Regulatory Guide 5.51

Management Review of Nuclear Material Control & Accounting Systems

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Issue date:	06/30/1975
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RG-5.51
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U.S. NUCLEAR REGULATORY COMMISSION June 1975 REGULATORY GUIDE

OFFICE OF STANDARDS DEVELOPMENT

REGULATORY GUIDE 5.51 MANAGEMENT REVIEW OF NUCLEAR MATERIAL

CONTROL AND ACCOUNTING SYSTEMS

A. INTRODUCTION

effective and appropriate and that such procedures are being carried out in practice. The NRC conducts Section 70.58, "Fundamental Nuclear Material Con compliance inspections to ensure that licensees' nuclear trols," of 10 CFR Part 70, "Special Nuclear Materials," material control and accounting systems are in compli requires, in paragraph 70.58(c), that certain licensees ance with the requirements of the regulations and authorized to possess more than one effective kilogram conditions of licenses. Licensee management, however, is of special nuclear material establish a management responsible for implementing the NRC requirements by system to provide for the development, revision, imple means of an effective system of nuclear material control mentation, and enforcement of nuclear material control and accounting.

and accounting procedures.

Assurance of the adequate discharge of this respon Such a system must provide for a review of the sibility is obtained by review, evaluation, and modifica nuclear material control system at least every 12 tion of the system by licensee management or represen months. The individuals performing this review must be tatives thereof. It is assumed for such a review that a independent both of nuclear material control manage system has been established, documented, and imple ment and of personnel who have direct responsibility for mented. The purposes of the review are to ensure that the receipt, custody, utilization, measurement, measure the system is being operated as designed and to ment quality, and shipment of nuclear material. This determine whether the established system is appropriate review must include a review and audit of material and effective for the current operations.

control and accounting procedures and practices and an audit of nuclear material records. The results of the Changes in management relationships, production review and audit, along with recommendations for technology or capacity, operating practices, or plant improvements, are required to be documented, reported mission could result in the need to change the material to the licensee's corporate and plant management, and control and accounting system. The management review kept available at the plant for inspection for a period of will provide evaluation of the system to determine five years. whether such changes should be made.

This guide describes the purpose and scope, person 2. Personnel nel qualifications, depth of detail, and procedures that are acceptable to the NRC staff for the management The people most knowledgeable of the material review of nuclear material control systems required control and accounting system of a plant are those under paragraph 70.58(c) of 10 CFR Part 70. directly responsible for its operation. These people, however, would have difficulty in conducting an objec

B. DISCUSSION

tive evaluation of their own system. Personnel other than those directly responsible for the system, but still

1. Purpose and Scope knowledgeable of its basic concepts, can provide an independent viewpoint. Such personnel also can view the The basis of any effective system of control is a system from a management standpoint, as well as from a program of review to ensure that the procedures are purely technical standpoint.

USNRC REGULATORY GUIDES Comments should be sent to the Secretary of the Commission. U.S. Nuclear Regulatory Guides are issued to describe and make available to the public Regulatory Commission Washington D.C. Attention Docling and methods acceptable to the- NRC staff of implementing specific parts of the Commissions regulations. to delineate techniques used by the staff in evalu The guides are issued in the following ton broad divisions sting specific problems or postulated accidents. or to provide guidance to appli cant. Regulatory Guides are not substitutes for regulations, end compliance 1. Power Reactors 6. Products with them is not required. Methods and solutions different from those set out in 2. Research and Test Reactors 7. Transportation the guides will be acceptable if they provide a basis for the findings requisite to 3. Fuels and Materials Facilities B. Occupational Health the issuance or continuance of a permit or license by the Commission. 4. Environmentel and Siting 9. Antitrust Review Comments and suggestions for improvements in these guides are encouraged 5. Materials and Plant Protection 10. General at ell limes, and guides will be revised, as appropriate. to accommodate com ments and to reflect new information or experience However. comments on Copies of published guides may be obtained by written request indicating the this guide. if received within about two months after its issuance, will be par divisions desired to the U.S. Nuclear Regulatory Commission. Washington. D.C.

ticularly useful in evaluating the need for an early revision 2066. Attention: Director. Office of Standards Development.

ENCLOSURE 1

3. Coverage 2. Personnel Personnel assigned to the review team should be Material control and accounting systems can be knowledgeable in the basic principles of material control divided into several areas of investigation for purposes of and accounting. They also should be selected so that a management review. These are: their responsibilities on the review team do not cause a conflict of interest with their regular duties. They should a. Internal Control, including storage and internal provide an independent viewpoint and one that is handling, tampersafmg, item identification and control, management oriented as well as technically oriented.

shipping and receiving control, scrap and waste control, and establishment of material balance and item control Individual members of the team should be knowl areas; edgeable in the specific disciplines appropriate to their assigned areas of investigation. Review team personnel b. Measurements System, including the measure should be sufficiently knowledgeable to permit them to ment and sampling procedures and the measurement evaluate the appropriateness of procedures as applied in quality assurance program; a given system. In this respect review team personnel should keep in mind the question: "Is there a better way c. Statistical Control, including the statistical of doing this and still complying with the system aspects of the measurement quality assurance program, requirements?"

shipper-receiver difference control and evaluation, and statistical methodology associated with measurement Task assignments for review team personnel should and material balance limits of error; be made in writing to ensure complete coverage and minimize duplication of effort. One person should be d. Physical Inventory; assigned the task of overall review coordination. For small facilities the entire review may possibly be done by e. Records and Reports; and one person if that person is knowledgeable in all aspects of the system.

f. Organization and Management.

3. Planning Other divisions or groupings could be used, depend Review of the nuclear material control and account ing on the design and complexity of the system being reviewed and the disciplines represented on the review ing systems should include advanced planning to estab team. For example, the measurement and sampling lish the extent and depth of coverage in each part of the procedures might be considered as a category separate system and to ensure that all parts are covered.

from the measurement quality assurance program. The way in which the system is divided or assigned for review a. Review Program is not particularly significant. It is important, however, A program for the review should be prepared to that the division and assignment of review tasks is such ensure complete coverage and development of adequate that all aspects are covered. information on which to base review decisions. The review program should include a checklist for the review to cover all parts of the material control and accounting

C. REGULATORY POSITION

system. A preprinted program can save considerable time in planning but should not be used as an inflexible The management review of nuclear material control checklist or as a substitute for judgment and initiative in and accounting systems should include the following investigation.

considerations and coverage.

The basic review program should be supple

1. Purpose and Scope mented with checklists and questionnaires for more detailed coverage of the various parts of the review.

The purpose of the management review of the Appendix A to this guide is an example of a review nuclear material control and accounting system should program checklist.

be to ensure that practices follow approved procedures and that practices and procedures are appropriate for b. Procedure Manual current operations and are in compliance with NRC

approved material control and accounting plans. The Review of the current procedure manuals and scope of the review should include evaluation of the completion of a procedure manual checklist should be a effectiveness of the system in maintaining control of and part of the review planning. Reviewers should use such accounting for the nuclear materials. Measures of effec reviews to familiarize themselves with current proce tiveness should be considered in each part of the review. dures and to identify changes that may need coverage in

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more depth. Appendix B to this guide is an example of a (2) Functional statements of responsibilities procedure manual checklist. and authorities;

c. Prior Review Workpapers (3) The system for development, revision, Prior review workpapers should be used to implementation, and enforcement of procedures; and acquaint the reviewers with past performance and audit procedures and to identify control practices that were (4) The effectiveness of the system in terms of previously found to be weak or inadequate. Such losses and material unaccounted for relative to expected practices should be noted for more thorough investiga values for these items.

tion, whereas areas that were found to be satisfactory Appendix C to this guide is an example of an and that had been reviewed thoroughly on the prior organization and management review checklist. Person review could be given less emphasis in the current nel conducting this part of the review should be review. knowledgeable of the basic concepts of management and administration. All review team personnel should be d. Correspondence, Reports, and Discussions made aware of the information developed in this part so that they may take into consideration any areas that Correspondence and reports pertaining to may be pertinent to their specific part of the review.

material control and accounting, as well as preliminary discussions with plant management, plant operations Information regarding organization and man personnel, and material control and accounting person agement should be contained in the facility organization nel, should be used to identify problem areas and areas manuals and charts, job descriptions, and instruction that require a thorough investigation during the review. manuals.

Discussion with the plant material control staff also should provide information for scheduling the nuclear b. Internal Control material records audit and the observation of a routine physical inventory. This part of the review should include review and evaluation of:

4. Coverage

(1) Internal storage and handling;

All parts of the nuclear material control and accounting system should be covered in each review. (2) Item identification and control;

However, not all parts need be given the same depth of coverage each time. Decisions as to depth of coverage (3) Tampersafing;

should be based on considerations such as evidence of A

problems in certain parts, changes in procedures, or (4) Shipping and receiving controls;

coverage in prior reviews. Information on which to base such decisions should be obtained before the review (5) Scrap and waste controls; and from sources such as prior review workpapers and reports, plant reports that give indications of problem (6) Material balance area and item control area areas, review of procedure manuals, and discussions with selection and establishment.

appropriate plant personnel.

Appendix D is an example of an internal To ensure complete coverage, review checklists and control checklist. Personnel conducting this part of the questionnaires should be used. Such checklists and review should be knowledgeable of the basic concepts of questionnaires are referenced in the following sections. material control.

These checklists and questionnaires should be considered only as guides and should not be used as a substitute for Information regarding internal control should judgment and investigative initiative. The subdivision of be contained in the facility procedure manuals, instruc the review into the parts covered in the following six tion manuals, and other facility management directives.

sections should be considered flexible. Other arrange ments may be used where appropriate to the facility and c. Measurements System the talents of the review team.

This part of the review should include review a. Organization and Management and evaluation of:

This part of the review should include review (1) Sampling and measurement points;

and evaluation of:

(2) Sampling methods including sample con

(1) Organizational relationships; trol procedures;

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(3) Weight and volume methods; analytical manuals, laboratory data records, and mea surement quality assurance manuals and data logs.

(4) Analytical methods including nondestruc tive methods; e. Physical Inventory This part of the review should include review

(5) Measurement data control procedures; and and evaluation of the facility's physical inventory procedures, instructions, and practice

s. The review

(6) Measurement quality assurance programs.

should include observation of a routine physical inven tory. The review need not include independent verifica Appendix E to this guide is an example of a tion of the physical inventory by the review team.

measurement system checklist. Personnel conducting this part of the review should be knowledgeable of the Appendix G is an example of a physical chemical and physical properties of the materials in inventory checklist. Personnel conducting this part of volved, of the fundamentals of sampling and measure the review should be knowledgeable of the basic ment of such materials, and of the basic concepts of concepts of material control and accounting, especially measurement quality assurance. those pertaining to the conduct of physical inventories (see Regulatory Guide 5.13, "Conduct of Nuclear Information regarding measurement systems Material Physical Inventories").

should be contained in the facility procedure manuals, analytical manuals, laboratory data records, and mea Information regarding physical inventories surement quality assurance manuals and data logs. should be contained in the facility procedure manuals and physical inventory instruction directives.

d. Statistical Controls f. Records and Reports This part of the review should include review and evaluation of: This part of the review should include a review and evaluation of the facility data-handling practices and

(1) The determination of measurement bias, procedures and an audit of nuclear material records.

random error variances, and limits of systematic error; Appendix H is an example of a records and reports checklist.

(2) The determination of material balance limits of uncertainty, i.e., limit of error of material Appendix I is an example of a nuclear materials unaccounted for (LEMUF); records audit program. Personnel conducting this part of the review should be knowledgeable in the basic con

(3) MUF - LEMUF evaluation; cepts of data handling and audit techniques and proce dures.

(4) Shipper-receiver difference evaluation and control; and Information regarding records and reports should be contained in the facility procedure manuals

(5) Statistical methodology employed in mea and in the facility records and reports pertaining to surement quality assurance. nuclear materials.

Appendix F to this guide is an example of a

D. IMPLEMENTATION

statistical control checklist. Personnel conducting this part of the review should be knowledgeable of the basic This section provides information to applicants and concepts of mathematical statistics and their application licensees regarding the staff's plans for using this to nuclear material control. (See Regulatory Guides regulatory guide.

5.18, "Limit of Error Concepts and Principles of Calculation in Nuclear Materials Control," 5.28, "Evalu Except in those cases in which the applicant or ation of Shipper-Receiver Differences in the Transfer of licensee proposes an alternative method, after publica Special Nuclear Materials;" and 5.33, "Statistical Evalua tion of this guide the Commission's staff will use the tion of Material Unaccounted For.") methods described herein for evaluating an applicant's or licensee's capability for and performance in complying Information regarding statistical controls with the specified portions of the Commission's regula should be contained in the facility procedure manuals, tions.

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APPENDIX A

Review Program Checklist

1. Planning the Review documents related to measurements reliability and material balance uncertainties to select areas for special a. General emphasis during the review.

Arrange with plant management and nuclear h. Records and Reports material control and accounting management for the review dates, inventory dates, and discussions with Identify the records that will be subject to the appropriate plant personnel. Request information from audit and special report items that merit special investi plant personnel on specific areas that they believe should gation. Complete the planning portion of the audit be given special attention during the review. program.

b. Personnel 2. Conducting the Review Prepare a schedule of review personnel with a. General specific assignments for each review team member. Each review team member should be given a copy of the (1) Discuss with plant management the general schedule. aspects of the scope of review.

c. Document Review (2) Discuss details of the review with material control and accounting management and arrange meet Each member of the review team should survey ings with other plant personnel as necessary.

prior review workpapers, suspense files, plant reports, and other documents pertinent to his assigned part of b. Organization and Management the review and should prepare a schedule of items for special investigation. Complete the organization and management checklist on the basis of document reviews, discussions d. Procedure Review with plant personnel, and observations during the review.

Each member of the review team should survey plant organization and procedure manuals pertinent to c. Internal Control his part of the review and prepare a schedule of items for special attention. Each member should complete a (I) Review notes and findings from reviews of procedure manual checklist or that portion of the the various aspects of internal control to determine checklist pertinent to his assigned tasks. adequacy with respect to:

e. Physical Inventory (a) Procedures reflecting actual practice and Review the plant procedures and instructions pertaining to the conduct of plant inventories. Make (b) Appropriateness and effectiveness of personnel inventory assignments and prepare specific the procedures.

inventory instructions for the review team.

(2) Complete the internal control checklist f. Measurement System Review using notes and observations collected during the review.

Review plant procedure manuals, prior work d. Measurement Systems Review papers, special reports, and other information to prepare or update measurement system flowcharts or data sheets (I) Review the measurement system with as shown in the measurement system checklist. Select appropriate plant personnel to determine adequacy with areas of the measurement system to be given special respect to:

emphasis during the review.

(a) Procedures reflecting actual practice g. Statistical Controls Review and Review measurements system reliability data, (b) Completeness, appropriateness, and measurements quality assurance procedures, and other effectiveness of the procedures.

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(2) Observe those areas selected in planning for g. Records and Reports emphasis during the review. Complete checklists as appropriate for the various aspects of the measurement Complete the review of the records and reports system. and the audit of the nuclear material records according e. Statistical Controls Review to the audit program.

(1) Review and evaluate the statistical basis for 3. Reporting Review Results measurement reliability for individual measurements, factors, and material balances in the areas selected for a. The team leader should discuss the review emphasis during the review. results with the review team to:

(2) Review and evaluate the statistical method (1) Determine the effectiveness and appropri ology and controls used in determining and controlling ateness of the plant material control and accounting limits of error for measurements, factors, and material system in its entirety and in its several parts.

balances.

(2) Determine the accuracy with which proce

(3) Complete the statistical control checklist dures reflect actual practice.

and evaluate the controls with respect to:

(3) Determine areas in which recommenda (a) Procedures reflecting actual practice tions for improvements are to be made.

and (b) Appropriateness and effectiveness of (4) Develop points for discussion with plant and material control and accounting managements.

the procedures.

b. Discuss the findings of the review with plant f. Physical Inventory and material control and accounting managements.

(i) Review detailed inventory plans with c. Prepare and issue the written report.

appropriate plant personnel.

(2) Observe inventory-taking as planned. Note 4. Review Workpapers changes and deviations from the plan. Document obser vations and complete the physical inventory checklist.

a. Complete and tie-in all workpapers.

(3) Evaluate inventory practices and proce dures with respect to: b. Index and cross-reference all workpapers to:

(a) Procedures and plans reflecting actual (1) Other workpapers practice and

(2) Review report (b) Appropriateness and effectiveness of the procedures. (3) Appropriate plant files.

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APPENDIX B

Procedure Manual Checklist When using a checklist to review a facility procedure (2) Description of the receiving and shipping manual, referenced supplementary documents and appen- procedures at each point dixes should be considered a part of the manual. With this taken into consideration, determine whether the b. Procedures for review, evaluation, and resolu facility procedure manuals contain the following infor- tion of shipper-receiver differences mation and whether that information is in agreement with current practices: c. Description of and procedures for determining, reporting, and recording other additions to or removals

1. Facility Organization from inventory a. Organization charts of: d. Procedures for evaluation and control of remov als from inventory, such as MUF and measured discards

(1) The facility organization e. Statements of receiving and shipping responsi

(2) The nuclear materials control and account- bilities ing unit

4. Inventory b. Charts and descriptions of all MBAs and ICAs a. Procedures by MBA or ICA

C. Basis for establishing MBAs and ICAs b. Statements of inventory timing and frequency d. Statements of responsibility and authority for:

C. Cutoff and plant shutdown procedures

(1) The central material control and account- ing unit d. Inventory measurement procedures

(2) MBA or ICA custodians e. Description of general inventory techniques

(3) Others concerned with material control f. Supplemental inventory instructions and accounting g. Statement of inventory responsibilities

2. Facility Operations a. Functional statement of the facility operations

5. Storage and Internal Transfers and processes a. Description of procedures and mechanisms for b. Material flow description segregating nuclear materials by material type and enrichment

(1) By charts b. Specific nuclear material identification and

(2) By narrative labeling procedures

(3) Including material composition and type at c. Description of tampersafmg procedures and significant points devices

(4) Including usual or normal material quanti d. Description of storage facilities ties

3. Receiving, Shipping, and Other Receipts and e. Description of burial grounds, including loca tion records Removals f. Description of procedures, documents, and a. Description of shipping and receiving points document flows for internal transfers of nuclear material

(1) Notation of these points on material flow g. Methods of determining nuclear material quan chart tities transferred or stored

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h. Statement of storage and internal transfer e. Description of the flow and use of measure responsibilities ment data

6. Scrap Control f. Procedures and techniques for statistical evalua a. Description of procedures for segregating, pack tion of:

aging, and identifying scrap

(1) Shipper-receiver differences b. Methods for determining the nuclear material content of scrap (2) Material unaccounted for c. Description of procedures for recovering (3) Individual measurement and shipment nuclear material from scrap, including offsite recovery if limits of error appropriate

(4) Calibration uncertainty

7. Measurements and Statistical Controls

(5) Other a. Description of nuclear material sampling and measurement points g. Statements of responsibility for measurements and statistical controls

(1) By process or material flowchart

(2) By narrative description

8. Records and Reports

(3) For all material streams b. Description of methods and techniques used at a. Chart of accounts each sampling and measurement point, including:

(1) General ledger accounts

(1) Weight or volume measurements

(2) Control accounts

(2) Sampling procedures

(3) Subsidiary accounts

(3) Special equipment for sampling or mea surements (4) Plant and MBA or ICA accounts

(4) Analytical procedures

b. Document flowchart

(5) Measurements for calculation of quantities (1) Physical flow of documents related to nuclear loss or production or factors

(2) Posting points c. Description of supporting programs:

(3) Retention points

(1) Scale and balance program

(4) Data elements

(2) Calibration programs c. Description of the system

(3) Quality control programs

(1) Posting procedures

(4) Analytical control programs

(2) Sample forms, including instructions d. Description of the techniques and programs used to determine and control the measurements system (3) Description and basis of reports biases, random error variances, and limits of systematic error (4) Method of compiling reports from records

)

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APPENDIX C

Organization and Management Checklist

1. Organization transfers, measurements, statistics, and the records and reports system?

a. Does the facility maintain current written procedures that contain organization charts or descrip d. Are statements of responsibility and authority tions of the plant management structure, identifying all provided for other positions concerned with input to the positions having responsibility for or control over special material control system, such as production quality nuclear material? Is the nuclear material control struc control, analytical laboratory, measurement system ture described, including the relationship of the material quality control, accounting, and auditing?

control functions and responsibilities to those of other organizational functions and responsibilities? e. Do the procedures contain the job titles of the key positions in the safeguards program and describe the b. Have appropriate separations of functic.s been required qualifications for these positions?

identified in the procedures to provide a system of control checks and balances?

2. Management

(1) Are the nuclear materials control and a. Are nuclear material control procedures and accounting functions organizationally independent of revisions reviewed and approved in writing by appropri the operating departments? ate management?

b. Are delegations of material control and

(2) Does the unit include (or have available)

personnel qualified in: accounting responsibilities made in writing?

c. Are nuclear material control procedures con (a) Accounting tained in standard operating procedures, process specifi cations, manufacturing instructions, etc., so that the (b) Analytical chemistry worker is informed of the accountability requirements of his job?

(c) Physics or nondestructive assay d. Is there evidence that appropriate management (d) Quality control action has been taken to ensure that practices comply with procedures?

(e) Statistics e. Is there evidence that appropriate management action has been taken to ensure that written procedures

(3) Can the material control and accounting are revised to reflect approved changes in material unit cross organizational lines to enforce policy? control and accounting practices?

(4) Are the analytical and assay measurement f. Were there any losses of discrete items or laboratories organizationally independent of the opera containers of special nuclear material? If so, was ting departments? appropriate management action taken?

c. Are statements of responsibility and authority g. Did MUF for any material balance exceed the included for those positions having responsibility for associated LEMUF for that balance? If so, was appropri receiving and shipping, inventory, storage and internal ate management action taken?

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APPENDIX D

Internal Control Checklist

1. Internal Storage and Handling (4) Is a lot or item number assigned upon receipt?

a. Are containers and items containing special (5) Is the material identified by its assigned nuclear material properly labeled and uniquely identi number on the various materials accounting and produc fied? tion forms?

(6) Are copies of receiving reports sent to the b. Are records maintained for containers and items in storage? Transferred to or from storage? materials accounting office:

c. Is there control of material removal from storage? (a) Immediately d. Is there segregation in storage of dissimilar (b) Directly materials, e.g., material types, enrichments, scrap, raw material, in-process material and product? (7) Is information from the receiving department compared with the quantities and description on the e. Are records maintained showing the identity, shipping form?

location, source, disposition, and special nuclear material content of all containers and items? (8) Is the checking completed prior to signing the shipping form that is returned to the shipper?

f. Are there records showing the quantities of special nuclear material added to, removed from, and currently (9) Are the shipping forms completed by the in process? receiver within the required time?

g. Are all transfers of special nuclear material (10) Is an item count made and the gross weight between MBAs or ICAs documented by means of of material determined on receipt?

transfer documents signed by appropriate authorized individuals? (11) Are tare and net weights determined?

h. Are transfer documents prenumbered, controlled, (12) Is material sampled and analyzed upon and accounted for? receipt?

i. Are tampersafing procedures used for effective (13) Does the receiver take an independent control of and accounting for special nuclear material? sample (or participate in the shipper's sampling)?

j. Is access to tampersafing devices and records b. Shipments controlled?

(1) Are written instructions as to lots or items to k. Do the tampersafing procedures include installa be shipped issued to the shipping departments?

tion of the devices by authorized personnel and the recording of the date and time of installation, along with (2) Is notice of shipment sent directly to the the identity of the device and the authorized installer? materials accounting office?

2. Shipping and Receiving Controls (3) Is the shipping form, NRC-741, prepared from loading sheets or other data received from the shipping a. Receipts department?

(4) After preparation, is the NRC-741 checked by

(1) Is receiving of special nuclear material central ized at the facility? other than the typist, prior to signature?

(2) Is receiving performed by employees other (5) Are the NRC-741's dispatched on time?

than those who keep material accounting records?

(6) Are there defined procedures for processing

(3) Is receipt of material acknowledged in writing receipted shipping forms returned by the receiver, by authorized employees? including:

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(b) 12 months (a) Review for authorized signatures and com pleteness of information (7) What basis is used for establishing the special (b) Evidence on the shipping form (e.g., by nuclear material content of scrap?

employee's initials) that the required work has been (8) Is there a program to evaluate and reduce done scrap generation?

(7) Is the gross weight of material determined prior to shipment? (9) Is there a program to evaluate and improve scrap measurements?

(8) Is the tare weight of each individual shipping container determined?

b. Waste

(9) Are there procedures in use to ensure that the (1) Are there procedures to ensure that wastes special nuclear material content of each container is containing special nuclear material are measured before valid? discard?

c. Shipper-Receiver Differences (2) What basis is used to determine the special nuclear material content of wastes?

(1) Are there established procedures for detecting and evaluating statistically significant shipper-receiver (3) Are there recording and reporting procedures differences? to ensure that the special nuclear material content of wastes is properly accounted for by:

(2) Do the plant records indicate any shipper receiver differences during the period covered by the (a) MBA

review?

(b) Process

(3) Were the shipper-receiver differences brought to the attention of the appropriate management person (c) Material type nel for evaluation?

(d) Type of discard

(4) Are written reports prepared regarding the resolution of shipper-receiver differences? (4) Are there fail-safe procedures or devices in use to ensure that significant quantities of special nuclear

3. Scrap and Waste Control material cannot be inadvertently discarded?

a. Scrap (5) Are there procedures for action in case of an inadvertent discard of a significant quantity of special nuclear material?

(1) Is scrap classified and identified for purposes of:

(6) Are there procedures or devices to monitor (a) Measurment waste streams that normally should not contain special nuclear material?

(b) Recovery (7) Are there continuing studies with respect to

(2) Is scrap packaged to facilitate accurate process discard residues to:

measurement? (a) Establish normal levels

(3) What portion of material balance uncertainty (b) Improve measurements for each material type is due to scrap?

(c) Reduce losses

(4) What percent of inventory is in scrap?

(8) Are control charts or other series evaluation

(5) Are there plans and schedules for timely mechanisms used for routine discard streams?

recovery of scrap?

4. Material Balance Areas and Item Control Areas

(6) Is there evidence of scrap on inventory longer a. Does each MBA or ICA have identifiable physical than:

boundaries sufficient to segregate the material in it from (a) 6 months that in all other areas?

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b. Are the number of MBAs and ICAs appropriate to j. Are material balances prepared for individual isolate losses and facilitate investigation? MBAs?

c. Are there procedures for providing valid measure ment values for special nuclear material being transferred k. Are MBA material balances used in evaluation of between MBAs and ICAs? total plant MUF and LEMUF?

d. Is MBA and ICA structure compatible with 1. Are there MBAs in which internal material management structure? balances are prepared?

e. Are different individuals assigned custodianship for MBAs or ICAs that have transactions with each m. Are MBAs and ICAs structured so that no other? material is in more than one at any one time and all materials are located in a control area?

f. Are custodians informed in writing of their responsibilities and duties?

n. Should consideration be given to dividing MBAs identified in question 1into separate MBAs?

g. Is there evidence that all items in ICAs are properly tampersafed or are sealed sources?

o. Are there other MBAs or ICAs that should be:

h. Are items in ICAs properly identified?

(I) Combined i. Is there evidence that model material balances were used in establishment of MBAs? (2) Divided

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APPENDIX E

Measurement System Checklist

1. Measurements Review b. Determine the extent of analytical control programs, participation in analytical exchange programs, a. Based on planning review of plant procedure validity and care of standards, and frequency of calibra manuals and other documents, select those measurement tion of measurement equipment.

points in the system to be reviewed in more detail. For each such point prepare a Measurement Point Data Sheet c. Does the measurement control program include:

such as the one shown in Annex I to this appendix.

(1) Sampling b. For each measurement point selected, review and discuss with the personnel responsible for the measure (2) Bulk measurement ments the procedures actually used.

(3) Nondestructive measurements

(1) Note any deviations from specified procedures or from good practice, along with any reasons for such (4) Analytical methods deviations.

(5) Use of control charts

(2) Review available data supporting the precision and accuracy statements associated with each measure d. Review Measurement Point Data Sheets, Analyt ment point. ical Laboratory Checklists, and Scale and Balance Checklist for data pertinent to measurement control.

c. Observe analytical laboratory operations and procedures, including contract laboratories, if appropri e. Are the performance trends shown by the control ate, and discuss them with laboratory personnel, as program acceptable?

appropriate. An Analytical Laboratory Checklist such as the one shown in Annex 2 to this appendix should be f. Are the frequencies of calibration, standardization, used. and precision checks acceptable?

d. Check scales and balances using standard weights g. Are quality control checks made in a representa and observe their use. A Scale and Balance Checklist tive fashion over time to include different equipment, such as the one shown in Annex 3 to this appendix shifts, and operators?

should be used.

h. Are personnel training and qualification programs

2. Measurement Quality Control carried out?

a. Review and discuss with the personnel responsible i. Are there records and procedures to ensure that the program of standardization and calibration of only trained and qualified personnel carry out material measurement equipment and analytical procedures. accounting measurements?

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APPENDIX E - ANNEX 1 Measurement Point Data Sheet This data sheet should be used to record observations 4. Review sampling procedures, including:

and information regarding the actual functioning of the plant's material accounting measurement system. The a. Portion sampled reviewer should be familiar with the plant's written procedures before observing the actual functioning of b. Basis for sampling, e.g., statistical plan, economic the system. criteria, judgment, etc.

c. Type and size of sample

1. Identify the measurement point by location, MBA, d. Sampling equipment process, flowchart reference, etc.

e. Special or unique techniques

2. Identify material by type, form, composition, normal quantities, source, use, and disposition.

f. Compositing

3. Review bulk measurements: g. Measurement control data a. Scale, tank volume, or pipeline data

5. Review analytical procedures, including:

b. Capacity a. Element concentration c. Measurement increment b. Isotopic composition d. Measurement control data c. Nondestructive assay e. Calibration procedure and frequency d. Measurement control data f. Calculation parameters and formulae e. Laboratory, including:

g. Factor data, including:

(1) Process lab

(1) Basis

(2) Plant lab

(2) Measured parameters

(3) Contract lab

(3) Measurement control data

6. Are the measurement methods at this measurement

(4) Frequency of verification point appropriate?

5.51-14

APPENDIX E - ANNEX 2 Analytical Laboratory Checklist This data sheet should be used to record observations a. The written analytical procedures and information regarding the actual functioning of the plant analytical laboratory. The reviewer should be b. The approved change procedures familiar with the written procedures pertinent to the laboratory before observing the actual laboratory opera- 10. Is there a standard form for reporting analytical tion. results that includes:

a. Date of analysis

1. Is the laboratory that performs material accounting analyses independent of the production organization?

b. Analytical results

2. Are written requests for analyses submitted to the c. Identity of:

laboratory with the samples?

(1) Analytical request

3. Are special prenumbered forms used for analytical requests? (2) Sample

4. Do the analytical requests include: (3) Analytical method a. Analyses required (4) Analyst b. Date of request d. Disposition of sample c. Identity of requesting unit 11. Are analytical results retained in the laboratory:

d. Identity of material sampled a. Files e. Identity, description, and quantity of sample b. Log books f. Disposition instructions for sample c. For 5 years g. Reporting instructions for results 12. Does the laboratory control program include:

5. What record is made of incoming samples: a. Disguised samples when appropriate a. Card file b. Adequately disguised samples b. Log book c. Internal standards AI A,, d. Reference standards traceable to national stand- ards d. Other e. Analyst certification

6. Are samples permanently and adequately identified? f. Independent evaluation such as participation in the SALE program

7. Are current written analytical procedures available to all appropriate analysts? 13. Are analytical services obtained from laboratories outside the plants?

8. Are there written approved procedures to provide for changes in analytical procedures? 14. Are the controls on any such outside analytical services adequate to ensure analytical results acceptable

9. Is there evidence that the analysts follow: to the criteria of thein-plant analytical program?

5.51-15

APPENDIX E - ANNEX 3 Scale and Balance Checklist

12. Are control charts or other statistical media main This -data sheet should be used to record observations tained for scale and balance precision and accuracy?

and information regarding the actual use, maintenance, and calibration of scales and balances used for material 13. Is statistical determination of precision and accounting purposes. The reviewer should be familiar accuracy (weighing limits of error) performed?

with the written procedures pertinent to the scales and balances used for material accounting before observing 14. Are buoyancy corrections made when appropriate?

the actual use.

1. Are written calibration and use procedures available? 15. Are weights handled carefully - not slid in place,

2. Is calibration performed properly and at satisfactory etc.?

intervals?

16. Are temperature and air current effects taken into

3. Are calibrations traceable to national standards? consideration in the procedures and in practice?

4. Are regular inspections, testing, and service per 17. Is proper action taken to correct weighing errors?

formed?

18. Are only approved scales used for material account

5. Are inspection stickers on equipment? ing?

6. Is there a training or qualification program for 19. Are scales checked before each use?

operators and supervisors?

20. Are scales permanently identified?

7. Are working standards available and satisfactory?

8. Are working standards checked? How often? 21. Are tags applied to scales which are out of order?

Do these tags show the reason why they are not used

9. Are standards accurate, handled with lifters or gloved and that calibration is required after repair?

hands, and kept under cover when not used?

22. Are weights verified by more than one person (or

10. Is the equipment sufficiently accurate for the printed tape) for shipments, receipts, scrap, etc.?

intended use?

23. Is responsibility for scale and balance use, mainte

11. Is the equipment being used within the manufac nance, and calibration assigned in writing?

turer's recommended capacity?

5.51-16

APPENDIX F

Statistical Controls Checklist

1. Review any information recorded by the measure 9. Is MUF localized by material balance area? By ment system reviewer that is pertinent to the statistical process within a material balance area?

controls of that system, including:

10. Are there routine procedures for investigating a. Scale and balance calibration and measurement excessive MUF?

control data

11. What evidence is there that such procedures have b. Sampling control data been used?

c. Analytical or NDA measurement control data 12. Are valid statistical techniques employed to evaluate MUF on a series, as well as on an individual, basis?

2. Are the data used for estimating bias and for determining error variances and limits of systematic 13. Do such techniques include the use of control errors of measurement: charts?

a. Generated by statistically valid procedures 14. Are there routine procedures for evaluating shipper receiver differences?

b. Sufficient in quality and quantity

15. Do these procedures include valid statistical tech c. Collected by procedures to ensure accuracy and niques for evaluating shipper-receiver differences by:

completeness

3. Are the data-handling and calculational procedures a. Individual shipment used to determine measurement precision and accuracy statistically valid and appropriate? b. Shipment series c. Individual lot or container

4. Are calibration data used appropriately in estimating measurement bias and limits of systematic errors?

16. Do these procedures include the use of control

5. Are sampling precision and accuracy based on statis charts?

tically valid sampling plans and studies?

17. Is there evidence that these procedures have been

6. Are replication program data used appropriately for used?

determination of random errors?

18. Is there evidence that significant shipper-receiver

7. Are the data-handling and calculational procedures differences have been investigated and reconciled?

used to determine material unaccounted for (MUF) and the limit of MUF statistically valid and appropriate? 19. Are the results from statistical evaluations made available to management and operating personnel for

8. Are the data-handling and calculational procedures control purposes?

used to determine the limits of error of the physical inventory statistically valid and appropriate? 20. Are data retained for five years?

5.51-17

APPENDIX G

Physical Inventory Checklist This checklist should be completed on the basis of b. The MBA and ICA custodians observations of a physical inventory being conducted at the plant under review. The observer should have c. Other appropriate operating personnel reviewed the general inventory procedures for the plant and the specific inventory instructions for those areas to 9. Did inventory orientation include:

be observed during the inventory.

a. Review of instructions by inventory personnel

1. Was the inventory based on measured quantities?

b. Tour of areas by teams

2. Was the inventory a shutdown, cleanout type; a dynamic type; or a combination thereof? c. Preliminary inspection by inventory supervisor

3. Was measurement information based on: 10. Were there any deviations from the written instruc a. Prior measurements ensured through item identifi tions?

cation and tampersafing 11. Were such deviations approved by the inventory supervisor?

b. Uniquely identified sealed sources

12. Were MBAs and ICAs inventoried separately so that c. Prior measurements verified by remeasurement the inventory could be compared with the book inven tory for each area?

d. Measurements made during the inventory

13. Were the various areas prepared for the inventory in e. Factors or calculated values. If factors were used, that:

were the factors determined on the basis of measure ments, their continued validity monitored through a a. Material was arranged to expedite inventory measurement control program, and the limits of error of the factors determined from the measurement control b. Process conditions were arranged so that quan program data? If calculated values were used, were they tities in difficult-to-measure locations were at a based on completely known and measured components? minimum

4. Were sufficient data available to determine the limits c. Items were properly labeled and identified of error for the inventory?

14. Was the inventory taken in a systematic and

5. Were the measurements and measurement controls accurate manner?

adequate to establish the quantity of material on inventory within valid limits of uncertainty? 15. Were inventory lists prepared from listing items from the floor or were prelisted items checked off as

6. Were proper cutoff procedures used for: items were located?

a. Internal transfers 16. Were there procedures to ensure that all items and material were listed once and only once?

b. Shipments and receipts

17. Was the physical inventory in agreement with the c. Records custodian's record inventory?

d. Processing 18. If there were differences, were appropriate actions taken to explain, investigate, and reconcile them?

7. Was one person assigned overall responsibility for the inventory? 19. Were the results of the physical inventory reflected in the material accounting records?

8. Were written inventory instructions issued to:

20. Was the inventory conducted within the required a. The inventory teams frequency interval?

5.51-18

APPENDIX H

Records and Reports Checklist

1. Is the plant material accounting system designed so 8. Are standard approved forms used to record adjust that it will clearly delineate the responsibility for the ments to the records, including the reason for the materials? adjustment?

2. Are double entry records maintained? 9. Is there a system for controlling and accounting for all such forms?

3. Are subsidiary accounts maintained for each MBA

and ICA? 10. Are all special nuclear material accounting measure ment data routinely reported to the material accounting

4. Are subsidiary accounts periodically reconciled to office?

control accounts?

11. Are such measurement data reported on standard

5. Are records maintained of: approved forms that adequately identify the material to which the measurement data apply?

a. Material added to, and removed from, the process

12. Are such measurement data used appropriately in b. The quantity of material in-process at any given preparation of material accounting records and reports?

time

13. Have the required Material Status Reports (Form c. Identity and location of items and containers NRC-742) and Material Transaction Reports (Form containing special nuclear material NRC-741) been:

d. Source and disposition of items containing special a. Prepared and submitted in the required time nuclear material b. Prepared accurately and according to approved

6. Are control and subsidiary accounts periodically plant procedures reconciled and adjusted to the results of physical inventories? c. Verified as to accuracy by a member of the

7. Is there written approval by authorized individuals material accounting staff other than the original preparer for all adjustments to: d. Signed by the appropriate authorized individual a. Control accounts 14. Are standard approved forms used to report internal material transfers between MBAs or ICAs?

b. Subsidiary accounts

15. Is there a system for controlling and accounting for c. Perpetual inventory records all such forms?

5.51-19

APPENDIX I

Audit Program Part I - Planning the Audit established before the review by using data from prior reviews and reports and general knowledge of the plant.

1. Document Review Part II - Conducting the Audit a. Review documents and contracts as indicated in the Review Program Checklist. Note items pertinent to 1. Initial Meetings records and reports examination.

At initial meetings with plant personnel:

b. Review plant reports (or suspense file notes) for:

a. Discuss information developed in audit planning

(1) Date and proper signature b. Review audit plans where necessary

(2) Proper form, including subschedules c. Discuss any changes in plant procedures that affect

(3) Basis for inventory records and reports d. Arrange for necessary assistance and availability of

(4) Explanation of MUF

records and reports

(5) Timely receipt

2. Review of Ledgers c. Review receiving and shipping documents (or suspense file notes) for preparation and issuance in Review general and subsidiary ledgers and list and accordance with requirements and regulations. investigate any unusual items occurring in journal vouchers or posting media.

d. Review backup documents and authorizations for measured discards. 3. Receipts e. Prepare notes in workpapers on specific items to a. Procurement investigate.

(1) Using invoices as bases, trace quantities to

2. Procedure Manuals and Internal Control permanent records.

a. Review procedure manuals, Internal Control (2) Test internal data supporting receipts (e.g., by Checklist, and associated documents to become use of receiving reports and measurement results), using reacquainted with facility records and reports. statistical samples where appropriate.

b. Prepare notes on specific items to be investigated. (3) Review purchase orders and payment vouchers to determine if quantities of material purchased agree

3. Trial Balances with invoices.

a. Using the plant material balance reports, schedule (4) Test-check extensions, footings, and postings external receipts and shipments and inventory adjust of invoices and/or other documents supporting quan ments (losses, measured discards, and material tities procured. Use statistical sampling plans where unaccounted for) by reporting identification symbol appropriate.

(RIS), contract number, material type, and date.

b. Other Source and Special Nuclear Material Catego b. Using the schedules prepared in 3a, set up pro ries forma trial balances for each material and material type, Check the bases of transfer and reconcile with the showing total facility balances in all cases.

corollary account under "Removals" (see 4d below).

4. Sampling Plans c. NRC Transfer Documents Prepare master data sheet and sampling plans for audit tests~to be performed on statistical sampling basis. Test-check postings of Form NRC-741 to the records.

Preliminary plans and sampling plan criteria can be Use statistical sampling plans where appropriate.

5.51-20

4. Removals Check bases of transfer and reconcile with corollary account under "Receipts" (see 3b above).

a. Measured Discards, Losses, and Material Unac counted For e. NRC Transfer Documents

(1) From material balance reports, prepare Test-check postings of Form NRC-741 to the records, schedules of each account for the survey period. using statistical sampling plans where appropriate.

(2) Trace schedule to ledgers. 5. Internal Transfers a. Trace documents supporting internal transfers

(3) Examine supporting evidence for posting (e.g., production notices, laboratory reports, weight documents. tallies, transfer forms) to records.

(4) Test-check postings of source documents to b. Check footings, postings, and extensions of intra ledgers, using statistical sampling plans where appropri area supporting documents.

ate.

c. Review internal transfer documents for propriety

(5) Check footings, extensions, and descriptions and numerical sequence of intra-area transfer forms.

of data on source documents to ascertain correctness and propriety of data. d. Reconcile records of internal transfers to books of final entry.

6. Measurement Records

(1) Check sales authorizations.

Trace on a selected basis, using statistical sampling

(2) Check sales slips and/or invoice quantities to plans when appropriate:

ledgers.

a. Quantities from records to laboratory workbooks

(3) Check footings, extensions, etc., of posting documents. b. Results in laboratory workbooks to quantities in records

(4) Trace postings to ledgers.

c. Extensions, footings, and descriptions, as appli c. Decay cable Check calculations on the basic posting documents 7. Findings and trace postings to records.

Summarize findings to be discussed with other team d. Other Source and Special Nuclear Material Catego members, facility personnel, and management and ries included in report.

5.51-21

UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D. C. 20555 POSTAGE AND FEES PAID

UNITED STATES NUCLEAR

OFFICIAL BUSINESS REGULATORY COMMISSION

PENALTY FOR PRIVATE USE, $300