Publication Date: 12/1/93
    Pages: 26
    Date Entered: 2/9/94
    Title: Material Control and Accounting for Uranium Enrichment Facilities Authorized to Produce Special Nuclear Material of Low Strategic Significance
    U.S. NUCLEAR REGULATORY COMMISSION December 1993
    REGULATORY GUIDE
    OFFICE OF NUCLEAR REGULATORY RESEARCH
    REGULATORY GUIDE 5.67
    (Draft was issued as DG-5002)
    MATERIAL CONTROL AND ACCOUNTING
    FOR URANIUM ENRICHMENT FACILITIES
    AUTHORIZED TO PRODUCE SPECIAL
    NUCLEAR MATERIAL OF LOW STRATEGIC SIGNIFICANCE
    CONTENTS
    Page
A. INTRODUCTION 1
B. DISCUSSION 1
C. REGULATORY POSITION 2
1. Performance Objectives 2
2. Organization 4
3. MC&A Procedures 5
4. Measurements 5
5. Measurement Control Program 6
6. Statistics 9
7. Physical Inventories 10
8. Item Control 12
9. Shipper-Receiver Comparisons 13
10. Assessment of the MC&A Program 14
    11. Resolving Indications of Unauthorized Production of
    Enriched Uranium and Missing Uranium 15
    12. Program for Precluding and Detecting Unauthorized
    Production of Enriched Uranium 17
    13. Recordkeeping 19
D. IMPLEMENTATION 20
    REGULATORY ANALYSIS 21
A. INTRODUCTION
    Section 74.33, "Material Control and Accounting for Uranium
    Enrichment Facilities Authorized To Produce Special Nuclear Material of
    Low Strategic Significance," of 10 CFR Part 74, Material Control and
    Accounting for Special Nuclear Material," contains the material control
    and accounting (MC&A) requirements applicable to enrichment facilities
    authorized to produce and possess more than 1 effective kilogram of
    special nuclear material (SNM) of low strategic significance.
    Section 74.33 establishes MC&A performance objectives to protect
    against, detect, and respond to the use of uranium enrichment equipment
    for the unauthorized production of SNM of moderate or high strategic
    significance or the introduction of undeclared source material (SM) into
    the process equipment for the unauthorized production of uranium of low
    strategic significance. In addition, 10 CFR 74.33 requires licensees to
    provide information that will aid in the investigation of missing uranium
    or unauthorized enrichment of uranium. Section 74.33 also specifies
    performance objectives and required system features and capabilities that
    are consistent with MC&A requirements applicable to other NRC-licensed
    activities involving the possession and use of more than 1 effective
    kilogram of SNM of low strategic significance. Licensees and applicants
    are required by 10 CFR 74.33(b)(1) to submit a fundamental nuclear
    material control plan describing how the performance objectives, system
    features and capabilities, and record-keeping requirements will be met.
    The general performance objectives, set forth in 10 CFR 74.33(a), that
    must be met by the licensee's MC&A program are:
1. Maintain accurate, current, and reliable information of and
    periodically confirm the quantities and locations of source material
    and special nuclear material in the licensee's possession;
2. Protect against and detect production of uranium enriched to 10
    percent* or more in the isotope U-235;
3. Protect against and detect unauthorized production of uranium of low
    strategic significance;
4. Resolve indications of missing uranium;
5. Resolve indications of production of uranium enriched to 10 percent
    or more in the isotope U-235 (for centrifuge enrichment facilities,
    this requirement does not apply to each cascade during its start-up
    process, not to exceed the first 24 hours);
6. Resolve indications of unauthorized production of uranium of low
    strategic significance;
7. Provide information to aid in the investigation of missing uranium;
8. Provide information to aid in the investigation of the production of
    uranium enriched to 10 percent or more in the isotope U-235; and
9. Provide information to aid in the investigation of unauthorized
    production of uranium of low strategic significance.
    /*/All enrichment levels specified in this guide should be treated as
    weight percent and not atom percent.
    This regulatory guide describes methods acceptable to the NRC staff
    for achieving the general performance objectives in 10 CFR 74.33. This
    regulatory guide discusses each important component of a licensee's MC&A
    program and describes methods that may be used to satisfy the rule.
    Any information collection activities mentioned in this regulatory
    guide are contained as requirements in 10 CFR Part 74, which provides the
    regulatory basis for this guide. The information collection requirements
    in 10 CFR Part 74 have been approved by the Office of Management and
    Budget, Approval No. 3150-0123.
B. DISCUSSION
    The MC&A requirements for uranium enrichment facilities specified in
    10 CFR 74.33 have been established to provide adequate safeguards for
    materials at such plants. The basis for such requirements is that the
    safeguards must be at least equivalent to those required for plants
    possessing material of equivalent safeguards significance. Since the
    requirements set forth in 10 CFR 74.33 are performance-based, this
    regulatory guide has been developed to describe one approach to meeting
    those requirements. The rationale for the approach is that the enrichment
    levels that are authorized for NRC-licensed enrichment plants will be the
    same general level as for licensees authorized to fabricate low enriched
    uranium fuel. However, enrichment facilities differ from fabrication
    facilities in that they possess equipment that could be used to produce
    SNM of moderate or high strategic significance. For this reason, the MC&A
    system for enrichment facilities must contain additional safeguards
    features to protect against and detect such activities.
    Since 10 CFR 74.33 is a performance-based regulation, it is the
    objectives rather than the means for achieving them that are defined in 10
    CFR 74.33(a). Thus, applicants or licensees are free to decide how to
    design, manage, and operate their MC&A systems. This regulatory guide is
    not intended to be an exhaustive description of all possible methods a
    licensee might use to achieve the desired objectives. Instead, this
    regulatory guide provides guidance on an acceptable approach for achieving
    the objectives in 10 CFR 74.33(a). Other alternatives are acceptable
    provided they satisfy the requirements of 10 CFR 74.33.
C. REGULATORY POSITION
1. PERFORMANCE OBJECTIVES
    Each licensee subject to 10 CFR 74.33 is required to implement and
    maintain an MC&A system that is capable of achieving the performance
    objectives of 10 CFR 74.33(a).
    1.1 Maintain Accurate, Current, and Reliable Information of and
    Periodically Confirm the Quantities and Locations of Source Material
    and Special Nuclear Material in the Licensee's Possession
    As used in this guide, accurate information means that the amounts
    and locations of the material in question are based on records and
    measurements; current information means that the licensee knows, through
    MC&A records, how much of this material is possessed at any given time and
    its location (i.e., in process or in storage); and reliable information
    means that the quantities and locations of all classes of material and
    items listed in the accounting records are, in fact, correct and
    verifiable.
    1.1.1 Shipments and Receipts
    The licensee must account for all SNM and SM received or shipped.
    This should be accomplished by maintaining reliable records that are based
    on measured values (10 CFR 74.33(c)(2)). Guidance on shipper-receiver
    procedures and the analysis of shipper-receiver data is provided in
    Regulatory Position 9 of this regulatory guide.
    1.1.2 Monitoring Material Movements
    The monitoring program must include the use of item control
    procedures to monitor the location and integrity of items and ensure that
    all SM and SNM quantities of record associated with receipts, shipments,
    discards, and ending inventory are based on measurements (10 CFR
    74.33(c)(6)). The monitoring program should also include process-
    monitoring procedures to maintain current knowledge of the total uranium
    and U-235 within the enrichment process. Guidance on the item control
    program is provided in Regulatory Position 8 of this regulatory guide,
    while guidance on measurements and measurement control programs are in
    Regulatory Positions 4 and 5, respectively. Monitoring the quantity of
    material in process may involve the use of production and quality control
    data. A detailed and accurate recordkeeping system for MC&A and
    production data must be maintained to provide knowledge of the quantity of
    material on a timely basis (10 CFR 74.33(d)).
    1.1.3 Dynamic Physical Inventories
    In order to verify that the controls described in Regulatory
    Position 1.1.2 have been effective, the licensee must perform a dynamic
    physical inventory at intervals not to exceed 65 days (10 CFR
    74.33(c)(4) (i)). This inventory provides a snapshot of the amount of
    material in process at a given time. Regulatory Position 7 provides
    guidance on the conduct of dynamic physical inventories.
    1.1.4 Yearly Plant Physical Inventory
    Once a year, at intervals not to exceed 370 days (10 CFR
    74.33(c)(4)(i)), the licensee must conduct a total plant inventory and
    must be able to detect, with at least a 90 percent power of detection, an
    actual loss or theft of a detection quantity (DQ) that may have occurred
    since the last yearly inventory. DQ is a site-specific parameter that
    depends upon the amount of material processed annually at each facility.
    To satisfy the requirement in 10 CFR 74.33(c)(4)(i) to confirm the
    quantity and location of all SNM and SM currently possessed by the
    enrichment facility, the licensee must conduct both a dynamic
    (nonshutdown) physical inventory of the uranium and U-235 contained within
    the enrichment processing equipment and a static physical inventory of all
    other uranium and U-235 that is not within the processing equipment.
    Criteria pertaining to physical inventories are discussed in Regulatory
    Position 7. The performance of a total plant inventory should include:
1. Measuring (or, when direct measurement is not feasible, using
    indirect measurements) all SNM and SM quantities on hand that have
    not previously been measured in their current form,
2. Verifying the physical presence of all uniquely identified SNM and
    SM items that the accounting records indicate are on hand,
3. Measuring a sample of randomly selected unencapsulated and tinsealed
    items, based on a statistical sampling plan, to confirm the previous
    measurements of SNM and SM contained in each of these items, which
    in turn will be used as the basis for accepting or rejecting the
    total SNM and SM contained in all such items, and
4. Verifying the integrity of all encapsulated items and all tamper-
    safed* items.
    /*/"Tamper-safing" is defined in 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 SNM within the container or vault.
    1.2 Protect Against and Detect Production of Uranium Enriched to 10
    Percent or More in the Isotope U-235
    The licensee should have a program for monitoring the isotopic
    composition of product and depleted uranium streams, independent of
    operations, that provides high assurance of timely detection of production
    of uranium enriched to 10 percent or more in the isotope U-235 before SNM
    of moderate strategic significance could be produced if such production
    could be achieved within 370 days. The licensee may also want to consider
    monitoring other parameters besides enrichment levels and instituting a
    personnel monitoring program to observe activities in the process areas to
    protect against the production of uranium enriched to 10 percent or more
    in the isotope U-235. The enrichment technology used may determine the
    extent of the program. For example, a limited program for a gaseous
    diffusion technology plant would be appropriate because it is difficult
    for a few people to reconfigure the equipment to produce higher
    enrichments in a short time, while a more extensive program for a
    centrifuge technology plant would be appropriate because of the ease of
    reconfiguring the machines to produce higher enrichments in a short period
    of time. The program can use nondestructive assay with fixed detectors,
    portable detectors, or UF6 samples taken and analyzed for U-235
    concentration.
    The program must be managed and maintained independent of the
    operations (production) unit organization (10 CFR 74.33(c)(1)(ii)), but it
    may make use of production and quality control data that are normally
    generated and used by production personnel. Additional guidance for this
    program is provided in Regulatory Position 12 of this regulatory guide.
    The NRC Operations Center must be notified within 1 hour of
    discovery of any actual production of uranium enriched to 10 percent or
    more in the isotope U-235 as required by 10 CFR 74.11. For centrifuge
    enrichment facilities, this requirement does not apply to each cascade
    during its start-up process, not to exceed the first 24 hours.
    1.3 Protect Against and Detect Unauthorized Production of Uranium of Low
    Strategic Significance
    A program must be implemented that will, with high assurance,
    protect against and detect the unauthorized production of uranium of low
    strategic significance that is not included in the facility's accounting
    records (10 CFR 74.33(a)(3)). The program should be capable of detecting
    the introduction of feed material not declared or recorded in the facility
    MC&A records. The program must be managed and maintained independently of
    the production or operations organizational unit (10 CFR 74.33(c)(1)
    (ii)), but should not be excluded from using process monitoring or
    production control data and equipment. Additional guidance for this
    program is provided in Regulatory Position 12.
    Pursuant to 10 CFR 74.11, discovery of actual unauthorized
    production of uranium of low strategic significance must be reported to
    the NRC Operations Center within 1 hour.
    1.4 Resolve Indications of Missing Uranium
    A formalized program to resolve any indication that uranium SM or
    SNM is missing must be developed (10 CFR 74.33(a)(4)). Resolution of such
    indicators means that the licensee has investigated all information
    relevant to the cause of the indicator and has concluded that a theft or
    loss of SNM or SM has not occurred. As stated in 10 CFR 74.33(c)(6), only
    indications that suggest a possible loss of items or of material from
    items involving 500 grams or more of U-235 need be investigated.
    The procedures that the licensee should under-take to resolve an
    indication of missing uranium depend on the nature of the indicator. In
    some cases, the resolution process would begin with a thorough review of
    the MC&A records to locate blatant errors such as omissions of entire
    items, data entry errors in computer programs or on records, incorrect
    entries, transcription errors, errors in estimating the amount of material
    holdup in equipment, or calculational errors. A detailed examination of
    the MC&A records for the applicable material type should identify gross
    errors. The next stage in the resolution process could be to isolate the
    storage area or the portions of the process that appear to be involved.
    Once this is accomplished, all the information that contributed to the
    determination of the SM and SNM quantities for that storage location or
    process stream should be verified. If there is still no resolution, the
    licensee should consider sampling and remeasuring the applicable material
    in the applicable storage area or process stream to verify the quantities.
    If the investigation of an indication results in a determination that an
    actual loss or theft has occurred, the loss or theft must be reported to
    the NRC in accordance with 10 CFR 74.11. Additional guidance on
    resolution of indications of missing uranium is presented in Regulatory
    Position 11.
    1.5 Resolve Indications of Production of Uranium Enriched to 10 Percent
    or More in the Isotope U-235
    A formalized program designed to resolve indications of the
    production of uranium enriched to 10 percent or more in the isotope U-235
    must be developed (10 CFR 74.33(a)(5)). Resolution of such indications
    means that the licensee has investigated all information relevant to the
    cause of the indicator and has concluded that enrichment of uranium to 10
    percent or more in the isotope U-235 has not occurred. Since unauthorized
    enrichment might not be detected on a timely basis through the conduct of
    the static physical inventories or periodic dynamic physical inventories,
    the resolution process should include investigating all the information
    that contributed to the indication of unauthorized enrichment. Upon
    receipt of an indication that uranium may have been or is being enriched
    to 10 percent or more, the licensee is required by 10 CFR 74.33(a)(5) to
    take appropriate actions to investigate and resolve the indicator.
    Material contained in any suspect process equipment or piping or in a
    suspect container should be measured to determine its U-235 concentration.
    If the indication was generated by instrumentation or measurements, the
    instruments or measurement systems used for monitoring should be examined
    to determine whether they are calibrated and functioning properly. An
    examination of the processing equipment should be performed to ensure that
    unauthorized modifications have not been made. The presence of uranium
    enriched to 10 percent or more should be verified through remeasuring the
    material in question, whether in item form or in process equipment.
    If the resolution process results in a determination that
    unauthorized enrichment of uranium to 10 percent or more in the isotope U-
    235 has actually occurred, this condition must be reported to the NRC
    according to 10 CFR 74.11. For centrifuge enrichment facilities, this
    requirement does not apply to each cascade during the start-up process,
    not to exceed the first 24 hours.
    Guidance on resolution of indications of uranium enriched to 10
    percent or more is presented in Regulatory Position 11.
    1.6 Resolve Indications of Unauthorized Production of Uranium of Low
    Strategic Significance
    A formalized program designed to resolve indications of the
    production of unauthorized uranium enriched to less than 10 percent in the
    isotope U-235 must be developed and followed (10 CFR 74.33 (a)(6)).
    Resolution of such indicators means that the licensee has investigated all
    information relevant to the cause of the indicator and has concluded that
    unauthorized (i.e., undeclared and clandestine) production of uranium
    enriched to less than 10 percent in the isotope U-235 has not occurred.
    Indicators of unauthorized production of uranium of low strategic
    significance can come from many different sources, some of which are
    listed in Regulatory Position 11.2. Therefore, the resolution process
    will be dictated by the type of indicator that occurs. For example, if an
    employee reports that there appears to be an excess of UF6 feed cylinders
    in a storage area, the resolution process might include verifying the
    report and making a detailed analysis of shipping and receiving records as
    well as production records. On the other hand, if it is discovered that
    the rate of enriched uranium production differs from scheduled production,
    it may be appropriate to sample and measure depleted UF6 containers to
    determine whether the U-235 concentration of the depleted uranium is
    consistent with the authorized and declared production of enriched
    uranium.
    In the event of any of these or other indications of unauthorized
    production of uranium enriched to less than 10 percent in the isotope U-
    235, the licensee should determine the cause of the indicator and conclude
    whether or not unauthorized production has occurred or is under way. A
    licensee determination that unauthorized production of uranium of low
    strategic significance has taken place is reportable according to 10 CFR
    74.11. Additional guidance on resolution of indications of unauthorized
    production of uranium of low strategic significance is included in
    Regulatory Position 11.
    1.7 Provide Information To Aid in the Investigation of Missing Uranium,
    the Production of Uranium Enriched to 10 Percent or More in the
    Isotope U-235, or the Unauthorized Production of Uranium of Low
    Strategic Significance
    As previously noted, the detection of any actual loss or theft of
    SNM, or any actual unauthorized production of enriched uranium, is
    reportable under 10 CFR 74.11. Such reports, depending upon the
    seriousness of the material facts, may result in investigations by the NRC
    or other government agencies. The purposes of such investigations would
    be to recover any lost or stolen material, to secure and control any
    unauthorized material produced, and to identify and bring to justice the
    individuals involved. NRC licensees are required by 10 CFR 74.33 (a)(7),
    (a)(8), and (a)(9) to provide any information, particularly the relevant
    information contained in the MC&A records, to assist the NRC or other
    government agencies in their investigations.
2. ORGANIZATION
    2.1 Corporate Organization
    At least one corporate-level official should have responsibilities
    pertaining to the control and accounting of all SM and SNM possessed by
    the licensee (10 CFR 74.33(c)(1)(i)).
    2.2 Facility Organization
    A comprehensive facility management structure should be developed
    (10 CFR 74.33(c)(1)). This structure should clearly establish where the
    responsibility lies for the (1) overall MC&A program, (2) SM and SNM
    custodianship, (3) receiving and shipping of SM and SNM, (4) analytical
    laboratories, (5) physical inventories, (6) monitoring programs to protect
    against and detect unauthorized enrichment activities, and (7) onsite
    nuclear material handling operations.
    The interrelationships of facility positions outside the MC&A
    organization that have responsibilities relating to MC&A activities (such
    as sampling, bulk measurements, analytical measurements) should be
    identified within the management structure.
    2.3 MC&A Organization
    A single individual should be designated as the overall manager of
    the MC&A program. In order to ensure independence of action and
    objectivity of decision making, the MC&A manager should either report
    directly to the facility manager or report to an individual with no
    production responsibilities who reports directly to the facility manager
    (10 CFR 74.33(c)(1)(ii)).
    The responsibilities and authority of each supervisor and manager
    should be established for the various functions within the MC&A
    organization (10 CFR 74.33(c)(1)(iii)). Careful consideration should be
    given to how the activities of one functional unit or individual serve as
    a control over or check the activities of other units or individuals. The
    MC&A manager should have the responsibility for reviewing and approving
    all written MC&A procedures, both within and outside his organization.
    MC&A managers should be appointed to oversee (1) the nuclear material
    accounting program, (2) the measurement control program, (3) the item
    control program, (4) the monitoring programs, and (5) the statistical
    program.
    Whenever more than one key MC&A function is assigned to the same
    person, specific procedures should be developed to preclude such things as
    (1) performance of accounting or record control functions by persons who
    also generate the associated source data and (2) any person having sole
    authority to evaluate or audit information for which he or she is
    responsible (10 CFR 74.33(c)(1)(iii)).
    2.4 MC&A System
    In order to maintain clear overall responsibility for MC&A functions
    (10 CFR 74.33(c)(1)(i)), responsibility for the following MC&A activities
    should be established:
1. Overall MC&A program management,
2. Measurements,
3. Accountability records,
4. Measurement control and statistics,
5. Item control,
6. Physical inventories,
7. Custodial responsibilities (SM and SNM storage and movement
    controls),
8. Monitoring program for detecting unauthorized enrichment activities,
9. Investigation and resolution of indicators (suggesting possible loss
    or possible unauthorized enrichment activities),
10. Receiving and shipping of SM and SNM,
    11. Analytical laboratories, and
    12. MC&A recordkeeping system and controls.
    Policies, instructions, procedures, duties, responsibilities, and
    delegations of authority should be developed to ensure that separation and
    overchecks are built into the MC&A system (10 CFR 74.33(c)(1)(iii)).
3. MC&A PROCEDURES
    Approved written MC&A procedures must be developed and periodically
    reviewed (10 CFR 74.33(c)(1)(iv). These procedures should address the
    following topics:
    . Accountability record system,
    . Sampling and measurements,
    . Measurement control program,
    . Item control program,
    . Static and dynamic physical inventories,
    . Investigation and resolution of loss indicators,
    . Investigation and resolution of indicators suggesting possible
    unauthorized enrichment activities,
    . Monitoring program to detect unauthorized enrichment activities,
    . Determination of the standard error of the inventory difference
    (SEID), active inventory, and inventory difference (ID),
    . MC&A recordkeeping system, and
    . Independent assessment of the effectiveness of the MC&A program.
4. MEASUREMENTS
    4.1 Measurement Systems
    Measurement systems and measurement procedures must be developed in
    order to meet the systems features and capabilities of 10 CFR 74.33(c)(2)
    and (3). A measurement system can be defined as any instrument or device,
    or combination of devices, used to derive a mass, volume, uranium element
    concentration, U-235 isotopic concentration, or U-235 content. Parameters
    that are important to most measurement systems include the measurement
    device or equipment used, standards used for calibration, and standards
    used for control. For analytical laboratory measurements, sampling
    equipment and technique used, sample aliquoting technique, and sample
    pretreatment methodology are often important parameters.
    4.1.1 Bulk Measurement Systems
    For each mass (weight) measurement system, a decision should be made
    as to the weighing device, the type of containers weighed, the material
    within the containers being weighed, the capacity of the weighing device,
    the range to be utilized, and the sensitivity of the device.
    For each volume measurement system, the vessel (tank, column, etc.)
    to which the measurement applies, the capacity of the vessel, the material
    being measured (including uranium and U-235 concentrations), the volume-
    measuring devices, and the sensitivity and range of operation of the
    system should be considered.
    4.1.2 Analytical Measurement Systems
    For each analytical (laboratory) measurement system to be used, the
    following should be considered:
1. Type of material or chemical compound (e.g., UF6, uranium
    alloy, U3O8, uranyl nitrate solution) being measured,
2. Characteristics to be measured (e.g., grams uranium per gram
    sample, U-235 isotopic concentration),
3. Analytical method used,
4. Sampling technique,
5. Sample handling (i.e., pre-analysis sample storage and
    treatment),
6. Measurement interferences (e.g., impurities), and
7. Expected measurement uncertainty.
    4.1.3 NDA Measurement Systems
    For each nondestructive assay (NDA) measurement system to be used,
    the following should be considered:
1. The NDA equipment package (detector and electronics),
2. The type of container being measured,
3. SM or SNM material type within the container,
4. Characteristics being measured,
5. Measurement configuration (e.g., source to detector distance,
    collimation, and shielding),
6. Calculational method, and
7. Expected measurement uncertainty.
    4.2 Measurement Uncertainties
    Special attention should be given to the expected measurement
    uncertainties for each measurement system, for example, the variance from
    calibration, the variance from sampling, and the random error components.
    The smaller each of these components can be made, the greater the
    likelihood that the performance objectives of 10 CFR 74.33 will be met.
    The units in which errors are expressed should be consistent with other
    sources of uncertainty.
    4.3 Measurement Procedures
    A set of approved written measurement procedures must be developed
    and followed (10 CFR 74.33(c)(1)(iv)). The organizational units
    responsible for the preparation, revision, and approval of the measurement
    procedures should be clearly identified. A periodic review of the
    measurement procedures must be conducted (10 CFR 74.33(c)(1)(iv)).
    Measurement procedures should be approved by the overall MC&A manager and
    by the manager of the organizational unit responsible for performing the
    measurement. Measurement procedures should also be approved by the
    measurement control program manager.
5. MEASUREMENT CONTROL PROGRAM
    5.1 Organization and Management
    The organization and management of the measurement control program
    should contain a measurement quality assurance function. Independence
    from the analytical laboratory and from other units performing either
    sample taking or measurements should be maintained (10 CFR
    74.33(c)(1)(iii)). The measurement control program manager should be at
    a management level that is sufficient to ensure objectivity and
    independence of action. Thus, the measurement control program manager
    should 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 measurement control program must be managed to ensure adequate
    calibration frequencies, sufficient control of biases, and sufficient
    measurement precision to achieve the capability required in 10 CFR
    74.33(c)(3).
    5.1.1 Functional Relationship
    The relationship and coordination among the measurement control
    program manager, the analytical laboratory, and any other groups
    performing measurements should be defined clearly (10 CFR 74.33(c)(1)(i)).
    There should be adequate assurance that the measurement control program
    manager has the authority to enforce all applicable measurement control
    requirements.
    5.1.2 Procedures
    The measurement control program procedures must be established and
    maintained (10 CFR 74.33(c)(1)(iv)). All the currently applicable written
    procedures pertaining to measurement control and measurement quality
    assurance should be reviewed annually. Responsibility for preparation,
    revision, and approval of the procedures should be assigned. Individual
    measurement control program procedures should be documented and approved
    by the measurement control manager (10 CFR 74.33(c)(1)(iv)). At a
    minimum, the procedures should address:
1. Calibration frequencies and methods,
2. Standards used for calibration (description and storage
    controls),
3. Standards used for control (obtaining or preparing standards
    and traceability of standards),
4. Control standard measurements,
5. Replicate sampling and replicate measurements,
6. Control limits and control responses,
7. Generation and collection of control data, and
8. Recordkeeping controls and requirements.
    5.1.3 Contractor Program Reviews
    If measurement services are provided by an outside contractor or
    company offsite laboratory, a review program should be developed to
    monitor the offsite measurements (10 CFR 74.33(c)(3)(iii)). The purpose
    of such a program is 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 10
    CFR 74.33(c). An initial review of the contractor's measurement control
    program should be conducted prior to licensee use of measurements
    performed by the contractor or offsite laboratory.
    All contractor or offsite laboratory review findings and
    recommendations should be documented and submitted to both the measurement
    control program manager and the overall MC&A manager in a timely fashion.
    The two managers should arrive at an agreement as to what corrective
    actions, if any, need to be taken, based on their evaluation of the
    report, and transmit these findings to the contractor or offsite
    laboratory in writing. Measurements performed by such contractors or
    offsite laboratories should not be used until the licensee has 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 be
    associated with, the contractor or offsite laboratory so that the
    independence of the conclusions may be maintained.
    5.2 Calibrations
    A calibration program that contains approved procedures for the
    following should be developed:
1. Calibration frequency for each measurement device or system,
2. Identification of the reference standards used for calibration
    of each measurement device or system,
3. Protection and control of calibration standards to maintain
    the validity of their certified or assigned values, and
4. The range of calibration for each measurement device or system
    and the minimum number of calibration runs (observations)
    needed to establish a calibration.
    In general, there are two types of measurement systems-those that
    are recalibrated periodically and those that are calibrated each time the
    system is used, based on one or a few measurements of representative
    standards. The latter type of calibration is often referred to as "point-
    calibration" and is regarded as being bias-free. In the former case, the
    calibration standards need not be representative because system bias is
    estimated from the periodic measurement of representative control
    standards. For point-calibrated measurement systems, the following
    calibration procedures should be followed.
1. The standard or set of standards used to calibrate the
    measurement system should be representative of the process
    unknowns that are measured by the system. That is, the
    representative calibration standard should undergo all the
    measurement steps in the same manner that the unknowns do.
2. One or more calibration standards should be processed
    (measured) along with each unknown or set of unknowns
    measured. That is, both the standard and the unknown are
    measured at the same time with the same person measuring both
    the standard and the unknown.
3. The measurement values assigned to the process unknowns are
    derived from the measurement response observed for the
    standard that was measured along with the unknowns.
4. 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. For unknowns of
    very low concentration, the measurement response should fall
    within plus or minus 4 standard deviations of the response for
    a standard measured at the same time as the unknown.
    For systems that are range-calibrated, SM or SNM accountability
    values should not be based on measurements that fall outside the range of
    calibration. The calibration standards for range-calibrated system need
    not be representative of the process material or items to be measured by
    the calibrated device or system. It is the primary measurement device,
    not necessarily the entire measurement system, that needs to be
    calibrated. This is particularly true when the primary measurement device
    is common to two or more measurement systems. For example, the Davies &
    Gray titration method is often used to analyze samples of different
    uranium materials to determine uranium concentration. In this case, two
    or more measurement systems involving different sampling methods,
    different sample pretreatment methods, and different control standards are
    being utilized. The potassium dichromate titrant is, however, common to
    all systems, and it is the titrant that is calibrated (or standardized)
    with a reference standard such as certified U3O8 or certified uranium
    metal.
    In the case of nonconsumable calibration standards such as weight
    standards, the frequency of recertification should be given special
    consideration. The recertification frequency should depend on how often
    the standards are handled, the standards' stability, and the adequacy of
    the controls used to maintain the integrity of the standards. Biannual
    recertification of such standards is usually acceptable.
    5.3 Control Standard Program
    For those measurement systems that are not point-calibrated, a
    defined program for the periodic measurement of control standards should
    be established and followed. Control standard measurements are performed
    to (1) monitor the stability of a previously established calibration
    factor and (2) estimate the bias of the measurement system over a
    specified period (e.g., an inventory period). The calibration factor is
    the numerical relationship between the observed output of a measurement
    system and the actual value of the characteristic being measured, as based
    on a traceable standard. If there is a possibility of a change in the
    standard's true value from factors such as evaporation, moisture pickup,
    or oxidation, the value of the standard should be checked periodically.
    To be representative of the process materials being measured, a
    control standard 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 potentially could produce 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 cylinders (both empty and
    full) of certified mass to avoid a bias effect caused by buoyancy or point
    loading.
    In addition to material composition and matrix factors, biases can
    be induced by changes in temperature, humidity, line voltage, and
    background radiation, or they may be operator-induced. Therefore, in
    scheduling control standard measurements, the following questions should
    be addressed:
    . Does operator-to-operator variation need to be considered and
    hence monitored?
    . Can environmental or other variables contribute to measurement
    bias?
    . 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? That is, does the relative percent bias
    vary 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?
    . How similar, 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 Program
    In order to estimate the combined analytical and sampling random
    error variance, measurements of replicate (duplicate) samples should be
    performed. Although it is not necessary to estimate how much of the total
    random error is due to sampling and how much is due to analysis, an
    estimate of the random analytical error variance can be obtained by
    performing replicate measurements on single samples. For nonsampling
    measurement systems such as NDA and weight-measurement systems, the random
    error variance can be derived from either replicate measurements performed
    on the process items or the replicate data generated from the measurement
    of control standards.
    For each measurement system involving sampling and analysis, the
    following should be considered: (a) the number of samples to be taken and
    measured and (b) the number of analyses to be performed on each sample.
    Replicate samples should be independent of one another. The minimum
    number of replicate samples measured for each analytical measurement
    system depends upon the number of batches* processed during the inventory
    period. If there are very few batches processed during the inventory
    period, replicate sample measurements on all the batches may be needed.
    If the process in question produces a large number of batches during an
    inventory period, each batch need not be subjected to replicate sampling.
    If 14 or fewer batches are processed during an inventory period, replicate
    samples from each batch should be measured. Otherwise, the minimum number
    of replicate samples to be measured should be the greater of 15 or 15
    percent of the batches generated, unless 15 percent exceeds 50, in which
    case the measurement of more than 50 replicate samples is not necessary.
    /*/"Batch" is defined in 10 CFR 74.4 as a portion of source material or
    SNM handled as a unit for accounting purposes at a key measurement point
    and for which the composition and quantity are defined by a single set of
    measurements. A batch may be in bulk SM or SNM form or contained in a
    number of separate items.
    5.5 Warning and Out-of-Control Limits
    Both warning and out-of-control limits should be established and
    used for both control standard and replicate measurements for those
    measurement systems used for nuclear material accountability. For point-
    calibrated systems, the assigned value of the standards measured along
    with the unknowns is assumed to be valid. Control limits for the
    verification measurements associated with such standards should be
    established. This is particularly applicable to those point-calibrated
    systems that use a single standard, or aliquots from a single standard,
    over any extended period of time.
    The warning and out-of-control limits are normally set based on a
    tradeoff between the cost of investigating and resolving incidents when
    limits are exceeded and the consequences of accepting measurements of poor
    quality. Warning limits should be set at the 0.05 level of significance
    and out-of-control limits should be set at the 0.001 level of
    significance. This means that 95 percent of the time the measurement
    response of the standard is expected to be within the warning limits and
    99.9 percent of the time it is expected to be within the out-of-control
    limits. When a measurement system generates a control measurement
    response 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 below the warning limit. At regular intervals determined in
    advance by the licensee, control standard measurements should be made and
    the data should be analyzed to determine whether control limits should be
    modified.
    5.5.1 Control Charts
    Measurement control data, such as control standard measurement
    results and the differences between measurement values of replicate pairs,
    may be analyzed by automated techniques but should be plotted on graphs.
    All control charts should be reviewed at least once every 2 weeks unless
    the measurement system in question was not used during that period. The
    purpose of this review is to ensure that all occurrences of standards
    measurements falling outside the warning and out-of-control limits are
    documented and appropriate action has been taken. This review is also
    intended to detect situations in which the limits are not exceeded but
    there are problems that would indicate that recalibration or other
    corrective action should be taken. The review should address the
    frequency that control data exceed either the warning or the out-of-
    control limits and should evaluate for any significant trends.
    5.5.2 Response Actions
    The analyst or operator performing a control measurement, or the
    applicable supervisor, should have the responsibility for promptly
    reporting to the measurement control program manager or the designee any
    control measurement that exceeds an out-of-control limit and for taking
    the system out of service with respect to accountability measurements.
    Response and corrective action requirements should be developed and
    documented. As a minimum, response to a reported incident of a control
    measurement exceeding an out-of-control limit should consist of:
1. Verifying that the measurement system in question has been
    taken out of service with respect to accountability
    measurements.
2. Documenting the occurrence of the event,
3. Performing at least two additional control standard
    measurements, and
4. If results of 3, above, do not show the system to be back in
    control, performing additional control measurements using a
    different control standard or different replicate sample (as
    appropriate), recalibrating the measurement system, or, if
    necessary, making system repairs.
    For those measurement systems that make a significant contribution
    to the magnitude of the standard error of the inventory difference (SEID),
    the response to an out-of-control condition should also include
    remeasurement of any samples (items) that were measured prior to the out-
    of-control condition but after the last within-control measurement. The
    validity of the prior measurements can be established without a complete
    remeasurement of all the samples (items) involved if remeasurement on a
    "last in, first out" basis is used. That is, the last sample (item)
    measured prior to the out-of-control measurement should be the first to be
    remeasured, and in reverse order continued until two consecutive
    remeasurements are found to be not statistically different from their
    initial measurements at the 95 percent confidence level. In other words,
    for two consecutive remeasurements, the statistical test of the null
    hypothesis that the difference between the measured and remeasured value
    is zero is not rejected.
6. STATISTICS
    In order to achieve the objectives and capabilities of 10 CFR 74.33,
    a statistical program must be instituted to evaluate the measurement
    control data, ensure that measurements are accurate and precise, ensure
    that measurement data are analyzed in a rigorous manner, and ensure that
    hypotheses concerning the status of the nuclear material possessed are
    appropriately tested. The NRC has sponsored the development of a
    comprehensive reference that specifically addresses the statistical
    treatment of SM and SNM measurement data. The statistical methods
    described in "Statistical Methods for Nuclear Material Management,"
    NUREG/CR-4604,* are acceptable to the NRC staff for satisfying the
    requirements of 10 CFR 74.33.
    /*/W. M. Bowen and C. A. Bennett, NUREG/CR-4604, December 1988. Copies
    may be purchased from the U.S. Government Printing Office, P.0. Box 37082,
    Washington, DC 20013-7082.
    At a minimum, the statistical program should address the following topics:
1. Procedures and methods for estimating measurement variance
    components,
2. Procedures and methods for determining and applying bias
    correction, including:
    . Frequency of bias estimates,
    . Method of determining the effect of a bias on the measured
    quantity of material in individual SM or SNM items,
    . Method for bias corrections to items and conditions under
    which they will be made,
    . Method for determining the effect of biases on inventory
    difference, and
    . Method for applying bias corrections to the inventory
    difference and the conditions under which they will be
    applied,
3. Procedures and methods for determining active inventory.
4. Procedures and methods for determining SEID,
5. Procedures and methods for determining the DQ,* and
6. Procedures and methods for determining the detection threshold
    (DT) values to be used to provide a 90 percent power of
    detecting a loss of a DQ amount of material, as required by 10
    CFR 74.33(c)(4).
    /*/DQ should not exceed 1.3 percent of the annual U-235 quantity
    introduced into the enrichment process except when the 1.3 percent is less
    than 25 kg U-235, in which case the DQ need not be less than 25 kg U-235.
    At least two individuals should independently verify the correctness
    of the SEID calculation for each total plant material balance. If the
    SEID value is calculated using a computer, verification may be
    accomplished during each physical inventory reconciliation process by two
    or more persons checking for correctness of the input data used by the
    computer to calculate SEID and checking the correctness of a sample
    calculation used to verify the computer program.
7. PHYSICAL INVENTORIES
    7.1 General Description
    Detailed procedures should be developed for the conduct of both
    dynamic physical inventories of the enrichment processing equipment and
    static-physical inventories of the balance of the plant (10 CFR
    74.33(c)(1)(iv)). The physical inventory functions and responsibilities
    should be clearly defined and comprehensively reviewed with all persons
    involved before the start of each dynamic and static physical inventory.
    For inventorying the SM and SNM that does not reside in the
    enrichment processing equipment, a book inventory listing derived from the
    MC&A records should be generated just prior to the actual start of the
    inventory. This listing should include all SM and SNM that the records
    indicate should be possessed by the licensee at the cut-off time, except
    for material to be covered by the dynamic physical inventory that is to be
    conducted in conjunction with the static inventory.
    For dynamic physical inventories, a book inventory quantity, to
    which the results of the dynamic physical inventory will be compared, is
    needed. One approach to estimating the in-process inventory is to
    calculate a quantity known as the "running book in-process inventory"
    (RBIPI). Essentially, this calculation is analogous to determining one's
    checkbook balance. First, the amount of SM and SNM introduced into the
    process since the last dynamic physical inventory is added to the amount
    that was in the process at that time. Then the amount of material removed
    from the process in the same time span is subtracted. The RBIPI is the
    quantity of uranium and U-235 calculated as follows:
    (Due to database constraints, the equation is not included. Please
    contact LIS to obtain a copy.)
    7.2 Organization, Procedures, and Schedules
    The composition and duties of the organization for the typical
    physical inventories, both dynamic and static, should be established in
    advance of the inventories. The individual having responsibility for the
    coordination of the physical inventory effort should be identified.
    Written procedures for both dynamic and static physical inventories should
    be developed and approved by the MC&A manager and no revisions should be
    made to these procedures without his or her approval (10 CFR
    74.33(c)(1)(iv)). Specific inventory instructions should be prepared and
    issued for each dynamic and static physical inventory.
    7.3 Inventory Composition
    The quantity of material within the enrichment equipment for both
    uranium and U-235 at the time of dynamic physical inventory should be
    accounted for. UF6 cylinders connected (valved in) to the enrichment
    process system should be included as part of the dynamic physical
    inventory. For static physical inventories, the item composition should
    be categorized as depleted uranium, natural uranium, or enriched uranium.
    If different size cylinders or other containers are used within one of the
    three UF6 categories, they should be treated as different item strata.
    7.4 Conducting Dynamic Physical Inventories
    The licensee is required by 10 CFR 74.33(c)(4) to perform a dynamic
    physical inventory, which involves striking a material balance around the
    processing equipment as described in Regulatory Position 7.1. In-direct
    measurements and production parameters (as well as the analysis of process
    samples) to determine the quantity of material within the enrichment
    process may be used. The estimate of the amount of material within the
    process should be compared to that shown by the MC&A records to provide an
    indication as to whether or not a loss or theft has occurred. The loss
    detection sensitivity associated with the bimonthly dynamic inventories
    should be sufficient to detect a loss or theft of DQ or greater over a 12-
    month period with at least a 90 percent power of detection. A DQ is a
    site-specific quantity of U-235, the value of which is discussed in
    Regulatory Position 6 of this regulatory guide.
    7.5 Conducting Static Physical Inventories
    Detailed written procedures and methods associated with performing
    static physical inventories should be developed (10 CFR 74.33(c)(1)(iv)).
    These procedures should address the following:
    . The organization and independence of inventory functions,
    . Assignment of inventory teams and the instructions given to
    each team,
    . The processes of obtaining, verifying, and recording source
    data,
    . Control of inventory forms,
    . The process for verifying the presence of each item while
    preventing multiple counting of any item, and
    . The procedures for halting processing and material movement
    after the physical inventory has started for nonenrichment
    processes such as scrap recovery.
    Procedures should be developed for item storage and handling or
    tamper-indicating methods that are used to ensure that prior measurements
    are valid and may be used for inventory purposes (10 CFR 74.33(c)(1)
    (iv)). Also, inventory procedures should address how item identities are
    verified and how tampering with the contents of items will be detected.
    For items that are not encapsulated, affixed with a tamper-
    indicating seal, or otherwise protected to ensure the validity of prior
    measurements, procedures should be developed for determining which items
    are to be measured at physical inventory time. Criteria should be
    developed for the justification of any proposed alternatives to
    measurement of any SM and SNM included in the inventory. A statistical
    sampling plan for determining how many and which items are to be randomly
    selected for remeasurement may be an alternative method to 100 percent
    verification of prior measurements. Such a plan should address the
    following:
    . The method of classifying into several strata the types of
    items to be sampled:
    . The method for calculating the sample size for each stratum;
    . The quality of the measurement methods used to verify original
    measurement values;
    . The procedure for reconciling discrepancies between original
    and remeasured values, including when additional tests and
    remeasurements would be performed: and
    . The basis for discarding the value of a previous measurement
    of SM or SNM value and replacing it with a remeasured value.
    One acceptable means for establishing the number of items to be
    randomly selected for remeasurement from a given material type is given by
    the following equation, which calculates the number of items that would
    need to be remeasured to give a 90 percent probability of detecting the
    loss of DQ kilograms of U-235 from the given material stratum:*
    (Due to database constraints, this equation is not included. Please
    contact LIS to obtain a copy.)
    /*/G.F. Piepel and R.J. Brouns, "Statistical Sampling Plans for Prior
    Measurement Verification and Determination of the SNM Content of
    Inventories," prepared for the NRC by Pacific Northwest Laboratory,
    NUREG/CR-2466 (PNL-4057), March 1982.
    Any items on ending inventory that have not been previously measured
    must be measured for inventory purposes (10 CFR 74.33(c)(2)).
    Procedures should be developed for determining when the element and
    isotope factors for items, objects, or containers will be measured
    directly for inventory and when they may be based on other measurements.
    These procedures should clarify the conditions under which it is
    permissible to apply an average enrichment factor to the measured uranium
    element content and the method used to determine the factor.
    If the content of items is established through prior measurements
    and those items are tamper-safed or access to them is controlled, the
    current SM or SNM quantity in those items may be based on those measured
    values. Otherwise, verification of SM or SNM content can be achieved by
    reweighing either (1) all the 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 a significant change in the uranium concentration (or weight
    fraction) or in the uranium isotopic composition. For example, oxidation
    or change in moisture content will alter the uranium concentration.
    7.6 Inventory Difference Limits and Response Actions
    A well-defined system for evaluating total plant inventory
    differences (IDs) and taking action when IDs exceed certain predetermined
    thresholds should be established and followed. As a minimum, there should
    be a response level if the U-235 ID is equal to or exceeds the detection
    threshold (DT). The DT for such an ID problem (DT = DQ - 1.3 SEID) may be
    interpreted in the following manner. If an actual loss or theft of a DQ
    amount or more occurred since the last static physical inventory, there is
    at least a 90 percent probability that the inventory difference will
    exceed the detection threshold. The above limit is expressed in terms of
    absolute values of ID (i.e., no regard for algebraic sign).
    For any unresolved ID that remains greater than or equal to DT (even
    if the ID is negative), the licensee may need to take steps for scheduling
    a plant-wide reinventory and investigation. Intermediate-level
    thresholds may be useful in order to provide a timely mechanism for
    detection of losses that are less than a DQ so that the occurrence of an
    ID greater than or equal to DT may be avoided in future physical
    inventories.
    The regulation in 10 CFR 74.33(c)(4)(i) requires static and dynamic
    physical inventories for both uranium element and U-235, and 10 CFR 74.33
    (c)(4)(ii) requires the reconciliation and adjustment of the book
    inventory for the results of the static physical inventory for both
    uranium element and U-235.
8. ITEM CONTROL
    8.1 Organization
    The person to be responsible for overseeing the item control program
    and the persons who have significant item control program responsibilities
    should be identified in the applicable MC&A procedures.
    8.2 General Description
    The MC&A system must maintain records of all SM and SNM items,
    regardless of quantity or duration of existence (10 CFR 74.33(c)(6)(i)).
    In addition, the item control program should provide current information
    about the location, identity, and uranium and U-235 quantity of all
    nonexempt SM and SNM items (10 CFR 74.33(c)(6)(i)). Items that can be
    exempt from item control program coverage are:
1. Items that exist for less than 14 calendar days, and
2. Any licensee-identified items containing less than 500 grams
    U-235 provided the cumulative total of such exempted items
    does not exceed 50 kilograms U-235.
    All items, whether or not they are subject to the item control
    program, should have a unique identity. For items subject to the item
    control program, the following are acceptable means for providing a unique
    identity:
    . A unique alpha-numeric identification on a tamper-safe seal
    that has been applied to a container of SM or SNM,
    . A unique alpha-numeric identification permanently inscribed,
    embossed, or stamped on the container or item itself, or
    . A uniquely prenumbered (or bar coded) label applied to each
    item; the label has adhesive qualities such that its removal
    from an item would preclude its reuse.
    Locations of items shown by the item control program records need
    not be unique, but location designations should be specific enough so that
    any item can be located in a timely fashion. The MC&A record system must
    be tamper-proof and controlled in such a manner that the record of an
    item's existence cannot be destroyed or falsified without a high
    probability of detection (10 CFR 74.33(d)(3)).
    Each nonexempt item should be stored and handled in a manner that
    enables detection of, and provides protection against, unauthorized or
    unrecorded removals of SM and SNM.
    8.3 Item Identity Controls
    Tamper-safe seals or other tamper-indicating devices may be used to
    provide unique item identity. Procedures should be developed for:
1. The type of seals utilized for the various types of containers
    stored,
2. The method of seal procurement and measures taken to ensure
    that duplicate (counterfeit) seals are not manufactured.
3. Seal storage, control, distribution, destruction, and
    accounting, and
4. Maintenance and control of seal usage and disposal records.
    8.4 Storage Controls
    Storage areas and controls for items are important elements in the
    item control program because they form the basis for accepting prior
    measurements of items, as opposed to remeasuring the item at inventory
    time. Any controls used to ensure the validity of prior measurements
    should be equivalent to the protection provided by tamper-safing seals.
    Both administrative controls (such as custodian assignments and limiting
    authorized access to storage areas) and physical controls (e.g., locked
    and alarmed doors) may be used.
    8.5 Item-Monitoring Methodology and Procedures
    As part of the item control program, a system of item monitoring
    that includes the following should be maintained:
1. Verification that items shown in the MC&A records are actually
    stored and identified in the manner indicated in the records,
2. Verification that generated items and changes in item
    locations are properly recorded in the MC&A record system in
    a timely manner, and
3. Detection, with high probability, of a real loss of items (or
    uranium from items) amounting to 500 grams or more of U-235.
    The item-monitoring system should periodically include:
    . Checking the actual storage status of a sufficient sample of
    randomly selected items from the item control program records
    from each stratum to confirm that the recorded information is
    correct,
    . Checking the accuracy of the item control program records for
    a sufficient sample of randomly selected items from each
    storage area to ensure that all items are being properly
    entered into the records, and
    . Checking the accuracy of a sufficient sample of randomly
    selected production records of created and consumed items.
    The actual frequency of the above checks and the size of the random
    sample should be a function of an expected discrepancy rate based on prior
    observations. Items that cannot be located are not discrepancies but
    indications of possible loss or theft. On the contrary, discrepancies are
    inadvertent conditions such as items not in assigned locations and
    incorrect entries in item control program records.
    8.6 Investigation and Resolution of Loss Indicators
    Procedures and controls should be developed to ensure that all
    incidents involving missing or compromised items or falsified item records
    will be investigated. A compromised item is one with evidence of
    tampering or an unsealed and unencapsulated item that has been assigned to
    a limited access, controlled storage area, but is found elsewhere. If any
    unencapsulated and unsealed item is located after it has been determined
    that it is missing or if an item is found to be compromised, the contents
    should be verified by measurement. Additional guidance on resolution of
    item discrepancies is included in Regulatory Position 11.
9. SHIPPER-RECEIVER COMPARISONS
    9.1 Receiving Procedures
    The first action to be taken by the licensee upon receipt of SM or SNM
    should be verification of the correct number of items, the correct
    identity of the items, and the integrity of the tamper-indicating seals.
    The maximum elapsed time for determining whether or not a significant
    shipper-receiver difference (SRD) exists should be established by the
    licensee and should not exceed 30 calendar days.
    9.2 Determination of Receiver's Values
    For natural UF6, the licensee may establish the receiver's values by
    measuring U-235 concentration (either by NDA or by sampling and analysis),
    weighing each cylinder, and using a nominal percent uranium factor. All
    SNM receipts, and any SM receipts not in the form of UF6, should be
    measured for uranium and U-235 content.
    9.3 Evaluation of SRDs
    SRDs greater than 500 grams of U-235 are evaluated by testing the
    hypothesis that the SRD equals zero. NUREG/CR-4604, "Statistical Method
    for Nuclear Material Management,"* in the chapter on hypothesis testing,
    provides methods that are acceptable to the NRC.
    /*/W.M. Bowen and C.A. Bennett, NUREG/CR-4604, December 1988. Copies may
    be purchased from the U.S. Government Printing Office, P.O. Box 37082,
    Washington, DC 20013-7082.
    9.4 Resolution of Significant SRDs
    Resolution of a significant SRD usually involves an independent
    measurement of retainer samples. A retainer sample is one taken prior to
    shipment of the material and kept until shipper-receiver comparisons are
    resolved and it is determined that there is no dispute concerning the
    amount shipped. Resolution of such SRDs could involve testing three
    hypotheses. The first hypothesis is that the difference between the
    shipper's weight and the receiver's weight is zero. The second hypothesis
    is that the difference between the shipper's percent uranium element
    measurement and the receiver's percent uranium element measurement is
    zero. The third hypothesis is that the difference between the shipper's
    U-235 measurement value and the receiver's U-235 measurement value is
    zero.
    If an SRD is statistically significant and it is 500 or more grams
    of U-235, it must be resolved (10 CFR 74.33(c)(7)). In the event that
    such an SRD occurs, the first thing to resolve is any significant
    difference between the shipper's and receiver's net weights of the
    material shipped (e.g., kilograms UF6). Since the shipper will not be
    able to repeat the measurements upon which his net weights will be based,
    the licensee's resolution procedure should specify how the net weight
    value to which both the shipper and receiver agree is to be determined.
    When the shipper's and receiver's net weights are in statistical agreement
    with one another, the receiver can proceed to resolve the differences in
    elemental and isotopic measurements of the material in question,
    including, if necessary, remeasurement by the shipper using the retained
    samples.
10. ASSESSMENT OF THE MC&A PROGRAM
    10.1 General Description
    The capabilities, performance, and overall effectiveness of the
    licensee's MC&A program must be independently reviewed and assessed at
    least every 24 months as required by 10 CFR 74.33(c)(8). This
    independence should be established by ensuring that the individual
    responsible for assessing each portion of the MC&A program does not have
    routine responsibilities within that program element. It is preferred
    that the entire MC&A program be reviewed and evaluated during each
    assessment. If so, intervals between assessments can be as long as 24
    months. If individual assessments do not cover the entire MC&A system,
    the intervals should be no longer than 12 months. "Interval" means the
    elapsed time between either the start of or termination of successive
    assessments.
    The responsibility and authority in the licensee's organizational
    structure for the assessment program should be at least one level higher
    than that of the MC&A manager. Such responsibility should include the
    selection of the assessment team leader and the initiation of corrective
    actions. Team 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 system for which that person has direct
    responsibility. Hence, the MC&A manager can not be a team member. Also,
    to guard against collusion, no pair of team members should perform
    assessments of each other's area of responsibility. 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 team
    should depend on the knowledge and expertise of the team relative to MC&A
    activities and on their experience in conducting reviews.
    Personnel assigned to the assessment team should have a good
    understanding of the objectives and the 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 system they review. The team should have
    authority to investigate all aspects of the MC&A system and should be
    given access to all necessary information.
    In order 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 must encompass the entire MC&A system, and
    the level of detail of the reviews should be sufficient to ensure that the
    assessment team has adequate information to make meaningful judgments of
    the MC&A program's effectiveness (10 CFR 74.33(c)(8)(i)). The report
    should provide findings pertaining to:
1. Organizational effectiveness to manage and execute MC&A
    activities,
2. Management responsiveness to indications of possible losses of
    uranium and of possible unauthorized enrichment activities,
3. Staff training and competency to carry out MC&A functions,
4. Reliability and accuracy of accountability measurements made
    on SM and SNM,
5. Effectiveness of the measurement control program in monitoring
    measurement systems and its sufficiency to meet the
    requirements for controlling and estimating both bias and
    SEID,
6. Accuracy of the material accounting records,
7. Effectiveness of the item control program to track and provide
    current knowledge of items,
8. Capability to promptly locate items and effectiveness in doing
    so,
9. Timeliness and effectiveness of SRD evaluations and resolution
    of excessive SRDs,
10. Reliability and effectiveness of the inventory-taking
    procedures,
    11. Capability to confirm the quantities and locations of SM and
    SNM,
    12. Capability to detect and resolve indications of unauthorized
    enrichment activities and the effectiveness of doing so, and
    13. Capability to detect and resolve indications of missing
    uranium and the effectiveness of doing so.
    On completion of each assessment, the findings and recommendations
    for corrective action, if any, must be documented (10 CFR
    74.33(c)(8)(ii)). The written report should be distributed to the plant
    manager, the MC&A manager, and other managers affected by the assessment.
    10.3 Management Review and Response to Report Findings and
    Recommendations
    Management should review the assessment report and take the
    necessary actions to correct any MC&A system deficiencies. The management
    review must be documented (10 CFR 74.33(c)(8)(iii)), 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.
    11. RESOLVING INDICATIONS OF UNAUTHORIZED PRODUCTION OF ENRICHED URANIUM
    AND MISSING URANIUM
    Procedures must be developed for resolving indicators of either
    missing uranium involving 500 or more grams U-235 or of indicators of
    unauthorized enrichment (10 CFR 74.33(a)(4), (5), (6), and 10 CFR
    74.33(c)(1)(iv) and (c)(5)). The three generic types of indications are:
1. Indications that either uranium source material or enriched uranium
    is missing,
2. Indications that unauthorized production of uranium of low strategic
    significance has been or is occurring, and
3. Indications that the enrichment equipment has been or is being used
    to produce enriched uranium with an enrichment of 10 percent or more
    in the isotope U-235.
    The resolution program should address the possible indicators of
    missing uranium. A determination of potential indicators that can be
    postulated for the three types of indications above should be made, and
    appropriate resolution procedures for each postulated indicator should be
    identified. In addition, the time limits within which resolution of
    indicators must be accomplished and the actions to be taken if resolution
    has not occurred within that time should be specified.
    11.1 Indicators of Missing Uranium
    Possible indicators of missing uranium include:
    . Determination through the item control program that a specific
    item is not in its authorized location and its actual location
    is not known,
    . Discovery of tampering with the MC&A records,
    . Discovery that an item's integrity or its tamper-indicating
    seal has been compromised,
    . A significantly lower remeasured value on any item, batch, or
    lot of measured material in which the difference between the
    original and remeasured values exceeds twice the standard
    error plus 500 grams or more U-235,
    . Discovery of unauthorized feed or withdrawal equipment in the
    processing area.
    . Information from the process control system indicating a
    potential loss of material from the process system.
    Resolution of an indication means that the licensee has concluded
    that a loss or theft of more than 500 grams of U-235 has not occurred.
    For each anticipated type of loss indicator, a detailed resolution
    procedure should be developed.
    When appropriate, the resolution process may include (1) a thorough
    check of the accountability records and source information, (2) locating
    and isolating the source of the problem, (3) isolating the exact reason
    for the problem within the area or processing unit, (4) determining the
    amounts of uranium and U-235 involved, and (5) making a determination that
    the indication is or is not resolved. The resolution procedures should be
    implemented in such a manner that no individual who could have been
    responsible for the potential loss could also be responsible for
    resolution.
    11.2 Indications of Unauthorized Production of Uranium Enriched to Less
    Than 10 Percent in the Isotope U-235
    Possible indicators of unauthorized production of uranium enriched
    to less than 10 percent in the isotope U-235 include:
    . Presence of unauthorized product, feed, or depleted uranium
    cylinders in the processing area,
    . Presence of UF6 cylinders that have not been entered into the
    MC&A record system,
    . Variations from planned production schedules,
    . A change in the enrichment assay of UF6 tails from that
    specified by production schedules,
    . An excess amount of depleted uranium or an excess rate of
    depleted uranium production,
    . Incorrectly identified cylinders, such as depleted uranium or
    feed identified as enriched product material,
    . Discovery of tampering with the MC&A records,
    . Discovery of unauthorized feed or withdrawal equipment in the
    processing area,
    . An allegation that unauthorized enrichment of uranium to 9.9
    percent or less in the isotope U-235 is or has been occurring,
    and
    . Reconfiguration of the enrichment equipment to permit
    unauthorized operation.
    Resolution of an indication means that the licensee has concluded
    that unauthorized production of uranium enriched to less than 10 percent
    in the isotope U-235 has not occurred and is not occurring. For each
    anticipated type of indicator, detailed resolution procedures should be
    developed.
    In the event of any of these or other indicators of possible
    unauthorized production of uranium enriched to less than 10 percent in the
    isotope U-235, the licensee should determine the indicator's cause and
    come to a conclusion as to whether or not unauthorized production has
    occurred or is occurring. If an indication of unauthorized production is
    determined to be true, the NRC must be notified within 1 hour pursuant to
    10 CFR 74.11.
    11.3 Indications of Unauthorized Production of Uranium Enriched to 10
    Percent or More in the Isotope U-235
    Possible indicators of unauthorized production of uranium enriched
    to 10 percent or greater in the isotope U-235 include:
    . Any measurement from a process stream monitoring program that
    indicates out-of-specification enrichment concentrations,
    . Unauthorized withdrawal equipment in the enrichment processing
    area,
    . Unauthorized reconfiguration of enrichment equipment,
    . Discovery that enrichment-level monitoring equipment has been
    compromised,
    . An allegation that unauthorized production of uranium enriched
    to 10 percent or more in the isotope U-235 has occurred or is
    occurring, and
    . Higher than normal nuclear signal, caused by the presence of
    uranium enriched to 10 percent or more, from a container or
    process system.
    Resolution of an indication means that the licensee has concluded
    that unauthorized production of uranium enriched to 10 percent or greater
    in the isotope U-235 has not occurred and is not occurring. For each
    anticipated type of indicator, detailed resolution procedures should be
    developed.
    Since unauthorized enrichment might not be detected through the
    conduct of static physical inventories or dynamic physical inventories,
    the resolution process should include the investigation of all the
    information that contributed to the indication of unauthorized enrichment.
    On receipt of an indication that uranium enriched to 10 percent or more
    may have been or is taking place, the licensee should verify, by
    remeasuring, whether material enriched to greater than 9.99 percent is
    present in the process equipment or items. Depending on the type of
    indicator, immediate isolation of the process area or storage area from
    which the indication was received may be needed until the indication is
    resolved. The instruments and measurement systems used for monitoring
    should be examined to determine whether they are functioning properly.
    The processing equipment should be thoroughly examined to ensure that
    unauthorized modifications have not been made. The presence of uranium
    enriched to 10 percent or more should be verified by remeasuring the
    material in question, whether in item form or in the process equipment.
    If this investigation determines that an indication of unauthorized
    enrichment to 10 percent or more is true, the NRC must be notified within
    1 hour of such determination pursuant to 10 CFR 74.11.
    If the investigation conducted to resolve the indication is
    inconclusive, further measures are needed before the licensee may conclude
    that the indication is resolved. To protect against the relocation and
    concealment of the enriched uranium, a thorough investigation of the
    entire facility should be performed by persons independent of the
    processing organization.
    12. PROGRAM FOR PRECLUDING OR DETECTING UNAUTHORIZED PRODUCTION OF
    ENRICHED URANIUM
    There are several alternative approaches available to protect
    against and detect unauthorized production of enriched uranium. The
    licensee may perform an analysis to identify and evaluate all credible
    scenarios through which clandestine enrichment could occur and provide a
    monitoring program to protect against and detect each scenario. One
    approach for detecting unauthorized production of uranium enriched to 10
    percent or more in the isotope U-235 would be a program to monitor the
    enrichment level of the uranium in all process streams and all possible
    withdrawal paths so that SNM of moderate strategic significance could not
    be produced within any period of 370 calendar days and any uranium
    enriched to 20 percent or more in the isotope U-235 would be detected.
    Detecting production from undeclared feed of enrichment levels that are
    within the limits authorized by license must rely on measures other than
    monitoring of enrichment levels.
    12.1 Organization
    The person responsible for executing the program for precluding or
    detecting unauthorized production of enriched uranium should be identified
    by title or position in the organization. This person need not be part of
    the MC&A organization, but must be independent of the production
    organization. Personnel who are assigned program responsibilities should
    also be independent of production supervision (10 CFR 74.33(c)(1)(ii)).
    This program should be well coordinated with both MC&A and production
    management. The program director should have the necessary authority to
    carry out all aspects of the program.
    12.2 Monitoring Program for Clandestine Enrichment Scenarios
    12.2.1 General Description of Program
    The overall design of this program should be based, at least in
    part, on a clandestine enrichment path analysis. That is, for each
    credible scenario for clandestine enrichment, there should be a monitoring
    system for the timely detection of that scenario.
    With respect to the monitoring program for detecting unauthorized
    production of uranium enriched to 10 percent or more, one acceptable
    approach would be to monitor the enrichment level in all process streams
    and all possible withdrawal paths, at adequate frequencies, so that (1)
    10,000 grams or more of U-235 contained in uranium enriched between 10 and
    20 percent (which would be SNM of moderately strategic significance) could
    not be produced within any period of 370 calendar days, and (2) any
    production of uranium enriched to 20 percent or more (i.e., HEU) would be
    detected before the production of HEU containing 1000 grams of U-235 could
    occur. That is to say, regardless of monitoring methodology, if
    unauthorized production of uranium enriched between 10 and 20 percent in
    U-235 occurs at such a slow rate that production of a quantity
    representing SNM of moderate strategic significance (i.e., 10,000 grams of
    U-235) would take more than 370 calendar days, it is not necessary that
    such production be detected by the monitoring program. However, if SNM of
    moderate strategic significance (involving uranium enriched between 10 and
    20 percent) can result from unauthorized enrichment activities within 370
    days or less, the monitoring is to detect such production before 10,000
    grams of U-235 contained in such material is produced. For unauthorized
    production of uranium enriched to 20 percent or more, regardless of the
    production rate, detection is to occur before 1000 grains of U-235
    contained in HEU is produced.
    These scenarios for production of uranium enriched to 10 percent or
    more in the isotope U-235 should include process system adjustments, batch
    recycle processing, cascade interconnections, cascade isolation, and
    cascade reconfiguration.
    To preclude unauthorized production of uranium enriched to 10
    percent or more in the isotope U-235, the following types of measures
    should be considered:
    . Process design features that preclude unauthorized enrichment
    to be conducted simultaneously with normal (authorized)
    production,
    . Personnel access controls that limit the number of individuals
    who could gain access to the enrichment processing equipment
    or its control mechanisms,
    . Physical security controls such as locked and alarmed doors or
    TV monitors that would detect unauthorized access to
    processing equipment or product material,
    . Process control systems that could detect unauthorized use of
    production equipment,
    . Production control and process monitoring activities that
    could contribute to the detection of the unauthorized
    production of uranium enriched to 10 percent or more in the
    isotope U-235, and
    . Use of tamper-indicating seals on process valves and flanges.
    For the program to protect against and detect unauthorized
    production of uranium enriched to less than 10 percent in the isotope U-
    235, the following topics should be considered:
    . The type of monitoring and surveillance, and its frequency, to
    be applied to the processing areas;
    . The type of monitoring and surveillance, and its frequency, to
    be applied to the process control room and other areas where
    operation of processing equipment can be controlled or
    modified;
    . The type of monitoring and surveillance, and its frequency, to
    be applied to potential feed and withdrawal areas:
    . Process monitoring activities (e.g., radiation and flow
    metering) other than process sampling that could contribute to
    the detection of unauthorized production;
    . Use of tamper-indicating seals on process valves and flanges;
    . Personnel access controls that limit the number of individuals
    who could gain access to the enrichment processing equipment
    or its control mechanisms;
    . Physical security controls such as locked and alarmed doors,
    closed circuit television monitors, etc., that would detect
    unauthorized access to processing equipment or product
    material;
    . Production control activities that could contribute to the
    detection of unauthorized production;
    . Employee education to increase the probability of reporting of
    potential unauthorized activities by facility personnel; and
    . Notification of appropriate MC&A personnel by operations
    organizations of the operating status of the cascades,
    especially when a cascade is isolated from the process stream.
    12.2.2 Program Sensitivity
    While any actual enrichment of uranium to 10 percent or more in the
    isotope U-235 is prohibited (except for cascade start-up in centrifuge
    facilities as noted in Regulatory Position 1.2), the detection sensitivity
    need not be absolute. Since large quantities of uranium enriched to
    between 10 and 20 percent in the isotope U-235 would be required for a
    meaningful malevolent activity, 10 CFR 74.33(c)(5) requires that
    production of uranium in this enrichment range be detected before SNM of
    a moderate strategic significance could be produced within a 370 day
    period. That is to say, there should be a high assurance of detecting the
    production of 10,000 grams or more of U-235 in the form of uranium
    enriched to between 10 and 20 percent in the isotope U-235. Production of
    uranium to greater than 20 percent in the isotope U-235 should be detected
    soon enough to preclude the actual production of 1 kilogram of U-235
    contained in HEU.
    12.2.3 Data, Information, and Activities To Be Monitored
    The means for independently verifying that the actual enrichment
    levels in the various process streams are consistent with design
    enrichment parameters should be developed. In developing the monitoring
    program, activities such as the following should be considered:
    . Independent weighing, sampling, and isotopic assay of material
    introduced at the feed addition stations,
    . Independent weighing, sampling, and isotopic assay of material
    withdrawn at the product and tails withdrawal stations,
    . Independent sampling and isotopic assay of in-process material
    at randomly selected points, and
    . Verification that the quantity of U-235 independently
    determined to be in the product and tails is consistent with
    the independently determined feed input.
    For gaseous diffusion and gas centrifuge facilities, the licensee or
    applicant should consider monitoring such process parameters as UF6 gas
    pressures, flow rates, enrichments, valve positions, operating parameters,
    cascade configuration and connections, and tracking all potential UF6
    containers in the process area. The purpose is to ensure that the amount
    of enriched uranium being produced agrees with production schedules.
    12.3 Program for Monitoring Output Streams
    The overall design of the program should include analysis of all
    processing and product streams to determine where uranium isotopic
    measurements should be made and at what frequency to preclude clandestine
    enrichment activities. That is, for each identified scenario for
    clandestine enrichment, there should be a monitoring system for the timely
    detection of any implementation of that scenario. Since NDA measurement
    techniques can be useful for detecting the presence of uranium enriched to
    unauthorized levels, the use of such techniques, either by manual
    measurements using portable NDA instruments or instruments that are
    permanently affixed to the process equipment, should be considered. In
    the former case, administrative controls should be used to detect or
    preclude collusion of the measurement personnel with a potential
    clandestine perpetrator. In the latter case, frequent inspection and
    testing of the instruments should be performed to detect or preclude
    tampering or disabling of the NDA measurement system.
    The scenario analysis should address each product stream regardless
    of material type or composition and should be conducted by persons that
    have a thorough knowledge of the processing equipment and enrichment
    technology. All conceptual means for production of uranium of enrichment
    levels equal to or greater than 10 percent in the isotope U-235 should be
    identified. These approaches should include process system adjustments,
    batch recycle processing, cascade interconnections, and cascade
    reconfiguration (e.g., increasing the number of stages).
    The extent of the monitoring program should depend on the same types
    of measures as those identified in Regulatory Position 12.2.1 for
    monitoring clandestine enrichment scenarios.
    12.4 Decision Criteria for Declaring Unauthorized Production
    An MC&A procedure that defines the basis for (a) declaring that
    unauthorized production of uranium enriched to 10 percent or more in the
    isotope U-235 has taken place and (b) declaring that unauthorized
    production of uranium enriched to less than 10 percent in the isotope U-
    235 has taken place should be developed.
    Whenever there is an indication that unauthorized enrichment is or
    may be occurring, that indication must be subject to the investigation and
    resolution requirements of 10 CFR 74.33(c)(5), which are discussed in
    Regulatory Position 11 of this regulatory guide. If actual unauthorized
    production of enriched uranium is discovered, that discovery must be
    reported to the NRC within one hour as required by 10 CFR 74.11.
    13. RECORDKEEPING
    13.1 Description of Records
    The MC&A program must utilize and retain all records, forms,
    reports, and standard operating procedures pursuant to 10 CFR 74.33(d).
    Such records should include, but are not limited to, the following:
    . Documents recording changes in the MC&A management structure
    or changes in responsibilities relating to MC&A positions,
    . Any procedures pertaining to accountability measurements
    (including sampling) and measurements related to the
    requirements of 10 CFR 74.33(c)(5),
    . Forms used to record or report measurement data and
    measurement results, including source data,
    . Forms (notebooks, etc.) used to record calibration data
    associated with any accountability measurement system,
    . Forms (notebooks, etc.) 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 used to record or report measurement control program
    data, control limit calculations, out-of-control
    investigations,
    . Forms (listings, instructions, etc.) associated with a
    physical inventory (both dynamic and static),
    . Forms (worksheets, etc.) used in the calculation of SEID, ID,
    and active inventory values,
    . Ledgers (journals, computer printout sheets, etc.) associated
    with the accountability system,
    . Ledgers (journals, computer printout sheets, etc.) associated
    with the item control program, including seal usage and
    "attesting to" records,
    . Completed DOE/NRC-742 and NRC-327 Forms and incoming and
    outgoing DOE/NRC-741 Forms,
    . Forms (memos, reports, etc.) associated with identification
    of, investigation of, and resolution of significant shipper-
    receiver differences,
    . Loss indication and alleged theft investigation reports,
    . Investigation reports pertaining to indications of
    unauthorized enrichment activities,
    . Investigation reports pertaining to excessive inventory
    differences,
    . Reports containing the findings and recommendations of MC&A
    system assessments as well as any letters or memos pertaining
    to actions in response to assessment team recommendations,
    . Forms used for recording data associated with the monitoring
    program,
    . Records and forms used to document authorized reconfiguration
    of enrichment equipment,
    . Status reports or summary reports pertaining to the monitoring
    for unauthorized enrichment and item monitoring programs, and
    . Training, qualification, and requalification reports or
    records.
    All retained records and reports must contain sufficient detail to
    enable NRC inspectors to determine that the licensee has attained the
    system features and capabilities and has met the general performance
    objectives (10 CFR 74.33(d)(1)).
    13.2 Program for Ensuring an Accurate and Reliable Record System
    Controls to ensure that records are highly accurate and reliable
    should be developed. Specific MC&A procedures dealing with record
    protection should be developed and followed. The record system should
    also provide a capability for easy traceability of all SM and SNM
    transactions from the point at which the data is generated to the final
    accounting records.
    This program should address the following topics:
    . The auditing system or program to verify the correctness and
    completeness of records,
    . The procedures designed to prevent or detect the falsification
    or destruction of data or records by an individual,
    . The plan for reconstructing lost or destroyed SM or SNM
    records,
    . Access controls used to ensure that only authorized persons
    can update and correct records, and
    . The protection and redundancy of the record system so that any
    act of record alteration or destruction will not eliminate the
    ability to provide complete MC&A information.
D. IMPLEMENTATION
    The purpose of this section is to provide information to applicants
    regarding the NRC staff's plans for using this regulatory guide.
    Except in those cases in which an applicant proposes an acceptable
    alternative method for complying with specified portions of the
    Commission's regulations, the methods described in this guide will be used
    in the evaluation of Fundamental Nuclear Material Control Plans submitted
    by applicants or licensees pursuant to 10 CFR 74.33.
    REGULATORY ANALYSIS
    A separate regulatory analysis was not prepared for this regulatory
    guide. The regulatory analysis prepared for 10 CFR 74.33, "Nuclear
    Material Control and Accounting for Uranium Enrichment Facilities
    Authorized To Produce Special Nuclear Material of Low Strategic
    Significance," provides the regulatory basis for this guide and examines
    the cost and benefits of the rule as implemented by the guide. The rule
    sets forth the NRC staff position on MC&A at licensed enrichment plants
    and provides safeguards to protect the health and safety of the public.
    While the costs of rulemaking in this instance are slightly higher than
    the costs of imposing license conditions, the advantages of promulgation
    by rulemaking include the opportunity for public comment, which better
    assures that all appropriate issues are raised prior to the imposition of
    these requirements.
    A copy of the regulatory analysis is available for inspection and
    copying for a fee at the NRC Public Document Room, 2120 L Street NW.,
    Washington, DC, as part of the file on the Federal Register Notice dated
    October 31, 1991 (56 FR 55991).