Acceptable Standard Format 

and Content for the Material 

Control and Accounting 

Plan Required for Special 

Nuclear Material of Low

Strategic Significance

Draft Report for Comment

Office of Nuclear Material Safety and Safeguards

NUREG-1065

Revision 3
NRC Reference Material 

As of November 1999, you may electronically access 

NUREG-series publications and other NRC records at 

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http://www.nrc.gov/reading-rm.html. Publicly released 

records include, to name a few, NUREG-series 

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NRC publications in the NUREG series, NRC 

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IN NRC PUBLICATIONS

Legally binding regulatory requirements are stated only 

in laws; NRC regulations; licenses, including technical 

specifications; or orders, not in NUREG-series 

publications. The views expressed in contractorprepared publications in this series are not necessarily 

those of the NRC.

The NUREG series comprises (1) technical and 

administrative reports and books prepared by the staff 

(NUREG–XXXX) or agency contractors (NUREG/CR–

XXXX), (2) proceedings of conferences (NUREG/CP–

XXXX), (3) reports resulting from international 

agreements (NUREG/IA–XXXX), (4) brochures 

(NUREG/BR–XXXX), and (5) compilations of legal 

decisions and orders of the Commission and Atomic and 

Safety Licensing Boards and of Directors’ decisions

under Section 2.206 of NRC’s regulations (NUREG–

0750).

DISCLAIMER: This report was prepared as an account 

of work sponsored by an agency of the U.S. 

Government. Neither the U.S. Government nor any 

agency thereof, nor any employee, makes any warranty, 

expressed or implied, or assumes any legal liability or 

responsibility for any third party’s use, or the results of 

such use, of any information, apparatus, product, or 

process disclosed in this publication, or represents that 

its use by such third party would not infringe privately 

owned rights.
Acceptable Standard Format 

and Content for the Material 

Control and Accounting 

Plan Required for Special 

Nuclear Material of Low 

Strategic Significance

Draft Report for Comment

Manuscript Completed: June 2013 

Date Published: September 2013

Office of Nuclear Material Safety and Safeguards

NUREG-1065

Revision 3
COMMENTS ON DRAFT REPORT

Any interested party may submit comments on this report for consideration by the NRC staff. 

Comments may be accompanied by additional relevant information or supporting data. Please 

specify the report number NUREG-1065 in your comments, and send them by the end of the 

comment period specified in the Federal Register notice announcing the availability of this 

report. 

Addresses: You may submit comments by any one of the following methods. Please include 

Docket ID NRC-2013-0195 in the subject line of your comments. Comments submitted in 

writing or in electronic form will be posted on the NRC website and on the Federal rulemaking 

website http://www.regulations.gov. 

Federal Rulemaking Website: Go to http://www.regulations.gov and search for documents 

filed under Docket ID NRC-2013-0195. Address questions about NRC dockets to Carol 

Gallagher at 301-287-3422 or by e-mail at Carol.Gallagher@nrc.gov.

Mail comments to: Cindy Bladey, Chief, Rules, Announcements, and Directives Branch

(RADB), Division of Administrative Services, Office of Administration, Mail Stop: 3WFN-06-A44, 

U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001. 

For any questions about the material in this report, please contact: Tom Pham, Senior 

Safeguards Analyst, at 301-287-9132 or by e-mail at Tom.Pham@nrc.gov.

Please be aware that any comments that you submit to the NRC will be considered a public 

record and entered into the Agencywide Documents Access and Management System 

(ADAMS). Do not provide information you would not want to be publicly available.
iii NUREG-1065, Revision 3

ABSTRACT

This document provides a revised structure for NUREG-1065, Revision 2, dated 1995, which 

contains information that the licensee or applicant should provide in its material control and 

accounting (MC&A) plan, formerly the fundamental nuclear material control (FNMC) plan. It 

applies to U.S. Nuclear Regulatory Commission (NRC) licensees (other than production or 

utilization facilities licensed in accordance with 10 CFR Part 50, “Domestic Licensing of 

Production and Utilization Facilities,” or 10 CFR Part 52, “Licenses, Certifications, and 

Approvals for Nuclear Power Plants,” and waste disposal facilities) authorized to possess and 

use more than 350 grams of unencapsulated special nuclear material (SNM) of low strategic 

significance. The revision has been structured to serve as a direct outline for licensees to use in 

preparing their MC&A plans.

This document provides a revised structure and information to facilitate compliance with 

10 CFR 74.3, “General performance objectives,” and 10 CFR 74.31, “Nuclear Material Control 

and Accounting for Special Nuclear Material of Low Strategic Significance,” regarding the 

licensee or applicant preparation and implementation of MC&A plans and corresponding NRC 

review and inspection. Presented herein is the acceptable format and content for those MC&A

plans, addressing (1) the performance objectives that must be met, (2) the MC&A program 

capabilities that must be achieved to meet those objectives, (3) the incorporation of checks and 

balances to detect falsification of data and reports that could conceal the theft or diversion of 

SNM, and (4) basic commitments that should be made.

This document includes guidance for implementing new requirements pertaining to

tamper-safing, and the designation of material balance areas and item control areas. All other 

modifications involve format and editorial changes designed to clarify and facilitate preparation 

or revision of the required MC&A plan. 

v NUREG-1065, Revision 3

CONTENTS

ABSTRACT...............................................................................................................................iii

CONTENTS............................................................................................................................... v

ABBREVIATIONS .....................................................................................................................ix

1. INTRODUCTION................................................................................................................... 1

2. GENERAL PERFORMANCE OBJECTIVES, RELATED REQUIREMENTS,

COMMITMENTS, AND ACCEPTANCE CRITERIA.............................................................. 3

3. MANAGEMENT STRUCTURE ............................................................................................. 7

3.0 Regulatory Intent ............................................................................................................. 7

3.1 Corporate Organization ................................................................................................... 7

3.2 Plant or Site Organization................................................................................................ 7

3.3 MC&A Organization......................................................................................................... 7

3.3.1 Responsibilities and Authority ................................................................................... 8

3.3.2 MC&A Procedures .................................................................................................... 9

3.4 Training and Qualification Requirements ........................................................................10

3.5 MC&A Program Description............................................................................................10

3.6 Material Control Boundaries ...........................................................................................11

3.7 Commitments and Acceptance Criteria...........................................................................11

4. MEASUREMENTS...............................................................................................................13

4.0 Regulatory Intent ............................................................................................................13

4.1 Measurement Points.......................................................................................................13

4.2 Measurement Systems...................................................................................................13

4.2.1 Bulk Measurement Systems.....................................................................................14

4.2.2 Analytical Measurement Systems ............................................................................14

4.2.3 NDA Measurement Systems ....................................................................................15

4.2.4 Other Measurement Systems...................................................................................15

4.3 Measurement Uncertainties............................................................................................15

4.4 Measurement Procedures ..............................................................................................15

4.5 Commitments and Acceptance Criteria...........................................................................16

5. MEASUREMENT CONTROL SYSTEM ...............................................................................19

5.0 Regulatory Intent ............................................................................................................19

5.1 Organization and Management.......................................................................................19

5.1.1 Functional Relationships ..........................................................................................19

5.1.2 Procedures...............................................................................................................19

5.1.3 Contractor Program Audits and Reviews..................................................................20

5.2 Calibrations ....................................................................................................................20

5.3 Control Standards...........................................................................................................22

5.4 Replicate Sampling.........................................................................................................23

5.5 Control Limits .................................................................................................................24

5.5.1 Measurement Control Data Analysis ........................................................................24

5.5.2 Response Actions ....................................................................................................25

5.6 Commitments and Acceptance Criteria...........................................................................26
NUREG-1065, Revision 3 vi

6. STATISTICS........................................................................................................................29

6.0 Regulatory Intent ............................................................................................................29

6.1 Determination of Measurement Uncertainties .................................................................29

6.2 Determination of Standard Error of the Inventory Difference...........................................30

6.3 Bias Corrections .............................................................................................................31

7. PHYSICAL INVENTORIES..................................................................................................33

7.0 Regulatory Intent ............................................................................................................33

7.1 General Description........................................................................................................33

7.2 Organization, Procedures, and Schedules......................................................................33

7.3 Typical Inventory Composition........................................................................................34

7.4 Description of Typical Item Strata ...................................................................................34

7.5 Conducting Physical Inventories.....................................................................................34

7.6 Inventory Difference Limits and Response Actions .........................................................37

7.7 Commitments and Acceptance Criteria...........................................................................38

8. ITEM CONTROL..................................................................................................................41

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

8.1 Organization ...................................................................................................................41

8.2 General Description........................................................................................................41

8.3 Item Identity Controls......................................................................................................42

8.4 Storage Controls.............................................................................................................42

8.5 Item Monitoring Methodology and Procedures................................................................42

8.6 Investigation and Resolution of Item Discrepancies........................................................43

8.7 Commitments and Acceptance Criteria...........................................................................43

9. SHIPPER-RECEIVER COMPARISONS ..............................................................................45

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

9.1 Receiving Procedures.....................................................................................................45

9.2 Determination of Receiver’s Values ................................................................................46

9.3 Evaluation of Shipper-Receiver Differences....................................................................46

9.4 Resolution of Significant Shipper-Receiver Differences ..................................................47

9.5 Commitments and Acceptance Criteria...........................................................................47

10. ASSESSMENT AND REVIEW OF THE MATERIAL CONTROL AND ACCOUNTING 

 PROGRAM.........................................................................................................................49

10.0 Regulatory Intent ..........................................................................................................49

10.1 General Description......................................................................................................49

10.2 Report of Findings and Recommendations ...................................................................50

10.3 Management Review and Response to Report Findings and Recommendations .........51

10.4 Commitments and Acceptance Criteria.........................................................................51

11. TAMPER-SAFING .............................................................................................................55

11.0 Regulatory Intent ..........................................................................................................55

11.1 Characteristics of Tamper-safing Devices.....................................................................55

11.2 Use of Tamper-safing Devices......................................................................................56

11.3 Description of Tamper-safing Records..........................................................................56

11.4 Commitments and Acceptance Criteria.........................................................................57
vii NUREG-1065, Revision 3

12. DESIGNATION OF MATERIAL BALANCE AREAS, ITEM CONTROL AREAS, 

 AND CUSTODIANS ..........................................................................................................59

12.0 Regulatory Intent ..........................................................................................................59

12.1 Material Control Boundaries .........................................................................................59

12.2 Custodians ...................................................................................................................59

12.3 Commitments and Acceptance Criteria.........................................................................59

13. RESOLVING INDICATIONS OF LOSS, THEFT, DIVERSION, OR MISUSE 

 OF SPECIAL NUCLEAR MATERIAL................................................................................61

13.0 Regulatory Intent ..........................................................................................................61

13.1 Methods and Procedures for Identifying Indicators .......................................................61

13.2 System and Procedures for Investigating and Resolving Loss Indicators......................61

13.3 Response Actions for Unresolved Indicators ................................................................62

13.4 Documentation Requirements ......................................................................................62

13.5 Commitments and Acceptance Criteria.........................................................................63

14. INFORMATIONAL AID FOR ASSISTING IN THE INVESTIGATION AND 

 RECOVERY OF MISSING SPECIAL NUCLEAR MATERIAL...........................................65

14.0 Regulatory Intent ..........................................................................................................65

14.1 Types of Information.....................................................................................................65

14.2 Information Indicating Possible Losses of SNM ............................................................65

14.3 Information on Resolving Indications of Missing SNM...................................................66

14.4 Commitments and Acceptance Criteria.........................................................................67

15. RECORDKEEPING ...........................................................................................................69

15.0 Regulatory Intent ..........................................................................................................69

15.1 Description of Records .................................................................................................69

15.2 Program and Controls for Ensuring an Accurate and Reliable Record System .............70

15.3 Commitments and Acceptance Criteria.........................................................................71

16. GLOSSARY.......................................................................................................................73

17. REFERENCES ..................................................................................................................79

ix NUREG-1065, Revision 3

ABBREVIATIONS 

CFR Code of Federal Regulations

DOE U.S. Department of Energy

DQ detection quantity

DT detection threshold

HEU high-enriched uranium

IAEA International Atomic Energy Agency

ICA item control area

ID inventory difference

LEU low-enriched uranium

MBA material balance area

MC&A material control and accounting

NDA nondestructive assay

NMMSS nuclear materials management and safeguards system

NRC U.S. Nuclear Regulatory Commission

SEID standard error of the inventory difference

SNM special nuclear material

SRD shipper-receiver difference

TID tamper-indicating device

U uranium

233U uranium-233

234U uranium-234

235U uranium-235

238U uranium-238

U3O8 Urano-uranic oxide

UF6 Uranium hexafluoride

wt % weight percent

1 NUREG-1065, Revision 3

1. INTRODUCTION

The Atomic Energy Act of 1954, as amended, directed the U.S. Atomic Energy Commission 

(AEC) to regulate the receipt, manufacture, production, transfer, possession, use, import, and 

export of special nuclear material (SNM) to protect the public health and safety, and to provide 

for the common defense and security. The Energy Reorganization Act of 1974 transferred all 

the licensing and related functions of the AEC to the U.S. Nuclear Regulatory Commission 

(NRC). 

The principal requirements for SNM licensing are found in Title 10 of the Code of Federal 

Regulations (10 CFR) Part 70, “Domestic Licensing of Special Nuclear Material,” and 

10 CFR Part 74, “Material Control and Accounting [MC&A] of Special Nuclear Material.” 

Regulations in 10 CFR 70.22 (b) specify that a license application must contain a complete 

description of the applicant’s program for the control and accounting of such SNM to show how 

compliance with the graded MC&A requirements of 10 CFR Part 74, subparts B-E, will be 

accomplished. This document describes the standard format and content suggested by the 

NRC for use in preparing MC&A plans for facilities authorized to hold SNM of low strategic 

significance. 

This introduction describes the basis for the five general performance objectives of 10 CFR 74.3

and the MC&A program features and capabilities needed to meet the objectives. Chapters 1-10

address the program capabilities needed to maintain accurate, current, and reliable information 

on the licensee’s SNM and to confirm its quantities and locations. Chapters 11 and 12 address 

the program capabilities needed to promptly investigate and resolve anomalies indicating a 

possible loss of SNM, and provide information to aid in the investigation and recovery of missing 

SNM. Chapter 13 addresses recordkeeping requirements. These 13 chapters provide an 

outline for an acceptable MC&A plan for facilities authorized to hold SNM of low strategic 

significance.

The acceptance criteria are for the use of applicants (or licensees) and NRC licensing 

reviewers. An application or proposed revisions that meet these criteria should be acceptable to 

the NRC staff. However, comprehensive criteria are included as examples, and each applicant 

or licensee should develop an MC&A program and plan that considers the unique features of its 

particular operation. Where additional guidance is available on particular topics, an appropriate 

reference is included in the acceptance criteria section. Recommendations in this document 

provide guidance to applicants and licensees. Licensees may use this guidance when making 

changes to their existing approved MC&A plans.

In preparing MC&A plans, applicants should consider the capabilities specified in 10 CFR 74.31, 

“Nuclear Material Control and Accounting for Special Nuclear Material of Low Strategic 

Significance,” and the general performance objectives specified in 10 CFR 74.3. After 

accepting an MC&A plan and imposing it as a condition of license, the NRC will evaluate the 

adequacy of a licensee’s MC&A performance by inspecting for performance with commitments 

and practices described in the plan.

Because 10 CFR 74.3 and 10 CFR 74.31 are performance-oriented regulations, they do not 

contain a detailed set of technical specifications. With this flexibility, applicants and licensees 

have many alternatives on how their overall MC&A program is designed, managed, and 

operated, which would permit a risk-informed performance-based approach that focuses on 

and, in turn, concentrates licensee resources on MC&A activities most important to safeguards. 
NUREG-1065, Revision 3 2

Accordingly, this document does not attempt to cover all possible methodologies that a licensee 

might use to meet the MC&A requirements. Instead, it provides examples of acceptable MC&A 

approaches. The document is intended for use by applicants, licensees, and the NRC 

safeguards licensing reviewers. Acceptance criteria are not to be regarded as rigid, fixed 

standards. That is, a lower effectiveness of one capability relative to a particular aspect can be 

tolerated if there is a compensating system feature, or combination of features, that provides an 

overall effective safeguards system. In the final analysis, an NRC reviewer must make a 

judgment on whether the applicant’s or licensee’s MC&A plan provides adequate assurance that 

regulatory requirements will be met. 

The contents of an MC&A plan are discussed in Chapters 3–15. The body of an approved 

MC&A plan will be made a condition of license in accordance with 10 CFR 70.32(c), and 

compliance with the MC&A plan commitments and pertinent procedures will be inspectable. 

Explanations and discussions in the plan should be sufficiently detailed and precise so that NRC 

licensing reviewers, NRC inspectors, and licensee personnel responsible for developing and 

implementing the plan have a clear and common understanding of what the MC&A plan 

requires.

The annex (or appendix) of an MC&A plan should provide supplementary and general 

information about the facility and the MC&A program (e.g., copies of blank record forms, site 

map, process diagrams, an example standard error of the inventory difference (SEID) 

calculation). The annex will not be incorporated as a condition of license and will not be the 

basis for inspection. Therefore, descriptions that the applicant or licensee present to satisfy 

regulatory intent must be in the plan itself, rather than the annex, and must provide adequate 

detail so that it is not largely dependent on examples or supplementary information in the annex 

for proper understanding. As a result, procedures detailed in the annex may be changed 

without NRC approval or notification, provided that plan commitments and capabilities are not 

degraded. 

By using this standard format for preparing an MC&A plan, a licensee or applicant will minimize 

administrative problems associated with the submittal, review, and approval of the plan. 

Preparation of an MC&A plan with this standard format will assist the NRC in evaluating the plan 

and in standardizing the licensing and review process. However, the NRC does not require 

conformance with the standard format. An applicant may use a different format if it provides an 

equal level of completeness and detail.
3 NUREG-1065, Revision 3

2. GENERAL PERFORMANCE OBJECTIVES, RELATED 

REQUIREMENTS,COMMITMENTS, 

AND ACCEPTANCE CRITERIA

General Performance Objectives

The five general material control and accounting (MC&A) performance objectives applicable to 

all U.S. Nuclear Regulatory Commission (NRC) Title 10 of the Code of Federal Regulations

(10 CFR) Part 70, “Domestic Licensing of Special Nuclear Material,” licensees are set forth in 

subpart A of 10 CFR Part 74, “Material Control and Accounting of Special Nuclear Material”

(10 CFR 74.3). The basis of these general performance objectives, and the related 

requirements in subpart C of 10 CFR Part 74 (applicable to NRC licensees authorized to hold 

special nuclear material (SNM) of low strategic significance) are discussed below.

1. Maintain accurate, current, and reliable information on, and confirm the quantities 

and locations of SNM in the licensee’s possession.

The purpose of this performance objective (10 CFR 74.3(a)) is to verify the presence of all SNM 

held by the licensee, and to detect the occurrence of any significant loss, including possible theft 

or diversion. To maintain current information on all such SNM, licensees should have in place a 

program that provides timely, accurate, and reliable information about the quantity and location 

of SNM in their possession. Accurate information means that item quantities for both the 

element uranium (U) and the isotope 235U are based on measured values or on reliable 

information. Reliable information means that the quantity of SNM in an item and the location of 

all items are known (except for items in solutions with a concentration of less than 5 grams of 

235U per liter, and items of waste destined for burial or incineration). The location designations 

must be specific enough to provide for the retrieval of the items in a prompt manner. Reliable 

information also means that the quantities and locations of all nonexempt SNM material, and 

items listed in the accounting records, are correct and verifiable.

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 

processed and (2) to ensure all SNM quantities of record associated with receipts, shipments, 

discards, and ending inventory are based on measurements. 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 must conduct total plant physical inventories at intervals not to exceed

370 calendar days in accordance with 10 CFR 74.31(c)(5). Each physical inventory must be 

conducted in a way 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 235U, the magnitude of which is discussed in Chapter 6.

The licensee should verify the presence of all SNM that the facility currently possesses, as 

stated in its accounting records. This verification is normally accomplished through 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 
NUREG-1065, Revision 3 4

100 percent basis) of the presence of all possessed SNM items (through unique item identities), 

and confirming the SNM quantities associated with unencapsulated and unsealed items on 

ending inventory. However, a dynamic (i.e., non-shutdown) inventory of some or all processing 

equipment may be used if the measurement uncertainty associated with the total material 

balance (for 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 7. In summary, a 

total plant physical inventory involves:

• verifying the presence, on a 100 percent basis, of all uniquely identified SNM items listed 

in the accounting records

• 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)

• measuring any items not previously measured

• verifying the identity and integrity of all encapsulated items and items affixed with 

tamper-indicating devices

• measuring an 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 it should not be excluded from using process 

monitoring and production control data.

2. Detect, respond to, and resolve any anomaly indicating a possible loss, theft,

diversion, or misuse of SNM.

3. Permit rapid determination of whether an actual loss, theft, diversion, or misuse of

SNM has occurred.

The purpose of these performance objectives in 10 CFR 74.3(b)-(c) is to ensure that licensees 

can adequately detect and respond to indications of possible loss, theft, diversion, or misuse of 

SNM and rapidly determine whether or not a loss, theft, diversion, or misuse of SNM occurred.

As further discussed in Chapter 13, the licensee or applicant should have a formalized program 

to detect, respond to, and resolve any anomaly that may indicate a possible loss of SNM. 

Resolution of such anomalies means that the licensee has made a rapid determination whether 

an actual loss of a significant quantity of SNM has occurred, including possible theft or 

diversion. An anomaly detected during a material balance closure needs to be investigated and 

resolved in accordance with 10 CFR 74.31(c)(5).

Resolution of an anomaly depends on the type of indicator. Various types of anomalies at 

plants could occur from a wide range of possible underlying scenarios (e.g., from unidentified or 

inadequately monitored loss mechanisms, simple theft, complex diversions). The investigation 

and resolution process 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 
5 NUREG-1065, Revision 3

computer programs or records, transcription errors, incorrect estimates of the amount of holdup 

in equipment, or calculation 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 the U.S. Nuclear Regulatory Commission (NRC) in accordance with

10 CFR 74.11, “Reports of Loss or Theft or Attempted Theft or Unauthorized Production of 

Special Nuclear Material.”

4. Provide information to aid in the investigation and recovery of missing SNM in the 

event of an actual loss, theft, diversion, or misuse.

The purpose of this performance objective in 10 CFR 74.3(d) is to ensure that licensees provide 

adequate assistance in any investigations that a government agency conducts of an actual loss, 

theft, diversion, or misuse of SNM. If the NRC 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 any information it considers relevant to the 

recovery of material involved in a loss, theft, or diversion . The burden shall be on the licensee 

to provide all information that it recognizes as relevant, as opposed to providing only information 

that the investigators request. Additional information and recommendations pertaining to 

providing information to aid in investigations are provided in Chapter 14.

5. Control access to MC&A information that might assist adversaries to carry out 

acts of theft, diversion, misuse, or radiological sabotage involving SNM.

The purpose of this performance objective in 10 CFR 74.3(e) is to implement the practices and 

procedures needed to provide effective material control and material accounting for deterrence 

and detection of theft, diversion, misuse, or radiological sabotage involving SNM. Components 

of control access to MC&A information may include access control, material containment, 

material surveillance, etc. Effective control systems should be multi-layered, and redundant 

systems should be used to eliminate the consequence of a single-point failure.

The licensee should implement an effective quality assurance program that minimizes the 

possibility of potential failures for the MC&A program. These control measures can provide

necessary checks and balances that contribute to deterrence of material loss, theft, diversion, or 

misuse. Access control involving all movements of people and materials into and out of the 

material access areas should be carefully monitored and controlled. Adequate containment and 

surveillance measures should provide assurance that the integrity of nuclear material values is 

maintained.

Primary attention should be paid to preventing errors or mistakes by MC&A personnel, and to 

prevent violations of procedures or compromises of MC&A information and data. A system of 

checks and balances should be established to ensure data accuracy; this system should detect 

any instances of unauthorized access to data. Mistakes because of inadequate training, 

accidents, improper equipment operation or maintenance, or any other unintentional actions,

can cause the MC&A program to lose its effectiveness.
NUREG-1065, Revision 3 6

Commitments and Acceptance Criteria Pertaining to General Performance Objectives

The applicant or licensee MC&A plan should provide definitive commitments that adhere to the 

regulatory requirements and meet the acceptance criteria for these general performance 

objectives and corresponding program capabilities. These commitments should be stated in the 

MC&A plan.

The commitments and acceptance criteria are listed in Chapters 3–5, and 7–15.

The following chapters of this document incorporate and expand on the performance objectives 

and the MC&A program and plan capabilities specified in 10 CFR 74.3 and 74.31. The chapters 

are arranged in a format and sequence to provide applicants and licensees an outline for their

required MC&A plans.
7 NUREG-1065, Revision 3

3. MANAGEMENT STRUCTURE

3.0 Regulatory Intent

The purpose of 10 CFR 74.31(c)(1) is to require licensees to implement a management 

structure that permits effective functioning of the material control and accounting (MC&A)

program. The regulations ensure that the plant management structure will not adversely affect 

MC&A program performance. Documentation, review and approval of critical procedures, and 

the assignment of key functions to specific positions eliminates ambiguities. The management 

structure is meant to separate key MC&A functions and provide overchecks that increase MC&A 

program reliability and make deceit and falsification less likely. It is also meant to free MC&A 

management personnel from conflicts of interest with other major functions, such as production.

3.1 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 be responsible for the 

control and accounting of all special nuclear material (SNM) that the licensee possesses.

3.2 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 

also should state how responsibilities are assigned for the following functions: 

• overall MC&A program 

• SNM custodianship

• receiving and shipping of SNM

• analytical laboratories 

• bulk and nondestructive assay (NDA) measurements

• sampling operations

• measurement control system

• physical inventories

• onsite SNM handling operations

A brief description should be provided for each site-level position, outside of the MC&A 

organization, which has responsibilities relating to MC&A activities (e.g., sampling, mass 

measurements, analytical measurements, and measurement control). For each position, the 

functions, responsibilities, and authorities should be clearly described.

3.3 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 MC&A plan must demonstrate the assurance of independence of action and 

objectivity of decision for the MC&A manager. Two options for meeting the organizational 
NUREG-1065, Revision 3 8

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.

3.3.1 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 MC&A 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 on how the MC&A manager ensures appropriate review and approval for all 

written procedures pertaining to MC&A-related activities, and to any future revisions that are 

issued both within and outside of the MC&A organization. In addition to the MC&A manager 

function, at a minimum, the functions listed below should be addressed:

• nuclear material accounting

• measurement control system

• item control system

• statistical applications

Whenever more than one key MC&A function is assigned to the same person, the MC&A plan 

should clearly describe the checks and balances that preclude the following:

• performance of accounting or record control functions by individuals who also generate 

source data

• assignment of sole authority to any individual to overcheck, evaluate, or audit 

information for which he or she is responsible

Examples of appropriate checks and balances are:

• Review measurement data and calculations by another individual.

• Maintain a duplicate copy of all source data and transfer forms under controls separate 

from the accounting function.

• Perform independent audits.

• Separate computer program maintenance from the program user function.

The management structure should assign responsibility for SNM undergoing processing and in 

storage to a single individual or group. The duties of the individual(s) should include but are not 

limited to:

• Maintaining appropriate inventory control over SNM in their assigned area

• Authorizing and recording all movements of SNM into and out of their assigned area
9 NUREG-1065, Revision 3

• Maintaining appropriate local MC&A records or ensuring that other records, such as 

production records, contain necessary MC&A information

• Participating in physical inventories as required

• Assisting in internal or external alarm resolution activities as required

• Ensuring that, when SNM is processed in bulk form, only authorized persons have 

hands-on access to the material

• Notifying proper authorities of irregularities in material and MC&A data handling.

For some individuals in management or supervisory positions, some modifications to 

procedures, such as restricted access without escort to some areas, may be necessary to 

provide sufficient assurance that the system cannot be compromised.

3.3.2 MC&A Procedures

Critical MC&A procedures 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 74.3 and the 

program capabilities of 10 CFR 74.31(c). The body of the MC&A plan should identify all critical 

MC&A procedures. A licensee’s development of its critical MC&A procedures, and any changes 

later made to them, should involve technical review by cognizant licensee personnel, be 

approved by line management directly affected, and also be approved by a level of 

management above the level responsible for executing the procedures. The MC&A plan should 

contain a definitive statement that the procedures will be followed. The set of critical MC&A 

procedures should, at a minimum, adequately address the following topics, regardless of which 

facility organizational group is responsible for the particular topic:

• accountability record system

• sampling and measurements

• measurement control system 

• item control system

• physical inventories

• investigation and resolution of shipper-receiver differences and loss indicators

• determination of standard error of the inventory difference (SEID), active inventory, and 

inventory difference (ID)

• providing information to aid in investigations

• MC&A recordkeeping

• independent assessment of the effectiveness of the MC&A program
NUREG-1065, Revision 3 10

• tamper-safing

• designation of material balance areas (MBAs), item control areas (ICAs), and custodial 

responsibilities

3.4 Training and Qualification Requirements

This section of the MC&A plan should describe the training programs that will be established 

and maintained to provide qualified personnel and the continuing level of qualification for the

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. 

3.5 MC&A Program Description

The length of this section and its level of detail will depend on the information provided in the 

previous sections of this chapter. The overall MC&A organization should be described in a way

that explains how the general performance objectives of 10 CFR 74.3 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:

• overall MC&A program management (Note: This individual should have no major 

non-MC&A-related responsibilities)

• measurements (Note: Responsibility may be divided on the basis of type of 

measurements, e.g., analytical laboratory measurements, NDA measurements, bulk 

measurements, and sampling)

• measurement control

• statistics

• accountability records

• item control

• physical inventories

• custodial responsibilities (e.g., SNM storage and movement controls)

• investigation and resolution of indicators that suggest possible loss of SNM

• receiving and shipping of SNM

• analytical laboratories

• MC&A recordkeeping system and controls
11 NUREG-1065, Revision 3

The MC&A program description should include 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 program.

3.6 Material Control Boundaries

This section of the MC&A plan should describe how the facility establishes various material 

control boundaries to minimize the occurrence of, and facilitate resolution of, MC&A anomalies, 

such as IDs, missing SNM items, and potential SNM theft or diversion.

The MC&A plan should describe the establishment of MBAs and ICAs because they are the 

basis for the control and accounting for all nuclear material in the facility. An MBA or ICA should 

correlate to physical or administrative boundaries and monitored locations. The MBA or ICA 

should be designed to limit losses to a specific area (i.e., the MBA should not be so large that it 

cannot localize inventory or process differences to a manageable level). Materials transferred 

into and out of an MBA or ICA must have quantitative measurements as specified in the MBA 

and ICA definitions in 10 CFR 74.4, “Definitions.”

The MC&A plan should describe roles and responsibilities of nuclear material custodians for 

MBAs and ICAs. The material custodian should have direct interaction with the MC&A 

organization and should be located within the physical operations area. Custodians who are 

responsible for more than one MBA or ICA should not be able to make material transfers 

between MBAs or ICAs under their direct control.

3.7 Commitments and Acceptance Criteria

In its MC&A plan, the applicant or licensee should provide definitive commitments that adhere to 

the regulatory requirements and meet acceptance criteria applicable to management structure. 

A finding that the licensee’s MC&A plan for management structure is acceptable and in 

accordance with the internal control requirements of 74.31(c)(1), will be based on, but not 

limited to, the following acceptance 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 or implement measurement 

control requirements, and conduct data analysis) are defined clearly 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 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.
NUREG-1065, Revision 3 12

• 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 through suitable controls and overchecks.

• The MC&A program management responsibility is designated to an individual at an 

organizational level sufficient to ensure independence of action and objectiveness of 

decisions.

• No two key MC&A functions are assigned to the same person unless sufficient checks 

and balances are provided. As a consequence of this criterion:

o 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

o No individual has the sole authority to overcheck, evaluate performance, or audit 

information for which he or she is responsible

• The responsibility for each MC&A function is assigned to a specific position in the 

organization, and the organization is structured so that key functions are separated or 

overcheck one another. The position descriptions are available in writing to the 

personnel affected.

• 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).

• 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.
13 NUREG-1065, Revision 3

4. MEASUREMENTS

4.0 Regulatory Intent

The intent of 10 CFR 74.31(c)(2) is for licensees to maintain a system of measurements to 

ensure that all quantities of special nuclear material (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 to 

ensure that the limit specified in 10 CFR 74.31(c)(4), for the total material control and 

accounting (MC&A) measurement uncertainty (associated with a physical inventory material 

balance), is not exceeded. Except for sealed sources, all SNM receipts are to be measured for 

the purpose of performing shipper-receiver evaluations. In the absence of any significant 

shipper-receiver differences (SRDs), 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 standard error of the inventory difference (SEID). It is also intended that a 

licensee’s measurement program provide bias estimates to be used in correcting inventory 

difference (ID) values and SRDs for significant measurement biases. Estimation of, and 

correction for, measurement bias is discussed further in Chapters 5 and 6.

4.1 Measurement Points

The MC&A plan should identify and describe each measurement 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 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) decontamination and recovery areas, (3) laboratory areas, and (4) feed and product 

sampling and transfer areas. 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.

4.2 Measurement Systems

The MC&A 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 should also be identified: (1) sampling technique and equipment used, (2) sample 

aliquoting technique, and (3) sample pretreatment methodology. Elements of the measurement 

control program (e.g., standards traceable to a national system) used for validating and 
NUREG-1065, Revision 3 14

determining control limits, precision, and accuracy levels for each measurement system used 

for accountability are described in Chapter 5.

The MC&A 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 purposes 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.

4.2.1 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 (e.g., capacity not to exceed X kilograms), range to be used, sensitivity of the 

device (e.g., sensitivity is +/- Y grams), and the calibration frequency. 

For each volume measurement system, the MC&A plan should identify the vessel (e.g., tank, 

column), capacity of the vessel to which the measurement applies (e.g., capacity not to exceed 

X liters), the material being measured, the volume measuring device and instrumentation, the 

sensitivity of each device and system (e.g., sensitivity is +/- Y milliliters), the range of operation 

or calibration, and the calibration frequency.

4.2.2 Analytical Measurement Systems

For each analytical measurement system, the MC&A plan should specify the following:

• type of material or chemical compound (e.g., UF6, uranium alloy, UO2, uranyl nitrate 

solution) being sampled and measured

• sampling technique(s)

• sample handling (i.e., pre-analysis sample storage and treatment)

• analytical method used

• characteristics measured (e.g., grams of uranium per gram sample, 235U isotopic 

concentration)

• measurement interferences

• expected measurement uncertainty

• types of calibration standard(s) and calibration frequency
15 NUREG-1065, Revision 3

4.2.3 NDA Measurement Systems

For each NDA measurement system, the MC&A plan should identify the following:

• the NDA equipment package (i.e., type and size of detector, and type of associated 

electronics and computer interface, as appropriate)

• the type of container measured

• SNM material type within container

• attribute measured

• measurement configuration (including source to detector distance)

• calculational method

• expected measurement uncertainties

4.2.4 Other Measurement Systems

If applicable, the MC&A plan also should identify any other measurement systems used for 

accounting purposes that do not fall within the three categories covered by Subsections 4.2.1, 

4.2.2, and 4.2.3.

4.3 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.

4.4 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 ensures 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 the manager of the 

organizational unit responsible for performing the measurement. The measurement control 

program manager should also approve measurement procedures.
NUREG-1065, Revision 3 16

The MC&A 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:

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

• removals from inventory (e.g., shipments and measured discards)

• material on ending inventory

For receipt of material, the licensee may 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 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.

4.5 Commitments and Acceptance Criteria

In its MC&A plan, the applicant or licensee should provide definitive commitments that adhere to 

the regulatory requirements and meet the acceptance criteria applicable to measurements. 

A finding that the licensee’s MC&A plan for assuring that all quantities of SNM are based on 

reliable measurements is acceptable and in accordance with 10 CFR 74.31(c)(2), will be based 

on, but not limited to, the following acceptance criteria:

• 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. 

The measurement control program will monitor and control key measurement systems 

and their standard deviations.

• A basic description or summary of each key measurement system that is used 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 235U 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 SEID.

• 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.
17 NUREG-1065, Revision 3

• All calibrations are made with the use of primary standards or primary reference 

materials (certified and issued by the National Institute of Standards and Technology 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 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 a uniform material batch (or lot), such as blended UO2 powder or 

sintered UO2 pellets, should be determined by direct mass measurement. However, the 

element or isotope concentrations for the batch do not have to be determined for each 

container; instead, they may be derived by sampling procedures, including:

• Analysis of composite samples or measurements of representative items, objects, or 

samples selected by statistical sampling

• Use of concentration or enrichment factors determined from historical averages, 

controlled input specifications values, or empirical relationships in which such values or 

relationships are tested periodically, 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 235U (per material type, per inventory period). 

Justification for any materials assigned common factors without batch-by-batch 

verification analyses should be presented in the MC&A plan.

19 NUREG-1065, Revision 3

5. MEASUREMENT CONTROL SYSTEM

5.0 Regulatory Intent

The intent of the measurement control requirements in 10 CFR 74.31(c)(3) and (4) is that 

measurement systems (described in Chapter 4) used to establish special nuclear material 

(SNM) accountability quantities be controlled by a formal measurement control system that 

results in a 235U total measurement standard error that is within 4,500 grams 235U or 

0.125 percent of the 235U 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 

material control and accounting (MC&A) measurement uncertainty (for 235U) must be less than 

the greater of 9,000 grams 235U or 0.25 percent of the 235U active inventory. It is also intended 

that the measurement control program also provides bias estimates for adjusting inventory

difference (ID) results and correcting shipper-receiver measurements for significant 

measurement biases.

5.1 Organization and Management

The organization and management of the measurement control system 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 system manager should be at a 

management level that is sufficiently high to ensure objectivity and independence of action. 

Thus, the measurement control system 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 system 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). 

5.1.1 Functional Relationships

The relationship and coordination between the measurement control system manager, the 

analytical laboratory, and other measurement performing groups needs to be clearly defined. 

Adequate assurance should be provided so that the measurement control system manager has 

the authority to enforce all applicable measurement control requirements.

5.1.2 Procedures

The measurement control system 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 system manager. The procedures should address the following:

• calibration frequencies and methods

• standards used for calibration (i.e., description and storage controls)
NUREG-1065, Revision 3 20

• standards used for control (i.e., method of obtaining or preparation, and traceability)

• control standard measurements

• replicate sampling and replicate measurements

• verification of process control instrumentation through comparison with other process 

instruments

• control limits and control responses

• generation and collection of control data

• recordkeeping controls and requirements

5.1.3 Contractor Program Audits and Reviews

If an outside contractor or offsite laboratory provides measurement services, the review program 

used to monitor the offsite measurements should be described. Such reviews are to ensure that 

the contractor or offsite 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 MC&A plan. An initial review of the contractor’s measurement control 

program should be conducted before licensee use of measurements performed by the 

contractor or offsite laboratory.

All contractor or offsite laboratory assessment findings and recommendations should be 

documented and submitted to both the measurement control system manager and the overall 

MC&A manager within 30 calendar days of review completion. 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 offsite laboratory in writing. The 

licensee should not use measurements performed by such contractors or offsite 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 offsite laboratory so 

that the independence of the conclusions may be maintained.

5.2 Calibrations

The MC&A plan should summarize the licensee’s calibration program and confirm that the 

licensee has written procedures covering the following topics:

• calibration frequency for each measurement device or system

• identification of the standards used for calibration of each measurement device or 

system

• protection and control of standards used to calibrate measurement systems to maintain 

the validity of their certified or assigned values
21 NUREG-1065, Revision 3

• 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 often is used 

to analyze samples for uranium concentration of two or more different material types (e.g., UF6, 

UO2, 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 (K2Cr2O7) 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 U3O8 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 depend 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 MC&A plan should contain a definitive statement that no SNM accountability value is based 

on a measurement that falls outside the range of calibration. The MC&A plan also should 

identify those measurement systems that are point-calibrated. A point-calibrated measurement 

system is one in which the following are true:

• The entire measurement system is calibrated with a standard or set of standards that is 

representative of the process unknowns that the system measures. That is, the 

representative calibration standard(s) undergoes all the measurement steps, and in the 

same manner, that the unknowns do.

• 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).

• 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).

• 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.
NUREG-1065, Revision 3 22

5.3 Control Standards

For measurement systems that are not point-calibrated, a defined method for the periodic 

measurement of control standards should be established and followed. Control standard 

measurements serve the dual purpose of (1) 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 8 weeks during a given material balance period, more than two 

control standard measurements per week of system use may be necessary 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 235U

(2) A minimum of 24 control standard measurements for those systems used to measure a 

total of 100 or more kilograms of 235U

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 the 

standard error of the inventory difference (SEID). Included within the set of key measurement 

systems should be any system used 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 (1) and (2), above, can be 

reduced to 8 and 16, respectively, for non-key measurement systems that measure from 10 to 

25 percent of the active inventory, and the minimum number of control standard measurements 

for situations (1) 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 point-calibrated, the control standards to be used for 

control standard measurements should be identified 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:

• Does the variation between analysts or operators need to be considered and therefore

monitored?

• Can environmental variables contribute to measurement bias?
23 NUREG-1065, Revision 3

• Is bias likely to vary with respect to the time of day?

• Is a particular bias likely to be long term, short term, or cyclic in nature?

• 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)?

• What controls or procedures are needed to ensure that sampling or aliquoting of the 

control standard is representative of the sampling or aliquoting of the process material?

• To estimate the bias for each measurement system, how alike—in terms of chemical 

composition, uranium concentration, density, homogeneity, and impurity content—

should the control standards be relative to the process unknowns?

5.4 Replicate Sampling

For systems involving sampling, duplicate measurements performed on single samples or 

measurements of replicate samples are necessary to estimate the combined analytical plus 

sampling random error. For nonsampling measurement systems such as nondestructive assay 

(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) percent of the accountability batches sampled (when less than eight batches)

(5) the greater of eight 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 MC&A 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 
NUREG-1065, Revision 3 24

systems, replicate data 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 

considered 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 U.S. Nuclear Regulatory 

Commission (NRC) recommends the statistical methods described in NUREG/CR-4604,

“Statistical Methods for Nuclear Material Management,” issued December 1988, for satisfying 

the statistical requirements of 10 CFR 74.31; see also Chapter 6 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.

5.5 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 used 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 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 licensee normally sets the warning and out-of-control limits based on a tradeoff between 

(1) the cost of investigating and resolving incidents in which limits are exceeded and (2) the cost 

of accepting measurements of poor quality. Warning limits set at the 0.05 level of significance 

and out-of-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 MC&A plan should clearly explain how control limits are established and the frequency for 

redetermining them.

5.5.1 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 for generation of control 

charts. All control charts should be reviewed at least once every 2 weeks unless 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. 
25 NUREG-1065, Revision 3

5.5.2 Response Actions

Either the analyst or the operator performing a control measurement or their supervisor should 

be responsible for promptly reporting any control measurement that exceeds an out-of-control 

limit. Such reporting should be made to the measurement control system 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:

• verifying that the measurement system in question has been taken out of service for

accountability measurements

• documenting the occurrence of the event

• performing at least two additional control measurements

• 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

• reviewing measurements performed on the system in question since the last in-control 

run to determine if there is a need to remeasure any items

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. 
NUREG-1065, Revision 3 26

5.6 Commitments and Acceptance Criteria

In its MC&A plan, the applicant or licensee should provide definitive commitments that adhere to 

the regulatory requirements and meet the acceptance criteria applicable to the measurement 

control system. A finding that the licensee’s MC&A plan for maintaining measurement quality 

and estimating measurement uncertainty values is acceptable and in accordance with 

10 CFR 74.31(c)(3) and (4), will be based on, but not limited to, the following acceptance 

criteria:

• The description of the measurement control system shows that the measurement 

systems that are the key contributors to the total measurement standard error will be 

routinely and adequately monitored for both bias and 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 are collected demonstrating 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 and 

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 affect the ID 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 

bias-free, 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 MC&A 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 ID (on line 7 of NRC Form 327).
27 NUREG-1065, Revision 3

• 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 4 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 generated more 

than 24 months before the current determination of such bias or standard deviation.

• The effort that the licensee expended in monitoring and controlling the bias and standard 

deviations of each measurement system is shown to be consistent with its impact on ID

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.

• Warning 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 (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 2 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 74.31(c)(4)) will not be jeopardized.

• 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 ID are included.
NUREG-1065, Revision 3 28

- 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 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 in 

the recommended NUREG/CR-4604 (1988), as well as in TID-26298 (1973), and the 

International Atomic Energy Agency (IAEA) statistics handbook (1989).

• The licensee will confirm that the accountability measurements that a contractor 

provides 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.

• The measurement systems have adequate calibration frequencies, sufficient control of 

biases, and sufficiently small standard deviations to achieve the requirements of 

10 CFR 74.31(c). A measurement control system is used—by both in-house activities 

and any contractor that performs MC&A measurement services for the licensee—to 

ensure that the quality of the measurements is maintained on a level consistent with the 

NRC requirements.
29 NUREG-1065, Revision 3

6. STATISTICS

6.0 Regulatory Intent

Proper use of statistics is important to ensuring that the regulatory requirements in 

10 CFR 74.31, “Nuclear Material Control and Accounting for Special Nuclear Material of Low 

Strategic Significance,” are met. An effective statistical program will ensure measurement 

systems perform within control limits, measurement uncertainties are calculated and 

propagated, the inventory difference (ID) and standard error of the inventory difference (SEID)

are properly determined, and significant shipper-receiver differences (SRDs) are identified. For 

example, 10 CFR 74.31(c)(5) requires licensees to calculate the ID and SEID for the material 

balance period terminated by each physical inventory. Proper use of statistics is important to 

correctly propagate the uncertainties from all measurements into an accurate SEID value.

6.1 Determination of Measurement Uncertainties

To achieve the general performance objectives of 10 CFR 74.3, and meet the 10 CFR 74.31

requirements, each licensee or applicant should institute a statistical program that evaluates the 

material control and accounting (MC&A) data to ensure that (1) the measurement data are 

analyzed in a rigorous manner and (2) statistical tests and inferences concerning the status of 

the nuclear material possessed are appropriately tested. The U.S. Nuclear Regulatory 

Commission (NRC) sponsored the development of a comprehensive reference that specifically 

addresses the statistical treatment of measurement control and accounting data. The NRC 

recommends the statistical methods described in NUREG/CR-4604, “Statistical Methods for 

Nuclear Material Management” (1988), as well as in TID-26298 (1973) and the International 

Atomic Energy Agency (IAEA) statistics handbook (1989), for satisfying the statistical 

requirements of 10 CFR 74.31.

The MC&A plan should:

• contain a detailed discussion of the procedures and methodologies for estimating 

measurement variance components

• discuss how biases are determined and how bias corrections are applied, including: 

o how often biases are estimated

o how the bias’ effect on the measured quantity of material in an item is determined

o when and how bias corrections to items are made

o how their effect on ID is determined

o when and how bias corrections are applied to the ID

• describe the procedure and means for determining active inventory

• provide all relevant information regarding the determination of the SEID
NUREG-1065, Revision 3 30

• specify the nominal (typical) detection quantity (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 235U, in 

which case the DQ need not be less than 25 kilograms of 235U. (Note: For those 

facilities that do not use 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 235U.)

• 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 ID limits and response actions.) 

6.2 Determination of Standard Error of the Inventory Difference

As defined in 10 CFR 74.4, the SEID means the standard deviation of an ID that takes into 

account all measurement error contributions to the ID components. 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 significance, 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 235U, as applicable) can be expressed as follows:

SEID = 

where

k = number of measurement systems

Gi = total grams uranium (or 235U) measured during inventory-period by 

measurement system i

(σi)s = systematic-error standard deviation for measurement system i

(σi)r = 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),

SEID = 

In theory, SEID provides the uncertainty, at the 67 percent confidence level, of the ID estimate.

The MC&A plan should provide all relevant information regarding the determination of SEID. 

There should also be a commitment 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 that the computer used to calculate SEID.
31 NUREG-1065, Revision 3

The method to be used for estimating the SEID for the typical material balance, as shown in the 

Annex, should be consistent with the following criteria:

• All reasonable and probable sources of measurement error for the key measurement 

systems affecting IDs are included.

• The selection of the key measurements whose variances are to be included in 

calculating the standard error is justified by an analysis of the relative magnitudes of the 

variance components of a typical ID and their comparative effect on the SEID.

• Any measurement error standard deviations not actually determined by the 

measurement control program are shown to be reasonable either by comparison with 

published state-of-the-art measurement performance in similar applications (see such 

sources as Rogers (1983), and Reilly and Evans (1977)) or with records of past 

performance data from the licensee’s facility. Records showing these data should be 

available to the NRC.

• The calculation of the SEID is performed in accordance with a recognized error 

propagation method. Such methods have been published by Jaech (1973) and the 

IAEA (1977).

6.3 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 ID value, it can be argued that 

such insignificant biases should be applied as a non-accounting adjustments to the initially 

calculated ID (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 optional.

For statistically significant biases (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 
NUREG-1065, Revision 3 32

to the accounting records or as an adjustment to the ID, 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 detection threshold (DT) value 

(2) The bias is greater than 0.0100 percent relative and also affects the ID value by more 

than 1,000 grams 235U.

Additionally, the net algebraic sum (expressed as grams 235U) 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 or 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:

• Applying such correction would cause the ID to exceed its DT value 

• The net correction impacts the ID value by more than 5.00 percent of the licensee’s DQ, 

or 10,000 grams 235U, whichever is larger

All measurement systems affecting an ID estimate or shipper-receiver comparison should be 

monitored for bias except as noted below. The intensity of the monitoring program is 

proportional to the significance of the measurement system for the test involved. The key 

measurement systems (i.e., those that contribute at least 10 percent of the estimated 

measurement standard deviation of an SRD or an ID estimator) should be tested for bias at 

least monthly except where:

• the measurement system has been demonstrated to be quite stable and the results 

predictable

• the system is defined as bias-free

Where the above conditions exist, the bias tests can be extended to 3 months or exempted 

altogether if the system qualifies as bias-free.

The bias tests should be made using the mean of at least eight control standard measurements. 

Bias corrections should be made to individual items if the bias exceeds twice the standard 

deviation of its estimator and also exceeds the rounding error of affected items. 

Measurement systems are statistically “bias-free” if a representative standard is run for each 

unknown or set of unknowns measured at the same time, or representative standards are 

measured before or after a group of process samples and the standard(s) measurement 

response and assigned value, rather than any previous calibration information, are used in 

determining the value of the unknown(s).
33 NUREG-1065, Revision 3

7. PHYSICAL INVENTORIES

7.0 Regulatory Intent

The intent of the physical inventory requirements in 10 CFR 74.31(c)(5) is to require licensees 

to perform annual physical inventories to confirm that a loss or diversion of a safeguards 

significant quantity (i.e., a detection quantity (DQ)) of low strategic special nuclear material 

(SNM) has not occurred. Licensees are required by 10 CFR 74.31(c)(5) to conduct physical 

inventories at intervals not to exceed 370 calendar days. 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 inventory difference 

(ID) depends on measurement errors, as well as various nonmeasurement contributors, such as 

recording errors, unmeasured losses, and unmeasured residual holdup as discussed further in 

Section 7.5 (see Glossary for the definition of “residual holdup”).

7.1 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.

The material control and accounting (MC&A) plan should contain a definitive statement that 

physical inventory functions and responsibilities are reviewed comprehensively with the involved 

individuals before the start of each physical inventory.

A book inventory listing, derived from the MC&A record system, should be generated just before 

the actual start of each physical inventory; such listing shall include all SNM that the records 

indicate the licensee should possess at the inventory cutoff time.

The ID and related information associated with each physical inventory of low-enriched uranium 

(LEU) (i.e., U.S. Department of Energy/U.S. Nuclear Regulatory Commission (DOE/NRC)

material code 20-E1 and 20-E2) are to be reported to the NRC, pursuant to 10 CFR 74.17(a), 

on an NRC Form 327 as the results of a physical inventory. In addition, if the licensee 

possesses any material associated with material codes 20-E3 and 20-E4 (i.e., high-enriched 

uranium (HEU)), 70 (233U), 50 (Plutonium), or, 83 (Plutonium-238), such material also must be 

subject to the physical inventory, and each material code ID and associated information must be 

reported on separate NRC 327 Forms.

7.2 Organization, Procedures, and Schedules

The MC&A plan should explain the makeup and duties of the typical physical inventory 

organization. The individual that has responsibility for the coordination of the physical inventory 

effort should be identified by position title. The MC&A plan also should indicate how the 

preparation and modification of inventory procedures is controlled.

The MC&A plan should contain a definitive statement that specific inventory instructions are 

prepared and issued for each physical inventory.
NUREG-1065, Revision 3 34

7.3 Typical Inventory Composition

The typical expected in-process inventory within the equipment for both uranium and 235U 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 material balance areas (MBAs) and item control areas 

(ICAs) to reflect the functional activities as follows:

Processing—an MBA in which occurs (1) routine transfers of nuclear material from one 

container to another, (2) changes in chemical assay, or (3) changes in chemical or 

physical form. Various measurements are required to define materials flows through the 

process and to perform physical inventories so that periodic material balances can be 

completed for the MBA. Because these measurements have associated uncertainties, a 

processing MBA will normally have a nonzero ID for each inventory. Of the total plant 

MBAs and ICAs, a relatively small number might be processing MBAs. Examples are 

the decontamination and recovery operations; analytical laboratory; and material 

rebatching, blending, and sampling operations. Physical inventories for the 

decontamination and recovery operations are the most complex and involve the most 

coordination and careful timing.

Storage—ICAs in which all materials are within containers with measured values and are 

being stored for future processing or shipment. Some minor sampling of containers can 

occur in a storage ICA. Because nuclear materials in a storage ICA primarily are 

accounted for on an item basis, a true 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 shipping—an ICA from which materials are shipped or into which 

materials are received from off site. This ICA type normally will 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.

7.4 Description of Typical Item Strata

The MC&A plan should describe the expected item population in terms of the following:

• type of item (i.e., stratum)

• expected range of the number of items within each stratum

• the average uranium and 235U content of the items within each stratum

• the expected rate of item generation and consumption for each stratum

7.5 Conducting Physical Inventories

The MC&A plan should contain a description of the inventory methodology, including cutoff and 

inventory minimization procedures, and should identify all measurements (including sampling) 

sufficient to meet the requirements of 10 CFR 74.31(c)(5). The MC&A plan also should contain 
35 NUREG-1065, Revision 3

sufficient information to show how the total in-process inventory for both uranium and 235U is 

obtained.

The means for measuring or estimating residual holdup should be addressed in detail, and the 

change or variation in such holdup from one physical inventory to the next also should be 

discussed. This information is important to ensure no SNM held under license (except for waste 

materials assigned to holding accounts in accordance with the exceptions provided in 

10 CFR 74.31(c)(6) and DOE/NRC Form-741 instructions) will be omitted, and no quantity will 

be counted more than once.

The MC&A plan also should contain adequate commitments to ensure 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 ensure that any SNM held under license (except for waste 

materials as noted above) is properly inventoried.

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 will 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:

• organization and separation of functions

• assignment of inventory teams and their training in the use of uniform practices

• obtaining, verifying, and recording of source data

• control of inventory forms

• assurance that item counts verify the presence of each item while preventing any item 

from being counted more than once

• 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 nondestructive assay (NDA) techniques to establish levels of residual holdup, if such 

holdup is significant.
NUREG-1065, Revision 3 36

Special item storage and handling or tamper-indicating methods, which are used to ensure that 

the previously measured and recorded SNM content values can be used for inventory purposes 

without remeasurements, also should be described. In addition, the MC&A plan should provide 

a description of how item identities are verified and how tampering with the contents of items will 

be detected or prevented.

Items that are not encapsulated, affixed with tamper-indicating device (TIDs), 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 

any proposed alternatives 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 MC&A plan should describe the sampling plan. Such description should 

include:

• the method of segregating the types of items to be sampled (i.e., selected for 

remeasurement)

• the procedure for calculating the sample size (i.e., the number of items) for each stratum

• the parameter to be measured (e.g., gross weight or total 235U content)

• the quality of the measurement methods used to verify original measurement values (for 

the parameter being measured)

• the procedure for reconciling discrepancies between original and remeasurement 

values, and for scheduling additional tests and remeasurements

• the basis for discarding an original SNM value and replacing it with a remeasurement 

value

One acceptable way for establishing the number of items (to be randomly selected for 

remeasurement) from a given stratum to give the required 90 percent power of detecting a loss 

of a DQ is given by the following equation: 

n = N [1 – (0.10)x/g]

where

n = number of items to be remeasured

N = total number of items in the stratum

x = maximum 235U content per item (kilograms)

g = DQ = detection quantity (kilograms 235U)

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 ≥ 0.5 N) from each stratum should be remeasured. If 
37 NUREG-1065, Revision 3

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 (2σ) should have its accounting 

value revised to reflect its remeasured quantity.

The MC&A 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 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 MC&A plan. For example, if the 235U 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 235U 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 TIDs 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 (1) 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 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.

7.6 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

235U ID ≥ 1.7(standard error of the inventory difference (SEID)) + 500 grams, or

U ID ≥ 1.7(SEID) + 10 kg U 

Significant ID problem

U or 235U ID ≥ 3(SEID) 

Major ID problem

235U ID ≥ 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 
NUREG-1065, Revision 3 38

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 MC&A plan should fully describe in definitive statements the minimum response actions for 

each ID action level.

7.7 Commitments and Acceptance Criteria

In its MC&A plan, the applicant or licensee should provide definitive commitments that adhere to 

the regulatory requirements and meet the acceptance criteria applicable to the physical 

inventories. A finding that the licensee’s MC&A plan for conducting physical inventories is 

acceptable and in accordance with 10 CFR 74.31(c)(5), will be based on, but not limited to, the 

following acceptance criteria:

• An MC&A program will be maintained that is capable of confirming, at intervals not to 

exceed 370 calendar days, the presence of all SNM expected to be present (at a given 

time) based on accurate, current, and reliable information. The inventory must ensure 

that no SNM held under license will be omitted, and no quantity will be counted more 

than once.

• Unless otherwise required by Facility Attachments that satisfy 10 CFR Part 75, 

“Safeguards on Nuclear Material—Implementation of US/IAEA [International Atomic 

Energy Agency] Agreement,” physical inventories will be performed at least every 

370 calendar days and will be used as the basis for reconciling and adjusting the book 

inventory that is done within 60 calendar 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 responsible for conducting the physical inventory.

• The individual responsible for conducting 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, 

except for waste materials assigned to holding accounts (in accordance with the 

exception provided in 10 CFR 74.31(c)(6) and DOE/NRC Form-741 instructions). All 

such listed SNM quantities are to be based on measurements, and no quantity will be 

counted more than once.

• Within 60 calendar days after the start of each physical inventory, the inventory 

difference (ID) will be determined. Any ID, which is rejected by a statistical test that has 

a 90 percent power of detecting a discrepancy of a quantity of 235U that the NRC
39 NUREG-1065, Revision 3

established on a site-specific basis, will be reported to the appropriate NRC safeguards 

organizational units.

• Discrepancies in the identity, quantity or location of items, objects or containers of SNM 

that are detected during a physical inventory will be corrected.

• ID 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.)

• 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 235U ID (after applying any appropriate bias corrections and prior 

period adjustments) is greater than the 235U detection threshold (DT) and is not resolved 

within the 60 calendar day reconciliation period, all SNM processing should be halted 

and a reinventory conducted. (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 235U 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 

235U.

• The MC&A plan contains adequate commitments to ensure 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 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 should 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 should

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 in significant amounts which remains 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 in the uranium concentration (or weight fraction) or 

in the uranium enrichment because of such factors as oxidation, change in moisture 

content, commingling with materials of different enrichment or different composition, 

etc., the previously determined uranium and 235U content may be accepted without 

verification of SNM content, provided the gross weight or net weight of all items within 
NUREG-1065, Revision 3 40

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 alternative 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 before 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 235U) 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 or loading pellets into fuel 

rods), unless the 0.90 or 1.30 percent of throughput (as appropriate) is less than 

25 kilograms 235U, in which case the DQ need not be less than 25 kilograms. The 235U

throughput is defined as the greater of “additions to process” or “removals from process”

during a 12-month inventory period.

• The MC&A plan should state 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 235U DQ for the inventory period in question. In general, a licensee 

may assume the ID distribution approximates a normal distribution, and therefore:

DT = DQ - 1.3(SEID)

• In general, a licensee may assume the ID distribution approximates a normal 

distribution. Acceptable methodology for calculating the measurement error contribution 

to the SEID by error propagation is found in NUREG-4604 (1988), TID-26298 (1973), 

and the IAEA statistics handbook (1989). Special attention is given to inclusion of all 

measurable sources of error to avoid underestimating the SEID.

• In addition to the DT ID alarm limit, there is at least one excessive ID warning 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 residual holdup and measured discards. 

Investigations are to be completed within 60 days after initiating the inventory (except 

when the NRC grants additional time for extenuating circumstances). 
41 NUREG-1065, Revision 3

8. ITEM CONTROL

8.0 Regulatory Intent

The intent of 10 CFR 74.31(c)(6) is to require licensees to establish, document, and maintain an 

item control system to protect against unauthorized and unrecorded removal of items, or of 

material from items, and to enable timely location of items. Items, as defined in 10 CFR 74.4, 

“Definitions,” mean any discrete quantity or container of special nuclear material (SNM) or 

source material, not undergoing processing, having a unique identity and also having an 

assigned element and isotope quantity. Examples of 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. To promptly locate a given item, sufficient 

current information must be recorded. 

8.1 Organization

The material control and accounting (MC&A) plan should identify the individual responsible for 

overseeing the item control system by position title. Positions of those individuals who have 

significant item control system responsibilities also should be identified.

8.2 General Description

The applicant or licensee should state that the overall MC&A program maintains a record of all 

SNM items, regardless of quantity or duration of existence. In addition, the item control system

should provide current knowledge of the location, identity, and quantity of all SNM contained in 

all items that are not excepted from the item control requirements. As stated in 

10 CFR 74.31(c)(6), the following items are excepted from its requirements:

• containers of waste (designated for burial or incineration)

• containers of solution in which the 235U concentration is less than 5.00 grams per liter.

All other items 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 system coverage, should have a unique identity. For 

items subject to the item control system, the following are acceptable ways to provide unique 

identity:

• a unique alpha-numeric identification on a tamper-indicating device (TID) applied to an 

SNM container

• a unique alpha-numeric identification permanently inscribed, embossed, or stamped on 

the container or item itself

• a uniquely prenumbered (or bar-coded) label applied to each item that has good 

adhesive qualities such that its removal from an item would preclude reuse of the label

Location designations that the MC&A records show need not be unique, but location 

designations should be specific enough so that any item may be located within 1 hour. Longer 

times may be acceptable but should be further justified in the MC&A plan. The MC&A record 
NUREG-1065, Revision 3 42

system should be controlled in such a way that the record of an item’s existence cannot be 

destroyed or falsified without a high probability of detection. Each nonexempt item should be 

stored and handled in a manner that enables detection of, and provides protection against, 

unauthorized or unrecorded removals of SNM.

8.3 Item Identity Controls

Descriptions should be provided of the item records showing how items are identified for each 

material type and each type of container. If the unique number on a TID is the basis for 

providing the unique item identity, the MC&A plan should:

• describe the type of TID used

• describe how the TIDs are obtained and what measures are carried out to ensure that 

duplicate (counterfeit) TIDs are not manufactured

• describe how the TIDs are stored, controlled, issued, and accounted for

• describe how TID usage and disposal records are maintained and controlled

Similar information should be provided for other methods of unique item identity (e.g., labels).

8.4 Storage Controls

Item storage areas and controls should be fully described in the MC&A 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-safing, which is 

defined by 10 CFR 74.4 as the use of devices on containers or vaults in a manner and at a time 

that ensures a clear indication of any violation of the integrity of previously made measurements 

of the SNM in the container or vault.

Both administrative controls (e.g., custodian assignments and limiting authorized access to 

storage areas) and physical controls (e.g., locked or alarmed doors) should be identified.

8.5 Item Monitoring Methodology and Procedures

As part of the item control system, a licensee should maintain a system of item monitoring that:

• verifies that items shown in the MC&A records are actually stored and identified in the 

manner indicated in the records

• verifies that generated items and changes in item locations are properly recorded in the 

MC&A record system in a timely manner

• can detect, with high probability, any real loss of items, or uranium from items 
43 NUREG-1065, Revision 3

The item monitoring system should conduct the following activities at least monthly:

• 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 system

records

• 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

• 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 MC&A plan should 

specify (1) minimum monitoring frequencies associated with each storage area, (2) discrepancy 

rates that trigger more frequent monitoring frequencies, and (3) commitments for resolving 

discrepancies.

8.6 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 (1) 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 11) of this document should be used to resolve item discrepancies. 

8.7 Commitments and Acceptance Criteria

In its MC&A plan, the licensee should provide definitive commitments that adhere to the 

regulatory requirements and meet the acceptance criteria applicable to maintaining current 

knowledge of items and detecting unauthorized removals. A finding that the licensee’s MC&A 

plan for the item control system is acceptable and in accordance with 10 CFR 74.31(c)(6), will 

be based on, but not limited to, the following acceptance criteria:

• 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 items that are produced, stored, processed, or otherwise handled 

together as a unit, such as a batch or sublot of material, may be 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.
NUREG-1065, Revision 3 44

• 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.

• Items that are excepted from the 10 CFR 74.31(c)(6) item control requirements fall into 

one of the following categories:

− Waste destined for burial or incineration;

− Solutions having less than a 5.00 grams 235U per liter concentration;

• 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.

• For items that are subject to the 10 CFR 74.31(c)(6) item control requirements, a record 

system will be maintained to provide knowledge of the current status of such items’

identity, uranium and 235U content, and stored location. For items subject to this 

commitment, the item control and records system provides the capability to promptly 

locate and confirm the existence of any specific item or group of items upon demand. 

The item record system is secured so that the record of an item’s existence cannot be 

destroyed or falsified by a single individual without a very high probability of detection.

• Each item subject to the 10 CFR 74.31(c)(6) item control requirements will be stored and 

handled in a manner that enables detection of or provides protection against 

unauthorized or unrecorded removals of SNM; knowledge of the SNM content is 

otherwise ensured by tamper-safing or maintaining the item as a sealed source (i.e., as 

encapsulated material).

• All incidents involving missing or compromised items or falsified item records will be 

investigated. A compromised item is one for which there is evidence of tampering or 

one that 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 predetermined by measurements (e.g., by nondestructive 

assay (NDA) or by weighing, sampling, and analysis). 
45 NUREG-1065, Revision 3

9. SHIPPER-RECEIVER COMPARISONS

9.0 Regulatory Intent

The intent of 10 CFR 74.31 (c)(7) is to require the licensee to conduct and document 

shipper-receiver comparisons for all special nuclear material (SNM) receipts, on a total 

shipment basis, and on an individual batch basis when required by 10 CFR Part 75, and ensure 

that any shipper-receiver difference (SRD) that is statistically significant and exceeds twice the 

estimated standard deviation of the difference estimator and 500 grams of 235U, is investigated 

and resolved.

9.1 Receiving Procedures

On receipt of SNM, the first action should be to verify the number of items, the item identities, 

and the integrity of individual items and of tamper-indicating devices (TIDs). All SNM shipments 

received from an external supplier are to be subject to shipper-receiver comparisons. Such 

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.

Previously, in approving material control and accounting (MC&A) plans, the U.S. Nuclear 

Regulatory Commission (NRC) staff has recognized situations in which the cost of conducting 

and documenting shipper-receiver comparisons outweighs the safety benefit of doing so, and 

has accordingly granted relief in the form of exemptions notwithstanding the 10 CFR 74.31(c)(7) 

provision that the requirement applies to “all SNM receipts.” Examples of situations in which 

such relief has been granted are:

• shipments containing less than 500 grams of 235U

• individual items containing less than 50 grams 235U

• encapsulated items, whose encapsulation integrity has not been compromised, and 

which the licensee is to retain as encapsulated items

• fuel assemblies and fuel rods that the licensee previously shipped and that are being 

returned, provided that the original encapsulation has not been compromised

• UF6 cylinders that are empty except for a heel quantity of UF6

• Heterogeneous scrap that must be subject to dissolution before a meaningful 

accountability measurement can be obtained. Both shipper and receiver should agree to 

accept the “after dissolution plus residue” measurements for accounting purposes.

In the future, should licensees seek similar relief from the 10 CFR 74.31(c)(7) requirements, 

specific exemption requests will need to be submitted in accordance with 10 CFR 74.7, “Specific 

Exemptions.” Whether granting such exemption requests are authorized by law and will not 

endanger life or property or the common defense and security, and are otherwise in the public 

interest, will be determined on a case-by-case basis.

For any SNM received, the licensee must provide all appropriate information on the 

U.S. Department of Energy (DOE)/NRC Form 741 that accompanies the shipment, in 
NUREG-1065, Revision 3 46

accordance with 10 CFR 74.15, “Nuclear Material Transaction Reports.” (Note: See 

NUREG/BR-0006, “Instructions for Completing Nuclear Material Transfer Reports (DOE/NRC 

Forms 741 and 740M),” for instructions and requirements for completing DOE/NRC Form 741.) 

9.2 Determination of Receiver’s Values

For UF6, the licensee may establish receiver’s values by (1) measuring the 235U isotopic 

concentration by nondestructive assay (NDA), (2) weighing each cylinder to determine net 

weight UF6 (gross weight minus certified cylinder tare weight), and (3) applying an historical 

established percent uranium factor (that is periodically confirmed or updated by measurement). 

This 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 usually can 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 identity 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.

The validity of the shipper’s data should be substantiated with appropriate and timely receiver 

checks and measurements, including gross weight, adequate sampling techniques, NDA 

measurements (if appropriate), and destructive measurements (scrap excepted). (See 

Chapter 4 on measurements.) Shipper’s values may be accepted and booked without receiver 

element or isotope measurements for encapsulated items, such as fuel elements or rods, if NDA 

measurement is not feasible.

9.3 Evaluation of Shipper-Receiver Differences

When shipper’s measurement uncertainty (or standard error) information is available, the 

following should define the estimated standard deviation of the difference estimator or combined 

standard error:

combined standard error = 

where

= shipper’s measurement standard error

= receiver’s measurement standard error
47 NUREG-1065, Revision 3

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 = 

= 1.414 

The difference between the shipper’s value and the receiver’s value (i.e., the SRD), in terms of 

the total shipment, must be considered significant whenever the SRD exceeds both 500 grams 

of 235U and twice the combined standard error. If subject to 10 CFR Part 75 (international 

safeguards), a SRD in excess of both 500 grams 235U and twice the combined standard error in

a single batch within the shipment also must be regarded as significant.

9.4 Resolution of Significant Shipper-Receiver Differences

The MC&A plan should describe the steps involved in investigating 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 the shipper’s and 

receiver’s weights differ by more than one-half of the total combined standard error.

9.5 Commitments and Acceptance Criteria

In its MC&A plan, the licensee should provide definitive commitments that adhere to the 

regulatory requirements and meet the acceptance criteria applicable to shipper-receiver 

comparisons. A finding that the licensee’s MC&A plan for conducting SRD evaluations and 

resolving significant SRDs is acceptable and in accordance with 10 CFR 74.31(c)(7), will be 

based on, but not limited to, the following acceptance criteria:

• Each shipping container is inspected within 5 working days after receipt for loss or 

damage to the container or TIDs to determine if SNM could have been removed. If the 

integrity of a container is questionable, the presence of all items that were packaged in 

the shipping container will be confirmed within 24 hours of discovering the questionable 

integrity. Only acceptable tamper-safing methods will be used as described in 

Section 11.1 of this document and as agreed to with the receiver.

• The receiver performs confirmatory measurements of scrap shipments 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 an SRD is based on statistical 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 
NUREG-1065, Revision 3 48

statistical analysis needed to evaluate the measurements. Investigation and resolution 

should be completed within 90 days of material receipt.

• Measurements of the quantity of SNM received in each shipment will be performed and 

the SRF will be tested for statistical significance. The element and isotope content of 

SNM shipped or received by the licensee are based on measurement systems subject to 

measurement control. Occurrences of significant SRDs in excess of 500 grams 235U and 

missing items will be reported promptly to the shipper.

• Measurement results for shipments and receipts will be 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 affect individual items by more than their rounding 

error in terms of 235U or uranium content.

• For SNM received, SRDs that are statistically significant and also greater than 

500 grams 235U, on a total shipment basis (and also on a batch basis when subject to 10 

CFR Part 75), will be detected within 30 calendar days of receipt. 

• The documentation of shipments and receipts should be completed and transmitted 

within the timeframe specified in NUREG/BR-0006.
49 NUREG-1065, Revision 3

10. ASSESSMENT AND REVIEW OF THE MATERIAL CONTROL 

AND ACCOUNTING PROGRAM

10.0 Regulatory Intent

The intent of 10 CFR 74.31(c)(8) is to require independent assessments of the MC&A program. 

Licensee management must periodically (at least every 24 months) review and assess the 

performance of the material control and accounting (MC&A) program, evaluate its effectiveness, 

and document management’s action on prior assessment recommendations and any identified 

deficiencies. It is intended that the review will be performed by knowledgeable, technically 

competent individuals free from conflicts of interest. Further, 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—including that of 

any contractor that performs MC&A measurements on the licensee’s behalf—must be made.

10.1 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 MC&A plan should 

describe the assessment and review program in terms of:

• maximum interval between assessments

• selection procedures for the assessment team

• number of team members to be selected

• qualification and expertise of team members

• independence of individual team members from the MC&A responsibilities and activities 

they are reviewing and assessing

• 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 program, individual 

subsystems should be assessed at intervals no greater than 12 calendar months. The schedule 

should ensure the entire program is reviewed over the course of 24 calendar months. Thus, the 

type of assessment (partial or total) and the maximum interval between assessments should be 

specified in the MC&A plan. “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 
NUREG-1065, Revision 3 50

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 program 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 program 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 depend 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 

program they review. The team should have authority to investigate all aspects of the MC&A 

program 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. 

10.2 Report of Findings and Recommendations

The areas to be reviewed should encompass the entire MC&A program, 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 program’s effectiveness. The team report, as a 

minimum, should state findings pertaining to:

• organizational effectiveness to manage and execute MC&A activities

• management responsiveness to indications of possible losses of uranium

• staff training and competency to carry out MC&A functions

• reliability and accuracy of accountability measurements made on special nuclear 

material (SNM)

• effectiveness of the measurement control system in monitoring measurement systems 

and its sufficiency to meet the requirements for controlling and estimating both bias and 

the standard error of the inventory difference (SEID)

• soundness of the material accounting records

• effectiveness of the item control system to track and provide current knowledge of items

• capability to promptly locate items and effectiveness in doing so

• timeliness and effectiveness of SRD evaluations and resolution of excessive SRDs

• soundness and effectiveness of the inventory-taking procedures
51 NUREG-1065, Revision 3

• capability to confirm the presence of SNM

• 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 that the assessment affects.

10.3 Management Review and Response to Report Findings and Recommendations

Management should review the assessment report and take the necessary actions to correct 

MC&A program deficiencies. The management review should be documented within 

30 calendar 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 MC&A plan should address resolution and followup 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.

10.4 Commitments and Acceptance Criteria

In its MC&A plan, the licensee should provide definitive commitments that adhere to the 

regulatory requirements and meet the acceptance criteria applicable to independent 

assessments of the MC&A program. A finding that the licensee’s MC&A plan for such 

assessments is acceptable and in accordance with 10 CFR 74.31(c)(8), will be based on, but 

not limited to, the following acceptance criteria:

• The capabilities and performance of the MC&A program 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 or assessment to the 

completion of the next will not exceed 24 calendar months.

• The periodic assessments will be comprehensive and sufficiently detailed to enable the 

assessment team to rate the MC&A program effectiveness, capability, and performance 

by comparison with the expected and required performance. The overall assessment 

objectives are to determine that the MC&A program, as designed and implemented, is 

continuing to meet the overall safeguards goals, and to identify weaknesses or 

deficiencies in the program 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 program effectiveness, which includes:

o Organizational effectiveness and management responsiveness to indicators of 

possible SNM losses

o Staff training and competency to carry out MC&A functions

o Soundness of the material accounting records
NUREG-1065, Revision 3 52

o Capability to promptly locate items

o Timeliness and effectiveness of SRD evaluations and resolution of significant 

SRDs

o Soundness of physical inventory procedures and practices

o Effectiveness of the measurement control system 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

o Capability to confirm the presence of SNM

o 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

• Qualified individuals from outside or qualified individuals from inside the facility 

organization whose work assignments and positions within the organization will not

impair their ability to make objective judgments of the MC&A program capabilities and 

performance perform the reviews and assessments. Personnel assigned to the 

assessment team will have an adequate understanding of the regulatory objectives and 

requirements of the MC&A program and will have sufficient knowledge and experience 

to be able to judge the adequacy of the parts of the program 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.

• An individual team member will not participate in the assessment of any part of the 

MC&A program for which he or she has direct responsibility. Also, an individual “A” will 

not assess any part of the program that is the responsibility of person “B” if “B” is 

assessing an area under the responsibility of “A.”

• The entire MC&A program 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 program and is demonstrated to be able to include any 

such changes made during the review or assessment). Conducting two or more 

assessments during a 24-month interval, in which only part of the MC&A program 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 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 assessment team leader will have no 

responsibility for managing or performing any of the MC&A functions.

• The responsibility and authority for the assessment program and for initiating corrective 
53 NUREG-1065, Revision 3

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 onsite plant manager.

• Each overall review and assessment will be conducted and completed in a time frame 

that is short (e.g., a week) with respect to the time for changes that have occurred in the 

MC&A program, and will include any such changes made during the time the review or 

assessment is being conducted.

• The completion date for any review or 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 or interview MC&A personnel, and such start date will be documented.

• The results of the assessment and recommendations for corrective action, if any, will be 

documented and reported to the plant manager and other managers that the 

assessment affects. Management will review the assessment report and take the 

necessary actions to correct MC&A program deficiencies. Such corrective actions 

(if any) that pertain to daily or weekly activities will be initiated within 40 calendar days 

after the submittal of the review or assessment final report.

• Management’s response to recommendations from the review and assessment, 

including any corrective actions that management ordered, and the expected time frame 

for completing such actions, will be documented within 30 calendar days following the 

submittal of the team’s report.

55 NUREG-1065, Revision 3

11. TAMPER-SAFING

11.0 Regulatory Intent

The intent of 10 CFR 74.31(c)(9) is to require licensees to maintain and follow tamper-safing 

procedures for special nuclear material (SNM) containers and vaults, including controlling

access to, and distribution of, unused seals and records. The purpose of such procedures is to

document the distribution, application, and destruction of tamper-safing devices, as well as

routine inventory of unused tamper-safing devices. Records are to be retained for at least 

3 years (or longer if specifically required by regulations external to 10 CFR 74.31) thereby 

providing a way to assess the performance of the tamper-safing program and inspect for 

compliance with regulatory requirements.

11.1 Characteristics of Tamper-safing Devices

Tamper-safing devices on containers or vaults are used to secure the integrity of SNM either 

when it is in transit or stored on site. The objective of tamper-indicating devices (TIDs) is to 

ensure that no tampering or entry has occurred while the TID is on the container. Therefore, for 

MC&A purposes, the degree of confidence in the selection of a TID sealing system will vary 

depending on its unique characteristics and intended use.

When selecting tamper-safing devices, licensees should consider the following:

• Intended use–the determination that the TID is appropriate for tamper-safing the 

container and withstanding the working environment, (i.e., temperature, moisture, 

repeated handling).

• Application–the relative ease or difficulty of physically applying the TID.

• Substitution–the ability of a TID to be destructively removed and replaced by a new TID

without detection.

• Removal and reapplication–the ability of a TID to be removed and reapplied without 

detection.

• Alteration of label data–the ability to alter recorded data on the TID without the alteration 

being apparent.

• Integrity verification–the degree of effort required to verify the TID is intact or indicates 

tampering.

The licensee should confirm manufacturer claims that the removal of a TID is not possible 

without detection by testing potential TIDs to see if they can be removed from the containers on 

which they are to be used. The licensee should confirm the results using the manufacturer’s 

documented procedures and the samples used. The experiments should be documented, both 

with regard to what techniques were used to attempt to defeat the TID and observations as to 

the degree of success in defeating the TID. In lieu of licensee testing, similar tests that an 

independent third party conducted may be considered acceptable.
NUREG-1065, Revision 3 56

11.2 Use of Tamper-safing Devices

The MC&A plan may allow the use of tamper-safing devices to:

• Ensure the long-term validity of measurement data—the application of a TID to an item 

containing measured quantities of nuclear materials may allow the licensee to maintain 

the validity of the original measured value, thus eliminating or decreasing the frequency 

of the need to remeasure the items to verify its nuclear material content.

• Reduce the effort to conduct physical inventories or item control activities—the 

application of a TID to a container housing multiple items may allow the licensee to 

maintain the validity of container’s contents, thus minimizing the number of items 

required to be verified during a physical inventory or item control activity.

• Provide assurance of integrity of in-transit material—the application of a TID to a 

shipping container may allow the licensee to maintain the validity of a shipping 

container’s contents and ensure that the integrity of the shipment has not been violated. 

To achieve this goal, the shipper should apply the TID(s) to the shipping container, verify 

the integrity of the TID(s) shortly before departure of the shipment, and provide the 

appropriate information (i.e., shipping container serial numbers, TID(s) type(s), and 

serial number(s)) to the receiver. Upon receipt of the shipment, the receiver should 

verify the shipping container serial numbers, TID(s) type(s), serial number(s), and the 

TID(s) integrity. Any discrepancies should be considered an MC&A anomaly and be 

addressed by the facility’s MC&A resolution program.

11.3 Description of Tamper-safing Records

The tamper-safing system should identify all records, forms, reports, and standard operating 

procedures used throughout the system. Such records should include, but are not limited to, 

the following:

• receipt of purchased TIDs

• issuance of TIDs

• identification of the person applying the TIDs

• identification of the person who verified the application of the TID

• identification of the container to which the TID was applied, including the TIDs serial 

identification (if applicable)

• removal and destruction of TIDs

• routine inventory of unused and unissued TIDs

• identification of roles and responsibilities, including:

• designation of the TID control officer(s)

• personnel approved to apply, verify, and destroy TIDs
57 NUREG-1065, Revision 3

• training of personnel in the application, verification and destruction of TIDs

11.4 Commitments and Acceptance Criteria

The acceptability of a TID is based on an evaluation of the attributes of the device in relation to 

time to defeat the tamper-indicating features. TIDs that the U.S. Nuclear Regulatory 

Commission (NRC) already deems acceptable include: Type E, pressure-sensitive, tamperevident wire seals, fiber optic seals and steel padlocks. Other tamper-safing devices may be 

equally acceptable. Licensees proposing to use TIDs not currently approved by the NRC must

provide the appropriate information, including references, to enable licensing reviewers to 

assess the adequacy of the proposed TID type.

In its MC&A plan, the licensee should provide definitive commitments that adhere to the 

regulatory requirements and meet the acceptance criteria applicable to the use of tamper-safing 

devices. A finding that the licensee’s MC&A plan for tamper-safing is acceptable and in 

accordance with 10 CFR 74.31(c)(9), will be based on, but not limited to, the following 

acceptance criteria:

• Only TIDs that are controlled and accounted for will be used to maintain the validity of 

previously established SNM quantities associated with items.

• Written procedures will be maintained to ensure that individuals authorized to handle 

TIDs are properly trained.

• Preferably a single individual, but no more than three individuals, none of whom have 

any responsibility for seal application or destruction, is (are) designated as the TID

control officer(s).

• Only individuals authorized for that purpose will apply and remove TIDs.

• Unused TIDs will be controlled and inventoried. Unissued TIDs are stored in a locked 

container within a room that is locked when unoccupied or in an approved repository. 

Blocks of TIDs issued to designated individuals are stored in a locked container within a 

room that is locked when unoccupied or in an approved repository.

• When TIDs are not in storage they are in the possession of authorized individuals 

(i.e., the TID control officer or person responsible for applying the TID). As a rule, the 

number of available TIDs issued to these individuals should be limited to a single day’s 

use.

• The licensee has in his possession a commitment from the seal manufacturer that plates 

and/or dies and production residuals are controlled and protected, and

• Upon removal, TIDs are destroyed (i.e., crimped, flattened, or otherwise rendered 

unusable) and properly disposed.

• Records of TID application, verification, removal, and destruction will be documented, 

and control measures will be implemented to prevent alteration of records for containers 

protected by TIDs.

59 NUREG-1065, Revision 3

12. DESIGNATION OF MATERIAL BALANCE AREAS, ITEM 

CONTROL AREAS, AND CUSTODIANS

12.0 Regulatory Intent

The intent of 10 CFR 74.31(c)(10) is to ensure that the material balance areas (MBAs) and item 

control areas (ICAs) that licensees designate will enable them to identify inventory differences 

(IDs) and item locations on a scale smaller than that of the entire plant. Regulations in 

10 CFR 74.31(c)(10) require licensees to designate MBAs and ICAs and assign custodial 

responsibilities for these areas, and to provide internal controls to deter or detect any diversion 

or misuse of special nuclear material (SNM) at the licensee’s facility. 

12.1 Material Control Boundaries

The MC&A plan should describe how the licensee establishes various material control 

boundaries to minimize the occurrence of, and facilitate resolution of, MC&A anomalies. 

Examples of such anomalies are inventory differences (IDs), missing SNM items, and potential 

theft or diversion of SNM.

Because MBAs and ICAs are important foundations for controlling and accounting for all SNM in 

a facility, the MC&A plan should describe the process for how their locations are chosen. An 

MBA or ICA should correlate to physical or administrative boundaries and monitored locations. 

The MBA or ICA should be designed to limit losses to a specific area (i.e., the MBA should not 

be so large that the licensee cannot localize inventory or process differences to a manageable 

level). Materials transferred into and out of an MBA or ICA must be subject to quantitative 

measurements, as specified in the definitions of MBAs and ICAs in 10 CFR 74.4, “Definitions.”

12.2 Custodians

The MC&A plan should describe the roles and responsibilities of the custodians for MBAs and 

ICAs. Each custodian should have direct interaction with the MC&A organization, and such 

individuals should be located within the physical operations area. Custodians who are 

responsible for more than one MBA or ICA should not have the authority to make material 

transfers between MBAs or ICAs that are both under their direct control.

12.3 Commitments and Acceptance Criteria

In its MC&A plan, the licensee should provide definitive commitments that adhere to the 

regulatory requirements and meet the acceptance criteria applicable to the designation of 

MBAs, ICAs, and custodians. A finding that the licensee’s MC&A plan for designating MBAs, 

ICAs, and custodians is acceptable and in accordance with 10 CFR 74.31(c)(10), will be based 

on, but not limited to the following acceptance criteria:

• MBAs and ICAs should have defined physical and administratively controlled areas that

allow for the physical and administrative control of nuclear materials such that the 

quantity of nuclear materials being moved into or out of the MBA is a 

measurement-based assigned value for element and isotope contents.

• MBAs and ICAs are established in such a way as to minimize the occurrence of, and 

facilitate the resolution of, MC&A anomalies.
NUREG-1065, Revision 3 60

• MBA and ICA structures are properly documented and clearly described, including 

physical boundaries and categories of material in the individual MBA or ICA. 

• Custodial responsibilities are assigned for each designated MBA and ICA.

• Custodians responsible for more than one MBA or ICA are not authorized to transfer 

material between MBAs and ICAs under their control.
61 NUREG-1065, Revision 3

13. RESOLVING INDICATIONS OF LOSS, THEFT, DIVERSION, 

OR MISUSE OF SPECIAL NUCLEAR MATERIAL

13.0 Regulatory Intent

The intent of the 10 CFR 74.3(b) and (c) general performance objectives is for licensees to be 

able to promptly investigate and resolve any indications of a possible loss, theft, diversion or 

misuse of special nuclear material (SNM), whether arising from errors or deliberate actions.

13.1 Methods and Procedures for Identifying Indicators

The material control and accounting (MC&A) plan should discuss the way that the licensee will 

resolve indicators of a possible loss, theft, diversion or misuse of SNM. The licensee’s 

resolution program should address the possible indicators of missing uranium. The MC&A plan 

should enumerate all the potential indicators that can be postulated and develop resolution 

procedures for each. Any anomaly could potentially be an indicator of loss, theft, diversion, or 

misuse of SNM. An anomaly is an unusual observable condition (such as excessive 

discrepancies, missing items, broken tamper-indicating devices (TIDs), or other possible 

indicators) that might result from theft, diversion, or other misuse of SNM. The terms “indicator” 

and “anomaly” may be used interchangeably to describe a condition that may require further 

investigation to determine if an actual loss, theft, diversion, or misuse of SNM occurred.

The following are examples of possible indicators of missing SNM:

• lack of agreement between a physical inventory and its associated book inventory in 

which the 235U inventory difference (ID) is positive and exceeds 1.7 times the standard 

error of the inventory difference (SEID) by more than 500 grams

• determination through the item control system that one or more items are not in their 

designated locations and the actual locations are not immediately known

• discovery that an item’s integrity or its TID was compromised

• information from the process control system indicating potential loss of material from the 

process system

• an allegation of theft or diversion 

13.2 System and Procedures for Investigating and Resolving Loss Indicators

One or more MC&A procedures should address the system and practices for investigating and 

resolving loss indicators. The licensee should have well-defined procedures for promptly 

investigating and resolving indications of possible missing SNM, and procedures for rapidly 

determining whether an actual loss of SNM has occurred. These procedures should include 

criteria for determining when an investigation of loss indicators can be concluded. 

Resolving a loss indicator means that the licensee has made a determination that loss, including 

possible diversion 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 MC&A plan. 
NUREG-1065, Revision 3 62

Any investigation of an indication of a loss or theft should provide, whenever possible, (1) 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 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 

way 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 U.S. Nuclear Regulatory Commission 

(NRC) within 1 hour of its determination in accordance with 10 CFR 74.11, “Reports of Loss or 

Theft or Attempted Theft or Unauthorized Production of Special Nuclear Material.” The MC&A 

plan should specify the time allowed for resolution. In general, a time not exceeding 72 hours 

should be adequate.

13.3 Response Actions for Unresolved Indicators

Response actions to unresolved indicators should be clearly defined and on a graded scale 

appropriate to the level of potential safeguards significance. The responsibility and authority for 

initiating and executing such escalating levels of response actions also should be defined.

For indicators of missing SNM, the level of safeguards concern is related to such factors as:

• the potential quantity of 235U involved

• 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, U3O8, uranyl nitrate solution, UF6, scrap, or waste)

13.4 Documentation Requirements

The MC&A plan should identify all documentation requirements associated with the licensee’s 

program for the reporting, investigation, and resolution of missing SNM indicators. Review and 

approval requirements and document custodial responsibility also should be defined. As a 

minimum, documentation of the following should be included:

• investigation procedures

• resolution procedures

• reporting of the indicator to MC&A management, including date and time the indicator 

was reported, name of individual who discovered the indicator, and description of 

indication
63 NUREG-1065, Revision 3

• investigation findings and conclusion, including resolution status, date issued, name and 

signature of principal investigator, and approval signature of MC&A manager

• reports made to the 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 the NRC individual contacted.

Additional types of information that may be necessary are described in Section 14.3 of this 

document. 

13.5 Commitments and Acceptance Criteria

In its MC&A plan, the licensee should provide definitive commitments that adhere to regulatory 

requirements and meet the acceptance criteria applicable to investigating and resolving 

anomalies indicating possible SNM misuse. A finding that the licensee’s MC&A plan for 

resolving indications of loss, theft, diversion, or misuse of SNM is acceptable and in accordance 

with 10 CFR 74.3(b) and (c), will be based on, but not limited to the following acceptance 

criteria:

• Adequate commitments are provided to ensure a high probability that any indicator of 

missing SNM will be (1) recognized as an indicator, (2) investigated, and (3) resolved.

• The licensee will conduct a prompt investigation for all indications of possible loss, theft, 

diversion, or misuse of SNM.

• A cause or probable cause that is based on objective evidence will be assigned to each 

indication of possible loss that the licensee investigates.

• Investigation and resolution procedures will provide for adequate overchecks to ensure 

that no individual who could have been responsible for a possible loss or theft of SNM 

would be the sole or primary individual responsible for resolving the indicator.

• No investigation relative to an indication of an SNM loss or theft exceeding the current 

detection quantity (DQ) should be declared as completed but unresolved without first 

conducting a shutdown, cleanout inventory in which all unsealed SNM is remeasured for 

element and isotope.

• The licensee will report the results of all investigations of alleged thefts, and any 

indications of a loss of SNM that remains unresolved after 30 calendar days, to the 

appropriate NRC MC&A licensing authority.

65 NUREG-1065, Revision 3

14. INFORMATIONAL AID FOR ASSISTING IN THE 

INVESTIGATION AND RECOVERY OF 

MISSING SPECIAL NUCLEAR MATERIAL

14.0 Regulatory Intent

The intent of 10 CFR 74.3(d) general performance objective is for licensees to have ready and 

provide to investigators any information deemed relevant to the recovery of special nuclear 

(SNM) involved in a loss or theft. The burden is on the licensee to provide (without being 

asked) all information that it recognizes as being relevant, as opposed to only providing 

information that the investigators are knowledgeable enough to request. This objective pertains 

to investigations and recovery operations, relating to actual (or highly suspected) events 

pertaining to missing SNM, which would be conducted by the U.S. Nuclear Regulatory 

Commission (NRC) or other government agencies, such as the Federal Bureau of 

Investigations. 

The 10 CFR 74.3(d) performance objective states that the licensee must be able to provide, in a 

timely manner, information to aid in the investigation and recovery of missing SNM in the event 

of an actual loss, theft, diversion or misuse. 

14.1 Types of Information

The kinds of information that may aid the investigation and recovery effort are:

• data or observations that led the licensee to determine that a loss or theft of uranium 

may have occurred

• data, observations, and assessments associated with attempts to resolve the indication 

of missing material 

• the time period during which the material may have left the facility

• the path and means by which the material may have left the facility

14.2 Information Indicating Possible Losses of SNM

Information indicating that a loss of uranium may have occurred can come from process or 

production yield data, physical inventory results, item control activities, or shipper-receiver 

comparisons. This information could include:

• material accountability data records and reports

• inventory records

• inventory difference (ID) and propagation of error calculations

• inventory reconciliation reports
NUREG-1065, Revision 3 66

• indications of unrecorded or unauthorized removals of SNM from storage or process 

locations

• reports of apparent destruction or falsification of records pertaining to SNM 

• records of broken tamper-indicating devices (TIDs) or compromised item integrity

• indications of unauthorized entry into SNM storage areas

• reports from monthly item status inspections

• material receipt and log records

• results from shipper-receiver difference (SRD) evaluations

• process quality assurance or production control records

• documentation relating to an alleged or confirmed theft

14.3 Information on Resolving Indications of Missing SNM

Information associated with resolving indications of missing SNM is provided in Chapter 13. 

This information and information that may aid in the recovery of missing material would include:

• the type of unauthorized activity detected

• the interval during which the loss may have occurred

• the amount of material and form of the material involved in the loss

• results of measures to validate indicators

• results of extended measures to resolve indicators

• results from special inventories (or re-inventories) and tests performed

• audit results of the SNM accountability source data

• assessments of measurement data and measurement controls

• results from reviews of the material control and accounting (MC&A) program and status 

of corrective actions

• history of indicator investigation and resolution activities

• anomaly investigation and resolution procedures and conclusions

• probable cause of the loss
67 NUREG-1065, Revision 3

• any abnormal events that may have contributed to or caused the loss

• 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 15.

14.4 Commitments and Acceptance Criteria

In its MC&A plan, the licensee should provide definitive commitments that adhere to regulatory 

requirements and meet the acceptance criteria applicable to providing information to assist in 

the investigations and recovery of missing uranium or unauthorized production. A finding that 

the licensee’s MC&A plan for providing informational aid is acceptable and in accordance with 

10 CFR 74.3(d), will be based on, but not limited to the following acceptance criteria:

• Procedures are in place for the efficient and timely gathering of relevant information to 

be provided to government investigators to aid them in the investigation and recovery 

activities associated with missing SNM.

• Information will be provided to appropriate government authorities to aid them in their 

investigation of indications or allegations of missing material and in the recovery of SNM 

in the event of a loss that could include theft or diversion.

69 NUREG-1065, Revision 3

15. RECORDKEEPING

15.0 Regulatory Intent

The intent of 10 CFR 74.31(d) is to require the licensee to establish and maintain records that 

demonstrate that the general performance objectives of 10 CFR 74.3 and the 

10 CFR 74.31(a)-(c) requirements have been met. Records should include those documenting 

the:

• receipt, shipment, disposal, and current inventory of special nuclear material (SNM) held 

under license

• quantities of SNM added to and removed from process 

• shipper-receiver evaluations associated with SNM receipts

Records must be retained for at least 3 years (or longer if specifically required by regulations 

external to 10 CFR 74.31), thereby providing a way for assessing the MC&A program 

performance and inspecting for compliance with regulatory requirements. However, in 

accordance with 10 CFR 74.19(b), material control and accounting (MC&A) procedures (as 

documented in licensee records) must be retained until the Commission terminates the license.

15.1 Description of Records

The MC&A plan should identify all records, forms, reports, and standard operating procedures 

that show compliance with the requirements of 10 CFR Part 74. Such records should include, 

but are not limited to, the following:

• documents that define changes in the MC&A management structure or changes in 

responsibilities relating to MC&A positions

• procedures pertaining to any accountability-related measurement or sampling operation

• forms used to record or to report measurement data and measurement results, including 

source data

• forms and notebooks used to record calibration data associated with any accountability 

measurement system

• forms and notebooks used to record quantities, volumes, and other data associated with 

the preparation of standards, both calibration and control, used in connection with

accountability measurement systems

• forms and official memos used to record or report measurement control system data, 

control limit calculations, and out-of-control investigations

• forms listing and providing instructions associated with physical inventories

• forms and formal worksheets used in the calculation of standard error of the inventory 

difference (SEID), inventory difference (ID), and active inventory values
NUREG-1065, Revision 3 70

• ledgers, journals, and computer printout sheets associated with the accountability 

system

• ledgers, journals, and computer printout sheets associated with the item control system,

including seal usage and “attesting to” records

• U.S. Department of Energy/U.S. Nuclear Regulatory Commission (DOE/NRC)

Forms 741 and 742 and NRC Form 327

• forms, memos, and reports associated with identification of, investigation of, and

resolution of significant shipper-receiver differences (SRDs)

• loss indication and alleged theft investigation reports

• investigation reports pertaining to excessive IDs

• official reports containing the findings and recommendations of MC&A program

assessments and any letters or memos pertaining to response actions to assessment 

team recommendations

• forms used for recording data associated with the item monitoring program

• monitoring program status or summary reports

• records of training sessions, including date given, topics covered, name of instruction(s), 

and names and signatures of those attending

• training, qualification, and requalification reports and records

Examples of the more important MC&A forms should be provided in the MC&A plan annex or 

appendix. The retained records and reports should contain sufficient detail to enable NRC 

inspectors to determine that the licensee has met the requirements of 10 CFR 74.31(a)-(c), and 

has met the general performance objectives of 10 CFR 74.3.

15.2 Program and Controls for Ensuring an Accurate and Reliable Record System

The MC&A 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:

• the auditing system or program to verify the correctness and completeness of records

• the overchecks for preventing or detecting missing or falsified data and records

• the plan for reconstructing lost or destroyed SNM records

• the access controls used to ensure that only authorized persons can update and correct 

records
71 NUREG-1065, Revision 3

• the protection and redundancy 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 74.3.

15.3 Commitments and Acceptance Criteria

In its MC&A plan, the licensee should provide definitive commitments that adhere to the 

regulatory requirements and meet the acceptance criteria applicable to recordkeeping. 

A finding that the licensee’s MC&A plan for the recordkeeping system is acceptable and in 

accordance with 10 CFR 74.31(d) will be based on, but not limited to, the following acceptance

criteria:

• Access to MC&A information will be controlled to provide deterrence and detection of 

theft, diversion, misuse, or radiological sabotage involving SNM.

• A record retention system is maintained for those records necessary to show that the 

MC&A system requirements of 10 CFR 74.31(c) have been met. Such records are 

retained for at least 3 years, unless a longer retention time is specified by 

10 CFR 74.15(b), 10 CFR Part 75, “Safeguards on Nuclear Material—Implementation of 

US/IAEA Agreement,” or by a specific license condition. The records referred to in 

10 CFR 75.22, “Accounting Records,” and 10 CFR 75.23, “Operating Records,” and 

generated during any period that the facility is under International Atomic Energy Agency 

(IAEA) safeguards will be retained for at least 5 years. Records of the following will be 

maintained current and will be retained for at least 3 years:

o Management structure, MC&A job descriptions, and MC&A policies and 

procedures

o Accounting source data records (accounting source data normally consist of 

shipping and receiving forms, physical inventory forms, and the forms used for 

initially recording measurement and measurement control data)

o Records of shipments and receipts and investigations of significant SRDs plus 

the information used to resolve them

o Measurement data for receipts, shipments, discards, and inventory 

o Calibration of measurement systems, measurement control data, bias estimates, 

and the statistical analyses of the measurement control data

o Data used to demonstrate that the measurement system performance achieves 

the SEID limits that 10 CFR 74.31(c)(4) requires

o Physical inventory listings and inventory work sheets

o 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 the 

detection quantity (DQ))
NUREG-1065, Revision 3 72

o Calculations of the SEID and information used to reconcile an excessive ID

(i.e., an ID that is greater than or equal to 3.00 times the SEID)

o Reports of investigations and resolution of indications of loss of SNM

o The results of independent assessments and management action taken to 

correct any deficiencies identified 

• 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.

• All SNM transactions from source data to final accounting records will be readily 

traceable.

• 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 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 permit traceability 

to the sources of the variances because of 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 to meet time restraints relative to 

their use. In general, the record retention system should 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 8.7.

• Overchecks or other controls, including access controls for updating and correcting 

records, are provided to prevent or detect errors in the records that would affect ID and 

item location.
73 NUREG-1065, Revision 3

16. GLOSSARY

The following terms are defined in the context of (1) their usage in this document or (2) how they 

should be used if contained in the material control and accounting (MC&A) plans submitted in 

accordance with 10 CFR 74.31, “Nuclear Material Control and Accounting for Special Nuclear 

Material of Low Strategic Significance.”

ACTIVE INVENTORY (AI)–The sum of beginning inventory (BI), additions to inventory (A), 

removals from inventory (R), and ending inventory (EI), after all common terms have been 

totally excluded. A common term is any special nuclear material (SNM) 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 (ID)). The active inventory is used as an 

indicator of processing throughput or measurement activity.

ADDITIONS TO INVENTORY–Quantities of SNM, of a given material type code, added to a 

plant inventory and which, before such addition, were not part of the plant’s total possessed 

quantity for the material type code in question.

ARTIFACT STANDARD–A container or item of certified mass, having a size, shape; and mass 

that is representative of a particular type of process related item or container (e.g., a UF6

cylinder). Weighing error that buoyancy causes is eliminated through the use of artifact 

standards for scale calibrations.

ASSIGNED VALUE–A value for mass, volume, SNM concentration, SNM quantity, etc., 

assigned to a standard weight, standard material, etc.; used for calibrating or controlling a 

measurement device or system. An assigned value may not necessarily be a certified value, 

but if not, it should be traceable to a certified standard. In any event, it is the best estimate of 

the standard’s true value.

BEGINNING INVENTORY (BI)–The total itemized quantity of SNM of a given material type code 

possessed by a “plant” at the start of a material balance period (inventory period). The BI 

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 unidirectional component of error that affects (to the same 

degree) all members of a measurement data set. A bias can thus 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. If a bias is large enough to have an effect on the 

recorded value of SNM items, the accountability values of such items should be appropriately 

adjusted. If a bias is too small to affect individual items, its effect across all measured items (or 

material quantities) should be determined as an absolute quantity (e.g., as grams U and grams 

235U). The net sum of all biases (as absolute quantities) not applied as corrections to individual 

items is then applied as a bias correction to ID.

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.
NUREG-1065, Revision 3 74

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 or certifies standards.

CHECK STANDARD (BENCH STANDARD, WORKING STANDARD)–A standard, not

necessarily traceable to a primary standard, which is used routinely (e.g., daily or weekly) to 

check (or verify) the reliability of a measurement device, instrument, etc. (including those of 

accountability measurement systems). Such standards are not, however, used for the actual 

calibration or control of accountability measurement systems.

COMBINED STANDARD ERROR–An error band derived from the respective standard error 

values associated with each of two measurements (usually independent of each other) 

performed on a given material quantity. For both measurement values (of the pair) to be 

regarded as being in agreement, they must not differ from each other by more than the 

calculated combined standard error, which is normally calculated by taking the square root of 

the sum of squared individual standard errors. That is:

combined S.E. = [(σ1)

2 + (σ2)2

]

1⁄2

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 or isotope quantity assigned to such item. 

Confirmatory measurements are sometimes used as the basis for concluding that previous 

measurement values for uranium and 235U (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.

DEPLETED URANIUM–Any uranium-bearing material whose combined 233U plus 235U isotopic 

content is less than 0.70 weight percent (wt %) (relative to total uranium elemental content).

DETECTION QUANTITY (DQ)–A site-specific 235U quantity for licensees subject to 

10 CFR 74.31, “Nuclear Material Control and Accounting for Special Nuclear Material of Low 

Strategic Significance,” or 10 CFR 74.33, “Nuclear Material Control and Accounting for Uranium 

Enrichment Facilities Authorized to Produce Special Nuclear Material of Low Strategic 

Significance.” The DQ is normally a function of annual throughput, but for low throughput 

low-enriched uranium (LEU) facilities, the DQ need not be less than 25 kilograms of 235U. 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) power of detection whenever a physical inventory is taken.

DETECTION THRESHOLD (DT)–An 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 DQ. 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)
75 NUREG-1065, Revision 3

ENDING INVENTORY (EI)–The total-itemized quantity of SNM of a given material type code 

possessed by a “plant” at the end of a material balance period, as determined by a physical 

inventory. The EI quantity for any given material balance period is (by definition) exactly equal 

to the BI quantity for the next period.

ENRICHED URANIUM–Any uranium-bearing material that does not qualify as natural or normal 

uranium, and whose combined 233U plus 235U isotopic content is 0.725 percent or higher by 

weight, relative to total uranium element content.

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 or prior period adjustment associated with the ID 

value.

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 byproduct 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 codes have been assigned as follows:

CODE MATERIAL TYPE

10 depleted uranium

20 enriched uranium (*)

50 plutonium

70 uranium-233 (**)

83 plutonium-238 (***)

88 thorium

89 uranium in cascades

(*) For U.S. Department of Energy/U.S. Nuclear Regulatory Commission (DOE/NRC) Form 742 

purposes, material code 20 has four subcodes (E1, E2, E3, and E4) to denote enrichment 

range. For NRC Form 327 purposes, code 20 has two subcodes, namely LEU and highenriched uranium (HEU).

(**) Uranium materials should be regarded as material code 70 if the 233U isotopic distribution is 

greater than (1) 10.00 wt % relative to total uranium element content, or (2) both the 235U

isotopic concentration and 5.00 percent by weight of the total uranium; otherwise report as 

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

(***) Plutonium materials should be regarded as material code 83 if the 238Pu isotopic 

distribution is greater than 10.00 wt % relative to total plutonium element content. Otherwise,

report as material code 50.

MEASURED DISCARD (MD)–A measured quantity of gaseous, liquid, or solid waste that a 

facility no longer possesses, or which has been transferred (accounting-wise) to a waste 
NUREG-1065, Revision 3 76

holding-account through a DOE/NRC Form 741 transaction. (Reference 10 CFR 74.13(a) for 

reporting of waste holding account.)

MEASUREMENT CONTROL SYSTEM–A managed system 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 % 

238U, 0.711 wt % 235U, and 0.006 wt % 234U.

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 233U plus 235U and (2) 

at least 99.200 wt % in 238U. (Note: All natural uranium having a 235U isotopic abundance in the 

range of 0.700 wt % to 0.724 wt % is normal uranium, but not all normal uranium is natural 

uranium.)

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), 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 internationally recognized bureau, laboratory, etc., that 

issues or certifies standards.

PRIOR PERIOD ADJUSTMENT–Any correction (i.e., adjustment) to an ID value because of a 

correction applied to a component of BI after the inventory period started. Such corrections may 

be because of the resolution of an 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 BI 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) 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.

RESIDUAL HOLDUP–Any SNM that remains within processing equipment (including ventilation 

filters and ductwork) after system draindown or cleanout. If, at the time of physical inventory, 

the total quantity of residual holdup is significant, such holdup must be measured (or estimated 

on the basis of partial measurements and engineering calculations) and included in the physical 

inventory listing. The uncertainty associated with a total measured or estimated residual holdup 

quantity must be included in the calculation of the SEID.
77 NUREG-1065, Revision 3

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 (of SNM) and what the receiving facility 

claims was received, where both shipper and receiver values are based on measurement.

STANDARD–See definitions for CERTIFIED STANDARD, CHECK STANDARD, CONTROL 

STANDARD, PRIMARY STANDARD, and STANDARD REFERENCE MATERIAL.

STANDARD DEVIATION–The random error (at the 67 percent confidence level) associated 

with a single value of a data set, which in turn 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: 

standard deviation = S = 

where 

n = number of measurements performed 

xi = the value obtained for the ith 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 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.

VERIFICATION MEASUREMENT–(1) A nondestructive assay (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).

79 NUREG-1065, Revision 3

17. REFERENCES

International Atomic Energy Agency (IAEA), IAEA Safeguards Statistical Concepts and 

Techniques, 4th revised edition, 1989, Vienna, Austria.

NUREG/BR-0006, “Instructions for Completing Nuclear Material Transfer Reports (DOE/NRC 

Forms 741 and 740M),” Revision 7, June 2008.

NUREG/BR-0007, “Instructions for the Preparation and Distribution of Material Status Reports 

(DOE/NRC Forms 742 and 742C),” Revision 6, December 2008.

NUREG/BR-0096, “Instructions and Guidance for Completing Physical Inventory Summary 

Reports (NRC Form 327),” October 1992.

UREG/CR-0602, “Active Nondestructive Assay of Nuclear Materials,” January 1981.

NUREG/CR-2078, “Handbook of Nuclear Safeguards Measurement Methods,” 

September 1983.

NUREG/CR-4604, “Statistical Methods for Nuclear Material Management,” December 1988.

NUREG/CR-5550, “Passive Nondestructive Assay of Nuclear Materials,” March 1991.

TID-26298, “Statistical Methods in Nuclear Material Control,” 1973.

Title 10 of the Code of Federal Regulations (10 CFR) Part 74, “Material Control and Accounting 

of Special Nuclear Material,” Subpart C, “Special Nuclear Material of Low Strategic 

Significance.”




UNITED STATES 

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

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

OFFICIAL BUSINESS
NUREG-1065, Rev. 3

Draft

Acceptable Standard Format and Content for the Material Control and 

Accounting Plan Required for Special Nuclear Material of

Low Strategic Significance