Publication Date: 6/1/80
    Pages: 10
    Date Entered: 2/23/84
    Title: SHIPPING AND RECEIVING CONTROL OF STRATEGIC SPECIAL NUCLEAR MATERIAL (6/76)
    Revision 1
    June 1980
    U.S. NUCLEAR REGULATORY COMMISSION
    REGULATORY GUIDE
    OFFICE OF STANDARDS DEVELOPMENT
    REGULATORY GUIDE 5.57
    (Task SG 908-4) SHIPPING AND RECEIVING CONTROL OF STRATEGIC
    SPECIAL NUCLEAR MATERIAL
A. INTRODUCTION
    Requirements for the physical protection of special nuclear material
    (SNM) at licensee facilities and in transit and of plants in which SNM is
    used are specified in 10 CFR Part 73, "Physical Protection of Plants and
    Materials," and are the subject of various regulatory guides issued or
    under (*) development. Section 73.20 of 10 CFR Part 73 provides the
    general performance objective and requirements for each licensee who is
    authorized to operate a fuel reprocessing plant pursuant to 10 CFR Part
    50, possesses or uses formula quantities of strategic special nuclear
    material (SSNM) at any site or contiguous sites subject to control by the
    licensee, is authorized to transport or deliver to a carrier for
    transportation pursuant to 10 CFR Part 70 formula quantities of SSNM,
    takes delivery of formula quantities of SSNM free on board (f.o.b.) the
    point at which it is delivered to a carrier for transportation, or imports
    or exports formula quantities of SSNM. Section 73.25 requires specific
    performance capabilities for physical protection of SSNM in transit.
    Section 73.45 requires specific performance capabilities for fixed site
    physical protection systems. This guide is applicable to the shipping and
    receiving control of SSNM subject to Sections 73.20, 73.25, and 73.45.
    Other regulations are also pertinent to shipping and receiving
    control. Section 70.58, "Fundamental Nuclear Material Controls," requires
    licensees to establish, maintain, and follow detailed fnndamental material
    control and accounting procedures, including procedures for shipping and
    receiving special nuclear material (SNM). Certain material control and
    accounting procedures related specifically to the protection of SSNM from
    theft during shipping and receiving and related to preventing the misuse
    of shipments to disguise a diversion are discussed in this guide.
    Additional guidance on fundamental material controls and accounting is
    included in the following regulatory guides:
    ----------
    (*) Lines indicate substantive changes from June 1976 version.
    ----------
    5.10 Selection and Use of Pressure-Sensitive Seals on Containers
    for Onsite Storage of Special Nuclear Material.
    5.12 General Use of Locks in the Protection and Control of
    Facilities and Special Nuclear Materials.
    5.13 Conduct of Nuclear Material Physical Inventories (In
    particular, Section C.2.b.(1), Receipts, Shipments, and Other
    Removals).
    5.15 Security Seals for the Protection and Control of Special
    Nuclear Material.
    5.45 Standard Format and Content for the Special Nuclear Material
    Control and Accounting Section of a Special Nuclear Material
    License Application.
    5.47 Control and Accountability of Plutonium in Waste Material.
    5.51 Management Review of Nuclear Material Control and Accounting
    Systems.
    Section 70.57 and paragraph (f) of Section 70.58 require that the
    licensee's measurement control program for SNM include a means for the
    control and evaluation of measurement bias, random errors, and limits on
    systematic errors for all parts of the measurement process, including
    scales, balances, volume measurements, analytical quality control,
    nondestructrive assay, and sampling. Certain measurements made in
    conjunction with shipping and receiving are used as part of the material
    accountability program and are subject to Section 70.57. Specific guidance
    on measurements and measurement control are provided in the following
    regulatory guides:
    5.4 Standard Analytical Methods for the Measurement of Uranium
    Tetrafluoride (UF(4)) and Uranium Hexafluoride (UF(6)).
    5.5 Standard Methods for Chemical, Mass Spectrometric, and
    Spectrochemical Analysis of Nuclear-Grade Uranium Dioxide
    Powders and Pellets.
    5.6 Standard Methods for Chemical, Mass Spectrometric, and
    Spectrochemical Analysis of Nuclear-Grade Plutonium Dioxide
    Powders and Pellets and Nuclear-Grade Mixed Oxides
    ([U,Pu])O(2).
    5.11 Nondestructive Assay of Special Nuclear Material Contained in
    Scrap and Waste.
    5.21 Nondestructive Uranium-235 Enrichment Assay by Gamma-Ray
    Spectrometry.
    5.34 Nondestructive Assay of Plutonium in Scrap by Spontaneous
    Fission Detection.
    5.53 Qualification, Calibration, and Error Estimation Methods for
    Nondestructive Assay.
    Licensees who transfer and receive SNM are required under Section
    70.54 to complete DOE/NRC Form-741, "Nuclear Material Transaction Report,"
    and submit a copy to the U.S. Department of Energy (DOE), Oak Ridge,
    Tennessee. In addition, paragraph 70.42(c) requires that, before
    transferring SNM, the person making the shipment verify that the recipient
    is authorized to receive the type, form, and quantity of SNM to be
    transferred. Paragraph 70.42(d) outlines the methods to be used to make
    this verification.
    Paragraph 70.58(g)(2) requires that procedures be established to
    review and evaluate shipper-receiver differences on an individual
    container or lot basis, a shipment basis, and a cumulative basis for
    shipments of like material. Guidelines are contained in Regulatory Guide
    5.28, "Evaluation of Shipper-Receiver Differences in the Transfer of
    Special Nuclear Materials." Any loss of SNM (other than normal operating
    loss) must, under Section 70.52, be reported immediately to the Director
    of the appropriate NRC Inspection and Enforcement Regional Office (listed
    in Appendix A to Part 73) by telephone, telegram, mailgram, or facsimile.
    This guide and the guides referenced above describe procedures
    acceptable to the NRC staff for complying with the Commission's
    regulations regarding the control of SSNM during preparation for shipment
    and receipt by a licensee. Safety-related requirements for packaging and
    transporting SNM are specified in 10 CFR Part 71, "Packaging of
    Radioactive Material for Transport and Transportation of Radioactive
    Material Under Certain Conditions," and in the applicable portions of the
    regulations appropriate to the mode of transportation in Title 49 of the
    Code of Federal Regulations. These requirements are not included in the
    scope of this guide.
B. DISCUSSION
    Adequate control of SSNM during transfer between licensees includes
    (1) physical protection of the material at the licensees' facilities and
    while in transit and (2) the timely, accurate, and independent
    identification and measurement of the SSNM by both shipper and receiver to
    determine and evaluate any shipper-receiver differences. These
    measurements are necessary to (1) detect loss or theft of SSNM being
    transferred between licensees, (2) detect and permit correction of
    clerical or handling errors, (3) detect falsification or errors in the
    shipment source data, (4) provide assurance that measurement bias is
    detected and corrected, and (5) detect and prevent the transfer of
    "inventory difference" (ID) from one licensee to another.
    The application of tamper-indicating seals to each item or container
    by the shipper immediately after sampling or assay, checks on those seals
    before shipment, and the prompt verification of the seals by the receiver
    can help ensure the integrity of the material measured. Additional
    receiving checks made immediately after receipt can determine if loss,
    theft, or substitution of SSNM may have occurred during transfer and can
    detect packaging and clerical mistakes. These checks can include counting
    and identifying the containers; identifying and weighing the containers or
    items received; comparing the results with the same information on a bill
    of lading, DOE/NRC Form-741, "Nuclear Material Transaction Report," or
    other appropriate document supplied by the shipper; and, to the extent
    possible, performing an overcheck of each container by nondestructive
    analysis to provide a gross verification of the SSNM content.
    After these initial checks have been made, prompt quantitative
    verification of the contents of each container will provide early
    assurance that the contents of the packages received are identical to
    those shipped. Written procedures that call for performing these
    verifications within specific time limits after shipment can help ensure
    that DOE/NRC Form-741 is filed in a timely fashion. In addition, the
    validity of both the shipper and receiver measurements is dependent on the
    existence of a program of standardization and calibration and control of
    measurement equipment and procedures.
    Prior coordination between the carrier and receiver can ensure that
    SSNM will be delivered to the receiver's facility at a time when trained
    personnel are available to properly handle the material received. This
    procedure will eliminate the possibility of material arriving at times
    when proper receiving checks or adequate physical security cannot be
    provided.
    Appropriate procedures that identify employees who are authorized to
    ship SSNM and the responsibilities of the various organizational
    components that have cognizance of the shipment will ensure that all
    aspects of the shipment are coordinated adequately. The following
    organizational components are listed with typical responsibilities as
    related to the shipment:
1. Organizational component that fabricates or assembles
    material:
    a. Determine the correct weights of the SSNM,
    b. Tamper-seal and document the contents of the containers.
    c. Obtain appropriate analysis of the SSNM,
    d. Ensure product specifications,
    e. Package material properly or provide guidance on
    packaging as required.
2. Shipping and receiving control:
    a. Prepare shipping forms,
    b. Ensure proper packaging,
    c. Check integrity and seal numbers of tamper-safed
    containers and identification numbers on such items as
    sealed fuel pins,
    d. Verify seal integrity and number of receipts,
    e. Check weight of items and containers.
3. Security:
    a. Accompany package to shipping area when appropriate,
    b. Be cognizant of the storage areas while shipment is in
    them,
    c. Guard shipment while it is being loaded,
    d. Coordinate security plans and arrangements with the
    dispatcher of the material,
    e. Obtain signed receipts and pass them on to the
    appropriate departments.
4. Traffic (dispatcher):
    a. Make carrier arrangements,
    b. Coordinate shipments and ensure that delivery is at a
    time when the proper personnel are available to properly
    handle the material received,
    c. Prepare bill of lading and other formal shipping papers,
    d. Notify receivers when shipments will be made and
    approximate time of scheduled arrival.
5. Nuclear materials control:
    a. Ensure that the receiver is authorized to receive the
    shipment of SSNM,
    b. Approve all SSNM shipping memos,
    c. Prepare and transmit DOE/NRC Form-741,
    d. Transmit information for computer records, if used,
    e. Arrange transfer of material to shipping area,
    f. Post shipping transactions to control records,
    g. Investigate and reconcile shipper-receiver differences.
    To document the transfer of SSNM containing 1 gram or more of
    contained uranium-235, uranium-233, or plutonium, DOE/NRC Form-741 is
    initiated on the day the material is shipped and distributed promptly by
    the shipper. Normally, the licensee receiving SSNM is required to
    independently measure its element and isotopic content and complete and
    distribute DOE/NRC Form-741 within 10 days of receipt of the material.
    However, if receipt measurements cannot be completed within 10 days, a
    licensee may prepare and distribute NRC Form-284, "Nuclear Material
    Transfer Report," or use DOE/NRC Form-741 as a temporary receipt record
    after performing an initial receiving check to verify that the items,
    containers, and gross quantities shipped have been received. In such
    cases, the receiver is then required to complete the measurements and
    report them on DOE/NRC Form-741 within 30 days of receipt of the shipment.
    If the material received is scrap or irradiated material that may take
    longer than 30 days to measure, DOE/NRC Form-741 is completed and
    distributed to indicate temporary acceptance of the shipper's values; at
    a later date, the receiver prepares and distributes a "corrected copy" of
    DOE/NRC Form-741 that reports the receiver's own measurements.(1) There
    are no requirements for shipments of nuclear wastes to burial grounds to
    be measured independently by the receiver. DOE and its prime contractors
    complete DOE/NRC Form-741 in accordance with DOE manual chapters.
C. REGULATORY POSITION
    Procedures should be provided to ensure that records reflect
    accurately the quantity and form of material shipped and received, to
    protect against the deliberate falsification of information on shipments
    or receipts to conceal diversion of SSNM, and to protect against the use
    of waste shipments or shipments of quantities not subject to Section 73.25
    as a means for unauthorized removal of SSNM from a licensee's facility.
    The following procedures are acceptable to the NRC staff.
1. PRESHIPMENT CONTROLS ON WASTE
    a. Nondestructive assay (NDA) measurements for accountability
    purposes should be made using one of the following procedures or an
    alternative procedure that provides equivalent protection against
    falsification of accountability measurements:
    (1) Measurements should be performed by two individuals
    working and recording as a team and who do not have access to material
    processing and storage areas,
    (2) Measurements should be performed by three individuals
    working and recording as a team, or
    (3) Arrangements should be made for independent verification
    of the accountability measurements by a party other than the licensee.
    b. Tamper-safing controls at the time of accountability
    measurements should include one of the following:
    ----------
    (1) Section 70.54 and the written instructions entitled
    "Instructions to NRC and Agreement State Licensees for Reporting Nuclear
    Material Transfers on DOE/NRC Form-741 - Nuclear Material Transaction
    Report," U.S. Nuclear Regulatory Commission. Copies of the latter may be
    obtained from the Division of Safeguards, Office of Nuclear Material
    Safety and Safeguards, U.S. Nuclear Regulatory Commission, Washington,
    D.C. 20555.
    ----------
    (1) If the containers being measured are already
    tamper-safed, individuals performing the measurement should confirm the
    seal identification and integrity, or
    (2) Containers should be sealed at the time of NDA
    measurement and each member of the team should attest in writing to the
    nature of the contents of the container and the seal identification.
    c. Prior to removal of a waste container from a material access
    area (MAA), an overcheck should be performed to ensure that the container
    is not being used as a means for concealment and unauthorized removal of
    SSNM from an MAA. Controls should also be placed on packaging of smaller
    containers that are sealed and subsequently combined in larger containers
    prior to final sealing and removal from an MAA. Teams performing
    functions for a. and b. above may simultaneously perform the functions
    described below. Acceptable procedures are:
    (1) For each stage in sequential packaging, containers
    should be filled and sealed by two individuals working and recording as a
    team and who do not have access to material processing and storage areas.
    Each individual should attest in writing to the nature of the contents of
    the container and the seal identification. At any stage in sequential
    packaging, the team filling the large container should include at least
    one individual who was not involved in filling the smaller containers,
    (2) Same as (1), except that, if any individual involved in
    filling and sealing the containers has access to material, three-man teams
    should be used,
    (3) Intermediate packaging may be performed by two-man teams
    if the final package receives an NDA overcheck using a segmented scanner
    with a transmission source or neutron counter, as appropriate, capable of
    detecting concealed SSNM and gamma ray or neutron absorbers of sufficient
    density to preclude accurate NDA measurement, or
    (4) Intermediate packaging may be performed by two-man teams
    if the final sealed package is retained in the MAA until the next material
    balance is closed. The package may be released if the inventory
    difference is less than the limit of error which in turn is less than 1/10
    of a formula quantity as defined in paragraph 73.2(bb). If the inventory
    difference for the period is greater than its limit of error, the
    containers should be unsealed and the contents verified in accordance with
    Regulatory Position C.1.c.(1) or (2) or left sealed and the contents
    verified in accordance with Regulatory Position C.1.c.(3) as a part of the
    investigation of the excessive inventory difference. If the limit of
    error is greater than 1/10 of a formula quantity, verification should be
    performed in accordance with Regulatory Position C.1.c.(1), (2), or (3)
    before the package is released.
2. OVERCHECKS ON PRODUCT, SAMPLES, AND SCRAP
    a. For shipments that are not subject to the in-transit physical
    protection requirements of Sections 73.20 and 73.25, overchecks such as
    those discussed in Regulatory Position C.1.c. above should be provided to
    protect against concealment and unauthorized removal of SSNM.
    b. If an independent accountability measurement is not required
    to be made by the receiver and reported within 30 days, NDA overchecks on
    accountability measurements should be provided by the shipper or controls
    such as those discussed in Regulatory Position C.1.a. should be provided.
3. ADDITIONAL SHIPPING CONTROLS
    a. Before shipping SSNM, the licensee should ensure that the
    intended receiver is authorized to receive the type, form, and quantity of
    SSNM to be transferred in accordance with Section 70.42. This does not
    include forecasting the receiver's inventory at the time the shipment
    arrives.
    b. The shipper should establish and maintain written procedures
    that identify employees who are authorized to initiate shipment of SSNM
    and identify the responsibilities of the various departments that should
    have cognizance of the shipment in accordance with paragraphs 70.58(b)(3)
    and 73.45(e)(2)(i).
    c. Written procedures should be established and maintained to
    assign to specific organizational components the responsibility for
    packaging the shipment and ensuring that it is packaged and transported in
    accordance with the provisions of 10 CFR Parts 70, 71, and 73 and other
    applicable regulations.
    d. Organizational components responsible for the shipment within
    the plant and in transit should have a set of written procedures that
    cover both normal and emergency conditions in accordance with paragraphs
    70.58(b)(3), 73.25(d), and 73.45(g).
    e. The shipper should notify the consignee of the pertinent
    details of the shipment as described in Section 73.27.
    f. The shipper should initiate and distribute a Nuclear Material
    Transaction Report (DOE/NRC Form-741) in accordance with Section 70.54 and
    the printed instructions for completing the form.
    g. In accordance with paragraph 73.45(e)(2)(ii), the shipping
    group should, as a minimum, check the items and tamper-safing tag
    information and the tag quantities against the information on the transfer
    forms. Each tamper-indicating device should be checked. It is also
    desirable that the shipping group make a gross weighing of each item.
    h. Shipper-receiver differences, the quantity difference between
    the amount of SSNM stated by the shipper as having been shipped and the
    amount received as measured by the receiver, should be reviewed and
    evaluated in accordance with paragraph 70.58(g).
4. RECEIPTS
    a. A licensee should accept receipt of only those types and
    quantities of SSNM authorized by his license. If other material is
    delivered to the facility, the licensee should notify the shipper
    immediately so that appropriate arrangements can be made for the
    disposition of the material and the continuous maintenance of adequate
    physical protection.
    b. Arrangements should be made to deliver the material to the
    receiver at a time when personnel are available to properly handle the
    material in accordance with paragraph 73.25(b)(1)(i). It is the
    responsibility of shipper, receiver, and carrier to ensure that trained
    personnel are available to properly handle deliveries of SNM. If it
    appears to the shipper or carrier that the shipment may arrive at a time
    other than that for which arrangements were made, the shipper or carrier
    should immediately inform the receiver so that the receiver can have
    trained personnel available when the shipment arrives. If the shipment
    fails to arrive at the scheduled time, the receiving licensee should
    notify the shipper in accordance with paragraph 73.71(b) so that a prompt
    investigation can be initiated.
    c. The identification and integrity of the shipper's
    tamper-safing devices on each item or container should be verified in
    accordance with paragraph 73.25(c)(4). The piece count and identification
    and gross weight of the items or containers received should be checked
    against the bill of lading, DOE/NRC Form-741, or other appropriate
    shipping document to provide assurance that the shipment was received
    intact. To the extent possible, an overcheck determination by NDA or
    other appropriate means should be made to provide a prompt estimate of the
    SSNM content of each item or container. After the initial receiving
    checks have been performed, the material should be sent to an area where
    the contents of the containers or items can be verified quantitatively in
    accordance with paragraph 70.58(e). Written procedures should be
    established and maintained for verifying the receipts within specific time
    limits so that DOE/NRC Form-741 can be filed within the time required by
    Section 70.54.
    d. If any of the tamper-safing devices have been disturbed in a
    way that may indicate an attempt to render the device inoperable or if the
    device has been damaged accidentally, the following actions should be
    taken:
    (1) The affected containers should be resealed immediately
    by the receiver with another tamper-safing device, and the resealing
    should be witnessed and attested to by the personnel delivering the
    containers.
    (2) After resealing, containers with damaged seals should be
    isolated until the licensee can inspect the containers to determine if a
    loss of SSNM has occurred. This should be accomplished in accordance with
    the procedures described in (3) and (4).
    (3) If a gross weight or NDA overcheck, as appropriate,
    indicates that the contents of any container appear to have been removed,
    the Director of the NRC Inspection and Enforcement (IE) Regional Office
    listed in Appendix A to 10 CFR Part 73 should be notified immediately in
    accordance with Section 73.71. The shipper should also be notified as
    soon as possible. Both IE and the shipper should be given the option of
    witnessing a quantitative assessment of the container's contents. The
    contents of the container should be quantitatively assessed as soon as
    possible. If the shipper and IE elect not to witness the measurement, the
    assessment should be witnessed and attested to by personnel from at least
    two different groups within the receiver's organization.
    (4) If the contents of the containers appear to be in order,
    the shipper should be notified and given the option of witnessing a
    quantitative assessment (weighing and sampling) of the containers contents
    within 48 hours following receipt of the shipment. If the shipper does
    not respond to this offer, the contents of the container should be
    assessed as soon as possible, but in no case later than 48 hours after
    receipt.
    (5) The shipper or IE should be given the results of the
    quantitative assessment immediately if either did not witness the
    assessment.
    e. Within the time specified in the instructions for the
    preparation of DOE/NRC Form-741, the receiver should make an accurate,
    precise, and independent measurement of the SSNM content of the material
    received. This measurement should be in accordance with a program for
    acceptable measurement quality as required by paragraph 70.58(f).
    f. The difference between the amount of SSNM stated by the
    shipper as having been shipped and the amount received as measured by the
    receiver should be reviewed and evaluated in accordance with paragraph
    70.58(g). All measurement discrepancies should be reported to the nuclear
    material control manager or alternate, who should personally verify the
    discrepancy in the presence of the employee who discovered them. Written
    procedures should quantitatively define what constitutes a discrepancy for
    each type of SSNM received. Appropriate action should be taken to
    reconcile those shipper-receiver differences that are statistically
    significant at the 95% confidence level, except for shipments that involve
    differences of 50 grams or less of U-235 or plutonium. When a discrepancy
    is identified, the nuclear material manager should resolve the discrepancy
    with the shipper. If the discrepancy cannot be resolved, the appropriate
    NRC Inspection and Enforcement Regional Office should be notified by
    telephone, telegram, mailgram, or facsimile. Additional guidance on
    shipper-receiver differences is contained in Regulatory Guide 5.28.
    g. Within 10 days of receipt of material, the receiver should
    complete and distribute the DOE/NRC Form-741 prepared by the shipper in
    accordance with Section 70.54. When receipt measurements cannot be
    completed within this 10-day period, the receiver should complete a
    temporary receipt in one of the following two ways: (1) as indicated in
    the instructions for reporting nuclear material transfers on DOE/NRC
    Form-741, complete blocks "Date Received or Correction Entered" and
    "Signature of Authorized Official and Date Signed" of the form, note on
    the form whether the containers, boxes, or cases reported as shipped were
    received, and mark on the form "Nuclear Material Transfer Receipt" or (2)
    if authorized in the license, prepare NRC form-284, "Nuclear Material
    Transfer Report," as a temporary receipt. In either case, a copy of the
    original DOE/NRC Form-741 issued by the shipper should then be completed
    and distributed within 30 days of receipt to show the receiver's
    measurements. However, if measurements of scrap and irradiated material
    cannot be completed and reported within 30 days of receipt of material and
    if a temporary receipt has been filed on NRC Form-284 or DOE/NRC Form-741,
    the licensee should complete DOE/NRC Form-741 accepting the shipper's
    weights and file a corrected copy to report his or her own measurements at
    a later date.
    VALUE/IMPACT STATEMENT
    A separate value/impact analysis has not been prepared for the
    revision to this regulatory guide. The changes were made to make the
    guide consistent with the upgraded physical protection amendments to the
    regulations published in the Federal Register November 28, 1979 (44 FR
    68184). A value/impact analysis prepared for the proposed amendments was
    made available in the Commission's Public Document Room, 1717 H Street
    NW., Washington, D.C., at the time the proposed amendments were published.
    This analysis is appropriate for the final amendments as well as for the
    regulatory guide revisions appropriate to those amendments.
    58