Regulatory Guide 5.57

Shipping and Receiving Control of Special Nuclear Material

ML13064A093
Person / Time
Issue date:	06/30/1976
From:	NRC/OSD
To:
References
RG-5.057
Download: ML13064A093 (8)

U.S. NUCLEAR REGULATORY COMMISSIONJune 19 76REGULAT ORY G UID'EOFFICE OF STANDARDS DEVELOPMENTREGULATORY GUIDE 5.57SHIPPING AND RECEIVING CONTROL OFSPECIAL NUCLEAR MATERIALA. INTRODUCTIONSection 70.58 of 10 CFR Part 70, "Special Nuclear Mate a requirescertain licensees authorized to possess at any one time a loca n specialnuclear material (SNM) in quantities exceeding one eff ilogram toestablish, maintain, and follow detailed fundamental ontrol andaccounting procedures for shipping and receiving SThe requirements for packaging and. transp *ng are specified in10 CFR Part 71, "Packaging of Radioactive Mater or ransport and Trans-portation of Radioactive Material Under Ce:n tions," and in theapplicable portions of the regulations a r to the mode of trans-portation in 49 CFR Parts 170-189, 14 C r 03., and 46 CFR Part 146.These requirements are not included' t pe of this guide.Requirements for the physic on of SNM at licensee facilitiesand of material in transit are e ein 10 CFR Part 73, "Physical Pro-tection of Plants and Material" an are the subject of various regulatoryguides issued or under dev m ection 73.30 of Part 73 requires thaturanium-235 (contained in rani i enriched to 20 percent or more in theU-235 isotope), uranium-2 p oniu", or any combination of these materialswhich is 5,000 grams or mo puted by the formula, grams = (grams con-tained U-235) + 2.5 (grams U-233 + grams plutonium), shall be shipped incontainers that sealed by tamper-indicating seals.1Licensees sfer and receive SNM are required under § 70.54 tocomplete F A-741, "Nuclear Material Transaction Report," andsubmit a y N .In addition, paragraph (c) of § 70.42 requires that,Regd uide 5.15, "Security Seals for the Protection and Control ofSpeci& uclear Material," identifies features of security seal systemsand des bes the types of tamper-indicating seals that are acceptableto the NRC staff for tamper-safing SNM.USNRC REGULATORY GUIDES Comments should be sent to the Secretary of the Commission, U.S. NuclearRegulatory Guides are issued to describe and make available to the public Regulatory Commission. Washington, D.C. 20555. Attention: Docketing andmethods acceptable to the NRC staff of implementing specific parts of the Service Section.Commission's regulations, to delineate techniques used by the staff in evalu- The guides are issued in the following ten broad divisions:sting specific problems or postulated accidents, or to provide guidance to appli-cants. Regulatory Guides are not substitutes tar regulations, and compliance 1. Power Reactors 6 Productswith them is not required. Methods and solutions different from those set out in 2. Research and Test Reactors 7 Transportationthe guides will be acceptable if they provide a basis for the findings requisite to 3. Fuels and Materials Facilities 8. Occupational Healththe issuance or continuance of a permit or license by the Commission. 4. Environmental and Siting 8. Antitrust ReviewComments and suggestions for improvements in these guides are encouraged 5. Materials and Plant Protection 10 Generalat all times., and guides will be revised, as appropriate, to accommodate com-ments and to reflect new information or experience. However. comments on Copies of published guides may be obtained by written request indicating thethis guide, if received within about two months after its issuance, will be par divisions desired to the U.S. Nuclear Regulatory Commission. Washington. D.Cticulariy useful in evaluating the need for an early revision. 20555, Attention: Director. Office of Standards Developmen before transferring SNM, the person making the shipment verify that therecipient is authorized to receive the type, form, and quantity of SNM to betransferred. Paragraph (d) of § 70.42 outlines the methods to be used tomake this verification. Further, by mutual arrangement with the carrier andthe receiver, the shipper is required by paragraph (b) of § 73.30 to arrangefor the delivery of the SNM to the receiver's facility at a time when trainedpersonnel are available to properly handle the material received, and under§ 73.36 the shipper and receiver are required to follow certain notificationprocedures.Section 70.57 and paragraph (f) of § 70.58 require that the licensee'smeasurement and control program for SNM must include a means for the controland evaluation of measurement bias and systematic and random errors forall parts of the measurement process, including scales, balances, volumemeasurements, analytical quality control, and sampling.Paragraph (g)(2) of § 70.58 requires that procedures be established toreview and evaluate shipper-receiver differences on an individual containeror lot basis, a shipment basis, and a cumulative basis for shipments of likematerial. Guidelines for performing the evaluation and resolution of shipper-receiver differences are contained in various other regulatory guides thathave been issued or are under development;2 these guidelines are notincluded in the scope of this guide. Any loss of SNM (other than normaloperating loss).must, under § 70.52, be reported to the Director of theappropriate NRC Inspection and Enforcement Regional Office (listed in Appen-dix A of Part 73) by telephone, telegram,, or teletype.This guide describes procedures acceptable to the NRC staff for comply-ing with the Commission's regulations regarding the control of SNM duringshipment and receipt by a licensee.B. DISCUSSIONAdequate control of SNM during transfer between licensees includes(1) physical protection of the material at the licensees' facilities andwhile in transit and (2) the timely, accurate, and independent identifica-tion and measurement of the SNM by both shipper and receiver to determineand evaluate any shipper-receiver differences. These measurements arenecessary to (1) detect the loss or theft of SNM being transferred betweenlicensees, (2) detect and permit correction of clerical or handling errors,(3) detect falsification or errors in the shipment source data, (4) provideassurance that measurement bias is detected and corrected, and (5) detectand prevent the transfer of "material unaccounted for" (MUF) from onelicensee to another.2Regulatory Guide 5.28, "Evaluation of Shipper-Receiver Differences in theTransfer of Special Nuclear Materials," is currently available. A regula-tory guide on the reconciliation of statistically significant shipper-receiver differences is under development.5.57- Where tamper-indicating seals are used, their application to each itemor container by the shipper immediately after sampling or assay and theprompt verification of these seals by the receiver can help ensure theintegrity of the material measured.Initial receiving checks, made immediately after receipt, can determineif loss, theft, or substitution of SNM may have occurred during transfer andcan detect packaging and clerical errors. The checks can include countingthe pieces; identifying and weighing the containers or items received;comparing the results with the same information on a bill of lading, FormNRC/ERDA-741 (Nuclear Material Transaction Report), or other appropriatedocument supplied by the shipper; and, to the extent possible, performing anovercheck of each container by nondestructive analysis or equivalent meansto provide a gross verification of the SNM content.After these initial checks have been made, prompt quantitative verifica-tion of the contents of each container will provide early assurance that thecontents of the packages received are identical to those shipped. Writtenprocedures that call for performing these verifications within specific timelimits after shipment can help ensure that Form NRC/ERDA-741 is filed in atimely fashion. In addition, the validity of both the shipper and receivermeasurements is dependent on the existence of a program of standardizationand calibration of measurement equipment and procedures.Prior coordination between the carrier and receiver can ensure that SNMwill be delivered to the receiver's facility at a time when trained personnelare available to properly handle the material received. This procedure willeliminate the possibility of material arriving during off hours when properreceiving checks or adequate physical security for the material cannot beensured.Appropriate procedures that identify employees who are authorized toship SNM and the responsibilities of the varfious organizational componentsthat have cognizance of the shipment will ensure that all aspects of theshipment are adequately coordinated. The following organizational compo-nents are listed with typical responsibilities as related to the shipment:1. Organizational component that fabricates or assembles material:a. Determine the correct weights of the SNM,b. Obtain appropriate analysis of the SNM,c. Ensure product specifications,d. Provide guidance as to packaging or package material properly asrequired.5.57--3 2. Shipping control:a. Prepare shipping forms,b. Arrange transfer of material to shipping area,c. Ensure proper packaging.3. Security:a. Accompany package to shipping area when appropriate,b. Be cognizant of the storage areas while shipment is in them,c. Guard shipment while it is being loaded,d. Plan and arrange with the dispatcher of the material,e. Obtain signed receipts and pass them on to the appropriatedepartments.4. Traffic (dispatcher):a. Make carrier arrangements,b. Coordinate shipments,c. Prepare bill of lading and other formal shipping papers,d. Notify receivers as to when shipments will be made and approximatetime of scheduled arrival.5. Nuclear materials control*:a. Approve all SNM shipping memos,b. Prepare and transmit NRC/IURA-741 forms,c. Transmit information for computer records, if used,d. Post shipping transactions to control records,e. Investigate and correct shipper-receiver differences.To document the transfer of SI! containing I gram or more c-f containeduranium-235, uranium-233, or plutonium, Form 7RC/ERDA-741 is initiated anddistributed by the shipper promptly after the material is shipped. Normally,the licensee receiving S'NM is required to measure independently its element5 .. 57-4 and isotopic content and complete and distribute Form NRC/ERDA-741 within 10days of receipt of the material. However, if receipt measurements cannot becompleted within 10 days, a licensee may, when authorized by his license,prepare and distribute Form NRC/ERDA-284, "Nuclear Material Transfer Report,"or use Form NRC/ERDA-741 as a temporary receipt record after performing aninitial receiving check to verify that the items, containers, and grossquantities shipped have been received. In such cases, the receiver is thenrequired to complete his measurements and report them on Form NRC/ERDA-741within 30 days of receipt of the shipment. If the material received isscrap or irradiated material that may take longer than 30 days to measure,Form NRC/ERDA-741 is completed and distributed to indicate temporary accep-tance of the shipper's values; at a later date, the receiver prepares anddistributes a "corrected copy" of Form NRC/ERDA-741 that reports the receiver'sown measurements.3C. REGULATORY POSITIONThe following methods are acceptable to the NRC staff for the controlof shipments and receipts of special nuclear material:1. Shippinga. Before shipping SNM, a licensee should ensure that the intendedreceiver is authorized to receive the type, form, and quantity of SNM tobe transferred.b. The element and isotopic content of the material to be shippedshould be measured and associated limits of error determined by a methodwhose validity is ensured by an ongoing quality control program. 'c. The shipper should establish and maintain written procedures thatidentify employees who are authorized to initiate shipment of SNM andidentify the responsibilities of the various departments that should havecognizance of the shipment.d. When shipments are required to be transported in containers thatare sealed by tamper-indicating seals, the shipper should seal all containersor items with the tamper-indicating device immediately after sampling orassaying to ensure the integrity of the material measure.3See § 70.54 of 10 CFR Part 70 and the written instructions entitled "Instruc-tions to NRC and Agreement State Licensees for Reporting Nuclear MaterialTransfers on Form NRC/ERDA-741 -Nuclear Material Transaction Report," U.S.Nuclear Regulatory Commission, July 1976. Copies of the letter may be obtainedfrom the Division of Safeguards, Office of Nuclear Materials Safety andSafeguards, U.S. Nuclear Regulatory Commission, Washington, D.C. 2055 e. Written procedures should be established and maintained toassign specific organizational components responsibility for packaging theshipment and ensuring that it is packaged and transported in accordancewith the provisions of 10 CFR Part 71 and other applicable regulations.f. Organizational components responsible for the shipment withinthe plant and in transit should have a set of written procedures thatcover both normal and emergency conditions.g. Under.§ 73.36(c)(1) the shipper is required to notify the con-signee of the pertinent details of the shipment. The notification shouldinclude the time and method of shipping, the name of the carrier, and theestimated time of arrival at the receiver's facility. In addition, theshipper should notify the receiver of the bill of lading number, the sealnumbers, the gross and net weights, and the element and isotopic contentof each item or container.h. The shipper should initiate and distribute a Nuclear MaterialTransaction Report (Form NRC/ERDA-741) in accordance with the printedinstructions on the form.2. Receiptsa. A licensee should accept rece~ipt of only those types and quanti-ties of SNM authorized by his license. If other material is delivered tohis facility, the licensee should notify the shipper immediately so thatappropriate arrangements can be made for the disposition of the materialand the continuous maintenance of adequate physical protection.b. Arrangements should be made to deliver the material to thereceiver at a time when he has personnel available to properly handle thematerial. If the shipment fails to arrive at the scheduled time, thereceiving licensee is required under § 73.36(e) to notify the shipper sothat a prompt investigation can be initiated.c. As soon as possible, but in no case more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> afterreceipt, the identification and integrity of the shipper's tamper-safingdevices on each item or container should be verified. The piece count andidentification and gross weight of the items or containers received shouldbe checked against the bill of lading, Form NRC/ERDA-741, or other appro-priate shipping document to provide assurance that the shipment was receivedintact. To the extent possible, an overcheck determination by nondestruc-tive analysis (NDA) or other appropriate means should be made to providea prompt estimate of the SNM content of each item or container. After theinitial receiving checks have been performed, the material should be sent5.57-6 to an area where the contents of the containers or items can be verifiedquantitatively. Written procedures should be established and maintainedfor verifying the receipts within specific time limits so that Form NRC/ERDA-741 can be filed within the required time.d. If any of the tamper-safing devices have been disturbed in a waythat may indicate an attempt to render the device inoperable or ifthe device has been accidentally damaged, the following actions should betaken:(1) The affected containers should immediately be resealed withanother tamper-safing device, and the resealing should be witnessed andattested to by the personnel delivering the containers.(2) The containers should be weighed and a determination madeas to whether any of the contents have been removed.(3) If the contents of the containers appear to be in order,the shipper should be notified and given the option of witnessing aquantitative assessment of the containers' contents within 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />sfollowing receipt of the shipment. If the shipper does not respond tothis offer, the contents of the container should be assessed as soon aspossible but in no case later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after receipt.(4) If the contents of the containers appear to have beenremoved, the shipper and the Director of the appropriate NRC Inspec-tion and Enforcement Regional Office listed in Appendix A of 10 CFRPart 73 should be notified and given the option of witnessing a quanti-tative assessment of the containers' contents within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> followingreceipt. If neither responds to this offer, the contents of the containershould be quantitatively assessed immediately and witnessed and attestedto by personnel from at least two different groups within the receiver'sorganization.e. Within the time specified in the instructions for the prepara-tion of Form NRC/ERDA-741, the receiver should make an accurate, precise,and independent measurement of the SNM content of the material received.This measurement should be in accordance with a program for acceptablemeasurement quality as required by paragraph (e) of § 70.58.f. The difference between the amount of SNM stated by the shipperas having been shipped and the amount received as measured by the receivershould be reviewed and evaluated.All measurement discrepancies should be reported to the nuclearmaterial control managers or their alternates, who should personallyverify the discrepancy in the presence of the employee who discoveredthem. Written procedures should quantitatively define what constitutesa discrepancy for each type of SNM received. Appropriate action should5.57-7 be taken to reconcile those shipper-receiver differences that arestatistically significant at the 95% confidence level, except for shipmentsthat involve differences of 50 grams or less of U-235 or plutonium.When a discrepancy is identified, the nuclear material manager shouldresolve the discrepancy with the shipper. If the discrepancy cannot beresolved, the appropriate NRC Inspection and Enforcement Regional Officeshould be notified by telephone, telegram, or teletype.g. Within 10 days of receipt of material, the receiver shouldcomplete and distribute the Form NRC/ERDA-741 prepared by the shipper.When receipt measurements cannot be completed within this 10-day period,the receiver should complete a temporary receipt in one of the followingtwo ways: (1) as indicated in the instructions3 for reporting nuclearmaterial transfers on Form NRC/ERDA-741, complete blocks 17A and 17B ofthe form, note on the form whether the containers, boxes, cases, etc..reported as shipped were received, and mark on the form: "NuclearMaterial Transfer Receipt" or (2) if authorized in the license, prepareForm NRC/ERDA-284, "Nuclear Material Transfer Report," as a temporaryreceipt. In either case, a copy of the original Form NRC/ERDA-741issued by the shipper should then be completed and distributed within 30days of receipt to show the receiver's measurements. However, ifmeasurements of scrap and irradiated material cannot be completed andreported within 30 days of receipt of' material and if a temporaryreceipt has been filed on a Form NRC/ERDA-284 or Form NRC/ERDA-741, thelicensee should complete Form NRC/ERDA-741 accepting the shipper'sweights and file a corrected copy to report his own measurements at alater date.D. IMPLEMENTATIONThis section provides information to applicants and licenseesregarding the NRC staff's plans for using this regulatory guide.This guide consists of a compilation of practices that are currentlyin use and are acceptable to the NRC staff. Therefore, except in thosecases in which the applicant or licensee proposes an acceptable alterna-tive method, the staff will use the method described herein in evaluatingan individual's capability for and performance in complying with specifiedportions of the Commission's regulations until this guide is revised asa result of suggestions from, the public or additional staff review.5.57-8