Revision 1 

June 1980 U.S. NUCLEAR REGULATORY COMMISSION

REGULATORY GUIDE 

OFFICE OF STANDARDS DEVELOPMENT 

REGULATORY GUIDE 5.57 

(Task SG 908-4) 

SHIPPING AND RECEIVING CONTROL OF STRATEGIC 

SPECIAL NUCLEAR MATERIAL

A. INTRODUCTION 

Requirements for the physical protection of special 

nuclear material (SNM) at licensee facilities and in transit 

and of plants in which SNM is used are specified in 10 CFR 

Part 73, "Physical Protection of Plants and Materials," and are the subject of various regulatory guides issued or under 

development. Section 73.20 of 10 CFR Part 73 provides 

the general performance objective and requirements for 

each licensee who is authorized to operate a fuel repro

cessing plant pursuant to 10 CFR Part 50, possesses or uses formula quantities of strategic special nuclear material 

(SSNM) at any site or contiguous sites subject to control by 

the licensee, is authorized to transport or deliver to a carrier 

for transportation pursuant to 10 CFR Part 70 formula 

quantities of SSNM, takes delivery of formula quantities of 

SSNM free on board (f.o.b.) the point at which it is delivered 

to a carrier for transportation, or imports or exports 

formula quantities of SSNM. Section 73.25 requires specific 

performance capabilities for physical protection of SSNM 

in transit. Section 73.45 requires specific performance 

capabilities for fixed site physical protection systems. This 

guide is applicable to the shipping and receiving control of 

SSNM subject to § § 73.20, 73.25, and 73.45. 

Other regulations are also pertinent to shipping and 

receiving control. Section 70.58, "Fundamental Nuclear 

Material Controls," requires licensees to establish, maintain, 

and follow detailed fundamental material control and 

accounting procedures, including procedures for shipping 

and receiving special nuclear material (SNM). Certain 

material control and accounting procedures related specifi

cally to the protection of SSNM from theft during shipping 

and receiving and related to preventing the misuse of 

shipments to disguise a diversion are discussed in this guide. 

Additional guidance on fundamental material controls and 

accounting is included in the following regulatory guides: 

Lines indicate substantive changes from June 1976 version.

USNRC REGULATORY GUIDES 

Regulatory Guides are issued to describe and make available to the public methods acceptable to the NRC staff of implementing specific parts of the Commission's regulations, to delineate tech niques used by the staff in evaluating specific problems or postu lated accidents or to provide guidance to applicants. Regulatory Guides are noi substitutes for regulations, and compliance with them is not required. Methods and solutions different from those set out in the guides will be acceptable if they provide a basis for the findings requisite to the issuance or continuance of a permit or license by the Commission. 

Comments and suggestions for improvements in these guides are encouraged at all times, and guides will be revised, as appropriate, to accommodate comments and to reflect new information or experience. This guide was revised as a result of substantive com ments received from the public and additional staff review.

5.10 Selection and Use of Pressure-Sensitive Seals on Containers for Onsite Storage of Special 

Nuclear Material. 

5.12 General Use of Locks in the Protection and 

Control of Facilities and Special Nuclear 

Materials. 

5.13 Conduct of Nuclear Material Physical Inven

tories (In particular, Section C.2.b.(l), Re

ceipts, Shipments, and Other Removals). 

5.15 Security Seals for the Protection and Control 

of Special Nuclear Material. 

5.45 Standard Format and Content for the Special 

Nuclear Material Control and Accounting Sec

tion of a Special Nuclear Material License 

Application. 

5.47 Control and Accountability of Plutonium in 

Waste Material. 

5.51 Management Review of Nuclear Material 

Control and Accounting Systems. 

Section 70.57 and paragraph (f) of § 70.58 require that 

the licensee's measurement control program for SNM include a means for the control and evaluation of measurement bias, 

random errors, and limits on systematic errors for all parts 

of the measurement process, including scales, balances, 

volume measurements, analytical quality control, nondestruc

trive assay, and sampling. Certain measurements made in con junction with shipping and receiving are used as part of the 

material accountability program and are subject to § 70.57. 

Specific guidance on measurements and measurement control 

are provided in the following regulatory guides: 

5.4 Standard Analytical Methods for the Mea

surement of Uranium Tetrafluoride (UF 4 ) 

and Uranium Hexafluoride (UF 6 ).

Comments should be sent to the Secretary of the Commission, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, Attention: Docketing and Service Branch. 

The guides are issued in the following ten broad divisions: 

1. Power Reactors 6. Products 2. Research and Test Reactors 7. Transportation 3. Fuels and Materials Facilities 8. Occupational Health 4. Environmental and Siting 9. Antitrust and Financial Review 5. Materials and Plant Protection 10. General 

Copies of issued guides may be purchased at the current Government Printing Office price. A subscription service for future guides in spe cific divisions is available through the Government Printing Office. Information on the subscription service and current GPO prices may be obtained by writing the U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, Attention: Publications Sales Manager.

*r
5.5 Standard Methods for Chemical, Mass Spec

trometric, and Spectrochemical Analysis of 

Nuclear-Grade Uranium Dioxide Powders 

and Pellets. 

5.6 Standard Methods for Chemical, Mass Spec

trometric, and Spectrochemical Analysis of 

Nuclear-Grade Plutonium Dioxide Powders 

and Pellets and Nuclear-Grade Mixed Oxides 

([U,Pul )02• 

5.11 Nondestructive Assay of Special Nuclear 

Material Contained in Scrap and Waste. 

5.21 Nondestructive Uranium-235 Enrichment 

Assay by Gamma-Ray Spectrometry. 

5.34 Nondestructive Assay of Plutonium in Scrap 

by Spontaneous Fission Detection. 

5.53 Qualification, Calibration, and Error Esti

mation Methods for Nondestructive Assay. 

Licensees who transfer and receive SNM are required 

under § 70.54 to complete DOE/NRC Form-741, "Nuclear 

Material Transaction Report," and submit a copy to the 

U.S. Department of Energy (DOE), Oak Ridge, Tennessee. 

In addition, paragraph 70.42(c) requires that, before trans

ferring SNM, the person making the shipment verify that 

the recipient is authorized to receive the type, form, and 

quantity of SNM to be transferred. Paragraph 70.42(d) out

lines the methods to be used to make this verification. 

Paragraph 70.58(g)(2) requires that procedures be estab

lished to review and evaluate shipper-receiver differences on 

an individual container or lot basis, a shipment basis, and a 

cumulative basis for shipments of like material. Guidelines 

are contained in Regulatory Guide 5.28, "Evaluation of 

Shipper-Receiver Differences in the Transfer of Special 

Nuclear Materials." Any loss of SNM (other than normal 

operating loss) must, under § 70.52, be reported immedi

ately to the Director of the appropriate NRC Inspection 

and Enforcement Regional Office (listed in Appendix A to 

Part 73) by telephone, telegram, mailgram, or facsimile. 

This guide and the guides referenced above describe pro

cedures acceptable to the NRC staff for complying with 

the Commission's regulations regarding the control of 

SSNM during preparation for shipment and receipt by a 

licensee. Safety-related requirements for packaging and 

transporting SNM are specified in 10 CFR Part 71, "Packag

ing of Radioactive Material for Transport and Transporta

tion of Radioactive Material Under Certain Conditions," 

and in the applicable portions of the regulations appropriate 

to the mode of transportation in Title 49 of the Code of 

Federal Regulations. These requirements are not included 

in the scope of this guide. 

B. DISCUSSION 

Adequate control of SSNM during transfer between 

licensees includes (1) physical protection of the material at

the licensees' facilities and while in transit and (2) the timely, 

accurate, and independent identification and measurement 

of the SSNM by both shipper and receiver to determine and 

evaluate any shipper-receiver differences. These measure

ments are necessary to (1) detect loss or theft of SSNM 

being transferred between licensees, (2) detect and permit 

correction of clerical or handling errors, (3) detect falsifica

tion or errors in the shipment source data, (4) provide 

assurance that measurement bias is detected and corrected, 

and (5) detect and prevent the transfer of "inventory 

difference" (ID) from one licensee to another. 

The application of tamper-indicating seals to each item 

or container by the shipper immediately after sampling or 

assay, checks on those seals before shipment, and the 

prompt verification of the seals by the receiver can help 

ensure the integrity of the material measured. Additional 

receiving checks made immediately after receipt can deter

mine if loss, theft, or substitution of SSNM may have 

occurred during transfer and can detect packaging and 

clerical mistakes. These checks can include counting and 

identifying the containers; identifying and weighing the 

containers or items received; comparing the results with the 

same information on a bill of lading, DOE/NRC Form-741, 

"Nuclear Material Transaction Report," or other appropriate 

document supplied by the shipper; and, to the extent 

possible, performing an overcheck of each container by 

nondestructive analysis to provide a gross verification of the 

SSNM content. 

After these initial checks have been made, prompt quan

titative verification of the contents of each container will pro

vide early assurance that the contents of the packages received 

are identical to those shipped. Written procedures that call 

for performing these verifications within specific time limits 

after shipment can help ensure that DOE/NRC Form-741 is 

filed in a timely fashion. In addition, the validity of boththe 

shipper and receiver measurements is dependent on the 

existence of a program of standardization and calibration 

and control of measurement equipment and procedures. 

Prior coordination between the carrier and receiver can 

ensure that SSNM will be delivered to the receiver's facility 

at a time when trained personnel are available to properly 

handle the material received. This procedure will eliminate 

the possibility of material arriving at times when proper 

receiving checks or adequate physical security cannot be 

provided. 

Appropriate procedures that identify employees who are 

authorized to ship SSNM and the responsibilities of the 

various organizational components that have cognizance of 

the shipment will ensure that all aspects of the shipment are 

coordinated adequately. The following organizational 

components 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 SSNM,

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b. Tamper-seal and document the contents of the 

containers, 

c. Obtain appropriate analysis of the SSNM, 

d. Ensure product specifications, 

e. Package material properly or provide guidance on 

packaging as required. 

2. Shipping and receiving control: 

a. Prepare shipping forms, 

b. Ensure proper packaging, 

c. Check integrity and seal numbers of tamper-safed 

containers and identification numbers on such 

items as sealed fuel pins, 

d. Verify seal integrity and number of receipts, 

e. Check weight of items and containers. 

3. Security: 

a. Accompany package to shipping area when appro

priate, 

b. Be cognizant of the storage areas while shipment is 

in them, 

c. Guard shipment while it is being loaded, 

d. Coordinate security plans and arrangements with 

the dispatcher of the material, 

e. Obtain signed receipts and pass them on to the 

appropriate departments. 

4. Traffic (dispatcher): 

a. Make carrier arrangements, 

b. Coordinate shipments and ensure that delivery is 

at a time when the proper personnel are available 

to properly handle the material received, 

c. Prepare bill of lading and other formal shipping 

papers, 

d. Notify receivers when shipments will be made and 

approximate time of scheduled arrival. 

5. Nuclear materials control: 

a. Ensure that the receiver is authorized to receive 

the shipment of SSNM, 

b. Approve all SSNM shipping memos, 

c. Prepare and transmit DOE/NRC Form-741, 

d. Transmit information for computer records, if 

used, 

e. Arrange transfer of material to shipping area, 

f. Post shipping transactions to control records, 

g. Investigate and reconcile shipper-receiver differences. 

To document the transfer of SSNM containing 1 gram or 

more of contained uranium-235, uranium-233, or plutonium, 

DOE/NRC Form-741 is initiated on the day the material is 

shipped and distributed promptly by the shipper. Normally, 

the licensee receiving SSNM is required to independently measure its element and isotopic content and complete and 

distribute DOE/NRC Form-741 within 10 days of receipt 

of the material. However, if receipt measurements cannot

be completed within 10 days, a licensee may prepare and 

distribute NRC Form-284, "Nuclear Material Transfer 

Report," or use DOE/NRC Form-741 as a temporary 

receipt record after performing an initial receiving check to 

verify that the items, containers, and gross quantities 

shipped have been received. In such cases, the receiver is 

then required to complete the measurements and report 

them on DOE/NRC Form-741 within 30 days of receipt of 

the shipment. If the material received is scrap or irradiated 

material that may take longer than 30 days to measure, 

DOE/NRC Form-741 is completed and distributed to 

indicate temporary acceptance of the shipper's values; at a later date, the receiver prepares and distributes a "corrected 

copy" of DOE/NRC Form-741 that reports the receiver's 

own measurements.1 There are no requirements for ship

ments of nuclear wastes to burial grounds to be measured 

independently by the receiver. DOE and its prime contractors 

complete DOE/NRC Form-741 in accordance with DOE 

manual chapters. 

C. REGULATORY POSITION 

Procedures should be provided to ensure that records 

reflect accurately the quantity and form of material shipped 

and received, to protect against the deliberate falsification 

of information on shipments or receipts to conceal diversion 

of SSNM, and to protect against the use of waste shipments 

or shipments of quantities not subject to § 73.25 as a 

means for unauthorized removal of SSNM from a licensee's 

facility. The following procedures are acceptable to the 

NRC staff. 

1. PRESHIPMENT CONTROLS ON WASTE 

a. Nondestructive assay (NDA) measurements for account

ability purposes should be made using one of the following 

procedures or an alternative procedure that provides equiv

alent protection against falsification of accountability mea

surements:

(1) Measurements should be performed by two indi

viduals working and recording as a team and who do not 

have access to material processing and storage areas, 

(2) Measurements should be performed by three indi

viduals working and recording as a team, or 

(3) Arrangements should be made for independent 

verification of the accountability measurements by a party 

other than the licensee. 

b. Tamper-safing controls at the time of accountability 

measurements should include one of the following: 

1

Section 70.54 and the written instructions entitled "Instructions 

to NRC and Agreement State Licensees for Reporting Nuclear Mate rial Transfers on DOE/NRC Form-741 - Nuclear Material Transaction Report," U.S. Nuclear Regulatory Commission. Copies of the latter 

may be obtained from the Division of Safeguards, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commis sion, Washington, D.C. 20555.

5.57-3
(1) If the containers being measured are already 

tamper-safed, individuals performing the measurement 

should confirm the seal identification and integrity, or 

(2) Containers should be sealed at the time of NDA 

measurement and each member of the team should attest in 

writing to the nature of the contents of the container and 

the seal identification. 

c. Prior to removal of a waste container from a material 

access area (MAA), an overcheck should be performed to 

ensure that the container is not being used as a means for 

concealment and unauthorized removal of SSNM from 

an MAA. Controls should also be placed on packaging of 

smaller containers that are sealed and subsequently combined 

in larger containers prior to final sealing and removal from 

an MAA. Teams performing functions for a. and b. above 

may simultaneously perform the functions described below. 

Acceptable procedures are: 

(1) For each stage in sequential packaging, containers 

should be filled and sealed by two individuals working and 

recording as a team and who do not have access to material 

processing and storage areas. Each individual should attest 

in writing to the nature of the contents of the container 

and the seal identification. At any stage in sequential 

packaging, the team filling the large container should 

include at least one individual who was not involved in 

filling the smaller containers, 

(2) Same as (1), except that, if any individual involved 

in filling and sealing the containers has access to material, 

three-man teams should be used, 

(3) Intermediate packaging may be performed by two

man teams if the final package receives an NDA overcheck 

1 using a segmented scanner with a transmission source or 

neutron counter, as appropriate, capable of detecting con

cealed SSNM and gamma ray or neutron absorbers of suffi

cient density to preclude accurate NDA measurement, or 

(4) Intermediate packaging may be performed by two

man teams if the final sealed package is retained in the MAA 

until the next material balance is closed. The package may 

be released if the inventory difference is less than the limit 

of error which in turn is less than 1/10 of a formula quantity 

as defined in paragraph 73.2(bb). If the inventory difference 

for the period is greater than its limit of error, the containers 

should be unsealed and the contents verified in accordance 

with Regulatory Position C. 1 .c.(1) or (2) or left sealed and 

the contents verified in accordance with Regulatory Posi

tion C. 1.c.(3) as a part of the investigation of the excessive 

inventory difference. If the limit of error is greater than 

1/10 of a formula quantity, verification should be performed 

in accordance with Regulatory Position C. 1.c.(1), (2), or (3) 

before the package is released. 

2. OVERCHECKS ON PRODUCT, SAMPLES, AND SCRAP 

a. For shipments that are not subject to the in-transit 

physical protection requirements of § § 73.20 and 73.25, 

overchecks such as those discussed in Regulatory Position

C.1.c. above should be provided to protect against conceal

ment and unauthorized removal of SSNM. 

b. If an independent accountability measurement is not 

required to be made by the receiver and reported within 

30 days, NDA overchecks on accountability measurements 

should be provided by the shipper or controls such as those 

discussed in Regulatory Position C.1.a. should be provided. 

3. ADDITIONAL SHIPPING CONTROLS 

a. Before shipping SSNM, the licensee should ensure 

that the intended receiver is authorized to receive the type, 

form, and quantity of SSNM to be transferred in accordance 

with § 70.42. This does not include forecasting the receiver's 

inventory at the time the shipment arrives. 

b. The shipper should establish and maintain written 

procedures that identify employees who are authorized to 

initiate shipment of SSNM and identify the responsibilities 

of the various departments that should have cognizance 

of the shipment in accordance with paragraphs 70.58(b)(3) 

and 73.45(e)(2)(i). 

c. Written procedures should be established and main

tained to assign to specific organizational components the 

responsibility for packaging the shipment and ensuring that 

it is packaged and transported in accordance with the 

provisions of 10 CFR Parts 70, 71, and 73 and other 

applicable regulations. 

d. Organizational components responsible for the shipment 

within the plant and in transit should have a set of written 

procedures that cover both normal and emergency conditions 

in accordance with paragraphs 70.58(b)(3), 73.25(d), and 

73.45(g). 

e. The shipper should notify the consignee of the 

pertinent details of the shipment as described in § 73.27. 

f. The shipper should initiate and distribute a Nuclear 

Material Transaction Report (DOE/NRC Form-741) in 

accordance with § 70.54 and the printed instructions for 

completing the form. 

g. In accordance with paragraph 73.45(e)(2)(ii), the 

shipping group should, as a minimum, check the items and 

tamper-safing tag information and the tag quantities against 

the information on the transfer forms. Each tamper-indicating 

device should be checked. It is also desirable that the 

shipping group make a gross weighing of each item. 

h. Shipper-receiver differences, the quantity difference 

between the amount of SSNM stated by the shipper as 

having been shipped and the amount received as measured 

by the receiver, should be reviewed and evaluated in accord

ance with paragraph 70.58(g). 

4. RECEIPTS 

a. A licensee should accept receipt of only those types 

and quantities of SSNM authorized by his license. If other

5.57-4

I
material is delivered to the facility, the licensee should 

notify the shipper immediately so that appropriate arrange ments can be made for the disposition of the material and 

the continuous maintenance of adequate physical protec

tion. 

b. Arrangements should be made to deliver the material 

to the receiver at a time when personnel are available to 

properly handle the material in accordance with paragraph 73.25(b)(1)(i). It is the responsibility of shipper, receiver, and carrier to ensure that trained personnel are available to properly handle deliveries of SNM. If it appears to the 

shipper or carrier that the shipment may arrive at a time other than that for which arrangements were made, the shipper or carrier should immediately inform the receiver so that the receiver can have trained personnel available when the shipment arrives. If the shipment fails to arrive at the 

scheduled time, the receiving licensee should notify the shipper in accordance with paragraph 73.71(b) so that a prompt investigation can be initiated. 

c. The identification and integrity of the shipper's tamper-safing devices on each item or container should be verified in accordance with paragraph 7 3 .25(c)(4). The 

piece count and identification and gross weight of the items or containers received should be checked against the bill of 

lading, DOE/NRC Form-74 1, or other appropriate shipping document to provide assurance that the shipment was received intact. To the extent possible, an overcheck 

determination by NDA or other appropriate means should 

be made to provide a prompt estimate of the SSNM content 

of each item or container. After the initial receiving checks have been performed, the material should be sent to an area where the contents of the containers or items can be verified quantitatively in accordance with paragraph 70.5 8(e). Written procedures should be established and maintained 

for verifying the receipts within specific time limits so that DOE/NRC Form-741 can be filed within the time required 

by § 70.54. 

d. If any of the tamper-safing devices have been disturbed 

in a way that may indicate an attempt to render the device inoperable or if the device has been damaged accidentally, the following actions should be taken: 

(1) The affected containers should be resealed 

immediately by the receiver with another tamper-safing device, and the resealing should be witnessed and attested 

to by the personnel delivering the containers. 

(2) After resealing, containers with damaged seals should be isolated until the licensee can inspect the containers 

to determine if a loss of SSNM has occurred. This should be accomplished in accordance with the procedures described 

in (3) and (4). 

(3) If a gross weight or NDA overcheck, as appropriate, indicates that the contents of any container appear to have 

been removed, the Director of the NRC Inspection and Enforcement (IE) Regional Office listed in Appendix A to 

10 CFR Part 73 should be notified immediately in accordance 

with § 73.71. The shipper should also be notified as soon as

possible. Both IE and the shipper should be given the option of witnessing a quantitative assessment of the container's 

contents. The contents of the container should be quantita tively assessed as soon as possible. If the shipper and IE elect 

not to witness the measurement, the assessment should be 

witnessed and attested to by personnel from at least two 

different groups within the receiver's organization. 

(4) If the contents of the containers appear to be in 

order, the shipper should be notified and given the option of witnessing a quantitative assessment (weighing and 

sampling) of the containers contents within 48 hours 

following receipt of the shipment. If the shipper does not 

respond to this offer, the contents of the container should 

be assessed as soon as possible, but in no case later than 48 hours after receipt. 

(5) The shipper or IE should be given the results of 

the quantitative assessment immediately if either did not 

witness the assessment. 

e. Within the time specified in the instructions for the 

preparation of DOE/NRC Form-741, the receiver should 

make an accurate, precise, and independent measurement 

of the SSNM content of the material received. This measure ment should be in accordance with a program for acceptable 

measurement quality as required by paragraph 70.58(f). 

f. The difference between the amount of SSNM stated by the shipper as having been shipped and the amount received as measured by the receiver should be reviewed and evaluated 

in accordance with paragraph 7 0.58(g). All measurement dis

crepancies should be reported to the nuclear material con trol manager or alternate, who should personally verify the 

discrepancy in the presence of the employee who discovered 

them. Written procedures should quantitatively define what 

constitutes a discrepancy for each type of SSNM received. 

Appropriate action should be taken to reconcile those shipper receiver differences that are statistically significant at the 

95% confidence level, except for shipments that involve 

differences of 50 grams or less of U-235 or plutonium. When a discrepancy is identified, the nuclear material manager should resolve the discrepancy with the shipper. If the 

discrepancy cannot be resolved, the appropriate NRC 

Inspection and Enforcement Regional Office should be notified by telephone, telegram, mailgram, or facsimile. 

Additional guidance on shipper-receiver differences is 

contained in Regulatory Guide 5.28. 

g. Within 10 days of receipt of material, the receiver 

should complete and distribute the DOE/NRC Form-741 

prepared by the shipper in accordance with § 70.54. When 

receipt measurements cannot be completed within this 

10-day period, the receiver should complete a temporary receipt in one of the following two ways: (1) as indicated 

in the instructions for reporting nuclear material transfers on DOE/NRC Form-741, complete blocks "Date Received or Correction Entered" and "Signature of Authorized 

Official and Date Signed" of the form, note on the form 

whether the containers, boxes, or cases reported as shipped were received, and mark on the form "Nuclear Material 

Transfer Receipt" or (2) if authorized in the license,

5.57-5
prepare NRC Form-284, "Nuclear Material Transfer Re

port," as a temporary receipt. In either case, a copy of the 

original DOE/NRC Form-741 issued by the shipper should 

then be completed and distributed within 30 days of 

receipt to show the receiver's measurements. However, if 

measurements of scrap and irradiated material cannot be

completed and reported within 30 days of receipt of 

material and if a temporary receipt has been filed on NRC 

Form-284 or DOE/NRC Form-741, the licensee should 

complete DOE/NRC Form-741 accepting the shipper's 

weights and file a corrected copy to report his or her own 

measurements at a later date.

5.57-6

I
VALUE/IMPACT STATEMENT

A separate value/impact analysis has not been prepared 

for the revision to this regulatory guide. The changes were 

made to make the guide consistent with the upgraded 

physical protection amendments to the regulations pub

lished in the Federal Register November 28, 1979 (44 FR 

68184). A value/impact analysis prepared for the proposed

amendments was made available in the Commission's Public 

Document Room, 1717 H Street NW., Washington, D.C., 

at the time the proposed amendments were published. This 

analysis is appropriate for the final amendments as well as 

for the regulatory guide revisions appropriate to those 

amendments.

5.57-7
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OFFICIAL BUSINESS 

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