ML20210T087: Difference between revisions

From kanterella
Jump to navigation Jump to search
(StriderTol Bot insert)
 
(StriderTol Bot change)
 
Line 17: Line 17:


=Text=
=Text=
{{#Wiki_filter:..          _______ ______ __
{{#Wiki_filter:.
                                                                ,f"''
,f"''
e                       u 5                         3 December 24, 1986                                                           SECY-86-380 RULEMAKING ISSUE (Affirmation)
e u
For:                 The Commissioners From:               Victor Stello, Jr.
5 3
December 24, 1986 SECY-86-380 RULEMAKING ISSUE (Affirmation)
For:
The Commissioners From:
Victor Stello, Jr.
Executive Director for Operations
Executive Director for Operations


Line 28: Line 32:
==Purpose:==
==Purpose:==
To obtain approval to publish the enclosed amendments to 10 CFR Part 74 as a final rule which would replace the material control and accounting (MC&A) requirements for fuel cycle facilities licensed to possess and use formula quantities of strategic special nuclear material (SSNM), except irradiated fuel reproces-sing plants.
To obtain approval to publish the enclosed amendments to 10 CFR Part 74 as a final rule which would replace the material control and accounting (MC&A) requirements for fuel cycle facilities licensed to possess and use formula quantities of strategic special nuclear material (SSNM), except irradiated fuel reproces-sing plants.
Category:           Major policy issue Discussion:         Background. Current domestic MC&A regulations for SSNM focus on bimonthly inventories as the principal indicator of material status. The usefulness of these inventories in providing assur-ance that significant quantities of SSNM have not been diverted has been limited by the difficulty encountered in conclusively resolving large inventory differences. This inability to resolve large discrepancies has necessitated reliance instead on material control records, physical security records, and intelligence information for the desired assurance.
Category:
Improvements to nuclear material accounting requirements were explicitly directed by Congress in NRC's Authorization Act for 1980 and the Appropriation Bill for 1981. On August 20, 1981, in response to SECY-81-432, the Commission approved the publication of an Advance Notice of Proposed Rulemaking (ANPRM) to solicit public comment on how to refocus the MC&A regulations for SSNM.
Major policy issue Discussion:
This Notice was published in the Federal Register on September 10, 1981 (46 FR 45144) and included a statement of rulemaking goals and five options for achieving the goals. The primary goals included: (1) timely and localized detection of a possible mate-rial loss, (2) rapid determination of whether an actual loss
Background.
Current domestic MC&A regulations for SSNM focus on bimonthly inventories as the principal indicator of material status.
The usefulness of these inventories in providing assur-ance that significant quantities of SSNM have not been diverted has been limited by the difficulty encountered in conclusively resolving large inventory differences.
This inability to resolve large discrepancies has necessitated reliance instead on material control records, physical security records, and intelligence information for the desired assurance.
Improvements to nuclear material accounting requirements were explicitly directed by Congress in NRC's Authorization Act for 1980 and the Appropriation Bill for 1981.
On August 20, 1981, in response to SECY-81-432, the Commission approved the publication of an Advance Notice of Proposed Rulemaking (ANPRM) to solicit public comment on how to refocus the MC&A regulations for SSNM.
This Notice was published in the Federal Register on September 10, 1981 (46 FR 45144) and included a statement of rulemaking goals and five options for achieving the goals.
The primary goals included: (1) timely and localized detection of a possible mate-rial loss, (2) rapid determination of whether an actual loss


==Contact:==
==Contact:==
C. Emeigh, NMSS 42-74769
C. Emeigh, NMSS 42-74769 W DD
_ ____ _ ____                      _        __                                        W DD


m .4 The Commissioners                                               occurred, and (3) ready availability of information to aid in the recovery of material in the event of an actual loss.     Two of the     -
m.4 The Commissioners
options for achieving these goals retained the current emphasis on periodic physical inventories. The other options introduced requirements for more timely use of process monitoring information for safeguards purposes and de-emphasized the importance and fre-quency of physical inyt.ntories.
* occurred, and (3) ready availability of information to aid in the recovery of material in the event of an actual loss.
Respondents to the ANPRM in some instances expressed reservations on the use of process monitoring information for safeguards pur-poses because of a lack of demonstrable evidence that it could be applied successfully, but they did not propose alternative MC&A improvements. Based on the comments received and on continuing technical studies, a decision was made to proceed with a proposed rule. The proposed rule that was forwarded to the Commission for publication included much of the substance of Options 3 and 4 of the ANPRM, rewritten to: (1) delete unnecessarily prescriptive requirements, (2) reduce the number of plans and programs required, (3) improve clarity, (4) incorporate certain capabilities to pro-tect against inside adversaries, and (5) provide flexibility for licensees to select the most cost-effective ways for achieving performance objectives. The proposed rule (SECY-83-83 dated February 25, 1983) was published in the Federal Register on February 2, 1984 (49 FR 4091). Public comments were requested by June 5, 1984, but at the request of interested parties, the time period was extended to September 5, 1984.
Two of the options for achieving these goals retained the current emphasis on periodic physical inventories.
Comments were received from four licensees and the Department of State which coordinated comments from the Executive Branch. The Department of State pointed out that since the International Atomic Energy Agency (IAEA) did not have experience with process and item monitoring concepts in their verification activities, it was not possible to judge the extent to which IAEA safeguards requirements would be met by the proposed regulations. After due consideration of this point, it was concluded that the proposed requirement for semiannual inventories would satisfy IAEA needs.
The other options introduced requirements for more timely use of process monitoring information for safeguards purposes and de-emphasized the importance and fre-quency of physical inyt.ntories.
The licensees raised several substantive technical issues that resulted in changes in the final amendments. These are discussed in detail in the Federal Register Notice (Enclosure A). Some comments did not result in changes to the proposed ule. Gener-ally those comments were based on a misinterpretation of the pro-posed amendments. Additionally, there were comments on the Standard Format / Acceptance Criteria document, the Regulatory Analysis, and the rulemaking process. Comments on the Standard Format / Acceptance Criteria were taken into account in the current version of the document. Comments on the Regulatory Analysis and the rulemaking process are addressed in the Federal Register Notice.
Respondents to the ANPRM in some instances expressed reservations on the use of process monitoring information for safeguards pur-poses because of a lack of demonstrable evidence that it could be applied successfully, but they did not propose alternative MC&A improvements.
Based on the comments received and on continuing technical studies, a decision was made to proceed with a proposed rule.
The proposed rule that was forwarded to the Commission for publication included much of the substance of Options 3 and 4 of the ANPRM, rewritten to:
(1) delete unnecessarily prescriptive requirements, (2) reduce the number of plans and programs required, (3) improve clarity, (4) incorporate certain capabilities to pro-tect against inside adversaries, and (5) provide flexibility for licensees to select the most cost-effective ways for achieving performance objectives.
The proposed rule (SECY-83-83 dated February 25, 1983) was published in the Federal Register on February 2, 1984 (49 FR 4091). Public comments were requested by June 5, 1984, but at the request of interested parties, the time period was extended to September 5, 1984.
Comments were received from four licensees and the Department of State which coordinated comments from the Executive Branch.
The Department of State pointed out that since the International Atomic Energy Agency (IAEA) did not have experience with process and item monitoring concepts in their verification activities, it was not possible to judge the extent to which IAEA safeguards requirements would be met by the proposed regulations.
After due consideration of this point, it was concluded that the proposed requirement for semiannual inventories would satisfy IAEA needs.
The licensees raised several substantive technical issues that resulted in changes in the final amendments.
These are discussed in detail in the Federal Register Notice (Enclosure A).
Some comments did not result in changes to the proposed ule.
Gener-ally those comments were based on a misinterpretation of the pro-posed amendments.
Additionally, there were comments on the Standard Format / Acceptance Criteria document, the Regulatory Analysis, and the rulemaking process.
Comments on the Standard Format / Acceptance Criteria were taken into account in the current version of the document.
Comments on the Regulatory Analysis and the rulemaking process are addressed in the Federal Register Notice.


                                                                                                    )
The Commissioners With the publication of the Low Enriched Uranium Reform Amendments in 1985, a new Part 74 was created for MC&A requirements to separ-ate them from the safety. requirements in Part 70 and to present the requirements in an orderly format. Consistent with the objec-tive of codifying all MC&A requirements in Part 74, requirements proposed as 65 70.81 through 70.89 have been redesignated as 65 74.51 through 74.59 in the final rule. The MC&A requirements that will remain in SS 70.51, 70.57 and 70.58 will apply only to strategic special nuclear material in irradiated fuel reprocessing i
  ..                                                                                                i The Commissioners                                                     With the publication of the Low Enriched Uranium Reform Amendments in 1985, a new Part 74 was created for MC&A requirements to separ-ate them from the safety. requirements in Part 70 and to present the requirements in an orderly format. Consistent with the objec-tive of codifying all MC&A requirements in Part 74, requirements proposed as 65 70.81 through 70.89 have been redesignated as 65 74.51 through 74.59 in the final rule. The MC&A requirements that will remain in SS 70.51, 70.57 and 70.58 will apply only to strategic special nuclear material in irradiated fuel reprocessing         i plants, special nuclear material of moderate strategic significance,       '
plants, special nuclear material of moderate strategic significance, and special nuclear material of low strategic significance possessed by licensees whose authorized possession does not require submission of an MC&A plan.
and special nuclear material of low strategic significance possessed by licensees whose authorized possession does not require submission of an MC&A plan.         In the future, performance-oriented MC&A require-ments for these classes of licensees will be added to Part 74.
In the future, performance-oriented MC&A require-ments for these classes of licensees will be added to Part 74.
Summary of Amendments. These final amendments implement the fol-lowing major changes to the current MC&A ragulations for SSNM.
Summary of Amendments. These final amendments implement the fol-lowing major changes to the current MC&A ragulations for SSNM.
o         Timely alarms will be generated for anomalies potentially indicative of SSNM losses through the use of production and quality control data for MC&A purposes, o         The ability to conclusively resolve MC&A alarms will be enhanced by decreasing the processing area and material quantity subject to an alarm, the number of persons who potentially could provide information about the cause of an alarm, and the length of time between a loss (or mistake) and its detection and resolution, o         The detection goal for abrupt losses from each unit process will be a formula quantity as defined in 5 73.2(bb).
o Timely alarms will be generated for anomalies potentially indicative of SSNM losses through the use of production and quality control data for MC&A purposes, o
!                      o         Alarm resolution decision criteria will be based on an assess-ment of whether interruption of processing activities would facilitate rapid resolution of a localized alarm.
The ability to conclusively resolve MC&A alarms will be enhanced by decreasing the processing area and material quantity subject to an alarm, the number of persons who potentially could provide information about the cause of an alarm, and the length of time between a loss (or mistake) and its detection and resolution, o
o         The MC&A system design will be required to include protection against a specifically identified threat from an insider, o         The total variance of inventory difference (ID), rather than just the variance of ID due to measurement uncertainty, will be permitted to be used in ID evaluation.
The detection goal for abrupt losses from each unit process will be a formula quantity as defined in 5 73.2(bb).
i o         Statistical terminology that is not in general use in the statistical community, a principal criticism of current requirments, will be eliminated.
o Alarm resolution decision criteria will be based on an assess-ment of whether interruption of processing activities would facilitate rapid resolution of a localized alarm.
l                     o         The frequency of physical inventories will be reduced from l                                 bimonthly to semiannual.
o The MC&A system design will be required to include protection against a specifically identified threat from an insider, o
The total variance of inventory difference (ID), rather than just the variance of ID due to measurement uncertainty, will be permitted to be used in ID evaluation.
i o
Statistical terminology that is not in general use in the statistical community, a principal criticism of current requirments, will be eliminated.
l o
The frequency of physical inventories will be reduced from l
bimonthly to semiannual.
l
l


The Comissionars                                               ;
The Comissionars ;
Costs and Benefits. The rule will affect four high enriched
Costs and Benefits. The rule will affect four high enriched uranium fuel processing facilities.
;.                                                                  uranium fuel processing facilities. It will also apply to new high enriched uranium and plutonium conversion and fabrication facilities if such facilities are licensed in the future.
It will also apply to new high enriched uranium and plutonium conversion and fabrication facilities if such facilities are licensed in the future.
The cost / benefit analysis summarized in the Regulatory Analysis i                                                                 (Enclosure C) shows that the amendments will be cost-effective for
The cost / benefit analysis summarized in the Regulatory Analysis i
:                                                                  the affected licensees. This will be accomplished by eliminating current requirements that are not cost-effective and by taking advantage of existing process, production, and quality control information for enhancing safeguards capabilities. Implementation costs for the entire industry are estimated to be on the order of
(Enclosure C) shows that the amendments will be cost-effective for the affected licensees. This will be accomplished by eliminating current requirements that are not cost-effective and by taking advantage of existing process, production, and quality control information for enhancing safeguards capabilities.
                                                                  $2.5M. These costs will be recovered in two to nine years, deperd-ing upon the facility type, through reductions in annual operating costs.
Implementation costs for the entire industry are estimated to be on the order of
$2.5M. These costs will be recovered in two to nine years, deperd-ing upon the facility type, through reductions in annual operating costs.
It should be noted that staff considered the fact that only four facilities will be affected by this rule, and the rule's major provisions could be readily implemented through license amendments.
It should be noted that staff considered the fact that only four facilities will be affected by this rule, and the rule's major provisions could be readily implemented through license amendments.
However, in view of the guidance provided by the NRC legal staff that new requirements of general applicability should be imposed by rule rather than order and the benefit to applicants of having currently applicable MC&A regulations in-place during the facility design stage, the decision was made to continue with a rulemaking.
However, in view of the guidance provided by the NRC legal staff that new requirements of general applicability should be imposed by rule rather than order and the benefit to applicants of having currently applicable MC&A regulations in-place during the facility design stage, the decision was made to continue with a rulemaking.


== Conclusion:==
==
The staff finds that the proposed amendments accomplish the objec-                 '
Conclusion:==
tive of upgrading material control and accounting for strategic special nuclear material consistent with .its strategic significance without creating a technically complex program that is heavily burdensome on the industry.
The staff finds that the proposed amendments accomplish the objec-tive of upgrading material control and accounting for strategic special nuclear material consistent with.its strategic significance without creating a technically complex program that is heavily burdensome on the industry.
Recommendation. That the Comission:                                                 !
Recommendation. That the Comission:
)                                                                 1. Approve the amendments and authorize publication of Enclo-sure A in the Federal Register as a final rule, to become effective 30 days after publication.
)
: 2. Certify, in order to satisfy the requirements of the Regulatory l                                                                       Flexibility Act, 5 U.S.C. 605(b), that this rule will not have l                                                                       a significant economic impact on a substantial number of small i
1.
Approve the amendments and authorize publication of Enclo-sure A in the Federal Register as a final rule, to become effective 30 days after publication.
2.
Certify, in order to satisfy the requirements of the Regulatory l
Flexibility Act, 5 U.S.C. 605(b), that this rule will not have l
a significant economic impact on a substantial number of small i
entities. This certification is included in the Federal Register Notice.
entities. This certification is included in the Federal Register Notice.
: 3. Note:
3.
l                                                                       a. That the appropriate Congressional comittees will be notified of this Comission action.
Note:
l                                                                       b. That the Comission has determined under the National
l a.
:                                                                              Environmental Policy Act of 1969, as amended, and the l                                                                             Comission's regulations in Subpart A of 10 CFR Part 51, i
That the appropriate Congressional comittees will be notified of this Comission action.
l b.
That the Comission has determined under the National Environmental Policy Act of 1969, as amended, and the l
Comission's regulations in Subpart A of 10 CFR Part 51, i
f
f


'  The Commissienzrs                                                       that this rule, if adopted, is not a major Federal action significantly affecting the quality of the human environ-ment and therefore an environmental impact statement is not required.
The Commissienzrs that this rule, if adopted, is not a major Federal action significantly affecting the quality of the human environ-ment and therefore an environmental impact statement is not required.
: c. That the Chief Counsel for Advocacy of Small Business Administration will be informed of the certification and the reason for it as required by the Regulatory Flexibility Act.
c.
: d. That a public announcement will be issued when the amendments are filed with the Office of the Federal Register.
That the Chief Counsel for Advocacy of Small Business Administration will be informed of the certification and the reason for it as required by the Regulatory Flexibility Act.
: e. That copies of this notice will be distributed to affected licensees and other interested parties by the Office of Administration,
d.
: f. That copies of the Regulatory Analysis and the Standard Format / Acceptance Criteria guide have been placed in the' NRC Public Document Room.
That a public announcement will be issued when the amendments are filed with the Office of the Federal Register.
: g. That this final rule amends information collection requirements that are subject to the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.). These require-ments were approved by the Office of Management and Budget approval numbers 3150-0009 for Part 70 and 3150-0123 for Part 74.
e.
: h. That ACRS decided to take no action on the rule.
That copies of this notice will be distributed to affected licensees and other interested parties by the Office of Administration, f.
: i. That the final rule and associated guidance will resolve deficiencies in the current MC&A rules that were iden-tified in the information report (SECY 80-514) on the Statistical Treatment of Inventory Differences.
That copies of the Regulatory Analysis and the Standard Format / Acceptance Criteria guide have been placed in the' NRC Public Document Room.
g.
That this final rule amends information collection requirements that are subject to the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.).
These require-ments were approved by the Office of Management and Budget approval numbers 3150-0009 for Part 70 and 3150-0123 for Part 74.
h.
That ACRS decided to take no action on the rule.
i.
That the final rule and associated guidance will resolve deficiencies in the current MC&A rules that were iden-tified in the information report (SECY 80-514) on the Statistical Treatment of Inventory Differences.
Victor Stello, Jr.
Victor Stello, Jr.
Executive Director for Operations
Executive Director for Operations


==Enclosures:==
==Enclosures:==
 
A.
A. Proposed Federal Register Notice B. Standard Format / Acceptance Criteria C. Regulatory Analysis D. Oraft Public Announcement
Proposed Federal Register Notice B.
Standard Format / Acceptance Criteria C.
Regulatory Analysis D.
Oraft Public Announcement


6'
6'
.o Commissioners' comments should be provided directly to the Office of the Secretary by c.o.b. Friday, January 16, 1987.
.o Commissioners' comments should be provided directly to the Office of the Secretary by c.o.b. Friday, January 16, 1987.
Commission Staff Office comments, if any, should be submitted to the Commissioners NLT Friday, January 9, 1987, with an information copy to the Office of the Secretary. If the paper is of such a nature that it requires additional time for analytical review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.
Commission Staff Office comments, if any, should be submitted to the Commissioners NLT Friday, January 9, 1987, with an information copy to the Office of the Secretary.
This paper is tentatively scheduled for affirmation at an Open Meeting during the Week of January 19, 1987.       Please refer to the appropriate Weekly Commission Schedule, when published, for a specific date and time.
If the paper is of such a nature that it requires additional time for analytical review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.
This paper is tentatively scheduled for affirmation at an Open Meeting during the Week of January 19, 1987.
Please refer to the appropriate Weekly Commission Schedule, when published, for a specific date and time.
DISTRIBUTION:
DISTRIBUTION:
Commissioners OGC (H Street)
Commissioners OGC (H Street)
Line 100: Line 151:


f
f
              ,l '
,l '
  . [ $-
. [ $-
ENCLOSURE A l
ENCLOSURE A l
I l
I l
l l
l l


    .'                                                                              [7590-01]
[7590-01]
r NUCLEAR REGULATORY COPMISSION 10 CFR Parts 70 and 74 Material Control and Accounting Requirements for Facilities Licensed to Possess and Use Formula Quantities of Strategic Special Nuclear Material AGENCY:   Nuclear Regulatory Commission ACTION:   Final rule SJMMARY:   The Nuclear Regulatory Commission is amending its material control aid accounting (MC&A) requirements 'or facilities licensed to possess and use formula quantities of strategic special nuclear material (SSNM).         These amend-ments will apply to all such fuel cyple facilities except irradiated fuel reprocess-ing plants, waste disposal operations. nuclear reactors, and users of nuclear materials in sealed sources. T;1e amer.dments will significantly strengthen MC&A capabilities at the affected facilities by requiring more timely detection of anomalies potentially indicative of SSNM losses and by providing for more rapid and conclusive resolution of discrepancies. The amendments will be cost-effective by virtue of the fact that current requirements which are not cost-effective will be eliminated and existing process, production, and quality con-trol information will be utilized to enhance material control and accounting capabilities.
r NUCLEAR REGULATORY COPMISSION 10 CFR Parts 70 and 74 Material Control and Accounting Requirements for Facilities Licensed to Possess and Use Formula Quantities of Strategic Special Nuclear Material AGENCY:
Nuclear Regulatory Commission ACTION:
Final rule SJMMARY:
The Nuclear Regulatory Commission is amending its material control aid accounting (MC&A) requirements 'or facilities licensed to possess and use formula quantities of strategic special nuclear material (SSNM).
These amend-ments will apply to all such fuel cyple facilities except irradiated fuel reprocess-ing plants, waste disposal operations. nuclear reactors, and users of nuclear materials in sealed sources.
T;1e amer.dments will significantly strengthen MC&A capabilities at the affected facilities by requiring more timely detection of anomalies potentially indicative of SSNM losses and by providing for more rapid and conclusive resolution of discrepancies.
The amendments will be cost-effective by virtue of the fact that current requirements which are not cost-effective will be eliminated and existing process, production, and quality con-trol information will be utilized to enhance material control and accounting capabilities.
ENCLOSURE A
ENCLOSURE A


EFFECTIVE DATE:
EFFECTIVE DATE:
i FOR FURTHER INFORMATION CONTACT:                   Mr. C. W. Emeigh, Safeguards Material Licensing and International Activities Branch, Division of Safeguards, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, Washington, D.C.                 20555 Telephone:   (301) 427-4769 SUPPLEMENTARY INFORMATION:
i FOR FURTHER INFORMATION CONTACT:
BACKGROUND The amended MC&A requirements are being codified in 10 CFR Part 74 which has been established for documentation of all specific domestic MC&A regulatory requirements.       Requirements for general licenses have been retained in Part 70.
Mr. C. W. Emeigh, Safeguards Material Licensing and International Activities Branch, Division of Safeguards, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, Washington, D.C.
Four high enriched uranium processing facilities will be subject to the amended requirements:                 Babcock and Wilcox, Lynchburg, Virginia; GA Technologies, San DieGo, California; Nuclear Fuel Services, Erwin, Tennesee; and United Nuclear Corporation, Uncasville, Connecticut.                   Licensees processing special nuclear material of low strategic significance will continue to be subject to S74.31, while licensees processing special nuclear material of moderate strategic significance and potential licensees processing strategic special nuclear material in irradiated fuel reprocessing plants will continue to be subject to the MC&A requirements contained in 10 CFR Part 70.
20555 Telephone:
Current domestic MC&A regulations for strategic special nuclear material require bimonthly inventories.                 Comparison of an inventory difference (ID) with 2
(301) 427-4769 SUPPLEMENTARY INFORMATION:
BACKGROUND The amended MC&A requirements are being codified in 10 CFR Part 74 which has been established for documentation of all specific domestic MC&A regulatory requirements.
Requirements for general licenses have been retained in Part 70.
Four high enriched uranium processing facilities will be subject to the amended requirements:
Babcock and Wilcox, Lynchburg, Virginia; GA Technologies, San DieGo, California; Nuclear Fuel Services, Erwin, Tennesee; and United Nuclear Corporation, Uncasville, Connecticut.
Licensees processing special nuclear material of low strategic significance will continue to be subject to S74.31, while licensees processing special nuclear material of moderate strategic significance and potential licensees processing strategic special nuclear material in irradiated fuel reprocessing plants will continue to be subject to the MC&A requirements contained in 10 CFR Part 70.
Current domestic MC&A regulations for strategic special nuclear material require bimonthly inventories.
Comparison of an inventory difference (ID) with 2


its associated limit of error (LEID) and with percent of throughput does not occur until nearly 30 days after the beginning of the physical inventory.                                       Con-sequently, a thorough investigation of any identified anomaly might not occur, in the worst case, for 90 days after the contributing event occurred.                                     The use-fulness of these bimonthly inventories in providing assurance that significant quantities of SSNM have not been diverted has been limited by the difficulty i
its associated limit of error (LEID) and with percent of throughput does not occur until nearly 30 days after the beginning of the physical inventory.
encountered in conclusively resolving large inventory differences.                                     This has necessitated reliance on material control data, plant security records, and intelligence information for the desired assurance.                                   Recognizing this short-coming, on August 20, 1981, the Commission approved publication of an Advance Notice of Proposed Rulemaking (ANPRM) to solicit public comment on how to revise
Con-sequently, a thorough investigation of any identified anomaly might not occur, in the worst case, for 90 days after the contributing event occurred.
'l MC&A regulations for SSNM that is capable of being made into fission explosives.
The use-fulness of these bimonthly inventories in providing assurance that significant quantities of SSNM have not been diverted has been limited by the difficulty i
The ANPRM, which was published in the Federal Register on September 10, 1981
encountered in conclusively resolving large inventory differences.
:                            (46 FR 45144), included goals of the rulemaking and five options for achieving 1
This has necessitated reliance on material control data, plant security records, and intelligence information for the desired assurance.
li                          those goals. The primary goals were stated as:                                 (1) timely and localized detec-
Recognizing this short-coming, on August 20, 1981, the Commission approved publication of an Advance Notice of Proposed Rulemaking (ANPRM) to solicit public comment on how to revise
!                            tion of anomalies potentially indicative of a material loss, (2) rapid deter-                                                   t mination of whether an actual loss had occurred, and (3) availability of information to aid in the recovery of material in the event of an actual loss.
'l MC&A regulations for SSNM that is capable of being made into fission explosives.
Two of the five options suggested in the ANPRM for achieving these goals retained an emphasis on periodic physical inventories.                                   The other three options i
The ANPRM, which was published in the Federal Register on September 10, 1981 (46 FR 45144), included goals of the rulemaking and five options for achieving 1
introduced requirements for the timely use of process monitoring information for safeguards purposes with de-emphasis of the importance and frequency of
l those goals.
!                            physical inventories. Responders to the ANPRM in some instances expressed reser-vations on the feasibility of using process monitoring information for safeguards                                               ,
The primary goals were stated as:
purposes because of the lack of demonstrable evidence of successful application,                                                 !
(1) timely and localized detec-i tion of anomalies potentially indicative of a material loss, (2) rapid deter-t mination of whether an actual loss had occurred, and (3) availability of information to aid in the recovery of material in the event of an actual loss.
h r
Two of the five options suggested in the ANPRM for achieving these goals retained an emphasis on periodic physical inventories.
t
The other three options i
,                                                                                                        3                                                   ;
introduced requirements for the timely use of process monitoring information for safeguards purposes with de-emphasis of the importance and frequency of physical inventories.
Responders to the ANPRM in some instances expressed reser-vations on the feasibility of using process monitoring information for safeguards purposes because of the lack of demonstrable evidence of successful application, h
r t
3


1 but suggested no alternatives.                     Based on the comments received and on the results of continuing technical studies, a decision was made to proceed.                                                   The proposed rule that was presented to the Commission for publication included much of the-substance of Options 3 and 4 of the ANPRM but was rewritten to:                                                   (1) delete unnecessarily prescriptive requirements, (2) reduce the number of plans and pro-
1 but suggested no alternatives.
;                  grams required, (3) improve clarity, (4) incorporate capabilities to protect
Based on the comments received and on the results of continuing technical studies, a decision was made to proceed.
;                  against certain types of inside adversary, and (5) provide flexibility for
The proposed rule that was presented to the Commission for publication included much of the-substance of Options 3 and 4 of the ANPRM but was rewritten to:
:                  licensees to select the most cost-effective ways of achieving performance objectives.                 The rule gave credit for SSNM in secure containment and recognized j                  differences with respect to safeguards vulnerability between processing SSNM in bulk form and in encapsulated form.
(1) delete unnecessarily prescriptive requirements, (2) reduce the number of plans and pro-grams required, (3) improve clarity, (4) incorporate capabilities to protect against certain types of inside adversary, and (5) provide flexibility for licensees to select the most cost-effective ways of achieving performance objectives.
I The proposed rule was published in the Federal Register on February 2, i                  1984 (49 FR 4091).                 Concurrent with the publication, copies of a Standard Format / Acceptance Criteria guide and a Regulatory Analysis were placed in the Public Document Room.                 Public comments were requested to be submitted by June                                                   <
The rule gave credit for SSNM in secure containment and recognized differences with respect to safeguards vulnerability between processing SSNM in j
5, 1984.               Citing technical complexity as the principal reason, the affected
bulk form and in encapsulated form.
;                  Ifcensees requested an extension of the comment period.                                               The comment period subsequently was extended to September 5, 1984 (June 19, 1984; 49 FR 25005).
I The proposed rule was published in the Federal Register on February 2, 1984 (49 FR 4091).
1 COMMENTS ON THE PROPOSED RULE The Commission received four letters from licensees and a memorandum from the Department of State commenting on the proposed rule.                                               Copies of the letters are available for pubite inspection and copying for a fee at the NRC Public Document Room at 1717 H Street NW., Wasington, D.C.                                               20555.                                     j 4
Concurrent with the publication, copies of a Standard i
!                                                                                4                                                                               [
Format / Acceptance Criteria guide and a Regulatory Analysis were placed in the Public Document Room.
  .--.-#._c-_m-.-_      ..,~_.,.m,--                               ~_   -_ -              ,,.,__---,._m.,-.,_,_y,,x._.                         w-y._,.____y
Public comments were requested to be submitted by June 5, 1984.
Citing technical complexity as the principal reason, the affected Ifcensees requested an extension of the comment period.
The comment period subsequently was extended to September 5, 1984 (June 19, 1984; 49 FR 25005).
1 COMMENTS ON THE PROPOSED RULE The Commission received four letters from licensees and a memorandum from the Department of State commenting on the proposed rule.
Copies of the letters are available for pubite inspection and copying for a fee at the NRC Public Document Room at 1717 H Street NW., Wasington, D.C.
20555.
j 4
4
[
.--.-#. c-m-.-
..,~_.,.m,--
~_
,,.,__---,._m.,-.,_,_y,,x._.
w-y._,.____y


a Changes in Response to Public Comments
a Changes in Response to Public Comments 1.
: 1. Three respondents expressed concern over the technical feasibility of implementing an MC&A system in compliance with proposed rule requirements. One respondent pointed out that experimentt.1 projects designec' to enhance near-real-time accounting failed to demonstrate the applicability of the technique in actual operating plants. A second respondent took issue with a statement in the Regulatory Analysis which indicated that the prompt accountability concept was technologically feasible and that significant benefits to MC&A systems could be achieved at moderate cost. The respondent cited results of a study performed at its site for the Commission as the basis for its skepticism. The third respondent expressed concern over the complex statistics that obviously would be involved in analyzing material control test data over space and time, as had been proposed.
Three respondents expressed concern over the technical feasibility of implementing an MC&A system in compliance with proposed rule requirements.
One respondent pointed out that experimentt.1 projects designec' to enhance near-real-time accounting failed to demonstrate the applicability of the technique in actual operating plants.
A second respondent took issue with a statement in the Regulatory Analysis which indicated that the prompt accountability concept was technologically feasible and that significant benefits to MC&A systems could be achieved at moderate cost.
The respondent cited results of a study performed at its site for the Commission as the basis for its skepticism.
The third respondent expressed concern over the complex statistics that obviously would be involved in analyzing material control test data over space and time, as had been proposed.
The Commission has re-evaluated the in process monitoring requirements in the proposed rule with respect to whether or not design goals could be achieved.
The Commission has re-evaluated the in process monitoring requirements in the proposed rule with respect to whether or not design goals could be achieved.
Based on this re-evaluation the Commission concluded that the objective of upgraded material control and accounting systems could be achieved through less drastic modification of existing requirements. This change in direction has resulted in deletion of multiple time and area-wide loss detection tests from the rule and addition of requirements for quality control tests and trend analyses at the unit process level. Additionally, physical inventory require-ments have been modified in the area of inventory difference evaluation criteria.
Based on this re-evaluation the Commission concluded that the objective of upgraded material control and accounting systems could be achieved through less drastic modification of existing requirements.
The significance of an inventory difference will be initially tested against a threshold that takes into account measurement error only. If this threshold is 5
This change in direction has resulted in deletion of multiple time and area-wide loss detection tests from the rule and addition of requirements for quality control tests and trend analyses at the unit process level.
Additionally, physical inventory require-ments have been modified in the area of inventory difference evaluation criteria.
The significance of an inventory difference will be initially tested against a threshold that takes into account measurement error only.
If this threshold is 5
w I
w I


exceeded, an investigation will be required which must include the computation of a second threshold that takes historical ID variation into account.
exceeded, an investigation will be required which must include the computation of a second threshold that takes historical ID variation into account.
: 2. A comment was received to the effect that research and development operations by design do not achieve the steady state conditions required for application of in process monitoring tests for loss detection. The respondent proposed that such operations be exempted from in process monitoring requirements and instead be subjected to either bimonthly inventories or periodic material balances coupled with item monitoring.
2.
A comment was received to the effect that research and development operations by design do not achieve the steady state conditions required for application of in process monitoring tests for loss detection.
The respondent proposed that such operations be exempted from in process monitoring requirements and instead be subjected to either bimonthly inventories or periodic material balances coupled with item monitoring.
The Commission agrees with this assessment and has modified the rule for research and development operations to require material balances on a lot or batch basis, item monitoring, and analysis of material balance data for trends.
The Commission agrees with this assessment and has modified the rule for research and development operations to require material balances on a lot or batch basis, item monitoring, and analysis of material balance data for trends.
An appropriate exemption has been added to $74.53(a) in addition to the new requirements in paragraph (c) of the same section.
An appropriate exemption has been added to $74.53(a) in addition to the new requirements in paragraph (c) of the same section.
: 3. A respondent stated an opinion that samples should be exempt from in-process monitoring requirements on the basis that the SSNM quantities in samples are small and would require the acquisition of a large number by an adversary in order to obtain five formula kilograms. Sample control systems would rapidly i   detect such a removal. An additional relevant point was the fact that the total quantity of SSNM in a laboratory is typically small.
3.
l         The Commission agrees with the respondent and exempted samples containing less than 0.05 formula kilograms of SSNM from in process monitoring requirements and modified item monitoring requirements to allow for the treatment of such samples as items. Larger samples are expected to be within the scope of a material control test whether it be applied in the originating process unit or in the laboratory. In the former case, adequate administrative controls
A respondent stated an opinion that samples should be exempt from in-process monitoring requirements on the basis that the SSNM quantities in samples are small and would require the acquisition of a large number by an adversary in order to obtain five formula kilograms.
Sample control systems would rapidly i
detect such a removal.
An additional relevant point was the fact that the total quantity of SSNM in a laboratory is typically small.
l The Commission agrees with the respondent and exempted samples containing less than 0.05 formula kilograms of SSNM from in process monitoring requirements and modified item monitoring requirements to allow for the treatment of such samples as items.
Larger samples are expected to be within the scope of a material control test whether it be applied in the originating process unit or in the laboratory.
In the former case, adequate administrative controls


would be required to protect the integrity of the sample until it was returned to the originating process unit.
would be required to protect the integrity of the sample until it was returned to the originating process unit.
: 4.           Two respondents expressed concern over the effect of data that is statistically non normal on the establishment of alarm thresholds for loss detection.                     The respondent indicated that analyses of current process monitoring data pointed up the fact that, for some units, test data were non normally distributed.
4.
The Commission agrees that this is a concern, especially if the tails of a statistical distribution come into consideration.                                               Unacceptably high false alarm rates will result when such conditions exist.                                               To alleviate this concern, the required detection probability for losses from individual process units has been revised downward from 99 percent to 95 percent.
Two respondents expressed concern over the effect of data that is statistically non normal on the establishment of alarm thresholds for loss detection.
: 5.       Comments were received from two licensees regarding the difficulties likely to be encountered in complying with the bias correction requirements reflected in the proposed rule.                                 The principal difficulty lies in the fact that bias corrections are not sufficiently timely to permit record corrections to be made on the process floor.                                 Retroactive corrections to the book records neces-sitate the correction of label values on individual items if the accounting sys-tem is to balance.
The respondent indicated that analyses of current process monitoring data pointed up the fact that, for some units, test data were non normally distributed.
The Commission agrees that bias corrections are difficult to accommodate in the accounting system.                                 However, accounting for the impact of biases is an important consideration in achieving a reliable MC&A system.                                                             Consequently, requirements for bias corrections have been retained but modified to resolve some of the associated difficulties.
The Commission agrees that this is a concern, especially if the tails of a statistical distribution come into consideration.
Unacceptably high false alarm rates will result when such conditions exist.
To alleviate this concern, the required detection probability for losses from individual process units has been revised downward from 99 percent to 95 percent.
5.
Comments were received from two licensees regarding the difficulties likely to be encountered in complying with the bias correction requirements reflected in the proposed rule.
The principal difficulty lies in the fact that bias corrections are not sufficiently timely to permit record corrections to be made on the process floor.
Retroactive corrections to the book records neces-sitate the correction of label values on individual items if the accounting sys-tem is to balance.
The Commission agrees that bias corrections are difficult to accommodate in the accounting system.
However, accounting for the impact of biases is an important consideration in achieving a reliable MC&A system.
Consequently, requirements for bias corrections have been retained but modified to resolve some of the associated difficulties.
i 7
i 7
        ,    ._7_. .- -    , _ . _ . - .         -
. 7.
                                                      . . , , . - _ .            -- -  . . _ . _ _ - ,        --,_.---..-,__.._-.r               -.,-
--,_.---..-,__.._-.r


a                                                                                                                                                                                                                                   .
a 6.
: 6.          A respondent requasted that consideration be given to permitting stor-age if untamper-sealed items,in- enclosures other than vaults.                                                                                                                 The respondent i
A respondent requasted that consideration be given to permitting stor-age if untamper-sealed items,in-enclosures other than vaults.
N        provided examplesif situktions in which untamper-sealed containers and unencapsulated solid fu'el forms were stored in controlled access areas for
The respondent i
                    . varying time periods during the fabrication process.                                                                             It was pointed out that in many instances it was impraci.ical to tamper-seal certain material forms and that minimal handling was important to prevent damage.                                                                                               ,
provided examplesif situktions in which untamper-sealed containers and N
The-respondent's. points are considered valid.                                                                   Consequehtly, the final rule has been modified to permit storage of untamper-sealed containers in permanently r
unencapsulated solid fu'el forms were stored in controlled access areas for
controlled access areas.                                         As indicated in the acceptance criteria, the area should be equipped with adequate controls to preclude undetected access to the SSNM by one individual in any position.                 3                                          The requirement to provide protection at least equivaledt to tamper-safing dictates the level of control that is n             ,.
. varying time periods during the fabrication process.
expected.                                               '
It was pointed out that in many instances it was impraci.ical to tamper-seal certain material forms and that minimal handling was important to prevent damage.
i           k                                                                .
The-respondent's. points are considered valid.
: 7.           One respondent stated that the requirements of 10 CFR 70.57 and 70.58 i
Consequehtly, the final rule has been modified to permit storage of untamper-sealed containers in permanently r
i                      should be             c' hanged               to performance-oriented safeguards. '
controlled access areas.
i                             >
As indicated in the acceptance criteria, the area should be equipped with adequate controls to preclude undetected access to the SSNM by one individual in any position.
The Commission agrees with the respondent's statement and has taken action to accomplish this task.                                         The quality assurance and accounting requirements in
The requirement to provide protection 3
                                                                                        .                            ,                                                                      e
at least equivaledt to tamper-safing dictates the level of control that is n
                      $70.89 of the proposed rule (S 74.59 of the final rule) have been replaced with portions of 10 CFR 70.57 and 70.58 that have been' rewritten to be performance I      i oriented, to deleta/ obsolete requirements, and to clarify the quality assurance
expected.
                                                                                  \
k i
l                     and accounting requirements applicable to Category I licensees.
7.
1 l
One respondent stated that the requirements of 10 CFR 70.57 and 70.58 i
should be ' hanged to performance-oriented safeguards. '
c i
i
>The Commission agrees with the respondent's statement and has taken action to accomplish this task.
The quality assurance and accounting requirements in e
' $70.89 of the proposed rule (S 74.59 of the final rule) have been replaced with portions of 10 CFR 70.57 and 70.58 that have been' rewritten to be performance i oriented, to deleta/ obsolete requirements, and to clarify the quality assurance I
\\
l and accounting requirements applicable to Category I licensees.
l 1
l l
l l
l t
l t
s j       It
s I
  +
j t
8
8
          ~-.1     ,,m.~+-.       .yo,-.-     ..-,--....-.,~e,       .
+
                                                                                          .-.,..-,#        . ,_,  e-     -      ~,.,.----.-r                 ___ ____.__. __ _ - - , - . - - - - - - . - - - - - - - - - -
~-.1
,,m.~+-.
.yo,-.-
..-,--....-.,~e, e-
~,.,.----.-r


Comments Not Incorporated
Comments Not Incorporated 1.
: 1. A respondent indicated that the 0.1 percent of active inventory limit on the standard error of the~ inventory difference estimator was not achievable for its particular process.
A respondent indicated that the 0.1 percent of active inventory limit on the standard error of the~ inventory difference estimator was not achievable for its particular process.
This comment appears to be the result of a misconception of what is being required. The proposed limit, while somewhat more restrictive than the current limit, should be achievable without extraordinary effort. Taking into account the differences in the method of computation, the current limit (i.e. 0.5% of additions to or removals from process expressed at the two standard deviation level) would equate to one standard deviation being less than 0.125 percent of active inventory. The decrease to 0.10 percent of active inventory is con-sidered justified on the premise that there have been significant advances in state-of-the-art measurement technology since the current limit was imposed. A review of the level of performance of current licensees supports this conclusion.
This comment appears to be the result of a misconception of what is being required.
: 2. A respondent expressed concern over the restrictions that might be imposed on the use of its workforce if detection within administratively controlled areas were to be required.
The proposed limit, while somewhat more restrictive than the current limit, should be achievable without extraordinary effort.
l This comment became moot when area loss detection requirements were deleted l       from the rule.
Taking into account the differences in the method of computation, the current limit (i.e. 0.5% of additions to or removals from process expressed at the two standard deviation level) would equate to one standard deviation being less than 0.125 percent of active inventory.
l
The decrease to 0.10 percent of active inventory is con-sidered justified on the premise that there have been significant advances in state-of-the-art measurement technology since the current limit was imposed.
: 3. A comment was received to the effect that the proposed 0.25 gm/ liter limit on the concentration of SSNM in scrap contained in 30 gallon or larger containers would have a significant impact on a licensee's storage capability.
A review of the level of performance of current licensees supports this conclusion.
Additionally, the respondent indicated that the proposed limit would have a
2.
,      significant impact on the amount of SSNM per container that they could receive from off-site for scrap recovery.
A respondent expressed concern over the restrictions that might be imposed on the use of its workforce if detection within administratively controlled areas were to be required.
This comment became moot when area loss detection requirements were deleted l
l from the rule.
l 3.
A comment was received to the effect that the proposed 0.25 gm/ liter limit on the concentration of SSNM in scrap contained in 30 gallon or larger containers would have a significant impact on a licensee's storage capability.
Additionally, the respondent indicated that the proposed limit would have a significant impact on the amount of SSNM per container that they could receive from off-site for scrap recovery.
9 i
9 i
L
L


The exemption. documented in 970.83(a)(2) of the proposed rule ($ 74.53(a)(2) of the final rule) is not intended to be a limit on the amount of SSNM per con-tainer. Instead the 0.25 gm/ liter criterion is considered a de minimis quantity below which application of the in process monitoring requirements of paragraph (b) of the same section is not required.
The exemption. documented in 970.83(a)(2) of the proposed rule ($ 74.53(a)(2) of the final rule) is not intended to be a limit on the amount of SSNM per con-tainer.
: 4. The necessity for including fuel fabrication facilities in the scope of rule applicability was-questioned by a respondent.     The contention was put forth that, unlike conversion facilities, the problems the rule is intended to address are not present in fabrication facilities (i.e. unmeasured side streams and large inventory differences).
Instead the 0.25 gm/ liter criterion is considered a de minimis quantity below which application of the in process monitoring requirements of paragraph (b) of the same section is not required.
The Commission agrees that excessive inventory differences are less likely to occur in fuel fabrication facilities since there is minimal handling of SSNM in bulk form and the materials do not change chemical form. However, this does not preclude the possibility of a significant diversion.       Consequently, the decision has been made to apply the rule to fuel fabrication as well as conversion facilities.
4.
: 5. Affected licensees stated that, in their opinion, the conclusions reflected in the Regulatory Analysis were not representative of the actual cost impact likely to be experienced at their facilities, i
The necessity for including fuel fabrication facilities in the scope of rule applicability was-questioned by a respondent.
In response, site-specific value/ impact analyses were performed. Informa-tion obtained in preparing those analyses has been taken into account in the 1
The contention was put forth that, unlike conversion facilities, the problems the rule is intended to address are not present in fabrication facilities (i.e. unmeasured side streams and large inventory differences).
The Commission agrees that excessive inventory differences are less likely to occur in fuel fabrication facilities since there is minimal handling of SSNM in bulk form and the materials do not change chemical form.
However, this does not preclude the possibility of a significant diversion.
Consequently, the decision has been made to apply the rule to fuel fabrication as well as conversion facilities.
5.
Affected licensees stated that, in their opinion, the conclusions reflected in the Regulatory Analysis were not representative of the actual cost impact likely to be experienced at their facilities, i
In response, site-specific value/ impact analyses were performed.
Informa-tion obtained in preparing those analyses has been taken into account in the 1
revised Regulatory Analysis prepared in support of the final rule.
revised Regulatory Analysis prepared in support of the final rule.
,      6. A respondent expressed concern that drastic changes in regulatory requirements, such as those incorporated in the proposed rule, were not receiv-ing adequate review within the Commission prior to publication for comment.       In particular, the respondent indicated that there should be more involvement of 10
6.
A respondent expressed concern that drastic changes in regulatory requirements, such as those incorporated in the proposed rule, were not receiv-ing adequate review within the Commission prior to publication for comment.
In particular, the respondent indicated that there should be more involvement of 10


licensing and inspection personnel in the rulemaking process in view of their roles in ultimately approving licensees' plans and inspecting their application.
licensing and inspection personnel in the rulemaking process in view of their roles in ultimately approving licensees' plans and inspecting their application.
The Commission does not agree with the respondent's position.                         Rulemaking procedures include scheduled milestones for review and comment by licensing, inspection, and other interested regulatory personnel during the formulation of new rules. Rules are particularly reviewed for inspectability prior to issuance.
The Commission does not agree with the respondent's position.
Other Changes
Rulemaking procedures include scheduled milestones for review and comment by licensing, inspection, and other interested regulatory personnel during the formulation of new rules. Rules are particularly reviewed for inspectability prior to issuance.
: 1.         Requirement: of the proposed rule in SS70.81 through 70.89 have been redesignated SS74.51 through 74.59 in the final rule.                         This change was made to be consistent with the Commission's objective of eventually incorporating all domestic MC&A regulatory requirements in Part 74.             With this action, the MC&A requirements in SS70.51, 70.57, and 70.58 apply only to licensees possessing and using special nuclear material of moderate strategic significance, strategic special nuclear material in irradiated fuel reprocessing plants, and special categories of licensees possessing SNM of low strategic significance who are not currently required to have an approved MC&A plan.                       Performance-oriented regulations subsequently are expected to be developed for those categories of licensees and incorporated in Part 74.
Other Changes 1.
Requirement: of the proposed rule in SS70.81 through 70.89 have been redesignated SS74.51 through 74.59 in the final rule.
This change was made to be consistent with the Commission's objective of eventually incorporating all domestic MC&A regulatory requirements in Part 74.
With this action, the MC&A requirements in SS70.51, 70.57, and 70.58 apply only to licensees possessing and using special nuclear material of moderate strategic significance, strategic special nuclear material in irradiated fuel reprocessing plants, and special categories of licensees possessing SNM of low strategic significance who are not currently required to have an approved MC&A plan.
Performance-oriented regulations subsequently are expected to be developed for those categories of licensees and incorporated in Part 74.
i l
i l
: 2.         The list of definitions in S74.4 has been expanded to include appro-l       priate definitions from Part 70 and new definitions applicable to the subject rule. Additional definitions may be added when the rules for other categories i
2.
i      of licensees, referenced above, are transferred to Part 74.                         With respect to i
The list of definitions in S74.4 has been expanded to include appro-l priate definitions from Part 70 and new definitions applicable to the subject rule. Additional definitions may be added when the rules for other categories i
11
of licensees, referenced above, are transferred to Part 74.
With respect to i
i 11


terminology, Part 74 reflects the terms the Commission now prefers when refer-ring to certain MC&A and statistical concepts.                       However, the language in Part 70 has not been changed.
terminology, Part 74 reflects the terms the Commission now prefers when refer-ring to certain MC&A and statistical concepts.
: 3. Irradiated fuel reprocessing plants have been deleted from the applica-bility statement in the final rule.                       This action was taken because of unresolved questions as to whether a reprocessing plant could comply with all rule require-ments and the negative outlook for domestic reprocessing in the near term.                           It is expected that by the time reprocessing becomes a viable option in the United States, there will be significant technological advances that will influence material control and accounting system design for such plants.
However, the language in Part 70 has not been changed.
: 4. A statement has been added to $74.51 to clarify the fact that licensees are required to follow currently approved fundamental nuclear material control plans until newly submitted plans are reviewed and approved.
3.
: 5. Section 74.51(c) has been modified to provide flexibility in the tim-ing of the implementation of commitments in support of the new rule.                           Depending upon current MC&A practices, the complexity of production operations, and advance planning by the licensees, the time within which adequate performance against rule requirements is achieved will vary from licensee to licensee.                         In some cases, current practices approach what would be expected under an upgraded MC&A system.     Under these conditions, a licensee may be able to achieve adequate performance in less than six months.                       At the other extreme, the current system may bear no resemblance to an upgraded system; hence, longer than six months 1
Irradiated fuel reprocessing plants have been deleted from the applica-bility statement in the final rule.
This action was taken because of unresolved questions as to whether a reprocessing plant could comply with all rule require-ments and the negative outlook for domestic reprocessing in the near term.
It is expected that by the time reprocessing becomes a viable option in the United States, there will be significant technological advances that will influence material control and accounting system design for such plants.
4.
A statement has been added to $74.51 to clarify the fact that licensees are required to follow currently approved fundamental nuclear material control plans until newly submitted plans are reviewed and approved.
5.
Section 74.51(c) has been modified to provide flexibility in the tim-ing of the implementation of commitments in support of the new rule.
Depending upon current MC&A practices, the complexity of production operations, and advance planning by the licensees, the time within which adequate performance against rule requirements is achieved will vary from licensee to licensee.
In some cases, current practices approach what would be expected under an upgraded MC&A system.
Under these conditions, a licensee may be able to achieve adequate performance in less than six months.
At the other extreme, the current system may bear no resemblance to an upgraded system; hence, longer than six months 1
may be required for full implementation of the rule.
may be required for full implementation of the rule.
: 6. The deletion of irradiated fuel reprocessing plants from the scope of the rule made the exemption for SSNM exhibiting external radiation in excess of 100 rem per hour at three feet irrelevant.                       Therefore, this proposed exemption 12 I
6.
The deletion of irradiated fuel reprocessing plants from the scope of the rule made the exemption for SSNM exhibiting external radiation in excess of 100 rem per hour at three feet irrelevant.
Therefore, this proposed exemption 12 I


has been deleted. Any Category I licensee who may have occasion to handle irradiated fuel may request an exemption from the in process monitoring require-ments of S 74.53(b).
has been deleted. Any Category I licensee who may have occasion to handle irradiated fuel may request an exemption from the in process monitoring require-ments of S 74.53(b).
: 7. For SSNM having an estiinated measurement uncertainty greater than five percent that is either input to or output from a unit operation that processes less than five formula kilograms in three months, a new exemption has been added to 974.53(a). This exemption is considered appropriate on the basis of the low throughput of the unit, the unattractive nature of the material, and the high uncertainty that would be associated with any material control test results.
7.
: 8. A requirement has been added to S74.55 to detect a five formula kilo-gram loss within two months for items stored in a permanently controlled access area located outside of an MAA.               This requirement was inadvertently omitted from the proposed rule.               This oversight has been discussed with affected licen-sees who concurred with the need for the requirement.
For SSNM having an estiinated measurement uncertainty greater than five percent that is either input to or output from a unit operation that processes less than five formula kilograms in three months, a new exemption has been added to 974.53(a). This exemption is considered appropriate on the basis of the low throughput of the unit, the unattractive nature of the material, and the high uncertainty that would be associated with any material control test results.
: 9. Miscellaneous minor changes have been made that have no impact on the substance of the rule.
8.
INTERNATIONAL CONSIDERATIONS It should be ncted that the performance goals for the rule, stated pre-viously, are domestic 00als and are considered to be appropriate for a subna-tional threat. For all U.S. licensees, the detection and response capability of the rule have been determined to be sufficient to adequately protect the public health and safety from a subnational threat.                     On the other hand, the International Atomic Energy Agency (IAEA), which is responsible for applying international safeguards in non-nuclear weapons states, must judge whether a 13
A requirement has been added to S74.55 to detect a five formula kilo-gram loss within two months for items stored in a permanently controlled access area located outside of an MAA.
This requirement was inadvertently omitted from the proposed rule.
This oversight has been discussed with affected licen-sees who concurred with the need for the requirement.
9.
Miscellaneous minor changes have been made that have no impact on the substance of the rule.
INTERNATIONAL CONSIDERATIONS It should be ncted that the performance goals for the rule, stated pre-viously, are domestic 00als and are considered to be appropriate for a subna-tional threat.
For all U.S. licensees, the detection and response capability of the rule have been determined to be sufficient to adequately protect the public health and safety from a subnational threat.
On the other hand, the International Atomic Energy Agency (IAEA), which is responsible for applying international safeguards in non-nuclear weapons states, must judge whether a 13


significant~ diversion has occurred in the face of a possible national conspiracy.
significant~ diversion has occurred in the face of a possible national conspiracy.
In order to reach its conclusion with the required level of certainty, the IAEA may find it necessary to continue to place primary reliance on periodic physical inventories as opposed to an analysis of process monitoring data, as promulgated in this rule.
In order to reach its conclusion with the required level of certainty, the IAEA may find it necessary to continue to place primary reliance on periodic physical inventories as opposed to an analysis of process monitoring data, as promulgated in this rule.
ENVIRONMENTAL IMPACT
ENVIRONMENTAL IMPACT CATEGORICAL EXCLUSION The material control and accounting (MC&A) requirements for licensees licensed to possess and use five or more formula kilograms of strategic special nuclear 1
,                                                                      CATEGORICAL EXCLUSION The material control and accounting (MC&A) requirements for licensees licensed to possess and use five or more formula kilograms of strategic special nuclear 1
material will be amended in two major ways:
material will be amended in two major ways:
l                                             The first major amendment will move certain safeguards related recordkeeping and reporting requirements now found in Part 70 to Part 74 to be consistent with the Commission's objective for separating safety requirements from safeguards requirements.
l The first major amendment will move certain safeguards related recordkeeping and reporting requirements now found in Part 70 to Part 74 to be consistent with the Commission's objective for separating safety requirements from safeguards requirements.
Pursuant to 10 CFR 51.22(c)(3)(ii) and (iii), a categorical exclusion is granted to amendments to Commission regulations that relate to recordkeeping and reporting requirements.           Moving the MC&A requirements from Part 70 to Part 74 meets the eligibility criteria for this categorical exclusion.                                                           Accord-l ingly, no environmental impact statement or environmental assessments needs'to be prepared in conjunction with the issuance of these amendments.
Pursuant to 10 CFR 51.22(c)(3)(ii) and (iii), a categorical exclusion is granted to amendments to Commission regulations that relate to recordkeeping and reporting requirements.
1 i                                                                                             14 l
Moving the MC&A requirements from Part 70 to Part 74 meets the eligibility criteria for this categorical exclusion.
Accord-l ingly, no environmental impact statement or environmental assessments needs'to be prepared in conjunction with the issuance of these amendments.
1 i
14 l
4
4
__....__-,.-.._-..__.,-m_._--.,,,_,..._..._.-.___,,                   . . __ ,._ _ _ - ,._    . _ _ _ . _ . _ . _ _ _ _ _ _ . , , . , _ . _ _ . _ _ . . _ . . , _ . _ . _ . , _ _ . . _ , . .
__....__-,.-.._-..__.,-m_._--.,,,_,..._..._.-.___,,


FINDING OF NO SIGNIFICANT ENVIRONMENTAL IMPACT: AVAILABILITY The second major amendment will modify material control and accounting requirements for licensees who possess and use formula quantities of strategic special nuclear material to achieve the following objectives:
FINDING OF NO SIGNIFICANT ENVIRONMENTAL IMPACT: AVAILABILITY The second major amendment will modify material control and accounting requirements for licensees who possess and use formula quantities of strategic special nuclear material to achieve the following objectives:
Prompt investigation of anomalies potentially indicative of SSNM losses, Timely detection of the possible abrupt loss of five or more formula kilograms of SSNM from individual unit processes, Rapid determination of whether an actual loss of five or more formula kilograms occurred, Ongoing confirmation of the presence of SSNM in assigned locations, and Timely generation of information to aid in the recovery of SSNM in the event of an actual loss.
Prompt investigation of anomalies potentially indicative of SSNM
: losses, Timely detection of the possible abrupt loss of five or more formula kilograms of SSNM from individual unit processes, Rapid determination of whether an actual loss of five or more formula kilograms occurred, Ongoing confirmation of the presence of SSNM in assigned locations, and Timely generation of information to aid in the recovery of SSNM in the event of an actual loss.
The principal differences between the MC&A requirements in this rule and those in the current rules are the use of process monitoring data for material control, a longer interval between physical inventories, and an item monitoring program designed to detect a five formula kilogram loss.
The principal differences between the MC&A requirements in this rule and those in the current rules are the use of process monitoring data for material control, a longer interval between physical inventories, and an item monitoring program designed to detect a five formula kilogram loss.
For the following reasons, the Commission has determined not to prepare an environmental impact statement for the second major amendment and, in accordance with 10 CFR 51.32 and 51.34, finds that the proposed amendments have no sig-nificant impact on the environment.
For the following reasons, the Commission has determined not to prepare an environmental impact statement for the second major amendment and, in accordance with 10 CFR 51.32 and 51.34, finds that the proposed amendments have no sig-nificant impact on the environment.
: 1. The rule will not result in changes in the licenses' processes or manufacturing procedures and therefore will not affect or alter any release of effluents to the environment.
1.
: 2. The rule will affect four high enriched uranium fuel processing facilities, all of whom have undergone individual NEPA review.
The rule will not result in changes in the licenses' processes or manufacturing procedures and therefore will not affect or alter any release of effluents to the environment.
2.
The rule will affect four high enriched uranium fuel processing facilities, all of whom have undergone individual NEPA review.
15
15


The environmental assessment upon which the foregoing determination is based is included in the Regulatory Analysis for this rulemaking action and is avail-able for public inspection at the NRC Public Document Room, 1717 H Street NW, Washington, D.C. Single copies of the environmental assessment and finding of no significant impact are available from Dr. W. B. Brown, Chief, Safeguards Material Licensing and International Activities Branch, Division of Safeguards, Office of Nuclear Material Safety and Safeguards, Nuclear Regulatory Commission, Washington D.C. 20555, telephone (301)427-4185.
The environmental assessment upon which the foregoing determination is based is included in the Regulatory Analysis for this rulemaking action and is avail-able for public inspection at the NRC Public Document Room, 1717 H Street NW, Washington, D.C.
4 PAPERWORK REDUCTION ACT STATEMENT This final rule amends information collection requirements that are subject to the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.). These require-ments were approved by the Office of Management and Budget approval number 3150-0009 (for Part 70) and 3150-0123 (for Part 74).
Single copies of the environmental assessment and finding of no significant impact are available from Dr. W. B. Brown, Chief, Safeguards Material Licensing and International Activities Branch, Division of Safeguards, Office of Nuclear Material Safety and Safeguards, Nuclear Regulatory Commission, Washington D.C. 20555, telephone (301)427-4185.
REGULATORY ANALYSIS The Commission has prepared a regulatory analysis on this final rule. The analysis examines the costs and benefits of the alternatives considered by the Commission. The analysis is available for inspection or copying for a fee in the NRC Public Document Room, 1717 H Street, NW, Washington, DC. Single copies of the analysis may be obtiined from (insert name, address and telephone number of contact person).
PAPERWORK REDUCTION ACT STATEMENT 4
This final rule amends information collection requirements that are subject to the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.).
These require-ments were approved by the Office of Management and Budget approval number 3150-0009 (for Part 70) and 3150-0123 (for Part 74).
REGULATORY ANALYSIS The Commission has prepared a regulatory analysis on this final rule.
The analysis examines the costs and benefits of the alternatives considered by the Commission.
The analysis is available for inspection or copying for a fee in the NRC Public Document Room, 1717 H Street, NW, Washington, DC.
Single copies of the analysis may be obtiined from (insert name, address and telephone number of contact person).
16
16


REGULATORY FLEXIBILITY CERTIFICATION In accordance with the Regulatory Flexibility Act of 1980, 5 U.S.C. 605(b),
REGULATORY FLEXIBILITY CERTIFICATION In accordance with the Regulatory Flexibility Act of 1980, 5 U.S.C. 605(b),
the Commission hereby certifies that this rule will not, if promulgated, have a significant economic impact on a substantial number of small entities. This rule affects four facilities that process high enriched uranium and is expected to result in a positive cost / benefit to the industry and, in addition, to provide enhanced safeguards capabilities. The facilities include: Babcock and Wilcox Company, Lynchburg, Virginia; GA Technologies, San Diego, California; Nuclear Fuel Services, Erwin, Tennessee; and United Nuclear Corporation, Uncasville, Connecticut. These companies are dominant in their service areas and do not fall within the definition of "small entities" set forth in the Regulatory Flexibility Act or by the Small Business Administration in 13 CFR Part 121.
the Commission hereby certifies that this rule will not, if promulgated, have a significant economic impact on a substantial number of small entities.
This rule affects four facilities that process high enriched uranium and is expected to result in a positive cost / benefit to the industry and, in addition, to provide enhanced safeguards capabilities.
The facilities include:
Babcock and Wilcox Company, Lynchburg, Virginia; GA Technologies, San Diego, California; Nuclear Fuel Services, Erwin, Tennessee; and United Nuclear Corporation, Uncasville, Connecticut. These companies are dominant in their service areas and do not fall within the definition of "small entities" set forth in the Regulatory Flexibility Act or by the Small Business Administration in 13 CFR Part 121.
BACKFIT ANALYSIS The staff has determined that a backfit analysis is not required for this rule since these amendments do not apply to 10 CFR Part 50 licensees.
BACKFIT ANALYSIS The staff has determined that a backfit analysis is not required for this rule since these amendments do not apply to 10 CFR Part 50 licensees.
LIST OF SUBJECTS IN 10 CFR PARTS 70 AND 74 Part 70: Accounting, Hazardous materials-transportation, Material control and accounting, Nuclear materials, Packaging and containers, Penalty, Radiation protection, Reporting and recordkeeping requirements, Scientific equipment, Security measures, Special nuclear material.
LIST OF SUBJECTS IN 10 CFR PARTS 70 AND 74 Part 70:
Accounting, Hazardous materials-transportation, Material control and accounting, Nuclear materials, Packaging and containers, Penalty, Radiation protection, Reporting and recordkeeping requirements, Scientific equipment, Security measures, Special nuclear material.
17
17


    ~.                                                                                                                                                                             .,
~.
  +
+
4 i
4 i
L Part 74:           Accounting, Material control and accounting, Nuclear materials, l
L l
Penalty, Reporting and recordkeeping requirements, Special nuclear material.
Part 74:
Accounting, Material control and accounting, Nuclear materials, Penalty, Reporting and recordkeeping requirements, Special nuclear material.
Under the authority of the Atomic Energy Act of 1954, as amended, the t
Under the authority of the Atomic Energy Act of 1954, as amended, the t
Energy Reorganization Act of 1974, as amended, and 5 U.S.C. 553, the NRC is adopting the following amendments to 10 CFR Parts 70 and 74.
Energy Reorganization Act of 1974, as amended, and 5 U.S.C. 553, the NRC is adopting the following amendments to 10 CFR Parts 70 and 74.
i PART 70 DOMESTIC LICENSING OF SPECIAL NUCLEAR MATERIAL
i PART 70 DOMESTIC LICENSING OF SPECIAL NUCLEAR MATERIAL 1.
: 1. The authority citation for Part 70 is revised to read as follows:
The authority citation for Part 70 is revised to read as follows:
Authority:             Secs. 51, 53, 161, 182, 183, 68 stat. 929, 930, 948, 953, 954, as amended, sec. 234, 83 stat. 444, as amended (42 U.S.C. 2071, 2073, 2201, 2232, 2233, 2282); secs. 201, as amended 202, 204, 206, 88 stat. 1242, as amended, 1244, 1245, 1246 (42 U.S.C 5841, 5845, 5846).
Authority:
j                         Section 70.7 also issued under Pub. L. 95-601, sec. 10, 92 Stat. 2951 (42 U.S.C. 5851).             Section 70.21(g) also issued under sec. 122, 68 Stat. 939
Secs. 51, 53, 161, 182, 183, 68 stat. 929, 930, 948, 953, 954, as amended, sec. 234, 83 stat. 444, as amended (42 U.S.C. 2071, 2073, 2201, 2232, 2233, 2282); secs. 201, as amended 202, 204, 206, 88 stat. 1242, as amended, 1244, 1245, 1246 (42 U.S.C 5841, 5845, 5846).
!                  (42 U.S.C. 2152).             Section 70.31 also issued under sec. 57d, Pub. L. 93-377, 88 Stat. 475 (42 U.S.C. 2077).                     Sections 70.36 and 70.44 also issued under l                   sec. 184, 68 Stat. 954, as amended (42 U.S.C 2234).                                                         Section 70.61 also issued
j Section 70.7 also issued under Pub. L. 95-601, sec. 10, 92 Stat. 2951 (42 U.S.C. 5851).
:                  under secs. 186, 187, 68 Stat. 955 (42 U.S.C. 2236, 2237).                                                         Section 70.62 also
Section 70.21(g) also issued under sec. 122, 68 Stat. 939 (42 U.S.C. 2152).
[                   issued under sec. 108, 68 Stat. 939, as amended (42 U.S.C. 2138) i
Section 70.31 also issued under sec. 57d, Pub. L. 93-377, 88 Stat. 475 (42 U.S.C. 2077).
!                        For the purposes of Sec. 223, 68 Stat. 958, as amended (42 U.S.C. 2273);
Sections 70.36 and 70.44 also issued under l
l                 $$ 70.3 70.19(c), 70.21(c), 70.22(a), (b), (d)-(k), 70.24(a) and (b),
sec. 184, 68 Stat. 954, as amended (42 U.S.C 2234).
!                  70.32(a)(3), (5), (6), (d), and (1) 70.36, 70.39(b) and (c), 70.41(a),
Section 70.61 also issued under secs. 186, 187, 68 Stat. 955 (42 U.S.C. 2236, 2237).
Section 70.62 also
[
issued under sec. 108, 68 Stat. 939, as amended (42 U.S.C. 2138) i For the purposes of Sec. 223, 68 Stat. 958, as amended (42 U.S.C. 2273);
l
$$ 70.3 70.19(c), 70.21(c), 70.22(a), (b), (d)-(k), 70.24(a) and (b),
70.32(a)(3), (5), (6), (d), and (1) 70.36, 70.39(b) and (c), 70.41(a),
70.42(a) and (c), 70.56, 70.57(b), (c), and (d), 70.58(a)-(g)(3), and (h)-(j)
70.42(a) and (c), 70.56, 70.57(b), (c), and (d), 70.58(a)-(g)(3), and (h)-(j)
I                 are issued under sec. 161b, 68 Stat. 948, as amended (42 U.S.C. 2201(b));
I are issued under sec. 161b, 68 Stat. 948, as amended (42 U.S.C. 2201(b));
i
i
                  $$ 70.7, 70.20a(a) and (d), 70.20b(c) and (e), 70.21(c), 70.24(b),
$$ 70.7, 70.20a(a) and (d), 70.20b(c) and (e), 70.21(c), 70.24(b),
l                     >
l 18 i
18 i
.n-.
    .n-. . , . -        ,n         ...- ---,            - , . , . . - . . - - - , . - . _ _ _ _ . , - . .                              - - . . - - . . - . _ , _ _ _ _ , .
,n


70.32(a)(6),-(c), (d), (e), and (g), 70.36, 70.51(c)-(g), 70.56, 70.57(b) and (d), and 70.58(a)-(g)(3) and (h)-(j) are issued under sec. 1611, 68 Stat. 949, as amended (42 U.S.C. 2201(i)); and $$ 70.20(d) and (e), 70.38, 70.51(b) and (1), 70.52, 70.53, 70.54, 70.55, 70.58(g)(4), (k), and (1), 70.59, and 70.60(b) and (c) are issued under sec. 1610, 68 Stat. 950, as amended (42 U.S.C. 2201(o)).
70.32(a)(6),-(c), (d), (e), and (g), 70.36, 70.51(c)-(g), 70.56, 70.57(b) and (d), and 70.58(a)-(g)(3) and (h)-(j) are issued under sec. 1611, 68 Stat. 949, as amended (42 U.S.C. 2201(i)); and $$ 70.20(d) and (e), 70.38, 70.51(b) and (1), 70.52, 70.53, 70.54, 70.55, 70.58(g)(4), (k), and (1), 70.59, and 70.60(b) and (c) are issued under sec. 1610, 68 Stat. 950, as amended (42 U.S.C. 2201(o)).
: 2. In S 70.22, paragraph (b) is revised to read as follows:
2.
    $ 70.22 Contents of applications.
In S 70.22, paragraph (b) is revised to read as follows:
n               a                   a                   a           *
$ 70.22 Contents of applications.
n a
a a
(b) Each application for a licensee to possess and use at any one time and location special nuclear material in a quantity exceeding one effective kilogram except for applications for use as sealed sources and for those uses involved in the operation of a nuclear reactor licensed pursuant to Part 50 of this chapter and those involved in a waste disposal operation, must contain a full description of the applicant's program for control and accounting for that special nuclear material which will be in the applicant's possession under license, to show how compliance with the requirements of 5 70.58, S 74.31 or S 74.51 of this chapter, as applicable, will be accomplished.
(b) Each application for a licensee to possess and use at any one time and location special nuclear material in a quantity exceeding one effective kilogram except for applications for use as sealed sources and for those uses involved in the operation of a nuclear reactor licensed pursuant to Part 50 of this chapter and those involved in a waste disposal operation, must contain a full description of the applicant's program for control and accounting for that special nuclear material which will be in the applicant's possession under license, to show how compliance with the requirements of 5 70.58, S 74.31 or S 74.51 of this chapter, as applicable, will be accomplished.
: 3. In S 70.32, paragraph (c)(1) is revised to read as follows:
3.
    $ 70.32 Conditions of licenses
In S 70.32, paragraph (c)(1) is revised to read as follows:
* A                   A                   A            A (c)(1) Each license authorizing the possession and use at any one time and location of special nuclear material in a quantity exceeding one effective kilogram, except for use as sealed sources and those uses involved in the operation of a nuclear reactor licensed pursuant to Part 50 of this chapter, 19
$ 70.32 Conditions of licenses A
A A
A (c)(1) Each license authorizing the possession and use at any one time and location of special nuclear material in a quantity exceeding one effective kilogram, except for use as sealed sources and those uses involved in the operation of a nuclear reactor licensed pursuant to Part 50 of this chapter, 19


i j                                                                                                                                ..
j i
and those involved in a waste disposal operation shall contain and be subject f                       to a condition requiring the licensee to maintain and follow:
and those involved in a waste disposal operation shall contain and be subject f
to a condition requiring the licensee to maintain and follow:
i (i) The program for control and accounting for special nuclear material i
i (i) The program for control and accounting for special nuclear material i
i                       and fundamental nuclear material controls' described pursuant to $$ 70.22(b),
i and fundamental nuclear material controls' described pursuant to $$ 70.22(b),
70.58(1), 74.31(b) or 74.51(c)(1) of this chapter, as appropriate;
70.58(1), 74.31(b) or 74.51(c)(1) of this chapter, as appropriate; (ii) The measurement control program for special nuclear material control and accounting described pursuant to SS 70.57(c), 74.31(b) or 74.59(e) of this chapter, as appropriate; and i
;                              (ii) The measurement control program for special nuclear material control and accounting described pursuant to SS 70.57(c), 74.31(b) or 74.59(e) of this chapter, as appropriate; and i
(iii) Such other material control procedures as the Commission determines to be essential for the safeguarding of special nuclear material and providing that the licensee shall make no change which would decrease the effectiveness to the material control and accounting program prepared pursuant to 55 70.22(b),
(iii) Such other material control procedures as the Commission determines to be essential for the safeguarding of special nuclear material and providing that the licensee shall make no change which would decrease the effectiveness to the material control and accounting program prepared pursuant to 55 70.22(b),
70.58(1), 70.51(g), 74.31(b) or 74.51(c)(1) of this chapter, and the measurement
70.58(1), 70.51(g), 74.31(b) or 74.51(c)(1) of this chapter, and the measurement control program prepared pursuant to $$ 70.57(c), 74.31(b) or 74.59(e) of this l
,                      control program prepared pursuant to $$ 70.57(c), 74.31(b) or 74.59(e) of this ll chapter without the prior approval of the Commission.                     A licensee desiring to l                       make such changes shall submit an application for amendment to its license pur-i i                       suant to S 70.34.
chapter without the prior approval of the Commission.
n               a                         a                             a               a dl                             4. In S 70.51, paragraph (b) and the introductory text of paragraph (e)                             i
A licensee desiring to l
;                      are revised to read as follows:
l make such changes shall submit an application for amendment to its license pur-i i
i 5 70.51 Material balance, inventory, and records requirements
suant to S 70.34.
!                              n                                          a                           a               n l
n a
5
a a
;                              (b) Licensees subject to the recordkeeping requirements of $$ 74.31 and 74.59 of this chapter are exempt from the requirements of $ 70.51 (b)(1) l                       through (5).                                                                                                   I i
a dl 4.
!                      Otherwise:
In S 70.51, paragraph (b) and the introductory text of paragraph (e) i are revised to read as follows:
i 5 70.51 Material balance, inventory, and records requirements n
a a
n l
5 (b) Licensees subject to the recordkeeping requirements of $$ 74.31 and 74.59 of this chapter are exempt from the requirements of $ 70.51 (b)(1) l through (5).
I i
Otherwise:
t l
t l
!                                                                        20 l
20 l


A                               A                           A           A                   A (e) Each licensee who is authorized to possess at any one time special nuclear material in a quantity exceeding one effective kilogram of strategic special nuclear material in irradiated fuel reprocessing operations or special nuclear material of moderate strategic significance and to use such special nuclear material for activities other than as sealed sources or those activities involved in the operation of a nuclear reactor licensed pursuant to Part 50 of this chapter or those involved in a waste disposal operation; or as reactor irradiated fuels involved in research, development, and evaluation programs in facilities other than irradiated fuel reprocessing plants, shall:
A A
A                               A                             A           A                   A
A A
: 5.             In S 70.57, the introduction to paragraph (b) is revised to read as follows:
A (e) Each licensee who is authorized to possess at any one time special nuclear material in a quantity exceeding one effective kilogram of strategic special nuclear material in irradiated fuel reprocessing operations or special nuclear material of moderate strategic significance and to use such special nuclear material for activities other than as sealed sources or those activities involved in the operation of a nuclear reactor licensed pursuant to Part 50 of this chapter or those involved in a waste disposal operation; or as reactor irradiated fuels involved in research, development, and evaluation programs in facilities other than irradiated fuel reprocessing plants, shall:
A A
A A
A 5.
In S 70.57, the introduction to paragraph (b) is revised to read as follows:
S 70.57 Measurement control program for special nuclear material control and accounting.
S 70.57 Measurement control program for special nuclear material control and accounting.
A                               A                             A           A                   A (b) In accordance with S 70.58(f), each licensee who is authorized to possess at any one time and location strategic special nuclear material in irradiated fuel reprocessing operations or special nuclear material of moderate strategic significance in a quantity exceeding one effective kilogram and to use such special nuclear material for activities other than as sealed sources or those activities involved in the operation of a nuclear reactor licensed pursuant to Part 50 of this chapter, or those involved in waste disposal operations, shall establish and maintain a measurement control program for special nuclear material control and accounting measurements.                       Each program function shall be identified and assigned in the licensee organization in 21
A A
A A
A (b) In accordance with S 70.58(f), each licensee who is authorized to possess at any one time and location strategic special nuclear material in irradiated fuel reprocessing operations or special nuclear material of moderate strategic significance in a quantity exceeding one effective kilogram and to use such special nuclear material for activities other than as sealed sources or those activities involved in the operation of a nuclear reactor licensed pursuant to Part 50 of this chapter, or those involved in waste disposal operations, shall establish and maintain a measurement control program for special nuclear material control and accounting measurements.
Each program function shall be identified and assigned in the licensee organization in 21


I accordance with 9 70.58(b)(2), and functional and organizational relationships shall be set forth in writing in accordance with 8 70.58(b)(3). The program shall be described in a manual referenced in the Plan which shall contain the proce-dures, instructions, and forms prepared to meet the requirements of this para-graph, including procedures for the preparation, review, approval, and prompt dissemination of any program modifications or changes. The licensee's program shall include the following:
I accordance with 9 70.58(b)(2), and functional and organizational relationships shall be set forth in writing in accordance with 8 70.58(b)(3).
: 6. In S 70.58, paragraph (a) is revised to read as follows:
The program shall be described in a manual referenced in the Plan which shall contain the proce-dures, instructions, and forms prepared to meet the requirements of this para-graph, including procedures for the preparation, review, approval, and prompt dissemination of any program modifications or changes.
                  $ 70.58 Fundamental nuclear material controls.
The licensee's program shall include the following:
(a) Each licensee who is authorized to possess at any one time and location strategic special nuclear material in irradiated fuel reprocessing operations or special nuclear material of moderate strategic significance in a quantity exceeding one effective kilogram, and to use such special nuclear material except for sealed sources and those uses involved in the operation of a nuclear reactor licensed pursuant to part 50 of this chapter and those involved in a waste disposal operation, shall establish, maintain, and follow written material control and accounting procedures in compliance with the fundamental nuclear material control requirements specified in paragraphs (b) through (k) of this
6.
;                section and such other controls as the Commission determines to be essential l
In S 70.58, paragraph (a) is revised to read as follows:
l                 for the control of and accounting for special nuclear material.
$ 70.58 Fundamental nuclear material controls.
A               A                   A                 A               A i
(a) Each licensee who is authorized to possess at any one time and location strategic special nuclear material in irradiated fuel reprocessing operations or special nuclear material of moderate strategic significance in a quantity exceeding one effective kilogram, and to use such special nuclear material except for sealed sources and those uses involved in the operation of a nuclear reactor licensed pursuant to part 50 of this chapter and those involved in a waste disposal operation, shall establish, maintain, and follow written material control and accounting procedures in compliance with the fundamental nuclear material control requirements specified in paragraphs (b) through (k) of this section and such other controls as the Commission determines to be essential l
l for the control of and accounting for special nuclear material.
A A
A A
A i
i 22
i 22


PART 74 - MATERIAL CONTROL AND ACCOUNTING OF SPECIAL NUCLEAR MATERIAL
PART 74 - MATERIAL CONTROL AND ACCOUNTING OF SPECIAL NUCLEAR MATERIAL 7.
: 7. The authority citation for Part 74 continues to read as follows:
The authority citation for Part 74 continues to read as follows:
AUTHORITY: Secs. 53, 57, 161, 182, 183, 68 Stat. 930, 932, 948, 953, 954, as amended, sec. 234, 83 Stat. 444, as amended (42 U.S.C. 2073, 2077, 2201,2232,2233,2282); secs.202,206,88 Stat.1244,1246(42U.S.C2273);
AUTHORITY: Secs. 53, 57, 161, 182, 183, 68 Stat. 930, 932, 948, 953, 954, as amended, sec. 234, 83 Stat. 444, as amended (42 U.S.C. 2073, 2077, 2201,2232,2233,2282); secs.202,206,88 Stat.1244,1246(42U.S.C2273);
il 74.31, 74.81, and 71.82 are issued under secs.161b and 1611, 68 Stat. 948, 949asamended(42U.S.C.2201(b),2201(1));andil74.11,74.13,and74.15 are issued under sec. 1610, 68 Stat. 950, as amended (42 U.S.C 2201(o)).         ,
il 74.31, 74.81, and 71.82 are issued under secs.161b and 1611, 68 Stat. 948, 949asamended(42U.S.C.2201(b),2201(1));andil74.11,74.13,and74.15 are issued under sec. 1610, 68 Stat. 950, as amended (42 U.S.C 2201(o)).
: 8. Section 74.4 is amended by placing the following definitions in the proper alphabetical sequence.
8.
Section 74.4 is amended by placing the following definitions in the proper alphabetical sequence.
6 74.4 Definitions As used in this part:
6 74.4 Definitions As used in this part:
              " Abrupt loss" means a loss occurring in the time interval between consecu-tive sequential performances of a material control test which is designed to detect anomalies potentially indicative of a loss of strategic special nuclear material from a specific unit of SSNM (i.e., a quantity characterized by a unique measurement) introduced into a process.
" Abrupt loss" means a loss occurring in the time interval between consecu-tive sequential performances of a material control test which is designed to detect anomalies potentially indicative of a loss of strategic special nuclear material from a specific unit of SSNM (i.e., a quantity characterized by a unique measurement) introduced into a process.
              " Accessible location" means a process location at which SSNM could be acquired without leaving evidence of the acquisition, i.e., without tools or other equipment to obviously violate the integrity of the containment.
" Accessible location" means a process location at which SSNM could be acquired without leaving evidence of the acquisition, i.e., without tools or other equipment to obviously violate the integrity of the containment.
              " Additions to material in process" means:   (i) receipts that are opened, except for receipts opened only for sampling and subsequently maintained under 23
" Additions to material in process" means:
(i) receipts that are opened, except for receipts opened only for sampling and subsequently maintained under 23


t I
t I
j   tamper-safing;(ii) opened sealed sources; and (iii) material removed from process for nonconformance with chemical or physical specifications that is subsequently reprocessed, measured for contained SSNM, and reintroduced to process.
j tamper-safing;(ii) opened sealed sources; and (iii) material removed from process for nonconformance with chemical or physical specifications that is subsequently reprocessed, measured for contained SSNM, and reintroduced to process.
            "Alam Threshold" means a predetermined quantity of SSNM calculated from l
l "Alam Threshold" means a predetermined quantity of SSNM calculated from
{   the specified probability of detection for a given loss and the standard devia-I tion associated with a material control test. An alann threshold serves to trigger a response action.
{
l           " Bias" means the deviation of the expected value of a random variable from the corresponding correct or assigned value.                                        .
the specified probability of detection for a given loss and the standard devia-I tion associated with a material control test. An alann threshold serves to trigger a response action.
            " Calibration" means the process of detennining the numerical relationship between the observed output of a measurement system and the value, based upon i
l
j   reference standards, of the characteristic being measured.
" Bias" means the deviation of the expected value of a random variable from the corresponding correct or assigned value.
            " Category IA material" means SSNM directly useable in the manufacture of a t
" Calibration" means the process of detennining the numerical relationship between the observed output of a measurement system and the value, based upon i
nuclear explosive device, except if:
j reference standards, of the characteristic being measured.
J
" Category IA material" means SSNM directly useable in the manufacture of a nuclear explosive device, except if:
!          (1) The dimensions are large enough (at least two meters in one dimension, greater than one meter in each of two dimensions, or greater than 25cm in
t J
!    eachofthreedimensions)toprecludehidingtheitemonanindividual, i
(1) The dimensions are large enough (at least two meters in one dimension, greater than one meter in each of two dimensions, or greater than 25cm in eachofthreedimensions)toprecludehidingtheitemonanindividual, i
l           (2) The total weight of five fonnula kilograms of SSNM plus its matrix (at least 50 kilograms) cannot be carried inconspicuously by one person, or j           (3) The quantity of SSNM (less than 0.05 fonnula kilograms) in each container requires protracted diversions in order to accumulate five l   formula kilograms.
l (2) The total weight of five fonnula kilograms of SSNM plus its matrix (at least 50 kilograms) cannot be carried inconspicuously by one person, or j
* l           " Category IB material" means all SSNM material other than Category IA.
(3) The quantity of SSNM (less than 0.05 fonnula kilograms) in each container requires protracted diversions in order to accumulate five l
            " Continuous process" means a unit process in which feed material must be l   introduced in a systematic manner in order to maintain equilibrium conditions.
formula kilograms.
l
" Category IB material" means all SSNM material other than Category IA.
" Continuous process" means a unit process in which feed material must be l
introduced in a systematic manner in order to maintain equilibrium conditions.
I 24
I 24


'~
'~
                " Controlled access area" means any temporarily or permanently established area which is clearly demarcated, access to which is controlled, and which affords isolation of the material or persons within it.
" Controlled access area" means any temporarily or permanently established area which is clearly demarcated, access to which is controlled, and which affords isolation of the material or persons within it.
                " Element" means uranium or plutonium.
" Element" means uranium or plutonium.
                " Estimate" means a specific numerical value arrived at by the application of an estimator.
" Estimate" means a specific numerical value arrived at by the application of an estimator.
                " Estimator" means a function of a sample measurement used to estimate a population parameter.
" Estimator" means a function of a sample measurement used to estimate a population parameter.
                " Fissile isotope" means: (1) uranium U-233 or (2) uranium-235 by enrichment category, (3) plutonium-239, and (4) plutonium-241.
" Fissile isotope" means: (1) uranium U-233 or (2) uranium-235 by enrichment category, (3) plutonium-239, and (4) plutonium-241.
                " Formula kilogram" means SSNM in any combination in a quantity of 1000 grams computed by the formula, grams = (grams contained U-235) + 2.5 (grams U-233 +
" Formula kilogram" means SSNM in any combination in a quantity of 1000 grams computed by the formula, grams = (grams contained U-235) + 2.5 (grams U-233 +
grams plutonium).
grams plutonium).
                " License," except where otherwise specified, means a ifcense issued pursuant to Part 70 of this chapter.
" License," except where otherwise specified, means a ifcense issued pursuant to Part 70 of this chapter.
                " Material" means special nuclear material.
" Material" means special nuclear material.
                " Material access area" means any location which contains special nuclear material, within a vault or a building, the roof, walls, and floor of which constitute a physical barrier.
" Material access area" means any location which contains special nuclear material, within a vault or a building, the roof, walls, and floor of which constitute a physical barrier.
                " Material balance" means the determination of an inventory difference (I0).
" Material balance" means the determination of an inventory difference (I0).
                "MC&A alarm" means a situation in which there is: (1) an out-of-location item or an item whose integrity has been violated, (2) an indication of a flow of SSNM where there should be none, or (3) a difference between a measured or observed amount or property of material and its corresponding predicted or pro-perty value that exceeds a threshold established to provide the detection capa-bility required by 9 74.53, 25
"MC&A alarm" means a situation in which there is: (1) an out-of-location item or an item whose integrity has been violated, (2) an indication of a flow of SSNM where there should be none, or (3) a difference between a measured or observed amount or property of material and its corresponding predicted or pro-perty value that exceeds a threshold established to provide the detection capa-bility required by 9 74.53, 25


          " Material control test" means a comparison of a pre-established alarm threshold with the results of a process difference or process yield performed on a unit process.
" Material control test" means a comparison of a pre-established alarm threshold with the results of a process difference or process yield performed on a unit process.
          " Material in process" means any special nuclcar material possessed by the
" Material in process" means any special nuclcar material possessed by the licensee except in unopened receipts, sealed sources, measured waste discards, and ultimate product maintained under tamper-safing.
  , licensee except in unopened receipts, sealed sources, measured waste discards, and ultimate product maintained under tamper-safing.
" Power of detection" means the probability that the critical value of a statistical test will be exceeded when there is an actual loss of a specific SSNM quantity.
          " Power of detection" means the probability that the critical value of a statistical test will be exceeded when there is an actual loss of a specific SSNM quantity.
" Process difference" (PD) means the determination of an ID on a unit pro-cess level with the additional qualification that difficult to measure compon-ents may be modelled.
          " Process difference" (PD) means the determination of an ID on a unit pro-cess level with the additional qualification that difficult to measure compon-
" Process yield" means the quantity of SSNM actually removed from a unit process compared with the quantity predicted (based on a measured input) to be available for removal.
  , ents may be modelled.
Process yield differs from a process difference in that holdup and sidestreams are not measured or modelled.
          " Process yield" means the quantity of SSNM actually removed from a unit process compared with the quantity predicted (based on a measured input) to be available for removal.     Process yield differs from a process difference in that holdup and sidestreams are not measured or modelled.
" Produce" when used in relation to special nuclear material, means: (1) to manufacture, make, produce, or refine special nuclear material; (2) to separate special nuclear material from other substances in which such material may be i
          " Produce" when used in relation to special nuclear material, means: (1) to manufacture, make, produce, or refine special nuclear material; (2) to separate special nuclear material from other substances in which such material may be i
contained; or (3) to make or to produce new special nuclear material.
contained; or (3) to make or to produce new special nuclear material.
i l
i l
          " Random error" means the deviation of a random variable from its expected value.
" Random error" means the deviation of a random variable from its expected value.
I         " Receipt" means special nuclear material received by a licensee from an f   off-site source.
I
" Receipt" means special nuclear material received by a licensee from an f
off-site source.
l l
l l
26 l
26 l
Line 388: Line 594:


4
4
            " Reference standard" means a material, device, or instrument whose assigned value is known relative to national standards or nationally' accepted measurement systems. This is also commonly referred to as a traceable standard.
" Reference standard" means a material, device, or instrument whose assigned value is known relative to national standards or nationally' accepted measurement systems.
            " Removals" means measured quantities of special nuclear material disposed of as discards, encapsulated as a sealed source, or in ultimate product placed under tamper-safing or shipped offsite.
This is also commonly referred to as a traceable standard.
            "Research and development" means: (1) theoretical analysis, exploration, or experimentation; or (2) the extension of investigative findings and theories of a scientific or technical nature into practical application for experimental and demonstration purposes, including the experimental production and testing of models, devices, equipment, materials, and processes.
" Removals" means measured quantities of special nuclear material disposed of as discards, encapsulated as a sealed source, or in ultimate product placed under tamper-safing or shipped offsite.
            " Scrap" means the various forms of special nuclear material generated dur-ing chemical and mechanical processing, other than recycle material and normal process intermediates, which are unsuS,able for continued processing, but all or part of which will be converted t useable material by appropriate recovery operations.
"Research and development" means: (1) theoretical analysis, exploration, or experimentation; or (2) the extension of investigative findings and theories of a scientific or technical nature into practical application for experimental and demonstration purposes, including the experimental production and testing of models, devices, equipment, materials, and processes.
            " Sealed source" means any special nuclear material that is physically encased in a capsule, rod, element, etc. that prevents the leakage or escape of the special nuclear material and that prevents removal of the special nuclear material without penetration of the casing.
" Scrap" means the various forms of special nuclear material generated dur-ing chemical and mechanical processing, other than recycle material and normal process intermediates, which are unsuS,able for continued processing, but all or part of which will be converted t useable material by appropriate recovery operations.
            " Standard Error of the Inventory Difference" (SEID) means the standard deviation of an inventory difference that takes into account all measurement error contributions to the components of the 10.
" Sealed source" means any special nuclear material that is physically encased in a capsule, rod, element, etc. that prevents the leakage or escape of the special nuclear material and that prevents removal of the special nuclear material without penetration of the casing.
            " Standard Error of the Process Difference" means the itandard deviation of a process difference value that takes into account both measurement and nonmea-surement contributions to the components of PD.
" Standard Error of the Inventory Difference" (SEID) means the standard deviation of an inventory difference that takes into account all measurement error contributions to the components of the 10.
" Standard Error of the Process Difference" means the itandard deviation of a process difference value that takes into account both measurement and nonmea-surement contributions to the components of PD.
27 u
27 u


              " Tamper-safing" means the use of devices on containers or vaults in a manner and at a time that ensures a clear indication of any violation of the integrity of previously made measurements of special nuclear material within the container or vault.
" Tamper-safing" means the use of devices on containers or vaults in a manner and at a time that ensures a clear indication of any violation of the integrity of previously made measurements of special nuclear material within the container or vault.
              " Traceability" means the ability to relate individual measurement results to national standards or nationally accepted measurement systems through an unbroken chain of comparisons.
" Traceability" means the ability to relate individual measurement results to national standards or nationally accepted measurement systems through an unbroken chain of comparisons.
              " Ultimate product" means any special nuclear material in the form of a pro-duct that would not be further processed at that licensed location.
" Ultimate product" means any special nuclear material in the form of a pro-duct that would not be further processed at that licensed location.
              " Unit process" means an identifiable segment or segments of processing activities for which the amounts of input and output SSNM are based on measurements.
" Unit process" means an identifiable segment or segments of processing activities for which the amounts of input and output SSNM are based on measurements.
              " Unopened receipts" means receipts not opened by the licensee, including receipts of sealed sources, and receipts opened only for sampling and sub-sequently maintained under tamper-safing.
" Unopened receipts" means receipts not opened by the licensee, including receipts of sealed sources, and receipts opened only for sampling and sub-sequently maintained under tamper-safing.
              " Vault" means a windowless enclosure with walls, floor, roof and door (s) designed and constructed to delay penetration from forced entry.
" Vault" means a windowless enclosure with walls, floor, roof and door (s) designed and constructed to delay penetration from forced entry.
: 9.     Subpart E ($$ 74.51 through 74.59) is added to read as follows:
9.
Subpart E ($$ 74.51 through 74.59) is added to read as follows:
t i
t i
28
28
Line 413: Line 621:
74.59 Quality Assurance and Accounting.
74.59 Quality Assurance and Accounting.
Subpart E - Formula Quantities of Strategic Special Nuclear Material
Subpart E - Formula Quantities of Strategic Special Nuclear Material
                                            $ 74.51 Nuclear Material Control and Accounting for Strategic Special Nuclear Material.
$ 74.51 Nuclear Material Control and Accounting for Strategic Special Nuclear Material.
(a) General performance objectives.                         Each licensee who is authorized to possess five or more formula kilograms of strategic special nuclear material (SSNM) and to use such material at any site, other than a nuclear reactor licensed pursuant to Part 50 of this chapter, an irradiated fuel reprocessing plant, or an operation involved with waste disposal shall establish, implement, and maintain a Commission approved material control and accounting (MC&A) system that will achieve the following objectives:
(a) General performance objectives.
Each licensee who is authorized to possess five or more formula kilograms of strategic special nuclear material (SSNM) and to use such material at any site, other than a nuclear reactor licensed pursuant to Part 50 of this chapter, an irradiated fuel reprocessing plant, or an operation involved with waste disposal shall establish, implement, and maintain a Commission approved material control and accounting (MC&A) system that will achieve the following objectives:
(1) Prompt investigation of anomalies potentially indicative of SSNM losses; (2) Timely detection of the possible abrupt loss of five or more formula kilograms of SSNM from an individual unit process; 29
(1) Prompt investigation of anomalies potentially indicative of SSNM losses; (2) Timely detection of the possible abrupt loss of five or more formula kilograms of SSNM from an individual unit process; 29


(3) Rapid determination of whether an actual loss of five or more formula i   kilograms occurred; (4) Ongoing confirmation of the presence of SSNM in assigned locations; and l         (5) Timely generation of information to aid in the recovery of SSNM in the event of an actual loss.
(3) Rapid determination of whether an actual loss of five or more formula i
l, j         (b) System Casabilities. To achieve the general performance objectives j   specified in S 74.51(a), the MC&A system must provide the capabilities described in SS 74.53, 74.55, 74.57 and 74.59, and must incorporate checks and balances that are sufficient to detect falsification of data and reports that could         ,
kilograms occurred; (4) Ongoing confirmation of the presence of SSNM in assigned locations; and l
conceal diversion by:
(5) Timely generation of information to aid in the recovery of SSNM in the event of an actual loss.
(1) An individual, including an employee in any position; or (2) Collusion between an individual with MC&A responsibilities and
l, j
: j. another individual who has responsibility or control within both the physical l   protection and the MC&A systems.
(b) System Casabilities.
(c)   !aolementation dates. Each licensee subject to the requirements of paragraph (a) of this section shall:
To achieve the general performance objectives j
specified in S 74.51(a), the MC&A system must provide the capabilities described in SS 74.53, 74.55, 74.57 and 74.59, and must incorporate checks and balances that are sufficient to detect falsification of data and reports that could conceal diversion by:
(1) An individual, including an employee in any position; or (2) Collusion between an individual with MC&A responsibilities and j.
another individual who has responsibility or control within both the physical l
protection and the MC&A systems.
(c)
!aolementation dates.
Each licensee subject to the requirements of paragraph (a) of this section shall:
(1) No later than (150 days after the effective date of these amendments),
(1) No later than (150 days after the effective date of these amendments),
submit a fundamental nuclear material control (FNMC) plan describing how the i
submit a fundamental nuclear material control (FNMC) plan describing how the i
Itcensee will comply with the requirements of paragraph (b) of this section; and I
Itcensee will comply with the requirements of paragraph (b) of this section; and I
l         (2) Within (360 days of the effective date of these amendments) or 90 days t
l (2) Within (360 days of the effective date of these amendments) or 90 days t
j   after the plan submitted pursuant to paragraph (c)(1) of this section is approved, whichever is later, implement the approved plan.     Current FNMC plans must be i
j after the plan submitted pursuant to paragraph (c)(1) of this section is approved, whichever is later, implement the approved plan.
l   followed untti new plans are approved by the NRC.
Current FNMC plans must be i
l followed untti new plans are approved by the NRC.
l l
l l
30 1
30 1
Line 434: Line 651:


(d) Exemptions.
(d) Exemptions.
(1) Notwithstanding paragraph (c)(2) of this section, a licensee may delay, for an additional 18 months, implementation of provisions of the plan involving process shutdown for resolution of alarms.                                             However, during such delay, the licensee shall continue to conduct inventories at bimonthly intervals.
(1) Notwithstanding paragraph (c)(2) of this section, a licensee may delay, for an additional 18 months, implementation of provisions of the plan involving process shutdown for resolution of alarms.
(2) Notwithstanding 574.59(f)(1), licensees shall perform bimonthly physical inventories for six months after NRC approval of the FNMC Plan submitted in response to the requirements of this Part or until the licensee has demonstrated performance acceptable to the NRC against all plan commitments and has received formal Commission approval to perform semiannual inventories.                                                                   ,
However, during such delay, the licensee shall continue to conduct inventories at bimonthly intervals.
4 5 74.53 Process Monitorina (a) Licensees subject to S 74.51 shall monitor internal transfers, storage, and processing of SSNM.         The process monitoring must achieve the a                detection capabilities described in paragraph (b) of this section for all SSNM except:
(2) Notwithstanding 574.59(f)(1), licensees shall perform bimonthly physical inventories for six months after NRC approval of the FNMC Plan submitted in response to the requirements of this Part or until the licensee has demonstrated performance acceptable to the NRC against all plan commitments and has received formal Commission approval to perform semiannual inventories.
4 5 74.53 Process Monitorina (a) Licensees subject to S 74.51 shall monitor internal transfers, storage, and processing of SSNM.
The process monitoring must achieve the detection capabilities described in paragraph (b) of this section for all a
SSNM except:
(1) SSNM that is subject to the item loss detection requirements of
(1) SSNM that is subject to the item loss detection requirements of
                  $74.55; j                       (2) Scrap in the form of small pieces, cuttings, chips, solutions or in other forms that result from a manufacturing process, held in containers of 30 gallons or larger, with an SSNM content of less than 0.25 grams per liter; (3) SSNM with an estimated measurement standard deviation greater than five percent that is either input or output material associated with a unit that processes less than five formula kilograms over a consecutive three-month period; and 31
$74.55; j
__ . . .        _ - . . _ ~ . . - . - . - _ - -      _
(2) Scrap in the form of small pieces, cuttings, chips, solutions or in other forms that result from a manufacturing process, held in containers of 30 gallons or larger, with an SSNM content of less than 0.25 grams per liter; (3) SSNM with an estimated measurement standard deviation greater than five percent that is either input or output material associated with a unit that processes less than five formula kilograms over a consecutive three-month period; and 31
. _ ~.


(4) 55 m involved in research and development operations that process less than five formula kilograms during any seven-consecu.tive-day period.
(4) 55 m involved in research and development operations that process less than five formula kilograms during any seven-consecu.tive-day period.
;                      (b) Unit Process Detection Cacability. For each unit process, a licensee 1                 shall establish a production quality control program capable of monitoring the j                 status of material in process. The program shall include:
(b) Unit Process Detection Cacability.
(1) A statistical test that has at least a 95 percent power of detecting an abrupt loss of five formula kilograms within three working days of a loss of
For each unit process, a licensee 1
  !                Category IA material from any accessible process location and within seven calendar days of a loss of Category IB material from any accessible process               !
shall establish a production quality control program capable of monitoring the j
Iocation; j                       (2) A quality control test whereby process differences greater than three i                 times the estimated standard deviation of the process difference estimator and j                 25 grams of SSW are investigated; and (3) A trend analysis for monitoring and evaluating sequences of material l
status of material in process. The program shall include:
control test results from each unit process to detemine if they indicate a
(1) A statistical test that has at least a 95 percent power of detecting an abrupt loss of five formula kilograms within three working days of a loss of Category IA material from any accessible process location and within seven calendar days of a loss of Category IB material from any accessible process Iocation; j
!                  pattern of losses or gains that are of safeguards significance.
(2) A quality control test whereby process differences greater than three i
!                        (c) For research and development operations exempt from the requirements of i
times the estimated standard deviation of the process difference estimator and j
j                 paragraph (b)ofthissection,thelicenseeshall:
25 grams of SSW are investigated; and (3) A trend analysis for monitoring and evaluating sequences of material l
i                                                                                                           ,
control test results from each unit process to detemine if they indicate a pattern of losses or gains that are of safeguards significance.
(1) Perform material balance tests on a lot or a batch basis, as appro-i                 priate, or monthly, whichever is sooner, and investigate any difference greater l                 than 200 grams of plutonium or U-233 or 300 grams of U-235 that exceeds three           ;
(c) For research and development operations exempt from the requirements of i
!                                                                                                          l times the estimated standard error of the inventory difference estimator;
j paragraph (b)ofthissection,thelicenseeshall:
i (1) Perform material balance tests on a lot or a batch basis, as appro-i priate, or monthly, whichever is sooner, and investigate any difference greater l
than 200 grams of plutonium or U-233 or 300 grams of U-235 that exceeds three l
{
{
times the estimated standard error of the inventory difference estimator; l
~
~
l
(2) Evaluate material balance results generated during an inventory period for indications of measurement biases or unidentified loss streams and investi-j gate, determine the cause(s) of, and institute corrective action for cumulative l
;                        (2) Evaluate material balance results generated during an inventory period for indications of measurement biases or unidentified loss streams and investi-j                 gate, determine the cause(s) of, and institute corrective action for cumulative         l l                                                                                                           !
l 32 l
32                                               l l
l 1
1                                                                                                           .


inventory differences generated during an inventory period that exceed three formula kilograms of SSM.
inventory differences generated during an inventory period that exceed three formula kilograms of SSM.
      $ 74.55 Item monitorina (a)   Licensees subject to 5 74.51 shall provide the detection capability described in paragraph (b) of this section for laboratory samples containing less than 0.05 formula kilograms of SSM and any uniquely identified items of SS M that have been quantitatively measured, the validity of that measurement independently confirmed, and that additionally have been either:
$ 74.55 Item monitorina (a)
Licensees subject to 5 74.51 shall provide the detection capability described in paragraph (b) of this section for laboratory samples containing less than 0.05 formula kilograms of SSM and any uniquely identified items of SS M that have been quantitatively measured, the validity of that measurement independently confirmed, and that additionally have been either:
(1) Tamper-safed or placed in a vault or controlled access area that pro-vides protection at least equivalent to tamper-safing; or (2) Sealed such that removal of SS W would be readily and permanently apparent (e.g., encapsulated).
(1) Tamper-safed or placed in a vault or controlled access area that pro-vides protection at least equivalent to tamper-safing; or (2) Sealed such that removal of SS W would be readily and permanently apparent (e.g., encapsulated).
(b) The licensee shall verify on a statistical sampling basis, the pre-sence and integrity of SSW ltems.     The statistical sampling plan must have at least a 99 percent power of detecting item losses that total five formula kilo-grams or more, plant-wide, within:
(b) The licensee shall verify on a statistical sampling basis, the pre-sence and integrity of SSW ltems.
(1)   Thirty calendar days for Category IA items and 60 calendar days for Category IB items contained in a vault or in a permanently controlled access area isolated from the rest of the material access area (MAA);
The statistical sampling plan must have at least a 99 percent power of detecting item losses that total five formula kilo-grams or more, plant-wide, within:
(1)
Thirty calendar days for Category IA items and 60 calendar days for Category IB items contained in a vault or in a permanently controlled access area isolated from the rest of the material access area (MAA);
(2) Three working days for Category IA items and seven calendar days for Category IB items located elsewhere in the MAA, except for reactor components measuring at least one meter in length and weighing in excess of 30 kilograms for which the time interval shall be 30 calendar days; 33
(2) Three working days for Category IA items and seven calendar days for Category IB items located elsewhere in the MAA, except for reactor components measuring at least one meter in length and weighing in excess of 30 kilograms for which the time interval shall be 30 calendar days; 33


f
f
                                                                                    /
/
(3) Sixtycalendardaysforitemsina.permanentlycontrolledacAssarea outside of an MAA;                           '
(3) Sixtycalendardaysforitemsina.permanentlycontrolledacAssarea outside of an MAA; (4) Sixty calendar days for saur.ies in a vault or permanently controlled access area and 30 calendar days for samples elsewhere in the MAA for samples
(4) Sixty calendar days for saur.ies in a vault or permanently controlled access area and 30 calendar days for samples elsewhere in the MAA for samples each containing less than 0.05 formula kilograms of SSNM.      ,
(
(
(c) Items containing scrap in the form of small pieces, cuttings,-chips, solutions or in other forms that result from a manufacturing process, held in               ,
each containing less than 0.05 formula kilograms of SSNM.
containers of 30 gallon or,largar, with an SSNM concentration of less thin 0.25 grams per liter are exempt from the requirements of,paragrarh (b) Sf this section.
(c) Items containing scrap in the form of small pieces, cuttings,-chips, solutions or in other forms that result from a manufacturing process, held in containers of 30 gallon or,largar, with an SSNM concentration of less thin 0.25 grams per liter are exempt from the requirements of,paragrarh (b) Sf this section.
6 74.57 Alarm resolution (a) Licensees subject to i 74.51 shall provide the MC&A alarm resolution       ,
6 74.57 Alarm resolution (a) Licensees subject to i 74.51 shall provide the MC&A alarm resolution capabilities described in paragraphs (b) through (f) of this section.
capabilities described in paragraphs (b) through (f) of this section.                             ,
)
(b) Licensees shall resolve the nature and cause of any liCAA alarm within               -
(b) Licensees shall resolve the nature and cause of any liCAA alarm within approved time periods.
                                                                                                  )
l (c) Each licensee shall notify by telephone, the appreoriate NRC Regional l
approved time periods.
Office listed in Appendix A of Part 73 of this cheptar of any l'CSA alarm that remains unresolved beyond the time period specified for its resolution in the licensee's fundamentcl nuclear materitt control plan. Notification shall occur l
(c) Each licensee shall notify by telephone, the appreoriate NRC Regional l
within 24 hours except when a holiday or wedend intervene in which car.e the notification shall occur on the next scheduled workday.
l Office listed in Appendix A of Part 73 of this cheptar of any l'CSA alarm that remains unresolved beyond the time period specified for its resolution in the licensee's fundamentcl nuclear materitt control plan. Notification shall occur l
The licensee may con-i sider an alarm to be resolved if:
within 24 hours except when a holiday or wedend intervene in which car.e the i
notification shall occur on the next scheduled workday. The licensee may con-         ;
sider an alarm to be resolved if:
(1) Clerical or computational error is found that clearly was the cause for the alarm; 34 l
(1) Clerical or computational error is found that clearly was the cause for the alarm; 34 l


gie             v ,e C   -                "
gie v,e C
f           . r- ' >
f
r;       l       ;
. r-r; l
?
?
(2) An assignable cause for the alarm is identified or it is substantiated
(2) An assignable cause for the alarm is identified or it is substantiated
                      ' that no material loss has occurred.
' that no material loss has occurred.
      ~
~
(d)     If a material loss has occurred, the licensee shall determine the' amount of SSNM lost and take corrective action to:
(d)
                                ' #(1) keturnout-ofplaceSSNM,ifpossible,toitsappropriateplace;
If a material loss has occurred, the licensee shall determine the' amount of SSNM lost and take corrective action to:
        /
' #(1) keturnout-ofplaceSSNM,ifpossible,toitsappropriateplace;
(2) Update and correct associated records; and (3) Modify'the MC&A system, if appropriate, to prevent similar future occurrences.,' :'       ,,      >
/
(2) Update and correct associated records; and (3) Modify'the MC&A system, if appropriate, to prevent similar future occurrences.,' :'
(e) The licensee shall provide an ability to rapidly assess the validity of alleged thefts.
(e) The licensee shall provide an ability to rapidly assess the validity of alleged thefts.
                                                                                                                          ~
~
(f)       If an abrupt loss detection estimate exceeds five formula kilograms of SSNM:
(f)
e,                               (1) Material processing operations related to the alarm must be suspended until completion of planned alare resolution activities, unless the suspension
If an abrupt loss detection estimate exceeds five formula kilograms of SSNM:
//                       of operations will adversely affect the ability to resolve the alarm.             Operation of continuous processes may continue for 24 hours from the time of the occurrence
e, (1) Material processing operations related to the alarm must be suspended until completion of planned alare resolution activities, unless the suspension
                          % che alarm during which time checks shall be made for mistakes in records or
//
          .        i     ;
of operations will adversely affect the ability to resolve the alarm.
Operation of continuous processes may continue for 24 hours from the time of the occurrence
% che alarm during which time checks shall be made for mistakes in records or i
calculations that could have caused the alarm.
calculations that could have caused the alarm.
(2) Within 24 ho'urs,- the licensee shall notify the appropriate NRC Regional Office by telephone that an MC&A alarm resolution proci. dure has been initiated.
(2) Within 24 ho'urs,- the licensee shall notify the appropriate NRC Regional Office by telephone that an MC&A alarm resolution proci. dure has been initiated.
                  /
/
                          $ 74'.59 Quality Assurance and Accountina Requirements (a)     Licensees subject to $ 74.51 shall provide the quality assurance and accounting capabilities descritied in paragraphs (b) through (h) of this section.
$ 74'.59 Quality Assurance and Accountina Requirements (a)
Licensees subject to $ 74.51 shall provide the quality assurance and accounting capabilities descritied in paragraphs (b) through (h) of this section.
35 L''
35 L''
w,-------.mn                           nn
w,-------.mn nn


  . .                                                                                          ~
~
t (b) ManagementStructbr.e. The licensee shall:
t (b) ManagementStructbr.e.
The licensee shall:
(1) Establish and mah)tain 'a management structure that includes clear overall responsibility for planning, coordinating, and administering material control and accounting functions, independence of material control and accounting functions from production responsibilities, and separation of functions such that the activities of one individual or organizational unit serve as controls over and' checks of the activities of others; and
(1) Establish and mah)tain 'a management structure that includes clear overall responsibility for planning, coordinating, and administering material control and accounting functions, independence of material control and accounting functions from production responsibilities, and separation of functions such that the activities of one individual or organizational unit serve as controls over and' checks of the activities of others; and
            ' (2) Provide for the adequate review, approval, and use of those material l       control and accounting procedures that are identified in the approved FNMC plan as being critical to1the effectiveness of..the described system.
' (2) Provide for the adequate review, approval, and use of those material l
(c) Personnel-Qualification and Training. The licensee shall assure that personnel who work in key positions where mistakes could degrade the effective-ness of the material control and accounting system are trained to maintain a high level of safeguards awareness and are qualified to perform their duties and/or responsibilities.
control and accounting procedures that are identified in the approved FNMC plan as being critical to1the effectiveness of..the described system.
(d) Measurecants. The licensee shall establish and maintain a system of measurements sufficient to:
(c) Personnel-Qualification and Training.
The licensee shall assure that personnel who work in key positions where mistakes could degrade the effective-ness of the material control and accounting system are trained to maintain a high level of safeguards awareness and are qualified to perform their duties and/or responsibilities.
(d) Measurecants.
The licensee shall establish and maintain a system of measurements sufficient to:
(1) Substantiate the plutonium element and uranium element and fissile isotope content of all SSNM received, produced, transferred between areas of custodial responsibility, on inventory, or shipped, discarded or otherwise removed from inventory; (2) Enable the estimation of the standard deviation associated with each measured quantity; and (3) Provide the data necessary for performance of the material control tests required by S74.53(b).
(1) Substantiate the plutonium element and uranium element and fissile isotope content of all SSNM received, produced, transferred between areas of custodial responsibility, on inventory, or shipped, discarded or otherwise removed from inventory; (2) Enable the estimation of the standard deviation associated with each measured quantity; and (3) Provide the data necessary for performance of the material control tests required by S74.53(b).
36
36


(e) Measurement Control.           The licensee shall assure that the quality of SSNM measurement systems and material processing practices is continually controlled to a level of effectiveness sufficient to satisfy the capabilities required for detection, response, and accounting.           To achieve this objective the licensee shall:
(e) Measurement Control.
(1) Perform engineering analyses and evaluations of the design, installation, preoperational tests, calibration, and operation of all measurement systems to be used for MC&A purposes; (2) Perform process and engineering tests using well characterized materials to establish or to verify the applicability of existing procedures for mixing and sampling SSNM and maintaining sample integrity during transport and storage. Tests must be repeated at least every three years, at any time there is a process modification that alters the physical or chemical composition of the SSNM, or whenever there is a change in the sampling technique or equipment.
The licensee shall assure that the quality of SSNM measurement systems and material processing practices is continually controlled to a level of effectiveness sufficient to satisfy the capabilities required for detection, response, and accounting.
(3) Generate current data on the performance of measurement processes, including, as appropriate, values for bias corrections, uncertainties on cali-bration factors, and random error standard deviations.           The program must include:
To achieve this objective the licensee shall:
(i) The ongoing use of standards for calibration and control of all applicable measurement systems.           Calibrations must be repeated whenever any change in a measurement system occurs which has the potential to affect a mea-surement result or when program data, generated by tests performed at a pre-determined frequency, indicate a need for recalibration.           Calibrations and tests must be based on standards with traceability to national standards or nationally accepted measurement systems; and 37
(1) Perform engineering analyses and evaluations of the design, installation, preoperational tests, calibration, and operation of all measurement systems to be used for MC&A purposes; (2) Perform process and engineering tests using well characterized materials to establish or to verify the applicability of existing procedures for mixing and sampling SSNM and maintaining sample integrity during transport and storage.
Tests must be repeated at least every three years, at any time there is a process modification that alters the physical or chemical composition of the SSNM, or whenever there is a change in the sampling technique or equipment.
(3) Generate current data on the performance of measurement processes, including, as appropriate, values for bias corrections, uncertainties on cali-bration factors, and random error standard deviations.
The program must include:
(i) The ongoing use of standards for calibration and control of all applicable measurement systems.
Calibrations must be repeated whenever any change in a measurement system occurs which has the potential to affect a mea-surement result or when program data, generated by tests performed at a pre-determined frequency, indicate a need for recalibration.
Calibrations and tests must be based on standards with traceability to national standards or nationally accepted measurement systems; and 37


(ii) A system of control measurements to provide current data for the.
(ii) A system of control measurements to provide current data for the.
estimation of the standard deviations that are significant contributors to the measurement uncertainties associated with shipper / receiver differences, inven-tory differences, and process differences.
estimation of the standard deviations that are significant contributors to the measurement uncertainties associated with shipper / receiver differences, inven-tory differences, and process differences.
(4) Utilize the data generated during the current material balance period for the estimation'of the standard error of the inventory difference (SEID) and the standard error of the process differences.     Calibration and measurement error data collected and used during immediately preceding material balance.
(4) Utilize the data generated during the current material balance period for the estimation'of the standard error of the inventory difference (SEID) and the standard error of the process differences.
Calibration and measurement error data collected and used during immediately preceding material balance.
periods may be combined with current data provided that the measurement systems are in statistical control and the combined data are utilized in characterizing the unknowns.
periods may be combined with current data provided that the measurement systems are in statistical control and the combined data are utilized in characterizing the unknowns.
(5) Evaluate all program data and information to assure that measurement performance is so controlled that the SEID estimator is less than 0.1 percent of active inventory.
(5) Evaluate all program data and information to assure that measurement performance is so controlled that the SEID estimator is less than 0.1 percent of active inventory.
(6) Apply bia.s cot-rections by an appropriate procedure whereby:
(6) Apply bia.s cot-rections by an appropriate procedure whereby:
!      (i) Bias corrections are applied to individual items if for any measurement system the relative bias estimate exceeds twice the standard deviation of its estimator, the absolute bias estimate exceeds 50 grams of SSNM when applied across all affected items, and the absolute bias estimate on an individual item basis exceeds the rounding error of affected items; (ii) All biases (regardless of significance) that are not applied as corrections to individual items are applied as a correction to the inventory difference.
(i) Bias corrections are applied to individual items if for any measurement system the relative bias estimate exceeds twice the standard deviation of its estimator, the absolute bias estimate exceeds 50 grams of SSNM when applied across all affected items, and the absolute bias estimate on an individual item basis exceeds the rounding error of affected items; (ii) All biases (regardless of significance) that are not applied as corrections to individual items are applied as a correction to the inventory difference.
(7) Investigate and take corrective action, as appropriate, to identify and reduce associated measurement biases when, for like material types (i.e.,
(7) Investigate and take corrective action, as appropriate, to identify and reduce associated measurement biases when, for like material types (i.e.,
measured by the same measurement system) the net cumulative shipper / receiver 38
measured by the same measurement system) the net cumulative shipper / receiver 38


differences accumulated over a six-month period exceed the larger of one formula kilogram or 0.1 percent of the total amount received.
differences accumulated over a six-month period exceed the larger of one formula kilogram or 0.1 percent of the total amount received.
(8) Establish and maintain a statistical control system designed to monitor the quality of each type of program measurement.     Control limits must be established to be equivalent to levels of significance of 0.05 and 0.001.
(8) Establish and maintain a statistical control system designed to monitor the quality of each type of program measurement.
Control data exceeding the 0.05 limits must be investigated and corrective action taken in a timely manner.     Whenever a single data point exceeds the 0.001 control limit, the measurement system in question must not be used for material control and accounting purposes until it has been brought into control at the 0.05 level.
Control limits must be established to be equivalent to levels of significance of 0.05 and 0.001.
(f) Physical Inventory. The licensee shall:
Control data exceeding the 0.05 limits must be investigated and corrective action taken in a timely manner.
Whenever a single data point exceeds the 0.001 control limit, the measurement system in question must not be used for material control and accounting purposes until it has been brought into control at the 0.05 level.
(f) Physical Inventory.
The licensee shall:
(1) Except as required by Part 75 of this Chapter, perform a physical inventory at least every six calendar months and within 45 days after the start of the ending inventory:
(1) Except as required by Part 75 of this Chapter, perform a physical inventory at least every six calendar months and within 45 days after the start of the ending inventory:
(i) Calculate the inventory difference, estimate the standard error of the inventory difference and investigate and report any difference that exceeds three times the standard error and 200 grams of plutonium or uranium-233 or 300 grams of uranium-235, and (ii) If required to perform an investigation pursuant to paragraph (i) of this section, evaluate the significance of the inventory difference relative to expected performance as determined from an analysis of an appropriate sequence of historical inventory differences.
(i) Calculate the inventory difference, estimate the standard error of the inventory difference and investigate and report any difference that exceeds three times the standard error and 200 grams of plutonium or uranium-233 or 300 grams of uranium-235, and (ii) If required to perform an investigation pursuant to paragraph (i) of this section, evaluate the significance of the inventory difference relative to expected performance as determined from an analysis of an appropriate sequence of historical inventory differences.
(iii) Investigate and report to the appropriate NRC Region Office any difference that exceeds three times the standard deviation determined from the l
(iii) Investigate and report to the appropriate NRC Region Office any difference that exceeds three times the standard deviation determined from the l
sequential analysis, and (iv) Perform a reinventory if directed to do so by the Commission; and l                                                 39 l
sequential analysis, and (iv) Perform a reinventory if directed to do so by the Commission; and l
39 l


(v) Reconcile and adjust the plant and subsidiary book records to the results of the physical inventory.
(v) Reconcile and adjust the plant and subsidiary book records to the results of the physical inventory.
(2)   Implement policies, practices, and procedures designed to ensure the quality of physical inventories.           These must include:
(2)
Implement policies, practices, and procedures designed to ensure the quality of physical inventories.
These must include:
(1) Development of procedures for tamper-safing of containers or vaults containing SSNM not in process that include adequate controls to assure the validity of assigned SSNM values; (ii) Maintenance of records of the quantities of SSNM added to and removed from process; (iii) Requirements for signed documentation of all SSNM transfers between areas with different custodial responsibility that reflect all quantities of SSNM transferred; (iv) Means for control of and accounting for internal transfer documents; (v) Cutoff procedures for transfers and processing so that all quantities of SSNM are inventoried and none are inventoried more than once; (vi) cutoff procedures for records and reports so that all transfers for the inventory and material balance interval and no others are included in the
(1) Development of procedures for tamper-safing of containers or vaults containing SSNM not in process that include adequate controls to assure the validity of assigned SSNM values; (ii) Maintenance of records of the quantities of SSNM added to and removed from process; (iii) Requirements for signed documentation of all SSNM transfers between areas with different custodial responsibility that reflect all quantities of SSNM transferred; (iv) Means for control of and accounting for internal transfer documents; (v) Cutoff procedures for transfers and processing so that all quantities of SSNM are inventoried and none are inventoried more than once; (vi) cutoff procedures for records and reports so that all transfers for the inventory and material balance interval and no others are included in the
(
(
records; (vii) Inventory procedures for sealed sources and containers or vaults containing SSNM that assure reliable identification and quantification of l contained SSNM; l
records; (vii) Inventory procedures for sealed sources and containers or vaults containing SSNM that assure reliable identification and quantification of l
l       (viii)   Inventory procedures for in process SSNM that provide for i
contained SSNM; l
measurement of quantities not previously measured for element and isotope, as appropriate, and remeasurement of material previously measured but whose validity has not been assured by tamper-safing or equivalent protection; and I                                               40
l (viii)
Inventory procedures for in process SSNM that provide for i
measurement of quantities not previously measured for element and isotope, as appropriate, and remeasurement of material previously measured but whose validity has not been assured by tamper-safing or equivalent protection; and I
40


e (ix) Written instructions for conducting physical inventories that detail assignments, responsibilities, and preparation for and performance of an inventory.
e (ix) Written instructions for conducting physical inventories that detail assignments, responsibilities, and preparation for and performance of an inventory.
(g) Accounting. The licensee shall establish auditable records sufficient to demonstrate that the requirements of SS 74.53, 74.55, 74.57, and 74.59 have been met and retain those records for at least three years unless a longer retention period is required by Part 75 of this Chapter.
(g) Accounting.
(h)   Internal Control. The licensee shall:
The licensee shall establish auditable records sufficient to demonstrate that the requirements of SS 74.53, 74.55, 74.57, and 74.59 have been met and retain those records for at least three years unless a longer retention period is required by Part 75 of this Chapter.
(h)
Internal Control.
The licensee shall:
(1) Establish procedures for shipping and receiving SSNM that provide for:
(1) Establish procedures for shipping and receiving SSNM that provide for:
(i) Accurate identification and measurement of the quantities shipped and received; (ii) Review and evaluation of shipper / receiver differences on an individual container or lot basis, as appropriate, on a shipment basis, and on a batch basis when required by Part 75 of this Chapter; (iii) Investigation and corrective action when shipper / receiver differences exceed twice the estimated standard deviation of the difference estimator and the larger of 0.5 percent of the amount of SSNM in the container, lot, or shipment, as appropriate, or 50 grams of SSNM; and (iv) Documentation of shipper / receiver difference evaluations, investigations, and corrective actions.
(i) Accurate identification and measurement of the quantities shipped and received; (ii) Review and evaluation of shipper / receiver differences on an individual container or lot basis, as appropriate, on a shipment basis, and on a batch basis when required by Part 75 of this Chapter; (iii) Investigation and corrective action when shipper / receiver differences exceed twice the estimated standard deviation of the difference estimator and the larger of 0.5 percent of the amount of SSNM in the container, lot, or shipment, as appropriate, or 50 grams of SSNM; and (iv) Documentation of shipper / receiver difference evaluations, investigations, and corrective actions.
(2) Establish a scrap control program that assures that:
(2) Establish a scrap control program that assures that:
(i) Internally generated scrap and scrap from other licensees or contractors l
(i) Internally generated scrap and scrap from other licensees or contractors l
t is segregated until accountability is established; and l           (ii) Any scrap measured with a standard deviation greater than five percent l
is segregated until accountability is established; and t
l (ii) Any scrap measured with a standard deviation greater than five percent l
of the measured amount is recovered so that the results are segregated by inventory 41
of the measured amount is recovered so that the results are segregated by inventory 41


period and received within six months of the end of the inventory period in which the scrap was generated except where it can be demonstrated that the scrap measurement uncertainty will not cause noncompliance with 9 74.59(e)(5).
period and received within six months of the end of the inventory period in which the scrap was generated except where it can be demonstrated that the scrap measurement uncertainty will not cause noncompliance with 9 74.59(e)(5).
(3)   Incorporate checks and balances in the MC&A system sufficient to contrcl the rate of human errors in material control and accounting
(3)
* information.
Incorporate checks and balances in the MC&A system sufficient to contrcl the rate of human errors in material control and accounting information.
(4) Perform independent assessments at least every 12 months that assess the performance of the MC&A system, review its effectiveness, and document management's action on prior assessment recommendations. Assessments must include an evaluation of the measurement control program of any outside contractor laboratory performing MC&A measurements for a licensee, unless the contractor is also subject to the requirements of $74.59(e).
(4) Perform independent assessments at least every 12 months that assess the performance of the MC&A system, review its effectiveness, and document management's action on prior assessment recommendations.
Assessments must include an evaluation of the measurement control program of any outside contractor laboratory performing MC&A measurements for a licensee, unless the contractor is also subject to the requirements of $74.59(e).
(5) Assign custodial responsibility in a manner that ensures that such responsibility can be effectively executed for all SSNM possessed under license.
(5) Assign custodial responsibility in a manner that ensures that such responsibility can be effectively executed for all SSNM possessed under license.
Dated at Washington, D.C. this                     day of                 1986 for the Nuclear Regulatory Commission.
Dated at Washington, D.C. this day of 1986 for the Nuclear Regulatory Commission.
P Samuel J. Chilk, Secretary of the Commission.
P Samuel J. Chilk, Secretary of the Commission.
42
42


5 4'       ..
5 4'
f ENCLOSURE B I
f ENCLOSURE B I
i
i


O' n
O' n
STANDARD FORMAT AND CONTENT / ACCEPTANCE CRITERIA GUIDE FOR THE MC&A REFORM AMENDMENT 10 CFR PART 74 SUBPART E FORMULA QUANTITIES OF STRATEGIC SPECIAL NUCLEAR l                               MATERIAL l
STANDARD FORMAT AND CONTENT / ACCEPTANCE CRITERIA GUIDE FOR THE MC&A REFORM AMENDMENT 10 CFR PART 74 SUBPART E FORMULA QUANTITIES OF STRATEGIC SPECIAL NUCLEAR l
MATERIAL l
l l
l l
i ENCLOSURE B l
i l
l
ENCLOSURE B l


TABLE OF CONTENTS
TABLE OF CONTENTS
                                                                                                                                          .Page INTRODUCTION .........................................................                                                           v GENERAL DISCUSSION ...................................................                                                           vii Chapter 1.0 ABRUPT LOSS DETECTION 1.1 Unit Process           Capability.....................................                                             1
.Page INTRODUCTION.........................................................
: 1. 2 Research/ Development Operations ............................                                                     10 4
v GENERAL DISCUSSION...................................................
Chapter 2.0 ITEM MONITORING 2.1 Item Loss Detection ........................................                                                       15 Chapter 3.0 ALARM RESOLUTION 3.1 Alarm Resolution ...........................................                                                       25 3.2 Alarm Reporting ............................................                                                       34 3.3 Alleged Thefts .............................................                                                       36 Chapter 4.0 QUALITY ASSURANCE AND ACCOUNTING 4.1 Management Structure .......................................                                                       41
vii Chapter 1.0 ABRUPT LOSS DETECTION 1.1 Unit Process Capability.....................................
: 4. 2 Personnel Qualification and Training .......................                                                     46 4.3 Measurements ...............................................                                                       48 4.4 Measurement Control ........................................                                                       50 4.5 Physical Inventory .........................................                                                       60 4.6 Accounting .................................................                                                       67 4.7 Shipments and Receipts .....................................                                                       69 4.8 Scrap Control ..............................................                                                       72 4.9 Human Errors ...............................................                                                       75 4.10 Independent Assessment .....................................                                                     84 4.11 SSNM Custodianship .........................................                                                     86 REFERENCES ...........................................................                                                           88 4
1
iii
: 1. 2 Research/ Development Operations............................
10 4
Chapter 2.0 ITEM MONITORING 2.1 Item Loss Detection........................................
15 Chapter 3.0 ALARM RESOLUTION 3.1 Alarm Resolution...........................................
25 3.2 Alarm Reporting............................................
34 3.3 Alleged Thefts.............................................
36 Chapter 4.0 QUALITY ASSURANCE AND ACCOUNTING 4.1 Management Structure.......................................
41
: 4. 2 Personnel Qualification and Training.......................
46 4.3 Measurements...............................................
48 4.4 Measurement Control........................................
50 4.5 Physical Inventory.........................................
60 4.6 Accounting.................................................
67 4.7 Shipments and Receipts.....................................
69 4.8 Scrap Control..............................................
72 4.9 Human Errors...............................................
75 4.10 Independent Assessment.....................................
84 4.11 SSNM Custodianship.........................................
86 REFERENCES...........................................................
88 iii 4


ACRONYMS and INITIALS CAA                 Controlled access area CUMSRD               Cumulative shipper-receiver difference FKG                 Formula kilogram FNMC                 Fundamental nuclear material control HEU                 High enriched uranium ID                   Inventory difference LEID                 Limit of error of the inventory difference MAA                 Material access area MC&A                 Material control and accounting NDA                 Nondestructive assay PD                   Process difference R&D                 Research and development SEID                 Standard error of the inventory difference SNM                 Special nuclear material SRD                 Shipper receiver difference SSNM                 Strategic special nuclear material iv
ACRONYMS and INITIALS CAA Controlled access area CUMSRD Cumulative shipper-receiver difference FKG Formula kilogram FNMC Fundamental nuclear material control HEU High enriched uranium ID Inventory difference LEID Limit of error of the inventory difference MAA Material access area MC&A Material control and accounting NDA Nondestructive assay PD Process difference R&D Research and development SEID Standard error of the inventory difference SNM Special nuclear material SRD Shipper receiver difference SSNM Strategic special nuclear material iv


c A   k   41._Al   _,ia 3.M._ -* e- -.----.e _ 4     h-     E 4 *m 4 . .r :w ,.s. 4.. w _a edw m (
c A
k 41._Al
_,ia 3.M._
e-
-.----.e 4
h-E 4
*m 4
.r
:w
,.s.
4..
w
_a edw m
(
?
?
INTRODUCTION The Atomic Energy Act of 1954, as amended, directed the Atomic Energy Comission
INTRODUCTION The Atomic Energy Act of 1954, as amended, directed the Atomic Energy Comission
              - (AEC) to regulate the receipt, manufacture, production, transfer, possession, use, import, and export of special nuclear material in order to protect the
- (AEC) to regulate the receipt, manufacture, production, transfer, possession, use, import, and export of special nuclear material in order to protect the public health and safety and to provide for the common defense and security.
.              public health and safety and to provide for the common defense and security.
l The Energy Reorganization Act of 1974 transferred all the licensing and related
l ~
~
The Energy Reorganization Act of 1974 transferred all the licensing and related functions of the AEC to the Nuclear Regulatory Commission (NRC).
functions of the AEC to the Nuclear Regulatory Commission (NRC).
!              The principal requirements with respect to special nuclear material licensing are found in Title 10, Code of Federal Regulations, Part 70 (10 CFR Part 70),
The principal requirements with respect to special nuclear material licensing are found in Title 10, Code of Federal Regulations, Part 70 (10 CFR Part 70),
                "Special Nuclear Material" and Part 74 (10 CFR Part 74), " Material Control and Accounting of Special Nuclear Material." Paragraph (B) of $70.22 of 10 CFR Part 70 specifies that special nuclear material control and accounting information must be provided in a license application to show how compliance with the fundamental nuclear material control requirements of $70.58, 974.31, or $74.51 will be accomplished.
"Special Nuclear Material" and Part 74 (10 CFR Part 74), " Material Control and Accounting of Special Nuclear Material." Paragraph (B) of $70.22 of 10 CFR Part 70 specifies that special nuclear material control and accounting information must be provided in a license application to show how compliance with the fundamental nuclear material control requirements of $70.58, 974.31, or $74.51 will be accomplished.
Purpose and Applicability 4
Purpose and Applicability 4
:              This document describes the standard format and content suggested by the NRC for use in preparing fundamental nuclear material control plans (FNMC) in response to the material control and accounting (MC&A) Reform Amendment (10 CFR 74.51).
This document describes the standard format and content suggested by the NRC for use in preparing fundamental nuclear material control plans (FNMC) in response to the material control and accounting (MC&A) Reform Amendment (10 CFR 74.51).
An intent and scope statement is provided for each requirement. These statements are intended to communicate the underlying objectives of each requirement and are not subject to negotiation in individual licensing actions. The document also provides acceptance criteria which will be utilized in the adequacy evalua-tion of submitted plans. To the extent possible. the criteria are presented in a performance-oriented format. Where prescriptive criteria were necessary, i             at least two alternatives normally are provided and additional alternative 4
An intent and scope statement is provided for each requirement.
approaches which provide an equivalent level of performance are encouraged.
These statements are intended to communicate the underlying objectives of each requirement and are not subject to negotiation in individual licensing actions.
i             Use of the Standard Format l'
The document also provides acceptance criteria which will be utilized in the adequacy evalua-tion of submitted plans.
By using this standard format for preparing an FNMC plan, a license applicant will minimize administrative problems associated with the submittal, review and approval of the plan. Preparation of an FNMC plan in accordance with this Standard Format will assist the NRC in evaluating the plan and in standardizing l             the licensing and review process. However, conformance with the standard format j             is not required by the NRC. An applicant may use a different format if it provides an equal level of completeness and detail.
To the extent possible. the criteria are presented in a performance-oriented format.
Where prescriptive criteria were necessary, i
at least two alternatives normally are provided and additional alternative approaches which provide an equivalent level of performance are encouraged.
4 i
Use of the Standard Format l
By using this standard format for preparing an FNMC plan, a license applicant will minimize administrative problems associated with the submittal, review and approval of the plan.
Preparation of an FNMC plan in accordance with this Standard Format will assist the NRC in evaluating the plan and in standardizing l
the licensing and review process.
However, conformance with the standard format j
is not required by the NRC.
An applicant may use a different format if it provides an equal level of completeness and detail.
Regardless of the format, the applicant should employ a plan / annex concept.
Regardless of the format, the applicant should employ a plan / annex concept.
All fundamental commitments which define the bounds within which the licensee will function and the detailed level of the performance of its MC&A system should be included in the body of the plan. In those cases where a demonstra-
All fundamental commitments which define the bounds within which the licensee will function and the detailed level of the performance of its MC&A system should be included in the body of the plan.
;            tion of a specific capability is called for, such information should be included in an annex to the plan which will not be incorporated as a condition of license.
In those cases where a demonstra-tion of a specific capability is called for, such information should be included in an annex to the plan which will not be incorporated as a condition of license.
Procedures detailed in the annex may be changed without NRC approval or notifica-tion provided plan commitments and capabilities are not degraded.
Procedures detailed in the annex may be changed without NRC approval or notifica-tion provided plan commitments and capabilities are not degraded.
i l
i l


t Use of Acceptance Criteria The Acceptance Criteria are for the use of the applicant and the licensing                 )
t Use of Acceptance Criteria The Acceptance Criteria are for the use of the applicant and the licensing reviewer.
reviewer. An application which meets these criteria should be acceptable to                 l the NRC staff. However, as noted above, those criteria which are prescriptive               '
An application which meets these criteria should be acceptable to the NRC staff.
in nature are ir.cluded as examples and each applicant should develop a material control and accounting program that takes into account the unique features of its particular operation.
However, as noted above, those criteria which are prescriptive in nature are ir.cluded as examples and each applicant should develop a material control and accounting program that takes into account the unique features of its particular operation.
Where additional guidance is available on particular topics, an appropriate reference is included in the Acceptance Criteria section.
Where additional guidance is available on particular topics, an appropriate reference is included in the Acceptance Criteria section.
vi
vi


                                            ~                                                   __
~
GENERAL DISCUSSION In this section, the license applicant should provide a general description of how its material control and accounting program satisfies the general perform-ance objectives of paragraph 74.51(a). The description should include informa-tion on the plant, the process, and key features of the material control and accounting program including physical organization, types of tests, and classification of material as bulk versus items.
GENERAL DISCUSSION In this section, the license applicant should provide a general description of how its material control and accounting program satisfies the general perform-ance objectives of paragraph 74.51(a).
The description should include informa-tion on the plant, the process, and key features of the material control and accounting program including physical organization, types of tests, and classification of material as bulk versus items.
The description should be sufficiently general to allow for significant modification without necessitating revision of this section.
The description should be sufficiently general to allow for significant modification without necessitating revision of this section.
vii
vii


d l               Questions and Answers
d l
: 1.                   Q:   Previously, material control and accounting (MC&A) regulations of 10CFR70.51(e),70.57,70.58 applied to fuel facility licensees authorized to possess and use a quantity of special nuclear material (SNM) exceeding one effective kilogram. The MC&A Reform Amendments would apply to fuel facility licensees possessing and using more than i                                           five formula kilograms of strategic SNM (SSNM). What is the dif-l                                           ference between effective and fomula kilograms?
Questions and Answers 1.
A:   Five formula kilograms (FKG) of high enriched uranium (HEU), plutonium, or U-233 has been established by the Commission as the quantity of strategic importance. For plutonium or U-233, the number of formula kilogram is defined as 2.5 times the weight in kilograms of the plutonium or U-233.                         For HEU enriched to 20 percent or more in uranium-235, it is defined as the weight in kilograms of the U-235 isotope. For plutonium or U-233, an effective kilogram is defined as
Q:
:                                            the weight in kilograms of the plutonium or U-233. For uranium enriched in the U-235 isotope more than 1 percent, it is defined as the weight in kilograms of the uranium element multiplied by the square of its enrichment expressed as a decimal fraction.
Previously, material control and accounting (MC&A) regulations of 10CFR70.51(e),70.57,70.58 applied to fuel facility licensees authorized to possess and use a quantity of special nuclear material (SNM) exceeding one effective kilogram. The MC&A Reform Amendments would apply to fuel facility licensees possessing and using more than i
The Reform Amendments apply to HEU, plutonium, and U-233, in quantities of 5 FKG or more. For plutonium and U-233, 5 FKG is the same amount of material as two effective kilograms. For HEU, 5 FKG varies from one effective kilogram for 20 percent enrichment to five effective kilograms for 100 percent enrichment. Licensees possessing and using more than one effective kilogram of SSNM of moderate strategic signif-icance would continue to be subject to the requirements of 10 CFR 70.51, 70.57, and 70.58. Licensees possessing and using more than one effec-tive kilogram of SNM of low strategic significance would be subject to the requirements of 10 CFR 74.31.
five formula kilograms of strategic SNM (SSNM). What is the dif-l ference between effective and fomula kilograms?
I               5 74.51(b) Threat Definition i
A:
: 2.                     Q:   Why does the collusion protection requirement read differently from that in 10 CFR 73.1(a)?
Five formula kilograms (FKG) of high enriched uranium (HEU), plutonium, or U-233 has been established by the Commission as the quantity of strategic importance.
:                                      A:   The physical protection requirements of 10 CFR 73.1(a) stipulate that                             ,
For plutonium or U-233, the number of formula kilogram is defined as 2.5 times the weight in kilograms of the plutonium or U-233.
'                                            collusion protection be provided against the conspiracy detailed in the design basis threat. To require the MC&A system to also protect against the same conspiracy would be excessive. The provisions of the MC&A Reform Amendments are designed to function in an integrated fashion with those of 10 CFR Part 73 while adding an independent verification, thus producing a more cost-effective system. Under 4
For HEU enriched to 20 percent or more in uranium-235, it is defined as the weight in kilograms of the U-235 isotope.
this new approach, MC&A is only required to protect against an insider's ability to cover up his/her theft.
For plutonium or U-233, an effective kilogram is defined as the weight in kilograms of the plutonium or U-233.
For uranium enriched in the U-235 isotope more than 1 percent, it is defined as the weight in kilograms of the uranium element multiplied by the square of its enrichment expressed as a decimal fraction.
The Reform Amendments apply to HEU, plutonium, and U-233, in quantities of 5 FKG or more.
For plutonium and U-233, 5 FKG is the same amount of material as two effective kilograms.
For HEU, 5 FKG varies from one effective kilogram for 20 percent enrichment to five effective kilograms for 100 percent enrichment. Licensees possessing and using more than one effective kilogram of SSNM of moderate strategic signif-icance would continue to be subject to the requirements of 10 CFR 70.51, 70.57, and 70.58.
Licensees possessing and using more than one effec-tive kilogram of SNM of low strategic significance would be subject to the requirements of 10 CFR 74.31.
I 5 74.51(b) Threat Definition 2.
Q:
Why does the collusion protection requirement read differently from that in 10 CFR 73.1(a)?
i A:
The physical protection requirements of 10 CFR 73.1(a) stipulate that l
collusion protection be provided against the conspiracy detailed in the design basis threat. To require the MC&A system to also protect against the same conspiracy would be excessive. The provisions of the MC&A Reform Amendments are designed to function in an integrated fashion with those of 10 CFR Part 73 while adding an independent verification, thus producing a more cost-effective system. Under this new approach, MC&A is only required to protect against an 4
insider's ability to cover up his/her theft.
viii
viii
  .wrw- -w*-m --yy,-.,_,y,.,__.-,i--.sg,-9       .w e q-~ . .     =,,-p-,-.,-.-__.                     --
.wrw-
-w*-m
--yy,-.,_,y,.,__.-,i--.sg,-9
.w e q-~..
=,,-p-,-.,-.-__.
-.y,7-.,w.,,y-mm-_-~p.,__.-y-,
--yw_-+,
y-,-
u_ - - - -
-___m..,, _ _.,,. __


MC&A system needs to protect against only a single insider, providing that individual does not have authority within the physical protection system that would permit him/her to participate in a conspiracy aimed at defeating the safeguards system. If an MC&A individual does have authority within the physical protection system, then the MC&A system is required to protect against.the cover-up of a collusion of that individual with ar.y other individual having MC&A authority.
MC&A system needs to protect against only a single insider, providing that individual does not have authority within the physical protection system that would permit him/her to participate in a conspiracy aimed at defeating the safeguards system.
This approach should relieve licensees of most of the burden which would result from requiring a totally redundant system while still
If an MC&A individual does have authority within the physical protection system, then the MC&A system is required to protect against.the cover-up of a collusion of that individual with ar.y other individual having MC&A authority.
;                                  maintaining the ability of the MC&A system to provide an extra level of independent protection and an added measure of assurance that the safeguards system as a whole has not been compromised.
This approach should relieve licensees of most of the burden which would result from requiring a totally redundant system while still maintaining the ability of the MC&A system to provide an extra level of independent protection and an added measure of assurance that the safeguards system as a whole has not been compromised.
: 3. Q:   What are examples of things this collusion requirement would affect?
3.
A:   Under this provision the licensee would be required to analyze all positions having responsibility within the MC&A system to determine if any also have responsibility within the physical protection system.
Q:
                                - A safeguards manager might be an example of such a position. If this position includes both MC&A and physical _ protection responsibilities, procedures would have to be developed to assure that when an individual in this job is performing an MC&A function, that this function be
What are examples of things this collusion requirement would affect?
,                                  performed under a three person rule, be independently checked later j                                 by a third party, or be otherwise protected against abuse of authority.
A:
l                                 Another example might be a worker on a shipping dock who has respon-
Under this provision the licensee would be required to analyze all positions having responsibility within the MC&A system to determine if any also have responsibility within the physical protection system.
;                                sibility for making a nondestructive assay measurement on a barrel and for moving that barrel out of the material access area (MAA).
- A safeguards manager might be an example of such a position.
If this position includes both MC&A and physical _ protection responsibilities, procedures would have to be developed to assure that when an individual in this job is performing an MC&A function, that this function be performed under a three person rule, be independently checked later j
by a third party, or be otherwise protected against abuse of authority.
l Another example might be a worker on a shipping dock who has respon-sibility for making a nondestructive assay measurement on a barrel and for moving that barrel out of the material access area (MAA).
Current practice for workers in positions such as this, however, already appears sufficient to meet the proposed provision and few if any changes are anticipated to be required.
Current practice for workers in positions such as this, however, already appears sufficient to meet the proposed provision and few if any changes are anticipated to be required.
For some individuals in management / supervisory positions, some                                         '
For some individuals in management / supervisory positions, some modifications to procedures, such as restricted access without escort to some areas, may be necessary to provide sufficient assurance _that the system cannot be compromised.
!                                  modifications to procedures, such as restricted access without escort to some areas, may be necessary to provide sufficient assurance _that the system cannot be compromised.
An MC&A function performed by a worker without physical protection system authority would need to be protected against a single insider threat.
:                                  An MC&A function performed by a worker without physical protection system authority would need to be protected against a single insider threat. However, it would need no overcheck if that individual had no " hands on" access to formula quantities of SSNM (e.g., a laboratory chemist).
However, it would need no overcheck if that individual had no " hands on" access to formula quantities of SSNM (e.g., a laboratory chemist).
                      $8 74.51(c), 74.59(e) Phase-In Period 3
$8 74.51(c), 74.59(e) Phase-In Period 4.
: 4. Q:   Will the physical inventory period go directly from two months to cix months?
Q:
:                            A:   The period between physical inventories will not increase from I
Will the physical inventory period go directly from two months to 3
bimonthly to semiannual until after the licensee has implemented all
cix months?
.                                  plan commitments, including necessary shutdown for alarm resolution,
A:
!                                  and demonstrated adequate performance against all commitments.
The period between physical inventories will not increase from I
bimonthly to semiannual until after the licensee has implemented all plan commitments, including necessary shutdown for alarm resolution, and demonstrated adequate performance against all commitments.
1 i
1 i
i ix
i ix


CHAPTER 1.0 ABRUPT LOSS DETECTION 1.1 Unit Process Detection Capability
CHAPTER 1.0 ABRUPT LOSS DETECTION 1.1 Unit Process Detection Capability
)                                                                         Requirement:         The rule requires that for each unit process, a licensee
)
  ;                                        establish a production quality control program capable of monitoring the status i
Requirement:
of material in process.                                   The program should include material control tests; the-results of which would be subjected to the following:
The rule requires that for each unit process, a licensee establish a production quality control program capable of monitoring the status of material in process.
A quality control test whereby results greater than both three times the estimated standard deviation of the process difference estimator                                                                         1 and 25 grams of SSNM are investigated, A statistical test that has at least a 95 percent power of detecting                                                                         J an abrupt loss of five formula kilograms within three working days of a loss of Category IA material from any accessible process location and seven calendar days of a loss of Category IB material from any accessible process location, and
The program should include material control tests; the-i results of which would be subjected to the following:
: a. trend analysis for monitoring and evaluating sequences of material                                                                         1 control test results from each unit process to determine if they
A quality control test whereby results greater than both three times the estimated standard deviation of the process difference estimator 1
and 25 grams of SSNM are investigated, A statistical test that has at least a 95 percent power of detecting J
an abrupt loss of five formula kilograms within three working days of a loss of Category IA material from any accessible process location and seven calendar days of a loss of Category IB material from any accessible process location, and
: a. trend analysis for monitoring and evaluating sequences of material
~
~
indicate a statistically significant recurrent loss or gain
control test results from each unit process to determine if they indicate a statistically significant recurrent loss or gain
;                                                                                    [74.53(b)].
[74.53(b)].
Intent and Scope: The intent of these requirements is to have in place a
Intent and Scope:
:                                        quality control program that will provide early indications of material losses that may be indicative.of a diversion or theft and a prompt detection system for significant abrupt diversions of 5 FKG or more. Through prompt detection,
The intent of these requirements is to have in place a quality control program that will provide early indications of material losses that may be indicative.of a diversion or theft and a prompt detection system for significant abrupt diversions of 5 FKG or more.
;                                          response and recovery actions can be initiated soon after a loss event while
Through prompt detection, response and recovery actions can be initiated soon after a loss event while circumstances surrounding the loss occurrence are fresh in the minds of cogni-zant personnel, and materials are available for remeasurement.
;                                          circumstances surrounding the loss occurrence are fresh in the minds of cogni-zant personnel, and materials are available for remeasurement.                                                                             In addition, i                                           fewer changes in process conditions, inventories, in process holdups, and item
In addition, i
:                                          locations will have occurred so that resolution probabilities are enhanced.
fewer changes in process conditions, inventories, in process holdups, and item locations will have occurred so that resolution probabilities are enhanced.
The detection times for a 5 FKG loss are maximums; hence, a licensee may use 1-shorter intervals for specific unit processes if so desired.
The detection times for a 5 FKG loss are maximums; hence, a licensee may use 1-shorter intervals for specific unit processes if so desired.
l 1
l 1
Plan / Annex Content:         The FNMC Plan contains the following affirmations and j                                         detailed commitments.                                     Supporting information, as appropriate, is included in j                                         the Annex.
Plan / Annex Content:
l                                                                       Section 1.1 of the Plan includes the following affirmations:
The FNMC Plan contains the following affirmations and j
o             Material control anomalies resulting from material control tests are investigated when such anomalies exceed three times the standard i                                                                                     deviation of the test statistic and also exceed 25 grams of SSNM.
detailed commitments.
!                                                                                    Results are documented.
Supporting information, as appropriate, is included in j
the Annex.
l Section 1.1 of the Plan includes the following affirmations:
o Material control anomalies resulting from material control tests are investigated when such anomalies exceed three times the standard i
deviation of the test statistic and also exceed 25 grams of SSNM.
Results are documented.
I l
I l
I l
I l                                                                                                                                  1 i
1 i
    . - , ,  . . - . - - - - - - - - - - - - , - . . . . - - . _ . . , - - - - - , -                        ,---,,-,,.-------n, -
,---,,-,,.-------n, n --.,, - - - - - - - - - -. -
_ _ - ,          . . - - , - - , - - -    n -- . , , - - - - - - - - - - . -   r---.
r---.


M o     The detection system is capable of detecting abrupt losses of Category IA material within three working days and Category IB mate-rial within seven calendar days of the loss occurrence from any accessible location, o   The action thresholds for the material control tests will be updated based on the first six months of operating data and thereafter as supported by the analysis of test data.
M o
o   All materials not qualifying for exemption under paragraphs 74.53(a)(1),
The detection system is capable of detecting abrupt losses of Category IA material within three working days and Category IB mate-rial within seven calendar days of the loss occurrence from any accessible location, o
The action thresholds for the material control tests will be updated based on the first six months of operating data and thereafter as supported by the analysis of test data.
o All materials not qualifying for exemption under paragraphs 74.53(a)(1),
(2), (3), or (4) are included under a material control test.
(2), (3), or (4) are included under a material control test.
o   Where credible substitute material is present and not controlled, the material control tests are capable of detecting diversions or thefts involving substitution of other material (s) for SSNM.
o Where credible substitute material is present and not controlled, the material control tests are capable of detecting diversions or thefts involving substitution of other material (s) for SSNM.
or No credible substitute materials are permitted inside the MAA, nor is it credible that substitute materials could be covertly introduced from outside the MAA.
or No credible substitute materials are permitted inside the MAA, nor is it credible that substitute materials could be covertly introduced from outside the MAA.
or Credible substitute materials are available within the MAA; however, sufficient controls are in place to preclude their use to conceal diversion.
or Credible substitute materials are available within the MAA; however, sufficient controls are in place to preclude their use to conceal diversion.
o   Automated or manual records of the location, movement, quantity and identity of SSNM are maintained as needed to perform the material control tests for abrupt loss detection.
o Automated or manual records of the location, movement, quantity and identity of SSNM are maintained as needed to perform the material control tests for abrupt loss detection.
o   Procedures will be implemented and maintained for monitoring and evaluating sequences of loss estimates for each unit process, and anomalous trends in sequences of abrupt loss estimators will be tested to determine if they indicate a recurrent loss trend that is of safeguards significance.
o Procedures will be implemented and maintained for monitoring and evaluating sequences of loss estimates for each unit process, and anomalous trends in sequences of abrupt loss estimators will be tested to determine if they indicate a recurrent loss trend that is of safeguards significance.
1.1.1 Process Subdivision and Measurement Points Describe the subdivision of the process to meet the unit detection require-ments and the associated measurements and measurement points.                                   A diagram or listing may be used to document this information.
1.1.1 Process Subdivision and Measurement Points Describe the subdivision of the process to meet the unit detection require-ments and the associated measurements and measurement points.
1.1.2 Material Control Tests Describe the material control tests for each unit process.                               The description should include: (1) identification of the test statistic, (2) the amounts and types of data used to establish uncertainties (sigmas), (3) tests for normality, (4) means of handling non-normal data, (5) tests for outliers, (6) methods for establishing alarm thresholds, (7) criteria for modifying alarm thresholds, and (8) the basis for the assignment of the start times for each material control test.
A diagram or listing may be used to document this information.
i                                                     2
1.1.2 Material Control Tests Describe the material control tests for each unit process.
The description should include:
(1) identification of the test statistic, (2) the amounts and types of data used to establish uncertainties (sigmas), (3) tests for normality, (4) means of handling non-normal data, (5) tests for outliers, (6) methods for establishing alarm thresholds, (7) criteria for modifying alarm thresholds, and (8) the basis for the assignment of the start times for each material control test.
i 2


In the Annex provide: (1) a detailed example alarm threshold calculation for one process unit, (2) a tabulation of the threshold values for all process units, (3) a tabulation of the detection times associated with each material control test, (4) the justification for the aerivation of each threshold value, and (5) a listing of Category IA and IB materials and the justification for the lower classification of the latter.
In the Annex provide:
1.1.3   Location Categorization Identify the locations within the facility classified as inaccessible.
(1) a detailed example alarm threshold calculation for one process unit, (2) a tabulation of the threshold values for all process units, (3) a tabulation of the detection times associated with each material control test, (4) the justification for the aerivation of each threshold value, and (5) a listing of Category IA and IB materials and the justification for the lower classification of the latter.
1.1.3 Location Categorization Identify the locations within the facility classified as inaccessible.
In the Annex provide the justification for classifying a location as inaccessible.
In the Annex provide the justification for classifying a location as inaccessible.
1.1.4 Material Substitution Identify all credible substitute materials at each location and the method of testing for substitution or of controlling the substitute material to prevent or detect attempts at substitution.                     The method of preventing credible substitute materials from being covertly introduced should also be described (NOTE:                                             Reference to the Physical Protection Plan is permitted).                                                                                     ,
1.1.4 Material Substitution Identify all credible substitute materials at each location and the method of testing for substitution or of controlling the substitute material to prevent or detect attempts at substitution.
The method of preventing credible substitute materials from being covertly introduced should also be described (NOTE:
Reference to the Physical Protection Plan is permitted).
l 1.1. 5 Exemptions Provide a listing of material types exempted from the abrupt loss detection tests with their locations and discuss the basis for the exemptions.
l 1.1. 5 Exemptions Provide a listing of material types exempted from the abrupt loss detection tests with their locations and discuss the basis for the exemptions.
1.1.6 Trend Analysis Describe the trend analysis techniques that will be employed to monitor sequences of process differences from material control tests.                     The description should include the decision criteria for ascertaining when a significant trend exists.
1.1.6 Trend Analysis Describe the trend analysis techniques that will be employed to monitor sequences of process differences from material control tests.
I Acceptance Criteria:             The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:
The description should include the decision criteria for ascertaining when a significant trend exists.
o     The licensee has developed a system of material control tests for detecting abrupt losses of bulk material from single units or loca-tions within the facility. The material control tests are capable of detecting a goal quantity loss with at least 95 percent probability of detection. The material control tests will have the following characteristics:
I Acceptance Criteria:
The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:
o The licensee has developed a system of material control tests for detecting abrupt losses of bulk material from single units or loca-tions within the facility.
The material control tests are capable of detecting a goal quantity loss with at least 95 percent probability of detection. The material control tests will have the following characteristics:
Each material control test encompasses the SSNM in a definite unit or location or over a span of locations comprising a segment of the process or a single point in the process.
Each material control test encompasses the SSNM in a definite unit or location or over a span of locations comprising a segment of the process or a single point in the process.
The material control test is based on a comparison of a measured value(s) of a quantity of material (s) or of a process variable with a reference value. The reference value is the expected or predicted quantity of material or value of the process variable in the absence of diversion or unexpected loss. Examples of
The material control test is based on a comparison of a measured value(s) of a quantity of material (s) or of a process variable with a reference value.
:                          possible material control tests are:
The reference value is the expected or predicted quantity of material or value of the process variable in the absence of diversion or unexpected loss.
Examples of possible material control tests are:
1 3
1 3
l
l


SSNM material balance; Mass (weight) balance; Volume balance; Yield versus expected or predicted yield; Liquid level versus predicted level; Solution density versus predicted density; Flow rate versus predicted flow rate; Bulk powder volume or volume times bulk density versus predicted quantity; NOA value versus predicted value; Isotopic ratio versus predicted value; Number of units, such as pellets, elements or pins versus predicted number; and Process control parameters such as pH, reagent volume, or extraction efficiency versus predicted values.
SSNM material balance; Mass (weight) balance; Volume balance; Yield versus expected or predicted yield; Liquid level versus predicted level; Solution density versus predicted density; Flow rate versus predicted flow rate; Bulk powder volume or volume times bulk density versus predicted quantity; NOA value versus predicted value; Isotopic ratio versus predicted value; Number of units, such as pellets, elements or pins versus predicted number; and Process control parameters such as pH, reagent volume, or extraction efficiency versus predicted values.
Each material control test has an action threshold (critical value) which, if exceeded, will be the cause for initiating the alarm resolution procedures prescribed in S 74.57.         In general, the action threshold or critical value can be set by a formula of the following type:
Each material control test has an action threshold (critical value) which, if exceeded, will be the cause for initiating the alarm resolution procedures prescribed in S 74.57.
A=G+i-Ko x where:       A = alarm threshold G = goal quantity (SFKg or less) x = mean assuming the null hypothesis, Ho, is true (Ho:L=0)
In general, the action threshold or critical value can be set by a formula of the following type:
L = zero loss i                                               K = factor based on POD l
A=G+i-Ko x where:
ox= standard deviation of the test statistics.
A = alarm threshold G = goal quantity (SFKg or less) x = mean assuming the null hypothesis, Ho, is true (Ho:L=0)
Key considerations applicable to this determination are:
L = zero loss i
K = factor based on POD l
o = standard deviation of the test statistics.
x Key considerations applicable to this determination are:
If the distribution of the source data can be reasonably
If the distribution of the source data can be reasonably
[                                   represented by a single normal model after the effects of l
[
l l                                                           4 L
represented by a single normal model after the effects of l
l l
4 L


human errors have been eliminated, use K=1.65 to achieve 95 percent detection probability.
human errors have been eliminated, use K=1.65 to achieve 95 percent detection probability.
Line 722: Line 1,068:
An in-depth study should be undertaken to identify the sources of error and adjustments should be made, as appropriate, in order that a single normal distribution adequately represents the data.
An in-depth study should be undertaken to identify the sources of error and adjustments should be made, as appropriate, in order that a single normal distribution adequately represents the data.
or The parameters (x, c) should be estimated, using a computer program as necessary, to maximize the likeli-hood function; then the critical point is determined by integrating the probability density function to the probability of interest.
or The parameters (x, c) should be estimated, using a computer program as necessary, to maximize the likeli-hood function; then the critical point is determined by integrating the probability density function to the probability of interest.
or A determination should be made as to whether the pre-sence of multiple distributions is the result of con-comitant data which occurred as the result of some recognized change that occurred during the test period (e.g. new and recycled material processed through an operation). If such data are available, the data should be split into subsets for testing.
or A determination should be made as to whether the pre-sence of multiple distributions is the result of con-comitant data which occurred as the result of some recognized change that occurred during the test period (e.g. new and recycled material processed through an operation).
If such data are available, the data should be split into subsets for testing.
When data do not seem to fit a normal distribution, an evaluation should be made to see if some mathematical func-tion of the data values will fit (transformation of data).
When data do not seem to fit a normal distribution, an evaluation should be made to see if some mathematical func-tion of the data values will fit (transformation of data).
A commonly used transformation is logarithms which is the basis for the lognormal distribution.
A commonly used transformation is logarithms which is the basis for the lognormal distribution.
Although there is no stated limit on the magnitude of the measurement and/or process uncertainty, the establishment i   of alarm thresholds indirectly limits the magnitude of these i   errors. That is, when the standard deviation of the test statistic becomes a large fraction of "G," there is an excessive number of false alarms.
Although there is no stated limit on the magnitude of the measurement and/or process uncertainty, the establishment i
The combined quality of the material control test and loss resolution dect'sions shall permit alarms remaining unresolved after the completion of the licensee's investigative activ-l   ities to be good indicators of an actual loss.     To achieve this objective, the licensee should demonstrate that the statistically expected number of false alarms will be less than 0.10 per inventory period for all abrupt bulk loss alarms exceeding 5 FKG (i.e., the predicted number of such unresolved alarms should be less than one in 10 inventory periods).
of alarm thresholds indirectly limits the magnitude of these i
errors.
That is, when the standard deviation of the test statistic becomes a large fraction of "G," there is an excessive number of false alarms.
The combined quality of the material control test and loss resolution dect'sions shall permit alarms remaining unresolved after the completion of the licensee's investigative activ-l ities to be good indicators of an actual loss.
To achieve this objective, the licensee should demonstrate that the statistically expected number of false alarms will be less than 0.10 per inventory period for all abrupt bulk loss alarms exceeding 5 FKG (i.e., the predicted number of such unresolved alarms should be less than one in 10 inventory periods).
i 5
i 5


M l
M The action thresholds are based on statistical hypothesis tests derived from the variances of the test statistics or on other technical bases for which it can be shown that the
The action thresholds are based on statistical hypothesis tests derived from the variances of the test statistics or on other technical bases for which it can be shown that the                                                                                                                     >
' power of the test for loss is satisfactory.
                                                                          ' power of the test for loss is satisfactory.
The measurement variances assumed by the licensee are either supported by published typical values (see Reilly and Evans (1977) or Rogers (1982) or others), the. licensees measurement control data, or historical data from the licensee's process or other similar processes.
The measurement variances assumed by the licensee are either supported by published typical values (see Reilly and Evans (1977) or Rogers (1982) or others), the. licensees measurement control data, or historical data from the licensee's process
The assumed process variances may be estimated by using conservative judgments based on i
!                                                                            or other similar processes. The assumed process variances
sound engineering principles if historical performance data for the licensee's process or similar processes are not available.
:                                                                            may be estimated by using conservative judgments based on i
If engineering judgments or typical values are used, the Plan should include provisions and schedules for i
sound engineering principles if historical performance data for the licensee's process or similar processes are not available. If engineering judgments or typical values are i                                                                            used, the Plan should include provisions and schedules for updating the estimated variances with actual performance data. The methods of estimating the loss detection sensi-tivity or the variances of loss detection parameters are satisfactorily explained and a credible justification for their use is given.
updating the estimated variances with actual performance data.
                        ,  o               All SSNM in bulk form in the MAA is.within the span of a material control test.                                           (Note: Exceptions to this requirement include
The methods of estimating the loss detection sensi-tivity or the variances of loss detection parameters are satisfactorily explained and a credible justification for their use is given.
;                                            (1) low-level waste which meets the criteria in 10 CFR 73.46(c)(6),
o All SSNM in bulk form in the MAA is.within the span of a material control test.
(2) laboratory samples containing less than 0.05 FKG (3) SSNM in i                                           research and development operations with throughputs less than 5 FKG during any seven consecutive days, and (4) SSNM in scrap and waste treatment operations conducted outside an MAA, (e.g. incinerator)).
(Note:
I                         o                 The tests for detecting abrupt losses at each accessible location will meet the three-and seven-day detection time goals for Category IA
Exceptions to this requirement include (1) low-level waste which meets the criteria in 10 CFR 73.46(c)(6),
!                                            and Category IB materials, respectively, under all routine conditions i                                           that are expected to prevail at the location.                                                                                         (Note: When detection I                                           times are interrupted by idle time caused by such things as weekends, i                                           holidays or vacations, the licensee shall make provisions for completing the tests before the idle time or for conducting additional tests to cover any material control tests that will not be completed. The i                                           additional tests shall achieve the same level of detection as the
(2) laboratory samples containing less than 0.05 FKG (3) SSNM in i
!                                            principal tests.)                                                                                                                                                                                               i o                 The licensee's classification of the process material as Category IA and Category IB is explained and justified in the Annex. Category IB materials are either (1) not usable for constructing a nuclear explosive device without further processing; (2) not susceptible to undetected i                                           removal from the MAA by an insider because of size, weight, or chemical hazard; or (3) of such low concentrations of SSNM that excessively large bulk quantities would be needed to obtain a formula quantity of SSNM.
research and development operations with throughputs less than 5 FKG during any seven consecutive days, and (4) SSNM in scrap and waste treatment operations conducted outside an MAA, (e.g. incinerator)).
o                 There is no limit or restriction on the number of control units into which a facility can be divided.                                                                         Loss detection sensitivity, false alarm rate, and loss localization capability are key determining factors.
I o
The tests for detecting abrupt losses at each accessible location will meet the three-and seven-day detection time goals for Category IA and Category IB materials, respectively, under all routine conditions i
that are expected to prevail at the location.
(Note: When detection I
times are interrupted by idle time caused by such things as weekends, i
holidays or vacations, the licensee shall make provisions for completing the tests before the idle time or for conducting additional tests to cover any material control tests that will not be completed.
The i
additional tests shall achieve the same level of detection as the principal tests.)
i o
The licensee's classification of the process material as Category IA and Category IB is explained and justified in the Annex.
Category IB materials are either (1) not usable for constructing a nuclear explosive device without further processing; (2) not susceptible to undetected i
removal from the MAA by an insider because of size, weight, or chemical hazard; or (3) of such low concentrations of SSNM that excessively large bulk quantities would be needed to obtain a formula quantity of SSNM.
o There is no limit or restriction on the number of control units into which a facility can be divided.
Loss detection sensitivity, false alarm rate, and loss localization capability are key determining factors.
The following criteria are appropriate in determining control unit boundaries:
The following criteria are appropriate in determining control unit boundaries:
6
6
  --_.yy .- _ _ . _ ,.      ._________.y.._,       , _ _ _ , _ , _ , , _ , ~ _ _ . _ , _ _ . , . _ _. ,,-_,. __ _ _ ,_ ,__, ,                                 ,_m ,,,_,___, ..., ,      ,, ,__,7 , _ . _ , ,
--_.yy
._________.y.._,
, _ _ _, _, _,, _, ~ _ _. _, _ _.,. _ _.,,-_,. __ _ _,_,__,,
,_m
,__,7


Material control tests should be performed on units generally consistent with readily assessable measurement points which naturally result from the process design. Process units should not be divided into smaller units for material control tests if such subdivision would cause the standard deviation of the test statistic to increase from below 850 formula grams U-235 (or equivalent units for tests not based on U-235) to above 850 formula grams U-235 unless such subdivision is necessary to meet the timeliness criteria of 5 74.53(b)(1).
Material control tests should be performed on units generally consistent with readily assessable measurement points which naturally result from the process design.
Process units should not be divided into smaller units for material control tests if such subdivision would cause the standard deviation of the test statistic to increase from below 850 formula grams U-235 (or equivalent units for tests not based on U-235) to above 850 formula grams U-235 unless such subdivision is necessary to meet the timeliness criteria of 5 74.53(b)(1).
Batch transfers should be utilized wherever they occur.
Batch transfers should be utilized wherever they occur.
Process variabilities should be localized to a control unit.
Process variabilities should be localized to a control unit.
Concentration differences between feed and product should be minimized wherever possible.
Concentration differences between feed and product should be minimized wherever possible.
Process units that operate continuously should be separated from those that operate in a batch mode.
Process units that operate continuously should be separated from those that operate in a batch mode.
False alarm rates should be minimized. The number of false alarms per inventory period should be less than one percent for all tests.
False alarm rates should be minimized.
o  The timeliness of abrupt loss detection at a single location is based on the interval between the time a goal quantity of SSNM becomes accessible for diversion and the completion of the material control test. The start time occurs when the quantity of SSNM is first equal to or greater than the established goal quantity.
The number of false alarms per inventory period should be less than one percent for all tests.
o  In determining accessibility for the purpose of establishing the start time for material control tests, SSNM may be treated as not accessible for diversion if:
The timeliness of abrupt loss detection at a single location is based o
Access to the SSNM is physically precluded without the need for visible puncturing, breaking, or otherwise violating the integrity of the process equipment containing the SSNM; or The state of the SSNM precludes diversion because of high temper-ature, chemical reactivity, radioactivity, or other chemical or i
on the interval between the time a goal quantity of SSNM becomes accessible for diversion and the completion of the material control test.
physical property; or The removal of the SSNM from its authorized location cannot be
The start time occurs when the quantity of SSNM is first equal to or greater than the established goal quantity.
(                   accomplished because the tools or equipment needed for its move-ment are unavailable; or The SSNM is dilute (solution) and requires a large vessel, the j                   presence of which could not escape notice; or The material is under the continuous surveillance of two or more
In determining accessibility for the purpose of establishing the start o
;                  individuals or an electronic or other type of monitoring system l
time for material control tests, SSNM may be treated as not accessible for diversion if:
Access to the SSNM is physically precluded without the need for visible puncturing, breaking, or otherwise violating the integrity of the process equipment containing the SSNM; or The state of the SSNM precludes diversion because of high temper-ature, chemical reactivity, radioactivity, or other chemical or physical property; or i
The removal of the SSNM from its authorized location cannot be
(
accomplished because the tools or equipment needed for its move-ment are unavailable; or The SSNM is dilute (solution) and requires a large vessel, the j
presence of which could not escape notice; or The material is under the continuous surveillance of two or more individuals or an electronic or other type of monitoring system l
that will detect attempts to remove material from a process.
that will detect attempts to remove material from a process.
(                                               7 i
(
7 i
l
l


o   The material control tests need only detect.those losses not involving substitution unless credible substitute materials are available in the same MAA in the form of uncontrolled material or are not prohibited
o The material control tests need only detect.those losses not involving substitution unless credible substitute materials are available in the same MAA in the form of uncontrolled material or are not prohibited as contraband from being brought into the MAA.
  !          as contraband from being brought into the MAA.
o Where credible substitute material is present and uncontrolled, the material control tests must be capable of detecting diversions employing substitution with the loss sensitivity and probability of detection required in S74.53.
o Where credible substitute material is present and uncontrolled, the material control tests must be capable of detecting diversions employing substitution with the loss sensitivity and probability of detection required in S74.53. If uranium of a lower enrichment is a credible uncontrolled substitute, a material control test must be capable of detecting isotopic dilution. Otherwise, a test that detects replace-ment by another element is adequate.
If uranium of a lower enrichment is a credible uncontrolled substitute, a material control test must be capable of detecting isotopic dilution.
o Material will be deemed not to be a credible substitute if it either:
Otherwise, a test that detects replace-ment by another element is adequate.
o Material will be deemed not to be a credible substitute if it either:
Has physical properties such as density, color, particle size, or other characteristics that will be immediately and unequivocally recognized to be different from the SSNM by personnel who routinely work with the SSNM; Has chemical properties that will always cause process upsets or degradation of product quality severe enough to be recognized and reported to a designated individual responsible for initiating ~
Has physical properties such as density, color, particle size, or other characteristics that will be immediately and unequivocally recognized to be different from the SSNM by personnel who routinely work with the SSNM; Has chemical properties that will always cause process upsets or degradation of product quality severe enough to be recognized and reported to a designated individual responsible for initiating ~
a response within the time period of the material control test; 1
a response within the time period of the material control test; Is controlled by a monitoring technique that provides assurance 1
Is controlled by a monitoring technique that provides assurance i                           that the substitute material cannot be brought into the material
i that the substitute material cannot be brought into the material access area; or Is controlled by a material accounting test that will detect J
;                            access area; or J          -
losses or diversion of the substitute material and in the absence of an alarm will' provide indirect assurance that an SSNM diversion involving substitution has not occurred.
Is controlled by a material accounting test that will detect losses or diversion of the substitute material and in the absence of an alarm will' provide indirect assurance that an SSNM diversion involving substitution has not occurred.
o Acceptable controls on substitute materials might include the following:
o Acceptable controls on substitute materials might include the following:
Access to the material is controlled through isolation in a locked limited access cabinet or room and access is restricted to indi-viduals who would not be involved in the actual handling of SSNM during production operations; i
Access to the material is controlled through isolation in a locked limited access cabinet or room and access is restricted to indi-viduals who would not be involved in the actual handling of SSNM during production operations; i
i Periodic material balances are performed on the substitute material inventory where the balance may merely entail a weight comparison of material on hand minus material issued for production with the beginning inventory; Semi quantitative N0A tests are performed on intermediate product materials from process operations where credible substitute mate-i                           rials might be introduced; or Credible substitute materials are stored outside the MAA and introduced only in amounts necessary for a shift or day's production.
i Periodic material balances are performed on the substitute material inventory where the balance may merely entail a weight comparison of material on hand minus material issued for production with the beginning inventory; Semi quantitative N0A tests are performed on intermediate product materials from process operations where credible substitute mate-i rials might be introduced; or Credible substitute materials are stored outside the MAA and introduced only in amounts necessary for a shift or day's production.
i 8
i 8
i
i
                                            - - . . , - - - . . . _ _ - - _ - - - . . - . _ - - - - , _ . ~ . . - - - . _       - - - . - _ - , . - - - ,
. -. _ - - - -, _. ~.. - - -. _


                                                                            .. l
1 o
                                                                              .. 1 o   For low throughput operations such as waste compactors and incinerators where throughput is less than five FKG in two months, and the measure-ment uncertainties on inputs and/or outputs are greater than five percent, the licensee should perform material balances on a batch basis and make appropriate corrections to the originating unit (s) or area cumulative balances to the extent practicable. Holdup deter-minations would be necessary only at the time of the physical inven-tory (or sooner for criticality reasons), and input-output differ-ences would need to be assessed only to the extent that significant trends would be investigated to identify measurement biases or an unaccounted for loss stream, o   For samples containing greater than 0.05 FKG and scrap and waste containers in laboratories, the licensee shall perform monthly material balances. These balances may be accomplished by:
For low throughput operations such as waste compactors and incinerators where throughput is less than five FKG in two months, and the measure-ment uncertainties on inputs and/or outputs are greater than five percent, the licensee should perform material balances on a batch basis and make appropriate corrections to the originating unit (s) or area cumulative balances to the extent practicable.
Holdup deter-minations would be necessary only at the time of the physical inven-tory (or sooner for criticality reasons), and input-output differ-ences would need to be assessed only to the extent that significant trends would be investigated to identify measurement biases or an unaccounted for loss stream, o
For samples containing greater than 0.05 FKG and scrap and waste containers in laboratories, the licensee shall perform monthly material balances.
These balances may be accomplished by:
Maintaining a dynamic record of the laboratory inventory.
Maintaining a dynamic record of the laboratory inventory.
Maintaining a continuous inventory of the contents of scrap and waste containers by logging the amounts of all additions to each container, and Measuring the contents of each container monthly to detect significant discrepancies where "significant" is defined as in excess of twice the standard deviation of the difference estimator.
Maintaining a continuous inventory of the contents of scrap and waste containers by logging the amounts of all additions to each container, and Measuring the contents of each container monthly to detect significant discrepancies where "significant" is defined as in excess of twice the standard deviation of the difference estimator.
o   Process difference estimates that exceed both three times the standard deviation of their estimator and 25 grams of SSNM shall be investigated and the results documented. The investigation should as a minimum include:
o Process difference estimates that exceed both three times the standard deviation of their estimator and 25 grams of SSNM shall be investigated and the results documented.
The investigation should as a minimum include:
A review of all source data and calculations for errors, A review of material control test results for the preceding SSNM quantity in the involved unit and the results of material control tests from the two adjacent units, An interview with process operators to ascertain if a perturbation in the process may have occurred, A check of sidestreams for abnormally high SSNM content, and An assessment of the possibility that additional holdup beyond what had been projected may have occurred.
A review of all source data and calculations for errors, A review of material control test results for the preceding SSNM quantity in the involved unit and the results of material control tests from the two adjacent units, An interview with process operators to ascertain if a perturbation in the process may have occurred, A check of sidestreams for abnormally high SSNM content, and An assessment of the possibility that additional holdup beyond what had been projected may have occurred.
o Two process difference estimates in succession that exceed three times the standard deviation of their estimators and three FKG should trigger additional investigative measures that include:
o Two process difference estimates in succession that exceed three times the standard deviation of their estimators and three FKG should trigger additional investigative measures that include:
Notification to the nuclear materials control manager, 9
Notification to the nuclear materials control manager, 9


Review of security records, Added surveillance measures in the involved process unit, and Performance of a physical inventory within two months.
Review of security records, Added surveillance measures in the involved process unit, and Performance of a physical inventory within two months.
o     The trend analysis required by $74.53(b)(3) can be accomplished by the application of appropriate parametric or nonparametric statistical techniques. Examples include: Page's Test, Runs Test, Dietz's Test, Power One Test, and a Mosum Test.
o The trend analysis required by $74.53(b)(3) can be accomplished by the application of appropriate parametric or nonparametric statistical techniques.
o     With respect to " safeguards significance" as it pertains to trend analysis, a trend should be considered significant when the applied test indicates it to be so and the absolute quantity involved is in excess of three FKG.
Examples include:
: 1. 2 Research and Development Operations Requirement. For research and development operations the rule requires each licensee to:
Page's Test, Runs Test, Dietz's Test, Power One Test, and a Mosum Test.
o With respect to " safeguards significance" as it pertains to trend analysis, a trend should be considered significant when the applied test indicates it to be so and the absolute quantity involved is in excess of three FKG.
: 1. 2 Research and Development Operations Requirement.
For research and development operations the rule requires each licensee to:
(1) Perform material balance tests on a lot or batch basis, as appropriate, or monthly, whichever is sooner, and investigate any difference greater' than 200 grams of plutonium or uranium-233 or 300 grams of uranium-235 that exceeds three times the standard error of the inventory difference estimator (S74.53(c)(1)); and (2) Evaluate material balance results generated during an inventory period for indications of bias or unidentified loss streams and investigate cumulative differences greater than three FKG of SSNM.
(1) Perform material balance tests on a lot or batch basis, as appropriate, or monthly, whichever is sooner, and investigate any difference greater' than 200 grams of plutonium or uranium-233 or 300 grams of uranium-235 that exceeds three times the standard error of the inventory difference estimator (S74.53(c)(1)); and (2) Evaluate material balance results generated during an inventory period for indications of bias or unidentified loss streams and investigate cumulative differences greater than three FKG of SSNM.
Intent and Scope. By design, research and development operations are dynamic in nature. Consequently, the prompt loss detection techniques that depend upon stable estimates of the uncertainties associated with material balances or
Intent and Scope.
.        process yields are inappropriate for loss detection. Taking into account the l         low throughput of such operations, periodic material balance tests on a lot or batch basis or monthly are deemed acceptable for loss detection.
By design, research and development operations are dynamic in nature.
Plan / Annex Content:   The FNMC Plan contains the following affirmations and detailed commitments.       Supporting information, as appropriate, is included in the Annex.
Consequently, the prompt loss detection techniques that depend upon stable estimates of the uncertainties associated with material balances or process yields are inappropriate for loss detection. Taking into account the l
low throughput of such operations, periodic material balance tests on a lot or batch basis or monthly are deemed acceptable for loss detection.
Plan / Annex Content:
The FNMC Plan contains the following affirmations and detailed commitments.
Supporting information, as appropriate, is included in the Annex.
Section 1.2 of the Plan includes the following affirmations:
Section 1.2 of the Plan includes the following affirmations:
o     Material balance tests are performed on lots or batches of material from research and development operations or on a monthly basis, whichever is sooner.
o Material balance tests are performed on lots or batches of material from research and development operations or on a monthly basis, whichever is sooner.
l o     Inventory differences that exceed 300 grams of uranium-235 (or 200 grams plutonium or uranium-233) and three times the standard error of the inventory difference estimator are investigated and resolved.
l o
Inventory differences that exceed 300 grams of uranium-235 (or 200 grams plutonium or uranium-233) and three times the standard error of the inventory difference estimator are investigated and resolved.
i 10
i 10


                                                                                                                                                            - - ~ . em:. -                            - - - - -
- - ~. m:. -
1                                     .  ,                                  ..
1 e
: ~.                                                               -
: ~.
                                                                                                                                                                                                        ;:          l o     Sequences of inventory differences are monitored for indications of a trend and cumulative differences exceeding three formula kilogrras are investigated.                                                                                                         /'                                       .;
o Sequences of inventory differences are monitored for indications of a trend and cumulative differences exceeding three formula kilogrras are investigated.
                                                                                                                                                          ..          ,:                                    . .c ,
/'
1.2.1 Lot / Batch Characterization                                                                                                                                               '
..c,
Provide the criteria that will be utilized to define a lot o'r batch.
1.2.1 Lot / Batch Characterization Provide the criteria that will be utilized to define a lot o'r batch.
3 1.2.2 Material Balance-Tests                                                                                           ;
3 1.2.2 Material Balance-Tests
                                                                                                                                                                    /
/
A           i Describe how the components of a process material balance will be ', C established including the. degree to which a. process will be cleaned out'and/or   ~
A i
holdup measurements will be performed. Discuss the handling of scrap indludirg 4
Describe how the components of a process material balance will be ', C established including the. degree to which a. process will be cleaned out'and/or holdup measurements will be performed. Discuss the handling of scrap indludirg
measurements, pre-treatment prior to recovery, and1 segregation.                                                                           ,,g Acceptance Criteriaj           The assessment of the 6dequacy of the information supplied above will be based on the following criteria or equivalent:                                                                     ,
~
c'     o o     Proposedmaterialsgroupingsintklotsorbatchesareacceptable taking into account prompt loss cetectiori, objectives, measurement                                                                     ,
4 measurements, pre-treatment prior to recovery, and1 segregation.
characterization, and processing constraints.
,,g Acceptance Criteriaj The assessment of the 6dequacy of the information supplied above will be based on the following criteria or equivalent:
.,                                      o-  The inputs to the standard error of the inventory difference are,m                                                                             <
c' o
!                                            reasonable and include all sources of measurement error.
Proposedmaterialsgroupingsintklotsorbatchesareacceptable o
i-i                                                                                                                           ,
taking into account prompt loss cetectiori, objectives, measurement characterization, and processing constraints.
o    Inventory differences on lots or, batches' generated duriis t.r. inver4 cry .
The inputs to the standard error of the inventory difference are,m o-reasonable and include all sources of measurement error.
period stay be based on weight cc'.vparisons provided:                                                               "
i-i Inventory differences on lots or, batches' generated duriis t.r. inver4 cry.
i Thelotsorbatchesreprese$tintermediateproducts,e                                                                         '
o period stay be based on weight cc'.vparisons provided:
y                 ,
i Thelotsorbatchesreprese$tintermediateproducts,e y
The input materials to the facility are measured for e1 hent ''
The input materials to the facility are measured for e1 hent ''
and/or isotope,                                                                                                     ,
and/or isotope, TherearenocrediblesubstitutematerialspNsentintheMAAor adequate centrols exist to preclude the use of' substitute materials to conceal a diversion, s
TherearenocrediblesubstitutematerialspNsentintheMAAor                                                                                                           '
3 The quantity of SSNM in sidestreams can be reliably measured, and The ultimate product of the operation is measured for element and/or isotope, as appropriate.
adequate centrols exist to preclude the use of' substitute materials to conceal a diversion,                                                                       -
s 3                                                         ,
The quantity of SSNM in sidestreams can be reliably measured, and The ultimate product of the operation is measured for element                                                                         '
and/or isotope, as appropriate.
t w
t w
I 4                                                                                             h l^                                                                                                                                                                                               _ ,
I h
                                                                                                                                                                  \
4 l ^
\\
l
l
                                                                                                                                        't                                                   i 11                                     -
't i
i e
11 i
l 1
e l
('
('
      . . - - . . - . . , _ _ - -,                  = . _ - _ . . -      - . _ _ _ _ _ -          . _ _ _ _ _ ,            -- - - . -                    ...,,l-_-,,
1
=.
...,,l-_-,,


V s'l-                         ,
V s'l-y-
y-                       .,                            ..
-.~
                          -.~
;9uestions and Answers 74.53 In-ProcessMonito$ing 1.
                              ;9uestions and Answers 74.53 In-ProcessMonito$ing
Q:
: 1.       Q:           What' forms (of SSNM are covered by this section?
What' forms (of SSNM are covered by this section?
A:           Bulk materials, including nontamper-safed containers of SSNM as well s                                                as materials in process equipment. In general, these requirements apply to material. that has to be measured or counted to verify its presence, rather than have its identification number and seal integrity checked.
A:
        ;                    2.       Q:           How does she lost detection mass sensitivity of 10 CFR 70.51, 70.57, and 70.58 compare to that of the proposed amendments?
Bulk materials, including nontamper-safed containers of SSNM as well as materials in process equipment.
A:           It is difficult to make this comparison because the current regulations do not explicitly specify loss detection performance capability required c
In general, these requirements s
                        ,        I of the licensees.
apply to material. that has to be measured or counted to verify its presence, rather than have its identification number and seal integrity checked.
                                                    .The current regulations (10 CFR 70.53(b)(1)) require the licensee to e
2.
report the probable cause if an inventory difference ~ exceeds both its H               /                                 measurement system limit of error and 200 grams of plutonium or f               l                                 uranium-233 on 300 grams of high enriched uranium or uranium-235 con-j; /                                           tained in high enriched uranium. The measurement system limit of 1"                                      error is permitted to be 0.5 percent of plant throughput. This reporting requirement is not equivalent to the response to a detec-tion alarm that the proposed rule would require. Further, it is not
Q:
                              .                      timely and does not require substantiation of the cause. Neverthe-
How does she lost detection mass sensitivity of 10 CFR 70.51, 70.57, and 70.58 compare to that of the proposed amendments?
[                         less, it provides a point for comparison. The proposed amendments t
A:
                                    ~
It is difficult to make this comparison because the current regulations do not explicitly specify loss detection performance capability required c
                                          %          require at least a 95 percent probability of detecting a five FKG a
of the licensees.
loss fron each unit process. To attain the same probability under the current regulations, the limit of error should not exceed one FKG* khich corresponds to 200 formula kilograms of bimonthly throughput.
I
: 3.       Q:           Would licensees be required to detect losses of amounts smaller than g                                     5 FKG?
.The current regulations (10 CFR 70.53(b)(1)) require the licensee to report the probable cause if an inventory difference ~ exceeds both its e
A:           The Commission has judged the risk to the public's health and safety
H
    /,           ~
/
of losses of less than 5 FKG of SSNM to be relatively small compared to losses of more than that amount. Under the current regulations, which include limits that are proportional to plant throughput, a small throughput licensee may be required to keep inventory differences less than a few hundred grams, while a large throughput facility may be allowed to operate with inventory differences of more than five FKG. The proposed amendments would apply the same detection goal quantity to all licensees, both large and small.                         These amendments
measurement system limit of error and 200 grams of plutonium or f
                                *This b based on studies that suggest that the true standard deviation of inventory difference is often about twice that due to measurement system error alone; and on the assumption that the true distribution is not symmetrically r                                 dir+.rfouted about zero.
l uranium-233 on 300 grams of high enriched uranium or uranium-235 con-j; /
tained in high enriched uranium.
The measurement system limit of error is permitted to be 0.5 percent of plant throughput.
This 1"
reporting requirement is not equivalent to the response to a detec-tion alarm that the proposed rule would require.
Further, it is not timely and does not require substantiation of the cause.
Neverthe-
[
less, it provides a point for comparison.
The proposed amendments require at least a 95 percent probability of detecting a five FKG
~
t loss fron each unit process.
To attain the same probability under a
the current regulations, the limit of error should not exceed one FKG* khich corresponds to 200 formula kilograms of bimonthly throughput.
3.
Q:
Would licensees be required to detect losses of amounts smaller than g
5 FKG?
A:
The Commission has judged the risk to the public's health and safety
/,
of losses of less than 5 FKG of SSNM to be relatively small compared
~
to losses of more than that amount.
Under the current regulations, which include limits that are proportional to plant throughput, a small throughput licensee may be required to keep inventory differences less than a few hundred grams, while a large throughput facility may be allowed to operate with inventory differences of more than five FKG.
The proposed amendments would apply the same detection goal quantity to all licensees, both large and small.
These amendments
*This b based on studies that suggest that the true standard deviation of inventory difference is often about twice that due to measurement system error alone; and on the assumption that the true distribution is not symmetrically r
dir+.rfouted about zero.
12
12


                                                  - y . .+
- y..+
* r s                                                                   ,
r s f
fg  would 5equire detection of single abrupt losses of 5' FKG with 95 percent or greater probability of detection.               They would also provide s
would 5equire detection of single abrupt losses of 5' FKG with 95 g percent or greater probability of detection.
a capability to detect smaller losses with reduced deteccion probability.
They would also provide a capability to detect smaller losses with reduced deteccion s
probability.
k Furthermore, each licensee who possesses one gram or more of U-235, U-233 or plutonium would continue to be required by 10 CFR 74.11 to
k Furthermore, each licensee who possesses one gram or more of U-235, U-233 or plutonium would continue to be required by 10 CFR 74.11 to
[,                  !
[
report any actual known:' loss' of SSNM, regardless of quantity.
report any actual known:' loss' of SSNM, regardless of quantity.
,                      t 4.     Q:   Arh nases,from any 1ccation required to be detected, or only losses a
t 4.
Q:
Arh nases,from any 1ccation required to be detected, or only losses a
from accessible locations?
from accessible locations?
                                                  ;,'                      'S A:     Lossas from any location must be detected.             The concept of3 accessible location applies only to the criteria for establishing andidetermining the, timeliness of the licensees' detec. tion capabilities. The detec-tion tima is the duration from when,the SSNM passes a place from where it is accessible to diversion to4the' time at which\its l'oss would be l
'S A:
f     detected.           Licensees are encouraged to have few accessible locations
Lossas from any location must be detected.
                                .)
The concept of3 accessible location applies only to the criteria for establishing andidetermining the, timeliness of the licensees' detec. tion capabilities. The detec-tion tima is the duration from when,the SSNM passes a place from where it is accessible to diversion to4the' time at which\\its l'oss would be l
                                '      since the risk of material being stolen is reduced by minimizing
f detected.
                        +
Licensees are encouraged to have few accessible locations
s"        opportunities for people to have. access to material or to have access to points of remote control over material flow if those controls could
.)
[                                     .be used to divert the flow into unadtt.orized locations.
since the risk of material being stolen is reduced by minimizing opportunities for people to have. access to material or to have access
l f_
+ s to points of remote control over material flow if those controls could
                    ' 5.         Q:   Should a glovebox be considered an " accessible location"?
[
A: ! Generally yes. Since such activities as a glove change or " bagging                   '
.be used to divert the flow into unadtt.orized locations.
cut" operation are considered routine, a removal of material via this route may not be'readily detectable. However, if there is an enforce-able policy that all removals from a glovebox must be accomplished by i
f_
at least two individuals and there arelno access points which could
l
!              2                      be accessed without an obvious indicasion, a glovebox may'be treated
' 5.
                  ,                    as inaccessible.
Q:
: 6. Q:   Will it be necessary to close a material balance in order to achieve the detection capabilities?
Should a glovebox be considered an " accessible location"?
                                            \
A: ! Generally yes.
3                     A:   No. ~ As defined in 10 CFR 70.51:
Since such activities as a glove change or " bagging cut" operation are considered routine, a removal of material via this route may not be'readily detectable.
                                        " Material balance" means a determination of an inventory differencei (ID)-(formerly called material unaccounted for (MUF)) by subtracting
However, if there is an enforce-able policy that all removals from a glovebox must be accomplished by i
  ,*                                  ending inventory (EI) plus removals (R) from beginning of inventory (BI) plus additions to inventory (A).
at least two individuals and there arelno access points which could 2
be accessed without an obvious indicasion, a glovebox may'be treated as inaccessible.
6.
Q:
Will it be necessary to close a material balance in order to achieve the detection capabilities?
\\
3 A:
No. ~ As defined in 10 CFR 70.51:
" Material balance" means a determination of an inventory differencei (ID)-(formerly called material unaccounted for (MUF)) by subtracting ending inventory (EI) plus removals (R) from beginning of inventory (BI) plus additions to inventory (A).
Mathematically, ID = BI + A - EI - R.
Mathematically, ID = BI + A - EI - R.
Paragraph 70.58(k) requires closing a measured material balance around each material balance area (MBA) and the total plant. All SNM received by an MBA, transferred frdm the MBA, discarded, or on inventory has i
Paragraph 70.58(k) requires closing a measured material balance around each material balance area (MBA) and the total plant.
to be measured and recorded to permit the iD to be determined                     ,
All SNM received by an MBA, transferred frdm the MBA, discarded, or on inventory has to be measured and recorded to permit the iD to be determined i
(10 CFR 70.58(e)). The ID is required to be calculated for both the element and fissile isotope of uranium.
(10 CFR 70.58(e)).
                                                                                    ;  4 y                                                                   13       ,
The ID is required to be calculated for both the element and fissile isotope of uranium.
t
4 y
        ?                                                                                     1 f(i
13 t
?
1 f(i


a,     _  m     .                                                        -            __ ..
a, m
4-In contrast to current regulations, it is not the intent of the proposed amendments to require measured balances as the only acceptable material control test for detection of losses.
4-In contrast to current regulations, it is not the intent of the proposed amendments to require measured balances as the only acceptable material control test for detection of losses.
It is the intent of the proposed amendment to assure that the detec-tion and localization performance criteria of the rule are met.       In some cases, a licensee may find no satisfactory alternative to closing a material balance in order to satisfy the performance criteria. In other cases, alternatives will be feasible.     (For example, see pages
It is the intent of the proposed amendment to assure that the detec-tion and localization performance criteria of the rule are met.
,                4-8 of NUREG/CR-1670, Volume 1, "The Use of Process Monitoring Data for Nuclear Material Accounting," October 1980, and pages 12-13 of               >
In some cases, a licensee may find no satisfactory alternative to closing a material balance in order to satisfy the performance criteria.
NUREG/CR-1686, Volume 1, " Feasibility and Cost / Benefit of Advanced Safeguards for Control of Nuclear Material In-Process," October 1980).
In other cases, alternatives will be feasible.
: 7. Q:   The measurement system error is not constrained by the detection pr:hability requirement without a false alarm limit. Isn't there a limit on how big the measurement error can be?
(For example, see pages 4-8 of NUREG/CR-1670, Volume 1, "The Use of Process Monitoring Data for Nuclear Material Accounting," October 1980, and pages 12-13 of NUREG/CR-1686, Volume 1, " Feasibility and Cost / Benefit of Advanced Safeguards for Control of Nuclear Material In-Process," October 1980).
A:   The problem that comes from too large a measurement or process uncertainty, which causes the standard deviation of the test statistic to be a large fraction of G, is excessive false alarms.     The rule does not limit the number of false alarms allowed. However, the alarm resolution requirements must be met. One approach to meeting those requirements is to reduce expected false alarms to a level below I
7.
the acceptable number of unresolvable alarms. Another approach is to
Q:
:              tolerate a fairly high rate of false alarms and have more accurate
The measurement system error is not constrained by the detection pr:hability requirement without a false alarm limit.
,              backup measurement systems or more accurate downstream measurements to help resolve the false alarms.     Criteria for the acceptability of the alarm resolution approach will provide the limits on measurement error-for detection and response.
Isn't there a limit on how big the measurement error can be?
: 8. Q: Why is there a requirement to investigate process differences that exceed three times the standard deviation of their estimator and 25 grams of SSNM.
A:
A: Differences that exceed three standard deviations are expected to be good quality control indicators for anomalies that could have an adverse impact on material control and accounting. In some units differences of such a magnitude might trigger an alarm potentially indicative of a 5 FKG loss, in which case alarm resolution procedures I               would be initiated. In other cases, the differences may be far less than the quantity necessary to trigger an alarm; however, investigative action is appropriate before the problem escalates to a more serious situation.
The problem that comes from too large a measurement or process uncertainty, which causes the standard deviation of the test statistic to be a large fraction of G, is excessive false alarms.
: 9. Q: What is to be accomplished by a trend analysis?
The rule does not limit the number of false alarms allowed.
A: Non-random behavior of process differences may indicate the presence l               of an unidentified bias, unmeasured loss stream, or a diverter. It       is l               important that trends be identified so that investigations can be initiated to uncover the cause.
However, the alarm resolution requirements must be met.
One approach to meeting those requirements is to reduce expected false alarms to a level below I
the acceptable number of unresolvable alarms.
Another approach is to tolerate a fairly high rate of false alarms and have more accurate backup measurement systems or more accurate downstream measurements to help resolve the false alarms.
Criteria for the acceptability of the alarm resolution approach will provide the limits on measurement error-for detection and response.
8.
Q:
Why is there a requirement to investigate process differences that exceed three times the standard deviation of their estimator and 25 grams of SSNM.
A:
Differences that exceed three standard deviations are expected to be good quality control indicators for anomalies that could have an adverse impact on material control and accounting.
In some units differences of such a magnitude might trigger an alarm potentially indicative of a 5 FKG loss, in which case alarm resolution procedures I
would be initiated.
In other cases, the differences may be far less than the quantity necessary to trigger an alarm; however, investigative action is appropriate before the problem escalates to a more serious situation.
9.
Q:
What is to be accomplished by a trend analysis?
A:
Non-random behavior of process differences may indicate the presence l
of an unidentified bias, unmeasured loss stream, or a diverter.
It is l
important that trends be identified so that investigations can be initiated to uncover the cause.
14
14


                                                                              /
/
: 10. Q: What constitutes a " working day" as used in this part?
10.
A: A working day is any 24 hour period during which material processing activities occur and there is material handling. A day during which activities such as maintenance of equipment, clean-up, autoclave monitoring, etc., occur would not be considered a work day unless SSNM handling was involved. The main criterion is whether or not the activities would afford the opportunity for diversion or theft.
Q:
What constitutes a " working day" as used in this part?
A:
A working day is any 24 hour period during which material processing activities occur and there is material handling.
A day during which activities such as maintenance of equipment, clean-up, autoclave monitoring, etc., occur would not be considered a work day unless SSNM handling was involved.
The main criterion is whether or not the activities would afford the opportunity for diversion or theft.
15
15


CHAPTER 2.0 ITEM MONITORING 2.1 Item Loss Detection Requirement: The rule' requires that each licensee establish the capability to detect a five formula kilogram loss in item form using any statistical test that has a 99 percent power of detection. Detection is to occur within:
CHAPTER 2.0 ITEM MONITORING 2.1 Item Loss Detection Requirement: The rule' requires that each licensee establish the capability to detect a five formula kilogram loss in item form using any statistical test that has a 99 percent power of detection.
Detection is to occur within:
(1) Thirty calendar days of a Category IA loss and 60 calendar days of a Category IB loss for those items in a vault or permanently controlled
(1) Thirty calendar days of a Category IA loss and 60 calendar days of a Category IB loss for those items in a vault or permanently controlled
-access area. isolated from the rest of the MAA; and
+
+
                          -access area. isolated from the rest of the MAA; and (2) Three working days of a Category IA loss and seven calendar days of a Category IB loss for items located elsewhere in the MAA except that the loss of reactor components at least one meter in length and in excess of 30 kilograms is to be detected within 30 calendar days; (3) Sixty calendar days from the loss of Category IB items in a permanently
(2) Three working days of a Category IA loss and seven calendar days of a Category IB loss for items located elsewhere in the MAA except that the loss of reactor components at least one meter in length and in excess of 30 kilograms is to be detected within 30 calendar days; (3) Sixty calendar days from the loss of Category IB items in a permanently controlled access area outside of an MAA; and (4) Sixty calendar days for samples in a vault or permanently controlled access area and 30 calendar days for samples elsewhere in the MAA for those samples containing less than 0.05 FKG of SSNM-($74.55(b)).
;                          controlled access area outside of an MAA; and (4) Sixty calendar days for samples in a vault or permanently controlled access area and 30 calendar days for samples elsewhere in the MAA for those samples containing less than 0.05 FKG of SSNM-($74.55(b)).
Items, except samples, are to be uniquely identified, quantitatively measured, with the validity of the measurement independently confirmed.
Items, except samples, are to be uniquely identified, quantitatively measured, with the validity of the measurement independently confirmed. Additionally, j             items are to be either:
Additionally, j
(1) Tamper-safed or placed in a vault or permanently controlled access area that provides protection at least equivalent to tamper-safing; or
items are to be either:
!              (2) Sealed such that removal of SSNM would be readily and permanently apparent (e.g., encapsulated) (74.55(a)).                                                                 ,
(1) Tamper-safed or placed in a vault or permanently controlled access area that provides protection at least equivalent to tamper-safing; or (2) Sealed such that removal of SSNM would be readily and permanently apparent (e.g., encapsulated) (74.55(a)).
Intent and Scope: The intent of this requirement is to ensure timely plant-wide detection of the loss of items that total 5 FKG or more. To achieve this capability, the licensee is expected to verify the presence and integrity of selected SSNM items on a periodic basis. The required frequency of tests                                   -
Intent and Scope:
:              for missing items is graded according to the relative attractiveness of the material type in the item, the ease with which the item could be diverted with-out being observed, and the degree of surveillance and containment provided for by the physical security. If SSNM is not tamper-safed, stored in a vault or permanently controlled access area that provides protection at least equivalent j             to tamper-safing, encapsulated, or in samples containing less than 0.05 FKG, it is not considered an item and the SSNM is subject to the in process control requirements for bulk material.
The intent of this requirement is to ensure timely plant-wide detection of the loss of items that total 5 FKG or more.
l                           The longer detection times for losses of items from permanently controlled access areas takes into account the added security afforded by the physical
To achieve this capability, the licensee is expected to verify the presence and integrity of selected SSNM items on a periodic basis.
.            protection measures required of such areas by 10 CFR Part 73. However, this provision should not be interpreted as authorizing the placement of materials in these areas other than those already authorized pursuant to Part 73.
The required frequency of tests for missing items is graded according to the relative attractiveness of the material type in the item, the ease with which the item could be diverted with-out being observed, and the degree of surveillance and containment provided for by the physical security.
a 4
If SSNM is not tamper-safed, stored in a vault or permanently controlled access area that provides protection at least equivalent j
16
to tamper-safing, encapsulated, or in samples containing less than 0.05 FKG, it is not considered an item and the SSNM is subject to the in process control requirements for bulk material.
l The longer detection times for losses of items from permanently controlled access areas takes into account the added security afforded by the physical protection measures required of such areas by 10 CFR Part 73. However, this provision should not be interpreted as authorizing the placement of materials in these areas other than those already authorized pursuant to Part 73.
a 16 4


    ~.                .                      -        -                            -  -              -                      .
~.
Plan / Annex Content:             The FNMC Plan contains the following affirmations and detailed commitments.                           Supporting information, as appropriate, is included in the Annex.
Plan / Annex Content:
The FNMC Plan contains the following affirmations and detailed commitments.
Supporting information, as appropriate, is included in the Annex.
Section 2.1 of the Plan includes is the following affirmations:
Section 2.1 of the Plan includes is the following affirmations:
o             The presence and integrity of selected SSNM items are verified periodically.     The item selection method has at least a 99 percent probability of detecting the loss of items plant-wide that total 5 FKG within:
o The presence and integrity of selected SSNM items are verified periodically.
The item selection method has at least a 99 percent probability of detecting the loss of items plant-wide that total 5 FKG within:
Thirty calendar days from loss for Category IA items and 60 calendar days from a loss for Category-IB items for items in a vault or a permanently controlled access area that is isolated
Thirty calendar days from loss for Category IA items and 60 calendar days from a loss for Category-IB items for items in a vault or a permanently controlled access area that is isolated
                                                          -from the rest of the material access area (MAA);
-from the rest of the material access area (MAA);
Three working days from a loss for Category IA items and seven calendar days from a loss for Category IB items located elsewhere in the MAA except for reactor components measuring at least'one meter in length and weighing in excess of 30 kilograms for which l                                                         the time interval shall be 30 calendar days.
Three working days from a loss for Category IA items and seven calendar days from a loss for Category IB items located elsewhere in the MAA except for reactor components measuring at least'one meter in length and weighing in excess of 30 kilograms for which l
the time interval shall be 30 calendar days.
Sixty calendar days from the loss of Category IB items in a per-manently controlled access area outside of an MAA; and Sixty calendar days for samples in a vault or permanently con-trolled access area and 30 calendar days for samples elsewhere in the MAA for samples each containing less than 0.05 FKG of SSNM.
Sixty calendar days from the loss of Category IB items in a per-manently controlled access area outside of an MAA; and Sixty calendar days for samples in a vault or permanently con-trolled access area and 30 calendar days for samples elsewhere in the MAA for samples each containing less than 0.05 FKG of SSNM.
: o.            Items are classified as either Category IA or IB at the time they are i
Items are classified as either Category IA or IB at the time they are o.
created in order to fix the frequency of tests for item' loss.
i created in order to fix the frequency of tests for item' loss.
o              Each SSNM item is uniquely identified; the SSNM content is quantitatively measured; the validity of the measurement is independently confirmed and assured through tamper-safing or storage in a vault or permanently controlled access area that provides protection at least equivalent
Each SSNM item is uniquely identified; the SSNM content is quantitatively o
,                                                to tamper-safing; and a record of the identity, location, and SSNM l
measured; the validity of the measurement is independently confirmed and assured through tamper-safing or storage in a vault or permanently controlled access area that provides protection at least equivalent to tamper-safing; and a record of the identity, location, and SSNM content is maintained.
content is maintained.
l o
o             Vaults or permanently controlled access areas isolated from the rest of the MAA are operated with physical and administrative controls over personnel access such that unauthorized additions and removals of items from the storage area will be either prevented or promptly detected. In addition, every change of inventory in the storage area is recorded.
Vaults or permanently controlled access areas isolated from the rest of the MAA are operated with physical and administrative controls over personnel access such that unauthorized additions and removals of items from the storage area will be either prevented or promptly detected.
i o               The operating procedures of item storage areas are documented.
In addition, every change of inventory in the storage area is recorded.
o              A designated individual is responsible for the operation of each such-storage area.
i o
l                                                                                 17 L
The operating procedures of item storage areas are documented.
A designated individual is responsible for the operation of each such-o storage area.
l 17 L
l
l


        ~
~
o     The response actions documented in Chapter 3.0 of this Plan will be initiated if one or more items are missing except where the missing
o The response actions documented in Chapter 3.0 of this Plan will be initiated if one or more items are missing except where the missing items total less than 10 grams U-235, U-233, or Pu.
;                      items total less than 10 grams U-235, U-233, or Pu.
1 2.1.1 Item Identification Describe the identification system (numeric or alpha-numeric) that will be used to assign unique identification to each item.
1 2.1.1     Item Identification Describe the identification system (numeric or alpha-numeric) that will be                       l used to assign unique identification to each item.       The description should
The description should include the features of the system which preclude falsification or which assure prompt detection of.such attempts.
:        include the features of the system which preclude falsification or which assure prompt detection of.such attempts.
2.1.2 Item Classification Provide the basis-for classifying items as material Category IB and any proposed exemptions from item control tests or from response actions, including a listing of the item categories involved and the rationale for such exemptions.
2.1.2   Item Classification Provide the basis-for classifying items as material Category IB and any proposed exemptions from item control tests or from response actions, including a listing of the item categories involved and the rationale for such exemptions.
2.1.3 Tamper-safina Describe the tamper-safing procedures that will be employed to assure the continuing validity of previously measured and attested to SSNM values assigned to unique items.
2.1.3   Tamper-safina Describe the tamper-safing procedures that will be employed to assure the continuing validity of previously measured and attested to SSNM values assigned to unique items.
Aspects to be addressed should include:
Aspects to be addressed should include: personnel involvement, types of seals, attesting to declarations, records, and inspection methods for detecting violations of item integrity.
personnel involvement, types of seals, attesting to declarations, records, and inspection methods for detecting violations of item integrity.
2.1.4 Accessibility Describe the personnel access controls, the surveillance procedures, and the records procedures for entrance and exit of personnel to and from vaults and/or permanently controlled access areas. If any of the above attributes are l         described in sufficient detail in the facility's Physical Security Plan, appro .
2.1.4 Accessibility Describe the personnel access controls, the surveillance procedures, and the records procedures for entrance and exit of personnel to and from vaults and/or permanently controlled access areas.
If any of the above attributes are l
described in sufficient detail in the facility's Physical Security Plan, appro.
priate references may be made.
priate references may be made.
2.1.5 Accounting and Control Procedures Describe the item accounting and control procedures for items placed in I
2.1.5 Accounting and Control Procedures Describe the item accounting and control procedures for items placed in I
and removed from secure storage.       The description should include item inventory records utilized.
and removed from secure storage.
2.1.6   Item Measurements Identify the measurement systems to be used for quantification of the SSNM content of items at item creation time.     The description also should include the i
The description should include item inventory records utilized.
confirmatory measurements used to quantitatively verify the SSNM content of nontamper-safed items placed into or removed from vault storage or a permanently controlled access area that is equivalent to tamper-safing, including the l         controls that prevent or detect attempts at substitution.
2.1.6 Item Measurements Identify the measurement systems to be used for quantification of the SSNM content of items at item creation time.
The description also should include the i
confirmatory measurements used to quantitatively verify the SSNM content of nontamper-safed items placed into or removed from vault storage or a permanently controlled access area that is equivalent to tamper-safing, including the l
controls that prevent or detect attempts at substitution.
18
18


ed 2.1.7   Item Verification Describe the item verification procedure.       The description should include:
ed 2.1.7 Item Verification Describe the item verification procedure.
The description should include:
The inventory sampling method, including the sample size selection equations, the inventory stratification plan, and the method of selecting the actual items to be verified; The extent to which cyclic, dynamic, or perpetual inventory data and production records, if any, will be used to modify or supplement the sample size, sample selection, or item verification procedures; and The minimum loss detection sensitivity and maximum time periods between item verifications for each category of material.
The inventory sampling method, including the sample size selection equations, the inventory stratification plan, and the method of selecting the actual items to be verified; The extent to which cyclic, dynamic, or perpetual inventory data and production records, if any, will be used to modify or supplement the sample size, sample selection, or item verification procedures; and The minimum loss detection sensitivity and maximum time periods between item verifications for each category of material.
In the Annex, provide the rationale for the item stratification plan.
In the Annex, provide the rationale for the item stratification plan.
2.1. 8 Sample Items Describe the technique that will be used to establish the sample population and how the presence of selected items will be verified.       Additionally describe how samples containing greater than 0.05 FKG will be monitored.
2.1. 8 Sample Items Describe the technique that will be used to establish the sample population and how the presence of selected items will be verified.
Acceptance Criteria:     The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:
Additionally describe how samples containing greater than 0.05 FKG will be monitored.
i o      The item identification system possesses attributes that assure unique
Acceptance Criteria:
:              item identification, preclude falsification, or as a minimum, make prompt detection of such attempts achievable. Factors to be considered in achieving this objective are:
The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:
The use of tamper-safe seal numbers for unique identification i                     represents an attractive alternative because:     the same number is used for both seal and item tracking, seal numbers cannot
i The item identification system possesses attributes that assure unique o
;                    be altered without leaving visible evidence, and seal distribu-tion and usage are controlled; The use of prenumbered containers which retain the same identifica-tion for repeat uses should generally be avoided unless detailed usage records are maintained that reflect the source and disposi-tion of items including times to fractions of a day; and l
item identification, preclude falsification, or as a minimum, make prompt detection of such attempts achievable.
Factors to be considered in achieving this objective are:
The use of tamper-safe seal numbers for unique identification i
represents an attractive alternative because:
the same number is used for both seal and item tracking, seal numbers cannot be altered without leaving visible evidence, and seal distribu-tion and usage are controlled; The use of prenumbered containers which retain the same identifica-tion for repeat uses should generally be avoided unless detailed usage records are maintained that reflect the source and disposi-tion of items including times to fractions of a day; and l
The use of pre printed labels or blank labels that are numbered as they are used is acceptable provided unauthorized alteration or replacement of the labels would be readily apparent to a knowledgeable observer.
The use of pre printed labels or blank labels that are numbered as they are used is acceptable provided unauthorized alteration or replacement of the labels would be readily apparent to a knowledgeable observer.
o     Independent confirmation of the SSNM content of items will be achieved by having a second person do the following:
o Independent confirmation of the SSNM content of items will be achieved by having a second person do the following:
Observe the bulk measurement and sampling of the item whose contents are to be determined, 1
Observe the bulk measurement and sampling of the item whose contents are to be determined, 1
I 19 l                                                                     -  -    . _.    .. -
I 19 l


Observe the nondestructive analysis of the item, or Perform a second' quantitative analysis independently that does not destroy the. integrity of the item, and Witness and attest to the application of an approved tamper-seal, or Accompany the first person and the item to a vault or permanently controlled access area which will provide storage equivalent to tamper-safing.
Observe the nondestructive analysis of the item, or Perform a second' quantitative analysis independently that does not destroy the. integrity of the item, and Witness and attest to the application of an approved tamper-seal, or Accompany the first person and the item to a vault or permanently controlled access area which will provide storage equivalent to tamper-safing.
o Storage that meets the physical security requirements for vaults, documented in Part 73, will meet the requirements of 10 CFR 74.55 for storage of items containing either Category IA or IB material.
o Storage that meets the physical security requirements for vaults, documented in Part 73, will meet the requirements of 10 CFR 74.55 for storage of items containing either Category IA or IB material.
o Storage that meets the following requirements will be accepted as a permanently controlled access area (CAA) isolated from the rest of the MAA for the purposes of 10 CFR 74.55:
o Storage that meets the following requirements will be accepted as a permanently controlled access area (CAA) isolated from the rest of the MAA for the purposes of 10 CFR 74.55:
CAA is equipped with physical protection capabilities required in Part 73; Access to the storage area is limited to the minimum number of persons necessary and records are kept of the persons who enter and leave it; Records of the items in storage are maintained; and An operator witinin the storage area will be continuously observed by another person, and all additions, removals and movements of material by either person are verifiable by the other person.
CAA is equipped with physical protection capabilities required in Part 73; Access to the storage area is limited to the minimum number of persons necessary and records are kept of the persons who enter and leave it; Records of the items in storage are maintained; and An operator witinin the storage area will be continuously observed by another person, and all additions, removals and movements of material by either person are verifiable by the other person.
o Storage will provide protection at least equivalent to tamper-safing if:
o Storage will provide protection at least equivalent to tamper-safing if:
Access to the vault or permanently controlled access area is limited to the minimum number of persons necessary, and records are kept of the persons who enter and leave it; l         -
Access to the vault or permanently controlled access area is limited to the minimum number of persons necessary, and records are kept of the persons who enter and leave it; l
The personnel authorized to enter and operate the vault or permanently controlled access area are not authorized to remove or handle SSNM beyond the boundaries of the vault or area unless controls are in place that would preclude an individual from
The personnel authorized to enter and operate the vault or permanently controlled access area are not authorized to remove or handle SSNM beyond the boundaries of the vault or area unless controls are in place that would preclude an individual from surreptitiously removing an item or any portion of an untamper-sealed container; A person entering the vault or permanently controlled access area will be accompanied by another person and all activities by either person will be verifiable by the other.
,                surreptitiously removing an item or any portion of an untamper-sealed container; A person entering the vault or permanently controlled access area will be accompanied by another person and all activities by either person will be verifiable by the other.         In addition, remote surveillance, such as closed circuit television, with the capability of seeing both operators at all times will be used.
In addition, remote surveillance, such as closed circuit television, with the capability of seeing both operators at all times will be used.
The remote surveillance need not be continuous if the occupants 20
The remote surveillance need not be continuous if the occupants 20


O*
O*
cannot determine or predict when they are or will be under
cannot determine or predict when they are or will be under
                                . surveillance; The SSNM content of nontamper-safed items will be measured, independently can' rmed by a second person, and the item will be under the continc^ s surveillance of the two persons from the time of measureme                   " ail placed in a. vault or permanently controlled access                 #  ,
. surveillance; The SSNM content of nontamper-safed items will be measured, independently can' rmed by a second person, and the item will be under the continc^
A record w               1 be maintained of the location, identity and SSNM content of the nontamper-safed items; The SSNM contents of nontamper-safed items will be verified by quantitative measurements when removed from a vault or permanently controlled access area except for solid components which can be verified by a weight check. The verification measurement and the original result shall agree within the combined measurement i-                               uncertainties. (Note: Random errors will generally ba the only component of the uncertainty except in those instances where a recalibration of the. measurement process has taken place.) The verification measurement should also detect substitution except where it can be demonstrated that no credible substitute material is present in the vault or permanently controlled access area; and The response actions documented in Chapter 3.0 will be initiated if an unauthorized vault or permanently controlled access area i
surveillance of the two persons from the s
time of measureme
" ail placed in a. vault or permanently controlled access A record w 1 be maintained of the location, identity and SSNM content of the nontamper-safed items; The SSNM contents of nontamper-safed items will be verified by quantitative measurements when removed from a vault or permanently controlled access area except for solid components which can be verified by a weight check.
The verification measurement and the original result shall agree within the combined measurement i-uncertainties.
(Note:
Random errors will generally ba the only component of the uncertainty except in those instances where a recalibration of the. measurement process has taken place.) The verification measurement should also detect substitution except where it can be demonstrated that no credible substitute material is present in the vault or permanently controlled access area; and The response actions documented in Chapter 3.0 will be initiated if an unauthorized vault or permanently controlled access area i
penetration is suspected or if the SSNM content of any container is unexplainable and significantly different from the recorded value.
penetration is suspected or if the SSNM content of any container is unexplainable and significantly different from the recorded value.
!                  o     The acceptability of tamper-seals will be based on an evaluation of I
o The acceptability of tamper-seals will be based on an evaluation of I
the seal attributes in relation to time to defeat and tamper-indicat-ing features. Seals already deemed acceptable by NRC include: Type E, Pressure-sensitive, and Steel Padlock (SAND 780400, Figure 14(2)).
the seal attributes in relation to time to defeat and tamper-indicat-ing features.
Other seals, such as fiber optic, may be equally acceptable. The licensee should provide the appropriate information, including references, to enable the licensing reviewer to assess the adequacy of other than currently approved seals.
Seals already deemed acceptable by NRC include:
o    The control of seals and seal records should preclude or make readily apparent any attempts at illicit use of seals.                         Potential contributors to these objectives should include commitments that:
Type E, Pressure-sensitive, and Steel Padlock (SAND 780400, Figure 14(2)).
Seals would be stored in a locked repository within a room that is locked when unoccupied, Blocks of seals issued to designated individuals would be afforded the same level of protection, A single individual without any responsibility for seal applica-4 tion or destruction would be designated as the seal control i                                officer, 4
Other seals, such as fiber optic, may be equally acceptable.
21 i
The licensee should provide the appropriate information, including references, to enable the licensing reviewer to assess the adequacy of other than currently approved seals.
The control of seals and seal records should preclude or make readily o
apparent any attempts at illicit use of seals.
Potential contributors to these objectives should include commitments that:
Seals would be stored in a locked repository within a room that is locked when unoccupied, Blocks of seals issued to designated individuals would be afforded the same level of protection, A single individual without any responsibility for seal applica-tion or destruction would be designated as the seal control 4
: officer, i
4 21 i


. s
s
                                                                          ~
~
4 The seal log book maintained by the control officer would be kept separate from the seals and stored in a locked repository, Individuals responsible for applying seals either would have unused seals in their personal possession or place them in a limited access locked compartment. As a general rule, the number of available seals issued to these individuals would be limited to a typical single day's use, The licensee would have in his possession a commitment from the seal manufacturer that plates and/or dies and production residuals will be controlled and protected, and Used Type E seals would be crimped, flattened or otherwise rendered unusable and properly disposed of.
The seal log book maintained by the control officer would be 4
o         The frequency of item verification tests should be consistent with
kept separate from the seals and stored in a locked repository, Individuals responsible for applying seals either would have unused seals in their personal possession or place them in a limited access locked compartment.
                              " times to detection" specified in $74.55(b).
As a general rule, the number of available seals issued to these individuals would be limited to a typical single day's use, The licensee would have in his possession a commitment from the seal manufacturer that plates and/or dies and production residuals will be controlled and protected, and Used Type E seals would be crimped, flattened or otherwise rendered unusable and properly disposed of.
o         The number of items to be verified should be sufficient to give a power of detection of at least 99 percent for a loss of items totaling 5 FKG
o The frequency of item verification tests should be consistent with
.                              from each stratum or inventory subdivision (a grouping into similar types and amounts of SSNM).           If all strata'in a facility are sampled                 '
" times to detection" specified in $74.55(b).
for verification with at least a 99 percent power of detecting a loss i                             of items containing 5 FKG, that criterion also will be achieved l-                             for a loss of items containing 5 FKG or more plant-wide.
o The number of items to be verified should be sufficient to give a power of detection of at least 99 percent for a loss of items totaling 5 FKG from each stratum or inventory subdivision (a grouping into similar types and amounts of SSNM).
o         The item inventory should be stratified or subdivided in a manner that assures at least a 99 percent power of detection while minimizing i                             the number of items to be verified. It is advantageous to subdivide
If all strata'in a facility are sampled for verification with at least a 99 percent power of detecting a loss i
;                              the inventory into classes or strata having approximately uniform i                             quantities of SSNM per item. A moderate range of SSNM contents within a class, such as i 10 to 20 percent, is usually advisable. Typical classes for sampling are-fuel elements, containers of scrap, containers of feed material, containers of waste, etc.
of items containing 5 FKG, that criterion also will be achieved l-for a loss of items containing 5 FKG or more plant-wide.
o         The means of determining the number of items to be verified per class or strata should be specifiec.           For example the equation 1
o The item inventory should be stratified or subdivided in a manner that assures at least a 99 percent power of detection while minimizing i
n = (N) (1 - pd)
the number of items to be verified.
;                              is an acceptable formula for calculating the sample size required
It is advantageous to subdivide the inventory into classes or strata having approximately uniform i
:                              from an inventory or any subset or group of size N, where d is the number of altered or missing items (defects) that total a goal quantity and 1-0 is the desired probability of obtaining one defect
quantities of SSNM per item.
'                              in the sample of n items where there are d defects (d21) in the population of items. The number d is a function of the amount of SSNM per item. If the SSNM content varies over the population of items, the largest value must be used to calculate d to ensure that n is large enough to guarantee that the power of detection is at least 99 percent.           This results in a conservative value of n, i.e., n is s
A moderate range of SSNM contents within a class, such as i 10 to 20 percent, is usually advisable.
i'
Typical classes for sampling are-fuel elements, containers of scrap, containers of feed material, containers of waste, etc.
<                                                                  22
o The means of determining the number of items to be verified per class or strata should be specifiec.
For example the equation 1
n = (N) (1 - pd) is an acceptable formula for calculating the sample size required from an inventory or any subset or group of size N, where d is the number of altered or missing items (defects) that total a goal quantity and 1-0 is the desired probability of obtaining one defect j
in the sample of n items where there are d defects (d21) in the population of items.
The number d is a function of the amount of SSNM per item.
If the SSNM content varies over the population of items, the largest value must be used to calculate d to ensure that n is large enough to guarantee that the power of detection is at least 99 percent.
This results in a conservative value of n, i.e., n is s
i' 22


4 larger than necessary. If a smaller item content were chosen, such 1-           as the average value, an informed adversary could selectively divert
4 larger than necessary.
:            only large items and thereby reduce the risk of detection.
If a smaller item content were chosen, such 1 -
as the average value, an informed adversary could selectively divert only large items and thereby reduce the risk of detection.
Additional points to consider in this regard include the following:
Additional points to consider in this regard include the following:
In those cases where the SSNM content per item is very small, the required sample size is a small fraction of the inventory.
In those cases where the SSNM content per item is very small, the required sample size is a small fraction of the inventory.
The result may even be that, in some instances the calculated sample size will be less than one. -However, such items cannot
The result may even be that, in some instances the calculated sample size will be less than one. -However, such items cannot be ignored.
'; .                be ignored. An acceptable approach would be to periodically verify one randomly selected item from the class at times chosen by random selection, such as by a random number generator.
An acceptable approach would be to periodically verify one randomly selected item from the class at times chosen by random selection, such as by a random number generator.
In some instances an entire stratum may contain less than 5 FKG, Nevertheless, such strata should be sampled like any other.
In some instances an entire stratum may contain less than 5 FKG, Nevertheless, such strata should be sampled like any other.
If the number of items, N, in each strata remains reasonably constant (such as within i 10 percent), it is not necessary to recalculate the fraction of the population, n/N, to be checked each time.
If the number of items, N, in each strata remains reasonably constant (such as within i 10 percent), it is not necessary to recalculate the fraction of the population, n/N, to be checked each time.
Neither the specific items to be verified in any particular instance nor items that won't be verified shall be predictable.
Neither the specific items to be verified in any particular instance nor items that won't be verified shall be predictable.
Every item in a strata has a non-zero probability of being-selected for verification.
Every item in a strata has a non-zero probability of being-selected for verification.
o When incorrect descriptive information for an item, such as item type,
When incorrect descriptive information for an item, such as item type, o
;.          seal number or location is found, the action to be taken will ensure a          that the item is located, is correctly identified and the deficiencies in the system are corrected.
seal number or location is found, the action to be taken will ensure that the item is located, is correctly identified and the deficiencies a
1 o  Item verification should include positive identification, seal inte-i         grity checks, container integrity checks, and location confirmation.
in the system are corrected.
j         Considerations related to verification include the following:
1 Item verification should include positive identification, seal inte-o i
grity checks, container integrity checks, and location confirmation.
j Considerations related to verification include the following:
Electronic or optical methods such as bar code readers may be used in place of manual methods to record item or seal numbers provided safeguards against falsification are in place.
Electronic or optical methods such as bar code readers may be used in place of manual methods to record item or seal numbers provided safeguards against falsification are in place.
If the licensee can demonstrate that seal falsification is non-creafble, seal identification can be done on a random basis provided an independent means of confirming item identity, such
If the licensee can demonstrate that seal falsification is non-creafble, seal identification can be done on a random basis provided an independent means of confirming item identity, such as unique container numbers, is available.
;                  as unique container numbers, is available.
Seal integrity checks normally will encompass visual examination l
Seal integrity checks normally will encompass visual examination l                   and, in the case of certain seals (e.g., Type E), physical handl-
and, in the case of certain seals (e.g., Type E), physical handl-ing.
!                  ing. Proposed shortcuts may be justified on the basis of low l                   strategic value, limited accessibility, frequency of checks, and i
Proposed shortcuts may be justified on the basis of low l
backup checks by production, quality assurance, production con-trol, etc. These should be reviewed for acceptability on a case-by-case basis.
strategic value, limited accessibility, frequency of checks, and i
backup checks by production, quality assurance, production con-trol, etc.
These should be reviewed for acceptability on a case-by-case basis.
23
23


1 e
1 e
The magnitude of the formal item verification effort'can be adjusted to take credit for other means of confirming the presence and identity of sealed items. Process control and accounting, quality control testing, and other production-operations routinely generate information that can serve to F
The magnitude of the formal item verification effort'can be adjusted to take credit for other means of confirming the presence and identity of sealed items.
verify the identity and presence of. sealed items. These sources can be used in lieu of item verification provided the frequency and loss detection sensitivity requirements of the item verifica-
Process control and accounting, quality control testing, and other production-operations routinely generate information that can serve to F
                . tion procedure are met and the use of the data for this purpose
verify the identity and presence of. sealed items.
.                is not predictable. Examples of specific sources of such data are:
These sources can be used in lieu of item verification provided the frequency and loss detection sensitivity requirements of the item verifica-
. tion procedure are met and the use of the data for this purpose is not predictable.
Examples of specific sources of such data are:
(1) Records that an item was created (tamper-safing procedure applied) or transferred within the required time span, as defined in $74.55(b);
(1) Records that an item was created (tamper-safing procedure applied) or transferred within the required time span, as defined in $74.55(b);
(2) Records that an item was inspected, tested, analyzed, altered, or subjected to any other production or quality assurance operation within the required time span; and (3) Production schedules showing that a particular item was
(2) Records that an item was inspected, tested, analyzed, altered, or subjected to any other production or quality assurance operation within the required time span; and (3) Production schedules showing that a particular item was
                        " cued up" for production planning purposes where the cueing process involved a check of identity and location.                               "
" cued up" for production planning purposes where the cueing process involved a check of identity and location.
Any items that have been verified by such a procedure within the time span required for that category of material can be exempted from formal item verification provided, as indicated above, item handling or movement is unpredictable to a potential diverter or the items will be physically accounted for by at least two individuals during sequential processing or inspection steps during the required time span. To exempt the above items from formal item verification, the items are simply dropped from the list of n items selected from the inventory list where n is the sample size required for verification.
Any items that have been verified by such a procedure within the time span required for that category of material can be exempted from formal item verification provided, as indicated above, item handling or movement is unpredictable to a potential diverter or the items will be physically accounted for by at least two individuals during sequential processing or inspection steps during the required time span.
o Small ite*t euch ac element sections and samples can be amassed in a tamper-safed container to alleviate excessive item verification.
To exempt the above items from formal item verification, the items are simply dropped from the list of n items selected from the inventory list where n is the sample size required for verification.
o Items will be classified as Category IB material and subject to the lower frequency item loss test if:
Small ite*t euch ac element sections and samples can be amassed in a o
tamper-safed container to alleviate excessive item verification.
o Items will be classified as Category IB material and subject to the lower frequency item loss test if:
The dimensions are large enough to preclude hiding the item on an individual (i.e. at least two meters in one dimension, greater than one meter in each of two dimensions, or greater than 25 cm in each of three dimensions.);
The dimensions are large enough to preclude hiding the item on an individual (i.e. at least two meters in one dimension, greater than one meter in each of two dimensions, or greater than 25 cm in each of three dimensions.);
The weight of 5 FKG of the material is so large that one person cannot carry the item inconspicuous 1y. The minimum weight to meet this criterion is 50 kilograms; or The quantity of SSNM in the item is so small that a large number of diversions are needed to accumulate 5 FKG. The maximum quantity to meet this criterion is 50 formula grams.
The weight of 5 FKG of the material is so large that one person cannot carry the item inconspicuous 1y.
The minimum weight to meet this criterion is 50 kilograms; or The quantity of SSNM in the item is so small that a large number of diversions are needed to accumulate 5 FKG.
The maximum quantity to meet this criterion is 50 formula grams.
24
24


The first two exceptions do not apply if the item can be opened or disassembled.and part or all of the SSNM removed without a high probability of being observed or detected, o  The presence of higher tier components such as fuel blocks, preassemblies, subassemblies, etc. stored outside of a permanently controlled access should be verified in accordance with a sampling plan that provides the capability to detect a 5 FKG loss within one month. One month is deemed to be acceptable on the basis of the large physical size and weight of these items and the restrictions on removing them from the MAA.
The first two exceptions do not apply if the item can be opened or disassembled.and part or all of the SSNM removed without a high probability of being observed or detected, The presence of higher tier components such as fuel blocks, preassemblies, o
o  Encapsulated items containing less than 200 grams of SSNM whose presence has been verified during the prior six months as part of a statistical sample or handling during routine production need not be reverified for physical inventory. Items whose presence has not been verified in the same time interval should be located by two person inventory teams.
subassemblies, etc. stored outside of a permanently controlled access should be verified in accordance with a sampling plan that provides the capability to detect a 5 FKG loss within one month.
o   Samples containing in excess of 0.05 FKG can be considered a side-stream in a bulk test performed in the originating process unit pro-l                   vided the samples are returned to process within seven days.           SSNM
One month is deemed to be acceptable on the basis of the large physical size and weight of these items and the restrictions on removing them from the MAA.
]                   removals from such samples should be documented and the area records corrected accordingly.
Encapsulated items containing less than 200 grams of SSNM whose presence o
has been verified during the prior six months as part of a statistical sample or handling during routine production need not be reverified for physical inventory.
Items whose presence has not been verified in the same time interval should be located by two person inventory teams.
o Samples containing in excess of 0.05 FKG can be considered a side-stream in a bulk test performed in the originating process unit pro-l vided the samples are returned to process within seven days.
SSNM
]
removals from such samples should be documented and the area records corrected accordingly.
1 l
1 l
l l
l l
l j                                                 25 l
l j
25 l


CHAPTER 3.0 ALARM RESOLUTION 3.1 Alarm Resolution Requirement: The rule requires that a licensee resolve the nature and cause of any MC&A alarm within an approved time period. If a loss has occurred, the licensee is to determine the amount of SSNM lost and, as appropriate, return out-of place SSNM to an appropriate place, update and correct involved records and modify the MC&A system to prevent similar occurrences in the future. Addi-tionally, if an abrupt loss detection estimate exceeds 5 FKG of SSNM, material processing operations related to the alarm are to be suspended until completion of planned resolution activities unless the suspension of operations will nega-tively affect the ability to resolve the alarm.               However, operations of con-tinuous processes may continue for a 24 hour period while checks are made for mistakes (9 74.57(b), (d), (e), and (g)(1)).
CHAPTER 3.0 ALARM RESOLUTION 3.1 Alarm Resolution Requirement:
Intent and Scope: The intent of these requirements is that the licensee's alarm resolution system will be able to respond promptly to alarms indicating a potential loss of SSNM and determine whether the alarm was caused by an actual loss or by a system error. The alarm resolution program also should be able to identify the type of system error or innocent cause so that remedial action can be taken. The alarm response should be timely to ensure that alarms are investigated and resolved promptly while memories of events leading up to the alarm are fresh, materials are still available for remeasurement, and fewer changes of process conditions, inventories, in process holdup, and item locations will have occurred. Prompt resolution will facilitate recovery of " lost" or stolen material.
The rule requires that a licensee resolve the nature and cause of any MC&A alarm within an approved time period.
Plan / Annex Content:   The FNMC Plan contains the following affirmations and detailed commitments.           Supporting information, as appropriate, is included in the Annex.
If a loss has occurred, the licensee is to determine the amount of SSNM lost and, as appropriate, return out-of place SSNM to an appropriate place, update and correct involved records and modify the MC&A system to prevent similar occurrences in the future.
Addi-tionally, if an abrupt loss detection estimate exceeds 5 FKG of SSNM, material processing operations related to the alarm are to be suspended until completion of planned resolution activities unless the suspension of operations will nega-tively affect the ability to resolve the alarm.
However, operations of con-tinuous processes may continue for a 24 hour period while checks are made for mistakes (9 74.57(b), (d), (e), and (g)(1)).
Intent and Scope:
The intent of these requirements is that the licensee's alarm resolution system will be able to respond promptly to alarms indicating a potential loss of SSNM and determine whether the alarm was caused by an actual loss or by a system error.
The alarm resolution program also should be able to identify the type of system error or innocent cause so that remedial action can be taken.
The alarm response should be timely to ensure that alarms are investigated and resolved promptly while memories of events leading up to the alarm are fresh, materials are still available for remeasurement, and fewer changes of process conditions, inventories, in process holdup, and item locations will have occurred.
Prompt resolution will facilitate recovery of " lost" or stolen material.
Plan / Annex Content:
The FNMC Plan contains the following affirmations and detailed commitments.
Supporting information, as appropriate, is included in the Annex.
Section 3.1 of the Plan includes the following affirmations:
Section 3.1 of the Plan includes the following affirmations:
o     A systematic investigation into the nature and cause of each MC&A alarm will continue until the cause has been established or a deter-mination has been made that the alarm is not resolvable with the information currently available. NRC will be notified when the latter situation occurs within 24 hours or within the next working day when a weekend or holiday intervenes.
o A systematic investigation into the nature and cause of each MC&A alarm will continue until the cause has been established or a deter-mination has been made that the alarm is not resolvable with the information currently available.
o     Written investigation procedures will be maintained which will include decision rules by which a particular cause or combination of causes will be accepted as the cause of an alarm.
NRC will be notified when the latter situation occurs within 24 hours or within the next working day when a weekend or holiday intervenes.
o     Investigation of alarms will be initiated promptly and the maximum allowable time periods for completion of the alarm resolution proce-dures will be as specified in Section 3.1.3 o     A search for a missing item will not be terminated until the item is either located or evic nce is obtained that the item has been destroyed.
o Written investigation procedures will be maintained which will include decision rules by which a particular cause or combination of causes will be accepted as the cause of an alarm.
o Investigation of alarms will be initiated promptly and the maximum allowable time periods for completion of the alarm resolution proce-dures will be as specified in Section 3.1.3 o
A search for a missing item will not be terminated until the item is either located or evic nce is obtained that the item has been destroyed.
A claim that an item containing more than 50 formula grams was destroyed without having been recorded will be supported by independent and concrete confirmatory evidence of destruction.
A claim that an item containing more than 50 formula grams was destroyed without having been recorded will be supported by independent and concrete confirmatory evidence of destruction.
26
26


P o
P o
o    If the integrity of'an item has been compromised, i.e., the container seal or the encapsulation has been altered or broken, an appropriate response procedure will be promptly initiated to determine whether any SS M is missing.
If the integrity of'an item has been compromised, i.e., the container o
I o   Compromised items will be placed under surveillance or in secure storage and will be remeasured within the time period specified in the plan. The quality of the remeasurement will be at least equal to the original measurement.
seal or the encapsulation has been altered or broken, an appropriate response procedure will be promptly initiated to determine whether any SS M is missing.
i                                                                                                       l i                                                                                                       l o   Following alarm resolution, appropriate corrective action will be-4 -
I o
taken to correct any records found in error, to return misplaced SS M         I to the proper location, if appropriate, and to revise the MC&A system to prevent similar occurrences in the future if such action is warranted. i i
Compromised items will be placed under surveillance or in secure storage and will be remeasured within the time period specified in the plan.
o    When an actual loss of SSM is indicated, the quantity of material lost will be estimated and other information which may aid in the recovery of the material, such as the material type and container type, and who last had responsibility for it will be generated, if possible.
The quality of the remeasurement will be at least equal to the original measurement.
3 o    When a detection alarm indicates a potential loss in excess of 5 FKG, continuous processing operations related to the alarm will be suspended within 24 hours after the alarm, and the suspension will be continued i
i l
until completion of the planned resolution activities unless the sus-pension would negatively affect the ability to resolve the alarm, or When a detection alarm indicates a potential loss in excess of 5 FKG, batch processing operations will be suspended immediately after the alarm or upon completion of the batch in process, and the suspension will be continued until completion of the planned resolution activities, f                   a    When a process is not shut down, equally effective alternative i                         measures will be taken when an alarm occurs to protect information 1
i o
Following alarm resolution, appropriate corrective action will be-4 -
taken to correct any records found in error, to return misplaced SS M to the proper location, if appropriate, and to revise the MC&A system to prevent similar occurrences in the future if such action is warranted.
i When an actual loss of SSM is indicated, the quantity of material i
o lost will be estimated and other information which may aid in the recovery of the material, such as the material type and container type, and who last had responsibility for it will be generated, if possible.
When a detection alarm indicates a potential loss in excess of 5 FKG, 3
o continuous processing operations related to the alarm will be suspended within 24 hours after the alarm, and the suspension will be continued i
until completion of the planned resolution activities unless the sus-pension would negatively affect the ability to resolve the alarm, or When a detection alarm indicates a potential loss in excess of 5 FKG, batch processing operations will be suspended immediately after the alarm or upon completion of the batch in process, and the suspension will be continued until completion of the planned resolution activities, f
When a process is not shut down, equally effective alternative a
i measures will be taken when an alarm occurs to protect information 1
and material that would be needed during the alarm investigation.
and material that would be needed during the alarm investigation.
l                         Alternative measures by unit process are documented in the procedures specified in Section 3.1.1.
l Alternative measures by unit process are documented in the procedures specified in Section 3.1.1.
5 3.1.1 A_larm Resolution Procedures Describe the alarm resolution procedures that will be applied to the various types of alarms and unit processes. The procedures should take into account credible innocent occurrences that may cause alarms indicating a potential SSM loss. The resolution procedure descriptions may be abbreviated.
5 3.1.1 A_larm Resolution Procedures Describe the alarm resolution procedures that will be applied to the various types of alarms and unit processes.
Also describe in the Plan the specific procedures to be employed in response to alarms indicating a potential loss in excess of 5 FKG. The description should identify those operations that will be shut down or alternative measures that will be employed in lieu of shutdown to facilitate an investigation.
The procedures should take into account credible innocent occurrences that may cause alarms indicating a potential SSM loss.
The resolution procedure descriptions may be abbreviated.
Also describe in the Plan the specific procedures to be employed in response to alarms indicating a potential loss in excess of 5 FKG.
The description should identify those operations that will be shut down or alternative measures that will be employed in lieu of shutdown to facilitate an investigation.
In the Annex, provide (1) a listing of identified credible causes of pos-sible alarms by unit process and details of the resolution procedures by which 27
In the Annex, provide (1) a listing of identified credible causes of pos-sible alarms by unit process and details of the resolution procedures by which 27


4 j'             specific causes could be identified, (2) a statistical estimate of the expected i               number of unresolvable alarms per inventory period with loss estimates greater than 5 FKG and a description of the estimation method, and (3) the justifica-                                         '
4 j'
tion for not shutting down certain process operations during an investigation.
specific causes could be identified, (2) a statistical estimate of the expected i
number of unresolvable alarms per inventory period with loss estimates greater than 5 FKG and a description of the estimation method, and (3) the justifica-tion for not shutting down certain process operations during an investigation.
i 3.1.2 Decision Rules Describe the types of information and data developed during response that t
i 3.1.2 Decision Rules Describe the types of information and data developed during response that t
will be accepted as sufficient evidence for assigning a specific cause to an 1
will be accepted as sufficient evidence for assigning a specific cause to an 1
alarm. The information and data described above should form the basis for development of the decision rules to be included in this section.                                     These rules should take into account every identified potential innocent cause that may result in a bulk or item loss alarm.
alarm.
I 3.1.3   Response Time Indicate the response times that will be allotted to resolve each alarm type. If alarms involving certain material types or alarms from certain processes require appreciably longer response times than those estimated in the acceptance i              criteria section on page 30, justify the indicated times.
The information and data described above should form the basis for development of the decision rules to be included in this section.
a 3.1.4   Item Discrepancies
These rules should take into account every identified potential innocent cause that may result in a bulk or item loss alarm.
)                     Describe the actions that will be taken in response to the following item 4
I 3.1.3 Response Time Indicate the response times that will be allotted to resolve each alarm type.
discrepancies:
If alarms involving certain material types or alarms from certain processes require appreciably longer response times than those estimated in the acceptance criteria section on page 30, justify the indicated times.
An item has apparently been destroyed without being recorded.
i a
3.1.4 Item Discrepancies
)
Describe the actions that will be taken in response to the following item discrepancies:
4 An item has apparently been destroyed without being recorded.
The integrity of a tamper-safed or encapsulated item has been compromised.
The integrity of a tamper-safed or encapsulated item has been compromised.
Unauthorized entry or other violation of control of a vault or a
Unauthorized entry or other violation of control of a vault or a permanently controlled access area has occurred.
!                              permanently controlled access area has occurred.
I i
I i
A significant difference between the measured input and output value of an untamper-safed item placed in vault or CAA storage has been detected, j                   The actions in response to these discrepancies should include decision i             rules which will be the basis of acceptable resolution.
A significant difference between the measured input and output value of an untamper-safed item placed in vault or CAA storage has been
.              Acceptance Criteria:                         The assessment of the adequacy of the information supplied l             above will be based on the following criteria or equivalent:
: detected, j
o         Resolution procedures are described for alarms that indicate a potential abrupt loss of 5 FKG of SSNM in bulk or item form. The l                             procedures take into account the expected differences in loss
The actions in response to these discrepancies should include decision i
!                            mechanisms and necessary differences in response approaches for in process materials, items, different material types, and different types of unit operations. The differences and variations in resolu-tion procedures are explained. Examples of different types of unit processes are:
rules which will be the basis of acceptable resolution.
l A bulk storage unit, 1
Acceptance Criteria:
The assessment of the adequacy of the information supplied l
above will be based on the following criteria or equivalent:
o Resolution procedures are described for alarms that indicate a potential abrupt loss of 5 FKG of SSNM in bulk or item form.
The l
procedures take into account the expected differences in loss mechanisms and necessary differences in response approaches for in process materials, items, different material types, and different types of unit operations.
The differences and variations in resolu-tion procedures are explained.
Examples of different types of unit l
processes are:
A bulk storage unit, 1
28 4
28 4
___.                . _ _ _ _ - ~ _ _ - - - _ _ . - ~ ~ _                      -
- ~
                                                                                      - - .-.~._ --- - ~ ~.-- _ --                  -
. - ~ ~
- -.-.~.
--- - ~ ~.--


A batch process with cleanout between batches and very small amounts of in process holdup, A continuous process with continuous flow between the unit process and the succeeding process, and A process with large hold-up inventories that cannot be measured directly without cleanout.
A batch process with cleanout between batches and very small amounts of in process holdup, A continuous process with continuous flow between the unit process and the succeeding process, and A process with large hold-up inventories that cannot be measured directly without cleanout.
o         The alarm resolution procedures provide a systematic and logical sequence of steps for determining the cause or causes of an alarm.
o The alarm resolution procedures provide a systematic and logical sequence of steps for determining the cause or causes of an alarm.
An example of a systematic approach to assessment would be:
An example of a systematic approach to assessment would be:
Check the data and calculations for clerical, transcription, or computational errors; Trace the data to the primary sources (operator logbooks or production records and analytical reports) to check for agreement; Compare the source data, such as item and batch sizes and numbers, inventory quantities and flow rates, to historical values to detect anomalies that may indicate an error of identification or measurement; Review downstream material balances for potential off-setting gains; Localize the source of the alarm as nearly as possible with regard to time, place, material type, and individuals potentially involved; Report a potential SSNM loss to security who then should imple-ment intensified search and surveillance procedures; Stop further processing in the unit process, if feasible, to retain items and inventory for remeasurement; and Remeasure t il items, inventories, batches, and/or samples from the unit process that are still available.
Check the data and calculations for clerical, transcription, or computational errors; Trace the data to the primary sources (operator logbooks or production records and analytical reports) to check for agreement; Compare the source data, such as item and batch sizes and numbers, inventory quantities and flow rates, to historical values to detect anomalies that may indicate an error of identification or measurement; Review downstream material balances for potential off-setting gains; Localize the source of the alarm as nearly as possible with regard to time, place, material type, and individuals potentially involved; Report a potential SSNM loss to security who then should imple-ment intensified search and surveillance procedures; Stop further processing in the unit process, if feasible, to retain items and inventory for remeasurement; and Remeasure t il items, inventories, batches, and/or samples from the unit process that are still available.
o         Each type of alarm response is identified with the corresponding types of material and/or unit processes and the credible innocent causes of the alarm. Examples of innocent causes would be:
o Each type of alarm response is identified with the corresponding types of material and/or unit processes and the credible innocent causes of the alarm.
A clerical or computational error is identified that clearly explains the alarm; A missing item is located; A claim that an item was added to the process, although no record j                                                     of the transfer was found, if substantiated through an actual yield versus predicted yield comparison; l
Examples of innocent causes would be:
A clerical or computational error is identified that clearly explains the alarm; A missing item is located; A claim that an item was added to the process, although no record j
of the transfer was found, if substantiated through an actual yield versus predicted yield comparison; l
i 29 l
i 29 l
i                                                                                                       . . - _  _- , ~ - . _ .
i
_-, ~ -. _.


            ~.
~.
A remeasurement confirms that error (s) in the original data               l caused the alarm; or A random fluctuation in the measurement process or a process variability is identified through sufficient measurements or additional processing.
A remeasurement confirms that error (s) in the original data l
o     The decision rules for a conclusion that a particular cause is applic-able and that the alarm is resolved are described. (Backup informa-tion about the rationale and justifications are included in the Annex.)
caused the alarm; or A random fluctuation in the measurement process or a process variability is identified through sufficient measurements or additional processing.
A decision rule must generally provide an objective basis for deciding whether or not the data and information acquired up to that point in the alarm assessment supports the hypothesis that the alarm was due to an innocent cause. Each decision rule should be based on the identification of a specific cause or a source of incorrect data that contributed to the alarm level of the loss estimator except that the rule may verify with high probability that no loss has occurred without having identified all contributing causes of the alarm.       Examples of acceptable decision rules are:                                                   '
o The decision rules for a conclusion that a particular cause is applic-able and that the alarm is resolved are described.
(Backup informa-tion about the rationale and justifications are included in the Annex.)
A decision rule must generally provide an objective basis for deciding whether or not the data and information acquired up to that point in the alarm assessment supports the hypothesis that the alarm was due to an innocent cause.
Each decision rule should be based on the identification of a specific cause or a source of incorrect data that contributed to the alarm level of the loss estimator except that the rule may verify with high probability that no loss has occurred without having identified all contributing causes of the alarm.
Examples of acceptable decision rules are:
A false alarm resulting from a mistake.
A false alarm resulting from a mistake.
: 1. A correctable mistake identified and supported by direct evidence such as comparison to data collection sheets, reading a column level, or measuring a sample.
1.
: 2. A correctable mistake or recordkeeping error identified and supported by at least two sources of independent indirect evidence such as consistency of process values, historical ranges, a loss followed by a gain in the following control unit such that an error in the transfer           i was identified as greater than measurement error, or an interview with operators who observed an unusual process             ,
A correctable mistake identified and supported by direct evidence such as comparison to data collection sheets, reading a column level, or measuring a sample.
condition.
2.
:                                3. A hypothesized uncorrectable mistake (or combination of 1                                       mistakes) or procedural error which is supported by a l                                       difference of opposite sign and comparable magnitude in a 1                                       related loss indicator and two sources of indirect evidence
A correctable mistake or recordkeeping error identified and supported by at least two sources of independent indirect evidence such as consistency of process values, historical ranges, a loss followed by a gain in the following control unit such that an error in the transfer i
!                                      such as process yield, balance around non-SSNM materials, i                                       process consistency, or measurement control data indicating a short term failure.
was identified as greater than measurement error, or an interview with operators who observed an unusual process condition.
A false alarm caused by stochastic fluctuations in the detection l                                 system.
3.
;                                1. An error resulting from measurement variability identified           ;
A hypothesized uncorrectable mistake (or combination of 1
and supported by remeasuring inventories or transfers where
mistakes) or procedural error which is supported by a l
:                                      the differences between the original and remeasurement values exceed the two sigma confidence interval used to monitor and control measurement performance.
difference of opposite sign and comparable magnitude in a 1
related loss indicator and two sources of indirect evidence such as process yield, balance around non-SSNM materials, i
process consistency, or measurement control data indicating a short term failure.
A false alarm caused by stochastic fluctuations in the detection l
system.
1.
An error resulting from measurement variability identified and supported by remeasuring inventories or transfers where the differences between the original and remeasurement values exceed the two sigma confidence interval used to monitor and control measurement performance.
i i
i i
l                                                         30 i
l 30 i


2..         An error resulting from variabilities in the process that is confirmed by processing the material through the process
2..
                                                                  ~
An error resulting from variabilities in the process that is confirmed by processing the material through the process and verifying the discrepancy by recovering the material.
and verifying the discrepancy by recovering the material.
~
: 3.           An error resulting from inadequate modeling of in process inventory where continued processing results in a stable
3.
!,                                    cumulative loss indicator.
An error resulting from inadequate modeling of in process inventory where continued processing results in a stable cumulative loss indicator.
j                       4.           A bias identified by an independent technique that results                       <
j 4.
l                                    from differences in material types being processed.
A bias identified by an independent technique that results l
i o    The alarm resolution time commitments ensure a reasonably prompt alarm
from differences in material types being processed.
.                  response.             The check of the loss indicator data for clerical mistakes
i The alarm resolution time commitments ensure a reasonably prompt alarm o
,                and data errors should normally be completed within 24 hours for any
response.
;                abrupt loss alarm. The maximum time for completion of the resolution i                 procedure for alarms indicating a possible abrupt loss of items that j                 were tamper-safed, encapsulated, or retained in a vault that provided
The check of the loss indicator data for clerical mistakes and data errors should normally be completed within 24 hours for any abrupt loss alarm.
:                protection equivalent to tamper-safing should normally not exceed three calendar days. The maximum time for completion of the resolu-
The maximum time for completion of the resolution i
:                tion procedure for alarms indicating a possible abrupt loss of SSNM i                 in any form or container that was not tamper-safed, encapsulated, or i                 stored in a vault equivalent to tamper-safing should not normally
procedure for alarms indicating a possible abrupt loss of items that j
,                exceed three working days. However, if longer time periods are 3                required for certain unit processes or types of necessary response activities, the licensee should explain and justify the proposed j                 times in the response plan submitted.
were tamper-safed, encapsulated, or retained in a vault that provided protection equivalent to tamper-safing should normally not exceed three calendar days.
!          o     When a tamper-safed or encapsulated item has been compromised, a remeasurement should be immediately undertaken. The maximum time
The maximum time for completion of the resolu-tion procedure for alarms indicating a possible abrupt loss of SSNM i
!                after the alarm for completing a remeasurement to confirm the contents i                 should normally not exceed two working days. Any proposed extension i                 of that time should be explained and justified.               An example of where
in any form or container that was not tamper-safed, encapsulated, or i
,                additional time might be necessary would be if isotopic measurements are performed off-site.
stored in a vault equivalent to tamper-safing should not normally exceed three working days.
o     When a vault or CAA providing protection equivalent to tamper-safing has been entered without authorization, when the prescribed vault r                protection has been compromised, or when other indications of loss of control are discovered, the entire vault contents should be accounted for within three calendar days by a piece count and attribute test of                               ;
However, if longer time periods are required for certain unit processes or types of necessary response 3
all items not tamper-safed or encapsulated, such as by weighing or NOA. Remeasurement of all items in the vault or permanently control-                             ,
activities, the licensee should explain and justify the proposed j
led access area not tamper-safed or encapsulated should be initiated within one working day. If a longer period is proposed, justification is provided. Since the number of samples to be analyzed is unknown, it is impractical to specify a time to complete the remeasurement.
times in the response plan submitted.
o When a tamper-safed or encapsulated item has been compromised, a remeasurement should be immediately undertaken.
The maximum time after the alarm for completing a remeasurement to confirm the contents i
should normally not exceed two working days.
Any proposed extension i
of that time should be explained and justified.
An example of where additional time might be necessary would be if isotopic measurements are performed off-site.
o When a vault or CAA providing protection equivalent to tamper-safing has been entered without authorization, when the prescribed vault protection has been compromised, or when other indications of loss of r
control are discovered, the entire vault contents should be accounted for within three calendar days by a piece count and attribute test of all items not tamper-safed or encapsulated, such as by weighing or NOA.
Remeasurement of all items in the vault or permanently control-led access area not tamper-safed or encapsulated should be initiated within one working day.
If a longer period is proposed, justification is provided.
Since the number of samples to be analyzed is unknown, it is impractical to specify a time to complete the remeasurement.
i 31
i 31


l i
i o
o  Remeasurements of the SSNM to verify the content or composition of items or bulk material associated with an alarm should be made to a standard deviation of the quantity estimate that is comparable to that of the book value, and the hypothesis that the difference between the initial and remeasurement value is zero should be tested at the 0.05 level of significance.
Remeasurements of the SSNM to verify the content or composition of items or bulk material associated with an alarm should be made to a standard deviation of the quantity estimate that is comparable to that of the book value, and the hypothesis that the difference between the initial and remeasurement value is zero should be tested at the 0.05 level of significance.
o   In the event that the cause of the alarm is claimed to be the destruction of an item such as by processing it.to another form, without the act having been recorded, confirmatory evidence should be developed to support the conclusion. The types of confirmatory evidence that are expected to be applicable are described in the plan. The evidence will be acceptable if it is relevant, concrete, independent, and objective. Examples of such evidence are:
o In the event that the cause of the alarm is claimed to be the destruction of an item such as by processing it.to another form, without the act having been recorded, confirmatory evidence should be developed to support the conclusion.
The measured density of a suspect solution is consistent with         '
The types of confirmatory evidence that are expected to be applicable are described in the plan.
the predicted density assuming the contents of the missing container had been added to the process,                             ;
The evidence will be acceptable if it is relevant, concrete, independent, and objective.
The actual yield from a suspect unit process is consistent with       i the predicted yield from that process if it contained the contents of the missing item, or                                 .
Examples of such evidence are:
                                                                                    ^
The measured density of a suspect solution is consistent with the predicted density assuming the contents of the missing container had been added to the process, The actual yield from a suspect unit process is consistent with i
the predicted yield from that process if it contained the contents of the missing item, or
^
The fact that th'e container was added to process can be attested to by two individuals.
The fact that th'e container was added to process can be attested to by two individuals.
o After an alarm has been resolved, the planned corrective action includes MC&A system revisions, if appropriate, that provide reason-able assurance that future alarms of that nature, i.e., having the same or a similar cause, will not occur. An example of where an MC&A system revision would be appropriate would be revision of a procedure or computer software that contains an error that caused an alarm.
o After an alarm has been resolved, the planned corrective action includes MC&A system revisions, if appropriate, that provide reason-able assurance that future alarms of that nature, i.e., having the same or a similar cause, will not occur.
I o If one or more items are not found in their recorded locations the ifcensee should normally declare the item (s) missing if not found or l         accounted for within: 24 hours for Category IA items totalling five i         formula kilograms or more and three working days for all other items.
An example of where an MC&A system revision would be appropriate would be revision of a procedure or computer software that contains an error that caused an alarm.
;        A search for a misplaced item that was not tamper-safed or encapsu-l         lated should not be terminated without NRC permission until the item
I o
'        is located or evidence of its destruction is obtained, except that a claim that an item was destroyed without recording the fact may be accepted if independent confirmatory evidence of destruction is             e obtained. Items containing less than 0.05 FKG are exempted from the requirements for confirmatory evidence. Searches for missing items should not be interrupted by idle time such as weekends, holidays, etc.
If one or more items are not found in their recorded locations the ifcensee should normally declare the item (s) missing if not found or l
o An item loss assessment procedure has been included which details a
accounted for within:
,        logical sequence of actions to resolve an apparent loss. A typical j         assessment sequence (not necessarily in the order listed) might be to:
24 hours for Category IA items totalling five i
formula kilograms or more and three working days for all other items.
A search for a misplaced item that was not tamper-safed or encapsu-l lated should not be terminated without NRC permission until the item i
is located or evidence of its destruction is obtained, except that a claim that an item was destroyed without recording the fact may be accepted if independent confirmatory evidence of destruction is e
obtained.
Items containing less than 0.05 FKG are exempted from the requirements for confirmatory evidence.
Searches for missing items should not be interrupted by idle time such as weekends, holidays, etc.
o An item loss assessment procedure has been included which details a logical sequence of actions to resolve an apparent loss.
A typical j
assessment sequence (not necessarily in the order listed) might be to:
Determine that the records are apparently correct by tracing the item identification and location information to its source data in inventory and production records; 32
Determine that the records are apparently correct by tracing the item identification and location information to its source data in inventory and production records; 32


0 Search other production and storage areas to determine if the item was transferred without supporting documentation; Identify all persons involved in creation and movement of the item (s) and question them for possible ways the item might have been misplaced or record errors made; Extend the search to other locations, particularly those suggested by the persons involved; Check for possible errors in the item records by evaluating the bulk material balances in the adjacent processing units; Reinventory all items of that type in storage locations routinely used for such items; and Extend the inventory search to items of similar size and appearance.
0 Search other production and storage areas to determine if the item was transferred without supporting documentation; Identify all persons involved in creation and movement of the item (s) and question them for possible ways the item might have been misplaced or record errors made; Extend the search to other locations, particularly those suggested by the persons involved; Check for possible errors in the item records by evaluating the bulk material balances in the adjacent processing units; Reinventory all items of that type in storage locations routinely used for such items; and Extend the inventory search to items of similar size and appearance.
o                     A description of the licensee's proposed course of action in response to a broken tamper-seal should include:
o A description of the licensee's proposed course of action in response to a broken tamper-seal should include:
Placing the item under surveillance immediately or in secured
Placing the item under surveillance immediately or in secured storage and remeasuring it as soon as practicable (time limits
^
^
storage and remeasuring it as soon as practicable (time limits specified) to determine if SSNM is missing, Performing blending, mixing, or splitting operations, if appro-priate, to assure that any samples taken for remeasurement are representative; and Testing the difference between the original and confirming measurement for statistical significance with a probability of no more than five percent of concluding that no SSNM is missing when in fact a loss has occurred. The quality of the remeasure-ment should be at least comparable to the original measurement.
specified) to determine if SSNM is missing, Performing blending, mixing, or splitting operations, if appro-priate, to assure that any samples taken for remeasurement are representative; and Testing the difference between the original and confirming measurement for statistical significance with a probability of no more than five percent of concluding that no SSNM is missing when in fact a loss has occurred.
o                     The operations that will be shut down to resolve alarms in excess of
The quality of the remeasure-ment should be at least comparable to the original measurement.
.                        5 FKG are identified or alternatives to shutdown are provided.
o The operations that will be shut down to resolve alarms in excess of 5 FKG are identified or alternatives to shutdown are provided.
Examples of acceptable alternatives might include:
Examples of acceptable alternatives might include:
Shutting down of only downstream operations to retain products that may require remeasurement, Discontinuing the processing of certain sidestreams to retain scrap or recyclable intermediates that may require remeasurement, Diverting scrap, waste or product from the alarming unit to auxiliary vessels or to a buffer storage area to retain the products for remeasurement, Collecting additional samples for remeasurement of materials that would become unavailable if operations were not suspended i                                       in the area under investigation.
Shutting down of only downstream operations to retain products that may require remeasurement, Discontinuing the processing of certain sidestreams to retain scrap or recyclable intermediates that may require remeasurement, Diverting scrap, waste or product from the alarming unit to auxiliary vessels or to a buffer storage area to retain the products for remeasurement, Collecting additional samples for remeasurement of materials that would become unavailable if operations were not suspended i
in the area under investigation.
i 33
i 33


    ~
~
The key consideration in employing alternatives to shutdown is that the licensee can show that no data or information needed for response will be lost if the alternative is used.
The key consideration in employing alternatives to shutdown is that the licensee can show that no data or information needed for response will be lost if the alternative is used.
o     The conditions for restart are specified. Fundamental to any decision to restart are the alarm has been resolved, i.e., an assignable cause has been found, the loss is real but remedial, or recovery action is underway or the alarm has not been resolved; however, all possible and necessary data associated with the process material have been acquired, and no information will be jeopardized by resuming operations, o    The quality of the licensee's loss resolution capability is such that the combination of the material control test and resolution decisions will permit alarms remaining unresolved after investigation to be good indicators of material loss. To achieve this objective, the licensee's planning data should demonstrate that the expected number of unresolved alarms in excess of 5 FKGs will be less than 0.10 abrupt loss alarms per inventory period.
o The conditions for restart are specified.
Fundamental to any decision to restart are the alarm has been resolved, i.e., an assignable cause has been found, the loss is real but remedial, or recovery action is underway or the alarm has not been resolved; however, all possible and necessary data associated with the process material have been acquired, and no information will be jeopardized by resuming operations, The quality of the licensee's loss resolution capability is such that o
the combination of the material control test and resolution decisions will permit alarms remaining unresolved after investigation to be good indicators of material loss.
To achieve this objective, the licensee's planning data should demonstrate that the expected number of unresolved alarms in excess of 5 FKGs will be less than 0.10 abrupt loss alarms per inventory period.
The following additional information is pertinent to this point:
The following additional information is pertinent to this point:
The only false alarms that need to be predicted are those due to                                                                 '
The only false alarms that need to be predicted are those due to normal process or measurement system statistical variation.
normal process or measurement system statistical variation. Mistakes in transcription of data or process upsets do not need to be predicted because the response procedures should be designed to correctly resolve alarms stemming from those types of events. False alarms due to statistical fluctuations are expected to be more difficult to resolve.
Mistakes in transcription of data or process upsets do not need to be predicted because the response procedures should be designed to correctly resolve alarms stemming from those types of events.
False alarms due to statistical fluctuations are expected to be more difficult to resolve.
One approach is to claim no credit for resolution of statistical alarms.
One approach is to claim no credit for resolution of statistical alarms.
In that case, the incremental expected number of alarms with discrepancies greater than 5 FKG can be calculated for a single test from the formula:
In that case, the incremental expected number of alarms with discrepancies greater than 5 FKG can be calculated for a single test from the formula:
l                               AN = 1 - F (5/a) where o = the predicted standard deviation of the detection test in test in FKG 1
l AN = 1 - F (5/a) where o = the predicted standard deviation of the detection test in test in FKG 1
F(x) = the predicted statistical distribution of the test statistic normalized by o.
F(x) = the predicted statistical distribution of the test statistic normalized by o.
This increment must then be multiplied by the expected number of times the test will be performed in an inventory period, and similar calcula-tions then added up over all tests in the facility. That sum must be
This increment must then be multiplied by the expected number of times the test will be performed in an inventory period, and similar calcula-tions then added up over all tests in the facility.
;                      less than 0.10, i.e., the number of such alarms must be less than one every 30 months.
That sum must be less than 0.10, i.e., the number of such alarms must be less than one every 30 months.
l 34 i
l 34 i
I
I


                                                                                          .. i If the distribution function cannot be assumed to the normal (Gaussian) and the true distribution cannot be adequately predicted, the Camp-Meidell inequality may be applied if it is reasonable to expect the true distribution will be symmetric and unimodal (see Shewhart (1931), pages 176-177; and Eisenhart, Hastay and Wallis (1947), page 49). The Camp-Meidell inequality permits a bound on N to be calculated from the formula:
i If the distribution function cannot be assumed to the normal (Gaussian) and the true distribution cannot be adequately predicted, the Camp-Meidell inequality may be applied if it is reasonable to expect the true distribution will be symmetric and unimodal (see Shewhart (1931), pages 176-177; and Eisenhart, Hastay and Wallis (1947), page 49).
AN5(f)(f)2 where a has units of formula kilograms. However, this will typically be useful only if s is less than 0.1 formula kilogram. A more useful approach would be to estimate the maximum range that the test statistic could have based on a physical model of the process and measurement systems under the hypothesis of no material diversion.     If this value is less than 5 FKG, set AN = 0.
The Camp-Meidell inequality permits a bound on N to be calculated from the formula:
Evaluation is more complicated if the licensee claims that response procedures will permit resolution of some fraction of the statistical false alarms. Such procedures would need to be summarized in the plan. One approach is to make additional measurements of inputs, products, sidestreams, and holdups to complete measured material balances where loss detectors are based on average expected yields.
AN5(f)(f)2 where a has units of formula kilograms.
Additional measurement of input quantities requires samples to be taken and retained. This would permit laboratory analyses to be made which are more reliable than NOA. The procedures also could utilize data resulting from processing the same batch through the next process step, data resulting from processing another batch through the same process step, and tests that eliminate intermediate measurement points by combining several process steps. In any of these cases, estimating the fraction of N that would be expected to remain unresolved requires detailed modeling of the response capability.
However, this will typically be useful only if s is less than 0.1 formula kilogram.
A Monte Carlo simulation method can be used to model the alarm response procedures and predict the resolution success rate.       (For a single i           material control test, refer to Tanner (1981).       For an entire plant, refer to Reardon, Heaberlin and Eggers (1982).       Detailed information is available in Eggers (1982)).
A more useful approach would be to estimate the maximum range that the test statistic could have based on a physical model of the process and measurement systems under the hypothesis of no material diversion.
Alternatively, if the licensee has a performance history of responses to and assessment of alarms, this may be cited in place of the simula-l           tion of a proposed response program if the experience demonstrates a
If this value is less than 5 FKG, set AN = 0.
;            capability to meet the commitment goals for resolving false alarms.
Evaluation is more complicated if the licensee claims that response procedures will permit resolution of some fraction of the statistical false alarms.
3.2 Alarm Reporting Requirement:     The rule requires that a licensee notify the appropriate NRC i
Such procedures would need to be summarized in the plan.
Regional Office Ifsted in Appendix A of Part 73 of this chapter of any MC&A alarm that remains unresolved beyond the time period specified for its resolu-tion. Notification is to occur within 24 hours or by the next working day when a weekend or holiday intervene. For alarm estimates that exceed 5 FKG, the 35 l
One approach is to make additional measurements of inputs, products, sidestreams, and holdups to complete measured material balances where loss detectors are based on average expected yields.
Additional measurement of input quantities requires samples to be taken and retained.
This would permit laboratory analyses to be made which are more reliable than NOA.
The procedures also could utilize data resulting from processing the same batch through the next process step, data resulting from processing another batch through the same process step, and tests that eliminate intermediate measurement points by combining several process steps.
In any of these cases, estimating the fraction of N that would be expected to remain unresolved requires detailed modeling of the response capability.
A Monte Carlo simulation method can be used to model the alarm response procedures and predict the resolution success rate.
(For a single i
material control test, refer to Tanner (1981).
For an entire plant, refer to Reardon, Heaberlin and Eggers (1982).
Detailed information is available in Eggers (1982)).
Alternatively, if the licensee has a performance history of responses to and assessment of alarms, this may be cited in place of the simula-l tion of a proposed response program if the experience demonstrates a capability to meet the commitment goals for resolving false alarms.
3.2 Alarm Reporting Requirement:
The rule requires that a licensee notify the appropriate NRC Regional Office Ifsted in Appendix A of Part 73 of this chapter of any MC&A i
alarm that remains unresolved beyond the time period specified for its resolu-tion.
Notification is to occur within 24 hours or by the next working day when a weekend or holiday intervene.
For alarm estimates that exceed 5 FKG, the 35 l


notification that an MC&A alarm resolution procedure has been initiated is to occur within 24 hours (74.57(c) and (g)(2)).
notification that an MC&A alarm resolution procedure has been initiated is to occur within 24 hours (74.57(c) and (g)(2)).
Intent and Scope:                           The intent of these requirements is that the NRC be made aware of potential MC&A discrepancies in a timely manner so that appro-priate actions can be initiated.
Intent and Scope:
Plan / Annex Content:                         The FNMC Plan contains the following affirmations and detailed commitments.                           Supporting information, as appropriate, is included
The intent of these requirements is that the NRC be made aware of potential MC&A discrepancies in a timely manner so that appro-priate actions can be initiated.
,                      in the Annex.
Plan / Annex Content:
The FNMC Plan contains the following affirmations and detailed commitments.
Supporting information, as appropriate, is included in the Annex.
Section 3.2 of the Plan includes the following affirmations:
Section 3.2 of the Plan includes the following affirmations:
o     The appropriate NRC Regional Office will be notified within 24 hours or by the next workday when a weekend or holiday intervene of any alarm that remains unresolved beyond the time limit specified for its                                                           I resolution in Section 3.1.3.
o The appropriate NRC Regional Office will be notified within 24 hours or by the next workday when a weekend or holiday intervene of any alarm that remains unresolved beyond the time limit specified for its I
o     The appropriate NRC Regional Office will be notified within 24 hours of the initiation of an alarm resolution procedure involving an alarm estimate that exceeds 5 FKG.
resolution in Section 3.1.3.
o The appropriate NRC Regional Office will be notified within 24 hours of the initiation of an alarm resolution procedure involving an alarm estimate that exceeds 5 FKG.
3.2.1 Reporting Responsibility Indicate how the responsibility for reporting unresolved alarms will be assigned in the organization.
3.2.1 Reporting Responsibility Indicate how the responsibility for reporting unresolved alarms will be assigned in the organization.
3.2.2   Information Discuss the types of information that will be provided to NRC and the schedule for updating the status of the unresolved alarms to NRC.
3.2.2 Information Discuss the types of information that will be provided to NRC and the schedule for updating the status of the unresolved alarms to NRC.
Acceptance Criteria:                           The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:
Acceptance Criteria:
o     The responsibility for reporting unresolved alarms is assigned at a i                                 sufficiently high level of responsibility within the licensee's organization that decisions on the need for reporting will be timely and unquestioned.
The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:
4 o     The information to be reported includes: the magnitude of the dis-i                                 crepancy indicated by the alarm, the investigation procedure, the status of the investigation, the status of the facility, the planned remedial measures, and the status of the security during the period.
o The responsibility for reporting unresolved alarms is assigned at a i
o     The remedial measures include assignment of responsibility for the investigation to a technically competent individual, rechecking the response of the measurement system to certified standards, outlining a schedule of recalibrations of the key measurement systems if appro-priate, in-situ or clean-out measurements of holdup, and statistical evaluation of the material accounting data.
sufficiently high level of responsibility within the licensee's organization that decisions on the need for reporting will be timely and unquestioned.
4 o
The information to be reported includes:
the magnitude of the dis-i crepancy indicated by the alarm, the investigation procedure, the status of the investigation, the status of the facility, the planned remedial measures, and the status of the security during the period.
o The remedial measures include assignment of responsibility for the investigation to a technically competent individual, rechecking the response of the measurement system to certified standards, outlining a schedule of recalibrations of the key measurement systems if appro-priate, in-situ or clean-out measurements of holdup, and statistical evaluation of the material accounting data.
l 36
l 36


o      With regard to' recurring losses, a significant loss trend will be reported within one week of its discovery and the progress of the resulting investigation will be reported monthly.
With regard to' recurring losses, a significant loss trend will be o
reported within one week of its discovery and the progress of the resulting investigation will be reported monthly.
1 3.3 Alleged Thefts i
1 3.3 Alleged Thefts i
i Requirement: .The rule requires that a licensee establish and maintain ability to respond rapidly to alleged thefts (74.57(f)).
i Requirement:.The rule requires that a licensee establish and maintain ability to respond rapidly to alleged thefts (74.57(f)).
i                                                       Intent and Scope:     The intent of this requirement is to have the capability in place to respond rapidly to alarms occurring external to the MC&A system.
i Intent and Scope:
The intent of this requirement is to have the capability in place to respond rapidly to alarms occurring external to the MC&A system.
The response capability should provide the information necessary to rapidly
The response capability should provide the information necessary to rapidly
{                                                   assess the validity of an alleged theft.
{
t Plan / Annex Content:     The FNMC Plan contains the following affirmations and detailed commitments.           Supporting information, as appropriate, is included                                           .
assess the validity of an alleged theft.
in the Annex.
t Plan / Annex Content:
The FNMC Plan contains the following affirmations and detailed commitments.
Supporting information, as appropriate, is included in the Annex.
Section 3.3 of the Plan includes the following affinnations:
Section 3.3 of the Plan includes the following affinnations:
i i                                                         o     An allegation or other indication of diversion of SSNM from its authorized location will be rapidly investigated and evidence
i i
!                                                                developed that supports either a confirmation or a denial.
o An allegation or other indication of diversion of SSNM from its authorized location will be rapidly investigated and evidence developed that supports either a confirmation or a denial.
!                                                          o     A contingency capability will be maintained to enable on demand loca-tion of any specific tamper-safed or encapsulated item or an unencapsulated item stored in a vault equivalent to tamper-safing j                                                               within eight hours, and to verify the presence of all items in a j                                                               vault within 72 hours.
o A contingency capability will be maintained to enable on demand loca-tion of any specific tamper-safed or encapsulated item or an unencapsulated item stored in a vault equivalent to tamper-safing j
j                                                          o    A contingency capability will be maintained to initiate an emergency plant-wide physical inventory of all SSNM in the plant, or in any portion of the plant, within 24 hours after receipt of an NRC order.
within eight hours, and to verify the presence of all items in a j
,                                                                (" Initiate" means to begin actions to place SSNM in a measurable form and perform necessary preparations for conducting a physical inventory).
vault within 72 hours.
1 o     Accurate item inventory records will be established and maintained to j
A contingency capability will be maintained to initiate an emergency j
o plant-wide physical inventory of all SSNM in the plant, or in any portion of the plant, within 24 hours after receipt of an NRC order.
(" Initiate" means to begin actions to place SSNM in a measurable form and perform necessary preparations for conducting a physical inventory).
1 o
Accurate item inventory records will be established and maintained to j
provide knowledge of the identity, location, and quantity of SSNM in the form of items outside a vault or permanently controlled access area, and the capability will be maintained to update the records rapidly enough to confirm the presence and integrity of any item I
provide knowledge of the identity, location, and quantity of SSNM in the form of items outside a vault or permanently controlled access area, and the capability will be maintained to update the records rapidly enough to confirm the presence and integrity of any item I
within 24 hours and, upon demand, all items within one week.
within 24 hours and, upon demand, all items within one week.
o     For material not in the form of items, accurate records will be i                                                               established and maintained on the quantities of SSNM which have been
o For material not in the form of items, accurate records will be i
,                                                                received, shipped, or otherwise removed from each MAA, and quantities of SSNM remaining within each MAA and the capability to update the
established and maintained on the quantities of SSNM which have been received, shipped, or otherwise removed from each MAA, and quantities of SSNM remaining within each MAA and the capability to update the records rapidly enough to meet the requirements of the emergency plant-wide physical inventory.
,                                                                records rapidly enough to meet the requirements of the emergency                                                       ;
i 3.3.1 Item Control System Describe the item control system that will be maintained in order to i
!                                                                plant-wide physical inventory.
readily determine the identity, quantity, and location of SSNM in item form i
i 3.3.1     Item Control System
i 37 f
!                                                        Describe the item control system that will be maintained in order to i                                                   readily determine the identity, quantity, and location of SSNM in item form i
w,,_.,-.-,-,v.-___.---,.~,.,..,_.m
i
,m,,,,m,--
!                                                                                                                        37 f
,mm,m_,._,
    -,- - - , . - w,,_.,-.-,-,v.-___.---,.~,.,..,_.m                               ,m,,,,m,--             ,  ,mm,m_,._,   _ _ ,,-.-m..m._             ,_m . . . - _            ,.p-._,
_ _,,-.-m..m._
,_m
,.p-._,


O
O O
!            O t
t can be The description should include the forms, records, and document flow paths. Where records are not centralized, the means of record verification by MC&A personnel and the responsibility for maintenance and disposition should be described.
can be The description should include the forms, records, and document flow paths. Where records are not centralized, the means of record verification by MC&A personnel and the responsibility for maintenance and disposition should be described.
3.3.2 Inventory Verification Describe the emergency physical inventory procedure, including a descrip-4 tion of the status that each unit operation should be in to be inventoried and indicate the status of each unit operation during its inventory.
3.3.2                     Inventory Verification 4
Describe the emergency physical inventory procedure, including a descrip-tion of the status that each unit operation should be in to be inventoried and indicate the status of each unit operation during its inventory.
In the Annex provide estimates of the times needed to perform and reconcile the inventory and to determine the associated projected variance.
In the Annex provide estimates of the times needed to perform and reconcile the inventory and to determine the associated projected variance.
;                                        3.3.3                   Record Maintenance Describe the protective measures that will be implemented to prevent loss, misplacement, or accidental destruction of inventory and item location records.
3.3.3 Record Maintenance Describe the protective measures that will be implemented to prevent loss, misplacement, or accidental destruction of inventory and item location records.
Acceptance Criteria:                                           The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:
Acceptance Criteria:
1 I                                                         o                 From the description of the SSNM item record system, it is evident that' the records of the identity and location of every item can be updated with sufficient speed to support the commitments that any randomly l                                                                             selected item within a vault can be located within eight hours, and any item outside a vault can be located within 24 hours.               The capa-bility also exists to locate all items within a vault within 72 hours and all items outside a vault or permanently controlled access area within one week.
The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:
i                                                         o                  Provisions are included for maintaining the availability of forms, tags, trained personnel, inventory listing, and other items that may be needed to initiate a plant-wide physical inventory within 24 hours.
1 I
l                                                                           The emergency inventory capability is designed to help answer the t
o From the description of the SSNM item record system, it is evident that' the records of the identity and location of every item can be updated with sufficient speed to support the commitments that any randomly l
selected item within a vault can be located within eight hours, and any item outside a vault can be located within 24 hours.
The capa-bility also exists to locate all items within a vault within 72 hours and all items outside a vault or permanently controlled access area within one week.
i Provisions are included for maintaining the availability of forms, o
tags, trained personnel, inventory listing, and other items that may be needed to initiate a plant-wide physical inventory within 24 hours.
l The emergency inventory capability is designed to help answer the t
following questions:
following questions:
Can it be determined conclusively that SSNM is or is not missing j                                                                                               from the facility?
Can it be determined conclusively that SSNM is or is not missing j
from the facility?
What quantity is missing?
What quantity is missing?
What material type is it? For example, what is its isotopic         '
What material type is it? For example, what is its isotopic composition, its chemical form, and its physical size?
composition, its chemical form, and its physical size?
Over what time period could it have been diverted?
Over what time period could it have been diverted?
Which plant employees or other individuals might have had access to it during that time?
Which plant employees or other individuals might have had access to it during that time?
Line 1,278: Line 1,900:
38
38


                                              ,,                                                                                      y .- - -                -
y.- - -
y                                 ,e..
y
s   V                                .
,e..
s o            Appropriate safeguirds are implessated to prevent loss, misple:e.nant,           ?
V s
I             i ^
s Appropriate safeguirds are implessated to prevent loss, misple:e.nant,
or accidental destruction of the inventory and iters 1ccation records.
?
s                                           i-o-          The data collecting, recording, and auditing procedures provir's Veasonable protection against errors in the records.
I i ^
4
o or accidental destruction of the inventory and iters 1ccation records.
                                                                                                                      .7 Questions and Answers                 ,,
s i-The data collecting, recording, and auditing procedures provir's Veasonable o-4 protection against errors in the records.
74.57 Alarm Resolution
.7 Questions and Answers 74.57 Alarm Resolution 1.
: 1. Q.           How do alarm resolution requirements integrate the contingency p1 w for MC&A events required in 10 CFR Part 737                                   -
Q.
                                                                                                                ~                                     '
How do alarm resolution requirements integrate the contingency p1 w for MC&A events required in 10 CFR Part 737
A.           Licensees' plans for response to MC&A indications of possible theft or missing SSNM are currently part cf the licensees' " Safeguard /
~
Contingency Plarp," required by 10 CFR 70.22(g), 73.40(b), and ,
A.
73.46(h). These were prepared in accordance with t.he criteria in Appendix C to 10 CFR Part 73 and Regulatory Guide 5.55, " Standard Format and Content of Safeguards Contingency Plans for Fuel Cycle Facilities." However, the regulations under which those plans were prepared and reviewed focused.on the physical security system. The proposed amendments would de*fne tt e performance to be achieved by the licensees in response to' detection alarms from the MC&4 system                                                         /
Licensees' plans for response to MC&A indications of possible theft or missing SSNM are currently part cf the licensees' " Safeguard /
and to external allegations of thefts.                             Furthermore, the preposed amendments would require reconsideration by:the licensee of what constitutes an MC&A detection, with increased attention paid to process and production anomalies that might b's due to SSNM loss, and less emphasis on pericdic physical inventories. Thus the licensees would have to submit revised FNMC plans to comply with the propose.d amendments, as well as reconsider the parts of their Safeguards Con-
Contingency Plarp," required by 10 CFR 70.22(g), 73.40(b), and,
                                                                                                ~
73.46(h).
tingency Plans dealing with MC&A events. Rather than duplicate the same words in both plans, either plan could incorporate by refereace appropriate pages of the other.
These were prepared in accordance with t.he criteria in Appendix C to 10 CFR Part 73 and Regulatory Guide 5.55, " Standard Format and Content of Safeguards Contingency Plans for Fuel Cycle Facilities." However, the regulations under which those plans were prepared and reviewed focused.on the physical security system.
: 2. Q.           What quality of loss resolution must the licensee achieve?
The proposed amendments would de*fne tt e performance to be achieved by the licensees in response to' detection alarms from the MC&4 system
A.           The combined quality of the material control test and loss roselution
/
!                    decisions shall permit alarms remaining unresolved after completian
and to external allegations of thefts.
!                    of the licensee's investigative activities to be good indicators of theft or diversion. This will be judged in two ways:
Furthermore, the preposed amendments would require reconsideration by:the licensee of what constitutes an MC&A detection, with increased attention paid to process and production anomalies that might b's due to SSNM loss, and less emphasis on pericdic physical inventories.
(1) During review of a licenseo's planned detection an:t alarm resolution capabilities, attentien will be directed to the abi?ity to resolve false abrupt loss alarms.               For the alarm resolution capat'il-ity to be acceptable, it must appear able to correctly identify all i
Thus the licensees would have to submit revised FNMC plans to comply with the propose.d amendments, as well as reconsider the parts of their Safeguards Con-
errors due to leaks, process upsets, or human itistakes that are large enough to cause an alarsn. With resp ct to other false alarms, in l                     particular those alarms that are expected to_ occur because of the l                     statistical nature of the processes and measurement systems, the
~
,                    alarm resolution capability need not be 100 percent effective.
tingency Plans dealing with MC&A events.
l                     However, for it to be acceptable, it must be effective enough to j                     satisfactorily limit the statistically expected rate of unresoltable false abrupt loss alarms. (The expected rate can be thought of as a weighted average of all possible rates, where the weights are the 39                                                                                                             ,
Rather than duplicate the same words in both plans, either plan could incorporate by refereace appropriate pages of the other.
l                                                                                                                                                        I
2.
          ~-,.-,-.,e.         w--._,-,._ -            ,, , , . . , _ , , . , , , , . . , _ - _
Q.
                                                                                                          -n     ..-,.-w ,.,e...wr-y       ,.v.r--     ywmy.
What quality of loss resolution must the licensee achieve?
A.
The combined quality of the material control test and loss roselution decisions shall permit alarms remaining unresolved after completian of the licensee's investigative activities to be good indicators of theft or diversion.
This will be judged in two ways:
(1) During review of a licenseo's planned detection an:t alarm resolution capabilities, attentien will be directed to the abi?ity to resolve false abrupt loss alarms.
For the alarm resolution capat'il-ity to be acceptable, it must appear able to correctly identify all errors due to leaks, process upsets, or human itistakes that are large i
enough to cause an alarsn. With resp ct to other false alarms, in l
particular those alarms that are expected to_ occur because of the l
statistical nature of the processes and measurement systems, the alarm resolution capability need not be 100 percent effective.
l However, for it to be acceptable, it must be effective enough to j
satisfactorily limit the statistically expected rate of unresoltable false abrupt loss alarms.
(The expected rate can be thought of as a weighted average of all possible rates, where the weights are the 39 l
I e----
-m- -,., =
~-,.-,-.,e.
w--._,-,._
.,.w_m--,,,m_,i.
..m
-n
..-,.-w
,.,e...wr-y
,.v.r--
ywmy.


I<
I<
a
a
        'l                                 likelihoods of-occurrence of those rates.) A satisfactory limit is
'l likelihoods of-occurrence of those rates.) A satisfactory limit is
                                /-         an expected rete of unresolvable large abrupt loss false alarms less a           than one per 10 years per plant.               A large false alarm is one whose loss estimate exceeds 5 FKG. Because-the licensee must be able to resolve all alarms other than those of a statistical nature, calcu-
/-
        ,,                                lation of the expected rate of unresolvable large abrupt loss false "L-                                       alarms reeds only consider false alarms of a statistical nature.
an expected rete of unresolvable large abrupt loss false alarms less a
                      '[                   (2) After the phase-in period is over and all elements of the t                          licensee's alarm resolution commitments have been implemented, the 4         'l       _.                  alarm resolution performance would be judged good when: (a) there have been no situations over the past year in which a large abrupt 3
than one per 10 years per plant.
A large false alarm is one whose loss estimate exceeds 5 FKG.
Because-the licensee must be able to resolve all alarms other than those of a statistical nature, calcu-lation of the expected rate of unresolvable large abrupt loss false "L-alarms reeds only consider false alarms of a statistical nature.
t
'[
(2) After the phase-in period is over and all elements of the licensee's alarm resolution commitments have been implemented, the 4
'l alarm resolution performance would be judged good when:
(a) there have been no situations over the past year in which a large abrupt 3
loss (alarm is found in subsequent audits or investigations to have beer) innocently caused but was not so resolved within the licensee's
loss (alarm is found in subsequent audits or investigations to have beer) innocently caused but was not so resolved within the licensee's
                    /                     time commitments; and (b) there are no unresolved large abrupt loss alarms remaining after the quarterly inventories and annual audit have been completed.
/
S 74.S7(f) Alleged Thefts
time commitments; and (b) there are no unresolved large abrupt loss alarms remaining after the quarterly inventories and annual audit have been completed.
: 3.         Q. What are alleged thefts?
S 74.S7(f) Alleged Thefts 3.
        ., . ' u 4   Alarms that originate external to the MC&A system.                                           Among these are any statements communicated directly or indirectly to facility staff, NRC, FBI, police, etc., that diversion of SSNM under license has
Q.
    ]'
What are alleged thefts?
occurred. The statements may or may not include details such as from which plant material was allegedly taken, which item was taken, or submittal of an alleged sample of the material. This covers threats allegedly from within as well as from outside the facility. An external alarm may include other indications such as an external assault that penetrated an MAA or the discovery that an MAA door had been opened from the inside.
4 Alarms that originate external to the MC&A system.
Among these are
.,. ' u any statements communicated directly or indirectly to facility staff, NRC, FBI, police, etc., that diversion of SSNM under license has
]
occurred.
The statements may or may not include details such as from which plant material was allegedly taken, which item was taken, or submittal of an alleged sample of the material.
This covers threats allegedly from within as well as from outside the facility.
An external alarm may include other indications such as an external assault that penetrated an MAA or the discovery that an MAA door had been opened from the inside.
l k
l k
I 40
I 40


                                  ' CHAPTER 4.0 QUALITY ASSURANCE 4.1 Management Structure                               '                                  !
' CHAPTER 4.0 QUALITY ASSURANCE 4.1 Management Structure Requirement:
Requirement:   The rule requires that a licensee:
The rule requires that a licensee:
(1) Establish a management structure that includes clearly defined a,                 responsibility for the planning, coordination, and administration of MC&A functions; independence of MC&A functions from production responsibilities; and separation of functions such that the activities of one indivfdual or organizational unit serve as controls over and checks of the activities of others.
(1) Establish a management structure that includes clearly defined a,
responsibility for the planning, coordination, and administration of MC&A functions; independence of MC&A functions from production responsibilities; and separation of functions such that the activities of one indivfdual or organizational unit serve as controls over and checks of the activities of others.
(2) Provide for the adequate review and use of those MC&A procedures that are identified in an approved plan as being critical to the effectiveness of the described system (874.59(b)). -
(2) Provide for the adequate review and use of those MC&A procedures that are identified in an approved plan as being critical to the effectiveness of the described system (874.59(b)). -
Intent and Scope: The intent of this section is to require licensees to implement a management structure that permits effece.ive functioning of the MC&A system. Documentation, review, and approval of the procedures and the assign-ment of the key functions to specific positions eliminates ambiguities about what is to be done by whom. . The management structure is meant to separate key MC&A functions from each other in order to provide cross-checks that increase MC&A system reliability and counter defeat of the system through neglect, deceit, or falsification, and to free MC&A management from conflicts of interest with other major responsibilities such as production.
Intent and Scope: The intent of this section is to require licensees to implement a management structure that permits effece.ive functioning of the MC&A system.
Plan / Annex content:   The FNMC Plan contains the following affirmations and detailed commitments.         Supporting information, as appropriate, is included in the Annex.
Documentation, review, and approval of the procedures and the assign-ment of the key functions to specific positions eliminates ambiguities about what is to be done by whom.. The management structure is meant to separate key MC&A functions from each other in order to provide cross-checks that increase MC&A system reliability and counter defeat of the system through neglect, deceit, or falsification, and to free MC&A management from conflicts of interest with other major responsibilities such as production.
Plan / Annex content:
The FNMC Plan contains the following affirmations and detailed commitments.
Supporting information, as appropriate, is included in the Annex.
Section 4.1 of the Plan includes the following affirmations:
Section 4.1 of the Plan includes the following affirmations:
o     The overall responsibility for MC&A system management is assigned'to a position that provides a separation from production responsibilities or any other responsibi'lities that may give rise to a conflict of interest.                                       <
o The overall responsibility for MC&A system management is assigned'to a position that provides a separation from production responsibilities or any other responsibi'lities that may give rise to a conflict of interest.
o     The responsibility for each MC&A function is assigned to a specific position in the organization in a way that key functions are cross-checked.
o The responsibility for each MC&A function is assigned to a specific position in the organization in a way that key functions are cross-checked.
o     The management structure and the critical MC&A policies and procedures are documented and provisions are made for review and approval prior to implementation.
o The management structure and the critical MC&A policies and procedures are documented and provisions are made for review and approval prior to implementation.
3   4.1.1 Organization a
3 4.1.1 Organization a
Describe the organization for MC&A including the functional responsibilities for each organizational unit and show how the MC&A organization is independent of responsibilities that have potentially conflicting goals.
Describe the organization for MC&A including the functional responsibilities for each organizational unit and show how the MC&A organization is independent of responsibilities that have potentially conflicting goals.
41
41
Line 1,341: Line 2,003:
Describe the policies, procedures, duties, responsibilities, and authorities associated with each position involved with an MC&A function in sufficient detail to demonstrate the cross-checks built into the MC&A system.
Describe the policies, procedures, duties, responsibilities, and authorities associated with each position involved with an MC&A function in sufficient detail to demonstrate the cross-checks built into the MC&A system.
In the Plan provide a listing (by title and procedure number) of the procedures deemed to be critical to the effectiveness of the MC&A system.
In the Plan provide a listing (by title and procedure number) of the procedures deemed to be critical to the effectiveness of the MC&A system.
Acceptance criteria:                                   The assessment of the adequacy of the information supplied             i above will be based on the following criteria or equivalent:
Acceptance criteria:
o     The MC&A organization is separate from the SSNM production organiza-tion and any other organization that generates source data, if practical.                               Otherwise controls are in place to ensure that process operations, measurements, measurement controls, accounting functions, and any other activities that influence MC&A system performance are carried out both in the letter and spirit of approved procedures; and                                         ,
The assessment of the adequacy of the information supplied i
that decisions impacting MC&A, that can conflict with production or other plant functions, are under the oversight of an independent authority.
above will be based on the following criteria or equivalent:
o The MC&A organization is separate from the SSNM production organiza-tion and any other organization that generates source data, if practical.
Otherwise controls are in place to ensure that process operations, measurements, measurement controls, accounting functions, and any other activities that influence MC&A system performance are carried out both in the letter and spirit of approved procedures; and that decisions impacting MC&A, that can conflict with production or other plant functions, are under the oversight of an independent authority.
An effective management structure will exhibit at least the following attributes:
An effective management structure will exhibit at least the following attributes:
The overall planning, coordination, and administration of the MC&A functions for SSNM is vested in a single individual at an organizational level that is sufficient to ensure independence of action and objectivity of decisions. The individual must be in a position to recommend and initiate timely action for the control and accounting of SSNM including delaying production, if necessary, and must not be enmeshed in a hierarchical framework that could inhibit or compromise independent action.
The overall planning, coordination, and administration of the MC&A functions for SSNM is vested in a single individual at an organizational level that is sufficient to ensure independence of action and objectivity of decisions.
The individual must be in a position to recommend and initiate timely action for the control and accounting of SSNM including delaying production, if necessary, and must not be enmeshed in a hierarchical framework that could inhibit or compromise independent action.
The assignment of MC&A functions in the licensee organization provides a separation of functions so that the activities of one individual or organizational unit serve as controls over and checks of the activities of other individuals or organizational units.
The assignment of MC&A functions in the licensee organization provides a separation of functions so that the activities of one individual or organizational unit serve as controls over and checks of the activities of other individuals or organizational units.
The critical MC&A runctions are documented in written procedures.                                         '
The critical MC&A runctions are documented in written procedures.
The procedures and any revision thereto are reviewed and approved by appropriate management personnel prior to implementation.
The procedures and any revision thereto are reviewed and approved by appropriate management personnel prior to implementation.
The individual with overall responsibility for the MC&A system will approve all procedures generated in the MC&A organization and be cognizant of all other procedures affecting MC&A.
The individual with overall responsibility for the MC&A system will approve all procedures generated in the MC&A organization and be cognizant of all other procedures affecting MC&A.
Critical MC&A procedures should, as a minimum, address the establishment of basic MC&A system policies, detection of the loss of a goal quantity, performance of the physical inventory, determination of inventory and shipper-receiver differences, establishment of measurement control policies, and determination                                           -
Critical MC&A procedures should, as a minimum, address the establishment of basic MC&A system policies, detection of the loss of a goal quantity, performance of the physical inventory, determination of inventory and shipper-receiver differences, establishment of measurement control policies, and determination of measurement and non-measurement errors critical to MC&A.
of measurement and non-measurement errors critical to MC&A.
42
42


o  The' responsibilities and authorities for each position assigned an           i SSNM control and accounting function are clearly defined in position descriptions that are accessible to all affected personnel and to the i             NRC upon request.
The' responsibilities and authorities for each position assigned an i
o   The individuals responsible for each MC&A function have sufficient authority to perform the function in the prescribed manner.
o SSNM control and accounting function are clearly defined in position descriptions that are accessible to all affected personnel and to the i
o   The overall management responsibility for the MC&A system is at a level at least comparable to the organization having responsibility           ;
NRC upon request.
,            for production or storage of SSNM, or a direct line of communication is provided to management level which has the authority to implement measures essential to effective MC&A.
o The individuals responsible for each MC&A function have sufficient authority to perform the function in the prescribed manner.
o    The individuals who generate source data, such as those performing measurements, preparing transfer forms, or preparing analytical reports do not perform any accounting or record control functions unless cross checks of the work are performed to prevent falsification.
o The overall management responsibility for the MC&A system is at a level at least comparable to the organization having responsibility for production or storage of SSNM, or a direct line of communication is provided to management level which has the authority to implement measures essential to effective MC&A.
Examples of appropriate checks and balances are:                             '
The individuals who generate source data, such as those performing o
1 Review of measurement data and calculations by another individual,     '
measurements, preparing transfer forms, or preparing analytical reports do not perform any accounting or record control functions unless cross checks of the work are performed to prevent falsification.
I Maintenance of a duplicate copy of all source data and transfer forms under controls separate from the accounting function, Performance of independent audits, and Separation of computer program maintenance from the program user function.
Examples of appropriate checks and balances are:
i       o   No individual has the sole authority to recheck, evaluate, or audit information for which that individual is responsible.
1 Review of measurement data and calculations by another individual, I
o No individual may have responsibility and control of both an MC&A and physical protection function unless independent crosschecks are in
Maintenance of a duplicate copy of all source data and transfer forms under controls separate from the accounting function, Performance of independent audits, and Separation of computer program maintenance from the program user function.
!          place to preclude defeat of the overall safeguards system. As a l           minimum the crosscheck must include countersigning by one other i           person of any SSNM transfer within an MAA and countersigning by two individuals for SSNM transfers out of an MAA.
i o
I o The management structure provides for assignment of a responsibility for SSNM undergoing processing and in storage to a single individual or group. The duties of the individual (s) include but are not limited to:
No individual has the sole authority to recheck, evaluate, or audit information for which that individual is responsible.
o No individual may have responsibility and control of both an MC&A and physical protection function unless independent crosschecks are in place to preclude defeat of the overall safeguards system. As a l
minimum the crosscheck must include countersigning by one other i
person of any SSNM transfer within an MAA and countersigning by two individuals for SSNM transfers out of an MAA.
I o
The management structure provides for assignment of a responsibility for SSNM undergoing processing and in storage to a single individual or group.
The duties of the individual (s) include but are not limited to:
l
l
[
[
Line 1,371: Line 2,041:
l 43
l 43


t Maintaining appropriate local MC&A records or assuring that other records, such as production records, contain necessary MC&A information; Participating in physical inventories as required; Assisting in internal or external alarm resolution activities as required; Assuring that, when SSNM is processed in bulk form, only authorized persons have hands-on access to the material; and     -
t Maintaining appropriate local MC&A records or assuring that other records, such as production records, contain necessary MC&A information; Participating in physical inventories as required; Assisting in internal or external alarm resolution activities as required; Assuring that, when SSNM is processed in bulk form, only authorized persons have hands-on access to the material; and Notifying proper authorities of irregularities in material and MC&A data handling.
Notifying proper authorities of irregularities in material and MC&A data handling.
Questions and Answers 1.
Questions and Answers
Q.
: 1. Q.       At what level of understanding should MC&A procedures be written?
At what level of understanding should MC&A procedures be written?
A.       Procedures such as those used in MC&A should be written so that any person performing the work should be able to understand the content and meaning of the actions to be taken, the warning statements, and all other messages. Generally, a twelfth grade level of vocabulary should be used in writing procedures. This restriction does not apply to the technical terminology included in the procedures, although these terms must then be included in any specific training that involved personnel are required to take.
A.
: 2. Q.       What is a systematic task analysis, and how will it help to define the content of procedures?
Procedures such as those used in MC&A should be written so that any person performing the work should be able to understand the content and meaning of the actions to be taken, the warning statements, and all other messages.
A.       A task analysis breaks down and evaluates in a systematic manner a human function in terms of the abilities, skills, knowledge, and attitudes required for performance of the function. These analyses may be performed to differing degrees of depth, depending on the information requirement and its specific application.
Generally, a twelfth grade level of vocabulary should be used in writing procedures.
This restriction does not apply to the technical terminology included in the procedures, although these terms must then be included in any specific training that involved personnel are required to take.
2.
Q.
What is a systematic task analysis, and how will it help to define the content of procedures?
A.
A task analysis breaks down and evaluates in a systematic manner a human function in terms of the abilities, skills, knowledge, and attitudes required for performance of the function.
These analyses may be performed to differing degrees of depth, depending on the information requirement and its specific application.
A task analysis will assist the procedure developer by systematically outlining the steps to be performed to complete a task, the personnel needed to complete each step, and the requirements of each person.
A task analysis will assist the procedure developer by systematically outlining the steps to be performed to complete a task, the personnel needed to complete each step, and the requirements of each person.
Procedures usually do not require an in-depth task analysis, but consideration of the needs of personnel will usually make procedures better.
Procedures usually do not require an in-depth task analysis, but consideration of the needs of personnel will usually make procedures better.
: 3. Q.     Why should procedures be reviewed and verified before being accepted for regular usuage?
3.
A.       Procedures that contain inaccurate or incomplete information are misleading and can be detrimental to MC&A information error rates.
Q.
Why should procedures be reviewed and verified before being accepted for regular usuage?
A.
Procedures that contain inaccurate or incomplete information are misleading and can be detrimental to MC&A information error rates.
Review by personnel who have previously performed similar tasks or are familiar with the process to be performed will frequently discover omissions of required information, misleading information, or mistakes.
Review by personnel who have previously performed similar tasks or are familiar with the process to be performed will frequently discover omissions of required information, misleading information, or mistakes.
44
44


Verification of the procedures involves field testing by the personnel who will be using the procedures to determine problems not found during the review phase.
Verification of the procedures involves field testing by the personnel who will be using the procedures to determine problems not found during the review phase.
4.2 Personnel Qualification and Training Requirement:   The rule requires that each licensee ensure that key per-sonnel, who work in positions involving tasks where mistakes could directly degrade the safeguards ~ capabilities of the MC&A system, are trained to maintain a high level of safeguards awareness and are qualified to perform their jobs (74.59(c)).
4.2 Personnel Qualification and Training Requirement:
Intent and Scope:   The intent of this section is to ensure that the effectiveness of the MC&A system is maintained by the qualification and training of key personnel. A training and qualification program can help ensure that these individuals are adequately prepared to perform their functions correctly with a minimum of errors. The program should be structured to define job requirements, to establish minimum qualifications for candidatas, to train and qualify the candidates, and to define requalification criteria.
The rule requires that each licensee ensure that key per-sonnel, who work in positions involving tasks where mistakes could directly degrade the safeguards ~ capabilities of the MC&A system, are trained to maintain a high level of safeguards awareness and are qualified to perform their jobs (74.59(c)).
Plan / Annex Content:   The FNMC Plan contains the following affirmations and detailed commitments.     Supporting information, as appropriate, is included in the Annex.
Intent and Scope:
The intent of this section is to ensure that the effectiveness of the MC&A system is maintained by the qualification and training of key personnel.
A training and qualification program can help ensure that these individuals are adequately prepared to perform their functions correctly with a minimum of errors.
The program should be structured to define job requirements, to establish minimum qualifications for candidatas, to train and qualify the candidates, and to define requalification criteria.
Plan / Annex Content:
The FNMC Plan contains the following affirmations and detailed commitments.
Supporting information, as appropriate, is included in the Annex.
Section 4.2 of the Plan includes the following affirmations:
Section 4.2 of the Plan includes the following affirmations:
o     The duties, responsibilities, essential functions, and qualifications of key MC&A positions, i.e., those involving tasks where mistakes could directly degrade the safeguards capabilities of the MC&A system, are defined in written job descriptions.
o The duties, responsibilities, essential functions, and qualifications of key MC&A positions, i.e., those involving tasks where mistakes could directly degrade the safeguards capabilities of the MC&A system, are defined in written job descriptions.
o    The individuals designated for key positions do not assume the posi-tions until they have demonstrated their competence through tests that will determine whether or not the individual satisfies the pre-established qualification criteria for the positions.
The individuals designated for key positions do not assume the posi-o tions until they have demonstrated their competence through tests that will determine whether or not the individual satisfies the pre-established qualification criteria for the positions.
o     A training and qualification program for key MC&A positions and a method of demonstrating continued competency of personnel has been implemented and will be maintained. The program is periodically updated to reflect changes in job requirements.
o A training and qualification program for key MC&A positions and a method of demonstrating continued competency of personnel has been implemented and will be maintained. The program is periodically updated to reflect changes in job requirements.
I l       o     The descriptions of the key job functions, the design of the training and qualification program, and the method of confirming qualifications of personnel are subject to the formal approval of the MC&A manager.
I l
o The descriptions of the key job functions, the design of the training and qualification program, and the method of confirming qualifications of personnel are subject to the formal approval of the MC&A manager.
4.2.1 Training Program Describe the fundamentals of the training program that will be implemented to ensure the competency of key MC&A personnel. The description should identify the training program structure, source of instructional material, and general training objectives.
4.2.1 Training Program Describe the fundamentals of the training program that will be implemented to ensure the competency of key MC&A personnel. The description should identify the training program structure, source of instructional material, and general training objectives.
In the Annex, provide an example of a typical training program for one typical position and a tabulation of the key MC&A positions.
In the Annex, provide an example of a typical training program for one typical position and a tabulation of the key MC&A positions.
Line 1,400: Line 2,087:
4.2.2 Qualification Program Describe the qualification program including generic qualification criteria for the. key MC&A positions and the criteria for assessing the need for requalification.
4.2.2 Qualification Program Describe the qualification program including generic qualification criteria for the. key MC&A positions and the criteria for assessing the need for requalification.
In the Annex, provide an example of the complete qualification criteria for a key MC&A position.
In the Annex, provide an example of the complete qualification criteria for a key MC&A position.
Acceptance Criteria:   The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:
Acceptance Criteria:
o   The list of key positions or functions includes all those for which errors or faulty performance could directly degrade SSNM control and accounting. These include MC&A management positions and individual contributor positions having responsibility for key measurements, data analysis, preparation of accountability source documents, and collecting or recording of other data having a direct impact on loss detection, alarm response, and quality assurance functions.
The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:
o   The qualification criteria for the key positions are consistent with the position descriptions and focus on minimum levels of education and experience, knowledge of the job content and its purposes, types and levels of skills or proficiencies, and understanding of the safeguards role and its importance. The criteria are defined in terms of measurable performance goals whenever possible.
o The list of key positions or functions includes all those for which errors or faulty performance could directly degrade SSNM control and accounting.
o   The training program emphasizes the job purpose and scope; relation-ship to other positions, especially the MC&A positions; the role or significance with respect to MC&A; technical knowledge; understanding of duties, responsibilities and procedures; and skill development.
These include MC&A management positions and individual contributor positions having responsibility for key measurements, data analysis, preparation of accountability source documents, and collecting or recording of other data having a direct impact on loss detection, alarm response, and quality assurance functions.
o   The training plans provide for a reasonable balance of theory and practice, or oral and written instruction versus demonstration and learning-by-doing, the use of on-job training for positions that are primarily operational or clerical, and individualized instruction based on performance goals whenever feasible.
o The qualification criteria for the key positions are consistent with the position descriptions and focus on minimum levels of education and experience, knowledge of the job content and its purposes, types and levels of skills or proficiencies, and understanding of the safeguards role and its importance.
o   Tests for positions requiring measurements, calculations, or recording of data and information will include demonstration of correct and accurate job performance. When operating procedures or manipulative skills are required, the tests will include hands-on demonstrations on competence.
The criteria are defined in terms of measurable performance goals whenever possible.
o   The continuing qualification of key personnel will be verified on an ongoing basis or at least every two years.
o The training program emphasizes the job purpose and scope; relation-ship to other positions, especially the MC&A positions; the role or significance with respect to MC&A; technical knowledge; understanding of duties, responsibilities and procedures; and skill development.
o   The training program provides for training of personnel already l                 experienced and functioning in MC&A positions at the time of Plan implementation when competency tests indicate that additional training is called for. The criterion will be whether or not the individual can function at the level of proficiency called for in the qualifica-tion criteria.
o The training plans provide for a reasonable balance of theory and practice, or oral and written instruction versus demonstration and learning-by-doing, the use of on-job training for positions that are primarily operational or clerical, and individualized instruction based on performance goals whenever feasible.
46 l                                                                 -_
o Tests for positions requiring measurements, calculations, or recording of data and information will include demonstration of correct and accurate job performance. When operating procedures or manipulative skills are required, the tests will include hands-on demonstrations on competence.
o The continuing qualification of key personnel will be verified on an ongoing basis or at least every two years.
o The training program provides for training of personnel already l
experienced and functioning in MC&A positions at the time of Plan implementation when competency tests indicate that additional training is called for.
The criterion will be whether or not the individual can function at the level of proficiency called for in the qualifica-tion criteria.
46 l


_4.3     Measurements Requirement:                       The rule requires that a licensee establish and maintain a system of measurements sufficient to:
_4.3 Measurements Requirement:
(1) Substantiate the plutonium element and uranium element and isotope content of all SSNM received, produced, transferred between areas of custodial responsibility, on inventory, or shipped, discarded, or
The rule requires that a licensee establish and maintain a system of measurements sufficient to:
* otherwise removed from inventory; (2) Provide the necessary data for the performance of the material control tests required by $74.53(b); and (3) Permit an estimation of the standard deviations associated with each measured quantity (74.59(d)).
(1) Substantiate the plutonium element and uranium element and isotope content of all SSNM received, produced, transferred between areas of custodial responsibility, on inventory, or shipped, discarded, or otherwise removed from inventory; (2) Provide the necessary data for the performance of the material control tests required by $74.53(b); and (3) Permit an estimation of the standard deviations associated with each measured quantity (74.59(d)).
Intent and Scope: The intent of these requirements is that all SSNM values                                             ?
Intent and Scope:
The intent of these requirements is that all SSNM values
?
used for MC&A purposes be based on measurements and the uncertainties associated with the measured values be quantifiable.
used for MC&A purposes be based on measurements and the uncertainties associated with the measured values be quantifiable.
Plan / Annex Content:                         The FNMC Plan contains the following affirmations and detailed commitments.                               Supporting information, as appropriate is included 1
Plan / Annex Content:
The FNMC Plan contains the following affirmations and detailed commitments.
Supporting information, as appropriate is included 1
in the Annex.
in the Annex.
                                                                                                                                                    }
}
Section 4.3 of the Plan includes the following affirmations:
Section 4.3 of the Plan includes the following affirmations:
o     Measurement systems are in place to substantiate the element and isotope content, as appropriate, of all SSNM received, produced, transferred between areas of custodial responsibility, on inventory, or shipped, discarded, or otherwise removed from inventory.
o Measurement systems are in place to substantiate the element and isotope content, as appropriate, of all SSNM received, produced, transferred between areas of custodial responsibility, on inventory, or shipped, discarded, or otherwise removed from inventory.
o     SSNM quantities transferred into and out of each unit process are based on measurements for mass, volume, element, and isotope, as necessary, to accommodate material loss detection tests.
o SSNM quantities transferred into and out of each unit process are based on measurements for mass, volume, element, and isotope, as necessary, to accommodate material loss detection tests.
o     Factors employed in process models are based on measurements and are updated at least annually.
o Factors employed in process models are based on measurements and are updated at least annually.
4.3.1 Measurement Points Identify each point in the process where measurements are made for special nuclear material control and accounting purposes. References to process flow diagrams included in the Annex are acceptable.
4.3.1 Measurement Points Identify each point in the process where measurements are made for special nuclear material control and accounting purposes.
References to process flow diagrams included in the Annex are acceptable.
4.3.2 Materials and Measurements Characterize the materials and measurements for each measurement point.
4.3.2 Materials and Measurements Characterize the materials and measurements for each measurement point.
One suitable means of presentation would be a coded chart showing the types of materials and the components of measurement involved at each measurement point (i.e. weight, volume, sampling, analytical assay, or nondestructive assay).
One suitable means of presentation would be a coded chart showing the types of materials and the components of measurement involved at each measurement point (i.e. weight, volume, sampling, analytical assay, or nondestructive assay).
47
47
_ _ . _ . . . .  .    .                                                                                                  _ .M__.._.__   _m._
.M__.._.__
_m._


In the Annex provide a detailed description of the measurement systems that will be employed for MC&A purposes. The description should include:
In the Annex provide a detailed description of the measurement systems that will be employed for MC&A purposes.
The description should include:
General characteristics (equipment, range of application'and sensitivity);
General characteristics (equipment, range of application'and sensitivity);
Method description, and Estimated measurement uncertainties (random and fixed).
Method description, and Estimated measurement uncertainties (random and fixed).
Acceptance Criteria.                             The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:
Acceptance Criteria.
o           All measurements points have been identified and as a minimum include the following:
The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:
o All measurements points have been identified and as a minimum include the following:
Facility receipts; Transfers oetween areas of custodial responsibility; Points where SSNM is produced; Unit process boundaries; Facility shipments including product, scrap, and waste; Effluent discharge points; and Significant sidestreams.
Facility receipts; Transfers oetween areas of custodial responsibility; Points where SSNM is produced; Unit process boundaries; Facility shipments including product, scrap, and waste; Effluent discharge points; and Significant sidestreams.
o           The material types to be measured at each measurement point and the measurement system involved are described in the Plan. A " measurement system" should include:
o The material types to be measured at each measurement point and the measurement system involved are described in the Plan.
A " measurement system" should include:
Sampling method (if appropriate),
Sampling method (if appropriate),
Mass or volume (if appropriate),
Mass or volume (if appropriate),
Line 1,440: Line 2,141:
The descriptions of the components of each measurement system reflected in the Annex should include:
The descriptions of the components of each measurement system reflected in the Annex should include:
Equipment, Synopsis of technique, Range of application, 48
Equipment, Synopsis of technique, Range of application, 48
          --~ry.-.------,,,,-,p                 -.,r,--ww       - - . . . -  , . , - . - , , . . _ , , - , . . , . _w-,,.-----,-,     .,..- - _ - - . _ , . - - - , , , , - - - - - - . . - , - - - - - - -
--~ry.-.------,,,,-,p
-.,r,--ww
_w-,,.-----,-,


O Sensitivity, Precautions, and Random / fixed error estimates.
O Sensitivity, Precautions, and Random / fixed error estimates.
o    The use of. factors is limited to those situations where timely mea-surements are impractical. A commitment should be included to the effect that factors will be based on measurements, monitored, and updated when appropriate statistical tests indicate the need for updating.
The use of. factors is limited to those situations where timely mea-o surements are impractical.
A commitment should be included to the effect that factors will be based on measurements, monitored, and updated when appropriate statistical tests indicate the need for updating.
In the Annex, the licensee should provide the justification for employing factors in lieu of measurements.
In the Annex, the licensee should provide the justification for employing factors in lieu of measurements.
o    Appropriate measurements for material control tests will depend upon the following considerations:
Appropriate measurements for material control tests will depend upon o
Availability of substitute materials, Predictability of material composition, and Material accessibility                                             '
the following considerations:
These considerations influence whether a test as simple as a weight compar-ison will suffice as a means of loss detection or a measurement for element and perhaps isotope is necessary.
Availability of substitute materials, Predictability of material composition, and Material accessibility These considerations influence whether a test as simple as a weight compar-ison will suffice as a means of loss detection or a measurement for element and perhaps isotope is necessary.
4.4 Measurement Control Requirements: The rule requires that a licensee assure that the quality of SSNM measurement systems and material processing practices is continually con-trolled to a level of effectiveness sufficient to satisfy the capabilities required for detection, response, and accounting.     To achieve this objective the license should:
4.4 Measurement Control Requirements: The rule requires that a licensee assure that the quality of SSNM measurement systems and material processing practices is continually con-trolled to a level of effectiveness sufficient to satisfy the capabilities required for detection, response, and accounting.
l       (1) Perform engineering analyses and evaluations of the design installa-tion, preoperational tests, calibration and operation of all measure-ment systems to be used for MC&A purposes.
To achieve this objective the license should:
l (1) Perform engineering analyses and evaluations of the design installa-tion, preoperational tests, calibration and operation of all measure-ment systems to be used for MC&A purposes.
(2) Perform process and engineering tests using well characterized materials to establish or to verify the applicability of existing procedures for mixing and sampling SSNM and maintaining sample integrity during transport and storage.
(2) Perform process and engineering tests using well characterized materials to establish or to verify the applicability of existing procedures for mixing and sampling SSNM and maintaining sample integrity during transport and storage.
(3) Generate current data on the performance of measurement processes, including, as appropriate, values for bias corrections, uncertainties on calibration factors, and random error standard deviations. The program shall include:
(3) Generate current data on the performance of measurement processes, including, as appropriate, values for bias corrections, uncertainties on calibration factors, and random error standard deviations.
(i) The ongoing use of standards for calibration and control of all applicable measurement systems. Calibrations shall be repeated whenever any significant change occurs in a measurement system 49
The program shall include:
(i) The ongoing use of standards for calibration and control of all applicable measurement systems.
Calibrations shall be repeated whenever any significant change occurs in a measurement system 49


l o
o or when program data, generated by tests performed at a predeter-mined frequency, indicate a need for recalibration. Calibrations and tests shall be based on standards with traceability to I
or when program data, generated by tests performed at a predeter-mined frequency, indicate a need for recalibration. Calibrations and tests shall be based on standards with traceability to a national standard or nationally accepted measurement system.             I (ii) A system of control measurements to provide current data for the determination of random errors that are significant contributors to the measurement uncertainties associated with shipper / receiver differences, inventory differences, and process. differences.
a national standard or nationally accepted measurement system.
(4) Utilize the data generated during the current material balance period for the estimation of the standard error of the inventory difference (SEID) and the standard deviations associated with the process differences. Measurement error data collected and used during imme-diately preceding material balance periods may be combined with cur-rent data provided that the measurement systems are in statistical control, and the data are utilized in the determination of current period SSNM values.
(ii) A system of control measurements to provide current data for the determination of random errors that are significant contributors to the measurement uncertainties associated with shipper / receiver differences, inventory differences, and process. differences.
(4) Utilize the data generated during the current material balance period for the estimation of the standard error of the inventory difference (SEID) and the standard deviations associated with the process differences.
Measurement error data collected and used during imme-diately preceding material balance periods may be combined with cur-rent data provided that the measurement systems are in statistical control, and the data are utilized in the determination of current period SSNM values.
(5) Evaluate all program data and information to assure that measurement performance is so controlled that the SEID estimator is less than 0.1 percent of active inventory for SSNM processing facilities.
(5) Evaluate all program data and information to assure that measurement performance is so controlled that the SEID estimator is less than 0.1 percent of active inventory for SSNM processing facilities.
(6) Apply bias corrections by an appropriate procedure whereby:
(6) Apply bias corrections by an appropriate procedure whereby:
(i) Bias corrections are applied to individual items whenever the bias estimate exceeds both twice the estimated standard devia-tion of the estimator, 50 grams of SSNM, and the rounding error of affected items.
(i) Bias corrections are applied to individual items whenever the bias estimate exceeds both twice the estimated standard devia-tion of the estimator, 50 grams of SSNM, and the rounding error of affected items.
(ii) The impact of all biases that are not applied as corrections to individual items, are applied as a correction to the inventory difference.
(ii) The impact of all biases that are not applied as corrections to individual items, are applied as a correction to the inventory difference.
l               (iii)   If, for like-material types, shipper / receiver differences accum-ulated over six month period exceed the larger of one FKG or 0.1 percent of the total amount received, then the licensee will investigate and take corrective action, as appropriate, to identify and reduce associated measurement biases.
l (iii)
(7) Establish and maintain a statistical control system designed to monitor the quality of each type of program measurement.       Control limits shall be established to be equivalent to levels of signif-icance of 0.05 and 0.001. Control data exceeding the 0.05 limits shall be investigated and corrective action taken in a timely manner.
If, for like-material types, shipper / receiver differences accum-ulated over six month period exceed the larger of one FKG or 0.1 percent of the total amount received, then the licensee will investigate and take corrective action, as appropriate, to identify and reduce associated measurement biases.
(7) Establish and maintain a statistical control system designed to monitor the quality of each type of program measurement.
Control limits shall be established to be equivalent to levels of signif-icance of 0.05 and 0.001.
Control data exceeding the 0.05 limits shall be investigated and corrective action taken in a timely manner.
Whenever data exceed the 0.001 control limit, the measurement system shall not be used for MC&A purposes until it has been brought into control at the 0.05 level.
Whenever data exceed the 0.001 control limit, the measurement system shall not be used for MC&A purposes until it has been brought into control at the 0.05 level.
Intent and Scope:       The intent of these requirements is that the licensee continually control the quality of measurement systems employed for MC&A to a l     level sufficient to satisfy the capabilities required for loss detection, l     response and accounting.         The goals of the quality control program for SSNM 50 l
Intent and Scope:
The intent of these requirements is that the licensee continually control the quality of measurement systems employed for MC&A to a l
level sufficient to satisfy the capabilities required for loss detection, l
response and accounting.
The goals of the quality control program for SSNM 50 l


                                                                                  ^
^
s l
s measurements are to maintain the SEID within the limits specified in
measurements are to maintain the SEID within the limits specified in
$74.59(e)(5) and minimize the measurement error contribution to the standard deviations associated with the material control tests required by 974.53(b).
              $74.59(e)(5) and minimize the measurement error contribution to the standard deviations associated with the material control tests required by 974.53(b).                                                               1 Plan / Annex Content:               The FNMC Plan contains the following affirmations                                         !
1 Plan / Annex Content:
and detailed commitments.                       Supporting information, as appropriate, is included                                       !
The FNMC Plan contains the following affirmations and detailed commitments.
in the Annex.
Supporting information, as appropriate, is included in the Annex.
Section 4.4 of the Plan includes the following affirmations:
Section 4.4 of the Plan includes the following affirmations:
o          Engineering analyses and evaluations are performed on the design,                                                   '
Engineering analyses and evaluations are performed on the design, o
installation, preoperational testing, calibration, and operation of all measurements systems to be used for MC&A purposes.
installation, preoperational testing, calibration, and operation of all measurements systems to be used for MC&A purposes.
o          Process and engineering tests are performed, using well characterized materials, to verify the applicability of mixing and sampling proce-dures,for SSNM and assure sample validity during transport and storage.
Process and engineering tests are performed, using well characterized o
o         Current data is generated during the inventory period for establish-ing bias correction values, uncertainties on calibration factors and random error variances.
materials, to verify the applicability of mixing and sampling proce-dures,for SSNM and assure sample validity during transport and storage.
o         Current inventory period data is utilized for the estimation of the SEID and the standard deviations associated with the process differences. Data generated in immediately preceding material balance periods may be combined with current data when it can be demonstrated that the data is from the same distribution, and the combined data are utilized to establish current period SSNM values, o         Measurement system performance is controlled such that the total SEID will not exceed 0.1 percent of the active inventory.
o Current data is generated during the inventory period for establish-ing bias correction values, uncertainties on calibration factors and random error variances.
,                      o         Bias corrections are applied to individual items whenever a bias estimate exceeds twice the estimated standard deviation of the esti-mator, 50 grams of SSNM, and the rounding error of affected items.
o Current inventory period data is utilized for the estimation of the SEID and the standard deviations associated with the process differences.
Otherwise the impact of uncorrected biases is applied as a correction the inventory difference.           Uncorrected biases are not entered in the accounting records.
Data generated in immediately preceding material balance periods may be combined with current data when it can be demonstrated that the data is from the same distribution, and the combined data are utilized to establish current period SSNM values, o
o           A statistical control system is maintained to ensure that measurements 1                                employed for MC&A purposes are obtained from measurement systems that are in a state of statistical control. Control limits are established l                                 at the 0.05 and 0.001 levels of significance.
Measurement system performance is controlled such that the total SEID will not exceed 0.1 percent of the active inventory.
l o           Bias corrections associated with material control tests are either applied prior to assessing the significance of the test results or are available for resolution.
o Bias corrections are applied to individual items whenever a bias estimate exceeds twice the estimated standard deviation of the esti-mator, 50 grams of SSNM, and the rounding error of affected items.
o           When a statistically significant change occurs in the estimated standard deviation of a material control test statistic, the alarm
Otherwise the impact of uncorrected biases is applied as a correction the inventory difference.
'                                  threshold of the test is adjusted as necessary to ensure that a goal quantity loss of SSNM will be detected with a probability at least as high as that required in the regulations (S 74.53(b)(2)). Additionally 4
Uncorrected biases are not entered in the accounting records.
51
o A statistical control system is maintained to ensure that measurements employed for MC&A purposes are obtained from measurement systems that 1
are in a state of statistical control.
Control limits are established l
at the 0.05 and 0.001 levels of significance.
l o
Bias corrections associated with material control tests are either applied prior to assessing the significance of the test results or are available for resolution.
o When a statistically significant change occurs in the estimated standard deviation of a material control test statistic, the alarm threshold of the test is adjusted as necessary to ensure that a goal quantity loss of SSNM will be detected with a probability at least as high as that required in the regulations (S 74.53(b)(2)).
Additionally 51 4
(
(
f
f


the change will be investigated to an extent sufficient to determine the cause, o   When a process modification occurs, sufficient data are generated to provide a reliable estimate of the standard deviation applicable to the material control test.
the change will be investigated to an extent sufficient to determine the cause, o
o   The magnitude of the uncertainties associated with process variabil-ities is determined and applied in the overall uncertainty (standard deviation) utilized in establishing alarm thresholds.
When a process modification occurs, sufficient data are generated to provide a reliable estimate of the standard deviation applicable to the material control test.
o   The cumulative shipper-receiver differences for each like material type are routinely monitored, and when they are determined to be statistically significant and exceed the larger of one FKG or 0.1 percent of the quantity shipped, corrective action is taken to identify and correct measurement biases, o   Contractors who perform MC&A measurement services will implement and maintain a control program for measurement errors and for human errors. The program will be of such depth and intensity as not to degrade the MC&A system.
o The magnitude of the uncertainties associated with process variabil-ities is determined and applied in the overall uncertainty (standard deviation) utilized in establishing alarm thresholds.
o   The estimated standard deviations of the material control test statistics are maintained at or below a level sufficient to achieve the loss detection capabilities established pursuant to S 74.53(b) without incurring an excessive rate of false alarms.
o The cumulative shipper-receiver differences for each like material type are routinely monitored, and when they are determined to be statistically significant and exceed the larger of one FKG or 0.1 percent of the quantity shipped, corrective action is taken to identify and correct measurement biases, o
o  Sufficient standards measurements and replicate analyses of process materials are performed to permit a determination of the standard deviation associated with each measured quantity.
Contractors who perform MC&A measurement services will implement and maintain a control program for measurement errors and for human errors.
The program will be of such depth and intensity as not to degrade the MC&A system.
o The estimated standard deviations of the material control test statistics are maintained at or below a level sufficient to achieve the loss detection capabilities established pursuant to S 74.53(b) without incurring an excessive rate of false alarms.
Sufficient standards measurements and replicate analyses of process o
materials are performed to permit a determination of the standard deviation associated with each measured quantity.
4.4.1 Measurement Control for Detection / Response Measurements Oc;cribc t.b.c measurement control program applicable to those measurement systems utilized for detection and response.
4.4.1 Measurement Control for Detection / Response Measurements Oc;cribc t.b.c measurement control program applicable to those measurement systems utilized for detection and response.
                                                ~
The descriptien should include:
The descriptien should include:
~
l The general types of standards that will be utilized; j
l The general types of standards that will be utilized; j
The procedure for certifying the values assigned to the standards; The minimum number and analysis frequency or schedule of standard and process material measurements that will be used to establish the l                 magnitude of biases, calibration and control measurement errors, and i                 variances of random errors; 1
The procedure for certifying the values assigned to the standards; The minimum number and analysis frequency or schedule of standard and process material measurements that will be used to establish the l
magnitude of biases, calibration and control measurement errors, and i
variances of random errors; 1
l The means of monitoring the magnitude of biases and variances; The criteria for determining the need for recalibration; The means of establishing mixing and sampling errors; The tests and criteria for judging the acceptability of data pooling; 52
l The means of monitoring the magnitude of biases and variances; The criteria for determining the need for recalibration; The means of establishing mixing and sampling errors; The tests and criteria for judging the acceptability of data pooling; 52
_ _ _  _              _ ~   -      -      -    - - - -
~


                  .        _        ._.        _    -. -      _ _ _ .              ~. _
~.
                                                                                              +-
+-
The measures to ensure that bias estimates and variances reflect the actual operating conditions and process materials; The tests that will be employed to identify outliers; and The tests for assessing the significance of bias estimates.
The measures to ensure that bias estimates and variances reflect the actual operating conditions and process materials; The tests that will be employed to identify outliers; and The tests for assessing the significance of bias estimates.
In the Annex provide:
In the Annex provide:
4 A listing of the standards to be used with each measurement system and, for in-house standards, how they will be prepared;
4 A listing of the standards to be used with each measurement system and, for in-house standards, how they will be prepared;
                      'A brief description of how assigned values of standards are determined; A brief description of the calibration procedures for each measurement system; and A listing of expected or estimated variances associated with each measurement system.
'A brief description of how assigned values of standards are determined; A brief description of the calibration procedures for each measurement system; and A listing of expected or estimated variances associated with each measurement system.
4.4.2 Measurement Control for Inventory and Shipper-Receiver Measurements Describe the measurement control program applicable to those measurement systems utilized for inventory and shipper-receiver purposes.         (Note: References
4.4.2 Measurement Control for Inventory and Shipper-Receiver Measurements Describe the measurement control program applicable to those measurement systems utilized for inventory and shipper-receiver purposes.
, may be made to Section 4.4.1, as appropriate.)
(Note:
4.4.3 Standard Error of the Inventory Difference Estimator Provide an explanation of~the statistical basis for determining the SEID estimator. The description should include the means of monitoring the overall measurement system uncertainties to ensure that the SEID does not exceed the 4
References may be made to Section 4.4.1, as appropriate.)
applicable limit defined in S 74.59(e)(5).
4.4.3 Standard Error of the Inventory Difference Estimator Provide an explanation of~the statistical basis for determining the SEID estimator.
1 In the Annex, provide the statistical model and equations or literature reference with an example calculation of a typical material balance.
The description should include the means of monitoring the overall measurement system uncertainties to ensure that the SEID does not exceed the applicable limit defined in S 74.59(e)(5).
4.4.4     Cumulative Shipper-Receiver Differences Describe the program for monitoring cumulative shipper-receiver differences (CUMSRD).       The description should include:
4 1
In the Annex, provide the statistical model and equations or literature reference with an example calculation of a typical material balance.
4.4.4 Cumulative Shipper-Receiver Differences Describe the program for monitoring cumulative shipper-receiver differences (CUMSRD).
The description should include:
The means of determining the uncertainty against which the significance of the difference will be assessed; and The course of action with respect to review of measurement systems, shipper notification, and treatment with respect to impact on ID (i.e., how the is. pact of the CUMSRD will be accounted for in the evaluation of ID significance).
The means of determining the uncertainty against which the significance of the difference will be assessed; and The course of action with respect to review of measurement systems, shipper notification, and treatment with respect to impact on ID (i.e., how the is. pact of the CUMSRD will be accounted for in the evaluation of ID significance).
Acceptance Criteria; The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:
Acceptance Criteria; The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:
53
53


L- :g
L-
: o. Proposed mixing and sampling studies appear to be adequate for assessing the capabilities of a sampling technique to produce representative samples. Considerations applicable to sampling techniques are:
:g o.
4 Sample size should be a function of material homogeneity, number of containers sampled (if compositing), physical form of the material, and the particular sampling device used.
Proposed mixing and sampling studies appear to be adequate for assessing the capabilities of a sampling technique to produce representative samples.
Considerations applicable to sampling techniques are:
Sample size should be a function of material homogeneity, number 4
of containers sampled (if compositing), physical form of the material, and the particular sampling device used.
Sampling of solutions containing solids should be avoided whenever possible unless it can be shown that representative sampling is possible or the solids have no SSNM content and do not contribute any significant error to the bulk volume or bulk weight measurement.
Sampling of solutions containing solids should be avoided whenever possible unless it can be shown that representative sampling is possible or the solids have no SSNM content and do not contribute any significant error to the bulk volume or bulk weight measurement.
Subsampling requirements should also be addressed in the sampling evaluations.
Subsampling requirements should also be addressed in the sampling evaluations.
Grab sampling should generally be avoided unless it can be shown that the involved materials are sufficiently homogeneous and stable.
Grab sampling should generally be avoided unless it can be shown that the involved materials are sufficiently homogeneous and stable.
Sample integrity during storage can be demonstrated by a comparison of measurement results taken immediately with results on the same samples following an extended period of storage.
Sample integrity during storage can be demonstrated by a comparison of measurement results taken immediately with results on the same samples following an extended period of storage.
o   Calibration and control standards have assigned or certified values that are traceable through an unbroken chain of comparisons, including the overall uncertainty in each, to a national standard or physical constant.
o Calibration and control standards have assigned or certified values that are traceable through an unbroken chain of comparisons, including the overall uncertainty in each, to a national standard or physical constant.
o Control standards should be representative of the material being measured with respect to matrix and SSNM concentration unless it can
o Control standards should be representative of the material being measured with respect to matrix and SSNM concentration unless it can be demonstrated that the non representative aspects have a negligible impact in that measurement results are unbiased.
!                                                              be demonstrated that the non representative aspects have a negligible impact in that measurement results are unbiased.
o Control measures that will ensure or confirm the continuing validity j
o Control measures that will ensure or confirm the continuing validity j                                                             of standards' assigned values are indicated.                               Examples of the types 3                                                              of controls that would be appropriate are:
of standards' assigned values are indicated.
Storage of metal standard weights in a non-corrosive atmosphere; Tamper-safing of NDA standards immediately after makeup; Storage of solution standards in more than one container when usage will be over an extended time period (e.g. > one month);
Examples of the types of controls that would be appropriate are:
l Storage of standards with an affinity for moisture in a l                                                                     desiccator; and Remeasurement of the standard to confirm that its value has not changed.
3 Storage of metal standard weights in a non-corrosive atmosphere; Tamper-safing of NDA standards immediately after makeup; Storage of solution standards in more than one container when usage will be over an extended time period (e.g. > one month);
l Storage of standards with an affinity for moisture in a l
desiccator; and Remeasurement of the standard to confirm that its value has not changed.
l 1
l 1
!                                                                                                                      54 1
54 1
1
1


0 i
0 i
o         The estimated standard deviations of the material control test statistics are derived from the monitoring program data that are collected in such a manner that they represent the current performance of the process and measurement systems.                                   Values obtained when the process is operating in an abnormal manner or when a significant process upset or anomaly has occurred will not be included in the data used to estimate the standard deviation. However, data are discarded only on the basis of pre-established objective criteria.
o The estimated standard deviations of the material control test statistics are derived from the monitoring program data that are collected in such a manner that they represent the current performance of the process and measurement systems.
Data may not be pooled over periods of time when significant process or measurement system changes have occurred. When data pooling is appropriate, statistical tests will be applied to demonstrate that the means and variances are from the same distribution at the 0.05 level of significance. The data will be tested for randomness (see Jaech, Section 2.9.2) and normality when tests, such as the F-test on variances, are distribution dependent.
Values obtained when the process is operating in an abnormal manner or when a significant process upset or anomaly has occurred will not be included in the data used to estimate the standard deviation.
The quality control program for monitoring detection system effec-tiveness should have as its key goal assurance that the estimates of standard deviations used in establishing action thresholds that comply with the detection probability criteria neither underestimate nor overestimate the true standard deviations of the tests. It is most important to ensure that the estimate of the mean and standard devia-tion for each material control test reflects the actual operating conditions and error sources. Generally, this is done by calculating them from sets of material control test data, but it is very impor-tant to avoid serious inflation of the variability of the data that would result in the event of actual losses of SSNM or out-of-control process variables. Therefore, both the measurement component and the overall standard deviation should be monitored for diagnostic purposes.
However, data are discarded only on the basis of pre-established objective criteria.
Failure to consider all sources of noncorrectable variation, including normal process variations, would result in an unrealistically small estimate. Use of too small an estimate could result in an action threshold being set too high to provide the required loss detection probability.
Data may not be pooled over periods of time when significant process or measurement system changes have occurred.
o       The standard deviation of each material control test statistic is periodically checked by comparing an estimate of the current standard deviation with the prior value used in setting the alarm threshold.
When data pooling is appropriate, statistical tests will be applied to demonstrate that the means and variances are from the same distribution at the 0.05 level of significance.
The data will be tested for randomness (see Jaech, Section 2.9.2) and normality when tests, such as the F-test on variances, are distribution dependent.
The quality control program for monitoring detection system effec-tiveness should have as its key goal assurance that the estimates of standard deviations used in establishing action thresholds that comply with the detection probability criteria neither underestimate nor overestimate the true standard deviations of the tests.
It is most important to ensure that the estimate of the mean and standard devia-tion for each material control test reflects the actual operating conditions and error sources. Generally, this is done by calculating them from sets of material control test data, but it is very impor-tant to avoid serious inflation of the variability of the data that would result in the event of actual losses of SSNM or out-of-control process variables.
Therefore, both the measurement component and the overall standard deviation should be monitored for diagnostic purposes.
Failure to consider all sources of noncorrectable variation, including normal process variations, would result in an unrealistically small estimate.
Use of too small an estimate could result in an action threshold being set too high to provide the required loss detection probability.
o The standard deviation of each material control test statistic is periodically checked by comparing an estimate of the current standard deviation with the prior value used in setting the alarm threshold.
The estimate of the current standard deviation will be based on at least the 10 most recent values of a test statistic whereas the reference value will be based on at least 20 values.
The estimate of the current standard deviation will be based on at least the 10 most recent values of a test statistic whereas the reference value will be based on at least 20 values.
o        The alarm threshold for a material control test is adjusted when a statistically significant change of the standard deviation is indicated. The change of the standard deviation is considered 4
The alarm threshold for a material control test is adjusted when a o
significant when the null hypothesis for an F test is rejected at the 0.05 level.
statistically significant change of the standard deviation is indicated.
i               o       Calibration procedures are adequate to ensure that the measurement systems will generate reliable results.                                     Considerations in this regard are:
The change of the standard deviation is considered significant when the null hypothesis for an F test is rejected at the 4
0.05 level.
i o
Calibration procedures are adequate to ensure that the measurement systems will generate reliable results.
Considerations in this regard are:
The number of runs to establish the initial calibration are sufficient to establish a reproducible calibration.
The number of runs to establish the initial calibration are sufficient to establish a reproducible calibration.
55 i
55 i
      -r ncr.,,   n,-- n           ,nn,,r.,   -,        .c- , - - - - - - - - - , - - , - - - , . -
-r ncr.,,
n,--
n
,nn,,r.,
.c-


The calibration range spans the anticipated range of process values and the standards are adequately spread over the range.
The calibration range spans the anticipated range of process values and the standards are adequately spread over the range.
For point calibrations utilizing a single calibration standard, the unknowns should be within i 10 percent of the assigned value of the involved standard.
For point calibrations utilizing a single calibration standard, the unknowns should be within i 10 percent of the assigned value of the involved standard.
o Standard measurements are spread out across the material balance period with the expressed objectives of monitoring calibrations for trends or sudden shifts and providing the necessary data for bias estimates.
o Standard measurements are spread out across the material balance period with the expressed objectives of monitoring calibrations for trends or sudden shifts and providing the necessary data for bias estimates.
o Recalibrations are performed when a need is identified.         Recalibrations would be deemed necessary when:
o Recalibrations are performed when a need is identified.
Recalibrations would be deemed necessary when:
A trend, shift, or out-of-control condition at the 0.001 level is detected; A bias estimate exceeds the 95 percent confidence level; A change in process materials occurs that extends the needed range of calibration or renders the calibration / control standards nonrepresentative; or A change or modification is made to a measurement system that has the potential to affect measurement results.
A trend, shift, or out-of-control condition at the 0.001 level is detected; A bias estimate exceeds the 95 percent confidence level; A change in process materials occurs that extends the needed range of calibration or renders the calibration / control standards nonrepresentative; or A change or modification is made to a measurement system that has the potential to affect measurement results.
o All measurement systems affecting a material control test, ID estimate, or shipper-receiver comparison are monitored for bias except as noted below. The intensity of the monitoring program is proportional to the significance of the measurement system for the test involved.
o All measurement systems affecting a material control test, ID estimate, or shipper-receiver comparison are monitored for bias except as noted below.
The intensity of the monitoring program is proportional to the significance of the measurement system for the test involved.
The key measurement systems, i.e., those that contribute greater than 90 percent of the estimated standard deviation due to measurements in the material control test and shipper receiver uncertainties and at least 90 percent of the measurement uncertainty associated with the 10 estimator, are tested for bias at least monthly except where:
The key measurement systems, i.e., those that contribute greater than 90 percent of the estimated standard deviation due to measurements in the material control test and shipper receiver uncertainties and at least 90 percent of the measurement uncertainty associated with the 10 estimator, are tested for bias at least monthly except where:
The measurement system has been demonstrated to be quite stable and the results predictable, The bias estimate of a measurement system utilized solely for material control test affects inputs and outputs equally and therefore the effects of bias cancel, The bias estimate for a measurement system utilized solely for material control test is shown to be constant and does not impact the material control test, or The system is defined as bias-free.
The measurement system has been demonstrated to be quite stable and the results predictable, The bias estimate of a measurement system utilized solely for material control test affects inputs and outputs equally and therefore the effects of bias cancel, The bias estimate for a measurement system utilized solely for material control test is shown to be constant and does not impact the material control test, or The system is defined as bias-free.
Line 1,559: Line 2,313:
56
56


The bias tests will be made using the mean of at least eight standard measurements. Bias corrections will be made to ids if the bias exceeds twice the standard deviation of its estimator, 50 grams of HEU, U-235, U-233, or Pu and the rounding error of affected items.
The bias tests will be made using the mean of at least eight standard measurements.
All other measurement systems shall be monitored for bias and tested every three months except for those measurement systems involved with movement of material across the MAA boundary and no cross-check measurement is performed. Such systems shall also be tested monthly.
Bias corrections will be made to ids if the bias exceeds twice the standard deviation of its estimator, 50 grams of HEU, U-235, U-233, or Pu and the rounding error of affected items.
Measurement systems are considered to be " bias-free" if a standard is run for each unknown or set of unknowns measured at the same time, or standards are measured before or after a group of process samples and the standard measurement response and assigned value, rather than any previous calibration information, are used in determining the value               .'
All other measurement systems shall be monitored for bias and tested every three months except for those measurement systems involved with movement of material across the MAA boundary and no cross-check measurement is performed.
of the unknown (s).
Such systems shall also be tested monthly.
o        The measurement control program produces data that are representative of actual operating conditions and all errors that impact ID. The uncertainty estimates that contribute more than 90 percent to the standard error of the ID estimator will be based on a minimum of 15 standard or replicate process material measurements, as appropriate.
Measurement systems are considered to be " bias-free" if a standard is run for each unknown or set of unknowns measured at the same time, or standards are measured before or after a group of process samples and the standard measurement response and assigned value, rather than any previous calibration information, are used in determining the value of the unknown (s).
o       The licensee has demonstrated that the standard error of the ID estimator meets the requirement of S 74.59(e)(5).
The measurement control program produces data that are representative o
I o       Error variances associated with calibrations will be determined and applied in accordance with the following:
of actual operating conditions and all errors that impact ID.
The uncertainty estimates that contribute more than 90 percent to the standard error of the ID estimator will be based on a minimum of 15 standard or replicate process material measurements, as appropriate.
o The licensee has demonstrated that the standard error of the ID estimator meets the requirement of S 74.59(e)(5).
I o
Error variances associated with calibrations will be determined and applied in accordance with the following:
For point calibrations, where a standard is measured with each unknown, the uncertainty associated with the standard measurement is treated as a random error, while the uncertainty associated with the standard's assigned value is treated as a fixed error.
For point calibrations, where a standard is measured with each unknown, the uncertainty associated with the standard measurement is treated as a random error, while the uncertainty associated with the standard's assigned value is treated as a fixed error.
For point calibrations, where standards are run before and after l'                   a group of process samples and the average measured value of the standards is utilized in the element and/or isotope determination, the uncertainty associated with the standard's average measured value is treated as a fixed error for the group of process samples.
For point calibrations, where standards are run before and after l'
a group of process samples and the average measured value of the standards is utilized in the element and/or isotope determination, the uncertainty associated with the standard's average measured value is treated as a fixed error for the group of process samples.
For line or curve calibrations, the uncertainty associated with the calibration parameters is treated as a fixed error.
For line or curve calibrations, the uncertainty associated with the calibration parameters is treated as a fixed error.
o       Correlation between terms are taken into account in the determination of fixed errors whenever bias corrections are made to calibrations.
o Correlation between terms are taken into account in the determination of fixed errors whenever bias corrections are made to calibrations.
o       Data from intercomparison programs and from intra-laboratory comparisons is not acceptable for determining bias.
o Data from intercomparison programs and from intra-laboratory comparisons is not acceptable for determining bias.
o       CUMSRDs on like kinds of material will be monitored for trends that may be indicative of a bias in the shipper's or receiver's measurements.
o CUMSRDs on like kinds of material will be monitored for trends that may be indicative of a bias in the shipper's or receiver's measurements.
For the purpose of this requirement, "like kinds of material" means 57
For the purpose of this requirement, "like kinds of material" means 57


l major categories having the same chemical and physical form (e.g., UFs.
l major categories having the same chemical and physical form (e.g., UFs.
Pu02 powder, UC coated particles, etc.).
Pu0 powder, UC coated particles, etc.).
The standard deviation applicable to a shipper-receiver difference will take into account all measurement variances and covarience.
2 The standard deviation applicable to a shipper-receiver difference will take into account all measurement variances and covarience.
effects.         The CUMSRD will be tested at the 0.05 significance level.
effects.
The CUMSRD will be tested at the 0.05 significance level.
If a significant difference is determined to exist and it exceeds one percent of the amount received, the licensee will conduct an investi-gation involving the shipper and a referee as appropriate.
If a significant difference is determined to exist and it exceeds one percent of the amount received, the licensee will conduct an investi-gation involving the shipper and a referee as appropriate.
Appropriate statistical methodology for analyzing CUMSRDs can be found in Rose and Scholz (1983).
Appropriate statistical methodology for analyzing CUMSRDs can be found in Rose and Scholz (1983).
o                       The methods of monitoring and controlling measurement performance are adequate to ensure the reliability of the measurement systems used for MC&A purposes. Examples of acceptable methods include control charts and automated data analysis performed on an ongoing basis.
o The methods of monitoring and controlling measurement performance are adequate to ensure the reliability of the measurement systems used for MC&A purposes.
Examples of acceptable methods include control charts and automated data analysis performed on an ongoing basis.
Considerations to be taken into account include:
Considerations to be taken into account include:
The proposed method is capable of providing timely information on the control status of measurement systems including the possible presence of unacceptable trends.
The proposed method is capable of providing timely information on the control status of measurement systems including the possible presence of unacceptable trends.
The control limits are established at the 0.05 and 0.001 levels of significance or are more conservative.
The control limits are established at the 0.05 and 0.001 levels of significance or are more conservative.
Response actions include commitments to (1) collect additional data when a single point exceeds the 0.05 limit, (2) notify the individual responsible for the measurement control program when two consecutive data points fall between the 0.05 and 0.001 limits, (3) initiate an investigation to identify an assignable cause when a data point exceeds the 0.001 out-of-control limit and (4) remove out-of-control measurement systems from service until control is restablished at the 0.05 control limit.
Response actions include commitments to (1) collect additional data when a single point exceeds the 0.05 limit, (2) notify the individual responsible for the measurement control program when two consecutive data points fall between the 0.05 and 0.001 limits, (3) initiate an investigation to identify an assignable cause when a data point exceeds the 0.001 out-of-control limit and (4) remove out-of-control measurement systems from service until control is restablished at the 0.05 control limit.
4.5 Physical Inventory Requirements:                             The rule requires that a licensee should:
4.5 Physical Inventory Requirements:
i                                   (1) Except as required by Part 75 of this Chapter, perform a physical inventory at least every six calendar months and within 45 days from the start of the ending inventory:
The rule requires that a licensee should:
Calculate the inventory difference, estimate the standard error of the inventory difference and investigate and report any dif-
i (1) Except as required by Part 75 of this Chapter, perform a physical inventory at least every six calendar months and within 45 days from the start of the ending inventory:
;                                                                        ference that exceeds three times the standard error and 200 grams                                             ,
Calculate the inventory difference, estimate the standard error of the inventory difference and investigate and report any dif-ference that exceeds three times the standard error and 200 grams of plutonium or uranium-233 or 300 grams of uranium-235, and If required to perform an investigation pursuant to paragraph (i) of this section, evaluate the significance of the inventory dif-ference relative to expected performance as determined from an analysis of an appropriate sequence of historical inventory differences.
of plutonium or uranium-233 or 300 grams of uranium-235, and If required to perform an investigation pursuant to paragraph (i)
1 I
,                                                                        of this section, evaluate the significance of the inventory dif-ference relative to expected performance as determined from an analysis of an appropriate sequence of historical inventory differences.
58 l
1 I                                                                                                 58 l
i
i
_ _ .  - _ .__ _.___ _. -._ _ ______..,____...____ ~,_ _....--_ -                                      _ , . . _ _ , _ _ _ _ . , . _ . ,- - - - . - . _ - . . - , _ . - _ ~ - -
- _.__ _.___ _.. _ ______..,____...____ ~,_ _....--_
_,.. _ _, _ _ _ _.,. _.,- - - -. -. _ -.. -, _. - _ ~ - -


Investigate and report to the appropriate NRC Region Office any
Investigate and report to the appropriate NRC Region Office any
                    ' difference that exceeds its limits of expectation; and Perform a reinventory if so directed by NRC; and Reconcile and adjust the plant and subsidiary book inventories to the results of the physical inventory.
' difference that exceeds its limits of expectation; and Perform a reinventory if so directed by NRC; and Reconcile and adjust the plant and subsidiary book inventories to the results of the physical inventory.
(2) Implement policies and procedures designed to ensure the quality of physical inventories. Appropriate practices and procedures shall include:
(2) Implement policies and procedures designed to ensure the quality of physical inventories.
Appropriate practices and procedures shall include:
Development of procedures for tamper-safing of containers or vaults containing SSNM not in process that include adequate controls to assure the validity of assigned SSNM values; Records of the quantities of SSNM added to and removed from process; Requirements for signed documentation of all SSNM transfer between areas with different custodial responsibility that reflects all quantities of SSNM transferred:
Development of procedures for tamper-safing of containers or vaults containing SSNM not in process that include adequate controls to assure the validity of assigned SSNM values; Records of the quantities of SSNM added to and removed from process; Requirements for signed documentation of all SSNM transfer between areas with different custodial responsibility that reflects all quantities of SSNM transferred:
Means for control of and accounting for internal transfer             <
Means for control of and accounting for internal transfer documents; Cutoff procedures for transfers and processing so that all quantities are inventoried and none are inventoried more than once; Cutoff procedures for records and reports so that all transfers for the inventory and material balance interval and no others are included in the records; Inventory procedures for sealed sources and containers or vaults containing SSNM that assure reliable identification and quantification of contained SSNM; Inventory procedures for in process SSNM that provide for measurement of quantities not previously measured for element and isotope, as appropriate, and remeasurement of material previously measured but whose validity has not been assured by tamper-safing; and l
documents; Cutoff procedures for transfers and processing so that all quantities are inventoried and none are inventoried more than once; Cutoff procedures for records and reports so that all transfers for the inventory and material balance interval and no others are included in the records; Inventory procedures for sealed sources and containers or vaults containing SSNM that assure reliable identification and quantification of contained SSNM; Inventory procedures for in process SSNM that provide for measurement of quantities not previously measured for element and isotope, as appropriate, and remeasurement of material previously measured but whose validity has not been assured by tamper-safing; and l
Written instructions for conducting physical inventories that detail assignments, responsibilities, preparation, and performance of inventory ($ 74.59(f)).
Written instructions for conducting physical inventories that detail assignments, responsibilities, preparation, and performance of inventory ($ 74.59(f)).
Intent and Scope:     Periodic physical inventories enable a licensee to adjust accounts to accurately reflect the status of the SSNM inventory within a facility.     Comparisons of the book inventory to the physical inventory, i.e.,
Intent and Scope:
the inventory difference, also serve as a quality control check on the perform-ance of the material control tests employed for prompt loss detection.         The subdivision of a facility into multiple process units and the performance of 59
Periodic physical inventories enable a licensee to adjust accounts to accurately reflect the status of the SSNM inventory within a facility.
Comparisons of the book inventory to the physical inventory, i.e.,
the inventory difference, also serve as a quality control check on the perform-ance of the material control tests employed for prompt loss detection.
The subdivision of a facility into multiple process units and the performance of 59


material control tests will enhance the resolution of significant ids through better loss localization capability.       Additionally, material control test results will be useful in pinpointing the time when an anomaly likely occurred.
material control tests will enhance the resolution of significant ids through better loss localization capability.
Plan / Annex Content:   The FNMC Plan contains the following affirmations and detailed commitments.       Supporting information, as appropriate, is included in the Annex.
Additionally, material control test results will be useful in pinpointing the time when an anomaly likely occurred.
Plan / Annex Content:
The FNMC Plan contains the following affirmations and detailed commitments.
Supporting information, as appropriate, is included in the Annex.
Section 4.5 of the Plan includes the following affirmations:
Section 4.5 of the Plan includes the following affirmations:
o     A measured physical inventory is performed every six calendar months and within 45 days of the start of the ending inventory:
o A measured physical inventory is performed every six calendar months and within 45 days of the start of the ending inventory:
An ID and associated standard error are calculated; Any ID greater than 300 grams of uranium-235 (200 grams of plutonium or uranium-233) and three times the standard SEID is investigated and reported; All investigations include an evaluation of the significance of the ID relative to expected performance as determined from an analysis of an appropriate sequence of historical inventory differences.
An ID and associated standard error are calculated; Any ID greater than 300 grams of uranium-235 (200 grams of plutonium or uranium-233) and three times the standard SEID is investigated and reported; All investigations include an evaluation of the significance of the ID relative to expected performance as determined from an analysis of an appropriate sequence of historical inventory differences.
Any difference that exceeds its limits of expectation is investi-gated and reported to the appropriate NRC Regional Office.
Any difference that exceeds its limits of expectation is investi-gated and reported to the appropriate NRC Regional Office.
Actions in response to excessive ids will be as described in Section 4.5.3.
Actions in response to excessive ids will be as described in Section 4.5.3.
The material accounting records are reconciled and adjusted to the results of the physical inventory.
The material accounting records are reconciled and adjusted to the results of the physical inventory.
4.5.1     Facility Preparation Describe the preparation of the facility for physical inventory.       The description should include:
4.5.1 Facility Preparation Describe the preparation of the facility for physical inventory.
The description should include:
The basic approach to facility preparation (e.g. draindown, cleanout, etc.);
The basic approach to facility preparation (e.g. draindown, cleanout, etc.);
The degree to which any inventory prelisting will be utilized, and the means of verifying the prelisted items; The means of controlling inventory listing forms and tags; The cutoff procedures for SSNM processing, transfers, and records adjustments to ensure an accurate recording of material transactions and inventory listing; The organization of the inventory teams including the cross-checks to prevent falsification and minimize mistakes; and 60
The degree to which any inventory prelisting will be utilized, and the means of verifying the prelisted items; The means of controlling inventory listing forms and tags; The cutoff procedures for SSNM processing, transfers, and records adjustments to ensure an accurate recording of material transactions and inventory listing; The organization of the inventory teams including the cross-checks to prevent falsification and minimize mistakes; and 60


The criteria for tamper-safing containers or vaults whose SSNM content will be accepted for inventory.
The criteria for tamper-safing containers or vaults whose SSNM content will be accepted for inventory.
4.5.2   Inventory Performance Describe how physical inventories are conducted.             The description should address the following:
4.5.2 Inventory Performance Describe how physical inventories are conducted.
The description should address the following:
The technique to assure that all SSNM is inventoried and none is counted more than once; The measurements that will be performed specifically for inventory purposes; The use of prior measurement data, factors, and composite data; The degree to which holdup will be cleaned out and the measurement of residual holdup; and The use of post-inventory inspection techniques (if employed).
The technique to assure that all SSNM is inventoried and none is counted more than once; The measurements that will be performed specifically for inventory purposes; The use of prior measurement data, factors, and composite data; The degree to which holdup will be cleaned out and the measurement of residual holdup; and The use of post-inventory inspection techniques (if employed).
In the Annex provide an example of a typical inventory listing by material type and quantity.
In the Annex provide an example of a typical inventory listing by material type and quantity.
4.5.3   Inventory Reconciliation Describe the reconciliation procedure including:
4.5.3 Inventory Reconciliation Describe the reconciliation procedure including:
The method of calculating the SEID, The criteria for investigation of ids that exceed three times the SEID, The method of establishing the limits of expectation against which current ID will be evaluated, The criteria for establishing the depth of investigation for excessive ids and the types of investigative actions, The handling of prior period adjustments and uncorrected biases, The method of adjusting the book records to the results of the physical inventory, and The means of establishing the active inventory including the source records that will be used in the computation.
The method of calculating the SEID, The criteria for investigation of ids that exceed three times the
Acceptance Criteria.     The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:
: SEID, The method of establishing the limits of expectation against which current ID will be evaluated, The criteria for establishing the depth of investigation for excessive ids and the types of investigative actions, The handling of prior period adjustments and uncorrected biases, The method of adjusting the book records to the results of the physical inventory, and The means of establishing the active inventory including the source records that will be used in the computation.
o     The physical inventory procedures provide for verifying the location and identity of all quantities of SSNM.             The SSNM quantity of each component in the material balance is based on measurements.           By-difference accounting is not acceptable.
Acceptance Criteria.
The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:
o The physical inventory procedures provide for verifying the location and identity of all quantities of SSNM.
The SSNM quantity of each component in the material balance is based on measurements.
By-difference accounting is not acceptable.
61
61


E
E Use of inventory cutoff and cutoff verification procedures, tag o.
: o.      Use of inventory cutoff and cutoff verification procedures, tag procedures, and post-inventory inspections or equally effective measures are used to ensure all quantities are accounted for and not counted more than once.                 Sufficient information is provided in the plan to show that the inventory process is organized and coordinated to ensure the use of uniform and consistent procedures for checking and recording the SSNM status.
procedures, and post-inventory inspections or equally effective measures are used to ensure all quantities are accounted for and not counted more than once.
o      The SSNM content of groups of like items can be determined by averaging typical contents as determined by measurements of representative item 4
Sufficient information is provided in the plan to show that the inventory process is organized and coordinated to ensure the use of uniform and consistent procedures for checking and recording the SSNM status.
,                                  samples of that material at the time of the inventory if the licensee
The SSNM content of groups of like items can be determined by averaging o
                                  -demonstrates that any additional uncertainty resulting from this averaging method is included in the SEID estimator.
typical contents as determined by measurements of representative item 4
i o      Adjustments to reconcile the book inventory to the physical inventory will be in accordance with commonly accepted accounting practices, and the i                                 adjustments will be traceable and auditable, o       The effect of prior period adjustments will be taken into account before the significance of the current period ID is assessed. Prior period adjustments could be the result of:
samples of that material at the time of the inventory if the licensee
Remeasurement of scrap generated and measured in a prior period but remeasured by a higher quality method in the current period resulting in the assignment of a different value; Recovery of scrap generated in a prior period where the process-ing to a better measurable form results in a " gain" or " loss" of material; or i                                 -
-demonstrates that any additional uncertainty resulting from this averaging method is included in the SEID estimator.
Resolution of an outstanding shipper-receiver difference from a prior
i Adjustments to reconcile the book inventory to the physical inventory will o
;                                          period.
be in accordance with commonly accepted accounting practices, and the i
The appropriate procedure for dealing with these discrepancies is, for purposes of ID evaluation, to modify the ID quantity by adding or
adjustments will be traceable and auditable, o
;                                  subtracting a quantity of SSNM equivalent to the adjustment prior to assessing the significance of the current period ID. However, as with the uncorrected bias case, the adjustment to the book records must include the prior period adjustments in order to bring the accounting records into balance.
The effect of prior period adjustments will be taken into account before the significance of the current period ID is assessed.
o      With respect to the processing of scrap generated in a prior period, the assigned value must be based on dissolver solution and dissolver residue measurements and not on the product of the scrap plant. This is because losses may occur during the separation and purification stage which should, in fact, be attributable to current period processing.
Prior period adjustments could be the result of:
o     All SSNM values on the physical inventory listing must be based on measurements.       Prior measurement values may be accepted for inventory provided they were determined on a measurement system subject to the licensee's measurement control program and the containers were either tamper-safed, stored in an area that provided protection equivalent to tamper-safing, or encapsulated.
Remeasurement of scrap generated and measured in a prior period but remeasured by a higher quality method in the current period resulting in the assignment of a different value; Recovery of scrap generated in a prior period where the process-ing to a better measurable form results in a " gain" or " loss" of material; or i
Resolution of an outstanding shipper-receiver difference from a prior period.
The appropriate procedure for dealing with these discrepancies is, for purposes of ID evaluation, to modify the ID quantity by adding or subtracting a quantity of SSNM equivalent to the adjustment prior to assessing the significance of the current period ID.
However, as with the uncorrected bias case, the adjustment to the book records must include the prior period adjustments in order to bring the accounting records into balance.
With respect to the processing of scrap generated in a prior period, o
the assigned value must be based on dissolver solution and dissolver residue measurements and not on the product of the scrap plant.
This is because losses may occur during the separation and purification stage which should, in fact, be attributable to current period processing.
o All SSNM values on the physical inventory listing must be based on measurements.
Prior measurement values may be accepted for inventory provided they were determined on a measurement system subject to the licensee's measurement control program and the containers were either tamper-safed, stored in an area that provided protection equivalent to tamper-safing, or encapsulated.
62 l
62 l


Line 1,645: Line 2,426:
All reasonable and probable sources of measurement error for the key measurement systems affecting ids are included.
All reasonable and probable sources of measurement error for the key measurement systems affecting ids are included.
The selection of the key measurements whose variances are to be included in calculating the standard error is justified by an analysis of the relative magnitudes of the variance components of a typical ID and their comparative effect on the SEID.
The selection of the key measurements whose variances are to be included in calculating the standard error is justified by an analysis of the relative magnitudes of the variance components of a typical ID and their comparative effect on the SEID.
Any measurement error standard deviations not actually determined by the measurement control program are shown to be reasonable either by comparison with published state-of-the-art measurement performance in similar applications (see such sources as Rogers (1982), and Reilly and Evans (1977)) or with records of past performance data from the licensee's facility.                                   Records showing these data must be available to the NRC.
Any measurement error standard deviations not actually determined by the measurement control program are shown to be reasonable either by comparison with published state-of-the-art measurement performance in similar applications (see such sources as Rogers (1982), and Reilly and Evans (1977)) or with records of past performance data from the licensee's facility.
The calculation of the SEID is performed in accordance with a recognized error propagation method. (Such methods have been published by Jaech (1973); Tingey, Lumb and Jones (1982); and                                         l the IAEA (1977)).
Records showing these data must be available to the NRC.
o Assessment of the significance of current period material balance results by sequential analysis of prior period ID data requires consideration of several relevant points.                                   These are:
The calculation of the SEID is performed in accordance with a recognized error propagation method.
The sequence of ids used for analysis should possess essentially the same components as the current period. That is, the through-puts should be approximately the same (e.g., i 25 percent to 30 percent), the same process units should be operational, and the process should not have undergone any major modifications.
(Such methods have been published by Jaech (1973); Tingey, Lumb and Jones (1982); and l
the IAEA (1977)).
o Assessment of the significance of current period material balance results by sequential analysis of prior period ID data requires consideration of several relevant points.
These are:
The sequence of ids used for analysis should possess essentially the same components as the current period.
That is, the through-puts should be approximately the same (e.g., i 25 percent to 30 percent), the same process units should be operational, and the process should not have undergone any major modifications.
With respect to the unit operations, it is not essential that all units operate every period but rather that the grouping of ids for analysis take into account which units were operative.
With respect to the unit operations, it is not essential that all units operate every period but rather that the grouping of ids for analysis take into account which units were operative.
As to process modifications, a major modification would be one that has a significant impact on measurement capabilities or holdup patterns. "Significant" means a change in the SEID of i 30 percent or greater.
As to process modifications, a major modification would be one that has a significant impact on measurement capabilities or holdup patterns.
The analysis of a sequence of ids to establish a representative standard deviation must take into account the covariances that exist between adjacent (lag 1) and alternate (lag 2) pairs.                                   The AAMASS methodology (Lumb and Tingey (1984) and INDEP (Lumb and Associates (1986) provide two acceptable means of determining the historical standard deviations taking covariances into account.
"Significant" means a change in the SEID of i 30 percent or greater.
o The criteria against which the significance of a current period ID should be evaluated can be established by at least two different methods. These are:
The analysis of a sequence of ids to establish a representative standard deviation must take into account the covariances that exist between adjacent (lag 1) and alternate (lag 2) pairs.
The AAMASS methodology (Lumb and Tingey (1984) and INDEP (Lumb and Associates (1986) provide two acceptable means of determining the historical standard deviations taking covariances into account.
o The criteria against which the significance of a current period ID should be evaluated can be established by at least two different methods.
These are:
63
63


Control chart limits constructed with current and historical material balance closure data, where such limits for further action should be established at a level of significance of 0.01. The limits should be based on the statistical variance-covariance structure of the current inventory difference and an appropriate sequence of previous inventory differences; or Three sigma control limits where sigma is determined as described above o   Excessive ids must be investigated and appropriate action taken.
Control chart limits constructed with current and historical material balance closure data, where such limits for further action should be established at a level of significance of 0.01.
The limits should be based on the statistical variance-covariance structure of the current inventory difference and an appropriate sequence of previous inventory differences; or Three sigma control limits where sigma is determined as described above o
Excessive ids must be investigated and appropriate action taken.
Following are actions that would be deemed appropriate:
Following are actions that would be deemed appropriate:
ID > 3 g and 300 grams U-235 (200gms Pu/u-233)
ID > 3 g and 300 grams U-235 (200gms Pu/u-233)
Line 1,663: Line 2,454:
(4) Review holdup estimates for reasonableness relative to historical data.
(4) Review holdup estimates for reasonableness relative to historical data.
(5) Calculate a standard deviation representative of relevant historical ID performance.
(5) Calculate a standard deviation representative of relevant historical ID performance.
SFKg > ID > 3 o ID (1) Compare material control test and item monitoring data l                       with results of the physical inventory.
SFKg > ID > 3 o ID (1) Compare material control test and item monitoring data l
l l               (2) Review results of trends analyses for all process units.
with results of the physical inventory.
l l
(2) Review results of trends analyses for all process units.
(3) Review conclusions of alarm investigations.
(3) Review conclusions of alarm investigations.
10FKg > ID > 3 o     and 5FKg ID (1) Same as above, and (2) Review plant security records.
10FKg > ID > 3 o and 5FKg ID (1) Same as above, and (2) Review plant security records.
(3) Conduct next inventory within two months or as directed by NRC ID > 3 o and 10FKg ID 64 l
(3) Conduct next inventory within two months or as directed by NRC ID > 3 o and 10FKg ID 64 l
I
I
Line 1,673: Line 2,466:
(3) Remeasure a statistically _ determined sample of the items-generated during the material balance period in question that is sufficient to detect ~the loss of 5 FKG with a.99%
(3) Remeasure a statistically _ determined sample of the items-generated during the material balance period in question that is sufficient to detect ~the loss of 5 FKG with a.99%
probability of detection.
probability of detection.
o   The concept of active. inventory is adequately described and represents .the quantity of material typically handled under normal plant operating conditions.
o The concept of active. inventory is adequately described and represents.the quantity of material typically handled under normal plant operating conditions.
Questions and Answers
Questions and Answers
              .1. Q. What is the distinction between an ID estimate and estimator?
.1.
i A. Because of unavoidable uncertainties in any measurement, the true amount of material being measured is unknown. The measurement can be
Q.
;                          considered to be a random variable characterized by a probability distribution. As a random variable, the measurement process is referred to in statistical terminology as an estimator. A particular value realized by applying an estimator is referred to as an estimate.
What is the distinction between an ID estimate and estimator?
A.
Because of unavoidable uncertainties in any measurement, the true i
amount of material being measured is unknown.
The measurement can be considered to be a random variable characterized by a probability distribution. As a random variable, the measurement process is referred to in statistical terminology as an estimator.
A particular value realized by applying an estimator is referred to as an estimate.
Since ID is a function of measured values, it is sometimes useful to distinguish between true ID, its estimator, and a single estimate.
Since ID is a function of measured values, it is sometimes useful to distinguish between true ID, its estimator, and a single estimate.
The ID calculated at the end of an inventory is a point estimate.
The ID calculated at the end of an inventory is a point estimate.
There is no guarantee, in fact it is highly unlikely, that the ID estimate will exactly equal the true ID. The ID estimator random variable can be written as:
There is no guarantee, in fact it is highly unlikely, that the ID estimate will exactly equal the true ID.
The ID estimator random variable can be written as:
ID = BI + A - EI - R,.
ID = BI + A - EI - R,.
where ending inventory (EI), beginning inventory (BI), additions (A)
where ending inventory (EI), beginning inventory (BI), additions (A) and removals (R) are also random variables.
!                        and removals (R) are also random variables. In this form of the ID equation the inventory terms must represent all inventory including residual holdup.
In this form of the ID equation the inventory terms must represent all inventory including residual holdup.
: 2. Q. Why not use limit of error as the measure of ID variability?
2.
A. Although the limit of error of ID (LEID) has been used for some time l                         in nuclear material accounting, the terminology is a departure from i
Q.
statistical terminology taught in schools and universities, and as a result, it has been the source of some confusion. In practice LEID has been calculated as twice the standard deviation of the measure-ment error associated with the ID. It should be realized that licensees need only use an estimate for the standard deviation.
Why not use limit of error as the measure of ID variability?
: 3.     Q. How does the constraint on measurement system quality, i.e., 0.1 percent of active inventory, compare to the LEID limit in 10 CFR 70.51?
A.
A. The LEID limit for most processes is 0.5 percent of the throughput, which is the larger of additions to or removals from process. Since i
Although the limit of error of ID (LEID) has been used for some time l
in nuclear material accounting, the terminology is a departure from i
statistical terminology taught in schools and universities, and as a result, it has been the source of some confusion.
In practice LEID has been calculated as twice the standard deviation of the measure-ment error associated with the ID.
It should be realized that licensees need only use an estimate for the standard deviation.
3.
Q.
How does the constraint on measurement system quality, i.e., 0.1 percent of active inventory, compare to the LEID limit in 10 CFR 70.51?
A.
The LEID limit for most processes is 0.5 percent of the throughput, which is the larger of additions to or removals from process.
Since i
65
65


active inventory, which replaces throughput because it is a more widely applicable measure of the amount of material subject to measure-ment error in an inventory period, involves the sum of additions and removals, it is approximately double throughput. Thus the LEID limit could be expressed as "approximately 0.25 percent of active inventory."
active inventory, which replaces throughput because it is a more widely applicable measure of the amount of material subject to measure-ment error in an inventory period, involves the sum of additions and removals, it is approximately double throughput.
The LEID is also twice the standard deviation of ID (measurement component only). Thus the LEID limit can be expressed as "twice the standard deviation must be less that 0.25 percent of active inventory."
Thus the LEID limit could be expressed as "approximately 0.25 percent of active inventory."
This equates to one standard deviation being less than 0.125 percent of active inventory. The proposed rule uses a limit of 0.100 percent of active inventory since measurement equipment is better than it was when the LEID limit of 0.5 percent throughput was originally proposed a decade ago.
The LEID is also twice the standard deviation of ID (measurement component only).
Thus the LEID limit can be expressed as "twice the standard deviation must be less that 0.25 percent of active inventory."
This equates to one standard deviation being less than 0.125 percent of active inventory.
The proposed rule uses a limit of 0.100 percent of active inventory since measurement equipment is better than it was when the LEID limit of 0.5 percent throughput was originally proposed a decade ago.
l 66
l 66


4.6 Accounting Requirements:   The rule requires that a licensee establish auditable records         9 sufficient to demonstrate that the requirements of'S$ 74.53, 74.55, 74.57 and               /
4.6 Accounting Requirements:
74.59 have been met. The records are to be retainid for at least three years or longer if/ required by Part 75 of this Chapter 16 74.59(g)).
The rule requires that a licensee establish auditable records 9
Intent and Scope:   The intent of these requirements is that the licensee establish antauditable records system that contains sufficient information to           '
sufficient to demonstrate that the requirements of'S$ 74.53, 74.55, 74.57 and
facilitate future reviews, audits, and inspections to demonstrate that all Plan '
/
commitments have been met.     As a minimum, the records system should include -           o data and information on material control tests; item monitoring; alarm resolu-tion; SSNM receipts, shipments, and discards; measurement control; physical inventories; and MC&A program assessments.
74.59 have been met.
Plan / Annex Content:   The FNMC Plan con'tains the following affirmations and detailed commitments.     Supporting information, as appropriate, is included in the Annex.
The records are to be retainid for at least three years or longer if/ required by Part 75 of this Chapter 16 74.59(g)).
Intent and Scope:
The intent of these requirements is that the licensee establish antauditable records system that contains sufficient information to facilitate future reviews, audits, and inspections to demonstrate that all Plan '
commitments have been met.
As a minimum, the records system should include -
o data and information on material control tests; item monitoring; alarm resolu-tion; SSNM receipts, shipments, and discards; measurement control; physical inventories; and MC&A program assessments.
Plan / Annex Content:
The FNMC Plan con'tains the following affirmations and detailed commitments.
Supporting information, as appropriate, is included in the Annex.
Section4.6ofPlanincludes'thefollowinghffirmations:
Section4.6ofPlanincludes'thefollowinghffirmations:
o     A records system is maintained that contains auditable records suffi-cient to demonstrate compliance with all commitments reflected iri ,
o A records system is maintained that contains auditable records suffi-cient to demonstrate compliance with all commitments reflected iri,
this Plan.
this Plan.
o    Sufficient protection and redundancy of the record system is provided so that an act of record alteration or destruction will not eliminate the capability to provide a complete and correct set of SSNM control and accounting information that could be used to detect the loss of a i goal quantity or more, resolve indications of missing material, or aid in the investigation and recovery of missirg riaterial.
Sufficient protection and redundancy of the record system is provided o
!        o     Controls are incorporated in the records system to maximize the likelihood that mistakes and attempts at data falsification will be detected, o     SSNM transactions are traceable from source data to the, final accounting records.
so that an act of record alteration or destruction will not eliminate the capability to provide a complete and correct set of SSNM control and accounting information that could be used to detect the loss of a i goal quantity or more, resolve indications of missing material, or aid in the investigation and recovery of missirg riaterial.
j 4.6.1 Records System l       Provide a general description of the records system including recordkeeping l
o Controls are incorporated in the records system to maximize the likelihood that mistakes and attempts at data falsification will be
policies and the types of data and information routinely recorded. The types of records to be retained and their form should also ba, described.
: detected, o
In the Annex, provide flow charts showing the flow of data from the source l documents to the final accounting records and the typical forms and report i
SSNM transactions are traceable from source data to the, final accounting records.
4.6.1 Records System j
l Provide a general description of the records system including recordkeeping l
policies and the types of data and information routinely recorded.
The types of records to be retained and their form should also ba, described.
In the Annex, provide flow charts showing the flow of data from the source l
documents to the final accounting records and the typical forms and report i
formats used throughout the PC&A system.
formats used throughout the PC&A system.
1 l                                           67
1 l
67


s     .~.
s
                \;
.~.
                    .f
\\;
        ,s       { g
.f
        ,i 1                 , 4.6.2     Record Maintenance i
,s
    ~
{ g
,i 1
, 4.6.2 Record Maintenance i
~
Describe the measures that will be taken to ensure record integrity including:
Describe the measures that will be taken to ensure record integrity including:
Ph.9sical protection; Nssignmentofoverallresponsibility; Access controls which permit only authorized updating and Grrecting of records; Cross-checks for preventing or detecting missing or falsified data and records, ensuring completeness of the records, and locating data discrepancies and errors; and Capability for reconstructing lost or destroyed records.
Ph.9sical protection; Nssignmentofoverallresponsibility; Access controls which permit only authorized updating and Grrecting of records; Cross-checks for preventing or detecting missing or falsified data and records, ensuring completeness of the records, and locating data discrepancies and errors; and Capability for reconstructing lost or destroyed records.
Acceptance Criteria:             The assessment of the adequacy of the information supplied above will be based on the following criteria:
Acceptance Criteria:
o         The records system provides for retention of key material accounting and original source data and relevant reports and documents including:
The assessment of the adequacy of the information supplied above will be based on the following criteria:
o The records system provides for retention of key material accounting and original source data and relevant reports and documents including:
Management structure; MC&A policies and procedures; Measurement data used for loss detection, alarm resolution and material balance accounting; Records of the investigation and resolution of alarms; i
Management structure; MC&A policies and procedures; Measurement data used for loss detection, alarm resolution and material balance accounting; Records of the investigation and resolution of alarms; i
                                              . Calibrations of measurement systems, measurement quality control data, bias adjustments and their backup data, and the i    statistical analyses of the measurement control data; Calculations of action thresholds for the detection system; Shipper / receiver data and investigations of significant shipper / receiver differences; j
Calibrations of measurement systems, measurement quality control data, bias adjustments and their backup data, and the statistical analyses of the measurement control data; i
Tamper-safing records (e.g. , application records, " attesting to" records, destruction records);
Calculations of action thresholds for the detection system; Shipper / receiver data and investigations of significant shipper / receiver differences; j
Physical inventory listings and inventory work sheets; Records of ids and calculations of the SEIDs; Reports of investigations and resolution of alarms, excessive ID estimates, and shipper / receiver differences; and j                                                                         68
Tamper-safing records (e.g., application records, " attesting to" records, destruction records);
: i.         _
Physical inventory listings and inventory work sheets; Records of ids and calculations of the SEIDs; Reports of investigations and resolution of alarms, excessive ID estimates, and shipper / receiver differences; and j
68 i.


4-     y Reports of periodic revi'ews and assessments and the resultant" '
4-y Reports of periodic revi'ews and assessments and the resultant" '
corrective actions taken by management.               -
corrective actions taken by management.
o    Records may be retained in hard copy, magnetic tapes or disks, microfiche, or other suitable forms.-
Records may be retained in hard copy, magnetic tapes or disks, o
s o     The records-and reports contain sufficient detail to enable inspectors to determine that SSNM control and accounting has been conducted in compliance with $$ 74.53, 74.55, 74,57 and 74.59.
microfiche, or other suitable forms.-
                  '1                     ?      .
s o
L          o'     The record system will be complete andisufficiently detailed to-permit auditing of all parts of the MC&A system. The records and reports will be readily traceable back to source documents.
The records-and reports contain sufficient detail to enable inspectors to determine that SSNM control and accounting has been conducted in compliance with $$ 74.53, 74.55, 74,57 and 74.59.
                                            .The record system will have sufficient redundancy to enable o
?
N                      reconstruction of lost or missing records se that a complete knowledge of the SSNM inventory is available. The capability for reconstruction of records will be provided by a subsystem at least equivalent.to the following: source data for receipts, shipments, internal transfers, adjustments, and corrections to the records.will be retained ~in a separate secure. location so that a single individual or a single event;cannot al_ter both accounting and source records.
'1 L
1 o     Cross-checks or other controls will be provided t'o prevent or detect errors in the records that would affect ids or item location records.
o' The record system will be complete andisufficiently detailed to-permit auditing of all parts of the MC&A system.
Examples of cross-checks or controls that might prevent       '
The records and reports will be readily traceable back to source documents.
or detect errors in the records system would include:
o
r Minimizing the number of people authorized to make data entries;                 '
.The record system will have sufficient redundancy to enable reconstruction of lost or missing records se that a complete N
UsingverificationmethodsfNrdataentryforshipments, i'
knowledge of the SSNM inventory is available.
The capability for reconstruction of records will be provided by a subsystem at least equivalent.to the following:
source data for receipts, shipments, internal transfers, adjustments, and corrections to the records.will be retained ~in a separate secure. location so that a single individual or a single event;cannot al_ter both accounting and source records.
1 o
Cross-checks or other controls will be provided t'o prevent or detect errors in the records that would affect ids or item location records.
Examples of cross-checks or controls that might prevent or detect errors in the records system would include:
r Minimizing the number of people authorized to make data entries; UsingverificationmethodsfNrdataentryforshipments, i'
receipts, waste discards, and item records (item records may be
receipts, waste discards, and item records (item records may be
                                                    -checked by random sampling rather than on a 100 percent basis);
-checked by random sampling rather than on a 100 percent basis);
and 1
and 1
cross-checking calculations, at least by random sampling.
cross-checking calculations, at least by random sampling.
l#                                     o     The records of the data that are the basis of the SEID will permit
l#
(                                           traceability to the sources of the variancet due to calibrations, ii                   i,                     bias adjustments, and random errors in Me neasurements. These1 t
o The records of the data that are the basis of the SEID will permit
j i         '
(
records may simply be summaries of edbrie :ons, bias tests, and variance monitoring data or contrcl yrt
traceability to the sources of the variancet due to calibrations, ii i,
[4.7 Shipments and Receipts Requiren.ent:       The rule requires that a licensee shall establish procedures for shipping and receiving SSNM that provide for:
bias adjustments, and random errors in Me neasurements.
These1 j
i records may simply be summaries of edbrie :ons, bias tests, and t
variance monitoring data or contrcl yrt
[4.7 Shipments and Receipts Requiren.ent:
The rule requires that a licensee shall establish procedures for shipping and receiving SSNM that provide for:
Accurate identification and measurement of the quantities shipped and rec,eived; l
Accurate identification and measurement of the quantities shipped and rec,eived; l
Review and evaluation of shipper / receiver differences on an individual container or lot basis, on a shipment basis, and on a batch basis when required by Part 75 of this Chapter; 69
Review and evaluation of shipper / receiver differences on an individual container or lot basis, on a shipment basis, and on a batch basis when required by Part 75 of this Chapter; 69


1 2
1 2
  .c I
.c I
Investigation-and corrective action when shipper / receiver differences exceed twice the estimated standard deviation of the difference                                       l
Investigation-and corrective action when shipper / receiver differences exceed twice the estimated standard deviation of the difference
                                . estimator and the larger of 0.5 percent of the amount of SSNM in the container or lot, as appropriate, and 50 grams of SSNM.
. estimator and the larger of 0.5 percent of the amount of SSNM in the container or lot, as appropriate, and 50 grams of SSNM.
Documentation of shipper / receiver evaluations, investigations and corrective actions ($ 74.59(h)(1)).
Documentation of shipper / receiver evaluations, investigations and corrective actions ($ 74.59(h)(1)).
Intent and Scope:         Timely and accurate quantification of the SSNM content of shipments and receipts is an essential component of an effective MC&A system.
Intent and Scope:
Timely and accurate quantification of the SSNM content of shipments and receipts is an essential component of an effective MC&A system.
When significant shipper / receiver differences are identified, it is imperative that they be resolved and contributing factors corrected.
When significant shipper / receiver differences are identified, it is imperative that they be resolved and contributing factors corrected.
Plan / Annex Content:             The FNMC Plan contains the following affirmations and detailed commitments.                   Supporting.information, as appropriate, is included in the Annex.
Plan / Annex Content:
Section 4.7 of the Plan includes the following affirmations:                                                   ,
The FNMC Plan contains the following affirmations and detailed commitments.
o         The element and isotopic content of SSNM shipments are based on                                       '
Supporting.information, as appropriate, is included in the Annex.
measurements obtained from measurement systems subject to the measurement control program.
Section 4.7 of the Plan includes the following affirmations:
o         Receipts of SSNM are checked and measured to confirm that the quantity received is consistent with the supporting documentation. Item checks and seal integrity inspections are completed within 24 hours of receipt.
o The element and isotopic content of SSNM shipments are based on measurements obtained from measurement systems subject to the measurement control program.
o Receipts of SSNM are checked and measured to confirm that the quantity received is consistent with the supporting documentation.
Item checks and seal integrity inspections are completed within 24 hours of receipt.
Receipt measurements are completed within 30 days of receipt except in the case of scrap.
Receipt measurements are completed within 30 days of receipt except in the case of scrap.
o         Shipper / receiver differences are investigated whenever they exceed twice the standard deviation of the difference estimator and the larger of 0.5 percent of the amount of SSNM in the container, lot or shipment, as appropriate, or 50 grams of SSNM.
o Shipper / receiver differences are investigated whenever they exceed twice the standard deviation of the difference estimator and the larger of 0.5 percent of the amount of SSNM in the container, lot or shipment, as appropriate, or 50 grams of SSNM.
o         Results of shipper / receiver difference investigations, including corrective actions, are documented and retained for at least three years.
o Results of shipper / receiver difference investigations, including corrective actions, are documented and retained for at least three years.
I 4.7.1     Receiving Procedure i                     Describe how materials are received, stored, and measured.                                     The latter should include a description of the sampling techniques employed.
I 4.7.1 Receiving Procedure i
4.7.2     Shipper-Receiver Differences Describe the investigation of significant shipper-receiver differences.
Describe how materials are received, stored, and measured.
The latter should include a description of the sampling techniques employed.
4.7.2 Shipper-Receiver Differences Describe the investigation of significant shipper-receiver differences.
The description should include:
The description should include:
The method of establishing the standard deviation of the shipper-receiver difference estimator under conditions where the shipper's uncertainty estimate is available and where it is unavailable; The conditions under which a referee laboratory is involved and the I                                 criteria for selecting a referee laboratory; 70 l
The method of establishing the standard deviation of the shipper-receiver difference estimator under conditions where the shipper's uncertainty estimate is available and where it is unavailable; The conditions under which a referee laboratory is involved and the I
criteria for selecting a referee laboratory; 70 l


The bases established for concluding that a significant difference is resolved; The procedure for adjusting book records to accommodate resolution of the difference; and-The procedure for establishing and resolving differences' involving scrap.
The bases established for concluding that a significant difference is resolved; The procedure for adjusting book records to accommodate resolution of the difference; and-The procedure for establishing and resolving differences' involving scrap.
Line 1,779: Line 2,628:
The measurement data and tamper-safing information provided to the.
The measurement data and tamper-safing information provided to the.
group responsible for SSNM shipments; The cross-checks, including any item checks or measurements, made by the shipping group; and The types of records maintained by the shipping group.
group responsible for SSNM shipments; The cross-checks, including any item checks or measurements, made by the shipping group; and The types of records maintained by the shipping group.
Acceptance criteria:     The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:
Acceptance criteria:
o    Receipts are inspected promptly to verify the validity of the shipper's data. Acceptable times to complete the verification measures are:
The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:
Receipts are inspected promptly to verify the validity of the shipper's o
data.
Acceptable times to complete the verification measures are:
Item verification, 24 hours; Seal integrity, 24 hours; Gross weight, 72 hours; NDA scans (if appropriate), 120 hours *; and SSNM measurements (scrap excepted), 30 days.
Item verification, 24 hours; Seal integrity, 24 hours; Gross weight, 72 hours; NDA scans (if appropriate), 120 hours *; and SSNM measurements (scrap excepted), 30 days.
Times other than those indicated above would be acceptable with adequate justification.
Times other than those indicated above would be acceptable with adequate justification.
o    Shipper's values may be accepted for encapsulated items such as fuel rods, elements, etc.
Shipper's values may be accepted for encapsulated items such as fuel rods, o
o     The investigation of statistically significant shipper-receiver differences should normally be completed within three months except where the difference exceeds 5 FKG. In the latter case, the discrepancy should be resolved within 30 days of the time that its existence is determined.
elements, etc.
o The investigation of statistically significant shipper-receiver differences should normally be completed within three months except where the difference exceeds 5 FKG.
In the latter case, the discrepancy should be resolved within 30 days of the time that its existence is determined.
* Qualitative or semi quantitative 71
* Qualitative or semi quantitative 71


  ..g The following stepwise analysis is an example of an acceptable approach for investigating a significant shipper-receiver difference:
..g The following stepwise analysis is an example of an acceptable approach for investigating a significant shipper-receiver difference:
The receiver should review his or her data to check for possible entry errors such as an incorrect number or the transposition of numbers.
The receiver should review his or her data to check for possible entry errors such as an incorrect number or the transposition of numbers.
The receiver should then review source data including the basic calculations and the associated measurement control data.
The receiver should then review source data including the basic calculations and the associated measurement control data.
Assuming the difference remains unresolved, the receiver should remeasure the SSNM content of the receipt.
Assuming the difference remains unresolved, the receiver should remeasure the SSNM content of the receipt.
If remeasurement fails to resolve the difference, the shipper should be notified and requested to conduct a similar investigation.
If remeasurement fails to resolve the difference, the shipper should be notified and requested to conduct a similar investigation.
If the two parties fail to resolve the difference, a referee laboratory should be involved. The shipper and receiver should mutually agree on the sampling procedure.
If the two parties fail to resolve the difference, a referee laboratory should be involved.
linless contractual requirements dictate otherwise, the value closest to the referee's value should be accepted and booked by both parties.           If the referee's value is not within statistical limits of either the shipper or receiver, the referee's value should be used.
The shipper and receiver should mutually agree on the sampling procedure.
o    For purposes of shipper-receiver evaluation, a lot may be defined in several ways.           These would include:
linless contractual requirements dictate otherwise, the value closest to the referee's value should be accepted and booked by both parties.
If the referee's value is not within statistical limits of either the shipper or receiver, the referee's value should be used.
For purposes of shipper-receiver evaluation, a lot may be defined in o
several ways.
These would include:
Multiple containers of a material that has been blended by a procedure that has been demonstrated to produce a homogeneous product; Multiple containers filled from a master container of homogeneous material (e.g., UFs cylinders);
Multiple containers of a material that has been blended by a procedure that has been demonstrated to produce a homogeneous product; Multiple containers filled from a master container of homogeneous material (e.g., UFs cylinders);
A quantity of scrap transferred on multiple transfer receipts (741s) but combined for processing through recovery.
A quantity of scrap transferred on multiple transfer receipts (741s) but combined for processing through recovery.
4.8 Scrap Control
4.8 Scrap Control Requirement:
;            Requirement: The rule requires that a licensee establish a scrap control program that assures that internally generated scrap is segregated from scrap from other licensees or contractors until accountability is established, and any scrap with a measurement standard deviation greater than five percent of the measured amount is recovered so that the results are segregated by inventory period and received within six months of the end of the inventory period in which the scrap was generated except where it can be demonstrated that the scrap measurement uncertainty will not cause noncompliance with S 74.59(e)(5) (See S 74.59(h)(2)).
The rule requires that a licensee establish a scrap control program that assures that internally generated scrap is segregated from scrap from other licensees or contractors until accountability is established, and any scrap with a measurement standard deviation greater than five percent of the measured amount is recovered so that the results are segregated by inventory period and received within six months of the end of the inventory period in which the scrap was generated except where it can be demonstrated that the scrap measurement uncertainty will not cause noncompliance with S 74.59(e)(5) (See S 74.59(h)(2)).
Intent and Scope:       The regular processing of scrap with relatively large i       measurement uncertainties precludes such scrap being the source of a problem at
Intent and Scope:
The regular processing of scrap with relatively large i
measurement uncertainties precludes such scrap being the source of a problem at
{
{
l                                                         72 l
l 72 l
.~....


the time of physical inventories.             Inaccurate scrap measurements could cause an apparent ID or conceal a theft or diversion.               Segregation of internally gener-ated scrap from that received from off-site until accountability is established ensures that potential anomalies in assigned values will be attributed to the appropriate facility.
the time of physical inventories.
Plan / Annex Content:     The FNMC Plan contains the following affirmations and detailed commitments.         Supporting information, as appropriate, is included in the Annex.
Inaccurate scrap measurements could cause an apparent ID or conceal a theft or diversion.
Segregation of internally gener-ated scrap from that received from off-site until accountability is established ensures that potential anomalies in assigned values will be attributed to the appropriate facility.
Plan / Annex Content:
The FNMC Plan contains the following affirmations and detailed commitments.
Supporting information, as appropriate, is included in the Annex.
Section 4.8 of the Plan includes the following affirmation:
Section 4.8 of the Plan includes the following affirmation:
o        Scrap control procedures are in place that provide for:
Scrap control procedures are in place that provide for:
Segregation in the recovery process of any scrap that originates from off site from scrap generated on-site until accountability has been established; and Recovery of scrap within six months after the inventory period in which it was generated, when such scrap has a standard deviation of its measurement estimator greater than five percent of the measured amount unless it can be shown that the total scrap measurement error will not cause noncompliance with S 74.59(e)(5).
o Segregation in the recovery process of any scrap that originates from off site from scrap generated on-site until accountability has been established; and Recovery of scrap within six months after the inventory period in which it was generated, when such scrap has a standard deviation of its measurement estimator greater than five percent of the measured amount unless it can be shown that the total scrap measurement error will not cause noncompliance with S 74.59(e)(5).
4.8.1       Location Identify the scrap and waste quantities of contained SSNM with respect to source, storage, and disposition.             Refer to process flow charts and plant operations descriptions included in the Annex.
4.8.1 Location Identify the scrap and waste quantities of contained SSNM with respect to source, storage, and disposition.
4.8.2       Processing Describe the program for in-house processing of scrap including recovery plant capacity, rate of recovery, and the estimated amount of scrap expected to be on hand at any given time. Describe any plans for shipments and for off-site recovery of scrap. Describe procedures for the control and discard of wastes containing SSNM, including procedures and capabilities for storage prior to discard.
Refer to process flow charts and plant operations descriptions included in the Annex.
4.8.3 Measurement Describe the procedures for determining the SSNM content of scrap and waste, including the criteria and procedures for segregation, identification, and classification of various kinds of scrap to facilitate measurement. Identify types and quantities of scrap expected to have measurement uncertainties greater than i 5 percent (la).
4.8.2 Processing Describe the program for in-house processing of scrap including recovery plant capacity, rate of recovery, and the estimated amount of scrap expected to be on hand at any given time.
4.8.4       Inventory Control l         Describe the control program that will be implemented to assure that scrap l   measured with an uncertainty greater than i 5 percent does not remain on
Describe any plans for shipments and for off-site recovery of scrap.
,  inventory longer than six months, or the measurement uncertainty associated l   with the scrap on hand will not cause noncompliance with $74.59(e)(5).
Describe procedures for the control and discard of wastes containing SSNM, including procedures and capabilities for storage prior to discard.
4.8.3 Measurement Describe the procedures for determining the SSNM content of scrap and waste, including the criteria and procedures for segregation, identification, and classification of various kinds of scrap to facilitate measurement.
Identify types and quantities of scrap expected to have measurement uncertainties greater than i 5 percent (la).
4.8.4 Inventory Control l
Describe the control program that will be implemented to assure that scrap l
measured with an uncertainty greater than i 5 percent does not remain on inventory longer than six months, or the measurement uncertainty associated l
with the scrap on hand will not cause noncompliance with $74.59(e)(5).
i 73 l
i 73 l
l
l


  ~.
~.
4.8.5     Recovery of Off-Site Scrap Describe the procedures that will be implemented to ensure that scrap received for recovery from off-site is segregated until accountability is established.         The description should address segregation during storage and processing.
4.8.5 Recovery of Off-Site Scrap Describe the procedures that will be implemented to ensure that scrap received for recovery from off-site is segregated until accountability is established.
Acceptance Criteria:         The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:
The description should address segregation during storage and processing.
o       A comparison of generation rates and recovery capacity indicates that adequate recovery capability exists to preclude the buildup of excess amounts of scrap.
Acceptance Criteria:
o       Where offsite recovery is utilized, the description of the program includes as a minimum:
The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:
o A comparison of generation rates and recovery capacity indicates that adequate recovery capability exists to preclude the buildup of excess amounts of scrap.
o Where offsite recovery is utilized, the description of the program includes as a minimum:
Types and estimated quantities of scrap to be shipped, Contractor's program to assure segregation of customer scrap, Basis for establishing accountability values, Contractor and shipper measurement responsibilities, and Proposed means of performing shipper / receiver comparisons (i.e.
Types and estimated quantities of scrap to be shipped, Contractor's program to assure segregation of customer scrap, Basis for establishing accountability values, Contractor and shipper measurement responsibilities, and Proposed means of performing shipper / receiver comparisons (i.e.
shipment basis, campaign basis, etc.).
shipment basis, campaign basis, etc.).
o       Special handling procedures for waste such as conversion to a better measurable form or independent measurement verification are described.
o Special handling procedures for waste such as conversion to a better measurable form or independent measurement verification are described.
o       Proposed measurement techniques for specific scrap types are described including:
o Proposed measurement techniques for specific scrap types are described including:
Material description, Specific NDA system to be employed (as appropriate),
Material description, Specific NDA system to be employed (as appropriate),
Container size, Mixing and blending operations (as appropriate),
Container size, Mixing and blending operations (as appropriate),
Line 1,830: Line 2,703:
Assay procedure.
Assay procedure.
An estimate of the measurement uncertainties associated with each scrap type should be included in the Annex.
An estimate of the measurement uncertainties associated with each scrap type should be included in the Annex.
l o       For those materials measured by NDA in 30 gallon drums or larger con-tainers, the licensee should commit to an annual evaluation to demon-     I strate the continuing reliability of the measurement system. Possible evaluation techniques include a destructive analysis, a second NDA 74
l o
For those materials measured by NDA in 30 gallon drums or larger con-tainers, the licensee should commit to an annual evaluation to demon-I strate the continuing reliability of the measurement system.
Possible evaluation techniques include a destructive analysis, a second NDA 74


technique not subject to the same potential interferences as the pri -
technique not subject to the same potential interferences as the pri -
mary technique, or a standard addition procedure.
mary technique, or a standard addition procedure.
o     The program for segregation of scrap generated off-site from on-site scrap appears adequate to protect against commingling. Possible techniques to achieve this objective are:
o The program for segregation of scrap generated off-site from on-site scrap appears adequate to protect against commingling.
Retain customer scrap in shipping containers prior to recovery, Isolate customer scrap in a particular section of a vault or permanently controlled access area, or Identify designated storage bins or shelves for application of shelves for application limited access controls, o     Segregation of customer scrap during processing is accomplished by cleaning the dissolver and accountability weigh tank before and after the recovery campaign. Additional processing of dissolver residues should be handled in the same manner unless the quantity involved is less than one FKG or the measurement uncertainty is less than i 5 percent (la).
Possible techniques to achieve this objective are:
4.9 Human Errors Requirement: The rule requires that a licensee incorporate checks and balances in the MC&A system to minimize the rate of human errors in MC&A infor-mation ($ 74.59(h)(3)).
Retain customer scrap in shipping containers prior to recovery, Isolate customer scrap in a particular section of a vault or permanently controlled access area, or Identify designated storage bins or shelves for application of shelves for application limited access controls, o
Intent and Scope:     The objective of this requirement is to reduce the frequency of human errors affecting MC&A information and to enhance the likeli-hood of detection when they do occur. This can be achieved by implementation of a system of checks and balances in MC&A information systems that involve generating, collecting, processing, computing, analyzing, summarizing, and reporting data.
Segregation of customer scrap during processing is accomplished by cleaning the dissolver and accountability weigh tank before and after the recovery campaign.
Plan / Annex Content:   The FNMC Plan contains the following affirmations and detailed commitments.       Supporting information, as appropriate, is included in an Annex.
Additional processing of dissolver residues should be handled in the same manner unless the quantity involved is less than one FKG or the measurement uncertainty is less than i 5 percent (la).
4.9 Human Errors Requirement:
The rule requires that a licensee incorporate checks and balances in the MC&A system to minimize the rate of human errors in MC&A infor-mation ($ 74.59(h)(3)).
Intent and Scope:
The objective of this requirement is to reduce the frequency of human errors affecting MC&A information and to enhance the likeli-hood of detection when they do occur.
This can be achieved by implementation of a system of checks and balances in MC&A information systems that involve generating, collecting, processing, computing, analyzing, summarizing, and reporting data.
Plan / Annex Content:
The FNMC Plan contains the following affirmations and detailed commitments.
Supporting information, as appropriate, is included in an Annex.
Section 4.9 of the Plan includes the following affirmations:
Section 4.9 of the Plan includes the following affirmations:
o     MC&A procedures will be developed and implemented in a manner that assures that the frequency and consequences of human errors will be minimized.
o MC&A procedures will be developed and implemented in a manner that assures that the frequency and consequences of human errors will be minimized.
o     MC&A procedures include job performance aids, where applicable, that help to reduce the frequency of human errors.
o MC&A procedures include job performance aids, where applicable, that help to reduce the frequency of human errors.
o     MC&A procedures will be formatted in a manner that facilitates a reduction in human errors and helps to make errors easier to identify.
o MC&A procedures will be formatted in a manner that facilitates a reduction in human errors and helps to make errors easier to identify.
75
75
: o.             MC&A activities associated with collecting and processing data, recordkeeping, and auditing are automated where it is practical and advantageous to do so.
 
o                A quality control system is in place to monitor the frequency of human errors and permit categorization of the types of errors encountered.
o.
4.9.1 Control Describe the techniques that will be employed to minimize the frequency of human errors and enhance the likelihood that they will be detected when they do
MC&A activities associated with collecting and processing data, recordkeeping, and auditing are automated where it is practical and advantageous to do so.
;                  occur. The description should address the use of:
A quality control system is in place to monitor the frequency of o
Control methods to ensure that current procedures are in place and being used,                                                                                 .
human errors and permit categorization of the types of errors encountered.
i Job performance aids, Automated data processing, 1                                 -
4.9.1 Control Describe the techniques that will be employed to minimize the frequency of human errors and enhance the likelihood that they will be detected when they do occur.
The description should address the use of:
Control methods to ensure that current procedures are in place and being used, i
Job performance aids, Automated data processing, 1
Personnel training and qualification, Preprinted forms, Multiple copy forms, and Data verification.
Personnel training and qualification, Preprinted forms, Multiple copy forms, and Data verification.
4.9.2 Monitoring
4.9.2 Monitoring Describe the quality control system that will be used to monitor the frequency and types of human errors.
:                                  Describe the quality control system that will be used to monitor the frequency and types of human errors.
1 Acceptance Criteria:
1 Acceptance Criteria:                                                     The adequacy of the information supplied above will be based on the following criteria or equivalent:
The adequacy of the information supplied above will be based on the following criteria or equivalent:
4 o               Procedures should be developed and used that will control the rate of i                                                 human error in MC&A data.
o Procedures should be developed and used that will control the rate of 4
i human error in MC&A data.
(
(
Specific procedures should be available to guide personnel in performing major or complex tasks associated with MC&A.
Specific procedures should be available to guide personnel in performing major or complex tasks associated with MC&A.
Procedures should be sufficiently explicit and comprehensive to.
Procedures should be sufficiently explicit and comprehensive to.
,                                                                  promote error free performance by the least skilled or least experienced person that will be assigned to perform the tasks specified by the procedures.
promote error free performance by the least skilled or least experienced person that will be assigned to perform the tasks specified by the procedures.
i Procedures should be based on the activities required to effectively accomplish the task.
i Procedures should be based on the activities required to effectively accomplish the task.
Procedures should be self-contained to avoid the need to refer to supporting documents.
Procedures should be self-contained to avoid the need to refer to supporting documents.
76 l , , . . . - . - - - . - - . - - - . . - - - , . - - . . - . . - - - - - . . - . - - . - - - _ . _ - -
76 l


Procedures should be written with flexibility in the sequence of events whenever possible.
Procedures should be written with flexibility in the sequence of events whenever possible.
Line 1,867: Line 2,754:
Procedures should be validated by means of field tests to ensure their clarity, comprehensiveness, and effectiveness.
Procedures should be validated by means of field tests to ensure their clarity, comprehensiveness, and effectiveness.
Personnel should be required to use and follow appropriate pro-cedures in performing complex MC&A tasks or tasks that affect MC&A.
Personnel should be required to use and follow appropriate pro-cedures in performing complex MC&A tasks or tasks that affect MC&A.
o Job performance aids must be considered for use in highly complex MC&A tasks.
o Job performance aids must be considered for use in highly complex MC&A tasks.
Job performance aids should assist novice users in their performance while not hindering the performance of experienced users.
Job performance aids should assist novice users in their performance while not hindering the performance of experienced users.
Terms and labels should match common usage for equipment labels and legends.
Terms and labels should match common usage for equipment labels and legends.
Line 1,874: Line 2,761:
The presentation of illustrations, graphs, and tables, if used, should be consistent throughout the procedure.
The presentation of illustrations, graphs, and tables, if used, should be consistent throughout the procedure.
Illustrations, tables, graphs, and other job performance aids, if used, should be appropriate to the task to be performed.
Illustrations, tables, graphs, and other job performance aids, if used, should be appropriate to the task to be performed.
o     Checklists or data tables should be provided for lengthy prerequisites, tests, and calculations.
o Checklists or data tables should be provided for lengthy prerequisites, tests, and calculations.
o     Illustrations should be used in place of long descriptions l
o Illustrations should be used in place of long descriptions l
where possible.
where possible.
;        o     Illustrations should be placed so that they can be referenced j               easily from the text section.
o Illustrations should be placed so that they can be referenced j
o     Illustrations should be clearly labeled and easy to read.
easily from the text section.
o     All tables and graphs should be clearly labeled in quanti-tative terms.
o Illustrations should be clearly labeled and easy to read.
! o The format of MC&A procedures should be arranged to help to reduce the rate of human error and to detect mistakes.
o All tables and graphs should be clearly labeled in quanti-tative terms.
o The format of MC&A procedures should be arranged to help to reduce the rate of human error and to detect mistakes.
l l
l l
The complexity, sentence length, and grammatical structure
The complexity, sentence length, and grammatical structure should be appropriate to the educational level of the least j
;        should be appropriate to the educational level of the least j       qualified user.
qualified user.
77 i
77 i


a
a
  's o-   Short sentences with concise and unambiguous language should be used.
's o-Short sentences with concise and unambiguous language should be used.
o     The level of detail in instructions should be adequate to avoid errors of omission.
o The level of detail in instructions should be adequate to avoid errors of omission.
o     No more than three simple task elements should be: included per step. More complex actions should be separated into additional steps.
o No more than three simple task elements should be: included per step.
Procedures should be formatted-to' allow experienced personnel to concentrate on major headings or capsule descriptions, while more detail is provided in clearly demarcated fashion for less experienced personnel.               Procedures may be formatted in " cookbook" fashion for ease of use when appropriate.
More complex actions should be separated into additional steps.
All steps and tasks should be stated as actions.                   The sequence of steps and tasks-in a procedure should be in the same sequence followed to accomplish the objective of the procedure.
Procedures should be formatted-to' allow experienced personnel to concentrate on major headings or capsule descriptions, while more detail is provided in clearly demarcated fashion for less experienced personnel.
Procedures may be formatted in " cookbook" fashion for ease of use when appropriate.
All steps and tasks should be stated as actions.
The sequence of steps and tasks-in a procedure should be in the same sequence followed to accomplish the objective of the procedure.
Attention getting warning and precaution notices should be placed immediately preceding applicable steps and, where required, should also be summarized at the beginning of the procedure.
Attention getting warning and precaution notices should be placed immediately preceding applicable steps and, where required, should also be summarized at the beginning of the procedure.
Summary information should be included at the beginning of every procedure. _All required supplies, tools, test equipment, docu-ments, and protective measures should be listed at the beginning of the procedure.
Summary information should be included at the beginning of every procedure. _All required supplies, tools, test equipment, docu-ments, and protective measures should be listed at the beginning of the procedure.
Line 1,900: Line 2,791:
The sequence of steps should be logical and accurate.
The sequence of steps should be logical and accurate.
Unnecessary memory recall should be avoided.
Unnecessary memory recall should be avoided.
l                                  -
The need for personnel to perform calculations and conversions l
The need for personnel to perform calculations and conversions should be avoided whenever possible.
should be avoided whenever possible.
Data collection tables and data reduction aids should be provided if lengthy tests and calculations cannot be avoided.
Data collection tables and data reduction aids should be provided if lengthy tests and calculations cannot be avoided.
Pre printed forms for recording data should be utilized when
Pre printed forms for recording data should be utilized when practical.
!                                              practical.
l Multiple copies of fonas, if needed, should be generated automatically in the data collection phase.
l Multiple copies of fonas, if needed, should be generated automatically in the data collection phase.
78 E       __ _ _ . _ ._ . _ . _. _ . _ . . _ _ .                      . . _ . _ . _ _              _            _ _ _ _ . _ . _ _ _
78 E


Formatting should be neat and simple and should be consistent among all related procedures.
Formatting should be neat and simple and should be consistent among all related procedures.
o  MCM data should be directly collected, input, checked, manipulated,.
MCM data should be directly collected, input, checked, manipulated,.
    . reported,-and audited by computer where it.is practical and advantageous to reduce the consequences and frequency of human' error in MC&A data as much as' practical.                     '
o
  .o _ Statistical quality control systems should be used to track the effectiveness of human error control measures and the frequency of i
. reported,-and audited by computer where it.is practical and advantageous to reduce the consequences and frequency of human' error in MC&A data as much as' practical.
human error in MC&A systems , and should be used to alert management
.o
,      whenever the rate of human error is in an out-of-tolerance condition.
_ Statistical quality control systems should be used to track the effectiveness of human error control measures and the frequency of i
[     -
human error in MC&A systems, and should be used to alert management whenever the rate of human error is in an out-of-tolerance condition.
The quality control system should be capable of determining if' l           and when an individual, procedure, or process makes more errors than is reasonably expected.
[
The quality control system should be capable of determining if' l
and when an individual, procedure, or process makes more errors than is reasonably expected.
The quality control system should be capable of determining both the individuals who require retraining due to their frequency of committing errors and the procedures and processes that should be revised to produce fewer human errors.
The quality control system should be capable of determining both the individuals who require retraining due to their frequency of committing errors and the procedures and processes that should be revised to produce fewer human errors.
Double checklists should be provided to allow auditing of data collection by a supervisor or other independent person that checks the results of the first person's work and signs off when i           the work is complete and accurate. Each data collection form should be checked by the originator to verify that the data are accurate.
Double checklists should be provided to allow auditing of data collection by a supervisor or other independent person that checks the results of the first person's work and signs off when i
When MC&A data processing is automated, quality control systems should also be automated, so that out-of-tolerance conditions,
the work is complete and accurate.
,            hu: nan errors, and other warnings can be detected and corrective i           actions can be taken promptly.
Each data collection form should be checked by the originator to verify that the data are accurate.
When MC&A data processing is automated, quality control systems should also be automated, so that out-of-tolerance conditions, hu: nan errors, and other warnings can be detected and corrective i
actions can be taken promptly.
A configuration management plan should be established for vital l
A configuration management plan should be established for vital l
MC&A equipment, computer software, and manuals.
MC&A equipment, computer software, and manuals.
Configuration control measures should be performed systematically and immediately reflect all changes as they are made.
Configuration control measures should be performed systematically and immediately reflect all changes as they are made.
Procedures and technical manuals should be stored, indexed, filed, and controlled in a manner that ensures easy retrieval and avail bility.
Procedures and technical manuals should be stored, indexed, filed, and controlled in a manner that ensures easy retrieval and avail bility.
The quality of operations and maintenance manuals should be one criterion in selecting between vendors when purchasing new                               '
The quality of operations and maintenance manuals should be one criterion in selecting between vendors when purchasing new I
I          equipment.
equipment.
MC&A equipment and computer software manuals supplied by vendors should be specific to the equipment model purchased and contain
MC&A equipment and computer software manuals supplied by vendors should be specific to the equipment model purchased and contain explicit troubitshooting, calibrating, and repair instructions l
,          explicit troubitshooting, calibrating, and repair instructions l           for hardware and coding and application instructions, if software                       [
for hardware and coding and application instructions, if software
[
is used.
is used.
79 l
79 l


    .v T
.v T
Personnel should perform quality control and quality assurance activities that are specified in the procedures.
Personnel should perform quality control and quality assurance activities that are specified in the procedures.
t             .o     Estimates of human error rates should be based on a human reliability
t
;                    analysis of the data collection process to determine a reasonable rcte of human error in MC&A data for the specific licensee.           ;
.o Estimates of human error rates should be based on a human reliability analysis of the data collection process to determine a reasonable rcte of human error in MC&A data for the specific licensee.
Reasonable estimates of human error rates should include input
Reasonable estimates of human error rates should include input regarding equipment design, plant policies and practices, and written procedures.
:                          regarding equipment design, plant policies and practices, and written procedures.
Reasonable estimates of human error rates should include input l
Reasonable estimates of human error rates should include input l                           regarding situational and personnel factors that may produce errors.
regarding situational and personnel factors that may produce errors.
Any potential problems that can reasonably be resolved following l                           a human reliability analysis should be resolved and the estimate of a reasonable error rate should be recalculated.
Any potential problems that can reasonably be resolved following l
a human reliability analysis should be resolved and the estimate of a reasonable error rate should be recalculated.
Questions and Answers.
Questions and Answers.
: 1.     Q:   What are some job performance aids that are used successfully?
1.
A:   Several job performance aids (JPA) are illustrations and diagrams, graphs for interpolation, approximate times to complete specific
Q:
.                    jobs, clearly stated decision-making cues and clues to the correct
What are some job performance aids that are used successfully?
<                  decision given specific cues, and data reduction aids. JPAs are good l                   as long as they do not cause the procedure to become difficult to use l                   because of too many aids, the wrong types of aids for that application, or presentation in an inappropriate manner. If the procedure can be written so than an cyperienced user can omit unnecessary aids meant for novice users, that in itself is a JPA and
A:
:                    will encourage procedure usage.
Several job performance aids (JPA) are illustrations and diagrams, graphs for interpolation, approximate times to complete specific jobs, clearly stated decision-making cues and clues to the correct decision given specific cues, and data reduction aids.
t
JPAs are good l
: 2.     Q:   Some of the notation and labels used on equipment at specific facilities may not be current with respect to recommen/cd
as long as they do not cause the procedure to become difficult to use l
;                    terminology. Should procedures use current terminology, or be
because of too many aids, the wrong types of aids for that application, or presentation in an inappropriate manner.
!                    consistent with the equipment?
If the procedure can be written so than an cyperienced user can omit unnecessary aids meant for novice users, that in itself is a JPA and will encourage procedure usage.
t 2.
Q:
Some of the notation and labels used on equipment at specific facilities may not be current with respect to recommen/cd terminology.
Should procedures use current terminology, or be consistent with the equipment?
1
1
}
}
j               A:   Ideally, equipment should be brought into compliance with the current i
j A:
idea of "best" notation on labels and panels. However, confusion could occur because personnel at the facility are accustomed to that terminology, so these labels probably should not be changed. In any case, procedure terminology should be consistent with equipment, as
Ideally, equipment should be brought into compliance with the current idea of "best" notation on labels and panels.
;                    should forms and other information to be employed by personnel at the l                   facility.
However, confusion i
(       3.     Q:   Why should there be no more than three actions per step in a I                   procedure?
could occur because personnel at the facility are accustomed to that terminology, so these labels probably should not be changed.
A:   By restricting the amount of information that personnel are required to remember while performing a procedure, there is a greater probability that the procedure will be performed correctly.
In any case, procedure terminology should be consistent with equipment, as should forms and other information to be employed by personnel at the l
facility.
(
3.
Q:
Why should there be no more than three actions per step in a I
procedure?
A:
By restricting the amount of information that personnel are required to remember while performing a procedure, there is a greater probability that the procedure will be performed correctly.
Remembering precise, numerical information is not a task that humans 80
Remembering precise, numerical information is not a task that humans 80


                                                                                                      ,      l t
t perform well.
perform well.     Using checklists or pre printed forms are methods to limit the amount of memorization required while reducing dependence on often bulky procedures.
Using checklists or pre printed forms are methods to limit the amount of memorization required while reducing dependence on often bulky procedures.
: 4. Q:   Why should an independent observer be used to sign off on checklists and other work?
4.
A: aan independent observer is useful in the event that a person makes a mistake, since an independent observer will often see mistakes               'l
Q:
;-                          whereas the person who made the original mistake, using the same logic or reviewing the work rather quickly, will be unable to 1
Why should an independent observer be used to sign off on checklists and other work?
A:
aan independent observer is useful in the event that a person makes a mistake, since an independent observer will often see mistakes
'l whereas the person who made the original mistake, using the same logic or reviewing the work rather quickly, will be unable to 1
recognize the problem.
recognize the problem.
: 5. Q:   What is configuration control and how is it applied to procedures?
5.
A: -Configuration control is a method by which the current official copies of procedures are maintained and controlled. Procedures that may be used in configuration control include sign offs by a responsible person on the released version, numbering and dating versions, and periodic checks of the individual procedures under the control of the procedure custodian or holder to make sure that current copies are being used.
Q:
: 6. Q:   What level of human error is reasonably achievable in MC&A data?
What is configuration control and how is it applied to procedures?
i                       A:   A reasonable amount of human error in MC&A data depends on the
A:
!                            systems that are in place to provide checks and balances to reduce errors. An effective program to reduce human error would employ I
-Configuration control is a method by which the current official copies of procedures are maintained and controlled.
techniques that limit human error by reducing the chances for errors to be made and not creating error-likely situations in the design of the work. However, without totally eliminating the human element from MC&A, there is no way to eliminate human error totally. Table 1 lists some of the applicable human error rates and situational multipliers from Swain and Guttmann (1983).
Procedures that may be used in configuration control include sign offs by a responsible person on the released version, numbering and dating versions, and periodic checks of the individual procedures under the control of the procedure custodian or holder to make sure that current copies are being used.
6.
Q:
What level of human error is reasonably achievable in MC&A data?
i A:
A reasonable amount of human error in MC&A data depends on the systems that are in place to provide checks and balances to reduce errors.
An effective program to reduce human error would employ I
techniques that limit human error by reducing the chances for errors to be made and not creating error-likely situations in the design of the work.
However, without totally eliminating the human element from MC&A, there is no way to eliminate human error totally.
Table 1 lists some of the applicable human error rates and situational multipliers from Swain and Guttmann (1983).
I l
I l
I l
I l
Line 1,975: Line 2,895:


s i
s i
Table 1 Errors Rate Associated with MC&A Data Collection These values are adapted from Swain and Guttmann and reflect some typical error probabilities for human activities in the MC&A process. For additional data and information on its usage, please refer to the cited document.
Table 1 Errors Rate Associated with MC&A Data Collection These values are adapted from Swain and Guttmann and reflect some typical error probabilities for human activities in the MC&A process.
Potential Error                                                                             Estimated Error Rate Failure to perform rule-based actions correctly when written procedures are available and used.............                                               .005 written procedures are not available or used..........                                                 1.0 Omitting a step or important instruction from a fo rmal p rocedu re. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .         .003 oral   instructions......................................                                       negligible Writing an item incorrectly in response to a fo rmal p rocedu re. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .         .003 oral   instructions......................................                                       negligible Carrying out a plant policy scheduled task such as periodic tests performed weekly, monthly, etc.......................                                                 .01 Using a written test or calibration procedure properly.....                                                 .01 Using a checklist     properly.................................                                               .5 Omitting items when procedures have check-off provisions and are correctly used........................................                                               .003 incorrectly used......................................                                                 .01 Omitting items when written procedures are available and are
For additional data and information on its usage, please refer to the cited document.
:    not used...............................................                                                     .05 e
Potential Error Estimated Error Rate Failure to perform rule-based actions correctly when written procedures are available and used.............
Errors of commission in reading and recording quantitative information from unannunciated displays analog meter..........................................                                               .003 digital readout.......................................                                               .001 chart recorder........................................                                               .006 printing recorder with large number of parameters.....                                                 .05 graphs................................................                                                 .01 recording tasks... ...................................                                               .005 simple arithmetic calculation.........................                                                 .01 Estimated probabilities that a checker will fail to detect errors made by others routine tasks, checker uses written materials.........                                                   .1 routine tasks, checker uses no written materials. . . . . .                                             .2 one-of-a-kind checking with alerting factors. . . . . . . . . .                                       .05 special measurements..................................                                                 .01 82
.005 written procedures are not available or used..........
1.0 Omitting a step or important instruction from a fo rmal p rocedu re....................................
.003 oral instructions......................................
negligible Writing an item incorrectly in response to a fo rmal p rocedu re....................................
.003 oral instructions......................................
negligible Carrying out a plant policy scheduled task such as periodic tests performed weekly, monthly, etc.......................
.01 Using a written test or calibration procedure properly.....
.01 Using a checklist properly.................................
.5 Omitting items when procedures have check-off provisions and are correctly used........................................
.003 incorrectly used......................................
.01 Omitting items when written procedures are available and are not used...............................................
.05 e
Errors of commission in reading and recording quantitative information from unannunciated displays analog meter..........................................
.003 digital readout.......................................
.001 chart recorder........................................
.006 printing recorder with large number of parameters.....
.05 graphs................................................
.01 recording tasks......................................
.005 simple arithmetic calculation.........................
.01 Estimated probabilities that a checker will fail to detect errors made by others routine tasks, checker uses written materials.........
.1 routine tasks, checker uses no written materials......
.2 one-of-a-kind checking with alerting factors..........
.05 special measurements..................................
.01 82


3 Table-1 (Continued)
3 Table-1 (Continued)
Modifications of estimated error rates for the effects of stress and experience level low stress............................................                 x2 optimum stress........................................                 x1 moderately high stress novice...........................................               x4 skilled..........................................               x2 extremely high stress (life threatening) novice...........................................               x10 skilled..........................................               x5 4.10 Independent Assessment
Modifications of estimated error rates for the effects of stress and experience level low stress............................................
      . Requirement:   The rule requires that a licensee independently assess the past performance of the MC&A system and review its effectiveness at least once every 12 months, including management's action on prior assessment recommenda-tions (S 74.59(h)(4)).
x2 optimum stress........................................
Intent and Scope:     The intent of the independent assessment of the MC&A system is to periodically review the system performance from an effectiveness perspective relative to the performance objectives defined in $74.51(a) and the system capabilities defined in $74.51(b).
x1 moderately high stress novice...........................................
Plan / Annex Content:   The FNMC Plan contains the following affirmations and detailed commitments. Supporting information, as appropriate, is included in the Annex.
x4 skilled..........................................
x2 extremely high stress (life threatening) novice...........................................
x10 skilled..........................................
x5 4.10 Independent Assessment
. Requirement:
The rule requires that a licensee independently assess the past performance of the MC&A system and review its effectiveness at least once every 12 months, including management's action on prior assessment recommenda-tions (S 74.59(h)(4)).
Intent and Scope:
The intent of the independent assessment of the MC&A system is to periodically review the system performance from an effectiveness perspective relative to the performance objectives defined in $74.51(a) and the system capabilities defined in $74.51(b).
Plan / Annex Content:
The FNMC Plan contains the following affirmations and detailed commitments.
Supporting information, as appropriate, is included in the Annex.
Section 4.10 of the Plan includes the following affirmations:
Section 4.10 of the Plan includes the following affirmations:
o     An effectiveness evaluation of the entire MC&A system is performed at e       least every 12 months, o     The assessment is performed by technically qualified individuals whose organizational positions and normal work assignments will not interfere with their ability to make objective decisions.
o An effectiveness evaluation of the entire MC&A system is performed at e
o     The assessment team leader will have no responsibility for performing or directly managing any part of the MC&A program.
least every 12 months, o
!      o     The details and results of the assessments and recommended corrective 7
The assessment is performed by technically qualified individuals whose organizational positions and normal work assignments will not interfere with their ability to make objective decisions.
o The assessment team leader will have no responsibility for performing or directly managing any part of the MC&A program.
o The details and results of the assessments and recommended corrective 7
actions are documented and reported to the plant manager.
actions are documented and reported to the plant manager.
I
I
~
~
o    Management will receive the assessment report and take the actions necessary to correct identified deficiencies.
Management will receive the assessment report and take the actions o
l       o     The actions taken to correct deficiencies are documented and reviewed l             during the subsequent assessment.
necessary to correct identified deficiencies.
l o
The actions taken to correct deficiencies are documented and reviewed l
during the subsequent assessment.
l t
l t
l 83 t
l 83 t
Line 1,999: Line 2,957:
s, 4.10.1 Assessment Program Describe the structure of the program including:
s, 4.10.1 Assessment Program Describe the structure of the program including:
The means of assuring independence of action and objectivity of decision; The technical qualifications of and the selection criteria for team members; The planned objective and sccpe of the assessment listing the general areas to be covered; and The organizational positions responsible for initiating the assessment, approving the membership of the assessment team, implementing the corrective actions that are deemed necessary, and providing follow-up action to assure that corrective actions have been implemented.
The means of assuring independence of action and objectivity of decision; The technical qualifications of and the selection criteria for team members; The planned objective and sccpe of the assessment listing the general areas to be covered; and The organizational positions responsible for initiating the assessment, approving the membership of the assessment team, implementing the corrective actions that are deemed necessary, and providing follow-up action to assure that corrective actions have been implemented.
In the Annex, provide a checklist of the fu.nctions to be reviewed in each area. Regulatory Guide 5.51 may be used as appropriate.
In the Annex, provide a checklist of the fu.nctions to be reviewed in each area.
Acceptance Criteria:                   The assessment of the adequacy of the information supplied above will be based on the following criteria:
Regulatory Guide 5.51 may be used as appropriate.
o      The assessment will include a comprehensive review of the MC&A system to independently assess the system design and evaluate its capabilities to achieve the general safeguards objectives and an audit and inspec-tion of the system performance, carried out in sufficient depth, to detect deficiencies or weaknesses in either the system design or implementation.
Acceptance Criteria:
o    The assessment encompasses the entire MC&A system with particular emphasis on abrupt loss detection, item control, and alarm resolution.
The assessment of the adequacy of the information supplied above will be based on the following criteria:
The emphasis is justified on the basis that these functions provide the primary assurance that no loss has occurred. The assessment program provides objective measure of:
The assessment will include a comprehensive review of the MC&A system o
Management effectiveness and responsiveness to indications of possible loss, Staff training and qualifications for particular job functions, Quality control of measurements and process variability, Timeliness of loss detection and response to alarms, and Alarm resolution effectiveness.                                                                                     '
to independently assess the system design and evaluate its capabilities to achieve the general safeguards objectives and an audit and inspec-tion of the system performance, carried out in sufficient depth, to detect deficiencies or weaknesses in either the system design or implementation.
o     The personnel assigned to the assessment team will have an understand-ing of the objectives and requirements applicable to the MC&A system and have sufficient knowledge and experience to be able to assess the adequacy of the function they are requested to review. The team 84 1
The assessment encompasses the entire MC&A system with particular o
emphasis on abrupt loss detection, item control, and alarm resolution.
The emphasis is justified on the basis that these functions provide the primary assurance that no loss has occurred.
The assessment program provides objective measure of:
Management effectiveness and responsiveness to indications of possible loss, Staff training and qualifications for particular job functions, Quality control of measurements and process variability, Timeliness of loss detection and response to alarms, and Alarm resolution effectiveness.
o The personnel assigned to the assessment team will have an understand-ing of the objectives and requirements applicable to the MC&A system and have sufficient knowledge and experience to be able to assess the adequacy of the function they are requested to review.
The team 84 1


o will not include MC&A management personnel but may include other MC&A staff provided no individual reviews his/her own area of responsibility nor the area of another MC&A team member.
o will not include MC&A management personnel but may include other MC&A staff provided no individual reviews his/her own area of responsibility nor the area of another MC&A team member.
o     The responsibility and authority for the assessment program and for initiating corrective actions is at least one organizational level higher than the MC&A manager.
o The responsibility and authority for the assessment program and for initiating corrective actions is at least one organizational level higher than the MC&A manager.
o     Outside contractor laboratories should be included in the the 12 months assessments.
o Outside contractor laboratories should be included in the the 12 months assessments.
4.11 SSNM Custodianship Requirement: The rule requires that a licensee assign custodial responsi-bility for all SSNM possessed under licensee in a manner that ensures that such responsibility can be effectively executed ($ 74.59(h)(5)).
4.11 SSNM Custodianship Requirement:
Intent and Scope:     The intent of this requirement is that there be a designated individual who is responsible for having knowledge of the placement and movement of SSNM within a specified area and transfers into and out of the area. Such an individual should be vested with the authority to obtain the information necessary to accomplish his/her. task and to assure that activities are carried out in accordance with approved policies and procedures.
The rule requires that a licensee assign custodial responsi-bility for all SSNM possessed under licensee in a manner that ensures that such responsibility can be effectively executed ($ 74.59(h)(5)).
Plan / Annex Content: ,The FNMC Plan contains the following affirmations and detailed commitments. Supporting information, as appropriate, is included in the Annex.
Intent and Scope:
The intent of this requirement is that there be a designated individual who is responsible for having knowledge of the placement and movement of SSNM within a specified area and transfers into and out of the area.
Such an individual should be vested with the authority to obtain the information necessary to accomplish his/her. task and to assure that activities are carried out in accordance with approved policies and procedures.
Plan / Annex Content:,The FNMC Plan contains the following affirmations and detailed commitments.
Supporting information, as appropriate, is included in the Annex.
5 Section 4.11 of the Plan include the following affirmations:
5 Section 4.11 of the Plan include the following affirmations:
e o     The SSNM processing facility is subdivided into a sufficient number of areas to ensure that custodial responsibilities can be effectively executed.
e o
o     A custodian and a minimum number of alternates are designated for l             each area subdivision.
The SSNM processing facility is subdivided into a sufficient number of areas to ensure that custodial responsibilities can be effectively executed.
l       o     Transfers of SSNM between areas of offferent custodial responsibility l             are measured for element and isotope, as appropriate, and results are i
o A custodian and a minimum number of alternates are designated for l
each area subdivision.
l o
Transfers of SSNM between areas of offferent custodial responsibility l
are measured for element and isotope, as appropriate, and results are i
documented on signed tranfer receipts.
documented on signed tranfer receipts.
1 4.11.1 Custodial Areas Identify the areas into which the facility will be devided to assure that custodianship can be effectively executed.         Reference to facility drawings included in the Annex is acceptable.
1 4.11.1 Custodial Areas Identify the areas into which the facility will be devided to assure that custodianship can be effectively executed.
Reference to facility drawings included in the Annex is acceptable.
4.11.2 Duties / Authority l
4.11.2 Duties / Authority l
Describe the duties of the SSNM custodians including defined authorities.
Describe the duties of the SSNM custodians including defined authorities.
Line 2,024: Line 2,997:
85
85


Acceptance Criteria:   The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent.
Acceptance Criteria:
o   Except for the stipulations that all SSNM crossing custodial area boundaries must be measured and custodians must be able to effectively execute their duties, there are no restrictions on how large an area can be. However, different MAAs should have different custodians, and within MAAs, areas with widely divergent functions should have different custodians. An example of the latter situation would be a fabrication plant where bulk material is handled in one area in the preparation of the fuel component of an element, and a second area is involved with machining and preparation of the element for higher tier fabrication.
The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent.
o   A current listing of designated custodians and alternates should be maintained, o   Custodians should be 'amiliar with SSNM processing activities as well as MC&A functions. A minimum of one year of experience in each of 4
o Except for the stipulations that all SSNM crossing custodial area boundaries must be measured and custodians must be able to effectively execute their duties, there are no restrictions on how large an area can be.
these areas is desirable, o   Custodians should not be appointed from production or production control to preclude the possibility of conflicts of interest.
However, different MAAs should have different custodians, and within MAAs, areas with widely divergent functions should have different custodians.
i 86 L                                                                                         - _
An example of the latter situation would be a fabrication plant where bulk material is handled in one area in the preparation of the fuel component of an element, and a second area is involved with machining and preparation of the element for higher tier fabrication.
o A current listing of designated custodians and alternates should be maintained, o
Custodians should be 'amiliar with SSNM processing activities as well as MC&A functions.
A minimum of one year of experience in each of these areas is desirable, 4
o Custodians should not be appointed from production or production control to preclude the possibility of conflicts of interest.
i 86 L


1 O
1 O
;          References ANSI N15.36.         Non-Destructive Assay Measurement Control and Assurance.
References ANSI N15.36.
American National Standards Institute, New York, New York (in preparation).                     :
Non-Destructive Assay Measurement Control and Assurance.
ANSI N15.41.         Guide to Nuclear Facility Measurement Control.       American National Standards Institute, New York, New York (in preparation).
American National Standards Institute, New York, New York (in preparation).
Augustson, R. H. 1978. DYMAC Demonstration Program: Phase I Experience.
ANSI N15.41.
Guide to Nuclear Facility Measurement Control.
American National Standards Institute, New York, New York (in preparation).
Augustson, R. H.
1978.
DYMAC Demonstration Program:
Phase I Experience.
LA-7126-MS, Los Alamos Scientific Laboratory, Los Alamos, New Mexico.
LA-7126-MS, Los Alamos Scientific Laboratory, Los Alamos, New Mexico.
Bowen, W. M.         1982. Evaluation of Simultaneous Testing Procedures for Nuclear
Bowen, W. M.
!              Materials Control and Accounting. NUREG/CR-2483 (PNL-4085), Pacific Northwest Laboratory, Richland, Washington.
1982.
Evaluation of Simultaneous Testing Procedures for Nuclear Materials Control and Accounting.
NUREG/CR-2483 (PNL-4085), Pacific Northwest Laboratory, Richland, Washington.
i i
i i
Brouns, R. J. and J. E. Fager. 1982. Detection Time Guidance. (Draft submitted to NMSS Division of Safeguards, January 1982.) Pacific Northwest Laboratory, Richland, Washington.
Brouns, R. J. and J. E. Fager.
Brouns, R. J. and F. P. Roberts. 1980. Training and Qualifying Personnel for                       ,
1982.
Performina Measurements for the Control and Accounting of Special Nuclear Material. NUREG/CR-0773 (PNL-3020). Pacific Northwest Laboratory, Richland, l             Washington.
Detection Time Guidance.
i
(Draft submitted to NMSS Division of Safeguards, January 1982.) Pacific Northwest Laboratory, Richland, Washington.
;          Brouns, R. J.,         F. P. Roberts, J. A. Merrill, and W. B. Brown.     1980. A i             Measurement Control Program for Nuclear Material Accounting. NUREGRR-0829 (PNL-3021). Pacific Northwest Laboratory, Richland, Washington.
Brouns, R. J. and F. P. Roberts.
Brouns, R. J.,         B. W. Smith, D. W. Brite, and C. O. Harvey. 1980. The Use of Process Monitoring Data for Nuclear Material Accounting: Vol. 1. Summary i             Report. NUREG/CR-1670 (PNL-3396). Pacific Northwest Laboratory, Richland, j             Washington. (Available in abbreviated form as R. J. Brouns and B. W. Smith.
1980.
j             1980. "The Use of Process Monitoring Data to Enhance Material Accounting."
Training and Qualifying Personnel for Performina Measurements for the Control and Accounting of Special Nuclear Material.
i             In Proceedings of the Institute of Nuclear Materials Management Meeting, IX,,
NUREG/CR-0773 (PNL-3020).
i             pp. 688-696.           Chicago, Illinois.)
Pacific Northwest Laboratory, Richland, l
i Cobb, D. D.     1981.         " Sequential Tests for Near-Real-Time Accounting." In               <
Washington.
Proceedings of the Institute of Nuclear Materials Management Meeting, X, pp. 62-70. Chicago, Illinois.
i Brouns, R.
David, H. A.         1970.     Order Statistics. John Wiley & Sons, New York.
J., F. P. Roberts, J. A. Merrill, and W. B. Brown.
Duggan, W. P., K. R. Byers, and L. Hulse.               1981. Criteria for Response to l             Special Nuclear Material and Control and Accounting System Alarms. NUREG/CR-
1980.
;            2399 (PNL-4091). Draft Report to the NRC. Pacific Northwest Laboratory, l             Richland, Washington.
A i
i Eggers, R. F. 1981. Detath.a Response to Alarms. Unpublished Report to the i             NRC. Pacific Northwest Laboratory, Richland, Washington.
Measurement Control Program for Nuclear Material Accounting.
I i           Eggers, R. F. 1982. Design Aids for Estimating the Frequency of Occurrence of
NUREGRR-0829 (PNL-3021).
(             Unresolved Plant-Wide False Alarms. Unpublished Report to the NRC. Pacific l             Northwest Laboratory, Richland, Washington.                                                     '
Pacific Northwest Laboratory, Richland, Washington.
l l                                                             87 I
Brouns, R.
J., B. W. Smith, D. W. Brite, and C. O. Harvey.
1980.
The Use of Process Monitoring Data for Nuclear Material Accounting:
Vol. 1. Summary i
Report.
NUREG/CR-1670 (PNL-3396).
Pacific Northwest Laboratory, Richland, j
Washington.
(Available in abbreviated form as R. J. Brouns and B. W. Smith.
j 1980.
"The Use of Process Monitoring Data to Enhance Material Accounting."
i In Proceedings of the Institute of Nuclear Materials Management Meeting, IX,,
i pp. 688-696.
Chicago, Illinois.)
i Cobb, D. D.
1981.
" Sequential Tests for Near-Real-Time Accounting."
In Proceedings of the Institute of Nuclear Materials Management Meeting, X, pp. 62-70.
Chicago, Illinois.
David, H. A.
1970.
Order Statistics.
John Wiley & Sons, New York.
Duggan, W. P., K. R. Byers, and L. Hulse.
1981.
Criteria for Response to l
Special Nuclear Material and Control and Accounting System Alarms.
NUREG/CR-2399 (PNL-4091).
Draft Report to the NRC.
Pacific Northwest Laboratory, l
Richland, Washington.
i Eggers, R. F.
1981.
Detath.a Response to Alarms.
Unpublished Report to the i
NRC.
Pacific Northwest Laboratory, Richland, Washington.
I i
Eggers, R. F.
1982.
Design Aids for Estimating the Frequency of Occurrence of
(
Unresolved Plant-Wide False Alarms.
Unpublished Report to the NRC.
Pacific l
Northwest Laboratory, Richland, Washington.
l l
87 I


                                                  - - -        .-        -    .      --                    ,__    -  =___
=___
                'Eisenhart, C., M. W. Hastay, and W. A. Wallis. 1947.                     Selected Techniques of Statistical Analysis. McGraw-Hill, New York.
'Eisenhart, C., M. W. Hastay, and W. A. Wallis.
Glancy, J.     E., G. Borgonovi, S. Donelson, et al.             1980. Feasibility and Cost /
1947.
Selected Techniques of Statistical Analysis.
McGraw-Hill, New York.
Glancy, J.
E., G. Borgonovi, S. Donelson, et al.
1980.
Feasibility and Cost /
Benefit of Advanced Safeguards for Control of Nuclear Material In-Process.
Benefit of Advanced Safeguards for Control of Nuclear Material In-Process.
NUREG/CR-1686 Vol. 1 (SAI 01580-343LJ). Science Applications, Inc.,
NUREG/CR-1686 Vol. 1 (SAI 01580-343LJ).
Science Applications, Inc.,
La Jolla, California.
La Jolla, California.
Graybill, F. A.         1976. Theory and Application of the Linear Model.             Duxbury Press, North Scituate, Massachusetts.
Graybill, F. A.
Hakkila, E. A., J. W. Barnes, T. R. Canada, et al.                   1977. Coordinated Safeguards for Materials Management in a Fuel Reprocessing Plant.                 Appendix.
1976.
(Part E), LA-6881, Vol. II.           Los Alamos Scientific Laboratory, Los Alamos, New Mexico.
Theory and Application of the Linear Model.
i                 Hakkila, E.     A., D. D. Cobb, H. A. Dayem, et al.           1980. Materials Management in an Internationally Safeguarded Fuels Reprocessing Plant.                 LA-8042, Vols. 1, 2, and 3.     Los Alamos Scientific Laboratory, Los Alamos, New Mexico.
Duxbury Press, North Scituate, Massachusetts.
Hawkins, R.     L., R. L. Lynch, and R. F. Lumb.           1980. Using Advanced Process Monitoring to Improve Material Control.             NUREG/CR-1676, Vol. 1 (NUSAC-556).
Hakkila, E.
A., J. W. Barnes, T. R. Canada, et al.
1977.
Coordinated Safeguards for Materials Management in a Fuel Reprocessing Plant.
Appendix.
(Part E), LA-6881, Vol. II.
Los Alamos Scientific Laboratory, Los Alamos, New Mexico.
i Hakkila, E.
A., D. D. Cobb, H. A. Dayem, et al.
1980.
Materials Management in an Internationally Safeguarded Fuels Reprocessing Plant.
LA-8042, Vols. 1, 2, and 3.
Los Alamos Scientific Laboratory, Los Alamos, New Mexico.
Hawkins, R.
L.,
R. L. Lynch, and R. F. Lumb.
1980.
Using Advanced Process Monitoring to Improve Material Control.
NUREG/CR-1676, Vol. 1 (NUSAC-556).
Nuclear Surveillance and Auditing Corporation, McLean, Virginia.
Nuclear Surveillance and Auditing Corporation, McLean, Virginia.
1
1 Hurt, R. D.,
;                Hurt, R.     D., S. J. Hure11, J. W. Wachter, et al. 1982. Experimental
S. J. Hure11, J. W. Wachter, et al.
!                      Demonstration of Microscopic Process Monitoring.             ORNL/TM-7848, Oak Ridge i
1982.
Experimental Demonstration of Microscopic Process Monitoring.
ORNL/TM-7848, Oak Ridge i
National Laboratory, Oak Ridge, Tennessee.
National Laboratory, Oak Ridge, Tennessee.
IAEA Safeguards Technical Manual, Part F - Statistical Concepts and Techniques.
IAEA Safeguards Technical Manual, Part F - Statistical Concepts and Techniques.
1977. IAEA-174, International Atomic Energy Agency, Vienna, Austria.
1977.
,                Jaech, J. L.       1973. Statistical Methods in Nuclear Material Control.                 TID-26298.
IAEA-174, International Atomic Energy Agency, Vienna, Austria.
Jaech, J. L.
1973.
Statistical Methods in Nuclear Material Control.
TID-26298.
National Technical Information Service, Springfield, Virginia.
National Technical Information Service, Springfield, Virginia.
Jaech, J. L.       1977. "On Forming Linear Combinations of Accounting Data to Detect Constant Small Losses." J. Nucl. Mater. Manage., VI(4):37-42.
Jaech, J. L.
l                 Juran, J. M. (ed.).         1951.       Quality Control Handbook.       McGraw-Hill Book Company,
1977.
;                      Inc., New York, New York.
"On Forming Linear Combinations of Accounting Data to Detect Constant Small Losses."
i                 Lumb and Associates 1986.               Inventory Difference Evaluation Program (INDEP)
J. Nucl. Mater. Manage., VI(4):37-42.
Lumb, R. and Tingey, F.               1981. Mathematical Derivation of the Automated i                       Material Accounting Statistics System (AMASS).             Nuclear Surveillance and Auditing Corporation. McLean, Virginia.
l Juran, J. M. (ed.).
Markin, J. T., A. L. Baker, and J. P. Shipley.                 1980.   " Implementing Advanced Data Analyses Techniques in Near-Real-Time Materials Accounting." In Proceedings of the Institute of Nuclear Materials Management Meeting, IX,
1951.
!                      pp. 236-244. Chicago, Illinois.
Quality Control Handbook.
!                Miles, J. C., J. E. Glancy, and S. E. Donelson.                 1979. Use of Process Mon-itoring Data for the Enhancement of Nuclear Material Control and Accounting.
McGraw-Hill Book Company, Inc., New York, New York.
NUREG/CR-1013 (MLM-2643). Mound Laboratories, Miamisburg, Ohio, and Science l                     Applications, Inc., La Jolla, California.
i Lumb and Associates 1986.
Inventory Difference Evaluation Program (INDEP)
Lumb, R. and Tingey, F.
1981.
Mathematical Derivation of the Automated i
Material Accounting Statistics System (AMASS).
Nuclear Surveillance and Auditing Corporation.
McLean, Virginia.
Markin, J.
T., A. L. Baker, and J. P. Shipley.
1980.
" Implementing Advanced Data Analyses Techniques in Near-Real-Time Materials Accounting."
In Proceedings of the Institute of Nuclear Materials Management Meeting, IX, pp. 236-244.
Chicago, Illinois.
Miles, J.
C., J. E. Glancy, and S. E. Donelson.
1979.
Use of Process Mon-itoring Data for the Enhancement of Nuclear Material Control and Accounting.
NUREG/CR-1013 (MLM-2643).
Mound Laboratories, Miamisburg, Ohio, and Science l
Applications, Inc., La Jolla, California.
88 t
88 t


Reardon, P.               T., S. W. Heaberlin, and R. F. Eggers.             1982. "An Assessment Method to Predict the Rate of Unresolved False Alarms," In Proceedings of the Institute of Nuclear Materials Mangement Meeting, XI, pp. 278-282. Chicago, Illinois.
Reardon, P.
Reilly, T. D. and M. L. Evans. 1977. Measurement Reliability for Nuclear Material Assay, LA-6574. Los Alamos Scientific Laboratory, Los Alamos, New Mexico.
T., S. W. Heaberlin, and R. F. Eggers.
Rogers, D. R. (ed.).                 1983. Handbook of Nuclear Safeguards Measurement Methods, NUREG/CR-2078 (MLM-2855). Mound Laboratories, Miamisburg, Ohio.
1982.
Rose, D. M. and F. W. Scholz.                 1983. Statistical Analysis of Cumulative Shipper-Receiver Data.               NUREG/CR-2819 (BCS 40384-0). Boeing Computer Services Company, Tukwilla, Washington.
"An Assessment Method to Predict the Rate of Unresolved False Alarms," In Proceedings of the Institute of Nuclear Materials Mangement Meeting, XI, pp. 278-282.
Rudy, C. R. , D. B. Armstrong, K. W. Foster, D. R. Rogers, and D. R. Hill.                           1982.
: Chicago, Illinois.
Controlled Unit Approach: An Application Manual.                           NUREG/CR-2538 (MLM-2881).
Reilly, T. D. and M. L. Evans.
1977.
Measurement Reliability for Nuclear Material Assay, LA-6574.
Los Alamos Scientific Laboratory, Los Alamos, New Mexico.
Rogers, D. R. (ed.).
1983.
Handbook of Nuclear Safeguards Measurement Methods, NUREG/CR-2078 (MLM-2855).
Mound Laboratories, Miamisburg, Ohio.
Rose, D. M. and F. W. Scholz.
1983.
Statistical Analysis of Cumulative Shipper-Receiver Data.
NUREG/CR-2819 (BCS 40384-0).
Boeing Computer Services Company, Tukwilla, Washington.
Rudy, C. R., D. B. Armstrong, K. W. Foster, D. R. Rogers, and D. R. Hill.
1982.
Controlled Unit Approach:
An Application Manual.
NUREG/CR-2538 (MLM-2881).
Mound Facility, Miamisburg, Ohio.
Mound Facility, Miamisburg, Ohio.
Seabaugh, P. W. , D. R. Rogers, H. A. Woltermann, et al. 1980. The Controllable Unit A?proach to Material Control:                         Application to a High Throughout Mixed 0xide )rocess. NUREG/CR-1214, Vols. 1, 2, and 3 (MLM-2532).                             Mound Laboratories, Miamisburg, Ohio.
Seabaugh, P. W., D. R. Rogers, H. A. Woltermann, et al.
Shewhart, W. A. 1931. Economic Control of Quality of Manufactured Products.
1980.
The Controllable Unit A?proach to Material Control:
Application to a High Throughout Mixed 0xide )rocess.
NUREG/CR-1214, Vols. 1, 2, and 3 (MLM-2532).
Mound Laboratories, Miamisburg, Ohio.
Shewhart, W. A.
1931.
Economic Control of Quality of Manufactured Products.
D. Van Nostrand Co., New York.
D. Van Nostrand Co., New York.
Shipley, J. P.               1981. " Decision-Directed Materials Accounting Procedures: An Overview." In Proceedings of the Institute of Nuclear Materials Management Meeting, X, pp. 281-287. Chicago, Illinois.
Shipley, J. P.
Smith, B. W., J. E. Fager, K. R. Byers, and R. F., Eggers. 1983. Testing of Safeguards Alarm Resolution Procedures in a Scrap Recovery Facility. Draft Report to the NRC. Pacific Northwest Laboratory, Richland, Washington.
1981.
Stewart, K. B.               1978. "The Loss Detection Powers of Four Loss Estimators."
" Decision-Directed Materials Accounting Procedures:
An Overview."
In Proceedings of the Institute of Nuclear Materials Management Meeting, X, pp. 281-287.
Chicago, Illinois.
Smith, B. W., J. E. Fager, K. R. Byers, and R. F.,
Eggers.
1983.
Testing of Safeguards Alarm Resolution Procedures in a Scrap Recovery Facility.
Draft Report to the NRC.
Pacific Northwest Laboratory, Richland, Washington.
Stewart, K. B.
1978.
"The Loss Detection Powers of Four Loss Estimators."
J. Nucl. Mater. Manage., VII(3):74-80.
J. Nucl. Mater. Manage., VII(3):74-80.
Swain, A. D. and H. E. Guttmann, August 1983. Handbook of Human Reliability Analysis with Emphasis on Nuclear Power Plant Applications. NUREG/CR-1278.
Swain, A. D. and H. E. Guttmann, August 1983.
Handbook of Human Reliability Analysis with Emphasis on Nuclear Power Plant Applications.
NUREG/CR-1278.
Sandia National Laboratories, Albuquerque, New Mexico.
Sandia National Laboratories, Albuquerque, New Mexico.
Tanner, J. 1981. False Alarm Resolution Assessment Methodology, Unpublished Report to the NRC. Pacific Northwest Laboratory, Richland, Washington.
Tanner, J.
Tingey, F. H.,               C. J. Barnhart, and R. F. Lumb.             1983. Resolving the Components of Process Variability and Estimating the Uncertainty of the LEID. NUSAC Report 752, Rev. 1.               NUSAC, Inc., Reston, Virginia.
1981.
Tingey, F. H., R. H. Lumb, and R. J. Jones. 1982. Statistical Guidance for Material Control Detection Tests. NUSAC Report 712 (Draft). NUSAC, Inc.,
False Alarm Resolution Assessment Methodology, Unpublished Report to the NRC.
Pacific Northwest Laboratory, Richland, Washington.
Tingey, F. H.,
C. J. Barnhart, and R. F. Lumb.
1983.
Resolving the Components of Process Variability and Estimating the Uncertainty of the LEID.
NUSAC Report 752, Rev. 1.
NUSAC, Inc., Reston, Virginia.
Tingey, F. H.,
R. H. Lumb, and R. J. Jones.
1982.
Statistical Guidance for Material Control Detection Tests.
NUSAC Report 712 (Draft).
NUSAC, Inc.,
Reston, Virginia.
Reston, Virginia.
Wincek, M.             A., K. B. Stewart, and G. F. Piepel.             1979. Statistical Methods for Evaluating Sequential Material Balance Data.                           NUREG/CR-0683 (PNL-2920).
Wincek, M.
.          Pacific Northwest Laboratory, Richland, Washington.
A., K. B. Stewart, and G. F. Piepel.
1 j                                                                       89 l
1979.
Statistical Methods for Evaluating Sequential Material Balance Data.
NUREG/CR-0683 (PNL-2920).
Pacific Northwest Laboratory, Richland, Washington.
1 j
89 l


  ~
~
3 3
3 3 EMCLOSURE C l
EMCLOSURE C l


!    t
t
  .1 REGULATORY ANALYSIS Material Control and Accounting Requirements for Facilities Licensed to Possess and Use Formula Quantities of Strategic Special Nuclear Material (10 CFR Part 74) 1.0 STATEMENT OF THE PROBLEM Although, under the requirements of 10 CFR Part 73, physical security systems protect against the theft of strategic special nuclear material (SSNM),
.1 REGULATORY ANALYSIS Material Control and Accounting Requirements for Facilities Licensed to Possess and Use Formula Quantities of Strategic Special Nuclear Material (10 CFR Part 74) 1.0 STATEMENT OF THE PROBLEM Although, under the requirements of 10 CFR Part 73, physical security systems protect against the theft of strategic special nuclear material (SSNM),
material control and accounting (MC&A) systems are needed that focus on the material in order to ensure that no covert theft succeeds despite the physical security system and to provide data needed to deal with reported allegations of theft.
material control and accounting (MC&A) systems are needed that focus on the material in order to ensure that no covert theft succeeds despite the physical security system and to provide data needed to deal with reported allegations of theft.
The current domestic MC&A regulations for high enriched uranium and pluto-nium focus on bimonthly physical inventories and the determination of a plant-wide inventory difference (ID) and its associated limit of error (LEID).
The current domestic MC&A regulations for high enriched uranium and pluto-nium focus on bimonthly physical inventories and the determination of a plant-wide inventory difference (ID) and its associated limit of error (LEID).
Comparison of the inventory difference with the LEID and percent of throughput does not occur until nearly 30 days after the beginning of the physical inventory.
Comparison of the inventory difference with the LEID and percent of throughput does not occur until nearly 30 days after the beginning of the physical inventory.
The usefulness of these inventories in providing the public with assurance that significant quantities of SSNM have not been diverted has been degraded by difficulty in conclusively resolving large ids. This has necessitated the sub-stitution of reliance on plant security records and intelligence information for the desired assurance.
The usefulness of these inventories in providing the public with assurance that significant quantities of SSNM have not been diverted has been degraded by difficulty in conclusively resolving large ids. This has necessitated the sub-stitution of reliance on plant security records and intelligence information for the desired assurance.
2.0 PROPOSED SOLUTION A rule has been developed which will reform the MC&A requirements for fuel cycle facilities that are licensed to possess and use formula quantities of SSNM. The Reform Amendments are a performance-oriented regulation that emphasizes timely detection of SSNM losses and provides for more conclusive resolution of discrepancies. By relaxation or elimination of those current requirements which are not cost-effective, and by taking advantage of process 1 ENCLOSURE C
2.0 PROPOSED SOLUTION A rule has been developed which will reform the MC&A requirements for fuel cycle facilities that are licensed to possess and use formula quantities of SSNM. The Reform Amendments are a performance-oriented regulation that emphasizes timely detection of SSNM losses and provides for more conclusive resolution of discrepancies.
By relaxation or elimination of those current requirements which are not cost-effective, and by taking advantage of process 1
ENCLOSURE C


controls, production controls, and quality controls already used by licensees, this can be accomplished with an annual cost reduction that will eventually I
controls, production controls, and quality controls already used by licensees, this can be accomplished with an annual cost reduction that will eventually I
offset implementation costs.
offset implementation costs.
3.0 ENVIRONMENTAL ASSESSMENT The estimated impact of the proposed amendments are assessed as follows:
3.0 ENVIRONMENTAL ASSESSMENT The estimated impact of the proposed amendments are assessed as follows:
: 1)   Status quo - The current material control and accounting requirements have virtually no impact on the environment because they have no
1)
{                                           significant effect on the process or effluents of the licensee.
Status quo - The current material control and accounting requirements have virtually no impact on the environment because they have no
: 2)   Recomended amendments to MC&A regulations - The changes will have no significant effect on the licensee's process or effluents. The rule i                                           change involves no new commitment for land use, air use, or water use. No new or exclusive use structure is necessary. There are no dangers to flora, fauna, or endangered species involved. There will
{
;                                            be no significant increase in individual or cumulative occupational                             I
significant effect on the process or effluents of the licensee.
!                                            radiation exposure. There is no significant increase in the potential for or consequences from radiological accidents. No new traffic patterns are involved. No new human, natural, or man-made resources are required.
2)
The foregoing forms a basis for a finding that this rulemaking action will have no significant impact on the human environment and a decision not to i                                 prepare an environmental impact statement.
Recomended amendments to MC&A regulations - The changes will have no significant effect on the licensee's process or effluents. The rule i
i 4.0 COSTS AND BENEFITS 4.1 Summary l                                       Results of regulatory analyses performed in support of the MC&A Reform
change involves no new commitment for land use, air use, or water use.
!                                Amendments indicate that significant safeguards benefits will accrue from these
No new or exclusive use structure is necessary. There are no dangers to flora, fauna, or endangered species involved. There will I
(                                 amendments. An initial moderate increase in costs will occur due to the i
be no significant increase in individual or cumulative occupational radiation exposure. There is no significant increase in the potential for or consequences from radiological accidents.
No new traffic patterns are involved.
No new human, natural, or man-made resources are required.
The foregoing forms a basis for a finding that this rulemaking action will have no significant impact on the human environment and a decision not to i
prepare an environmental impact statement.
i 4.0 COSTS AND BENEFITS 4.1 Summary l
Results of regulatory analyses performed in support of the MC&A Reform Amendments indicate that significant safeguards benefits will accrue from these
(
amendments. An initial moderate increase in costs will occur due to the i


implementation effort. However, savings in annual operating costs will offset the implementation costs for the fabrication facilities within four to seven           !
implementation effort. However, savings in annual operating costs will offset the implementation costs for the fabrication facilities within four to seven years and within two to nine years for the conversion facilities.
years and within two to nine years for the conversion facilities.                     l Benefits of the MC&A Reform Amendments include:
Benefits of the MC&A Reform Amendments include:
Providing more timely SSNM loss alarms through use of production and quality control measurements instead of less timely comparisons of plant-wide ID and LEID;
Providing more timely SSNM loss alarms through use of production and quality control measurements instead of less timely comparisons of plant-wide ID and LEID; Increasing the ability to confidently resolve MC&A alarms by:
            -    Increasing the ability to confidently resolve MC&A alarms by:
(a) Decreasing the area and material subject to the alarms, (b) Decreasing the number of persons who need to be investigated, and (c) Decreasing the length of time in question; Basing detection criteria on the quantity of safeguards significance (i.e., 5 FKG) rather than on throughput of SSNM at a facility; Basing detection criteria on sound statistical principles and resolv-ing those statistical deficiencies, identified in the " Report on the Statistical Treatment of Inventory Differences" (SECY 80-514),* which are resolvable by this rulemaking; Basing criteria for interruption of processing activities on an assessment of whether the interruption will facilitate the resolution of a localized alarm involving a significant quantity of SSNM rather than the inability to resolve an imbalance resulting from the taking of periodic inventories; i
(a) Decreasing the area and material subject to the alarms, (b) Decreasing the number of persons who need to be investigated, and (c) Decreasing the length of time in question; Basing detection criteria on the quantity of safeguards significance (i.e., 5 FKG) rather than on throughput of SSNM at a facility; Basing detection criteria on sound statistical principles and resolv-ing those statistical deficiencies, identified in the " Report on the Statistical Treatment of Inventory Differences" (SECY 80-514),* which are resolvable by this rulemaking; Basing criteria for interruption of processing activities on an assessment of whether the interruption will facilitate the resolution of a localized alarm involving a significant quantity of SSNM rather than the inability to resolve an imbalance resulting from the taking of periodic inventories; i
      *This report is available for inspection and copying for a fee in the NRC Public Document Room, 1717 H Street NW., Washington, DC 20555.
*This report is available for inspection and copying for a fee in the NRC Public Document Room, 1717 H Street NW., Washington, DC 20555.
3                           ENCLOSURE C
3 ENCLOSURE C


                                                                                        }
}
LRequiring an integrated safeguards approach towards protection against' falsification and deceit by multiple insiders that recognizes the collusion protection provided by the physical security upgrade, yet assures that MC&A will provide an independent check of physical security protection; Focusing training and qualification requirements on those positions involving tasks where error or negligence could directly and adversely affect MC&A capabilities; and l
LRequiring an integrated safeguards approach towards protection against' falsification and deceit by multiple insiders that recognizes the collusion protection provided by the physical security upgrade, yet assures that MC&A will provide an independent check of physical security protection; Focusing training and qualification requirements on those positions involving tasks where error or negligence could directly and adversely affect MC&A capabilities; and Permitting greater licensee flexibility by making quality assurance and accounting requirements less prescriptive.
Permitting greater licensee flexibility by making quality assurance         l and accounting requirements less prescriptive.
Additional benefits accrue through the elimination or decrease of current -
l l
requirements which are no longer needed because of the new requirements or because of their relatively low cost-effectiveness.
Additional benefits accrue through the elimination or decrease of current -     '
Some of these changes are:
requirements which are no longer needed because of the new requirements or             )
because of their relatively low cost-effectiveness. Some of these changes are:
Increasing the period between physical inventories from bimonthly to semiannual; and Changing processing of scrap requirements to a performance-oriented approach, rather than the previous " command and control" approach,
Increasing the period between physical inventories from bimonthly to semiannual; and Changing processing of scrap requirements to a performance-oriented approach, rather than the previous " command and control" approach,
(             to allow the licensee to use more cost-effective methods.                   '
(
4 i       Estimates have been developed that indicate annual cost savings associated l
to allow the licensee to use more cost-effective methods.
l with these changes will more than offset the increased costs associated with the new requirements over a peroid of years. Both the increased costs and cost savings attributable to the Reform Amendments are compared to the current requirements in Table 1. The figures set forth in Table 1 are further described in Section 4.3 (Results of Cost Estimate Analysis) within. The costs and savings shown in this table have been developed to encompass facilities similar to the four current Category I facilities. Of the four currently licensed facilities, two are primarily engaged in uranium fuel fabrication operations such as welding and machining, and two operate uranium conversion processes in which the chemical form of the uranium is changed. Three of the 4
4 i
Estimates have been developed that indicate annual cost savings associated l
l with these changes will more than offset the increased costs associated with the new requirements over a peroid of years.
Both the increased costs and cost savings attributable to the Reform Amendments are compared to the current requirements in Table 1.
The figures set forth in Table 1 are further described in Section 4.3 (Results of Cost Estimate Analysis) within.
The costs and savings shown in this table have been developed to encompass facilities similar to the four current Category I facilities. Of the four currently licensed facilities, two are primarily engaged in uranium fuel fabrication operations such as welding and machining, and two operate uranium conversion processes in which the chemical form of the uranium is changed.
Three of the 4


y
y e
                                                                    ^
^
e four operate scrap dissolution and recovery processes. Actuai costs to individ-ual facilities will depend upon the size and type of facility and thn degree to which they may have already implemented some of the requirements such as'a pro-cess monitoring system. The cost ranges depicted in Table 1 reflect these differences in facilities and'also the uncertainties in the cost estimates.
four operate scrap dissolution and recovery processes.
p' It should be noted that a number of additional savings, not shown in       '
Actuai costs to individ-ual facilities will depend upon the size and type of facility and thn degree to which they may have already implemented some of the requirements such as'a pro-cess monitoring system.
Table 1, might accrue to licensees due to implementation of the Reform Amend-ments. For example, potential savings might accrue if licensees were able to reduce their uranium inventories as a result of implementing the process moqi-toring system required by the Reforto Amendments. An LEU facilit9 referenced in the Results section reduced its_ uranium inventory by 60 percent after imple-menting a process monitoring system. Improvements to production due to   ,      3 increased accuracy and quick accessibility to the data base are s9milarly     ;
The cost ranges depicted in Table 1 reflect these differences in facilities and'also the uncertainties in the cost estimates.
* difficult to evaluate.                             ,
p' It should be noted that a number of additional savings, not shown in Table 1, might accrue to licensees due to implementation of the Reform Amend-ments.
Besides improvements to domestic safeguards, a possible a'dditional benefit associated with adoption of the MCIA Reform Amendments is that, experience gained during implementation may be useful to the International Atomic Energy Agency (IAEA) regarding its interest in strengthening international safeguards. One report presented to an International Working Group supporting IAEA noted. that:           ,
For example, potential savings might accrue if licensees were able to reduce their uranium inventories as a result of implementing the process moqi-toring system required by the Reforto Amendments.
          "...the most fundamental advantage of process monitoring is that it could enhance the diversion detection capabflity of an international safeguards system without requiring the instillation of dedicated safe-guards instrumentation.... The more aburdant and diverse the process data available to the safeguards systtm, the more broadly based its diversion detection capability becomes. In fact, a process monitoring system that exploits the relationships between a wide variety and a                 l large number of process variables may'be able to provide some inherent protection against instrument or software tampering."1                               I
An LEU facilit9 referenced in the Results section reduced its_ uranium inventory by 60 percent after imple-menting a process monitoring system.
Improvements to production due to 3
increased accuracy and quick accessibility to the data base are s9milarly difficult to evaluate.
Besides improvements to domestic safeguards, a possible a'dditional benefit associated with adoption of the MCIA Reform Amendments is that, experience gained during implementation may be useful to the International Atomic Energy Agency (IAEA) regarding its interest in strengthening international safeguards.
One report presented to an International Working Group supporting IAEA noted. that:
"...the most fundamental advantage of process monitoring is that it could enhance the diversion detection capabflity of an international safeguards system without requiring the instillation of dedicated safe-guards instrumentation....
The more aburdant and diverse the process data available to the safeguards systtm, the more broadly based its diversion detection capability becomes.
In fact, a process monitoring system that exploits the relationships between a wide variety and a l
large number of process variables may'be able to provide some inherent I
protection against instrument or software tampering."1
(
(
However, weight cannot be given to this benefit because the concept has yet to be accepted for use in the IAEA safeguards system.
However, weight cannot be given to this benefit because the concept has yet to be accepted for use in the IAEA safeguards system.
5
5


': r
,n;
    ,n; ' -    -                                                  -'                  -    -
': r 4
4
:By'
:By'                                                                                                       ,
! Table 1 Estimated Costs (+) and Savings (-) Anticipated With the MC&A Reform Amendments ($K)
                                  ! Table 1 Estimated Costs (+) and Savings (-) Anticipated With the MC&A Reform Amendments ($K)
!,,[
!,,[                                                                         Type of Facility Fuel Fab.                   Conversion One Time Implementation Costs Labor                                 +325 to +592               +572 to + 581 Capital Expenditures                   +70 to + 83               +88 to + 354 Lost ProdiJction                             0                         0 TOTAL *                         +395 to +675               +660 to + 935 Annual Costs.
Type of Facility Fuel Fab.
FNMC Plan and Operating                               5 to     15               10 to   17 Procedures Loss Detection, Response                           -140 to -437               -545 to -368 and Physical Inventory Qual,ity Assurance                                   40 to 133                 115 to 166 Defense Against Falsification                       40 to 133                 60 to 133 TOTAL *                           -55 to -156               -302 to -110**
Conversion One Time Implementation Costs Labor
            *The projected savings assume that the facilities would be operating at or
+325 to +592
,            near capacity.
+572 to + 581 Capital Expenditures
            **This total is not a sum of the components because the component extremes woulet not all apply to the same facility.
+70 to + 83
+88 to + 354 Lost ProdiJction 0
0 TOTAL *
+395 to +675
+660 to + 935 Annual Costs.
FNMC Plan and Operating 5 to 15 10 to 17 Procedures Loss Detection, Response
-140 to -437
-545 to -368 and Physical Inventory Qual,ity Assurance 40 to 133 115 to 166 Defense Against Falsification 40 to 133 60 to 133 TOTAL *
-55 to -156
-302 to -110**
*The projected savings assume that the facilities would be operating at or near capacity.
**This total is not a sum of the components because the component extremes woulet not all apply to the same facility.
4.2 Resultr, of Feasibility and Value/ Impact Studies
4.2 Resultr, of Feasibility and Value/ Impact Studies
                                                                        't Several studies have been performed under NRC contract to assess the feasibility of implementing the MC&A Reform Amendments and to assess the value/ impact implications of shortening detection and response time require-ments.         Results of these studies confirm that the prompt accountability concept is technologically feasible and that significant benefits to MC&A systems could be achieved.                                                     -
't Several studies have been performed under NRC contract to assess the feasibility of implementing the MC&A Reform Amendments and to assess the value/ impact implications of shortening detection and response time require-ments.
Results of these studies confirm that the prompt accountability concept is technologically feasible and that significant benefits to MC&A systems could be achieved.
6
6


5 is
5 is
    'e Battelle-Pacific Northwest Laboratories (PNL) performed a value/ impact analysis of 12 combinations (including the current requirements) of alternative detection and response times.2 The objective of their study was to provida information that would aid in determining optimal detection and response times.
'e Battelle-Pacific Northwest Laboratories (PNL) performed a value/ impact analysis of 12 combinations (including the current requirements) of alternative detection and response times.2 The objective of their study was to provida information that would aid in determining optimal detection and response times.
The alternative detection times they assessed range from a high of 1 week to a low of 4 hours. Alternative response (conclusive resolution) times vary from 12 hours to 3 days.
The alternative detection times they assessed range from a high of 1 week to a low of 4 hours.
For purposes of ranking the alternatives, PNL dev, eloped safeguards value   ;
Alternative response (conclusive resolution) times vary from 12 hours to 3 days.
criteria that were intended to capture the most, significant safeguards values.
For purposes of ranking the alternatives, PNL dev, eloped safeguards value criteria that were intended to capture the most, significant safeguards values.
The value criteria included detection capability, retrieval potential, and deterrence value. Each of the timeliness alternatives was assigned a relative value according to each of the value criteria.
The value criteria included detection capability, retrieval potential, and deterrence value.
PNL's value assessment of the alternatives shows that all the alternatives provide significant improvement over the status quo in achieving increased timeliness of material loss detection and determination of the cause of an apparent loss. Among the non-status quo alternatives, safeguards values'were shown to increase with faster detection times, as did costs.
Each of the timeliness alternatives was assigned a relative value according to each of the value criteria.
PNL's value assessment of the alternatives shows that all the alternatives provide significant improvement over the status quo in achieving increased timeliness of material loss detection and determination of the cause of an apparent loss.
Among the non-status quo alternatives, safeguards values'were shown to increase with faster detection times, as did costs.
The alternatives that had the highest value/ impact ratios were the alternatives with 3-day detection capabilities.
The alternatives that had the highest value/ impact ratios were the alternatives with 3-day detection capabilities.
As reflected in PNL's value assessment, shorter detection times genbrally decrease the probability of successful completion of a theft.         Shorter detection times also increase the probability for resolving the cause of the loss                     ,
As reflected in PNL's value assessment, shorter detection times genbrally decrease the probability of successful completion of a theft.
indicator landimprovechancesofmaterialretrievalshouldatheftoccur.                             ,
Shorter detection times also increase the probability for resolving the cause of the loss indicator landimprovechancesofmaterialretrievalshouldatheftoccur.
Periods shorter than 24 hours (e.g. , 8 hours and 4' hours) were eliminated from considsration, not only because of the dramatic increase in cost, but because of the potential harmful effect of the excessive numbers of false alarms that they would cause, some of which could be unresolvable. The increase in                     r cost between 3-day detection and 24-hour detection is about 50 percent. There is more than a 100 percent increase in echieving an=8-hour detection as compared to a 3-day capability and more than 200 percent cost increase to achieve a 4-hour detection capability. The 3-day detection capability for highly desir-
Periods shorter than 24 hours (e.g., 8 hours and 4' hours) were eliminated from considsration, not only because of the dramatic increase in cost, but because of the potential harmful effect of the excessive numbers of false alarms that they would cause, some of which could be unresolvable.
  .            able SSNM has been adopted in the MC&A Reform Amendments because it reflects,'
The increase in r
cost between 3-day detection and 24-hour detection is about 50 percent.
There is more than a 100 percent increase in echieving an=8-hour detection as compared to a 3-day capability and more than 200 percent cost increase to achieve a 4-hour detection capability.
The 3-day detection capability for highly desir-able SSNM has been adopted in the MC&A Reform Amendments because it reflects,'
the highest value impact ratio and because it will significantly improve safe-guards without imposing what HRC staff consider an economic hardship to the
the highest value impact ratio and because it will significantly improve safe-guards without imposing what HRC staff consider an economic hardship to the
                                                      ~
~
industry.
industry.
l t
l t
      , ,r ,.,      .,- ,        .,.            ,-.            -
,r


d Additional studies have subsequently been performed to confirm the feasibility of achieving short detection and response capabilities at all existing facilities as well as at proposed reprocessing facilities. These studies were performed by Science Applications, Inc. (SAI), NUSAC, Inc., PNL, and Los Alamos National Laboratory (LANL). SAI performed a study at a small conversion facility to determine the feasibility and cost-benefit of achieving a 24-hour theft detection capability for 5 Fkg of U-235.3 SAI's study showed that existing in process controls in the fuel conversion and fabrication process could be used to achieve material loss detection within 24 hours for many simple-diversion paths. They found that advanced controls also could be designed to achieve timely detection of diversion scenarios involving sophisticated substitution tactics. A later study by SAI of a large throughput conversion facility concluded that it was feasible for that facility to meet the proposed Reform Amendments, and that the net savings would likely exceed the net costs.4 NUSAC, Inc., performed a parallel study of alternative process monitoring techniques in a high throughput, high enriched uranium scrap recovery facility.s They developed alternatives to reflect varying degrees of sophistication with respect to prompt accountability techniques. The more sophisticated alternatives achieved faster detection at greater cost. NUSAC's study showed that the cost of achieving various detection times varied approximately linearly.
d Additional studies have subsequently been performed to confirm the feasibility of achieving short detection and response capabilities at all existing facilities as well as at proposed reprocessing facilities.
PNL and LANL performed analyses of a hypothetical facility having three lines: UFs conversion, fuel fabrication, and uranium scrap recovery. Both of these studies demonstrated how such a facility could meet the performance requirements of the Reform Amendments.8'7 These studies have focused considerable attention on the impact of current measurement technique uncertainties, particularly those associated with NDA, on the calculated standard deviation to be associated with the various material control tests. They have also focused on the implications as to whether or not all of the detection and response capability requirements can be met and what the rate of anticipated unresolved false alarms will be.     One conclusion of these studies has been that current measurement technology is entirely adequate to permit compliance with the Reform Amendments in a practical manner.
These studies were performed by Science Applications, Inc. (SAI), NUSAC, Inc., PNL, and Los Alamos National Laboratory (LANL).
SAI performed a study at a small conversion facility to determine the feasibility and cost-benefit of achieving a 24-hour theft detection capability for 5 Fkg of U-235.3 SAI's study showed that existing in process controls in the fuel conversion and fabrication process could be used to achieve material loss detection within 24 hours for many simple-diversion paths.
They found that advanced controls also could be designed to achieve timely detection of diversion scenarios involving sophisticated substitution tactics.
A later study by SAI of a large throughput conversion facility concluded that it was feasible for that facility to meet the proposed Reform Amendments, and that the net savings would likely exceed the net costs.4 NUSAC, Inc., performed a parallel study of alternative process monitoring techniques in a high throughput, high enriched uranium scrap recovery facility.s They developed alternatives to reflect varying degrees of sophistication with respect to prompt accountability techniques.
The more sophisticated alternatives achieved faster detection at greater cost.
NUSAC's study showed that the cost of achieving various detection times varied approximately linearly.
PNL and LANL performed analyses of a hypothetical facility having three lines:
UFs conversion, fuel fabrication, and uranium scrap recovery.
Both of these studies demonstrated how such a facility could meet the performance requirements of the Reform Amendments.8'7 These studies have focused considerable attention on the impact of current measurement technique uncertainties, particularly those associated with NDA, on the calculated standard deviation to be associated with the various material control tests.
They have also focused on the implications as to whether or not all of the detection and response capability requirements can be met and what the rate of anticipated unresolved false alarms will be.
One conclusion of these studies has been that current measurement technology is entirely adequate to permit compliance with the Reform Amendments in a practical manner.
The impact on safeguards effectiveness resulting from relaxing physical inventories from bimonthly to semiannually or annually was assessed by Lawrence Livermore National Laboratory (LLNL).s They determined that with prompt accountability in place, lit le degradation in safeguards would occur from 4
The impact on safeguards effectiveness resulting from relaxing physical inventories from bimonthly to semiannually or annually was assessed by Lawrence Livermore National Laboratory (LLNL).s They determined that with prompt accountability in place, lit le degradation in safeguards would occur from 4
8
8


reducing the number of physical inventories. Prompt accountability neasares were shown in LLNL's analysis to be effective in preventing and deterring scenarios that physical inventories are incapable of doing. An.3ng 28 diversion scenarios, only five were negatively affected by the relaxation of inventory     !
reducing the number of physical inventories.
frequency, and these were only slightly degraded. All five of these scenarios involved small quantity diversions well within the 5 formula kilogram capability.
Prompt accountability neasares were shown in LLNL's analysis to be effective in preventing and deterring scenarios that physical inventories are incapable of doing.
An.3ng 28 diversion scenarios, only five were negatively affected by the relaxation of inventory frequency, and these were only slightly degraded.
All five of these scenarios involved small quantity diversions well within the 5 formula kilogram capability.
4.3 Results of Cost Estimation Analyses Data developed by NRC contractors and data developed in-house have been analyzed to develop cost estimates for two categories of HEU facilities:
4.3 Results of Cost Estimation Analyses Data developed by NRC contractors and data developed in-house have been analyzed to develop cost estimates for two categories of HEU facilities:
(1) Fuel fabrication facilities - Facilities engaged in the production of fuel assemblies. Bulk materials are blended and then fabricated into items which subsequently undergo numerous physical transformations.
(1) Fuel fabrication facilities - Facilities engaged in the production of fuel assemblies.
Bulk materials are blended and then fabricated into items which subsequently undergo numerous physical transformations.
One of these facilities has an associated scrap recovery capability.
One of these facilities has an associated scrap recovery capability.
(2) Conversion facilities - Facilities primarily engaged in operations involving the chemical and/or physical transformation of bulk materials into a form suitable to be used in the fabrication of fuel assemblies.
(2) Conversion facilities - Facilities primarily engaged in operations involving the chemical and/or physical transformation of bulk materials into a form suitable to be used in the fabrication of fuel assemblies.
All of these facilities have associated scrap recovery operations, and some also produce the fuel assemblies.
All of these facilities have associated scrap recovery operations, and some also produce the fuel assemblies.
Each facility type underwent a two-step evaluation process to assess (1) any changes to annual operating costs once the Reform Amendments had been implemented and (2) the initial cost to implement the Reform Amendments. No attempt was made to introduce an amortized implementation expense into the annual operating cost.
Each facility type underwent a two-step evaluation process to assess (1) any changes to annual operating costs once the Reform Amendments had been implemented and (2) the initial cost to implement the Reform Amendments.
l           Annual operating costs were evaluated from the viewpoint of the expected difference between the level of effort now being expended by the licensee and the level of effort anticipated to be required under the Reform Amendments.
No attempt was made to introduce an amortized implementation expense into the annual operating cost.
Estimated cost differentials were based on a judgment of whether the part of the MC&A system under consideration should cost more, the same, or less under
l Annual operating costs were evaluated from the viewpoint of the expected difference between the level of effort now being expended by the licensee and the level of effort anticipated to be required under the Reform Amendments.
;      the Reform Amendments than it now costs under existing regulations. Three cost 9
Estimated cost differentials were based on a judgment of whether the part of the MC&A system under consideration should cost more, the same, or less under the Reform Amendments than it now costs under existing regulations.
Three cost 9


e e
e e
categories were identified.         These are (1) labor costs associated with additional personnel, (2) additional materials and maintenance, and (3) produc-tion opportunity costs. Production opportunity costs encompass the value of any increase or decrease to production attributable to the Reform Amendments.
categories were identified.
One-time implementation costs or "backfitting" costs were evaluated separately for each facility type. Included were all costs anticipated to be incurred by a licensee in modifying an operation to enable it to operate in compliance with the proposed amendments. The cost of additional labor to alter practices and procedures, revise Fundamental Nuclear Material Control (FNMC) plans, develop software, perform modeling experiments, and install new equip-ment were evaluated under implementation labor. The cost of new measurement instruments, hardware to modify the process lines, and augmentation to data handling systems, such as computers and purchased software packages, were included under implementation capital expense. The possibility of lost production due to downtime required to install and test new equipment and to implement and debug new practices and procedures also was evaluated.
These are (1) labor costs associated with additional personnel, (2) additional materials and maintenance, and (3) produc-tion opportunity costs.
4.3.1 Fuel Fabrication Facilities Analyses of current practices at fuel fabrication facilities reveal that expenditure of labor for item verification programs and for detection and response procedures on a scrap line would change minimally under the proposed amendments.     Annual operating costs will be incurred for application of the loss detection tests, alarm resolution investigations, and the quality assurance requirements.         Maintenance of the FNMC Plan and operating procedures l is estimated to require $5K to $15K. This includes procedure revisions required to accommodate changes in operations and lessons learned in test applications.
Production opportunity costs encompass the value of any increase or decrease to production attributable to the Reform Amendments.
Tradeoffs will exist in the application of bulk loss tests, item monitoring, alarm resolution, and physical inventory requirements. The reduction in the number of physical inventories will result in a savings that will more than offset the additional effort needed to meet the prompt detection requirements.
One-time implementation costs or "backfitting" costs were evaluated separately for each facility type.
Included were all costs anticipated to be incurred by a licensee in modifying an operation to enable it to operate in compliance with the proposed amendments.
The cost of additional labor to alter practices and procedures, revise Fundamental Nuclear Material Control (FNMC) plans, develop software, perform modeling experiments, and install new equip-ment were evaluated under implementation labor.
The cost of new measurement instruments, hardware to modify the process lines, and augmentation to data handling systems, such as computers and purchased software packages, were included under implementation capital expense.
The possibility of lost production due to downtime required to install and test new equipment and to implement and debug new practices and procedures also was evaluated.
4.3.1 Fuel Fabrication Facilities Analyses of current practices at fuel fabrication facilities reveal that expenditure of labor for item verification programs and for detection and response procedures on a scrap line would change minimally under the proposed amendments.
Annual operating costs will be incurred for application of the loss detection tests, alarm resolution investigations, and the quality assurance requirements.
Maintenance of the FNMC Plan and operating procedures l
is estimated to require $5K to $15K.
This includes procedure revisions required to accommodate changes in operations and lessons learned in test applications.
Tradeoffs will exist in the application of bulk loss tests, item monitoring, alarm resolution, and physical inventory requirements.
The reduction in the number of physical inventories will result in a savings that will more than offset the additional effort needed to meet the prompt detection requirements.
Alarm resolution is expected to require five percent or less of the total time since the licensee should experience few, if any, alarms in the absence of diversion, 10 l
Alarm resolution is expected to require five percent or less of the total time since the licensee should experience few, if any, alarms in the absence of diversion, 10 l
l
l


e theft, or previously undetected process error. The annual cost for loss detection, response and physical inventories has been estimated to range from a savings of
e theft, or previously undetected process error.
      $140K to $437K. Quality assurance, consisting of personnel qualification and training, quality control, and audits is estimated to cost $40K to $133K.
The annual cost for loss detection, response and physical inventories has been estimated to range from a savings of
$140K to $437K.
Quality assurance, consisting of personnel qualification and training, quality control, and audits is estimated to cost $40K to $133K.
Protection against falsification and deceit was also estimated at $40K to $133K.
Protection against falsification and deceit was also estimated at $40K to $133K.
Other changes to operating expenses are expected to be minimal.     Depending on factors such as the size of the facility and on whether or not it has a scrap line, the net change in annual operating costs has been estimated to be between -$55K and -$156K.
Other changes to operating expenses are expected to be minimal.
Depending on factors such as the size of the facility and on whether or not it has a scrap line, the net change in annual operating costs has been estimated to be between -$55K and -$156K.
Implementation labor expense at fuel fabrication facilities was assessed at $325K to $592K divided as follows:
Implementation labor expense at fuel fabrication facilities was assessed at $325K to $592K divided as follows:
Between $100K and $148K to provide a revised FNMC plan and new operating procedures to meet the Reform Amendments.
Between $100K and $148K to provide a revised FNMC plan and new operating procedures to meet the Reform Amendments.
Line 2,236: Line 3,443:
Between $100K and $148K to implement the various elements of quality assurance and accounting.
Between $100K and $148K to implement the various elements of quality assurance and accounting.
Between $50K and $74K for development of MC&A supplements to protect against collusion involving falsification and deceit.
Between $50K and $74K for development of MC&A supplements to protect against collusion involving falsification and deceit.
Capital expenses associated with implementation are expected to be minimal and are primarily associated with upgrading the computer system. Capital expenses are estimated at between $70K and $83K.
Capital expenses associated with implementation are expected to be minimal and are primarily associated with upgrading the computer system.
Capital expenses are estimated at between $70K and $83K.
i Since no loss of production is expected to result due to the implementation effort, the total implementation or "backfitting" expense (labor plus capital expense) is expected to be $395 to $675K depending on whether or not the facility has a scrap recovery area.
i Since no loss of production is expected to result due to the implementation effort, the total implementation or "backfitting" expense (labor plus capital expense) is expected to be $395 to $675K depending on whether or not the facility has a scrap recovery area.
l                                                 11
l 11


e d
e d
4.3.2   Conversion Facilities While additional operator and MC&A labor is anticipated to be required to meet the detection and response capabilities of the Reform Amendments for the primarily batch and semi-continuous operations encountered at conversion facilities, it is anticipated that the net annual operating expenses will be reduced at these facilities primarily due to the relaxation in the physical inventory requirement. The anticipated changes to annual operating expenses have been broken down as follows:
4.3.2 Conversion Facilities While additional operator and MC&A labor is anticipated to be required to meet the detection and response capabilities of the Reform Amendments for the primarily batch and semi-continuous operations encountered at conversion facilities, it is anticipated that the net annual operating expenses will be reduced at these facilities primarily due to the relaxation in the physical inventory requirement.
The anticipated changes to annual operating expenses have been broken down as follows:
Labor for additional sampling, measurements, chemical analyses, calibrations, data handling, and response activities required to meet the detection and response capabilities $155K to $532K.
Labor for additional sampling, measurements, chemical analyses, calibrations, data handling, and response activities required to meet the detection and response capabilities $155K to $532K.
Production improvement due to reduction in number of physical inventories and consequent reduction in downtime to perform physical inventories and in quantity of scrap generated preparatory to performing physical inventories. Also, labor savings due to reduction in number of physical inventories, in LEID calculation effort and in ID reconciliation effort:   $700K to $900K savings.*
Production improvement due to reduction in number of physical inventories and consequent reduction in downtime to perform physical inventories and in quantity of scrap generated preparatory to performing physical inventories.
Quality assurance, consisting of personnel qualification and training:   $115K to $166K.
Also, labor savings due to reduction in number of physical inventories, in LEID calculation effort and in ID reconciliation effort:
Protection against falsification and deceit:   $60K to $133K.
$700K to $900K savings.*
Maintenance of the FNMC Plan and operating procedures:   $10K to $17K.
Quality assurance, consisting of personnel qualification and training:
$115K to $166K.
Protection against falsification and deceit:
$60K to $133K.
Maintenance of the FNMC Plan and operating procedures:
$10K to $17K.
* Lost production due to shutdown pending resolution of 5 FKG loss alarms is expected to be negligible because of the low annual likelihood of such alarms.
* Lost production due to shutdown pending resolution of 5 FKG loss alarms is expected to be negligible because of the low annual likelihood of such alarms.
l 12 I
l 12 I
Line 2,252: Line 3,466:
e Over the range of facilities evaluated, the net change in annual operating costs is anticipated to range from a savings of $110K to $302K per year.
e Over the range of facilities evaluated, the net change in annual operating costs is anticipated to range from a savings of $110K to $302K per year.
Implementation labor expense at conversion facilities was assessed at
Implementation labor expense at conversion facilities was assessed at
  $572K to $581K. Capital expenses at conversion facilities could be substantial due to the need for improved measurement systems, for modifications to the process to allow adequate sampling and holdup estimation, and for upgrading the data handling systems. The total value has been estimated at $88K to $354K. It is not anticipated that there will be any lost production as a result of making modifications and installing equipment.
$572K to $581K.
Capital expenses at conversion facilities could be substantial due to the need for improved measurement systems, for modifications to the process to allow adequate sampling and holdup estimation, and for upgrading the data handling systems.
The total value has been estimated at $88K to $354K.
It is not anticipated that there will be any lost production as a result of making modifications and installing equipment.
The total cost of the implementation effort at conversion facilities is therefore expected to be $660 to $935K.
The total cost of the implementation effort at conversion facilities is therefore expected to be $660 to $935K.
5.0 ADDITIONAL POTENTIAL COST SAVINGS Along with the safeguards benefit that will be realized due to the prompt accountability requirements of the Reform Amendments, there are also significant potential cost savings to be realized after implementation is complete. One potential cost savings is the labor savings resulting from the relaxation of the physical inventory requirement. Another is the increased production resulting from both the reduction in downtime required to conduct physical inventories and the reduction in the amount of scrap generated in preparation for physical inventories.
5.0 ADDITIONAL POTENTIAL COST SAVINGS Along with the safeguards benefit that will be realized due to the prompt accountability requirements of the Reform Amendments, there are also significant potential cost savings to be realized after implementation is complete.
In addition to the costs and savings discussed in the Results section, there are also some subtle and slightly more difficult to evaluate potential savings which should result from utilization of an advanced process monitoring system. A high throughput LEU fabrication facility has indicated that through the use of such a system, they have been able to reduce their annual variable operating costs by 35 percent.9 The savings came from several sources, most related to the increased accuracy and quick accessibility of their data base.
One potential cost savings is the labor savings resulting from the relaxation of the physical inventory requirement.
The computerized system has allowed significant labor savings in the entry, manipulation, and retrieval of data required for the MC&A system as well as for production and quality control. The computerized system has enabled the LEU facility to reduce its labor requirements per physical inventory by 50 percent.
Another is the increased production resulting from both the reduction in downtime required to conduct physical inventories and the reduction in the amount of scrap generated in preparation for physical inventories.
Increased accuracy and quick accessibility permit error detection during material processing. Earlier error detection prevents further commingling of 13
In addition to the costs and savings discussed in the Results section, there are also some subtle and slightly more difficult to evaluate potential savings which should result from utilization of an advanced process monitoring system.
A high throughput LEU fabrication facility has indicated that through the use of such a system, they have been able to reduce their annual variable operating costs by 35 percent.9 The savings came from several sources, most related to the increased accuracy and quick accessibility of their data base.
The computerized system has allowed significant labor savings in the entry, manipulation, and retrieval of data required for the MC&A system as well as for production and quality control.
The computerized system has enabled the LEU facility to reduce its labor requirements per physical inventory by 50 percent.
Increased accuracy and quick accessibility permit error detection during material processing.
Earlier error detection prevents further commingling of 13


e e
e e
    "off-spec" material which must eventually be rejected and recovered as. scrap.
"off-spec" material which must eventually be rejected and recovered as. scrap.
The LEU facility also attributes to the computerized process monitoring system savings from reducing their uranium inventory by about 60 percent.
The LEU facility also attributes to the computerized process monitoring system savings from reducing their uranium inventory by about 60 percent.
Los Alamos National Laboratory also has a computerized process monitoring system (PFLASS), and they report a savings of a million dollars a year in labor as well as an increase in production of 15-20 percent.20 There are undoubtedly distinguishing characteristics of the current Category I Iicensees that would preclude their achieving such a magnitude of efficiencies (e.g., 35 percent savings in variable costs). These differences include a much lower throughput and the production of fuel of one enrichment instead of varying enrichments. However, it seems reasonable to assume that labor reduction in performing MC&A and production control functions due to a computerized system could reduce variable operating costs at these facilities by 5 percent and that efficiencies from earlier detection of errors could reduce costs by 1 percent.         It is recognized that these savings are subject to some uncertainty because of the lack of direct transferability of the experience of one LEU facility to the four subject HEU facilities. However, one subject HEU facility is in the process of implementing a computerized system for process monitoring as well as for many other purposes. It is presumed that as a profit-maximizing firm, such a system would not be' implemented without expectation of receiving sufficient economic benefits to offset the capital expense.
Los Alamos National Laboratory also has a computerized process monitoring system (PFLASS), and they report a savings of a million dollars a year in labor as well as an increase in production of 15-20 percent.20 There are undoubtedly distinguishing characteristics of the current Category I Iicensees that would preclude their achieving such a magnitude of efficiencies (e.g., 35 percent savings in variable costs).
These differences include a much lower throughput and the production of fuel of one enrichment instead of varying enrichments.
However, it seems reasonable to assume that labor reduction in performing MC&A and production control functions due to a computerized system could reduce variable operating costs at these facilities by 5 percent and that efficiencies from earlier detection of errors could reduce costs by 1 percent.
It is recognized that these savings are subject to some uncertainty because of the lack of direct transferability of the experience of one LEU facility to the four subject HEU facilities.
: However, one subject HEU facility is in the process of implementing a computerized system for process monitoring as well as for many other purposes.
It is presumed that as a profit-maximizing firm, such a system would not be' implemented without expectation of receiving sufficient economic benefits to offset the capital expense.
l l
l l
i 14
i 14


0 e
0 e
References *
References
: 1. Hurt, R. D., " Process Monitoring Applications to International Safeguards,"
* 1.
Hurt, R. D., " Process Monitoring Applications to International Safeguards,"
presented at the meeting of Subgroup I of the International Working Group for Reprocessing Plant Safeguards, June 25-26, 1930.
presented at the meeting of Subgroup I of the International Working Group for Reprocessing Plant Safeguards, June 25-26, 1930.
: 2. Byers, K. R. and S. W. Heaberlin, "Value-Impact Analysis of Alternatives for Prompt Accountability of SSNM," Draft PNL Report, December 1980.
2.
: 3. Glancy J., et al., " Feasibility and Cost / Benefit of Advanced Safeguards for Control of Nuclear Material In-Process," SAI, Inc., NUREG/CR-1686, August 1980.
Byers, K. R. and S. W. Heaberlin, "Value-Impact Analysis of Alternatives for Prompt Accountability of SSNM," Draft PNL Report, December 1980.
: 4. McDaniel, T. L., et al., "A Test Application of the NRC Reform Amendments to a Licensed Facility," SAI, Inc., November 1982.
3.
: 5. Hawkins, R. L., et al., "Using Advanced Process Monitoring to Improve Material Control," NUSAC, Inc., NUREG/CR-1676, NUSAC-556, September 1980.
Glancy J., et al., " Feasibility and Cost / Benefit of Advanced Safeguards for Control of Nuclear Material In-Process," SAI, Inc., NUREG/CR-1686, August 1980.
: 6. Eggers, R. F., et al, " Examples of MC&A Systems to Meet Prompt Accountability Specifications," PNL, December 1982.
4.
: 7. Stirpe, D., et al., "MC&A Reform Amendments:         Example System Beta, Variance Estimates and Performance Evaluation," LANL, August 1982.
McDaniel, T.
: 8. Al-Ayat, R. and B. Judd, "Value-Impact Analysis of Material Control and Accounting Upgrade Rule Alternatives," LLNL, November 1980.
L., et al., "A Test Application of the NRC Reform Amendments to a Licensed Facility," SAI, Inc., November 1982.
: 9. Kaplan,   A., General Electric-Wilmington, telephone conversation, February 2, 1981.
5.
: 10. Malanify, J. J., et al., "An Operational Advanced Materials Control and Accountability System," Nuclear Materials Management, Winter 1980.
Hawkins, R.
L., et al., "Using Advanced Process Monitoring to Improve Material Control," NUSAC, Inc., NUREG/CR-1676, NUSAC-556, September 1980.
6.
Eggers, R.
F., et al, " Examples of MC&A Systems to Meet Prompt Accountability Specifications," PNL, December 1982.
7.
Stirpe, D., et al., "MC&A Reform Amendments:
Example System Beta, Variance Estimates and Performance Evaluation," LANL, August 1982.
8.
Al-Ayat, R. and B. Judd, "Value-Impact Analysis of Material Control and Accounting Upgrade Rule Alternatives," LLNL, November 1980.
9.
: Kaplan, A., General Electric-Wilmington, telephone conversation, February 2, 1981.
10.
Malanify, J.
J., et al., "An Operational Advanced Materials Control and Accountability System," Nuclear Materials Management, Winter 1980.
l l
l l
l l
l l
* Questions concerning the availability of these documents should be addressed to Dr. W. B. Brown, Office of Nuclear Material Safety and Safeguards, U.S.
* Questions concerning the availability of these documents should be addressed to Dr. W. B. Brown, Office of Nuclear Material Safety and Safeguards, U.S.
Nuclear Regulatory Commission, Washington, DC 20555, phone (301) 427-4755.
l Nuclear Regulatory Commission, Washington, DC 20555, phone (301) 427-4755.
l l
l l
l l
l l
l 15
15


      --~
J
J
    'N
--~
'N
~
~
1 4
1 4
Line 2,298: Line 3,540:


DRAFT i
DRAFT i
NRC AMENDS MATERIAL CONTROL AND ACCOUNTING REGULATIONS FOR CERTAIN FUEL CYCLE FACILITIES The Nuclear Regulatory Commission is strengthening its regulations-for material control and accounting at certain types of fuel facilities by requiring                                                         3 more timely detection of a pc:sible loss of uranium, more conclusive determina-tion of whether material is actually missing, and improved availability of information to help recover the material in case of an actual loss.
NRC AMENDS MATERIAL CONTROL AND ACCOUNTING REGULATIONS FOR CERTAIN FUEL CYCLE FACILITIES The Nuclear Regulatory Commission is strengthening its regulations-for material control and accounting at certain types of fuel facilities by requiring 3
                            .The affected licensees are the operators of four high-enriched uranium processing facilities:                                                         Nuclear Fuel Services, Erwin, Tennessee; GA Technologies, San Diego, California; United Nuclear Corporation, Uncasville Connecticut; and Babcock and Wilcox, Lynchburg, Virginia.                                                                             ;
more timely detection of a pc:sible loss of uranium, more conclusive determina-tion of whether material is actually missing, and improved availability of information to help recover the material in case of an actual loss.
i                             Under the amended regulations, licensees will use data obtained by
.The affected licensees are the operators of four high-enriched uranium processing facilities:
;            in process monitoring of internal transfers, item control, ard material pro-cessing to detect possible losses more quickly.                                                         Ability to resolve discre-pancies and determine whether material is actually missing will be improved by decreasing the area and quantity of material subject to detailed examination, the number of employees potentially involved, and the time between a loss or mistake and its detection and resolution.
Nuclear Fuel Services, Erwin, Tennessee; GA Technologies, San Diego, California; United Nuclear Corporation, Uncasville Connecticut; and Babcock and Wilcox, Lynchburg, Virginia.
The amendments also require affected licensees to establish a system capable of detecting falsification of data to conceal diversion of nuclear material.                           They must provide protection against diversion by an employee in any position and against collusion between an individual with material control l
i Under the amended regulations, licensees will use data obtained by in process monitoring of internal transfers, item control, ard material pro-cessing to detect possible losses more quickly.
L ,     - , _ _ . , _ _ _ . . - .... _ ,_. .._.__.____. _ ._,..___ _ ._ _ _ _ _ _ _ _ . _ _ _ _ . . _
Ability to resolve discre-pancies and determine whether material is actually missing will be improved by decreasing the area and quantity of material subject to detailed examination, the number of employees potentially involved, and the time between a loss or mistake and its detection and resolution.
The amendments also require affected licensees to establish a system capable of detecting falsification of data to conceal diversion of nuclear material.
They must provide protection against diversion by an employee in any position and against collusion between an individual with material control l
L,


T ORAFT 6
T ORAFT 6
and accounting responsibilities and another individual with responsibilities in both that area and physical security.
and accounting responsibilities and another individual with responsibilities in both that area and physical security.
A proposed rule on this subject was issued on February 2, 1984. Changes made as a result of the comments received and details of the final rule are contained in a Federal Register notice published on                         .
A proposed rule on this subject was issued on February 2, 1984.
3 I
Changes made as a result of the comments received and details of the final rule are contained in a Federal Register notice published on 3
i 2
I i
                                                                    - ._.- - _.  .-.}}
2
.-.}}

Latest revision as of 01:11, 6 December 2024

Requests Approval to Publish Encl Amends to 10CFR74, Replacing Matl Control & Accounting Requirements for Fuel Cycle Facilities Licensed to Possess & Use SSNM Formula Quantities,Except Irradiated Fuel Reprocessing Plants
ML20210T087
Person / Time
Issue date: 12/24/1986
From: Stello V
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
TASK-RIA, TASK-SE SECY-86-380, NUDOCS 8702180056
Download: ML20210T087 (167)
v • d • e


Text

.

,f"

e u

5 3

December 24, 1986 SECY-86-380 RULEMAKING ISSUE (Affirmation)

For:

The Commissioners From:

Victor Stello, Jr.

Executive Director for Operations

Subject:

MATERIAL CONTROL AND ACCOUNTING REQUIREMENTS FOR FACILITIES LICENSED TO POSSESS AND USE FORMULA' QUANTITIES OF STRATEGIC SPECIAL NUCLEAR MATERIAL

Purpose:

To obtain approval to publish the enclosed amendments to 10 CFR Part 74 as a final rule which would replace the material control and accounting (MC&A) requirements for fuel cycle facilities licensed to possess and use formula quantities of strategic special nuclear material (SSNM), except irradiated fuel reproces-sing plants.

Category:

Major policy issue Discussion:

Background.

Current domestic MC&A regulations for SSNM focus on bimonthly inventories as the principal indicator of material status.

The usefulness of these inventories in providing assur-ance that significant quantities of SSNM have not been diverted has been limited by the difficulty encountered in conclusively resolving large inventory differences.

This inability to resolve large discrepancies has necessitated reliance instead on material control records, physical security records, and intelligence information for the desired assurance.

Improvements to nuclear material accounting requirements were explicitly directed by Congress in NRC's Authorization Act for 1980 and the Appropriation Bill for 1981.

On August 20, 1981, in response to SECY-81-432, the Commission approved the publication of an Advance Notice of Proposed Rulemaking (ANPRM) to solicit public comment on how to refocus the MC&A regulations for SSNM.

This Notice was published in the Federal Register on September 10, 1981 (46 FR 45144) and included a statement of rulemaking goals and five options for achieving the goals.

The primary goals included: (1) timely and localized detection of a possible mate-rial loss, (2) rapid determination of whether an actual loss

Contact:

C. Emeigh, NMSS 42-74769 W DD

m.4 The Commissioners

  • occurred, and (3) ready availability of information to aid in the recovery of material in the event of an actual loss.

Two of the options for achieving these goals retained the current emphasis on periodic physical inventories.

The other options introduced requirements for more timely use of process monitoring information for safeguards purposes and de-emphasized the importance and fre-quency of physical inyt.ntories.

Respondents to the ANPRM in some instances expressed reservations on the use of process monitoring information for safeguards pur-poses because of a lack of demonstrable evidence that it could be applied successfully, but they did not propose alternative MC&A improvements.

Based on the comments received and on continuing technical studies, a decision was made to proceed with a proposed rule.

The proposed rule that was forwarded to the Commission for publication included much of the substance of Options 3 and 4 of the ANPRM, rewritten to:

(1) delete unnecessarily prescriptive requirements, (2) reduce the number of plans and programs required, (3) improve clarity, (4) incorporate certain capabilities to pro-tect against inside adversaries, and (5) provide flexibility for licensees to select the most cost-effective ways for achieving performance objectives.

The proposed rule (SECY-83-83 dated February 25, 1983) was published in the Federal Register on February 2, 1984 (49 FR 4091). Public comments were requested by June 5, 1984, but at the request of interested parties, the time period was extended to September 5, 1984.

Comments were received from four licensees and the Department of State which coordinated comments from the Executive Branch.

The Department of State pointed out that since the International Atomic Energy Agency (IAEA) did not have experience with process and item monitoring concepts in their verification activities, it was not possible to judge the extent to which IAEA safeguards requirements would be met by the proposed regulations.

After due consideration of this point, it was concluded that the proposed requirement for semiannual inventories would satisfy IAEA needs.

The licensees raised several substantive technical issues that resulted in changes in the final amendments.

These are discussed in detail in the Federal Register Notice (Enclosure A).

Some comments did not result in changes to the proposed ule.

Gener-ally those comments were based on a misinterpretation of the pro-posed amendments.

Additionally, there were comments on the Standard Format / Acceptance Criteria document, the Regulatory Analysis, and the rulemaking process.

Comments on the Standard Format / Acceptance Criteria were taken into account in the current version of the document.

Comments on the Regulatory Analysis and the rulemaking process are addressed in the Federal Register Notice.

The Commissioners With the publication of the Low Enriched Uranium Reform Amendments in 1985, a new Part 74 was created for MC&A requirements to separ-ate them from the safety. requirements in Part 70 and to present the requirements in an orderly format. Consistent with the objec-tive of codifying all MC&A requirements in Part 74, requirements proposed as 65 70.81 through 70.89 have been redesignated as 65 74.51 through 74.59 in the final rule. The MC&A requirements that will remain in SS 70.51, 70.57 and 70.58 will apply only to strategic special nuclear material in irradiated fuel reprocessing i

plants, special nuclear material of moderate strategic significance, and special nuclear material of low strategic significance possessed by licensees whose authorized possession does not require submission of an MC&A plan.

In the future, performance-oriented MC&A require-ments for these classes of licensees will be added to Part 74.

Summary of Amendments. These final amendments implement the fol-lowing major changes to the current MC&A ragulations for SSNM.

o Timely alarms will be generated for anomalies potentially indicative of SSNM losses through the use of production and quality control data for MC&A purposes, o

The ability to conclusively resolve MC&A alarms will be enhanced by decreasing the processing area and material quantity subject to an alarm, the number of persons who potentially could provide information about the cause of an alarm, and the length of time between a loss (or mistake) and its detection and resolution, o

The detection goal for abrupt losses from each unit process will be a formula quantity as defined in 5 73.2(bb).

o Alarm resolution decision criteria will be based on an assess-ment of whether interruption of processing activities would facilitate rapid resolution of a localized alarm.

o The MC&A system design will be required to include protection against a specifically identified threat from an insider, o

The total variance of inventory difference (ID), rather than just the variance of ID due to measurement uncertainty, will be permitted to be used in ID evaluation.

i o

Statistical terminology that is not in general use in the statistical community, a principal criticism of current requirments, will be eliminated.

l o

The frequency of physical inventories will be reduced from l

bimonthly to semiannual.

l

The Comissionars ;

Costs and Benefits. The rule will affect four high enriched uranium fuel processing facilities.

It will also apply to new high enriched uranium and plutonium conversion and fabrication facilities if such facilities are licensed in the future.

The cost / benefit analysis summarized in the Regulatory Analysis i

(Enclosure C) shows that the amendments will be cost-effective for the affected licensees. This will be accomplished by eliminating current requirements that are not cost-effective and by taking advantage of existing process, production, and quality control information for enhancing safeguards capabilities.

Implementation costs for the entire industry are estimated to be on the order of

$2.5M. These costs will be recovered in two to nine years, deperd-ing upon the facility type, through reductions in annual operating costs.

It should be noted that staff considered the fact that only four facilities will be affected by this rule, and the rule's major provisions could be readily implemented through license amendments.

However, in view of the guidance provided by the NRC legal staff that new requirements of general applicability should be imposed by rule rather than order and the benefit to applicants of having currently applicable MC&A regulations in-place during the facility design stage, the decision was made to continue with a rulemaking.

==

Conclusion:==

The staff finds that the proposed amendments accomplish the objec-tive of upgrading material control and accounting for strategic special nuclear material consistent with.its strategic significance without creating a technically complex program that is heavily burdensome on the industry.

Recommendation. That the Comission:

)

1.

Approve the amendments and authorize publication of Enclo-sure A in the Federal Register as a final rule, to become effective 30 days after publication.

2.

Certify, in order to satisfy the requirements of the Regulatory l

Flexibility Act, 5 U.S.C. 605(b), that this rule will not have l

a significant economic impact on a substantial number of small i

entities. This certification is included in the Federal Register Notice.

3.

Note:

l a.

That the appropriate Congressional comittees will be notified of this Comission action.

l b.

That the Comission has determined under the National Environmental Policy Act of 1969, as amended, and the l

Comission's regulations in Subpart A of 10 CFR Part 51, i

f

The Commissienzrs that this rule, if adopted, is not a major Federal action significantly affecting the quality of the human environ-ment and therefore an environmental impact statement is not required.

c.

That the Chief Counsel for Advocacy of Small Business Administration will be informed of the certification and the reason for it as required by the Regulatory Flexibility Act.

d.

That a public announcement will be issued when the amendments are filed with the Office of the Federal Register.

e.

That copies of this notice will be distributed to affected licensees and other interested parties by the Office of Administration, f.

That copies of the Regulatory Analysis and the Standard Format / Acceptance Criteria guide have been placed in the' NRC Public Document Room.

g.

That this final rule amends information collection requirements that are subject to the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.).

These require-ments were approved by the Office of Management and Budget approval numbers 3150-0009 for Part 70 and 3150-0123 for Part 74.

h.

That ACRS decided to take no action on the rule.

i.

That the final rule and associated guidance will resolve deficiencies in the current MC&A rules that were iden-tified in the information report (SECY 80-514) on the Statistical Treatment of Inventory Differences.

Victor Stello, Jr.

Executive Director for Operations

Enclosures:

A.

Proposed Federal Register Notice B.

Standard Format / Acceptance Criteria C.

Regulatory Analysis D.

Oraft Public Announcement

6'

.o Commissioners' comments should be provided directly to the Office of the Secretary by c.o.b. Friday, January 16, 1987.

Commission Staff Office comments, if any, should be submitted to the Commissioners NLT Friday, January 9, 1987, with an information copy to the Office of the Secretary.

If the paper is of such a nature that it requires additional time for analytical review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.

This paper is tentatively scheduled for affirmation at an Open Meeting during the Week of January 19, 1987.

Please refer to the appropriate Weekly Commission Schedule, when published, for a specific date and time.

DISTRIBUTION:

Commissioners OGC (H Street)

OI OCA OIA OPA REGIONAL OFFICES EDO OGC (MNBB)

ACRS ASLBP ASLAP SECY

f

,l '

. [ $-

ENCLOSURE A l

I l

l l

[7590-01]

r NUCLEAR REGULATORY COPMISSION 10 CFR Parts 70 and 74 Material Control and Accounting Requirements for Facilities Licensed to Possess and Use Formula Quantities of Strategic Special Nuclear Material AGENCY:

Nuclear Regulatory Commission ACTION:

Final rule SJMMARY:

The Nuclear Regulatory Commission is amending its material control aid accounting (MC&A) requirements 'or facilities licensed to possess and use formula quantities of strategic special nuclear material (SSNM).

These amend-ments will apply to all such fuel cyple facilities except irradiated fuel reprocess-ing plants, waste disposal operations. nuclear reactors, and users of nuclear materials in sealed sources.

T;1e amer.dments will significantly strengthen MC&A capabilities at the affected facilities by requiring more timely detection of anomalies potentially indicative of SSNM losses and by providing for more rapid and conclusive resolution of discrepancies.

The amendments will be cost-effective by virtue of the fact that current requirements which are not cost-effective will be eliminated and existing process, production, and quality con-trol information will be utilized to enhance material control and accounting capabilities.

ENCLOSURE A

EFFECTIVE DATE:

i FOR FURTHER INFORMATION CONTACT:

Mr. C. W. Emeigh, Safeguards Material Licensing and International Activities Branch, Division of Safeguards, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, Washington, D.C.

20555 Telephone:

(301) 427-4769 SUPPLEMENTARY INFORMATION:

BACKGROUND The amended MC&A requirements are being codified in 10 CFR Part 74 which has been established for documentation of all specific domestic MC&A regulatory requirements.

Requirements for general licenses have been retained in Part 70.

Four high enriched uranium processing facilities will be subject to the amended requirements:

Babcock and Wilcox, Lynchburg, Virginia; GA Technologies, San DieGo, California; Nuclear Fuel Services, Erwin, Tennesee; and United Nuclear Corporation, Uncasville, Connecticut.

Licensees processing special nuclear material of low strategic significance will continue to be subject to S74.31, while licensees processing special nuclear material of moderate strategic significance and potential licensees processing strategic special nuclear material in irradiated fuel reprocessing plants will continue to be subject to the MC&A requirements contained in 10 CFR Part 70.

Current domestic MC&A regulations for strategic special nuclear material require bimonthly inventories.

Comparison of an inventory difference (ID) with 2

its associated limit of error (LEID) and with percent of throughput does not occur until nearly 30 days after the beginning of the physical inventory.

Con-sequently, a thorough investigation of any identified anomaly might not occur, in the worst case, for 90 days after the contributing event occurred.

The use-fulness of these bimonthly inventories in providing assurance that significant quantities of SSNM have not been diverted has been limited by the difficulty i

encountered in conclusively resolving large inventory differences.

This has necessitated reliance on material control data, plant security records, and intelligence information for the desired assurance.

Recognizing this short-coming, on August 20, 1981, the Commission approved publication of an Advance Notice of Proposed Rulemaking (ANPRM) to solicit public comment on how to revise

'l MC&A regulations for SSNM that is capable of being made into fission explosives.

The ANPRM, which was published in the Federal Register on September 10, 1981 (46 FR 45144), included goals of the rulemaking and five options for achieving 1

l those goals.

The primary goals were stated as:

(1) timely and localized detec-i tion of anomalies potentially indicative of a material loss, (2) rapid deter-t mination of whether an actual loss had occurred, and (3) availability of information to aid in the recovery of material in the event of an actual loss.

Two of the five options suggested in the ANPRM for achieving these goals retained an emphasis on periodic physical inventories.

The other three options i

introduced requirements for the timely use of process monitoring information for safeguards purposes with de-emphasis of the importance and frequency of physical inventories.

Responders to the ANPRM in some instances expressed reser-vations on the feasibility of using process monitoring information for safeguards purposes because of the lack of demonstrable evidence of successful application, h

r t

3

1 but suggested no alternatives.

Based on the comments received and on the results of continuing technical studies, a decision was made to proceed.

The proposed rule that was presented to the Commission for publication included much of the-substance of Options 3 and 4 of the ANPRM but was rewritten to:

(1) delete unnecessarily prescriptive requirements, (2) reduce the number of plans and pro-grams required, (3) improve clarity, (4) incorporate capabilities to protect against certain types of inside adversary, and (5) provide flexibility for licensees to select the most cost-effective ways of achieving performance objectives.

The rule gave credit for SSNM in secure containment and recognized differences with respect to safeguards vulnerability between processing SSNM in j

bulk form and in encapsulated form.

I The proposed rule was published in the Federal Register on February 2, 1984 (49 FR 4091).

Concurrent with the publication, copies of a Standard i

Format / Acceptance Criteria guide and a Regulatory Analysis were placed in the Public Document Room.

Public comments were requested to be submitted by June 5, 1984.

Citing technical complexity as the principal reason, the affected Ifcensees requested an extension of the comment period.

The comment period subsequently was extended to September 5, 1984 (June 19, 1984; 49 FR 25005).

1 COMMENTS ON THE PROPOSED RULE The Commission received four letters from licensees and a memorandum from the Department of State commenting on the proposed rule.

Copies of the letters are available for pubite inspection and copying for a fee at the NRC Public Document Room at 1717 H Street NW., Wasington, D.C.

20555.

j 4

4

[

.--.-#. c-m-.-

..,~_.,.m,--

~_

,,.,__---,._m.,-.,_,_y,,x._.

w-y._,.____y

a Changes in Response to Public Comments 1.

Three respondents expressed concern over the technical feasibility of implementing an MC&A system in compliance with proposed rule requirements.

One respondent pointed out that experimentt.1 projects designec' to enhance near-real-time accounting failed to demonstrate the applicability of the technique in actual operating plants.

A second respondent took issue with a statement in the Regulatory Analysis which indicated that the prompt accountability concept was technologically feasible and that significant benefits to MC&A systems could be achieved at moderate cost.

The respondent cited results of a study performed at its site for the Commission as the basis for its skepticism.

The third respondent expressed concern over the complex statistics that obviously would be involved in analyzing material control test data over space and time, as had been proposed.

The Commission has re-evaluated the in process monitoring requirements in the proposed rule with respect to whether or not design goals could be achieved.

Based on this re-evaluation the Commission concluded that the objective of upgraded material control and accounting systems could be achieved through less drastic modification of existing requirements.

This change in direction has resulted in deletion of multiple time and area-wide loss detection tests from the rule and addition of requirements for quality control tests and trend analyses at the unit process level.

Additionally, physical inventory require-ments have been modified in the area of inventory difference evaluation criteria.

The significance of an inventory difference will be initially tested against a threshold that takes into account measurement error only.

If this threshold is 5

w I

exceeded, an investigation will be required which must include the computation of a second threshold that takes historical ID variation into account.

2.

A comment was received to the effect that research and development operations by design do not achieve the steady state conditions required for application of in process monitoring tests for loss detection.

The respondent proposed that such operations be exempted from in process monitoring requirements and instead be subjected to either bimonthly inventories or periodic material balances coupled with item monitoring.

The Commission agrees with this assessment and has modified the rule for research and development operations to require material balances on a lot or batch basis, item monitoring, and analysis of material balance data for trends.

An appropriate exemption has been added to $74.53(a) in addition to the new requirements in paragraph (c) of the same section.

3.

A respondent stated an opinion that samples should be exempt from in-process monitoring requirements on the basis that the SSNM quantities in samples are small and would require the acquisition of a large number by an adversary in order to obtain five formula kilograms.

Sample control systems would rapidly i

detect such a removal.

An additional relevant point was the fact that the total quantity of SSNM in a laboratory is typically small.

l The Commission agrees with the respondent and exempted samples containing less than 0.05 formula kilograms of SSNM from in process monitoring requirements and modified item monitoring requirements to allow for the treatment of such samples as items.

Larger samples are expected to be within the scope of a material control test whether it be applied in the originating process unit or in the laboratory.

In the former case, adequate administrative controls

would be required to protect the integrity of the sample until it was returned to the originating process unit.

4.

Two respondents expressed concern over the effect of data that is statistically non normal on the establishment of alarm thresholds for loss detection.

The respondent indicated that analyses of current process monitoring data pointed up the fact that, for some units, test data were non normally distributed.

The Commission agrees that this is a concern, especially if the tails of a statistical distribution come into consideration.

Unacceptably high false alarm rates will result when such conditions exist.

To alleviate this concern, the required detection probability for losses from individual process units has been revised downward from 99 percent to 95 percent.

5.

Comments were received from two licensees regarding the difficulties likely to be encountered in complying with the bias correction requirements reflected in the proposed rule.

The principal difficulty lies in the fact that bias corrections are not sufficiently timely to permit record corrections to be made on the process floor.

Retroactive corrections to the book records neces-sitate the correction of label values on individual items if the accounting sys-tem is to balance.

The Commission agrees that bias corrections are difficult to accommodate in the accounting system.

However, accounting for the impact of biases is an important consideration in achieving a reliable MC&A system.

Consequently, requirements for bias corrections have been retained but modified to resolve some of the associated difficulties.

i 7

. 7.

--,_.---..-,__.._-.r

a 6.

A respondent requasted that consideration be given to permitting stor-age if untamper-sealed items,in-enclosures other than vaults.

The respondent i

provided examplesif situktions in which untamper-sealed containers and N

unencapsulated solid fu'el forms were stored in controlled access areas for

. varying time periods during the fabrication process.

It was pointed out that in many instances it was impraci.ical to tamper-seal certain material forms and that minimal handling was important to prevent damage.

The-respondent's. points are considered valid.

Consequehtly, the final rule has been modified to permit storage of untamper-sealed containers in permanently r

controlled access areas.

As indicated in the acceptance criteria, the area should be equipped with adequate controls to preclude undetected access to the SSNM by one individual in any position.

The requirement to provide protection 3

at least equivaledt to tamper-safing dictates the level of control that is n

expected.

k i

7.

One respondent stated that the requirements of 10 CFR 70.57 and 70.58 i

should be ' hanged to performance-oriented safeguards. '

c i

i

>The Commission agrees with the respondent's statement and has taken action to accomplish this task.

The quality assurance and accounting requirements in e

' $70.89 of the proposed rule (S 74.59 of the final rule) have been replaced with portions of 10 CFR 70.57 and 70.58 that have been' rewritten to be performance i oriented, to deleta/ obsolete requirements, and to clarify the quality assurance I

\\

l and accounting requirements applicable to Category I licensees.

l 1

l l

l t

s I

j t

8

+

~-.1

,,m.~+-.

.yo,-.-

..-,--....-.,~e, e-

~,.,.----.-r

Comments Not Incorporated 1.

A respondent indicated that the 0.1 percent of active inventory limit on the standard error of the~ inventory difference estimator was not achievable for its particular process.

This comment appears to be the result of a misconception of what is being required.

The proposed limit, while somewhat more restrictive than the current limit, should be achievable without extraordinary effort.

Taking into account the differences in the method of computation, the current limit (i.e. 0.5% of additions to or removals from process expressed at the two standard deviation level) would equate to one standard deviation being less than 0.125 percent of active inventory.

The decrease to 0.10 percent of active inventory is con-sidered justified on the premise that there have been significant advances in state-of-the-art measurement technology since the current limit was imposed.

A review of the level of performance of current licensees supports this conclusion.

2.

A respondent expressed concern over the restrictions that might be imposed on the use of its workforce if detection within administratively controlled areas were to be required.

This comment became moot when area loss detection requirements were deleted l

l from the rule.

l 3.

A comment was received to the effect that the proposed 0.25 gm/ liter limit on the concentration of SSNM in scrap contained in 30 gallon or larger containers would have a significant impact on a licensee's storage capability.

Additionally, the respondent indicated that the proposed limit would have a significant impact on the amount of SSNM per container that they could receive from off-site for scrap recovery.

9 i

L

The exemption. documented in 970.83(a)(2) of the proposed rule ($ 74.53(a)(2) of the final rule) is not intended to be a limit on the amount of SSNM per con-tainer.

Instead the 0.25 gm/ liter criterion is considered a de minimis quantity below which application of the in process monitoring requirements of paragraph (b) of the same section is not required.

4.

The necessity for including fuel fabrication facilities in the scope of rule applicability was-questioned by a respondent.

The contention was put forth that, unlike conversion facilities, the problems the rule is intended to address are not present in fabrication facilities (i.e. unmeasured side streams and large inventory differences).

The Commission agrees that excessive inventory differences are less likely to occur in fuel fabrication facilities since there is minimal handling of SSNM in bulk form and the materials do not change chemical form.

However, this does not preclude the possibility of a significant diversion.

Consequently, the decision has been made to apply the rule to fuel fabrication as well as conversion facilities.

5.

Affected licensees stated that, in their opinion, the conclusions reflected in the Regulatory Analysis were not representative of the actual cost impact likely to be experienced at their facilities, i

In response, site-specific value/ impact analyses were performed.

Informa-tion obtained in preparing those analyses has been taken into account in the 1

revised Regulatory Analysis prepared in support of the final rule.

6.

A respondent expressed concern that drastic changes in regulatory requirements, such as those incorporated in the proposed rule, were not receiv-ing adequate review within the Commission prior to publication for comment.

In particular, the respondent indicated that there should be more involvement of 10

licensing and inspection personnel in the rulemaking process in view of their roles in ultimately approving licensees' plans and inspecting their application.

The Commission does not agree with the respondent's position.

Rulemaking procedures include scheduled milestones for review and comment by licensing, inspection, and other interested regulatory personnel during the formulation of new rules. Rules are particularly reviewed for inspectability prior to issuance.

Other Changes 1.

Requirement: of the proposed rule in SS70.81 through 70.89 have been redesignated SS74.51 through 74.59 in the final rule.

This change was made to be consistent with the Commission's objective of eventually incorporating all domestic MC&A regulatory requirements in Part 74.

With this action, the MC&A requirements in SS70.51, 70.57, and 70.58 apply only to licensees possessing and using special nuclear material of moderate strategic significance, strategic special nuclear material in irradiated fuel reprocessing plants, and special categories of licensees possessing SNM of low strategic significance who are not currently required to have an approved MC&A plan.

Performance-oriented regulations subsequently are expected to be developed for those categories of licensees and incorporated in Part 74.

i l

2.

The list of definitions in S74.4 has been expanded to include appro-l priate definitions from Part 70 and new definitions applicable to the subject rule. Additional definitions may be added when the rules for other categories i

of licensees, referenced above, are transferred to Part 74.

With respect to i

i 11

terminology, Part 74 reflects the terms the Commission now prefers when refer-ring to certain MC&A and statistical concepts.

However, the language in Part 70 has not been changed.

3.

Irradiated fuel reprocessing plants have been deleted from the applica-bility statement in the final rule.

This action was taken because of unresolved questions as to whether a reprocessing plant could comply with all rule require-ments and the negative outlook for domestic reprocessing in the near term.

It is expected that by the time reprocessing becomes a viable option in the United States, there will be significant technological advances that will influence material control and accounting system design for such plants.

4.

A statement has been added to $74.51 to clarify the fact that licensees are required to follow currently approved fundamental nuclear material control plans until newly submitted plans are reviewed and approved.

5.

Section 74.51(c) has been modified to provide flexibility in the tim-ing of the implementation of commitments in support of the new rule.

Depending upon current MC&A practices, the complexity of production operations, and advance planning by the licensees, the time within which adequate performance against rule requirements is achieved will vary from licensee to licensee.

In some cases, current practices approach what would be expected under an upgraded MC&A system.

Under these conditions, a licensee may be able to achieve adequate performance in less than six months.

At the other extreme, the current system may bear no resemblance to an upgraded system; hence, longer than six months 1

may be required for full implementation of the rule.

6.

The deletion of irradiated fuel reprocessing plants from the scope of the rule made the exemption for SSNM exhibiting external radiation in excess of 100 rem per hour at three feet irrelevant.

Therefore, this proposed exemption 12 I

has been deleted. Any Category I licensee who may have occasion to handle irradiated fuel may request an exemption from the in process monitoring require-ments of S 74.53(b).

7.

For SSNM having an estiinated measurement uncertainty greater than five percent that is either input to or output from a unit operation that processes less than five formula kilograms in three months, a new exemption has been added to 974.53(a). This exemption is considered appropriate on the basis of the low throughput of the unit, the unattractive nature of the material, and the high uncertainty that would be associated with any material control test results.

8.

A requirement has been added to S74.55 to detect a five formula kilo-gram loss within two months for items stored in a permanently controlled access area located outside of an MAA.

This requirement was inadvertently omitted from the proposed rule.

This oversight has been discussed with affected licen-sees who concurred with the need for the requirement.

9.

Miscellaneous minor changes have been made that have no impact on the substance of the rule.

INTERNATIONAL CONSIDERATIONS It should be ncted that the performance goals for the rule, stated pre-viously, are domestic 00als and are considered to be appropriate for a subna-tional threat.

For all U.S. licensees, the detection and response capability of the rule have been determined to be sufficient to adequately protect the public health and safety from a subnational threat.

On the other hand, the International Atomic Energy Agency (IAEA), which is responsible for applying international safeguards in non-nuclear weapons states, must judge whether a 13

significant~ diversion has occurred in the face of a possible national conspiracy.

In order to reach its conclusion with the required level of certainty, the IAEA may find it necessary to continue to place primary reliance on periodic physical inventories as opposed to an analysis of process monitoring data, as promulgated in this rule.

ENVIRONMENTAL IMPACT CATEGORICAL EXCLUSION The material control and accounting (MC&A) requirements for licensees licensed to possess and use five or more formula kilograms of strategic special nuclear 1

material will be amended in two major ways:

l The first major amendment will move certain safeguards related recordkeeping and reporting requirements now found in Part 70 to Part 74 to be consistent with the Commission's objective for separating safety requirements from safeguards requirements.

Pursuant to 10 CFR 51.22(c)(3)(ii) and (iii), a categorical exclusion is granted to amendments to Commission regulations that relate to recordkeeping and reporting requirements.

Moving the MC&A requirements from Part 70 to Part 74 meets the eligibility criteria for this categorical exclusion.

Accord-l ingly, no environmental impact statement or environmental assessments needs'to be prepared in conjunction with the issuance of these amendments.

1 i

14 l

4

__....__-,.-.._-..__.,-m_._--.,,,_,..._..._.-.___,,

FINDING OF NO SIGNIFICANT ENVIRONMENTAL IMPACT: AVAILABILITY The second major amendment will modify material control and accounting requirements for licensees who possess and use formula quantities of strategic special nuclear material to achieve the following objectives:

Prompt investigation of anomalies potentially indicative of SSNM

losses, Timely detection of the possible abrupt loss of five or more formula kilograms of SSNM from individual unit processes, Rapid determination of whether an actual loss of five or more formula kilograms occurred, Ongoing confirmation of the presence of SSNM in assigned locations, and Timely generation of information to aid in the recovery of SSNM in the event of an actual loss.

The principal differences between the MC&A requirements in this rule and those in the current rules are the use of process monitoring data for material control, a longer interval between physical inventories, and an item monitoring program designed to detect a five formula kilogram loss.

For the following reasons, the Commission has determined not to prepare an environmental impact statement for the second major amendment and, in accordance with 10 CFR 51.32 and 51.34, finds that the proposed amendments have no sig-nificant impact on the environment.

1.

The rule will not result in changes in the licenses' processes or manufacturing procedures and therefore will not affect or alter any release of effluents to the environment.

2.

The rule will affect four high enriched uranium fuel processing facilities, all of whom have undergone individual NEPA review.

15

The environmental assessment upon which the foregoing determination is based is included in the Regulatory Analysis for this rulemaking action and is avail-able for public inspection at the NRC Public Document Room, 1717 H Street NW, Washington, D.C.

Single copies of the environmental assessment and finding of no significant impact are available from Dr. W. B. Brown, Chief, Safeguards Material Licensing and International Activities Branch, Division of Safeguards, Office of Nuclear Material Safety and Safeguards, Nuclear Regulatory Commission, Washington D.C. 20555, telephone (301)427-4185.

PAPERWORK REDUCTION ACT STATEMENT 4

This final rule amends information collection requirements that are subject to the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.).

These require-ments were approved by the Office of Management and Budget approval number 3150-0009 (for Part 70) and 3150-0123 (for Part 74).

REGULATORY ANALYSIS The Commission has prepared a regulatory analysis on this final rule.

The analysis examines the costs and benefits of the alternatives considered by the Commission.

The analysis is available for inspection or copying for a fee in the NRC Public Document Room, 1717 H Street, NW, Washington, DC.

Single copies of the analysis may be obtiined from (insert name, address and telephone number of contact person).

16

REGULATORY FLEXIBILITY CERTIFICATION In accordance with the Regulatory Flexibility Act of 1980, 5 U.S.C. 605(b),

the Commission hereby certifies that this rule will not, if promulgated, have a significant economic impact on a substantial number of small entities.

This rule affects four facilities that process high enriched uranium and is expected to result in a positive cost / benefit to the industry and, in addition, to provide enhanced safeguards capabilities.

The facilities include:

Babcock and Wilcox Company, Lynchburg, Virginia; GA Technologies, San Diego, California; Nuclear Fuel Services, Erwin, Tennessee; and United Nuclear Corporation, Uncasville, Connecticut. These companies are dominant in their service areas and do not fall within the definition of "small entities" set forth in the Regulatory Flexibility Act or by the Small Business Administration in 13 CFR Part 121.

BACKFIT ANALYSIS The staff has determined that a backfit analysis is not required for this rule since these amendments do not apply to 10 CFR Part 50 licensees.

LIST OF SUBJECTS IN 10 CFR PARTS 70 AND 74 Part 70:

Accounting, Hazardous materials-transportation, Material control and accounting, Nuclear materials, Packaging and containers, Penalty, Radiation protection, Reporting and recordkeeping requirements, Scientific equipment, Security measures, Special nuclear material.

17

~.

+

4 i

L l

Part 74:

Accounting, Material control and accounting, Nuclear materials, Penalty, Reporting and recordkeeping requirements, Special nuclear material.

Under the authority of the Atomic Energy Act of 1954, as amended, the t

Energy Reorganization Act of 1974, as amended, and 5 U.S.C. 553, the NRC is adopting the following amendments to 10 CFR Parts 70 and 74.

i PART 70 DOMESTIC LICENSING OF SPECIAL NUCLEAR MATERIAL 1.

The authority citation for Part 70 is revised to read as follows:

Authority:

Secs. 51, 53, 161, 182, 183, 68 stat. 929, 930, 948, 953, 954, as amended, sec. 234, 83 stat. 444, as amended (42 U.S.C. 2071, 2073, 2201, 2232, 2233, 2282); secs. 201, as amended 202, 204, 206, 88 stat. 1242, as amended, 1244, 1245, 1246 (42 U.S.C 5841, 5845, 5846).

j Section 70.7 also issued under Pub. L.95-601, sec. 10, 92 Stat. 2951 (42 U.S.C. 5851).

Section 70.21(g) also issued under sec. 122, 68 Stat. 939 (42 U.S.C. 2152).

Section 70.31 also issued under sec. 57d, Pub. L.93-377, 88 Stat. 475 (42 U.S.C. 2077).

Sections 70.36 and 70.44 also issued under l

sec. 184, 68 Stat. 954, as amended (42 U.S.C 2234).

Section 70.61 also issued under secs. 186, 187, 68 Stat. 955 (42 U.S.C. 2236, 2237).

Section 70.62 also

[

issued under sec. 108, 68 Stat. 939, as amended (42 U.S.C. 2138) i For the purposes of Sec. 223, 68 Stat. 958, as amended (42 U.S.C. 2273);

l

$$ 70.3 70.19(c), 70.21(c), 70.22(a), (b), (d)-(k), 70.24(a) and (b),

70.32(a)(3), (5), (6), (d), and (1) 70.36, 70.39(b) and (c), 70.41(a),

70.42(a) and (c), 70.56, 70.57(b), (c), and (d), 70.58(a)-(g)(3), and (h)-(j)

I are issued under sec. 161b, 68 Stat. 948, as amended (42 U.S.C. 2201(b));

i

$$ 70.7, 70.20a(a) and (d), 70.20b(c) and (e), 70.21(c), 70.24(b),

l 18 i

.n-.

,n

70.32(a)(6),-(c), (d), (e), and (g), 70.36, 70.51(c)-(g), 70.56, 70.57(b) and (d), and 70.58(a)-(g)(3) and (h)-(j) are issued under sec. 1611, 68 Stat. 949, as amended (42 U.S.C. 2201(i)); and $$ 70.20(d) and (e), 70.38, 70.51(b) and (1), 70.52, 70.53, 70.54, 70.55, 70.58(g)(4), (k), and (1), 70.59, and 70.60(b) and (c) are issued under sec. 1610, 68 Stat. 950, as amended (42 U.S.C. 2201(o)).

2.

In S 70.22, paragraph (b) is revised to read as follows:

$ 70.22 Contents of applications.

n a

a a

(b) Each application for a licensee to possess and use at any one time and location special nuclear material in a quantity exceeding one effective kilogram except for applications for use as sealed sources and for those uses involved in the operation of a nuclear reactor licensed pursuant to Part 50 of this chapter and those involved in a waste disposal operation, must contain a full description of the applicant's program for control and accounting for that special nuclear material which will be in the applicant's possession under license, to show how compliance with the requirements of 5 70.58, S 74.31 or S 74.51 of this chapter, as applicable, will be accomplished.

3.

In S 70.32, paragraph (c)(1) is revised to read as follows:

$ 70.32 Conditions of licenses A

A A

A (c)(1) Each license authorizing the possession and use at any one time and location of special nuclear material in a quantity exceeding one effective kilogram, except for use as sealed sources and those uses involved in the operation of a nuclear reactor licensed pursuant to Part 50 of this chapter, 19

j i

and those involved in a waste disposal operation shall contain and be subject f

to a condition requiring the licensee to maintain and follow:

i (i) The program for control and accounting for special nuclear material i

i and fundamental nuclear material controls' described pursuant to $$ 70.22(b),

70.58(1), 74.31(b) or 74.51(c)(1) of this chapter, as appropriate; (ii) The measurement control program for special nuclear material control and accounting described pursuant to SS 70.57(c), 74.31(b) or 74.59(e) of this chapter, as appropriate; and i

(iii) Such other material control procedures as the Commission determines to be essential for the safeguarding of special nuclear material and providing that the licensee shall make no change which would decrease the effectiveness to the material control and accounting program prepared pursuant to 55 70.22(b),

70.58(1), 70.51(g), 74.31(b) or 74.51(c)(1) of this chapter, and the measurement control program prepared pursuant to $$ 70.57(c), 74.31(b) or 74.59(e) of this l

chapter without the prior approval of the Commission.

A licensee desiring to l

l make such changes shall submit an application for amendment to its license pur-i i

suant to S 70.34.

n a

a a

a dl 4.

In S 70.51, paragraph (b) and the introductory text of paragraph (e) i are revised to read as follows:

i 5 70.51 Material balance, inventory, and records requirements n

a a

n l

5 (b) Licensees subject to the recordkeeping requirements of $$ 74.31 and 74.59 of this chapter are exempt from the requirements of $ 70.51 (b)(1) l through (5).

I i

Otherwise:

t l

20 l

A A

A A

A (e) Each licensee who is authorized to possess at any one time special nuclear material in a quantity exceeding one effective kilogram of strategic special nuclear material in irradiated fuel reprocessing operations or special nuclear material of moderate strategic significance and to use such special nuclear material for activities other than as sealed sources or those activities involved in the operation of a nuclear reactor licensed pursuant to Part 50 of this chapter or those involved in a waste disposal operation; or as reactor irradiated fuels involved in research, development, and evaluation programs in facilities other than irradiated fuel reprocessing plants, shall:

A A

A A

A 5.

In S 70.57, the introduction to paragraph (b) is revised to read as follows:

S 70.57 Measurement control program for special nuclear material control and accounting.

A A

A A

A (b) In accordance with S 70.58(f), each licensee who is authorized to possess at any one time and location strategic special nuclear material in irradiated fuel reprocessing operations or special nuclear material of moderate strategic significance in a quantity exceeding one effective kilogram and to use such special nuclear material for activities other than as sealed sources or those activities involved in the operation of a nuclear reactor licensed pursuant to Part 50 of this chapter, or those involved in waste disposal operations, shall establish and maintain a measurement control program for special nuclear material control and accounting measurements.

Each program function shall be identified and assigned in the licensee organization in 21

I accordance with 9 70.58(b)(2), and functional and organizational relationships shall be set forth in writing in accordance with 8 70.58(b)(3).

The program shall be described in a manual referenced in the Plan which shall contain the proce-dures, instructions, and forms prepared to meet the requirements of this para-graph, including procedures for the preparation, review, approval, and prompt dissemination of any program modifications or changes.

The licensee's program shall include the following:

6.

In S 70.58, paragraph (a) is revised to read as follows:

$ 70.58 Fundamental nuclear material controls.

(a) Each licensee who is authorized to possess at any one time and location strategic special nuclear material in irradiated fuel reprocessing operations or special nuclear material of moderate strategic significance in a quantity exceeding one effective kilogram, and to use such special nuclear material except for sealed sources and those uses involved in the operation of a nuclear reactor licensed pursuant to part 50 of this chapter and those involved in a waste disposal operation, shall establish, maintain, and follow written material control and accounting procedures in compliance with the fundamental nuclear material control requirements specified in paragraphs (b) through (k) of this section and such other controls as the Commission determines to be essential l

l for the control of and accounting for special nuclear material.

A A

A A

A i

i 22

PART 74 - MATERIAL CONTROL AND ACCOUNTING OF SPECIAL NUCLEAR MATERIAL 7.

The authority citation for Part 74 continues to read as follows:

AUTHORITY: Secs. 53, 57, 161, 182, 183, 68 Stat. 930, 932, 948, 953, 954, as amended, sec. 234, 83 Stat. 444, as amended (42 U.S.C. 2073, 2077, 2201,2232,2233,2282); secs.202,206,88 Stat.1244,1246(42U.S.C2273);

il 74.31, 74.81, and 71.82 are issued under secs.161b and 1611, 68 Stat. 948, 949asamended(42U.S.C.2201(b),2201(1));andil74.11,74.13,and74.15 are issued under sec. 1610, 68 Stat. 950, as amended (42 U.S.C 2201(o)).

8.

Section 74.4 is amended by placing the following definitions in the proper alphabetical sequence.

6 74.4 Definitions As used in this part:

" Abrupt loss" means a loss occurring in the time interval between consecu-tive sequential performances of a material control test which is designed to detect anomalies potentially indicative of a loss of strategic special nuclear material from a specific unit of SSNM (i.e., a quantity characterized by a unique measurement) introduced into a process.

" Accessible location" means a process location at which SSNM could be acquired without leaving evidence of the acquisition, i.e., without tools or other equipment to obviously violate the integrity of the containment.

" Additions to material in process" means:

(i) receipts that are opened, except for receipts opened only for sampling and subsequently maintained under 23

t I

j tamper-safing;(ii) opened sealed sources; and (iii) material removed from process for nonconformance with chemical or physical specifications that is subsequently reprocessed, measured for contained SSNM, and reintroduced to process.

l "Alam Threshold" means a predetermined quantity of SSNM calculated from

{

the specified probability of detection for a given loss and the standard devia-I tion associated with a material control test. An alann threshold serves to trigger a response action.

l

" Bias" means the deviation of the expected value of a random variable from the corresponding correct or assigned value.

" Calibration" means the process of detennining the numerical relationship between the observed output of a measurement system and the value, based upon i

j reference standards, of the characteristic being measured.

" Category IA material" means SSNM directly useable in the manufacture of a nuclear explosive device, except if:

t J

(1) The dimensions are large enough (at least two meters in one dimension, greater than one meter in each of two dimensions, or greater than 25cm in eachofthreedimensions)toprecludehidingtheitemonanindividual, i

l (2) The total weight of five fonnula kilograms of SSNM plus its matrix (at least 50 kilograms) cannot be carried inconspicuously by one person, or j

(3) The quantity of SSNM (less than 0.05 fonnula kilograms) in each container requires protracted diversions in order to accumulate five l

formula kilograms.

l

" Category IB material" means all SSNM material other than Category IA.

" Continuous process" means a unit process in which feed material must be l

introduced in a systematic manner in order to maintain equilibrium conditions.

I 24

'~

" Controlled access area" means any temporarily or permanently established area which is clearly demarcated, access to which is controlled, and which affords isolation of the material or persons within it.

" Element" means uranium or plutonium.

" Estimate" means a specific numerical value arrived at by the application of an estimator.

" Estimator" means a function of a sample measurement used to estimate a population parameter.

" Fissile isotope" means: (1) uranium U-233 or (2) uranium-235 by enrichment category, (3) plutonium-239, and (4) plutonium-241.

" Formula kilogram" means SSNM in any combination in a quantity of 1000 grams computed by the formula, grams = (grams contained U-235) + 2.5 (grams U-233 +

grams plutonium).

" License," except where otherwise specified, means a ifcense issued pursuant to Part 70 of this chapter.

" Material" means special nuclear material.

" Material access area" means any location which contains special nuclear material, within a vault or a building, the roof, walls, and floor of which constitute a physical barrier.

" Material balance" means the determination of an inventory difference (I0).

"MC&A alarm" means a situation in which there is: (1) an out-of-location item or an item whose integrity has been violated, (2) an indication of a flow of SSNM where there should be none, or (3) a difference between a measured or observed amount or property of material and its corresponding predicted or pro-perty value that exceeds a threshold established to provide the detection capa-bility required by 9 74.53, 25

" Material control test" means a comparison of a pre-established alarm threshold with the results of a process difference or process yield performed on a unit process.

" Material in process" means any special nuclcar material possessed by the licensee except in unopened receipts, sealed sources, measured waste discards, and ultimate product maintained under tamper-safing.

" Power of detection" means the probability that the critical value of a statistical test will be exceeded when there is an actual loss of a specific SSNM quantity.

" Process difference" (PD) means the determination of an ID on a unit pro-cess level with the additional qualification that difficult to measure compon-ents may be modelled.

" Process yield" means the quantity of SSNM actually removed from a unit process compared with the quantity predicted (based on a measured input) to be available for removal.

Process yield differs from a process difference in that holdup and sidestreams are not measured or modelled.

" Produce" when used in relation to special nuclear material, means: (1) to manufacture, make, produce, or refine special nuclear material; (2) to separate special nuclear material from other substances in which such material may be i

contained; or (3) to make or to produce new special nuclear material.

i l

" Random error" means the deviation of a random variable from its expected value.

I

" Receipt" means special nuclear material received by a licensee from an f

off-site source.

l l

26 l

l

4

" Reference standard" means a material, device, or instrument whose assigned value is known relative to national standards or nationally' accepted measurement systems.

This is also commonly referred to as a traceable standard.

" Removals" means measured quantities of special nuclear material disposed of as discards, encapsulated as a sealed source, or in ultimate product placed under tamper-safing or shipped offsite.

"Research and development" means: (1) theoretical analysis, exploration, or experimentation; or (2) the extension of investigative findings and theories of a scientific or technical nature into practical application for experimental and demonstration purposes, including the experimental production and testing of models, devices, equipment, materials, and processes.

" Scrap" means the various forms of special nuclear material generated dur-ing chemical and mechanical processing, other than recycle material and normal process intermediates, which are unsuS,able for continued processing, but all or part of which will be converted t useable material by appropriate recovery operations.

" Sealed source" means any special nuclear material that is physically encased in a capsule, rod, element, etc. that prevents the leakage or escape of the special nuclear material and that prevents removal of the special nuclear material without penetration of the casing.

" Standard Error of the Inventory Difference" (SEID) means the standard deviation of an inventory difference that takes into account all measurement error contributions to the components of the 10.

" Standard Error of the Process Difference" means the itandard deviation of a process difference value that takes into account both measurement and nonmea-surement contributions to the components of PD.

27 u

" Tamper-safing" means the use of devices on containers or vaults in a manner and at a time that ensures a clear indication of any violation of the integrity of previously made measurements of special nuclear material within the container or vault.

" Traceability" means the ability to relate individual measurement results to national standards or nationally accepted measurement systems through an unbroken chain of comparisons.

" Ultimate product" means any special nuclear material in the form of a pro-duct that would not be further processed at that licensed location.

" Unit process" means an identifiable segment or segments of processing activities for which the amounts of input and output SSNM are based on measurements.

" Unopened receipts" means receipts not opened by the licensee, including receipts of sealed sources, and receipts opened only for sampling and sub-sequently maintained under tamper-safing.

" Vault" means a windowless enclosure with walls, floor, roof and door (s) designed and constructed to delay penetration from forced entry.

9.

Subpart E ($$ 74.51 through 74.59) is added to read as follows:

t i

28

SUBPART E - FORMULA QUANTITIES OF STRATEGIC SPECIAL NUCLEAR MATERIAL Sec.

74.51 Nuclear Material Control and Accounting for Strategic Special Nuclear Material 74.53 Process Monitoring.

74.55 Item Monitoring.

74.57 Alarm Resolution.

74.59 Quality Assurance and Accounting.

Subpart E - Formula Quantities of Strategic Special Nuclear Material

$ 74.51 Nuclear Material Control and Accounting for Strategic Special Nuclear Material.

(a) General performance objectives.

Each licensee who is authorized to possess five or more formula kilograms of strategic special nuclear material (SSNM) and to use such material at any site, other than a nuclear reactor licensed pursuant to Part 50 of this chapter, an irradiated fuel reprocessing plant, or an operation involved with waste disposal shall establish, implement, and maintain a Commission approved material control and accounting (MC&A) system that will achieve the following objectives:

(1) Prompt investigation of anomalies potentially indicative of SSNM losses; (2) Timely detection of the possible abrupt loss of five or more formula kilograms of SSNM from an individual unit process; 29

(3) Rapid determination of whether an actual loss of five or more formula i

kilograms occurred; (4) Ongoing confirmation of the presence of SSNM in assigned locations; and l

(5) Timely generation of information to aid in the recovery of SSNM in the event of an actual loss.

l, j

(b) System Casabilities.

To achieve the general performance objectives j

specified in S 74.51(a), the MC&A system must provide the capabilities described in SS 74.53, 74.55, 74.57 and 74.59, and must incorporate checks and balances that are sufficient to detect falsification of data and reports that could conceal diversion by:

(1) An individual, including an employee in any position; or (2) Collusion between an individual with MC&A responsibilities and j.

another individual who has responsibility or control within both the physical l

protection and the MC&A systems.

(c)

!aolementation dates.

Each licensee subject to the requirements of paragraph (a) of this section shall:

(1) No later than (150 days after the effective date of these amendments),

submit a fundamental nuclear material control (FNMC) plan describing how the i

Itcensee will comply with the requirements of paragraph (b) of this section; and I

l (2) Within (360 days of the effective date of these amendments) or 90 days t

j after the plan submitted pursuant to paragraph (c)(1) of this section is approved, whichever is later, implement the approved plan.

Current FNMC plans must be i

l followed untti new plans are approved by the NRC.

l l

30 1

k

(d) Exemptions.

(1) Notwithstanding paragraph (c)(2) of this section, a licensee may delay, for an additional 18 months, implementation of provisions of the plan involving process shutdown for resolution of alarms.

However, during such delay, the licensee shall continue to conduct inventories at bimonthly intervals.

(2) Notwithstanding 574.59(f)(1), licensees shall perform bimonthly physical inventories for six months after NRC approval of the FNMC Plan submitted in response to the requirements of this Part or until the licensee has demonstrated performance acceptable to the NRC against all plan commitments and has received formal Commission approval to perform semiannual inventories.

4 5 74.53 Process Monitorina (a) Licensees subject to S 74.51 shall monitor internal transfers, storage, and processing of SSNM.

The process monitoring must achieve the detection capabilities described in paragraph (b) of this section for all a

SSNM except:

(1) SSNM that is subject to the item loss detection requirements of

$74.55; j

(2) Scrap in the form of small pieces, cuttings, chips, solutions or in other forms that result from a manufacturing process, held in containers of 30 gallons or larger, with an SSNM content of less than 0.25 grams per liter; (3) SSNM with an estimated measurement standard deviation greater than five percent that is either input or output material associated with a unit that processes less than five formula kilograms over a consecutive three-month period; and 31

. _ ~.

(4) 55 m involved in research and development operations that process less than five formula kilograms during any seven-consecu.tive-day period.

(b) Unit Process Detection Cacability.

For each unit process, a licensee 1

shall establish a production quality control program capable of monitoring the j

status of material in process. The program shall include:

(1) A statistical test that has at least a 95 percent power of detecting an abrupt loss of five formula kilograms within three working days of a loss of Category IA material from any accessible process location and within seven calendar days of a loss of Category IB material from any accessible process Iocation; j

(2) A quality control test whereby process differences greater than three i

times the estimated standard deviation of the process difference estimator and j

25 grams of SSW are investigated; and (3) A trend analysis for monitoring and evaluating sequences of material l

control test results from each unit process to detemine if they indicate a pattern of losses or gains that are of safeguards significance.

(c) For research and development operations exempt from the requirements of i

j paragraph (b)ofthissection,thelicenseeshall:

i (1) Perform material balance tests on a lot or a batch basis, as appro-i priate, or monthly, whichever is sooner, and investigate any difference greater l

than 200 grams of plutonium or U-233 or 300 grams of U-235 that exceeds three l

{

times the estimated standard error of the inventory difference estimator; l

~

(2) Evaluate material balance results generated during an inventory period for indications of measurement biases or unidentified loss streams and investi-j gate, determine the cause(s) of, and institute corrective action for cumulative l

l 32 l

l 1

inventory differences generated during an inventory period that exceed three formula kilograms of SSM.

$ 74.55 Item monitorina (a)

Licensees subject to 5 74.51 shall provide the detection capability described in paragraph (b) of this section for laboratory samples containing less than 0.05 formula kilograms of SSM and any uniquely identified items of SS M that have been quantitatively measured, the validity of that measurement independently confirmed, and that additionally have been either:

(1) Tamper-safed or placed in a vault or controlled access area that pro-vides protection at least equivalent to tamper-safing; or (2) Sealed such that removal of SS W would be readily and permanently apparent (e.g., encapsulated).

(b) The licensee shall verify on a statistical sampling basis, the pre-sence and integrity of SSW ltems.

The statistical sampling plan must have at least a 99 percent power of detecting item losses that total five formula kilo-grams or more, plant-wide, within:

(1)

Thirty calendar days for Category IA items and 60 calendar days for Category IB items contained in a vault or in a permanently controlled access area isolated from the rest of the material access area (MAA);

(2) Three working days for Category IA items and seven calendar days for Category IB items located elsewhere in the MAA, except for reactor components measuring at least one meter in length and weighing in excess of 30 kilograms for which the time interval shall be 30 calendar days; 33

f

/

(3) Sixtycalendardaysforitemsina.permanentlycontrolledacAssarea outside of an MAA; (4) Sixty calendar days for saur.ies in a vault or permanently controlled access area and 30 calendar days for samples elsewhere in the MAA for samples

(

each containing less than 0.05 formula kilograms of SSNM.

(c) Items containing scrap in the form of small pieces, cuttings,-chips, solutions or in other forms that result from a manufacturing process, held in containers of 30 gallon or,largar, with an SSNM concentration of less thin 0.25 grams per liter are exempt from the requirements of,paragrarh (b) Sf this section.

6 74.57 Alarm resolution (a) Licensees subject to i 74.51 shall provide the MC&A alarm resolution capabilities described in paragraphs (b) through (f) of this section.

)

(b) Licensees shall resolve the nature and cause of any liCAA alarm within approved time periods.

l (c) Each licensee shall notify by telephone, the appreoriate NRC Regional l

Office listed in Appendix A of Part 73 of this cheptar of any l'CSA alarm that remains unresolved beyond the time period specified for its resolution in the licensee's fundamentcl nuclear materitt control plan. Notification shall occur l

within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> except when a holiday or wedend intervene in which car.e the notification shall occur on the next scheduled workday.

The licensee may con-i sider an alarm to be resolved if:

(1) Clerical or computational error is found that clearly was the cause for the alarm; 34 l

gie v,e C

f

. r-r; l

?

(2) An assignable cause for the alarm is identified or it is substantiated

' that no material loss has occurred.

~

(d)

If a material loss has occurred, the licensee shall determine the' amount of SSNM lost and take corrective action to:

' #(1) keturnout-ofplaceSSNM,ifpossible,toitsappropriateplace;

/

(2) Update and correct associated records; and (3) Modify'the MC&A system, if appropriate, to prevent similar future occurrences.,' :'

(e) The licensee shall provide an ability to rapidly assess the validity of alleged thefts.

~

(f)

If an abrupt loss detection estimate exceeds five formula kilograms of SSNM:

e, (1) Material processing operations related to the alarm must be suspended until completion of planned alare resolution activities, unless the suspension

//

of operations will adversely affect the ability to resolve the alarm.

Operation of continuous processes may continue for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the time of the occurrence

% che alarm during which time checks shall be made for mistakes in records or i

calculations that could have caused the alarm.

(2) Within 24 ho'urs,- the licensee shall notify the appropriate NRC Regional Office by telephone that an MC&A alarm resolution proci. dure has been initiated.

/

$ 74'.59 Quality Assurance and Accountina Requirements (a)

Licensees subject to $ 74.51 shall provide the quality assurance and accounting capabilities descritied in paragraphs (b) through (h) of this section.

35 L

w,-------.mn nn

~

t (b) ManagementStructbr.e.

The licensee shall:

(1) Establish and mah)tain 'a management structure that includes clear overall responsibility for planning, coordinating, and administering material control and accounting functions, independence of material control and accounting functions from production responsibilities, and separation of functions such that the activities of one individual or organizational unit serve as controls over and' checks of the activities of others; and

' (2) Provide for the adequate review, approval, and use of those material l

control and accounting procedures that are identified in the approved FNMC plan as being critical to1the effectiveness of..the described system.

(c) Personnel-Qualification and Training.

The licensee shall assure that personnel who work in key positions where mistakes could degrade the effective-ness of the material control and accounting system are trained to maintain a high level of safeguards awareness and are qualified to perform their duties and/or responsibilities.

(d) Measurecants.

The licensee shall establish and maintain a system of measurements sufficient to:

(1) Substantiate the plutonium element and uranium element and fissile isotope content of all SSNM received, produced, transferred between areas of custodial responsibility, on inventory, or shipped, discarded or otherwise removed from inventory; (2) Enable the estimation of the standard deviation associated with each measured quantity; and (3) Provide the data necessary for performance of the material control tests required by S74.53(b).

36

(e) Measurement Control.

The licensee shall assure that the quality of SSNM measurement systems and material processing practices is continually controlled to a level of effectiveness sufficient to satisfy the capabilities required for detection, response, and accounting.

To achieve this objective the licensee shall:

(1) Perform engineering analyses and evaluations of the design, installation, preoperational tests, calibration, and operation of all measurement systems to be used for MC&A purposes; (2) Perform process and engineering tests using well characterized materials to establish or to verify the applicability of existing procedures for mixing and sampling SSNM and maintaining sample integrity during transport and storage.

Tests must be repeated at least every three years, at any time there is a process modification that alters the physical or chemical composition of the SSNM, or whenever there is a change in the sampling technique or equipment.

(3) Generate current data on the performance of measurement processes, including, as appropriate, values for bias corrections, uncertainties on cali-bration factors, and random error standard deviations.

The program must include:

(i) The ongoing use of standards for calibration and control of all applicable measurement systems.

Calibrations must be repeated whenever any change in a measurement system occurs which has the potential to affect a mea-surement result or when program data, generated by tests performed at a pre-determined frequency, indicate a need for recalibration.

Calibrations and tests must be based on standards with traceability to national standards or nationally accepted measurement systems; and 37

(ii) A system of control measurements to provide current data for the.

estimation of the standard deviations that are significant contributors to the measurement uncertainties associated with shipper / receiver differences, inven-tory differences, and process differences.

(4) Utilize the data generated during the current material balance period for the estimation'of the standard error of the inventory difference (SEID) and the standard error of the process differences.

Calibration and measurement error data collected and used during immediately preceding material balance.

periods may be combined with current data provided that the measurement systems are in statistical control and the combined data are utilized in characterizing the unknowns.

(5) Evaluate all program data and information to assure that measurement performance is so controlled that the SEID estimator is less than 0.1 percent of active inventory.

(6) Apply bia.s cot-rections by an appropriate procedure whereby:

(i) Bias corrections are applied to individual items if for any measurement system the relative bias estimate exceeds twice the standard deviation of its estimator, the absolute bias estimate exceeds 50 grams of SSNM when applied across all affected items, and the absolute bias estimate on an individual item basis exceeds the rounding error of affected items; (ii) All biases (regardless of significance) that are not applied as corrections to individual items are applied as a correction to the inventory difference.

(7) Investigate and take corrective action, as appropriate, to identify and reduce associated measurement biases when, for like material types (i.e.,

measured by the same measurement system) the net cumulative shipper / receiver 38

differences accumulated over a six-month period exceed the larger of one formula kilogram or 0.1 percent of the total amount received.

(8) Establish and maintain a statistical control system designed to monitor the quality of each type of program measurement.

Control limits must be established to be equivalent to levels of significance of 0.05 and 0.001.

Control data exceeding the 0.05 limits must be investigated and corrective action taken in a timely manner.

Whenever a single data point exceeds the 0.001 control limit, the measurement system in question must not be used for material control and accounting purposes until it has been brought into control at the 0.05 level.

(f) Physical Inventory.

The licensee shall:

(1) Except as required by Part 75 of this Chapter, perform a physical inventory at least every six calendar months and within 45 days after the start of the ending inventory:

(i) Calculate the inventory difference, estimate the standard error of the inventory difference and investigate and report any difference that exceeds three times the standard error and 200 grams of plutonium or uranium-233 or 300 grams of uranium-235, and (ii) If required to perform an investigation pursuant to paragraph (i) of this section, evaluate the significance of the inventory difference relative to expected performance as determined from an analysis of an appropriate sequence of historical inventory differences.

(iii) Investigate and report to the appropriate NRC Region Office any difference that exceeds three times the standard deviation determined from the l

sequential analysis, and (iv) Perform a reinventory if directed to do so by the Commission; and l

39 l

(v) Reconcile and adjust the plant and subsidiary book records to the results of the physical inventory.

(2)

Implement policies, practices, and procedures designed to ensure the quality of physical inventories.

These must include:

(1) Development of procedures for tamper-safing of containers or vaults containing SSNM not in process that include adequate controls to assure the validity of assigned SSNM values; (ii) Maintenance of records of the quantities of SSNM added to and removed from process; (iii) Requirements for signed documentation of all SSNM transfers between areas with different custodial responsibility that reflect all quantities of SSNM transferred; (iv) Means for control of and accounting for internal transfer documents; (v) Cutoff procedures for transfers and processing so that all quantities of SSNM are inventoried and none are inventoried more than once; (vi) cutoff procedures for records and reports so that all transfers for the inventory and material balance interval and no others are included in the

(

records; (vii) Inventory procedures for sealed sources and containers or vaults containing SSNM that assure reliable identification and quantification of l

contained SSNM; l

l (viii)

Inventory procedures for in process SSNM that provide for i

measurement of quantities not previously measured for element and isotope, as appropriate, and remeasurement of material previously measured but whose validity has not been assured by tamper-safing or equivalent protection; and I

40

e (ix) Written instructions for conducting physical inventories that detail assignments, responsibilities, and preparation for and performance of an inventory.

(g) Accounting.

The licensee shall establish auditable records sufficient to demonstrate that the requirements of SS 74.53, 74.55, 74.57, and 74.59 have been met and retain those records for at least three years unless a longer retention period is required by Part 75 of this Chapter.

(h)

Internal Control.

The licensee shall:

(1) Establish procedures for shipping and receiving SSNM that provide for:

(i) Accurate identification and measurement of the quantities shipped and received; (ii) Review and evaluation of shipper / receiver differences on an individual container or lot basis, as appropriate, on a shipment basis, and on a batch basis when required by Part 75 of this Chapter; (iii) Investigation and corrective action when shipper / receiver differences exceed twice the estimated standard deviation of the difference estimator and the larger of 0.5 percent of the amount of SSNM in the container, lot, or shipment, as appropriate, or 50 grams of SSNM; and (iv) Documentation of shipper / receiver difference evaluations, investigations, and corrective actions.

(2) Establish a scrap control program that assures that:

(i) Internally generated scrap and scrap from other licensees or contractors l

is segregated until accountability is established; and t

l (ii) Any scrap measured with a standard deviation greater than five percent l

of the measured amount is recovered so that the results are segregated by inventory 41

period and received within six months of the end of the inventory period in which the scrap was generated except where it can be demonstrated that the scrap measurement uncertainty will not cause noncompliance with 9 74.59(e)(5).

(3)

Incorporate checks and balances in the MC&A system sufficient to contrcl the rate of human errors in material control and accounting information.

(4) Perform independent assessments at least every 12 months that assess the performance of the MC&A system, review its effectiveness, and document management's action on prior assessment recommendations.

Assessments must include an evaluation of the measurement control program of any outside contractor laboratory performing MC&A measurements for a licensee, unless the contractor is also subject to the requirements of $74.59(e).

(5) Assign custodial responsibility in a manner that ensures that such responsibility can be effectively executed for all SSNM possessed under license.

Dated at Washington, D.C. this day of 1986 for the Nuclear Regulatory Commission.

P Samuel J. Chilk, Secretary of the Commission.

42

5 4'

f ENCLOSURE B I

i

O' n

STANDARD FORMAT AND CONTENT / ACCEPTANCE CRITERIA GUIDE FOR THE MC&A REFORM AMENDMENT 10 CFR PART 74 SUBPART E FORMULA QUANTITIES OF STRATEGIC SPECIAL NUCLEAR l

MATERIAL l

l l

i l

ENCLOSURE B l

TABLE OF CONTENTS

.Page INTRODUCTION.........................................................

v GENERAL DISCUSSION...................................................

vii Chapter 1.0 ABRUPT LOSS DETECTION 1.1 Unit Process Capability.....................................

1

1. 2 Research/ Development Operations............................

10 4

Chapter 2.0 ITEM MONITORING 2.1 Item Loss Detection........................................

15 Chapter 3.0 ALARM RESOLUTION 3.1 Alarm Resolution...........................................

25 3.2 Alarm Reporting............................................

34 3.3 Alleged Thefts.............................................

36 Chapter 4.0 QUALITY ASSURANCE AND ACCOUNTING 4.1 Management Structure.......................................

41

4. 2 Personnel Qualification and Training.......................

46 4.3 Measurements...............................................

48 4.4 Measurement Control........................................

50 4.5 Physical Inventory.........................................

60 4.6 Accounting.................................................

67 4.7 Shipments and Receipts.....................................

69 4.8 Scrap Control..............................................

72 4.9 Human Errors...............................................

75 4.10 Independent Assessment.....................................

84 4.11 SSNM Custodianship.........................................

86 REFERENCES...........................................................

88 iii 4

ACRONYMS and INITIALS CAA Controlled access area CUMSRD Cumulative shipper-receiver difference FKG Formula kilogram FNMC Fundamental nuclear material control HEU High enriched uranium ID Inventory difference LEID Limit of error of the inventory difference MAA Material access area MC&A Material control and accounting NDA Nondestructive assay PD Process difference R&D Research and development SEID Standard error of the inventory difference SNM Special nuclear material SRD Shipper receiver difference SSNM Strategic special nuclear material iv

c A

k 41._Al

_,ia 3.M._

e-

-.----.e 4

h-E 4

  • m 4

.r

w

,.s.

4..

w

_a edw m

(

?

INTRODUCTION The Atomic Energy Act of 1954, as amended, directed the Atomic Energy Comission

- (AEC) to regulate the receipt, manufacture, production, transfer, possession, use, import, and export of special nuclear material in order to protect the public health and safety and to provide for the common defense and security.

l The Energy Reorganization Act of 1974 transferred all the licensing and related

~

functions of the AEC to the Nuclear Regulatory Commission (NRC).

The principal requirements with respect to special nuclear material licensing are found in Title 10, Code of Federal Regulations, Part 70 (10 CFR Part 70),

"Special Nuclear Material" and Part 74 (10 CFR Part 74), " Material Control and Accounting of Special Nuclear Material." Paragraph (B) of $70.22 of 10 CFR Part 70 specifies that special nuclear material control and accounting information must be provided in a license application to show how compliance with the fundamental nuclear material control requirements of $70.58, 974.31, or $74.51 will be accomplished.

Purpose and Applicability 4

This document describes the standard format and content suggested by the NRC for use in preparing fundamental nuclear material control plans (FNMC) in response to the material control and accounting (MC&A) Reform Amendment (10 CFR 74.51).

An intent and scope statement is provided for each requirement.

These statements are intended to communicate the underlying objectives of each requirement and are not subject to negotiation in individual licensing actions.

The document also provides acceptance criteria which will be utilized in the adequacy evalua-tion of submitted plans.

To the extent possible. the criteria are presented in a performance-oriented format.

Where prescriptive criteria were necessary, i

at least two alternatives normally are provided and additional alternative approaches which provide an equivalent level of performance are encouraged.

4 i

Use of the Standard Format l

By using this standard format for preparing an FNMC plan, a license applicant will minimize administrative problems associated with the submittal, review and approval of the plan.

Preparation of an FNMC plan in accordance with this Standard Format will assist the NRC in evaluating the plan and in standardizing l

the licensing and review process.

However, conformance with the standard format j

is not required by the NRC.

An applicant may use a different format if it provides an equal level of completeness and detail.

Regardless of the format, the applicant should employ a plan / annex concept.

All fundamental commitments which define the bounds within which the licensee will function and the detailed level of the performance of its MC&A system should be included in the body of the plan.

In those cases where a demonstra-tion of a specific capability is called for, such information should be included in an annex to the plan which will not be incorporated as a condition of license.

Procedures detailed in the annex may be changed without NRC approval or notifica-tion provided plan commitments and capabilities are not degraded.

i l

t Use of Acceptance Criteria The Acceptance Criteria are for the use of the applicant and the licensing reviewer.

An application which meets these criteria should be acceptable to the NRC staff.

However, as noted above, those criteria which are prescriptive in nature are ir.cluded as examples and each applicant should develop a material control and accounting program that takes into account the unique features of its particular operation.

Where additional guidance is available on particular topics, an appropriate reference is included in the Acceptance Criteria section.

vi

~

GENERAL DISCUSSION In this section, the license applicant should provide a general description of how its material control and accounting program satisfies the general perform-ance objectives of paragraph 74.51(a).

The description should include informa-tion on the plant, the process, and key features of the material control and accounting program including physical organization, types of tests, and classification of material as bulk versus items.

The description should be sufficiently general to allow for significant modification without necessitating revision of this section.

vii

d l

Questions and Answers 1.

Q:

Previously, material control and accounting (MC&A) regulations of 10CFR70.51(e),70.57,70.58 applied to fuel facility licensees authorized to possess and use a quantity of special nuclear material (SNM) exceeding one effective kilogram. The MC&A Reform Amendments would apply to fuel facility licensees possessing and using more than i

five formula kilograms of strategic SNM (SSNM). What is the dif-l ference between effective and fomula kilograms?

A:

Five formula kilograms (FKG) of high enriched uranium (HEU), plutonium, or U-233 has been established by the Commission as the quantity of strategic importance.

For plutonium or U-233, the number of formula kilogram is defined as 2.5 times the weight in kilograms of the plutonium or U-233.

For HEU enriched to 20 percent or more in uranium-235, it is defined as the weight in kilograms of the U-235 isotope.

For plutonium or U-233, an effective kilogram is defined as the weight in kilograms of the plutonium or U-233.

For uranium enriched in the U-235 isotope more than 1 percent, it is defined as the weight in kilograms of the uranium element multiplied by the square of its enrichment expressed as a decimal fraction.

The Reform Amendments apply to HEU, plutonium, and U-233, in quantities of 5 FKG or more.

For plutonium and U-233, 5 FKG is the same amount of material as two effective kilograms.

For HEU, 5 FKG varies from one effective kilogram for 20 percent enrichment to five effective kilograms for 100 percent enrichment. Licensees possessing and using more than one effective kilogram of SSNM of moderate strategic signif-icance would continue to be subject to the requirements of 10 CFR 70.51, 70.57, and 70.58.

Licensees possessing and using more than one effec-tive kilogram of SNM of low strategic significance would be subject to the requirements of 10 CFR 74.31.

I 5 74.51(b) Threat Definition 2.

Q:

Why does the collusion protection requirement read differently from that in 10 CFR 73.1(a)?

i A:

The physical protection requirements of 10 CFR 73.1(a) stipulate that l

collusion protection be provided against the conspiracy detailed in the design basis threat. To require the MC&A system to also protect against the same conspiracy would be excessive. The provisions of the MC&A Reform Amendments are designed to function in an integrated fashion with those of 10 CFR Part 73 while adding an independent verification, thus producing a more cost-effective system. Under this new approach, MC&A is only required to protect against an 4

insider's ability to cover up his/her theft.

viii

.wrw-

-w*-m

--yy,-.,_,y,.,__.-,i--.sg,-9

.w e q-~..

=,,-p-,-.,-.-__.

-.y,7-.,w.,,y-mm-_-~p.,__.-y-,

--yw_-+,

y-,-

u_ - - - -

-___m..,, _ _.,,. __

MC&A system needs to protect against only a single insider, providing that individual does not have authority within the physical protection system that would permit him/her to participate in a conspiracy aimed at defeating the safeguards system.

If an MC&A individual does have authority within the physical protection system, then the MC&A system is required to protect against.the cover-up of a collusion of that individual with ar.y other individual having MC&A authority.

This approach should relieve licensees of most of the burden which would result from requiring a totally redundant system while still maintaining the ability of the MC&A system to provide an extra level of independent protection and an added measure of assurance that the safeguards system as a whole has not been compromised.

3.

Q:

What are examples of things this collusion requirement would affect?

A:

Under this provision the licensee would be required to analyze all positions having responsibility within the MC&A system to determine if any also have responsibility within the physical protection system.

- A safeguards manager might be an example of such a position.

If this position includes both MC&A and physical _ protection responsibilities, procedures would have to be developed to assure that when an individual in this job is performing an MC&A function, that this function be performed under a three person rule, be independently checked later j

by a third party, or be otherwise protected against abuse of authority.

l Another example might be a worker on a shipping dock who has respon-sibility for making a nondestructive assay measurement on a barrel and for moving that barrel out of the material access area (MAA).

Current practice for workers in positions such as this, however, already appears sufficient to meet the proposed provision and few if any changes are anticipated to be required.

For some individuals in management / supervisory positions, some modifications to procedures, such as restricted access without escort to some areas, may be necessary to provide sufficient assurance _that the system cannot be compromised.

An MC&A function performed by a worker without physical protection system authority would need to be protected against a single insider threat.

However, it would need no overcheck if that individual had no " hands on" access to formula quantities of SSNM (e.g., a laboratory chemist).

$8 74.51(c), 74.59(e) Phase-In Period 4.

Q:

Will the physical inventory period go directly from two months to 3

cix months?

A:

The period between physical inventories will not increase from I

bimonthly to semiannual until after the licensee has implemented all plan commitments, including necessary shutdown for alarm resolution, and demonstrated adequate performance against all commitments.

1 i

i ix

CHAPTER 1.0 ABRUPT LOSS DETECTION 1.1 Unit Process Detection Capability

)

Requirement:

The rule requires that for each unit process, a licensee establish a production quality control program capable of monitoring the status of material in process.

The program should include material control tests; the-i results of which would be subjected to the following:

A quality control test whereby results greater than both three times the estimated standard deviation of the process difference estimator 1

and 25 grams of SSNM are investigated, A statistical test that has at least a 95 percent power of detecting J

an abrupt loss of five formula kilograms within three working days of a loss of Category IA material from any accessible process location and seven calendar days of a loss of Category IB material from any accessible process location, and

a. trend analysis for monitoring and evaluating sequences of material

~

control test results from each unit process to determine if they indicate a statistically significant recurrent loss or gain

[74.53(b)].

Intent and Scope:

The intent of these requirements is to have in place a quality control program that will provide early indications of material losses that may be indicative.of a diversion or theft and a prompt detection system for significant abrupt diversions of 5 FKG or more.

Through prompt detection, response and recovery actions can be initiated soon after a loss event while circumstances surrounding the loss occurrence are fresh in the minds of cogni-zant personnel, and materials are available for remeasurement.

In addition, i

fewer changes in process conditions, inventories, in process holdups, and item locations will have occurred so that resolution probabilities are enhanced.

The detection times for a 5 FKG loss are maximums; hence, a licensee may use 1-shorter intervals for specific unit processes if so desired.

l 1

Plan / Annex Content:

The FNMC Plan contains the following affirmations and j

detailed commitments.

Supporting information, as appropriate, is included in j

the Annex.

l Section 1.1 of the Plan includes the following affirmations:

o Material control anomalies resulting from material control tests are investigated when such anomalies exceed three times the standard i

deviation of the test statistic and also exceed 25 grams of SSNM.

Results are documented.

I l

I l

1 i

,---,,-,,.-------n, n --.,, - - - - - - - - - -. -

r---.

M o

The detection system is capable of detecting abrupt losses of Category IA material within three working days and Category IB mate-rial within seven calendar days of the loss occurrence from any accessible location, o

The action thresholds for the material control tests will be updated based on the first six months of operating data and thereafter as supported by the analysis of test data.

o All materials not qualifying for exemption under paragraphs 74.53(a)(1),

(2), (3), or (4) are included under a material control test.

o Where credible substitute material is present and not controlled, the material control tests are capable of detecting diversions or thefts involving substitution of other material (s) for SSNM.

or No credible substitute materials are permitted inside the MAA, nor is it credible that substitute materials could be covertly introduced from outside the MAA.

or Credible substitute materials are available within the MAA; however, sufficient controls are in place to preclude their use to conceal diversion.

o Automated or manual records of the location, movement, quantity and identity of SSNM are maintained as needed to perform the material control tests for abrupt loss detection.

o Procedures will be implemented and maintained for monitoring and evaluating sequences of loss estimates for each unit process, and anomalous trends in sequences of abrupt loss estimators will be tested to determine if they indicate a recurrent loss trend that is of safeguards significance.

1.1.1 Process Subdivision and Measurement Points Describe the subdivision of the process to meet the unit detection require-ments and the associated measurements and measurement points.

A diagram or listing may be used to document this information.

1.1.2 Material Control Tests Describe the material control tests for each unit process.

The description should include:

(1) identification of the test statistic, (2) the amounts and types of data used to establish uncertainties (sigmas), (3) tests for normality, (4) means of handling non-normal data, (5) tests for outliers, (6) methods for establishing alarm thresholds, (7) criteria for modifying alarm thresholds, and (8) the basis for the assignment of the start times for each material control test.

i 2

In the Annex provide:

(1) a detailed example alarm threshold calculation for one process unit, (2) a tabulation of the threshold values for all process units, (3) a tabulation of the detection times associated with each material control test, (4) the justification for the aerivation of each threshold value, and (5) a listing of Category IA and IB materials and the justification for the lower classification of the latter.

1.1.3 Location Categorization Identify the locations within the facility classified as inaccessible.

In the Annex provide the justification for classifying a location as inaccessible.

1.1.4 Material Substitution Identify all credible substitute materials at each location and the method of testing for substitution or of controlling the substitute material to prevent or detect attempts at substitution.

The method of preventing credible substitute materials from being covertly introduced should also be described (NOTE:

Reference to the Physical Protection Plan is permitted).

l 1.1. 5 Exemptions Provide a listing of material types exempted from the abrupt loss detection tests with their locations and discuss the basis for the exemptions.

1.1.6 Trend Analysis Describe the trend analysis techniques that will be employed to monitor sequences of process differences from material control tests.

The description should include the decision criteria for ascertaining when a significant trend exists.

I Acceptance Criteria:

The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:

o The licensee has developed a system of material control tests for detecting abrupt losses of bulk material from single units or loca-tions within the facility.

The material control tests are capable of detecting a goal quantity loss with at least 95 percent probability of detection. The material control tests will have the following characteristics:

Each material control test encompasses the SSNM in a definite unit or location or over a span of locations comprising a segment of the process or a single point in the process.

The material control test is based on a comparison of a measured value(s) of a quantity of material (s) or of a process variable with a reference value.

The reference value is the expected or predicted quantity of material or value of the process variable in the absence of diversion or unexpected loss.

Examples of possible material control tests are:

1 3

l

SSNM material balance; Mass (weight) balance; Volume balance; Yield versus expected or predicted yield; Liquid level versus predicted level; Solution density versus predicted density; Flow rate versus predicted flow rate; Bulk powder volume or volume times bulk density versus predicted quantity; NOA value versus predicted value; Isotopic ratio versus predicted value; Number of units, such as pellets, elements or pins versus predicted number; and Process control parameters such as pH, reagent volume, or extraction efficiency versus predicted values.

Each material control test has an action threshold (critical value) which, if exceeded, will be the cause for initiating the alarm resolution procedures prescribed in S 74.57.

In general, the action threshold or critical value can be set by a formula of the following type:

A=G+i-Ko x where:

A = alarm threshold G = goal quantity (SFKg or less) x = mean assuming the null hypothesis, Ho, is true (Ho:L=0)

L = zero loss i

K = factor based on POD l

o = standard deviation of the test statistics.

x Key considerations applicable to this determination are:

If the distribution of the source data can be reasonably

[

represented by a single normal model after the effects of l

l l

4 L

human errors have been eliminated, use K=1.65 to achieve 95 percent detection probability.

If an analysis of test data indicates the presence of mul-tiple distributions, one of the following actions would be appropriate:

An in-depth study should be undertaken to identify the sources of error and adjustments should be made, as appropriate, in order that a single normal distribution adequately represents the data.

or The parameters (x, c) should be estimated, using a computer program as necessary, to maximize the likeli-hood function; then the critical point is determined by integrating the probability density function to the probability of interest.

or A determination should be made as to whether the pre-sence of multiple distributions is the result of con-comitant data which occurred as the result of some recognized change that occurred during the test period (e.g. new and recycled material processed through an operation).

If such data are available, the data should be split into subsets for testing.

When data do not seem to fit a normal distribution, an evaluation should be made to see if some mathematical func-tion of the data values will fit (transformation of data).

A commonly used transformation is logarithms which is the basis for the lognormal distribution.

Although there is no stated limit on the magnitude of the measurement and/or process uncertainty, the establishment i

of alarm thresholds indirectly limits the magnitude of these i

errors.

That is, when the standard deviation of the test statistic becomes a large fraction of "G," there is an excessive number of false alarms.

The combined quality of the material control test and loss resolution dect'sions shall permit alarms remaining unresolved after the completion of the licensee's investigative activ-l ities to be good indicators of an actual loss.

To achieve this objective, the licensee should demonstrate that the statistically expected number of false alarms will be less than 0.10 per inventory period for all abrupt bulk loss alarms exceeding 5 FKG (i.e., the predicted number of such unresolved alarms should be less than one in 10 inventory periods).

i 5

M The action thresholds are based on statistical hypothesis tests derived from the variances of the test statistics or on other technical bases for which it can be shown that the

' power of the test for loss is satisfactory.

The measurement variances assumed by the licensee are either supported by published typical values (see Reilly and Evans (1977) or Rogers (1982) or others), the. licensees measurement control data, or historical data from the licensee's process or other similar processes.

The assumed process variances may be estimated by using conservative judgments based on i

sound engineering principles if historical performance data for the licensee's process or similar processes are not available.

If engineering judgments or typical values are used, the Plan should include provisions and schedules for i

updating the estimated variances with actual performance data.

The methods of estimating the loss detection sensi-tivity or the variances of loss detection parameters are satisfactorily explained and a credible justification for their use is given.

o All SSNM in bulk form in the MAA is.within the span of a material control test.

(Note:

Exceptions to this requirement include (1) low-level waste which meets the criteria in 10 CFR 73.46(c)(6),

(2) laboratory samples containing less than 0.05 FKG (3) SSNM in i

research and development operations with throughputs less than 5 FKG during any seven consecutive days, and (4) SSNM in scrap and waste treatment operations conducted outside an MAA, (e.g. incinerator)).

I o

The tests for detecting abrupt losses at each accessible location will meet the three-and seven-day detection time goals for Category IA and Category IB materials, respectively, under all routine conditions i

that are expected to prevail at the location.

(Note: When detection I

times are interrupted by idle time caused by such things as weekends, i

holidays or vacations, the licensee shall make provisions for completing the tests before the idle time or for conducting additional tests to cover any material control tests that will not be completed.

The i

additional tests shall achieve the same level of detection as the principal tests.)

i o

The licensee's classification of the process material as Category IA and Category IB is explained and justified in the Annex.

Category IB materials are either (1) not usable for constructing a nuclear explosive device without further processing; (2) not susceptible to undetected i

removal from the MAA by an insider because of size, weight, or chemical hazard; or (3) of such low concentrations of SSNM that excessively large bulk quantities would be needed to obtain a formula quantity of SSNM.

o There is no limit or restriction on the number of control units into which a facility can be divided.

Loss detection sensitivity, false alarm rate, and loss localization capability are key determining factors.

The following criteria are appropriate in determining control unit boundaries:

6

--_.yy

._________.y.._,

, _ _ _, _, _,, _, ~ _ _. _, _ _.,. _ _.,,-_,. __ _ _,_,__,,

,_m

,__,7

Material control tests should be performed on units generally consistent with readily assessable measurement points which naturally result from the process design.

Process units should not be divided into smaller units for material control tests if such subdivision would cause the standard deviation of the test statistic to increase from below 850 formula grams U-235 (or equivalent units for tests not based on U-235) to above 850 formula grams U-235 unless such subdivision is necessary to meet the timeliness criteria of 5 74.53(b)(1).

Batch transfers should be utilized wherever they occur.

Process variabilities should be localized to a control unit.

Concentration differences between feed and product should be minimized wherever possible.

Process units that operate continuously should be separated from those that operate in a batch mode.

False alarm rates should be minimized.

The number of false alarms per inventory period should be less than one percent for all tests.

The timeliness of abrupt loss detection at a single location is based o

on the interval between the time a goal quantity of SSNM becomes accessible for diversion and the completion of the material control test.

The start time occurs when the quantity of SSNM is first equal to or greater than the established goal quantity.

In determining accessibility for the purpose of establishing the start o

time for material control tests, SSNM may be treated as not accessible for diversion if:

Access to the SSNM is physically precluded without the need for visible puncturing, breaking, or otherwise violating the integrity of the process equipment containing the SSNM; or The state of the SSNM precludes diversion because of high temper-ature, chemical reactivity, radioactivity, or other chemical or physical property; or i

The removal of the SSNM from its authorized location cannot be

(

accomplished because the tools or equipment needed for its move-ment are unavailable; or The SSNM is dilute (solution) and requires a large vessel, the j

presence of which could not escape notice; or The material is under the continuous surveillance of two or more individuals or an electronic or other type of monitoring system l

that will detect attempts to remove material from a process.

(

7 i

l

o The material control tests need only detect.those losses not involving substitution unless credible substitute materials are available in the same MAA in the form of uncontrolled material or are not prohibited as contraband from being brought into the MAA.

o Where credible substitute material is present and uncontrolled, the material control tests must be capable of detecting diversions employing substitution with the loss sensitivity and probability of detection required in S74.53.

If uranium of a lower enrichment is a credible uncontrolled substitute, a material control test must be capable of detecting isotopic dilution.

Otherwise, a test that detects replace-ment by another element is adequate.

o Material will be deemed not to be a credible substitute if it either:

Has physical properties such as density, color, particle size, or other characteristics that will be immediately and unequivocally recognized to be different from the SSNM by personnel who routinely work with the SSNM; Has chemical properties that will always cause process upsets or degradation of product quality severe enough to be recognized and reported to a designated individual responsible for initiating ~

a response within the time period of the material control test; Is controlled by a monitoring technique that provides assurance 1

i that the substitute material cannot be brought into the material access area; or Is controlled by a material accounting test that will detect J

losses or diversion of the substitute material and in the absence of an alarm will' provide indirect assurance that an SSNM diversion involving substitution has not occurred.

o Acceptable controls on substitute materials might include the following:

Access to the material is controlled through isolation in a locked limited access cabinet or room and access is restricted to indi-viduals who would not be involved in the actual handling of SSNM during production operations; i

i Periodic material balances are performed on the substitute material inventory where the balance may merely entail a weight comparison of material on hand minus material issued for production with the beginning inventory; Semi quantitative N0A tests are performed on intermediate product materials from process operations where credible substitute mate-i rials might be introduced; or Credible substitute materials are stored outside the MAA and introduced only in amounts necessary for a shift or day's production.

i 8

i

. -. _ - - - -, _. ~.. - - -. _

1 o

For low throughput operations such as waste compactors and incinerators where throughput is less than five FKG in two months, and the measure-ment uncertainties on inputs and/or outputs are greater than five percent, the licensee should perform material balances on a batch basis and make appropriate corrections to the originating unit (s) or area cumulative balances to the extent practicable.

Holdup deter-minations would be necessary only at the time of the physical inven-tory (or sooner for criticality reasons), and input-output differ-ences would need to be assessed only to the extent that significant trends would be investigated to identify measurement biases or an unaccounted for loss stream, o

For samples containing greater than 0.05 FKG and scrap and waste containers in laboratories, the licensee shall perform monthly material balances.

These balances may be accomplished by:

Maintaining a dynamic record of the laboratory inventory.

Maintaining a continuous inventory of the contents of scrap and waste containers by logging the amounts of all additions to each container, and Measuring the contents of each container monthly to detect significant discrepancies where "significant" is defined as in excess of twice the standard deviation of the difference estimator.

o Process difference estimates that exceed both three times the standard deviation of their estimator and 25 grams of SSNM shall be investigated and the results documented.

The investigation should as a minimum include:

A review of all source data and calculations for errors, A review of material control test results for the preceding SSNM quantity in the involved unit and the results of material control tests from the two adjacent units, An interview with process operators to ascertain if a perturbation in the process may have occurred, A check of sidestreams for abnormally high SSNM content, and An assessment of the possibility that additional holdup beyond what had been projected may have occurred.

o Two process difference estimates in succession that exceed three times the standard deviation of their estimators and three FKG should trigger additional investigative measures that include:

Notification to the nuclear materials control manager, 9

Review of security records, Added surveillance measures in the involved process unit, and Performance of a physical inventory within two months.

o The trend analysis required by $74.53(b)(3) can be accomplished by the application of appropriate parametric or nonparametric statistical techniques.

Examples include:

Page's Test, Runs Test, Dietz's Test, Power One Test, and a Mosum Test.

o With respect to " safeguards significance" as it pertains to trend analysis, a trend should be considered significant when the applied test indicates it to be so and the absolute quantity involved is in excess of three FKG.

1. 2 Research and Development Operations Requirement.

For research and development operations the rule requires each licensee to:

(1) Perform material balance tests on a lot or batch basis, as appropriate, or monthly, whichever is sooner, and investigate any difference greater' than 200 grams of plutonium or uranium-233 or 300 grams of uranium-235 that exceeds three times the standard error of the inventory difference estimator (S74.53(c)(1)); and (2) Evaluate material balance results generated during an inventory period for indications of bias or unidentified loss streams and investigate cumulative differences greater than three FKG of SSNM.

Intent and Scope.

By design, research and development operations are dynamic in nature.

Consequently, the prompt loss detection techniques that depend upon stable estimates of the uncertainties associated with material balances or process yields are inappropriate for loss detection. Taking into account the l

low throughput of such operations, periodic material balance tests on a lot or batch basis or monthly are deemed acceptable for loss detection.

Plan / Annex Content:

The FNMC Plan contains the following affirmations and detailed commitments.

Supporting information, as appropriate, is included in the Annex.

Section 1.2 of the Plan includes the following affirmations:

o Material balance tests are performed on lots or batches of material from research and development operations or on a monthly basis, whichever is sooner.

l o

Inventory differences that exceed 300 grams of uranium-235 (or 200 grams plutonium or uranium-233) and three times the standard error of the inventory difference estimator are investigated and resolved.

i 10

- - ~. m:. -

1 e

~.

o Sequences of inventory differences are monitored for indications of a trend and cumulative differences exceeding three formula kilogrras are investigated.

/'

..c,

1.2.1 Lot / Batch Characterization Provide the criteria that will be utilized to define a lot o'r batch.

3 1.2.2 Material Balance-Tests

/

A i

Describe how the components of a process material balance will be ', C established including the. degree to which a. process will be cleaned out'and/or holdup measurements will be performed. Discuss the handling of scrap indludirg

~

4 measurements, pre-treatment prior to recovery, and1 segregation.

,,g Acceptance Criteriaj The assessment of the 6dequacy of the information supplied above will be based on the following criteria or equivalent:

c' o

Proposedmaterialsgroupingsintklotsorbatchesareacceptable o

taking into account prompt loss cetectiori, objectives, measurement characterization, and processing constraints.

The inputs to the standard error of the inventory difference are,m o-reasonable and include all sources of measurement error.

i-i Inventory differences on lots or, batches' generated duriis t.r. inver4 cry.

o period stay be based on weight cc'.vparisons provided:

i Thelotsorbatchesreprese$tintermediateproducts,e y

The input materials to the facility are measured for e1 hent

and/or isotope, TherearenocrediblesubstitutematerialspNsentintheMAAor adequate centrols exist to preclude the use of' substitute materials to conceal a diversion, s

3 The quantity of SSNM in sidestreams can be reliably measured, and The ultimate product of the operation is measured for element and/or isotope, as appropriate.

t w

I h

4 l ^

\\

l

't i

11 i

e l

('

1

=.

...,,l-_-,,

V s'l-y-

-.~

9uestions and Answers 74.53 In-ProcessMonito$ing 1.

Q:

What' forms (of SSNM are covered by this section?

A:

Bulk materials, including nontamper-safed containers of SSNM as well as materials in process equipment.

In general, these requirements s

apply to material. that has to be measured or counted to verify its presence, rather than have its identification number and seal integrity checked.

2.

Q:

How does she lost detection mass sensitivity of 10 CFR 70.51, 70.57, and 70.58 compare to that of the proposed amendments?

A:

It is difficult to make this comparison because the current regulations do not explicitly specify loss detection performance capability required c

of the licensees.

I

.The current regulations (10 CFR 70.53(b)(1)) require the licensee to report the probable cause if an inventory difference ~ exceeds both its e

H

/

measurement system limit of error and 200 grams of plutonium or f

l uranium-233 on 300 grams of high enriched uranium or uranium-235 con-j; /

tained in high enriched uranium.

The measurement system limit of error is permitted to be 0.5 percent of plant throughput.

This 1"

reporting requirement is not equivalent to the response to a detec-tion alarm that the proposed rule would require.

Further, it is not timely and does not require substantiation of the cause.

Neverthe-

[

less, it provides a point for comparison.

The proposed amendments require at least a 95 percent probability of detecting a five FKG

~

t loss fron each unit process.

To attain the same probability under a

the current regulations, the limit of error should not exceed one FKG* khich corresponds to 200 formula kilograms of bimonthly throughput.

3.

Q:

Would licensees be required to detect losses of amounts smaller than g

5 FKG?

A:

The Commission has judged the risk to the public's health and safety

/,

of losses of less than 5 FKG of SSNM to be relatively small compared

~

to losses of more than that amount.

Under the current regulations, which include limits that are proportional to plant throughput, a small throughput licensee may be required to keep inventory differences less than a few hundred grams, while a large throughput facility may be allowed to operate with inventory differences of more than five FKG.

The proposed amendments would apply the same detection goal quantity to all licensees, both large and small.

These amendments

  • This b based on studies that suggest that the true standard deviation of inventory difference is often about twice that due to measurement system error alone; and on the assumption that the true distribution is not symmetrically r

dir+.rfouted about zero.

12

- y..+

r s f

would 5equire detection of single abrupt losses of 5' FKG with 95 g percent or greater probability of detection.

They would also provide a capability to detect smaller losses with reduced deteccion s

probability.

k Furthermore, each licensee who possesses one gram or more of U-235, U-233 or plutonium would continue to be required by 10 CFR 74.11 to

[

report any actual known:' loss' of SSNM, regardless of quantity.

t 4.

Q:

Arh nases,from any 1ccation required to be detected, or only losses a

from accessible locations?

'S A:

Lossas from any location must be detected.

The concept of3 accessible location applies only to the criteria for establishing andidetermining the, timeliness of the licensees' detec. tion capabilities. The detec-tion tima is the duration from when,the SSNM passes a place from where it is accessible to diversion to4the' time at which\\its l'oss would be l

f detected.

Licensees are encouraged to have few accessible locations

.)

since the risk of material being stolen is reduced by minimizing opportunities for people to have. access to material or to have access

+ s to points of remote control over material flow if those controls could

[

.be used to divert the flow into unadtt.orized locations.

f_

l

' 5.

Q:

Should a glovebox be considered an " accessible location"?

A: ! Generally yes.

Since such activities as a glove change or " bagging cut" operation are considered routine, a removal of material via this route may not be'readily detectable.

However, if there is an enforce-able policy that all removals from a glovebox must be accomplished by i

at least two individuals and there arelno access points which could 2

be accessed without an obvious indicasion, a glovebox may'be treated as inaccessible.

6.

Q:

Will it be necessary to close a material balance in order to achieve the detection capabilities?

\\

3 A:

No. ~ As defined in 10 CFR 70.51:

" Material balance" means a determination of an inventory differencei (ID)-(formerly called material unaccounted for (MUF)) by subtracting ending inventory (EI) plus removals (R) from beginning of inventory (BI) plus additions to inventory (A).

Mathematically, ID = BI + A - EI - R.

Paragraph 70.58(k) requires closing a measured material balance around each material balance area (MBA) and the total plant.

All SNM received by an MBA, transferred frdm the MBA, discarded, or on inventory has to be measured and recorded to permit the iD to be determined i

(10 CFR 70.58(e)).

The ID is required to be calculated for both the element and fissile isotope of uranium.

4 y

13 t

?

1 f(i

a, m

4-In contrast to current regulations, it is not the intent of the proposed amendments to require measured balances as the only acceptable material control test for detection of losses.

It is the intent of the proposed amendment to assure that the detec-tion and localization performance criteria of the rule are met.

In some cases, a licensee may find no satisfactory alternative to closing a material balance in order to satisfy the performance criteria.

In other cases, alternatives will be feasible.

(For example, see pages 4-8 of NUREG/CR-1670, Volume 1, "The Use of Process Monitoring Data for Nuclear Material Accounting," October 1980, and pages 12-13 of NUREG/CR-1686, Volume 1, " Feasibility and Cost / Benefit of Advanced Safeguards for Control of Nuclear Material In-Process," October 1980).

7.

Q:

The measurement system error is not constrained by the detection pr:hability requirement without a false alarm limit.

Isn't there a limit on how big the measurement error can be?

A:

The problem that comes from too large a measurement or process uncertainty, which causes the standard deviation of the test statistic to be a large fraction of G, is excessive false alarms.

The rule does not limit the number of false alarms allowed.

However, the alarm resolution requirements must be met.

One approach to meeting those requirements is to reduce expected false alarms to a level below I

the acceptable number of unresolvable alarms.

Another approach is to tolerate a fairly high rate of false alarms and have more accurate backup measurement systems or more accurate downstream measurements to help resolve the false alarms.

Criteria for the acceptability of the alarm resolution approach will provide the limits on measurement error-for detection and response.

8.

Q:

Why is there a requirement to investigate process differences that exceed three times the standard deviation of their estimator and 25 grams of SSNM.

A:

Differences that exceed three standard deviations are expected to be good quality control indicators for anomalies that could have an adverse impact on material control and accounting.

In some units differences of such a magnitude might trigger an alarm potentially indicative of a 5 FKG loss, in which case alarm resolution procedures I

would be initiated.

In other cases, the differences may be far less than the quantity necessary to trigger an alarm; however, investigative action is appropriate before the problem escalates to a more serious situation.

9.

Q:

What is to be accomplished by a trend analysis?

A:

Non-random behavior of process differences may indicate the presence l

of an unidentified bias, unmeasured loss stream, or a diverter.

It is l

important that trends be identified so that investigations can be initiated to uncover the cause.

14

/

10.

Q:

What constitutes a " working day" as used in this part?

A:

A working day is any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period during which material processing activities occur and there is material handling.

A day during which activities such as maintenance of equipment, clean-up, autoclave monitoring, etc., occur would not be considered a work day unless SSNM handling was involved.

The main criterion is whether or not the activities would afford the opportunity for diversion or theft.

15

CHAPTER 2.0 ITEM MONITORING 2.1 Item Loss Detection Requirement: The rule' requires that each licensee establish the capability to detect a five formula kilogram loss in item form using any statistical test that has a 99 percent power of detection.

Detection is to occur within:

(1) Thirty calendar days of a Category IA loss and 60 calendar days of a Category IB loss for those items in a vault or permanently controlled

-access area. isolated from the rest of the MAA; and

+

(2) Three working days of a Category IA loss and seven calendar days of a Category IB loss for items located elsewhere in the MAA except that the loss of reactor components at least one meter in length and in excess of 30 kilograms is to be detected within 30 calendar days; (3) Sixty calendar days from the loss of Category IB items in a permanently controlled access area outside of an MAA; and (4) Sixty calendar days for samples in a vault or permanently controlled access area and 30 calendar days for samples elsewhere in the MAA for those samples containing less than 0.05 FKG of SSNM-($74.55(b)).

Items, except samples, are to be uniquely identified, quantitatively measured, with the validity of the measurement independently confirmed.

Additionally, j

items are to be either:

(1) Tamper-safed or placed in a vault or permanently controlled access area that provides protection at least equivalent to tamper-safing; or (2) Sealed such that removal of SSNM would be readily and permanently apparent (e.g., encapsulated) (74.55(a)).

Intent and Scope:

The intent of this requirement is to ensure timely plant-wide detection of the loss of items that total 5 FKG or more.

To achieve this capability, the licensee is expected to verify the presence and integrity of selected SSNM items on a periodic basis.

The required frequency of tests for missing items is graded according to the relative attractiveness of the material type in the item, the ease with which the item could be diverted with-out being observed, and the degree of surveillance and containment provided for by the physical security.

If SSNM is not tamper-safed, stored in a vault or permanently controlled access area that provides protection at least equivalent j

to tamper-safing, encapsulated, or in samples containing less than 0.05 FKG, it is not considered an item and the SSNM is subject to the in process control requirements for bulk material.

l The longer detection times for losses of items from permanently controlled access areas takes into account the added security afforded by the physical protection measures required of such areas by 10 CFR Part 73. However, this provision should not be interpreted as authorizing the placement of materials in these areas other than those already authorized pursuant to Part 73.

a 16 4

~.

Plan / Annex Content:

The FNMC Plan contains the following affirmations and detailed commitments.

Supporting information, as appropriate, is included in the Annex.

Section 2.1 of the Plan includes is the following affirmations:

o The presence and integrity of selected SSNM items are verified periodically.

The item selection method has at least a 99 percent probability of detecting the loss of items plant-wide that total 5 FKG within:

Thirty calendar days from loss for Category IA items and 60 calendar days from a loss for Category-IB items for items in a vault or a permanently controlled access area that is isolated

-from the rest of the material access area (MAA);

Three working days from a loss for Category IA items and seven calendar days from a loss for Category IB items located elsewhere in the MAA except for reactor components measuring at least'one meter in length and weighing in excess of 30 kilograms for which l

the time interval shall be 30 calendar days.

Sixty calendar days from the loss of Category IB items in a per-manently controlled access area outside of an MAA; and Sixty calendar days for samples in a vault or permanently con-trolled access area and 30 calendar days for samples elsewhere in the MAA for samples each containing less than 0.05 FKG of SSNM.

Items are classified as either Category IA or IB at the time they are o.

i created in order to fix the frequency of tests for item' loss.

Each SSNM item is uniquely identified; the SSNM content is quantitatively o

measured; the validity of the measurement is independently confirmed and assured through tamper-safing or storage in a vault or permanently controlled access area that provides protection at least equivalent to tamper-safing; and a record of the identity, location, and SSNM content is maintained.

l o

Vaults or permanently controlled access areas isolated from the rest of the MAA are operated with physical and administrative controls over personnel access such that unauthorized additions and removals of items from the storage area will be either prevented or promptly detected.

In addition, every change of inventory in the storage area is recorded.

i o

The operating procedures of item storage areas are documented.

A designated individual is responsible for the operation of each such-o storage area.

l 17 L

l

~

o The response actions documented in Chapter 3.0 of this Plan will be initiated if one or more items are missing except where the missing items total less than 10 grams U-235, U-233, or Pu.

1 2.1.1 Item Identification Describe the identification system (numeric or alpha-numeric) that will be used to assign unique identification to each item.

The description should include the features of the system which preclude falsification or which assure prompt detection of.such attempts.

2.1.2 Item Classification Provide the basis-for classifying items as material Category IB and any proposed exemptions from item control tests or from response actions, including a listing of the item categories involved and the rationale for such exemptions.

2.1.3 Tamper-safina Describe the tamper-safing procedures that will be employed to assure the continuing validity of previously measured and attested to SSNM values assigned to unique items.

Aspects to be addressed should include:

personnel involvement, types of seals, attesting to declarations, records, and inspection methods for detecting violations of item integrity.

2.1.4 Accessibility Describe the personnel access controls, the surveillance procedures, and the records procedures for entrance and exit of personnel to and from vaults and/or permanently controlled access areas.

If any of the above attributes are l

described in sufficient detail in the facility's Physical Security Plan, appro.

priate references may be made.

2.1.5 Accounting and Control Procedures Describe the item accounting and control procedures for items placed in I

and removed from secure storage.

The description should include item inventory records utilized.

2.1.6 Item Measurements Identify the measurement systems to be used for quantification of the SSNM content of items at item creation time.

The description also should include the i

confirmatory measurements used to quantitatively verify the SSNM content of nontamper-safed items placed into or removed from vault storage or a permanently controlled access area that is equivalent to tamper-safing, including the l

controls that prevent or detect attempts at substitution.

18

ed 2.1.7 Item Verification Describe the item verification procedure.

The description should include:

The inventory sampling method, including the sample size selection equations, the inventory stratification plan, and the method of selecting the actual items to be verified; The extent to which cyclic, dynamic, or perpetual inventory data and production records, if any, will be used to modify or supplement the sample size, sample selection, or item verification procedures; and The minimum loss detection sensitivity and maximum time periods between item verifications for each category of material.

In the Annex, provide the rationale for the item stratification plan.

2.1. 8 Sample Items Describe the technique that will be used to establish the sample population and how the presence of selected items will be verified.

Additionally describe how samples containing greater than 0.05 FKG will be monitored.

Acceptance Criteria:

The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:

i The item identification system possesses attributes that assure unique o

item identification, preclude falsification, or as a minimum, make prompt detection of such attempts achievable.

Factors to be considered in achieving this objective are:

The use of tamper-safe seal numbers for unique identification i

represents an attractive alternative because:

the same number is used for both seal and item tracking, seal numbers cannot be altered without leaving visible evidence, and seal distribu-tion and usage are controlled; The use of prenumbered containers which retain the same identifica-tion for repeat uses should generally be avoided unless detailed usage records are maintained that reflect the source and disposi-tion of items including times to fractions of a day; and l

The use of pre printed labels or blank labels that are numbered as they are used is acceptable provided unauthorized alteration or replacement of the labels would be readily apparent to a knowledgeable observer.

o Independent confirmation of the SSNM content of items will be achieved by having a second person do the following:

Observe the bulk measurement and sampling of the item whose contents are to be determined, 1

I 19 l

Observe the nondestructive analysis of the item, or Perform a second' quantitative analysis independently that does not destroy the. integrity of the item, and Witness and attest to the application of an approved tamper-seal, or Accompany the first person and the item to a vault or permanently controlled access area which will provide storage equivalent to tamper-safing.

o Storage that meets the physical security requirements for vaults, documented in Part 73, will meet the requirements of 10 CFR 74.55 for storage of items containing either Category IA or IB material.

o Storage that meets the following requirements will be accepted as a permanently controlled access area (CAA) isolated from the rest of the MAA for the purposes of 10 CFR 74.55:

CAA is equipped with physical protection capabilities required in Part 73; Access to the storage area is limited to the minimum number of persons necessary and records are kept of the persons who enter and leave it; Records of the items in storage are maintained; and An operator witinin the storage area will be continuously observed by another person, and all additions, removals and movements of material by either person are verifiable by the other person.

o Storage will provide protection at least equivalent to tamper-safing if:

Access to the vault or permanently controlled access area is limited to the minimum number of persons necessary, and records are kept of the persons who enter and leave it; l

The personnel authorized to enter and operate the vault or permanently controlled access area are not authorized to remove or handle SSNM beyond the boundaries of the vault or area unless controls are in place that would preclude an individual from surreptitiously removing an item or any portion of an untamper-sealed container; A person entering the vault or permanently controlled access area will be accompanied by another person and all activities by either person will be verifiable by the other.

In addition, remote surveillance, such as closed circuit television, with the capability of seeing both operators at all times will be used.

The remote surveillance need not be continuous if the occupants 20

O*

cannot determine or predict when they are or will be under

. surveillance; The SSNM content of nontamper-safed items will be measured, independently can' rmed by a second person, and the item will be under the continc^

surveillance of the two persons from the s

time of measureme

" ail placed in a. vault or permanently controlled access A record w 1 be maintained of the location, identity and SSNM content of the nontamper-safed items; The SSNM contents of nontamper-safed items will be verified by quantitative measurements when removed from a vault or permanently controlled access area except for solid components which can be verified by a weight check.

The verification measurement and the original result shall agree within the combined measurement i-uncertainties.

(Note:

Random errors will generally ba the only component of the uncertainty except in those instances where a recalibration of the. measurement process has taken place.) The verification measurement should also detect substitution except where it can be demonstrated that no credible substitute material is present in the vault or permanently controlled access area; and The response actions documented in Chapter 3.0 will be initiated if an unauthorized vault or permanently controlled access area i

penetration is suspected or if the SSNM content of any container is unexplainable and significantly different from the recorded value.

o The acceptability of tamper-seals will be based on an evaluation of I

the seal attributes in relation to time to defeat and tamper-indicat-ing features.

Seals already deemed acceptable by NRC include:

Type E, Pressure-sensitive, and Steel Padlock (SAND 780400, Figure 14(2)).

Other seals, such as fiber optic, may be equally acceptable.

The licensee should provide the appropriate information, including references, to enable the licensing reviewer to assess the adequacy of other than currently approved seals.

The control of seals and seal records should preclude or make readily o

apparent any attempts at illicit use of seals.

Potential contributors to these objectives should include commitments that:

Seals would be stored in a locked repository within a room that is locked when unoccupied, Blocks of seals issued to designated individuals would be afforded the same level of protection, A single individual without any responsibility for seal applica-tion or destruction would be designated as the seal control 4

officer, i

4 21 i

s

~

The seal log book maintained by the control officer would be 4

kept separate from the seals and stored in a locked repository, Individuals responsible for applying seals either would have unused seals in their personal possession or place them in a limited access locked compartment.

As a general rule, the number of available seals issued to these individuals would be limited to a typical single day's use, The licensee would have in his possession a commitment from the seal manufacturer that plates and/or dies and production residuals will be controlled and protected, and Used Type E seals would be crimped, flattened or otherwise rendered unusable and properly disposed of.

o The frequency of item verification tests should be consistent with

" times to detection" specified in $74.55(b).

o The number of items to be verified should be sufficient to give a power of detection of at least 99 percent for a loss of items totaling 5 FKG from each stratum or inventory subdivision (a grouping into similar types and amounts of SSNM).

If all strata'in a facility are sampled for verification with at least a 99 percent power of detecting a loss i

of items containing 5 FKG, that criterion also will be achieved l-for a loss of items containing 5 FKG or more plant-wide.

o The item inventory should be stratified or subdivided in a manner that assures at least a 99 percent power of detection while minimizing i

the number of items to be verified.

It is advantageous to subdivide the inventory into classes or strata having approximately uniform i

quantities of SSNM per item.

A moderate range of SSNM contents within a class, such as i 10 to 20 percent, is usually advisable.

Typical classes for sampling are-fuel elements, containers of scrap, containers of feed material, containers of waste, etc.

o The means of determining the number of items to be verified per class or strata should be specifiec.

For example the equation 1

n = (N) (1 - pd) is an acceptable formula for calculating the sample size required from an inventory or any subset or group of size N, where d is the number of altered or missing items (defects) that total a goal quantity and 1-0 is the desired probability of obtaining one defect j

in the sample of n items where there are d defects (d21) in the population of items.

The number d is a function of the amount of SSNM per item.

If the SSNM content varies over the population of items, the largest value must be used to calculate d to ensure that n is large enough to guarantee that the power of detection is at least 99 percent.

This results in a conservative value of n, i.e., n is s

i' 22

4 larger than necessary.

If a smaller item content were chosen, such 1 -

as the average value, an informed adversary could selectively divert only large items and thereby reduce the risk of detection.

Additional points to consider in this regard include the following:

In those cases where the SSNM content per item is very small, the required sample size is a small fraction of the inventory.

The result may even be that, in some instances the calculated sample size will be less than one. -However, such items cannot be ignored.

An acceptable approach would be to periodically verify one randomly selected item from the class at times chosen by random selection, such as by a random number generator.

In some instances an entire stratum may contain less than 5 FKG, Nevertheless, such strata should be sampled like any other.

If the number of items, N, in each strata remains reasonably constant (such as within i 10 percent), it is not necessary to recalculate the fraction of the population, n/N, to be checked each time.

Neither the specific items to be verified in any particular instance nor items that won't be verified shall be predictable.

Every item in a strata has a non-zero probability of being-selected for verification.

When incorrect descriptive information for an item, such as item type, o

seal number or location is found, the action to be taken will ensure that the item is located, is correctly identified and the deficiencies a

in the system are corrected.

1 Item verification should include positive identification, seal inte-o i

grity checks, container integrity checks, and location confirmation.

j Considerations related to verification include the following:

Electronic or optical methods such as bar code readers may be used in place of manual methods to record item or seal numbers provided safeguards against falsification are in place.

If the licensee can demonstrate that seal falsification is non-creafble, seal identification can be done on a random basis provided an independent means of confirming item identity, such as unique container numbers, is available.

Seal integrity checks normally will encompass visual examination l

and, in the case of certain seals (e.g., Type E), physical handl-ing.

Proposed shortcuts may be justified on the basis of low l

strategic value, limited accessibility, frequency of checks, and i

backup checks by production, quality assurance, production con-trol, etc.

These should be reviewed for acceptability on a case-by-case basis.

23

1 e

The magnitude of the formal item verification effort'can be adjusted to take credit for other means of confirming the presence and identity of sealed items.

Process control and accounting, quality control testing, and other production-operations routinely generate information that can serve to F

verify the identity and presence of. sealed items.

These sources can be used in lieu of item verification provided the frequency and loss detection sensitivity requirements of the item verifica-

. tion procedure are met and the use of the data for this purpose is not predictable.

Examples of specific sources of such data are:

(1) Records that an item was created (tamper-safing procedure applied) or transferred within the required time span, as defined in $74.55(b);

(2) Records that an item was inspected, tested, analyzed, altered, or subjected to any other production or quality assurance operation within the required time span; and (3) Production schedules showing that a particular item was

" cued up" for production planning purposes where the cueing process involved a check of identity and location.

Any items that have been verified by such a procedure within the time span required for that category of material can be exempted from formal item verification provided, as indicated above, item handling or movement is unpredictable to a potential diverter or the items will be physically accounted for by at least two individuals during sequential processing or inspection steps during the required time span.

To exempt the above items from formal item verification, the items are simply dropped from the list of n items selected from the inventory list where n is the sample size required for verification.

Small ite*t euch ac element sections and samples can be amassed in a o

tamper-safed container to alleviate excessive item verification.

o Items will be classified as Category IB material and subject to the lower frequency item loss test if:

The dimensions are large enough to preclude hiding the item on an individual (i.e. at least two meters in one dimension, greater than one meter in each of two dimensions, or greater than 25 cm in each of three dimensions.);

The weight of 5 FKG of the material is so large that one person cannot carry the item inconspicuous 1y.

The minimum weight to meet this criterion is 50 kilograms; or The quantity of SSNM in the item is so small that a large number of diversions are needed to accumulate 5 FKG.

The maximum quantity to meet this criterion is 50 formula grams.

24

The first two exceptions do not apply if the item can be opened or disassembled.and part or all of the SSNM removed without a high probability of being observed or detected, The presence of higher tier components such as fuel blocks, preassemblies, o

subassemblies, etc. stored outside of a permanently controlled access should be verified in accordance with a sampling plan that provides the capability to detect a 5 FKG loss within one month.

One month is deemed to be acceptable on the basis of the large physical size and weight of these items and the restrictions on removing them from the MAA.

Encapsulated items containing less than 200 grams of SSNM whose presence o

has been verified during the prior six months as part of a statistical sample or handling during routine production need not be reverified for physical inventory.

Items whose presence has not been verified in the same time interval should be located by two person inventory teams.

o Samples containing in excess of 0.05 FKG can be considered a side-stream in a bulk test performed in the originating process unit pro-l vided the samples are returned to process within seven days.

SSNM

]

removals from such samples should be documented and the area records corrected accordingly.

1 l

l l

l j

25 l

CHAPTER 3.0 ALARM RESOLUTION 3.1 Alarm Resolution Requirement:

The rule requires that a licensee resolve the nature and cause of any MC&A alarm within an approved time period.

If a loss has occurred, the licensee is to determine the amount of SSNM lost and, as appropriate, return out-of place SSNM to an appropriate place, update and correct involved records and modify the MC&A system to prevent similar occurrences in the future.

Addi-tionally, if an abrupt loss detection estimate exceeds 5 FKG of SSNM, material processing operations related to the alarm are to be suspended until completion of planned resolution activities unless the suspension of operations will nega-tively affect the ability to resolve the alarm.

However, operations of con-tinuous processes may continue for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period while checks are made for mistakes (9 74.57(b), (d), (e), and (g)(1)).

Intent and Scope:

The intent of these requirements is that the licensee's alarm resolution system will be able to respond promptly to alarms indicating a potential loss of SSNM and determine whether the alarm was caused by an actual loss or by a system error.

The alarm resolution program also should be able to identify the type of system error or innocent cause so that remedial action can be taken.

The alarm response should be timely to ensure that alarms are investigated and resolved promptly while memories of events leading up to the alarm are fresh, materials are still available for remeasurement, and fewer changes of process conditions, inventories, in process holdup, and item locations will have occurred.

Prompt resolution will facilitate recovery of " lost" or stolen material.

Plan / Annex Content:

The FNMC Plan contains the following affirmations and detailed commitments.

Supporting information, as appropriate, is included in the Annex.

Section 3.1 of the Plan includes the following affirmations:

o A systematic investigation into the nature and cause of each MC&A alarm will continue until the cause has been established or a deter-mination has been made that the alarm is not resolvable with the information currently available.

NRC will be notified when the latter situation occurs within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or within the next working day when a weekend or holiday intervenes.

o Written investigation procedures will be maintained which will include decision rules by which a particular cause or combination of causes will be accepted as the cause of an alarm.

o Investigation of alarms will be initiated promptly and the maximum allowable time periods for completion of the alarm resolution proce-dures will be as specified in Section 3.1.3 o

A search for a missing item will not be terminated until the item is either located or evic nce is obtained that the item has been destroyed.

A claim that an item containing more than 50 formula grams was destroyed without having been recorded will be supported by independent and concrete confirmatory evidence of destruction.

26

P o

If the integrity of'an item has been compromised, i.e., the container o

seal or the encapsulation has been altered or broken, an appropriate response procedure will be promptly initiated to determine whether any SS M is missing.

I o

Compromised items will be placed under surveillance or in secure storage and will be remeasured within the time period specified in the plan.

The quality of the remeasurement will be at least equal to the original measurement.

i l

i o

Following alarm resolution, appropriate corrective action will be-4 -

taken to correct any records found in error, to return misplaced SS M to the proper location, if appropriate, and to revise the MC&A system to prevent similar occurrences in the future if such action is warranted.

i When an actual loss of SSM is indicated, the quantity of material i

o lost will be estimated and other information which may aid in the recovery of the material, such as the material type and container type, and who last had responsibility for it will be generated, if possible.

When a detection alarm indicates a potential loss in excess of 5 FKG, 3

o continuous processing operations related to the alarm will be suspended within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the alarm, and the suspension will be continued i

until completion of the planned resolution activities unless the sus-pension would negatively affect the ability to resolve the alarm, or When a detection alarm indicates a potential loss in excess of 5 FKG, batch processing operations will be suspended immediately after the alarm or upon completion of the batch in process, and the suspension will be continued until completion of the planned resolution activities, f

When a process is not shut down, equally effective alternative a

i measures will be taken when an alarm occurs to protect information 1

and material that would be needed during the alarm investigation.

l Alternative measures by unit process are documented in the procedures specified in Section 3.1.1.

5 3.1.1 A_larm Resolution Procedures Describe the alarm resolution procedures that will be applied to the various types of alarms and unit processes.

The procedures should take into account credible innocent occurrences that may cause alarms indicating a potential SSM loss.

The resolution procedure descriptions may be abbreviated.

Also describe in the Plan the specific procedures to be employed in response to alarms indicating a potential loss in excess of 5 FKG.

The description should identify those operations that will be shut down or alternative measures that will be employed in lieu of shutdown to facilitate an investigation.

In the Annex, provide (1) a listing of identified credible causes of pos-sible alarms by unit process and details of the resolution procedures by which 27

4 j'

specific causes could be identified, (2) a statistical estimate of the expected i

number of unresolvable alarms per inventory period with loss estimates greater than 5 FKG and a description of the estimation method, and (3) the justifica-tion for not shutting down certain process operations during an investigation.

i 3.1.2 Decision Rules Describe the types of information and data developed during response that t

will be accepted as sufficient evidence for assigning a specific cause to an 1

alarm.

The information and data described above should form the basis for development of the decision rules to be included in this section.

These rules should take into account every identified potential innocent cause that may result in a bulk or item loss alarm.

I 3.1.3 Response Time Indicate the response times that will be allotted to resolve each alarm type.

If alarms involving certain material types or alarms from certain processes require appreciably longer response times than those estimated in the acceptance criteria section on page 30, justify the indicated times.

i a

3.1.4 Item Discrepancies

)

Describe the actions that will be taken in response to the following item discrepancies:

4 An item has apparently been destroyed without being recorded.

The integrity of a tamper-safed or encapsulated item has been compromised.

Unauthorized entry or other violation of control of a vault or a permanently controlled access area has occurred.

I i

A significant difference between the measured input and output value of an untamper-safed item placed in vault or CAA storage has been

detected, j

The actions in response to these discrepancies should include decision i

rules which will be the basis of acceptable resolution.

Acceptance Criteria:

The assessment of the adequacy of the information supplied l

above will be based on the following criteria or equivalent:

o Resolution procedures are described for alarms that indicate a potential abrupt loss of 5 FKG of SSNM in bulk or item form.

The l

procedures take into account the expected differences in loss mechanisms and necessary differences in response approaches for in process materials, items, different material types, and different types of unit operations.

The differences and variations in resolu-tion procedures are explained.

Examples of different types of unit l

processes are:

A bulk storage unit, 1

28 4

- ~

. - ~ ~

- -.-.~.

--- - ~ ~.--

A batch process with cleanout between batches and very small amounts of in process holdup, A continuous process with continuous flow between the unit process and the succeeding process, and A process with large hold-up inventories that cannot be measured directly without cleanout.

o The alarm resolution procedures provide a systematic and logical sequence of steps for determining the cause or causes of an alarm.

An example of a systematic approach to assessment would be:

Check the data and calculations for clerical, transcription, or computational errors; Trace the data to the primary sources (operator logbooks or production records and analytical reports) to check for agreement; Compare the source data, such as item and batch sizes and numbers, inventory quantities and flow rates, to historical values to detect anomalies that may indicate an error of identification or measurement; Review downstream material balances for potential off-setting gains; Localize the source of the alarm as nearly as possible with regard to time, place, material type, and individuals potentially involved; Report a potential SSNM loss to security who then should imple-ment intensified search and surveillance procedures; Stop further processing in the unit process, if feasible, to retain items and inventory for remeasurement; and Remeasure t il items, inventories, batches, and/or samples from the unit process that are still available.

o Each type of alarm response is identified with the corresponding types of material and/or unit processes and the credible innocent causes of the alarm.

Examples of innocent causes would be:

A clerical or computational error is identified that clearly explains the alarm; A missing item is located; A claim that an item was added to the process, although no record j

of the transfer was found, if substantiated through an actual yield versus predicted yield comparison; l

i 29 l

i

_-, ~ -. _.

~.

A remeasurement confirms that error (s) in the original data l

caused the alarm; or A random fluctuation in the measurement process or a process variability is identified through sufficient measurements or additional processing.

o The decision rules for a conclusion that a particular cause is applic-able and that the alarm is resolved are described.

(Backup informa-tion about the rationale and justifications are included in the Annex.)

A decision rule must generally provide an objective basis for deciding whether or not the data and information acquired up to that point in the alarm assessment supports the hypothesis that the alarm was due to an innocent cause.

Each decision rule should be based on the identification of a specific cause or a source of incorrect data that contributed to the alarm level of the loss estimator except that the rule may verify with high probability that no loss has occurred without having identified all contributing causes of the alarm.

Examples of acceptable decision rules are:

A false alarm resulting from a mistake.

1.

A correctable mistake identified and supported by direct evidence such as comparison to data collection sheets, reading a column level, or measuring a sample.

2.

A correctable mistake or recordkeeping error identified and supported by at least two sources of independent indirect evidence such as consistency of process values, historical ranges, a loss followed by a gain in the following control unit such that an error in the transfer i

was identified as greater than measurement error, or an interview with operators who observed an unusual process condition.

3.

A hypothesized uncorrectable mistake (or combination of 1

mistakes) or procedural error which is supported by a l

difference of opposite sign and comparable magnitude in a 1

related loss indicator and two sources of indirect evidence such as process yield, balance around non-SSNM materials, i

process consistency, or measurement control data indicating a short term failure.

A false alarm caused by stochastic fluctuations in the detection l

system.

1.

An error resulting from measurement variability identified and supported by remeasuring inventories or transfers where the differences between the original and remeasurement values exceed the two sigma confidence interval used to monitor and control measurement performance.

i i

l 30 i

2..

An error resulting from variabilities in the process that is confirmed by processing the material through the process and verifying the discrepancy by recovering the material.

~

3.

An error resulting from inadequate modeling of in process inventory where continued processing results in a stable cumulative loss indicator.

j 4.

A bias identified by an independent technique that results l

from differences in material types being processed.

i The alarm resolution time commitments ensure a reasonably prompt alarm o

response.

The check of the loss indicator data for clerical mistakes and data errors should normally be completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for any abrupt loss alarm.

The maximum time for completion of the resolution i

procedure for alarms indicating a possible abrupt loss of items that j

were tamper-safed, encapsulated, or retained in a vault that provided protection equivalent to tamper-safing should normally not exceed three calendar days.

The maximum time for completion of the resolu-tion procedure for alarms indicating a possible abrupt loss of SSNM i

in any form or container that was not tamper-safed, encapsulated, or i

stored in a vault equivalent to tamper-safing should not normally exceed three working days.

However, if longer time periods are required for certain unit processes or types of necessary response 3

activities, the licensee should explain and justify the proposed j

times in the response plan submitted.

o When a tamper-safed or encapsulated item has been compromised, a remeasurement should be immediately undertaken.

The maximum time after the alarm for completing a remeasurement to confirm the contents i

should normally not exceed two working days.

Any proposed extension i

of that time should be explained and justified.

An example of where additional time might be necessary would be if isotopic measurements are performed off-site.

o When a vault or CAA providing protection equivalent to tamper-safing has been entered without authorization, when the prescribed vault protection has been compromised, or when other indications of loss of r

control are discovered, the entire vault contents should be accounted for within three calendar days by a piece count and attribute test of all items not tamper-safed or encapsulated, such as by weighing or NOA.

Remeasurement of all items in the vault or permanently control-led access area not tamper-safed or encapsulated should be initiated within one working day.

If a longer period is proposed, justification is provided.

Since the number of samples to be analyzed is unknown, it is impractical to specify a time to complete the remeasurement.

i 31

i o

Remeasurements of the SSNM to verify the content or composition of items or bulk material associated with an alarm should be made to a standard deviation of the quantity estimate that is comparable to that of the book value, and the hypothesis that the difference between the initial and remeasurement value is zero should be tested at the 0.05 level of significance.

o In the event that the cause of the alarm is claimed to be the destruction of an item such as by processing it.to another form, without the act having been recorded, confirmatory evidence should be developed to support the conclusion.

The types of confirmatory evidence that are expected to be applicable are described in the plan.

The evidence will be acceptable if it is relevant, concrete, independent, and objective.

Examples of such evidence are:

The measured density of a suspect solution is consistent with the predicted density assuming the contents of the missing container had been added to the process, The actual yield from a suspect unit process is consistent with i

the predicted yield from that process if it contained the contents of the missing item, or

^

The fact that th'e container was added to process can be attested to by two individuals.

o After an alarm has been resolved, the planned corrective action includes MC&A system revisions, if appropriate, that provide reason-able assurance that future alarms of that nature, i.e., having the same or a similar cause, will not occur.

An example of where an MC&A system revision would be appropriate would be revision of a procedure or computer software that contains an error that caused an alarm.

I o

If one or more items are not found in their recorded locations the ifcensee should normally declare the item (s) missing if not found or l

accounted for within:

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for Category IA items totalling five i

formula kilograms or more and three working days for all other items.

A search for a misplaced item that was not tamper-safed or encapsu-l lated should not be terminated without NRC permission until the item i

is located or evidence of its destruction is obtained, except that a claim that an item was destroyed without recording the fact may be accepted if independent confirmatory evidence of destruction is e

obtained.

Items containing less than 0.05 FKG are exempted from the requirements for confirmatory evidence.

Searches for missing items should not be interrupted by idle time such as weekends, holidays, etc.

o An item loss assessment procedure has been included which details a logical sequence of actions to resolve an apparent loss.

A typical j

assessment sequence (not necessarily in the order listed) might be to:

Determine that the records are apparently correct by tracing the item identification and location information to its source data in inventory and production records; 32

0 Search other production and storage areas to determine if the item was transferred without supporting documentation; Identify all persons involved in creation and movement of the item (s) and question them for possible ways the item might have been misplaced or record errors made; Extend the search to other locations, particularly those suggested by the persons involved; Check for possible errors in the item records by evaluating the bulk material balances in the adjacent processing units; Reinventory all items of that type in storage locations routinely used for such items; and Extend the inventory search to items of similar size and appearance.

o A description of the licensee's proposed course of action in response to a broken tamper-seal should include:

Placing the item under surveillance immediately or in secured storage and remeasuring it as soon as practicable (time limits

^

specified) to determine if SSNM is missing, Performing blending, mixing, or splitting operations, if appro-priate, to assure that any samples taken for remeasurement are representative; and Testing the difference between the original and confirming measurement for statistical significance with a probability of no more than five percent of concluding that no SSNM is missing when in fact a loss has occurred.

The quality of the remeasure-ment should be at least comparable to the original measurement.

o The operations that will be shut down to resolve alarms in excess of 5 FKG are identified or alternatives to shutdown are provided.

Examples of acceptable alternatives might include:

Shutting down of only downstream operations to retain products that may require remeasurement, Discontinuing the processing of certain sidestreams to retain scrap or recyclable intermediates that may require remeasurement, Diverting scrap, waste or product from the alarming unit to auxiliary vessels or to a buffer storage area to retain the products for remeasurement, Collecting additional samples for remeasurement of materials that would become unavailable if operations were not suspended i

in the area under investigation.

i 33

~

The key consideration in employing alternatives to shutdown is that the licensee can show that no data or information needed for response will be lost if the alternative is used.

o The conditions for restart are specified.

Fundamental to any decision to restart are the alarm has been resolved, i.e., an assignable cause has been found, the loss is real but remedial, or recovery action is underway or the alarm has not been resolved; however, all possible and necessary data associated with the process material have been acquired, and no information will be jeopardized by resuming operations, The quality of the licensee's loss resolution capability is such that o

the combination of the material control test and resolution decisions will permit alarms remaining unresolved after investigation to be good indicators of material loss.

To achieve this objective, the licensee's planning data should demonstrate that the expected number of unresolved alarms in excess of 5 FKGs will be less than 0.10 abrupt loss alarms per inventory period.

The following additional information is pertinent to this point:

The only false alarms that need to be predicted are those due to normal process or measurement system statistical variation.

Mistakes in transcription of data or process upsets do not need to be predicted because the response procedures should be designed to correctly resolve alarms stemming from those types of events.

False alarms due to statistical fluctuations are expected to be more difficult to resolve.

One approach is to claim no credit for resolution of statistical alarms.

In that case, the incremental expected number of alarms with discrepancies greater than 5 FKG can be calculated for a single test from the formula:

l AN = 1 - F (5/a) where o = the predicted standard deviation of the detection test in test in FKG 1

F(x) = the predicted statistical distribution of the test statistic normalized by o.

This increment must then be multiplied by the expected number of times the test will be performed in an inventory period, and similar calcula-tions then added up over all tests in the facility.

That sum must be less than 0.10, i.e., the number of such alarms must be less than one every 30 months.

l 34 i

I

i If the distribution function cannot be assumed to the normal (Gaussian) and the true distribution cannot be adequately predicted, the Camp-Meidell inequality may be applied if it is reasonable to expect the true distribution will be symmetric and unimodal (see Shewhart (1931), pages 176-177; and Eisenhart, Hastay and Wallis (1947), page 49).

The Camp-Meidell inequality permits a bound on N to be calculated from the formula:

AN5(f)(f)2 where a has units of formula kilograms.

However, this will typically be useful only if s is less than 0.1 formula kilogram.

A more useful approach would be to estimate the maximum range that the test statistic could have based on a physical model of the process and measurement systems under the hypothesis of no material diversion.

If this value is less than 5 FKG, set AN = 0.

Evaluation is more complicated if the licensee claims that response procedures will permit resolution of some fraction of the statistical false alarms.

Such procedures would need to be summarized in the plan.

One approach is to make additional measurements of inputs, products, sidestreams, and holdups to complete measured material balances where loss detectors are based on average expected yields.

Additional measurement of input quantities requires samples to be taken and retained.

This would permit laboratory analyses to be made which are more reliable than NOA.

The procedures also could utilize data resulting from processing the same batch through the next process step, data resulting from processing another batch through the same process step, and tests that eliminate intermediate measurement points by combining several process steps.

In any of these cases, estimating the fraction of N that would be expected to remain unresolved requires detailed modeling of the response capability.

A Monte Carlo simulation method can be used to model the alarm response procedures and predict the resolution success rate.

(For a single i

material control test, refer to Tanner (1981).

For an entire plant, refer to Reardon, Heaberlin and Eggers (1982).

Detailed information is available in Eggers (1982)).

Alternatively, if the licensee has a performance history of responses to and assessment of alarms, this may be cited in place of the simula-l tion of a proposed response program if the experience demonstrates a capability to meet the commitment goals for resolving false alarms.

3.2 Alarm Reporting Requirement:

The rule requires that a licensee notify the appropriate NRC Regional Office Ifsted in Appendix A of Part 73 of this chapter of any MC&A i

alarm that remains unresolved beyond the time period specified for its resolu-tion.

Notification is to occur within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or by the next working day when a weekend or holiday intervene.

For alarm estimates that exceed 5 FKG, the 35 l

notification that an MC&A alarm resolution procedure has been initiated is to occur within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (74.57(c) and (g)(2)).

Intent and Scope:

The intent of these requirements is that the NRC be made aware of potential MC&A discrepancies in a timely manner so that appro-priate actions can be initiated.

Plan / Annex Content:

The FNMC Plan contains the following affirmations and detailed commitments.

Supporting information, as appropriate, is included in the Annex.

Section 3.2 of the Plan includes the following affirmations:

o The appropriate NRC Regional Office will be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or by the next workday when a weekend or holiday intervene of any alarm that remains unresolved beyond the time limit specified for its I

resolution in Section 3.1.3.

o The appropriate NRC Regional Office will be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the initiation of an alarm resolution procedure involving an alarm estimate that exceeds 5 FKG.

3.2.1 Reporting Responsibility Indicate how the responsibility for reporting unresolved alarms will be assigned in the organization.

3.2.2 Information Discuss the types of information that will be provided to NRC and the schedule for updating the status of the unresolved alarms to NRC.

Acceptance Criteria:

The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:

o The responsibility for reporting unresolved alarms is assigned at a i

sufficiently high level of responsibility within the licensee's organization that decisions on the need for reporting will be timely and unquestioned.

4 o

The information to be reported includes:

the magnitude of the dis-i crepancy indicated by the alarm, the investigation procedure, the status of the investigation, the status of the facility, the planned remedial measures, and the status of the security during the period.

o The remedial measures include assignment of responsibility for the investigation to a technically competent individual, rechecking the response of the measurement system to certified standards, outlining a schedule of recalibrations of the key measurement systems if appro-priate, in-situ or clean-out measurements of holdup, and statistical evaluation of the material accounting data.

l 36

With regard to' recurring losses, a significant loss trend will be o

reported within one week of its discovery and the progress of the resulting investigation will be reported monthly.

1 3.3 Alleged Thefts i

i Requirement:.The rule requires that a licensee establish and maintain ability to respond rapidly to alleged thefts (74.57(f)).

i Intent and Scope:

The intent of this requirement is to have the capability in place to respond rapidly to alarms occurring external to the MC&A system.

The response capability should provide the information necessary to rapidly

{

assess the validity of an alleged theft.

t Plan / Annex Content:

The FNMC Plan contains the following affirmations and detailed commitments.

Supporting information, as appropriate, is included in the Annex.

Section 3.3 of the Plan includes the following affinnations:

i i

o An allegation or other indication of diversion of SSNM from its authorized location will be rapidly investigated and evidence developed that supports either a confirmation or a denial.

o A contingency capability will be maintained to enable on demand loca-tion of any specific tamper-safed or encapsulated item or an unencapsulated item stored in a vault equivalent to tamper-safing j

within eight hours, and to verify the presence of all items in a j

vault within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

A contingency capability will be maintained to initiate an emergency j

o plant-wide physical inventory of all SSNM in the plant, or in any portion of the plant, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after receipt of an NRC order.

(" Initiate" means to begin actions to place SSNM in a measurable form and perform necessary preparations for conducting a physical inventory).

1 o

Accurate item inventory records will be established and maintained to j

provide knowledge of the identity, location, and quantity of SSNM in the form of items outside a vault or permanently controlled access area, and the capability will be maintained to update the records rapidly enough to confirm the presence and integrity of any item I

within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and, upon demand, all items within one week.

o For material not in the form of items, accurate records will be i

established and maintained on the quantities of SSNM which have been received, shipped, or otherwise removed from each MAA, and quantities of SSNM remaining within each MAA and the capability to update the records rapidly enough to meet the requirements of the emergency plant-wide physical inventory.

i 3.3.1 Item Control System Describe the item control system that will be maintained in order to i

readily determine the identity, quantity, and location of SSNM in item form i

i 37 f

w,,_.,-.-,-,v.-___.---,.~,.,..,_.m

,m,,,,m,--

,mm,m_,._,

_ _,,-.-m..m._

,_m

,.p-._,

O O

t can be The description should include the forms, records, and document flow paths. Where records are not centralized, the means of record verification by MC&A personnel and the responsibility for maintenance and disposition should be described.

3.3.2 Inventory Verification Describe the emergency physical inventory procedure, including a descrip-4 tion of the status that each unit operation should be in to be inventoried and indicate the status of each unit operation during its inventory.

In the Annex provide estimates of the times needed to perform and reconcile the inventory and to determine the associated projected variance.

3.3.3 Record Maintenance Describe the protective measures that will be implemented to prevent loss, misplacement, or accidental destruction of inventory and item location records.

Acceptance Criteria:

The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:

1 I

o From the description of the SSNM item record system, it is evident that' the records of the identity and location of every item can be updated with sufficient speed to support the commitments that any randomly l

selected item within a vault can be located within eight hours, and any item outside a vault can be located within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The capa-bility also exists to locate all items within a vault within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and all items outside a vault or permanently controlled access area within one week.

i Provisions are included for maintaining the availability of forms, o

tags, trained personnel, inventory listing, and other items that may be needed to initiate a plant-wide physical inventory within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

l The emergency inventory capability is designed to help answer the t

following questions:

Can it be determined conclusively that SSNM is or is not missing j

from the facility?

What quantity is missing?

What material type is it? For example, what is its isotopic composition, its chemical form, and its physical size?

Over what time period could it have been diverted?

Which plant employees or other individuals might have had access to it during that time?

Which plant employees may be able to provide information useful for its recovery.

38

y.- - -

y

,e..

V s

s Appropriate safeguirds are implessated to prevent loss, misple:e.nant,

?

I i ^

o or accidental destruction of the inventory and iters 1ccation records.

s i-The data collecting, recording, and auditing procedures provir's Veasonable o-4 protection against errors in the records.

.7 Questions and Answers 74.57 Alarm Resolution 1.

Q.

How do alarm resolution requirements integrate the contingency p1 w for MC&A events required in 10 CFR Part 737

~

A.

Licensees' plans for response to MC&A indications of possible theft or missing SSNM are currently part cf the licensees' " Safeguard /

Contingency Plarp," required by 10 CFR 70.22(g), 73.40(b), and,

73.46(h).

These were prepared in accordance with t.he criteria in Appendix C to 10 CFR Part 73 and Regulatory Guide 5.55, " Standard Format and Content of Safeguards Contingency Plans for Fuel Cycle Facilities." However, the regulations under which those plans were prepared and reviewed focused.on the physical security system.

The proposed amendments would de*fne tt e performance to be achieved by the licensees in response to' detection alarms from the MC&4 system

/

and to external allegations of thefts.

Furthermore, the preposed amendments would require reconsideration by:the licensee of what constitutes an MC&A detection, with increased attention paid to process and production anomalies that might b's due to SSNM loss, and less emphasis on pericdic physical inventories.

Thus the licensees would have to submit revised FNMC plans to comply with the propose.d amendments, as well as reconsider the parts of their Safeguards Con-

~

tingency Plans dealing with MC&A events.

Rather than duplicate the same words in both plans, either plan could incorporate by refereace appropriate pages of the other.

2.

Q.

What quality of loss resolution must the licensee achieve?

A.

The combined quality of the material control test and loss roselution decisions shall permit alarms remaining unresolved after completian of the licensee's investigative activities to be good indicators of theft or diversion.

This will be judged in two ways:

(1) During review of a licenseo's planned detection an:t alarm resolution capabilities, attentien will be directed to the abi?ity to resolve false abrupt loss alarms.

For the alarm resolution capat'il-ity to be acceptable, it must appear able to correctly identify all errors due to leaks, process upsets, or human itistakes that are large i

enough to cause an alarsn. With resp ct to other false alarms, in l

particular those alarms that are expected to_ occur because of the l

statistical nature of the processes and measurement systems, the alarm resolution capability need not be 100 percent effective.

l However, for it to be acceptable, it must be effective enough to j

satisfactorily limit the statistically expected rate of unresoltable false abrupt loss alarms.

(The expected rate can be thought of as a weighted average of all possible rates, where the weights are the 39 l

I e----

-m- -,., =

~-,.-,-.,e.

w--._,-,._

.,.w_m--,,,m_,i.

..m

-n

..-,.-w

,.,e...wr-y

,.v.r--

ywmy.

I<

a

'l likelihoods of-occurrence of those rates.) A satisfactory limit is

/-

an expected rete of unresolvable large abrupt loss false alarms less a

than one per 10 years per plant.

A large false alarm is one whose loss estimate exceeds 5 FKG.

Because-the licensee must be able to resolve all alarms other than those of a statistical nature, calcu-lation of the expected rate of unresolvable large abrupt loss false "L-alarms reeds only consider false alarms of a statistical nature.

t

'[

(2) After the phase-in period is over and all elements of the licensee's alarm resolution commitments have been implemented, the 4

'l alarm resolution performance would be judged good when:

(a) there have been no situations over the past year in which a large abrupt 3

loss (alarm is found in subsequent audits or investigations to have beer) innocently caused but was not so resolved within the licensee's

/

time commitments; and (b) there are no unresolved large abrupt loss alarms remaining after the quarterly inventories and annual audit have been completed.

S 74.S7(f) Alleged Thefts 3.

Q.

What are alleged thefts?

4 Alarms that originate external to the MC&A system.

Among these are

.,. ' u any statements communicated directly or indirectly to facility staff, NRC, FBI, police, etc., that diversion of SSNM under license has

]

occurred.

The statements may or may not include details such as from which plant material was allegedly taken, which item was taken, or submittal of an alleged sample of the material.

This covers threats allegedly from within as well as from outside the facility.

An external alarm may include other indications such as an external assault that penetrated an MAA or the discovery that an MAA door had been opened from the inside.

l k

I 40

' CHAPTER 4.0 QUALITY ASSURANCE 4.1 Management Structure Requirement:

The rule requires that a licensee:

(1) Establish a management structure that includes clearly defined a,

responsibility for the planning, coordination, and administration of MC&A functions; independence of MC&A functions from production responsibilities; and separation of functions such that the activities of one indivfdual or organizational unit serve as controls over and checks of the activities of others.

(2) Provide for the adequate review and use of those MC&A procedures that are identified in an approved plan as being critical to the effectiveness of the described system (874.59(b)). -

Intent and Scope: The intent of this section is to require licensees to implement a management structure that permits effece.ive functioning of the MC&A system.

Documentation, review, and approval of the procedures and the assign-ment of the key functions to specific positions eliminates ambiguities about what is to be done by whom.. The management structure is meant to separate key MC&A functions from each other in order to provide cross-checks that increase MC&A system reliability and counter defeat of the system through neglect, deceit, or falsification, and to free MC&A management from conflicts of interest with other major responsibilities such as production.

Plan / Annex content:

The FNMC Plan contains the following affirmations and detailed commitments.

Supporting information, as appropriate, is included in the Annex.

Section 4.1 of the Plan includes the following affirmations:

o The overall responsibility for MC&A system management is assigned'to a position that provides a separation from production responsibilities or any other responsibi'lities that may give rise to a conflict of interest.

o The responsibility for each MC&A function is assigned to a specific position in the organization in a way that key functions are cross-checked.

o The management structure and the critical MC&A policies and procedures are documented and provisions are made for review and approval prior to implementation.

3 4.1.1 Organization a

Describe the organization for MC&A including the functional responsibilities for each organizational unit and show how the MC&A organization is independent of responsibilities that have potentially conflicting goals.

41

f 4.1.2 Policies and Procedures i

Describe the policies, procedures, duties, responsibilities, and authorities associated with each position involved with an MC&A function in sufficient detail to demonstrate the cross-checks built into the MC&A system.

In the Plan provide a listing (by title and procedure number) of the procedures deemed to be critical to the effectiveness of the MC&A system.

Acceptance criteria:

The assessment of the adequacy of the information supplied i

above will be based on the following criteria or equivalent:

o The MC&A organization is separate from the SSNM production organiza-tion and any other organization that generates source data, if practical.

Otherwise controls are in place to ensure that process operations, measurements, measurement controls, accounting functions, and any other activities that influence MC&A system performance are carried out both in the letter and spirit of approved procedures; and that decisions impacting MC&A, that can conflict with production or other plant functions, are under the oversight of an independent authority.

An effective management structure will exhibit at least the following attributes:

The overall planning, coordination, and administration of the MC&A functions for SSNM is vested in a single individual at an organizational level that is sufficient to ensure independence of action and objectivity of decisions.

The individual must be in a position to recommend and initiate timely action for the control and accounting of SSNM including delaying production, if necessary, and must not be enmeshed in a hierarchical framework that could inhibit or compromise independent action.

The assignment of MC&A functions in the licensee organization provides a separation of functions so that the activities of one individual or organizational unit serve as controls over and checks of the activities of other individuals or organizational units.

The critical MC&A runctions are documented in written procedures.

The procedures and any revision thereto are reviewed and approved by appropriate management personnel prior to implementation.

The individual with overall responsibility for the MC&A system will approve all procedures generated in the MC&A organization and be cognizant of all other procedures affecting MC&A.

Critical MC&A procedures should, as a minimum, address the establishment of basic MC&A system policies, detection of the loss of a goal quantity, performance of the physical inventory, determination of inventory and shipper-receiver differences, establishment of measurement control policies, and determination of measurement and non-measurement errors critical to MC&A.

42

The' responsibilities and authorities for each position assigned an i

o SSNM control and accounting function are clearly defined in position descriptions that are accessible to all affected personnel and to the i

NRC upon request.

o The individuals responsible for each MC&A function have sufficient authority to perform the function in the prescribed manner.

o The overall management responsibility for the MC&A system is at a level at least comparable to the organization having responsibility for production or storage of SSNM, or a direct line of communication is provided to management level which has the authority to implement measures essential to effective MC&A.

The individuals who generate source data, such as those performing o

measurements, preparing transfer forms, or preparing analytical reports do not perform any accounting or record control functions unless cross checks of the work are performed to prevent falsification.

Examples of appropriate checks and balances are:

1 Review of measurement data and calculations by another individual, I

Maintenance of a duplicate copy of all source data and transfer forms under controls separate from the accounting function, Performance of independent audits, and Separation of computer program maintenance from the program user function.

i o

No individual has the sole authority to recheck, evaluate, or audit information for which that individual is responsible.

o No individual may have responsibility and control of both an MC&A and physical protection function unless independent crosschecks are in place to preclude defeat of the overall safeguards system. As a l

minimum the crosscheck must include countersigning by one other i

person of any SSNM transfer within an MAA and countersigning by two individuals for SSNM transfers out of an MAA.

I o

The management structure provides for assignment of a responsibility for SSNM undergoing processing and in storage to a single individual or group.

The duties of the individual (s) include but are not limited to:

l

[

Maintaining appropriate inventory control over SSNM in their assigned area; Authorizing and recording all movements of SSNM into and out of their assigned area; i

l 43

t Maintaining appropriate local MC&A records or assuring that other records, such as production records, contain necessary MC&A information; Participating in physical inventories as required; Assisting in internal or external alarm resolution activities as required; Assuring that, when SSNM is processed in bulk form, only authorized persons have hands-on access to the material; and Notifying proper authorities of irregularities in material and MC&A data handling.

Questions and Answers 1.

Q.

At what level of understanding should MC&A procedures be written?

A.

Procedures such as those used in MC&A should be written so that any person performing the work should be able to understand the content and meaning of the actions to be taken, the warning statements, and all other messages.

Generally, a twelfth grade level of vocabulary should be used in writing procedures.

This restriction does not apply to the technical terminology included in the procedures, although these terms must then be included in any specific training that involved personnel are required to take.

2.

Q.

What is a systematic task analysis, and how will it help to define the content of procedures?

A.

A task analysis breaks down and evaluates in a systematic manner a human function in terms of the abilities, skills, knowledge, and attitudes required for performance of the function.

These analyses may be performed to differing degrees of depth, depending on the information requirement and its specific application.

A task analysis will assist the procedure developer by systematically outlining the steps to be performed to complete a task, the personnel needed to complete each step, and the requirements of each person.

Procedures usually do not require an in-depth task analysis, but consideration of the needs of personnel will usually make procedures better.

3.

Q.

Why should procedures be reviewed and verified before being accepted for regular usuage?

A.

Procedures that contain inaccurate or incomplete information are misleading and can be detrimental to MC&A information error rates.

Review by personnel who have previously performed similar tasks or are familiar with the process to be performed will frequently discover omissions of required information, misleading information, or mistakes.

44

Verification of the procedures involves field testing by the personnel who will be using the procedures to determine problems not found during the review phase.

4.2 Personnel Qualification and Training Requirement:

The rule requires that each licensee ensure that key per-sonnel, who work in positions involving tasks where mistakes could directly degrade the safeguards ~ capabilities of the MC&A system, are trained to maintain a high level of safeguards awareness and are qualified to perform their jobs (74.59(c)).

Intent and Scope:

The intent of this section is to ensure that the effectiveness of the MC&A system is maintained by the qualification and training of key personnel.

A training and qualification program can help ensure that these individuals are adequately prepared to perform their functions correctly with a minimum of errors.

The program should be structured to define job requirements, to establish minimum qualifications for candidatas, to train and qualify the candidates, and to define requalification criteria.

Plan / Annex Content:

The FNMC Plan contains the following affirmations and detailed commitments.

Supporting information, as appropriate, is included in the Annex.

Section 4.2 of the Plan includes the following affirmations:

o The duties, responsibilities, essential functions, and qualifications of key MC&A positions, i.e., those involving tasks where mistakes could directly degrade the safeguards capabilities of the MC&A system, are defined in written job descriptions.

The individuals designated for key positions do not assume the posi-o tions until they have demonstrated their competence through tests that will determine whether or not the individual satisfies the pre-established qualification criteria for the positions.

o A training and qualification program for key MC&A positions and a method of demonstrating continued competency of personnel has been implemented and will be maintained. The program is periodically updated to reflect changes in job requirements.

I l

o The descriptions of the key job functions, the design of the training and qualification program, and the method of confirming qualifications of personnel are subject to the formal approval of the MC&A manager.

4.2.1 Training Program Describe the fundamentals of the training program that will be implemented to ensure the competency of key MC&A personnel. The description should identify the training program structure, source of instructional material, and general training objectives.

In the Annex, provide an example of a typical training program for one typical position and a tabulation of the key MC&A positions.

45

4.2.2 Qualification Program Describe the qualification program including generic qualification criteria for the. key MC&A positions and the criteria for assessing the need for requalification.

In the Annex, provide an example of the complete qualification criteria for a key MC&A position.

Acceptance Criteria:

The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:

o The list of key positions or functions includes all those for which errors or faulty performance could directly degrade SSNM control and accounting.

These include MC&A management positions and individual contributor positions having responsibility for key measurements, data analysis, preparation of accountability source documents, and collecting or recording of other data having a direct impact on loss detection, alarm response, and quality assurance functions.

o The qualification criteria for the key positions are consistent with the position descriptions and focus on minimum levels of education and experience, knowledge of the job content and its purposes, types and levels of skills or proficiencies, and understanding of the safeguards role and its importance.

The criteria are defined in terms of measurable performance goals whenever possible.

o The training program emphasizes the job purpose and scope; relation-ship to other positions, especially the MC&A positions; the role or significance with respect to MC&A; technical knowledge; understanding of duties, responsibilities and procedures; and skill development.

o The training plans provide for a reasonable balance of theory and practice, or oral and written instruction versus demonstration and learning-by-doing, the use of on-job training for positions that are primarily operational or clerical, and individualized instruction based on performance goals whenever feasible.

o Tests for positions requiring measurements, calculations, or recording of data and information will include demonstration of correct and accurate job performance. When operating procedures or manipulative skills are required, the tests will include hands-on demonstrations on competence.

o The continuing qualification of key personnel will be verified on an ongoing basis or at least every two years.

o The training program provides for training of personnel already l

experienced and functioning in MC&A positions at the time of Plan implementation when competency tests indicate that additional training is called for.

The criterion will be whether or not the individual can function at the level of proficiency called for in the qualifica-tion criteria.

46 l

_4.3 Measurements Requirement:

The rule requires that a licensee establish and maintain a system of measurements sufficient to:

(1) Substantiate the plutonium element and uranium element and isotope content of all SSNM received, produced, transferred between areas of custodial responsibility, on inventory, or shipped, discarded, or otherwise removed from inventory; (2) Provide the necessary data for the performance of the material control tests required by $74.53(b); and (3) Permit an estimation of the standard deviations associated with each measured quantity (74.59(d)).

Intent and Scope:

The intent of these requirements is that all SSNM values

?

used for MC&A purposes be based on measurements and the uncertainties associated with the measured values be quantifiable.

Plan / Annex Content:

The FNMC Plan contains the following affirmations and detailed commitments.

Supporting information, as appropriate is included 1

in the Annex.

}

Section 4.3 of the Plan includes the following affirmations:

o Measurement systems are in place to substantiate the element and isotope content, as appropriate, of all SSNM received, produced, transferred between areas of custodial responsibility, on inventory, or shipped, discarded, or otherwise removed from inventory.

o SSNM quantities transferred into and out of each unit process are based on measurements for mass, volume, element, and isotope, as necessary, to accommodate material loss detection tests.

o Factors employed in process models are based on measurements and are updated at least annually.

4.3.1 Measurement Points Identify each point in the process where measurements are made for special nuclear material control and accounting purposes.

References to process flow diagrams included in the Annex are acceptable.

4.3.2 Materials and Measurements Characterize the materials and measurements for each measurement point.

One suitable means of presentation would be a coded chart showing the types of materials and the components of measurement involved at each measurement point (i.e. weight, volume, sampling, analytical assay, or nondestructive assay).

47

.M__.._.__

_m._

In the Annex provide a detailed description of the measurement systems that will be employed for MC&A purposes.

The description should include:

General characteristics (equipment, range of application'and sensitivity);

Method description, and Estimated measurement uncertainties (random and fixed).

Acceptance Criteria.

The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:

o All measurements points have been identified and as a minimum include the following:

Facility receipts; Transfers oetween areas of custodial responsibility; Points where SSNM is produced; Unit process boundaries; Facility shipments including product, scrap, and waste; Effluent discharge points; and Significant sidestreams.

o The material types to be measured at each measurement point and the measurement system involved are described in the Plan.

A " measurement system" should include:

Sampling method (if appropriate),

Mass or volume (if appropriate),

Chemical assay, or Nondestructive assay, Isotopic analyses (if appropriate),

The descriptions of the components of each measurement system reflected in the Annex should include:

Equipment, Synopsis of technique, Range of application, 48

--~ry.-.------,,,,-,p

-.,r,--ww

_w-,,.-----,-,

O Sensitivity, Precautions, and Random / fixed error estimates.

The use of. factors is limited to those situations where timely mea-o surements are impractical.

A commitment should be included to the effect that factors will be based on measurements, monitored, and updated when appropriate statistical tests indicate the need for updating.

In the Annex, the licensee should provide the justification for employing factors in lieu of measurements.

Appropriate measurements for material control tests will depend upon o

the following considerations:

Availability of substitute materials, Predictability of material composition, and Material accessibility These considerations influence whether a test as simple as a weight compar-ison will suffice as a means of loss detection or a measurement for element and perhaps isotope is necessary.

4.4 Measurement Control Requirements: The rule requires that a licensee assure that the quality of SSNM measurement systems and material processing practices is continually con-trolled to a level of effectiveness sufficient to satisfy the capabilities required for detection, response, and accounting.

To achieve this objective the license should:

l (1) Perform engineering analyses and evaluations of the design installa-tion, preoperational tests, calibration and operation of all measure-ment systems to be used for MC&A purposes.

(2) Perform process and engineering tests using well characterized materials to establish or to verify the applicability of existing procedures for mixing and sampling SSNM and maintaining sample integrity during transport and storage.

(3) Generate current data on the performance of measurement processes, including, as appropriate, values for bias corrections, uncertainties on calibration factors, and random error standard deviations.

The program shall include:

(i) The ongoing use of standards for calibration and control of all applicable measurement systems.

Calibrations shall be repeated whenever any significant change occurs in a measurement system 49

o or when program data, generated by tests performed at a predeter-mined frequency, indicate a need for recalibration. Calibrations and tests shall be based on standards with traceability to I

a national standard or nationally accepted measurement system.

(ii) A system of control measurements to provide current data for the determination of random errors that are significant contributors to the measurement uncertainties associated with shipper / receiver differences, inventory differences, and process. differences.

(4) Utilize the data generated during the current material balance period for the estimation of the standard error of the inventory difference (SEID) and the standard deviations associated with the process differences.

Measurement error data collected and used during imme-diately preceding material balance periods may be combined with cur-rent data provided that the measurement systems are in statistical control, and the data are utilized in the determination of current period SSNM values.

(5) Evaluate all program data and information to assure that measurement performance is so controlled that the SEID estimator is less than 0.1 percent of active inventory for SSNM processing facilities.

(6) Apply bias corrections by an appropriate procedure whereby:

(i) Bias corrections are applied to individual items whenever the bias estimate exceeds both twice the estimated standard devia-tion of the estimator, 50 grams of SSNM, and the rounding error of affected items.

(ii) The impact of all biases that are not applied as corrections to individual items, are applied as a correction to the inventory difference.

l (iii)

If, for like-material types, shipper / receiver differences accum-ulated over six month period exceed the larger of one FKG or 0.1 percent of the total amount received, then the licensee will investigate and take corrective action, as appropriate, to identify and reduce associated measurement biases.

(7) Establish and maintain a statistical control system designed to monitor the quality of each type of program measurement.

Control limits shall be established to be equivalent to levels of signif-icance of 0.05 and 0.001.

Control data exceeding the 0.05 limits shall be investigated and corrective action taken in a timely manner.

Whenever data exceed the 0.001 control limit, the measurement system shall not be used for MC&A purposes until it has been brought into control at the 0.05 level.

Intent and Scope:

The intent of these requirements is that the licensee continually control the quality of measurement systems employed for MC&A to a l

level sufficient to satisfy the capabilities required for loss detection, l

response and accounting.

The goals of the quality control program for SSNM 50 l

^

s measurements are to maintain the SEID within the limits specified in

$74.59(e)(5) and minimize the measurement error contribution to the standard deviations associated with the material control tests required by 974.53(b).

1 Plan / Annex Content:

The FNMC Plan contains the following affirmations and detailed commitments.

Supporting information, as appropriate, is included in the Annex.

Section 4.4 of the Plan includes the following affirmations:

Engineering analyses and evaluations are performed on the design, o

installation, preoperational testing, calibration, and operation of all measurements systems to be used for MC&A purposes.

Process and engineering tests are performed, using well characterized o

materials, to verify the applicability of mixing and sampling proce-dures,for SSNM and assure sample validity during transport and storage.

o Current data is generated during the inventory period for establish-ing bias correction values, uncertainties on calibration factors and random error variances.

o Current inventory period data is utilized for the estimation of the SEID and the standard deviations associated with the process differences.

Data generated in immediately preceding material balance periods may be combined with current data when it can be demonstrated that the data is from the same distribution, and the combined data are utilized to establish current period SSNM values, o

Measurement system performance is controlled such that the total SEID will not exceed 0.1 percent of the active inventory.

o Bias corrections are applied to individual items whenever a bias estimate exceeds twice the estimated standard deviation of the esti-mator, 50 grams of SSNM, and the rounding error of affected items.

Otherwise the impact of uncorrected biases is applied as a correction the inventory difference.

Uncorrected biases are not entered in the accounting records.

o A statistical control system is maintained to ensure that measurements employed for MC&A purposes are obtained from measurement systems that 1

are in a state of statistical control.

Control limits are established l

at the 0.05 and 0.001 levels of significance.

l o

Bias corrections associated with material control tests are either applied prior to assessing the significance of the test results or are available for resolution.

o When a statistically significant change occurs in the estimated standard deviation of a material control test statistic, the alarm threshold of the test is adjusted as necessary to ensure that a goal quantity loss of SSNM will be detected with a probability at least as high as that required in the regulations (S 74.53(b)(2)).

Additionally 51 4

(

f

the change will be investigated to an extent sufficient to determine the cause, o

When a process modification occurs, sufficient data are generated to provide a reliable estimate of the standard deviation applicable to the material control test.

o The magnitude of the uncertainties associated with process variabil-ities is determined and applied in the overall uncertainty (standard deviation) utilized in establishing alarm thresholds.

o The cumulative shipper-receiver differences for each like material type are routinely monitored, and when they are determined to be statistically significant and exceed the larger of one FKG or 0.1 percent of the quantity shipped, corrective action is taken to identify and correct measurement biases, o

Contractors who perform MC&A measurement services will implement and maintain a control program for measurement errors and for human errors.

The program will be of such depth and intensity as not to degrade the MC&A system.

o The estimated standard deviations of the material control test statistics are maintained at or below a level sufficient to achieve the loss detection capabilities established pursuant to S 74.53(b) without incurring an excessive rate of false alarms.

Sufficient standards measurements and replicate analyses of process o

materials are performed to permit a determination of the standard deviation associated with each measured quantity.

4.4.1 Measurement Control for Detection / Response Measurements Oc;cribc t.b.c measurement control program applicable to those measurement systems utilized for detection and response.

The descriptien should include:

~

l The general types of standards that will be utilized; j

The procedure for certifying the values assigned to the standards; The minimum number and analysis frequency or schedule of standard and process material measurements that will be used to establish the l

magnitude of biases, calibration and control measurement errors, and i

variances of random errors; 1

l The means of monitoring the magnitude of biases and variances; The criteria for determining the need for recalibration; The means of establishing mixing and sampling errors; The tests and criteria for judging the acceptability of data pooling; 52

~

~.

+-

The measures to ensure that bias estimates and variances reflect the actual operating conditions and process materials; The tests that will be employed to identify outliers; and The tests for assessing the significance of bias estimates.

In the Annex provide:

4 A listing of the standards to be used with each measurement system and, for in-house standards, how they will be prepared;

'A brief description of how assigned values of standards are determined; A brief description of the calibration procedures for each measurement system; and A listing of expected or estimated variances associated with each measurement system.

4.4.2 Measurement Control for Inventory and Shipper-Receiver Measurements Describe the measurement control program applicable to those measurement systems utilized for inventory and shipper-receiver purposes.

(Note:

References may be made to Section 4.4.1, as appropriate.)

4.4.3 Standard Error of the Inventory Difference Estimator Provide an explanation of~the statistical basis for determining the SEID estimator.

The description should include the means of monitoring the overall measurement system uncertainties to ensure that the SEID does not exceed the applicable limit defined in S 74.59(e)(5).

4 1

In the Annex, provide the statistical model and equations or literature reference with an example calculation of a typical material balance.

4.4.4 Cumulative Shipper-Receiver Differences Describe the program for monitoring cumulative shipper-receiver differences (CUMSRD).

The description should include:

The means of determining the uncertainty against which the significance of the difference will be assessed; and The course of action with respect to review of measurement systems, shipper notification, and treatment with respect to impact on ID (i.e., how the is. pact of the CUMSRD will be accounted for in the evaluation of ID significance).

Acceptance Criteria; The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:

53

L-

g o.

Proposed mixing and sampling studies appear to be adequate for assessing the capabilities of a sampling technique to produce representative samples.

Considerations applicable to sampling techniques are:

Sample size should be a function of material homogeneity, number 4

of containers sampled (if compositing), physical form of the material, and the particular sampling device used.

Sampling of solutions containing solids should be avoided whenever possible unless it can be shown that representative sampling is possible or the solids have no SSNM content and do not contribute any significant error to the bulk volume or bulk weight measurement.

Subsampling requirements should also be addressed in the sampling evaluations.

Grab sampling should generally be avoided unless it can be shown that the involved materials are sufficiently homogeneous and stable.

Sample integrity during storage can be demonstrated by a comparison of measurement results taken immediately with results on the same samples following an extended period of storage.

o Calibration and control standards have assigned or certified values that are traceable through an unbroken chain of comparisons, including the overall uncertainty in each, to a national standard or physical constant.

o Control standards should be representative of the material being measured with respect to matrix and SSNM concentration unless it can be demonstrated that the non representative aspects have a negligible impact in that measurement results are unbiased.

o Control measures that will ensure or confirm the continuing validity j

of standards' assigned values are indicated.

Examples of the types of controls that would be appropriate are:

3 Storage of metal standard weights in a non-corrosive atmosphere; Tamper-safing of NDA standards immediately after makeup; Storage of solution standards in more than one container when usage will be over an extended time period (e.g. > one month);

l Storage of standards with an affinity for moisture in a l

desiccator; and Remeasurement of the standard to confirm that its value has not changed.

l 1

54 1

1

0 i

o The estimated standard deviations of the material control test statistics are derived from the monitoring program data that are collected in such a manner that they represent the current performance of the process and measurement systems.

Values obtained when the process is operating in an abnormal manner or when a significant process upset or anomaly has occurred will not be included in the data used to estimate the standard deviation.

However, data are discarded only on the basis of pre-established objective criteria.

Data may not be pooled over periods of time when significant process or measurement system changes have occurred.

When data pooling is appropriate, statistical tests will be applied to demonstrate that the means and variances are from the same distribution at the 0.05 level of significance.

The data will be tested for randomness (see Jaech, Section 2.9.2) and normality when tests, such as the F-test on variances, are distribution dependent.

The quality control program for monitoring detection system effec-tiveness should have as its key goal assurance that the estimates of standard deviations used in establishing action thresholds that comply with the detection probability criteria neither underestimate nor overestimate the true standard deviations of the tests.

It is most important to ensure that the estimate of the mean and standard devia-tion for each material control test reflects the actual operating conditions and error sources. Generally, this is done by calculating them from sets of material control test data, but it is very impor-tant to avoid serious inflation of the variability of the data that would result in the event of actual losses of SSNM or out-of-control process variables.

Therefore, both the measurement component and the overall standard deviation should be monitored for diagnostic purposes.

Failure to consider all sources of noncorrectable variation, including normal process variations, would result in an unrealistically small estimate.

Use of too small an estimate could result in an action threshold being set too high to provide the required loss detection probability.

o The standard deviation of each material control test statistic is periodically checked by comparing an estimate of the current standard deviation with the prior value used in setting the alarm threshold.

The estimate of the current standard deviation will be based on at least the 10 most recent values of a test statistic whereas the reference value will be based on at least 20 values.

The alarm threshold for a material control test is adjusted when a o

statistically significant change of the standard deviation is indicated.

The change of the standard deviation is considered significant when the null hypothesis for an F test is rejected at the 4

0.05 level.

i o

Calibration procedures are adequate to ensure that the measurement systems will generate reliable results.

Considerations in this regard are:

The number of runs to establish the initial calibration are sufficient to establish a reproducible calibration.

55 i

-r ncr.,,

n,--

n

,nn,,r.,

.c-

The calibration range spans the anticipated range of process values and the standards are adequately spread over the range.

For point calibrations utilizing a single calibration standard, the unknowns should be within i 10 percent of the assigned value of the involved standard.

o Standard measurements are spread out across the material balance period with the expressed objectives of monitoring calibrations for trends or sudden shifts and providing the necessary data for bias estimates.

o Recalibrations are performed when a need is identified.

Recalibrations would be deemed necessary when:

A trend, shift, or out-of-control condition at the 0.001 level is detected; A bias estimate exceeds the 95 percent confidence level; A change in process materials occurs that extends the needed range of calibration or renders the calibration / control standards nonrepresentative; or A change or modification is made to a measurement system that has the potential to affect measurement results.

o All measurement systems affecting a material control test, ID estimate, or shipper-receiver comparison are monitored for bias except as noted below.

The intensity of the monitoring program is proportional to the significance of the measurement system for the test involved.

The key measurement systems, i.e., those that contribute greater than 90 percent of the estimated standard deviation due to measurements in the material control test and shipper receiver uncertainties and at least 90 percent of the measurement uncertainty associated with the 10 estimator, are tested for bias at least monthly except where:

The measurement system has been demonstrated to be quite stable and the results predictable, The bias estimate of a measurement system utilized solely for material control test affects inputs and outputs equally and therefore the effects of bias cancel, The bias estimate for a measurement system utilized solely for material control test is shown to be constant and does not impact the material control test, or The system is defined as bias-free.

Where the above conditions exist, the bias tests can be extended to three months or exempted altogether if the system qualifies as bias-free.

56

The bias tests will be made using the mean of at least eight standard measurements.

Bias corrections will be made to ids if the bias exceeds twice the standard deviation of its estimator, 50 grams of HEU, U-235, U-233, or Pu and the rounding error of affected items.

All other measurement systems shall be monitored for bias and tested every three months except for those measurement systems involved with movement of material across the MAA boundary and no cross-check measurement is performed.

Such systems shall also be tested monthly.

Measurement systems are considered to be " bias-free" if a standard is run for each unknown or set of unknowns measured at the same time, or standards are measured before or after a group of process samples and the standard measurement response and assigned value, rather than any previous calibration information, are used in determining the value of the unknown (s).

The measurement control program produces data that are representative o

of actual operating conditions and all errors that impact ID.

The uncertainty estimates that contribute more than 90 percent to the standard error of the ID estimator will be based on a minimum of 15 standard or replicate process material measurements, as appropriate.

o The licensee has demonstrated that the standard error of the ID estimator meets the requirement of S 74.59(e)(5).

I o

Error variances associated with calibrations will be determined and applied in accordance with the following:

For point calibrations, where a standard is measured with each unknown, the uncertainty associated with the standard measurement is treated as a random error, while the uncertainty associated with the standard's assigned value is treated as a fixed error.

For point calibrations, where standards are run before and after l'

a group of process samples and the average measured value of the standards is utilized in the element and/or isotope determination, the uncertainty associated with the standard's average measured value is treated as a fixed error for the group of process samples.

For line or curve calibrations, the uncertainty associated with the calibration parameters is treated as a fixed error.

o Correlation between terms are taken into account in the determination of fixed errors whenever bias corrections are made to calibrations.

o Data from intercomparison programs and from intra-laboratory comparisons is not acceptable for determining bias.

o CUMSRDs on like kinds of material will be monitored for trends that may be indicative of a bias in the shipper's or receiver's measurements.

For the purpose of this requirement, "like kinds of material" means 57

l major categories having the same chemical and physical form (e.g., UFs.

Pu0 powder, UC coated particles, etc.).

2 The standard deviation applicable to a shipper-receiver difference will take into account all measurement variances and covarience.

effects.

The CUMSRD will be tested at the 0.05 significance level.

If a significant difference is determined to exist and it exceeds one percent of the amount received, the licensee will conduct an investi-gation involving the shipper and a referee as appropriate.

Appropriate statistical methodology for analyzing CUMSRDs can be found in Rose and Scholz (1983).

o The methods of monitoring and controlling measurement performance are adequate to ensure the reliability of the measurement systems used for MC&A purposes.

Examples of acceptable methods include control charts and automated data analysis performed on an ongoing basis.

Considerations to be taken into account include:

The proposed method is capable of providing timely information on the control status of measurement systems including the possible presence of unacceptable trends.

The control limits are established at the 0.05 and 0.001 levels of significance or are more conservative.

Response actions include commitments to (1) collect additional data when a single point exceeds the 0.05 limit, (2) notify the individual responsible for the measurement control program when two consecutive data points fall between the 0.05 and 0.001 limits, (3) initiate an investigation to identify an assignable cause when a data point exceeds the 0.001 out-of-control limit and (4) remove out-of-control measurement systems from service until control is restablished at the 0.05 control limit.

4.5 Physical Inventory Requirements:

The rule requires that a licensee should:

i (1) Except as required by Part 75 of this Chapter, perform a physical inventory at least every six calendar months and within 45 days from the start of the ending inventory:

Calculate the inventory difference, estimate the standard error of the inventory difference and investigate and report any dif-ference that exceeds three times the standard error and 200 grams of plutonium or uranium-233 or 300 grams of uranium-235, and If required to perform an investigation pursuant to paragraph (i) of this section, evaluate the significance of the inventory dif-ference relative to expected performance as determined from an analysis of an appropriate sequence of historical inventory differences.

1 I

58 l

i

- _.__ _.___ _.. _ ______..,____...____ ~,_ _....--_

_,.. _ _, _ _ _ _.,. _.,- - - -. -. _ -.. -, _. - _ ~ - -

Investigate and report to the appropriate NRC Region Office any

' difference that exceeds its limits of expectation; and Perform a reinventory if so directed by NRC; and Reconcile and adjust the plant and subsidiary book inventories to the results of the physical inventory.

(2) Implement policies and procedures designed to ensure the quality of physical inventories.

Appropriate practices and procedures shall include:

Development of procedures for tamper-safing of containers or vaults containing SSNM not in process that include adequate controls to assure the validity of assigned SSNM values; Records of the quantities of SSNM added to and removed from process; Requirements for signed documentation of all SSNM transfer between areas with different custodial responsibility that reflects all quantities of SSNM transferred:

Means for control of and accounting for internal transfer documents; Cutoff procedures for transfers and processing so that all quantities are inventoried and none are inventoried more than once; Cutoff procedures for records and reports so that all transfers for the inventory and material balance interval and no others are included in the records; Inventory procedures for sealed sources and containers or vaults containing SSNM that assure reliable identification and quantification of contained SSNM; Inventory procedures for in process SSNM that provide for measurement of quantities not previously measured for element and isotope, as appropriate, and remeasurement of material previously measured but whose validity has not been assured by tamper-safing; and l

Written instructions for conducting physical inventories that detail assignments, responsibilities, preparation, and performance of inventory ($ 74.59(f)).

Intent and Scope:

Periodic physical inventories enable a licensee to adjust accounts to accurately reflect the status of the SSNM inventory within a facility.

Comparisons of the book inventory to the physical inventory, i.e.,

the inventory difference, also serve as a quality control check on the perform-ance of the material control tests employed for prompt loss detection.

The subdivision of a facility into multiple process units and the performance of 59

material control tests will enhance the resolution of significant ids through better loss localization capability.

Additionally, material control test results will be useful in pinpointing the time when an anomaly likely occurred.

Plan / Annex Content:

The FNMC Plan contains the following affirmations and detailed commitments.

Supporting information, as appropriate, is included in the Annex.

Section 4.5 of the Plan includes the following affirmations:

o A measured physical inventory is performed every six calendar months and within 45 days of the start of the ending inventory:

An ID and associated standard error are calculated; Any ID greater than 300 grams of uranium-235 (200 grams of plutonium or uranium-233) and three times the standard SEID is investigated and reported; All investigations include an evaluation of the significance of the ID relative to expected performance as determined from an analysis of an appropriate sequence of historical inventory differences.

Any difference that exceeds its limits of expectation is investi-gated and reported to the appropriate NRC Regional Office.

Actions in response to excessive ids will be as described in Section 4.5.3.

The material accounting records are reconciled and adjusted to the results of the physical inventory.

4.5.1 Facility Preparation Describe the preparation of the facility for physical inventory.

The description should include:

The basic approach to facility preparation (e.g. draindown, cleanout, etc.);

The degree to which any inventory prelisting will be utilized, and the means of verifying the prelisted items; The means of controlling inventory listing forms and tags; The cutoff procedures for SSNM processing, transfers, and records adjustments to ensure an accurate recording of material transactions and inventory listing; The organization of the inventory teams including the cross-checks to prevent falsification and minimize mistakes; and 60

The criteria for tamper-safing containers or vaults whose SSNM content will be accepted for inventory.

4.5.2 Inventory Performance Describe how physical inventories are conducted.

The description should address the following:

The technique to assure that all SSNM is inventoried and none is counted more than once; The measurements that will be performed specifically for inventory purposes; The use of prior measurement data, factors, and composite data; The degree to which holdup will be cleaned out and the measurement of residual holdup; and The use of post-inventory inspection techniques (if employed).

In the Annex provide an example of a typical inventory listing by material type and quantity.

4.5.3 Inventory Reconciliation Describe the reconciliation procedure including:

The method of calculating the SEID, The criteria for investigation of ids that exceed three times the

SEID, The method of establishing the limits of expectation against which current ID will be evaluated, The criteria for establishing the depth of investigation for excessive ids and the types of investigative actions, The handling of prior period adjustments and uncorrected biases, The method of adjusting the book records to the results of the physical inventory, and The means of establishing the active inventory including the source records that will be used in the computation.

Acceptance Criteria.

The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:

o The physical inventory procedures provide for verifying the location and identity of all quantities of SSNM.

The SSNM quantity of each component in the material balance is based on measurements.

By-difference accounting is not acceptable.

61

E Use of inventory cutoff and cutoff verification procedures, tag o.

procedures, and post-inventory inspections or equally effective measures are used to ensure all quantities are accounted for and not counted more than once.

Sufficient information is provided in the plan to show that the inventory process is organized and coordinated to ensure the use of uniform and consistent procedures for checking and recording the SSNM status.

The SSNM content of groups of like items can be determined by averaging o

typical contents as determined by measurements of representative item 4

samples of that material at the time of the inventory if the licensee

-demonstrates that any additional uncertainty resulting from this averaging method is included in the SEID estimator.

i Adjustments to reconcile the book inventory to the physical inventory will o

be in accordance with commonly accepted accounting practices, and the i

adjustments will be traceable and auditable, o

The effect of prior period adjustments will be taken into account before the significance of the current period ID is assessed.

Prior period adjustments could be the result of:

Remeasurement of scrap generated and measured in a prior period but remeasured by a higher quality method in the current period resulting in the assignment of a different value; Recovery of scrap generated in a prior period where the process-ing to a better measurable form results in a " gain" or " loss" of material; or i

Resolution of an outstanding shipper-receiver difference from a prior period.

The appropriate procedure for dealing with these discrepancies is, for purposes of ID evaluation, to modify the ID quantity by adding or subtracting a quantity of SSNM equivalent to the adjustment prior to assessing the significance of the current period ID.

However, as with the uncorrected bias case, the adjustment to the book records must include the prior period adjustments in order to bring the accounting records into balance.

With respect to the processing of scrap generated in a prior period, o

the assigned value must be based on dissolver solution and dissolver residue measurements and not on the product of the scrap plant.

This is because losses may occur during the separation and purification stage which should, in fact, be attributable to current period processing.

o All SSNM values on the physical inventory listing must be based on measurements.

Prior measurement values may be accepted for inventory provided they were determined on a measurement system subject to the licensee's measurement control program and the containers were either tamper-safed, stored in an area that provided protection equivalent to tamper-safing, or encapsulated.

62 l

o The method to be used for estimating the SEID for the typical material balance, as shown in the Annex, meets the following criteria:

All reasonable and probable sources of measurement error for the key measurement systems affecting ids are included.

The selection of the key measurements whose variances are to be included in calculating the standard error is justified by an analysis of the relative magnitudes of the variance components of a typical ID and their comparative effect on the SEID.

Any measurement error standard deviations not actually determined by the measurement control program are shown to be reasonable either by comparison with published state-of-the-art measurement performance in similar applications (see such sources as Rogers (1982), and Reilly and Evans (1977)) or with records of past performance data from the licensee's facility.

Records showing these data must be available to the NRC.

The calculation of the SEID is performed in accordance with a recognized error propagation method.

(Such methods have been published by Jaech (1973); Tingey, Lumb and Jones (1982); and l

the IAEA (1977)).

o Assessment of the significance of current period material balance results by sequential analysis of prior period ID data requires consideration of several relevant points.

These are:

The sequence of ids used for analysis should possess essentially the same components as the current period.

That is, the through-puts should be approximately the same (e.g., i 25 percent to 30 percent), the same process units should be operational, and the process should not have undergone any major modifications.

With respect to the unit operations, it is not essential that all units operate every period but rather that the grouping of ids for analysis take into account which units were operative.

As to process modifications, a major modification would be one that has a significant impact on measurement capabilities or holdup patterns.

"Significant" means a change in the SEID of i 30 percent or greater.

The analysis of a sequence of ids to establish a representative standard deviation must take into account the covariances that exist between adjacent (lag 1) and alternate (lag 2) pairs.

The AAMASS methodology (Lumb and Tingey (1984) and INDEP (Lumb and Associates (1986) provide two acceptable means of determining the historical standard deviations taking covariances into account.

o The criteria against which the significance of a current period ID should be evaluated can be established by at least two different methods.

These are:

63

Control chart limits constructed with current and historical material balance closure data, where such limits for further action should be established at a level of significance of 0.01.

The limits should be based on the statistical variance-covariance structure of the current inventory difference and an appropriate sequence of previous inventory differences; or Three sigma control limits where sigma is determined as described above o

Excessive ids must be investigated and appropriate action taken.

Following are actions that would be deemed appropriate:

ID > 3 g and 300 grams U-235 (200gms Pu/u-233)

(1) Review inventory listing to ensure that all items have been listed.

(2) Review measurement results for previously unidentified biases.

(3) Review inventory documentation and book records for human errors.

(4) Review holdup estimates for reasonableness relative to historical data.

(5) Calculate a standard deviation representative of relevant historical ID performance.

SFKg > ID > 3 o ID (1) Compare material control test and item monitoring data l

with results of the physical inventory.

l l

(2) Review results of trends analyses for all process units.

(3) Review conclusions of alarm investigations.

10FKg > ID > 3 o and 5FKg ID (1) Same as above, and (2) Review plant security records.

(3) Conduct next inventory within two months or as directed by NRC ID > 3 o and 10FKg ID 64 l

I

(1) Same as above (2) Prepare facility for an immediate reinventory.

(3) Remeasure a statistically _ determined sample of the items-generated during the material balance period in question that is sufficient to detect ~the loss of 5 FKG with a.99%

probability of detection.

o The concept of active. inventory is adequately described and represents.the quantity of material typically handled under normal plant operating conditions.

Questions and Answers

.1.

Q.

What is the distinction between an ID estimate and estimator?

A.

Because of unavoidable uncertainties in any measurement, the true i

amount of material being measured is unknown.

The measurement can be considered to be a random variable characterized by a probability distribution. As a random variable, the measurement process is referred to in statistical terminology as an estimator.

A particular value realized by applying an estimator is referred to as an estimate.

Since ID is a function of measured values, it is sometimes useful to distinguish between true ID, its estimator, and a single estimate.

The ID calculated at the end of an inventory is a point estimate.

There is no guarantee, in fact it is highly unlikely, that the ID estimate will exactly equal the true ID.

The ID estimator random variable can be written as:

ID = BI + A - EI - R,.

where ending inventory (EI), beginning inventory (BI), additions (A) and removals (R) are also random variables.

In this form of the ID equation the inventory terms must represent all inventory including residual holdup.

2.

Q.

Why not use limit of error as the measure of ID variability?

A.

Although the limit of error of ID (LEID) has been used for some time l

in nuclear material accounting, the terminology is a departure from i

statistical terminology taught in schools and universities, and as a result, it has been the source of some confusion.

In practice LEID has been calculated as twice the standard deviation of the measure-ment error associated with the ID.

It should be realized that licensees need only use an estimate for the standard deviation.

3.

Q.

How does the constraint on measurement system quality, i.e., 0.1 percent of active inventory, compare to the LEID limit in 10 CFR 70.51?

A.

The LEID limit for most processes is 0.5 percent of the throughput, which is the larger of additions to or removals from process.

Since i

65

active inventory, which replaces throughput because it is a more widely applicable measure of the amount of material subject to measure-ment error in an inventory period, involves the sum of additions and removals, it is approximately double throughput.

Thus the LEID limit could be expressed as "approximately 0.25 percent of active inventory."

The LEID is also twice the standard deviation of ID (measurement component only).

Thus the LEID limit can be expressed as "twice the standard deviation must be less that 0.25 percent of active inventory."

This equates to one standard deviation being less than 0.125 percent of active inventory.

The proposed rule uses a limit of 0.100 percent of active inventory since measurement equipment is better than it was when the LEID limit of 0.5 percent throughput was originally proposed a decade ago.

l 66

4.6 Accounting Requirements:

The rule requires that a licensee establish auditable records 9

sufficient to demonstrate that the requirements of'S$ 74.53, 74.55, 74.57 and

/

74.59 have been met.

The records are to be retainid for at least three years or longer if/ required by Part 75 of this Chapter 16 74.59(g)).

Intent and Scope:

The intent of these requirements is that the licensee establish antauditable records system that contains sufficient information to facilitate future reviews, audits, and inspections to demonstrate that all Plan '

commitments have been met.

As a minimum, the records system should include -

o data and information on material control tests; item monitoring; alarm resolu-tion; SSNM receipts, shipments, and discards; measurement control; physical inventories; and MC&A program assessments.

Plan / Annex Content:

The FNMC Plan con'tains the following affirmations and detailed commitments.

Supporting information, as appropriate, is included in the Annex.

Section4.6ofPlanincludes'thefollowinghffirmations:

o A records system is maintained that contains auditable records suffi-cient to demonstrate compliance with all commitments reflected iri,

this Plan.

Sufficient protection and redundancy of the record system is provided o

so that an act of record alteration or destruction will not eliminate the capability to provide a complete and correct set of SSNM control and accounting information that could be used to detect the loss of a i goal quantity or more, resolve indications of missing material, or aid in the investigation and recovery of missirg riaterial.

o Controls are incorporated in the records system to maximize the likelihood that mistakes and attempts at data falsification will be

detected, o

SSNM transactions are traceable from source data to the, final accounting records.

4.6.1 Records System j

l Provide a general description of the records system including recordkeeping l

policies and the types of data and information routinely recorded.

The types of records to be retained and their form should also ba, described.

In the Annex, provide flow charts showing the flow of data from the source l

documents to the final accounting records and the typical forms and report i

formats used throughout the PC&A system.

1 l

67

s

.~.

\\;

.f

,s

{ g

,i 1

, 4.6.2 Record Maintenance i

~

Describe the measures that will be taken to ensure record integrity including:

Ph.9sical protection; Nssignmentofoverallresponsibility; Access controls which permit only authorized updating and Grrecting of records; Cross-checks for preventing or detecting missing or falsified data and records, ensuring completeness of the records, and locating data discrepancies and errors; and Capability for reconstructing lost or destroyed records.

Acceptance Criteria:

The assessment of the adequacy of the information supplied above will be based on the following criteria:

o The records system provides for retention of key material accounting and original source data and relevant reports and documents including:

Management structure; MC&A policies and procedures; Measurement data used for loss detection, alarm resolution and material balance accounting; Records of the investigation and resolution of alarms; i

Calibrations of measurement systems, measurement quality control data, bias adjustments and their backup data, and the statistical analyses of the measurement control data; i

Calculations of action thresholds for the detection system; Shipper / receiver data and investigations of significant shipper / receiver differences; j

Tamper-safing records (e.g., application records, " attesting to" records, destruction records);

Physical inventory listings and inventory work sheets; Records of ids and calculations of the SEIDs; Reports of investigations and resolution of alarms, excessive ID estimates, and shipper / receiver differences; and j

68 i.

4-y Reports of periodic revi'ews and assessments and the resultant" '

corrective actions taken by management.

Records may be retained in hard copy, magnetic tapes or disks, o

microfiche, or other suitable forms.-

s o

The records-and reports contain sufficient detail to enable inspectors to determine that SSNM control and accounting has been conducted in compliance with $$ 74.53, 74.55, 74,57 and 74.59.

?

'1 L

o' The record system will be complete andisufficiently detailed to-permit auditing of all parts of the MC&A system.

The records and reports will be readily traceable back to source documents.

o

.The record system will have sufficient redundancy to enable reconstruction of lost or missing records se that a complete N

knowledge of the SSNM inventory is available.

The capability for reconstruction of records will be provided by a subsystem at least equivalent.to the following:

source data for receipts, shipments, internal transfers, adjustments, and corrections to the records.will be retained ~in a separate secure. location so that a single individual or a single event;cannot al_ter both accounting and source records.

1 o

Cross-checks or other controls will be provided t'o prevent or detect errors in the records that would affect ids or item location records.

Examples of cross-checks or controls that might prevent or detect errors in the records system would include:

r Minimizing the number of people authorized to make data entries; UsingverificationmethodsfNrdataentryforshipments, i'

receipts, waste discards, and item records (item records may be

-checked by random sampling rather than on a 100 percent basis);

and 1

cross-checking calculations, at least by random sampling.

l#

o The records of the data that are the basis of the SEID will permit

(

traceability to the sources of the variancet due to calibrations, ii i,

bias adjustments, and random errors in Me neasurements.

These1 j

i records may simply be summaries of edbrie :ons, bias tests, and t

variance monitoring data or contrcl yrt

[4.7 Shipments and Receipts Requiren.ent:

The rule requires that a licensee shall establish procedures for shipping and receiving SSNM that provide for:

Accurate identification and measurement of the quantities shipped and rec,eived; l

Review and evaluation of shipper / receiver differences on an individual container or lot basis, on a shipment basis, and on a batch basis when required by Part 75 of this Chapter; 69

1 2

.c I

Investigation-and corrective action when shipper / receiver differences exceed twice the estimated standard deviation of the difference

. estimator and the larger of 0.5 percent of the amount of SSNM in the container or lot, as appropriate, and 50 grams of SSNM.

Documentation of shipper / receiver evaluations, investigations and corrective actions ($ 74.59(h)(1)).

Intent and Scope:

Timely and accurate quantification of the SSNM content of shipments and receipts is an essential component of an effective MC&A system.

When significant shipper / receiver differences are identified, it is imperative that they be resolved and contributing factors corrected.

Plan / Annex Content:

The FNMC Plan contains the following affirmations and detailed commitments.

Supporting.information, as appropriate, is included in the Annex.

Section 4.7 of the Plan includes the following affirmations:

o The element and isotopic content of SSNM shipments are based on measurements obtained from measurement systems subject to the measurement control program.

o Receipts of SSNM are checked and measured to confirm that the quantity received is consistent with the supporting documentation.

Item checks and seal integrity inspections are completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of receipt.

Receipt measurements are completed within 30 days of receipt except in the case of scrap.

o Shipper / receiver differences are investigated whenever they exceed twice the standard deviation of the difference estimator and the larger of 0.5 percent of the amount of SSNM in the container, lot or shipment, as appropriate, or 50 grams of SSNM.

o Results of shipper / receiver difference investigations, including corrective actions, are documented and retained for at least three years.

I 4.7.1 Receiving Procedure i

Describe how materials are received, stored, and measured.

The latter should include a description of the sampling techniques employed.

4.7.2 Shipper-Receiver Differences Describe the investigation of significant shipper-receiver differences.

The description should include:

The method of establishing the standard deviation of the shipper-receiver difference estimator under conditions where the shipper's uncertainty estimate is available and where it is unavailable; The conditions under which a referee laboratory is involved and the I

criteria for selecting a referee laboratory; 70 l

The bases established for concluding that a significant difference is resolved; The procedure for adjusting book records to accommodate resolution of the difference; and-The procedure for establishing and resolving differences' involving scrap.

4.7.3 Shipping Procedure Describe the preparation and certification procedures for shipping SSNM.

The description should include:

The measurement data and tamper-safing information provided to the.

group responsible for SSNM shipments; The cross-checks, including any item checks or measurements, made by the shipping group; and The types of records maintained by the shipping group.

Acceptance criteria:

The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:

Receipts are inspected promptly to verify the validity of the shipper's o

data.

Acceptable times to complete the verification measures are:

Item verification, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; Seal integrity, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; Gross weight, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; NDA scans (if appropriate), 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> *; and SSNM measurements (scrap excepted), 30 days.

Times other than those indicated above would be acceptable with adequate justification.

Shipper's values may be accepted for encapsulated items such as fuel rods, o

elements, etc.

o The investigation of statistically significant shipper-receiver differences should normally be completed within three months except where the difference exceeds 5 FKG.

In the latter case, the discrepancy should be resolved within 30 days of the time that its existence is determined.

  • Qualitative or semi quantitative 71

..g The following stepwise analysis is an example of an acceptable approach for investigating a significant shipper-receiver difference:

The receiver should review his or her data to check for possible entry errors such as an incorrect number or the transposition of numbers.

The receiver should then review source data including the basic calculations and the associated measurement control data.

Assuming the difference remains unresolved, the receiver should remeasure the SSNM content of the receipt.

If remeasurement fails to resolve the difference, the shipper should be notified and requested to conduct a similar investigation.

If the two parties fail to resolve the difference, a referee laboratory should be involved.

The shipper and receiver should mutually agree on the sampling procedure.

linless contractual requirements dictate otherwise, the value closest to the referee's value should be accepted and booked by both parties.

If the referee's value is not within statistical limits of either the shipper or receiver, the referee's value should be used.

For purposes of shipper-receiver evaluation, a lot may be defined in o

several ways.

These would include:

Multiple containers of a material that has been blended by a procedure that has been demonstrated to produce a homogeneous product; Multiple containers filled from a master container of homogeneous material (e.g., UFs cylinders);

A quantity of scrap transferred on multiple transfer receipts (741s) but combined for processing through recovery.

4.8 Scrap Control Requirement:

The rule requires that a licensee establish a scrap control program that assures that internally generated scrap is segregated from scrap from other licensees or contractors until accountability is established, and any scrap with a measurement standard deviation greater than five percent of the measured amount is recovered so that the results are segregated by inventory period and received within six months of the end of the inventory period in which the scrap was generated except where it can be demonstrated that the scrap measurement uncertainty will not cause noncompliance with S 74.59(e)(5) (See S 74.59(h)(2)).

Intent and Scope:

The regular processing of scrap with relatively large i

measurement uncertainties precludes such scrap being the source of a problem at

{

l 72 l

.~....

the time of physical inventories.

Inaccurate scrap measurements could cause an apparent ID or conceal a theft or diversion.

Segregation of internally gener-ated scrap from that received from off-site until accountability is established ensures that potential anomalies in assigned values will be attributed to the appropriate facility.

Plan / Annex Content:

The FNMC Plan contains the following affirmations and detailed commitments.

Supporting information, as appropriate, is included in the Annex.

Section 4.8 of the Plan includes the following affirmation:

Scrap control procedures are in place that provide for:

o Segregation in the recovery process of any scrap that originates from off site from scrap generated on-site until accountability has been established; and Recovery of scrap within six months after the inventory period in which it was generated, when such scrap has a standard deviation of its measurement estimator greater than five percent of the measured amount unless it can be shown that the total scrap measurement error will not cause noncompliance with S 74.59(e)(5).

4.8.1 Location Identify the scrap and waste quantities of contained SSNM with respect to source, storage, and disposition.

Refer to process flow charts and plant operations descriptions included in the Annex.

4.8.2 Processing Describe the program for in-house processing of scrap including recovery plant capacity, rate of recovery, and the estimated amount of scrap expected to be on hand at any given time.

Describe any plans for shipments and for off-site recovery of scrap.

Describe procedures for the control and discard of wastes containing SSNM, including procedures and capabilities for storage prior to discard.

4.8.3 Measurement Describe the procedures for determining the SSNM content of scrap and waste, including the criteria and procedures for segregation, identification, and classification of various kinds of scrap to facilitate measurement.

Identify types and quantities of scrap expected to have measurement uncertainties greater than i 5 percent (la).

4.8.4 Inventory Control l

Describe the control program that will be implemented to assure that scrap l

measured with an uncertainty greater than i 5 percent does not remain on inventory longer than six months, or the measurement uncertainty associated l

with the scrap on hand will not cause noncompliance with $74.59(e)(5).

i 73 l

l

~.

4.8.5 Recovery of Off-Site Scrap Describe the procedures that will be implemented to ensure that scrap received for recovery from off-site is segregated until accountability is established.

The description should address segregation during storage and processing.

Acceptance Criteria:

The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent:

o A comparison of generation rates and recovery capacity indicates that adequate recovery capability exists to preclude the buildup of excess amounts of scrap.

o Where offsite recovery is utilized, the description of the program includes as a minimum:

Types and estimated quantities of scrap to be shipped, Contractor's program to assure segregation of customer scrap, Basis for establishing accountability values, Contractor and shipper measurement responsibilities, and Proposed means of performing shipper / receiver comparisons (i.e.

shipment basis, campaign basis, etc.).

o Special handling procedures for waste such as conversion to a better measurable form or independent measurement verification are described.

o Proposed measurement techniques for specific scrap types are described including:

Material description, Specific NDA system to be employed (as appropriate),

Container size, Mixing and blending operations (as appropriate),

Sampling technique, and l

Assay procedure.

An estimate of the measurement uncertainties associated with each scrap type should be included in the Annex.

l o

For those materials measured by NDA in 30 gallon drums or larger con-tainers, the licensee should commit to an annual evaluation to demon-I strate the continuing reliability of the measurement system.

Possible evaluation techniques include a destructive analysis, a second NDA 74

technique not subject to the same potential interferences as the pri -

mary technique, or a standard addition procedure.

o The program for segregation of scrap generated off-site from on-site scrap appears adequate to protect against commingling.

Possible techniques to achieve this objective are:

Retain customer scrap in shipping containers prior to recovery, Isolate customer scrap in a particular section of a vault or permanently controlled access area, or Identify designated storage bins or shelves for application of shelves for application limited access controls, o

Segregation of customer scrap during processing is accomplished by cleaning the dissolver and accountability weigh tank before and after the recovery campaign.

Additional processing of dissolver residues should be handled in the same manner unless the quantity involved is less than one FKG or the measurement uncertainty is less than i 5 percent (la).

4.9 Human Errors Requirement:

The rule requires that a licensee incorporate checks and balances in the MC&A system to minimize the rate of human errors in MC&A infor-mation ($ 74.59(h)(3)).

Intent and Scope:

The objective of this requirement is to reduce the frequency of human errors affecting MC&A information and to enhance the likeli-hood of detection when they do occur.

This can be achieved by implementation of a system of checks and balances in MC&A information systems that involve generating, collecting, processing, computing, analyzing, summarizing, and reporting data.

Plan / Annex Content:

The FNMC Plan contains the following affirmations and detailed commitments.

Supporting information, as appropriate, is included in an Annex.

Section 4.9 of the Plan includes the following affirmations:

o MC&A procedures will be developed and implemented in a manner that assures that the frequency and consequences of human errors will be minimized.

o MC&A procedures include job performance aids, where applicable, that help to reduce the frequency of human errors.

o MC&A procedures will be formatted in a manner that facilitates a reduction in human errors and helps to make errors easier to identify.

75

o.

MC&A activities associated with collecting and processing data, recordkeeping, and auditing are automated where it is practical and advantageous to do so.

A quality control system is in place to monitor the frequency of o

human errors and permit categorization of the types of errors encountered.

4.9.1 Control Describe the techniques that will be employed to minimize the frequency of human errors and enhance the likelihood that they will be detected when they do occur.

The description should address the use of:

Control methods to ensure that current procedures are in place and being used, i

Job performance aids, Automated data processing, 1

Personnel training and qualification, Preprinted forms, Multiple copy forms, and Data verification.

4.9.2 Monitoring Describe the quality control system that will be used to monitor the frequency and types of human errors.

1 Acceptance Criteria:

The adequacy of the information supplied above will be based on the following criteria or equivalent:

o Procedures should be developed and used that will control the rate of 4

i human error in MC&A data.

(

Specific procedures should be available to guide personnel in performing major or complex tasks associated with MC&A.

Procedures should be sufficiently explicit and comprehensive to.

promote error free performance by the least skilled or least experienced person that will be assigned to perform the tasks specified by the procedures.

i Procedures should be based on the activities required to effectively accomplish the task.

Procedures should be self-contained to avoid the need to refer to supporting documents.

76 l

Procedures should be written with flexibility in the sequence of events whenever possible.

Knowledgeable personnel should prepare and review procedures before they are implemented.

Procedures should be validated by means of field tests to ensure their clarity, comprehensiveness, and effectiveness.

Personnel should be required to use and follow appropriate pro-cedures in performing complex MC&A tasks or tasks that affect MC&A.

o Job performance aids must be considered for use in highly complex MC&A tasks.

Job performance aids should assist novice users in their performance while not hindering the performance of experienced users.

Terms and labels should match common usage for equipment labels and legends.

Quantities and dimensional units shoula correspond to referenced displays, documents, and information.

Uncommon and inconsistent abbreviations should be avoided.

The presentation of illustrations, graphs, and tables, if used, should be consistent throughout the procedure.

Illustrations, tables, graphs, and other job performance aids, if used, should be appropriate to the task to be performed.

o Checklists or data tables should be provided for lengthy prerequisites, tests, and calculations.

o Illustrations should be used in place of long descriptions l

where possible.

o Illustrations should be placed so that they can be referenced j

easily from the text section.

o Illustrations should be clearly labeled and easy to read.

o All tables and graphs should be clearly labeled in quanti-tative terms.

o The format of MC&A procedures should be arranged to help to reduce the rate of human error and to detect mistakes.

l l

The complexity, sentence length, and grammatical structure should be appropriate to the educational level of the least j

qualified user.

77 i

a

's o-Short sentences with concise and unambiguous language should be used.

o The level of detail in instructions should be adequate to avoid errors of omission.

o No more than three simple task elements should be: included per step.

More complex actions should be separated into additional steps.

Procedures should be formatted-to' allow experienced personnel to concentrate on major headings or capsule descriptions, while more detail is provided in clearly demarcated fashion for less experienced personnel.

Procedures may be formatted in " cookbook" fashion for ease of use when appropriate.

All steps and tasks should be stated as actions.

The sequence of steps and tasks-in a procedure should be in the same sequence followed to accomplish the objective of the procedure.

Attention getting warning and precaution notices should be placed immediately preceding applicable steps and, where required, should also be summarized at the beginning of the procedure.

Summary information should be included at the beginning of every procedure. _All required supplies, tools, test equipment, docu-ments, and protective measures should be listed at the beginning of the procedure.

All applicable referenced documents should be listed in one section of the procedure.

Quality control and quality assurance points should be identified.

Decision-making cues should be clearly stated.

Sub-tasks and sub-tests should be set off with separate headings or by an appropriate indentation.

The sequence of steps should be logical and accurate.

Unnecessary memory recall should be avoided.

The need for personnel to perform calculations and conversions l

should be avoided whenever possible.

Data collection tables and data reduction aids should be provided if lengthy tests and calculations cannot be avoided.

Pre printed forms for recording data should be utilized when practical.

l Multiple copies of fonas, if needed, should be generated automatically in the data collection phase.

78 E

Formatting should be neat and simple and should be consistent among all related procedures.

MCM data should be directly collected, input, checked, manipulated,.

o

. reported,-and audited by computer where it.is practical and advantageous to reduce the consequences and frequency of human' error in MC&A data as much as' practical.

.o

_ Statistical quality control systems should be used to track the effectiveness of human error control measures and the frequency of i

human error in MC&A systems, and should be used to alert management whenever the rate of human error is in an out-of-tolerance condition.

[

The quality control system should be capable of determining if' l

and when an individual, procedure, or process makes more errors than is reasonably expected.

The quality control system should be capable of determining both the individuals who require retraining due to their frequency of committing errors and the procedures and processes that should be revised to produce fewer human errors.

Double checklists should be provided to allow auditing of data collection by a supervisor or other independent person that checks the results of the first person's work and signs off when i

the work is complete and accurate.

Each data collection form should be checked by the originator to verify that the data are accurate.

When MC&A data processing is automated, quality control systems should also be automated, so that out-of-tolerance conditions, hu: nan errors, and other warnings can be detected and corrective i

actions can be taken promptly.

A configuration management plan should be established for vital l

MC&A equipment, computer software, and manuals.

Configuration control measures should be performed systematically and immediately reflect all changes as they are made.

Procedures and technical manuals should be stored, indexed, filed, and controlled in a manner that ensures easy retrieval and avail bility.

The quality of operations and maintenance manuals should be one criterion in selecting between vendors when purchasing new I

equipment.

MC&A equipment and computer software manuals supplied by vendors should be specific to the equipment model purchased and contain explicit troubitshooting, calibrating, and repair instructions l

for hardware and coding and application instructions, if software

[

is used.

79 l

.v T

Personnel should perform quality control and quality assurance activities that are specified in the procedures.

t

.o Estimates of human error rates should be based on a human reliability analysis of the data collection process to determine a reasonable rcte of human error in MC&A data for the specific licensee.

Reasonable estimates of human error rates should include input regarding equipment design, plant policies and practices, and written procedures.

Reasonable estimates of human error rates should include input l

regarding situational and personnel factors that may produce errors.

Any potential problems that can reasonably be resolved following l

a human reliability analysis should be resolved and the estimate of a reasonable error rate should be recalculated.

Questions and Answers.

1.

Q:

What are some job performance aids that are used successfully?

A:

Several job performance aids (JPA) are illustrations and diagrams, graphs for interpolation, approximate times to complete specific jobs, clearly stated decision-making cues and clues to the correct decision given specific cues, and data reduction aids.

JPAs are good l

as long as they do not cause the procedure to become difficult to use l

because of too many aids, the wrong types of aids for that application, or presentation in an inappropriate manner.

If the procedure can be written so than an cyperienced user can omit unnecessary aids meant for novice users, that in itself is a JPA and will encourage procedure usage.

t 2.

Q:

Some of the notation and labels used on equipment at specific facilities may not be current with respect to recommen/cd terminology.

Should procedures use current terminology, or be consistent with the equipment?

1

}

j A:

Ideally, equipment should be brought into compliance with the current idea of "best" notation on labels and panels.

However, confusion i

could occur because personnel at the facility are accustomed to that terminology, so these labels probably should not be changed.

In any case, procedure terminology should be consistent with equipment, as should forms and other information to be employed by personnel at the l

facility.

(

3.

Q:

Why should there be no more than three actions per step in a I

procedure?

A:

By restricting the amount of information that personnel are required to remember while performing a procedure, there is a greater probability that the procedure will be performed correctly.

Remembering precise, numerical information is not a task that humans 80

t perform well.

Using checklists or pre printed forms are methods to limit the amount of memorization required while reducing dependence on often bulky procedures.

4.

Q:

Why should an independent observer be used to sign off on checklists and other work?

A:

aan independent observer is useful in the event that a person makes a mistake, since an independent observer will often see mistakes

'l whereas the person who made the original mistake, using the same logic or reviewing the work rather quickly, will be unable to 1

recognize the problem.

5.

Q:

What is configuration control and how is it applied to procedures?

A:

-Configuration control is a method by which the current official copies of procedures are maintained and controlled.

Procedures that may be used in configuration control include sign offs by a responsible person on the released version, numbering and dating versions, and periodic checks of the individual procedures under the control of the procedure custodian or holder to make sure that current copies are being used.

6.

Q:

What level of human error is reasonably achievable in MC&A data?

i A:

A reasonable amount of human error in MC&A data depends on the systems that are in place to provide checks and balances to reduce errors.

An effective program to reduce human error would employ I

techniques that limit human error by reducing the chances for errors to be made and not creating error-likely situations in the design of the work.

However, without totally eliminating the human element from MC&A, there is no way to eliminate human error totally.

Table 1 lists some of the applicable human error rates and situational multipliers from Swain and Guttmann (1983).

I l

I l

1 81

s i

Table 1 Errors Rate Associated with MC&A Data Collection These values are adapted from Swain and Guttmann and reflect some typical error probabilities for human activities in the MC&A process.

For additional data and information on its usage, please refer to the cited document.

Potential Error Estimated Error Rate Failure to perform rule-based actions correctly when written procedures are available and used.............

.005 written procedures are not available or used..........

1.0 Omitting a step or important instruction from a fo rmal p rocedu re....................................

.003 oral instructions......................................

negligible Writing an item incorrectly in response to a fo rmal p rocedu re....................................

.003 oral instructions......................................

negligible Carrying out a plant policy scheduled task such as periodic tests performed weekly, monthly, etc.......................

.01 Using a written test or calibration procedure properly.....

.01 Using a checklist properly.................................

.5 Omitting items when procedures have check-off provisions and are correctly used........................................

.003 incorrectly used......................................

.01 Omitting items when written procedures are available and are not used...............................................

.05 e

Errors of commission in reading and recording quantitative information from unannunciated displays analog meter..........................................

.003 digital readout.......................................

.001 chart recorder........................................

.006 printing recorder with large number of parameters.....

.05 graphs................................................

.01 recording tasks......................................

.005 simple arithmetic calculation.........................

.01 Estimated probabilities that a checker will fail to detect errors made by others routine tasks, checker uses written materials.........

.1 routine tasks, checker uses no written materials......

.2 one-of-a-kind checking with alerting factors..........

.05 special measurements..................................

.01 82

3 Table-1 (Continued)

Modifications of estimated error rates for the effects of stress and experience level low stress............................................

x2 optimum stress........................................

x1 moderately high stress novice...........................................

x4 skilled..........................................

x2 extremely high stress (life threatening) novice...........................................

x10 skilled..........................................

x5 4.10 Independent Assessment

. Requirement:

The rule requires that a licensee independently assess the past performance of the MC&A system and review its effectiveness at least once every 12 months, including management's action on prior assessment recommenda-tions (S 74.59(h)(4)).

Intent and Scope:

The intent of the independent assessment of the MC&A system is to periodically review the system performance from an effectiveness perspective relative to the performance objectives defined in $74.51(a) and the system capabilities defined in $74.51(b).

Plan / Annex Content:

The FNMC Plan contains the following affirmations and detailed commitments.

Supporting information, as appropriate, is included in the Annex.

Section 4.10 of the Plan includes the following affirmations:

o An effectiveness evaluation of the entire MC&A system is performed at e

least every 12 months, o

The assessment is performed by technically qualified individuals whose organizational positions and normal work assignments will not interfere with their ability to make objective decisions.

o The assessment team leader will have no responsibility for performing or directly managing any part of the MC&A program.

o The details and results of the assessments and recommended corrective 7

actions are documented and reported to the plant manager.

I

~

Management will receive the assessment report and take the actions o

necessary to correct identified deficiencies.

l o

The actions taken to correct deficiencies are documented and reviewed l

during the subsequent assessment.

l t

l 83 t

s, 4.10.1 Assessment Program Describe the structure of the program including:

The means of assuring independence of action and objectivity of decision; The technical qualifications of and the selection criteria for team members; The planned objective and sccpe of the assessment listing the general areas to be covered; and The organizational positions responsible for initiating the assessment, approving the membership of the assessment team, implementing the corrective actions that are deemed necessary, and providing follow-up action to assure that corrective actions have been implemented.

In the Annex, provide a checklist of the fu.nctions to be reviewed in each area.

Regulatory Guide 5.51 may be used as appropriate.

Acceptance Criteria:

The assessment of the adequacy of the information supplied above will be based on the following criteria:

The assessment will include a comprehensive review of the MC&A system o

to independently assess the system design and evaluate its capabilities to achieve the general safeguards objectives and an audit and inspec-tion of the system performance, carried out in sufficient depth, to detect deficiencies or weaknesses in either the system design or implementation.

The assessment encompasses the entire MC&A system with particular o

emphasis on abrupt loss detection, item control, and alarm resolution.

The emphasis is justified on the basis that these functions provide the primary assurance that no loss has occurred.

The assessment program provides objective measure of:

Management effectiveness and responsiveness to indications of possible loss, Staff training and qualifications for particular job functions, Quality control of measurements and process variability, Timeliness of loss detection and response to alarms, and Alarm resolution effectiveness.

o The personnel assigned to the assessment team will have an understand-ing of the objectives and requirements applicable to the MC&A system and have sufficient knowledge and experience to be able to assess the adequacy of the function they are requested to review.

The team 84 1

o will not include MC&A management personnel but may include other MC&A staff provided no individual reviews his/her own area of responsibility nor the area of another MC&A team member.

o The responsibility and authority for the assessment program and for initiating corrective actions is at least one organizational level higher than the MC&A manager.

o Outside contractor laboratories should be included in the the 12 months assessments.

4.11 SSNM Custodianship Requirement:

The rule requires that a licensee assign custodial responsi-bility for all SSNM possessed under licensee in a manner that ensures that such responsibility can be effectively executed ($ 74.59(h)(5)).

Intent and Scope:

The intent of this requirement is that there be a designated individual who is responsible for having knowledge of the placement and movement of SSNM within a specified area and transfers into and out of the area.

Such an individual should be vested with the authority to obtain the information necessary to accomplish his/her. task and to assure that activities are carried out in accordance with approved policies and procedures.

Plan / Annex Content:,The FNMC Plan contains the following affirmations and detailed commitments.

Supporting information, as appropriate, is included in the Annex.

5 Section 4.11 of the Plan include the following affirmations:

e o

The SSNM processing facility is subdivided into a sufficient number of areas to ensure that custodial responsibilities can be effectively executed.

o A custodian and a minimum number of alternates are designated for l

each area subdivision.

l o

Transfers of SSNM between areas of offferent custodial responsibility l

are measured for element and isotope, as appropriate, and results are i

documented on signed tranfer receipts.

1 4.11.1 Custodial Areas Identify the areas into which the facility will be devided to assure that custodianship can be effectively executed.

Reference to facility drawings included in the Annex is acceptable.

4.11.2 Duties / Authority l

Describe the duties of the SSNM custodians including defined authorities.

I l

85

Acceptance Criteria:

The assessment of the adequacy of the information supplied above will be based on the following criteria or equivalent.

o Except for the stipulations that all SSNM crossing custodial area boundaries must be measured and custodians must be able to effectively execute their duties, there are no restrictions on how large an area can be.

However, different MAAs should have different custodians, and within MAAs, areas with widely divergent functions should have different custodians.

An example of the latter situation would be a fabrication plant where bulk material is handled in one area in the preparation of the fuel component of an element, and a second area is involved with machining and preparation of the element for higher tier fabrication.

o A current listing of designated custodians and alternates should be maintained, o

Custodians should be 'amiliar with SSNM processing activities as well as MC&A functions.

A minimum of one year of experience in each of these areas is desirable, 4

o Custodians should not be appointed from production or production control to preclude the possibility of conflicts of interest.

i 86 L

1 O

References ANSI N15.36.

Non-Destructive Assay Measurement Control and Assurance.

American National Standards Institute, New York, New York (in preparation).

ANSI N15.41.

Guide to Nuclear Facility Measurement Control.

American National Standards Institute, New York, New York (in preparation).

Augustson, R. H.

1978.

DYMAC Demonstration Program:

Phase I Experience.

LA-7126-MS, Los Alamos Scientific Laboratory, Los Alamos, New Mexico.

Bowen, W. M.

1982.

Evaluation of Simultaneous Testing Procedures for Nuclear Materials Control and Accounting.

NUREG/CR-2483 (PNL-4085), Pacific Northwest Laboratory, Richland, Washington.

i i

Brouns, R. J. and J. E. Fager.

1982.

Detection Time Guidance.

(Draft submitted to NMSS Division of Safeguards, January 1982.) Pacific Northwest Laboratory, Richland, Washington.

Brouns, R. J. and F. P. Roberts.

1980.

Training and Qualifying Personnel for Performina Measurements for the Control and Accounting of Special Nuclear Material.

NUREG/CR-0773 (PNL-3020).

Pacific Northwest Laboratory, Richland, l

Washington.

i Brouns, R.

J., F. P. Roberts, J. A. Merrill, and W. B. Brown.

1980.

A i

Measurement Control Program for Nuclear Material Accounting.

NUREGRR-0829 (PNL-3021).

Pacific Northwest Laboratory, Richland, Washington.

Brouns, R.

J., B. W. Smith, D. W. Brite, and C. O. Harvey.

1980.

The Use of Process Monitoring Data for Nuclear Material Accounting:

Vol. 1. Summary i

Report.

NUREG/CR-1670 (PNL-3396).

Pacific Northwest Laboratory, Richland, j

Washington.

(Available in abbreviated form as R. J. Brouns and B. W. Smith.

j 1980.

"The Use of Process Monitoring Data to Enhance Material Accounting."

i In Proceedings of the Institute of Nuclear Materials Management Meeting, IX,,

i pp. 688-696.

Chicago, Illinois.)

i Cobb, D. D.

1981.

" Sequential Tests for Near-Real-Time Accounting."

In Proceedings of the Institute of Nuclear Materials Management Meeting, X, pp. 62-70.

Chicago, Illinois.

David, H. A.

1970.

Order Statistics.

John Wiley & Sons, New York.

Duggan, W. P., K. R. Byers, and L. Hulse.

1981.

Criteria for Response to l

Special Nuclear Material and Control and Accounting System Alarms.

NUREG/CR-2399 (PNL-4091).

Draft Report to the NRC.

Pacific Northwest Laboratory, l

Richland, Washington.

i Eggers, R. F.

1981.

Detath.a Response to Alarms.

Unpublished Report to the i

NRC.

Pacific Northwest Laboratory, Richland, Washington.

I i

Eggers, R. F.

1982.

Design Aids for Estimating the Frequency of Occurrence of

(

Unresolved Plant-Wide False Alarms.

Unpublished Report to the NRC.

Pacific l

Northwest Laboratory, Richland, Washington.

l l

87 I

=___

'Eisenhart, C., M. W. Hastay, and W. A. Wallis.

1947.

Selected Techniques of Statistical Analysis.

McGraw-Hill, New York.

Glancy, J.

E., G. Borgonovi, S. Donelson, et al.

1980.

Feasibility and Cost /

Benefit of Advanced Safeguards for Control of Nuclear Material In-Process.

NUREG/CR-1686 Vol. 1 (SAI 01580-343LJ).

Science Applications, Inc.,

La Jolla, California.

Graybill, F. A.

1976.

Theory and Application of the Linear Model.

Duxbury Press, North Scituate, Massachusetts.

Hakkila, E.

A., J. W. Barnes, T. R. Canada, et al.

1977.

Coordinated Safeguards for Materials Management in a Fuel Reprocessing Plant.

Appendix.

(Part E), LA-6881, Vol. II.

Los Alamos Scientific Laboratory, Los Alamos, New Mexico.

i Hakkila, E.

A., D. D. Cobb, H. A. Dayem, et al.

1980.

Materials Management in an Internationally Safeguarded Fuels Reprocessing Plant.

LA-8042, Vols. 1, 2, and 3.

Los Alamos Scientific Laboratory, Los Alamos, New Mexico.

Hawkins, R.

L.,

R. L. Lynch, and R. F. Lumb.

1980.

Using Advanced Process Monitoring to Improve Material Control.

NUREG/CR-1676, Vol. 1 (NUSAC-556).

Nuclear Surveillance and Auditing Corporation, McLean, Virginia.

1 Hurt, R. D.,

S. J. Hure11, J. W. Wachter, et al.

1982.

Experimental Demonstration of Microscopic Process Monitoring.

ORNL/TM-7848, Oak Ridge i

National Laboratory, Oak Ridge, Tennessee.

IAEA Safeguards Technical Manual, Part F - Statistical Concepts and Techniques.

1977.

IAEA-174, International Atomic Energy Agency, Vienna, Austria.

Jaech, J. L.

1973.

Statistical Methods in Nuclear Material Control.

TID-26298.

National Technical Information Service, Springfield, Virginia.

Jaech, J. L.

1977.

"On Forming Linear Combinations of Accounting Data to Detect Constant Small Losses."

J. Nucl. Mater. Manage., VI(4):37-42.

l Juran, J. M. (ed.).

1951.

Quality Control Handbook.

McGraw-Hill Book Company, Inc., New York, New York.

i Lumb and Associates 1986.

Inventory Difference Evaluation Program (INDEP)

Lumb, R. and Tingey, F.

1981.

Mathematical Derivation of the Automated i

Material Accounting Statistics System (AMASS).

Nuclear Surveillance and Auditing Corporation.

McLean, Virginia.

Markin, J.

T., A. L. Baker, and J. P. Shipley.

1980.

" Implementing Advanced Data Analyses Techniques in Near-Real-Time Materials Accounting."

In Proceedings of the Institute of Nuclear Materials Management Meeting, IX, pp. 236-244.

Chicago, Illinois.

Miles, J.

C., J. E. Glancy, and S. E. Donelson.

1979.

Use of Process Mon-itoring Data for the Enhancement of Nuclear Material Control and Accounting.

NUREG/CR-1013 (MLM-2643).

Mound Laboratories, Miamisburg, Ohio, and Science l

Applications, Inc., La Jolla, California.

88 t

Reardon, P.

T., S. W. Heaberlin, and R. F. Eggers.

1982.

"An Assessment Method to Predict the Rate of Unresolved False Alarms," In Proceedings of the Institute of Nuclear Materials Mangement Meeting, XI, pp. 278-282.

Chicago, Illinois.

Reilly, T. D. and M. L. Evans.

1977.

Measurement Reliability for Nuclear Material Assay, LA-6574.

Los Alamos Scientific Laboratory, Los Alamos, New Mexico.

Rogers, D. R. (ed.).

1983.

Handbook of Nuclear Safeguards Measurement Methods, NUREG/CR-2078 (MLM-2855).

Mound Laboratories, Miamisburg, Ohio.

Rose, D. M. and F. W. Scholz.

1983.

Statistical Analysis of Cumulative Shipper-Receiver Data.

NUREG/CR-2819 (BCS 40384-0).

Boeing Computer Services Company, Tukwilla, Washington.

Rudy, C. R., D. B. Armstrong, K. W. Foster, D. R. Rogers, and D. R. Hill.

1982.

Controlled Unit Approach:

An Application Manual.

NUREG/CR-2538 (MLM-2881).

Mound Facility, Miamisburg, Ohio.

Seabaugh, P. W., D. R. Rogers, H. A. Woltermann, et al.

1980.

The Controllable Unit A?proach to Material Control:

Application to a High Throughout Mixed 0xide )rocess.

NUREG/CR-1214, Vols. 1, 2, and 3 (MLM-2532).

Mound Laboratories, Miamisburg, Ohio.

Shewhart, W. A.

1931.

Economic Control of Quality of Manufactured Products.

D. Van Nostrand Co., New York.

Shipley, J. P.

1981.

" Decision-Directed Materials Accounting Procedures:

An Overview."

In Proceedings of the Institute of Nuclear Materials Management Meeting, X, pp. 281-287.

Chicago, Illinois.

Smith, B. W., J. E. Fager, K. R. Byers, and R. F.,

Eggers.

1983.

Testing of Safeguards Alarm Resolution Procedures in a Scrap Recovery Facility.

Draft Report to the NRC.

Pacific Northwest Laboratory, Richland, Washington.

Stewart, K. B.

1978.

"The Loss Detection Powers of Four Loss Estimators."

J. Nucl. Mater. Manage., VII(3):74-80.

Swain, A. D. and H. E. Guttmann, August 1983.

Handbook of Human Reliability Analysis with Emphasis on Nuclear Power Plant Applications.

NUREG/CR-1278.

Sandia National Laboratories, Albuquerque, New Mexico.

Tanner, J.

1981.

False Alarm Resolution Assessment Methodology, Unpublished Report to the NRC.

Pacific Northwest Laboratory, Richland, Washington.

Tingey, F. H.,

C. J. Barnhart, and R. F. Lumb.

1983.

Resolving the Components of Process Variability and Estimating the Uncertainty of the LEID.

NUSAC Report 752, Rev. 1.

NUSAC, Inc., Reston, Virginia.

Tingey, F. H.,

R. H. Lumb, and R. J. Jones.

1982.

Statistical Guidance for Material Control Detection Tests.

NUSAC Report 712 (Draft).

NUSAC, Inc.,

Reston, Virginia.

Wincek, M.

A., K. B. Stewart, and G. F. Piepel.

1979.

Statistical Methods for Evaluating Sequential Material Balance Data.

NUREG/CR-0683 (PNL-2920).

Pacific Northwest Laboratory, Richland, Washington.

1 j

89 l

~

3 3 EMCLOSURE C l

t

.1 REGULATORY ANALYSIS Material Control and Accounting Requirements for Facilities Licensed to Possess and Use Formula Quantities of Strategic Special Nuclear Material (10 CFR Part 74) 1.0 STATEMENT OF THE PROBLEM Although, under the requirements of 10 CFR Part 73, physical security systems protect against the theft of strategic special nuclear material (SSNM),

material control and accounting (MC&A) systems are needed that focus on the material in order to ensure that no covert theft succeeds despite the physical security system and to provide data needed to deal with reported allegations of theft.

The current domestic MC&A regulations for high enriched uranium and pluto-nium focus on bimonthly physical inventories and the determination of a plant-wide inventory difference (ID) and its associated limit of error (LEID).

Comparison of the inventory difference with the LEID and percent of throughput does not occur until nearly 30 days after the beginning of the physical inventory.

The usefulness of these inventories in providing the public with assurance that significant quantities of SSNM have not been diverted has been degraded by difficulty in conclusively resolving large ids. This has necessitated the sub-stitution of reliance on plant security records and intelligence information for the desired assurance.

2.0 PROPOSED SOLUTION A rule has been developed which will reform the MC&A requirements for fuel cycle facilities that are licensed to possess and use formula quantities of SSNM. The Reform Amendments are a performance-oriented regulation that emphasizes timely detection of SSNM losses and provides for more conclusive resolution of discrepancies.

By relaxation or elimination of those current requirements which are not cost-effective, and by taking advantage of process 1

ENCLOSURE C

controls, production controls, and quality controls already used by licensees, this can be accomplished with an annual cost reduction that will eventually I

offset implementation costs.

3.0 ENVIRONMENTAL ASSESSMENT The estimated impact of the proposed amendments are assessed as follows:

1)

Status quo - The current material control and accounting requirements have virtually no impact on the environment because they have no

{

significant effect on the process or effluents of the licensee.

2)

Recomended amendments to MC&A regulations - The changes will have no significant effect on the licensee's process or effluents. The rule i

change involves no new commitment for land use, air use, or water use.

No new or exclusive use structure is necessary. There are no dangers to flora, fauna, or endangered species involved. There will I

be no significant increase in individual or cumulative occupational radiation exposure. There is no significant increase in the potential for or consequences from radiological accidents.

No new traffic patterns are involved.

No new human, natural, or man-made resources are required.

The foregoing forms a basis for a finding that this rulemaking action will have no significant impact on the human environment and a decision not to i

prepare an environmental impact statement.

i 4.0 COSTS AND BENEFITS 4.1 Summary l

Results of regulatory analyses performed in support of the MC&A Reform Amendments indicate that significant safeguards benefits will accrue from these

(

amendments. An initial moderate increase in costs will occur due to the i

implementation effort. However, savings in annual operating costs will offset the implementation costs for the fabrication facilities within four to seven years and within two to nine years for the conversion facilities.

Benefits of the MC&A Reform Amendments include:

Providing more timely SSNM loss alarms through use of production and quality control measurements instead of less timely comparisons of plant-wide ID and LEID; Increasing the ability to confidently resolve MC&A alarms by:

(a) Decreasing the area and material subject to the alarms, (b) Decreasing the number of persons who need to be investigated, and (c) Decreasing the length of time in question; Basing detection criteria on the quantity of safeguards significance (i.e., 5 FKG) rather than on throughput of SSNM at a facility; Basing detection criteria on sound statistical principles and resolv-ing those statistical deficiencies, identified in the " Report on the Statistical Treatment of Inventory Differences" (SECY 80-514),* which are resolvable by this rulemaking; Basing criteria for interruption of processing activities on an assessment of whether the interruption will facilitate the resolution of a localized alarm involving a significant quantity of SSNM rather than the inability to resolve an imbalance resulting from the taking of periodic inventories; i

  • This report is available for inspection and copying for a fee in the NRC Public Document Room, 1717 H Street NW., Washington, DC 20555.

3 ENCLOSURE C

}

LRequiring an integrated safeguards approach towards protection against' falsification and deceit by multiple insiders that recognizes the collusion protection provided by the physical security upgrade, yet assures that MC&A will provide an independent check of physical security protection; Focusing training and qualification requirements on those positions involving tasks where error or negligence could directly and adversely affect MC&A capabilities; and Permitting greater licensee flexibility by making quality assurance and accounting requirements less prescriptive.

Additional benefits accrue through the elimination or decrease of current -

requirements which are no longer needed because of the new requirements or because of their relatively low cost-effectiveness.

Some of these changes are:

Increasing the period between physical inventories from bimonthly to semiannual; and Changing processing of scrap requirements to a performance-oriented approach, rather than the previous " command and control" approach,

(

to allow the licensee to use more cost-effective methods.

4 i

Estimates have been developed that indicate annual cost savings associated l

l with these changes will more than offset the increased costs associated with the new requirements over a peroid of years.

Both the increased costs and cost savings attributable to the Reform Amendments are compared to the current requirements in Table 1.

The figures set forth in Table 1 are further described in Section 4.3 (Results of Cost Estimate Analysis) within.

The costs and savings shown in this table have been developed to encompass facilities similar to the four current Category I facilities. Of the four currently licensed facilities, two are primarily engaged in uranium fuel fabrication operations such as welding and machining, and two operate uranium conversion processes in which the chemical form of the uranium is changed.

Three of the 4

y e

^

four operate scrap dissolution and recovery processes.

Actuai costs to individ-ual facilities will depend upon the size and type of facility and thn degree to which they may have already implemented some of the requirements such as'a pro-cess monitoring system.

The cost ranges depicted in Table 1 reflect these differences in facilities and'also the uncertainties in the cost estimates.

p' It should be noted that a number of additional savings, not shown in Table 1, might accrue to licensees due to implementation of the Reform Amend-ments.

For example, potential savings might accrue if licensees were able to reduce their uranium inventories as a result of implementing the process moqi-toring system required by the Reforto Amendments.

An LEU facilit9 referenced in the Results section reduced its_ uranium inventory by 60 percent after imple-menting a process monitoring system.

Improvements to production due to 3

increased accuracy and quick accessibility to the data base are s9milarly difficult to evaluate.

Besides improvements to domestic safeguards, a possible a'dditional benefit associated with adoption of the MCIA Reform Amendments is that, experience gained during implementation may be useful to the International Atomic Energy Agency (IAEA) regarding its interest in strengthening international safeguards.

One report presented to an International Working Group supporting IAEA noted. that:

"...the most fundamental advantage of process monitoring is that it could enhance the diversion detection capabflity of an international safeguards system without requiring the instillation of dedicated safe-guards instrumentation....

The more aburdant and diverse the process data available to the safeguards systtm, the more broadly based its diversion detection capability becomes.

In fact, a process monitoring system that exploits the relationships between a wide variety and a l

large number of process variables may'be able to provide some inherent I

protection against instrument or software tampering."1

(

However, weight cannot be given to this benefit because the concept has yet to be accepted for use in the IAEA safeguards system.

5

,n;

': r 4

By'

! Table 1 Estimated Costs (+) and Savings (-) Anticipated With the MC&A Reform Amendments ($K)

!,,[

Type of Facility Fuel Fab.

Conversion One Time Implementation Costs Labor

+325 to +592

+572 to + 581 Capital Expenditures

+70 to + 83

+88 to + 354 Lost ProdiJction 0

0 TOTAL *

+395 to +675

+660 to + 935 Annual Costs.

FNMC Plan and Operating 5 to 15 10 to 17 Procedures Loss Detection, Response

-140 to -437

-545 to -368 and Physical Inventory Qual,ity Assurance 40 to 133 115 to 166 Defense Against Falsification 40 to 133 60 to 133 TOTAL *

-55 to -156

-302 to -110**

  • The projected savings assume that the facilities would be operating at or near capacity.
    • This total is not a sum of the components because the component extremes woulet not all apply to the same facility.

4.2 Resultr, of Feasibility and Value/ Impact Studies

't Several studies have been performed under NRC contract to assess the feasibility of implementing the MC&A Reform Amendments and to assess the value/ impact implications of shortening detection and response time require-ments.

Results of these studies confirm that the prompt accountability concept is technologically feasible and that significant benefits to MC&A systems could be achieved.

6

5 is

'e Battelle-Pacific Northwest Laboratories (PNL) performed a value/ impact analysis of 12 combinations (including the current requirements) of alternative detection and response times.2 The objective of their study was to provida information that would aid in determining optimal detection and response times.

The alternative detection times they assessed range from a high of 1 week to a low of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Alternative response (conclusive resolution) times vary from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to 3 days.

For purposes of ranking the alternatives, PNL dev, eloped safeguards value criteria that were intended to capture the most, significant safeguards values.

The value criteria included detection capability, retrieval potential, and deterrence value.

Each of the timeliness alternatives was assigned a relative value according to each of the value criteria.

PNL's value assessment of the alternatives shows that all the alternatives provide significant improvement over the status quo in achieving increased timeliness of material loss detection and determination of the cause of an apparent loss.

Among the non-status quo alternatives, safeguards values'were shown to increase with faster detection times, as did costs.

The alternatives that had the highest value/ impact ratios were the alternatives with 3-day detection capabilities.

As reflected in PNL's value assessment, shorter detection times genbrally decrease the probability of successful completion of a theft.

Shorter detection times also increase the probability for resolving the cause of the loss indicator landimprovechancesofmaterialretrievalshouldatheftoccur.

Periods shorter than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (e.g., 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and 4' hours) were eliminated from considsration, not only because of the dramatic increase in cost, but because of the potential harmful effect of the excessive numbers of false alarms that they would cause, some of which could be unresolvable.

The increase in r

cost between 3-day detection and 24-hour detection is about 50 percent.

There is more than a 100 percent increase in echieving an=8-hour detection as compared to a 3-day capability and more than 200 percent cost increase to achieve a 4-hour detection capability.

The 3-day detection capability for highly desir-able SSNM has been adopted in the MC&A Reform Amendments because it reflects,'

the highest value impact ratio and because it will significantly improve safe-guards without imposing what HRC staff consider an economic hardship to the

~

industry.

l t

,r

d Additional studies have subsequently been performed to confirm the feasibility of achieving short detection and response capabilities at all existing facilities as well as at proposed reprocessing facilities.

These studies were performed by Science Applications, Inc. (SAI), NUSAC, Inc., PNL, and Los Alamos National Laboratory (LANL).

SAI performed a study at a small conversion facility to determine the feasibility and cost-benefit of achieving a 24-hour theft detection capability for 5 Fkg of U-235.3 SAI's study showed that existing in process controls in the fuel conversion and fabrication process could be used to achieve material loss detection within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for many simple-diversion paths.

They found that advanced controls also could be designed to achieve timely detection of diversion scenarios involving sophisticated substitution tactics.

A later study by SAI of a large throughput conversion facility concluded that it was feasible for that facility to meet the proposed Reform Amendments, and that the net savings would likely exceed the net costs.4 NUSAC, Inc., performed a parallel study of alternative process monitoring techniques in a high throughput, high enriched uranium scrap recovery facility.s They developed alternatives to reflect varying degrees of sophistication with respect to prompt accountability techniques.

The more sophisticated alternatives achieved faster detection at greater cost.

NUSAC's study showed that the cost of achieving various detection times varied approximately linearly.

PNL and LANL performed analyses of a hypothetical facility having three lines:

UFs conversion, fuel fabrication, and uranium scrap recovery.

Both of these studies demonstrated how such a facility could meet the performance requirements of the Reform Amendments.8'7 These studies have focused considerable attention on the impact of current measurement technique uncertainties, particularly those associated with NDA, on the calculated standard deviation to be associated with the various material control tests.

They have also focused on the implications as to whether or not all of the detection and response capability requirements can be met and what the rate of anticipated unresolved false alarms will be.

One conclusion of these studies has been that current measurement technology is entirely adequate to permit compliance with the Reform Amendments in a practical manner.

The impact on safeguards effectiveness resulting from relaxing physical inventories from bimonthly to semiannually or annually was assessed by Lawrence Livermore National Laboratory (LLNL).s They determined that with prompt accountability in place, lit le degradation in safeguards would occur from 4

8

reducing the number of physical inventories.

Prompt accountability neasares were shown in LLNL's analysis to be effective in preventing and deterring scenarios that physical inventories are incapable of doing.

An.3ng 28 diversion scenarios, only five were negatively affected by the relaxation of inventory frequency, and these were only slightly degraded.

All five of these scenarios involved small quantity diversions well within the 5 formula kilogram capability.

4.3 Results of Cost Estimation Analyses Data developed by NRC contractors and data developed in-house have been analyzed to develop cost estimates for two categories of HEU facilities:

(1) Fuel fabrication facilities - Facilities engaged in the production of fuel assemblies.

Bulk materials are blended and then fabricated into items which subsequently undergo numerous physical transformations.

One of these facilities has an associated scrap recovery capability.

(2) Conversion facilities - Facilities primarily engaged in operations involving the chemical and/or physical transformation of bulk materials into a form suitable to be used in the fabrication of fuel assemblies.

All of these facilities have associated scrap recovery operations, and some also produce the fuel assemblies.

Each facility type underwent a two-step evaluation process to assess (1) any changes to annual operating costs once the Reform Amendments had been implemented and (2) the initial cost to implement the Reform Amendments.

No attempt was made to introduce an amortized implementation expense into the annual operating cost.

l Annual operating costs were evaluated from the viewpoint of the expected difference between the level of effort now being expended by the licensee and the level of effort anticipated to be required under the Reform Amendments.

Estimated cost differentials were based on a judgment of whether the part of the MC&A system under consideration should cost more, the same, or less under the Reform Amendments than it now costs under existing regulations.

Three cost 9

e e

categories were identified.

These are (1) labor costs associated with additional personnel, (2) additional materials and maintenance, and (3) produc-tion opportunity costs.

Production opportunity costs encompass the value of any increase or decrease to production attributable to the Reform Amendments.

One-time implementation costs or "backfitting" costs were evaluated separately for each facility type.

Included were all costs anticipated to be incurred by a licensee in modifying an operation to enable it to operate in compliance with the proposed amendments.

The cost of additional labor to alter practices and procedures, revise Fundamental Nuclear Material Control (FNMC) plans, develop software, perform modeling experiments, and install new equip-ment were evaluated under implementation labor.

The cost of new measurement instruments, hardware to modify the process lines, and augmentation to data handling systems, such as computers and purchased software packages, were included under implementation capital expense.

The possibility of lost production due to downtime required to install and test new equipment and to implement and debug new practices and procedures also was evaluated.

4.3.1 Fuel Fabrication Facilities Analyses of current practices at fuel fabrication facilities reveal that expenditure of labor for item verification programs and for detection and response procedures on a scrap line would change minimally under the proposed amendments.

Annual operating costs will be incurred for application of the loss detection tests, alarm resolution investigations, and the quality assurance requirements.

Maintenance of the FNMC Plan and operating procedures l

is estimated to require $5K to $15K.

This includes procedure revisions required to accommodate changes in operations and lessons learned in test applications.

Tradeoffs will exist in the application of bulk loss tests, item monitoring, alarm resolution, and physical inventory requirements.

The reduction in the number of physical inventories will result in a savings that will more than offset the additional effort needed to meet the prompt detection requirements.

Alarm resolution is expected to require five percent or less of the total time since the licensee should experience few, if any, alarms in the absence of diversion, 10 l

l

e theft, or previously undetected process error.

The annual cost for loss detection, response and physical inventories has been estimated to range from a savings of

$140K to $437K.

Quality assurance, consisting of personnel qualification and training, quality control, and audits is estimated to cost $40K to $133K.

Protection against falsification and deceit was also estimated at $40K to $133K.

Other changes to operating expenses are expected to be minimal.

Depending on factors such as the size of the facility and on whether or not it has a scrap line, the net change in annual operating costs has been estimated to be between -$55K and -$156K.

Implementation labor expense at fuel fabrication facilities was assessed at $325K to $592K divided as follows:

Between $100K and $148K to provide a revised FNMC plan and new operating procedures to meet the Reform Amendments.

Between $75K and $222K to develop and implement a new loss detection and response system in the process areas and, if one exists, in the scrap recovery area.

Between $100K and $148K to implement the various elements of quality assurance and accounting.

Between $50K and $74K for development of MC&A supplements to protect against collusion involving falsification and deceit.

Capital expenses associated with implementation are expected to be minimal and are primarily associated with upgrading the computer system.

Capital expenses are estimated at between $70K and $83K.

i Since no loss of production is expected to result due to the implementation effort, the total implementation or "backfitting" expense (labor plus capital expense) is expected to be $395 to $675K depending on whether or not the facility has a scrap recovery area.

l 11

e d

4.3.2 Conversion Facilities While additional operator and MC&A labor is anticipated to be required to meet the detection and response capabilities of the Reform Amendments for the primarily batch and semi-continuous operations encountered at conversion facilities, it is anticipated that the net annual operating expenses will be reduced at these facilities primarily due to the relaxation in the physical inventory requirement.

The anticipated changes to annual operating expenses have been broken down as follows:

Labor for additional sampling, measurements, chemical analyses, calibrations, data handling, and response activities required to meet the detection and response capabilities $155K to $532K.

Production improvement due to reduction in number of physical inventories and consequent reduction in downtime to perform physical inventories and in quantity of scrap generated preparatory to performing physical inventories.

Also, labor savings due to reduction in number of physical inventories, in LEID calculation effort and in ID reconciliation effort:

$700K to $900K savings.*

Quality assurance, consisting of personnel qualification and training:

$115K to $166K.

Protection against falsification and deceit:

$60K to $133K.

Maintenance of the FNMC Plan and operating procedures:

$10K to $17K.

  • Lost production due to shutdown pending resolution of 5 FKG loss alarms is expected to be negligible because of the low annual likelihood of such alarms.

l 12 I

e Over the range of facilities evaluated, the net change in annual operating costs is anticipated to range from a savings of $110K to $302K per year.

Implementation labor expense at conversion facilities was assessed at

$572K to $581K.

Capital expenses at conversion facilities could be substantial due to the need for improved measurement systems, for modifications to the process to allow adequate sampling and holdup estimation, and for upgrading the data handling systems.

The total value has been estimated at $88K to $354K.

It is not anticipated that there will be any lost production as a result of making modifications and installing equipment.

The total cost of the implementation effort at conversion facilities is therefore expected to be $660 to $935K.

5.0 ADDITIONAL POTENTIAL COST SAVINGS Along with the safeguards benefit that will be realized due to the prompt accountability requirements of the Reform Amendments, there are also significant potential cost savings to be realized after implementation is complete.

One potential cost savings is the labor savings resulting from the relaxation of the physical inventory requirement.

Another is the increased production resulting from both the reduction in downtime required to conduct physical inventories and the reduction in the amount of scrap generated in preparation for physical inventories.

In addition to the costs and savings discussed in the Results section, there are also some subtle and slightly more difficult to evaluate potential savings which should result from utilization of an advanced process monitoring system.

A high throughput LEU fabrication facility has indicated that through the use of such a system, they have been able to reduce their annual variable operating costs by 35 percent.9 The savings came from several sources, most related to the increased accuracy and quick accessibility of their data base.

The computerized system has allowed significant labor savings in the entry, manipulation, and retrieval of data required for the MC&A system as well as for production and quality control.

The computerized system has enabled the LEU facility to reduce its labor requirements per physical inventory by 50 percent.

Increased accuracy and quick accessibility permit error detection during material processing.

Earlier error detection prevents further commingling of 13

e e

"off-spec" material which must eventually be rejected and recovered as. scrap.

The LEU facility also attributes to the computerized process monitoring system savings from reducing their uranium inventory by about 60 percent.

Los Alamos National Laboratory also has a computerized process monitoring system (PFLASS), and they report a savings of a million dollars a year in labor as well as an increase in production of 15-20 percent.20 There are undoubtedly distinguishing characteristics of the current Category I Iicensees that would preclude their achieving such a magnitude of efficiencies (e.g., 35 percent savings in variable costs).

These differences include a much lower throughput and the production of fuel of one enrichment instead of varying enrichments.

However, it seems reasonable to assume that labor reduction in performing MC&A and production control functions due to a computerized system could reduce variable operating costs at these facilities by 5 percent and that efficiencies from earlier detection of errors could reduce costs by 1 percent.

It is recognized that these savings are subject to some uncertainty because of the lack of direct transferability of the experience of one LEU facility to the four subject HEU facilities.

However, one subject HEU facility is in the process of implementing a computerized system for process monitoring as well as for many other purposes.

It is presumed that as a profit-maximizing firm, such a system would not be' implemented without expectation of receiving sufficient economic benefits to offset the capital expense.

l l

i 14

0 e

References

  • 1.

Hurt, R. D., " Process Monitoring Applications to International Safeguards,"

presented at the meeting of Subgroup I of the International Working Group for Reprocessing Plant Safeguards, June 25-26, 1930.

2.

Byers, K. R. and S. W. Heaberlin, "Value-Impact Analysis of Alternatives for Prompt Accountability of SSNM," Draft PNL Report, December 1980.

3.

Glancy J., et al., " Feasibility and Cost / Benefit of Advanced Safeguards for Control of Nuclear Material In-Process," SAI, Inc., NUREG/CR-1686, August 1980.

4.

McDaniel, T.

L., et al., "A Test Application of the NRC Reform Amendments to a Licensed Facility," SAI, Inc., November 1982.

5.

Hawkins, R.

L., et al., "Using Advanced Process Monitoring to Improve Material Control," NUSAC, Inc., NUREG/CR-1676, NUSAC-556, September 1980.

6.

Eggers, R.

F., et al, " Examples of MC&A Systems to Meet Prompt Accountability Specifications," PNL, December 1982.

7.

Stirpe, D., et al., "MC&A Reform Amendments:

Example System Beta, Variance Estimates and Performance Evaluation," LANL, August 1982.

8.

Al-Ayat, R. and B. Judd, "Value-Impact Analysis of Material Control and Accounting Upgrade Rule Alternatives," LLNL, November 1980.

9.

Kaplan, A., General Electric-Wilmington, telephone conversation, February 2, 1981.

10.

Malanify, J.

J., et al., "An Operational Advanced Materials Control and Accountability System," Nuclear Materials Management, Winter 1980.

l l

l l

  • Questions concerning the availability of these documents should be addressed to Dr. W. B. Brown, Office of Nuclear Material Safety and Safeguards, U.S.

l Nuclear Regulatory Commission, Washington, DC 20555, phone (301) 427-4755.

l l

l l

15

J

--~

'N

~

1 4

ENCLOSURE D

DRAFT s

t PUBLIC ANNOUNCEMENT ENCLOSURE D

DRAFT i

NRC AMENDS MATERIAL CONTROL AND ACCOUNTING REGULATIONS FOR CERTAIN FUEL CYCLE FACILITIES The Nuclear Regulatory Commission is strengthening its regulations-for material control and accounting at certain types of fuel facilities by requiring 3

more timely detection of a pc:sible loss of uranium, more conclusive determina-tion of whether material is actually missing, and improved availability of information to help recover the material in case of an actual loss.

.The affected licensees are the operators of four high-enriched uranium processing facilities:

Nuclear Fuel Services, Erwin, Tennessee; GA Technologies, San Diego, California; United Nuclear Corporation, Uncasville Connecticut; and Babcock and Wilcox, Lynchburg, Virginia.

i Under the amended regulations, licensees will use data obtained by in process monitoring of internal transfers, item control, ard material pro-cessing to detect possible losses more quickly.

Ability to resolve discre-pancies and determine whether material is actually missing will be improved by decreasing the area and quantity of material subject to detailed examination, the number of employees potentially involved, and the time between a loss or mistake and its detection and resolution.

The amendments also require affected licensees to establish a system capable of detecting falsification of data to conceal diversion of nuclear material.

They must provide protection against diversion by an employee in any position and against collusion between an individual with material control l

L,

T ORAFT 6

and accounting responsibilities and another individual with responsibilities in both that area and physical security.

A proposed rule on this subject was issued on February 2, 1984.

Changes made as a result of the comments received and details of the final rule are contained in a Federal Register notice published on 3

I i

2

.-.

Retrieved from "https://kanterella.com/w/index.php?title=ML20210T087&oldid=4015468"