Regulatory Guide 5.51: Difference between revisions

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{{Adams
{{Adams
| number = ML16223A915
| number = ML003739225
| issue date = 10/31/2016
| issue date = 06/30/1975
| title = Independent Assessment of Nuclear Material Control and Accounting Systems
| title = Management Review of Nuclear Material Control & Accounting Systems
| author name =  
| author name =  
| author affiliation = NRC/RES
| author affiliation = NRC/RES
Line 9: Line 9:
| docket =  
| docket =  
| license number =  
| license number =  
| contact person = Bayssie M
| contact person =  
| case reference number = DG-5049
| document report number = RG-5.51
| document report number = RG 5.51, Rev. 1
| package number = ML16223A911
| document type = Regulatory Guide
| document type = Regulatory Guide
| page count = 43
| page count = 22
}}
}}
{{#Wiki_filter:U.S. NUCLEAR REGULATORY COMMISSION                                                         October 2016 OFFICE OF NUCLEAR REGULATORY RESEARCH                                                              Revision 1 Technical Lead REGULATORY GUIDE
{{#Wiki_filter:U.S. NUCLEAR REGULATORY COMMISSION                                                                                                                 June 1975 REGULATORY GUIDE
                                                                                                                                      G. Tuttle REGULATORY GUIDE 5.51 (Draft was issued as DG-5049, dated September 2015)
        OFFICE OF STANDARDS DEVELOPMENT
      INDEPENDENT ASSESSMENT OF NUCLEAR MATERIAL
                                                                          REGULATORY GUIDE 5.51 MANAGEMENT REVIEW OF NUCLEAR MATERIAL
                        CONTROL AND ACCOUNTING SYSTEMS
                                                            CONTROL AND ACCOUNTING SYSTEMS


==A. INTRODUCTION==
==A. INTRODUCTION==
Purpose This regulatory guide (RG) describes a method that the staff of the U.S. Nuclear Regulatory Commission (NRC) considers acceptable for the independent assessment of nuclear material control and accounting (MC&A) systems.
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.


Applicability This RG applies to Category I, II, and III fuel cycle facilities, including uranium enrichment facilities, that are subject to the Code of Federal Regulations (10 CFR) Part 74, Material Control and Accounting of Special Nuclear Material, (Ref. 1).
and accounting procedures.
Applicable Regulations
      *    10 CFR 74, Material Control and Accounting of Special Nuclear Material, requires that certain licensees authorized to possess more than one effective kilogram of special nuclear material (SNM) shall implement and maintain a Commission-approved MC&A system that will achieve the objectives specific to the strategic significance of the material in its possession.


o    10 CFR 74.31(c)(8) requires that licensees for facilities with SNM of low strategic significance must conduct a periodic independent assessment of the effectiveness of the MC&A system.
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.


o    10 CFR 74.33(c)(8) requires that licensees for low enriched uranium enrichment facilities must conduct a periodic independent assessment of the effectiveness of the MC&A system.
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.


o    10 CFR 74.43(b)(8) requires that licensees for facilities with SNM of moderate strategic significance must conduct a periodic independent assessment of the effectiveness of the MC&A system.
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
 
Written suggestions regarding this guide or development of new guides may be submitted through the NRCs public Web site under the Regulatory Guides document collection of the NRC Library at http://www.nrc.gov/reading-rm/doc-collections/reg-guides/contactus.html.
 
Electronic copies of this regulatory guide, previous versions of this guide, and other recently issued guides are available through the NRCs public Web site under the Regulatory Guides document collection of the NRC Library at http://www.nrc.gov/reading-rm/doc-collections/. The regulatory guide is also available through the NRCs Agencywide Documents Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html, under ADAMS Accession No. ML16223A915. The regulatory analysis may be found in ADAMS
under Accession No. ML16223A917 and the staff responses to the public comments on DG-5049 may be found under ADAMS Accession No.
 
ML16223A913.
 
o    10 CFR 74.59(h)(4) requires that licensees for facilities with formula quantities of strategic SNM must conduct a periodic independent assessment of the effectiveness of the MC&A
              system.
 
Related Guidance
    *  NUREG-1065, Acceptable Standard Format and Content for the Fundamental Nuclear Material Control (FNMC) Plan Required for Low-Enriched Uranium Facilities (Ref. 2), provides guidance in the assessment and review of MC&A systems for low-enriched uranium facilities.
 
*  NUREG-1280, Standard Format and Content Acceptance Criteria for the Material Control and Accounting (MC&A) Reform Amendment: 10 CFR Part 74, Subpart E, (Ref. 3), provides guidance in the assessment and review of MC&A systems for facilities with formula quantities of strategic SNM.
 
*  NUREG/CR-5734, Recommendations to the NRC on Acceptable Standard Format and Content for the Fundamental Nuclear Material Control (FNMC) Plan Required for Low-Enriched Uranium Enrichment Facilities (Ref. 4), provides guidance in the assessment and review of MC&A systems for low-enriched uranium enrichment facilities.
 
Purpose of Regulatory Guides The NRC issues regulatory guides to describe to the public methods that the staff considers acceptable for use in implementing specific parts of the agencys regulations, to explain techniques that the staff uses in evaluating specific problems or postulated events, and to provide guidance to applicants.
 
Regulatory guides are not substitutes for regulations and compliance with them is not required. Methods and solutions that differ from those set forth in regulatory guides will be deemed acceptable if they provide a basis for the findings required for the issuance or continuance of a permit or license by the Commission.
 
Paperwork Reduction Act This regulatory guide contains and references information collections covered by 10 CFR Part 74 that are subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). These information collections were approved by the Office of Management and Budget (OMB), control number 3150-0123.
 
Public Protection Notification The NRC may not conduct nor sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid OMB control number.
 
RG 5.51, Rev. 1, Page 2
 
TABLE OF CONTENTS
                                                                                                                                                  Page
 
==A. INTRODUCTION==
................................................................................................................................... 1
 
==B. DISCUSSION==
.......................................................................................................................................... 4 C. STAFF REGULATORY GUIDANCE .................................................................................................... 6
 
==D. IMPLEMENTATION==
............................................................................................................................ 11 REFERENCES ........................................................................................................................................... 13 APPENDIX A: ASSESSMENT PROGRAM CHECKLIST .................................................................... A-1 APPENDIX B: PROCEDURES MANUAL CHECKLIST...................................................................... B-1 APPENDIX C: ORGANIZATION AND MANAGEMENT CHECKLIST ............................................ C-1 APPENDIX D: INTERNAL CONTROL CHECKLIST .......................................................................... D-1 APPENDIX E: MEASUREMENT SYSTEM CHECKLIST ................................................................... E-1 APPENDIX E - ANNEX 1: MEASUREMENT POINT DATA SHEET ................................................ E-3 APPENDIX E - ANNEX 2: ANALYTICAL LABORATORY CHECKLIST ....................................... E-5 APPENDIX E - ANNEX 3: SCALE AND BALANCE CHECKLIST ................................................... E-7 APPENDIX F: STATISTICAL CONTROLS CHECKLIST .................................................................... F-1 APPENDIX G: PHYSICAL INVENTORY CHECKLIST ...................................................................... G-1 APPENDIX H: RECORDS AND REPORTS CHECKLIST ................................................................... H-1 APPENDIX I: AUDIT PROGRAM ...........................................................................................................I-1 RG 5.51, Rev. 1, Page 3


==B. DISCUSSION==
==B. DISCUSSION==
Reason for Revision This revision of RG 5.51 (Revision 1) provides guidance that conforms with the requirements in
tive evaluation of their own system. Personnel other than those directly responsible for the system, but still
10 CFR Part 74, Material Control and Accounting of Special Nuclear Material, as well as incorporating experience gained since the RG was initially published in June 1975. For example, the guidance for performing independent assessments has been expanded to include process monitoring and item monitoring for Category I fuel cycle facilities, and to include guidance for uranium enrichment facilities.
        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.
 
In addition, Revision 1 addresses changes in MC&A terminology since this RG was published in 1975;
for example, the term management review has been replaced by independent assessment, and material unaccounted for by inventory difference.
 
Background The basis of any effective system of control is a program of review to ensure that the procedures are effective and appropriate and that such procedures are being carried out in practic
 
====e. The NRC====
conducts inspections to ensure that licensees MC&A systems are compliant with the NRC-approved fundamental nuclear material control (FNMC) plans and that the performance of such systems effectively meets the requirements of the 10 CFR Part 74 regulations and any applicable license conditions. Licensee management, however, is responsible for implementing the NRC requirements by maintaining an effective MC&A system.
 
The individuals performing independent assessments should be independent both from nuclear material control management and from personnel who have direct responsibility for the receipt, custody, use, measurement, measurement quality, and shipment of nuclear material. On-site MC&A staff may be used for portions of such assessments as long as they are not assessing areas for which they are directly responsible.
 
These assessments include a review of MC&A procedures and practices, and a review of nuclear material records. The results of the independent assessments, along with recommendations for improvements, should be documented, reported to the licensees corporate and plant management, and kept available at the plant for inspection for a period specified in: 10 CFR 74.31(d) for facilities with SNM of low strategic significance (i.e., Category III facilities); 10 CFR 74.33(d) for low enriched uranium enrichment facilities; 10 CFR 74.43(d) for facilities with SNM of moderate strategic significance (i.e., Category II facilities); and 10 CFR 74.59(g) for facilities with formula quantities of strategic SNM
(i.e., Category I facilities).
        Assessment, evaluation, and modification of the system by licensee management or representatives ensures the adequate discharge of this responsibility. It is assumed for such an assessment that a system has been established, documented, and implemented. The purposes of the assessment are to ensure that the MC&A system is being operated as designed and to determine if the established system is appropriate and effective for the current operations.
 
Changes in management relationships, production technology or capacity, operating practices, or plant mission could result in the need to change the MC&A system. The independent assessment will provide evaluation of the system to determine whether such changes should be made.
 
RG 5.51, Rev. 1, Page 4
 
This assessment process should extend beyond a routine review for compliance with existing procedures and commitments. An acceptable assessment should provide perspectives relative to overall program effectiveness and to the adequacy of the program to meet and satisfy regulatory intent.
 
The people most knowledgeable of a facilitys MC&A system are those directly responsible for its operation. These people, however, would have difficulty in conducting an objective evaluation of their own system. Personnel other than those directly responsible for the system, but still knowledgeable of its basic concepts, can provide an independent viewpoint. Such personnel also can view the system from a management standpoint, as well as from a purely technical standpoint.
 
Harmonization with International Standards The NRC staff reviewed guidance from the International Atomic Energy Agency (IAEA), and the International Organization for Standardization (ISO), and did not identify any standards that provided useful guidance to NRC staff, applicants, or licensees.
 
RG 5.51, Rev. 1, Page 5
 
C. STAFF REGULATORY GUIDANCE
        The independent assessment of MC&A systems should include the following considerations and coverage. Although this guide is prepared for assessments of facilities having special nuclear material, production facilities having only source material are encouraged to conduct independent assessments using this guide, as appropriate.
 
1.      Purpose and Scope of the Independent Assessment The purpose of the independent assessment of an MC&A system should be to ensure that approved procedures are followed, that practices and procedures are appropriate for current operations and are in compliance with NRC-approved FNMC plans, and that performance of MC&A functions are effectively executed. The scope of the assessment should include evaluation of the effectiveness of the system in maintaining control of and accounting for the nuclear materials. Measures of effectiveness should be considered in each part of the assessment.
 
a.      MC&A systems should be divided into the following areas of investigation for purposes of an independent assessment:
        (1)      Organization and Management;
        (2)      Internal Control, including storage and internal handling, item identification and control, shipping and receiving control, scrap and waste control, and detection of unauthorized production for enrichment plants;
        (3)      Measurement System, including the measurement and sampling procedures and the measurement quality-assurance program;
        (4)      Statistical Control, including the statistical aspects of the measurement quality-assurance program, shipper-receiver difference control and evaluation, statistical methodology associated with measurement and material balance standard errors, and statistical methods used for item and process monitoring;
        (5)      Physical Inventory; and
        (6)      Records and Reports.
 
b.      Other divisions or groupings should be used, depending on the design and complexity of the system being reviewed and the disciplines represented on the assessment team. For example, the measurement and sampling procedures might be considered as a category separate from the measurement quality-assurance program. The way in which the system is divided or assigned for assessment is not particularly significant. It is important, however, that the division and assignment of assessment tasks is such that all aspects are covered.
 
c.      In addition to independent periodic assessments, the facility management of the MC&A function should also conduct ongoing internal reviews of the same subject matter in a manner that reflects continuing attention to assessing operational performance and identifying opportunities for improvement.
 
d.      Consistent with methodologies described in 10 CFR Part 74, the assessments should include a review and evaluation of any contractor who performs special nuclear material accountability measurements for the licensee.
 
RG 5.51, Rev. 1, Page 6


2.     Personnel Qualifications for the Independent Assessment Team a.     Personnel assigned to the assessment team should be knowledgeable in the basic MC&A
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.
        principles. They also should be selected so that their responsibilities on the assessment team do not cause a conflict of interest with their regular duties. They should provide an independent viewpoint that is management-oriented as well as technically oriented. On-site MC&A staff may be used for portions of the assessment as long as they are not assessing areas for which they are directly responsible.


b.      Individual members of the team should be knowledgeable in the specific disciplines appropriate to their assigned areas of investigation. Assessment team personnel should be sufficiently knowledgeable to permit them to evaluate the appropriateness of procedures as applied in a given system. In this respect, assessment team personnel should keep in mind the question, Is there a better way of doing this and still meet the system requirements?
ticularly useful in evaluating the need for an early revision                        2066. Attention: Director. Office of Standards Development.
c.      Task assignments for assessment team personnel should be made in writing to ensure complete coverage and minimize duplication of effort. One person should be assigned the task of overall assessment coordination. For small facilities, the entire assessment may be done by one person if that person is knowledgeable in all aspects of the system.


3.      Planning for the Independent Assessment Assessment of MC&A systems should include advanced planning to establish the extent and depth of coverage in each part of the system, and to ensure that all parts are covered.
ENCLOSURE 1


====a. Assessment Program====
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.
        (1)      A program for the assessment should be prepared to ensure complete coverage and development of adequate information on which to base assessment decisions. The assessment program should include a checklist for the assessment that covers all parts of the material control and accounting system. A preprinted program can save considerable time in planning but should not be used as an inflexible checklist or as a substitute for judgment and initiative in investigation.


(2)      The basic assessment program should be supplemented with checklists and questionnaires for more detailed coverage of the various parts of the assessment.
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.


Appendix A to this guide is an example of an assessment program checklist.
f.  Organization and Management.


b.     Procedure Manual Review of the current procedure manuals and completion of a procedure manual checklist should be a part of the assessment planning. Reviewers should use such reviews to familiarize themselves with current procedures and to identify changes that may need coverage in more depth. Appendix B to this guide is an example of a procedure manual checklist.
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.


c.     Prior Assessment Documentation Prior assessment documentation should be used to acquaint the team members with past performance and review procedures, and to identify control practices that were previously found to be weak or inadequate. Such practices should be noted for more thorough investigation, RG 5.51, Rev. 1, Page 7
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


whereas areas that were found to be satisfactory and that had been reviewed thoroughly on the prior assessment could be given less emphasis in the current assessment.
==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.


d.      Correspondence, Reports, and Discussions MC&A correspondence and reports, as well as preliminary discussions with plant management, plant operations personnel, and MC&A personnel should be used to identify problem areas and areas that require a thorough investigation during the assessment. Discussion with the plant material control staff should also provide information for scheduling reviews of nuclear material records; and, when the review team plans to observe any parts of the physical inventory, the schedule for the inventory observations.
considerations and coverage.


4.      Coverage of the Independent Assessment All parts of the MC&A system should be covered in each assessment. However, not all parts of the MC&A system need be given the same depth of coverage each time. Decisions as to depth of coverage should be based on considerations such as evidence of problems in any parts of the MC&A
The basic review program should be supple
system, changes in procedures, or coverage in prior assessments. Information on which to base such decisions should be obtained before an assessment begins. In this regard, information should be obtained from sources such as prior assessment documentation and reports, plant reports that give indications of problem areas, review of procedure manuals, and discussions with appropriate plant personnel.
  1.   Purpose and Scope                                      mented with checklists and questionnaires for more detailed coverage of the various parts of the review.


The effectiveness of collusion-protection procedures should also be included in assessments. The MC&A system needs to protect against a single material control and accounting insider colluding with an external person, providing that the insider does not have authority within the physical protection system that would permit participation in an attempt to defeat the MC&A system. Additional guidance regarding collusion protection related to material control and accounting is contained in NUREG-1280, Standard Format and Content Acceptance Criteria for the Material Control and Accounting (MC&A) Reform Amendment: 10 CFR Part 74, Subpart E (NUREG-1280, Revision 1).
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.
         The independent assessment should include elements which test the performance of MC&A staff in the discharge of their responsibilities. Specific testing should include general areas of performance unless known weaknesses have been identified, in which case more comprehensive testing should be performed in those areas. Appendices D through I to this guide contain examples of performance tests that could be conducted with the understanding that the testing to be performed should be appropriate for the type of operations conducted at the facility.


To ensure complete coverage, assessment checklists and questionnaires should be used. Such checklists and questionnaires are cited in the following sections. These checklists and questionnaires should be considered only as guides and should not be used as a substitute for judgment and investigative initiative. The subdivision of the assessment into parts covered in the following six sections should be considered flexible. Other arrangements may be used where appropriate to the facility and the talents of the assessment team.
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
                                                            5.51-2


a.       Organization and Management This part of the assessment should include review and evaluation of the following:
more depth. Appendix B to this guide is an example of a                (2) Functional statements of responsibilities procedure manual checklist.                                    and authorities;
        (1)      organizational relationships;
    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.
        (2)     functional statements of responsibilities and authorities;
                                            RG 5.51, Rev. 1, Page 8


(3)      the system for development, revision, implementation, and enforcement of procedures;
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.
             and
  (4)      the effectiveness of the system in terms of losses and material unaccounted for relative to expected values for these items.


Appendix C to this guide is an example of an organization and management review checklist.
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.


Personnel conducting this part of the assessment should be knowledgeable of the basic concepts of management and administration. All assessment team personnel should be made aware of the information developed in this part so that they may take into consideration any areas that might be pertinent to their specific part of the assessment.
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:


Information regarding organization and management should be contained in the facilitys organization manuals and charts, job descriptions, and instruction manuals.
===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.


b. Internal Control This part of the assessment should include review and evaluation of the following:
appropriate plant personnel.
  (1)      internal storage and handling,
  (2)      item identification and control,
  (3)      tamper-safing,
  (4)      shipping and receiving controls,
  (5)      scrap and waste controls, and
  (6)      detection of unauthorized production for enrichment facilities.


Appendix D to this guide is an example of an internal control checklist. Personnel conducting this part of the assessment should be knowledgeable of the basic concepts of material control.
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.


Information regarding internal control should be contained in the facilitys procedure manuals, instruction manuals, and other facility management directives.
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.


c. Measurement System This part of the assessment should include review and evaluation of the following:
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.
  (1)      sampling and measurement points;
  (2)      weight and volume methods;
  (3)      analytical methods including nondestructive methods;
  (4)      measurement data control procedures; and
  (5)      measurement quality-assurance programs.


Appendix E to this guide is an example of a measurement system checklist. Personnel conducting this part of the assessment should be knowledgeable of the chemical and physical properties of the materials involved, of the fundamentals of sampling and measurement of such materials, and of the basic concepts of measurement quality assurance.
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;
                                                        5.51-3


Information regarding measurement systems should be contained in the facilitys procedure manuals, analytical manuals, laboratory data records, and measurement quality-assurance manuals and data logs.
(3)  Weight and volume methods;                    analytical manuals, laboratory data records, and mea surement quality assurance manuals and data logs.


RG 5.51, Rev. 1, Page 9
(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


d. Statistical Controls This part of the assessment should include review and evaluation of the following:
====s. The review====
  (1)      the determination of measurement bias, random error variances, and systematic error variances;
          (6) Measurement quality assurance programs.
  (2)      the determination of material balance limits of uncertainty, i.e., the standard error of the inventory difference (SEID);
  (3)      inventory difference (ID) and SEID evaluation;
  (4)      process monitoring and abrupt alarms;
  (5)      shipper-receiver difference evaluation and control; and
  (6)     statistical methodology used in measurement quality assurance.


Appendix F to this guide is an example of a statistical control checklist. Personnel conducting this part of the assessment should be knowledgeable of the basic concepts of mathematical statistics and their application to nuclear material control.
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.


Information regarding statistical controls should be contained in the facilitys procedure manuals, analytical manuals, laboratory data records, and measurement quality-assurance manuals and data logs.
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.


e. Physical Inventory This part of the assessment should include review and evaluation of the facilitys physical inventory procedures, instructions, and practices. The assessment should include observation of at least part of a routine physical inventory. The assessment need not include independent verification of the physical inventory by the review team.
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.


Appendix G is an example of a physical inventory checklist. Personnel conducting this part of the assessment should be knowledgeable of the basic concepts of material control and accounting, especially those pertaining to the conduct of physical inventories.
random error variances, and limits of systematic error;        Appendix H is an example of a records and reports checklist.


Information regarding physical inventories should be contained in the facilitys procedure manuals and physical inventory instruction directives.
(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.


f. Records and Reports This part of the assessment should include review and evaluation of the facilitys data-handling practices and procedures and an audit of nuclear material records. Appendix H is an example of a records and reports checklist.
(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 I is an example of a nuclear material records audit program. Personnel conducting this part of the assessment should be knowledgeable in the basic concepts of data handling, audit techniques, and MC&A procedures.
Appendix F to this guide is an example of a                          
 
RG 5.51, Rev. 1, Page 10


==D. IMPLEMENTATION==
==D. IMPLEMENTATION==
The purpose of this section is to provide information on how applicants and licensees 1 may use this guide and information regarding the NRCs plans for using this regulatory guide. In addition, it describes how the NRC staff complies with the Backfit Rules in 10 CFR 70.76, 10 CFR 72.62, and
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.
10 CFR 76.76, each titled Backfitting.
 
Use by Applicants and Licensees Applicants and licensees may voluntarily 2 use the guidance in this document to demonstrate compliance with the underlying NRC regulations. Methods or solutions that differ from those described in this regulatory guide may be deemed acceptable if they provide sufficient basis and information for the NRC staff to verify that the proposed alternative demonstrates compliance with the appropriate NRC
regulations. Current licensees may continue to use guidance the NRC found acceptable for complying with the identified regulations as long as their current licensing basis remains unchanged. The acceptable guidance may be a previous version of this regulatory guide.
 
Licensees may use the information in this regulatory guide for actions which do not require NRC
review and approval such as changes to a facility design under 10 CFR 70.72, Facility Changes and Change Process; 10 CFR 72.48, Changes, Tests, and Experiments; or 10 CFR 76.68, Plant Changes.
 
Licensees may use the information in this regulatory guide or applicable parts of this guide to assist in resolving regulatory or inspection issues.
 
Use by NRC Staff The NRC staff does not intend or approve any imposition or backfitting of the guidance in this regulatory guide on licensees. The NRC staff does not expect any existing licensee to use or commit to using the guidance in this regulatory guide unless the licensee makes a change to its licensing basis. The NRC staff does not expect or plan to request licensees to voluntarily adopt this regulatory guide to resolve a generic regulatory issue. The NRC staff does not expect or plan to initiate NRC regulatory action which would require the use of this regulatory guide. Examples of such unplanned NRC regulatory actions include issuance of an order requiring the use of the regulatory guide, generic communication, or promulgation of a rule requiring the use of this regulatory guide without further backfit consideration.
 
During regulatory discussions on plant-specific operational issues, the staff may discuss with licensees various actions consistent with staff positions in this regulatory guide as one acceptable means of meeting the underlying NRC regulatory requirement. Such discussions would not ordinarily be considered backfitting even if prior versions of this regulatory guide are part of the licensing basis of the facility. However, unless this regulatory guide is part of the licensing basis for a facility, the staff may not represent to the licensee that the licensees failure to comply with the positions in this regulatory guide constitutes a violation.
 
1        In this section, licensees refers to holders of, and the term applicants refers to applicants for, the following:
          (1) special nuclear material licenses under 10 CFR Part 70, (2) licenses for independent spent fuel storage installations or monitored retrievable storage installations or certificates of compliance for spent fuel storage cask designs under
          10 CFR Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste, and (3) certificates of compliance or approvals of a compliance plan for gaseous diffusion plants under 10 CFR Part 76, Certification of Gaseous Diffusion Plants.
 
2        In this section, voluntary and voluntarily means that the licensee is seeking the action of its own accord, without the force of a legally binding requirement or an NRC representation of further licensing or enforcement action.
 
RG 5.51, Rev. 1, Page 11


If an existing licensee voluntarily seeks a license amendment or change and (1) the NRC staffs consideration of the request involves a regulatory issue directly relevant to this new or revised regulatory guide and (2) the specific subject matter of this regulatory guide is an essential consideration in the staffs determination of the acceptability of the licensees request, the staff may request that the licensee either follow the guidance in this regulatory guide or provide an equivalent alternative process that demonstrates compliance with the underlying NRC regulatory requirements. This is not considered backfitting as defined in 10 CFR 70.76(a)(1), 10 CFR 72.62(a), or 10 CFR 76.76(a)(1).
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.
        Additionally, an existing applicant may be required to comply with new rules, orders, or guidance if 10 CFR 70.76(a)(3), 10 CFR 72.62(c), or 10 CFR 76.76(a)(3) applies.


If a licensee believes that the NRC is either using this regulatory guide or requesting or requiring the licensee to implement the methods or processes in this regulatory guide in a manner inconsistent with the discussion in this Implementation section, the licensee may file a backfit appeal with the NRC in accordance with the guidance in NUREG-1409, Backfitting Guidelines (Ref. 5), and NRC Management Directive 8.4, Management of Facility-Specific Backfitting and Information Collection (Ref. 6).
5.51-4
                                            RG 5.51, Rev. 1, Page 12
 
REFERENCES 3
1. U.S. Code of Federal Regulations, Material Control and Accounting of Special Nuclear Material, Part 74, Chapter I, Title 10, Energy.
 
2. U.S. Nuclear Regulatory Commission, Acceptable Standard Format and Content for the Fundamental Nuclear Material Control (FNMC) Plan Required for Low-Enriched Uranium Facilities, NUREG-1065.
 
3. U.S. Nuclear Regulatory Commission, Standard Format and Content Acceptance Criteria for the Material Control and Accounting (MC&A) Reform Amendment, NUREG-1280, Rev. 1, Washington DC, April 1995.
 
4. U.S. Nuclear Regulatory Commission, Recommendations to the NRC on Acceptable Standard Format and Content for the Fundamental Nuclear Material Control (FNMC) Plan Required for Low-Enriched Uranium Enrichment Facilities, NUREG/CR-5734 (K/ITP-415). (ADAMS
  Accession No. ML031340297).
5. U.S. Nuclear Regulatory Commission, Backfitting Guidelines, NUREG-1409, July 1990.
 
6. U.S. Nuclear Regulatory Commission, Management of Facility-Specific Backfitting and Information Collection, Management Directive 8.4, October 2013.
 
3  Publicly available NRC published documents are available electronically through the NRC Library on the NRCs public Web site at: http://www.nrc.gov/reading-rm/doc-collections/. The documents can also be viewed online or printed for a fee in the NRCs Public Document Room (PDR) at 11555 Rockville Pike, Rockville, MD; the mailing address is USNRC PDR, Washington, DC 20555; telephone 301-415-4737 or 800-397-4209; fax 301-415-3548; and e-mail pdr.resource@nrc.gov.
 
RG 5.51, Rev. 1, Page 13


APPENDIX A
APPENDIX A
                              Assessment Program Checklist A-1. Planning the Assessment a.  General Arrange with plant management and nuclear material control and accounting management for the assessment dates, inventory dates, and discussions with appropriate plant personnel. Request information from plant personnel on specific areas that they believe should be given special attention during the assessment.
                                              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.
b.  Personnel Prepare a schedule of the assessment with specific assignments for each assessment team member. Each assessment team member should be given a copy of the schedule.
 
c.  Document Review Each member of the assessment team should survey previous assessment documentation, plant reports, and other documents pertinent to his or her assigned part of the assessment and should prepare a schedule of items for special investigation.
 
d.  Procedure Review Each member of the assessment team should survey plant organization and procedure manuals pertinent to his or her part of the assessment, and prepare a schedule of items for special attention.
 
Each member should complete a procedure manual checklist, or that portion of the checklist pertinent to his or her assigned tasks.
 
e.  Physical Inventory Review the plant procedures and instructions pertaining to the conduct of plant physical inventories. If observing any part of a routine physical inventory, make personnel inventory assignments and prepare specific inventory instructions for the assessment team.
 
f.  Measurement System Review Review plant procedure manuals, prior assessment documentation, special reports, and other information to prepare or update measurement system flowcharts or data sheets as shown in the measurement system checklist (see Appendix E for examples). Select areas of the measurement system to be given special emphasis during the assessment.
 
g.  Statistical Controls Review Review measurement system reliability data, measurements quality-assurance procedures, and other material balance uncertainties to select areas for special emphasis during the assessment.
 
Appendix A to RG 5.51, Page A-1
 
hRecords and Reports Identify the records that will be subject to the audit and special report items that merit special investigation. Complete the planning portion of the audit program.
 
A-2. Conducting the Assessment
 
====a. General====
    (1)      Discuss with plant management the general aspects of the scope of assessment.


(2)      Discuss details of the assessment with material control and accounting management, and arrange meetings with other plant personnel as necessary.
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.  Organization and Management Complete the organization and management checklist on the basis of document reviews, discussions with plant personnel, and observations during the assessment.
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. Internal Control====
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.
    (1)     Review notes and findings from previous assessments of the various aspects of internal control to determine adequacy with respect to the following:
              (a)      procedures reflecting actual practice, and (b)      appropriateness and effectiveness of the procedures.


(2)      Complete the internal control checklist using notes and observations collected during the assessment.
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.


====d. Measurement System====
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:
    (1)     Review the measurement system with appropriate plant personnel to determine adequacy with respect to the following:
    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.
              (a)     procedures reflecting actual practice, and (b)     completeness, appropriateness, and effectiveness of the procedures.


(2)      Observe those areas selected in planning for emphasis during the assessment. Complete the checklists as appropriate for the various aspects of the measurement system.
inventory instructions for the review team.


====e. Statistical Controls====
(2) Complete the internal control checklist f.  Measurement System Review                             using notes and observations collected during the review.
    (1)     Review and evaluate the statistical basis for measurement reliability for individual measurements, factors, and material balances in the areas selected for emphasis during the assessment.


(2)     Review and evaluate the statistical methodology and controls used in determining and controlling limits of error for measurements, factors, and material balances.
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.


(3)      Complete the statistical control checklist and evaluate the controls with respect to the following:
(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.
              (a)     procedures reflecting actual practice, and (b)     appropriateness and effectiveness of the procedures.


====f. Physical Inventory====
5.51-5
    (1)      Review detailed inventory plans with appropriate plant personnel.


Appendix A to RG 5.51, Page A-2
(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.


(2)     When observing the physical inventory process, note any changes and deviations from the inventory plan. Document observations and complete the physical inventory checklist.
(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.


(3)    Evaluate inventory practices and procedures with respect to the following:
balances.
            (a)    procedures and plans reflecting actual practice, and (b)    appropriateness and effectiveness of the procedures.


g.  Records and Reports Complete the assessment of the records and reports, and the audit of the nuclear material records according to the audit program.
(2) Determine the accuracy with which proce
          (3) Complete the statistical control checklist        dures reflect actual practice.


A-3. Reporting Assessment Results a.  The team leader should discuss the assessment results with the assessment team to:
and evaluate the controls with respect to:
    (1)     Determine the effectiveness and appropriateness of the plant material control and accounting system in its entirety and in its several parts.
                                                                          (3) Determine areas in which recommenda (a) Procedures reflecting actual practice        tions for improvements are to be made.


(2)     Determine the accuracy with which procedures reflect actual practice.
and (b) Appropriateness and effectiveness of                    (4) Develop points for discussion with plant and material control and accounting managements.


(3)    Determine areas in which to make recommendations for improvement.
the procedures.


(4)    Develop points for discussion with plant and material control and accounting managements.
b. Discuss the findings of the review with plant f.  Physical Inventory                                    and material control and accounting managements.


bDiscuss the findings of the assessment with plant and material control and accounting managements.
(i) Review detailed    inventory    plans with            cPrepare and issue the written report.


c.  Prepare and issue the written report.
appropriate plant personnel.


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


A-4. Reviewing Documentation a.  Review all assessment documentation for completeness.
a.  Complete and tie-in all workpapers.


b.  Index and cross-reference all documentation to the following:
(3) Evaluate inventory practices and proce dures with respect to:                                              b.  Index and cross-reference all workpapers to:
    (1)     other documents,
              (a) Procedures and plans reflecting actual                  (1) Other workpapers practice and
    (2)     the assessment report, and
                                                                          (2) Review report (b) Appropriateness and effectiveness of the procedures.                                                          (3) Appropriate plant files.
    (3)     appropriate plant files.


Appendix A to RG 5.51, Page A-3
5.51-6


APPENDIX B
APPENDIX B
                                  Procedures Manual Checklist Performance should be reviewed to ensure compliance with approved procedures. The items below suggest areas for coverage.
                                            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
                                                          5.51-7


B-1Facility Organization a.     Organization charts of:
h. Statement of storage and internal transfer                  e. Description of the flow and use of measure responsibilities                                              ment data
      (1)     the facility organization, and
6.  Scrap Control                                                  fProcedures and techniques for statistical evalua a. Description of procedures for segregating, pack        tion of:
      (2)     the nuclear material control and accounting unit.
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


b.     Statements of responsibility and authority for:
===8. Records and Reports===
      (1)     the central material control and accounting unit, and
          (3) For all material streams b. Description of methods and techniques used at                a.  Chart of accounts each sampling and measurement point, including:
      (2)     others concerned with material control and accounting.
                                                                          (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-2.  Facility Operations a.    Functional statement of the facilitys operations and processes b.     Material flow description:
====b. Document flowchart====
      (1)      by charts,
          (5) Measurements for calculation of quantities                  (1) Physical flow of documents related to nuclear loss or production or factors
      (2)      by narrative,
                                                                          (2) Posting points c.  Description of supporting programs:
      (3)      including material composition and type at significant points, and
                                                                          (3) Retention points
      (4)      including usual or normal material quantities.
          (1) Scale and balance program
 
                                                                          (4) Data elements
B-3.  Receiving, Shipping, and Other Receipts and Removals a.    Description of shipping and receiving points:
          (2) Calibration programs c.   Description of the system
      (1)      notation of these points on the material flowchart, and
          (3) Quality control programs
      (2)     description of the receiving and shipping procedures at each point.
                                                                          (1) Posting procedures
 
          (4) Analytical control programs
b.    Procedures for review, evaluation, and resolution of significant shipper-receiver differences.
                                                                          (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
 
                                                                                                                          )
c.    Description of and procedures for determining, reporting, and recording other additions to or removals from inventory.
                                                        5.51-8
 
d.    Procedures for evaluation and control of removals from inventory such as inventory difference (ID) and measured discards.
 
e.    Statements of receiving and shipping responsibilities.
 
B-4.  Inventory a.    statements of inventory timing and frequency, b.    cutoff and plant shutdown procedures, c.    inventory measurement procedures, Appendix B to RG 5.51, Page B-1
 
d.  description of general inventory techniques, e.  supplemental inventory instructions, and f.  statement of inventory responsibilities.
 
B-5. SNM Storage, Internal Transfers, and Item Control a.  description of procedures and mechanisms for segregating nuclear materials by material type and enrichment;
b.  specific nuclear material identification and labeling procedures;
c.  description of tamper-safing procedures and devices;
d.  description of storage facilities;
e.  description of burial grounds, including location records;
f.  description of procedures, documents, and document flows for internal transfers of nuclear material;
g.  methods of determining nuclear material quantities transferred or stored;
h.  statements of storage and internal transfer responsibilities; and i.  description of item monitoring activities.
 
B-6. Scrap Control a.  description of procedures for segregating, packaging, and identifying scrap;
b.  methods for determining the nuclear material content of scrap; and c.  description of procedures for recovering nuclear material from scrap, including offsite recovery, if appropriate.
 
B-7. Measurements and Statistical Controls a.  Description of nuclear material sampling and measurement points:
    (1)      by process or material flowchart,
    (2)     by narrative description, and
    (3)      for all material streams.
 
b.  Description of methods and techniques used at each sampling and measurement point, including:
    (1)     weight or volume measurements,
    (2)     sampling procedures,
    (3)     special equipment for sampling or measurements,
    (3)      analytical procedure, and Appendix B to RG 5.51, Page B-2
 
(5)     measurements for calculation of quantities related to nuclear loss (such as ID), or production (such as receipts), or calculation of factors used in determining item or production quantities.
 
c.   Description of supporting programs:
      (1)     scale and balance program,
      (2)     calibration programs,
      (4)     quality-control programs, and
      (4)     analytical control programs.
 
d.   Description of techniques and programs used to determine and control the measurements systems biases, random error variances, and systematic error variances.
 
e.    Description of the flow and use of measurement data.
 
f.    Procedures and techniques for statistical evaluation of:
      (1)      shipper-receiver differences;
      (2)      inventory differences;
      (3)      individual measurement and shipment limits of error;
      (5)      calibration uncertainty; and
      (5)      process monitoring data, if applicable.
 
g.    Statements of responsibility for measurements and statistical controls.
 
B-8.  Process Monitoring Program for Category I Facilities a.    description of process monitoring activities, b.    investigation and resolution of abrupt alarms, and c.    investigation of three-sigma and trend indicators.
 
B-9.  Detection of Unauthorized Production and Enrichment for Uranium Enrichment Facilities a.    description of the unauthorized production and enrichment program, and b.    resolution activities for indicators of unauthorized production or enrichment.
 
B-10. Records and Reports a.    Charts of accounts:
      (1)      general ledger accounts,
      (2)      control accounts,
      (3)      subsidiary accounts, and
      (4)      plant accounts.
 
b.    Document flowchart:
      (1)      physical flow of documents,
      (2)      posting points,
      (3)      retention points, and
      (4)      data elements.
 
Appendix B to RG 5.51, Page B-3
 
c. Description of the system:
  (1)    posting procedures,
  (2)    sample forms, including instructions,
  (3)    description and basis of reports, and
  (4)     method of generating reports from records.
 
Appendix B to RG 5.51, Page B-4


APPENDIX C
APPENDIX C
                      Organization and Management Checklist C-1. Organization a.   Does the facility maintain current written procedures that contain organization charts or descriptions of the management structure, identifying all positions having responsibility for or control over special nuclear material? Is the nuclear material control structure described, including the relationship of the material control functions and responsibilities to those of other organizational functions and responsibilities?
                                      Organization and Management Checklist
b.  Have appropriate separations of functions been identified in the procedures to provide a system of control checks and balances?
1. Organization                                                 transfers, measurements, statistics, and the records and reports system?
     (1)      Are the nuclear material control and accounting functions organizationally independent of the operating departments?
    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?
    (2)      Does the unit include (or have available) personnel qualified in:
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?
              (a)    accounting, (b)    analytical chemistry, (c)    physics or nondestructive assay, (d)    quality control, and (e)    statistics?
identified in the procedures to provide a system of control checks and balances?                                     
    (3)      Can the material control and accounting unit cross organizational lines to enforce policy?
    (4)      Are the analytical and assay measurement laboratories organizationally independent of the operating departments?
c.  Are statements of responsibility and authority included for those positions having responsibility for receiving and shipping, inventory, storage, and the internal reports system?
d.  Are statements of responsibility and authority provided for other positions concerned with input to the material control system, such as production quality control, the analytical laboratory, measurement system quality control, accounting, and auditing?
e.   Does the procedures contain the job titles of the key positions in the safeguards program, and describe the required qualifications for these positions?
C-2. Management a.  Are nuclear material control procedures and revisions reviewed and approved by appropriate management?
b.  Are delegations of material control and accounting responsibilities documented?
c.  Are nuclear material control procedures contained in standard operating procedures, process specifications, manufacturing instructions, etc., so that the worker is informed of the accountability requirements of his or her job?
d.  Is there evidence that appropriate management action has been taken to ensure that practices comply with procedures?
                                     Appendix C to RG 5.51, Page C-1


e. Is there evidence that appropriate management action has been taken to ensure that procedures are revised to reflect approved changes in material control and accounting practices?
===2. Management===
f. Were there any losses of discrete items or containers of special nuclear material? If so, was appropriate management action taken?
          (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?
g. Did the inventory difference (ID) for any material balance exceed the associated control limits for that balance? If so, was appropriate management action taken?
                                                                      b. Are delegations of material control          and
                                Appendix C to RG 5.51, Page C-2
          (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?
                                                            5.51-9


APPENDIX D
APPENDIX D
                                  Internal Control Checklist D-1. Internal Storage and Handling a.   Are containers and items containing special nuclear material properly labeled and uniquely identified?
                                            Internal Control Checklist
b.   Are records maintained for containers and items in storage? Transferred to or from storage?
1. Internal Storage and Handling                                       (4) Is a lot or item number assigned upon receipt?
c.   Is there control of material removal from storage?
    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?
d.   Is there segregation in storage of dissimilar materials, e.g., material types, enrichments, scrap, raw material, in-process material, and product?
                                                                        (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:
e.   Are records maintained showing the identity, location, source, disposition, and special nuclear material content of all containers and items?
    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?
f.   Are there records showing the quantities of special nuclear material added to the process, removed from the process, and currently in process?
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?
g.  Are all transfers of special nuclear material documented by appropriate authorized individuals?
    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?
h.  Are transfer transactions numbered, recorded, and controlled by authorized individuals?
    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?
i.  Are tamper-safing procedures used for effective control of and accounting for special nuclear material?
transfer documents signed by appropriate authorized individuals?                                                            (11) Are tare and net weights determined?
j.  Is access to tamper-safing devices and records controlled?
    h. Are transfer documents prenumbered, controlled,                  (12) Is material sampled and analyzed upon and accounted for?                                                receipt?
k.  Do the tamper-safing procedures include installation of the devices by authorized personnel, and the recording of the date and time of installation, along with the identity of the device and the authorized installer?
    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)?
D-2. Shipping and Receiving Controls
    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?
====a. Receipts====
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?
    (1)      Is receiving of special nuclear material centralized at the facility?
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?
    (2)      Is receiving performed by employees other than those who keep material accounting records?
                                                                        (4) After preparation, is the NRC-741 checked by
    (3)      Is receipt acknowledged and does it require the signature of an authorized person recorded manually (or by electronic means in the case of a computerized system)?
      (1) Is receiving of special nuclear material central ized at the facility?                                            other than the typist, prior to signature?
    (4)      Is a lot or item number assigned on receipt?
      (2) Is receiving performed by employees other                    (5) Are the NRC-741's dispatched on time?
    (5)      Is the material identified by its assigned number on the various materials accounting and production forms?
than those who keep material accounting records?
    (6)      Are copies of receiving reports sent to the materials accounting office:
                                                                        (6) Are there defined procedures for processing
              (a)      Immediately, and (b)      directly?
      (3) Is receipt of material acknowledged in writing        receipted shipping forms returned by the receiver, by authorized employees?                                         including:
                                    Appendix D to RG 5.51, Page D-1
                                                            5.51-10
 
(7)    Are differences in shipper and receiver data identified and investigated?
    (8)    Is the receipt verification performed and documented in the facility records before returning U.S. Department of Energy (DOE)/U.S. Nuclear Regulatory Commission (NRC) Form 741, Nuclear Material Transaction Report, to the shipper?
    (9)     Are the DOE/NRC Form 741s completed by the receiver within the required time?
    (10)   Is an item count made and the gross weight of the material determined on receipt?
    (11)   Are tare (empty) and net weights determined?
    (12)   Is material sampled and analyzed on receipt?
    (13)   Does the receiver take an independent sample (or participate in the shippers sampling)?
 
====b. Shipments====
    (1)     Are written instructions about lots or items to be shipped issued to the shipping department?
    (2)     Is notice of the shipment sent directly to the material accounting office?
    (3)     Is the shipping form, DOE/NRC Form 741, prepared from loading sheets or other data received from the shipping department?
    (4)     After the preparer completes DOE/NRC Form 741, is a copy crosschecked by a second person to confirm the correctness of the data entered?
    (5)     Are DOE/NRC Form 741s dispatched on time?
    (6)     Are there defined procedures for processing receipted shipping documents returned by the receiver, including documented acceptance of the information received by an authorized person?
    (7)    Is the gross weight of material determined before shipment?
    (8)    Is the tare weight of each individual shipping container determined?
    (9)    Are there procedures in use to ensure that the special nuclear material content of each container is valid?
c.   Shipper-Receiver Difference
    (1)    Are there established procedures for detecting and evaluating statistically significant shipper-receiver difference?
    (2)    Do the plant records indicate any significant shipper-receiver difference during the period covered by the review?
    (3)    Were the significant shipper-receiver differences brought to the attention of the appropriate management personnel for evaluation?
    (4)    Are written reports prepared regarding the resolution of significant shipper-receiver differences?
D-3. Scrap and Waste Control


====a. Scrap====
(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?
    (1)     Is scrap classified and identified for purposes of:
employee's initials) that the required work has been                  (8) Is there a program to evaluate and reduce done scrap generation?
            (a)     measurement, and (b)      recovery?
      (7) Is the gross weight of material determined prior to shipment?                                                    (9) Is there a program to evaluate and improve scrap measurements?
    (2)    Is scrap packaged to facilitate accurate measurement?
        (8) Is the tare weight of each individual shipping container determined?                                             
    (3)    What portion of material balance uncertainty for each material type is caused by scrap?
    (4)    What percent of inventory is in scrap?
    (5)    Are there plans and schedules for timely recovery of scrap?
    (6)    Is there evidence of scrap on inventory longer than:
            (a)      6 months, or (b)      12 months?
    (7)     What basis is used for establishing the special nuclear material content of scrap?
                                    Appendix D to RG 5.51, Page D-2
 
(8)     Is there a program to evaluate and reduce scrap generation?
    (9)     Is there a program to evaluate and improve scrap measurements?


====b. Waste====
====b. Waste====
    (1)     Are there procedures to ensure that wastes containing special nuclear material are measured before discard?
        (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?
    (2)     What basis is used to determine the special nuclear material content of wastes?
    c. Shipper-Receiver Differences                                    (2) What basis is used to determine the special nuclear material content of wastes?
    (3)     Are there recording and reporting procedures to ensure that the special nuclear material content of wastes is properly accounted for by:
        (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:
            (a)     process, (b)     material type, and (c)     type of discard?
        (2) Do the plant records indicate any shipper receiver differences during the period covered by the                      (a) MBA
    (4)     Are there fail-safe procedures or devices in use to ensure that significant quantities of special nuclear material cannot be inadvertently discarded?
review?
     (5)     Are there procedures for action in case a significant quantity of special nuclear material is inadvertently discarded?
                                                                          (b) Process
    (6)     Are there procedures or devices to monitor waste streams that normally should not contain special nuclear material?
        (3) Were the shipper-receiver differences brought to the attention of the appropriate management person                    (c) Material type nel for evaluation?
    (7)     Are there continuing studies with respect to process discard residues to:
                                                                            (d) Type of discard
            (a)     establish normal levels, (b)     improve measurements, and (c)     reduce losses?
        (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
    (8)     Are control charts or other series evaluation mechanisms used for routine discard streams?
3. Scrap and Waste Control                                      material cannot be inadvertently discarded?
D-4. Detection of Unauthorized Production and Enrichment for Enrichment Facilities a.   Does the facility have a detection program, independent from production, which provides high assurance of detecting unauthorized production and unauthorized enrichment?
     a. Scrap                                                          (5) Are there procedures for action in case of an inadvertent discard of a significant quantity of special nuclear material?
b.   Have all credible scenarios of unauthorized production or enrichment been identified?
        (1) Is scrap classified and identified for purposes of:
c.  For each scenario, is there a system in place for the timely detection of that scenario?
                                                                        (6) Are there procedures or devices to monitor (a) Measurment                                      waste streams that normally should not contain special nuclear material?
d.   Are indicators of unauthorized production or enrichment investigated and resolved in a timely manner?
            (b) Recovery                                              (7) Are there continuing studies with respect to
D-5. Performance Testing Examples a.  Observe the performance of application and removal of tamper-safing seals.
        (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?
                                                            51-11


b.   Observe the performance of checking and documenting the receipt of shipments.
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?
c.   Observe the performance of controlling, weighing, and documenting shipments.
    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?
d.   Observe the performance of internal transfers of special nuclear material (SNM), including the timeliness of documenting the transfers.
    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?
Appendix D to RG 5.51, Page D-3
    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
                                                      5.51-12


APPENDIX E
APPENDIX E
                            Measurement System Checklist E-1. Measurement Review a.   Based on the planning review of plant procedure manuals and other documents, select those measurement points in the system to be reviewed in more detail. For each such point, prepare a Measurement Point Data Sheet such as the one shown in Annex 1 to this appendix.
                                          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.
b.  For each measurement point selected, review and discuss with the personnel responsible for the measurements the procedures actually used.
 
(1)    Note any deviations from specified procedures or from good practice, along with any reasons for such deviations.
 
(2)    Review available data supporting the precision and accuracy statements associated with each measurement point.
 
c.  Observe analytical laboratory operations and procedures, including contract laboratories, if appropriate, and discuss them with laboratory personnel, as appropriate. An Analytical Laboratory Checklist such as the one shown in Annex 2 to this appendix should be used.
 
d.  Check scales and balances using standard weights and observe their use. A Scale and Balance Checklist such as the one shown in Annex 3 to this appendix should be used.


E-2. Measurement Quality Control a.   Review and discuss the program of standardization and calibration of measurement equipment and analytical procedures with the personnel responsible.
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.


b.   Determine the extent of analytical control programs, participation in analytical exchange programs, validity and care of standards, and frequency of calibration measurement equipment.
(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.


c.  Does the measurement control program include:
(3) Nondestructive measurements
    (1)    sampling,
      (1) Note any deviations from specified procedures or from good practice, along with any reasons for such                (4) Analytical methods deviations.
    (2)    bulk measurement,
    (3)     nondestructive measurements,
    (4)     analytical methods, and
    (5)     use of control charts?
d.  Review Measurement Point Data Sheets, Analytical Laboratory Checklists, and Scale and Balance Checklist for data pertinent to measurement control.


e.  Are the performance trends shown by the control program acceptable?
(5) Use of control charts
f.  Are the frequencies of calibration, standardization, and precision checks acceptable?
      (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.
g.   Are quality control checks made in a representative fashion over time to include different equipment, shifts, and operators?
h.  Are personnel training and qualification programs carried out?
                                  Appendix E to RG 5.51, Page E-1


i.   Are there records and procedures to ensure that only trained and qualified personnel carry out material accounting measurements?
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?
E-3. Performance Testing Examples a.   Observe selected sample-taking and trace the actions performed on transfer of the samples to the analytical laboratory and receipt by the laboratory to ensure that controls of and accounting for the samples transferred are effectively performed.
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.


b.   Select items for nondestructive assay measurement, observe their measurement, evaluate the results against the book values, and evaluate the results to measurement limits of error.
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?
                                                        5.51-13


c.   Select items for weighing, observe their weighing, evaluate the results against the book values, and evaluate the results to measurement limits of error.
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.


Appendix E to RG 5.51, Page E-2
c. Type and size of sample
1. Identify the measurement point by location, MBA,              d. Sampling equipment process, flowchart reference, etc.


APPENDIX E - ANNEX 1 Measurement Point Data Sheet This data sheet should be used to record observations and information regarding the actual functioning of the plants material accounting measurement system. The reviewer should be familiar with the plants written procedures before observing the actual functioning of the system.
e. Special or unique techniques
2. Identify material by type, form, composition, normal quantities, source, use, and disposition.


E1-1.   Identify the measurement point by location, process, flowchart reference, etc.
====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


E1-2.   Identify material by type, form, composition, normal quantities, source, use, and disposition.
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:


E1-3.  Review bulk measurements:
====a. Date of analysis====
a.     Scale, tank volume, or pipeline data;
1. Is the laboratory that performs material accounting analyses independent of the production organization?             
b.      Capacity;
c.      Measurement increment;
d.      Measurement control data;
e.      Calibration procedure and frequency;
f.     Calculation parameters and formulae;
g.      Factor data, including:
        (1)      basis,
        (2)      measured parameters,
        (3)      measurement control data, and
        (4)      frequency of verification.


E1-4.   Review sampling procedures, including:
====b. Analytical results====
a.     portion sampled;
2. Are written requests for analyses submitted to the              c. Identity of:
b.     basis for sampling, e.g., statistical plan, economic criteria, judgment, etc.;
laboratory with the samples?
c.     type and size of sample;
                                                                      (1) Analytical request
d.     sampling equipment;
3. Are special prenumbered forms used for analytical requests?                                                              (2) Sample
e.     special or unique techniques;
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:
f.     compositing; and g.      measurement control data.
    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 to RG 5.51, Page E-3
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.


E1-5. Review analytical procedures, including:
1. Are written calibration and use procedures available?       15. Are weights handled carefully - not slid in place,
a.    Element concentration;
2. Is calibration performed properly and at satisfactory      etc.?
b.    Isotopic concentration;
intervals?
c.    Nondestructive assay;
                                                              16. Are temperature and air current effects taken into
d.    Measurement-control data; and e.    Laboratory, including:
3. Are calibrations traceable to national standards?           consideration in the procedures and in practice?
      (1)    process lab,
4. Are regular inspections, testing, and service per            17. Is proper action taken to correct weighing errors?
      (2)    plant lab, and
formed?
      (3)    contract lab.
                                                              18. Are only approved scales used for material account
 
5. Are inspection stickers on equipment?                      ing?
E1-6. Are the measurement methods at this measurement point appropriate?
6. Is there a training or qualification program for             19. Are scales checked before each use?
                                  Appendix E to RG 5.51, Page E-4
operators and supervisors?
 
                                                                20. Are scales permanently identified?
APPENDIX E - ANNEX 2 Analytical Laboratory Checklist This data sheet should be used to record observations and information regarding the actual functioning of the plants analytical laboratory. The reviewer should be familiar with the written procedures pertinent to the laboratory before observing the actual laboratory operation.
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?
E2-1.  Is the laboratory that performs material accounting analyses independent of the production organization?
                                                                Do these tags show the reason why they are not used
E2-2.   Are requests for analyses submitted to the laboratory identifiable with the samples?
9. Are standards accurate, handled with lifters or gloved      and that calibration is required after repair?
E2-3.  Are special pre-numbered forms used for analytical reasons? For computerized systems, are control numbers used to log samples for analysis?
hands, and kept under cover when not used?
E2-4.   Do the analytical requests include:
                                                                22. Are weights verified by more than one person (or
a.      analysis required;
10. Is the equipment sufficiently accurate for the            printed tape) for shipments, receipts, scrap, etc.?
b.      date of request;
intended use?
c.      identity of requesting unit;
                                                                23. Is responsibility for scale and balance use, mainte
d.      identity of material sampled;
  11. Is the equipment being used within the manufac            nance, and calibration assigned in writing?
e.      identity, description, and quantity of sample;
turer's recommended capacity?
f.     disposition instructions for sample; and g.      reporting instructions for results?
                                                          5.51-16
E2-5.  What record is made of incoming samples:
a.      computerized tracking system, c.      manually prepared card file or log book, d.      analyst assigned, or e.      other?
E2-6.   Are samples permanently and adequately identified?
E2-7.   Are current written analytical procedures available to all appropriate analysts?
E2-8.  Are there written approved procedures for handling changes in analytical procedures?
                                        Appendix E to RG 5.51, Page E-5
 
E2-9.  Is there evidence that the analysts follow:
a.    the written analytical procedures, and b.    the approved change procedures?
E2-10. Is there a standard form for reporting analytical results that includes:
a.    Date of analysis?
b.    Analytical results?
c.    Identity of:
      (1)      analytical request,
      (2)      sample,
      (3)      analytical method, and
      (4)      analyst?
d.    Disposition of sample?
E2-11. Are analytical results retained in the laboratory:
a.    files;
b.    log books; and c.    for the retention period in accordance with 10 CFR Part 74, Material Control and Accounting of Special Nuclear Material.
 
E2-12. Does the laboratory control program include:
a.    disguised samples when appropriate, b.    adequately disguised samples, c.    internal standards, d.    reference standards traceable to national standards, e.    analyst certification, and f.    independent evaluation such as participation in the safeguards analytical laboratory evaluation (SALE) program?
E2-13. Are analytical services obtained from laboratories outside the plants?
E2-14. Are the controls on any such outside analytical services adequate to ensure analytical results acceptable by the criteria of the in-plant analytical program?
                                      Appendix E to RG 5.51, Page E-6
 
APPENDIX E - ANNEX 3 Scale and Balance Checklist This data sheet should be used to record observations and information regarding the actual use, maintenance, and calibration of scales and balances used for material accounting purposes. The reviewer should be familiar with the written procedures pertinent to the scales and balances used for material accounting before observing their actual use.
 
E3-1.  Are written calibration and use procedures available?
E3-2.  Is calibration performed properly and at satisfactory intervals?
E3-3.  Are calibrations traceable to national standards?
E3-4.  Are regular inspections, testing, and service performed?
E3-5.   Are inspection stickers on equipment?
E3-6.   Is there a training or qualification program for operators and supervisors?
E3-7.   Are working standards available and satisfactory?
E3-8.   Are working standards checked? How often?
E3-9.  Are working standards accurate, handled with lifters or gloved hands, and kept under cover when not used?
E3-10. Is the equipment sufficiently accurate for its intended use?
E3-11. Is the equipment being used with the manufacturers recommended capacity?
E3-12. Are control charts or other statistical media maintained for scale and balance precision and accuracy?
E3-13. Is statistical determination of precision and accuracy (weighing limits of error) performed?
E3-14. Are buoyancy corrections made when appropriate?
E3-15. Are weights handled carefully - not slid in place, etc.?
E3-16. Are temperature and air-current effects taken into consideration in the procedures and in practice?
E3-17. Is proper action taken to correct weighing errors?
E3-18. Are only approved scales used for material accounting?
E3-19. Are scales checked before each use?
E3-20. Are scales permanently identified?
                                        Appendix E to RG 5.51, Page E-7
 
E3-21. Are tags applied to scales that are out of order? Do these tags show the reason why the scales should not be used and that calibration is required after repair?
E3-22. Are weights verified by more than one person (or printed tape) for shipments, receipts, scrap, etc.?
E3-23. Is responsibility for scale and balance use, maintenance, and calibration assigned in writing?
                                      Appendix E to RG 5.51, Page E-8


APPENDIX F
APPENDIX F
                                  Statistical Controls Checklist F-1. Review any information recorded by the measurement system reviewer that is pertinent to the statistical controls of that system, including:
                                          Statistical Controls Checklist
a.   scale and balance calibration and measurement-control data, b.   sampling control data, and c.   analytical or non-destructive assay (NDA) measurement control data.
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:
F-2. Are the data used for estimating bias and for determining error variances and limits of systematic errors of measurement:
                                                              10. Are there routine procedures for investigating a. Scale and balance calibration and measurement           excessive MUF?
a.   generated by statistically valid procedures, b.   sufficient in quality and quantity, and c.   collected using procedures that ensure accuracy and completeness?
control data
F-3. Are the data-handling and calculational procedures used to determine measurement precision and accuracy statistically valid and appropriate?
                                                              11. What evidence is there that such procedures have b. Sampling control data                                   been used?
F-4. Are calibration data used appropriately in estimating measurement bias and the limits of systematic errors?
    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?
F-5. Are sampling precision and accuracy based on statistically valid sampling plans and studies?
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?
F-6. Are replication program data used appropriately for determination of random errors?
    a. Generated by statistically valid procedures             14. Are there routine procedures for evaluating shipper receiver differences?
F-7. Are data-handling and calculational procedures used to determine inventory difference (ID) and the limit of ID statistically valid and appropriate?
    b. Sufficient in quality and quantity
F-8. Are data-handling and calculational procedures used to determine the limits of error of the physical inventory valid and appropriate?
                                                              15. Do these procedures include valid statistical tech c. Collected by procedures to ensure accuracy and         niques for evaluating shipper-receiver differences by:
F-9.  Can the ID be localized to a specific area? Can the ID be localized to a specific process within an area?
completeness
F-10. Are there routine procedures for investigating excessive ID?
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
F-11. What evidence is there that such procedures have been used?
4. Are calibration data used appropriately in estimating measurement bias and limits of systematic errors?
F-12. Are valid statistical techniques employed to evaluate ID on a series, as well as on an individual basis?
                                                              16. Do these procedures include the use of control
F-13. Do such techniques include the use of control charts?
5. Are sampling precision and accuracy based on statis        charts?
                                      Appendix F to RG 5.51, Page F-1
tically valid sampling plans and studies?
 
                                                              17. Is there evidence that these procedures have been
F-14. For process monitoring at Category I fuel cycle facilities, evaluate the status of abrupt alarms.
6. Are replication program data used appropriately for       used?
 
determination of random errors?
a.    Determine the adequacy of the frequency of abrupt alarms.
                                                              18. Is there evidence that significant shipper-receiver
 
7. Are the data-handling and calculational procedures         differences have been investigated and reconciled?
b.    Are abrupt alarm thresholds and number of false alarms statistically in sync?
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
c.    Is the alarm threshold smaller or larger than the three-sigma limit?
8. Are the data-handling and calculational procedures         control purposes?
d.    Are there a large number of three-sigma indicators?
used to determine the limits of error of the physical inventory statistically valid and appropriate?               20. Are data retained for five years?
F-15. Evaluate alarm resolution and three-sigma and trend testing.
                                                        5.51-17
 
a.    Are licensee decision rules for alarm resolution adequate and are they followed in resolving alarms?
b.    Determine the significance of trends and/or whether alarm threshold models for each control unit are reasonable.
 
c.    Do any of the alarms give indication of excessive process variation or improper modeling?
F-16. Evaluate the item monitoring program.
 
a.    For Category I fuel cycle facilities, does the item monitoring program provide the detection capabilities required?
b.    For all other fuel cycle facilities, do the item monitoring activities ensure current knowledge of items?
F-17. Are there routine procedures for evaluating shipper-receiver differences?
F-18. Do these procedures include valid statistical techniques for evaluating shipper-receiver difference by:
a.    individual shipment, b.    shipment series, and c.    individual lot or container?
F-19. Do these procedures include the use of control charts?
F-20. Is there evidence that these procedures have been used?
F-21. Is there evidence that significant shipper-receiver differences have been investigated and reconciled?
F-22. Are results from statistical evaluations made available to management and operating personnel for control purposes?
F-23. Are data retained in accordance with appropriate requirements in 10 CFR Part 74, Material Control and Accounting of Special Nuclear Material?
                                      Appendix F to RG 5.51, Page F-2
 
F-24. Performance Testing Examples a.    Observe and evaluate the collection data and its use in estimating bias and determining error variances and limits of systematic errors of measurement.
 
b.    Observe the process and evaluate the rationale used in preparing control charts.
 
c.    Observe the performance of supervisory review of key elements of the program.
 
Appendix F to RG 5.51, Page F-3


APPENDIX G
APPENDIX G
                                    Physical Inventory Checklist This checklist should be used to record observations and information regarding conduct of physical inventories. For any parts of the inventory to be observed, the reviewer should be familiar with the plants general inventory procedures and the specific instructions under which the inventory is being conducted.
                                          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.


G-1.   Was the inventory based on measured quantities?
a. Review of instructions by inventory personnel
G-2.   Was the inventory a shutdown/cleanout type, a dynamic type, or a combination thereof?
1. Was the inventory based on measured quantities?
G-3.   Was measurement information based on:
                                                                  b. Tour of areas by teams
a.     prior measurements ensured through item identification and tamper-safing, b.     uniquely identified sealed sources, c.     prior measurements verified by remeasureing, d.     measurements made during the inventory, and e.     factors or calculated values? If factors were used, were the factors determined on the basis of measurement, their continued validity monitored through a measurement-control program, and the limits of error of the factors determined from the measurement-control programs data? If calculated values were used, were they based on completely known and measured components?
2. Was the inventory a shutdown, cleanout type; a dynamic type; or a combination thereof?                           c. Preliminary inspection by inventory supervisor
G-4.   Were sufficient data available to determine the limits of error for the inventory?
3. Was measurement information based on:                     10. Were there any deviations from the written instruc a. Prior measurements ensured through item identifi        tions?
G-5.   Were the measurements and measurement controls adequate to establish the quantity of material on inventory within valid limits of uncertainty?
cation and tampersafing                                      11. Were such deviations approved by the inventory supervisor?
G-6.    Were proper cutoff procedures used for:
    b. Uniquely identified sealed sources
a.      internal transfers, b.      shipments and receipts, c.      records, and d.      processing?
                                                                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?
G-7.    Was one person assigned overall responsibility for the inventory?
    d. Measurements made during the inventory
G-8.    Were written inventory instructions issued to:
                                                                13. Were the various areas prepared for the inventory in e. Factors or calculated values. If factors were used,     that:
a.      the inventory teams, and b.      other appropriate operating personnel?
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
                                        Appendix G to RG 5.51, Page G-1
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
G-9.  Did inventory orientation include:
5. Were the measurements and measurement controls             accurate manner?
a.    review of instructions by inventory personnel, b.    tours of areas by team members unfamiliar with area activities, and c.    preliminary inspection by an inventory supervisor?
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
G-10. Were there any deviations from the written instructions?
6. Were proper cutoff procedures used for:                    items were located?
G-11. Were such deviations approved by the inventory supervisor?
    a. Internal transfers                                      16. Were there procedures to ensure that all items and material were listed once and only once?
G-12. Were the various areas prepared for the inventory in that:
    b. Shipments and receipts
a.    material was arranged to expedite inventory, b.    process conditions were arranged so that quantities in difficult-to-measure locations were at a minimum, and c.    items were properly labeled and identified?
                                                                17. Was the physical inventory in agreement with the c. Records                                                custodian's record inventory?
G-13. Was the inventory taken in a systematic and accurate manner?
    d. Processing                                              18. If there were differences, were appropriate actions taken to explain, investigate, and reconcile them?
G-14. Were inventory lists prepared from listing items from the floor or were prelisted items checked off as items were located?
7. Was one person assigned overall responsibility for the inventory?                                                      19. Were the results of the physical inventory reflected in the material accounting records?
G-15. Were there procedures to ensure that all items, material, and locations were listed once and only once?
8. Were written inventory instructions issued to:
G-16. Was the physical inventory in agreement with the book inventory?
                                                              20. Was the inventory conducted within the required a. The inventory teams                                    frequency interval?
G-17. If there were differences, were appropriate actions taken to explain, investigate, and reconcile them?
                                                        5.51-18
G-18. Were the results of the physical inventory reflected in the material accounting records?
G-19. Was the inventory conducted within the required frequency interval?
G-20. Performance Testing Examples a.    Select specific inventory items from inventory data and investigate whether all data elements in the records are in agreement with corresponding data revealed by physical examination of the items on the floor.
 
b.    Observe and evaluate the acceptability of the process for taking in-process inventory.
 
c.    Observe performance of the inventory, if possible.
 
Appendix G to RG 5.51, Page G-2


APPENDIX H
APPENDIX H
                              Records and Reports Checklist H-1. Is the plant material accounting system designed so that it will clearly delineate the responsibility for the materials?
                                        Records and Reports Checklist
H-2.  Are double-entry records maintained?
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?
H-3.  Are records maintained of:
2. Are double entry records maintained?                      9. Is there a system for controlling and accounting for all such forms?
a.    material added to, and removed from, the process;
3. Are subsidiary accounts maintained for each MBA
b.    the quantity of material in process at any given time;
and ICA?                                                       10. Are all special nuclear material accounting measure ment data routinely reported to the material accounting
c.    identity and location of items and containers containing special nuclear material; and d.    source and disposition of items containing special nuclear material?
4. Are subsidiary accounts periodically reconciled to          office?
H-4.  Are control accounts periodically reconciled and adjusted to the results of physical inventories?
control accounts?
H-5.  Is there written approval by authorized individuals for all adjustments to:
                                                                11. Are such measurement data reported on standard
a.    control accounts, and b.    perpetual inventory records?
5. Are records maintained of:                                  approved forms that adequately identify the material to which the measurement data apply?
H-6.  Are standard approved forms or their computerized equivalents used to record all adjustments to the records, including the reason for the adjustment?
    a. Material added to, and removed from, the process
H-7. Is there a system for controlling and accounting for all such paper forms used? If a computerized system is used, have acceptable transaction controls been programmed into the software?
                                                                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?
H-8. Are all special nuclear material accounting measurement data routinely reported to the material accounting office?
time
H-9. Are such measurement data reported on standard approved forms that adequately identify the material to which the measurement data apply?
                                                                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:
H-10. Are such measurement data used appropriately in preparation of material accounting records and reports?
    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
H-11. Have the required Material Status Reports (U.S. Department of Energy (DOE)/U.S. Nuclear Regulatory Commission (NRC) Forms 742, Material Balance Report, and 742C, Physical Inventory Listing) and Nuclear Material Transaction Reports (DOE/NRC Forms 741, Nuclear Material Transaction Report, and 740M, Concise Note) been:
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
a.   prepared and submitted in the required time, b.   prepared accurately and according to approved plant procedures, and Appendix H to RG 5.51, Page H-1
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?
 
c.   verified to be accurate by a member of the material accounting staff other than the original preparer?
H-12. Performance Testing Examples a.    Examine book adjustments for the assessment period, identify representative adjustments, and interview all parties to the transactions in order to evaluate the process followed in each step;
      observe and evaluate any book adjustment made during the review.
 
b.   Discuss with software representatives the computer logic used in selecting records and generating certain reports used by the accounting office as a way of evaluating whether the correct records were used in report generation; also, have a test conducted to illustrate the accuracy of the report-generation process.


c.   If a software change is made during the assessment, determine whether at least one other person participated in the review of coding and testing of the change.
====b. Subsidiary accounts====
 
                                                              15. Is there a system for controlling and accounting for c. Perpetual inventory records                            all such forms?
Appendix H to RG 5.51, Page H-2
                                                        5.51-19


APPENDIX I
APPENDIX I
                                              Audit Program In addition to the specific topical areas described in the preceding appendices, the following audit steps cover the remaining general areas of interest.
                                                  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.


I-1.     Planning the Audit I-1.1    Document Review a.       Review documents and contracts as indicated in the Assessment Program Checklist. Note items pertinent to records and reports examination.
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.


b.       Review plant reports for:
At initial meetings with plant personnel:
        (1)     date and proper signature or authorized computerized equivalent;
    b. Review plant reports (or suspense file notes) for:
        (2)     proper form, including subschedules;
                                                                  a. Discuss information developed in audit planning
        (3)     basis for inventory;
        (1) Date and proper signature b. Review audit plans where necessary
        (4)     explanation of ID; and
        (2) Proper form, including subschedules c. Discuss any changes in plant procedures that affect
        (5)     timely receipt.
        (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.


c.       Review receiving and shipping documents for preparation and issuance in accordance with requirements and regulations.
d. Review backup documents and authorizations for measured discards.                                            3. Receipts e. Prepare notes in workpapers on specific items to            a. Procurement investigate.


d.       Review backup documents and authorizations for measured discards.
(1) Using invoices as bases, trace quantities to
2. Procedure Manuals and Internal Control                    permanent records.


e.       Prepare notes on specific items to investigate.
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.


I-1.2    Procedure Manuals and Internal Control a.       Review procedure manuals, Internal Control Checklist, and associated documents to become reacquainted with facility records and reports.
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.


b.       Prepare notes on specific items to be investigated.
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.


I-1.3    Trial Balances a.      Select the categories of material balance data: external receipts, external shipments, and inventory adjustments (losses, measured discards, and inventory difference) by reporting identification symbol (RIS) (if more than one are used), contract number, material type, and date.
(RIS), contract number, material type, and date.


b.       Using the categories of material balance data, prepare pro-forma trial balance and examine for unusual balances.
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.


I-1.4   Sampling Plans Prepare master data sheet and sampling plans for audit test to be performed on statistical sampling basis.
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 established before the assessment by using data from prior assessments and reports and general knowledge of the plant.
Preliminary plans and sampling plan criteria can be           Use statistical sampling plans where appropriate.


Appendix I to RG 5.51, Page I-1
5.51-20


I-2.    Conducting the Audit I-2.1   Initial Meetings At the initial meeting with plant personnel:
4. Removals                                                      Check bases of transfer and reconcile with corollary account under "Receipts" (see 3b above).
a.       Discuss information developed in audit planning.
     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.


b.      Review audit plans where necessary.
(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.


c.       Discuss any changes in plant procedures that affect records and reports.
(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.


d.      Arrange for necessary assistance and availability of records and reports.
ate.


I-2.2    Review of Ledgers Review general and subsidiary ledgers and list and investigate any unusual items occurring in journal vouchers or posting media.
c. Review internal transfer documents for propriety
      (5) Check footings, extensions, and descriptions and numerical sequence of intra-area transfer forms.


I-2.3    Receipts
of data on source documents to ascertain correctness and propriety of data.                                             d. Reconcile records of internal transfers to books of final entry.
 
====a. Procurement====
        (1)      Using invoices as bases, trace quantities to permanent records.
 
(2)      Test internal data supporting receipts (e.g., receiving reports and measurement results),
                  using statistical samples where appropriate.
 
(3)      Review purchase orders and payment vouchers to determine whether quantities of material purchased are consistent with invoices.
 
(4)      Select data on a statistical sampling basis to verify accurate calculations of extensions, footings and postings of invoices and/or other documents supporting quantities procured.
 
b.      Other Source and Special Nuclear Material Categories Check the bases of transfer and reconcile with the corollary account under Removals (see I-2.4 below).
c.      U.S. Nuclear Regulatory Commission (NRC) Transfer Documents Test-check postings of U.S. Department of Energy (DOE)/NRC Form 741, Nuclear Material Transaction Report, to the records. Use statistical sampling plans where appropriate.
 
I-2.4    Removals a.      Measured Discards, Losses, and Inventory Differences
        (1)      Select data from material balance reports and generate schedules of each account for the survey period.
 
(2)      Trace schedules to ledgers.
 
(3)      Examine supporting evidence for posting documents.
 
(4)      Test-check posting of source documents to ledgers, using statistical sampling plans where appropriate.
 
(5)      Check footings, extensions, and descriptions of data on source documents to ascertain correctness and propriety of data.
 
Appendix I to RG 5.51, Page I-2


====b. Sales====
====b. Sales====
        (1)      Check sales authorizations.
(2)      Check sales slip and/or invoice quantities to ledgers.
(3)      Check footings, extensions, etc., of posting documents.
(4)      Trace postings to ledgers.
c.      Decay Check calculations on the basic posting documents and trace postings to records.
d.      Other Source and Special Nuclear Material Categories Check bases of transfer and reconcile with corollary account under Receipts (see I-2.3 above).
e.      NRC Transfer Documents Test-check postings of DOE/NRC Form 741 to the records. Use statistical sampling plans where appropriate.
I-2.5    Internal Transfers a.      Trace documents supporting internal transfers (e.g., production notes, laboratory reports, weight tallies, and transfer forms) to records.


b.       Check footings, postings, and extensions of intra-area supporting documents.
===6. Measurement Records===
      (1) Check sales authorizations.


c.      Review internal transfer documents for propriety and numerical sequence of intra-area transfer forms.
Trace on a selected basis, using statistical sampling
      (2) Check sales slips and/or invoice quantities to    plans when appropriate:
ledgers.


d.       Reconcile records of internal transfers to books of final entry.
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.


I-2.6    Measurement Records Trace on a selected basis, using statistical sampling plans when appropriate:
c. Extensions, footings, and descriptions, as appli c. Decay                                                  cable Check calculations on the basic posting documents        7. Findings and trace postings to records.
a.      quantities from records to laboratory workbooks;
b.      results in laboratory workbooks to quantities in records; and c.       extensions, footings, and descriptions, as applicable.


I-2.7    Performance Testing Examples Observe the transfer of DOE/NRC Form 741 data to the Nuclear Materials Management and Safeguards System (NMMSS), and evaluate the effectiveness of actions taken by staff to ensure that the facility maintains agreement between its own data and data submitted to the NMMSS.
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.


I-2.8    Findings Summarize findings to be discussed with other team members, facility personnel, and management and included in the report.
5.51-21


Appendix I to RG 5.51, Page I-3}}
UNITED STATES
NUCLEAR REGULATORY COMMISSION
    WASHINGTON, D. C. 20555 POSTAGE AND FEES PAID
                                  UNITED STATES NUCLEAR
        OFFICIAL BUSINESS          REGULATORY COMMISSION
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Latest revision as of 10:47, 28 March 2020

Management Review of Nuclear Material Control & Accounting Systems
ML003739225
Person / Time
Issue date: 06/30/1975
From:
Office of Nuclear Regulatory Research
To:
References
RG-5.51
Download: ML003739225 (22)


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.

b. Sales

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