Issue Date: 10/26/2011 C3-1 1246

APPENDIX C3

TRAINING REQUIREMENTS AND QUALIFICATION JOURNAL FOR MATERIAL 

CONTROL AND ACCOUNTING LICENSE REVIEWER 

I. TRAINING REQUIREMENTS

A. Applicability

The training described below is required for all personnel assigned as material control 

and accounting (MC&A) license reviewers.

B. Training

1. Required Training

a. Initial Training

i. Agency-Level Knowledge

ii. Office-Level Knowledge

iii. Ethics, Objectivity, and Professional Conduct

iv. Differing Views and Staff Diversity

b. Core License Reviewer Training

i. Title 10 of the Code of Federal Regulations

ii. Exploring the Fuel Facility Licensing Program

iii. Licensing Actions

iv. Interacting with Stakeholders

v. The Inspection Program

vi. MC&A/FNMC Plans

c. MC&A Training

i. MC&A Management Structure

ii. Measurements and Measurement Control

iii. Item Control and Item Monitoring
Issue Date: 10/26/2011 C3-2 1246

iv. Physical Inventory

v. Process Monitoring

vi. Detection of Unauthorized Production

vii. Resolution Program

viii. Recordkeeping/Independent Assessments

d. On the Job Training

e. Specialized Training

i. Site Access Training (H100 or H101)

ii. Fuel Cycle Processes (F201 or F201S)

iii. Regulatory Process

iv. Communications (complete at least one)

1. Technical Writing

2. Conducting Effective Public Meetings

3. Media Training Workshop

v. Basic MC&A Training (complete as needed based on 

experience in consultation with Branch Chief)

(1) MCA-101DC – Introduction to Nuclear Material Control & 

Accounting

(2) Measurement of Nuclear Material

(3) MCA-110 – Basics of Nuclear Materials Accountability

(4) MCA-120 – Basics of Nuclear Materials Control

(5) MCA-130 – Statistical Concepts in MC&A

vi. Additional Post Qualification MC&A Training (complete as 

needed based on experience in consultation with Branch 

Chief)
Issue Date: 10/26/2011 C3-3 1246

(1) MCA-260 – Physical Inventories for MC&A

(2) Fundamentals of Nondestructive Assay

(3) Statistical Concepts in Nuclear Safeguards

2. Supplemental Training. Additional training beyond that identified as Core 

Training. This training will be determined by the individual’s supervisor. It will 

depend on the individual’s previous work experience and planned licensing 

activities in specific areas.

3. Refresher Training. Refresher training will be determined by management

on a case-by-case basis.

II. QUALIFICATION JOURNAL

Purpose

This Qualification Journal (Journal) implements NRC Manual Chapter 1246 by 

establishing the minimum training requirements for personnel assigned as material 

control and accounting (MC&A) license reviewers. 

This Journal establishes the minimum training requirements consistent with NRC 

Manual Chapter 1246. The document consists of a series of qualification guides and 

signature cards. Each signature card is used to document task completion, as indicated 

by the appropriate signature blocks. It establishes the minimum knowledge levels or 

areas of study that must be completed for each signature card. These signature cards 

provide traceable documentation to show that minimum requirements are met for each 

MC&A license reviewer.

Journal Format

The Qualification Cards will be divided into the following three sub-sections:

1. Evaluation Criteria

2. Tasks

3. Supervisor Approval

Each section will contain multiple items, e.g. documents, tasks, questions, etc. The 

tasks must be initialed by the supervisor or the proctor approved by the supervisor. The 

tasks will be labeled with a review tag to help identify the amount of effort the individual 

is expected to undertake. The review level may be adjusted by the individual’s 

supervisor on a case by case basis.
Issue Date: 10/26/2011 C3-4 1246

Basic = B:

Scan the information, but do not read word-for-word. Become knowledgeable of 

the purpose and general content. Be aware the information exists, know where it 

can be accessed, and know how it is used. Expect Qualification Questions 

regarding awareness of the information and where to find it. (Example Question:

If uncertain how to report travel time on the weekend, where would one find 

guidance on this topic.)

Intermediate = I:

Familiarity plus: Review the entire body of information. Understand how the 

information correlates to the roles, responsibilities, and assignments of the 

position. Expect a few Qualification Questions to be drawn from key concepts in 

the material. Be prepared to give basic examples of how the information would 

be used on the job.

(Example Question: What role does 10 CFR 73 play in the regulation of our 

licensees?)

Comprehensive = C

Basic plus: Study the entire body of information thoroughly. Be prepared to 

explain the basic steps needed to complete key tasks associated with the 

subject. Rather understand and be able to describe the process, the regulatory 

basis, and the importance of applicable guidance. 

(Example Question: If a licensee submits an MC&A (or Fundamental Nuclear 

Material Control [FNMC]) Plan for a new facility process, describe how you would 

conduct the review and summarize the regulatory requirements needed for 

approval.)

Proctors

In order to support the “On the Job Training” requirements, the candidate will work 

under the direction of a qualified MC&A license reviewer to complete the required 

training. Any qualified member of the staff, as approved by the supervisor, may review 

and initial specific items on the qualification cards. The qualification board should seek 

to tailor the qualification process to the experience and training level of the reviewer and 

to meet the needs of the NRC. 

Qualification Journal Notebook

The qualification program involves two major tasks. First, the individual must review the 

material specified in the Qualification Cards listed below. Once the material has been 

reviewed to the satisfaction of the individual’s First Line Supervisor, the appropriate box 

below must be initialed. Second, after the qualification cards have been signed, the 

individual must appear before a Qualification Board, as described in Section 1246-08. 

At the successful completion of this Board review, the Second Line Supervisor, a Senior 

Executive Service (SES) manager, must provide the approval signatures. To complete 

your qualification, you are to complete the following signature cards. All signoffs shall 
Issue Date: 10/26/2011 C3-5 1246

include the signature of the responsible reviewer and the date. Maintain these cards in a 

notebook along with any background or written material required by the program. This 

notebook will comprise your NRC Qualification Journal. 

Additional guidance, including sample oral board questions, is provided in the 

Knowledge Management Center at 

http://nrcknowledgecenter.nrc.gov/CommunityBrowser.aspx?id=1546&lang=en-US.

New Employees

New employees to the agency who are hired to NMSS shall complete, “New Employee 

Orientation Checklist”. The NMSS “New Employee Orientation Checklist” generally 

includes activities that a new NMSS employee would encounter in the first few weeks of 

employment. For activities that require more than the first few weeks of employment, 

employees can finish the activities in parallel with a qualification plan. The New 

Employee Orientation Checklist can be found in 

http://www.internal.nrc.gov/HR/pdf/orientation-checklist.pdf.
Issue Date: 10/26/2011 C3-6 1246

FUEL CYCLE MC&A LICENSE REVIEWER

QUALIFICATION JOURNAL NOTEBOOK

Name:

Position:

Branch:

Individual Education, Training and Experience (insert or attach description):

Beginning Date of Training and Qualification:

Proposed Completion Date of Training and Qualification:

(not to exceed 2 years from beginning date)

Acceptance of Qualification Plan

Employee Signature: _____________________________ Date: _________

Branch Chief Signature: ____________________________ Date: _________

Completion of All Requirements except Oral Board

Employee Signature: _____________________________ Date: _________

Branch Chief Signature: ____________________________ Date: _________

Successful Completion of Oral Board

SES Signature: _____________________________Date: _________

Signature: _____________________________ Date: _________

Signature: _____________________________ Date: _________

Signature: _____________________________ Date: _________
Issue Date: 10/26/2011 C3-7 1246

Qualification Guide 1

Agency-Level Knowledge

PURPOSE. The purpose of this activity is to familiarize the employee with the structure 

of the Agency and some impacts from regulatory history on the regulatory framework 

under which today’s NRC staff functions. Employees should gain an understanding of 

how the agency was formed and how it contributes as an independent agency.

EVALUATION CRITERIA.

At the completion of this activity you should be able to:

1. Describe the statutes authorizing NRC activities.

2. Describe the history of the NRC.

3. Describe the NRC's Strategic Plan.

4. Describe how the NRC regulates.

5. Describe the organization and functions of NRC offices.

6. Describe the License Fee Program.

7. Describe major document collections including the general topic and the intended 

audience of each.

8. Describe how the Commission operates

9. Describe how the staff communicates with the Commission

10. Describe how the NRC responds to emergencies.

TASKS.

1. Statutes - Locate the discussion of statutory authority on the public website. (Select 

"About NRC," then select "Governing Legislation".)

a. In general, what is the purpose of the Atomic Energy Act (AEA) of 1954?

b. What is 11(e)2 material? See AEA Section 11 - Definitions.

c. What is "Restricted Data"? See AEA Section 11 - Definitions.

d. What AEA section defines "Safeguards Information"? See AEA Chapter 12 -

Control of Information.

e. What AEA section gives the public the right to know about significant actions and 

the right to request a hearing (e.g., to participate in the regulatory process)? See 

AEA Chapter 16 - Judicial Review.

f. When the Commission establishes an Agreement with a State, is the 

Commission's authority delegated or discontinued? See AEA Section 274 -

Cooperation with States.
Issue Date: 10/26/2011 C3-8 1246

g. Agreements with States are limited to what material? See AEA Section 274.

h. In general, what is the purpose of AEA Title II?

i. Does the NRC license or certify gaseous diffusion plants? See AEA Chapter 27 -

Licensing and Regulation of Uranium Enrichment Facilities.

j. In general, what is the purpose of the Energy Reorganization Act (ERA) of 1974?

k. Does the NRC belong to a Branch of the Federal Government, or is it an 

independent agency? See ERA Section 201.

l. What employee protection is provided by the ERA? See ERA Section 211 -

Employee Protection.

m. In general, what is the purpose of the Administrative Procedures Act? See 

summary on public web site. 

n. In general, what is the purpose of the National Environmental Policy Act? See 

summary on public web site. 

o. In general, what is the purpose of the Energy Policy Act of 1992? Search 

website. In addition, see NUREG-0980.

p. In general, what is the purpose of the Energy Policy Act of 2005? What security 

requirements did it impose? Search website. In addition, see NUREG-0980.

2. History - Locate the discussion of NRC history on the public website. (Select "About 

NRC," then select "History". Also see NUREG/BR-0175.)

a. In general, what was the concern that led to re-organizing the Atomic Energy

Commission and creating NRC?

b. How did NRC's regulatory approach change after the accident at Three Mile 

Island?

c. In general, describe some major issues that have been addressed regarding 

nuclear materials safety.

3. Strategic Plan - Locate the discussion of the Strategic Plan on the public website. 

(Select "About NRC," then select "Plans, Budget, & Performance". Also see 

NUREG-1614.)

a. What are the key elements of the Strategic Plan?

b. What is the mission of the NRC?

c. What are the values of the NRC?

d. What are the Strategic Goals of the NRC?

e. Scan the Strategic Outcomes and Safety Goal Strategies. Know where to find 

them.
Issue Date: 10/26/2011 C3-9 1246

4. How We Regulate - Locate the discussion of regulations on the public website. 

(Select "About NRC," then select "How We Regulate".) Describe the key elements of 

our regulatory system.

5. Organization - Locate the discussion of organization on the public website. (Select 

"About NRC," then select "Organization and Functions".)

a. Note which office report directly to the Commission and which offices report to 

the Executive Director of Operations (EDO). Know where to find the information.

b. Who is serving on the Commission currently?

c. What is the function of the Office of the EDO? Which Deputy EDO is responsible 

for our office?

d. Which Congressional Oversight Committees does the Office of Congressional 

Affairs keep informed?

e. Which Assistant General Counsel handles fuel cycle issues?

f. What kind of licenses does the Office of International Programs issue?

g. Who are the Public Affairs Officers in Region II?

h. Which office codifies Commission decisions in memoranda to the staff?

i. Which office investigates charges of criminal activity by NRC staff?

j. Which office investigates charges of criminal activity by licensees?

k. Which office is responsible for the Agreement State Program?

l. Which office manages the NRC Operations Center?

m. Which Region implements the Fuel Facility Inspection Program?

n. Which office is responsible for the Agencywide Document Access and 

Management System (ADAMS)?

o. Which office delivers your mail?

p. Which office implements the Employee Mentoring Program?

q. Which office has oversight of safety culture issues?

6. License Fee Program - Locate the discussion of fees on the public website. (Select 

"About NRC," then select "How We Regulate," then select "Licensing," then select 

'License Fees.")

a. Why does the NRC charge fees for licensing actions?

b. Which parts of NRC regulations establish the fees licensees must pay?

c. Which office is responsible for the NRC Fee Policy?
Issue Date: 10/26/2011 C3-10 1246

7. Major Document Collections - Locate document collections on the internal website. 

(Under "Agencywide" select "Info Resources" and then select the collection of 

interest.

a. What are the purpose and the audience for Management Directives (See MD 

1.1)?

b. What is a NUREG? (See brief statement on NUREG home page. Note different 

types of NUREGs.)

c. What is the purpose and audience for a Regulatory Guide? (See brief statement 

on Regulatory Guide home page. Note different divisions of guides.)

d. What is the purpose and audience of a Standard Review Plan (SRP)? SRP's are 

issued as what type of document?

e. What types of documents are provided for inspectors in the Inspection Manual? 

(See Inspection Manual Chapter 0040, Sections 07.01 - 07.04)

f. What is the purpose of the Enforcement Policy (not the Enforcement Manual)? 

In what form is the policy being maintained currently? (Select "Enforcement" in 

the "Document Collections" section of the web page.)

8. How the Commission Operates - Locate discussion on public web site (Go to "About 

NRC", select "Organization & Functions", select "The Commission", select "DirectSetting and Policymaking Activities".)

a. What is a SECY paper?

b. What is a Commission Action Memoranda?

c. Check the schedule of upcoming Commission meetings and attend a meeting 

(on a topic related to your area if possible).

d. What is a Staff Requirements Memoranda?

e. What is a Commission Voting Record?

9. Communications with the Commission - Locate the "Offices" section on the internal

website and select "OEDO". Select "Info for the Commission" and then select 

"Procedures."

a. What is the purpose of a Drop-In Briefing Package? Know where to find the 

guidance.

b. What is the purpose of a Commissioners' Assistants Note? Know where to find 

the guidance.

c. What is the purpose of a Daily Note and a One Week Look Ahead? Know where 

to find the guidance.

d. Skim the last several EDO Updates to identify topics of interest to senior 

managers. (From the OEDO home page select "News from the EDO.")

e. If possible, attend a Commission All-Hands Meeting.
Issue Date: 10/26/2011 C3-11 1246

10. NRC Response to Emergencies - Locate discussion on public web site (Under 

"Spotlight", select "Emergency Preparedness". Scroll down and select "How We 

respond to an Emergency.") In addition, see MD 8.2, NRC Incident response 

Program.

a. What is NRC's highest priority when responding to an emergency?

b. With respect to other Federal agencies, what is NRC's role when the emergency 

occurs at a facility licensed by NRC or an Agreement State?

c. What changes when an emergency rises to the level of General Emergency, or is 

terrorist-related?

d. In general, describe the NRC response modes.

e. Describe the Fuel Cycle Safety Team functions (On the internal web page, under 

Offices select NMSS, then look under Emergency Preparedness)
Issue Date: 10/26/2011 C3-12 1246

SUPERVISOR APPROVAL:

Basic = B, Intermediate = I, Comprehensive= C

B NRC Statutory Authority 

B NRC History 

C NRC Strategic Plan

I How NRC Regulates

B Organization and Function of Offices

B License Fee Program 

B Document Collections 

B How the Commission Operates 

B Communications with the Commission 

B NRC Response to Emergencies 

Initials Date

Initials Date

Initials Date

Initials Date

Initials Date

Initials Date

Initials Date

Initials Date

Initials Date

Initials Date
Issue Date: 10/26/2011 C3-13 1246

Qualification Guide 2

Office-Level Knowledge

PURPOSE. The purpose of this activity is to familiarize the employee with the structure, 

procedures and functions of the Office of Nuclear Material Safety and Safeguards.

 

EVALUATION CRITERIA.

At the completion of this guide you should be able to:

1. Describe the NMSS Mission, Goals, and Values.

2. Describe the NMSS organization and functions.

3. Describe NMSS Office Letters (location and general topics).

4. Describe the various coordinators that NMSS has 

5. Describe the NMSS Delegation of Authority

6. Describe how to use the NMSS Ticket Tracking System

TASKS.

1. Mission, Goals and Values - Locate on internal website (Find "Offices", click on 

"NMSS", then scroll down and click on "Mission, Goals and Values".)

a. Do the NMSS goals match the Agency goals?

b. In general, describe the NMSS values and some aspects of those values.

c. Review the NMSS Operating Plan for the current fiscal year. (Located on S: 

drive)

2. Organization and Functions - Locate on internal website (Find "Offices", click on 

"NMSS", then scroll down and click on information needed.)

a. Who are the current Office Director and Deputy Office Director?

b. In general, describe the function of each division.

c. If you had a question about criticality safety, which Branch Chief would you call?

d. If you had a question about a centrifuge enrichment plant, which Branch Chief 

would you call?
Issue Date: 10/26/2011 C3-14 1246

e. If you had a question about the shielding in a spent fuel shipping cask, which 

Branch Chief would you call?

f. If you had a question about the Licensing Support Network for the high-level 

waste repository, which Branch Chief would you call?

3. Office Letters - Locate the NMSS Policy and Procedures Letters in ADAMS (Launch 

the ADAMS Document Manager and sign in. In the Main Library, open the NMSS 

P&P folder.)

a. Note that many of these letters are outdated. Review the "NMSS P&P Index" 

file.

b. What is the policy for radiation protection of NMSS staff (see P&PL 1-42)? In 

addition to the responsibilities of all staff, what special responsibilities does

female staff have? How do you obtain a dosimeter?

c. Where do find guidance on withholding information from the public (see P&PL 1-

85)? Is OGC concurrence required on routine withholding determinations?

d. Where do you find guidance on posting notices on the NRC website of hearing 

opportunities for major licensing actions (see P&PL 1-86)?

e. Where do you find guidelines for voice mail and e-mail (see P&PL 1-87)?

f. Where do you find HRMS codes you can use to charge your time (see P&PL 2-

3)?

4. Office Coordinators - Locate on internal website (Find "Offices", click on "NMSS", 

then scroll down and click on "Contacts and Resources List".)

a. Who is the Training Coordinator that can help you register for a class?

b. Who is the Event Coordinator that can help you find an event report?

c. Who is the Allegation Coordinator that can help you follow-up on a phone call 

regarding discrimination by a licensee?

d. Who is the Enforcement Coordinator that can help you prepare for an 

enforcement panel?

e. Who is the Generic Communications Coordinator that can help you write an 

Information Notice?
Issue Date: 10/26/2011 C3-15 1246

f. Who is the Inspection Manual Coordinator that can help you revise an Inspection 

Procedure?

g. Who is the Radiation Safety Officer who can help you get a dosimeter?

5. Delegation of Authority - Locate on internal website (Find "Offices", click on "NMSS", 

then scroll down to "Important" and click on "Delegation of Authority".)

a. Note the actions that must be signed by the Office Director.

b. Under FCSS, who can approve licensing actions (amendments, reviews, 

renewals, and new applications)?

c. Who can approve travel?

d. What can a Project Manager approve?

6. Ticket Tracking System - Locate on internal website (Find "Offices", click on "NMSS", 

then scroll down and click on "Ticket Status".)

a. Run a report on all open tickets due in the next 30 days. Note the type of actions 

being tracked.

b. Open a ticket. What do the Special Instructions say? Who has the lead? Are 

other people assigned to provide input? When is input due? When is the final 

product due?

7. Read the most recent "Director's Greeting" and "Deputy Director's Corner." Attend 

an NMSS All Hands Meeting.

SUPERVISOR APPROVAL:

Basic = B, Intermediate = I, Comprehensive= C

C NMSS Mission, Goals, and Values 

I Organization and Functions 

B NMSS Office Letters 

B Office Coordinators 

B Delegation of Authority 

B Ticket Tracking System 

B Director Messages and All Hands Meeting 

Initials Date

Initials Date

Initials Date

Initials Date

Initials Date

Initials Date

Initials Date
Issue Date: 10/26/2011 C3-16 1246

Qualification Guide 3

Ethics, Objectivity and Professional Conduct

PURPOSE. The purpose of this activity is to acquaint employees with the NRC’s 

expectations of employee conduct, protocol, and professionalism. Employee conduct is 

a vital component of the NRC’s credibility as an effective regulator. Employees 

represent the Agency in interactions with licensee management and workers, local 

officials, media, and the public. This activity will assist employees to understand NRC 

procedures, policies, and expectations related to Headquarters employee conduct. This 

activity will also help employees enhance their professional conduct that is needed to be 

an effective employee.

 

EVALUATION CRITERIA.

At the completion of this guide you should be able to:

1. Describe the behavior expected of NRC employees at work.

2. Describe what the “appearance of impartiality or impropriety” means.

3. In general, describe the Office of Government Ethics (OGE) standards of ethical 

conduct.

4. Describe the behavior expected when NRC employees interact with other parties.

5. Describe the behavior expected when NRC employees visit other locations.

TASKS.

1. Behavior at Work - Locate ethics information on the internal website. (Under Offices, 

select "OGC," then select "Ethics." Complete the online training if not completed 

already. Review the resource information provided. If the answer cannot be found, 

call one of the OGC contacts listed or consult your supervisor.)

a. With regard to alcohol and illegal drugs?

b. With regard to official business and personal relationships?

c. With regard to business partnerships with licensees?

d. With regard to work habits and professional demeanor?

2. Appearance of Impartiality - Complete the online ethics training described in Task 2. 
Issue Date: 10/26/2011 C3-17 1246

3. OGE Standards of Conduct regarding the following – Complete the online ethics 

training in Task 2:

a. Gifts from outside sources.

b. Gifts between employees.

c. Conflicting financial interests.

d. Seeking other employment.

e. Misuse of power.

f. Outside activities.

4. Interaction with Other Parties – Complete the online ethics training in Task 2. Review 

the NRC Principles of Good Regulation and NMSS Values (Go to public website, 

select “About NRC,” then select “Values”.)

a. Personnel of licensees, vendors or applicants.

b. Other NRC employees.

c. Members of the general public; another resource is the Office of Public Affairs.

d. Public interest groups - Another resource is the Office of Public Affairs.

e. Allegers and concerned citizens - Another resource is the NMSS Allegation 

Coordinator.

5. Conduct at other Locations - Complete the online ethics training in Task 2. Review 

the NRC Principles of Good Regulation and NMSS Values (Go to public website, 

select “About NRC,” then select “Values”.)

a. The site of licensees, vendors or applicants.

b. Headquarters, regional office or training center.

c. Public meetings.

d. Conferences.
Issue Date: 10/26/2011 C3-18 1246

SUPERVISOR APPROVAL:

Basic = B, Intermediate = I, Comprehensive= C

C Behavior at Work

C Appearance of Impartiality

B Standards of Conduct

I Interaction with Other Parties

I Conduct at Other Locations

Initials Date

Initials Date

Initials Date

Initials Date

Initials Date
Issue Date: 10/26/2011 C3-19 1246

Qualification Guide 4

Differing Views and Staff Diversity

PURPOSE. The purpose of the activity is to become familiar with the informal and 

formal processes for pursuing resolution of differing views or opinions and encourage 

diversity in opinion and staff. Our workforce represents diversity in gender, ethnicity, 

occupation, and age, and that diversity makes us stronger. It is the policy of the NRC 

and the responsibility of all NRC supervisory and managerial personnel to maintain a 

working environment that encourages each employee to make known his/her best 

professional judgment even though that judgment may differ from the prevailing staff 

view, disagree with a management decision or policy position or take issue with 

proposed or established agency practices.

EVALUATION CRITERIA.

At the completion of this guide you should be able to:

1. In general, describe the Differing Professional Opinion (DPO) program.

2. Describe the NRC Non-concurrence process.

3. Describe an Open Collaborative Work Environment.

4. Describe the Open Door Policy.

5. Describe the grievance process. 

6. In general, describe how the Agency supports diversity in the staff.

TASKS.

1. DPO Program - Locate MD 10.159, “The NRC Differing Professional Opinions 

Program”. In addition, locate information on Differing Views on the internal website

(Under "Agencywide" select "Employee Resources," scroll down to "Employee 

Concerns" and select "Differing Views".).

a. What is the DPO policy?

b. What are the objectives of the program?

c. In general, how is a DPO submitted?
Issue Date: 10/26/2011 C3-20 1246

2. Non-Concurrence Process - Locate MD 10.158, "NRC Non-Concurrence Process". 

In addition, locate information on Non-Concurrence Process on the internal website 

under Differing Views.

a. What is the NCP policy?

b. What are the objectives of the program?

c. In general, how does the process work?

3. Open Collaborative Work Environment - On the internal website, look under 

Agencywide links and select OCWE.

a. What is an OCWE?

b. What does it mean to be a "Team Player"?

c. Describe the different ways to raise a concern.

4. Open Door Policy - Locate MD 10.160, "Open Door Policy". In addition, locate 

information on the Open Door Policy on the internal website under OCWE.

a. What is the Open Door Policy?

b. What are the objectives of the program?

c. In general, how does the process work?

5. Grievance Process - Locate the Grievance Procedures in the Collective Bargaining 

Agreement (On the internal website, under "Agencywide" select 'Employee 

Resources," scroll down to "Union" and select "Collective Bargaining Agreement." In 

the agreement, go to Article 51 - Grievance Procedures.")

a. What is considered a grievance? 

b. What matters are excluded from the process?

c. Know how to contact the Union office for more information.

6. Diversity - Locate NUREG/BR-0316, “Comprehensive Diversity Management Plan”.

a. What are the goals of the Diversity Management Program?

b. What is the role of an employee in the program?

c. If possible, attend an EEO Commission briefing.
Issue Date: 10/26/2011 C3-21 1246

SUPERVISOR APPROVAL:

Basic = B, Intermediate = I, Comprehensive= C

B DPO Program

B Non-Concurrence Process

C Open Collaborative Work Environment

B Open Door Policy 

B Grievance Process

B Diversity

Initials Date

Initials Date

Initials Date

Initials Date

Initials Date

Initials Date
Issue Date: 10/26/2011 C3-22 1246

Qualification Guide 5

Title 10 of the Code of Federal Regulations

PURPOSE. The Code of Federal Regulations (CFR) provides that licensees and 

certificate holders (Note - the term licensee will be used throughout this document to 

represent both licensees and certificate holders) comply with those Parts of the CFR 

that pertain to the possession, use, storage, disposal and transportation of radioactive 

materials. Fuel facilities are required to develop, document, and implement a material 

control and accounting program commensurate with the scope and extent of licensed 

activities within the plants. For this reason, it is mandatory that all material control and 

accounting (MC&A) license reviewers gain a comprehensive knowledge of the contents 

of relevant MC&A requirements in the CFR. This activity will provide the license 

reviewer with detailed knowledge of the contents of the requirements and how to apply 

the appropriate MC&A regulation requirements.

EVALUATION CRITERIA.

At the completion of this guide you should be able to:

1. Identify, recognize and locate specific MC&A topics presented in 10 CFR Part 74,

and compare and contrast MC&A requirements for the different facility types/safeguards 

categories.

2. Discuss and interpret the contents of 10 CFR Parts 70, 75, and 76.

3. Discuss 10 CFR 2.390.

4. Discuss 10 CFR Parts 30, 40, 71, 72, 73, 95, 110, and 150.

TASKS.

1. 10 CFR Part 74

a. Review Part 74 Subpart A including general performance objectives and 

definitions. 

b. Review Part 74 Subpart B on general reporting and recordkeeping 

requirements. Identify the three primary reports licensees must submit and 

discuss the purpose of each.

c. Review Part 74 Subpart C on the performance objectives and system 

capabilities for Category III facilities. Identify the differences in the 

requirements for Category III fuel fabrication facilities and enrichment 

facilities. 
Issue Date: 10/26/2011 C3-23 1246

d. Review Part 74 Subpart D on the performance objectives and system 

capabilities for Category II facilities. Identify the differences in the 

requirements for Category II facilities and Category III facilities.

e. Review Part 74 Subpart E on the performance objectives and system 

capabilities for Category I facilities. Identify the differences in the graded 

requirements for Category I, II, and III facilities.

2. 10 CFR Parts 70, 75, and 76

a. Review Part 70 on domestic licensing of special nuclear material. Identify 

the sections specific to MC&A.

b. Review Part 75 on implementation of the US/IAEA agreement for the 

application of safeguards in the United States.

c. Review Part 76 on certification of gaseous diffusion plants.

 

3. Review 10 CFR 2.390(d) for the requirement on disclosure of MC&A related 

information

4. Review 10 CFR Parts 30, 40, 71, 72, 73, 95, 110, and 150. Identify any information 

related to MC&A.

SUPERVISOR APPROVAL:

Basic = B, Intermediate = I, Comprehensive= C

C 10 CFR Part 74 

C 10 CFR Parts 70, 75, and 76

C 10 CFR 2.390(d)

B 10 CFR Parts 30, 40, 71, 72, 73, 95, 110, and 150

Initials Date

Initials Date

Initials Date

Initials Date
Issue Date: 10/26/2011 C3-24 1246

Qualification Guide 6

Exploring the Fuel Facility Licensing Program

PURPOSE. The purpose of the activity is to become familiar with the fuel facility 

licensing program and the roles and responsibilities of an MC&A License Reviewer. 

EVALUATION CRITERIA.

At the completion of this guide, you should be able to: 

1. Describe the role of an MC&A license reviewer. 

2. Discuss fundamentals of the licensing process including the role of the project 

manager (PM).

3. Discuss the documents that MC&A license reviewers should maintain and be familiar 

with.

4. Discuss expectations regarding knowledge of the licensee facilities.

5. Discuss the content of 10 CFR 70.32(c) “Conditions of Licenses,” and 70.34 

“Amendment of Licenses.”

TASKS.

1. MC&A License Reviewer Role – Discuss the role of an MC&A license reviewer with a 

qualified reviewer. Identify the various actions that a license reviewer may undertake.

2. Licensing Fundamentals - Review Chapters 1-5 of the Fuel Cycle PM Handbook. 

(On the Internal website, select "Organization," than click on "NMSS," then select 

"Quick Links.") Discuss the licensing process with a qualified PM.

a. Discuss how the PM and license reviewer interact regarding licensing actions.

b. Discuss how the PM and license reviewer interact with licensees.

c. Discuss what contact information the PM uses to communicate with the licensee 

and the Region.

3. Documents – discuss with a qualified MC&A license reviewer the following: 

a. What documents should an MC&A license reviewer maintain in the office? Make 

a list.

b. What is the classification level for each of the documents listed.
Issue Date: 10/26/2011 C3-25 1246

c. Where are the documents kept? How are they protected? 

4. Facility Knowledge.

a. Discuss with a qualified MC&A reviewer the knowledge a license reviewer should 

have of the licensed facilities.

b. Describe how a reviewer maintains unescorted access to a facility. Consult the 

NMSS Radiation Safety Officer if necessary.

c. What information is available to maintain knowledge of a facility’s MC&A program?

5. License Amendments – Review 10 CFR 70.32(c) and 70.34.

a. Discuss with a qualified MC&A license reviewer examples of changes that may 

decrease the effectiveness of a licensee’s MC&A program. What changes 

wouldn’t decrease the effectiveness? When can the changes be implemented?

b. Discuss the types of amendments that would be made under 10 CFR 70.34. 

What types of changes are included? When can these changes be 

implemented?

c. Discuss the types of license exemptions requested by licensees. How is the 

licensing process completed for those requests?

SUPERVISOR APPROVAL:

Basic = B, Intermediate = I, Comprehensive= C

C MC&A License Reviewer Role 

C Licensing Fundamentals

C Documents

C Facility Knowledge

C Amendments 

Initials Date

Initials Date

Initials Date

Initials Date

Initials Date
Issue Date: 10/26/2011 C3-26 1246

Qualification Guide 7

Licensing Actions

PURPOSE. The purpose of the activity is to become familiar with how the MC&A 

license reviewer receives and responds to a licensing action. 

EVALUATION CRITERIA.

At the completion of this guide, you should be able to: 

1. Describe what a Technical Assignment Control (TAC) number is and what it is used 

for.

2. Describe what a Technical Assistance Request (TAR) is and how to respond to a 

TAR.

3. Describe the objective of the Safeguards Evaluation Report.

4. Describe the process for requesting additional information from a licensee.

5. Describe the roles and responsibilities of a PM and their interaction with the license 

reviewer.

6. Describe what an acceptance review is and when it should be completed.

TASKS.

1. TAC Numbers – Discuss with a qualified license reviewer or PM what a TAC number 

is and how it is used in HRMS to charge time spent on a licensing action.

2. Technical Assistance Requests (TARs) - See Chapter 11 of PM Handbook.

a. Review Chapter 11 of the PM Handbook

b. Obtain a TAR from a qualified license reviewer. Identify who sent the TAR, the 

TAC number, deadlines for completing the tasks, and the reason for the request.

c. Discuss with a qualified reviewer the purpose of the TAR acceptance review and 

how one is conducted.

3. Safeguards Evaluation Reports (SERs) - see Chapter 12 of the PM Handbook.

a. What is the purpose of a Safeguards Evaluation Report (SER)? When is an SER 

written?
Issue Date: 10/26/2011 C3-27 1246

b. Why should a draft SER be prepared before additional information is requested?

c. Review an SER for an existing facility and identify the key components of each

section. Discuss your observations with a qualified license reviewer.

d. Review an SER for a new facility license application. Identify the key 

components of each section. Discuss your observations with a qualified license 

reviewer.

4. Request for Additional Information (RAI) - see Chapter 13 of the PM Handbook.

a. Review Chapter 13 of the PM handbook for guidance on how an RAI question 

should be worded.

b. Why must a regulatory requirement be cited?

(i) Is compliance with guidance required? (See the statement at the bottom of 

first page of any final Regulatory Guide.)

(ii) Why is it useful to call a licensee and discuss the requests before they are 

issued?

(iii) What does 2.108(a) say about RAI responses?

c. Review the list of RAIs for an existing facility license amendment. Read the 

corresponding sections of the licensee’s FNMC Plan and identify what triggered 

each RAI question. Discuss your observations with a qualified license reviewer.

d. Review the list of RAIs for a new facility license application. Read the 

corresponding sections of the licensee’s FNMC Plan and identify what triggered 

each RAI question. Discuss your observations with a qualified license reviewer.

5. Discuss with two senior PMs their roles during a licensing action and how they 

interact with an MC&A license reviewer.

6. Acceptance Review – Review the information on acceptance reviews in Section 9.5 

of the PM handbook and discuss with a senior PM.

SUPERVISOR APPROVAL:

Basic = B, Intermediate = I, Comprehensive= C

C TAC Numbers

C Technical Assistance Requests

Initials Date

Initials Date
Issue Date: 10/26/2011 C3-28 1246

C Safeguards Evaluation Reports

C Requests for Additional Information

C Roles/Responsibilities and Interaction with a PM

C Acceptance Reviews

 

Initials Date

Initials Date

Initials Date

Initials Date
Issue Date: 10/26/2011 C3-29 1246

Qualification Guide 8

Interacting with Stakeholders

PURPOSE. The purpose of this activity is to become familiar with procedures for 

interacting with other NRC staff, licensees, and the public.

EVALUATION CRITERIA.

At the completion of this guide you should be able to:

1. Describe how a license reviewer should interact with a licensee.

2. Describe how a license reviewer should interact with other NRC staff.

3. Describe how a license reviewer should interact with the public.

4. Describe how a license reviewer should support a hearing process.

TASKS.

1. Interacting with a Licensee (see Chapters 4 and 5 of the PM Handbook):

a. How does a license reviewer maintain objectivity?

b. How should licensee documents be handled?

c. How should conference calls be used and documented?

2. Interacting with Other NRC Staff:

a. Which areas are inspected by Headquarters staff and which areas are inspected 

by Regional staff?

b. Who are the Project Managers for each fuel facility? (Locate on the internal 

NMSS web site)

c. Review some recent MC&A inspection reports for a fuel facility. Were there any 

violations? Were there any inspection follow-up items? Were there any 

unresolved issues?

d. Review the last License Performance Review (LPR) for a fuel facility. Did it 

identify any areas needing improvement?

3. Interacting with the Public (see Chapters 4 and 5 of the PM Handbook – while the 

Handbook is written for PMs, the guidance is also appropriate for a license reviewer)
Issue Date: 10/26/2011 C3-30 1246

a. Describe how a license reviewer should communicate with the public. What 

should a reviewer strive to do? What should a reviewer refrain from doing?

b. Describe how a public meeting should be conducted. What statements should 

be made? What forms should be provided? How should it be documented?

c. How does a license reviewer handle remarks from a member of the public 

alleging licensee misconduct or problems at the site? (Complete the online 

Allegation training.)

d. What does 10 CFR 2.206 allow a member of the public to request? Describe the 

process for handling these requests.

4. Hearing Process:

a. Review NMSS P&PL 1-86, “NMSS Staff Support of the Hearing Process in 10 

CFR Part 2.”

b. Discuss the pre-hearing process with respect to hearing notices and admissibility 

of intervention petitions.

c. Discuss the hearing process with respect to testimony/exhibits, evidentiary 

hearing and adjudicatory records, and responsibility of the staff to preserve 

documents.

d. Discuss the post-hearing process with respect to board and/or Commission 

decisions.

SUPERVISOR APPROVAL:

Basic = B, Intermediate = I, Comprehensive= C

C Interacting with a Licensee

C Interacting with Other NRC Staff 

C Interacting with the Public 

C Hearing Process 

Initials Date

Initials Date

Initials Date

Initials Date
Issue Date: 10/26/2011 C3-31 1246

Qualification Guide 9

The Inspection Program

PURPOSE. The purpose of this activity is to become familiar with the inspection 

program for fuel cycle facilities.

EVALUATION CRITERIA.

At the completion of this guide you should have a clear understanding of the following:

1. Types of Inspection Manual Documents.

2. NMSS Responsibilities for the Inspection Manual

3. The Fuel Cycle Inspection Program in Manual Chapter (MC) 2600

4. MC&A Inspection Programs

TASKS.

1. Types of Inspection Manual Documents (see Manual Chapter 0040, on the internal 

web site, select Info Resources, scroll down to Key Guidance Documents and select 

Inspection Manual)

a. What information does a Manual Chapter contain? (see definitions in Section 

0040-03 and formats in Section 0040-07)

b. What information does an Inspection Procedure (IP) contain?

c. What information does a Temporary Instruction (TI) contain?

2. NMSS Responsibilities

a. What are the NMSS responsibilities in the inspection manual? (see Section 

0040-04)

b. Who is the current NMSS Inspection Manual Coordinator? (on the internal web 

site, select NMSS, and then select the Contacts and Resources List)

3. Fuel Cycle Inspection Program in MC 2600

a. NSIR is responsible for what part of the inspection program? (see Section 2600-

05)

b. The FCSS/Technical Support Branch is responsible for what part of the 

inspection program?
Issue Date: 10/26/2011 C3-32 1246

c. The FCSS/Material Control and Accounting Branch is responsible for what part of 

the inspection program?

d. In general, describe the inspection program elements. (see Section 2600-07)

e. What is the Master Inspection Plan? (see Section 2600-08)

f. What tools are used to assess facility performance? (see Section 2600-12)

g. Under the Core Inspection Program, what type of fuel facility receives the most 

inspection effort? (see MC 2600, Appendix B)

h. In general, describe the Resident Inspector program. (see MC 2600, Appendix 

C)

i. When planning for an inspection, what input is requested from the 

license/technical reviewer? (see MC 2600, Appendix D)

j. Discuss with an MC&A inspector the outstanding inspection issues and 

resolution actions/activities.

4. MC&A Inspection Programs

a. Review MC 2683 which describes the MC&A inspection program for fuel cycle 

facilities. Discuss the program with a qualified license reviewer or experienced 

MC&A inspector.

b. Review MC 2515 which describes the light-water reactor inspection program –

operations phase. Locate the MC&A portion of the program and review the 

applicable IP for MC&A.

c. Review MC 2561 which describes the decommissioning power reactor inspection 

program. Locate the MC&A portion of the program and review the applicable IP 

for MC&A.

d. Review MC 2545 which describes the research and test reactor inspection 

program. Locate the MC&A portion of the program and review the applicable IP 

for MC&A.

SUPERVISOR APPROVAL:

Basic = B, Intermediate = I, Comprehensive= C

B Types of Inspection Manual Documents

Initials Date
Issue Date: 10/26/2011 C3-33 1246

B NMSS Responsibilities

I Fuel Cycle Inspection Program in MC 2600

I MC&A Inspection Programs

Initials Date

Initials Date

Initials Date
Issue Date: 10/26/2011 C3-34 1246

Qualification Guide 10

MC&A/FNMC Plans

PURPOSE. The NRC requires that licensees develop a Material Control and 

Accounting Plan (formerly Fundamental Nuclear Material Control Plan) describing how 

the performance objectives and system features and capabilities delineated in 10 CFR 

Part 74 will be met. As an MC&A license reviewer, you will be reviewing these plans to 

ensure that they meet the requirements set forth by those regulations. For a new facility, 

you will be reviewing the entire plan. For this reason, it is vital that a MC&A license 

reviewer gain a detailed knowledge of the contents of a licensee’s MC&A/FNMC Plan. 

This guide will provide MC&A license reviewers with the detailed knowledge of the 

contents of an MC&A/FNMC Plan, the location of the applicable information and 

requirements for specific topics, and how to apply the requirements.

EVALUATION CRITERIA.

At the completion of this guide, you should be able to:

1. Identify the applicable sections of Part 74 for facilities designated by your supervisor 

or the person designated as a resource, and discuss the required system capabilities for 

each of those facilities. At least one Category I and one Category III facility should be 

chosen.

2. Identify and discuss the applicable NUREG describing the acceptable MC&A/FNMC 

Plan format for each of the designated facilities.

3. Discuss process/material flow diagrams for the designated facilities.

4. Discuss each facility’s MC&A program as described in the MC&A/FNMC Plan.

TASKS.

1. MC&A Regulations - For each facility designated by your supervisor or qualified 

MC&A license reviewer, identify and review the applicable MC&A regulations in 

10 CFR Part 74. 

2. Acceptable MC&A/FNMC Plan Format - Identify and review the appropriate 

NUREG specifying acceptable MC&A/FNMC Plan format for the facilities

designated in Task 1 above.

3. Facility Process/Material Flow

a. Identify each material process conducted at the selected facilities including: 

chemical/physical form of SNM input to process, chemical/physical changes 

to SNM during processing, and chemical/physical form of output from the 

process. 
Issue Date: 10/26/2011 C3-35 1246

b. Identify sources of input materials (receipts) and destination of process 

outputs (shipments).

4. Facility MC&A/FNMC Plan Review

a. Review the MC&A/FNMC Plan for the facilities and compare the information 

in the Plan to the guidance in the applicable NUREG. 

b. Identify areas where the Plan deviates from the guidance and discuss with a 

knowledgeable MC&A staff member. 

SUPERVISOR APPROVAL:

Basic = B, Intermediate = I, Comprehensive= C

C MC&A Regulations

C Acceptable MC&A/FNMC Plan Format and NUREG Review

C Facility Process/Material Flow

C Facility MC&A/FNMC Plan Review

Initials Date

Initials Date

Initials Date

Initials Date
Issue Date: 10/26/2011 C3-36 1246

Qualification Guide 11

MC&A Management Structure

PURPOSE. The purpose of this guide is to familiarize you with the requirements and 

guidance for a facility MC&A management structure, which includes organization, 

procedures, and training and qualification. An adequate management structure permits 

effective functioning of the MC&A system. Documentation, review and approval of 

procedures eliminate ambiguities about what is to be done and by whom. A training 

and qualification program can help ensure individuals are adequately prepared to 

perform their functions correctly with a minimum of errors. 

EVALUATION CRITERIA.

At the completion of this guide, you should be able to:

1. Discuss the MC&A management structure requirements applicable to each of the 

facility types/safeguards categories.

2. Discuss the elements of an effective MC&A management structure as described in 

guidance documents.

3. Discuss the MC&A management structure for a facility designated by your 

supervisor or person designated as a resource for this activity. 

TASKS.

1. MC&A Management Structure Requirements in 10 CFR Part 74

a. Review the requirements for a licensees MC&A management structure, 

including organizational structure, independence from production 

responsibilities, procedures, and training and qualification, for each facility 

type/safeguards category.

b. Identify the differences in MC&A management structure requirements for 

the different facility types/safeguards categories. 

2. MC&A Management Structure Guidance

a. Review the guidance for implementing an adequate management structure 

for a Category I facility contained in applicable sections of NUREG-1280.

b. Review the guidance for implementing an adequate management structure 

for a Category II facility contained in applicable sections of the Category II 

NUREG.
Issue Date: 10/26/2011 C3-37 1246

b. Review the guidance for implementing an adequate management structure 

for a Category III facility contained in Chapter 1 of NUREG-1065.

c. Compare and contrast the Category III facility guidance with the guidance for 

a Category I and Category II facility.

d. Review the guidance for implementing an adequate management structure 

for a Category III enrichment facility contained in Chapter 1 of NUREG/CR5734.

e. Compare and contrast the Category III enrichment facility guidance with the 

guidance for other Category III facilities.

3. Facility Example - Review the MC&A/FNMC Plan section on MC&A management 

structure for a facility designated by your supervisor or person designated as a 

resource for this activity.

SUPERVISOR APPROVAL:

Basic = B, Intermediate = I, Comprehensive= C

C MC&A Management Structure Requirements

C MC&A Management Structure Guidance

C Facility Example

Initials Date

Initials Date

Initials Date
Issue Date: 10/26/2011 C3-38 1246

Qualification Guide 12

Measurements and Measurement Control

PURPOSE. The purpose of this guide is to familiarize you with the requirements and 

guidance for a licensee’s measurement and measurement control programs. Licensees 

must maintain a system of measurements to ensure that all quantities of SNM in the 

accounting records are based on reliable measurements, and must control the quality of 

measurements to satisfy the capabilities required for loss detection, response, and 

accounting. 

EVALUATION CRITERIA.

At the completion of this guide, you should be able to:

1. Discuss the measurement systems and measurement control requirements

applicable to each of the facility types/safeguards categories.

2. Identify the major categories of MC&A measurements and discuss the specific 

measurement systems used for each of the measurement categories identified. 

3. Discuss the elements of an effective measurements program.

4. Discuss the elements of an effective measurement control program.

5. Discuss measurement error variance estimates.

6. Discuss the MC&A measurements and measurement control program for a 

facility designated by your supervisor or person designated as a resource for this 

activity.

TASKS.

1. Measurements and Measurement Control Requirements in 10 CFR Part 74

a. Review the requirements for measurement systems and measurement 

control for each facility type/safeguards category.

b. Identify the differences in requirements for the different facility 

types/safeguards categories.

2. MC&A Measurement Systems - Read Appendix 13B, Measurement Systems, of 

NUREG/CR-4604. Be prepared to discuss the major categories of MC&A 

measurements and the specific measurement systems used for each of the 

measurement categories identified.
Issue Date: 10/26/2011 C3-39 1246

3. Measurement Systems Guidance - Review the acceptable elements of a 

measurements program for the following:

a. Category I facility, as described in Chapter 5 of NUREG-1280.

b. Category II facility, as described in Chapter 2 of the Category II NUREG.

c. Category III facility, as described in Chapter 2 of NUREG-1065.

d. Category III enrichment facility, as described in Chapter 2 of NUREG/CR5734.

4. Measurement Control Program Guidance - Review the acceptable elements of a 

measurement control program for the following:

a. Category I facility, as described in Chapter 6 of NUREG-1280.

b. Category II facility, as described in Chapter 3 of the Category II NUREG.

c. Category III facility, as described in Chapter 3 of NUREG-1065.

d. Category III enrichment facility, as described in Chapter 3 of NUREG/CR5734.

5. Measurement Error Variances - Review Chapter 3, Sources of Uncertainty in 

Nuclear Materials Control, of TID-26298. Be prepared to discuss random and 

systematic measurement error variance estimates.

6. Facility Example – Review the MC&A/FNMC Plan section on measurements and 

measurement control for a facility designated by your supervisor or person 

designated as a resource for this activity.

SUPERVISOR APPROVAL:

Basic = B, Intermediate = I, Comprehensive= C

C Measurements and Measurement Control Requirements

C MC&A Measurement Systems

C Measurement Systems Guidance

C Measurement Control Program Guidance

C Measurement Error Variances

C Facility Example

Initials Date

Initials Date

Initials Date

Initials Date

Initials Date

Initials Date
Issue Date: 10/26/2011 C3-40 1246

Qualification Guide 13

Item Control and Item Monitoring

PURPOSE. The purpose of this guide is to familiarize you with the requirements and 

guidance for a licensee’s item control/item monitoring program. For all facilities, the 

licensee must implement item control procedures that protect against unauthorized and 

unrecorded removal of items, or of material from items, and enable timely location of 

items. 

EVALUATION CRITERIA.

At the completion of this guide, you should be able to:

1. Discuss the item control/item monitoring requirements and guidance for a 

Category I facility.

2. Discuss the item control requirements and guidance for a Category II facility. 

3. Discuss the item control requirements and guidance for a Category III facility.

4. Discuss differences in item control/item monitoring for the different facility 

types/safeguards categories. 

TASKS.

1. Item Control/Monitoring for a Cat I facility

a. Review the item monitoring requirements for a Category I facility as 

specified in 10 CFR 74.55.

b. Review the acceptable elements of an item monitoring program as 

described in Chapter 2 of NUREG-1280.

c. Review the MC&A/FNMC Plan section on item monitoring for a Category I 

facility designated by your supervisor or person designated as a resource 

for this activity.

2. Item Control/Monitoring for a Cat II facility

a. Review the item monitoring requirements for a Category II facility as 

specified in 10 CFR 74.43.

b. Review the acceptable elements of an item control/monitoring program as 

described in Chapter 2 of the Category II NUREG.
Issue Date: 10/26/2011 C3-41 1246

c. Review the MC&A/FNMC Plan section on item monitoring for a Category I 

facility designated by your supervisor or person designated as a resource 

for this activity.

3. Item Control/Monitoring for a Category III facility

a. Review the item control requirements for a Category III facility as specified 

in 10 CFR 74.31 and 10 CFR 74.33.

b. Review the acceptable elements of an item control program for a Category 

III facility, as described in Chapter 6 of NUREG-1065, and for a Category 

III enrichment facility, as described in Chapter 6 of NUREG/CR-5734.

c. Review the MC&A/FNMC Plan section on item control/monitoring for a 

Category III facility designated by your supervisor or person designated as a 

resource for this activity.

4. Facility Comparison – Compare and contrast the item control/monitoring 

requirements and guidance for the different facility types/safeguards categories, 

in particular the regulatory requirement differences between a Category I facility 

and any other facility category.

SUPERVISOR APPROVAL:

Basic = B, Intermediate = I, Comprehensive= C

C Item Control/Monitoring for a Category I Facility

C Item Control/Monitoring for a Category II Facility

C Item Control/Monitoring for a Category III Facility

C Facility Comparison

Initials Date

Initials Date

Initials Date

Initials Date
Issue Date: 10/26/2011 C3-42 1246

Qualification Guide 14

Physical Inventory

PURPOSE. The purpose of this guide is to familiarize you with the requirements and 

guidance for conducting a physical inventory. Periodic physical inventories enable a 

licensee to adjust accounts to accurately reflect the status of the inventory. For 

Category I facilities, comparisons of the book inventory to the physical inventory serve 

as a quality control check on the performance of the material control tests employed for 

prompt loss detection. For Category II and Category III facilities, annual physical 

inventories are performed to confirm that a loss or diversion of a significant quantity of 

SNM has not occurred. 

EVALUATION CRITERIA.

At the completion of this guide, you should be able to:

1. Discuss the physical inventory requirements and guidance for a Category I 

facility.

2. Discuss the physical inventory requirements and guidance for a Category II 

facility.

 

3. Discuss the physical inventory requirements and guidance for a Category III 

facility.

4. Discuss limits of error and the standard error of the inventory difference.

5. Discuss the results of an inventory as reported on NRC Form 327.

6. Discuss any differences in physical inventory requirements and/or guidance for 

the different facility types/safeguards categories. 

TASKS.

1. Physical Inventory for a Category I facility

a. Review the physical inventory requirements for a Category I facility as 

specified in 10 CFR 74.59.

b. Review the acceptable elements for conducting a physical inventory for a 

Category I facility as described in Chapter 8 of NUREG-1280:

(i) Facility Preparation.

(ii) Inventory Performance.
Issue Date: 10/26/2011 C3-43 1246

(iii) Inventory Reconciliation.

(iv) Standard Error of the Inventory Difference Estimator.

c. Review the MC&A/FNMC Plan section on physical inventory for a 

Category I facility designated by your supervisor or person designated as 

a resource for this activity.

2. Physical Inventory for a Category II facility

a. Review the physical inventory requirements for a Category II facility as 

specified in 10 CFR 74.43.

b. Review the acceptable elements for conducting a physical inventory for a 

Category II facility as described in Chapter 5 of the Category II NUREG:

(i) Facility Preparation.

(ii) Inventory Performance.

(iii) Inventory Reconciliation.

(iv) Standard Error of the Inventory Difference Estimator.

c. Review the MC&A/FNMC Plan section on physical inventory for a 

Category II facility designated by your supervisor or person designated as 

a resource for this activity.

3. Physical Inventory for Category III facilities

a. Review the physical inventory requirements for a Category III facility as 

specified in 10 CFR 74.31, and for a Category III enrichment facility as 

specified in Section 74.33. What are the differences? What are the 

similarities?

b. Review the acceptable elements for conducting a physical inventory for a 

Category III facility as described in NUREG-1065:

(i) Chapter 5, Physical Inventories.

(ii) Determination of SEID.

(iii) Bias Corrections.

c. Review the acceptable elements for conducting a physical inventory for a 

Category III enrichment facility as described in NUREG/CR-5734:
Issue Date: 10/26/2011 C3-44 1246

(i) Chapter 5, Physical Inventories.

(ii) Determination of SEID.

d. Review the MC&A/FNMC Plan section on physical inventory for a 

Category III facility designated by your supervisor or person designated as 

a resource for this activity.

4. Review Chapters 4, 5, and 6 in TID-26298 for a general discussion of limits of 

error and calculating the standard error of the inventory difference (SEID).

5. Review the inventory reporting requirements in 10 CFR 74.17 and NUREG/BR0096 for instructions and guidance for completing NRC Form 327. Be prepared 

to discuss the various items that are reported on the form.

6. Facility Comparison – Compare and contrast the physical inventory requirements 

and guidance for the different facility types/safeguards categories.

SUPERVISOR APPROVAL:

Basic = B, Intermediate = I, Comprehensive= C

C Physical Inventory for a Category I Facility

C Physical Inventory for a Category II Facility

C Physical Inventory for Category III Facilities

C Limit of Error and SEID

C NRC Form 327 and NURG/BR-0096

C Facility Comparison

Initials Date

Initials Date

Initials Date

Initials Date

Initials Date

Initials Date
Issue Date: 10/26/2011 C3-45 1246

Qualification Guide 15

Process Monitoring

PURPOSE. The purpose of this guide is to familiarize you with the requirements and 

guidance for a licensee’s process monitoring program. For Category I facilities, 

licensees must have a quality control program that will provide early indications of 

diversion or theft and a prompt detection system for significant abrupt diversions of five 

formula kilograms or more. 

EVALUATION CRITERIA.

At the completion of this guide, you should be able to:

1. Discuss the process monitoring requirements.

2. Discuss the elements of an effective process monitoring program. 

3. Discuss the process monitoring program for a facility designated by your 

supervisor or person designated as a resource for this activity.

TASKS.

1. Review the process monitoring requirements for a Category I facility as specified 

in 10 CFR 74.53.

2. Review the acceptable elements of a process monitoring program as described 

in Chapter 1 of NUREG-1280:

a. Process Subdivision and Measurement Points.

b. Material Control Tests.

c. Location Categorization and Material Substitution.

d. Exemptions.

e. Trend Analysis.

3. Facility Example – Review the MC&A/FNMC Plan section on process monitoring 

for a facility designated by your supervisor or person designated as a resource 

for this activity.
Issue Date: 10/26/2011 C3-46 1246

SUPERVISOR APPROVAL:

Basic = B, Intermediate = I, Comprehensive= C

C Process Monitoring Requirements

C Process Monitoring Guidance

C Facility Example

Initials Date

Initials Date

Initials Date
Issue Date: 10/26/2011 C3-47 1246

Qualification Guide 16

Detection of Unauthorized Production

PURPOSE. The purpose of this guide is to familiarize you with the requirements and 

guidance for an enrichment facility’s program to protect against and detect unauthorized 

production of enriched uranium. 

EVALUATION CRITERIA.

At the completion of this guide, you should be able to:

1. Discuss the requirements pertaining to precluding and detecting unauthorized 

production of enriched uranium.

2. Discuss the elements of an effective detection program.

3. Discuss the program for detection of unauthorized production for a facility 

designated by your supervisor or person designated as a resource for this 

activity.

TASKS.

1. Review the detection program requirements for an enrichment facility as 

specified in 10 CFR 74.33.

2. Review the guidance for an acceptable detection program as described in 

Chapter 9 of NUREG/CR-5734:

a. Organization.

b. General Description of Program.

c. Data, Information, and Activities to be Monitored.

d. Reporting and Documentation Requirements.

3. Facility Example – Review the MC&A/FNMC Plan section on detection of 

unauthorized production for a facility designated by your supervisor or person 

designated as a resource for this activity.

SUPERVISOR APPROVAL:

Basic = B, Intermediate = I, Comprehensive= C

C Detection of Unauthorized Production Requirements

Initials Date
Issue Date: 10/26/2011 C3-48 1246

C Detection Of Unauthorized Production Guidance

C Facility Example

Initials Date

Initials Date
Issue Date: 10/26/2011 C3-49 1246

Qualification Guide 17

Resolution Program

PURPOSE. The purpose of this guide is to familiarize you with the requirements and 

guidance for resolving an indicator of potential loss of nuclear material. For Category I 

facilities, the resolution program must be able to respond promptly to process and item 

monitoring alarms and determine whether the alarm was caused by an actual loss or by 

a system error. For all facilities, the licensee must investigate and resolve indicators of 

potential loss including significant shipper-receiver differences (SRDs), excessive 

inventory differences (IDs), and item control discrepancies. For enrichment facilities, 

indicators of unauthorized production must also be investigated and resolved. 

EVALUATION CRITERIA.

At the completion of this guide, you should be able to:

1. Discuss the resolution program requirements and guidance for Category I 

facilities.

2. Discuss the resolution program requirements and guidance for Category II 

facilities.

3. Discuss the resolution program requirements and guidance for Category III 

facilities.

 

4. Discuss the resolution program requirements and guidance for Category III

enrichment facilities.

5. Discuss any differences in resolution program requirements and/or guidance for 

the different facility types/safeguards categories. 

TASKS.

1. Resolution Program for a Category I facility

a. Review the alarm resolution requirements for a Category I facility as 

specified in 10 CFR 74.57.

b. Review the requirements for resolution of excessive IDs and significant 

SRDs for Category I facilities as specified in 10 CFR 74.59(f) and (h).

c. Review the guidance for development of MC&A alarm resolution 

procedures in NUREG/CR-4108.

d. Review the acceptable elements for resolving alarm indicators for a 

Category I facility as described in NUREG-1280.
Issue Date: 10/26/2011 C3-50 1246

e. Review the acceptable elements for resolving excessive IDs and 

significant SRDs for a Category I facility as described in NUREG-1280:

(i) Inventory Reconciliation.

(ii) Shipper-Receiver Differences.

f. Review, for a particular Category I facility, the MC&A/FNMC Plan sections 

on alarm resolution, resolving excessive IDs and resolving significant 

SRDs.

2. Resolution Program for a Category II facility

a. Review the requirements for resolving excessive IDs and significant SRDs 

for a Category II facility as specified in 10 CFR 74.43.

b. Review the guidance for resolving excessive IDs, significant SRDs, and 

item control discrepancies for a Category II facility as described in the 

Category II NUREG:

(i) Inventory Difference Limits and Response Actions.

(ii) Shipper-Receiver Comparisons.

(iii) Investigation and Resolution of Item Discrepancies.

(iv) Resolving Indications of Missing Uranium.

c. Review, for a particular Category II facility, the MC&A/FNMC Plan sections 

on resolving excessive IDs, significant SRDs, and item control 

discrepancies.

3. Resolution Program for a Category III facility

a. Review the requirements for resolving excessive IDs and significant SRDs 

for a Category III facility as specified in 10 CFR 74.31.

b. Review the guidance for resolving excessive IDs, significant SRDs, and 

item control discrepancies for a Category III facility as described in 

NUREG-1065:

(i) Inventory Difference Limits and Response Actions.

(ii) Shipper-Receiver Comparisons.
Issue Date: 10/26/2011 C3-51 1246

(iii) Investigation and Resolution of Item Discrepancies.

(iv) Resolving Indications of Missing Uranium.

c. Review, for a particular Category III facility, the MC&A/FNMC Plan 

sections on resolving excessive IDs, significant SRDs, and item control 

discrepancies.

4. Resolution Program for a Category III enrichment facility

a. Review the requirements for resolving excessive IDs, significant SRDs, 

and indications of unauthorized production for a Category III enrichment 

facility as specified in 10 CFR 74.33.

b. Review the guidance for resolving excessive IDs, significant SRDs, item 

control discrepancies, and indicators of unauthorized production for a 

Category III enrichment facility as described in NUREG/CR-5734:

(i) Inventory Difference Limits and Response Actions.

(ii) Shipper-Receiver Comparisons.

(iii) Investigation and Resolution of Item Discrepancies.

(iv) Resolving Indications of Missing Uranium and of Unauthorized 

Production of Enriched Uranium.

c. Review, for a particular Category III enrichment facility, the MC&A/FNMC 

Plan sections on resolving excessive IDs, significant SRDs, item control 

discrepancies, and indicators of unauthorized production.

5. Facility Comparison – Compare and contrast the resolution program 

requirements and guidance for the different facility types/safeguards categories.

 

SUPERVISOR APPROVAL:

Basic = B, Intermediate = I, Comprehensive= C

C Resolution Program for a Category I Facility

C Resolution Program for a Category II Facility

C Resolution Program for a Category III Facility

C Resolution Program for a Category II Enrichment Facility

C Facility Comparison

Initials Date

Initials Date

Initials Date

Initials Date

Initials Date
Issue Date: 10/26/2011 C3-52 1246

Qualification Guide 18

Recordkeeping/Independent Assessments

PURPOSE. The purpose of this guide is to familiarize you with the requirements and 

guidance for a facility’s recordkeeping system and for performance of independent 

assessments of the MC&A program. The licensee must have an auditable records 

system that contains sufficient information to facilitate further review, audits, and 

inspections to demonstrate that all MC&A/FNMC Plan commitments have been met. An 

independent assessment of the MC&A program enables the licensee to evaluate the 

overall effectiveness of the MC&A program relative to the performance objectives and 

system capabilities specified in the regulations. 

EVALUATION CRITERIA.

At the completion of this guide, you should be able to:

1. Discuss the recordkeeping requirements and guidance for the different facility 

types/safeguards categories.

2. Discuss the independent assessment requirements and guidance for the different 

facility types/safeguards categories.

3. Discuss the requirements for preparing and distributing Nuclear Material 

Transaction Reports and Material Status Reports.

TASKS.

1. Recordkeeping

a. Review the recordkeeping requirements for the different facility 

types/safeguards categories as specified in 10 CFR Part 74.

b. Identify any differences in recordkeeping requirements for the different 

facility types/safeguards categories. 

c. Review the guidance for implementing an adequate recordkeeping system 

for the following:

(i) Category I facility, contained in NUREG-1280.

(ii) Category II facility, contained in the Category II NUREG.

(iii) Category III facility, contained in NUREG-1065.

(iv) Category III enrichment facility, contained in NUREG/CR-5734.
Issue Date: 10/26/2011 C3-53 1246

d. Compare the recordkeeping requirements specified in 10 CFR Part 74 

with requirements in 10 CFR Part 75.

2. Independent Assessments

a. Review the requirements for conducting an independent assessment of 

the MC&A program for the different facility types/safeguards categories as 

specified in 10 CFR Part 74.

b. Identify any differences in the requirements for conducting the assessment 

for the different facility types/safeguards categories. 

c. Review the guidance for conducting an independent assessment of the 

MC&A program for the following:

(i) Category I facility, contained in NUREG-1280.

(ii) Category I facility, contained in the Category II NUREG.

(iii) Category III facility, contained in NUREG-1065.

(iv) Category III enrichment facility, contained in NUREG/CR-5734.

3. Material Status Reports and Nuclear Material Transaction Reports 

a. Review the requirements for preparing and distributing Material Status 

Reports and Nuclear Material Transaction Reports as specified in 10 CFR 

74.13 and 74.15.

b. Review the guidance for preparing and distributing Material Status 

Reports and Nuclear Material Transaction Reports contained in 

NUREG/BR-0007 and NUREG/BR-0006.

SUPERVISOR APPROVAL:

Basic = B, Intermediate = I, Comprehensive= C

C Recordkeeping

C Independent Assessments

C Material Status and Nuclear Material Transaction Reports

Initials Date

Initials Date

Initials Date
Issue Date: 10/26/2011 C3-54 1246

Qualification Guide 19

On The Job Training

PURPOSE. The purpose of this activity is to work with an experienced MC&A license 

reviewer to apply the knowledge gained from this qualification journal to actions 

associated with reference facilities.

EVALUATION CRITERIA.

1. Site Visits

2. TARs and Acceptance Reviews

3. Requesting Additional Information

4. Safeguards Evaluation Reports

5. Amendment Requests – 10 CFR 70.32 and 70.34

TASKS.

1. Site Visits

a. Arrange a visit to either one Category I facility, or enrichment facility, or Category 

III fuel fabrication facility.

b. Process a Form 277 to transfer your security clearance to the site, if necessary.

c. Obtain an NRC dosimeter.

d. Review the facility MC&A/FNMC Plan.

e. Visit the site.

f. Discuss the visit with a qualified MC&A license reviewer after the visit.

2. TARs and Acceptance Reviews – Work with a qualified MC&A license reviewer to 

complete the following tasks:

a. Review a new TAR. Identify who sent the TAR, the TAC number, 

deadlines for completing the tasks, and the reason for the request. 

b. Discuss the information with a license reviewer. Describe how you would 

proceed with the TAR.
Issue Date: 10/26/2011 C3-55 1246

c. Review a licensing action and determine if acceptable, and review the 

basis for acceptability with a qualified license reviewer.

3. Requesting Additional Information – Work with a qualified MC&A license reviewer to 

complete the following tasks:

a. Review a new license application for RAIs and develop the RAIs if 

applicable. Discuss the RAIs with the license reviewer.

b. If there are no current new applications being reviewed, obtain an original 

version of the application for a currently licensed facility and compare 

RAIs you develop with the RAIs sent to the licensee.

c. Review an amendment request for RAIs and develop the RAIs if 

applicable. Discuss the RAIs with the license reviewer.

4. Safeguards Evaluation Reports – Work with a qualified MC&A license reviewer to 

complete the following tasks:

a. Develop an SER for a license amendment request. Review and discuss 

the SER with the license reviewer.

b. Repeat 4.a. above as needed to ensure understanding of SER 

development.

5. Amendment Requests – Work with a qualified MC&A license reviewer to complete 

the following tasks:

a. Review a license amendment request submitted under 10 CFR 70.32(c). 

Identify the changes that were made and why they are allowed under 10 

CFR 70.32(c). 

b. Review a license amendment request submitted under 10 CFR 70.34. 

Which changes required the amendment be made under 70.34? Were 

there any changes that could have been made under 70.32(c) (had they 

been submitted separately)?

c. If possible, review a license exemption request. Work with the license 

reviewer and the facility Project Manager to complete the task.

SUPERVISOR APPROVAL:

Basic = B, Intermediate = I, Comprehensive= C

C Site Visits

Date Initials
Issue Date: 10/26/2011 C3-56 1246

C TARs and Acceptance Reviews

C Requesting Additional Information

C Safeguards Evaluation Reports

C Amendment Requests

Initials Date

Initials Date

Initials Date

Initials Date
Issue Date: 10/26/2011 C3-57 1246

Qualification Guide 20

Specialized Training

PURPOSE. The purpose of this activity is to complete formal classes which teach skills 

and knowledge important to MC&A license reviewer functions.

EVALUATION CRITERIA.

1. Site Access Training

2. Fuel Cycle Processes

3. Regulatory Process

4. Communications

5. Basic MC&A Training

6. Additional Post Qualification MC&A Training

TASKS.

1. Site Access Training – Complete H100 or H101

2. Fuel Cycle Processes – Complete F201 or F201S

3. Regulatory Process 

4. Communications – Complete at least one of the following classes:

a. Technical Writing

b. Conducting Effective Public Meetings

c. Media Training Workshop

5. Basic MC&A Training – Complete basic MC&A training as needed based on 

experience in consultation with Branch Chief:

Note: An asterisk (*) indicates the training is available through the DOE National 

Training Center (NTC). See the website http://ntc.doe.gov. The preferred method for 

completing the training is through the classroom version at the NTC. If not available 

in a timely manner, the class may be taken self-study using material on the MC&A 

Branch Sharepoint site working with a qualified MC&A reviewer or inspector.

a. *MCA-101DC - Introduction to Nuclear Material Control & Accounting (DOE NTC)
Issue Date: 10/26/2011 C3-58 1246

b. Measurement of Nuclear Material (self-study)

c. *MCA-110 – Basics of Nuclear Materials Accountability (DOE NTC or self-study)

d. *MCA-120 – Basics of Nuclear Materials Control (DOE NTC or self-study)

e. *MCA-130 – Statistical Concepts in MC&A (DOE NTC or self-study)

6. Additional Post Qualification MC&A Training – Complete post qualification MC&A 

training as needed based on experience in consultation with Branch Chief:

Note: An asterisk (*) indicates the training is available through the DOE National 

Training Center (NTC). See note above.

The “Fundamentals of Nondestructive Assay” and “Statistical Concepts in Nuclear 

Safeguards” courses are taught at Los Alamos National Laboratory (LANL). See the 

LANL website for information about these courses.

a. *MCA-260 – Physical Inventories for MC&A (DOE NTC or self-study)

b. Fundamentals of Nondestructive Assay (LANL)

c. Statistical Concepts in Nuclear Safeguards (LANL)

SUPERVISOR APPROVAL:

Basic = B, Intermediate = I, Comprehensive= C

C Site Access Training

C Fuel Cycle Processes

C Regulatory Process

I Communications

C Basic MC&A Training

C Additional Post Qualification MC&A Training

Initials Date

Initials Date

Initials Date

Initials Date

Initials Date

Initials Date
Issue Date: 10/26/2011 C3-1 1246

Attachment 1

Revision History for IMC 1246, Appendix C3

Commitment 

Tracking 

Number

Issue Date Description of Change Training 

Needed

Training 

Completion 

Date

Comment 

Resolution 

Accession Number

n/a 10/26/2011 Added new Qualification Journal for material 

control and accounting license reviewer. No n/a n/a