Regulatory Guide 5.57

(Revision 1), Shipping and Receiving Control of Strategic Special Nuclear Material

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Issue date:	06/30/1980
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RG-5.57 Rev 1
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Revision 1 June 1980

U.S. NUCLEAR REGULATORY COMMISSION

REGULATORY GUIDE

OFFICE OF STANDARDS DEVELOPMENT

REGULATORY GUIDE 5.57 (Task SG 908-4)

SHIPPING AND RECEIVING CONTROL OF STRATEGIC

SPECIAL NUCLEAR MATERIAL

A. INTRODUCTION

5.10 Selection and Use of Pressure-Sensitive Seals on Containers for Onsite Storage of Special Requirements for the physical protection of special Nuclear Material.

nuclear material (SNM) at licensee facilities and in transit and of plants in which SNM is used are specified in 10 CFR 5.12 General Use of Locks in the Protection and Part 73, "Physical Protection of Plants and Materials," and Control of Facilities and Special Nuclear are the subject of various regulatory guides issued or under Materials.

• r development. Section 73.20 of 10 CFR Part 73 provides the general performance objective and requirements for 5.13 Conduct of Nuclear Material Physical Inven each licensee who is authorized to operate a fuel repro tories (In particular, Section C.2.b.(l), Re cessing plant pursuant to 10 CFR Part 50, possesses or ceipts, Shipments, and Other Removals).

uses formula quantities of strategic special nuclear material (SSNM) at any site or contiguous sites subject to control by

5.15 Security Seals for the Protection and Control the licensee, is authorized to transport or deliver to a carrier of Special Nuclear Material.

for transportation pursuant to 10 CFR Part 70 formula quantities of SSNM, takes delivery of formula quantities of 5.45 Standard Format and Content for the Special SSNM free on board (f.o.b.) the point at which it is delivered Nuclear Material Control and Accounting Sec to a carrier for transportation, or imports or exports tion of a Special Nuclear Material License formula quantities of SSNM. Section 73.25 requires specific Application.

performance capabilities for physical protection of SSNM

in transit. Section 73.45 requires specific performance 5.47 Control and Accountability of Plutonium in capabilities for fixed site physical protection systems. This Waste Material.

guide is applicable to the shipping and receiving control of SSNM subject to § § 73.20, 73.25, and 73.45.

5.51 Management Review of Nuclear Material Control and Accounting Systems.

Other regulations are also pertinent to shipping and receiving control. Section 70.58, "Fundamental Nuclear Section 70.57 and paragraph (f) of § 70.58 require that Material Controls," requires licensees to establish, maintain, the licensee's measurement control program for SNM include and follow detailed fundamental material control and a means for the control and evaluation of measurement bias, accounting procedures, including procedures for shipping random errors, and limits on systematic errors for all parts and receiving special nuclear material (SNM). Certain of the measurement process, including scales, balances, material control and accounting procedures related specifi volume measurements, analytical quality control, nondestruc cally to the protection of SSNM from theft during shipping trive assay, and sampling. Certain measurements made in con and receiving and related to preventing the misuse of junction with shipping and receiving are used as part of the shipments to disguise a diversion are discussed in this guide.

material accountability program and are subject to § 70.57.

Additional guidance on fundamental material controls and Specific guidance on measurements and measurement control accounting is included in the following regulatory guides:

are provided in the following regulatory guides:

5.4 Standard Analytical Methods for the Mea surement of Uranium Tetrafluoride (UF 4 )

Lines indicate substantive changes from June 1976 version.

and Uranium Hexafluoride (UF 6 ).

USNRC REGULATORY GUIDES Comments should be sent to the Secretary of the Commission, Regulatory Guides are issued to describe and make available to the U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, public methods acceptable to the NRC staff of implementing Attention: Docketing and Service Branch.

specific parts of the Commission's regulations, to delineate tech niques used by the staff in evaluating specific problems or postu The guides are issued in the following ten broad divisions:

lated accidents or to provide guidance to applicants. Regulatory Guides are noi substitutes for regulations, and compliance with 1. Power Reactors 6. Products them is not required. Methods and solutions different from those set 2. Research and Test Reactors 7. Transportation out in the guides will be acceptable if they provide a basis for the 3. Fuels and Materials Facilities 8. Occupational Health findings requisite to the issuance or continuance of a permit or 4. Environmental and Siting 9. Antitrust and Financial Review license by the Commission. 5. Materials and Plant Protection 10. General Copies of issued guides may be purchased at the current Government Comments and suggestions for improvements in these guides are encouraged at all times, and guides will be revised, as appropriate, Printing Office price. A subscription service for future guides in spe to accommodate comments and to reflect new information or cific divisions is available through the Government Printing Office.

experience. This guide was revised as a result of substantive com Information on the subscription service and current GPO prices may ments received from the public and additional staff review. be obtained by writing the U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, Attention: Publications Sales Manager.

5.5 Standard Methods for Chemical, Mass Spec the licensees' facilities and while in transit and (2) the timely, trometric, and Spectrochemical Analysis of accurate, and independent identification and measurement Nuclear-Grade Uranium Dioxide Powders of the SSNM by both shipper and receiver to determine and and Pellets. evaluate any shipper-receiver differences. These measure ments are necessary to (1) detect loss or theft of SSNM

I

5.6 Standard Methods for Chemical, Mass Spec being transferred between licensees, (2) detect and permit trometric, and Spectrochemical Analysis of correction of clerical or handling errors, (3) detect falsifica Nuclear-Grade Plutonium Dioxide Powders tion or errors in the shipment source data, (4) provide and Pellets and Nuclear-Grade Mixed Oxides assurance that measurement bias is detected and corrected,

([U,Pul )02* and (5) detect and prevent the transfer of "inventory difference" (ID) from one licensee to another.

5.11 Nondestructive Assay of Special Nuclear Material Contained in Scrap and Waste. The application of tamper-indicating seals to each item or container by the shipper immediately after sampling or

5.21 Nondestructive Uranium-235 Enrichment assay, checks on those seals before shipment, and the Assay by Gamma-Ray Spectrometry. prompt verification of the seals by the receiver can help ensure the integrity of the material measure

d. Additional

5.34 Nondestructive Assay of Plutonium in Scrap receiving checks made immediately after receipt can deter by Spontaneous Fission Detection. mine if loss, theft, or substitution of SSNM may have occurred during transfer and can detect packaging and

5.53 Qualification, Calibration, and Error Esti clerical mistakes. These checks can include counting and mation Methods for Nondestructive Assay. identifying the containers; identifying and weighing the containers or items received; comparing the results with the Licensees who transfer and receive SNM are required same information on a bill of lading, DOE/NRC Form-741, under § 70.54 to complete DOE/NRC Form-741, "Nuclear "Nuclear Material Transaction Report," or other appropriate Material Transaction Report," and submit a copy to the document supplied by the shipper; and, to the extent U.S. Department of Energy (DOE), Oak Ridge, Tennessee. possible, performing an overcheck of each container by In addition, paragraph 70.42(c) requires that, before trans nondestructive analysis to provide a gross verification of the ferring SNM, the person making the shipment verify that SSNM content.

the recipient is authorized to receive the type, form, and quantity of SNM to be transferred. Paragraph 70.42(d) out After these initial checks have been made, prompt quan titative verification of the contents of each container will pro lines the methods to be used to make this verification.

vide early assurance that the contents of the packages received Paragraph 70.58(g)(2) requires that procedures be estab are identical to those shipped. Written procedures that call for performing these verifications within specific time limits lished to review and evaluate shipper-receiver differences on an individual container or lot basis, a shipment basis, and a after shipment can help ensure that DOE/NRC Form-741 is filed in a timely fashion. In addition, the validity of boththe cumulative basis for shipments of like material. Guidelines are contained in Regulatory Guide 5.28, "Evaluation of shipper and receiver measurements is dependent on the existence of a program of standardization and calibration Shipper-Receiver Differences in the Transfer of Special Nuclear Materials." Any loss of SNM (other than normal and control of measurement equipment and procedures.

operating loss) must, under § 70.52, be reported immedi Prior coordination between the carrier and receiver can ately to the Director of the appropriate NRC Inspection and Enforcement Regional Office (listed in Appendix A to ensure that SSNM will be delivered to the receiver's facility Part 73) by telephone, telegram, mailgram, or facsimile. at a time when trained personnel are available to properly handle the material received. This procedure will eliminate This guide and the guides referenced above describe pro the possibility of material arriving at times when proper cedures acceptable to the NRC staff for complying with receiving checks or adequate physical security cannot be the Commission's regulations regarding the control of provided.

SSNM during preparation for shipment and receipt by a licensee. Safety-related requirements for packaging and Appropriate procedures that identify employees who are transporting SNM are specified in 10 CFR Part 71, "Packag authorized to ship SSNM and the responsibilities of the ing of Radioactive Material for Transport and Transporta various organizational components that have cognizance of tion of Radioactive Material Under Certain Conditions," the shipment will ensure that all aspects of the shipment are and in the applicable portions of the regulations appropriate coordinated adequately. The following organizational to the mode of transportation in Title 49 of the Code of components are listed with typical responsibilities as related Federal Regulations. These requirements are not included to the shipment:

in the scope of this guide.

B. DISCUSSION

1. Organizational component that fabricates or assembles material:

Adequate control of SSNM during transfer between licensees includes (1) physical protection of the material at a. Determine the correct weights of the SSNM,

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b. Tamper-seal and document the contents of the be completed within 10 days, a licensee may prepare and containers, distribute NRC Form-284, "Nuclear Material Transfer c. Obtain appropriate analysis of the SSNM, Report," or use DOE/NRC Form-741 as a temporary d. Ensure product specifications, receipt record after performing an initial receiving check to e. Package material properly or provide guidance on verify that the items, containers, and gross quantities packaging as required. shipped have been received. In such cases, the receiver is then required to complete the measurements and report

2. Shipping and receiving control: them on DOE/NRC Form-741 within 30 days of receipt of the shipment. If the material received is scrap or irradiated a. Prepare shipping forms, material that may take longer than 30 days to measure, b. Ensure proper packaging, DOE/NRC Form-741 is completed and distributed to c. Check integrity and seal numbers of tamper-safed indicate temporary acceptance of the shipper's values; at a containers and identification numbers on such later date, the receiver prepares and distributes a "corrected items as sealed fuel pins, copy" of DOE/NRC Form-741 that reports the receiver's d. Verify seal integrity and number of receipts, own measurements. 1 There are no requirements for ship e. Check weight of items and containers. ments of nuclear wastes to burial grounds to be measured independently by the receiver. DOE and its prime contractors

3. Security: complete DOE/NRC Form-741 in accordance with DOE

manual chapters.

a. Accompany package to shipping area when appro priate,

C. REGULATORY POSITION

b. Be cognizant of the storage areas while shipment is in them, Procedures should be provided to ensure that records c. Guard shipment while it is being loaded, reflect accurately the quantity and form of material shipped d. Coordinate security plans and arrangements with and received, to protect against the deliberate falsification the dispatcher of the material, of information on shipments or receipts to conceal diversion e. Obtain signed receipts and pass them on to the of SSNM, and to protect against the use of waste shipments appropriate departments. or shipments of quantities not subject to § 73.25 as a means for unauthorized removal of SSNM from a licensee's

4. Traffic (dispatcher): facility. The following procedures are acceptable to the NRC staff.

a. Make carrier arrangements, b. Coordinate shipments and ensure that delivery is 1. PRESHIPMENT CONTROLS ON WASTE

at a time when the proper personnel are available to properly handle the material received, a. Nondestructive assay (NDA) measurements for account c. Prepare bill of lading and other formal shipping ability purposes should be made using one of the following papers, procedures or an alternative procedure that provides equiv d. Notify receivers when shipments will be made and alent protection against falsification of accountability mea approximate time of scheduled arrival. surements:

5. Nuclear materials control: (1) Measurements should be performed by two indi viduals working and recording as a team and who do not a. Ensure that the receiver is authorized to receive have access to material processing and storage areas, the shipment of SSNM,

b. Approve all SSNM shipping memos, (2) Measurements should be performed by three indi c. Prepare and transmit DOE/NRC Form-741, viduals working and recording as a team, or d. Transmit information for computer records, if used, (3) Arrangements should be made for independent e. Arrange transfer of material to shipping area, verification of the accountability measurements by a party f. Post shipping transactions to control records, other than the licensee.

g. Investigate and reconcile shipper-receiver differences.

b. Tamper-safing controls at the time of accountability To document the transfer of SSNM containing 1 gram or measurements should include one of the following:

more of contained uranium-235, uranium-233, or plutonium, DOE/NRC Form-741 is initiated on the day the material is shipped and distributed promptly by the shipper. Normally, 1 Section 70.54 and the written instructions entitled

"Instructions the licensee receiving SSNM is required to independently to NRC and Agreement State Licensees for Reporting Nuclear Mate measure its element and isotopic content and complete and rial Transfers on DOE/NRC Form-741 - Nuclear Material Transaction Report," U.S. Nuclear Regulatory Commission. Copies of the latter distribute DOE/NRC Form-741 within 10 days of receipt may be obtained from the Division of Safeguards, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commis of the material. However, if receipt measurements cannot sion, Washington, D.C. 20555.

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(1) If the containers being measured are already C.1.c. above should be provided to protect against conceal tamper-safed, individuals performing the measurement ment and unauthorized removal of SSNM.

should confirm the seal identification and integrity, or

(2) Containers should be sealed at the time of NDA

measurement and each member of the team should attest in b. If an independent accountability measurement is not required to be made by the receiver and reported within

30 days, NDA overchecks on accountability measurements I

writing to the nature of the contents of the container and should be provided by the shipper or controls such as those the seal identification. discussed in Regulatory Position C.1.a. should be provided.

c. Prior to removal of a waste container from a material 3. ADDITIONAL SHIPPING CONTROLS

access area (MAA), an overcheck should be performed to ensure that the container is not being used as a means for a. Before shipping SSNM, the licensee should ensure concealment and unauthorized removal of SSNM from that the intended receiver is authorized to receive the type, an MAA. Controls should also be placed on packaging of form, and quantity of SSNM to be transferred in accordance smaller containers that are sealed and subsequently combined with § 70.42. This does not include forecasting the receiver's in larger containers prior to final sealing and removal from inventory at the time the shipment arrives.

an MAA. Teams performing functions for a. and b. above may simultaneously perform the functions described below. b. The shipper should establish and maintain written Acceptable procedures are: procedures that identify employees who are authorized to initiate shipment of SSNM and identify the responsibilities

(1) For each stage in sequential packaging, containers of the various departments that should have cognizance should be filled and sealed by two individuals working and of the shipment in accordance with paragraphs 70.58(b)(3)

recording as a team and who do not have access to material and 73.45(e)(2)(i).

processing and storage areas. Each individual should attest in writing to the nature of the contents of the container c. Written procedures should be established and main and the seal identification. At any stage in sequential tained to assign to specific organizational components the packaging, the team filling the large container should responsibility for packaging the shipment and ensuring that include at least one individual who was not involved in it is packaged and transported in accordance with the filling the smaller containers, provisions of 10 CFR Parts 70, 71, and 73 and other applicable regulations.

(2) Same as (1), except that, if any individual involved in filling and sealing the containers has access to material, d. Organizational components responsible for the shipment three-man teams should be used, within the plant and in transit should have a set of written procedures that cover both normal and emergency conditions

(3) Intermediate packaging may be performed by two in accordance with paragraphs 70.58(b)(3), 73.25(d), and man teams if the final package receives an NDA overcheck 73.45(g).

1 using a segmented scanner with a transmission source or neutron counter, as appropriate, capable of detecting con e. The shipper should notify the consignee of the cealed SSNM and gamma ray or neutron absorbers of suffi pertinent details of the shipment as described in § 73.27.

cient density to preclude accurate NDA measurement, or f. The shipper should initiate and distribute a Nuclear

(4) Intermediate packaging may be performed by two Material Transaction Report (DOE/NRC Form-741) in man teams if the final sealed package is retained in the MAA accordance with § 70.54 and the printed instructions for until the next material balance is closed. The package may completing the form.

be released if the inventory difference is less than the limit of error which in turn is less than 1/10 of a formula quantity g. In accordance with paragraph 73.45(e)(2)(ii), the as defined in paragraph 73.2(bb). If the inventory difference shipping group should, as a minimum, check the items and for the period is greater than its limit of error, the containers tamper-safing tag information and the tag quantities against should be unsealed and the contents verified in accordance the information on the transfer forms. Each tamper-indicating with Regulatory Position C. 1.c.(1) or (2) or left sealed and device should be checked. It is also desirable that the the contents verified in accordance with Regulatory Posi shipping group make a gross weighing of each item.

tion C. 1.c.(3) as a part of the investigation of the excessive inventory difference. If the limit of error is greater than h. Shipper-receiver differences, the quantity difference

1/10 of a formula quantity, verification should be performed between the amount of SSNM stated by the shipper as in accordance with Regulatory Position C. 1.c.(1), (2), or (3) having been shipped and the amount received as measured before the package is released. by the receiver, should be reviewed and evaluated in accord ance with paragraph 70.58(g).

2. OVERCHECKS ON PRODUCT, SAMPLES, AND SCRAP

4. RECEIPTS

a. For shipments that are not subject to the in-transit physical protection requirements of § § 73.20 and 73.25, a. A licensee should accept receipt of only those types overchecks such as those discussed in Regulatory Position and quantities of SSNM authorized by his licens

e. If other

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material is delivered to the facility, the licensee should notify the shipper immediately so that appropriate arrange possible. Both IE and the shipper should be given the option ments can be made for the disposition of the material of witnessing a quantitative assessment of the container's and contents. The contents of the container should be quantita the continuous maintenance of adequate physical protec tively assessed as soon as possible. If the shipper and IE elect tion.

not to witness the measurement, the assessment should be witnessed and attested to by personnel from at least two b. Arrangements should be made to deliver the material to the receiver at a time when personnel are available different groups within the receiver's organization.

to properly handle the material in accordance with paragraph

73.25(b)(1)(i). It is the responsibility of shipper, receiver, (4) If the contents of the containers appear to be in and carrier to ensure that trained personnel are available order, the shipper should be notified and given the option to of witnessing a quantitative assessment (weighing and properly handle deliveries of SNM. If it appears to the sampling) of the containers contents within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> shipper or carrier that the shipment may arrive at a time other than that for which arrangements were made, following receipt of the shipment. If the shipper does the not shipper or carrier should immediately inform the receiver respond to this offer, the contents of the container should so be assessed as soon as possible, but in no case later than that the receiver can have trained personnel available when the shipment arrives. If the shipment fails to arrive at 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after receipt.

the scheduled time, the receiving licensee should notify the (5) The shipper or IE should be given the results of shipper in accordance with paragraph 73.71(b) so that a the quantitative assessment immediately if either did not prompt investigation can be initiated.

witness the assessment.

c. The identification and integrity of the shipper's tamper-safing devices on each item or container should e. Within the time specified in the instructions for the be preparation of DOE/NRC Form-741, the receiver should verified in accordance with paragraph 7 3 .25(c)(4).

The make an accurate, precise, and independent measurement piece count and identification and gross weight of the items or containers received should be checked against the bill of the SSNM content of the material received. This measure of ment should be in accordance with a program for acceptable lading, DOE/NRC Form-74 1, or other appropriate shipping document to provide assurance that the shipment measurement quality as required by paragraph 70.58(f).

was received intact. To the extent possible, an overcheck determination by NDA or other appropriate means should f. The difference between the amount of SSNM stated by be made to provide a prompt estimate of the SSNM content the shipper as having been shipped and the amount received of each item or container. After the initial receiving checks as measured by the receiver should be reviewed and evaluated have been performed, the material should be sent to an in accordance with paragraph 7 0.58(g). All measurement dis area crepancies should be reported to the nuclear material con where the contents of the containers or items can be trol manager or alternate, who should personally verify the verified quantitatively in accordance with paragraph 70.5

8(e). discrepancy in the presence of the employee who discovered Written procedures should be established and maintained for verifying the receipts within specific time limits so them. Written procedures should quantitatively define what that constitutes a discrepancy for each type of SSNM received.

DOE/NRC Form-741 can be filed within the time required Appropriate action should be taken to reconcile those shipper by § 70.54.

receiver differences that are statistically significant at the d. If any of the tamper-safing devices have been disturbed 95% confidence level, except for shipments that involve in a way that may indicate an attempt to render the device differences of 50 grams or less of U-235 or plutonium. When inoperable or if the device has been damaged accidentally, a discrepancy is identified, the nuclear material manager the following actions should be taken: should resolve the discrepancy with the shipper. If the discrepancy cannot be resolved, the appropriate NRC

(1) The affected containers should be resealed Inspection and Enforcement Regional Office should be immediately by the receiver with another tamper-safing notified by telephone, telegram, mailgram, or facsimile.

device, and the resealing should be witnessed and attested Additional guidance on shipper-receiver differences is to by the personnel delivering the containers. contained in Regulatory Guide 5.28.

(2) After resealing, containers with damaged seals g. Within 10 days of receipt of material, the receiver should be isolated until the licensee can inspect the containers should complete and distribute the DOE/NRC Form-741 to determine if a loss of SSNM has occurred. This should prepared by the shipper in accordance with § 70.54. When be receipt measurements cannot be completed within this accomplished in accordance with the procedures described

10-day period, the receiver should complete a temporary in (3) and (4).

receipt in one of the following two ways: (1) as indicated

(3) If a gross weight or NDA overcheck, as appropriate, in the instructions for reporting nuclear material transfers indicates that the contents of any container appear to have on DOE/NRC Form-741, complete blocks "Date Received been removed, the Director of the NRC Inspection and or Correction Entered" and "Signature of Authorized Enforcement (IE) Regional Office listed in Appendix A Official and Date Signed" of the form, note on the form to whether the containers, boxes, or cases reported as shipped

10 CFR Part 73 should be notified immediately in accordance with § 73.71. The shipper should also be notified as soon were received, and mark on the form "Nuclear Material as Transfer Receipt" or (2) if authorized in the license,

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prepare NRC Form-284, "Nuclear Material Transfer Re completed and reported within 30 days of receipt of material and if a temporary receipt has been filed on NRC

port," as a temporary receipt. In either case, a copy of the Form-284 or DOE/NRC Form-741, the licensee should original DOE/NRC Form-741 issued by the shipper should complete DOE/NRC Form-741 accepting the shipper's then be completed and distributed within 30 days of weights and file a corrected copy to report his or her own I

receipt to show the receiver's measurements. However, if measurements at a later date.

measurements of scrap and irradiated material cannot be

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VALUE/IMPACT STATEMENT

A separate value/impact analysis has not been prepared amendments was made available in the Commission's Public for the revision to this regulatory guide. The changes were Document Room, 1717 H Street NW., Washington, D.C.,

made to make the guide consistent with the upgraded at the time the proposed amendments were published. This physical protection amendments to the regulations pub analysis is appropriate for the final amendments as well as lished in the Federal Register November 28, 1979 (44 FR for the regulatory guide revisions appropriate to those

68184). A value/impact analysis prepared for the proposed amendments.

5.57-7

UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D. C. 20555 POSTAGE AND FEES PAID

U.S. NUCLEAR REGULATORY

OFFICIAL BUSINESS

COMMISSION

PENALTY FOR PRIVATE USE, $300