Commission Recommendation of 11 February 2009 on the implementation of a nuclear material accountancy and control system by operators of nuclear installations (notified under document number C(2009) 785)
Date: 2009-02-11
Institutions: European Commission
Subjects: EAEC, EU action, accounting, data processing, fact-finding mission, mining extraction, nuclear fuel, quality control of industrial products

12.2.2009

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Official Journal of the European Union

L 41/17

RECOMMENDATIONS

COMMISSION

COMMISSION RECOMMENDATION

of 11 February 2009

on the implementation of a nuclear material accountancy and control system by operators of
nuclear installations

(notified under document number C(2009) 785)

(2009/120/Euratom)

THE COMMISSION OF THE EUROPEAN COMMUNITIES,

HEREBY RECOMMENDS:

Having regard to the Treaty establishing the European Atomic
Energy Community,
in particular Article 77 and
Article 124 thereof,

and

(1) Whereas

Regulation

Commission

(Euratom) No
302/2005 of 8 February 2005 on the application of
Euratom safeguards (1) defined the nature and extent of
the requirements provided for
the
Euratom Treaty in order to permit accounting for ores,
source materials and special
fissile materials used or
produced.

in Article 79 of

(2) Whereas Article 7 of Regulation (Euratom) No 302/2005
to maintain a system of
requires nuclear operators
accountancy and control for nuclear materials, and sets
out some requirements for such a system.

(3) Whereas the Commission working document entitled
‘Implementing Euratom Treaty Safeguards’
(IETS) (2),
contains the requirement that the Commission draw up
a reference framework for high-quality nuclear material
accountancy and control (NMAC) systems. It also states
that auditing of nuclear operators' NMAC systems will be
one of the Commission’s supervisory activities.

(4) Whereas the European Safeguards Research and Develop­
ment Association (Esarda) presented in 2007 a Guideline
for Good Practice in Nuclear Materials Accountancy and
Control Systems dealing with the elements of the NMAC
system that could be audited and the possible criteria for
indicating quality performance in each of these elements,

Section 1 — Purpose and scope

This Recommendation describes the reference characteristics of
an operator’s NMAC system complying with the legal obli­
gations of Regulation (Euratom) No 302/2005. Some characte­
ristics described in this Recommendation are only relevant to
facilities with corresponding activities (3).

Section 2 — Terms and definitions

‘Containment’ is a structural feature of a facility, container
1.
or equipment which is used to establish the physical integrity of
an area or item (including safeguards equipment or data) and to
maintain the continuity of knowledge of the area or item by
preventing undetected access to, or movement of, nuclear or
other material, or
interference with the contained items.
Examples are the walls of a storage room or of a storage
pool, transport flasks and storage containers.

‘Corrective action’ means action to eliminate the cause of
2.
a detected NMAC discrepancy, anomaly or other undesirable
situation. Corrective action is taken to prevent
recurrence.
There is a distinction between correction and corrective action.

‘Data processing’
results

3.
measurement
production of a variety of
supporting
documents related to material tracking by the facility itself.

is the link between the creation of
and the
and material-tracking data
regulatory reports, documents
internal working

Euratom verification

and

(1) OJ L 54, 28.2.2005, p. 1.
(2) SEC(2007) 293.

(3) The references to measurement and material balance testing will be
irrelevant in an item facility which involves no measurement.

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‘Inventory control’ by the nuclear operator is a quality
4.
control programme aimed at ensuring agreement between
records and the physical
situation in a timely manner.
Inventory control should include resolving and reporting on
found discrepancies as well as reconciliation with other local
accounts and central accounts.

(LII)

The ‘List of inventory items’

5.
is a complete list of
nuclear material (NM) items in a material balance area (MBA)
or a specified location within an MBA produced as a result of
applying an installation procedure. The list may include material
that is handled as a batch. The list should include the identities
and locations of the items or batches. The mass values and
other characteristics of the items or batches should be traceable.

‘Material balance test’ means the method for assessing the
6.
material balance value; taking into account the justified esti­
the balance test will
mation of measurement uncertainty,
decide whether the balance is acceptable or not.

‘Material balance discrepancy’ means a material balance

7.
value which is not accepted by the material balance test.

‘Measurement’ means

8.
the
the
quantity and the characterisation of accounted nuclear material.

activity to determine

‘Nuclear material accountancy and control’ (NMAC) means
9.
all activities in a nuclear installation concerning the accountancy
and control of nuclear material, including the determination and
processing of data and the reporting to the Commission.

‘NMAC discrepancy’ means any discrepancy between two
10.
or more pieces of NMAC information (e.g. records) where this
discrepancy cannot be justified after taking account of legitimate
legitimate uncertainty estimation.
measurement variation or
NMAC discrepancies
discrepancies,
material balance discrepancies and nuclear material control
discrepancies.

include measurement

‘Nuclear material control discrepancy’ means a non-
location of nuclear

12.
conformance in the identification or
material.

‘Nuclear material tracking’ means the documentation of
13.
the identification, the movements, the location and the basic
characteristics of every item of nuclear material in the MBA. In
particular, tracking includes operating records that are the basis
for re-batching, new measurement, shipper-receiver difference
and category change declarations.

‘Nuclear operator’ means a person or undertaking setting
14.
up or operating an installation for the production, separation,
reprocessing, storage or other use of source material or special
fissile material. The term is also used to refer to the organisation
ultimately responsible for NMAC compliance with Regulation
(Euratom) No 302/2005.

‘Performance indicator’ means a leading indicator of
team, organisation or

15.
attainment achieved by an individual,
an action.

‘Physical

inventory taking’
(PIT) means the process to
16.
produce a complete list of the nuclear material
items for an
MBA as a basis for allowing verification of physical inventory
by Commission inspectors.

‘Physical inventory verification’ (PIV) means an inspection
17.
the operator’s physical
activity that verifies the validity of
inventory taking and closes the material balance period. The
basis for a PIV is the list of inventory items (LII) drawn up
by the operator. The LII data are correlated with the physical
inventory listing reports.

‘Quality control’

18.
ensure that the quality requirements are fulfilled.

(QC) means a control designed to

‘Quality management

19.
coordinated
activities to direct and control an organisation with regard to
quality.

system’ means

‘NMAC anomaly’ is an NMAC discrepancy or series of
11.
discrepancies that are consistent with the absence or gain of a
significant amount of nuclear material. An NMAC anomaly can
be detected during an investigation of NMAC discrepancies of
whatever kind.

‘Quality assurance’ (QA) means the part of the quality
20.
management system focused on providing confidence regarding
fulfilment of the quality requirements.

‘Traceability’ means the ability to trace the history, appli­

21.
cation or location of that which is under consideration.

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Section 3 — The management of an NMAC system

Organisation and responsibilities

1.
Senior management should ensure that responsibilities
and authorities are defined and communicated within the
organisation. A member of
should be
the management
appointed who,
irrespective of other responsibilities, should
have responsibility for annually assuring the chief executive
for
officer,
purpose.

the entire NMAC system is fit

in writing,

that

2. Management
taken together
should also comprise organisational procedures and communi­
cation patterns that:

roles and responsibilities

(a)

transmit information about NMAC performance both hier­
archically and across functional responsibility areas;

(b) assign responsibilities
on

required
improvement is needed;

based

for
criteria

improvement of NMAC as
recognising when

for

(c) provide the NMAC Manager with NMAC anomalies infor­

mation;

(d) ensure staff involved in NMAC activities have the appro­

priate competences;

(e) ensure appropriate awareness of

the legal obligations

concerning safeguards.

Quality management and control

The key tasks should incorporate quality assurance and
these measures

3.
quality control measures. The objectives of
should include:

(a) reduction of the intrinsic risk of human errors;

(b) ensuring the correct

functioning of

instrumentation and

software;

(c) provision of a variety of

management
(performance indicators);

to any sign of

indicators designed to alert
inadequate performance

(d) internal assessment in order to detect poor performance;

(e) a

corrective
performance.

action mechanism for

cases of poor

Section 4 — Measurement and measurement control

quantification and characterisation of the material that has to
be referred to in accounting declarations. The measurement
activities should be conducted so as to have traceability in the
event of investigation of an anomaly. Measurement activities
should include the measurement of material but also the
processes whereby measured material is selected as representa­
tive of a set of material and all subsequent treatment of this
sample material (sampling, sample shipment and preparation)
and the required data treatment processes. It also should include
measurement activities required for measurement control and
quality assurance.

Accountancy data requirements

In order

2.
measurements, the following should be taken into account:

to ensure appropriate performance of

the

(a) validation of the applied measurements methods;

(b) traceability of measurement results;

(c) precision and accuracy;

(d) that each measurement result is approved by a responsible

person;

(e)

that sampling is representative of the material.

In cases where accounting data are based on calculations
3.
that are not direct measurements,
should be
validated, traceable and approved. Similar requirements apply
to item counting.

the values

Measurement control

4.
A measurement control programme should be in place in
order to ensure the validity of the measurement results and their
uncertainties used for accountancy declarations.

5.

The measurement control programme should include:

(a) measures to ensure that the instrumentation is performing

as required;

(b) assurance that accountancy mass values are free from any
the measurement

significant measurement bias and that
uncertainty is appropriately estimated;

(c) records of all data of the measurement control programme;

Measurement programme

(d) description of the measurement equipment and methods;

1. Where measurements are performed, a programme should
be established for providing sufficiently accurate and precise

(e) approval of the measurement procedures.

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Section 5 — Nuclear material tracking

The nuclear material

1.
tracking should document any
movement of and the location of every item of nuclear
material. It also should imply knowledge of the characteristics
the material and its containment. Any action involving
of
nuclear material
the identification,
that affects the location,
the nature or the quantity of the nuclear material should be
tracking should
documented.
re-batching, new
include
measurement, shipper-receiver difference and category change
declarations.

In particular, nuclear material

the basis

that are

records

for

Identity

2.
Nuclear material should, where practical, be in containers
having a recorded unique identity. When nuclear material is not
in a transportable container, a well delimited process location
may be considered both as the identity of the ‘container’ and as
the location of the container/material. This includes material in
Identities of containers
process vessels or other equipment.
inventory
for
legible
and readily
should be permanent
checking. If the identity of the item needs to be changed, the
link between old and new identities should be recorded.
If
nuclear material
is in some form of double containment, the
nature and characteristics of the material in any container or
location should be traceable through identification control.

Identification of storage location

for

The locations in which nuclear material can be held
3.
should have identities
recording the
that are a basis
location and transfers of material. Specific positions within
areas should be mentioned, where appropriate, as part of the
specification of
location. The records for storage
control should ensure that the identities of the contents of
each storage location are known and that the location of any
identified item can be derived. The nature and characteristics of
the material in any location should be available through identi­
fication control or other means.

the exact

Material tracking during production

4. When nuclear material enters a process (or is repackaged),
the production records should allow identification of the items
from which the material has been fed into the process (or into
new containers). This is intended to provide traceability of the
relevant nuclear characteristics of the material in process.

Production records should specify the amount of material fed
into the process or repackaged and, as mentioned, traceability of
information related to the nature of the nuclear material should
be maintained.

When new items or sets of material arise as a result of
processing or repackaging, mass values and identities should

be established for these items and their identity should be
linked to the relevant mass results and measurement history.

Inventory control

5.

Inventory control by the nuclear operator should:

(a) ensure that all nuclear material

transfers from stores to
process areas and vice versa are recorded (Key Measurement
Points, KMP);

(b) verify regularly that stock records correspond to KMP flow
records, storage location records and processing records,
and regularly reconcile local
records and central MBA
records;

(c)

take into account the operating records of the inventory
control measures
that ensure continuity of knowledge
about the nuclear material contents of items;

(d) regularly check the agreement between the information of

material present and the physical reality;

(e) resolve and report on found discrepancies and reconciliation

with other local accounts or central accounts.

In the event of a transfer of nuclear material that is not a
transfer of a contained item,
the transfer
material should be measured.

the amount of

Management of discrepancies

6.
The installation should have an approach that recognises
and investigates NMAC discrepancies, and documents their
treatment. The approach should:

(a)

indicate for each discrepancy type the investigative actions
to be taken and the conditions in each case that are
considered to resolve the discrepancy. Actions to be taken
should include personnel responsibilities and the additional
data to be employed;

(b) make the appropriate correction of records and regulatory

declarations when a discrepancy has been resolved;

(c) record when a discrepancy remains unresolved and the

action taken to resolve it.

Management of anomalies

The installation should have an approach in place that
7.
corresponds to the reporting obligations under Article 6 and
Article 14 (Special
reports) of Regulation (Euratom) No
302/2005.
In addition to the management of discrepancies
described in point 6 of Section 5 of this Recommendation,
the approach should:

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(a) recognise, investigate and document the treatment of NMAC
anomalies corresponding to Article 15(a) of Regulation
(Euratom) No 302/2005.
Such NMAC investigations
should aim to establish in a timely manner the accountancy
evidence showing that all material is accounted for;

3.

The data-processing capabilities should also include:

(a) provision of inventory lists permitting inventory checking

by the operator;

(b) recognise, investigate and document the treatment of other
situations corresponding to Article 15(b) of Regulation
(Euratom) No 302/2005;

(b) inventory lists providing any information necessary for
identifying discrepancies between the locations described
in the records and the real physical location;

(c) define personnel responsibilities and the form of internal
communication required when actions under Article 15(a)
or (b) of Regulation (Euratom) No 302/2005 are required.
The approach should also define the mechanisms under
which the personnel will inform the Commission;

(d) define personnel responsibilities and authority in order to
provide ‘further details or explanations’ when requested
under Article 14 of Regulation (Euratom) No 302/2005.

Section 6 — Data processing and control

A data-processing

1.
producing:

system should

be

implemented

(a) safe and secure storage of all data required for the proper

working of the NMAC system;

(b) declarations required by Regulation (Euratom) No 302/2005
(inventory change reports, material balance reports, physical
inventory listings, special reports, advanced notifications);

(c) support of regular reconciliation of local records and central
MBA records, when the accountancy of nuclear material in
process involves separate storage of these records;

(d) the possibility of

arising from
discrepancy investigation for inventory checking and recon­
ciliation;

corrections

including

(e) documentation of the results of

inventory checking and
database reconciliation, including documentation of discre­
pancies encountered for the purpose of performance indi­
cators.

execution,

4.
The procedures for data-processing execution activities
should provide the NMAC system manager with supervisory
information. This should include the staff members initiating
the application
each software
program(s) involved as well as identification of the location of
the data inputs used and the location of
the data outputs
created. It should also be possible to identify any execution of
application software or access to records and data which do not
conform to the authorised data processing policy.

identification of

(c) material balance standard deviation for material balance

Traceability

tests (if appropriate);

(d) various types of documents linked to inventory change (IC)

declarations such as shipping documentation;

(e) working documents for routine inventory control;

(f) working documents for PIT;

The data-processing system should produce the infor­
5.
mation required by Regulation (Euratom) No 302/2005 and
also maintain traceability for all the information provided. It
should be possible to identify any information or data that
could be needed to resolve discrepancies and anomalies
arising from the requirements of Regulation (Euratom) No
302/2005.

Section 7 — Material balance

Receipts and shipments

(g) a list of inventory items (LII) resulting from PIT and used

during PIV or other verification.

Nuclear operators

1.
including:

should apply reception procedures,

2.
Data-processing procedures should be in place to correct
records and generate correction declarations as appropriate for
any situation where a discrepancy has been detected. Trace­
ability should be maintained during such correction processes.
Quality control and quality assurance measures should ensure
the completeness and the correctness of the data-processing
system.

(a) check

of

shipper

information

(completeness,

self-

consistency);

(b) check of the nature, identity and integrity of the transport
container and seals and initial check on the nature of
nuclear material (when appropriate);

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(c)

introduction of the received material into the accountancy
process;

mation in the data-processing systems (when discrepancies
are found) as well as rules for transmitting such corrections
to the data-processing department;

(d) recognition and treatment of shipper-receiver differences;

(e) corrective actions in the event of discrepancies;

(f)

recording in a manner that guarantees traceability;

(g) ensuring that the obligations laid down in Articles 21 and
22 of Regulation (Euratom) No 302/2005 are respected.

(e)

the MBA list of inventory items presented to Commission
inspectors as a basis for PIV should be authenticated by the
signature of a responsible person before being handed over;

(f)

in a PIT approach for a storage area relying entirely on
transfer records, the credibility of the approach should be
enhanced by having:

(i) QC and QA provisions for the creation of records of

Nuclear operators

2.
defining:

should apply shipping procedures

transfers;

(a)

the content of the information being sent to the recipient;

storage locations;

(ii) QC and QA measures ensuring reliable records of

(b) how the accountancy should be updated;

(iii) routine recording of the fact that these QA and QC

provisions and measures have been carried out;

(c) corrective actions and the appropriate response to situations

of discrepancy indicated by the recipient;

(d) the preparation and execution of the shipment process;

(e) recordkeeping in a manner that guarantees traceability;

(f) activities to ensure that the obligations laid down in Articles
21 and 22 of Regulation (Euratom) No 302/2005 are
respected.

Physical inventory taking (PIT)

3.
A physical inventory of each MBA should be taken every
calendar year and the period between two successive physical
inventory takings should not exceed 14 months. The PIT
procedures
to the
for
inventory items for
Commission and providing the list of
In particular, nuclear
inventory verifications
physical
operators should have PIT procedures taking account of the
following needs:

reporting

include

should

those

(PIV).

(iv) assurance of material

integrity during presence within

the area;

(v) independent confirmation that

transfer

records are

complete.

The list of inventory items for formal verification purposes

4.
should include for each item:

(a)

location and storage position within location;

(b) type of container and identity of container (if relevant);

(c) material type;

(d) mass of nuclear material per item (gross,

tare and net

weight);

(a) definition of PIT working methods and responsibilities for

each storage area and process area;

(e) enrichment of uranium;

(b) establishment of a reliable itemised list of all the material in
the MBA. Such procedures should be

each location of
designed to ensure that no material is overlooked;

(c)

the execution of the physical inventory taking needs to be
recorded;

(d) if there are PIT activities involving physical checks (tag-
check or measurement),
the procedures should include
rules for defining the necessary corrections to the infor­

(f)

isotopic composition of plutonium (if available).

The list of inventory items should include entries for material
that is difficult to measure either due to its location (process
vessel hold-up) or because it
is in a form unsuitable for
measurement.
In such cases, the operator should declare an
estimated range of mass for each item and traceability should
provide the link to the data used for
the estimate. Mass
estimates for material that is inaccessible or in process vessels
should include the location of the material. The mass values for
measured discards, accidental
losses and transfers to waste
should have a traceable history.

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Material balance tests

forming part of

5.
In an MBA involving processing or re-measurement, the
material balance derived from a PIT, and also the process area
material balances
an inventory control
should be tested for acceptance using balance
approach,
standard deviations that take into account justified measurement
uncertainty and in the case of estimated amounts, the process
and measurement uncertainty. These tests should be an integral
part of the QA system.

The procedures for any balance test should take into account
the following:

(a) software for computing the standard deviation of any
the quality approach for

balance should come under
software and its use;

(d) the method should provide balance standard deviations
which correctly reflect
the pattern of processing during
the balance interval and which also correctly reflect the
measurement history (or estimation method) of the mass
values used to compute the balance;

(e) where

estimates of

in-process material are based on
historical
information or on modelling of some kind, the
estimation method and the method of establishing the
uncertainty should be described in a technical document;

(f)

the work procedures for balance testing, the software user
guide, the software description and the technical method
documents should be written in such a manner that their
completeness and mutual consistency can be recognised.

This Recommendation is addressed to the Member States.

(b) accountancy and measurement method data used for
computing the standard deviation of any balance should
come under the quality approach for data and its use;

Done at Brussels, 11 February 2009.

(c)

the algorithms used to compute standard deviation should
be described in a technical document;

For the Commission

Andris PIEBALGS
Member of the Commission