Publication Date: 3/1/75     Pages: 4     Date Entered: 2/23/84     Title: INTERNAL TRANSFERS OF SPECIAL NUCLEAR MATERIAL     March 1975     U.S. NUCLEAR REGULATORY COMMISSION     REGULATORY GUIDE     OFFICE OF STANDARDS DEVELOPMENT     REGULATORY GUIDE 5.49     INTERNAL TRANSFERS OF SPECIAL NUCLEAR MATERIAL A. INTRODUCTION     Paragraph 70.51(e) of 10 CFR Part 70 requires, with certain     exceptions stated in the rule, that each licensee authorized to possess     more than one effective kilogram of special nuclear material (SNM)     maintain certain procedures. These procedures are to include:     (1) Records of the quantities of SNM added to or removed from     the process;     (2) Documentation of all transfers of SNM between     material-balance areas to show the identity and quantity of SNM     transferred;     (3) Requirements for authorized signatures on each document used     to record the transfer of SNM between material-balance areas; and     (4) Means for control of and accounting for internal transfer     documents.     Paragraph 70.58(e) requires licensees to establish, maintain, and     follow a system for measuring the SNM transferred between     material-balance areas and item-control areas.     Paragraph 70.58(f) requires that licensees have a program that     evaluates and controls the quality of their measurement system.     Additionally, all licensees authorized to possess SNM must comply     with paragraph 70.51(b) of 10 CFR Part 70. That rule requires licensees     to keep records showing, among other things, the inventory of all SNM in     their possession and its location.     This guide sets forth acceptable methods for controlling and     documenting transfers of SNM within a plant site in order to meet the     requirements listed above. B. DISCUSSION     To help determine when and where losses of SNM have occurred     within a plant, each licensee subject to the requirements of paragraph     70.58(d) of 10 CFR Part 70 should divide the plant into a number of     areas and account for the SNM in each of these areas separately. The     number of areas should be sufficient to localize nuclear material losses     or thefts and identify the mechanisms.     In the past, all of these accounting areas have been called     "material-balance areas." More precise terminology now in use     distinguishes between material-balance areas (MBAs) and item-control     areas (ICAs).(*) The newer usage will be followed in this guide. Under     this usage, MBAs and ICAs are contrasted on the basis of how SNM is     accounted for within the area.     SNM can enter and leave an ICA only as a number of discrete,     unique items. It is also accounted for as discrete items, with account     books containing records of the amount of SNM in each of these items.     The presence of all material in an ICA is assured by showing the     presence of each item. No change takes place in the form or amount of     SNM in any item in an ICA.     MBAs, in contrast, generally are process areas in which some     physical or chemical change is made in the SNM. Material in MBAs thus     should be accounted for on the basis of measured amounts of input,     output, and inventory. Loss of material from an MBA can be assured only     by balancing these quantities. However, since no measurement can be     free from error, errors will be included in the material balance. Hence     each material balance in an MBA results in some positive or negative     amount of material unaccounted for (MUF)-solely as a result of errors     made in measuring. In an ICA, on the other hand, MUF cannot be ascribed     to errors in measurement; it can result only from a misplacement, loss,     or theft of one or more discrete items of SNM.     ----------     (*) See Regulatory Guide 5.26, "Selection of Material Balance     Areas and Item Control Areas."     ----------     Licensees control and account for their holdings of SNM, in part,     by setting up procedures to monitor the movement of SNM from one MBA or     ICA to another. The movements are documented by means of internal     material transfer tickets (MTs). These tickets (a) provide needed data     to the nuclear material accounting office, (b) provide a record of each     internal transfer of SNM, and (c) meet the signature requirements of     paragraph 70.51(e).     MTs in most cases are paper forms with multiple copies. However,     they may also consist of a single original, which contains the     authorized signatures. Copies are then made on an office copying machine     or are produced as computer output. Descriptions in this guide are     limited to MTs of these two kinds (multiple copy and single original).     Guidance will be provided later to cover the use of precoded computer     cards or punched tape as MTs by those facilities that are planning on     using computerized real-time material-accounting systems. C. REGULATORY POSITION 1. Control of internal transfers of special nuclear material.     The guidelines under this heading pertain to procedures for controlling     the transfer of special nuclear material (SNM) within a facility.     a. The custodian of a receiving material-balance area     (MBA) or item-control area (ICA) should not accept custody of SNM unless     a properly completed internal material transfer ticket (MT) has been     received before or at the same time as the SNM.     b. SNM may not be transferred into or out of an ICA     unless the SNM consists only of identifiable items that are sealed     sources or tamper-safed.     c. For any transfer outside of a material access area     that involves moving plutonium, uranium 233, or uranium enriched to 20     percent or more in the isotope U-235 in the amounts listed in paragraph     73.1(b) of 10 CFR Part 73,(*) the SNM should be under the continual     surveillance of two persons. Where feasible, one of these persons     should be from the originating MBA or ICA and the other from the     receiving MBA or ICA.     d. For any transfer outside of a protected area that     involves the amounts and kinds of SNM cited in paragraph c above, the     SNM should be escorted by one or more armed guards in addition to the     two persons who maintain surveillance between material access areas. At     least one armed guard should escort such transfers that are wholly on     land under the control of the licensee. Two or more armed guards should     accompany any such transfer that crosses a public road or other land not     under control of the licensee.     ----------     (*) Material described in section 73.6 of 10 CFR Part 73 is     excepted.     ---------- 2. Internal material transfer tickets. The guidelines under     this heading pertain to the tickets that are used for documenting     transfers of SNM within a facility.     a. Each MT should show all of the following information:     (1) Date of transfer;     (2) Identity of MBAs or ICAs from and to which     transfer is made;     (3) Identity, amount, enrichment (where applicable),     and form of the SNM transferred;     (4) Sample number and/or analytical request form     number;     (5) Applicable data on -     (a) Identity of uniquely identifiable items,     (b) Identity of tamper-safing devices,     (c) Lot number(s),     (d) Batch number(s),     (e) Job number(s),     (f) Contract number(s), and     (g) For scrap, the appropriate classification;     (6) Signatures of the participating MBA/ICA     custodians or their designated agents.     b. When possible, SNM should not be transferred until     analytical results have been obtained. If a transfer must be made     before chemical or isotopic analysis is complete, the MT should show     amounts of SNM based on nominal values or best available data. The MT     should also show the identifying number on the analytical request form     so that the nuclear material accounting department can later adjust the     records to the actual amount transferred.     c. The MT should contain enough information to enable the     recorded measurement and tamper-safing data associated with the transfer     to be confirmed.     d. Entries on MTs should not be erased or obliterated.     Alterations, as by lining through, should be initialed. No entry should     be made by pencil.     e. MTs should be prenumbered in sequence, and all copies     should bear the same number as the original. All forms should be     accounted for. The nuclear material accounting department should     maintain and control (assign and account for) the supply of MT forms and     should record the disposition of all forms in a log book. The supply of     forms and the log book should be kept in a locked area when unattended.     f. The nuclear material accounting department should     review each MT for completeness. Copies of completed MTs should be     distributed to all affected persons or departments, including at least     the custodians of the originating and receiving MBAs or ICAs.     g. The completed original of the MT should be retained     for at least five years. As a rule, the original should be retained by     the nuclear material accounting department. However, if the form also     is used for production purposes, the production department may retain     the original.     h. Damaged or misused MTs should be marked "VOID." All     voided copies should be forwarded to the nuclear material accounting     department for logging.     i. MTs may have uses other than those that are the     subject of this guide. Their use in production control has been     suggested above. They also may be used to record and report such SNM     accounting data as burnup, material unaccounted for (MUF), or measured     discards of waste. 3. Measurement of transferred material. The guidelines under     this heading pertain to the measurements associated with SNM transferred     within a facility.     a. The following SNM may be transferred out of and into     MBAs or ICAs without measuring the contained SNM:     (1) Samples that have been determined by other means     to contain less than ten grams of plutonium, uranium 233, or uranium     235;     (2) Reactor-irradiated fuels involved in research,     development, and evaluation programs in facilities other than     irradiated-fuel reprocessing plants; and     (3) Sealed plutonium-beryllium sources.     b. Except for the items listed in paragraph 3.a., all SNM     should be transferred out of and into MBAs or ICAs on the basis of     acceptable accountability measurements. To be acceptable, the     measurements should:     (1) Be made in accordance with a measurement program     that is controlled to conform with proposed section 70.57 of 10 CFR Part     70;     (2) Be validated by intact tamper-safing until the     material has been accepted by the custodian of the receiving MBA/ICA or     his designated agent; and     (3) Have the tamper-safing applied as a part of the     sampling procedure(*) (if the SNM is assayed by traditional methods     based on chemical analysis) or prior to measurement (if the SNM is     assayed by nondestructive analysis).     c. When SNM is transferred via pipeline from one MBA to     another, the SNM should be measured in the receiving MBA prior to any     physical or chemical change in the material.     d. For any transfer of identifiable items of encapsulated     SNM, the recorded amount of SNM transferred should be that measured at     the time of encapsulation.     e. The custodian of the originating MBA should measure     all tare and gross weights. The custodian of the receiving MBA should     measure all gross weights and confirm the absence of arithmetic errors.     He may also confirm the tare weights as a check on the originating MBA.     A duly designated agent may act for a custodian in the actions named in     this paragraph.     f. If the gross weight measured at the receiving MBA     differs from that reported on the MT by the custodian of the originating     MBA by a statistically significant amount, the SNM should be left in the     transfer container until the difference has been resolved. The value     agreed upon must be acceptable to both of the MBA custodians involved     and to the nuclear material accounting department. D. IMPLEMENTATION     The purpose of this section is to provide information to     applicants and licensees regarding the NRC staff's plans for utilizing     this regulatory guide.     Except in those cases in which the applicant proposes an alternate     method for complying with specified portions of the Commission's     regulations, the method described herein will be used in the evaluation     of submittals in connection with special nuclear material license,     operating license, or construction permit applications docketed after     October 1, 1975.     ----------     (*) See Regulatory Guides 5.10, "Selection and Use of     Pressure-Sensitive Seals on Containers for Onsite Storage of Special     Nuclear Material," and 5.15, "Security Seals for the Protection and     Control of Special Nuclear Material."     ----------     If an applicant whose application for a special nuclear material     or an operating license or construction permit is docketed on or before     October 1, 1975, wishes to use this regulatory guide in developing     submittals for applications, the pertinent portions of the application     will be evaluated on the basis of this guide.     54