of approved manuals, are established and maintained (2) stating which (8) types of calibration standard (s) and organizational units are responsible for the 4
calibration frequency preparation, revision, and approval of measurement procedures, and (3) defining the requirements for 2.2.3 NDA Measurement Systems periodic review of the procedures.
For each NDA measurement system, the FNMC A clear statement should be made defining how the l
plan should identify the following:
facility assures that a measurement procedure cannot be used for accountability purposes without j
(1) the NDA equipment package (i.e., type and documented approval. Each procedure should be j
I size of detector, and type of associated approved by the overall MC&A n anager and by electronics and computer interface, as the manager of the organizational umt responsible appropriate) for performing the measurement. Measurement procedures also should be approved by the (2) the type of container measured measurement control program manager.
i (3)
SNM material type within container The FNMC plan should provide a definitive statement that all SNM quantities in the material (4) attribute measured accounting records are based on measured values f
and that measurement systems are maintained for (5) measurement configuration (including source the measurement of SNM associated with the to detector distance) following:
(6) calculational method (1) additions to inventory (e.g., receipts)
(7) expected measurement uncertainties (2) removals from inventory (e.g., shipments and measured discards) i (3) material on ending inventory NUREG-1065 Rev. 2 16 i
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Measurements For receipt of material, the licensee may use NBL, or equivalent organization) or with shipper's measured values rather than its own reference standards traceable to primary measurements, provided that (1) a shipper-receiver standards. The standards used for comparison, based on attributes or confirmatory calibrations need not be representative of the measurements, shows no significant shipper-unknowr.s to be measured by the system receiver diffrence (SRD) [as defined by 10 CFR unless it is to be regarded as a bias-free 74.31(c)(7)], (M in the case of a significant system that is calibrated during each time of difference between shipper and receiver, no use, in which case the calibrations standards significant difference exists between shipper's value must be representative.
and the umpire value used to resolve the difference; or (3) the material in question is exempted from When determining an SNM quantity by weighing, shipper-receiver comparison requirements (e.g.,
sampling, and analyses, the net weight of material sealed sources and samples). However, when in each item within an uniform material batch (or booking shipper's values, the shipper's lot), such as blended UO powder or sintered UO 2
2 measurement uncertainty should be used when pellets, must be determined by direct mass determining SEID.
measurenent. However, the element and/or isotope countrations for the batch need not be determined for each container, but instead may be derived by 2.5 Acceptance Criteria sampling procedures, including:
A judgment as to the acceptability of the applicant's Analysis of composite samples or or licensee's system for accountability measure-measurements of representative items, ments, as described in the FNMC plan, will be objects or samples selected by based on (but not limited to) the following critena:
statistical sampling; or A basic description or summary of each key Use of concentration and/or measurement system which is utilized to enrichment factors determined from generate SNM quantities for accountability historical averages, controlled input purposes is provided. A measurement specifications values, or empirical system being defined as any mstrument or relationships where such values or device, or combination of devices, used to relationships are periodically tested, derive (1) an element concentratmn, (2) an their uncertainties or bounds have been isotope quantity, (3) a U-235 enrichment or determined to be within 2.00 percent isotopic distribution, (4) a bulk material mass of the factor value, and where (weight), or (5) a bulk material volume, and diversions with material substitution which can be characterized by its random are improbable. However, and systematic error components.
heterogeneous materials, such as ammonium diuranate, may not be The set of key measurement systems, based assigned common factors unless the on recent (or anticipated) measurement quantities are small, such as less than control data and modes of process 500 grams of contained U-235 (per operations, is expected to account for at least material type, per inventory period).
90 percent of the total measurement Justification for any materials assigned uncertainty contribution to the standard error common factors without of inventory difference.
batch-by-batch verification analyses The recahbration frequency for each measurement system is compatible with its 2.6 Amrmations expected stability. Recalibratmns for all measurement systems sh9uld be performed at frequencies compatible with widely The two attirmation statements, given on page 6 established, or licensee demonstrated, under section (2), relating to the measurement l
stability for each particular system, system capability required by 10 CFR 74.31(c)(2) must be stated (without modification)in the FNMC All calibrations are made with the use of plan.
=
primary standards or primary reference materials (certified and issued by NIST or 17 NUREG-1065 Rev. 2 1
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3 Measurement Control Program 3,0 Regulatory Intent 3.1.2 Procedures The intent of 10 CFR 74.31(c)(4)is that The measurement control program procedures should be established and maintained in a manual measurement systems used to establish SNM secountability quantities be controlled by.; formal that is kept current and readily available. This measurement control program that results tn a U-manual should contain all the currently applicable 235 total measurement standard error that is within written procedures pertaining to measurement 4
4500 grams U-235 or 0.125 percent of the U-235 control and measurement quality assurance.
ective inventory quantity (whichever is greater).
Responsibility for preparation, revision, and Hat is, in terms of a 95 percent confidence level, approval of manual procedures should be specified, twice the standard error associated with a material Individual measurement control procedures should balance total MC&A measurement uncertainty (for have documented approval by the measurement U-235) must be less than the greater of 9,000 control program manager. The procedures should grzms U-235 or 0.25 percent of the U-235 active address the following:
inventory. It is also intended that the program i
(1) calibration frequencies and methods j
provide bias estimates to be used for adjusting J
inventory difference results and correcting shipper-(2) standards used for calibration (i.e.,
receiver measurements for significant measurement description and storage controls) biases.
(3) standards used for control (i.e., method of i
3.1 Organization and Management obtaining or preparation, and traceability)
The organization and management of the (4) contml standard measurements measurement control program should be described in sufficient detail to show how the measurement (5) replicate sampling and replicate quality assurance function is assigned and how measurements independence from the analytical laboratory and other units performing either sample taking or (6) verification of process control measurements is maintained. The measurement instrumentation through comparison with ccmtrol program manager should be at a other process instruments management level that is sufficiently high to ensure objectivity and independence of action. Thus, the (7) control limits and control responses measurement control program manager could either report dirstly to the overall MC&A manager or, if (8) generation and collection of control data in a dif ferent organizational unit, be on the same i
i level as the MC&A manager.
(9) recordkeeping controls and requirements i
The licensee's measurement control program should 3.1.3 Contractor Program Audits and be properly managed to ensure adequate calibration Reyjews j
frequencies, sufficient control of biases, and i
sufficient measurement precision to achieve the If measurement services are provided by an outside caf.chilities required by la CFR 74.31(c)(3) and contractor or off-site laboratory, the review (4).
program used to monitor the off-site measurements should be described. Such reviews are to ensure 3.1.1 Funct.ional Relat,onships that the contractor or off-site laboratory has an i
i acceptable measurement control program to the The relationship and coordination between the extent that use of the contractor's measurements measurement control program manager, the will not compromise the licensee's ability to meet analytical laboratory, and other measurement any measurement or measurement control performing groups needs to be clearly defined.
requirement contained in either 10 CFR 74.31(c) or Adequate assurance should be provided that the in its FNMC plan. An initial review of the measurement control program manager has the contractor's measurement control program should authority to enforce all applicable measurement be conducted before licensee use of measurements control requirements.
performed by the contractor or off-site laboratory.
19 NUREG-1065 Rev. 2 l
Measuremeut Control l
All contractor or off-site laboratory assessment it is the primary measurement device, not necess-findings and recommendations should be arily the entire measurement system, that needs to documented and submitted to both the measurement be calibrated, especially when the primary measure-control program manager and the overall MC&A ment device is common to two or more measure-manager within 30 days of completion of the ment systems. For example, the Davies & Gray review. The two managere should arrive at an titrimetric method is often used to analyze samples agreement on correct!'.*e actions that should be for uranium concentration of two or more different taken, based on their evaluation of the report, and material types (e.g., UF., UO, UNH solutions).
2 should transmit these findings to the contractor or in this case, more than one measurement system is of f site laboratory in writing. The licensee should involved because different sampling and sample
{
not use measurements performed by such pretreatment methods and different control contractors or off-site laboratories until they have standards are used. The potassium dichromate verified that the corrective actions have been titrant, however, is common to the systems; thus, instituted.
the titrant is what is calibrated (or standardized) with a primary reference material such as certified The persons who conduc.. contractor review need K:Cr:0,, certified U 0, or certified uranium metal.
3 not be employed by the licensee; but they should not be employed by, or in any way associated with, in the case of nonconsumable standards used to the contractor or of f-site laboratory so that the calibrate measurement systems (e.g., weight independence of the conclusions may be standards), the frequency of recertification of maintained.
assigned values should be specified. The recertification frequency should be dependent on 3.2 Calibrations how often the standards are handled, the standard's stability, and the adequacy of the controls used to i
maintain the integrity of the standards. Biennial f
a ' NMC pid should summarize the licensee'"
recertification of such standards is usually l
c6 tion program and confirm that the licensee acceptable.
has w,itten procedures covermg the following topics:
The FNMC plan should contain a definitive state-ment that no SNM accountability value is based on (1) calibration frequency for each measurement a measurement that falls outside the range of device or system calibration. The FNMC plan also should identify those measurement systems that are point-l (2) identification of the standards used for calibrated. A point-calibrated measurement system l
calibration of each measurement device or is one in which the following are true:
l system I
(1)
The entire measurement system is calibrated (3) protection and control of standards used to with a standard or set of standards that is calibrate measurement systems to maintain representative of the process unknowns that the validity of their certified or assigned are measured by the system. That is, the value" representative calibration standard (s) undergoes all the measurement steps, and in (4) the range of cahbration for each the same manner, that the unknowns do.
measorement device or system and the j
minimem number of calibration run" (2)
One or more calibration standards are (observa tions) needed to establish a processed and measured along with each calibraton unknown or set of unknowns measured.
That is, both the standard (s) and unknown (s)
Unlike cont.ol standards, standards used for are measured during the same general time colibrating ineasurement systems need not be interval, with the same individual measuring representative of the process material or items to be both the standard (s) and unknown (s).
measured b the cabbrated device or system. If f
practical, the standard used during the calibration (3)
The measurement values assigned to the process should be subjected to all the urps involved process unknowns are derived from the in the measurement process that the process measurement response observed for the unknowns are subjected to (e.g., sampL standard (s) that was measured along with the pretreatment), but this need not always be the case.
unknown (s).
NUREG-1065 Rev. 2 20
Measurement Control (4)
The measurement response for each unknown be reduced to 8 and 16, respectively, for non-key should fall within plus or minus 10 percent measurement systems that measure from 10 to 25 of the response for a standard measured at percent of the active inventory, and the minimum the same time as the unknown, or as in the number of control nandard measurements for case of a low concentration unknown, the situations (i) s.r.d C) can be further reduced to 4 difference between the unknown's response and 8, respectively, for those non-key systems used and the standard's response should be less to measure less than 10 percent of the active than four times the standard deviation inventory quantity.
associated with the standard's response.
Control standards should be representative of the 3.3 Control Standard Program pmcess material or items being measured. To be representative, the standards need not always be identical to the process unknowns; but any For those measurement systems that are not point-constituent of the process material, or any factor eclibrated, a defined program for the periodic associated with a process item, that produces a bias measurement of control standards should be effect on the measurement should be present to the established and followed. Control standard same degree in the control standards. For scales measurements serve the dual purpose of (1) used to weigh very large items, such as UF.
m(mitoring the stability of a previously determined cylinders, the control standard weights should be colibration factor, and (2) estimating the average artifact standards (e.F., both empty and full UF.
system bias over a period of time (e.g., an inven-cylinders) of certified mass to avoid a bias effect tory period). The minimum total number of control caused by buoyancy or point loading.
standard measurements during the time perimi, as well as the typical frequency, needs to be specified For each measurement system that is not point-for each measurement system. Generally speaking, cal brated, the control standards to be used for for each key measurement system, a minimum of control standard measurements should be identified two control standard measurements should be made and/or described. Along with material composition during each week that the system is in use. For and matrix factors, biases also can be induced by those key systems that are used less than eight changes in (among other things) temperature, weeks during a given material balance period, more humidity, line voltage, and background radiation.
than two control standard measurements per week Biases also can be operator or analyst induced.
of system use may be necessary in order to Therefore, the scheduling of control standard provide:
measurements should be based on the following considerations:
(1)
A minimum of 12 control standard measurements for those systems used during (1)
Does the variation between analysts or the material balance period to measure operators need to be considered and hence material towing less than 100 kilograms of monitored?
U-235 (2)
Can environmental variables contnbute to (2)
A minimum of 24 control standard measurement bias?
measurements for those systems used to measure a total of 100 or more kilograms of (3) is bias likely to vary with respect to the time U-235 l
of day?
Key measurement systems for the current inventory (4) is a particular bias likely to be long term, penod are any set of designated measurement short term, or cyclic in nature?
systems (of the licensee's choosing) which, based on the most recent previous period, account for at (5) is bias a function of the process measurement least 90 percent of the total measurement variance values over the range of calibration (i.e., is contribution to SEID. Included within the set of the relative percent bias nonuniform over the key measurement systems, should be any system range of calibration)?
utilized to measure an SNM quantity (during an inventory period) greater than 25 percent of the (6)
What controls or procedures are needed to cctive inventory, regardless of its contribution to ensure that sampling or aliquoting of the SEID. The minimum number of control standard control standard is representative of the measurements for situations (1) and (2), above, can 21 NUREG-1065 Rev. 2
)
)
l
\\
Measurement Control 1
sampling or aliquoting of the process how many samples are taken and measured for each material?
accountability hatch measurement, and (2) how many analyses are performed on each acco mtability (7)
To estimate the bian for e.ach measurement sample, if two or more samples are used and one l
system, how much alike - in terms of or more analyses per sample are performed for each chemical composition, uranium accountability hatch measurement, replicate concentration, density, homogeneity, and requirements are automatically met. If, however, impurity content - should the control one sample per batch is normally used for standards be relative to the process accountability purposes, the replicate program unknowns?
should include a periodic taking of a second (i.e.,
replicate) sample. For NDA and mass (weight) 3.4 Replicate Program measurement Systems replicate da'a caa he obtained either from the repeat measurements on production items or by using the data generated For systems involving sampling, duplicate measure-from the control standard program. That is, each ments performed on single samplea and/or measure-consecutive pair of control standard measurements j
ments of replicate samples are necessary to estimate (for a given NDA or mass system) can be regarded the combined analytical plus sampling random as a replicate pair. The minimum number of error. For nonsampling measurement systems such replicate measurements performed during an as NDA and weight measurement systems, the inventory penod for a given key NDA or mass random measurement vanance component can be system should be as given in items (1), (2), or (3),
derived either from (1) replicate measurements above, except that the numbers or percentages are performed on process items, or (2) the data gener-in terms of items measured, rather than batches i
tied from the measurement of control standards.
sampled. Likewise, for non-key NDA and mass measurement systems, the minimum number of The licensee should ensure that replicate samples replicate measurements should be as given in items q
cre independent of one another. The number of (4), (5), or (6) above. The scatter in the repeat replicate samples mes.sured for each analytical measurements is used to estimate the randern error measurement system, that is designated as a key variance using a statistical technique known as the measurement system, dun,ng an mventory period one-way analysis of variance. (The statistical should be equal to one of the following:
methods described in Statistical Methods for Nuclear Material Management, NUREG/CR-4604, (1) 100 percent of the accountability batches are recommended by NRC for satisfying the sampled (when less than 15 batches) statistical requirements of 10 CFR 74.31 see also Chapter 4 of this document.) Replication not only (2) the greater of 15 samples or 15 percent of improves the precision of results obtained from the the accountability hatches sampled statistical analysis of the measurement data, it also can detect gross errors in the data.
I (3) 50 samples (when 15 percent of the batches is greater than 50) 3.5 Control Limits For noi-key analytical measurement systems, the minimust number of replicate samples to be Both warning and out-of-control limits are to be f
measured during an inventory period should be established and used for control standard measure-equal to one of the following:
ments for those measurement systems used for nuclear material accountability. Out-of-control (4) 100 percent of the accountability hatches limits are also to be utilized for replicate samped (when less than 8 batches) measurements and measurement of replicate samples. However, warning limits are optional for (5) the greater of R samples or 10 percent of the the replicate program. For point-calibrated l
accounttbility batches sampled systems, the assigned value of the standard (s) j measured along with the unknown (s)is assumed to (6) 25 samples (when 10 percent of the batches be valid. If the standard's true value could change is greater than 25) because of factors such as evaporation, moisture pickup, or oxidation. the value of the standard j
For each measurement system involving sampling should be checked periodically. Therefore, control i
cad analysis, the I NMC plan should indicate (1) limits for the verification measurements associated NUREG-1065 Rev. 2 22 i
i i
Measurement Control with such standards should be established. This is or her designee) should be responsible for, and especially true for those point-calibrated systems have the authority for, determining and executing that use a single standard, or aliquots from a single additional response and corrective actions as standard, over any extended period of time.
deemed appropriate.
The warning and out-of-control limits are normally The minimum response to a reported incident of a set by the licensee based on a tradeoff between (1) control measurement exceeding an out-of-control the cost of investigating and resolving incidents limit should consist of the following:
where limits are exceeded and (2) the cost of r.ccepting measurements of poor quality. Waming (1) verifying that the measurement system in limits set at the 0.05 level of significance and out-question has been taken out of service with of-control limits set at the 0.001 level of respect to accountability measurements significance are usually sufficient. When a system generates a control measurement that falls beyond (2) documenting the occurrence of the event en out-of-control limit, the system should not be used for accounting purposes until it has been (3) performing at least two additional control brought back into control (i.e., within the upper measurements and lower warning limit).
(4) performing additional control measurements, Control limits should be recalculated at a if results of item 3 do not show the system to l
predetermined frequency and modified if required.
be back in control, using a different control The FNMC plan should clearly explain how control standard or different replicate sample (as limits are established and the frequency for appropriate) or recalibrating the measurement redetermining them, system, or making any necessary system repairs 3.5.1 Measuretnent Control Data Analysis For those measurement systems that make a significant contribution to the SEID, the response to remeasurement of any samples (k" I"'I" *
""' *I #""
" " ^
Measurement control data such as control standard or items) that were l
measurement results and the differences between measured before the out-of-control condition but 1
measurement values of replicate pr ; ;hould be after the last within-control measurement. The plotted manually on graphs or entened into a validity of the previous measurements can be computer data base for generation of control charts.
established without a complete remeasurement of all All control charts should be reviewed at least once the samples (or items) anvolved if remeasurement every two weeks unless a measurement system was g,,.last in, first out" hasis is used. That is, the not used dunng that penod. The review should last sample (or item) measured before the essess the fregt{ency of control data exceeding out-of-control measurement, should be the first to either the warnmg or the out-of-control limits and be remeasured, and continuing in reverse order also provide an evaluatien for any sigmficant until two consecutive remeasurements are found to trends.
be in agreement with their initial measurement at the 95 percent confidence level.
3.5.2 Response Act. ions O
Either the analyst or the operator performing a control measurement or their supervisor should h:ve the responsibility for promptly reporting any A judgesnt as to whether the applicant's or control measurement that exceeds an out-of-control licensee's measurement control program, as limit. Such reporting should be made to the described and committed to in the FNMC plan, is measurement control program manager (or his or acceptable will be based on (but not limited to) the her designee), who should have the responsibility following criteria:
cnd authority to carry out or direct the necessary The description of the measurement control response and corrective actions.
program shows that the measurement systems Minimum response and minimum cornxtive action that are the key contributors to the total requirements should be clearly defined. In measurement standard error will be routinely addition, the measurement control manager (or his and adequately monitored for both bias and 23 NUREG-1065 Rev. 2
)
1
)
Measurement Ccmtrol random error. The standard deviations of applies can be determined). Bias corrections f
measurement systems are estimated from (expressed as both grams element and grams replicate data from measurements made in isotope) are derived for each significant bias the same manner as made routinely on (based on the quantity of measured SNM to typical proccas samples and items. If which the bias applies). The FNMC plan standard deviations are based on replicated must confirm that each significant bias is measurementa of standards (for NDA or either applied as corrections to items listed in mass measurement systems), data is collected the accounting records (if the conection for that demonstrates that the standard deviation an individual item is greater than the estimates do not differ significantly from rounding error for that item), or included in those based on replicated process item the net bias correction to inventory difference measurements. INOTE: For analytical (on line 7 of NRC Form 327).
chemistry measurements, the combined Schedules and frequencies of replicate and analytical plus sampling random error must be derived from the measurement of replicate control standard measurements are designed process samples rather than based on so that the estimates of standard deviations multiple measurements of a standard.]
and measurement biases will be based on measurement control data collected under the All reasonable and probable sources of same measurement circumstances and over measurement error, such as the effects of the same time span corresponding to that of sampling, instruments, environmental factors, the SNM accounting measurements to which and variability between operator / analysts are the standard deviations and bias estimates included in the estimates for standard will be applied. The standard deviation and deviations, either directly as experimental bias of each key measurement sys*em should variables in an analysis of variance or by be evaluated periodically. The frequency of being included in the sample of measurement such evaluations should typically be at least control data from which the standard every four months. When determining the deviations are determined. It must be shown average bias and standard deviation of a that it is reasonable to expect that the particular measurement system for an inven-measurement systems that could significantly tory period, pooling of data from previous impact the inventory difference will be in determinations may be used only if statistical control (when used for accounting purposes) tests show that the standard deviations and so that twice the total measurement standard biases from prior determinations do not differ error will be within the limits stated in 10 significantly from that of the current period, CFR 74.31(c)(4) when calculated at the time and further provided the pooled data do not of a physical inventory.
include any data generated more than 24 months prior to the current determination of Bias tests are made by measurements of such bias or standard deviation, representative control standards whose The effort expended by the licensee in assigned values are traceable to national measurement systems. As reasonably monitoring and controlling the bias and achievable, the control standards should standard deviations of each measurement closely resemble the unknowns to which the system is shown to be consistent with its measurement is applied, and the impact on inventory difference and the total measurement procedures and conditions of measurement standard error. The number of measurement must closely resemble those of degrees of freedom for estimating the typical measurements made on process measurement standard deviation may be unknowns.
graded according to its contribution to the total measurement standard error.
A record of bias estimates for each key
' Warning limits for a change in bias (for those measurement system (not defined as a bias-free, point-in-time calibrated system), as systems that are not point-in-time calibrated, derived from control standard measurements, bias free) will be set at the 0.05 level of is maintained. The basis for determining the significance (or tighter), unless adequate time frame associated with each significant justification for less stringent limits is bias needs to be provided (so that the provided. Warning limits are optional, quantity of measured SNM to which that bias huever, for the monitoring of replicate data NUREG-1065 Rev. 2 24
~
Measurement Control (for standard deviations). If a control datum published measurement performance in exceeds this limit, the individual responsible similar applications.
for the measurement control program will be notified (this normally should occur within
- The calculation of the total measurement 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) and a data review will be initiated standard error is performed in accordance to find the cause, and corrective action will with a recognized error propagation method.
be taken when appropriate. Such reviews Such methods have been published by Jaech and corrective actions are completed and (1973), Lumb and Tingey (1981), and the documented within two weeks.
I AEA (1977).
The licensee will confirm that the Unless adequate justification for less stringent linuts is provided, out-of-control limits for accountability measurements provided by a both standard deviation and bias are set at the contractor are controlled by a measurement 0.001 level of significance for all key control program, and that the licensee will measurement systems, except that no bias confirm that the contractor's measurement control limits are needed for bias-free, control program is adequate by conducting point-in-time calibrated systems. If a control audit and assessment reviews of the datum exceeds this limit, the system in contractor's program at intervals not to question shall not be used for MC&A exceed 24 months.
purposes until corrective action and resolution is completed, and the system is 3.7 Affirmations back in control within the upper and lower boundaries of the warning limit. Likewise, The four affirmation statements, given on page 6 any measurement values generated between the last within control datum and the under section (3), relatmg to the measurement out-of-control datum shall not be used for control system capabilities required by 10 CFR 74.31(c)(3) and (4), must be stated (without MC&A purposes until their validity has been confirmed. Such confirnution can be modification)in the FNMC plan.
accomplished by remeasurement of the involved items or sarnples on a "last in, first out" basis until two consecutive remeasurements are found to be in agreement with their initial measurement at the 95 percent confidence level. It should be noted that other criteria for initiating corrective action relative to potentially out-of-control measurement systems may be accepted where it can be demonstrated that the licensee's capability to meet the 0.25 percent of active inventory limit for total MC&A measurement uncertainty (as specified in 10 CFR 74.31(c)(4)) will not be jeopardized.
The approach used for bounding the total measurement standard error for a typical material balance period meets the following criteria:
All reasonable and probable sources of measurement error affecting inventory difference are included.
Any assumed measurement standard deviations are shown to be reasonable.
They may be shown to be reasonable by comparison to either records of the licensee's past performance data or to 25 NUREG-1065 Rev. 2
-~
4 Statistics i
4.1 Determination of should be limited to 0.90 percent of annual additions to or removals from process, but Measurement Uncerta. t.in ies l
need not be less than 25 kilograms of U-235)
To achieve the objectives and capabilities of 10 (6) specify the methodology for determining ID CFR 74.31, each licensee or applicant should threshold values to be used to provide a 90 institute a statistical program that evaluates the percent power of detecting a loss of a DQ, as MC&A data to ensure that (1) the measurement required by 10 CFR 74.31 (c)(5). (See data are analyzed in a rigorous manner and (2)
Chapter 5 for additional information on hypotheses concerning the status of the nuclear inventory difference limits and response material possessed are appropriately tested. NRC actions.)
sponsored the development of a comprehensive reference that specifically addresses the statistical 4.2 Determination of SEID treatment of measurement control and accounting data. The statistical methods described in this reference, " Statistical Methods for Nuclear Material As defined m. 10 CFR 74.4, the " standard error of Management," NUREG/CR-4604, are recom-inventory difference" means the standard deviation mended by NRC for satisfying the statistical of ar, invent ry difference that takes into account all requirements of 10 CFR 74.31.
measurement error contributions to the components of the ID For strategic SNM facilities, The FNMC plan should n nmeasurement contributors to the ID are not to be included in the SEID calculation. However, for (1) contain a detailed discussion of the facilities possessing only SNM of low strategic procedures and methodologies for estimating 8igmficance, the NRC allows b,censees to take measurement variance components limited credit for nonmeasurement contributors. It is not really possible to quantify the (2) discuss how biases are determined and how mmmeasurement contribution to the uncertainty bias corrections are applied, including:
".ss ciated with a given ID, but 10 CFR 74.31 licensees are permitted to assume that the total (a) how often biases are estimated nonmeasurement contnbution to SEID equals the (b) how the bias' effect on the measured t tal measurement ermr contribution. When quantity of material in an item is mcluding only measurement uncertainty, SEID (for determined either U or U-235, as applicable) can be expressed (c) when and how bias corrections to as follows:
i items are made k
(d) how their effect on inventory SEID = [ E (G,): {(ai)/ + (a,)f/n}]"
l difference is determined 8=I (e) when and how bias corrections are where i
l applied to the ID k
= number of measurement systems (3) describe the procedure and means for G,
= total grams uranium (or U-235) determining active inventory measured during inventory pericd by measurement system i (4) provide all relevant information regarding the (ai), = systematic error standard deviation determination of the SEID for measurement system i (a,), = random error standard deviation for l
(5) specify the nominal (typical) DQ, and the measurement system i method for determining the actual DQ for a n
= number of batches (items) measured given material balance period. Also confirm by measurement system i that DQ will not exceed 1.30 percent of the larger of annual additions to or removals When taking the maximum allowable credit for from process, except when 1.30 percent of nonmeasurement contribution (which assumes a 1:1 additions to or removals fmm process is less ratio of measurement to nonmeasurement that 25 kilograms of U-235, in which case contributions),
the DQ need not be less than 25 kilograms of k
U-235 [ NOTE: For those facilities that do SEID = l 2 E (G,) ((a,)/ +(a,)//n}j'?
not utilize any chemical processing, DQ j,j 27 NUREG-1065 Rev. 2
Statistics In theory, SEID provides the uncertainty, at the 67 Nevertheless, in view of the very large quantity of percent confidence level, of the ID.
SNM (of low strategic significance) that is of a safeguards significance, NRC acceptance criteria The FNMC plan must provide all relevant does not normally call for applying bias corrections information regarding the determination of SEID.
to either the accounting records or as an adjustment There should also be a commitment that at least two to ID unless the effect of a single significant bias or individuals independently verify the correctness of the net sum of all significant biases is unusually the SEID calculation for each total plant material large.
Idance. If the SEID value is calculated by a computer, the verification by two or more persons As a minimum, to meet NRC acceptance criteria, a involves a checking for correctness of the input data bias correction for a single key measurement used by the computer to calculate SEID.
system should be considered "significant," and thus applied either as corrections to the accounting 4.3 Bias Corrections records or as aa adjustment to the inventory. icant difference, if (1) such bias is statistically sigmf.
at the 95 percent confidence level, an_d (2) either or From a statistical perspective, biases that are n21 both of the following are also true:
statistically significant (at the 95 percent confidence level) should never be applied as adjustments 1.
Applying the correction would cause the (corrections) to the accounting records. If one ID to exceed its DT value, or wishes to obtain the best estimate of the true inventory difference value, it can be argued that II.
The bias is greater than 0.0100 percent such insignificant biases should be applied as a relative and also impacts the ID value by non-accounting adjustments to the initially more than 1,000 grams U-235.
calculated inventory difference (as obtained from the ID equation: ID = BI + A - R - EI). Such Additionally, the net algebraic sum (expressed as practice is not deemed necessary, however, for grams U-235) of all statistically significant (95 material balances pertaining to SNM of low percent confidence level) biases, from key strategic sigmficance, and thus is purely optional.
measurement systems not defined as bias-free, that have not been applied as a correction / adjustment For biases that are statistically significant (at the 95 under condition I and/or 11, above, is considered to percent confidence level), it is common practice to be "significant" and is to be applied as a net cdjust the accounting values for individualitems if adjustment to the ID if either or both of the the bias effect (as grams element and grams following are true:
isotope) on the item is more than the rounding error for that item, and if less than the rounding error, to 111.
Applying such correction would cause the cpply the bias as a non-accounting adjustment to the ID to exceed its DT value, or ID. Under a well designed and well managed measurement control program, bias corrections to IV.
The net correction impacts the ID value by the accounting records should seldom, if ever, be more than 5.00 percent of the licensee's necessary under the above mentioned approach.
DQ, or 10,000 grams U-235, whichever is Although the effect on an individualitem from a gE#
statistically significant bias should be negligible, the effect of that bias across hundreds or thousands of items (whose SNM values were derived from the biased measurement system) could have a very significant impact on the ID value.
NUREG-1065 Rev. 2 28
\\
5 Physical Inventories 5.0 Regulatory Intent 5.2 Organization, Procedures, and Schedules The principal method of confirming the presence of SNM is to perform a physical inventory and The FNMC plan should explain the makeup and compare it to the book (record) inventory. If all duties of the typical physical inventory SNM is included, the expected difference between organization. The individual having responsibility the book inventory and the physical mventory is for the coordination of the physical inventory effort zero plus or minus the measurement uncertainty should be identified by position title. The FNMC associated with both the physical and book plan also should indicate how the preparation and inventories. In any actual case, the size of the modification of inventory procedures are controlled.
estimated ID depends on measurement errors, as well as various nonmeasurement contributors such as recording errors, unmeasured losses, unmeasured The FNMC plan should contain a defmitive holdup, etc. He intent of 10 CFR 74.31(c)(5) is t statement that specific inventory instructions are require hcensees to perform annual physical prepared and issued for each physical inventory.
inventories so to confirm that a loss or diversion of a safeguards significant quantity (i.e., a DQ) of low 5.3 Typical Inventory Composition strategic SNM has not occurred.
The typical expected in-process inventory within the 5.1 General Description equipment for both uranium and U-235 at the time of the physical inventory should be specified. A typical composition of SNM as stored items at the The applicant or licensee should provide a general time of a physical inventory also should be description of how physical inventories of the plant presented. Plants may be (but are not required to will be planned, conducted, assessed, and reported, be) divided into a number of MBAs and ICAs to reflect the functional activities as follows:
The FNMC plan should contain a definitive Processine - An MBA in which occurs (1) routine statement that physical inventory functions and transfers of nuclear material from one container to responsibilities are reviewed comprehensively with another, (2) changes in chemical assay, or (3) the involved individuals before the start of each changes in chemical or physical form. Various physical inventory.
measurements are required to define materials flows through the process and to perform physical A book inventory listing, derived from the MC&A inventories so that periodic material balances can be record system, should be generated just before the completed for the MBA. Because these actual start of each physical inventory; such listing measurements have associated uncertainties, a shall include all SNM that the records indicate processing MBA will normally have a nonzero ID should be possessed by the licensee at the inventory for each inventory. Of the total plant MBAs and cutoff time.
ICAs, a relatively small number might be processing MBAs. Examples are the The inventory difference and related information decontamination and recovery operations; analytical associated with each physical inventory of low-laboratory; and material rebatching, blending, and 4
enriched uranium (LEU) (i.e., DOE /NRC material sampling operations. Physical inventories for the code 20-El and 20-E2) are to be reported to the decontamination and recovery operations are the NRC, pursuant to 74.17(a), on an NRC Form 327 most complex and involve the most coordination ca the results of a physical inventory. In addition, and careful timing.
if any material associated with material codes 20-E3 and 20-E4 (i.e., high-enriched uranium),70 Storace - ICAs in which all materials are within (U-233),50 (Plutonium), or 83 (Plutonium-238)is containers with measured values and are being possessed by the licensee, such material must als stored for future processing or shipment. Some be subject to the physical inventory, and each minor sampling of containers can occur in a storage material code inventory difference and associated ICA. Because nuclear materials in a storage ICA l
information must be reported on separate NRC 327 are primarily accounted for on an item basis, a true Forms.
29 NUREG-1065 Rev. 2 l
Physical Inventories storage ICA typically will have a zero ID for each instructions on data submission to the accountability inventory period when all items are accounted for organization should be identified. The instructions cnd their integrity and previously documented should highlight any required devia6on from normal measured values are confirmed.
inventory procedures contained in the plant's operating procedures.
Receivine and shionine - An ICA from which materials are shipped or into which materials are A description of the procedures and methodologies received from off-site. This ICA type will associated with performing physical inventories normally serve as an interim storage area and will should be provided in sufficient detail to see more activity (i.e., changes in current demonstrate tnat valid physical inventories are inventory) than the typical storage ICA. At some conducted. Such description should include a facilities, sampling and rebatching of items may general outline of the following-occur in this type of ICA.
(1) organization and separation of functions 5.4 Description of Typical Item (2) assignment of inventory teams and their g
trammg m the use of uniform practices
]
The FNMC plan should describe the expected item (3) obtaining, verifying, and recording of population in terms of the following:
source data (1) type of item (i.e., stratum)
(4) control of inventory forms (2) expected range of the number of items (5) assurance that item counts verify the within each stratum presence of each item while preventing any item from being counted more than once (3) the average uranium and U-235 content of the items within each stratum (6) implementation of cutoff and material 4
handling procedures (4) the expected rate of item generation and consumption for each stratum Decontamination and recovery is a complex operation involving the disassembly and 5.5 Conducting Physical decontamination of failed pieces of rocess P
Inventories 9" T * #" "
- ##'I " "'"* "'"
types of scrap materials. The basic inventory procedure should involve establishing a cutoff of A description of the methodology, including cutoff raovement of materials into the area and processing and inventory minimization procedures, should be all materials to a measurable form, such as presented; and all measurements (including containers of solution or oxide. Except for the sampling) should be identified. The FNMC plan decontamination enclosure in which in-process should contain sufficient infonnation to show how solutions are mixed, sampled, and measured the total in-process inventory for both uranium and volumetrica!!y, the inventory process should involve U-235 is obtained.
emptying and flushing of process systems and piping, which then could be measured using NDA The means for measuring or estimating residual techniques to establish levels of residual holdup, if process material (i.e., holdup) should be addressed such holdup is significant.
in detail. The change or variation in such deposited holdup from one physical inventory to the next Special item storage and handling or tamper-should also be discussed.
indicating methods, which are used to ensure that the previously measured and recorded SNM A detailed inventory notice should be prepared for content values can be used for inventory purposes each physical inventory. The notice should be without remeasurements, should also be described.
issued to all involved parties and should conWn in addition, the FNMC plan should provide a instructions that defme the timing and performance description of how item identities are verified and of various inventory steps and conditions under bow tampering with the contents of items will be which the inventory is to be taken. Specific detected or prevented.
sampling points throughout the process and NUREG-1065 Rev. 2 30
Physical Inventories items that are not encapsulated, affixed with When using such a statistical sampling plan to tamper-indicating seals, or otherwise protected to confirm the validity of prior measurements, the ensure the validity of prior measurements need remeasurement value obtained for each item (among special attention. The basis for determining which the n items remeasured) must be compared to its items are to be measured at physical inventory time original value, if the difference for a given item and the justification of any proposed alternatives to exceeds some pre-determined limit (usually three measurement of any SNM included in the inventory times the standard deviation of the measurement, or should be presented. If statistical sampling is 3 sigma), that item is designated as a " defect". To proposed as an alternative method to 100 percent achieve the 90 percent power of detection capability venfication, the FNMC plan should describe the for detecting a loss of a DQ, there must be at least sampling plan. Such description should include:
a 90 percent probability that one or more " defects
- will be encountered among the items remeasured (1) the method of segregating the types of across all involved stata if an actual loss of a DQ items to be sampled (i.e., selected for has occurred. If, across all strata, one or more remeasurement) defects are encountered, a second set of n randomly selected items (or all remaining items if n 2 0.5 N)
(2) the procedure for calculating the sample from each stratum should be remeasured. If one or size (i.e., the number of items) for each more defects are encountered (across all item stata) stratum while performing any second round of remeasure-ments, all unsealed and unencapsulated items not (3) the parameter to be measured (e.g.,
yet remeasured are to be remeasured. Any item, gross weight or total U-235 content) regardless of whether there are any defects, whose remeasured value differs from its original measure-(4) the quality of the measurement methods ment by more than two sigma (2a) should have its used to verify original measurement accounting value revised to reflect its remeasured values (for the parameter being quantity.
measured)
The FNMC plan also should contain a definitive (5) the procedure for reconciling statement that all items on ending inventory that discrepancies between original and have not been previously measured are measured remeasurement values, and for for inventory purposes.
scheduling additional tests and remeasurements The decision rationale for determining when the element and isotope factors for items, objects, or (6) the basis for discarding an original SNM containers are measured directly for inventory and value and replacing it with a when they may be based on other measurements remeasurement value should be presented in the FNMC plan. For example, if the U-235 contained in liquid waste One accep'able means for establishing the number batches is derived by applying an average of items (to be randomly selected for enrichment factor to the measured uranium element remeasurement) from a given stratum to give the content, the rationale for such practice (as opposed required 90 percent power of detecting a loss of a to measuring each batch for both uranium and detection quantity is given by the following U-235 content) should be discussed, and the method equation:
for establishing the average enrichment factor should be described.
n = N l1 - (0.10)"]
If the content of items is established through prior where measurements and those items are sealed with tamper-indicating devices or access to them is number of items to be remeasured controlled, the SNM quantity in those items may n =
N= total number of items in the stratum be based on those measured values. Otherwise, maximum U-235 content per item verification of SNM coatent can be achieved by x =
(kilograms) reweighing either (1) ab items within a given DQ = detection quantity (kilograms stratum or (2) randomly selected items from the g
=
U-235) stratum based on a statistical sampling plan. A statistical sampling plan will not be acceptable if there is any likelihood of any significant change in 31 NUREG-1065 Rev. 2
Phyrical Inventories the uranium concentration (or weight fraction) or in 5.7 Acceptance Criteria
~
the uranium isotopic distribution because of such factors as oxidation, change in moisture content, commingling with materials of different A j,udgment that the applicant's or licensee's plan i
for physical inventories is acceptable will be based enrichments, or different compositions.
on (but not limited to) the following criteria:
5.6 Inventory DifTerence Limits The FNMC plan contains adequate and Response Actions commitments to assure that each physical l
inventory will be organized and coordinated that all involved persons are instructed in s
Each licensee should have a well-defined system for ev:luating total plant ids and taking actions when the use of umform procedures of checking "b exceed certain predetermined thresholds. As a SNM quantity and recording observations.
The means fm conducting the inventory must minimum, there should be two response levels, and d
insure that no SNM currently on hand (with three levels are recommended, for excessive ids.
The following would be an acceptable approach for the possible exception of holding account waste materials and residual holdup following three increasing levels of response actions with cleanout that can be regarded as zero by iespect to physical inventories:
definition) will be omitted and no quantity will be counted more than once.
Warning-level ID The inventory procedures provide for U-235 ID 2 1.7(SEID) + 500 grams, and confirming the presence of all items by direct U ID 21.7 (SEID) + 10 kg U observation and the presence of all quantities of SNM, that are neither encapsulated nor Significant ID problem U or U-235 ID 2 3 (SEID) tamper-safed, by direct measurement or an acceptable altemative. The proposed alternatives to remeasurement must satisfy Mrjor ID problem U-235 ID 2 DQ - 1.3 (SEID) one of the following criteria:
s l
All of the above limits are expressed in terms of The SNM content is verified by tbsolute values of ID without regard for algebraic sign. The minimum response for a warning-level statistical sampling and measurement ID should be a documented licensee investigation of representative items, objects or samples of the material. The total conducted by the MC&A organization. Such an investigation should pmvide a conclusion for the overall sampling plan shall support the
}
probable cause of the excessive ID and give capability for detecting any loss m recommendations for avoiding recurrences. When excess of the current DQ with 90 a warning-level ID is positive, it should be regarded percent (or better) probability.
r.s being equivalent to an indicator of a possible loss that requires investigation and resolution.
The previous measurement results are accepted because the items are stored 1
in a c<mtrolled access enclosure that For a significant ID problem, an extensive investigation by the licensee should be conducted.
provides protection equivalent to
]
If a significant ID problem cannot be satisfactorily tamper-safing.
explained, a reinventory may be needed.
Residual holdup (that is too large to be i
For any unresolved ID determination that remains a regarded as zero by definition) major ID problem (without regard to algebraic remaining after cleanout or draindown sign), the licensee should c(mduct a plant-wide may be estimated if the estimate is reinventory and investigation. The NRC considers based on previously measured values, j
a positive ID large enough to be a major ID and it is perimlically verified or validated.
problem as a very serious condition.
The FNMC plan should fully describe in definitive For material whose SNM content has statements the minimum response actions for each been previously measured, and there is ID action level, no likelihood of any significant change t
NUREG-1065 Rev. 2 32
-"- - ^ ^ - - - - - - -
m-m
... - -. _. -. - - - -. _ -. - _. ~ - _. - -
~-.
t i
e Physical Inventories i
t in the uranium concentration (or
" additional to process" or " removals from weight fraction) or in the uranium process" during a 12-month inventory period.
enrichment due to such factors as oxidation, change in moisture content.
The information in the FNMC plan shows i
commingling with materials of that the DT for an excessive ID will result in different enrichment or different a 90 percent (or better) probability of v
composition, etc., the previously detecting a discrepancy (i.e., an apparent determined uranium and U-235 content gain or loss) equal to or larger than the may be accepted without verification U-235 DQ for the inventory period in
[
of SNM content provided the gross question. In general, a licensee may assume I
weight and/or net weight of all items the ID distribution approximates a normal within the population is confirmed by distribution, and therefore:
i (1) a 100 percent reweighing of all such items, or (2) reweighing an DT = DQ - 1.30(SEID)
{
adequate number of randomly selected items (based on a statistical sampling Acceptable methodology for calculating the t
plan) to provide a 90 percent (or measurement error contribution to the SEID i
better) probability of detecting a loss by error propagation is found in Jaech l
equal to or greater than the current (1973), IAEA (1977), and Lumb and Tingey DQ.
(1981). Special attention is given to inclusion of all applicable and measurable l
As an additional altemative to remeasurement sources of error to avoid underestimating the f
(of unsealed SNM) at physical inventory SEID.
time, a program of routine process t
e in addition to the DT ID alarm limit monitoring will be acceptable when the combination of the process monitoring
[ required by 10 CFR 74.31(c)(5)], there is at l
program and the inventory procedures will least one excessive ID warning level limit achieve the same level of loss detection that when exceeded will require an capability as that provided by a physical investigative response action. The resources j
inventory in which all unencapsulated items and level of effort to be committed to the,
are either tamper-safed or remeasured.
investigation of an excessive ID will be proportional to the magnitude of the ID, but Any previously measured, but unsealed (or will be sufficient to reassess the results of the unencapsulated) SNM that is on hand at the physical inventory, the accounting reccrds, time of the physical inventory, and which is and the measurement control program data; l
to be intrtxiuced into subsequent processing to confirm the relevant calculations and data steps prior to inventory reconciliation r.hould analysis; and when necessary, to carry out be remeasured or have its prior measurement searches for unmeasured inventory such as value confirmed (by an r.cceptable holdup and discards. Investigations are to be alternative) before the subsequent processing completed within 60 days after initiating the i
is initiated.
inventory (except when additional time is i
granted by the NRC for extenuating The DQ (in kilograms U-235) for any given circumstances).
l inventory period will be no greater than 1.30 percent of that period's throughput for 5.8 AfUrmations i
facilities involved in chemical processing (such as UF. conversion, scrap recovery, oxidation or reduction processes, etc.), and The 11 affirmation statements, given on pages 6 no greater than 0.90 percent of throughput and 7 under section (5), and the first performance for facilities where material only undergoes bjective af firmation statement listed on page 5 j
physical changes (such as pressing UO related to physical inventories must be stated i
2 powder into pellets and/or loading pellets (without any modification) in the FNMC plan.
(
into fuel rods), unless the 0.90 or 1.30 percent of throughput (as appropriate) is less j
than 25 kilograms U-235, in which case the j
DQ need not he less than 25 kilograms. The 1
U-235 throughput is defined as the greater of 33 NUREG-1065 Rev. 2
+
4 i
6 Item Control 6.0 Regulatory Intent (1) items whose time of existence plus the time to record the item (since its generation) plus the time to locate the item is less than 14 The intent of 10 CFR 74.31(c)(6) is to require calendar days licensees to implement item control procedures that protect against unauthorized and unrecorded (2) any bcensee-identified items listed by r:moval of items, or of material from items, and material type containing less than 500 grams that enable timely location of items. Items are of U-235 each but not to exceed a plant total known quantities of SNM in well-defined and of 50 kilograms of U-235 uniquely identified containment such as cans, drums, and canisters, or fixed units such as fuel (3) containers of waste (designated for burid or e.saemblies. Un--containerized solid SNM, such as incineration), and solution containers in uranium metal ingots or buttons, are also items if which the U-235 concentration is less than they are uniquely identi6ed, in order to promptly 5.00 grams per liter.
loc:te a given item, sufficient current information must be recorded. These item control requirements Each item that is not exempt from the item control rpply only to items for which the total length of program should be stored and handled in a manner time that the item exists plus the length of time it that enables detection of, and provides protection takes to hicate it (after having been recorded) against, unauthorized or imrecorded removals of exceeds 14 days. For example, if an item has been SNM. All items, whether or not they are subject to in existence for 10 days, the licensee must be item control program coverage, should have a crpable of making a record of the item and locatmg unique identity. For items subject to the item the item within 4 days in order for the item to be control program, the following are acceptable exempt from the current knowledge requirement.
means for providing unique identity:
Conversely, if the time to make a record of an item plus the time it takes to locate the item equals 4.
(1) a unique alpha-numeric identi6 cation on a days, then if the item exists for less than 10 days it tamper-indicating seal applied to a container need not be formally entered into the current of SNM knowledge system. Also in order to eliminate the need to keep records for insigniGcant quan'.ities of (2) a unique alpha-numeric identincation SNM, waste containers and most solutions are permanently inscribed, embossed, or stamped exempt. Licensees are given some flexibility in on the container or item itself controlling items by permitting an additional exemption of up to a total of 50 kilograms U-235 in (3) a uniquely prenumbered (or bar-coded) label items each containing less than 500 grams of applied to each item having good adhesive U-235.
qualities such that its removal from an item would preclude its reuse 6.1 Organization Location designations shown by the MC&A records need not be unique, but h> cation designations should The FNMC plan should identify the individual be specib_e enough so that any item may be hicated responsible for overseeing the item control program within I hour. Longer times may be acceptable but by position title. Positions of those individuals who should be furtherjustified in the FNMC plan. The h2ve significant item control program MC&A record system should be controlled m such responsibilities should also be identified.
a manner that the record of an item's existence cannot be destroyed or falsifial without a high 6.2 General Descr. t.ip ion probability of detection. Each nonexempt item should be stored and handled in a manner that The applicant or licensee should state that the enables detection of, and provides protection overall MC&A system maintains a record of all against, unauthorized or unrecorded removals of SNM items, regardless of quantity or duration of SNM.
existence. In addition, the item control program should provide current knowledge of the location, 6.3 Item Identity Controls identity, and quantity of all SNM contained in all hems that t.re not exempt from item control. Items at can be exempt from item control program Descriptions should be provided of the item records showing how items are identified for each material coverage are:
type and each type of container, if the unique 35 NUREG-1065 Rev. 2
= _.
. ~.
Item Control i
number on a tamper-indicating seal is the basis for The item monitoring system should conduct the providing unique item identity, the FNMC plan following activities at least on a monthly basis:
should:
(1) for each item inventory stratum, compare the (1) describe the type of seal used actual storage status to the recorded status of a sufficient sample of randomly selected (2) describe how the seals are obtained and what items from the item control program records measures are implemented to ensure that duplicate (counterfeit) seals are not (2) for each item inventory stratum, check the manufactured accuracy of the MC&A records for a sufficient sample of randomly selected items (3) describe how the seals are stored, controlled, from each storage area i
issued, and accounted for (3) check the accuracy of a sufficient sample of (4) describe how seal usage and disposal records randomly selected production records of are maintained and controlled created and consumed items Similar information should be provided for other The actual frequency of the above activities, and methods of unique item identity (e.g., labels),
the size of the random sample, should be a function of the expected discrepancy rate based on prior 6.4 Storage Controls observations. The FNMC plan should specify (1) minimum monitoring frequencies associated with each storage area, (2) discrepancy rates that trigger Item storage areas and controls should be fully more frequent monitoring frequencies, and (3) described in the FNMC plan. In pasticular, commitments for resolving discrepancies.
controls that are used as the basis for ensuring the vdues of prior measurements, as opposed t 6.6 Investigation and Resolution r:measurmg the item at inventory time, should be discussed in detail and the rationale for accepting or iten,i niscrepancies prior measurements explained. Any controls used to ensure the validity of prior measurements should The applicant or licensee should provide definitive be eqmvalent to the protection provided by statements of the procedures and controls that will tamper-indicating seals, ensure that all incidents involving missing or compromised items or falsified item records will be Both administrative controls (e.g., custodian investigated. A compromised item is (1) one assignments and limiting authonzed access t displaying evidence of tampering or (2) an storage areas) and physical controls (e.g., locked unencapsulated and unsealed item assigned to a and/or alarmed doors) should be identified.
controlled, limited-access storage area that is found 6.5 Item Monitoring Methodology and Procedures If any unencapsulated and unsealed item is k>cated
~
after having been determined to be missing, or if an item is found to be compromised, its contents As part of the item control program, a licensee should be reestablished by measurement (e.g., by should mamtam a system of item monitoring that:
NDA or by weighing, sampling, and analysis).
Recommendations on resolution of indicators (1) verifies that items shown m. the MC&A (Chapter 9) of this document should be used to J
records are actually stored and identified in resolve item discrepancies.
the manner mdicated in the records 6.7 Acceptance Criteria (2) verifies that generated items and changes in l
item locations are properly recorded in the MC&A record system in a timely manner A judgment that the licensee's FNMC plan for the control of items subject to the requirements of (3) can detect, with high probability, any real 10 CFR 74.31(c)(6)is acceptable will be based on loss of items, or uranium from items (but not limited to) the following criteria:
amounting to 500 grams or more of U-235 NUREG-1065 Rev. 2 36
Item Control The licensee's item reco.d system uniquely Solutions having less than a 5.00 identifies items. The records include grams U-235 per liter concentration; information on the chemical form, quantity or of material (element and isotope), physical description, identification label or number, Items individually containing less than and location. The system provides 500 grams U-235 each, not to exceed reasonable assurance of detecting falsification a total of 50 kilograms of U-235.
or destruction of records of an item's The FNMC plan makes commitments for existence. Groups of items that are produced, stored, processed, or otherwise determining the total quantity of U-235 in handled together as a unit, such as a batch or items exempted from control on the basis that sublot of material, may be exempt from the they contain less than 500 grams U-235 each, requirements for identification of each item if so as to assure that the total 50 kilogram the group is uniquely identified and stored as U-235 limit is not exceeded.
a separate group under conditions such that A current rccounting is maintained of the group identity, composition and quantity will be maintained constant, total quantity of SNM contained in items that are exempted from item control. The e
The record of the status of an item can be accounts identify the quantities by material completed or updated in sufficient time to type category far both controlled and allow the licensee to meet the requirements exempted items.
for promptly locating an item.
6.8 Affirmations For items that will not be remeasured at inventory time, the item control procedures provide reasonable assurance that the SNM The four affirmation staternents, given on pages 7 contents stated in the records are valid and and 8 under section (6), relating to the current that unauthorimd removal of SNM from the knowledge requirements of to CFR 74.31(c)(6) item has not occurred. Remeasurement is must be stated (without modification) in the FNMC not necessary if the SNM content of the item plan.
was measured previously and reasonable assurance is provided that the SNM content has not subsequently changed.
Items that are exempted from item control pmcedures must fall into at least one of the following categories:
Items that are in existence for only a relatively short period of time, as defined in 10 CFR 74.31(c)(6);
Waste destined for burial or incineration; 37 NUREG-1065 Rev. 2
7 Shipper-Receiver Comparisons 7.0 Regulatory Intent dissolution plus residue measurements for accounting purposes.
The intent of 10 CFR 74.31 (c)(7) is to require the For any SNM received, the licensee must provide material control and accounting system to promptly all appropriate information on the DOE /NRC Form detect and resolve all significant shipper 7eceiver 741 that accompanies the shipment. (NOTE: See (S/R) differences. S/R comparisons are important NUREG/BR-0006 for instructions and requirements for confirming that either shippers' and receivers
- for completing DOE /NRC Form 741.)
values are acceptable for establishing the book acmunting quantities associated with received 7.2 Determination of Receiver's material, or detecting unacceptable shippers or receivers
- values.
Values 7.1 Receiving Procedures For UF., the licensee may establish receiver's values by (1) measuring the U-235 isotopic Regardless of whether or not formal S/R concentration by NDA, (2) weighing each cylinder evaluations are to be performed, the first action to to determine net weight UF. (gross weight minus be taken on receipt of SNM should be the certified cylinder tare weight), and (3) applying a verification of the number of items, the item historical established percent uranium factor (that is identities, and the integrity of individual items and periodically confirmed or updated by measurement),
of tamper-indicating seals. Except for certain Such a practice avoids the need to sample UF.
specified types of material, all SNM shipments cylinders and analyze the samples (except when received from an external supplier are to be subject obtaimng data to establish or update the historical to S/R comparisons. Such S/R comparisons involve percent U factor). Ilowever, it is more desirable measurement of received material by the receiver, and common practice to derive UF, receipt values or by the receiver's contractor (who is independent based on the measurement of UF. samples.
of the shipper), and comparing receiver's total Arrangements can usually be made with the UF.
receipt measurement for element and isotope to that supplier to provide samples of the shipped UF..
of the shipper's. The FNMC plan should identify The receiving facility should have an agent (who is what material types, if any, are exempted from S/R independent of the shipper) witness the sampling evaluations. Receipt materials which may be (that represents the UF. contained in the cylinder (s) exempted from S/R comparisons include:
to be shipped), apply a tamper-indicating seal to the sample, and verify the unique identify of the filled (1) shipments containing less than 500 grams cylinder.
U-235; SNM receipts not in the form of UF. should be (2) individual items containing less than 25 measured for total quantity (mass), element grams U-235 when the total shipment is less emcentration, and isotope abundance, as opposed than 2000 grams U-235; to usmg a historical factor for deriving element content.
(3) encapsulated items, whose encapsulation integrity has not been compromised, and 7.3 Evaluation of Shipper-which are to be retained by the licensee as Receiver Differences encapsulated items; (4) fuel assemblies and fuel rods previously When shipper's raeasurement uncertainty (or standard error) information is available, the shipped by the licensee that are being retumed, provided that the original following should define the combined measurement standard error:
encapsulation has not been compromised; combined standard error = [(o )2 + (a,)2l "
(5)
UF. cylinders that are empty except for a s
heel quantity of UF. ; and where (6) lieterogeneous scrap that must be subject to dissolution before a meaningful accountability 8s = shipper's measurement standard error va = receiver's measurement standard error measurement can be obtained, and both shipper and receiver agree to accept the after 39 NUREG-1065 Rev. 2
i 4
Shipper-Receiver Comparisons 4
If the shipper's measurement uncertainty values are significant SRDs is acceptable will be based on (but
?,
not available, the receiver can assume that the not limited to) the following criteria:
shipper's measurement uncertainty is equal to (but Each shipping container is inspected within 3 no greater than)its own uncertainty, in this situation (i.e., both shipper and receiver have the working days after receipt. If the integrity of same measurement uncertainty), the following a container is questionable, the presence of
]
becomes the combined measurement standard error:
all items that were packaged in the shipping container are confirmed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of combined standard error = [ 2 (a )2] ira discovering the questionable integrity.
= 1.414 a
]
n Confirmatory measurements of scrap i
The difference between the shipper's value and the shipments are performed by the receiver to receiver's value (i.e., the SRD), in terms of the determine the amount of element and isotope total shipment, must be regarded as significant within a time period consistent with the whenever the SRD exceeds both 500 grams of accountability needs of the shipper.
U-235 anc' twice the combined standard error. If 4
The test far significance of a SRD is based subject to 10 CFR Part 75 (international safeguards), a SRD in excess of both 500 grams on hypothesis tests.
U-235 and twice the combined standard error with The investigation procedure for significant respect to a single batch within the shipment must i
also be regarded as significant.
SRDs is sufficiently comprehensive to ensure that the difference will be resolved.
7.4 Resolution of Significant Comprehensiveness is sufficient if the Heensee shows the capabihty tuer#y Shipper-Receiver Differences records, resample, perform remeasurements, establish liaisan with the shipper, provide The FNMC plan should describe the steps involved samples to a referee laboratory, and perform with the investigation of a significant SRD and the statistical analysis needed to evaluate the discuss how such difference is resolved. The measurements.
criteria for defining a resolved SRD also should be presented. Generally, resolution of a significant 7.6 Aflirmations SRD involves a referee (or umpire) measurement of a retainer sample (s) but not of the material weight.
The six affirmation statements, given on page 8 T'ie resolution process should specify whose weight value is used in the resolution process if shipper's under section (7), relating to the resolution of and receiver's weights differ by more than one-half sigmficant shipper-receiver differences, as required of the total combined standard error.
by 10 CFR 74.31(c)(7), must be stated (without modification)in the FNMC plan.
7.5 Acceptance Criteria A judgment that the applicant's licensee's FNMC plan for conducting S/R evaluations and resolving 1
NUREG 1065 Rev. 2 40 l
l l
8 Assessment and Review of the Material Control and Accounting Program 8.0 Regulatory Intent assessed at intervals no greater than 12 calendar months. Thus, the type of assessment (partial or total) and the maximum interval between The intent of 10 CFR 74.31(c)(8)is to require assessments should be specified. " Interval" means management to periodically review and assess the the elapsed time between either the start of or performance of the MC&A system and evaluate its termination of successive assessments, overall effectiveness. It is intended that the review will be performed by knowledgeable, technically The responsibility and authority for the assessment competent individuals free from conflicts of interest program should lie at least one level higher in the and that the deficiencies will be brought to the licensee's organizational structure than that of the attention of plant management so that the MC&A manager. Such responsibility should deficiencies will be corrected. It should be include selecting 'the assessment team leader and emphasized that this review process is intended t initiating corrective actions. Team members may be much more than a routine audit for compiknee be selected from the facility staff or from outside, with existing procedures and commitments.
but an individual member should not panicipate in Conclusions and recommendations relative to the assessment of the parts of the MC&A system overall program effectiveness and to the adequacy for which that person has direct responsibility.
of the program to meet and satisfy regulatory intent 11ence, the MC&A manager may not be a team l
cre to be made.
member. Also, a given individual should not assess the parts of the system that are the responsibility of I
8.1 General Description another team member if the other team member is assessing the given individual's area. The leader of The capabilities, performance, and overall the assessment team should have no responsibilities effectiveness of the licensee's MC&A program for managing any of the MC&A elements being assessed.
should be independently reviewed and assessed at least every 24 months. The FNMC plan should describe the assessment and review program in The minimum number of individuals on any given terms of, assessment should be dependent on the knowledge l
and expertise of the team relative to MC&A (1) maximum interval between assessments activities and their experience in conducting assessments. Personnel assigned to the assessment (2) selection procedures for the assessment team team should have a demonstrated understanding of the regulatory obj,ectives and requirements of the (3) number of team members to be selected MC&A program and should have sufficient knowledge and experience to be able tojudge the (4) qualification and expertise of team members adequacy of the parts of the system they review.
The team should have authority to investigate all (5) independence of individual team members aspects of the MC&A system and should be given from the MC&A responsibilities and access to all necessary mformation.
activities they are reviewing and assessing To provide a meaningful and timely assessment, the (6) maximum elapsed time and minimum actual review and evaluation process should not be effort to be used for completion of the pr tracted. The actual review and investigation assessment and issuance of a final team activities should be completed in 30 calendar days, with an additional 15 calendar days allowed for repon completing and issumg a final team report.
The entire MC&A program generally should be reviewed and evaluated during each assessment.
When this occurs, intervals between assessments can be as much as 24 calendar months. However, ifindividual asse'. eats only cover part of the MC&A system, iv Jual subsystems should be 41 NUREG-1065 Rev. 2 i
l l
l l
Assessment 8.3 Management Review and 8.2 Report of Findings and Response to Report Findings Recommendations and Recommendations The areas to be reviewed should encompass the Management should review the assessment report entire MC&A system, and the level of detail of the and take the necessary actions to correct MC&A reviews should be sufficient to ensure that the system deficiencies. The management review essessment team has adequate information to make should be documented within 30 days following the reasoned judgments of the MC&A system submittal of the assessment team's report, and it effectiveness. The team report, as a minimum, should include a schedule for the correction of should state findings pertaining to:
deficiencies. Corrective actions, if any, that pertain to daily or weekly activities should be initiated (1) organizational effectiveness to manage and promptly after the submittal of the final assessment execute MC&A activities report.
(2) management responsiveness to indications of The FNMC plan should address resolution and possible losses of uranium follow.up actions associated with concerns identified in the assessment report. The individuals l
(3) staff training and competency to carry out responsible for resolving identified concerns, and MC&A functions the timeliness of such resolution, should be specified.
l (4) reliability and accuracy of accountability measurements made on SNM 8A M M
Qiteria (5) effectiveness of the measurement control program in monitoring measurement systems A judgment that the applicant's or licensee's and its sufficiency to meet the requireroents program for independent assessment of the MC&A for controlling and estimating loth bias and program is acceptable will be based on (but not SEID limited to) the following criteria:
The periodie assessments will be (6) soundness of the material accounting records comprehensive and sufficiently detailed to l
(7) effectiveness of the item control program to enable the assessment team to rate the track and to provide current knowledge of MC&A system effectiveness, capability, and items performance by comparison with the expected and required performance. The (8) capability to promptly kicate items and overall asassment objectives are to effectiveness in doing so determine that the MC&A system, as l
designed and implemented, is continuing to (9) timeliness and effectiveness of SRD meet the overall safeguards goals, and to evaluations and resolution of excessive SRDs identify weaknesses or deficiencies in the system design or performance that may need (10) soundness and effectiveness of the inventory-correcting.
taking procedures The areas to be reviewed encompass the (11) capability to confirm the presence of SNM entire MC&A program and the level of detail of the reviews is sufficient to ensure that the (12) capability to detect and resolse indications of assessment team has adequate information to missing uranium make reasoned judgments of the MC&A system effectiveness which includes:
On completion of each assessment, the findings and reconunendations for corrective action, if any, Organizational effectiveness and should be documented. The written report should management responsiveness to be distributed to the plant manager, the MC&A indicators of possible SNM losses; manager, and other managers affected by the ossessment.
(
NUREG-1065 Rev. 2 42
l i
1 Assessment Statf training and competency to carry "B" is assessing an area under the out MC&A functions; responsibility of " A" l
Soundness of the material accounting The entire MC&A system will be reviewed l
records; and evaluated during each single assessment (to be completed within an elapsed time that Capability to promptly lo: ate items; is short relative to the time between changes in the MC&A system and is demonstrated to Timeliness and effectiveness of S/R be able to include any such changes made difference evaluations and resolution of during the review / assessment). Conducting significant SRDs; two or more assessments during a 24-month interval, in which only part of the MC&A Soundness of physical inventory system is covered in each, is not deemed procedures and practices; acceptable. That is, reviewing a single component of the MC&A program at Effectiveness of the measurement 24-month intervals is not very meaningful control prograrn to monitor key unless a knowledge is obtained of how well measurement systems, establish bias the other components currently interact.
estimates and measurement Piecemeal review and evaluation is uncertainties, and meet the permissible, however, if each subsystem is requirements for contro' ling the total covered at 12-nwnth (or less) intervals.
MC&A measurement uncertainty The leader of the assessment team will have associated v ith ID; no resp (msibilities for performing or Capability to confirm the presence of managing the functions being assessed.
SNM; and The responsibility and authority for the Capability to resolve indications of assessment program and for initiating missing SNM and aid in any corrective actions will lie: (1) at least one government led investigation pertaining level higher in the organization than the to missing SNM, and provide MC&A manager, or (2) at a level equal to information that would aid in the that of the on-site plant manager.
recovery of missing SNM.
8.5 Affirmations Generally accepted auditing principles are j
used to check each type of record in which a representative sample (of a sufficient number)
The seven affirmation statements, given on pages 8 of randomly selected records is examined, and 9 under section (8), relating to the independent assessment and evaluation of the MC&A system Personnel assigned to the assessment team effectiveness requirements of 10 CFR 74.31(c)(8) will have an adequate understanding of the must be stated (without modification)in the FNMC regulatory objectives and requirements of the plan.
MC&A system and will have sufficient knowledge and experience to be able to judge the adequacy of the pans of the system they are asked to review. The team will have authority to investigate any aspect of the MC&A program and will have access to all relevant information.
An individual team member will not participate in the assessment of any part of the MC&A system for which he or she has direct responsibility. Also, an individual "A" will not assess any part of the system that is the responsibility of person "B" if 43 NUREG-1065 Rev. 2
9 Resolving Indications of Missing Uranium 9.0 Regulatory Intent indicators of possible missing uranium (involving 500 grams or more of U-235). Likewise, there should be established criteria for defining what The intent of 10 CFR 74.31(a)(2)is for h.eensees t constitutes resolution of an investigated indicator, react to (i.e., investigate and resolve) any off-normal or abnormal conditions or situations that Resolution of an indicator means that the licensee suggest a likelihood that 500 grams or more of has made a determination that loss or theft has not U-235 may be missmg (whether the cause is occurred and is not occurring. For each type of r.ccadental or deliberate).
indicator, the licensee should develop detailed resolution procedures and should describe or outline 9.1 Methods and Procedures for them in the FNMC plan.
Identifying Indicators Any investigation of an indication of a loss or theft i
should provide, whenever possible, (1) an estimate
)
~ FNMC plan should discuss the means by which of the quantity of SNM involved,(2) the material the acensee will resolve mdicators of missing type or physical form of the material, (3) the type I
uranium involving 500 grams or more of U-235, of unauthorized activity or event detected, (4) the The licensee's resolution program should address time frame within which the loss or activity could the possible indicators of missing uranium. The have occurred, (5) the most probable cause(s), and FNMC plan should enumerate all the potential (6) recommendations for precluding reoccurrence.
indicators that can be postulated and develop resolution procedures for each.
For indications that a loss or theft of more than 500 grams of U-235 may have occurred, the resolution The following are examples of possible indicators process should include (1) thoroughly checking the i
of missing uranium:
accountability records and source information, (2) hicating the source of the problem, (3) isolating the (1) lack of egreement between a physical exact reason for the problem within the area or inventory and its associated book inventory processing unit, (4) determining the amounts of in which the U-235 ID is positive and SNM involved, and (5) making a determination exceeds 1.7 times the SEID by more than that the indication is or is not resolved. The 4
500 grams resolution procedures should be prepared in s.uch a manner that no individual that could have been (2) determination through the item control.
responsible for the potential loss also would he program that one or more items are not in responsible for its resolution. If an investigation of their designated locations and the actual an indicator results in a conclusion that the l
k> cations are not immediately known ndication is true, such conclusion must be reported to the NRC within I hour of its determination (3) discovery that an item's integrity or its pursuant to !0 CFR 74.11. The FNMC plan tamper-indicating seal was compromised should show u.e reasonable time allowed for resolution. In general, a time not exceeding 72 (4) information from the process control system hours should be adequate.
indicating potential loss of material from the P " *** "7'"'
9.3 Response Actions for (5) an allegation of theft or diversion Unresolved Indicators 9.2 System and Procedures for Response actions to unresolved indicators should be Investigating and Resolving clearly defined and should be on a graded scale Indicators appropriate t the level of potential safeguards sigmficance. The responsibility and authority for irutiating and executing response actions also should At least one major MC&A procedure should be defined.
rddress the system and practices for investigating and resolving loss indicators because this topic For indicators of missing uranium, the level of pertains to one of the three performance objectives safeguards concern is related to such factors as:
of 10 CFR 7411(a). Thus, the licensee should have well-defined procedures for investigating (1) the potential quantity of U-235 involved 45 NUREG-1065 Rev. 2
I Resolving Indications of Missing Uranium (2) the material attractiveness of the potential individual responsible for resolving the missing uranium (in terms of fabricating a indicator.
nuclear explosive device) relative to its No investigation relative to an indication of enrichment and composition or form (e.g.,
U metal, U 0,, uranyl nitrate solution, UF.,
a loss or theft of SNM exceeding the current 3
scrap, or waste)
DQ shall be declared as completed but unresolved without first conducting a 9.4 Documentation Requirements shutdown, cleanout inventony in which all unsealed SNM is remeasured for element The FNMC plan should identify all documentation requirements associated with the licensee's program 9.6 Affirmations for the reportmg, mvestigation, and resolution of missing uranium indicators. Review and approval requirements and document custodial responsibility The three affirmation statements pertaining to the clso should be defined. As a minimum, 10 CFR 74.31(a)(2) performance objective, listed as documentation of the following should be included:
bullets two, four, and five in the section at the top of page 5 (" Affirmations Pertaining to Performance (1) investigation procedures Objectives"), must be stated (without modification) in the FNMC plan.
(2) resolution procedures (3) reporting of indicator to MC&A management including date and time the indicator was reported, name of individual who discovered the indicator, and description of indication (4) investigation findings and conclusion, including resolution status, date issued, name and signature of principal investigator, and approval signature of MC&A manager (5) reports made to NRC for unresolved indicators and for indicators determined to be real, including date and time the report was made, method of communication, and name of NRC individual contacted 9.5 Acceptance Criteria A judgment that the applicant's or the licensee's plan for resolving indications of missing SNM is acceptable will be based on (but not limited to) the following criteria:
Adequate commitments are provided to assure a high probability that any indicator of missing SNM th t could involve 500 grams or more of U-235 will be (1) recognized as an indicator, (2) investigated, and (3) resolved.
Investigation and resolution procedures will provide for adequate overchecks to assure that no individual who could have been responsible for a possible loss or theft of SNM would be the sole or primary NUREG-1065 Rev. 2 46 i
l l
l 10 Informational Aid for Assisting in the Investigation and Recovery of Missing Uranium 10.0 Regulatory Intent (6) reports of apparent destruction or falsification of records pertaining to SNM The 10 CFR 74.31(a)(3) performance objective (7) records of broken tamper-indicating devices pertains to mvestigations, relatmg to actual (or or compromised item integrity highly suspected) events pertaining to missing uranium, conducted by the NRC and/or other (8) indications of unauthorized entry into SNM government agencies. The intent is for licensees t storage areas have ready for and to provide to the investigators any information deemed relevant to the recovery of (9)
Reports from monthly item status material involved in a loss, or theft. The burden inspections I
I shall be on the licensee, to provide (without being asked to) all information that it recognizes as being (10) material receipt and log-in records relevant, as opposed to only previding information that the investigators are knowledgeable enough t (11) results from shipper-receiver difference recluest.
evaluations 10.1 Information Aid (12) process quality assurance or production control records The kinds of information that may aid the (13) documentation relating to an alleged or investigation and recovery effort are:
cenfirmed theft (1) data or observations that led the licensee to Information associated with resolving indications of determine that a loss or theft of uranium missing uranium are provided in Chapter 9. This may have occurred information and information that may be of aid in the recovery of missing material would include:
i (2) data, observations, and assessments associated with attempts to resolve the (1) the type of unauthorized activity detected l
indication of missing material (2) the interval during which the loss may have (3) the time period during which the material occurred may have left the facility (3) the amount of material and form of the (4) the path and means by which the material material involved in the loss may have left the facility (4) results of measures to validate indicators Information indicating that a loss of uranium mcy have occurred can come from process monitoring (5) results of extended measures to resolve or production yield data, physical inventory mdicators results, item monitoring audits, and shipper, receiver comparisons. This information could (6) results from special inventories (or include:
reinventories) and tests performed I
(1) material accountability data records and (7) audit results of the SNM accountability reports source data (2) inventory records (8) assessments of measurement data and measurement controls (3) inventory difference and propagation of error calculations (9) results from reviews of the material control and accounting program and status of (4'
inventory reconciliation reports comctive actions (5) indications of unrecorded or unauthorized (10) history of indicator investigation and removals of SNM from storage or process resolution activities locations 47 NUREG-l%5 Rev. 2
Ascisting Investigations (11) indicator investigation and resolution procedures and conclusions (12) probable cause of the h>ss (13) any abnormal events that may have contributed to or caused the loss (14) the names of individuals who could have been responsible for the loss i
Much of the backup information necessary to assist in an investigation would be records maintained in the facility records system described in Chapter 11.
10.2 Acceptance Criteria t
A judgment that the applicant's or the licensee's plan for informational aid for assisting in the investigation and recovery of missing uranium is acceptable will be based on (but not limited to) the following criterion:
Procedures are in place for the efficient and timely gathering of relevant information to provide government investigators so as to aid them in the investigation and recovery activities associated with missing SNM.
10.3 Affirmations
[
The affirmation statement pertaining to the 10 CFR 74.31(a)(3) performance objective listed as the third bullet in the " Affirmations Pertaining to Performance Objectives" section on page 5. must be stated (wi'.hout modification)in the FNMC plan.
f NUREG-1065 Rev. 2 48
l 11 Recordkeeping l
11.0 Regulatory Intent (9) ledsers, journais, and computer printout sheets asniated with the accountability The intent of 10 CFR 74.31(d) is to require the l
establishment, maintenance, and protection of a (10) ledgers, journals, and computer printout recordkeeping system that will demonstrate that the sheets associated with the item control system capability requirements of 10 CFR program, including seal usage and " attesting 74.31(c)(1) through (8) have been met. Records to" records are to be retained for at least three years (or longer if specifically required by regulations external t (11) DOE /NRC fi>rms 741 and 742 10 CFR 74.31) thereby providing a means for aasessing the performance of the MC&A system (12) forms, memos, and reports associated with and inspecting for comphance with regulatory identification of, investigation of, and requirements.
resolution of significant SRDs 11.1 Description of Records (i3) ioss inaication and aiieged thert investigation reports The FNMC plan should identify all records, forms, reports, and standard operating procedures that (14) investigation reports pertaining to excessive I
ids i
must be retained for a minimum of 3 years, as required by 10 CFR 74.31(d). Such records should include, bt.t an not limited to, the following:
(15) official reports containing the findings and recommendations of MC&A system l
(1) documents that define changes in the MC&A assessments and any letters or memos management structure or changes in pertaining to response actions to assessment team recommendations r.sponsibilities relating to MC&A positions; l
(2)
,oc edures pertaining to any accountability (16) fi>rms used fi>r recording data associated w" sed measurement or sampling operation with the item monitoring program l
(3) fi>rms used to record or to report (17) m nitoring program status or summary measurement data and measurement results, feP"'18 including source data (18) records of training sessions including date (4) forms and notehooks used to record given, topics covered, name of instructor (s),
calibration data associated with any names and signatures of those attending accountability measurement system l
(19) traming, qualification, and requalification I
(5) fi>rms and notebooks used to record reports and records quantities, volumes, and other data associated with the preparation of standards, Examples of the more important MC&A forms both calibration and control, used in should be provided in the FNMC plan annex or connection with accountability measurement appendix. The retained records and reports should systems contain suf ficient detail to enable NRC inspo: tors to determine that the licensee has implemented the (6) forms and official memos used to record or system features and capabilities of 10 CFP 74.31(c) report sneasurement control program data, and has met the general perfiirmance objwt.ves of control limit calculations, and out-of-control 10 CFR 74.31(a).
investigations (7) forms listing and providmg instructions associated with physical inventories (8) forms and formal worksheets used in the calculation of SEID, ID, and active inventory values 49 NUREG-1065 Rev. 2
l Recordkeeping 1
l After this time, any 11.2 Program and Controls beca **P ***d:le is acceptable for the readable facsimi fOr Ensuring an Accurate remainder of the required retention period.
and Reliable Record All other records may be retained as hard System c py, mier fiche, permanent computer readable forms, or other permanently readable forms.
He FNMC plan should describe the controls used to ensure that records are highly accurate and He retained records and reports contain
- reliable, sufficient detail to enable NRC inspectors to l
determine that the control and accounting of ne record system also should provide a capability the SNM has complied with the for easy traceability of all SNM transactions from requirements of 10 CFR 74.31(c) and has source data to final accounting records.
met the general performance objectives of 10 CFR 74.31(a).
The following topics should be addressed:
The records will be retrievable, sufficiently I
(1) the auditing system or program to verify the complete and detailed to permit auditing all correctness and completeness of records parts of the MC&A system, and traceable back to original source data.
(2) the overchecks for preventing or detecting missing or falsified data and records The records of the data that are the basis of the calculated SEID will pennit traceability (3) the plan for reconstructing lost or destroyed to the sources of the variances due to SNM records calibrations, bias adjustments and random effects in the measurements. Rese records (4) the aceras controls used to ensure that only may be summaries of calibrations, bias tests, authorized persons can update and correct and variance monitoring data or control records charts.
(5) the protection and redundance of the record The record system will have sufficient system such that any act of record alteration redundancy to enable reconstruction of lost l
or destruction will not eliminate the ability or missing records so that knowledge of the to provide a complete and correct set of SNM inventory is always available. The l
SNM control and accounting information primary records, as contrasted with needed to achieve the performance duplicate or backup records, will be objectives of 10 CFR 74.31.
provided security against computer failure, fire or water damage, vandalism, and access 11.3 Acceptance Criteria by unauthorized persons.
All retained MC&A records are to be A judgment that the licensee's commitments for readily accessible, in order to meet time recordkeeping are acceptable will be based on (but restramts relative to their use. In general, not limited to) the following criteria:
the record retention system is to possess the capability to retrieve records used for The FNMC plan shows that key material measurement control or accountability f
accounting and original source data within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if the record was generated documents and relevant reports and within the past 12 months, and within 7 documents will be retained for three years calendar days if generated more than 12 or as long as needed to show continuing months ago. Physical mventory listings are compliance with 10 CFR Part 74. (For t be available within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for the latest example, records of the organization two physical inventories. Item control structure cannot be destroyed if the current records are to be retnevable in time to structure is still the same.)
satisfy the enteria m Section 6.7.
He source data will be retained in its Overchecks or other controls m. eluding original form until the physical inventory access mntrols for updating and correcting and any subsequent ID investigations have NUREG 1065 Rev. 2 50
Recordkreping records are provided so as to prevent or detect errors in the records that would affect inventory difference and item location.
l 11.4 Aflirmations The affirmation statements relating to the recordkeeping requirements of 10 CFR 74.31(d) as listed on pages 9 and 10, must be stated (without modification)in the FNMC plan.
l l
l l
l l
i 51 NUREG-1065 Rev. 2
Glossary Glossary The following terms are defined in the context of (1) their usage in this document and/or (2) how BEGINNING INVENTORY - For each material they should be used if contained in the fundamental type code, the total itemized quantity of SNM nuclear material control (FNMC) plans submitted possessed by a facility at the start of a material i
pursuant to 10 CFR 74.31.
balance period (i.e., inventory period). The l
beginning inventory quantity for any given material i
ACCOUNTABILITY - The determination of, and balance period is (by definition) exactly equal to the current record maintenance of, special nuclear ending inventory quantity for the immediately i
material (SNM) quantities associated with (1) previous period.
receipts, (2) shipments, (3) measured discards, (4) l transfers into or between material balance areas BIAS (MEASUREMENT BIAS)- A constant, (MBAs) and/or item control areas (ICAs), and (5) unidirectional component of error that affects all total material on current inventory.
members of a measurement data set. Thus, a bias can be estimated from the deviation of the mean of ACCOUNTANCY (ACCOUNTING) - The several measurements of a representative standard records (e.g., ledgers, joumals, source documents, from the reference value (or assigned value) of such etc.) associated with accountability, standard.
ACTIVE INVENTORY - The sum of beginning CALIBRATION - The process of determining the inventory (BI), additions to inventory (A), removals numerical relationship between the observed output from inventory (R), and ending inventory (EI) after of a measurement system and the actual value of all common terms have been totally excluded. A the characteristic being measured, as based on common term is any SNM material value (or item) primary or reference standards.
thzt appears in both BI and El, or both BI and R, or both A and R, or both A and EI, with both CERTIFIED STANDARD - A standard weight, values derived from the same measurement (and material, device, or instrument having an assigned l
thus, does not contribute to the uncertainty value that is guaranteed to be within specified limits l
associated with the current period inventory by a nationally or intemationally recognized difference). The active inventory is used as an organization (e.g., bureau, laboratory, etc.) that indicator of processing throughput and/or issues and/or certifies standards.
processing activity.
CiiECK STANDARD (BENCH STANDARD, ADDITIONS TO INVENTORY - Quantities of WORKING STANDARD)- A standard, not SNM, of a given material type code, added to a necessarily traceable to a primary standard, that is
' plant" inventory and which, prior to such addition, used routinely (e.g., daily or weekly) to check (or were not part of the plant's total possessed quantity verify) the reliability of a measurement device, for the material type code in question.
instrument, etc. (including those of accountability measurement systems). Such standards are not, ARTIFACT STANDARD - A container or item, however, used for the actual calibration or control of certified mass, having a size, shape, and mass of accountability measurement systems.
that is representative of a particular type of process-related item or container (e.g., a UF. cylinder).
COMBINED STANDARD ERROR - An error Weighing error caused by buoyancy is eliminated band derived from the respective standard error by the use of artifact standards for scale values associated with each of two measurements calibrations.
(usually indepenient of each other) performed on a given material quantity. For both measurement ASSIGNED VALUE - A value for mass, volume, values (of the pair) to be regarded as being in SNM concentration, SNM quantity, etc., assigned agreement, they must not differ from each other by to a standard weight, standard material, etc., used more than the calculated combined standard error, for calibrating and/or controlling a measurement which is normally calculated by taking the square device or system. An assigned value may not root of the sum of squared individual standard necessarily be a certified value, but if not, should errors. That is:
be traceable to a certified standard. In any event, it is the best estimate of the standard's true value.
combined S.E. = [(a )2 + (a2)2] %
i
$3 NUREG-1065 Rev. 2
l 1
l i
Glossary i
t CONFIRMATORY MEASUREMENT - A the standard error of the inventory difference measurement that confirms (within measurement (SEID), as shown by the following equation:
uncertainty at the 95 percent confidence level) a previously established parameter, such as net DT = DQ - 1.3 (SEID) weight, enrichment, etc., associated with an SNM item (or SNM quantity), but which does not EFFECTIVE KILOGRAM - An effective thoroughly verify the previously established element kilogram of SNM means (1) for plutonium and and/or isotope quantity assigned to such item.
U-233, their weight in kilograms; (2) for uranium Confirmatory measurements are sometimes used as with an enrichment in the isotope U-235 of
(
the basis for concluding that previous measurement 1.00 wt % (i.e.,0.01 g U-235/g U) and above, its values for uranium and U-235 (or element and element weight in kilograms multiplied by the isotope) quantities are still valid.
square of its enrichment expressed as a decimal weight fraction; and (3) for uranium with an CONTROL STANDARD - A standard that (1) is enrichment in U-235 below 1.00 wt %, but above representative of the process material being 0.71 wt %, its element weight in kilograms measured and (2) is itself measured periodically to multiplied by 0.0001.
monitor for and to estimate any bias associated with the measurements of the process material in ENDING INVENTORY - For each material type question. A control standard must be traceable to a code, the total itemized quantity of SNM possessed l
primary standard or to a primary reference by a facility at the end of a material balance period, l
material.
as determined by a physical inventory. The ending inventory quantity for any given material balance CUSTODIAN - A designated individual who is period is (by definition) exactly equal to the responsible for (1) the control and movement of all beginning inventory quantity for the next period.
l SNM within a specified control area, and (2) maintaining records relative to all SNM that is ENRICHED URANIUM - Any uranium-bearing transferred into or out of the area and that is material that does not qualify as natural uranium currently located within the control area. Control and whose combined U-233 plus U-235 isotopic creas are usually designated as MBAs or ICAs.
content is 0.72 wt % or higher relative to total l
From the standpoint of good safeguards practice, a uranium elemental content.
single individual should not be a custodian of more than one control area.
FORMULA KILOGRAM (FKG)- The number of formula kilograms is computed by the following DEPLETED URANIUM - Any uranium-bearing equation:
material whose combined U-233 plus U-235 isotopic content is less than 0 'O wt % (relative to FKG =
total uranium elemental content).
[(grams U-235 contained in high-enriched uranium) + 2.5 (grams U-233 +
DETECTION QUANTITY (DQ)- A site-specific plutonium))
U-235 quar,tity of SNM for licensees whose divided by 1000 processing activities are limited to SNM of low strategic significance. He DQ is normally a FORMULA QUANTITY - Strategic SNM in any function of annual throughput, but for low-combination in a quantity of 5.00 FKGs or more.
throughput low-enriched uranium (LEU) facilities, the DQ need not be less than 25 kilograms of HIGH-ENRICHED URANIUM (HEU)- Any U-235. The DQ also can be described as a goal uranium-bearing material whose U-235 isotopic quantity, the loss or theft of which must be detected content is 20.00 wt % or more relative to total with a 90 percent (or better) probability at the time uranium elemental content.
of a physicalinventory.
INVENTORY DIFFERENCE (ID)- ne DETECTION THRESHOLD (DT)- An inventory arithmetic difference between a book inventory and difference (ID) limit that will be exceeded (with the corresponding physical inventory, calculated by 90 percent or higher probability) by an ID resulting subtracting ending inventory (EI) plus removals from the taking of a physical inventory whenever from inventory (R) from beginning inventory (BI) there has been an actual loss of a detection plus additions to inventory (A). Mathematically, quantity. The DT is a function of both the DQ and this can be expressed as:
ID = (B1 + A) - (El + R)
NUREG 1065 Rev. 2 54
Glossary INVENTORY RECONCILIATION - The SNM and by-product materials. These codes are edjustment of the book record quantity of both used by the Nuclear Materials Management and element and fissile isotopes to reflect the results of Safeguards System (NMMSS) for tracking U.S.-
a physical int entory. In the broad sense, inventory owned.ad U.S.-possessed materials worldwide, reconciliatiori also includes the activities of For SNM, seven material type codes have been calculating (i) the ID for the material balance assigned as follows:
period in question, (2) the uncertainty (i.e., SEID) value associited with the ID, (3) the active CODE M ATEktAL TYPE DeP *ted Ur*aium l
inventory fcor the period, and (4) any bias 10 3
sdjustment and/or prior period adjustment c ]""'"M '
20 En 9
u essociated with the ID value.
70 Uranium-233 t")
83 Plutonium-238 (*")
ITEM - Any discrete quantity or container of 88 norium 89 Uranium in Ca. cades SNM, not undergoing processing, having a unique identity an,d also having assigned uranium and U-
- For DOE /NRC Form 742. material code 20 has 4 235 quanuties.
subcodes to denote enrichment range: El, E2, E3, and E4. For NRC Form 327. material code 20 has 2 subcodes: LEU and ITEM CONTROL AREA (ICA)- An identifiable HEU.
i l
physical area for the storage and control of SNM
" Uranium materials should be resarded si material items. Control of items moving into or out of an code 70 if the U-233 immyie abundance is greater than (1)
' U # *' " " "" '
""I"* emental content r (2)
Y tem identity and SNM 9uantity as both (a) the U-233 im*M "bundance.
ICA is b i
>pic a is greater than the U-235 determined from previous measurement.
i,y,pic abundance and (b> ihe U-233 im+rie abundance exceeda 5.00 wt % relative to total elemental uranium content; m
ITEM CONTROL PROGRAM - A system that otherwise repon as matenal code 10. 20. or si, as appropriate.
trecks (i.e., records) the creation, identity, location,
'" Plutonium materials should be regarded as material c de 83 ir me plutomune238 im>iopk abundance is grenier man and disposition of all SNM items of certain 10 00 wt % relative to total plutonium elemental content; predetermined item categories. Ir. addition, item otherwise. report as material code 50.
control programs usually provide a periodic verification of item existence and kication for static MEASURED DISCARD - A batch or quantity of items.
waste, whose SNM content has been determined by measurement, that (1) has been shipped to a LOW-ENRICilED URANIUM (LEU)- Arv disposal site, released to the environment, or stored uranium-bearing material whose U-235 isotop.s on site, and (2) has been taken of f the accounting content is greater than 0.72 wt % but less than ledgers as part of the current inventory of possessed 20.00 wt % relative to total uranium elemental SNM.
content.
MEASUREMENT - The process of determining a MATERIAL BALANCE - A comparison on a (1) uranium elemental concentration, (2) specific measured basis of beginning inventory plus uranium isotopic content, (3) U-235 enrichment l
additions to inventory to ending inventory plus re.
(i.e., isotopic abundance), (4) bulk material mass or l
movals from inventory for a given control area (or item mass, or (5) bulk material volume.
combination of control areas) ovn a specified Measurement values are derived through a period of time.
calibration process that establishes the relationship between instrument (i.e., device) response and the MATERIAL BALANCE AREA (MBA)- An parameter being determined.
identifiable physical area for the physical and administrative control of nuclear material such that MEASUREMENT CONTROL PROGRAM - A the quantity of nuclear material being moved into or managed program for monitoring and controlling out of the MBA is represented by a measured value both accuracy and precision of SNM accountability (for both element and isotope).
measurements.
M ATERIAL BALANCE. PERIOD - The time NATURAL URANIUM - Any uranium-bearing span to which a material balance or physical material whose uranium isotopic distribution has not inventory pertains.
been altered from its naturally occurring state.
Natural uranium is nominally 99.283 wt % U-238, MATERIAL TYPE CODES - Number codes for 0.711 wt W U-235, and 0.006 wt % U-234.
identifying basic material types with respect to SM, 55 NUREG-1065 Rev. 2
Glossary NORM AL URANIUM - Any uranium-bearing internationally recognized bureau, laboratory, etc.,
material having a uranium isotopic distribution that that issues and/or certifies standards.
can be characterized as being (1) 0.700 wt % to 0.724 wt % in combined U-233 plus U-235 and (2)
PRIOR PERIOD ADJUSTMENT - Any at least 99.200 wt % in U-238. (NOTE: All correction (i.e., adjustment) to an ID value because natural uranium having a U-235 isotopic abundance of a correction applied to a component of beginning in the range of 0.700 wt % to 0.724 wt % is inventory after the inventory period started. Such normal uranium, but not all normal uranium is corrections may be due to resolution of a shipper-nitural uranium.)
receiver difference (SRD) on matenal received during a prior inventory period, correction of a PHYSICAL INVENTORY - A determination by recording error, etc. Because these types of physical means (visual and measurement) of the corrections have nothing to do with current period quantity of SNM on hand for a given material type losses or errors, and because the official beginning code at a specified point in time. The primary inventory value is not adjusted, an adjustment to the purpose for a physical inventory is to confirm the ID value (derived from the ID equation) is obsence of (or to detect) a loss, theft, or diversion necessary to obtain an ID that reflects only current of SNM. For the conclusion drawn from a physical period activity.
inventory to be messingful, not only does the physical presence of all material (or at least the vast PROCESS MONITORING - A system of majority of the traterial) need to be confirmed, but monitoring production data (e.g., flow rates, yields, the quantities of material in the inventory also need densities, etc.) and of production control or quality to be remeasurec, or other assurance provided, to control measurements (as opposed to accountability l
verify that prior naasurements are still valid.
measurements) that could provide early (i.e.,
Physical inventories are to be conducted on a timely) detection of an anomaly that may indicate a
- plant" as well as on a " material type code
- basis.
significant loss or theft of SNM or indicate unauthorized enrichment activities.
PLANT - For SNM control and accounting purposes, a plant is defined as a set of processes or RANDOM ERROR - The variation encountered in operations (on the same site, but not necessarily all all measurement work, characterized by the random in the same building) coordinated into a single occurrence of both positive and negative deviations manufacturing, research and development, or from a mean value.
testing effort. Most licensees have only one plant in this context. Independent on-site manufacturing RECElPT - A quantity of SNM in a shipment i
efforts, such as a scrap recovery operation serving received by a facility from another facihty.
both on-site and off-site customers, should be treated as separate plants.
REFERENCE STANDARD - A material, device, or instrument whose assigned value is traceable to a POINT-CALIBRATED MEASUREMENT national standard (i.e., primary standard) or nation-SYSTEM - A measurement system in which the ally accepted measurement system.
measurement value assigned to an unknown measured by the system is derived from the REMOVALS FROM INVENTORY - All response obtained from the measurement of a measured quantities of SNM falling within the representative calibration standard (s) that was categories of (1) shipments, (2) measured discards measured along with (i.e., at the same time as) the released to the environment, (3) measured discards unknown. The standard (s) must undergo all the transported off-site, and (4) measured discards measurement steps (e.g., aliquoting, sample stored on-site and formally transferred in the pretreatment, etc.), and in the same manner, as the accounting records to a holding account via a unknown. Point-calibrated measurement systems DOE /NRC Form 741 transaction.
can be regarded as bias free, provided that adequate controls are in place to ensure the validity of the RESOLUTION OF AN INDICATOR - A standard's assigned value, dermitive determination (with auditable evidence) by the licensee that an indicated possible theft or PRIMARY STANDARD - Any device or material loss of uranium was a false indicator.
having a characteristic or parameter (such as mass, uranium concentration, uranium isotopic distri-SHIPPER-RECEIVER DIFFERENCE (SRD)-
bution, etc.) whose value is certified (within a The difference between what a sending facility specified uncertainty) by a nationally or (i.e., shipper) claims was contained in a shipment NUREG-1065 Rev. 2 56
Glossary (of SNM) and what the receiving facility claims l
was received, where both shipper's and receiver's E( xi - x )2 l
values are based on measurement.
std. dev.
=
n-1 l
SPECIAL NUCLEAR MATERIAL (SNM) - (1) l Plutonium, U-233, uranium enriched in U-235, and l
cny other material that the NRC, pursuant to the where I
provisions of Section 51 of the Atomic Energy Act l
of 1954 (as amended), determines to be SNM; or n=
number of measurements performed (2) any material artificially enriched in any of the xi =
the value obtained for the i th foregoing. There are three levels of strategic measurement for i = 1, 2, 3.......n significance applied to SNM, depending on the type x=
the average value for all n end quantity, defined as follows:
measurements l
SNM OF HIGH STRATEGIC SIGNIFICANCE l
- Same as FORMULA QUANTITY (see STANDARD ERROR - The random error (at the l
definition).
67 percent confidence level) associated with the average, or mean, value of a data set derived from SNM OF MODERATE STRATEGIC repetitive determinations on the same item or SIGNIFICANCE - (1) Less than a formula sample. Mathematically, standard error is the quantity, but more than 1,000 grams of U-235 standard deviation divided by the square root of the contained in HEU, or more than 500 grams of number of individual measurements used to derive U-233 or plutonium, or more than a combined the mean value.
l quantity of 1,000 formula grams when formula grams are computed by the following equation:
STANDARD ERROR OF THE INVENTORY DIFFERENCE (SEID) - For licensees subject to formula grams = (grams U-235 in HEU) 10 CFR 74.31 or 74.33, non-measurement
+ 2 (grams U-233 + grams Pu) contributions to the uncertainty of ID can be assumed or estimated, but can not exceed the or (2) 10,000 grams or more of U-235 contained measurement contribution. Thus for 74.31 and in LEU enriched to 10.00 wt % or more, but 74.33 licensees, SEID is equal to the square root of less than 20.00 wt %, U-235.
the sum of both measurement and non-measurement variances associated with the ID.
SNM OF LOW STRATEGIC SIGNIFICANCE
- (1) Less than an amount of SNM of moderate STANDARD REFERENCE MATERIAL - A strategic significance, but more than 15 grams of material or substance that qualifies as a primary l
(a) U-235 contained in HEU, (b) U-233, standard and whose concentration with respect to a l
(c) plutonium, or (d) any combination thereof; nuclide or isotope, a chemical element, or chemical (2) less than 10,000 grams but more than 1,000 compound is certified within a specified l
grams of U-235 contained in LEU enriched to uncertainty.
I 10.00 wt % or more (but less than 20.00 wt %)
U-235; or (3) 10,000 grams or more of U-235 SYSTEM ATIC ERROR - A unidirectional error contained in LEU enriched above natural but that affects all members of a data set. The terms less than 10.00 wt % U-235.
- bias" and
- systematic error" are often interchanged. However, any determined bias (i.e.,
STANDARD - See definitions for CERTIFIED a bias estimated from control standard STANDARD, CHECK STANDARD, CONTROL measurements) has an uncertainty value associated STANDARD, PRIM ARY STANDARD, and with it. Thus, after correcting for any estimated REFERENCE STANDARD.
bias, the uncertainty of that bias can be regarded as a systematic error. If an estimated bias is not STANDARD DEVIATION - The random error applied as a correction, the combination of the bias (at the 67 percent confidence level) associated with plus its uncertainty should be regarded as the o single value of a data set, which in tum is also a systematic error.
measure (or indication) of the precision relating to a set of measurements (or set of data) pertaining to the same item or sample of material. S'andard deviation is calculated as follows:
57 NUREG-1065 Rev. 2
}
I
l' Glossary TRACEABILITY - The ability to relate individual measurement results to national standards (i.e.,
primary standards) or nationally accepted
- measurement systems through an unbroken chain of l
compensons.
VERIFICATION MEASUREMENT-(1) An NDA measurement of an item conducted to verify that a previous NDA measurement value for isotope content of that item is still valid. (2)'The re-weighing and re-sampling of an item, batch, lot, j
l or sublot and performing chemical assays of the re-sample for element and isotope concentrations so as to verify a previously measured value for element and isotope content of the item (batch, lot, j
or sublot). Verification is achieved if the original
{
and verification measurement values (for element and isotope quantities) agree within the range of measurement uncensinty (at the 95 percent confidence level).
NUREG-1065 Rev. 2 58
NRC FORM 336 U.S. NI.,'OLL/,R REGULATORY COMM:SSION
- 1. REPORT NUMBER t
Rev.5sna
- Num-C 1102, pp i
anos,saca BIBLIOGRAPHIC DATA SHEET b"'5 " *"v l (See instructions on the reverse)
NUREG-1%5 Rev. 2
- m. nTLE AND SUBTnLE
' Acceptable Standard Format and Content for the Fundamental Nuclear Material
- 3. DATE REPORT PUBUSHED Control (FNMC) Plan Required for Low-Enriched Uranium Facilities l
MONTH YEAR December 1995
- 6. TYPE OF REPORT
'Ibchnical D. R. Joy
- 7. PERIOD COVERED (Irelusive Dates) l l
S. PERFORMING ORGANIZATION - NAME AND ADDRESS (if NRC, prov6de Division. Ofice or Region, U.S. Nuclear Regulatory Commission, and malling address; if contractor, provide name and malling address.)
Division of Fuct Cycle Safety and Safeguards Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
- 9. SPONSORfNG ORGANIZATION - NAME AND ADDRESS (if NRC, type 'Same as above"; if contractor, provide NRC Dwiston, Office or Region, U.S. Nuclear Regulatory Commission, and rnalling address.)
Same as item #8 I
i l
- 10. W3PLEMENTARY NOTES
- 11. ABSTRACT (200 words or less)
This report documents a standard format suggested by the NRC for use in preparing fundamental nuclear material control (FNMC) plans as required by the Low Enriched Uranium Reform Amendments (10CFR 74.31). This report also describes the necessary contents of a comprehensive plan and provides example acceptance criteria which are intended to commjnicate acceptable means of achieving the performance capabilities of the Reform Amendments.
By using the suggested format, the licensee or applicant will minimize administrative problems associated with the submittal, review and approval of the FNMC plan. Preparation of the plan in accordance with this format will assist the NRC in evaluating the plan and in standardizing the review and licensing process. Ilowever, conformance with this guidance is not required by the NRC. A license applicant who employs a format that provides a equal level of completeness and detail may use their own format.'Ihis document is also intended for providing guidance to licens-ees when making revisions to their FNMC plan.
- 13. AVAILABlUTY STATEMENT
- 12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.)
Unlimited
- 14. SECURITY CLASSIFICATION Reform Amendments (Th F*8')
Low Enriched Uranium Unclassified LEU Fuel Fabrication (ma Reparo Material Control and Accounting Special Nuclear Material Unclassified SNM of Low Strategic Significance is. NuMetR Oe PAGeS
- 16. PRICE NRC FORM 335 (2-89)
l l
l Printed on recycled paper Federal Recycling Program l
t
~
CONTROL (FNMC) PIAN REQUIRED FOR LOW-ENIUCIIED URANIU5V FACILITIES -
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' UNITED STATES
'. RRST CLASS MAtk.
,j ENUCLEAR REGULATORY COMMISSION.
POSTAGE AND FEES PAfD -
- +.
e ' ' *
/ WASHINGTON, D.C. 20555-0001 -
--usNRCi
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' PERMIT NO.'G-67 l-~
OFFICIAL BUSINESS
, FENALTY FOR PRIVATE USE, 4300 -
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