Number range CHAPTER **NRC INSPECTION MANUAL** DNS/NSIR

TEMPORARY INSTRUCTION 2800/035

VERIFICATION OF LICENSEE RESPONSES TO NRC BULLETIN 2003-04 REGARDING
INVENTORIES OF SOURCE AND SPECIAL NUCLEAR MATERIALS TRACKED IN THE
NUCLEAR MATERIALS MANAGEMENT AND SAFEGUARDS SYSTEM

APPLICABILITY: All U.S. Nuclear Regulatory Commission (NRC) and
Agreement State licensees who have in their possession, or are licensed
to possess, one or more of the following: foreign-obligated natural
uranium, depleted uranium, or thorium; uranium enriched in the isotope
uranium-235; uranium-233; plutonium; or plutonium-238.

2800/035-01 OBJECTIVES

01.01 To physically confirm that the inventories of foreign-obligated
source material and/or special nuclear material possessed by a
representative sample of Nuclear Regulatory Commission (NRC) and/or
Agreement State licensees were appropriately reported and documented in
the Nuclear Materials Management and Safeguards System (NMMSS) in
accordance with NRC Bulletin No. 2003-04, "Rebaselining of Data in the
Nuclear Materials Management and Safeguards System." A copy of this
document is provided in Appendix A of this temporary instruction (TI).

01.02 To obtain other administrative and technical information
concerning the licensee's possession of foreign-obligated source
material and/or special nuclear materials. This objective supports NRC
oversight of the operation of NMMSS.

2800/035-02 BACKGROUND

The Nuclear Materials Management and Safeguards System (NMMSS) is
operated by a contractor on behalf of the U.S. Department of Energy
(DOE) and the Nuclear Regulatory Commission (NRC). NMMSS serves as the
U.S. Government's information system for current and historical data on
the receipt, shipment, and inventory adjustment of certain source and
special nuclear materials. Information related to the possession of
these materials is reported to NMMSS for more than 1,300 accounts that
are held by either DOE-operated or NRC- or Agreement State-licensed
facilities.

NMMSS is also used to provide information to the U.S. Department of
State to satisfy agreements with other nations that require the
accounting of foreign-obligated source material and special nuclear
material imported to and exported from the United States.
Foreign-obligated source material is source material that is tracked by
NMMSS in accordance with treaty or agreement obligations that the United
States has with other nations to treat nuclear materials in a manner
consistent with that treaty or agreement. For example, certain source
material may be sold by or to the United States with the understanding
that the material will only be used for peaceful purposes such as power
generation and not used in a nuclear weapons program.

Approximately 1,000 NRC and Agreement State licensees are required by 10
CFR Parts 40, 72, 74, and 150 to submit reports to NMMSS if they ship,
receive, or adjust their onsite inventories for materials that are equal
to or greater than the quantities shown in the following table:

NMMSS Reportable Quantities

  --------------------------------------- -------------------------------
  **ISOTOPE OR ELEMENT**                  **REPORTABLE QUANTITY**

  Plutonium-238                           0.1 gram

  Plutonium                               1 gram

  Enriched uranium                        1 gram uranium-235

  Uranium-233                             1 gram

  Foreign-obligated thorium               1 kilogram

  Foreign-obligated natural uranium       1 kilogram

  Foreign-obligated depleted uranium      1 kilogram
  --------------------------------------- -------------------------------

In addition, about 170 of these Agreement State and NRC licensees are
required to submit periodic Material balance reports concerning the
quantities of special nuclear material that the licensee has received,
produced, possessed, transferred, consumed, or disposed of. This
additional reporting requirement is based on these licensees'
authorization to possess special nuclear material in a quantity totaling
more than 350 grams of contained uranium-235, uranium-233, or plutonium,
or any combination thereof. NMMSS reconciles these periodic reports to
account for all foreign-obligated source material and special nuclear
material possessed by these licensees.

Recent reviews by DOE and the NRC Offices of the Inspector General
identified concerns regarding the data maintained in NMMSS. For example,
many licensees that possess less than 350 grams of special nuclear
material and whose possession is relatively static are not required to
submit annual reports to NMMSS. As such, there was not an opportunity
previously to confirm the balances listed by NMMSS for such facilities.
The Commission issued a Staff Requirements Memorandum (SRM-02-0093),
which in part directed the staff to improve NMMSS performance and
operations and to strengthen NRC's oversight of the tracking of special
nuclear materials. As part of the response to that SRM, the staff
developed and issued the bulletin in Appendix A. The bulletin requested
affected licensees to perform a one-time reporting of the quantities of
special nuclear material (SNM) and foreign-obligated source material in
their possession.

DOE requires all facilities possessing certain government-owned
materials, including tritium, americium, and californium, to report the
possession of these materials to NMMSS periodically. To support DOE in
its efforts to improve NMMSS performance, the bulletin further requested
any Agreement State or NRC licensee possessing these government-owned
materials to report the possession of these materials to NMMSS as well.
However, there are no NRC regulatory requirements regarding the
reporting of these materials to NMMSS and the possession of these
materials will not be subject to review under this TI.

The TI is to confirm that a representative sample of licensees have
reported their inventories pursuant to the bulletin and to verify that
the NMMSS database correctly reflects the forms and quantities of
foreign-obligated source material and special nuclear material actually
possessed by the licensees. In addition, inspections conducted in
accordance with this TI will verify that certain administrative
information in NMMSS is accurate.

2800/035-03 INSPECTION REQUIREMENTS

03.01 [Scope of Inspection]{.underline}. The inspection described in
this TI will be conducted of selected licensees possessing subject
material. For the purposes of this TI, the term "subject material" is
defined as foreign-obligated source material and SNM licensed by NRC or
an Agreement State that is subject to NMMSS tracking and/or reporting
requirements.

The performance goal associated with the inspection is common defense
and security. However, if health and safety or security findings
involving other NRC-licensed materials are identified, the inspector
should inform the licensee and the cognizant technical point-of-contact
in the NRC Regional office.

The scope of any inspection of an Agreement State licensee conducted by
NRC personnel under this TI will be focused on compliance with NMMSS
reporting requirements. If health and safety issues are identified by
NRC staff during TI inspections of Agreement State licensees, the
inspector should immediately contact the cognizant Agreement State
Radiation Control Program and provide any information regarding the
issues.

**NOTE**: Should an immediate health and safety issue be identified, the
inspector should promptly notify the licensee as well as the responsible
State agency. If you cannot contact the cognizant Agreement State
radiation control staff, you should promptly notify the NRC's Director
of the Office of State and Tribal Programs, and ask that they notify the
cognizant Agreement State. The Agreement State program has the
responsibility for any further inquiry, follow up, or enforcement, if
appropriate. NRC inspectors plan to only cite Agreement State licensees
for violations related to NMMSS reporting requirements in 10 CFR Part
150.

03.02 [Criteria for Selecting Licensees for Inspection]{.underline}. The
Office of Nuclear Security and Incident Response (NSIR) will develop the
list of NRC and Agreement State licensees who are to be inspected under
this TI. NSIR will make the selections with the assistance of the Office
of Nuclear Materials Safety and Safeguards (NMSS) and, when appropriate,
the Office of State and Tribal Programs (OSTP), along with the Agreement
States.

The material accountability programs of licensees that possess more than
350 grams of subject material are evaluated by various NRC Material
Control and Accountability (MC&A) inspection programs. These MC&A
inspections, along with regular reconciliation of the licensee's
material inventory by NMMSS, provide reasonable assurance that such
licensees have adequate procedures to secure and account for subject
material in their possession.

Facilities selected for inspection under this TI will be an NRC or an
Agreement State licensed facility that holds a NMMSS account**.** The
sample selection will be biased toward those eligible licensees who have
little or no contact with NMMSS and/or are not routinely inspected by
the NRC's MC&A inspection program. Within this group, sample selection
will also consider licensees with:

a.  comparatively large quantities of the subject material; and/or,

b.  forms or quantities of subject material that warrant additional
    consideration based on other safety and/or security concerns such as
    suitability for malicious use,

c.  prior escalated enforcement history concerning materials security
    and/or accountability.

Permittees authorized to possess subject material pursuant to the Master
Materials Licenses (MMLs) issued to the U.S. Air Force, the U.S. Navy
and the U.S. Department of Veterans Affairs will also be considered for
inspection under this TI. Other licensees may also be selected for
inspections under this TI.

03.03 [Inspection Planning and Preparation]{.underline}. Using the
criteria described above, NSIR staff will prepare a list of licensees
selected for inspection under this TI. This list will include the
licensee's reporting identification symbol (RIS). The RIS is a
facility-specific three-digit code used to identify the facility in the
NMMSS database. The responsible inspection staff will be provided with
this list of selected inspections. For the inspections conducted by
inspectors from the NRC regional offices, the list of selected
inspections shall be provided to the responsible regional Division of
Nuclear Material Safety.

NMMSS tracks quantities of subject material by material type (MT) and
does not track licensee inventories of subject material down to the item
level. For example, NMMSS cannot provide information regarding the model
number and serial number of devices or sources containing subject
material. In preparing for the inspection, the inspector should sum the
masses for each MT reported by NMMSS, and be prepared to do the same
during the inspection when examining the licensee's inventory records.
The table below lists the MT codes for subject material.

  ----------------------------------------------------- -----------------
  **MATERIAL TYPE**                                     **MT CODE**

  Foreign-obligated depleted uranium\*                  MT 10

  Enriched uranium                                      MT 20

  Plutonium                                             MT 50

  Uranium 233                                           MT 70

  Foreign-obligated normal uranium\*                    MT 81

  Plutonium 238                                         MT 83\*\*

  Foreign-obligated thorium\*                           MT 88

  Uranium in cascade                                    MT 89
  ----------------------------------------------------- -----------------

\* Only foreign-obligated source material is subject to the bulletin and
this TI

\*\* Plutonium that is more than 10% Pu^238^ of total Pu by weight is
reported as Pu^238^

In preparing for each inspection, inspectors should obtain a summary of
the subject material listed in the licensee's NMMSS account for
comparison with the licensee's own inventory records. NRC inspectors
shall contact the NMMSS contractor (telephone 770-662-8110, ext 116), a
minimum of 21 calendar days prior to the start of the inspection. The
inspector should provide the NMMSS contractor with the RIS of the
selected licensee and request a "Task 8 inspection package" to obtain
the necessary information regarding the licensee's possession of subject
material.

A Task 8 inspection package will contain the following documents:

-   A copy of DOE/NRC Form 742, "Material Balance Report," prepared by
    the licensee, summarizing the quantities of subject materials, by
    material type, possessed by the licensee. The information in this
    report will have been subjected to the one-time reconciliation
    completed by the NMMSS contractor in response to Bulletin No.
    2003-04 (Appendix A).

-   The TJ-45 report, prepared by the NMMSS contractor, listing each of
    the licensee's account transactions resulting from the reported
    receipt or transfer of subject material since the reconciliation.

-   The D-3 report listing the identifying and administrative
    information for the particular NMMSS account holder.

NRC region-based inspectors planning an inspection pursuant to this TI
should obtain an inspection report number in accordance with their
region's procedures. Headquarters-based inspectors should contact NSIR
PMDA personnel to obtain an inspection report number. Prior to the
inspection, inspectors shall e-mail the inspection report number and the
planned date of inspection to the individuals designated in the CONTACTS
section of this TI.

Inspectors shall announce each inspection conducted under this TI to
ensure that cognizant licensee personnel are available. Inspectors will
verify contact information and make the necessary arrangements to visit
the licensees' facilities. The cognizant Agreement State radiation
control program office must be notified a minimum of 21 days prior to
the scheduled inspection date of an Agreement State licensee.

Inspectors are cautioned that at a minimum, NMMSS data is
Sensitive-Unclassified Official Use Only (OUO) information. Since it
will generally be necessary to take NMMSS data on the inspection,
inspectors must be familiar with, and comply with, the OUO information
storage and handling requirements specified in NRC Management Directive
(MD) 12.6, "NRC Sensitive Unclassified Information Security Program."
Any losses or compromise of OUO data must be reported to the NRC's
Division of Facility Security in accordance with MD 12.6. Inspectors
must also be cautious with regard to handling licensee information that
may be classified, sensitive, or proprietary. For more information,
contact the appropriate regional or NSIR security advisor, or refer to
the security services Web page,
http://www.internal.nrc.gov/ADM/DFS/dfs.html.

2800/035-04 INSPECTION GUIDANCE

04.01 [Initial Meeting with Licensee]{.underline}. The initial contact
may be made with the licensee's Radiation Safety Officer or other
responsible individual. Notify senior licensee management and offer an
abbreviated entrance meeting (face-to-face or by telephone). Explain the
objectives and scope of the inspection.

Review the regulatory requirements for NMMSS reporting and the bulletin
with responsible licensee technical staff. Review the licensee's
response to the bulletin.

Discuss the location of all subject material possessed by the licensee.
Obtain and review the most recent record of physical inventory performed
by the licensee and compare it with the information documented in the
licensee's NMMSS account on the DOE/NRC Form 742, "Material Balance
Report," provided by the NMMSS contractor. The licensee's records should
document any receipt or transfer of subject material that occurred
subsequently to the most recent filing of the Form 742 in the TJ-45
report.

04.02 [Inventory Verification]{.underline}. Verify the information
listed on the licensee's inventory record by walking down the licensee's
facility and (if practicable) visually identifying each item listed on
the licensee's inventory. If appropriate, verify the presence of the
subject material with a radiation survey instrument. The intent of the
measurement is to verify the presence of radioactive material rather
than to determine the quantity of material present. The inspector should
not ask licensee personnel to open any container or otherwise change the
container's shielding to facilitate this survey.

During the walk down, examine the physical condition of devices and/or
containers containing subject material. Evaluate the effectiveness of
the licensee's procedures for secure storage and handling of subject
materials. Discuss the licensee maintenance of devices containing
subject material, including leak tests, and verify that the licensee is
performing maintenance as required. Determine if the posting and
labeling of subject material are adequate.

Review licensee records documenting the receipt, transfer, and disposal
of subject materials. Compare these records with the TJ-45 report data
provided by the NMMSS contractor. Evaluate the effectiveness of licensee
procedures for updating inventory records as the result of these types
of transactions and document any apparent discrepancies.

If the licensee is no longer actively conducting a principal activity
using the subject material and has no intent to resume that principal
activity in the future, review the requirements for timely
decommissioning, specified in 10 CFR 40.42(d) and 10 CFR 70.38(d). If
the licensee notes that it has nuclear material that it no longer needs
or wants and asks for guidance for disposition, document this issue in
the inspection findings. The technical points of contact for the TI will
then ensure that the DOE contact information for retrieval of
government-owned nuclear material is provided to the licensee.

Should an NRC inspector be inspecting an Agreement State licensee, the
inspector should be familiar with the comparable provisions of the
Agreement State's regulations regarding timely and effective
decommissioning. The inspector should refer the licensee to the
cognizant State radiation control program office regarding additional
information about these requirements. **NOTE**: inspectors need not be
experts on an Agreement State's regulations, but rather should have a
minimum amount of high-level information and be able to inform an
Agreement State licensee that a requirement does exist and whom the
licensee should contact for further information.

NRC staff inspecting NRC licensees, consistent with the guidance in
Inspection Manual Chapter 2800, "Materials Inspection Program" (IMC
2800), should discuss any observed NMMSS discrepancies with licensee
personnel and document any potential violations appropriately.

If the licensee possesses the subject material in sufficient quantity to
be subject to NMMSS requirements and has not reported the material, or
if discrepancies exist between the licensee's inventory records and the
NMMSS-generated inventory, licensee personnel should be encouraged to
promptly contact the NMMSS operator by telephone (770-662-8110, ext.
116) and either report their holdings pursuant to Bulletin 2003-04 or
correct their physical holding by submitting appropriate records.

Any licensee that does not currently possess any subject material and
that has not made any report in accordance with the bulletin should be
encouraged to submit a written statement to the NRC as soon as possible
providing the information specified in the bulletin.

04.03 [Determine the Location of Unaccounted-for Subject
Material]{.underline}. The licensee is responsible for ensuring adequate
security and accountability for subject material. If the licensee cannot
account for subject material, the inspector should review any available
history (e.g., leak tests, inventory records, utilization logs).
Determine the areas where subject materials may have been used or
stored. Interview licensee personnel who may remember using or storing
subject material. For the purposes of this TI, unaccounted-for material
involves only subject material that the licensee believed to be on the
site.

If unaccounted-for subject material may be on the site, discuss what
actions the licensee may take to search for the material. Examine areas
where the licensee stores surplus material and equipment to decide if
the licensee does, in fact, still possess the unaccounted-for material.

If the licensee shipped unaccounted-for subject material without proper
documentation, discuss what actions the licensee plans to take to
determine the location of the material and, if possible and appropriate,
to retrieve the material. The ability to retrieve the material will
depend on the date of the transfer, the purpose of the transfer (sale,
transfer of surplus, disposal), the business of the transferee, and the
availability of information.

If the licensee transferred subject material to a person not authorized
to possess or use the material, obtain as much information as possible
regarding the name and location of the transferee, as well as contact
information for any individuals (e.g., licensee personnel, transport
personnel) who would have knowledge of the transferred subject material.

In any case involving unaccounted-for subject material, immediately
contact responsible NRC Regional management and the NMMSS Headquarters
points-of-contact listed on page 10. Concurrently, apprize licensee
management and remind them of the licensee's responsibility to
immediately notify the NRC or the cognizant Agreement State of lost or
stolen nuclear material in accordance with 10 CFR 20.2011 or equivalent
Agreement State regulations. Collect sufficient information to support
potential short-term NRC regulatory actions, such as the preparation of
a confirmatory action letter or an order, and potential longer term
escalated enforcement actions.

The inspector shall report the unaccounted-for subject materials to the
Nuclear Materials Events Database (NMED). Instructions for a ‟complete"
record are provided in IMC 2800, Enclosure 6. Because this TI instructs
an inspector to profile the subject records in ADAMS as ‟not publicly
available," the regional office must forward paper copies of documents
regarding unaccounted-for materials to the NMED contractor and the NMED
Project Coordinator.

04.04 [Review of Other Administrative Information]{.underline}. Since
inspections and other face-to-face meetings with many licensees are
infrequent, review administrative information listed in the
NMMSS-provided D-3 report with licensee personnel to ensure that the
information is up to date. This information includes, but is not be
limited to,

-   mailing address

-   physical or shipping address (for transmitting information via
    nonpostal methods that cannot use a post office box)

-   telephone number, FAX number, and e-mail address for primary
    technical point of contact

-   telephone number, fax number, and e-mail address for primary
    management point of contact

-   the license numbers of NRC or Agreement State licenses that
    authorize the possession of subject material

Advise the licensee to ask the NMMSS contractor to make any necessary
changes to the licensee's administrative information regarding its NMMSS
account.

2800/035-05 INSPECTION DOCUMENTATION AND REPORTING REQUIREMENTS

Inspections conducted under this TI are to be documented in accordance
with the guidance in IMC 2800. To streamline the documentation of
inspection findings, NRC and Agreement State inspectors record the
findings in accordance with the guidance in IMC 2800 for NRC Form 591M,
"Safety Inspection Report," provided as Appendix B to the TI. In
addition, inspectors should use the NMMSS Verification Inspection
Documentation Form, Parts 1 and 2 in Appendix C to this TI, to record
specific inspection findings regarding the licensees inventory. The
exercise of enforcement discretion should be also be documented in item
6, Part 2 of Appendix C.

**NOTE**: List the serial numbers and activity of any sealed sources
possessed by the licensee containing one curie or more of plutonium 238
or plutonium 239 in Part 2 of Appendix C to this TI.

The dates and results of inspection will be recorded in the Licensing
Tracking System (LTS). Inspections conducted in accordance with this TI
will not impact the due date of the next routine inspection unless
inspection findings (for example, resulting in escalated enforcement)
specifically warrant a change.

Since inspection findings and much of the data used in the this
inspection is "Business Proprietary" or "Sensitive-Unclassified Official
Use Only," inspectors must protect inspection documentation and ensure
that inspection results will be placed in ADAMS as "non publically
available" documents. ADAMS accession numbers for documents describing
all inspection results (such as completed NRC Form 591M's or enforcement
letters) will be provided to the cognizant headquarters or regional
licensing office or Agreement State. Inspectors are strongly encouraged
to document inspection results electronically to simplify archiving and
allow text searches of inspection findings. Electronic copies of the
completed inspection documentation will also be forwarded to the
individuals identified in Section 2800/035-07, "CONTACTS," in this TI.
Electronic copies of the completed Appendix C shall be provided to the
Office of Enforcement.

2800/035-06 COMPLETION SCHEDULE

The goal is for initial inspections to be completed within 1 year of the
effective date of this TI. Any required follow up inspections should be
completed within 1 year of the initial TI inspection.

2800/035-07 EXPIRATION

This TI will remain in effect until all sites identified in the site
list have been inspected and the follow up inspections have been
completed.

2800/035-08 CONTACTS

Please contact one of the following individuals regarding any questions
you may have concerning this TI.

> Larry C. Harris
>
> Fuel Cycle and Special Security Programs Section
>
> Division of Nuclear Safety
>
> Office of Nuclear Security and Incident Response
>
> Telephone number: (301) 415-5072
>
> Mail stop: T4D8
>
> E-mail: lch1@nrc.gov
>
> Brian G. Horn
>
> Fuel Cycle and Special Security Programs Section
>
> Division of Nuclear Safety
>
> Office of Nuclear Security and Incident Response
>
> Telephone number: (301) 415-8128
>
> Mail stop: T4D8
>
> E-mail: bgh1@nrc.gov
>
> John M. Pelchat
>
> Fuel Cycle and Special Security Programs Section
>
> Division of Nuclear Safety
>
> Office of Nuclear Security and Incident Response
>
> Telephone number: (404) 562-4729
>
> Mail stop: Region II
>
> E-mail: jmp2@nrc.gov

2800/035-09 STATISTICAL DATA REPORTING

Time spent in implementing this TI should be charged to TI 2800-035.

2800/035-10 ORIGINATING ORGANIZATION INFORMATION

10.01 [Organizational Responsibility]{.underline}. The Fuel Cycle and
Special Security Programs Section, Division of Nuclear Safety, Officer
of Nuclear Security and Incident Response, initiated this TI. The
development of this TI was coordinated with the Rulemaking and Guidance
Branch, Division of Industrial and Nuclear Materials Safety, Office of
Nuclear Materials Safety and Safeguards, and the Office of Nuclear
Reactor Regulation.

10.02 [Resource Estimate]{.underline}. The average inspection time per
site is expected to be approximately 10 hours. This estimate includes
preparation, onsite time, closeout, and travel. If the implementation of
this TI is integrated into a routine scheduled inspection, it is
expected that the requirements of this TI will require an additional 2
hours to complete. Inspections at specific sites may require
substantially more or less time, depending on the circumstances.

10.03 [Other]{.underline}. None.

10.04 [Training]{.underline}. Inspectors who have received NMMSS
training on reporting requirements and the format of NMMSS-produced
inventory reports and who qualified under IMC 1246, "Inspector
Qualifications," are required to complete the inspection. It is
anticipated that specific training will be provided by NSIR staff either
by conducting training sessions in each of the three NRC regional
offices that perform material inspections or via video tele-conference.
It is expected that the training will take less than three hours.

Inspectors completing the training will be familiar with the purpose and
function of NMMSS, the bulletin, and the TI for assessing licensee
responses to the bulletin. Inspectors will also be familiar with the
format and content of NMMSS records that will be used during the
inspection as part of the inventory verification process and with
expectations regarding the documentation of inspection results.

END

Attachments:

A. NRC BULLETIN 2003-04: Rebaselining of Data in the Nuclear Materials
Management and Safeguards System

B. Safety Inspection Report and Compliance Inspection Form (NRC Form
591M Parts 1 - 3)

C. NMMSS Verification Inspection Documentation - Parts 1 and 2

Attachment A

NRC BULLETIN 2003-04

Rebaselining of Data in the Nuclear Materials Management and Safeguards
System

PAGE INTENTIONALLY BLANK

UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS

OFFICE OF NUCLEAR REACTOR REGULATION

Washington, D.C. 20555-0001

October 8, 2003

> NRC BULLETIN 2003-04: REBASELINING OF DATA IN THE NUCLEAR MATERIALS
> MANAGEMENT AND SAFEGUARDS SYSTEM

Addressees

All U.S. Nuclear Regulatory Commission (NRC) licensees, Agreement State
licensees, and Certificate Holders (hereafter referred to as licensees)
who:

-   Have in their possession, or are licensed to possess, one or more of
    the following: foreign obligated natural uranium, depleted uranium,
    or thorium; uranium enriched in the isotope U-235, U-233, plutonium,
    plutonium-238, or who currently have unreconciled nuclear material
    balances with the Nuclear Materials Management and Safeguards System
    (NMMSS).

Purpose

NRC is issuing this bulletin to:

-   Notify licensees about performance concerns associated with their
    reporting data to, and the resulting material balances contained in,
    the NMMSS database;

-   Request affected licensees to perform a one-time reporting of the
    quantities of special nuclear material (SNM) and/or foreign
    obligated source material in their possession, specified as:

> \(a\) A quantity of SNM defined by 10 CFR 72.76, 72.78, 74.15, and
> 150.16, as 1 gram or more of contained uranium-235, uranium-233,
> plutonium, or 0.1 gram or more plutonium-238 that is greater than 10
> percent of the total plutonium by weight; or
>
> \(b\) A quantity of foreign obligated source material (i.e., natural
> uranium, depleted uranium, or thorium) defined by 10 CFR 40.64 and
> 150.17 as 1 kilogram or more.

\(iii\) Request affected licensees to perform a one-time reporting of
the quantities of other types of Government-owned materials, specified
as any quantity of deuterium, tritium, curium, americium, neptunium,
californium, berkelium, or enriched lithium in their possession
(hereafter referred to as other Government-owned materials);

\(iv\) Request affected licensees to submit the results of this one-time
reporting of the balances of the requested material types directly to
NMMSS, as described in NUREG/BR - 0006 or 0007 and NMMSS Report D-24, as
referenced in 10 CFR 40.64, 72.76, 72.78, 74.13, 74.15, 150.16, and
150.17, and to coordinate with NMMSS staff, the resolution of any
discrepancies that become evident, based on a comparison of the results
of the one- time reporting and previously existing licensee nuclear
material balances.

Background/Discussion

NMMSS is the U.S. national database used jointly by the U.S. Department
of Energy (DOE) and NRC for tracking certain nuclear materials and other
Government-owned materials. A DOE contractor maintains NMMSS for both
agencies. A recent audit report by the DOE Office of Inspector General
found that DOE could not fully account for Government-owned materials
and nuclear materials loaned or leased to domestic licensees, based on
information contained in the NMMSS database. (This report is available
through the Internet at http://www.ig.doe.gov/pdf/ig-0529.pdf) NRC
believes that until NMMSS balances are confirmed on the basis of an
accurate one-time reporting of the requested inventory data, NMMSS
cannot be considered a useful tool to monitor nuclear material holdings
at licensee sites.

NRC's objective is to confirm that the licensee inventories and the
NMMSS database records are in agreement for SNM and foreign-obligated
source material. NRC regulations contained in 10 CFR 40.64, 72.76,
72.78, 74.13, 74.15, 150.16, and 150.17 require licensees to report
material transfers and inventory adjustments to NMMSS. Presently,
licensees that are not required to report their physical inventories of
source material and SNM to NMMSS do not have a way to reconcile their
inventory information with the NMMSS database. In these cases, the
quantities and types of source, SNM, and Government-owned materials in
NMMSS represent only "book" values that change over time, depending on
the details contained in material transfer reports which the licensees
are required to submit when nuclear material is moved from one site to
another, or when an inventory adjustment occurs at the licensees' site.

Ascertaining the actual locations and quantities of nuclear material
licensees possess through a one-time reporting of inventory holdings,
and identifying and resolving obvious NMMSS database discrepancies, are
the first steps toward eliminating anomalous balances and restoring
credibility to NMMSS account balances.

Once the licensees' inventory values are submitted to NMMSS, the NMMSS
staff will compare the reported information to the NMMSS book values.
Where discrepancies are identified, NMMSS staff will attempt to resolve
them by examining existing NMMSS records and assisting licensees to
correct errors that may have occurred. Discrepancies that cannot be
resolved readily, in contacts between NMMSS staff and licensees, may be
referred to NRC, which will take further steps to resolve the
discrepancies.

Requested Action

Within 90 days of the date of this bulletin, and preferably, as soon as
is reasonably achievable, affected licensees are requested to report
their possessed quantities of nuclear materials of the types specified
above. Typically, such listings may be the result of the most recent
physical inventory or book values. Licensees should report these
quantities as stipulated in NUREG/BR-0006 or 0007 and NMMSS Report D-24,
which are referenced in 10CFR 40.64, 72.76, 72.78, 74.13, 74.15, 150.16,
and 150.17. Licensees should ensure that their onsite material balances
are accurately reflected in the NMMSS database. Copies of NUREG/BR-0006
and 0007 may be obtained from NRC's web site at
http://www.nrc.gov/reading-rm/doc-collections/nuregs/brochures/, or by
contacting the technical contacts, listed below, in the Office of
Nuclear Security and Incident Response, Division of Nuclear Security,
Washington, DC 20555-0001.

Licensees reporting other types of Government-owned materials, specified
as any quantity of deuterium, tritium, curium, americium, neptunium,
californium, berkelium, or enriched lithium, should contact Mr. Kelly
Coady at DOE (301) 903-1360 or kelly.coady@hq.doe.gov) for guidance.

Addressees that do not currently possess any amounts of the types of
nuclear material to be reported should report this in the format
described in NUREG/BR - 0007. Addressees that believe this request is
not applicable to them or who cannot meet the requested submission date
are requested to submit a written response to that effect, by regular
mail, to: U.S. Nuclear Regulatory Commission, Attn. Larry Harris, Mail
stop T-4-D-8, Washington, DC 20555-0001. Such response should include
the licensee's name and address, as described in the specific license,
and the licensee's reporting identification symbol (RIS) code, normally
used for submitting electronic reports to the NMMSS database, and a
statement of why it is not responding in a manner consistent with this
bulletin.

Federal Register Notification

A notice of opportunity for public comment on this bulletin was not
published in the Federal Register because NRC is requesting information
from affected licensees, on an expedited basis, to assess compliance
with applicable regulatory requirements. The information is time
sensitive, since it is for the purpose of confirming that NMMSS records
accurately reflect licensee inventory holdings.

Paperwork Reduction Act Statement

This Bulletin contains information collection requirements that are
subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501, et
seq.). These information collections were approved by the Office of
Management and Budget (OMB), approval number 3150-0011, which expires
January 31, 2004.

The burden to the public for these mandatory information collections is
estimated to average six hours per response. This time includes the time
for reviewing instructions, searching existing data sources, gathering
the data needed, and completing and reviewing the information
collection. Send comments about this burden estimate or any other aspect
of these information collections, including suggestions for reducing the
burden, to the Records Management Branch (T-5F52), U.S. Nuclear
Regulatory Commission, Washington, D.C. 20555-0001, or by Internet
e-mail to INFOCOLLECTS@NRC.GOV; and to the Desk Officer, Office of
Information and Regulatory Affairs, NEOB-10202 (3150-0011), Office of
Management and Budget, Washington, D.C. 20503.

Public Protection Notification

NRC may not conduct nor sponsor, and a person is not required to respond
to, an information collection, unless the requesting document displays a
currently valid OMB control number. Small Business Regulatory
Enforcement Fairness Act NRC has determined that this action is not
subject to the Small Business Regulatory Enforcement Fairness Act of
1996.

If you have any questions about this matter, please contact the
technical contacts listed below.

> /RA/ /RA/

Bruce A. Boger, Director Charles L. Miller, Director

Division of Inspection Program Management Division of Industrial and

Office of Nuclear Reactor Regulation Medical Nuclear Safety

> Office of Nuclear Material Safety and Safeguards

Technical Contacts: Larry Harris, NSIR Brian Horn, NSIR

E-mail: nmmss@nrc.gov E-mail: nmmss@nrc.gov

Attachment B

Safety Inspection Report and Compliance Inspection

Form

(NRC Form 591M Parts 1 - 3)

PAGE INTENTIONALLY BLANK

<table>
<colgroup>
<col style="width: 2%" />
<col style="width: 3%" />
<col style="width: 3%" />
<col style="width: 8%" />
<col style="width: 6%" />
<col style="width: 8%" />
<col style="width: 1%" />
<col style="width: 12%" />
<col style="width: 2%" />
<col style="width: 2%" />
<col style="width: 1%" />
<col style="width: 12%" />
<col style="width: 2%" />
<col style="width: 2%" />
<col style="width: 16%" />
<col style="width: 10%" />
<col style="width: 2%" />
</colgroup>
<tbody>
<tr class="odd">
<td colspan="5"><p><strong>NRC FORM 591M PART 1</strong></p>
<p>(10-2003)</p>
<p>10 CFR 2.201</p></td>
<td colspan="7"></td>
<td colspan="5"><strong>U.S. NUCLEAR REGULATORY COMMISSION</strong></td>
</tr>
<tr class="even">
<td colspan="17"><strong>SAFETY INSPECTION REPORT AND COMPLIANCE
INSPECTION</strong></td>
</tr>
<tr class="odd">
<td colspan="9">1. LICENSEE/LOCATION INSPECTED:</td>
<td colspan="8">2. NRC/REGIONAL OFFICE</td>
</tr>
<tr class="even">
<td></td>
<td colspan="7"><p><strong>[Licensee]</strong></p>
<p><strong>[Licensee Address 1]</strong></p>
<p><strong>[Licensee Address 2]</strong></p></td>
<td></td>
<td rowspan="2"></td>
<td colspan="6" rowspan="2"><p><strong>US NUCLEAR REGULATORY
COMMISSION</strong></p>
<p><strong>[Regional Office] or [NSIR}</strong></p></td>
<td rowspan="2"></td>
</tr>
<tr class="odd">
<td colspan="4">REPORT NUMBER(S)</td>
<td colspan="4"><strong>[Report No.]</strong></td>
<td></td>
</tr>
<tr class="even">
<td colspan="6">3. DOCKET NUMBER(S)</td>
<td colspan="7">4. LICENSEE NUMBER(S)</td>
<td colspan="4">5. DATE(S) OF INSPECTION</td>
</tr>
<tr class="odd">
<td></td>
<td colspan="5"><strong>[Docket No.]</strong></td>
<td></td>
<td colspan="6"><strong>[License No.]</strong></td>
<td></td>
<td colspan="3"><strong>[Date of Inspection]</strong></td>
</tr>
<tr class="even">
<td colspan="17"><strong>LICENSEE:</strong></td>
</tr>
<tr class="odd">
<td colspan="17">The inspection was an examination of the activities
conducted under your license as they relate to radiation safety and to
compliance with the Nuclear Regulatory Commission (NRC) rules and
regulations and the conditions of your license. The inspection consisted
of selective examinations of procedures and representative records,
interviews with personnel, and observations by the inspector. The
inspection findings are as follows:</td>
</tr>
<tr class="even">
<td colspan="2">G</td>
<td colspan="15">1. Based on the inspection findings, no violations were
identified.</td>
</tr>
<tr class="odd">
<td colspan="17"></td>
</tr>
<tr class="even">
<td colspan="2">G</td>
<td colspan="15">2. Previous violation(s) closed.</td>
</tr>
<tr class="odd">
<td colspan="17"></td>
</tr>
<tr class="even">
<td colspan="2">G</td>
<td colspan="15" rowspan="2">3. The violation(s), specifically described
to you by the inspector as non-cited violations, are not being cited
because they were self-identified, non-repetitive, and corrective action
was or is being taken, and the remaining criteria in the NRC Enforcement
Policy, NUREG-1600, to exercise discretion, were satisfied.</td>
</tr>
<tr class="odd">
<td colspan="2"></td>
</tr>
<tr class="even">
<td colspan="3" rowspan="5"></td>
<td></td>
<td colspan="13">Non-Cited Violation(s) was/were discussed involving the
following requirement(s) and Corrective Action(s):</td>
</tr>
<tr class="odd">
<td colspan="13"></td>
<td></td>
</tr>
<tr class="even">
<td colspan="13" rowspan="2"></td>
<td rowspan="3"></td>
</tr>
<tr class="odd">
</tr>
<tr class="even">
<td colspan="13"></td>
</tr>
<tr class="odd">
<td colspan="2">G</td>
<td colspan="15" rowspan="2">4. During this inspection certain of your
activities, as described below and/or attached, were in violation of NRC
requirements and are being cited. This form is a NOTICE OF VIOLATION,
which may be subject to posting in accordance with 10 CFR 19.11.</td>
</tr>
<tr class="even">
<td colspan="2"></td>
</tr>
<tr class="odd">
<td colspan="3"></td>
<td colspan="13"></td>
<td></td>
</tr>
<tr class="even">
<td colspan="17"><strong>Licensee’s Statement of Corrective Actions for
Item 4, above</strong>.</td>
</tr>
<tr class="odd">
<td colspan="17">I hereby state that, within 30 days, the actions
described by me to the inspector will be taken to correct the violations
identified. This statement of corrective actions is made in accordance
with the requirements of 10 CFR 2.201 (corrective steps already taken,
corrective steps which will be taken, date when full compliance will be
achieved). I understand that no further written response to NRC will be
required, unless specifically requested.</td>
</tr>
<tr class="even">
<td colspan="4">Title</td>
<td colspan="7">Printed Name</td>
<td colspan="4">Signature</td>
<td colspan="2">Date</td>
</tr>
<tr class="odd">
<td colspan="4" rowspan="2">LICENSEE’S REPRESENTATIVE</td>
<td colspan="7" rowspan="2"></td>
<td colspan="4" rowspan="2"></td>
<td colspan="2" rowspan="2"></td>
</tr>
<tr class="even">
</tr>
<tr class="odd">
<td colspan="4" rowspan="2">NRC INSPECTOR</td>
<td colspan="7" rowspan="2"><strong>[Inspector]</strong></td>
<td colspan="4" rowspan="2"></td>
<td colspan="2" rowspan="2"></td>
</tr>
<tr class="even">
</tr>
</tbody>
</table>

> NRC FORM 591M PART 1 (10-2003)

<table>
<colgroup>
<col style="width: 2%" />
<col style="width: 2%" />
<col style="width: 9%" />
<col style="width: 8%" />
<col style="width: 10%" />
<col style="width: 1%" />
<col style="width: 14%" />
<col style="width: 17%" />
<col style="width: 3%" />
<col style="width: 1%" />
<col style="width: 25%" />
<col style="width: 2%" />
</colgroup>
<tbody>
<tr class="odd">
<td colspan="4"><p><strong>NRC FORM 591M PART 2</strong></p>
<p>(10-2003)</p>
<p>10 CFR 2.201</p></td>
<td colspan="4"></td>
<td colspan="4"><strong>U.S. NUCLEAR REGULATORY COMMISSION</strong></td>
</tr>
<tr class="even">
<td colspan="12"><p><strong>SAFETY INSPECTION REPORT</strong></p>
<p><strong>AND COMPLIANCE INSPECTION</strong></p></td>
</tr>
<tr class="odd">
<td colspan="7">1. LICENSEE</td>
<td colspan="5">2. NRC/REGIONAL OFFICE</td>
</tr>
<tr class="even">
<td></td>
<td colspan="6"><strong>[Licensee]</strong></td>
<td colspan="5" rowspan="2"><strong>Region I</strong></td>
</tr>
<tr class="odd">
<td colspan="3">REPORT</td>
<td colspan="4"></td>
</tr>
<tr class="even">
<td colspan="5">3. DOCKET NUMBER(S)</td>
<td colspan="4">4. LICENSE NUMBER(S)</td>
<td colspan="3">5. DATE(S) OF INSPECTION</td>
</tr>
<tr class="odd">
<td></td>
<td colspan="4"><strong>[Docket No.]</strong></td>
<td></td>
<td colspan="3"><strong>[License No.]</strong></td>
<td></td>
<td colspan="2"></td>
</tr>
<tr class="even">
<td colspan="12"></td>
</tr>
<tr class="odd">
<td colspan="2"></td>
<td colspan="9">(Continued)</td>
<td></td>
</tr>
<tr class="even">
<td colspan="2"></td>
<td colspan="9"></td>
<td></td>
</tr>
<tr class="odd">
<td colspan="12"></td>
</tr>
</tbody>
</table>

NRC FORM 591M PART 2 (10-2003)

+------------+----------+---+----------+-------+---+---+-----------------+
| **NRC FORM |          |   |          |       | * |   |                 |
| 591M PART  |          |   |          |       | * |   |                 |
| 3**        |          |   |          |       | U |   |                 |
|            |          |   |          |       | . |   |                 |
| (10-2003)  |          |   |          |       | S |   |                 |
|            |          |   |          |       | . |   |                 |
| 10 CFR     |          |   |          |       | N |   |                 |
| 2.201      |          |   |          |       | U |   |                 |
|            |          |   |          |       | C |   |                 |
|            |          |   |          |       | L |   |                 |
|            |          |   |          |       | E |   |                 |
|            |          |   |          |       | A |   |                 |
|            |          |   |          |       | R |   |                 |
|            |          |   |          |       | R |   |                 |
|            |          |   |          |       | E |   |                 |
|            |          |   |          |       | G |   |                 |
|            |          |   |          |       | U |   |                 |
|            |          |   |          |       | L |   |                 |
|            |          |   |          |       | A |   |                 |
|            |          |   |          |       | T |   |                 |
|            |          |   |          |       | O |   |                 |
|            |          |   |          |       | R |   |                 |
|            |          |   |          |       | Y |   |                 |
|            |          |   |          |       | * |   |                 |
|            |          |   |          |       | * |   |                 |
|            |          |   |          |       |   |   |                 |
|            |          |   |          |       | * |   |                 |
|            |          |   |          |       | * |   |                 |
|            |          |   |          |       | C |   |                 |
|            |          |   |          |       | O |   |                 |
|            |          |   |          |       | M |   |                 |
|            |          |   |          |       | M |   |                 |
|            |          |   |          |       | I |   |                 |
|            |          |   |          |       | S |   |                 |
|            |          |   |          |       | S |   |                 |
|            |          |   |          |       | I |   |                 |
|            |          |   |          |       | O |   |                 |
|            |          |   |          |       | N |   |                 |
|            |          |   |          |       | * |   |                 |
|            |          |   |          |       | * |   |                 |
+------------+----------+---+----------+-------+---+---+-----------------+
| ***Docket  |          |   |          |       |   |   |                 |
| File       |          |   |          |       |   |   |                 |
| Info       |          |   |          |       |   |   |                 |
| rmation*** |          |   |          |       |   |   |                 |
|            |          |   |          |       |   |   |                 |
| **SAFETTY  |          |   |          |       |   |   |                 |
| INSPCTION  |          |   |          |       |   |   |                 |
| REPORT**   |          |   |          |       |   |   |                 |
|            |          |   |          |       |   |   |                 |
| **AND      |          |   |          |       |   |   |                 |
| COMPLIANCE |          |   |          |       |   |   |                 |
| IN         |          |   |          |       |   |   |                 |
| SPECTION** |          |   |          |       |   |   |                 |
+------------+----------+---+----------+-------+---+---+-----------------+
| 1\.        |          |   |          | 2\.   |   |   |                 |
| LICENSEE   |          |   |          | NR    |   |   |                 |
|            |          |   |          | C/REG |   |   |                 |
|            |          |   |          | IONAL |   |   |                 |
|            |          |   |          | O     |   |   |                 |
|            |          |   |          | FFICE |   |   |                 |
+------------+----------+---+----------+-------+---+---+-----------------+
| **\[Li     |          |   |          | **R   |   |   |                 |
| censee\]** |          |   |          | egion |   |   |                 |
|            |          |   |          | I**   |   |   |                 |
+------------+----------+---+----------+-------+---+---+-----------------+
| REPORT     |          |   |          |       |   |   |                 |
| NUMBER(S)  |          |   |          |       |   |   |                 |
| **\[Report |          |   |          |       |   |   |                 |
| No.\]**    |          |   |          |       |   |   |                 |
+------------+----------+---+----------+-------+---+---+-----------------+
| 3\. Docket |          | 4 |          |       |   | 5 |                 |
| Number(s)  |          | \ |          |       |   | \ |                 |
|            |          | . |          |       |   | . |                 |
|            |          | L |          |       |   | D |                 |
|            |          | i |          |       |   | A |                 |
|            |          | c |          |       |   | T |                 |
|            |          | e |          |       |   | E |                 |
|            |          | n |          |       |   | ( |                 |
|            |          | s |          |       |   | S |                 |
|            |          | e |          |       |   | ) |                 |
|            |          | N |          |       |   | O |                 |
|            |          | u |          |       |   | F |                 |
|            |          | m |          |       |   | I |                 |
|            |          | b |          |       |   | N |                 |
|            |          | e |          |       |   | S |                 |
|            |          | r |          |       |   | P |                 |
|            |          | ( |          |       |   | E |                 |
|            |          | s |          |       |   | C |                 |
|            |          | ) |          |       |   | T |                 |
|            |          |   |          |       |   | I |                 |
|            |          |   |          |       |   | O |                 |
|            |          |   |          |       |   | N |                 |
+------------+----------+---+----------+-------+---+---+-----------------+
| **\[Docket |          | * |          |       |   |   |                 |
| No.\]**    |          | * |          |       |   |   |                 |
|            |          | \ |          |       |   |   |                 |
|            |          | [ |          |       |   |   |                 |
|            |          | L |          |       |   |   |                 |
|            |          | i |          |       |   |   |                 |
|            |          | c |          |       |   |   |                 |
|            |          | e |          |       |   |   |                 |
|            |          | n |          |       |   |   |                 |
|            |          | s |          |       |   |   |                 |
|            |          | e |          |       |   |   |                 |
|            |          | N |          |       |   |   |                 |
|            |          | o |          |       |   |   |                 |
|            |          | . |          |       |   |   |                 |
|            |          | \ |          |       |   |   |                 |
|            |          | ] |          |       |   |   |                 |
|            |          | * |          |       |   |   |                 |
|            |          | * |          |       |   |   |                 |
+------------+----------+---+----------+-------+---+---+-----------------+
| 6\.        |          | 7 |          |       |   |   |                 |
| INSPECTION |          | \ |          |       |   |   |                 |
| PROCEDURES |          | . |          |       |   |   |                 |
| USED       |          | I |          |       |   |   |                 |
|            |          | N |          |       |   |   |                 |
|            |          | S |          |       |   |   |                 |
|            |          | P |          |       |   |   |                 |
|            |          | E |          |       |   |   |                 |
|            |          | C |          |       |   |   |                 |
|            |          | T |          |       |   |   |                 |
|            |          | I |          |       |   |   |                 |
|            |          | O |          |       |   |   |                 |
|            |          | N |          |       |   |   |                 |
|            |          | F |          |       |   |   |                 |
|            |          | O |          |       |   |   |                 |
|            |          | C |          |       |   |   |                 |
|            |          | U |          |       |   |   |                 |
|            |          | S |          |       |   |   |                 |
|            |          | A |          |       |   |   |                 |
|            |          | R |          |       |   |   |                 |
|            |          | E |          |       |   |   |                 |
|            |          | A |          |       |   |   |                 |
|            |          | S |          |       |   |   |                 |
+------------+----------+---+----------+-------+---+---+-----------------+
| **\[       |          |   |          |       |   |   |                 |
| INSPECTION |          |   |          |       |   |   |                 |
| PROC       |          |   |          |       |   |   |                 |
| EDURES\]** |          |   |          |       |   |   |                 |
+------------+----------+---+----------+-------+---+---+-----------------+
| **SU       |          |   |          |       |   |   |                 |
| PPLEMENTAL |          |   |          |       |   |   |                 |
| INSPECTION |          |   |          |       |   |   |                 |
| INF        |          |   |          |       |   |   |                 |
| ORMATION** |          |   |          |       |   |   |                 |
+------------+----------+---+----------+-------+---+---+-----------------+
| 1\.        | 2\.      |   | 3\.      |       |   |   | 4\. TELEPHONE   |
| PROGRAM    | PRIORITY |   | LICENSEE |       |   |   | NUMBER          |
|            |          |   | CONTACT  |       |   |   |                 |
| **\[Prog.  | **\[Prio |   |          |       |   |   | **\[Contact     |
| Code\]**   | rity\]** |   | **\[     |       |   |   | No.\]**         |
|            |          |   | Licensee |       |   |   |                 |
|            |          |   | Con      |       |   |   |                 |
|            |          |   | tact\]** |       |   |   |                 |
+------------+----------+---+----------+-------+---+---+-----------------+
| G Main     |          |   |          |       |   |   |                 |
| Office     |          |   |          |       |   |   |                 |
| Inspection |          |   |          |       |   |   |                 |
| Next       |          |   |          |       |   |   |                 |
| Inspection |          |   |          |       |   |   |                 |
| Date:      |          |   |          |       |   |   |                 |
+------------+----------+---+----------+-------+---+---+-----------------+
| G Field    |          |   |          |       |   |   |                 |
| Office     |          |   |          |       |   |   |                 |
+------------+----------+---+----------+-------+---+---+-----------------+
| G          |          |   |          |       |   |   |                 |
| Temporary  |          |   |          |       |   |   |                 |
| Job Site   |          |   |          |       |   |   |                 |
+------------+----------+---+----------+-------+---+---+-----------------+
| **PROGRAM  |          |   |          |       |   |   |                 |
| SCOPE**    |          |   |          |       |   |   |                 |
+------------+----------+---+----------+-------+---+---+-----------------+

NRC FORM 591M PART 3 (10-2003)

PAGE INTENTIONALLY BLANK

Attachment C

NMMSS Verification Inspection Documentation

PAGE INTENTIONALLY BLANK

TI - 2800/035

NMMSS Verification Inspection Documentation - Part 1

Licensee Identification

  ------------------------------ ------- ------------ --------------------
  Licensee Name                  RIS     License No.  Docket No (if
                                                      applicable)

                                                      
  ------------------------------ ------- ------------ --------------------

+-----------------------------------------------------------------------+
| > Mailing Address                                                     |
+-----------------------------------------------------------------------+

  --------------- -------------------------------------------------------
  Street Address  
  1               

  Street Address  
  2               
  --------------- -------------------------------------------------------

  ------ --------------------------------- ------- ---- --------- ----------
  City                                     State        Zip Code  

  ------ --------------------------------- ------- ---- --------- ----------

  --------------------------------------- -------------------------- ----
  Physical Address                        Check Here If Same as      
                                          Above                      

  --------------------------------------- -------------------------- ----

  --------------- -------------------------------------------------------
  Street Address  
  1               

  Street Address  
  2               
  --------------- -------------------------------------------------------

  ------ --------------------------------- ------- ---- --------- ----------
  City                                     State        Zip Code  

  ------ --------------------------------- ------- ---- --------- ----------

  ------------------------------------------------------ ----- -- ------ --
  Was D-3 administrative information reviewed by         Yes      No     
  licensee & up-to-date                                                  

  If not up-to-date, was licensee prompted to contact    Yes      No     
  NMMSS contractor                                                       
  ------------------------------------------------------ ----- -- ------ --

  -----------------------------------------------------------------------
  **NOTE**: See
  [http://www.nmmss.com/NMMSST1.nsf/mainFS?OpenFrameSet]{.underline} for
  NMMSS Change of Authorized Contacts Response Form

  -----------------------------------------------------------------------

SUMMARY OF TASK 8 INSPECTION PACKAGE INFORMATION

  --------------------------------------------------------- -------------
  Date of Reconciled DOE/NRC Form 742 (see Task 8           
  inspection package)                                       

  Date of TJ-45 (see Task 8 inspection package)             
  --------------------------------------------------------- -------------

  ------------------------------------------------------------ ----------
  Does TJ-45 document receipt or transfer of subject material  Yes No

  ------------------------------------------------------------ ----------

VERIFICATION OF NMMSS ACCOUNT DATA

+-------------------+------+------------+------------+---------------+
| Material Type     | MT   |  -        | Un         | Comment       |
|                   | Code | Material   | documented |               |
| \* - Foreign      |      |            |            | Reference     |
| Obligated Only    |      | in Account | D          |               |
|                   |      |            | ifferences |               |
+-------------------+------+------------+------------+---------------+
| Depleted          | MT   |            | Yes No     |               |
| uranium\*         | 10   |            |            |               |
+-------------------+------+------------+------------+---------------+
| Enriched uranium  | MT   |            | Yes No     |               |
|                   | 20   |            |            |               |
+-------------------+------+------------+------------+---------------+
| Plutonium         | MT   |            | Yes No     |               |
|                   | 50   |            |            |               |
+-------------------+------+------------+------------+---------------+
| Uranium 233       | MT   |            | Yes No     |               |
|                   | 70   |            |            |               |
+-------------------+------+------------+------------+---------------+
| Normal uranium\*  | MT   |            | Yes No     |               |
|                   | 81   |            |            |               |
+-------------------+------+------------+------------+---------------+
| Plutonium 238     | MT   |            | Yes No     |               |
|                   | 83\* |            |            |               |
+-------------------+------+------------+------------+---------------+
| Thorium\*         | MT   |            | Yes No     |               |
|                   | 88   |            |            |               |
+-------------------+------+------------+------------+---------------+
| Uranium in        | MT   |            | Yes No     |               |
| cascade           | 89   |            |            |               |
+-------------------+------+------------+------------+---------------+

TI - 2800/035

NMMSS Verification Inspection Documentation - Part 2

Description of Undocumented Differences

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  1      MT                         
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  2      MT                         
         [\_\_\_\_\_]{.underline}   

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  3      MT                         
         [\_\_\_\_\_]{.underline}   

  ------ -------------------------- -----------------------------------------------------

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TI - 2800/035

NMMSS Verification Inspection Documentation - Part 2

Description of Undocumented Differences (continued)

  ------ -------------------------- -----------------------------------------------------
  4      MT                         
         [\_\_\_\_\_]{.underline}   

  ------ -------------------------- -----------------------------------------------------

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  ------ -------------------------- -----------------------------------------------------
  5      MT                         
         [\_\_\_\_\_]{.underline}   

  ------ -------------------------- -----------------------------------------------------

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  ------ ------------------------------- --------------------------------
  6      Other Inspector Comments or     
         Findings                        

  ------ ------------------------------- --------------------------------

  -----------------------------------------------------------------------

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