NUREG-1065

Rev. 2

Xcceptable Standard Format and,

Content for the, Fundamental

Nuclear Material Control

(FNMC) -Plan Required for

Low-Enriched Uranium Facilities

J.S . Nuclear Regulatory Commission

Office of Nuclear Material Safety and Safeguards

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NUREG-1065

Rev. 2

Acceptable Standard Format and

Content for the Fundamental

Nuclear Material Control

(FNMC) Plan Required for

Low-Enriched Uranium Facilities

Manuscript Completed: November 1995

Date Published: December 1995

D. R. Joy

Division of Fuel Cycle Safety and Safeguards

Office of Nuclear Material Safety and Safeguards

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001
Abstract

This document provides a revised structure for

NUREG-1065, Revision 1, dated 1985, which

contains information that the licensee or applicant

should provide in its fundamental nuclear material

control (FNMC) plan. The revised structure has

been patterned after the acceptable standard format

and content for the FNMC plan required for low

enriched uranium enrichment facilities,

NUREG/CR-5734, KIITP-415, dated 1991. That

document was structured in a manner to serve as a

direct outline for licensees preparation of their

FNMC plan while NUREG-1065 was structured to

more closely follow and elaborate on the contents

of 10 CFR 74.31.

This revised structure for NUREG-1065 continues

to implement the requirements of 10 CFR 74.31.

It applies to NRC licensees (other than production or utilization facilities licensed pursuant to

10 CFR Part 50 or Part 70 and waste disposal

facilities) that are authorized to possess and use

more than one effective kilogram of unencapsulated

SNM of low strategic significance. Unlike the

structure of the enrichment guide, however, this

revision for NUREG-1065 includes a complete set

of affirmations required from licensees. These are

the same affirmations that appeared in Revision 1 of

NUREG-1065 but in some instances the language

has been modified to clarify intent.

All other modifications involve format and editorial

changes designed to provide clarifications and

facilitate preparation or revision of the required

FNMC plan.

NUREG-1065 Rev. 2 ..
Contents

Pare

Abstract ......... iii

Acronyms .ix

Introduction ........................................................ -.. I

Performance Objectives, System Features and Capabilities, and Affirmations . 3

Performance Objectives . 3

Affirmations Pertaining to Performance Objectives . 5

Affirmations Pertaining to System Capabilities . 5

1 Organization . 11

1.0 Regulatory Intent ...... ........... ......... 11

1.1 Corporate Organization ............ 11

12 Plant or Site Organization ........... 11

1.3 MC&A Organization ............................... 11

.1.3.1 Responsibilities and Authority .......................... 11

1.32 MC&A Procedures .......................... 12

1.4 Training and Qualification Requirements - ........................ 12

1.5 MC&A System Description .............. ....... . ...... 12

1.6 Acceptance Criteria ..... ......................... 13

1.7 Affirmations ............ ................. 14

2 Measurements .15

2.0 Regulatory Intent ...... ............................ 15

2.1 Measurement Points ............... 15

22 Measurement Systems ....................... ...... 15

22.1 Bulk Measurement Systems ............................ 15

222 Analytical Measurement Systems . ........................... 16

22.3 NDA Measurement Systems ... - 16

22.4 Other Measurement Systems .... 16

2.3 Measurement Uncertainties .......... .................................... 16

2.4 Measurement Procedures ............................... .............. 1.....6 16

2.5 Acceptance Criteria ................... 17

2.6 Affirmations .... ........... .... S 17

3 Measurement Control Program .19

3.0 Regulatory Intent .. 19

3.1 Organization and Management .. 19

3.1.1 Functional Relationships .19

3.12 Procedures .19

3.1.3 Contractor Program Audits and Reviews .19

32 Calibrations ................... . 20

3.3 Control Standard Program .................. 21

3.4 Replicate Program ................... 22

3.5 Control Limits .. ............................. 22

3.5.1 Measurement Control Data Analysis. ............................... 23

3.52 Response Actions ............................... 23

3.6 Acceptance Criteria ............. 23

3.7 Affirmations ............. 25

v NUREG-1065 Rev. 2
4 Statistics ......................................... .27

4.1 Determination of Measurement Uncertainties .................................... 27

4.2 Determination of SEID . .......................................... 27

43 Bias Corrections .......................................... 28

S Physical Inventories .......................................... 29

5.0 Regulatory Intent ................................ 5.1 General Description .............................. 52 Organization, Procedures, and Schedules .............. 5.3 Typical Inventory Composition ...................... 5.4 Description of Typical Item Strata ................... 5.5 Conducting Physical Inventories ..................... 5.6 Inventory Difference Limits and Response Actions ....... 5.7 Acceptance Criteria .............................. 5.8 Affirmations ...................................

29

29

29

29

30

30

32

32

33

6 Item Control .......... 35

6.0 Regulatory Intent ...................................

6.1 Organization ......................................

62 General Description ................................. 6.3 Item Identity Controls ............................... 6.4 Storage Controls ................................... 6.5 Item Monitoring Methodology and Procedures ............. 6.6 Investigation and Resolution of Item Discrepancies .......... 6.7 Acceptance Criteria ................................. 6.8 Affirmations ......................................

35

35

35

35

36

36

36

36

37

7 Shipper-Receiver Comparisons ....................... 39

7.0 Regulatory Intent ................................. 7.1 Receiving Procedures .............................. 72 Determination of Receiver's Values ................... 7.3 Evaluation of Shipper-Receiver Differences .............. 7.4 Resolution of Significant Shipper-Receiver Differences .....

7.5 Acceptance Criteria ............................... 7.6 Affirmations ....................................

8 Assessment and Review of the Material Control and Accounting Program .....................

39

39

39

39

40

40

40

41

8.0 Regulatory Intent ......................................................... 41

8.1 General Description ....................................................... 41

82 Report of Findings and Recommendations ..................................... 42

8.3 Management Review and Response to Report Findings and Recommendations .... ....... 42

8.4 Acceptance Criteria ....................................................... 42

8.5 Affirmations ........................................................... 43

9 Resolving Indications of Missing Uranium .45

9.0 Regulatory Intent ................... .............................. 45

9.1 Methods and Procedures for Identifying Indicators .............. ................. 45

9.2 System and Procedures for Investigating and Resolving Indicators ..... ............... 45

9.3 Response Actions for Unresolved Indicators ........... ......................... 45

9.4 Documentation Requirements .............................................. 46

9.5 Acceptance Criteria . ................................................ 46

9.6 Affirmations . ................................................... 46

NUREG-1065 Rev. 2

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vi
10 Informational Aid for Assisting in the Investigation and Recovery of Missing Uranium ..... . . . . . 47

10.0 Regulatory Intent ............. ... .. ... .. ... .. .. ... .. .. ... .. .. ... . 47

10.1 Information Aid ............. .. .. .. .. ... .. .. .. .. ... .. .. .. .. .. .. . 47

10.2 Acceptance Criteria .............................................. 48

10.3 Affirmations .................................................. 48

11 Recordkeeping ...................................................... . 49

11.0 Regulatory Intent ............................................... . 49

11.1 Description of Records ............................................ . 49

11.2 Program and Controls for Ensuring an Accurate and Reliable Record System .5.0... . . . . . . 0

11.3 Acceptance Criteria ............. .. .. .. ... .. .. .. .. ... .. .. .. .. .. ... . 50

11.4 Affirnations .................................................. . 51

Glossary ............................................................. . 53

vii NUREG-1065 Rev. 2
Acronyms

Code of Federal Regulations

Detection quantity

Detection threshold

Formula kilogram

Fundamental nuclear naterial control

High-enriched uranium

International Atomic Energy Agency

Item control area

Inventory difference

Low-enriched uranium

Material balance area

Material control and accounting

Nondestructive assay

Nuclear Materials Management and

Safeguards System

NRC

SEID

SNM

SRD

U

U-233

U-234

U-235

U-238

U0 2

U30a

UF6

wt 

U. S. Nuclear Regulatory Commission

Standard error of the inventory

difference

Special nuclear material

Shipper-receiver difference

Uranium

Uranium-233

Uranium-234

Uranium-235

Uranium-238

Uranium dioxide

Urano-uranic oxide

Uranium hexafluoride

Weight percent

NUREG-1065 Rev. 2

CFR

DQ

DT

FKG

FNMC

HEU

IAEA

ICA

ID

LEU

MBA

MC&A

NDA

NMMSS

ix
Introduction

An applicant's fundamental nuclear material control

(FNMC) plan must demonstrate how the basic

capabilities specified in 10 CFR 74.31(c) are

achieved and maintained and how such capabilities

are used to achieve the performance objectives

listed in 10 CFR 74.31(a). After accepting an

FNMC plan and imposing it as a condition of

license, the U.S. Nuclear Regulatory Commission

(NRC) will judge the adequacy of a licensee's

materials control and accountability (MC&A)

performance by inspecting for compliance vith

commitments and practices described in the plan.

Because 0 CFR 74.31 is, for the most part, a

performance-oriented regulation, the emphasis is on

defining objectives rather than the means for

achieving them. Thus, applicants and licensees

have many alternatives with regard to how their

MC&A system and program are designed,

managed, and operated. Hence, this document

cannot begin to cover all possible methodologies

that a licensee might use to achieve the desired

objectives. Instead, this document provides

examples of acceptable MC&A approaches

commonly or typically used by low enriched

uranium fuel fabricators. This document is

intended for use by applicants, licensees, and NRC

safeguards licensing reviewers. For the most part,

recommended criteria are not to be regarded as

rigid, fixed standards. That is, a lower

effectiveness of one feature relative to a particular

aspect can be tolerated if there is a compensating

feature, or combination of features, that provides an

overall effective safeguards system. Although not

likely, a licensee could fail to meet most of the

criteria recommended in this document and still

achieve the regulatory objectives. In the final

analysis, an NRC reviewer must make a judgment

as to whether the applicant or licensee can achieve

with high probability, without going beyond its

FNMC plan commitments, the objectives stated in

10 CFR 74.31(a). The recommendations provided

herein pertain to both applicant submitted FNMC

plans and any revisions made to existing approved

plans.

Pages 3 through 10 of this introduction section

describe the basis of the three general performance

objectives of 10 CFR 74.31 and the MC&A system

features and capabilities needed to meet the

objectives. The chapters that follow incorporate

and expand on (1) the general performance

objectives, and (2) the system features and

capabilities. The first eight chapters are arranged

in a sequence corresponding to the system

capabilities required by 10 CFR 74.31(c)(1) through

(8), of which (c)(5), and hence chapter 5, deals

with the first performance objective of confirming

the presence of SNM. Chapters 9 and 10 address

the second and third performance objectives ---

"resolving indications of rissing uranium' and aid

in the investigation and recovery of nissing

material". Chapter 11 deals with the record

keeping requirements of 10 CFR 74.31(d).

Together these 11 chapters provide applicants or

licensees an outline for an FNMC plan.

The body of an FNMC plan, corresponding to

Chapters 1 through 11, shall be a condition of

license, and compliance with the FNMC plan

commitments, the required affirmations, and related

procedures will be inspectable. Explanations and

discussions appearing in the body of the plan should

be detailed and precise, as opposed to general and

vague, so that all parties concerned (i.e., NRC

licensing reviewers, NRC inspectors, and licensee

personnel responsible for plan execution) have a

clear and nonconflicting understanding of the what,

how, and when aspects of each plan commitment.

The annex (or appendix) of an FNMC plan should

provide supplementary and general information

about the facility and the MC&A system e.g.,

copies of blank record forms, site map, process

diagrams, an example standard error of the

inventory difference (SEID) calculation, etc.]. The

annex will not be incorporated as a condition of

license and will not be the basis for inspection.

Thus, descriptions presented by the applicant or

licensee to satisfy regulatory intent must be in the

plan itself, rather than the annex, and must provide

adequate detail so as not to be largely dependent on

examples or supplementary information in the

annex for proper understanding.

1 NUREG-1065 Rev. 2
Performance Objectives, System Features

and Capabilities, and Affirmations

Performance Objectives

The general performance objectives and the system

capabilities to be addressed by the FNMC plan are

set forth in 10 CFR 74.31. The basis on which

each of the three general performance objectives

and eight system capabilities were formed is

described in the following paragraphs of this section

together with identification of the related required

licensee affirmations.

General Performance Objectives

1. Confirm the presence of special nuclear

material

The purpose of this objective is to verify the

presence of or to detect the occurrence of

any significant loss or theft of special nuclear

material (SNM). To naintain current

information of the SNM in their possession,

licensees should have in place a program that

provides timely, accurate, reliable

information about the quantity and location of

materials in their possession. Accurate

information means that item quantities for

both the element uranium and the isotope U235 are based on measured values or on

reliable factors. Reliable information means

that the quantity of material in an item and

the location of all items is known (with the

possible exception of items that have been

created, transferred, or consumed within the

past 8 hours) and that the location

designations are specific enough to provide

for the retrieval of the items in a prompt

manner. Reliable informtion also-means

that the quantities and locations of all classes

of material and'items listed in the'accounting

records are correct and verifiable (with the

possible exception of items that have been

created, transferred, or consumed within the

past 8 hours).

The licensee or applicant should accurately

account for all SNM that is received and

shipped by maintaining reliable records based

on accurate measurements. When a shipment

is received, the licensee should begin

monitoring movement and location of the

material within the facility using item control

procedures (1) to monitor the location and

integrity of items until they are introduced to

the process and (2) to ensure all SNM

quantities of record associated with receipts,

shipments, discards, and ending inventory

are based on measurements.

Recommendations for meeting the

- performance objectives for the item control

program are provided in Chapter 6 of this

document, and for measurements and

measurement control programs are provided

in Chapters 2 and 3, respectively.

Monitoring the material in process may

involve the use of process or material control

data. A detailed and accurate recordkeeping

system for the generated data that provides

knowledge of the material's location on a

timely basis should be maintained to support

this function.

The licensee should conduct total plant

physical inventories at an average interval of

no more than 12 months, with no single

interval (between any two consecutive

physical inventories) being greater than 13

calendar months. Each physical inventory

must be conducted in a manner that provides

at least a 90 percent power of detecting any

actual loss or theft of a detection quantity

(DQ) that may have occurred since the last

yearly inventory. A DQ is a site-specific

quantity of U-235, the magnitude of which is

discussed in Chapter 4 of this document.

The icensee should verify the presence of all

SNM currently possessed by the facility, as

stated in its accounting records. This

verification is normally accomplished by a

shutdown and cleanout of processing

equipment, measurement of cleanout

materials and measurement of any materials

not previously measured in their existing

form, visual verification (on a 100 percent

basis) of the presence of all possessed SNM

items (by means of unique item identities),

and confirning the SNM quantities

associated with unencapsulated and unsealed

items on ending inventory. However, a

dynamic (i.e., nonshutdown) inventory of

some or all processing equipment may be

utilized if the measurement uncertainty

associated with the total material balance (for

3 NUREG-1065 Rev. 2
Objectives and Capabilities

the inventory period) is within the 0.25

percent of active inventory constraint

specified in 10 CFR 74.31(c)(4).

Recommendations pertaining to physical

inventories are detailed in Chapter 5 of this

document. In summary, a total plant

physical inventory involves:

(1) verifying the presence, on a 100

percent basis, of all uniquely identified

SNM items listed in the accounting

records

(2) measuring (by direct measurement or,

if direct measurement is not feasible,

by indirect measurement) all bulk

SNM quantities on hand (i.e., all

SNM not in item form)

(3) measuring any items not previously

measured

(4) verifying the identity and integrity of

all encapsulated items and items

affixed with tamper-indicating seals

(5) measuring a SNM related parameter

for a sample of randomly selected

unencapsulated and unsealed items,

based on a statistical sampling plan, to

verify the previously measured

quantities of SNM contained in such

items

The physical inventory program should be

managed and maintained independent of the

production or operations organization but

should not be excluded from using process

monitoring and production control data.

2. Resolve Indications of Missing Uraniun

The licensee or applicant should have a

formalized program to resolve any indication

that SNM is missing. Resolution of such

indicators means that the licensee has made a

determination that a theft or loss of SNM has

not occurred. Only indications that suggest a

possible loss of items or material from items

equal to or greater than 500 grans of U-235

need be investigated; a possible loss of a

detection quantity detected'during a material

balance closure needs to be investigated and

resolved in accordance with 74.31(c)(5).

Multiple loss indications from items and/or

process equipment within a material balance

period must be resolved even though the loss

from each event is less than 500 grams of

U-235. This resolution need not occur until

the total potential loss equals or exceeds 500

grams of U-235.

Resolution of an indicator depends on the

type of indicator. Anomalies at plants can

indicate a number of scenarios from simple

theft to complex diversions. The resolution

process in some cases should begin with a

thorough review of the MC&A records to

locate blatant errors. These errors might

include omissions of entire items, incorrect

entries to computer programs or records,

transcription errors, incorrect estimates of the

amount of holdup in equipment, or

calculational errors. A detailed examination

of the MC&A records for each material type

should identify gross errors. The next stage

in the resolution process would be to isolate

the process or storage area that appears to be

causing the anomaly. Once this is

accomplished, all of the information that

contributed to the SNM quantities for that

location should be verified. If resolution still

is not accomplished, the licensee should

remeasure and sample material in the process

or storage areas to verify quantities. If the

investigation of an indicator results in a

determination that an actual loss or theft has

occurred, the loss or theft must be reported

to NRC pursuant to 10 CFR 74.11.

3. Aid in the Investigation and Recovery of

Missing Material

If the NRC and/or other government agencies

deem it necessary to conduct an investigation

relating to actual (or highly suspected) events

pertaining to missing material, the licensee is

to provide, without specifically being asked,

any information deemed relevant to the

recovery of material involved in a loss, theft,

or diversion . The burden shall be on the

licensee to provide (without being asked) all

information that it recognizes as being

relevant, as opposed to providing only

information that the investigators request.

Additional information and recommendations

pertaining to providing information to aid in

NUREG-1065 Rev. 2 4
Objectives and Capabilities

investigations are provided in Chapter 10 of

this document.

The licensee is required to make affirmations

with respect to these three performance

objectives and the eight system capabilities, and

these must be stated (without any modification)

in the FNMC plan. The affirmations are listed

below:

Affirmations Pertaining to Performance

Objectives

* An MC&A system will be maintained that is

capable of confirming, at least annually, the

presence of all SNM expected to be present

(at a given time) based on the ac'counting

ledgers, with the possible exception of waste

materials transferred to (via DOE/NRC Form

741 transactions) and stored in holding

accounts.

* An expeditious investigation will be promptly

initiated for all indications of significant

losses (500 grams of U-235) of SNM and

each alegation or indication of SNM theft.

* Information will be provided to appropriate

Federal Authorities to aid in their investigation of indications of missing naterial and in

the recovery of SNM in the event of a loss,

theft, or unauthorized diversion.

* A cause or probable cause that is based on

objective evidence will be assigned to each

indication of possible loss that is

investigated.

* The results of all investigations of alleged

thefts, and any indications of a significant

loss (500 grams U-235) which remain'

unresolved after 30 calendar days shall be

reported to the'appropriate NRC MC&A

licensing authority.

Affirmations Pertaining to SystemCapabilities

To meet the three general objectives, the MC&A

system depends on features and capabilities as

required by 10 CFR 74.31(c)(1) through (c)(8) and

74.31(d). These system capabilities and their'

related affirnation statements are identified below,

and are discussed in Chapters I through 8 and 11 of

this document.

(1) Establish, document and naintain a

management structure which assures clear

overall responsibility for material control and

accounting functions, independence of

MC&A management from production

-responsibilities, separation of key

responsibilities and adequate review and use

of critical material control and accounting

procedures.

In its FNMC plan,-the licensee must make

the following affirmations with respect to

managernent structure:

* Responsibility for the overall MC&A system

management is assigned to a position that is

separate from production responsibilities or

any other responsibilities that may give rise

to conflict of interest.

* The responsibility for each MC&A function

is assigned to a specific position in the

organization, and the organization is

structured in a way that the key functions are

separated or overcheck one another. The

position descriptions are available in writing

to the personnel affected.

* The facility organization and the MC&A

policies and procedures are documented.

* All critical MC&A procedures, and any

revisions thereto, are reviewed and approved

prior to their implementation.

* Management policies are established,

documented and maintained to ensure that all

critical MC&A procedures are adhered to

including measurement procedures used for

accountability purposes.

(2) Establish and maintain a measurement system

which ensures all quantities in the material

accounting records are based on measured

values.

5 NUREG-1065 Rev. 2
Objectives and Capabilities

The licensee must make the following affirmations with respect to the.

accountability measurement system: * A program of measurement procedures and

methods is maintained for all SNM receipts, removals and inventory items, and all

quantities of SNM in the material accounting

records are based on measured values.

* Measurement systems that are the key

contributors to the total measurement

standard error will be identified. The list

will be reviewed annually and updated as

necessary. These are considered as key

measurement systems and their standard

deviations are monitored and controlled by

the measurement control program.

(3) Follow a measurement control program

which assures that measurement bias is

estimated and significant biases are

eliminated from inventory difference values

of record.

The licensee must make the following affirmations with respect to measurement

quality:

* A measurement control program is followed

by which all measurement biases associated

with key measurement systems, are estimated

and any significant biases are eliminated

from inventory difference (ID) values and

shipper/receiver differences.

* The calculation of the measurement

contributions to SEID are traceable to the

appropriate measurement error data and to

the calibration standards used.

* The total measurement uncertainty is

controlled so that twice its standard error for

each material balance period will be less than

the greater of 9,000 grams of U-235 or 0.25

percent of the active U-235 inventory for the

inventory period. (NOTE: "Twice the

standard error associated with total

measurement uncertainty" can also be

denoted as LEID", i.e., "the limit of error

of the inventory difference").

* The measurement systems have adequate

calibration frequencies, sufficient control of

biases, and sufficiently small standard

deviations to achieve the requirements of

74.31(c)(4). A measurement control

program is used by both in-house and by any

utilized contractor to assure that the quality

of the measurements is maintained on a level

consistent with the regulatory requirements.

(4) In each inventory period, control total

material control and accounting measurement

uncertainty so that twice its standard error

is less than the greater of 9,000 grams of

U-235 or 0.25% of the U-235 active inventory, and assure that any measurement

performed under contract are controlled so

that the licensee can satisfy the requirements.

(5) Unless otherwise-required to satisfy 10 CFR

Part 75, perform physical inventories at least

every 12 months (with no more than 13

calendar months between any two consecutive physical inventories); and, within 60

days after the start of the inventory, reconcilc

and adjust the book inventory to the results

of the physical inventory, and resolve, or

report an inability to resolve, any inventory

difference which is rejected by a statistical

test which has a 90% power of detecting a

discrepancy of a quantity of U-235

established by NRC on a site specific basi..

The licensee must make the following

affirmations with respect to physical

inventories:

* An MC&A system will be naintained that ,

capable of confirning, at least annually, the

presence of all SNM expected to be present

(at a given time) based on the accounting

ledgers, with the possible exception of wate

materials transferred to (via DOE/NRC

Form 741 transactions) and stored in holding

accounts.

* Unless otherwise required by Facility

Attachments that satisfy 10 CFR Part 75,

physical inventories will, on the average, be

performed at least every 12 months (with no

more than a 13 calendar month interval

between consecutive physical inventory dates)

and will be used as the basis for reconciling

and adjusting the book inventory which is

done within 60 days after the start of each

physical inventory.

* For each physical inventory, inventory

procedures are clearly written and are

reviewed and approved by the individual

NUREG-1065 Rev. 2 6
Objectives and Capabilities

responsible for the conduct of the physical

inventory.

* The individual responsible for the conduct of

the physical inventory is either free from

potential conflicts of interest or is

overchecked sufficiently to prevent

compromising the validity of the physical

inventory.

* Each physical inventory listing will include

all SNM possessed (on the inventory date),

with the possible exception of waste materials

assigned to holding accounts (in accordance

with DOE/NRC Form-741 instructions) and

residual holdup that can be regarded as zero

by definition, and that all such listed SNM

quantities shall be based on measurements

(for SNM quantity).

* Within 60 days after the start of each

physical inventory, the inventory difference

will be determined. Any inventory

difference, which is rejected by a statistical

test that has a 90% power of detecting a

discrepancy of a quantity of U-235

established by the NRC on a site-specific

basis, will be reported to the appropriate

MC&A licensing and MC&A inspection

organizational units at NRC Headquarters.

* Discrepancies in the identity, quantity or

location of items, objects or containers of

SNM that are detected during a physical

inventory will be corrected.

* Inventory difference values will be corrected

for (1) accounting adjustments resulting from

prior period activity, and (2) significant

biases that have not been'previously taken

into account. (NOTE: See the definition of

.significant bias' in Chapter 4 of this Plan).

* Adjustments made to reconcile the book

inventory to the physical inventory are in

accordance with standard accounting

practices and are traceable and auditable in

the MC&A records.'

* Whenever a finalized U-235 ID (after

applying any appropriate bias corrections and

prior period adjustments) is greater than the

U-235 detection threshold (DT) and is not

resolved within the 60-day reconciliation

period, all SNM processing will be halted

unless otherwise authorized by the NRC.

[NOTE: This applies to both positive and

negative ID values.]

* The results of all physical inventories and of

investigations and resolution actions following any excessive U-235 ID are recorded and

auditable. An excessive ID is one (regardless of the algebraic sign) that exceeds both

3.00 times SEID and 9,000 grams U-235.

(6) Maintain current knowledge of items when

the sum of the time of existence of an item,

the time to make a record of the item, and

the time necessary to locate the item exceeds

14 days. Store and handle, or subsequentlv

measure, items in a manner so that

unauthorized removals of substantial

quantities of material from items will be

detected. Exempted are items individually

containing less than 500 grams of U-235 up

to a total of 50 kilograms of U-235, solution.

with a concentration of less than 5 grams of

U-235 per liter, and items of waste destined

for burial or incineration.

The licensee must make the following

afirmations with respect to maintaining

current knowledge of items and detecting

unauthorized removals:

* For items not exempted from item control

program coverage, a record system is

maintained to provide a knowledge of the

current status of such items for which the

sum of the elapsed time from initial

generation of the item plus the time required

to locate the item, including any time

required to complete or update item records,

would exceed 14 calendar days. For items

subject to this commitment, the item control

and records system provides the capability to

promptly, locate and confirm the existence of y . i_t..em.

any specific item or group of items upon

demand. The item record system is secured

in such a manner that the record of an item's

existence cannot be destroyed or falsified by

a single'individual without a very high

probability of detection.

7 NUREG-1065 Rev. 2
Objectives and Capabilities

* Each item (unless it is an exempted item) is

stored and handled in a manner that enables

detection of or provides protection against

unauthorized or unrecorded removals of

SNM; otherwise knowledge of the SNM

content is assured by seals or maintaining the

item as a sealed source (i.e., as encapsulated

material).

* All incidents involving missing or

compromised items or falsified item records

are investigated. (A compromised item is

one for which there is evidence of tampering

or which is found outside its assigned

controlled access area.)

* The contents of a compromised item or an

unsealed, unencapsulated item located after it

has been missing will be redetermined by

measurements (i.e., by NDA or by weighing,

sampling and analysis).

(7) Resolve on a shipment basis and, when

required to satisfy Part 75 of this chapter,

also on a batch basis, shipper/receiver

differences that exceed both twice the

combined measurement standard error for

that shipment (and/or batch) and 500 grams

of U-235.

The licensee must make the following

affirmations with respect to resolving

shipper/receiver differences:

* Each shipment received is inspected for loss

or damage to the container or seals to

determine if SNM could have been removed.

If the integrity of the shipping container is

questionable, the presence of all items that

were packaged in the container will be

verified.

* Except for those materials specifically

identified as exempted in Chapter 7 of this

FNMC plan, measurements of the quantity of

SNM received in each shipment are

performed and the shipper/receiver difference

is tested for statistical significance.

Occurrences of significant shipper/receiver

differences in excess of 500 grams U-235

and missing items are reported to the shipper

promptly.

* For SNM received, shipper/receiver

differences that are statistically significant

and also greater than 500 grams U-235, on a

total shipment basis (and also on a batch

basis when subject to 10 CFR Part 75), are

detected within 30 days of receipt except for

those materials specifically identified in

Chapter 7 of this FNMC plan as being

exempted from shipper/receiver evaluations.

* Measurement results for shipments and

receipts are corrected for biases that are

significant at the 0.05 level (i.e., for any bias

that exceeds two times the standard error

associated with a mean), and which impact

individual items by more than their rounding

error in terms of U-235 and/or uranium

content.

* A significant shipper/receiver difference,

e.g., one that exceeds both twice the

combined measurement standard deviation

for that shipment (and also any batch when

subject to Part 75) and 500 grams of U-235,

is promptly investigated and resolved on a

shipment basis and also on a batch basis

when required to satisfy 10 CFR 75.4(d).

* Significant shipper/receiver differences, as

defined above, are reported to the

appropriate NRC safeguards licensing

organizational unit by telephone or facsimile

within 5 calendar days of determining such

significant difference.

(8) Independently assess the effectiveness of the

material control and accounting system at

least every 24 months, and document

management's action on prior assessment

recommendations.

The licensee must make the following

affirnations with respect to independent

assessment and evaluation of the MC&A

system effectiveness:

* The capabilities and performance of the

MC&A system will be reviewed and its

effectiveness will be independently assessed

at least every 24 months. That is, the

nominal elapsed time from the completion of

one review/assessment to the completion of

the next will not exceed 24 calendar months.

NUREG-1065 Rev. 2 8
Objectives and Capabilities

* Reviews and assessments are performed

either by qualified individuals from outside

or qualified individuals from inside the

facility organization whose work assignments

and positions within the organization will not

inpair their ability to nake objective

judgements of the MC&A system capabilities

and performance.

* Each overall review and assessment will be

conducted and completed in a time frame that

is short with respect to the time for changes

to have occurred in the MC&A system and

will include any such changes made during

the time the review/assessment is being

conducted.

* The completion date for any

review/assessment is defined as the date

when the team submits its final written report

(of findings and recommendations) to plant

management. The start date is the first day

in which one or more team members actually

inspect records and/or interview MC&A

personnel, and such start date will be

documented.

* The assessment team leader will have no

responsibility for managing or performing

any of the MC&A functions.

* The results of the assessment and

recommendations for corrective action, if

any, will be documented and reported to the

plant manager and other managers affected

by the assessment. Management will review

the assessment report and take the necessary

actions to correct MC&A system

deficiencies. Such corrective actions (if any)

that pertain to daily or weekly activities will

be initiated within 40 calendar days following

the submittal of the review/assessment final

report.

* Management's response to recommendations

from the review and assessment, including

any corrective actions ordered by

management and the expected time frame for

completing such actions, will be documented

within 30 days following the submittal of the

team's report.

The MC&A recordkeeping requirements of 10 CFR

74.31 (d) are as follows:

(1) Each licensee shall establish records that will

demonstrate that the system capabilities

requirements have been met and maintain

these records for at least three years, unless a

longer retention time is required by Part 75

of this chapter.

(2) Records which must be rnaintained pursuant

to 10 CFR Part 74.may be the original or a

reproduced copy or a microform, if such

reproduced copy or rnicroform is duly

authenticated by authorized personnel and the

microform is capable of producing a clear

and legible copy after storage for the period

specified by Commission regulations. The

record also may be stored in electronic media

with the capability for producing legible,

accurate, and complete records during the

required retention period.' Records such as

letters, drawings,'and specifications must

include all pertinent information such as

stamps, initials, and signatures.

(3) The licensee shall 'naintain adequate

safeguards against tampering with and loss of

records.

The licerLsee must make the following

affirrmations with respect to recordkeeping:

* A record retention system is maintained for

those records necessary to show that the

MC&A system requirements of 10 CFR

74.3 1(c) have been met. Such records are

retained for at least thre'e years. The records

referred to in 10 CFR 75.22 and 75.23 and

generated during any period that the facility

is under International Ato'rnic Energy Agency

(IAEA) safeguards will be retained for at

least five years. Records of the following

will be maintained current and will be

retained for at least three years:

- Management structure, MC&A job

descriptions, and MC&A policies and

procedures;

- Accounting source data records

(accounting source data normally

9 NUREG-1065 Rev. 2
Objectives and Capabilities

consist of shipping and receiving

forms, physical inventory forms, and

the forms used for initially recording

measurement and measurement control

data. After an item is destroyed, the

item location record needs to be

retained for an additional 14 days but

then may be destroyed);

Records of shipmeints and receipts and

investigations of significant

shipper/receiver differences plus the

information used to resolve them;

Measurement data for receipts,

shipments, discards, and inventory;

Calibration of measurement systems,

measurement control data, bias

estimates, and the statistical analyses

of the measurement control data;

* Sufficient protection and redundancy of the

record system is provided so that an act of

record alteration or destruction will not

eliminate the capability to provide a complete

and correct set of SNM control and

accounting information that could be used to

confirm the presence of SNM, resolve

indications of missing material, or aid in the

investigation and recovery of missing

material.

* Ready traceability will be provided for all

SNM transactions from source data to final

accounting records.

The following chapters of this document incorporate

and expand on the performance objectives and on

the system features and capabilities of 10 CFR

74.31. The chapters are arranged in a format and

sequence to provide applicants and licensees an

outline for the FNMC plan.

Data used to demonstrate that the

measurement system performance

achieves the standard deviation limits

required by 10 CFR 74.31(c)(4);

Physical inventory listings and

inventory work sheets;

Calculations of detection thresholds for

excessive IDs of a safeguards

significance (i.e., ID alarm point for

detecting a loss equal to or greater

than DQ);

Calculations of the standard error of

the estimated ID and information used

to reconcile an excessive ID (i.e., an

ID that is > 3.00 times SEID);

Reports of investigations and

resolution of indications of loss of

SNM; and

The results of independent assessments

and management action taken to

correct any deficiencies identified.

NUREG-1065 Rev. 2 10
1 Organization

1.0 Regulatory Intent

The intent of 10 CFR 74.31(c)(1) is to require

licensees to implement a management structure that

permits effective functioning of the MC&A system,

and assures that the MC&A program performance

will not be adversely affected by the plant

management structure. Documentation, review and

approval of the procedures, and the assignment of

the key functions to specific positions eliminates

ambiguities about what is to be done by whom.

The management structure is meant to separate key

MC&A functions from each other in order to

provide overchecks that increase MC&A system

reliability and counter defeat of the system through

deceit and falsification. It is also meant to free

MC&A management from conflicts of interest with

other major functions such as production.

1.1 Corporate Organization

The corporate structure'should be described, and all

corporate organization positions that have responsibilities related to MC&A at the licensee's site

should be identified. A description of the

corporate-level functions, responsibilities, and

authorities for MC&A program oversight and

assessments should be provided. At least one

corporate official should have responsibilities

pertaining to the control and accounting of all SNM

possessed by the licensee.

1.2 Plant or Site Organization

A description of the site's management structure

emphasizing MC&A should be provided. The site

management structure should be described to the

extent that it can be clearly shown that the MC&A

organization is independent of potentially

conflicting responsibilities. This description should

also indicate how responsibilities are assigned for

the following functions:

(1) overall MC&A program or system

(2) SNM custodianship

(3) receiving and shipping of SNM

(4) analytical laboratories

(6) sampling operations

(7) measurement control program

(8) physical inventories

(9) on-site SNM handling operations

A brief description should be provided for each

site-level position, outside of the MC&A

organization,'that has responsibilities relating to

MC&A activities (e.g., sampling, nass

measurements, analytical measurements, and

measurement control). For each position, the

functions, responsibilities, and authorities should be

clearly described.

1.3 MC&A Organization

An organizational chart and position-by-position

description of the entire MC&A organization should

be provided. An individual should be designated as

the overall manager of the MC&A program and the

FNMC plan must demonstrate the assurance of

independence of action and objectivity of decision

for the MC&A manager. Two options for meeting

the organizational independence are (1) report

directly to the plant or site manager or (2) report to

an individual who reports directly to the plant or

site manager and who has no production

responsibilities.

1.3.1 Responsibilities and Authority

A description that clearly indicates the

responsibilities and authority of each supervisor and

manager should be provided for the various

functions within the MC&A organization. The

description should indicate how the activities of one

functional unit or individual serve as a control over,

or checks on, the activities of other units or

individuals. The FNMC plan should explain how

coordination is achieved and maintained between

the MC&A organization and other plant 

organizational groups that perform MC&A-related

activities' A'definitive statement should be made

specifying how the MC&A manager assures

appropriate review and approval for all written procedures pertaining to MC&A-related activities, and

to any future revisions thereto, that are issued both

within and outside of the MC&A organization. In

(5) bulk and NDA measurements

I1I NUREG-1065 Rev. 2
Organization

addition to the MC&A manager function, the

functions to be addressed should include, as a

minimum, the following:

(1) nuclear material accounting

(2) measurement control program

(3) item control program

(4) statistical applications

Whenever more than one key MC&A function is

assigned to the same person, the FNMC plan

should clearly describe the checks and balances that

preclude the following:

(1) performance of accounting or record control

functions by individuals who also generate

source data

(2) assignment of sole authority to any individual

to overcheck, evaluate, or audit information

for which he or she is responsible

1.3.2 MC&A Procedures

Critical MC&A procedures to be described are

those written procedures which, if not performed

correctly, could result in a failure to achieve one or

more of the performance objectives of 10 CFR

74.31(a) and the system capabilities of 10 CFR

74.31(c). All critical MC&A procedures should be

identified in the body of the FNMC plan. The

FNMC plan also should contain a definitive

statement that the procedures will be followed.

This set of critical MC&A procedures should, as a

minimum, adequately address the following topics,

regardless of which facility organizational group is

responsible for the particular topic:

(1) accountability record system

(2) sampling and measurements

(3) measurement control program

(4) item control program

(5) physical inventories

(6) investigation and resolution of loss indicators

(7) determination of SEID, active inventory, and

inventory difference

(8) providing information to aid in investigations

(9) MC&A recordkeeping system

(10) independent assessment of the effectiveness

of the MC&A program

1.4 Training and Qualification

Requirements

This section of the FNMC plan should describe the

training programs to be established and maintained

to provide qualified personnel and to provide for

the continuing level of qualification with respect to

personnel assigned to MC&A responsibilities.

Training procedures and qualification criteria

should be discussed in definitive statements.

Minimum qualification requirements should be

stated for each key MC&A position.

1.5 MC&A System Description

The length of this section and its level of detail will

be dependent on the information provided in the

previous sections of this chapter. The overall

MC&A organization should be described in a

manner that explains how the general performance

objectives of 10 CFR 74.31(a) and the capabilities

of 10 CFR 74.31(c) will be effectively achieved.

The individual who has responsibility for each of

the following MC&A-related functions should be

specified by title:

(1) overall MC&A program management (Note:

This individual should have no major non

MC&A-related responsibilities.)

(2) measurements [Note: Responsibility may be

divided on the basis of type of measurements

(e.g., analytical laboratory measurements,

NDA measurements, bulk measurements, and

sampling).]

(3) measurement control and statistics

(4) accountability records

NUREG-1065 Rev. 2 12
Organization

(5) item control

(6) physical inventories

(7) custodial responsibilities (e.g., SNM storage

and movement controls)

(8) investigation and resolution of indicators that

suggest possible loss of SNM

(9) receiving and shipping of SNM

(10) analytical laboratories

(11) MC&A recordkeeping system and controls

The information in this chapter should include a

description of the policies, instructions, procedures,

duties, responsibilities, and delegation of authority

in sufficient detail to demonstrate the separation of

duties or overchecks built into the MC&A system.

This section should also include a discussion

relating to critical MC&A procedures including a

summary of the review, approval, and

implementation control and requirements. Critical

MC&A procedures and all changes to them should

undergo technical review by cognizant members of

the staff and be approved by line management

directly affected and by a level of management

above the level responsible for executing the

procedures (but not beyond on site plant

management).

1.6 Acceptance Criteria

A judgment that the applicant's or licensee's

approach for establishing and documenting an

effective MC&A program that will be maintained

by an acceptable organizational (management)

structure, as described in the FNMC plan, will be

based on (but not limited to) the following criteria:

* The authorship, approval authorizations, and

effective dates of MC&A policies and

procedures will be documented, and will

involve appropriate management and

technical staff.

* The responsibilities and authorities for each

position assigned a function having a

significant impact on SNM control and

accounting (including all positions authorized

to control SNM movement, generate source

data, define and/or implement measurement

control requirements, and conduct data

analysis) are clearly defined in a written

position description that defines the

responsibilities for that position.

* The qualifications and experience required

for each position assigned an SNM control

and accounting function will be sufficient to

permit adequate performance of the duties

required of that position.

* The descriptions (in the FNMC plan) of the

management structure and assignment of

duties and authorities show that those

responsible for each MC&A function will

have sufficient authority to perform the

function in the intended manner.

* The MC&A organization is separate from the

production organization and is also separate

from organizations that generate source data,

if practical; otherwise, independence of the

functions is attained by suitable controls and

overchecks.

* The responsibility for MC&A program

management is designated to an individual at

an organizational level sufficient to assure

independence of action and objectiveness of

decisions.

* No two key MC&A functions are assigned to

the same person unless adequate checks and

balances are provided. As a consequence of

this criterion:

- Individuals who generate source data,

such as performing measurements, or

perform shipping and receiving

activities, do not perform any

accounting or record control functions

unless suitable overchecks are

provided to prevent falsification of

both source data and accounting

records, and

- No individual has the sole authority to

overcheck, evaluate performance, or

audit information for which he/she is

responsible.

* Critical MC&A procedures and all changes

to them which directly affect the licensee's

ability to detect the loss of SNM or to

13 NUREG-1065 Rev. 2
Organization

resolve indications of missing SNM, as per

10 CFR 74.31(a), undergo technical review

by cognizant members of the staff and will

be approved by line management directly

affected and by a level of management above

the le-vel responsible for executing the critical

procedures (but not beyond on-site

management).

All current critical MC&A procedures are

made easily accessible to all affected

individuals, and are maintained to show for

each procedure (1) the revision number, (2)

date issued, (3) who prepared the procedure,

and (4) who approved the procedure (as

indicated by signature and date signed).

1.7 Affirmations

The five affirmation statements related to MC&A

management structure, given on page 5 under

section (1), must be stated (without modifcation) in

the FNMC plan.

NUREG-1065 Rev. 2 14
2 Measurements

2.0 Regulatory Intent

The intent of 10 CFR 74.31(c)(2) is that licensees

must maintain a system of measurements to assure

that all quantities of SNM (both element and fissile

isotope) in the accounting records are based on

reliable measurements. The measurement

uncertainty associated with the values entered into

the accounting records must be sufficiently small so

as to assure that the limit specified in 10 CFR

74.31(c)(4), for the total MC&A measurement

uncertainty (associated with a physical inventory

material balance), is not exceeded. Except for

sealed sources, samples, and other certain

materials, all SNM receipts'are to be measured for

the purpose of performing shipper-receiver

evaluations. In the absence of any significant

shipper-receiver difference, a licensee may book

either its measured values or the shipper's measured

values. When recording shipper's values (for SNM

receipts), the measurement uncertainty associated

with the shipper's values needs to be known and

used in the determination of SEID. It is also

intended that a licensee's measurement program

provide bias estimates to be used in correcting

inventory difference values and shipper-receiver

differences for significant measurement biases. The

estimation of measurement bias is discussed in

Chapter 3 (Measurement Control Program).

2.1 Measurement Points

The FNMC plan should identify and describe each

measurement that is used for accounting purposes.

Measurements (1) establish the quantities in each

custodial area, material balance area (MBA), or

item control area (ICA) and in the facility as a

whole, and (2) contribute to the desired capability

to localize losses and to generate and to assess

alarms. Measurement points and/or sampling -

stations should be selected to provide quantitative

information about material flows and inventories

that will permit detection and localization of any

loss or diversion, or to confirm that no diversion

has occurred. Typically, three functional types of

MBAs and ICAs are present: (1) processing,--(2)

storage, and (3) receiving and shipping. The

identification and definition of measurement points

for processing MBAs are necessary because of the

physical or chemical changes of the nuclear

materials that occur in these MBAs. The storage

and the'receiving and shipping areas are typically

ICAs. Typical processing MBAs include (1)

processing areas, (2) decontamnination and recovery

areas, (3) laboratory areas, and (4) feed and

product sampling and transfer areas.

2.2 Measurement Systems

The FNMC plan should describe in detail each

measurement system used for nuclear material

accounting purposes. The principal elements and

operations involved in the measurement systems for

MC&A encompass mass (or weight) or volume

determination; sampling; chemical analyses for

element and isotope; and nondestructive assay

(NDA). Each measurement system should also be

defined or identified by its unique set of the

following parameters: (1) measurement device or

equipment used, (2) standards used for calibration,

and (3) standards used for control. Additionally,

for analytical laboratory measurements, the

following'also should be identified: '(1) sampling

technique and equipment used, (2) sample

aliquoting tech-nique, and (3) sample pretreatment

methodology. Elements of the measurement control

program (e.g., standards traceable to a national

system) used for validating and determining control

limits, precision, and accuracy levels for each

measure-ment system used for accountability are

described in Chapter 3.

The FNMC plan should provide descriptions for

each measurement system associated with bulk,

analytical, and NDA measurements, and should

identify, where applicable, any other measurement

systems used for accounting urposes that do not

fall within these-categories. These descriptions

should provide sufficient information to demonstrate

how the systems are implemented to ensure the

capability to meet the precision and accuracy limits.

The following sections provide examples of the

types of information necessary for selected

measurement systems.

2.2.1 Bulk Measurement Systems

For each weighing system, the applicant or licensee

should specify the type of weighing device, the type

of container(s) weighed, material within the

containers being weighed, capacity of the weighing

device, range to be used, sensitivity of the device,

and the calibration frequency. The description

should include the capacity and the sensitivity of the

scale (e.g., capacity not to exceed X kilograms, and

sensitivity to be at least as good as Y grams).

For each volume measurement system, the FNMC

plan should identify the vessel (e.g., tank, column,

etc.), capacity of the vessel to which the

measurement applies, the material being measured,

the volume measuring device and instrumentation,

the sensitivity of each device and system, the range

15 NUREG-1065 Rev. 2
Measurements

of operation and/or calibration, and the calibration

frequency.

2.2.2 Analytical Measurement Systems

For each analytical measurement system, the

FNMC plan should specify the following:

(1) type of material or chemical compound (e.g.,

UF6, uranium alloy, UO2, uranyl nitrate

solution) being sampled and measured

(2) sampling technique

(3) sample handling (i.e., pre-analysis sample

storage and treatment)

(4) analytical method used

(5) characteristics measured (e.g., grams of

uranium per gram sample, U-235 isotopic

concentration)

(6) measurement interferences

(7) expected measurement uncertainty

(8) types of calibration standard(s) and

calibration frequency

2.2.3 NDA Measurement Systems

For each NDA measurement system, the FNMC

plan should identify the following:

(1) the NDA equipment package (i.e., type and

size of detector, and type of associated

electronics and computer interface, as

appropriate)

(2) the type of container measured

(3) SNM material type within container

(4) attribute measured

(5) measurement configuration (including source

to detector distance)

(6) calculational method

(7) expected measurement uncertainties

2.2.4 Other Measurement Systems

If applicable, the FNMC plan also should identify

any other measurement systems used for accounting

purposes that do not fall within the three categories

covered by subsections 2.2.1, 2.2.2, and 2.2.3.

2.3 Measurement Uncertainties

The expected measurement uncertainties of the

described measurement systems should be provided.

Variance components for calibration, sampling,

random, and systematic error for each measurement

system should be stated. The units in which the

errors are expressed should be clearly identified.

2.4 Measurement Procedures

The licensee or applicant should define how

assurance is demonstrated that measurement

procedures (i.e., methods) are established,

approved, and maintained. This can be

accomplished by (1) making a definitive statement

that an approved measurement procedures (i.e.,

methods) manual, or set of approved manuals, are

established and maintained, (2) stating which

organizational units are responsible for the

preparation, revision, and approval of measurement

procedures, and (3) defining the requirements for

periodic review of the procedures.

A clear statement should be made defining how the

facility assures that a measurement procedure

cannot be used for accountability purposes without

documented approval. Each procedure should be

approved by the overall MC&A manager and by

the manager of the organizational unit responsible

for performing the measurement. Measurement

procedures also should be approved by the

measurement control program manager.

The FNMC plan should provide a definitive

statement that all SNM quantities in the material

accounting records are based on measured values

and that measurement systems are maintained for

the measurement of SNM associated with the

following:

(1) additions to inventory (e.g., receipts)

(2) removals from inventory (e.g., shipments and

measured discards)

(3) material on ending inventory

NUREG-1065 Rev. 2 16
Measurements

For receipt of material, the licensee nay use

shipper's measured values rather than its own

measurements, provided that (1) a shipper-receiver

comparison, based on attributes or confirmatory

measurements, shows no significant shipperreceiver difference (SRD) [as defined by 10 CFR

74.31(c)(7)]; (2) in the case of a significant

difference between shipper and receiver, no

significant difference exists between shipper's value

and the umpire value used to resolve the difference;

or (3) the material in question is exempted from

shipper-receiver comparison requirements (e.g.,

sealed sources and samples). However, when

booking shipper's values, the shipper's

measurement uncertainty should be used when

determining SEID.

2.5 Acceptance Criteria

A judgment as to the acceptability of the applicant's

or licensee's system for accountability measurements, as described in the FNMC plan, will be

based on (but not limited to) the following criteria:

* A basic description or summary of each key

measurement system which is utilized to

generate SNM quantities for accountability

purposes is provided. A measurement

system being defined as any instrument or

device, or combination of devices, used to

derive (1) an element concentration, (2) an

isotope quantity, (3) a U-235 enrichment or

isotopic distribution, (4) a bulk material mass

(weight), or (5) a bulk material volume, and

which can be characterized by its random

and systematic error components.

* The set of key measurement systems, based

on recent (or anticipated) measurement

control data and modes of process

operations, is expected to account for at least

90 percent of the total measurement

uncertainty contribution to the standard error

of inventory difference.

* The recalibration frequency for each

measurement system is compatible with its

expected stability. Recalibrations for all

measurement systems should be performed at

frequencies compatible with widely

established, or licensee demonstrated,

stability for each particular system.

* All calibrations are made with the use of

primary standards or primary reference

materials (certified and issued by NIST or

NBL, or equivalent organization) or with

reference standards traceable to primary

standards. The standards used for

calibrations need not be representative of the

unknowns to be measured by the system

unless it is to be regarded as a bias-free

system that is calibrated during each time of

use, in which case the calibrations standards

must be representative.

When determining an SNM quantity by weighing,

sampling, and analyses, the net weight of material

in each item within an uniform material batch (or

lot), such as blended U02 powder or sintered U02

pellets, must be determined by direct mass

measurement. However, the element and/or isotope

concentrations for the batch need not be determined

for each container, but instead may be derived by

sampling procedures, including:

- Analysis of composite samples or

measurements of representative items,

objects or samples selected by

statistical sampling; or

- Use of concentration and/or

enrichment factors determined from

historical averages, controlled input

specifications values, or empirical

relationships where such values or

relationships are periodically tested,

their uncertainties or bounds have been

determined to be within 2.00 percent

of the factor value, and where

diversions with material substitution

are improbable. However,

heterogeneous materials, such as

ammonium diuranate, may not be

assigned common factors unless the

quantities are small, such as less than

500 grams of contained U-235 (per

material type, per inventory period).

Justification for any materials assigned

common factors without

batch-by-batch verification analyses

must be presented in the FNMC plan.

2.6 Affirmations

The two affirmation statements, given on page 6

under section (2), relating to the measurement

system capability required by 10 CFR 74.31(c)(2)

must be stated (without modification) in the FNMC

plan.

17 NUREG-1065 Rev. 2
3 Measurement Control Program

3.0 Regulatory Intent

The intent of 10 CFR 74.31(c)(4) is that

measurement systems used to establish SNM

accountability quantities be controlled by a formal

measurement control program that results in a U235 total measurement standard error that is within

4500 grams U-235 or 0.125 percent of the U-235

active inventory quantity (whichever is greater).

That is, in terms of a 95 percent confidence level,

twice the standard error associated with a material

balance total MC&A measurement uncertainty (for

U-235) must be less than the greater of 9,000

grams U-235 or 0.25 percent of the U-235 active

inventory. It is also intended that the program

provide bias estimates to be used for adjusting

inventory difference results and correcting shipperreceiver measurements for significant measurement

biases.

3.1 Organization and Management

The organization and management of the

measurement control program should be described

in sufficient detail to show how the measurement

quality assurance function is assigned and how

independence from the analytical laboratory and

other units performing either sample taking or

measurements is maintained. The measurement

control program manager should be at a

management level that is sufficiently high to ensure

objectivity and independence of action. Thus, the

measurement control program manager could either

report directly to the overall MC&A manager or, if

in a different organizational unit, be on the same

level as the MC&A manager.

The licensee's measurement control program should

be properly managed to ensure adequate calibration

frequencies, sufficient control of biases, and

sufficient measurement precision to achieve the

capabilities required by 10 CFR 74.31(c)(3) and

(4).

3.1.1 Functional Relationships

The relationship and coordination between the

measurement control program manager, the

analytical laboratory, and other measurement

performing groups needs to be clearly defined.

Adequate assurance should be provided that the

measurement control program manager has the

authority to enforce all applicable measurement

control requirements.

3.1.2 Procedures

The measurement control program procedures

should be established and maintained in a manual

that is kept current and readily available. This

manual should contain all the currently applicable

written procedures pertaining to measurement

control and measurement quality assurance.

Responsibility for preparation, revision, and

approval of manual procedures should be specified.

Individual measurement control procedures should

have documented approval by the measurement

control program manager. The procedures should

address the following:

(1) calibration frequencies and methods

(2) standards used for calibration (i.e.,

description and storage controls)

.(3)

(4)

(5)

standards used for control (i.e., method of

obtaining or preparation, and traceability)

control standard measurements

replicate sampling and replicate

measurements

(6) verification of process control

instrumentation through comparison with

other process instruments

-(7)

! (8)

control limits and control responses

generation and collection of control data

(9) recordkeeping controls and requirements

3.1.3 Contractor Program Audits and

Reviews

If measurement services are provided by an outside

contractor or off-site laboratory, the review

program used to monitor the off-site measurements

should be described. Such reviews are to ensure

that the contractor or off-site laboratory has'an

acceptable measurement control program to the

extent that use of the contractor's measurements

will not compromise the licensee's ability to meet

any measurement or measurement control 

requirement contained in either 10 CFR 74.31(c) or

in its FNMC plan. An initial review of the

contractor's measurement control program should

be conducted before licensee use of measurements

performed by the contractor or off-site laboratory.

NUREG-1065 Rev. 2

: I 

Pikent th2 ue nf the rnntrarknr'.q mf--q.,,urL-,mt-nt-q

19
Measurement Control

All contractor or off-site laboratory assessment

findings and recommendations should be

documented and submitted to both the measurement

control program manager and the overall MC&A

manager within 30 days of completion of the

review. The two managers should arrive at an

agreement on corrective actions that should be

taken, based on their evaluation of the report, and

should transmit these findings to the contractor or

off-site laboratory in writing. The licensee should

not use measurements performed by such

contractors or off-site laboratories until they have

verified that the corrective actions have been

instituted.

The persons who conduct a contractor review need

not be employed by the licensee; but they should

not be employed by, or in any way associated with,

the contractor or off-site laboratory so that the

independence of the conclusions may be

maintained.

3.2 Calibrations

The FNMC plan should sumnarize the licensee's

calibration program and confirm that the licensee

has-written procedures covering the following

topics:

(I) calibration frequency for each measurement

device or system

(2) identification of the standards used for

calibration of each measurement device or

system

(3) protection and control of standards used to

calibrate measurement systems to maintain

the validity of their certified or assigned

values

(4) the range of calibration for each

measurement device or system and the

minimum number of calibration runs

(observations) needed to establish a

calibration

Unlike control standards, standards used for

calibrating measurement systems need not be

representative of the process material or items to be

measured by the calibrated device or system. If

practical, the standard used during the calibration

process should be subjected to all the steps involved

in the measurement process that the process

unknowns are subjected to (e.g., sample

pretreatment), but this need not always be the case.

It is the primary measurement device, not necessarily the entire measurement system, that needs to

be calibrated, especially when the primary measurement device is common to two or more measurement systems. For example, the Davies & Gray

titrimetric method is often used to analyze samples

for uranium concentration of two or more different

material types (e.g., UF6 , U0 2 , UNH solutions).

In this case, more than one measurement system is

involved because different sampling and sample

pretreatment methods and different control

standards are used. The potassium dichromate

titrant, however, is common to the systems; thus,

the titrant is what is calibrated (or standardized)

with a primary reference material such as certified

K2Cr2O7 , certified U30, or certified uranium metal.

In the case of nonconsumable standards used to

calibrate measurement systems (e.g., weight

standards), the frequency of recertification of

assigned values should be specified. The

recertification frequency should be dependent on

how often the standards are handled, the standard's

stability, and the adequacy of the controls used to

maintain the integrity of the standards. Biennial

recertification of such standards is usually

acceptable.

The FNMC plan should contain a definitive statement that no SNM accountability value is based on

a measurement that falls outside the range of

calibration. The FNMC plan also should identify

those measurement systems that are pointcalibrated. A point-calibrated measurement system

is one in which the following are true:

(I) The entire measurement system is calibrated

with a standard or set of standards that is

representative of the process unknowns that

are measured by the system. That is, the

representative calibration standard(s)

undergoes all the measurement steps, and in

the same manner, that the unknowns do.

(2) One or more calibration standards are

processed and measured along with each

unknown or set of unknowns measured.

That is, both the standard(s) and unknown(s)

are measured during the same general time

interval, with the same individual measuring

both the standard(s) and unknown(s).

(3) The measurement values assigned to the

process unknowns are derived from the

measurement response observed for the

standard(s) that was measured along with the

unknown(s).

NUREG-1065 Rev. 2 20
Measurement Control

(4) The measurement response for each unknown

should fall within plus or minus 10 percent

of the response for a standard measured at

the same time as the unknown, or as in the

case of a low concentration unknown, the

difference between the unknown's response

and the standard's response should be less

than four times the standard deviation

associated with the standard's response.

3.3 Control Standard Program

For those measurement systems that are not pointcalibrated, a defined program for the periodic

measurement of control standards should be

established and followed. Control standard

measurements serve the dual purpose of (l)

monitoring the stability of a previously determined

calibration factor, and (2) estimating the average

system bias over a period of time (e.g., an inventory period). The minimum total number of control

standard measurements during the time period, as

well as the typical frequency, needs to be specified

for each measurement system. Generally speaking,

for each key measurement system, a minimum of

two control standard measurements should be made

during each week that the system is in use. For

those key systems that are used less than eight

weeks during a given material balance period, more

than two control standard measurements per week

of system use may be necessary in order to

provide:

(1) A minimum of 12 control standard

measurements for those systems used during

the material balance period to measure

material totaling less than 100 kilograms of

U-235

(2) A minimum of 24 control standard

measurements for those systems used to

measure a total of 100 or more kilograms of

U-235

Key measurement systems for the current inventory

period are any set of designated measurement

systems (of the licensee's choosing) which, based

on the most recent previous period, account for at

least 90 percent of the total measurement variance

contribution to SEID. Included within the set of

key measurement systems, should be any system

utilized to measure an SNM quantity (during an,

inventory period) greater than 25 percent of the

active inventory, regardless of its contribution to

SEID. The minimum number of control standard

measurements for situations (I) and (2), above, can

be reduced to 8 and 16, respectively, for non-key

measurement systems that measure from 1) to 25

percent of the active inventory, and the minimum

number of control standard measurements for

situations (I) and (2) can be further reduced to 4

and 8, respectively, for those non-key systems used

to measure less than 10 percent of the active.

inventory quantity.

Control standards should be representative of the

.process material or items being measured. To be

representative, the standards need not always be

identical to the process unknowns; but any

constituent of the process material, or any factor

associated with a process item, that produces a bias

effect on the measurement should be present to the

same degree in the control standards. For scales

used to weigh very large items, such as UF6

cylinders, the control standard weights should be

artifact standards (e.g., both empty and full UF6

cylinders) of certified mass to avoid a bias effect

caused by buoyancy or point loading.

For each measurement system that is not pointcalibrated, the control standards to be used for

control standard measurements should be identified

and/or described. Along with material composition

and matrix factors, biases also can be induced by

changes in (among other things) temperature,

humidity, line voltage, and background radiation.

Biases also can be operator or analyst induced.

Therefore, the scheduling of control standard

measurements should be based on the following

considerations:

(1) Does the variation between analysts or

operators need to be considered and hence

monitored?

-(2) Can environmental variables contribute to

measurement bias?

(3) Is bias likely to vary with respect to the time

of day?

(4) Is a particular bias likely to be long term,

short term, or cyclic in nature?

(5) Is bias a function of the process measurement

values over the range of calibration (i.e., is

the relative percent bias nonuniform over the

range of calibration)?

(6) What controls or procedures are needed to

-I ensure that sampling or aliquoting of the

control standard is representative of the

21 NUREG-1065 Rev. 2
Measurement Control

sampling or aliquoting of the process

material?

(7) To estimate the bias for each measurement

system, how much alike - in terms of

chemical composition, uranium

concentration, density, homogeneity, and

impurity content - should the control

standards be relative to the process

unknowns?

3.4 Replicate Program

For systems involving sampling, duplicate measurements performed on single samples and/or measurements of replicate samples are necessary to estimate

the combined analytical plus sampling random

error. For nonsampling measurement systems such

as NDA and weight measurement systems, the

random measurement variance component can be

derived either from (1) replicate measurements

performed on process items, or (2) the data generated from the measurement of control standards.

The licensee should ensure that replicate samples

are independent of one another. The number of

replicate samples measured for each analytical

measurement system, that is designated as a key

measurement system, during an inventory period

should be equal to one of the following:

(1) 100 percent of the accountability batches

sampled (when less than 15 batches)

(2) the greater of 15 samples or 15 percent of

the accountability batches sampled

(3) 50 samples (when 15 percent of the batches

is greater than 50)

For non-key analytical measurement systems, the

minimum number of replicate samples to be

measured during an inventory period should be

equal to one of the following:

(4) 100 percent of the accountability batches

sampled (when less than 8 batches)

(5) the greater of 8 samples or 10 percent of the

accountability batches sampled

(6) 25 samples (when 10 percent of the batches

is greater than 25)

For each measurement system involving sampling

and analysis, the FNMC plan should indicate (1)

how many samples are taken and measured for each

accountability batch measurement, and (2) how

many analyses are performed on each accountability

sample. If two or more samples are used and one

or more analyses per sample are performed for each

accountability batch measurement, replicate

requirements are automatically met. If, however,

one sample per batch is normally used for

accountability purposes, the replicate program

should include a periodic taking of a second (i.e.,

replicate) sample. For NDA and mass (weight)

measurement systems, replicate dst. can be

obtained either from the repeat measurements on

production items or by using the data generated

from the control standard program. That is, each

consecutive pair of control standard measurements

(for a given NDA or mass system) can be regarded

as a replicate pair. The minimum number of

replicate measurements performed during an

inventory period for a given key NDA or mass

system should be as given in items (1), (2), or (3),

above, except that the numbers or percentages are

in terms of items measured, rather than batches

sampled. Likewise, for non-key NDA and mass

measurement systems, the minimum number of

replicate measurements should be as given in items

(4), (5), or (6) above. The scatter in the repeat

measurements is used to estimate the random error

variance using a statistical technique known as the

one-way analysis of variance. (The statistical

methods described in Statistical Methods for

Nuclear Material Management, NUREG/CR-4604,

are recommended by NRC for satisfying the

statistical requirements of 10 CFR 74.31; see also

Chapter 4 of this document.) Replication not only

improves the precision of results obtained from the

statistical analysis of the measurement data, it also

can detect gross errors in the data.

3.5 Control Limits

Both warning and out-of-control limits are to be

established and used for control standard measurements for those measurement systems used for

nuclear material accountability. Out-of-control

limits are also to be utilized for replicate

measurements and measurement of replicate

samples. However, warning limits are optional for

the replicate program. For point-calibrated

systems, the assigned value of the standard(s)

measured along with the unknown(s) is assumed to

be valid. If the standard's true value could change

because of factors such as evaporation, moisture

pickup, or oxidation, the value of the standard

should be checked periodically. Therefore, control

limits for the verification measurements associated

NUREG-1065 Rev. 2 22
Measurement Control

with such standards should be established. This is

especially true for those point-calibrated systems

that use a single standard, or aliquots from a single

standard, over any extended period of time.

The warning and out-of-control limits are nornnally

set by the licensee based on a tradeoff between (1)

the cost of investigating and resolving incidents

where limits are exceeded and (2) the cost of

accepting measurements of poor quality. Warning

limits set at the 0.05 level of significance and outof-control limits set at the 0.001 level of

significance are usually sufficient. When a system

generates a control measurement that falls beyond

an out-of-control limit, the system should not be

used for accounting purposes until it has been

brought back into control (i.e., within the upper

and lower warning limit).

Control limits should be recalculated at a

predetermined frequency and modified if required.

The FNMC plan should clearly explain how control

limits are established and the frequency for

redetermining them.

3.5.1 Measurement Control Data

Analysis

Measurement control data such as control standard

measurement results and the-differences between

measurement values of replicate pairs should be

plotted manually on graphs or entered into a

computer data base for generation of control charts.

All control charts should be reviewed at least once

every two weeks uiless a measurement system was

not used during that period. The review should

assess the frequency of control data exceeding

either the warning or the out-of-control limits and

also provide an evaluation for, any significant

trends.

3.5.2 Response Actions

Either the analyst or the operator performing a

control measurement or their supervisor should

have the responsibility for promptly reporting any

control measurement that exceeds an out-of-control

limit. Such reporting should be made to the

measurement control program manager (or his or

her designee), who should have the responsibility

and authority to carry out or-direct the necessary

response and corrective actions.

Minimum response and minimum corrective action

requirements should be clearly defined. In

addition, the measurement control manager (or his

or her designee) should be responsible for, and

have the authority for, determining and executing

additional response and corrective actions as

deemed appropriate.

The minimum response to a reported incident of a

control measurement exceeding an out-of-control

limit should consist of.the following:.

(1) verifying that the measurement system in

question has been taken out of service with

respect to accountability measurements

(2) documenting the occurrence of the event

(3) performing at least two additional control

measurements

(4) performing additional control measurements,

if results of item 3 do not show the system to

be back in control, using a different control

standard or different replicate sample (as

appropriate) or recalibrating the measurement

system, or making any necessary system.-

repairs

For those measurement systems that make a

significant contribution to the SEID, the response to

an out-of-control condition also should include the

remeasurement of any samples (or items) that were

measured before the out-of-control condition but

after the last within-control measurement. The

validity of the previous' measurements can be

established without a complete remeasurement of all

the samples (or items) involved if remeasurement

on a last in, first out" basis is used.- That is, the

last sample (or item) measured before the

out-of-control measurement, should be the first to

be remeasured, and continuing in reverse order

until two consecutive remeasurements are found to

be in agreement with their initial measurement at

the 95 percent confidence level.

3.6 Acceptance Criteria

A judgment as to whether the applicant's or

licensee's measurement control program, as

described and committed to in the FNMC plan, is

acceptable will be based on (but not limited to) the

following criteria:

The description' of the measurement control

program showsJthat the measurement systems

that are the key contributors to the total

measurement standard error will be routinely

and adequately monitored for both bias and

23- NUREG-1065 Rev. 2
Measurement Control

random error. The standard deviations of

measurement systems are estimated from

replicate data from measurements made in

the same manner as made routinely on

typical process samples and items. If

standard deviations are based on replicated

measurements of standards (for NDA or

mass measurement systems), data is collected

that demonstrates that the standard deviation

estimates do not differ significantly from

those based on replicated process item

measurements. [NOTE: For analytical

chemistry measurements, the combined

analytical plus sampling random error must

be derived from the measurement of replicate

process samples rather than based on

multiple measurements of a standard.]

All reasonable and probable sources of

measurement error, such as the effects of

sampling, instruments, environmental factors,

and variability between operator/analysts are

included in the estimates for standard

deviations, either directly as experimental

variables in an analysis of variance or by

being included in the sample of measurement

control data from which the standard

deviations are determined. It must be shown

that it is reasonable to expect that the

measurement systems that could significantly

impact the inventory difference will be in

control (when used for accounting purposes)

so that twice the total measurement standard

error will be within the limits stated in 10

CFR 74.31(c)(4) when calculated at the time

of a physical inventory.

* Bias tests are made by measurements of

representative control standards whose

assigned values are traceable to national

measurement systems. As reasonably

achievable, the control standards should

closely resemble the unknowns to which the

measurement is applied, and the

measurement procedures and conditions of

measurement must closely resemble those of

typical measurements made on process

unknowns.

* A record of bias estimates for each key

measurement system (not defined as a biasfree, point-in-time calibrated system), as

derived from control standard measurements,

is maintained. The basis for determining the

time frame associated with each significant

bias needs to be provided (so that the

quantity of measured SNM to which that bias

applies can be determined). Bias corrections

(expressed as both grams element and grams

isotope) are derived for each significant bias

(based on the quantity of measured SNM to

which the bias applies). The FNMC plan

must confirm that each significant bias is

either applied as corrections to items listed in

the accounting records (if the correction for

an individual item is greater than the

rounding error for that item), or included in

the net bias correction to inventory difference

(on line 7 of NRC Form 327).

* Schedules and frequencies of replicate and

control standard measurements are designed

so that the estimates of standard deviations

and measurement biases will be based on

measurement control data collected under the

same measurement circumstances and over

the same time span corresponding to that of

the SNM accounting measurements to which

the standard deviations and bias estimates

will be applied. The standard deviation and

bias of each key measurement system should

be evaluated periodically. The frequency of

such evaluations should typically be at least

every four months. When determining the

average bias and standard deviation of a

particular measurement system for an inventory period, pooling of data from previous

determinations may be used only if statistical

tests show that the standard deviations and

biases from prior determinations do not differ

significantly from that of the current period,

and further provided the pooled data do not

include any data enerated more than 24

months prior to the current determination of

such bias or standard deviation.

* The effort expended by the licensee in

monitoring and controlling the bias and

standard deviations of each measurement

system is shown to be consistent with its

impact on inventory difference and the total

measurement standard error. The number of

degrees of freedom for estimating the

measurement standard deviation may be

graded according to its contribution to the

total measurement standard error.

* Waming limits for a change in bias (for those

systems that are not point-in-time calibrated,

bias free) will be set at the 0.05 level of

significance (or tighter), unless adequate

justification for less stringent limits is

provided. Warning limits are optional,

however, for the monitoring of replicate data

NUREG-1065 Rev. 2 24
Measurement Control

(for standard deviations). If a control datum

exceeds this limit, the individual responsible

for the measurement control program will be

notified (this normally should occur within

72 hours) and a data review will be initiated

to find the cause, and corrective action will

be taken when appropriate. Such reviews

and corrective actions are completed and

documented within two weeks.

Unless adequate justification for less stringent

limits is provided, out-of-control limits for

both standard deviation and bias are set at the

0.001 level of significance for all key

measurement systems, except that no bias

control limits are needed for bias-free,

point-in-time calibrated systems. If a control

datum exceeds this limit, the system in

question shall not be used for MC&A

purposes until corrective action and

resolution is completed, and the system is

back in control within the upper and lower

boundaries of the warning limit. Likewise,

any measurement values generated between

the last within control datum and the

out-of-control datum shall not be used for

MC&A purposes until their validity has been

confirmed. Such confirmation can be

accomplished by remeasurement of the

involved items or samples on a last in, first

out" basis until two consecutive

remeasurements are found to be in agreement

with their initial measurement at the 95

percent confidence level. It should be noted

that other criteria for initiating corrective

action relative to potentially out-of-control

measurement systems may be accepted where

it can be demonstrated that the licensee's

capability to meet the 0.25 percent of active

inventory limit for total MC&A measurement

uncertainty (as specified in 10 CFR

74.3 1(c)(4)) will not be jeopardized.

published measurement performance in

similar applications.

- The calculation of the total measurement

standard error is performed in accordance

with a recognized error propagation method.

Such methods have been published by Jaech

(1973), Lumb and Tingey (1981), and the

IAEA (1977).

* The licensee will confirm that the

accountability measurements provided by a

contractor are controlled by a measurement

control program, and that the licensee will

confirm that the contractor's measurement

control program is adequate by conducting

audit and assessment reviews of the

contractor's program at intervals not to

exceed 24 months.

3.7 Affirmations

The four affirmation statements, given on page 6

under section (3), relating to the measurement

control system capabilities required by 10 CFR

74.31(c)(3) and (4), must be stated (without

modification) in the FNMC plan.

The approach used for bounding the total

measurement standard error for a typical

material balance period meets the following

criteria:

- All reasonable and probable sources of

measurement error affecting inventory

difference are included.

- Any assumed measurement standard

deviations are shown to be reasonable.

They may be shown to be reasonable

by comparison to either records of the

licensee's past performance data or to

25 NUREG-1065 Rev. 2
4 Statistics

4.1 Determination of

Measurement Uncertainties

To achieve the objectives and capabilities of 10

CFR 74.31, each licensee or applicant should

institute a statistical program that evaluates the

MC&A data to ensure that () the measurement

data are analyzed in a rigorous manner and (2)

hypotheses concerning the status of the nuclear

material possessed are appropriately tested. NRC

sponsored the development of a comprehensive

reference that specifically addresses the statistical

treatment of measurement control and accounting -

data. The statistical methods described in this

reference, Statistical Methods for Nuclear Material

Management," NUREG/CR-4604, are recommended by NRC for satisfying the statistical

requirements of 10 CFR 74.31.

The FNMC plan should

(1) contain a detailed discussion of the

procedures and methodologies for estimating

measurement variance components

(2) discuss how biases are determined and how

bias corrections are applied, including:

(a) how often biases are estimated-

(b) how the bias' effect on the measured

quantity of material in an item is

determined

(c) when and how bias corrections to

items are made

(d) how their effect on inventory

difference is determined

(e) when and how bias corrections are

applied to the ID

(3) describe the procedure and means for

determining active inventory

(4) provide all relevant information regarding the

determination of the SEID

(5) specify the nominal (typical) DQ, and the

method for determining the actual DQ for a

given material balance period. Also confirm

that DQ will not exceed 1.30 percent of the

larger of annual additions to or removals

from process, except when 1.30 percent of

additions to or removals from process is less

that 25 kilograms of U-235, in which case

the DQ need not be less than 25 kilograms of

U-235 [NOTE: For those facilities that do

not utilize any chemical processing, DQ

should be limited to 0.90 percent of annual

additions to or removals from process, but

need not be less than 25 kilograms of U-235]

(6) specify the methodology for determining ID

threshold values to be used to provide a 90

percent power of detecting a loss of a DQ, as

required by 10 CFR 74.31 (c)(5). (See

Chapter 5 for additional information on

inventory difference limits and response

actions.)

4.2 Determination of SEID

As defined in 10 CFR 74.4, the standard error of

inventory difference' means the standard deviation

of an inventory difference that takes into account all

measurement error contributions to the'components

of the ID. For strategic SNM facilities,

nonmeasurement contributors to the ID are not to

be included in the SEID calculation. However, for

facilities possessing only SNM of low strategic

sigrificance, the NRC allows licensees to take

limited credit for nonmeasurement contributors. It

is not really possible to quantify the

nonmeasurement contribution to' the uncertainty

associated with a given ID, but 10 CFR 74.31

licensees are permitted to assume that the total

nonmeasurement'contribution to SEID equals the

total measurement error contribution. When

.including only measurement uncertainty, SEID (for

-either U or U-235, as applicable) can be expressed

as follows:

k

SEID = I E (Gj)2 {(a;),2 + (a;)r2 /n}I"2

i=l

where

k = number of measurement systems

Gi = total grams uranium (or U-235)

;measured during inventory-period

by measurement system i

(u1) = systematic-error standard deviation

for measurement system i

(a.), = random error'standard deviation for

measurement system i

n = number of batches (items) measured '

by measurement system i

When taking the maximum allowable credit for

nonmeasurement contribution (which assumes a 1:1

ratio of measurement to nonmeasurement

contributions),

k

SEID = 2E (G1)

2 ((or,). +(u),21n}r'2

i=l

27. NUREG-1065 Rev. 2
Statistics

In theory, SEID provides the uncertainty, at the 67

percent confidence level, of the ID.

The FNMC plan must provide all relevant

infornation regarding the determination of SEID.

There should also be a comrnitment that at least two

individuals independently verify the correctness of

the SEID calculation for each total plant material

balance. If the SEID value is calculated by a

computer, the verification by two or more persons

involves a checking for correctness of the input data

used by the computer to calculate SEID.

4.3 Bias Corrections

From a statistical perspective, biases that are not

statistically significant (at the 95 percent confidence

level) should never be applied as adjustments

(corrections) to the accounting records. If one

wishes to obtain the best estimate of the true

inventory difference value, it can be argued that

such insignificant biases should be applied as a

non-accounting adjustments to the initially

calculated inventory difference (as obtained from

the ID equation: ID = BI + A - R - El). Such

practice is not deemed necessary, however, for

material balances pertaining to SNM of low

strategic significance, and thus is purely optional.

For biases that are statistically significant (at the 95

percent confidence level), it is common practice to

adjust the accounting values for individual items if

the bias effect (as grams element and grams

isotope) on the item is more than the rounding error

for that item, and if less than the rounding error, to

apply the bias as a non-accounting adjustment to the

ID. Under a well designed and well managed

measurement control program, bias corrections to

the accounting records should seldom, if ever, be

necessary under the above mentioned approach.

Although the effect on an individual item from a

statistically significant bias should be negligible, the

effect of that bias across hundreds or thousands of

items (whose SNM values were derived from the

biased measurement system) could have a very

significant impact on the ID value.

Nevertheless, in view of the very large quantity of

SNM (of low strategic significance) that is of a

safeguards significance, NRC acceptance criteria

does not normally call for applying bias corrections

to either the accounting records or as an adjustment

to ID unless the effect of a single significant bias or

the net sum of all significant biases is unusually

large.

As a minimum, to meet NRC acceptance criteria, a

bias correction for a single key measurement

system should be considered 'significant," and thus

applied either as corrections to the accounting

records or as an adjustment to the inventory

difference, if (1) such bias is statistically significant

at the 95 percent confidence level, and (2) either or

both of the following are also true:

1. Applying the correction would cause the

ID to exceed its DT value, or

II. The bias is greater than 0.0100 percent

relative and also impacts the ID value by

more than 1,000 grams U-235.

Additionally, the net algebraic sum (expressed as

grams U-235) of all statistically significant (95

percent confidence level) biases, from key

measurement systems not defined as bias-free, that

have not been applied as a correction/adjustment

under condition I and/or II, above, is considered to

be significant' and is to be applied as a net

adjustment to the ID if either or both of the

following are true:

III. Applying such correction would cause the

ID to exceed its DT value, or

IV. The net correction impacts the ID value by

more than 5.00 percent of the licensee's

DQ, or 10,000 grams U-235, whichever is

larger.

NUREG-1065 Rev. 2 28
5 Physical Inventories

5.0 Regulatory Intent

The principal method of confirming the presence of

SNM is to perform a physical inventory and

compare it to the book (record) inventory. If all

SNM is included, the expected difference between

the book inventory and the physical inventory is

zero plus or minus the measurement uncertainty

associated with both the physical and book

inventories. In any actual case, the size of the

estimated ID depends on measurement errors, as

well as various nonmeasurement contributors such

as recording errors, unmeasured losses, unmeasured

holdup, etc. The intent of 10 CFR 74.3 1(c)(5) is to

require licensees to perform annual physical

inventories so to confirm that a loss or diversion of

a safeguards significant quantity (i.e., a DQ) of low

strategic SNM has not occurred.

5.1 General Description

The applicant or licensee should provide a general

description of how physical inventories of the plant

will be planned, conducted, assessed, and reported.

5.2 Organization, Procedures,

and Schedules

The FNMC plan should explain the makeup and

duties of the typical physical inventory

organization. The individual having responsibility

for the coordination of the physical inventory effort

should be identified by position title. The FNMC

plan also should indicate how the preparation and

modification of inventory procedures are confrolled.

The FNMC plan should contain a definitive

statement that specific inventory instructions are

prepared and issued for each physical inventory.

5.3 Typical Inventory Composition

The typical expected in-process inventory within the

equipment for both uranium and U-235 at the time

of the physical inventory should be specified. A

typical composition of SNM as stored items at the

time of a physical inventory 'also should be

presented. Plants may be (but are not required to

be) divided into a number of MBAs and ICAs to

reflect the functional activities as follows:

The FNMC plan should contain a definitive - - - Processing - An MBA in which occurs (1) routine

statement that physical inventory functions and transfers of nuclear material from one container to

responsibilities are reviewed comprehensively with - another, (2) changes in chemical assay, or (3)

the involved individuals before the start of each changes in chemical or physical form. Various

physical inventory, - measurements are required to define materials flows

- through the process and to perform physical A book inventoiy listing, derived from the MC&A inventories so that periodic material balances can be

record system, should be generated just before the completed for the MBA. Because these

actual start of each physical inventory; such listing measurements have associated uncerainties, a

shall include all SNM that the'records indicate' processing MBA will normally have a nonzero ID

should be possessed by the licensee at the inventory for each inventory. Of the total plant MBAs and

cutoff time. - -ICAs, a relatively small number might be

The rprocessing inventory differenc ad MBAs. Examples are the

'Me inventory difference and related inforniation decontamination and recovery operations; analytical

associated with each physical inventory of low- laboratory; and material rebatching, blending, and

enriched uranium (LEU) (i.e.,'-DOE/NRC material ' -sampling operations. Physical inventories for the

code 20-El and 20-E2) are to be reported to the decontamination and recovery operations are the

NRC, pursuant to 74.17(a), on an NRC Form 327 'most complex and involve the most coordination

as the results of a physical inventory. In addition, and careful timing.

it any matenal associated witn matenal coaes 2u-E.3

and 20-E4 (i.e., high-enriched uranium), 70 - ' Storae'-ICAs in which all materials are within

(U-233), 50 (Plutonium), or, 83 (Plutonium-238) is ' containers with measured values and are being

possessed by the licensee; such material must also 2 stored for future processing or shipment. Some

be subject to the physical inventory,' and each ' . rminor sampling of containers can occur in a storage

material code inventory difference and associated ' * ICA. Because nuclear materials in a storage ICA

information must be reported on separate 'NRC 327 are primarily accounted for on an item basis, a true

Forms.

29 NUREG-1065 Rev. 2
Physical Inventories

storage ICA typically will have a zero ID for each

inventory period when all items are accounted for

and their integrity and previously documented

measured values are confirmed.

Receiving and shinpin - An ICA from which

materials are shipped or into which materials are

received from off-site. This ICA type will

normally serve as an interim storage area and will

see more activity (i.e., changes in current

inventory) than the typical storage ICA. At some

facilities, sampling and rebatching of items may

occur in this type of ICA.

5.4 Description of Typical Item

Strata

The FNMC plan should describe the expected item

population in terms of the following:

(1) type of item (i.e., stratum)

(2) expected range of the number of items

within each stratum

(3) the average uranium and U-235 content

of the items within each stratum

(4) the expected rate of item generation and

consumption for each stratum

5.5 Conducting Physical

Inventories

A description of the methodology, including cutoff

and inventory mirimization procedures, should be

presented; and all measurements (including

sampling) should be identified. The FNMC plan

should contain sufficient information to show how

the total in-process inventory for both uranium and

U-235 is obtained.

The means for measuring or estimating residual

process material (i.e., holdup) should be addressed

in detail. The change or variation in such deposited

holdup from one physical inventory to the next

should also be discussed.

A detailed inventory notice should be prepared for

each physical inventory. The notice should be

issued to all involved parties and should contain

instructions that define the timing and performance

of various inventory steps and conditions under

which the inventory is to be taken. Specific

sampling points throughout the process and

instructions on data submission to the accountability

organization should be identified. The instructions

should highlight any required deviation from normal

inventory procedures contained in the plant's

operating procedures.

A description of the procedures and methodologies

associated with performing physical inventories

should be provided in sufficient detail to

demonstrate that valid physical inventories are

conducted. Such description should include a

general outline of the following:

(1) organization and separation of functions

(2) assignment of inventory teams and their

training in the use of uniform practices

(3) obtaining, verifying, and recording of

source data

(4) control of inventory forms

(5) assurance that item counts verify the

presence of each item while preventing any

item from being counted more than once

(6) implementation of cutoff and material

handling procedures

Decontamination and recovery is a complex

operation involving the disassembly and

decontamination of failed pieces of process

equipment, and recovery of uranium from various

types of scrap materials. The basic inventory

procedure should involve establishing a cutoff of

movement of materials into the area and processing

all materials to a measurable form, such as

containers of solution or oxide. Except for the

decontamination enclosure in which in-process

solutions are mixed, sampled, and measured

volumetrically, the inventory process should involve

emptying and flushing of process systems and

piping, which then could be measured using NDA

techniques to establish levels of residual holdup, if

such holdup is significant.

Special item storage and handling or tamperindicating methods, which are used to ensure that

the previously measured and recorded SNM

content values can be used for inventory purposes

without remeasurements, should also be described.

In addition, the FNMC plan should provide a

description of how item identities are verified and

how tampering with the contents of items will be

detected or prevented.

NUREG-1065 Rev. 2 30
Physical Inventories

Items that are not encapsulated, affixed with

tamper-indicating seals, or otherwise protected to

ensure the validity of prior measurements need

special attention. The basis for determining which

items are to be measured at physical inventory time

and the justification of anyIproposed altematives to

measurement of any SNM included in the inventory

should be presented. If statistical sampling is

proposed as an alternative method to 100 percent

verification, the FNMC plan should describe the

sampling plan. Such description should include:

(I) the method of segregating the types of

items to be smpled (i.e., selected for

remeasurement)

(2) the procedure for calculating the sample

size (i.e., the number of items) for each

stratum

(3) the parameter to be measured (e.g.,

gross weight or total U-235 content)

(4) the quality of the measurement methods

used to verify original measurement

values (for the parameter being

measured)

(5) the procedure for reconciling

discrepancies between original and

remeasurement values, and for

scheduling additional tests and

remeasurements

(6) the basis for discarding an original 'SNM

value and replacing it with a

remeasurement value

One acceptable means for establishing the number

of items (to be randomly selected for

remeasurement) from a giver stratum to give the

required 90 percent power of detecting a loss of a

detection quantity is given by the following

equation:

n = N [ - (0.10)"!

where

n = number of itens to be remeasured

N total number of itens in the stratum

x = maximum U-235 content per item

(kilograms)

g = DQ = detection quantity (kilograms

U-235)

When using such a statistical sampling plan to

confirm the validity of prior measurements, the

remeasurement value obtained for each item (among

the n items remeasured) must be compared to its

original value. If the difference for a given item

exceeds some pre-determined limit (usually three

times the standard deviation of the measurement, or ,

3 sigma), that item is designated as a defect". To

achieve the 90 percent power of detection capability

for detecting a loss of a DQ, there must be at least

a 90 percent probability that one or more defects'

will be encountered among the items remeasured

across all involved stata if an actual loss of a DQ

has occurred. If,,across all strata, one or more

defects are encountered, a second set of n randomly

selected items (or all remaining items if n 2 0.5 N)

from each stratum should be remeasured. If one or

more defects are encountered (across all item stata)

while performing any second round of remeasurements, all unsealed and unencapsulated items not

yet remeasured are to be remeasured. Any item,

regardless of whether there are any defects, whose

remeasured value differs from its original measurement by more than two sigma (2a) should have its

accounting value revised to reflect its remeasured

quantity.

The FNMC plan also should contain a definitive

statement that all items on ending inventory that

have not been previously measured are measured

for inventory purposes.

The decision rationale for determining when the

element and isotope factors for items, objects, or

containers are measured directly for inventory and

when they may be based on other measurements

should be presented in the FNMC plan. For

example, if the U-235 contained in liquid waste

batches is derived by applying an average

enrichment factor to the measured uranium element

content, the rationale for such practice (as opposed

to measuring each batch for both uranium and

U-235 content) should be discussed, and the method

for establishing the average enrichment factor

should be described.

If the content of items is established through prior

measurements and those items are sealed with

tamper-indicating devices or access to them is

controlled, the SNM quantity in those items may';

be based on those measured values. Otherwise,

verification of SNM content can be achieved by

reweighing either (I) all items within a given

stratum or (2) randomly selected items from the

stratum based on a statistical sampling plan. A

statistical sampling plan will not be acceptable if

there is any likelihood of any significant change in

31 NUREG-1065 Rev. 2
Physical Inventories

the uranium concentration (or weight fraction) or in

the uranium isotopic distribution because of such

factors as oxidation, change in moisture content,

commingling with materials of different

enrichments, or different compositions.

5.6 Inventory Difference Limits

and Response Actions

Each licensee should have a well-defined system for

evaluating total plant IDs and taking actions when

IDs exceed certain predetermined thresholds. As a

minimum, there should be two response levels, and

three levels are recommended, for excessive IDs.

The following would be an acceptable approach for

three increasing levels of response actions with

respect to physical inventories:

Warning-level ID

U-235 ID 2 1.7(SEID) + 500 grams, and

U ID 2 1.7 (SEID) + 10 kg U

Significant ID problem

U or U-235 ID 2 3 (SEID)

Major ID problem

U-235 ID 2 DQ - 1.3 (SEID)

All of the above limits are expressed in terms of

absolute values of ID without regard for algebraic

sign. The minimum response for a warning-level

ID should be a documented licensee investigation

conducted by the MC&A organization. Such an

investigation should provide a conclusion for the

probable cause of the excessive ID and give

recommendations for avoiding recurrences. When

a warning-level ID is positive, it should be regarded

as being equivalent to an indicator of a possible loss

that requires investigation and resolution.

For a significant ID problem, an extensive

investigation by the licensee should be conducted.

If a significant ID problem cannot be satisfactorily

explained, a reinventory may be needed.

For any unresolved ID determination that remains a

major ID problem (without regard to algebraic

sign), the licensee should conduct a plant-wide

reinventory and investigation. The NRC considers

a positive ID large enough to be a major ID

problem as a very serious condition.

The FNMC plan should fully describe in definitive

statements the minimum response actions for each

ID action level.

5.7 Acceptance Criteria

A judgment that the applicant's or licensee's plan

for physical inventories is acceptable will be based

on (but not linited to) the following criteria:

* The FNMC plan contains adequate

comnitments to assure that each physical

inventory will be organized and coordinated

so that all involved persons are instructed in

the use of uniform procedures of checking

SNM quantity and recording observations.

The means for conducting the inventory must

insure that no SNM currently on hand (with

the possible exception of holding account

waste materials and residual holdup following

cleanout that can he regarded as zero by

definition) will be omitted and no quantity

will be counted more than once.

* The inventory procedures provide for

confirming the presence of all items by direct

observation and the presence of all quantities

of SNM, that are neither encapsulated nor

tamper-safed, by direct measurement or an

acceptable alternative. The proposed

alternatives to remeasurement must satisfy

one of the following criteria:

- The SNM content is verified by

statistical sampling and measurement

of representative items, objects or

samples of the material. The total

overall sampling plan shall support the

capability for detecting any loss in

excess of the current DQ with 90

percent (or better) probability.

- The previous measurement results are

accepted because the items are stored

in a controlled access enclosure that

provides protection equivalent to

tamper-safing.

- Residual holdup (that is too large to be

regarded as zero by definition)

remaining after cleanout or draindown

may be estimated if the estimate is

based on previously measured values,

and it is periodically verified or

validated.

- For material whose SNM content has

been previously measured, and there is

no likelihood of any significant change

NUREG-1065 Rev. 2 32
Physical Inventories

in the uranium concentration (or

weight fraction) or in the uranium

enrichment due to such factors as

oxidation, change in moisture content,

commingling with materials of

different enrichment or different

composition, etc., the previously

determined uranium and U-235 content

may be accepted without verification

of SNM content provided the gross

weight and/or net weight of all items

within the population is confirmed by

(1) a 100 percent reweighing of all

such items, or (2) reweighing an

adequate number of randomly selected

items (based on a statistical sampling

plan) to provide a 90 percent (or

better) probability of detecting a loss

equal to or greater than the current

DQ.

* As an additional altemative to remeasurement

(of unsealed SNM) at physical inventory

time, a program of routine process

monitoring will be acceptable when the

combination of the process monitoring

program and the inventory procedures will

achieve the same level of loss detection

capability as that provided by a physical

inventory in which all unencapsulated items

are either tamper-safed or remeasured.

* Any previously measured, but unsealed (or

unencapsulated) SNM that is on hand at the

time of the physical inventory, and which is

to be introduced into subsequent processing

steps prior to inventory reconciliation should

be remeasured or have its prior measurement

value confirmed (by an acceptable

alternative) before the subsequent processing

is initiated.

* The DQ (in kilograms U-235) for any given

inventory period will be no greater than 1.30

percent of that period's throughput for

facilities involved in chemical processing

(such as UF6 conversion, scrap recovery,

oxidation or reduction processes, etc.), and

no greater than 0.90 percent of throughput

for facilities where material only undergoes

physical changes (such as pressing UO2

powder into pellets and/or loading pellets

into fuel rods), unless the 0.90 or 1.30

percent of throughput (as appropriate) is less

than 25 kilograms U-235, in which case the

DQ need not be less than 25 kilograms. The

U-235 throughput is defined as the greater of

.additional to process" or -removals from

process" during a 12-month inventory period.

* The information in the FNMC plan shows

that the DT for an excessive ID will result in

a 90 percent (or better) probability of

detecting a discrepancy (i.e., an apparent

gain or loss) equal to or larger than the

U-235 DQ for the inventory period in

question. In general, a licensee may assume

the ID distribution approximates a normal

distribution, and therefore:

DT = DQ - 1.30(SEID)

Acceptable methodology for calculating the

measurement error contribution to the SEID

by error propagation is found in Jaech

(1973), IAEA (1977), and Lumb and Tingey

(1981). Special attention is given to

inclusion of all applicable and measurable

sources of error to avoid underestimating the

SEID.

* In addition to the DT ID alarm limit

[required by 10 CFR 74.31(c)(5)], there is at

least one excessive ID waming level limit

that when exceeded will require an

investigative response action. The resources

and level of effort to be committed to the

investigation of an excessive ID will be

proportional to the magnitude of the ID, but

will be sufficient to reassess the results of the

physical inventory, the accounting records,

and the measurement control program data;

to confirm the relevant calculations and data

analysis; and when necessary, to carry out

searches for unmeasured inventory such as

holdup and discards. Investigations are to be

completed within 60 days after initiating the

inventory (except when additional time is

granted by the NRC for extenuating

circumstances).

5.8 Affirmations

The 11 affirmation statements, given on pages 6

and 7 under section (5), and the first performance

objective affirmation statement listed on page 5,

related to physical inventories must be stated

(without any modification) in the FNMC plan.

33 NUREG-1065 Rev. 2
6 Item Control

6.0 Regulatory Intent

The intent of 10 CFR 74.31(c)(6) is to require

licensees to implement item control procedures that

protect against unauthorized and unrecorded

removal of items, or of material from items, and

that enable timely location of items. Items are

known quantities of SNM in well-defined and

uniquely identified containment such as cans,

drums, and canisters, or fixed units such as fuel

assemblies. Un-containerized solid SNM, such as

uranium metal ingots or buttons, are also items if

they are uniquely identified. In order. to promptly

locate a given item, sufficient current information

must be recorded. These item control requirements

apply only to items for which the total length of

time that the item exists plus the length of time it

takes to locate it (after,having been recorded)

exceeds 14 days. For example, if an item has been

in existence for 10 days, the licensee must be

capable of making a record of the item and locating

the item within 4 days in order for the item to be

exempt from the current knowledge requirement.

Conversely, if the time to make a record of an item

plus the time it takes to locate the item equals 4

days, then if the item exists for less than 10 days it

need not be formally entered into the current

knowledge system. Also in order to eliminate the

need to keep records for insignificant quantities of

SNM, waste containers and most solutions are

exempt. Licensees are given some flexibility in

controlling items by permitting an additional -

exemption of up to a total of 50 kilograms U-235 in

items each containing less than 500 grams of

U-235.

i 1 flwnon

(1) items whose time of existence plus the time

to record the item (since its generation) plus

the time to locate the item is less than 14

calendar days

(2) any licensee-identified items listed by

material type containing less than 500 grams

of U-235 each but not to exceed a plant total

of 50 kilograms of U-235

(3) containers of waste (designated for burial or

incineration), and solution containers in

which the U-235 concentration is less than

5.00 grams per liter.

Each item that is not exempt from the item control

program should be stored and handled in a manner

that enables detection of, and provides protection

against, unauthorized or unrecorded removals of

SNM. All items, whether or not they are subject to

item control program coverage, should have a

unique identity. For items subject to the item

control program, the following are acceptable

means for providing unique identity:

(1) a unique alpha-numeric identification on a

tamper-indicating seal applied to a container

of SNM

(2) a unique alpha-numeric identification

permanently inscribed, embossed, or stamped

on the container or item itself

(3) a uniquely prenumbered (or bar-coded) label

applied to each item having good adhesive.

qualities such that its removal from an item

-. would preclude its reuse

Location designations shown by the MC&A records

The FNMC plan sbould identify the individual need not be unique, but location designations should

responsible for overseeing the item control program be specific enough so that any item may be located

by position title. Positions of those individuals who within I hour. Longer times may be acceptable but

have significant item control program should be further justified in the FNMC plan. The

responsibilities' should also be identified.-'' ' MC&A record system should be controlled in such

a manner that the record of an item's existence

6.2 General Description - - . cannot be destroyed or falsified without a high probability of detection., Each nonexempt item -

- should be stored and handled in a manner that.

The applicant or licensee should state that the enables detection of, and provides protection

overall MC&A system maintains a record of all against, unauthorized or unrecorded removals of

SNM items, regardless of quantity or duration of SNM.

existence. In addition, the item control program

should provide current knowledge of the location, - 6.3 Item Identity Controls

identity, and quantity of all SNM contained in all

items hat are' not exempt from item control. terns ;-'-; : itesthat ae otexemp t fromim iotmronrol.ram - Descriptions should be provided of the item records

thtcanerae exempt:from item control p showing how items are identified for each material

type and each type of container. If the unique

35 NUREG-1065 Rev. 2
Item Control

number on a tamper-indicating seal is the basis for

providing unique item identity, the FNMC plan

should:

(1) describe the type of seal used

(2) describe how the seals are obtained and what

measures are implemented to ensure that

duplicate (counterfeit) seals are not

manufactured

(3) describe how the seals are stored, controlled,

issued, and accounted for

(4) describe how seal usage and disposal records

are maintained and controlled

Similar information should be provided for other

methods of unique item identity (e.g., labels).

6.4 Storage Controls

Item storage areas and controls should be fully

described in the FNMC plan. In particular,

controls that are used as the basis for ensuring the

values of prior measurements, as opposed to

remeasuring the item at inventory time, should be

discussed in detail and the rationale for accepting

prior measurements explained. Any controls used

to ensure the validity of prior measurements should

be equivalent to the protection provided by

tamper-indicating seals.

Both administrative controls (e.g., custodian

assignments and limiting authorized access to

storage areas) and physical controls (e.g., locked

and/or alarmed doors) should be identified.

6.5 Item Monitoring Methodology

and Procedures

As part of the item control program, a licensee

should maintain a system of item monitoring that:

(1) verifies that items shown in the MC&A

records are actually stored and identified in

the manner indicated in the records

(2) verifies that generated items and changes in

item locations are properly recorded in the

MC&A record system in a timely manner

(3) can detect, with high probability, any real

loss of items, or uranium from items

amounting to 500 grams or more of U-235

The item monitoring system should conduct the

following activities at least on a monthly basis:

(1) for each item inventory stratum, compare the

actual storage status to the recorded status of

a sufficient sample of randomly selected

items from the item control program records

(2) for each item inventory stratum, check the

accuracy of the MC&A records for a

sufficient sample of randomly selected items

from each storage area

(3) check the accuracy of a sufficient sample of

randomly selected production records of

created and consumed items

The actual frequency of the above activities, and

the size of the random sample, should be a function

of the expected discrepancy rate based on prior

observations. The FNMC plan should specify (1)

minimum monitoring frequencies associated with

each storage area, (2) discrepancy rates that trigger

more frequent monitoring frequencies, and (3)

comnitments for resolving discrepancies.

6.6 Investigation and Resolution

of Item Discrepancies

The applicant or licensee should provide definitive

statements of the procedures and controls that will

ensure that all incidents involving missing or

compromised items or falsified item records will be

investigated. A compromised item is () one

displaying evidence of tampering or (2) an

unencapsulated and unsealed item assigned to a

controlled, limited-access storage area that is found

elsewhere.

If any unencapsulated and unsealed item is located

after having been determined to be missing, or if an

item is found to be compromised, its contents

should be reestablished by measurement (e.g., by

NDA or by weighing, sampling, and analysis).

Recommendations on resolution of indicators

(Chapter 9) of this document should be used to

resolve item discrepancies.

6.7 Acceptance Criteria

A judgment that the licensee's FNMC plan for the

control of items subject to the requirements of

10 CFR 74.31(c)(6) is acceptable will be based on

(but not linited to) the following criteria:

NUREG-1065 Rev. 2 36
Item Control

* The licensee's item record system uniquely

identifies items. The records include

information on the chemical form, quantity

of material (element and isotope), physical

description, identification label or number,

and location. The system provides

reasonable assurance of detecting falsification

or destruction of records of an item's

existence. Groups of itens that are

produced, stored, processed, or otherwise

handled together as a unit, such as a batch or

sublot of material, may be exempt from the

requirements for identification of each item if

the group is uniquely identified and stored as

a separate group under conditions such that

group identity, composition and quantity will

be maintained constant.

* The record of the status of an item can be

completed or updated in sufficient time to

allow the licensee to meet the requirements

for promptly locating an item.

* For items that will not be remeasured at

inventory time, the item control procedures

provide reasonable assurance that the SNM

contents stated in the records are valid and

that unauthorized removal of SNM from the

item has not occurred. Remeasurement is

not necessary if the SNM content of the item

was measured previously and reasonable

assurance is provided that the SNM content

has not subsequently changed.

- Solutions having less than a 5.00

grams U-235 per liter concentration;

or

- Items individually containing less than

500 grams U-235 each, not to exceed

a total of 50 kilograms of U-235.

• The FNMC plan makes commitments for

determining the total quantity of U-235 in

items exempted from control on the basis that

they contain less than 500 grams U-235 each,

so as to assure that the total 50 kilogram

U-235 limit is not exceeded.

* A current accounting is maintained of the

total quantity of SNM contained in items that

are exempted from item control. The

accounts identify the quantities by material

type category for both controlled and

exempted items.

6.8 Affirmations

The four affirmation statements, given on pages 7

and 8 under section (6), relating to the current

knowledge requirements of 10 CFR 74.31(c)(6)

must be stated (without modification) in the FNMC

plan.

* Items that are exempted from item control

procedures must fall into at least one of the

following categories:

- Items that are in existence for only a

relatively short period of time, as

defined in 10 CFR 74.31(c)(6);

- Waste destined for burial or

incineration;

37 NUREG-1065 Rev. 2
7 Shipper-Receiver Comparisons

7.0 Regulatory Intent

The intent of 10 CFR 74.31 (c)(7) is to require the

material control and accounting system to promptly'

detect and resolve all significant shipper-receiver

(SIR) differences. SIR comparisons are important

for confirming that either shippers' and receivers'

values are acceptable for establishing the book

accounting quantities associated with received

material, or detecting unacceptable shippers' or

receivers' values.

7.1 Receiving Procedures

Regardless of whether or not formal S/R

evaluations are to be performed, the first action to

be taken on receipt of SNM should be the

verification of the number of items, the item

identities, and the integrity of individual items and

of tamper-indicating seals. Except for certain

specified types of material, all SNM shipments

received from an external supplier are to be subject

to SIR comparisons. Such SIR comparisons involve

measurement'of received material by the receiver,

or by the receiver's contractor (who is independent

of the shipper), and comparing receiver's total

receipt measurement for element and isotope to that

of the shipper's.'' The FNMC plan should identify

what material types, if any, are exempted from S/R

evaluations. Receipt materials which may be

exempted from SIR comparisons include:

(1) shipments containing less than 500 grams

U-235;

(2) individual items containing less than 25

grams U-235 when the total shipment is less

than 2000 grams U-235;

(3) encapsulated items, whose encapsulation

integrity has not been compromised, and

which are to be retained by the licensee as

encapsulated items;

(4) fuel assemblies and fuel rods previously

shipped by the licensee that are being

returned, provided that the original

encapsulation has not been compromised;

(5) UF6 cylinders that are empty except for a

heel quantity of UF6 ; and

(6) Heterogeneous scrap that must be subject to

dissolution before a meaningful accountability

measurement can be obtained, and both

shipper and receiver agree to accept the after

dissolution plus residue" measurements for

accounting purposes.

For any SNM received, the licensee must provide

all appropriate information on the DOE/NRC Form

741 that accompanies'the shipment. (NOTE: See

NUREG/BR-0006 for instructions and requirements

for completing DOE/NRC Form 741.)

7.2 Determination of Receiver's

Values

For UF6 , the licensee may establish receiver's

values by (1) measuring the U-235 isotopic

concentration by NDA, (2) weighing each cylinder

to determiine net weight UF6 (gross weight minus

certified cylinder tare weight), and (3) applying a

historical established percent uranium factor (that is

periodically confirmed or updated by measurement).

Such a practice avoids the need to sample UF6

cylinders and analyze the samples (except when

obtaining data to' establish or update the historical

percent U factor). However, it is more desirable

and common practice to derive UF6 receipt values

based on the measurement of UF6 samples.

Arrangements can usually be made with the UF6

supplier to provide samples of the shipped UF6 .

The receiving facility should have an agent (who is

independent of the shipper) witness the sampling

(that represents the UF6 contained in the cylinder(s)

to be shipped), apply a tamper-indicating seal to the

sample, and verify the unique identify of the filled

cylinder.

SNM 'receipts not in the form of UF6 should be

measured for total quantity (mass), element

concentration, and isotope abundance, as opposed

to using a historical factor for deriving element

content.

7.3 Evaluation of ShipperReceiver Differences

When shipper's measurement uncertainty (or

standard error) information is available, the

following should define the combined measurement

standard error:

combined standard error = (4x.)2 + (R) 21 12

where

as = shipper's measurement standard error

aR = receiver's measurement standard error

39 NUREG-1065 Rev. 2
Shipper-Receiver Comparisons

If the shipper's measurement uncertainty values are

not available, the receiver can assume that the

shipper's measurement uncertainty is equal to (but

no greater than) its own uncertainty. In this

situation (i.e., both shipper and receiver have the

same measurement uncertainty), the following

becomes the combined measurement standard error:

combined standard error = [ 2 (R) 21 11

= 1.4 14 aR

The difference between the shipper's value and the

receiver's value (i.e., the SRD), in terms of the

total shipment, must be regarded as significant

whenever the SRD exceeds both 500 grams of

U-235 and twice the combined standard error. If

subject to 10 CFR Part 75 (international

safeguards), a SRD in excess of both 500 grams

U-235 and twice the combined standard error with

respect to a single batch within the shipment must

also be regarded as significant.

7.4 Resolution of Significant

Shipper-Receiver Differences

The FNMC plan should describe the steps involved

with the investigation of a significant SRD and

discuss how such difference is resolved. The

criteria for defining a resolved SRD also should be

presented. Generally, resolution of a significant

SRD involves a referee (or umpire) measurement of

a retainer sample(s) but not of the material weight.

The resolution process should specify whose weight

value is used in the resolution process if shipper's

and receiver's weights differ by more than one-half

of the total combined standard error.

significant SRDs is acceptable will be based on (but

not limited to) the following criteria:

* Each shipping container is inspected within 3

working days after receipt. If the integrity of

a container is questionable, the presence of

all items that were packaged in the shipping

container are confirmed within 24 hours of

discovering the questionable integrity.

* Confirmatory measurements of scrap

shipments are performed by the receiver to

determine the amount of element and isotope

within a time period consistent with the

accountability needs of the shipper.

* The test for significance of a SRD is based

on hypothesis tests.

* The investigation procedure for significant

SRDs is sufficiently comprehensive to ensure

that the difference will be resolved.

Comprehensiveness is sufficient if the

licensee shows the capability to verify

records, resample, perform remeasurements,

establish liaison with the shipper, provide

samples to a referee laboratory, and perform

the statistical analysis needed to evaluate the

measurements.

7.6 Affirmations

The six affirmation statements, given on page 8

under section (7), relating to the resolution of

significant shipper-receiver differences, as required

by 10 CFR 74.31(c)(7), must be stated (without

modification) in the FNMC plan.

7.5 Acceptance Criteria

A judgment that the applicant's licensee's FNMC

plan for conducting S/R evaluations and resolving

NUREG-1065 Rev. 2 40
8 Assessment and Review of the Material Control

and Accounting Program

8.0 Regulatory Intent

The intent of 10 CFR 74.31(c)(8) is to require

management to periodically review and assess the

performance of the MC&A system arid evaluate its

overall effectiveness. It is intended that the review

will be performed by knowledgeable, technically

competent individuals free from conflicts of interest

and that the deficiencies will be brought to the

attention of plant management so that the

deficiencies will be corrected. It should be

emphasized that this review process is'intended to

be much more than a routine audit for compliance

with existing procedures and commitments.

Conclusions and recommendations relative to

overall program effectiveness and to the adequacy

of the program to meet and satisfy regulatory intent

are to be made.

8.1 General Description

The capabilities,-performance, and overall

effectiveness of the licensee's MC&A program

should be independently reviewed and assessed at

least every 24 months. The FNMC plan should

describe the assessment and review program'in

terms of:

(1) maximum interval between assessments

(2) selection procedures for the assessment team

(3) number of team members to be selected

(4)

(5)

qualification and expertise of team members

independence of individual team members

from the MC&A responsibilities and

activities they are reviewing and assessing

(6) maximum elapsed time and minimum actual

effort to be used for completion of the

assessment and issuance of a final team

report

The entire MC&A program generally should be

reviewed and evaluated during each assessment.

When this occurs, intervals between assessments

can be as much as 24'calendar months. However,

if individual assessments only cover part of the

MC&A system, individual subsystems should be

assessed at intervals no greater than 12 calendar

months. Thus, the type of assessment (partial or

total) and the maximum interval between

assessments should be specified. "Interval' means

the elapsed time between either the start of or

-termination of successive assessments.

The responsibility and authority for the assessment

program should lie at least one level higher in the

licensee's organizational structure than that of the

MC&A manager.. Such responsibility should

include selecting the assessment team leader and

initiating corrective actions. Team members may

be selected from the facility staff or from outside,

but an individual member should not participate in

the assessment of the parts of the MC&A system

for which that person has direct responsibility.

Hence, the MC&A manager may not be a team

member. Also, a given individual should not assess

the parts of the system that are the responsibility of

another team member if the other team member is

assessing the given individual's area. The leader of

-the assessment team should have no responsibilities

for managing any of the MC&A elements being

assessed.

The minimum number of individuals on any given

assessment should be dependent on the knowledge

and expertise of the team relative to MC&A

activities and their experience in conducting

assessments. Personnel assigned to the assessment

team should have a demonstrated understanding of

the regulatory objectives and requirements of the

MC&A program and should have sufficient

knowledge and experience to be able to judge the

adequacy of the parts of the system they review.

The team should have authority to investigate all

aspects of the MC&A system and should be given

access to all necessary information.

To provide a meaningful and timely assessment, the

review and evaluation process should not be

protracted. The actual review and investigation

activities should .be completed in 30 calendar days,

with an additional 15 calendar days allowed for

completing and issuing a final team report.

NUREG-1065 Rev. 2

.

41
Assessment

8.2 Report of Findings and

Recommendations

The areas to be reviewed should encompass the

entire MC&A system, and the level of detail of the

reviews should be sufficient to ensure that the

assessment team has adequate information to make

reasoned judgments of the MC&A system

effectiveness. The team report, as a minimum,

should state findings pertaining to:

(1) organizational effectiveness to manage and

execute MC&A activities

(2) management responsiveness to indications of

possible losses of uranium

(3) staff training and competency to carry out

MC&A functions

(4) reliability and accuracy of accountability

measurements made on SNM

(5) effectiveness of the measurement control

program in monitoring measurement systems

and its sufficiency to meet the requirements

for controlling and estimating both bias and

SEID

(6) soundness of the material accounting records

(7) effectiveness of the item control program to

track and to provide current knowledge of

items

(8) capability to promptly locate items and

effectiveness in doing so

(9) timeliness and effectiveness of SRD

evaluations and resolution of excessive SRDs

(10) soundness and effectiveness of the inventorytaking procedures

(11) capability to confirm the presence of SNM

(12) capability to detect and resolve indications of

missing uranium

On completion of each assessment, the findings and

recommendations for corrective action, if any,

should be documented. The written report should

be distributed to the plant manager, the MC&A

manager, and other managers affected by the

assessment.

8.3 Management Review and

Response to Report Findings

and Recommendations

Management should review the assessment report

and take the necessary actions to correct MC&A

system deficiencies. The management review

should be documented within 30 days following the

submittal of the assessment team's report, and it

should include a schedule for the correction of

deficiencies. Corrective actions, if any, that pertain

to daily or weekly activities should be initiated

promptly after the submittal of the final assessment

report.

The FNMC plan should address resolution and

follow-up actions associated with concerns

identified in the assessment report. The individuals

responsible for resolving identified concerns, and

the timeliness of such resolution, should be

specified.

8.4 Acceptance Criteria

A judgment that the applicant's or licensee's

program for independent assessment of the MC&A

program is acceptable will be based on (but not

limited to) the following criteria:

* The periodic assessments will be

comprehensive and sufficiently detailed to

enable the assessment team to rate the

MC&A system effectiveness, capability, and

performance by comparison with the

expected and required performance. The

overall assessment objectives are to

determine that the MC&A system, as

designed and implemented, is continuing to

meet the overall safeguards goals, and to

identify weaknesses or deficiencies in the

system design or performance that may need

correcting.

* The areas to be reviewed encompass the

entire MC&A program and the level of detail

of the reviews is sufficient to ensure that the

assessment team has adequate information to

make reasoned judgments of the MC&A

system effectiveness which includes:

- Organizational effectiveness and

management responsiveness to

indicators of possible SNM losses;

NUREG-1065 Rev. 2 42
Assessment

- Staff training and competency to carry

out MC&A functions;

- Soundness of the material accounting

records;

- Capability to promptly locate items;

- Timeliness and effectiveness of S/R

difference evaluations and resolution of

significant SRDs;

- Soundness of physical inventory

procedures and practices;

- Effectiveness of the measurement

control program to monitor key

measurement systems, establish bias

estimates and measurement

uncertainties, and meet the

requirements for controlling the total

MC&A measurement uncertainty

associated with ID;

- Capability to confirm the presence of

SNM; and

- Capability to resolve indications of

missing SNM and aid in any

government led investigation pertaining

to missing SNM, and provide

information that would aid in the

recovery of missing SNM.

* Generally accepted auditing principles are

used to check each type of record in which a

representative sample (of a sufficient number)

of randomly selected records is examined.

* Personnel assigned to the assessment team

will have an adequate understanding of the

regulatory objectives and requirements of the

MC&A system and will have sufficient

knowledge and experience to be able to judge

the adequacy of the parts of the system they

are asked to review. The team will have

authority to investigate any aspect of the

MC&A program and will have access to all

relevant information.

-B" is assessing an area under the

responsibility of 'A".

* The entire MC&A system will be reviewed

and evaluated during each single assessment

(to be completed within an elapsed time that

is short relative to the time between changes

in the MC&A system and is demonstrated to

be able to include any such changes made

during the review/assessment). Conducting

two or more assessments during a 24-month

interval, in which only part of the MC&A

system is covered in each, is not deemed

acceptable. That is, reviewing a single

component of the MC&A program at

24-month intervals is not very meaningful

unless a knowledge is obtained of how well

the other components currently interact.

Piecemeal review and evaluation is

permissible, however, if each subsystem is

covered at 12-month (or less) intervals.

* The leader of the assessment team will have

no responsibilities for performing or

managing the functions being assessed.

* The responsibility and authority for the

assessment program and for initiating

corrective actions will lie: (1) at least one

level higher in the organization than the

MC&A manager, or (2) at a level equal to

that of the on-site plant manager.

8.5 Afirmations

The seven affirmation statements, given on pages 8

and 9 under section (8), relating to the independent

assessment and evaluation of the MC&A system

effectiveness requirements of 10 CFR 74.31(c)(8)

must be stated (without modification) in the FNMC

plan.

* An individual team member will not

participate in the assessment of any part of

the MC&A system for which he or she has

direct responsibility. Also, an individual

"A" will not assess any part of the system

that is the responsibility of person "B" if

43 NUREG-1065 Rev. 2
9 Resolving Indications of Missing Uranium

9.0 Regulatory Intent

The intent of 10 CFR 74.31(a)(2) is for licensees to

react to (i.e., investigate and resolve) any

off-normal or abnormal conditions or situations that

suggest a likelihood that 500 grams or more of

U-235 may be missing (whether the cause is

accidental or deliberate).

9.1 Methods and Procedures for

Identifying Indicators

The FNMC plan should discuss the means by which

the licensee will resolve indicators'of missing

uranium involving 500 grams or more of U-235.

The licensee's resolution program should address

the possible indicators of missing uranium. The'

FNMC plan should enumerate all 'the potential

indicators that can be postulated and develop

resolution procedures for each.

The following are examples of possible indicators

of missing uranium:

(1) lack of agreement between a physical

inventory and its associated book inventory

in which the U-235 ID is positive and

exceeds 1.7 times the SEID by more than

500 grams

(2) determination through the item control

program that one or more items are not in

their designated locations and the actual

locations are not immediately known

(3) discovery that an item's integrity or its

tamper-indicating seal was compromised

(4) information from the process control system

indicating potential loss of material from the

process system.

(5) an allegation of theft or diversion

9.2 System and Procedures for

Investigating and Resolving

Indicators

At least one major MC&A procedure should

address the system and practices for investigating

and resolving loss indicators because this topic

pertains to one of the three performance objectives

of 10 CFR 74.31(a). Thus, the licensee should

have well-defined procedures for investigating

indicators of possible missing uranium (involving

500 grams or more of U-235). Likewise, there

should be established criteria for defining what

constitutes resolution of an investigated indicator.

Resolution of an indicator means that the licensee

has made a determination that loss or theft has not

occurred and is not occurring. For each type of

indicator, the licensee should'develop detailed

resolution procedures and should describe or outline

them in the FNMC plan.

Any investigation of an indication of a loss or theft

should provide, whenever possible, () an estimate

of the quantity of SNM involved, (2) the material

type or physical form of the material, (3) the type

of unauthorized activity or event detected, (4) the

time frame within which the loss or activity could

have occurred, (5) the most probable cause(s), and

(6) recommendations for precluding reoccurrence.

For indications that a loss or theft of more than 500

grams of U-235 may have occurred, the resolution

process should include (1) thoroughly checking the

accountability records and source information, (2)

locating the source of the problem, (3) isolating the

exact reason for the problem within the area or

processing unit, (4) determining the amounts of

SNM involved, and (5) making a determination

that the indication is or is not resolved. The

resolution procedures should be prepared in such a

manner that no individual that could have been

responsible for the potential loss also would be

responsible for its resolution. If an investigation of

an indicator results in a conclusion that the

indication is true, such conclusion must be reported

to the NRC within I hour of its determination

pursuant to 10 CFR 74.11. The FNMC plan

should show the reasonable time allowed for

resolution. In general, a time not exceeding 72

hours should be adequate.

9.3 Response Actions for

Unresolved Indicators

Response actions to unresolved indicators should be

clearly defined and should be on a graded scale

appropriate to the level of potential safeguards

significance. The responsibility and authority for

initiating and executing response actions also should

be defined.

For indicators of missing uranium, the level of

safeguards concern is related to such factors as:

(1) the potential quantity of U-235 involved

45 NUREG-1065 Rev. 2
Resolving Indications of Missing Uranium

(2) the material attractiveness of the potential

missing uranium (in terms of fabricating a

nuclear explosive device) relative to its

enrichment and composition or form (e.g.,

U metal, U308, uranyl nitrate solution, UF6,

scrap, or waste)

9.4 Documentation Requirements

The FNMC plan should identify all documentation

requirements associated with the licensee's program

for the reporting, investigation, and resolution of

missing uranium indicators. Review and approval

requirements and document custodial responsibility

also should be defined. As a minimum,

documentation of the following should be included:

(1) investigation procedures

(2) resolution procedures

individual responsible for resolving the

indicator.

No investigation relative to an indication of

a loss or theft of SNM exceeding the current

DQ shall be declared as completed but

unresolved without first conducting a

shutdown, cleanout inventory in which all

unsealed SNM is remeasured for element

and isotope.

9.6 Affirmations

The three affirmation statements pertaining to the

10 CFR 74.31(a)(2) performance objective, listed as

bullets two, four, and five in the section at the top

of page 5 ("Affirmations Pertaining to Performance

Obe 'ctives"), must be stated (without modification)

in the FNMC plan.

(3) reporting of indicator to MC&A

management including date and time the

indicator was reported, name of individual

who discovered the indicator, and

description of indication

(4) investigation findings and conclusion,

including resolution status, date issued,

name and signature of principal investigator,

and approval signature of MC&A manager

(5) reports made to NRC for unresolved

indicators and for indicators determined to

be real, including date and time the report

was made, method of communication, and

name of NRC individual contacted

9.5 Acceptance Criteria

A judgment that the applicant's or the licensee's

plan for resolving indications of missing SNM is

acceptable will be based on (but not limited to) the

following criteria:

Adequate commitments are provided to assure a

high probability that any indicator of missing SNM

that could involve 500 grams or more of U-235 will

be (1) recognized as an indicator, (2) investigated,

and (3) resolved.

* Investigation and resolution procedures will

provide for adequate overchecks to assure

that no individual who could have been

responsible for a possible loss or theft of

SNM would be the sole or primary

NUREG-1065 Rev. 2 46
10 Informational Aid for Assisting in the Investigation and

Recovery of Missing Uranium

10.0 Regulatory Intent

The 10 CFR 74.31(a)(3) performance objective

pertains to investigations, relating to actual (or

highly suspected) events pertaining to missing

uranium, conducted by the NRC and/or other

government agencies. The intent is for licensees to

have ready for and to provide to the investigators

any information deemed relevant to the recovery of

material involved in a loss, or theft. The burden

shall be on the licensee to provide (without being

asked to) all information that it recognizes as being

relevant, as opposed to only providing information

that the investigators are knowledgeable enough to

request.

10.1 Information Aid

The kinds of information that may aid the

investigation and recovery effort are:

(1) data or observations that led the licensee to

determine that a loss or theft of uranium

may have occurred

(2) data, observations, and assessments

associated with attempts to resolve the

indication of missing material

(3) the time period during which the material

may have left the facility

(4) the path and means by which the material

may have left the facility

Information indicating that a loss of uranium may

have occurred can come from process monitoring

or production yield data, physical inventory

results, item monitoring audits, and shipperreceiver comparisons. This information could

include:

(1) material accountability data records and

reports

(2) inventory records

(3) inventory difference and propagation of

error calculations

(4) inventory reconciliation reports

(5) indications of unrecorded or unauthorized

removals of SNM from storage or process

locations

(6) reports of apparent destruction or

falsification of records pertaining to SNM

(7) records of broken tamper-indicating devices

or compromised item integrity

(8) indications of unauthorized entry into SNM

storage areas

(9) Reports from monthly item status

inspections

(10) material receipt and log-in records

(11) results from shipper-receiver difference

evaluations

(12) process quality assurance or production

control records

(13) documentation relating to an alleged or

confirmed theft

Information associated with resolving indications of

missing uranium are provided in Chapter 9. This

infornation and inforrnation that may be of aid in

the recovery of missing material would include:

(1) the type of unauthorized activity detected

(2) the interval during which the loss may have

occurred

(3) the amount of material and form of the 

material involved in the loss -

(4) results of measures to validate indicators

(5) results of extended measures to resolve

indicators

(6) results from special inventories (or

reinventories) and tests performed

(7) audit results of the SNM accountability

source data

(8) assessments of measurement data and

measurement controls

(9) results from reviews of the material control

and accounting program and status of

corrective actions

(10) history of indicator investigation and

resolution activities

47 NUREG-1065 Rev. 2
Assisting Investigations

(11) indicator investigation and resolution

procedures and conclusions

(12) probable cause of the loss

(13) any abnormal events that may have

contributed to or caused the loss

(14) the names of individuals who could have

been responsible for the loss

Much of the backup information necessary to assist

in an investigation would be records maintained in

the facility records system described in Chapter 11.

10.2 Acceptance Criteria

A judgment that the applicant's or the licensee's

plan for informational aid for assisting in the

investigation and recovery of rmissing uranium is

acceptable will be based on (but not limited to) the

following criterion:

Procedures are in place for the efficient and

timely gathering of relevant information to

provide government investigators so as to

aid them in the investigation and recovery

activities associated with missing SNM.

10.3 Affirmations

The affirmation statement pertaining to the 10 CFR

74.31(a)(3) performance objective listed as the third

bullet in the Affirmations Pertaining to

Performance Objectives' section on page 5, must

be stated (without modification) in the FNMC plan.

NUREG-1065 Rev. 2 48
11 Recordkeeping

11.0 Regulatory Intent

The intent of 10 CFR 74.31(d) is to require the

establishment, maintenance, and protection of a

recordkeeping system that will demonstrate that the

system capability requirements of 10 CFR

74.31(c)(1) through (8) have been met. Records

are to be retained for at least three years (or longer

if specifically required by regulations external to

10 CFR 74.31) thereby providing a means for

assessing the performance of the MC&A system

and inspecting for compliance with regulatory

requirements.

11.1 Description of Records

The FNMC plan should identify all records, forms,

reports, and standard operating procedures that

must be retained for a minimum of 3 years, as

required by 10 CFR 74.31(d). Such records should

include, but are not limited to, the following:

(1) documents that define changes in the MC&A

management structure or changes in

responsibilities relating to MC&A positions;

(2) procedures pertaining to any accountability

related measurement or sampling operation

(3) forms used to record or to report

measurement data and measurement results,

including source data

(4) forms and notebooks used to record

calibration data'associated with any

accountability measurement system

(5) forms and notebooks used to record

quantities, volumes, and Iother data

associated with the preparation of standards,

both calibration and control, used in'

connection witb accountability measurement

systems

(6) forms and official memos used to'record or

report measurement control program data,

control limit calculations, and out-of-control

investigations

(7) forms listing and providing instructions

associated with physical inventories

(8) forms and formal worksheets used in the

calculation of SEID, ID, and active'

inventory values

(9) ledgers, journals, and computer printout

sheets associated with the accountability

system

(10) ledgers, journals, and computer printout

sheets associated with the item control

program, including seal usage and attesting

to' records

(11) DOE/NRC forms 741 and 742

(12) forms, memos, and reports associated with

identification of, investigation of, and

resolution of significant SRDs

(13) loss indication and alleged theft investigation

reports

(14) investigation reports pertaining to excessive

IDs

(15) official reports containing the findings and

recommendations of MC&A system

assessments and any letters or memos

pertaining to response actions to assessment

team recommendations

(16) forms used for recording data associated

with the item monitoring program

(17) monitoring program status or summary

reports

(18) records of training sessions including date

given, topics covered, name of instructoroo.

names and signatures of those attending

(19) training, qualification, and requalification

reports and records

Examples of the more important MC&A forms

should be provided in the FNMC plan annex or

appendix. The retained records and reports should

contain sufficient detail to enable NRC inspectors to

determine that the licensee has implemented the

system features and capabilities of 10 CFR 74.3 1(c)

and has met the general performance'objectives of

10 CFR 74.31(a).

49 NUREG-1065 Rev. 2
Rc.ordkeeping

11.2 Program and Controls

for Ensuring an Accurate

and Reliable Record

System

The FNMC plan should describe the controls used

to ensure that records are highly accurate and

reliable.

The record system also should provide a capability

for easy traceability of all SNM transactions from

source data to final accounting records.

The following topics should be addressed:

(1) the auditing system or program to verify the

correctness and completeness of records

(2) the overchecks for preventing or detecting

missing or falsified data and records

(3) the plan for reconstructing lost or destroyed

SNM records

(4) the access controls used to ensure that only

authorized persons can update and correct

records

(5) the protection and redundance of the record

system such that any act of record alteration

or destruction will not eliminate the ability

to provide a complete and correct set of

SNM control and accounting information

needed to achieve the performance

objectives of 10 CFR 74.31.

11.3 Acceptance Criteria

A judgment that the licensee's commitments for

recordkeeping are acceptable will be based on (but

not limited to) the following criteria:

* The FNMC plan shows that key material

accounting and original source data

documents and relevant reports and

documents will be retained for three years

or as long as needed to show continuing

compliance with 10 CFR Part 74. (For

example, records of the organization

structure cannot be destroyed if the current

structure is still the same.)

* The source data will be retained in its

original form until the physical inventory

and any subsequent ID investigations have

been completed. After this time, any

readable facsimile is acceptable for the

remainder of the required retention period.

All other records may be retained as hard

copy, microfiche, permanent computer

readable forms, or other permanently

readable forms.

* The retained records and reports contain

sufficient detail to enable NRC inspectors to

determine that the control and accounting of

the SNM has complied with the

requirements of 10 CFR 74.31(c) and has

met the general performance objectives of

10 CFR 74.31(a).

* The records will be retrievable, sufficiently

complete and detailed to permit auditing all

parts of the MC&A system, and traceable

back to original source data.

* The records of the data that are the basis of

the calculated SEID will perrit traceability

to the sources of the variances due to

calibrations, bias adjustments and random

effects in the measurements. These records

may be summaries of calibrations, bias tests,

and variance monitoring data or control

charts.

* The record system will have sufficient

redundancy to enable reconstruction of lost

or missing records so that knowledge of the

SNM inventory is always available. The

primary records, as contrasted with

duplicate or backup records, will be

provided security against computer failure,

fire or water damage, vandalism, and access

by unauthorized persons.

* All retained MC&A records are to be

readily accessible, in order to meet time

restraints relative to their use. In general,

the record retention system is to possess the

capability to retrieve records used for

measurement control or accountability

within 24 hours if the record was generated

within the past 12 months, and within 7

calendar days if generated more than 12

months ago. Physical inventory listings are

to be available within 24 hours for the latest

two physical inventories. Item control

records are to be retrievable in time to

satisfy the criteria in Section 6.7.

* Overchecks or other controls including

access controls for updating and correcting

NUREG-1065 Rev. 2 50
Recordkeeping

records are provided so as to prevent or

detect errors in the records that would affect

inventory difference and item location.

11.4 Affirmations

The affirmation statements relating to the

recordkeeping requirements of 10 CFR 74.31(d) as

listed on pages 9 and 10, must be stated (without

modification) in the FNMC plan.

51 NUREG-1065 Rev. 2
Glossary

Glossary

The following terms are defmed in the context of

(1) their usage in this document and/or (2) how

they should be used if contained in the fundamental

nuclear material control (FNMC) plans submitted

pursuant to 10 CFR 74.31.

ACCOUNTABILITY - The determination of, and

current record maintenance of, special nuclear

material (SNM) quantities associated with (1)

receipts, (2) shipments, (3) measured discards, (4)

transfers into or between material balance areas

(MBAs) and/or item control areas (ICAs), and (5)

total material on current inventory.

ACCOUNTANCY (ACCOUNTING) - The

records (e.g., ledgers, journals, source documents,

etc.) associated with accountability.

ACIVE INVENTORY - The sum of beginning

inventory (BI), additions to inventory (A), removals

from inventory (R), and ending inventory (El) after

all common terms have been totally excluded. A

common term is any SNM material value'(or item)

that appears in both BI and EI, or both BI and R,

or both A and R, or both A and EI,with both

values derived from the'same measurement (and

thus, does not contribute to the uncertainty

associated with the current period inventory

difference). The active inventory is used as'an

indicator of processing throughput and/or

BEGINNING INVENTORY '-For each material

type code, the total itemized quantity of SNM

possessed by a facility at the start of a material

balance period (i.e., inventory period). -The

beginning inventory quantity for any given material

balance period is (by definition) exactly equal to the

ending inventory quantity for the immediately

previous period.

BIAS (MEASUREMENT BIAS) A constant,

unidirectional component of error that affects all

members of a measurement data set. Thus, a bias

can be estimated from the deviation of the mean of

several measurements of a representative standard

from the reference value (or assigned value) of such

standard.

CALIBRATION - The process of determining the

numerical relationship between the observed output

of a measurement system and the actual value of

the characteristic being measured, as based on

primary or reference standards.

CERTIFIED STANDARD - A standard weight,

material, device, or instrument having an assigned

value that is guaranteed to be within specified limits

by a nationally or internationally recognized

organization (e.g., bureau, laboratory, etc.) that'

issues and/or certifies standards.

processing activity.

CHECK STANDARD (BENCH STANDARD,

ADDITIONS TO INVENTORY - Quantities of WORKING STANDARD) - A standard, not

SNM, of a given material type code, added to a necessarily traceable to a primary standard, that is

.plant' inventory and which, prior to such addition, used routinely (e.g., daily or weekly) to check (or

were not part of the plant's total possessed quantity verify) the reliability of a measurement device,

for the material type code in question. - instrument, etc. (including those of accountability

measurement systems). Such standards are not,

ARTIFACT STANDARD - A container or item, however, used for the actual calibration or control

of certified mass, having a size, shape; and mass of accountability measurement systems.

that is representative of a particular type of processrelated item or container (e.g., a UF6 cylinder).' COMBINED STANDARD ERROR - An error

Weighing error caused by buoyancy is eliminated '`- --band derived from the respective standard error

by the use of artifact standards for scale i' values associated with each of two measurements

calibrations. (usually independent of each other) performed on a

given material quantity. For both measurement

ASSIGNED VALUE - A value for rmass, volume, values (of the pair) to be regarded as being in

SNM concentration, SNM quantity, etc., assigned agreement, they must not differ from each other by

to a standard weight, standard material, etc.:; used more than the calculated combined standard error,

for calibrating and/or controlling a measurement' which is normally calculated by taking the square

device or system. An assigned value may not root of the sum of squared individual standard

necessarily be a certified value, but if not, should -errors. That is:

be traceable to a certified standard. In any event, it

is the best estimate of the standard's true value. combined S.E. = [(,)2 + (or)21 'h

53- NUREG-1065 Rev. 2
Glossary

CONFIRMATORY MEASUREMENT - A

measurement that confirms (within measurement

uncertainty at the 95 percent confidence level) a

previously established parameter, such as net

weight, enrichment, etc., associated with an SNM

item (or SNM quantity), but which does not

thoroughly verify the previously established element

and/or isotope quantity assigned to such item.

Confirmatory measurements are sometimes used as

the basis for concluding that previous measurement

values for uranium and U-235 (or element and

isotope) quantities are still valid.

CONTROL STANDARD - A standard that (1) is

representative of the process material being

measured and (2) is itself measured periodically to

monitor for and to estimate any bias associated with

the measurements of the process material in

question. A control standard must be traceable to a

primary standard or to a primary reference

material.

CUSTODIAN - A designated individual who is

responsible for (1) the control and movement of all

SNM within a specified control area, and

(2) maintaining records relative to all SNM that is

transferred into or out of the area and that is

currently located within the control area. Control

areas are usually designated as MBAs or ICAs.

From the standpoint of good safeguards practice, a

single individual should not be a custodian of more

than one control area.

DEPLETED URANIUM - Any uranium-bearing

material whose combined U-233 plus U-235

isotopic content is less than 0.70 wt % (relative to

total uranium elemental content).

DETECTION QUANTITY (DQ) - A site-specific

U-235 quantity of SNM for licensees whose

processing activities are limited to SNM of low

strategic significance. The DQ is normally a

function of annual throughput, but for lowthroughput low-enriched uranium (LEU) facilities,

the DQ need not be less than 25 kilograms of

U-235. The DQ also can be described as a goal

quantity, the loss or theft of which must be detected

with a 90 percent (or better) probability at the time

of a physical inventory.

DETECTION THRESHOLD (DT) - An inventory

difference (ID) limit that will be exceeded (with

90 percent or higher probability) by an ID resulting

from the taking of a physical inventory whenever

there has been an actual loss of a detection

quantity. The DT is a function of both the DQ and

the standard error of the inventory difference

(SEID), as shown by the following equation:

DT = DQ - 1.3 (SEID)

EFFECTIVE KILOGRAM - An effective

kilogram of SNM means (1) for plutonium and

U-233, their weight in kilograms; (2) for uranium

with an enrichment in the isotope U-235 of

1.00 wt % (i.e., 0.01 g U-235/g U) and above, its

element weight in kilograms multiplied by the

square of its enrichment expressed as a decimal

weight fraction; and (3) for uranium with an

enrichment in U-235 below 1.00 wt %, but above

0.71 wt %, its element weight in kilograms

multiplied by 0.0001.

ENDING INVENTORY - For each material type

code, the total itemized quantity of SNM possessed

by a facility at the end of a material balance period,

as determined by a physical inventory. The ending

inventory quantity for any given material balance

period is (by definition) exactly equal to the

beginning inventory quantity for the next period.

ENRICHED URANIUM - Any uranium-bearing

material that does not qualify as natural uranium

and whose combined U-233 plus U-235 isotopic

content is 0.72 wt % or higher relative to total

uranium elemental content.

FORMULA KILOGRAM (FKG)- The number of

formula kilograms is computed by the following

equation:

FKG =

[(grams U-235 contained in high-enriched

uranium) + 2.5 (grams U-233 +

plutonium)]

divided by 1000

FORMULA QUANTITY - Strategic SNM in any

combination in a quantity of 5.00 FKGs or more.

HIGH-ENRICHED URANIUM (HEU) - Any

uranium-bearing material whose U-235 isotopic

content is 20.00 wt or more relative to total

uranium elemental content.

INVENTORY DIFFERENCE (ID) -The

arithmetic difference between a book inventory and

the corresponding physical inventory, calculated by

subtracting ending inventory (El) plus removals

from inventory (R) from beginning inventory (BI)

plus additions to inventory (A). Mathematically,

this can be expressed as:

ID = (BI + A) - (El + R)

NUREG-1065 Rev. 2 54
Glossary

INVENTORY RECONCILIATION - The 

adjustment of the book record quantity of both

element and fissile isotopes to reflect the results of

a physical inventory. In the broad sense, inventory

reconciliation also includes the activities of

calculating (1) the ID for the material balance

period in question, (2) the uncertainty (i.e., SEID)

value associated with the ID, (3) the active

inventory for the period, and (4) any bias

adjustment and/or prior period adjustment

associated with the ID value.

ITEM - Any discrete quantity or container of

SNM, not undergoing processing, having a unique

identity and also having assigned uranium and U235 quantities.

ITEM CONTROL AREA (ICA) - An identifiable

physical area for the storage and control of SNM

items. Control of items moving into or out of an

ICA is by item identity and SNM quantity as

determined from previous measurement.

ITEM CONTROL PROGRAM -A system that

tracks (i.e., records) the creation, identity, location,

and disposition of all SNM items of certain

predetermined item categories. In addition, item

control programs usually provide a periodic

verification of item existence and location for static

items.

LOW-ENRICHED URANIUM (LEU) -. Any

uranium-bearing material whose U-235 isotopic

content is greater than 0.72 wt % but less than

20.00 wt % relative to total uranium elemental

content.

MATERIAL BALANCE- A comparison on a

measured basis of beginning inventory plus,

additions to inventory to ending inventory plus removals from inventory for a given'control area (or

combination of control areas) over a specified

period of time.

MATERIAL BALANCE AREA (MBA) - An

identifiable physical area for- the physical and

administrative control of nuclear material such that

the quantity of nuclear material being moved into or

out of the MBA is represented by a measured value

(for both element and isotope).: 

MATERIAL BALANCE PERIOD - The time

span to which a material balance or physical

inventory pertains.

MATERIAL TYPE CODES -Number codes for

identifying basic material types with respect to SM,

SNM and by-product materials. These codes are

used by the Nuclear Materials Management and

Safeguards System (NMMSS) for tracking U.S.-

owned and U.S.-possessed materials worldwide.

For SNM, seven material type codeshave been

assigned as follows:

CODE

10

20

50

70

83

88

89

MATERIAL TYPE

Depleted Uranium

Enriched Uranium ()

Plutonium

Uranium-233 (**)

Plutonium-238 (***)

Thorium

Uranium in Cascades

'For DOEINRC Form 742, naterial code 20 has 4

subcodes to denote enrichment range: El, E2, E3, and E4. For

NRC Form 327. material code 20 has 2 subcodes: LEU and

HEU.

**Uranium naterials should be regarded as material

code 70 if the U-233 isotopic abundance is greater than (1)

10.00 wt % relative to total uranium elemental content or (2)

both (a) the U-233 isotopic abundance is greater than the U-235

isotopic abundance and (b) the U-233 isotopic abundance

exceeds 5.00 wt % relative to total elemental uranium content;

otherwise report as material code 10, 20, or 81. as appropriate.

**Plutonium materials should be regarded as material

code 83 if the plutonium-238 isotopic abundance is greater than

10.00 wt % relative to total plutonium elemental content;

otherwise, report as material code 50.

MEASURED DISCARD - A batch or quantity of

waste, whose SNM content has been determined by

measurement, that (I) has been shipped to a,

disposal site, released to the environment, or stored

on site, and (2) has been taken off the accounting

ledgers as part of the current inventory of possessed

SNM.

MEASUREMENT - The process of determining a

(1) uranium elemental concentration, (2) specific

uranium isotopic content, (3) U-235 enrichment

(i.e., isotopic abundance), (4) bulk material mass or

item mass, or (5) bulk material volume.

Measurement values are derived through a

calibration process that establishes the relationship

between instrument (i.e., device) response and the

parameter being determined.-

MEASUREMENT CONTROL PROGRAM - A

managed program for monitoring and controlling

both accuracy and precision of SNM accountability

measurements.

NATURAL URANIUM - Any uranium-bearing

material whose uranium isotopic distribution has not

= been altered from its naturally occurring state.

Natural uranium is nominally 99.283 wt % U-238,

0.711 wt % U-235, and 0.006 wt % U-234.

55- NUREG-1065 Rev. 2
Glossary

NORMAL URANIUM - Any uranium-bearing

material having a uranium isotopic distribution that

can be characterized as being (1) 0.700 wt % to

0.724 wt % in combined U-233 plus U-235 and (2)

at least 99.200 wt % in U-238. (NOTE: All

natural uranium having a U-235 isotopic abundance

in the range of 0.700 wt % to 0.724 wt % is

normal uranium, but not all normal uranium is

natural uranium.)

PHYSICAL INVENTORY - A determination by

physical means (visual and measurement) of the

quantity of SNM on hand for a given material type

code at a specified point in time. The primary

purpose for a physical inventory is to confirm the

absence of (or to detect) a loss, theft, or diversion

of SNM. For the conclusion drawn from a physical

inventory to be meaningful, not only does the

physical presence of all material (or at least the vast

majority of the material) need to be confirmed, but

the quantities of material in the inventory also need

to be remeasured, or other assurance provided, to

verify that prior measurements are still valid.

Physical inventories are to be conducted on a

.plant' as well as on a material type code' basis.

PLANT - For SNM control and accounting

purposes, a plant is defined as a set of processes or

operations (on the same site, but not necessarily all

in the same building) coordinated into a single

manufacturing, research and development, or

testing effort. Most licensees have only one plant

in this context. Independent on-site manufacturing

efforts, such as a scrap recovery operation serving

both on-site and off-site customers, should be

treated as separate plants.

POINT-CALIBRATED MEASUREMENT

SYSTEM - A measurement system in which the

measurement value assigned to an unknown

measured by the system is derived from the

response obtained from the measurement of a

representative calibration standard(s) that was

measured along with (i.e., at the same time as) the

unknown. The standard(s) must undergo all the

measurement steps (e.g., aliquoting, sample

pretreatment, etc.), and in the same manner, as the

unknown. Point-calibrated measurement systems

can be regarded as bias free, provided that adequate

controls are in place to ensure the validity of the

standard's assigned value.

PRIMARY STANDARD - Any device or material

having a characteristic or parameter (such as mass,

uranium concentration, uranium isotopic distribution, etc.) whose value is certified (within a

specified uncertainty) by a nationally or

intemationally recognized bureau, laboratory, etc.,

that issues and/or certifies standards.

PRIOR PERIOD ADJUSTMENT - Any

correction (i.e., adjustment) to an ID value because

of a correction applied to a component of beginning

inventory after the inventory period started. Such

corrections may be due to resolution of a shipperreceiver difference (SRD) on material received

during a prior inventory period, correction of a

recording error, etc. Because these types of

corrections have nothing to do with current period

losses or errors, and because the official beginning

inventory value is not adjusted, an adjustment to the

ID value (derived from the ID equation) is

necessary to obtain an ID that reflects only current

period activity.

PROCESS MONITORING - A system of

monitoring production data (e.g., flow rates, yields,

densities, etc.) and of production control or quality

control measurements (as opposed to accountability

measurements) that could provide early (i.e.,

timely) detection of an anomaly that may indicate a

significant loss or theft of SNM or indicate

unauthorized enrichment activities.

RANDOM ERROR - The variation encountered in

all measurement work, characterized by the random

occurrence of both positive and negative deviations

from a mean value.

RECEIPT - A quantity of SNM in a shipment

received by a facility from another facility.

REFERENCE STANDARD - A material, device,

or instrument whose assigned value is traceable to a

national standard (i.e., primary standard) or nationally accepted measurement system.

REMOVALS FROM INVENTORY - All

measured quantities of SNM falling within the

categories of (1) shipments, (2) measured discards

released to the environment, (3) measured discards

transported off-site, and (4) measured discards

stored on-site and formally transferred in the

accounting records to a holding account via a

DOE/NRC Form 741 transaction.

RESOLUTION OF AN INDICATOR - A

definitive determination (with auditable evidence)

by the licensee that an indicated possible theft or

loss of uranium was a false indicator.

SHIPPER-RECEIVER DIFFERENCE (SRD) -

The difference between what a sending facility

(i.e., shipper) claims was contained in a shipment

NUREG-1065 Rev. 2 56
Glossary

(of SNM) and what the receiving facility claims

was received, where both shipper's and receiver's

values are based on measurement.

SPECIAL NUCLEAR MATERIAL (SNM) - (1)

Plutonium, U-233, uranium enriched in U-235, and

any other material that the NRC, pursuant to the

provisions of Section 51 of the Atomic Energy Act

of 1954 (as amended), determines to be SNM; or

(2) any material artificially enriched in any of the

foregoing. There are three levels of strategic

significance applied to SNM, depending on the type

and quantity, defined as follows:

SNM OF HIGH STRATEGIC SIGNIFICANCE

- Same as FORMULA QUANTITY (see

definition).

SNM OF MODERATE STRATEGIC

SIGNIFICANCE - (1) Less than a formula

quantity, but more than 1,000 grams of U-235

contained in HEU, or more than 500 grams of

U-233 or plutonium, or more than a combined

quantity of 1,000 formula grams when formula

grams are computed by the following equation:

formula grams = (grams U-235 in HEU)

+ 2 (grams U-233 + grams Pu)

or (2) 10,000 grams or more of U-235 contained

in LEU enriched to 10.00 wt % or more, but

less than 20.00 wt %, U-235.

SNM OF LOW STRATEGIC SIGNIFICANCE

- (1) Less than an amount of SNM of moderate

strategic significance, but more than 15 grams of

(a) U-235 contained in HEU, (b) U-233,

(c) plutonium, or (d) any combination thereof;

(2) less than 10,000 grans but more than 1,000

grams of U-235 contained in LEU enriched to

10.00 wt % or more (but less than 20.00 wt %)

U-235; or (3) 10,000 grams or more of U-235

contained in LEU enriched above natural but

less than 10.00 wt % U-235.

STANDARD - See definitions for CERTIFIED

STANDARD, CHECK STANDARD, CONTROL

STANDARD, PRIMARY STANDARD, and

REFERENCE STANDARD.

STANDARD DEVIATION - The random error

(at the 67 percent confidence level) associated with

a single value of a data set, which in tum is also a

measure (or indication) of the precision relating to a

set of measurements (or set of data) pertaining to

the same item or sample of material. Standard

deviation is calculated as follows:

| E ( ~- )

std. dev. = I ,.- 

n-I

]h

where

n = number of measurements performed

xi= the value obtained for the i th

measurement for i 1, 2, 3 ....... n

x = the average value for all n

measurements

STANDARD ERROR - The random error (at the

67 percent confidence level) associated with the

average, or mean, value of a data set derived from

repetitive determinations on the same item or

sample. Mathematically, standard error is the

standard deviation divided by the square root of the

number of individual measurements used to derive

the mean value.

STANDARD ERROR OF THE INVENTORY

DIFFERENCE (SEID) - For licensees subject to

10 CFR 74.31 or 74.33, non-measurement

contributions to the uncertainty of ID can be

assumed or estimated, but can not exceed the

measurement contribution. Thus for 74.31 and

74.33 licensees, SEID is equal to the square root of

the sum of both measurement and non-measurement

variances associated with the ID.

STANDARD REFERENCE MATERIAL - A

material or substance that qualifies as a primary

standard and whose concentration with respect to a

nuclide or isotope, a chemical element, or chemical

compound is certified within a specified

uncertainty.

SYSTEMATIC ERROR - A unidirectional error

that affects all members of a data set. The terms

'bias' and systematic error' are often

interchanged. However, any determined bias (i.e.,

a bias estimated from control standard

measurements) has an uncertainty value associated

with it. Thus, after correcting for any estimated

bias, the uncertainty of that bias can be regarded as

a systematic error. If an estimated bias is not

applied as a correction, the combination of the bias

plus its uncertainty should be regarded as the

systematic error.

57 NUREG-1065 Rev. 2
Glossary

TRACEABILITY - The ability to relate individual

measurement results to national standards (i.e.,

primary standards) or nationally accepted

measurement systems through an unbroken chain of

comparisons.

VERIFICATION MEASUREMENT - (I) An

NDA measurement of an item conducted to verify

that a previous NDA measurement value for isotope

content of that item is still valid. (2) The

re-weighing and re-sampling of an item, batch, lot,

or sublot and performing chemical assays of the

re-sample for element and isotope concentrations so

as to verify a previously measured value for

element and isotope content of the item (batch, lot,

or sublot). Verification is achieved if the original

and verification measurement values (for element

and isotope quantities) agree within the range of

measurement uncertainty (at the 95 percent

confidence level).

NUREG-1065 Rev. 2 58
NRC FORM 335 U.S. NUCLEAR REGULATORY CO.MMISSION 1. REPORT NUMBER (2-ag) - ~~~~~~~~~~~~~~~~~~~~~~~~(Assig

by NRC, Add Vol., NRCM1102 Supp. * Rev..* and AddenidumT Num3201, 3202 BIBLIOGRAPHIC DATA SHEET bers, If an

(See Instructlons on the reverse) NUREG-1065

Rev. 2

2. TITLE AND SUBTITLE

Acceptable Standard Format and Content for the Fundamental Nuclear Material 3. DATE REPORT PUBUSHED

Control (FNMC) Plan Required for Low-Enriched Uranium Facilities MONTH I YEAR

December 1995

4. FIN OR GRANT NUMBER

5. AUTHOR(S) 6. TYPE OF REPORT

D. R. Joy Technical

7. PERIOD COVERED (Inclusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (f NRC, provide Division. Office or Region, U.S. Nuclear Regulatory Commission, and

mailing address; It contractor, provide name and mailing address.)

Division of Fuel Cycle Safety and Safeguards

Office of Nuclear Material Safety and Safeguards

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC. type 'Same as above'; If contractor, provide NRC Division, Office or Region.

U.S. Nuclear Regulatory Commission, and mailing address.)

Same as item #8

10. SUPPLEMENTARY NOTES

11. ABSTRACT (200 words or less)

This report documents a standard format suggested by the NRC for use in preparing fundamental nuclear material

control (FNMC) plans as required by the Low Enriched Uranium Reform Amendments (1OCFR 74.31). This report

also describes the necessary contents of a comprehensive plan and provides example acceptance criteria which are

intended to commjnicate acceptable means of achieving tbe performance capabilities of the Reform Amendments.

By using the suggested format, the licensee or applicant will minimize administrative problems associated with the

submittal, review and approval of the FNMC plan. Preparation of the plan in accordance with this format will assist

the NRC in evaluating the plan and in standardizing the review and licensing process. However, conformance with

this guidance is not required by the NRC. A license applicant who employs a format that provides a equal level of

completeness and detail may use their own format. This document is also intended for providing guidance to licensees when making revisions to their FNMC plan.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers In locating the report.) 13. AVAILABILITY STATEMENT

Unlimited

Reform Amendments 14. SECURITY CLASSIFICATION

Low Enriched Uranium (This Page)

LEU Fuel Fabrication Unclassified

Material Control and Accounting (This Report)

Special Nuclear Material Unclassified

SNM of Low Strategic Significance 15. NUMBER OF PAGES

16. PRiCE

NRC FORM 335 (2-89)
Federal Recycling Program