NOT MEASUREMENT
SENSITIVE
DOE-STD-1194-2011
JUNE 2011
────────────────
CHANGE NOTICE NO.2
DECEMBER 2012
────────────────
CHANGE NOTICE NO.3
OCTOBER 2013
DOE STANDARD
NUCLEAR MATERIALS CONTROL AND
ACCOUNTABILITY
U.S. Department of Energy AREA SANS
Washington, D.C. 20585
DISTRIBUTION STATEMENT A. Approved for public release; distribution is unlimited.
ATTACHMENT 1
Change Notice No. 3 DOE –STD-1194-2011
October 2013
Nuclear Materials Control and Accountability
Table of Changes
Page/Section
Change
Page 57/Section 6.4.4.1.
Change from, “ Accounting records and source
documents shall include item identification,
material type, form, quantity, location, gross
weight, net weight, isotope, element concentration,
enrichment for nuclear materials in all MBAs. (If
available)” to” Accounting records and source
documents shall include permanent/indelible item
identification to the extent practicable, material
type, form, quantity, location, gross weight, net
weight, isotope, element concentration, enrichment
for nuclear materials in all MBAs. (If available)”
ATTACHMENT 2
Change Notice No. 2 DOE –STD-1194-2011
December 2012
Nuclear Materials Control and Accountability
Table of Changes
Page/Section
Change
Page 19/Section 6.2.1.1.
Correct “….. value of 239 may be assumed.” , to
…..value of Pu-239 may be assumed.
Page 40/Section 6.2.7.2/
Table 6.2-3: Nuclear
Material Control Measures for Category I
SNM/ Paragraph 2
Correct ….”(See Section XXX - Two- Person
Rule), to (See Section 6.2.4.2 - Two- Person
Rule)
Page 55/Section 6.4 (4)
Change from, “The accounting system provides
data and reports on accountable nuclear material to
NMMSS and Nuclear Materials Inventory
Assessments.”, to “The accounting system
provides data for reporting on accountable nuclear
material to NMMSS and Nuclear Materials
Inventory Assessments.”
Page 57/Section 6.4.3.3
Change from, “ To meet emergency needs the
accounting system shall be capable of being
updated daily or on demand, and a physical
inventory listing of all SNM must be generated
within 3 hours of the request.”, to “To meet
emergency needs the accounting system shall be
capable of being updated daily or on demand, and
a book inventory listing of all SNM must be
generated within 3 hours of the request.”
ATTACHMENT 3
Change Notice No. 1 DOE –STD-1194-2011
August 2011
Nuclear Materials Control and Accountability
Table of Changes
Page/Section
Change
Title Page
Formatting and font size adjusted.
Page 2/Section 4.h.
Reference to document was updated from DOE M
470.4-1 Chg 2, Safeguards and Security Program
Planning and Management, dated 10-2-10 to DOE
O 470.4B, Safeguards and Security Program,
dated 7-21-11.
Page 2/Section 4.i.
Reference to document was updated from
DOE M
470.4-2A Physical Protection, dated 7-23-09
to DOE O 473.3, Protection Program Operations,
dated 6-27-11.
Page 2/Section4.j.
Reference to document was updated from DOE M
470.4-4A, Chg 1, Information Security Manual,
dated 10-12-10 to DOE O 471.6, Information
Security, dated 6-20-11.
Page 2/Section4.k.
Reference to document was updated from DOE M
470.4-5 Personnel Security, dated 8-26-05 to DOE
O 472.2, Personnel Security, dated 7-27-11.
DOE-STD-1194-2011
i
This page is intentionally left blank.
DOE-STD-1194-2011
ii
TABLE OF CONTENTS
FOREWORD
..................................................................................................................................................................................... iii
1 . S C O P E
........................................................................................................................................................................................... 1
2. PUR POS E
..................................................................................................................................................................................... 1
3. APPLICABILITY
......................................................................................................................................................................... 1
4. REF ERE NCE S
............................................................................................................................................................................ 1
5. ACRONYMS AND DEFINITIONS
...................................................................................................................................................... 3
6. SPECIFICATIONS
............................................................................................................................................................................... 6
6.1 Program Management
............................................................................................................................................................... 6
6.1.1 Program Management Objectives
........................................................................................................................................... 6
6.1.2 Material Control and Accountability Organization and Resources
......................................................................................... 6
6.1.3 Material Control and Accountability Plan
.............................................................................................................................. 7
6.1.4 Personnel Training and Qualification
..................................................................................................................................... 8
6.1.5 Change Control
...................................................................................................................................................................... 10
6.1.6 Incident Investigation and Reporting
.................................................................................................................................. 11
6.1.7 Performance Testing
.............................................................................................................................................................. 11
6.1.8 Material Control and Accountability Assessments
............................................................................................................ 15
6.2 Material Control
....................................................................................................................................................................... 18
6.2.1 Nuclear Material Categorization
............................................................................................................................................. 18
6.2.2 Graded Nuclear Material Control
........................................................................................................................................... 26
6.2.3 Access Controls
..................................................................................................................................................................... 27
6.2.4 Material Surveillance
........................................................................................................................................................... 28
6.2.5 Deactivation and Decommissioning
....................................................................................................................................... 37
6.2.6 Termination of Safeguards
.................................................................................................................................................... 38
6.2.7 Returning Materials to the Active Inventory
.......................................................................................................................... 39
6.3 Measurements ............................................................................................................................................................................ 43
6.3.1 Types of Measurements
...................................................................................................................................................... 43
6.3.2 Measurement Methods and Procedures
.............................................................................................................................. 44
6.3.3 Selection and Qualification of Measurement Methods
...................................................................................................... 46
6.3.4 Measurement Control Program
.......................................................................................................................................... 47
6.3.5 Calibration and Standards
................................................................................................................................................... 50
6.3.6 Control Limits
..................................................................................................................................................................... 51
6.4 Accounting ................................................................................................................................................................................. 56
6.4.1 General Accounting Practices
............................................................................................................................................. 56
6.4.2 Account Structure
................................................................................................................................................................ 57
6.4.3 Accounting Systems
............................................................................................................................................................ 57
6.4.4 Accounting Data and Records
............................................................................................................................................... 59
6.4.5 Accounting Reports
............................................................................................................................................................. 60
6.5 Physical Inventory ..................................................................................................................................................................... 63
6.5.1 General Inventory Procedures
............................................................................................................................................. 63
6.5.2 Scheduling and Planning Inventories
................................................................................................................................. 65
6.5.3 Automated Physical Inventories
......................................................................................................................................... 65
6.5.4 Inventory of Unmeasured, Poorly-Measured, Irradiated, and Inaccessible Materials
.......................................................... 66
6.5.5 Evaluating Inventory Programs
.......................................................................................................................................... 67
6.5.6 Inventory Reconciliation
.................................................................................................................................................... 67
6.5.7 Special (Emergency) Inventories
....................................................................................................................................... 68
APPENDICES .............................................................................................................................................................................................
Appendix A: Suggested MC&A Plan Format .................................................................................................................... A-1
Appendix B: Graded Safeguards Table ............................................................................................................................... B-1
Appendix C: Special Nuclear Materials ............................................................................................................................. C-1
Appendix D: Other Accountable Nuclear Materials ......................................................................................................... D-1
CONCLUDING MATERIAL.................................................................................................................................................................. 72
DOE-STD-1194-2011
iii
FOREWORD
This Department of Energy Standard is for use by all DOE elements.
Beneficial comments (recommendations, additions, and deletions) and any pertinent data
that may improve this document should be mailed to the U.S. Department of Energy;
Office of Health, Safety, and Security; Office of Security Policy, GTN/HS-51; 1000
Independence Ave., SW; Washington, DC 20585-1290, or e-mailed to
DOE Technical Standards do not establish requirements. However, all or part of the
provisions in this Standard can become requirements under the following circumstances:
(1)
They are explicitly stated to be requirements in a DOE requirements document (e.g., a
purchase requisition);
(2)
The organization makes a commitment to meet a Standard in a contract,
implementation plan, or program plan; or
(3)
When incorporated into a contract.
Throughout this Standard, the words “must” or “shall” are used to denote actions that must be
performed if the objectives of this Standard are to be met. If the provisions in this Standard
are made requirements through one of the three ways discussed above, then the “shall”
statements would become requirements. Goals or intended functionality are indicated by
“will,” “may,” or “should.” It is not appropriate to consider that “should” statements would
automatically be converted to “shall” statements as this action would violate the
consensus process used to approve this standard.
This Standard was prepared following requirements for due process, consensus, and approval
as required by the U.S. Department of Energy Standards Program. Consensus is established
when substantial agreement has been reached by all members of the writing team and the
Standard has been approved through the DOE directives approval process (REVCOM).
Substantial agreement means much more than a simple majority, but not necessarily
unanimity. Consensus requires that all views and objections be considered, and that a
concerted effort be made toward their resolution.
DOE-STD-1194-2011
1
NUCLEAR MATERIAL CONTROL AND ACCOUNTABILITY
1.
SCOPE
This document describes establishing and maintaining a Material Control and
Accountability (MC&A) program, where each MC&A program element is a part of a
quality MC&A program. Each site/facility operator needs to establish a sustainable,
effective graded safeguards program for the control and accounting of nuclear materials
to detect and deter theft and diversion, and to prevent the unauthorized control of a
weapon, test device, or materials that can be used to make an improvised nuclear
device. The MC&A program implements a defense-in-depth system to ensure that
all accountable nuclear materials are in their authorized location and being used for
their intended purposes such that single component failures will not result in
significant vulnerabilities. An effective and efficient MC&A program is based on
the strategic and monetary value of the nuclear material.
Under the current MC&A DOE Order 474.2, Nuclear Material Control and
Accountability, site/facility operators have many alternatives with regard to how their
MC&A program is designed, managed, and operated. This technical standard is one
methodology that can be used to achieve the desired compliance. The Technical
Standard provides an acceptable MC&A approach commonly or typically used
throughout the DOE and NRC. In the final analysis, DOE line management reviewer
must make a judgment as to whether the site/facility operator can achieve, with high
probability, the objectives stated in DOE O 474.2.
2.
PURPOSE
The purpose of this technical standard is to provide site/facility operators with an
accepted compliance-based means that is acceptable in meeting DOE metrics for MC&A
policy requirement objectives. This is not intended to expand on the DOE O 474.2.
3.
APPLICABILITY
This Technical Standard can be used by all site/facility operators with accountable
nuclear materials and in so doing, will meet all requirements in DOE O 474.2. It also
provides MC&A assessment guidance that can be used by DOE and NNSA to
evaluate the adequacy of MC&A programs and MC&A Plans.
4.
REFERENCES
a.
DOE O 200.1A, Information Technology Management, dated 12-23-08.
b.
DOE
O 205.1B, Department of Energy Cyber Security Program, dated 5-16-11.
c.
DOE O 243.1,
Records Management Program
, dated 2-3-06.
DOE-STD-1194-2011
2
d.
DOE O 251.1C, Departmental Directives Program, dated 1-15-09.
e.
DOE O 413.3B, Program and Project Management for the Acquisition of Capital
Assets, dated 11-29-10 and series of 19 Guides dated 11-07 thru 3-7-10.
f.
DOE O 430.1B, Chg 2, Real Property Asset Management, dated 2-8-08.
g.
DOE O 470.3B,
Graded Security Protection (GSP) Policy
, dated 8-12-08.
h.
DOE O 470.4B,
Safeguards and Security Program
, dated 7-21-11.
i.
DOE O 473.3, Protection Program Operations, dated 6-27-11
j.
DOE O 471.6,
Information Security
, dated 6-20-11.
k.
DOE O 472.2,
Personnel Security
, dated 7-27-11.
l.
DOE O 474.2,
Nuclear Material Control and Accountability
, dated 6-27-2011.
m.
DOE O 422.1, Conduct of Operations, dated 6-29-10.
n.
DOE Administrative Records Schedule 18: Security, Emergency
Planning, and Safety Records, Rev.1, dated 6- 07.
o.
International Target Values 2000 for Measurement Uncertainties in
Safeguarding Nuclear Materials
, IAEA Report STR-327, published
April 2001.
p.
C.W. Coates, B.L. Broadhead, A.M. Krichinsky, R.W. Leggett, M.B. Emmett,
J.B. Hines, Radiation Effects on Personnel Performance Capability and a
Summary of Dose Levels for Spent Research Reactor Fuels, ORNL/TM-
2005/261, Oak Ridge National Laboratory (December 2005).
q.
ASTM C 1215-92 (1997). Standard Guide for Preparing and Integrating
Precision and Bias Statements in Test Methods Standards Used in the
Nuclear Industry.
r.
Nuclear Materials Management and Safeguards System (NMMSS) User
Guide 1.0, via web link (Go to http://www.hss.energy.gov/nmmss/ under
Info), dated October 2008.
s.
References commonly used in the Safeguards and Security Program are
located on the Policy Information Resource website http://pir.pnl.gov.
DOE-STD-1194-2011
3
5.
ACRONYMS AND DEFINITIONS
ACRONYMS:
CFO
Cognizant Field Office
DAC
Daily Administrative Check
DoD
The U.S. Department of Defense
DOE
The U.S. Department of Energy
IAEA
International Atomic Energy Agency
LANMAS
Local Area Nuclear Material Accountability Software
LEID
Limit of Error of the Inventory Difference
MAA
Material Access Area
MBA
Material Balance Area
MBR
Material Balance Report
MC&A
Material Control and Accountability
NBL
New Brunswick Laboratory
NDA
Nondestructive Assay
NIST
National Institute of Standards and Technology
NMMSS
Nuclear Materials Management and Safeguards System
NNSA
National Nuclear Security Administration
NOL
Normal Operating Losses
NRC
Nuclear Regulatory Commission
NTC
National Training Center
PA
Protected Area
PPA
Property Protection Area
REVCOM
Review and Comment, for the U.S. Department of Energy Directives System
RFID
Radiofrequency Identification
RIS
Reporting Identification Symbol
SEID Standard Error of the Inventory Difference
SNM
Special Nuclear Material
TID
Tamper-Indicating Device
VA
Vulnerability Assessment
DOE-STD-1194-2011
4
DEFINITIONS:
Accountable Nuclear Material
is all materials regulated by DOE O 474.2
Active inventory
is the sum of additions to inventory, beginning inventory, ending
inventory, and removals from inventory, after all common terms have been excluded.
Common terms are any material values, which appear in the active inventory calculation
more than once and come from the same measurement.
Beginning inventory (BI)
is the book inventory quantity at the beginning of an inventory
period.
Confirmation Measurement
is a qualitative or quantitative measurement made to verify the
integrity of an item by testing whether some attribute or characteristic of the nuclear
material in the item is consistent with the expected attribute or characteristic of the
material. The measurement method used for confirmatory measurements must be capable
of determining the presence of a specific attribute of the material, consistent with valid
acceptance, and rejection criteria.
Critical System Element is a component or subcomponent of a safeguards and
security protection system that directly affects the ability of the system to
perform a required function. Critical components may be equipment,
procedures, or personnel.
Highly Irradiated is material sufficiently radioactive to ensure a high probability of failure of
task(s) by an adversary. The determination of high probability of failure of task(s) must be
coordinated with the sites risk assessment and/or other assessments performed by the site.
Inventory difference
(ID)
is the arithmetic difference obtained by subtracting the quantity
of SNM tabulated from a physical inventory from the book inventory quantity. Book
inventory quantity is equivalent to the beginning inventory (BI), plus additions to
inventory (A) minus removals from inventory (R), while the physical inventory quantity
is the ending inventory (EI) for the material balance period in question (as physically
determined). Thus mathematically, ID = (BI + A-R) -EI or ID = BI + A-R-EI.
ID
is
sometimes also referred to as material unaccounted for in the international community.
Key Measurement Point is a location where nuclear material appears in such a form
that it may be measured to determine material flow or inventory. Includes, but is not
limited to, the inputs and outputs (including measured discards) and holdings in
material balance areas.
Material Balance
is a calculation evaluating the physical inventory of nuclear material
actually present in an area using beginning and ending inventories after considering transfers
of nuclear material into and out of the material balance area.
Material Balance Area (MBA)
is an area that is both a subsidiary account of materials at a
facility and a single geographical area that has defined boundaries and is an integral
DOE-STD-1194-2011
5
operation. It is used to identify the location and quantity of nuclear materials in the
facility.
Physical inventory
is the determination on a measured basis of the quantity of special
nuclear material on hand at a given time. The methods of physical inventory and
associated measurements will vary depending on the material to be inventoried and the
process involved.
Random Error is the chance variation encountered in all measurement work
characterized by the random occurrence of both positive and negative deviations
from the mean value. (ASTM C1215-92(1997), Standard Guide for Preparing
and Interpreting Precision and Bias Statements in Test Method Standards Used
in the Nuclear Industry)
Reportable Quantity
is the amount of accountable nuclear material for which
changes in quantity, form, composition, location, or program code must be reported to
the National Nuclear Materials Management and Safeguards System (NMMSS), as
required by DOE O 474.2.
Systematic Error is a unidirectional error that affects all members of a data set. The
terms "bias" and "systematic error" are often interchanged. However, any determined
bias (i.e., a bias estimated from control standard measurements) has an uncertainty value
associated with it. Thus, after correcting for any estimated bias, the uncertainty of that
bias can be regarded as a systematic error. If an estimated bias is not applied as a
correction, the combination of the bias, plus its uncertainty, should be regarded as the
systematic error.
Tamper-Indicating Device (TID)
is a device that may be used on items such as
containers and doors, which because of its uniqueness in design or structure, reveals
violations of containment integrity. These devices on doors (and fences) are more
generally called security seals.
Verification Measurement
is a quantitative re-measurement of the amount of nuclear
material in an item made to verify the quantity of nuclear material present. Verification
measurements, when used to adjust accountability records, must have accuracy and
precision comparable to, or better than, the original measurement method
DOE-STD-1194-2011
6
6 SPECIFICATIONS
6.1 PROGRAM MANAGEMENT
6.1.1 Program Management Objectives
(a) The program ensures that documentation is sufficient to maintain a
comprehensive, effective, and cost-efficient program to control and account
for nuclear materials.
(b) The program defines MC&A system elements with performance goals that
reflect consequence of loss or misuse of the material managed by the program.
(c) The program must be graded (i.e., graded protection and graded safeguards)
based on the consequence of loss and contain control and accounting
mechanisms for nuclear materials.
(d) The program establishes and maintains an evaluation program that monitors
the effectiveness of the MC&A system.
(e) The program responds effectively and efficiently to material loss indicators,
anomalous conditions, and degradation of system performance.
(f) Program management ensures the integration of MC&A with Safeguards &
Security and other site programs.
6.1.2 MC&A Organization and Resources
Site/facility operators need to implement a management structure that permits effective
functioning of the MC&A program. Additionally, personnel and equipment resources need to
be clearly delineated. Eliminating ambiguities, about what is to be done by whom, will help
to counter the defeat of the system through neglect, deceit, or falsification, and will free
MC&A management from conflicts of interest with other major responsibilities, such as
mission-related objectives.
6.1.2.1 The site/facility operator management structure shall provide effective control of
accountable nuclear materials.
6.1.2.2 The MC&A organization shall be independent of plant/facility operation
organizations, such that MC&A objectives are met regardless of plant mission
concerns.
6.1.2.3 The internal controls that ensure separation of duties shall be documented. An
individual shall not have sole authority to oversee, evaluate performance, and audit
information for which he/she is responsible.
6.1.2.4 MC&A organization, management structure, lines of authority and points of
interface shall be documented. Functions and responsibilities of the personnel of
the MC&A organization may be delineated on an organizational chart.
6.1.2.5 MC&A activities shall be coordinated and integrated with those of the analytical
and nondestructive assay (NDA) laboratories, site protection programs, operations,
safety, and emergency planning.
DOE-STD-1194-2011
7
6.1.2.6 Responsibilities and authorities for all MC&A activities shall be defined and
documented. At a minimum, the following organizational units and their functions
shall be addressed:
MC&A and nuclear materials management organizations.
Security organization that has responsibility for security systems, control of
locks, assisting in vault ingress and egress, monitoring SNM transfers and
when assigned, the performance testing of SNM portal monitoring, material
surveillance and access controls.
Operational organizational units that have responsibility for processing or
testing nuclear materials, process monitoring, conducting inventories,
nuclear material transfers, and appointing tamper-indicating device (TID)
custodians, TID applicators/verifiers, and material balance area (MBA)
custodians or representatives (when not assigned to the MC&A
organization).
Measurement organizational units that have responsibility for
activities associated with destructive and nondestructive
measurements and their functionality in relationship to process and
accountability measurements, including waste measurements.
Administrative organizational units that include planning, assessments,
testing, training, document preparation, and incident reporting.
6.1.2.7 Line Management shall ensure that the resources and personnel needed to implement
and maintain an effective MC&A program are identified, documented, and
available for work on that project.
6.1.3 MC&A Plan
The approved MC&A Plan provides the safeguards authorization for the site/facility operator
to possess accountable nuclear materials and specifies how those materials are accounted for
and controlled on a graded safeguards basis. It includes all fundamental commitments that
define the bounds within, which the MC&A program will function and the detailed level of
performance. The MC&A plan must define the critical system elements for the MC&A
Program and if there are none, the plan must state this. Development of performance goals
should be methodical and address areas where the most benefit will be achieved within the
constraints of existing resources.
6.1.3.1 The MC&A Plan shall accurately describe the overall MC&A program and its
associated system of controls in sufficient detail to allow evaluation by DOE/NNSA
oversight organizations (The MC&A Plan may be documented similar to the
example outlined in Appendix A).
DOE-STD-1194-2011
8
6.1.3.2 The site/facility operator shall identify key measurement points and types of
measurements in a process map or description (e.g., plan of the day); transfer
operations showing transfer documentation and checks to be performed; and
physical inventories showing the interrelated activities of materials handlers,
measurement personnel, accountants, and statisticians, as applicable.
6.1.3.3 Procedures referenced in the body of the MC&A Plan or detailed in an appendix
may be changed without DOE approval, provided plan commitments and
capabilities are not degraded as a result of the change.
6.1.3.4 Procedures shall be established by the site/facility operator for emergency
conditions and periods when MC&A systems are inoperative. These measures shall
ensure that access to or removal of SNM would be detected during these periods.
6.1.3.5 The MC&A Plan shall describe how MC&A will be implemented following new
construction projects and renovations to existing process areas. Changes to site
operations shall be evaluated for impact to MC&A programs prior to
implementation.
6.1.3.6 The MC&A Plan shall include a description of which MC&A records will be
retained and the length of time they will be retained as required by DOE O 243.1,
Records Management Program.
6.1.3.7 During surveys, DOE line management will further evaluate the Plan by inspecting
and testing MC&A elements against the program element objectives, and
evaluating overall MC&A system effectiveness.
6.1.4 Personnel Training and Qualification
In order to ensure that the MC&A program is implemented effectively and as described in the
MC&A Plan, personnel at all levels of all organizations with MC&A duties and responsibilities
need to be knowledgeable of the MC&A plan and the program it represents. A familiarization
of operations coupled with the MC&A Training and Qualification Program can help ensure
that these individuals are adequately prepared to perform their functions correctly.
6.1.4.1 The MC&A Training and Qualification Program
6.1.4.1.1 The MC&A Training and Qualification Program shall have training that is
evaluated at the site level for consistency with DOE policy and needs, which may
be provided by an external resource.
6.1.4.1.2 The MC&A Training and Qualification Program shall be documented and:
Identify MC&A jobs and their requirements,
Establish minimum qualifications for candidates,
Provide training materials sufficient to ensure that candidates understand
applicable procedures and are qualified to carry out their assigned duties, and
Define re-qualification criteria.
DOE-STD-1194-2011
9
6.1.4.1.3 Training plans shall be derived from a valid needs analysis and periodically
reviewed, at least annually, to ensure that they are current with MC&A jobs
requirements. The training plans shall identify:
Training goals and objectives for each lesson
Positions that receive MC&A training
Types of training used (e.g., on-the-job, classroom, or computer based)
Whether the training is initial or refresher
Whether training is knowledge- and/or performance-based
Lesson materials
Student evaluation and pass/fail criteria
Completion of testing or granting of equivalency documented in the training
records system
6.1.4.1.4 Training that meets analysis requirements can be provided by external resources
such as commercial vendors or other Government training agencies (e.g., National
Training Center).
6.1.4.2 Measurements Training
Measurements are the basis for nuclear materials accountability, and as such, specific training
needs must be afforded to individuals responsible for making these measurements and
evaluating measurement results.
6.1.4.2.1 In addition to the MC&A Training and Qualification Program requirements stated
above, the training needs for personnel who perform sampling and bulk
measurements, NDA measurements, and destructive assay measurements shall be
documented in a measurement or training plan and implemented.
6.1.4.2.2 The measurement or training plan shall include the qualification criteria for
acceptable levels of proficiency prior to personnel performing measurements.
When changes are made in devices or measurement methods being used, the
measurement or training plan shall be reviewed and updated as appropriate.
6.1.4.2.3 Measurement personnel who perform destructive analyses shall demonstrate
proficiency for each method at least once a day or for each batch. It is acceptable to
demonstrate re-qualification based on performance of the measurement on a routine
basis.
6.1.4.2.4 Personnel shall be knowledgeable of the standards and their values for each
measurement system. Where sampling of bulk material is necessary, personnel
shall be familiar with the sampling and sub-sampling programs that are
implemented to ensure that portions of bulk material taken for measurement are
representative of the total bulk material and that sampling errors are minimized.
6.1.4.3 A system of managing MC&A training records shall be developed and maintained
with:
DOE-STD-1194-2011
10
Dates of courses, course title, personnel attendance, and scores/grades
achieved, where applicable
Retention of records in electronic or hardcopy form
Retention of records of training provided at the NTC recorded by the NTC
and the organization sponsoring the individual
Retention of records of training provided at other facilities, including
contractor or other Government facilities (records are provided to and
retained by the organization sponsoring the individual).
6.1.5 Change Control
6.1.5.1 A change control process shall be used to ensure that changes to a procedure,
process, or measurement system are introduced in a controlled and coordinated
manner. Change control reduces the possibility that unnecessary changes/errors
will be introduced to a system or process without forethought. The goals of a
change control procedure should include minimal disruption to services, reduction
in back-out activities, and cost-effective utilization of resources involved in
implementing change.
6.1.5.2 The MC&A Plan must be under change control. Conflicts in upgrading or changing
procedures, processes, systems, or software that are integral to MC&A reporting
and accountability must be avoided. The procedure development, review, revision,
and approval process in DOE O 422.1, Conduct of Operations, Attachment 2,
Section 2, p. Technical Procedures, should be followed. The following is an
example of a change control process:
1. Request for change: The site/facility operator (MC&A personnel) initiates
by making a formal request for something to be changed to management.
The management change control team then records and categorizes that
request. This categorization would include estimates of importance, impact,
and complexity.
2. Assessment of impacts: The impact assessor(s) then make their risk
analysis typically by answering a set of questions concerning risk, both to
the system and to the process, and follow this by making a judgment on who
should carry out the change. If the change requires more than one type of
assessment, the head of the change control team will consolidate these.
Everyone with a stake in the change then must meet to determine whether
there is a technical justification for the change. The change is then sent to
the operations team for planning.
3. Plan: Management will assign the change to a specific team, usually one
with the specific role of carrying out this particular type of change. The
team's first job is to plan the change in detail, as well as construct a backup
plan in case the change needs to be backed out.
DOE-STD-1194-2011
11
4. Test/Approve: If all affected agree with the plan, the delivery team will
build the solution, which will then be tested. They will then seek approval
and request a time and date to carry out the implementation phase.
5. Implement: The site/facility operator must determine a time, date, and cost
of implementation. Following implementation, it is usual to carry out a
post-implementation review which would take place at another meeting.
6. Close Change Action: When all agree that the change was implemented
correctly, the change action can be closed.
6.1.6 Incident Investigation and Reporting
When an incident involving an actual or potential loss of nuclear material is indicated, prompt
actions are necessary to correctly identify the cause in a timely manner. Prompt resolution will
facilitate recovery of “lost” or stolen material, when the following exist:
memories of events leading up to an alarm are fresh,
materials are still available for re-measurement, and
fewer changes in process conditions, inventories, in-process holdup, and item locations
have occurred.
6.1.6.1 An incident shall be reported to DOE line management in accordance with the
reporting requirements, stated in DOE M 470.4-1 Chg 2, Safeguards and Security
Program Planning and Management.
6.1.6.2 The site/facility operator’s alarm resolution program shall identify the type of
anomaly and its cause.
6.1.6.3 Actions shall be taken to ensure that investigation and resolution occurs in a timely
manner.
6.1.7 Performance Testing
Performance testing is required to document MC&A system element and procedure
capability. It is used to validate functional requirements, system operability, and
effectiveness of implementation. Performance testing supports validation of vulnerability
assessments and self-assessments, and must be conducted with the highest regard for the
safety and health of personnel, protection of the environment, protection of Government
property, and national security interests. When used to support vulnerability assessments,
consideration shall be given to depict a level of realism for tests to be representative of the
capabilities of current DOE O 470.3B, Graded Security Protection (GSP) Policy.
6.1.7.1 The site/facility operator shall establish an MC&A Performance Testing Program to
evaluate MC&A system elements that can detect a threat in time to detect loss or
diversion, as well as elements that assure SNM is properly protected and is in
accountability. Critical system elements may include equipment, procedures, and
people.
DOE-STD-1194-2011
12
6.1.7.2 Each MC&A system element or elements identified by the MC&A Performance
Testing Program shall be tested for effectiveness, covering the range of
performance parameters required in the MC&A Plan. These tests, and the number
of tests needed, shall be conducted:
On a schedule based on a combination of graded safeguards, system
reliability, and past performance testing results,
After any equipment repairs, and
After each inoperative or ineffective state for MC&A systems.
6.1.7.3 Safeguards and security performance tests involving MC&A system elements shall
be performed at least every 365 days (annually not to exceed twelve months). The
test shall be based on a comprehensive site or facility threat scenario that
demonstrates overall facility safeguards and security system effectiveness. When
vulnerability assessments are conducted, comprehensive threat scenarios
documented in the vulnerability assessment shall be used.
6.1.7.4 The following MC&A system elements must be tested:
(1) Access controls for Category I and II quantities of SNM - Performance tests for
access controls must be designed and conducted to evaluate the effectiveness.
The tests conducted must demonstrate detection of unauthorized access with at
least a 95 percent probability. Testing of access controls must be facility-
specific, and the scope and the extent of the testing must be documented by the
site/facility operator and approved at a level as specified in the MC&A Plan.
(2) Material surveillance activities for Category I and II quantities of SNM -
Performance tests must be designed and conducted to evaluate the effectiveness
of material surveillance activities. The tests conducted must demonstrate
detection of unauthorized actions, with at least a 95 percent probability.
Material surveillance testing must be facility-specific, and the scope and the
extent of the testing must be documented by the site/facility operator, and at a
level as specified in the MC&A Plan.
(3) Tamper-indicating device application and record system - The TID record
system must accurately reflect the location and identity of TIDs for at least 99
percent of the TIDs inspected. The TID program must ensure that TIDs are
properly in place for at least 95 percent of the TIDs inspected.
a. To comply with the TID performance requirement, TIDs must be
inspected for all items selected for physical inventory and/or transfer.
b. Testing to ensure TIDs are properly in place must include checking to
see that the TID has been properly applied and the integrity of the TID
has not been violated.
c. Performance must be verified at least every 365 days (e.g., annually not
to exceed twelve months) except for facilities whose physical
DOE-STD-1194-2011
13
inventories are conducted less frequently than once a year. For such
facilities, performance must be verified at the same frequency as
inventories are conducted.
d. Testing for this requirement is not intended to require destruction of
properly applied TIDs, whose integrity has not been violated.
Example 6.1.7-1
During a fiscal year, a facility makes 1,500 transfers and 1,000 of them involve
TID’ed items. The physical inventories conducted involve the inspection of 500
items with TIDs. In both cases, there is a procedure requirement to check that
the TID is accurately reflected in the records, and validate that the TID is in
place. Procedures require the facility to report any discrepancies. During the
calendar year, there is a report of 2 TIDs were incorrectly identified
(transposition errors) and 1 TID was improperly applied. The calculation
required is 2/1500 = 0.13 percent incorrectly identified, and 1/1500= 0.067
percent not properly in place. Both of these meet the 99 percent and 95 percent
requirement.
(4) SNM and Metal Portal Monitoring - Performance testing requirements must
include those necessary to verify vulnerability assessments, detection
requirements, and applicable tests described in ASTM International Standard
Guides.
(5) Accounting Record System - The accounting record system must accurately
reflect item identity and location for at least 99 percent of items selected for
physical inventory and/or transfer. If more than 1 percent of the accounting
records selected is found to be in error, corrective actions must be taken for the
accounting system as a whole. Prior definition of what constitutes an error must
be specified. Performance must be verified at least every 365 days (e.g.,
annually, not to exceed twelve months) except for facilities whose physical
inventories are conducted less frequently than once a year. For such facilities,
performance must be verified at the same frequency as inventories are
conducted.
(6) Confirmation/Verification Measurements - For Category I and II items,
acceptance/rejection criteria for verification measurements and, where
technically feasible, for confirmatory measurements, must be based on the
standard deviation for the measurement method under operating conditions.
Control limits for such criteria must be set at no wider than three times the
standard deviation for the method. The control limits must be reviewed and
approved by DOE line management
(7) Inventory Difference Control Limits for MBAs - For Category I and II, MBAs,
limits-of-error must not exceed a 2 percent of the active inventory during the
inventory period and must not exceed a Category II quantity of material. For
Category III and IV, MBAs, limits-of-error of inventory differences must not
exceed a specified percentage of the active inventory during the inventory
DOE-STD-1194-2011
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period to a maximum of a specified quantity; the specified percentage and
maximum quantity must be approved by DOE line management. The term
“active inventory” means the sum of additions to inventory, beginning
inventory, ending inventory, inventory adjustments, and removals from
inventory after all “common terms” have been excluded (in this context,
“common terms” are material values that appear in the active inventory
calculation more than once and come from the same measurement).
Example 6.1.7-2
The below data were observed at the end of an inventory period
for a Category I MBA within a conversion facility that receives
plutonium oxide (PuO
2
) and converts it to plutonium metal. Are
the limits of error for the inventory difference excessive?
Inventory Difference (ID): 2,600 g Pu
Limit of Error for the Inventory Difference (LEID): 3,100 g Pu
Active Inventory: 85,000 g Pu
The LEID of 3,100 g Pu exceeds 0.02*85,000 g Pu = 1,700 g Pu,
which is two percent of the active inventory. Furthermore, if all
of the SNM is conservatively assumed to be Attractiveness Level
B (plutonium metal), the LEID of 3,100 g Pu also exceeds 2,000
g Pu, which is the upper limit of a Category II quantity. For both
conditions, the inventory difference must be investigated.
6.1.7.5 The program shall include a comprehensive set of tests and a frequency of testing
that confirm the capability of implemented and operating MC&A elements. The
scope and frequency of testing shall be based on the graded safeguards concept with
greater testing for Category I locations of SNM than for Category IV locations.
Example 6.1.7-3
A site has 3 Category I MBAs, one of which is a storage MBA and the other
two MBAs are processing areas. There are also 6 Category III MBAs and 8
Category IV MBAs. What would be a possible testing frequency for the
conduct of performance tests?
Answer: Although there are less Category I MBAs, these are more important
and the emphasis should be on MC&A in these areas. The site determined that
50 performance tests would be conducted during the year. The DOE approved
MC&A Plan states that the Category I MBAs are weighted 5 times more
heavily than Category III’s, but performance tests are conducted only one time
for the Category IV’s. The first iteration of performance tests was 25, 5, 1 as a
weighting, which would only be 31 tests. Next are 35, 7, 2, or 44 tests. The
DOE-STD-1194-2011
15
final determination was 38, 9, 3 as the number of performance tests to be
conducted in these Category I, III, and IV MBAs respectively during the year.
6.1.7.6 A description of the MC&A Performance Testing Program shall be provided that
includes the development, implementation, revision, and recordkeeping of test plans
and the preparation of reports. Recordkeeping of performance tests shall be capable
of providing an audit trail that clearly shows the relationship between test data and
test documentation.
6.1.7.7 MC&A program documentation shall address actions taken as a result of
performance test failures. Unsatisfactory performance test results are determined
from criteria specified in test plans, and the site/facility operator shall develop
corrective action plans and, where necessary, take compensatory measures. MC&A
program documentation shall specify when operations protected by inadequate
MC&A measures are altered or suspended.
6.1.7.8 The MC&A program shall be considered in a degraded mode until such testing has
confirmed the operability of all applicable performance parameters. Compensatory
measures may be required during such degraded modes. System elements shall be
evaluated for continuing operability through the conduct of operability tests.
6.1.8 MC&A Assessments
MC&A assessments are periodically conducted to:
Provide assurance to the site/facility operator, and the DOE that safeguards and MC&A
interests and activities are protected at the required levels
Provide a basis for management decisions regarding the MC&A implementation
program, including allocation of resources, acceptance of risk, and mitigation of
vulnerabilities
Identify MC&A program strengths and weaknesses
Provide documentation of compliance- and performance-based oversight activities.
MC&A system effectiveness is determined using assessments and performance testing to
ensure that all elements of the MC&A program are functioning correctly and as planned.
6.1.8.1 The site/facility operator shall establish a self-assessment program to assess the
integrity and quality of its MC&A systems and procedures. The program must
determine the effectiveness of the MC&A system, under both normal operations
and emergency conditions, in deterring, detecting and responding to the
unauthorized removal of SNM from its authorized location and other unauthorized
activities.
6.1.8.2 The scope and content of self-assessments shall be graded based on MBA category
and be documented with the following topics:
Identification of abnormal situations;
DOE-STD-1194-2011
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Loss mechanisms, loss detection capabilities, and localization of inventory
differences;
Selection, maintenance, calibration, and testing functions to ensure proper
equipment and system performance;
MC&A system checks and balances, including separation of responsibilities and
duties, used to identify irregularities and detect tampering with materials or
MC&A system components;
Change controls, including authorization requirements, to detect unauthorized
or inappropriate modification of system components, procedures, or data. The
change control system must address requirements for review, authorization,
documentation, notification, and controls on equipment selection, procurement,
and maintenance;
Procedures or checks to ensure the reliability and accuracy of MC&A data and
information;
Performance testing conducted by the facility operator. This portion of the
assessment should address the design of performance tests and the results
obtained by the testing program since the last assessment;
Procedures for emergency conditions and for periods when MC&A system
components are inoperative;
Material containment, material access, and material surveillance procedures;
Physical inventory program and reconciliation practices;
Accounting system procedures, capabilities, and sensitivities;
Measurement control program; and
TID programs.
6.1.8.3 The self-assessment program shall have a documented schedule, which will be
provided to DOE line management with updates whenever schedule changes are
made. In addition to scheduled assessments, assessments shall be conducted prior
to start-up of new facilities or operations, whenever changes are made in facilities,
operations, or MC&A features that might alter the performance of the MC&A
system, and whenever performance test and assessment results indicate a decline in
performance.
6.1.8.4 The results of performance tests and the assessments of the above MC&A elements
shall be incorporated into an annual evaluation of MC&A system capabilities. This
MC&A system effectiveness evaluation shall be used to support the identification
of MC&A resources and personnel needed to meet program objectives.
6.1.8.5 Self-assessments shall be performed by qualified personnel who are
organizationally independent of process operations.
DOE-STD-1194-2011
17
6.1.8.6 Findings from MC&A self-assessments, shall be maintained in a tracking system
and include a corrective action plan. The corrective action plan shall include:
Schedule for completion
Compensatory measures, when a vulnerability to SNM or the MC&A system is
identified
Evaluation for trends to identify systemic and systematic causal factors.
6.1.8.7 In addition to the assessments described above, knowledgeable personnel,
independent of the MC&A organization, shall conduct internal audits to fairly
evaluate the MC&A function for compliance with internal plans and procedures.
The frequency of these audits must be specified in the MC&A Plan.
DOE-STD-1194-2011
18
6.2 MATERIAL CONTROL
An effective material control program element ensures that nuclear materials are
properly protected and that they are not removed from their authorized location without
approval or timely detection.
The objectives of a nuclear material control system are to:
Detect, assess, and prevent unauthorized access to nuclear material.
Detect, assess, and communicate alarms to response personnel in time to impede
unauthorized use of nuclear material.
Provide loss detection capability for nuclear material, and when not in its authorized
location, be able to provide accurate information needed to assist in locating the
material in a timely manner.
The material containment and surveillance program in conjunction with other security
program elements must have the capability to detect, assess, and respond to
unauthorized activities and anomalous conditions/events.
In coordination with security organizations, material control measures, assure that
appropriate protection and controls are applied to nuclear materials, according to the
quantity and attractiveness of the material.
6.2.1 Nuclear Material Categorization
The material category of SNM locations (e.g., MBAs, material access areas (MAA),
protected areas (PA), and facilities) shall be determined to establish the required protection
levels. Using the quantities of SNM present, and the attractiveness level and categorization
steps below, the material category is determined directly from Appendix B, Graded
Safeguards Table.
6.2.1.1 The attractiveness level of SNM shall be determined and used to assign category
designation to nuclear materials and their locations. The attractiveness level
determination is performed before consideration of the irradiation levels.
DOE O 474.2, Nuclear Material Control and Accountability, ranks SNM based on
their usefulness in constructing a weapon and/or an improvised nuclear device. The
attractiveness level ranking, ranges from Attractiveness Level A materials, which are
directly usable as a weapon and/or an improvised nuclear device to Attractiveness
Level E materials, which require difficult and complex processing before they can be
used to construct a weapon and/or improvised nuclear device.
For Attractiveness Level B through E, the determination shall be made using the
decision tree shown in Figure 6.2-1.
Weight percent SNM is calculated separately for each type of SNM present, by
dividing the weight of the SNM in an item or sample by the net weight of the
item or sample. The net weight is the weight of the material containing the
SNM without simple mechanical removal of cladding or packaging that is
DOE-STD-1194-2011
19
determined by a qualified measurement method.
The weight % SNM used in the calculation is the element weight % for
plutonium or U-233 isotope weight %, or the U-235 weight % for enriched
uranium, and should come from measurements of the isotopic composition.
However, the atomic weight of plutonium may be taken from historical or "flow
sheet" values or a value of Pu-239 may be assumed.
Calculating atom % is only necessary for possible Attractiveness Level B SNM.
Chemical compounds of SNM and SNM metal that is < 50% enriched cannot
exceed the 50 atom % criterion. In addition, even if the SNM is present as
metal, it is only necessary to determine atom % if the SNM exceeds 50 weight
%. Atom% is calculated using the following formula:
The sum in the denominator of the equation is over all
known and quantified elements in the material.
Weight% is calculated using the following formula:
DOE-STD-1194-2011
20
MATERIAL TYPE
U-235
Pu or U-233
Pu-238
ENRICHMENT %
ISOTOPIC CONTENT
< 20
≥ 50
< 20%
≥20% - ≤60%
> 60%
PHYSICAL FORM
WEIGHT % SNM
E
E
> 0.1
≤ 0.1
E
D
≥1 - ≤25
< 1.0
> 25
D
E
C
SOLID
SOLUTION
WEIGHT % SNM
CONCENTRATION
GRAMS/LITER
≥ 10
< 10
CHEMICAL FORM
COMPOUND
METAL
C
WEIGHT % SNM
≤ 50
> 50
C
ATOM % SNM
≤ 50
> 50
C
B
Boxes are questions or decisions; answers
are given along the lines. The result is a
letter representing the attractiveness level.
Figure 6.2-1. Decision tree for determination
of material attractiveness level for special
nuclear material (SNM).
≥20 - <50
WEIGHT % SNM
≤ 0.1
> 0.1
E
D
WEIGHT % SNM
≤ 0.1
> 0.1
E
D
DOE-STD-1194-2011
21
a. Attractiveness Level A: Weapons and test devices; partially assembled weapons
and test devices sufficient to construct an improvised nuclear device using
commercially available parts and materials.
b. Attractiveness Level B: Pure forms of SNM with a total SNM content exceeding
50 atom percent; that is, greater than half of the atoms present in the material
must be SNM. The SNM can be used in its existing form, or that can be utilized
after simple mechanical removal of cladding, packaging, or matrix material to
produce a weapon/improvised nuclear device through casting, forming, or other
nonchemical operations.
c. Attractiveness Level C: High-grade SNM that can be easily converted to metal.
Generally, these materials are of high purity and require relatively little
processing time or effort to obtain Level B material.
d. Attractiveness Level D: Low-grade SNM that are more dilute or of lower purity
than Level C materials, and require greater processing time or greater processing
complexity to convert to metal than Level C materials.
e. Attractiveness Level E: All accountable nuclear materials that do not meet the
criteria for Attractiveness Level A through D.
6.2.1.1.1 Combined with the radiation dose rate, weight and weight percent SNM can enter
into a site’s decision to assign a lower attractiveness to an item. If any of the
following conditions exist, then the Attractiveness Level of accountable nuclear
materials, with a high dose rate, may be assigned protection at a lower Attractiveness
Level:
6.2.1.1.1.1 Radiation: Items can be considered highly irradiated and may be
protected as attractiveness level E. For radiation to be a mitigating factor,
the radiation environment may be taken into consideration after
determining the attractiveness level. A way to determine whether
protection appropriate to a lower attractiveness level may be acceptable is
as follows:
Obtain adversary task list and the task time for each.
Determine cumulative radiation dose upon completion of each task.
Determine whether all tasks would be completed before
incapacitation.
If all tasks unlikely to be complete then attractiveness level E.
6.2.1.1.1.2 Net Weight: Item net weight can be considered, if an item is heavy such
that removal from its location is restricted to the use of special tools or
equipment, and those tools or equipment are controlled, locked and
alarmed. For weight to be considered a mitigating factor, the item must:
DOE-STD-1194-2011
22
Weigh 100 kg or more after all mechanically attached material is
removed; and
Contain less than 2 kg plutonium or less than 5 kg U-235 (greater
than 20 percent enriched) if the SNM were separated from the other
materials.
A net weight of 100 kg or more combined with the high radiation
level makes removal of an item very difficult for an individual
adversary. When an item contains less than a quantity necessary for
an improvised nuclear device, multiple items must be removed, which
increase radiation exposure and removal task time. Consideration of
weight plus radiation dose may allow reduction of attractiveness level
at lower levels of radiation.
6.2.1.1.1.3 Weight Percent: Item weight percent can be considered, if the item
contains less than one weight percent plutonium or less than one weight
percent U-235, when the uranium enrichment is greater than 20% U-235
However, weight percent must be calculated without mechanically
attached material. Also, if items such as fuel rods contain end caps
containing no SNM, the weight percent must be calculated as if the end
caps have been cut off.
Any decision to reduce the attractiveness level of nuclear material must be
supported by an analysis that documents any change in risk by assigning a
lower attractiveness level.
Attractiveness Level Determination
Example 6.2.1-1
Uranium-235 Fuel Element
Using the decision tree in Figure 6.2-1
Scenario 1: Unirradiated plates of 90 weight percent plutonium (Pu) alloyed
with zirconium. Collectively, the Pu isotopes constitute 77 atom percent of the
total material.
Line
SNM Attribute
Characteristic
Decision
1
Material Type
Pu
2
Physical Form
Solid
3
Weight% SNM (Pu)
≥ 10%
4
Chemical Form
Metal
5
Weight% SNM (Pu)
> 50%
6
Atom% SNM (Pu)
> 50%
Attractiveness Level
B
DOE-STD-1194-2011
23
Scenario 2: Uranium oxide (UO
2
) containing uranium enriched to 25 weight
percent U-235. The U-235 isotope constitutes 22 weight percent of the total
material.
Line
SNM Attribute
Characteristic
Decision
1
Material Type
U-235
2
Enrichment%
≥ 20% and < 50%
3
Weight% SNM (U-235)
> 0.1%
Attractiveness Level
D
6.2.1.2. Determination of category involves grouping materials by type, attractiveness level,
and quantity. Material quantities are element weights for plutonium and isotope
weights for uranium-235 (U-235) and uranium-233 (U-233). For the purposes of
category determination, quantities of plutonium Material Type Code 40 and
Material Type Code 50 are combined and considered as one material type. The
Material Types can be found in Appendix C Special Nuclear Materials and
Appendix D Other Accountable Nuclear Materials. Directions for determining the
material category when multiple material types and attractiveness levels must be
considered are provided in the following paragraphs.
a. One Material Type, One Attractiveness Level. Sum the material in the
attractiveness level and determine the category from Appendix B, Graded
Safeguards Table.
b. One Material Type, Multiple Attractiveness Levels (where a Category III or
greater quantity of B-level material is included).
(1) Determine the amounts of SNM for materials in each of attractiveness levels
B, C, and D.
(2) Calculate the “effective” quantity for attractiveness levels B and C by
multiplying the quantity in attractiveness levels B and C by the appropriate
factors in Table 6.2-1, Effective Quantities.
(3) Sum the effective amounts in attractiveness levels B and C.
(4) Compare the total effective amount, as calculated in section 6.2.1 .2.b (3)
above, to the amounts in attractiveness level B from Appendix B, Graded
Safeguards Table.
(5) Compare the amount of attractiveness level D to Appendix B, Graded
Safeguards Table.
(6) The material category is the highest level of material category determined
using the procedures in sections 6.2.1.2.b (1) through 6.2.1.2.b (4), or in
section 6.2.1.2.b (5).
c. One Material Type, Multiple Attractiveness Levels (where less than a Category
III quantity of B-level material is included).
DOE-STD-1194-2011
24
(1) Determine the amounts of SNM for all attractiveness levels.
(2) Compare the total amounts in each level to those in Appendix B, Graded
Safeguards.
(3) The material category level is the highest level of the material categories
determined using the procedures in sections 6.2.1.2.c(1) and 6.2.1.2.c(2)
(4) Multiple Material Types.
(a)
Determine the category for each material type following the above
procedures.
(b)
The category is that determined for the individual material type that
requires the highest level of protection.
Table 6.2-1: Effective Quantities
Attractiveness Level
Pu/U-233 Factor
U-235 Factor
B
1
1
C
1
/
3
¼
6.2.1.3. Facility protection strategy changes resulting from changes in safeguards category
based on materials holdings at the facility and the credibility of rollup shall be
reviewed and approved by DOE line management.
6.2.1.4. Roll-up is the accumulation of smaller quantities of SNM to a higher category,
based upon the categorizations steps listed above. In order to determine the
credibility of roll-up, the attractiveness level, quantity and location must be known
for all SNM. Activities, such as pre-approved transfers by both the MC&A
organization and the shipping and receiving MBA custodians, phone-ahead
authorizations, or preliminary calculations by the accounting system with
computerized notification, shall be used to monitor roll-up. Unless it has been
demonstrated by a vulnerability assessment that roll-up is not credible, SNM must
be safeguarded and protected based on the total quantity of SNM for a location
(e.g., MAA, PA, building, or group of buildings).
DOE-STD-1194-2011
25
Table 6.2-2: Example of Rollup Determination
MBA
Category
Where
Located
Quantity of
Category B
Material
Quantity of
Category C
Material
1
III
LA Inside PA
Pu: 199 grams
Pu: 1,800 grams
2
III
LA Inside PA
Pu: 199 grams
Pu: 1,800 grams
3
III
LA Inside PA
Pu: 199 grams
Pu: 660 grams
4
III
In LA Outside PA
HEU: 150 gU-235
HEU: 3,200 gU-235
5
III
In LA Outside PA
HEU: 150 gU-235
HEU: 2,950 gU-235
Analyses:
The questions that must be answered are:
(1) Do the three Category III MBAs inside the PA total to a
Category I quantity?
(2) Do the two Category III MBAs outside the PA total to a
Category II quantity?
The answer to (1) is found by:
199+ 199 + 199 + 1/3 (1,800 +1,800 + 660) = 597 + 1420 = 2017
(see DOE O 474.2, Attachment 2, Table B)
This is a Category I quantity and, therefore, should be protected
in an MAA. The inventory of one MBA could also be reduced
by 200 grams of B material or 600 grams of C material and the
roll-up would be less than a Category I quantity.
The answer to (2) is found by:
150 + 150 =300 g of B material is less than a Category III quantity, but
3,200 + 2,950 = 6,150g U-235 which is a Category II quantity
and must be in a PA.
DOE-STD-1194-2011
26
Table 6.2-3. Additional Attractiveness Level E Criteria for SNM
6.2.2. Graded Nuclear Material Control
To effectively control and account for nuclear materials and meet the nuclear material
control system objectives stated above, the site/facility operator shall establish and follow a
graded nuclear material control program that provides the greatest relative amount of
control and accountability for the types and quantities of SNM that can be most effectively
used in a nuclear explosive device.
6.2.2.1. The nuclear material control measures for Category I locations shall, at a minimum,
consist of those measures shown in Table 6.2-3, Nuclear Material Control Measures
for Category I SNM.
6.2.2.2. The nuclear material control measures for Category II locations shall, at a
minimum, consist of those measures shown in Table 6.2-4, Nuclear Material
Control Measures for Category II SNM.
Description/Form
Maximum SNM
concentration
*
(wt%) for
MC&A and physical
protection termination
Maximum SNM
concentration
*
(wt%) for
only physical protection
equivalent to Category
IV
SNM solutions and oxides: nitrate, caustic or
chloride solutions, contaminated/impure oxides,
metal fines and turnings, glove box sweepings
0.1
N/A
SNM amenable to dissolution and subsequent
separation: pyrochemical salts, chloride melt,
hydroxide cake, floor sweepings, alumina,
condensates reduction residues, sand, slag, and
crucible, magnesium oxide crucibles spent fuel and
spent fuel residues
0.1
0.2
SNM in organic matrixes or requiring mechanical
separation disassembly and subsequent multiple
recovery operations: HEPA filters, organic
solutions, oils and sludges, graphite or carbon scrap,
surface contaminated plastics, metal components,
combustible rubber
0.2
1.0
SNM bound in matrix of solid, sintered, or
agglomerated refractory materials: SNM
embedded in glass or plastic, high-fired incinerator
ash, spent resins, salt sludges, raffinates, and sulfides
0.5
2.0
SNM microencapsulated in refractory compounds
or in solid-dilution: vitrified, bituminized,
cemented, or polymer-encapsulated materials, SNM
alloyed with refractory elements (tungsten, platinum,
chromium, stainless steel); ceramic/glass salvage
1.0
5.0
*
SNM weight percent is based on element weight for plutonium and isotope weight for U-235 and U-233.
DOE-STD-1194-2011
27
6.2.2.3. The nuclear material control measures for Category III locations shall, at a
minimum, consist of those measures shown in Table 6.2-5, Nuclear Material
Control Measures for Category III SNM.
6.2.2.4. The nuclear material control measures for Category IV locations shall, at a
minimum, consist of those measures shown in Table 6.2-6, Nuclear Material
Control Measures for Category IV SNM.
6.2.3. Access Controls
The site/facility operator shall develop and maintain a system for controlling access to
nuclear material and nuclear material accounting data and equipment, consistent with the
graded safeguards concept.
6.2.3.1 The site/facility operator shall identify persons authorized access for each MBA
that have a need for access to perform assigned duties, or have a need to access
nuclear materials, and shall control access to only those persons.
6.2.3.2 This list shall be prepared and maintained by the Facility or Building Manager with
concurrence by the MC&A Manager. Personnel on an authorized access list must:
have the DOE-required security clearance for the category of material
in the area as designated in DOE M 470.4-5, Personnel Security,
have a need to access for their job function,
know the safeguards and security requirements for the area, and be
trained in the appropriate MC&A procedures for their function.
6.2.3.3 The system for controlling access shall consist of procedures and/or equipment,
consistent with the requirements in DOE M 470.4-2, Chg1, Physical Protection,
and is capable of detecting unauthorized access and communicating this
information to assessment and response personnel.
6.2.3.4 The system shall function during normal, as well as unusual and emergency
conditions.
6.2.3.5 In defining access controls for nuclear materials, the site/facility operator can
designate certain materials, as inaccessible. The following cases are considered
inaccessible when accompanied by a justification:
The nuclear material precludes diversion because of high temperature,
chemical reactivity, radioactivity, or other chemical or physical
property.
The removal of nuclear material from its authorized location cannot be
accomplished because the tools or equipment needed for its removal are
not available or would be readily detected.
DOE-STD-1194-2011
28
Justification for determining inaccessibility shall be documented and supported
by an assessment that considers adversary actions, nuclear material
characteristics, engineered systems and barriers, administrative procedures, and
site/facility response actions.
6.2.3.6 For SNM that is accessible, the site/facility operator shall implement procedures to
minimize the quantity of material that is not in the storage configuration for the
MBA category in which it resides.
When SNM is not in storage, it shall be considered “in use” which means that it is
actively involved in a process, experiment, measurement, transfer, or other
operation approved for the MBA.
6.2.3.7 For each system used for nuclear material accounting data, the site/facility
operator shall control access to material control and accounting data and
information.
a. The site/facility operator shall identify persons that can enter, change, or
access nuclear information and data.
b. The site/facility operator shall use administrative procedures, surveillance
systems, and physical security systems as mechanisms to deny and detect
unauthorized access to data-generating and recording devices, measurement
equipment, tamper-indication devices, and other types of equipment used in
MC&A activities.
c. Original source documents that are used to define inventories and
measurement data shall be protected from deliberate alterations that could
change the accounting record data.
d. Original source documents that require alterations that could change
accounting record data must re-verified by a second authorized persons
signature.
6.2.4. Material Surveillance
The material surveillance program is primarily concerned with detection of insider
adversary activities, and is, therefore, a collection of information through devices and/or
personnel observation to detect unauthorized movements of nuclear material, tampering
with containment of nuclear material, falsification of information related to location and
quantities of nuclear material, and tampering with safeguards devices. In order for visual
surveillance to be considered effective, the person(s) observing must be capable of
recognizing unauthorized activities, correctly assessing the situation, and reporting the
activities to appropriate response personnel in time to deter theft, diversion, or radiological
sabotage. If the recognition, assessment, or reporting is not effectively implemented, then
the visual surveillance methodology is deficient, and additional means must be used to
ensure detection and response.
DOE-STD-1194-2011
29
6.2.4.1 Authorized locations. Nuclear material locations must be identified and be
consistent with Site Security Plans and vulnerability assessments. Authorized
locations can be fixed, i.e., vault and shelf location; or in-transit between MBAs or
offsite shipments and receipts.
a. The authorized location for nuclear material, in use or in storage, shall be the
documented location in MC&A records whether in an MBA, vault, room,
glove box, process line or transit vehicle. Any item found not in its assigned
location should be considered as potentially diverted until it is proven
otherwise.
b. If any of the following conditions are not met, then nuclear material in-transit
are in an unauthorized location and should be considered as potentially
diverted until proven otherwise:
The item is in a transfer device authorized for the transfer of nuclear
material
The item was placed in the transfer device at an authorized loading
point by personnel authorized to place nuclear material in the transfer
device
The transfer device is operated by personnel authorized to operate the
device and to transfer nuclear material
The transfer device is en route on an authorized route between the
loading point and the authorized destination
The transfer device makes no unauthorized stops while en route, and
the transfer time between source and destination does not exceed the
maximum time established by the site/facility operator for transfer.
The item is removed from the transfer device only at the authorized
destination, and by personnel authorized to remove nuclear material.
6.2.4.2 Two-Person Rule. When the Two-Person Rule is used as a material surveillance
measure or administrative control, the two authorized persons assigned
responsibility for maintaining direct control of the items shall be physically
located where they have an unobstructed view of each other and/or the item(s),
and can positively detect unauthorized or incorrect procedures.
a. These individuals must have training appropriate to the reason for access, and
must not have conflicting job duties; i.e., protective force personnel should
not be the witness (second person) for custodian or process activities.
Procedures for implementing the two-person rule must be documented.
b. When the Two-Person Rule is implemented, surveillance shall be sufficient to
ensure that unauthorized or unaccompanied authorized personnel cannot enter
the area undetected (e.g. when the door is unlocked or open).
DOE-STD-1194-2011
30
Example 6.2.4-1
Situations exist where routine operational surveillance is
necessary and these activities are typically carried out by a single
individual. When areas contain Category I or II quantities of
SNM, these activities must be carried out using the two-person
rule. However, the use of technology to enhance material
surveillance or to “act” as the second person in two-person rule
situations is acceptable when an alarm and a response would
occur prior to a person gaining access to Category I or II
quantities of SNM. Video intrusion detection or similar
hardware and software systems that continuously monitor items
or area locations for unauthorized access or anomalous
conditions indicating unauthorized access are acceptable
substitutes for the second person provided that they have been,
and continue to be, extensively tested and positively detect and
issue an immediate response to unauthorized access under
operating conditions.
6.2.4.3 Daily Administrative Check (DAC). A DAC is a methodology that is used in
Category I MBAs to detect anomalous conditions and to determine that SNM is
not in unauthorized locations.
a. DAC programs shall be described in the MC&A Plan and can consist of
various safeguards and security features already in place or may take
advantage of routine production procedures. The DAC program description
shall include the following:
Duties, authorities and/or responsibilities of each organization
involved in performing, reviewing, resolving, and reporting the
DAC
Areas and/or items requiring a DAC
Methodologies or techniques used in performing a DAC
Personnel responsible for performing a DAC and the training required
Recordkeeping requirements, including forms used, reports
generated, retention periods, and signature requirements
Anomaly identification, response and notification procedures.
b. SNM locations and credible paths identified in vulnerability assessments
shall be included in the checks.
c. The DAC shall be performed by facility personnel each day that the
MBA is entered and shall be performed in all rooms entered if the MBA
consists of more than one room.
DOE-STD-1194-2011
31
d. The DAC shall consist of visual inspection, which can include checks of
TID integrity, checks of DOE approved locks, confirmation of serial
numbers or other identifiers for individual items, item counts,
confirmation of SNM locations or other checks that would provide
obvious indicators of abnormalities or discrepancies. Surveillance
technologies such as camera systems, alarm systems, metal and/or SNM
portal monitors can be used to assist in checking locations and SNM.
e. On workdays in which an entry is not made into an MBA, the status
of the intrusion detection system shall be checked and documented.
6.2.4.4 Tamper-Indicating Device (TID). An item is tamper-indicating when it is
constructed or protected with a TID such that a malevolent act cannot be
accomplished without permanently altering the item or TID in a manner that would
be obvious during visual inspection. Tamper indication, in conjunction with other
material control and security measures, provides assurance that an item has not
been altered in some way since the last time it was inspected or since the item was
made tamper-indicating.
a. DOE considers the TID an effective indicator of container violation only
when items are under a DOE-approved material surveillance program
appropriate for the category of material in the area. The material
surveillance program must have demonstrated effective performance
while items are in that location. If the material surveillance program
malfunctions for a period of time greater than that required to defeating a
TID, then TIDs in that area provide little or no assurance of container
integrity.
b. A TID applied to a container in a Category I or II MBA with effective
material surveillance measures in place provides greater assurance of
container integrity than a TID applied to a container in a Category III or
IV MBA, also with effective material surveillance measures in place for
the area. However, since the material in the container is less attractive
and/or smaller in quantity, the application of a TID still has value in
meeting the objectives of a TID program albeit less than for higher
category areas. When TIDs are considered for vulnerability assessments
or system performance evaluations, the site/facility operator shall
determine the value of TIDs in meeting the program objectives.
c. When a site/facility operator uses TIDs, the TID program shall consist of
the following elements:
1.
Acquisition/Procurement/Destruction. Procurement procedures specify that
vendors provide assurance that the TIDs are unique and are not duplicated
for another customer. A TID administrator is assigned responsibility to
account for TIDs received from vendors and ensure that they are destroyed
when removed from an item or location. Once a TID is removed or
violated, it shall be destroyed to a level that, if reapplied, it would not pass
DOE-STD-1194-2011
32
an integrity check. Destruction procedures specify how to render TIDs
ineffective and prevent their reuse.
2.
Types of TIDs Used and Containers or items that are inherently self
tamper indicating. The MC&A Plan or associated TID manual
describes the types of TIDs used and how the TIDs are applied.
Containers or items considered inherently tamper-indicating are listed
as such in the MC&A Plan.
3.
Unique TID Identification. The TID has unique characteristics such as
sequential serial numbers, logos, etc. Uniqueness of TIDs increases the
defense-in-depth by making them more difficult to duplicate. When a TID
has multiple sides consisting of separate parts (e.g., Type E cup seal), each
part shall have the same unique identification markings so that a portion of
the TID cannot be replaced without notice.
4.
Storage. TIDs are stored in a locked repository with key or
combination access when they are received onsite by the TID
administrator. The TID administrator distributes the seals to TID
custodians who are responsible for similar storage of the TIDs until
they are applied.
5.
Issuance. TIDs are accountable from cradle to grave. Logs are maintained
that record each transfer of TIDs, (i.e., from TID Administrator to TID
Custodian and from TID Custodian to TID applicator). When TIDs are
applied, a record shows who applied the TID, who observed the TID being
applied, and when and to what container the TID was applied. When a TID
is removed and destroyed, a record of destruction is maintained identifying
who removed the TID, date of removal and who witnessed the removal.
6.
Personnel Authorized to Apply, Remove, and Dispose of TIDs. Personnel
responsible for use and control of TIDs are clearly identified and training
requirements are documented. Only personnel who have completed the
training program are authorized custodians, appliers, and verifiers.
7.
Procedures for TID Application and Removal. Each TID type used by the
site/facility contractor for SNM containers and locations has a documented
application and removal procedure. Procedures may be part of MBA
procedures or a general procedure applicable to all MBAs.
8.
Frequency and Method of TID Verification. The TIDs are properly applied
and the integrity of the TID has not been violated for at least 95 percent of
the TIDs inspected. The TID record system accurately reflects the location
and identity of TIDs for at least 99 percent of the TIDs inspected. Accuracy
of location and identity is obtained from routine physical inventories and
from transfers of material between MBAs. The MC&A Plan shall specify
how the “counting” of accuracy, identity, location, and correct application
are recorded.
9.
Procedures for Responding to and Reporting TID Violations. The MC&A
program shall specify who is responsible for checking TIDs and reporting
anomalies. Although the program is the responsibility of the MC&A
organization, many other groups are the actual end-user of the TID program.
DOE-STD-1194-2011
33
Line personnel, operators, MBA custodians, etc. are all possible users. The
individual(s) discovering the violated TID shall notify supervision
immediately and report the TID condition, identification number, container
number and location. The procedures shall specify who is responsible for
reporting an anomaly that is a DOE-reportable occurrence. When the TID
integrity or container has been violated, the container contents shall be
verified. When a TID is accidentally violated in a Category III or IV MBA,
a replacement TID may be applied without further verification. When a
TID is accidentally violated in a Category I or II MBA and the damage is
witnessed by two authorized individuals knowledgeable of TID procedures,
a replacement TID may be applied without further verification. If the
condition that caused the TID to be violated is determined and the contents
are verified, a replacement TID can be applied. A suspect TID shall be held
until investigation has resolved the situation and the TID administrator
approves disposal of the TID.
10.
Frequency and Method of Internal Program Audits. Performance shall be
verified at least annually (at least every 12 months) except for facilities
whose physical inventories are conducted less frequently than once a year.
For such facilities, performance shall be verified at the same frequency as
inventories are conducted. Auditors are not associated with the TID
program. Auditors check the serial numbers of the seals against the log
books and seal inventory of unused seals; identify weaknesses in the seal
program; investigate discrepancies in the seal inventory; verify seal
applications and destruction; verify that deficiencies in the TID program
have been corrected; and check for deviations from established procedures.
6.2.4.5 Process Monitoring. Process monitoring is a methodology to ensure that SNM is
in its authorized location and when effectively implemented, it is a useful tool to
detect anomalous process conditions and indicate losses of SNM well before the
scheduled physical inventory. If this methodology is used, the MC&A Plan shall
describe:
the methodology for division of processes into units for the detecting the
loss of control of a significant quantity. The units shall be consistent with
accessible measurements points that result from the process design. There
is no limit or restriction on the number of units into which a process or
facility can be divided.
the material control tests used for detecting abrupt losses of bulk material
from a single process unit, the loss detection capability, and the timeliness
of the detection.
the alarm threshold (critical value), which if exceeded initiates
alarm resolution procedures.
Example 6.2.4-2
As an example of a process monitoring program, unit processes would
be tested weekly by monitoring inputs and outputs and comparing the
process difference result to expected values. The test would have at
DOE-STD-1194-2011
34
least a 95 percent probability of detecting the loss of a Category I
quantity during the week from accessible process locations. In
addition, the process monitoring program would also include a trend
analysis to evaluate statistically significant recurrent loss or gain from
each unit process or loss and subsequent gain in successive unit
processes. Process difference estimates that exceed both 3 times the
standard deviation of their estimator and 50 grams would be
investigated. Investigations would be resolved prior to the next
weekly test.
6.2.4.6 Item Monitoring. Item monitoring is a methodology that can be used in Category I
and II areas as part of the material surveillance program to ensure timely detection
of the loss of items that total a significant quantity. SNM is considered to be an
item if it meets one of the following criteria:
(1) uniquely identifiable material, e.g., piece part, inside or out of a glove-box
line
(2) stored within a vault
(3) encapsulated
(4) within a tamper-indicating sealed container
(5) stored in an area with controlled access that provides protection at least
equivalent to tamper-indicating.
If this methodology is used to verify the presence and integrity of selected SNM
items on a periodic basis, the MC&A Plan shall describe the:
item monitoring sampling method, including the sample size selection
equations, the inventory stratification plan, and the method of selecting the
actual items to be verified
extent to which cyclic, dynamic, or perpetual inventory data and production
records are used to modify or supplement the sample size, sample selection,
or item verification
minimum loss detection sensitivity and maximum time period between item
verification for each stratum of SNM.
actions to be taken when loss detection sensitivity is exceeded, including
timeliness for resolution.
item selected for monitoring that does not exist because it has been
processed will be reviewed for documentation to ensure that the item was
processed as specified.
The frequency of tests for missing items should be graded according to the
relative attractiveness of the material type of the item, the ease with which the
item could be diverted without being observed and the degree of surveillance and
containment provided by the material control and physical security systems.
DOE-STD-1194-2011
35
The magnitude of the formal item verification effort can be adjusted to take credit
for other means of confirming the presence and identity of items with applied TIDs.
Process control and accounting, quality control testing, and other production
operations routinely generate information that can serve to verify the identity and
presence of items with applied TIDs. These sources can be used in lieu of item
verification provided the frequency and loss detection sensitivity requirements of
the item verification procedure are met and the use of the data for this purpose is
not predictable.
Example 6.2.4-3
In conjunction with installed material surveillance measures in a facility, item
monitoring for Category I and II items in process areas is performed weekly
by randomly selecting items and locating them in an MBA. Using the same
sample size as for the items in process, the item monitoring within storage
areas is performed every 2 months by randomly selecting and locating items.
The sample size n is computed using the approximation
n = N (1-
1/d
),
where N is the population size, d is a conjectured or assumed number of
defects (altered or missing items that cannot be reconciled or located), and β is
a tolerable probability that none of the defects will appear in a random sample
of size n, if there are in fact d defects within the population. In other words, β
represents an acceptable probability of not sampling any of the d defects and
therefore erroneously concluding that the population contains less than d
defects, when the actual number of defects is equal to d. The equation
provides a suitable estimate of the required sample size, provided that the
sample is large (at least 30) and is a small proportion of the population (less
than 10%) and that the number of defects is also a small proportion of the total
population (less than 10%).
For a population of N=1000 items containing 10% defective items (d=100), a
random sample of size n=30 will select one or more of the defects with 0.95
probability (i.e., β=0.05). Numerically, the sample size is computed as
1000*(1-0.05
0.01
) = 29.5 ≈ 30
For this example, the computed sample size is such that 95% of all samples (of
size 30) that are randomly selected from a population having 10% defectives
will result in at least one defect being drawn in the sample.
The ‘probability of loss detection’ (1- β) and the associated ‘loss detection
sensitivity’ (d) must be approved by DOE line management. Once these are
specified, the number of items n to be selected from a population of size N is
calculated from the equation.
DOE-STD-1194-2011
36
The same equation can be used for determining the number of items to be evaluated
during a physical inventory, where in that case, d (a percentage of the total
population) is called the ‘minimum detectable defect’ and (1- β)*100% is called the
‘confidence level.’. See Section 6.5.1.3 and Table 6.5-1.
6.2.4.7 Transfers. When nuclear material is transferred from one MBA to another or
shipped to or received from an offsite location, checks must be made to ensure that
there are no anomalous conditions.
a. The items being transferred shall be checked by both the shipper and
receiver against authorized transfer forms or computer records to ensure
that only the correct items are being moved and the container integrity has
not been violated.
b. When the nuclear material passes an MAA or PA portal, the items shall be
checked by the protective force against the transfer documentation.
c. When the nuclear material being transferred between MBAs is not an item,
the material characteristics, such as volume, weight and radiation signature
shall be checked when it is shipped and when it is received by an MBA
custodian.
d. When nuclear material is received into an MBA, the transaction is
promptly entered into the accountability records.
e. When an onsite transfer of a Category I or II quantity occurs, a time limit for
the transfer shall be established and monitored such that a protective force
response is initiated if the time limit is exceeded.
6.2.4.8 Waste Monitoring. All liquid, solid, and gaseous waste streams leaving a material
access area shall be monitored for SNM.
a. Instrumentation shall be maintained and controlled to ensure that it is
capable of detecting, in combination with other detection elements, the
removal of a Category I quantity of SNM through a credible theft or
diversion scenario, as determined by a Vulnerability Assessment (VA).
b. Monitoring instrumentation can be semi-quantitative, provided that the
monitors used are capable of detecting gamma/neutron radiation
characteristics of the type specified for the SNM in the area.
c. Environmental and waste management instrumentation can be used if the
detection objective is met and anomaly reporting is directly made to a
security organization where a proper response can be initiated.
6.2.4.9. Portal Monitoring. Portal monitoring refers to monitoring personnel and vehicle
egress from an MAA and PA.
DOE-STD-1194-2011
37
a. The systems used for portal monitoring shall meet the requirements
specified in DOE M 470.4-2, Chg 1, Physical Protection.
b. The SNM and metal detectors in combination shall detect unshielded and
shielded test sources described in ASTM portal monitoring standards.
6.2.5 Deactivation and Decommissioning (D&D)
There are two general cases associated with the D&D of a facility containing accountable
nuclear material: (1) The facility was previously placed in an inactive condition and
safeguards has been terminated on all accountable material in the facility, and (2) The facility
transitions directly from the operations phase of its life-cycle into the D&D phase.
6.2.5.1 D&D for Inactive Facilities
a. Identify the total quantity of accountable material to be removed from the facility
and coordinate with Physical Security to develop a security plan that provides the
appropriate degree of security for the material being removed from the facility.
b. Make a determination of the need to return any of the material being removed to the
active inventory. If this is required, use the process defined in section 6.2.7.
c. Conduct oversight of all measurements on material removed to ensure the measured
values are in reasonable agreement with the holdup values assigned to the areas
from which the materials were removed.
d. Obtain approval to terminate safeguards on materials that were returned to the
active inventory if required using the process in 6.2.6.
6.2.5.2 D&D for Active Facilities
a. Conduct removal of material from the facility (or a portion of the facility) until a
sufficient removal has occurred to permit termination of safeguards on the facility
(or portion of the facility).
b. Obtain approval to terminate safeguards on the facility (or portion of the facility)
using the process in section 6.2.6. NOTE: The approval for termination may be
obtained as a process description that identifies the methodology that will be used
to reduce the inventory in a portion of a facility to a level that will permit the
termination of safeguards.
6.2.6 Termination of Safeguards
Termination of safeguards exempts nuclear materials from MC&A requirements and thereby
removes the safeguards basis for applying physical protection requirements for theft and
diversion of nuclear material. Materials for which safeguards are terminated may still need to
be protected and controlled pursuant to other DOE security directives or site policy based on
the specific details of the material and/or location. Termination of safeguards implies that a
DOE-STD-1194-2011
38
waste management organization will continue to control and account for the material in
accordance with waste management regulations.
6.2.6.1 Safeguards can be terminated on nuclear materials provided the following
conditions are met:
a. If the material is SNM or protected as SNM, it shall be Attractiveness Level
“E” and have a measured value.
b. The material has been determined by DOE line management to be
of no programmatic value to DOE.
c. The radiological sabotage risks associated with the materials have been
evaluated and additional measures beyond waste management regulations put
in place to ensure that protection requirements, if applicable, will be met after
safeguards termination. Only nuclear materials that are of radiological
sabotage concern need to be evaluated against this requirement.
d. The material is transferred to the control of a waste management or D&D
organization where the material is accounted for and protected in accordance
with waste management regulations. The material shall not be collocated with
other accountable nuclear materials.
e. When considering safeguards termination of SNM other than Attractiveness
Level “E”, the DOE/NNSA Departmental Element shall approve shall
approve the termination request after consultation with the HSS Office of
Security Policy.
f. If SNM Category II or greater is being considered for termination, a security
analysis for theft or diversion must be performed, and approval received from
the responsible DOE/NNSA Departmental Element.
6.2.6.2 Terminating safeguards on SNM holdup can occur only after the holdup has been
measured and properly credited to the accountability books. Unless demonstrated
to be otherwise, the attractiveness level and/or category of SNM in process holdup
shall be considered to be the highest attractiveness level and/or category of the
total SNM put into the process during its lifetime. Hold up can be designated
recoverable or unrecoverable.
a. “Recoverable holdup” is the material that can be recovered during D&D
operations. This material may have been affixed to system components and
materials, but during D&D the material will loosen or become retrievable.
Within the accounting system this type of material is also referred to as “process
holdup”.
b. “Unrecoverable holdup” is material that is inaccessible in the facility even
during the D&D process. This material is embedded in and affixed to system
components (equipment holdup) and material (glass, plastics, metals, concrete
DOE-STD-1194-2011
39
slab, etc.). This holdup is considered beyond economical and technical
recovery.
6.2.6.3 Management of Terminated Materials - The MC&A organization shall coordinate
with the Security organization to provide accountability information
(Attractiveness and Category) for terminated materials. This includes materials
exhumed from waste trenches, removed from inactive facilities, etc. This
information will permit the determination of the proper physical security
protection measures as specified in DOE M 470.4-2, Physical Protection.
6.2.7 Returning Terminated Materials to the Active Inventory
Accountability values for material being returned to the active inventory will be established
using one of the following methods:
6.2.7.1 Perform an accountability measurement on the material and use the value obtained
as the accountability value.
6.2.7.2 Perform research to establish the history associated with the material:
(1) The accountability value for the material at the time of safeguards termination,
(2) Evidence that the material has remained in a condition that ensures it has not
been tampered with, for example, an intact TID, storage in a location considered
to provide assurance of tamper detection, etc.
(3) Return the material to the active inventory using the value obtained from the
historical research.
DOE-STD-1194-2011
40
Table 6.2-3: Nuclear Material Control Measures for Category I SNM
Category I MBAs are located in a Material Access Area. Authorized activities and the
authorized locations for nuclear materials in each MBA are identified.
When in use, SNM is controlled by two authorized and trained personnel with a “Q”
security clearance (See Section 6.2.4.2 - Two- Person Rule) and who participate in a
Human Reliability Program that has demonstrated effective performance. One person
meeting these requirements may access the area when a vulnerability assessment shows
that direct access to Category I quantities of SNM is not possible without detection, or there
is a system of hardware, procedures, and administrative controls sufficient to ensure that no
unauthorized accumulation of a Category I quantity of material occurs without timely
detection.
When not in use, SNM is stored in vaults or vault-type rooms meeting the requirements of
DOE Manual 470.4-2, Change 1,
Physical Protection.
Two authorized and trained
individuals are present when opening and closing storage areas. Security devices or
protective force personnel ensure that the two people are authorized. The Two-Person
Rule or equivalent surveillance procedure is in effect at any time the storage area is not
locked and protected by an active alarm system and security cameras.
A Daily Administrative Check (DAC) methodology is implemented in Category I MBAs
and in lower category MBAs where rollup to a Category I quantity has been determined
to be credible. The DAC detects abnormalities, tampering, and SNM that is not in
authorized locations (See Section 6.2.4.3 – Daily Administrative Check).
Nuclear material types, forms, and amounts authorized to be removed from the security
area are identified in the MC&A Plan.
Liquid, solid, and gaseous waste materials leaving an MAA are monitored.
Instrumentation and methods used to monitor waste and equipment removed from an
MAA is able to detect, in combination with other detection elements, the removal of a
Category I quantity of SNM through a credible theft or diversion scenario, as determined
by a VA.
Items placed in storage and both SNM and non-SNM waste containers transferred across a
security boundary are tamper-indicating.
When a processing operation involves changes in material characteristics with a Category I
throughput during an inventory period, a process monitoring program is used to detect
anomalous conditions and indicate losses between physical inventories.
DOE-STD-1194-2011
41
Table 6.2-4: Nuclear Material Control Measures for Category II SNM
Category II MBA is located in a Protected Area or higher security area. Authorized
activities and the authorized locations for nuclear materials in each MBA are
identified.
Controlled by two authorized and trained personnel with a minimum of an “L”
security clearance. (See Section 6.2.4.2 - Two-Person Rule). A “Q” security
clearance is required to access Category II material if rollup to a Category I
quantity is credible or if a vulnerability assessment determines that an additional
clearance is required.
When not in use, SNM is stored in vaults or vault-type rooms meeting the
requirements of DOE Manual 470.4-2, Change 1,
Physical Protection.
Two
authorized and trained individuals are present when opening and closing storage
areas. Security devices or protective force personnel ensure that the two people are
authorized. The Two-Person Rule or equivalent surveillance procedure is in effect
at any time the storage area is not locked and protected by an active alarm system
and security cameras.
Nuclear material types, forms, and amounts authorized to be removed from the
security area are identified in the MC&A Plan
Items placed in storage and both SNM and non-SNM waste containers transferred
across a security boundary are tamper indicating.
When a processing operation involves changes in material characteristics with a
Category I through put during an inventory period, a process monitoring program is
used to detect anomalous conditions and indicate losses between and during physical
inventories periods.
DOE-STD-1194-2011
42
Table 6.2-5: Nuclear Material Control Measures for Category III SNM
Category III quantities must be located in a Limited Area or higher security area.
Authorized activities and the authorized locations for nuclear materials in each MBA are
identified.
Controlled by authorized and trained personnel with a minimum of an “L” security
clearance. A “Q” security clearance is required for materials when a VA determines that
additional clearance is necessary to minimize risk.
When not in use, SNM are stored in an approved locked repository. Security-locked doors
will allow a room to serve as a repository. Acceptable locks are a three-position changeable
combination lock meeting GSA standards for classified storage, or a DOE-approved
automated access control device. Storage locations and areas where SNM is in-use but
unattended, are protected by an intrusion detection system or patrolled at intervals not
exceeding eight hours.
SNM items that are not being processed or will be stored for more than 6 months are
tamper-indicating. SNM containers leaving the MBA are tamper-indicating.
Controls associated with a Protected Area or Material Access Area is sufficient by
themselves for Category III SNM, unless they are identified as credible substitution
materials for higher category SNM.
Multiple Category III and IV locations outside a Protected Area do not total a Category II or
greater quantity; or an assessment shows rollup is not credible.
When a processing operation involves changes in material characteristics with a Category I
throughput during an inventory period, a process monitoring program is used to detect
anomalous conditions and indicate losses between physical inventories.
Table 6.2-6: Nuclear Material Control Measures for Category IV Nuclear Materials
MBA located in a Property Protection Area or higher security area. Authorized activities
and the authorized locations for nuclear materials in each MBA are identified.
Controlled by authorized and trained personnel.
Stored in an approved locked building, area, cabinet, or container that is not man portable.
Locksets are pick-resistant with strict key control and accountability. An automated
access control device approved by DOE may be used.
SNM items that are not being processed or will be stored for more than 6 months are
tamper-indicating. SNM containers leaving the MBA are tamper-indicating.
Controls associated with a Protected Area or Material Access Area is sufficient by
themselves for Category IV nuclear materials unless they are identified as credible
substitution materials for higher category SNM.
Multiple Category III and IV locations outside a Protected Area do not total a Category II or
greater quantity; or an assessment shows rollup is not credible.
When a processing operation involves changes in material characteristics with a Category I
throughput during an inventory period, a process monitoring program is used to detect
anomalous conditions and indicate losses between physical inventories.
DOE-STD-1194-2011
43
6.3 MEASUREMENTS
Measurements are the basis of accounting for inventories and transfers and provide
assurance that no nuclear material is missing. They provide information on quantities,
isotopic composition and weight percent determination of nuclear material in given
locations which is essential to determining category levels and protection requirements.
All nuclear material quantities in the material accounting records shall be based on
measured values for element and isotope for nuclear material associated with:
Additions to inventory (e.g., receipts)
Removals from inventory (e.g., shipments and measured discards)
Material on hand at the time of inventory.
Objectives of a measurements program are as follows:
The measurements program must provide measured values with uncertainties sufficient to
detect theft or diversion of nuclear material.
The measurement control program must assure the quality of measurements made for
MC&A purposes.
When material not amenable to measurement is received at a facility and receipt
measurements are not possible, the material can be entered into the accounting records
based on shipper’s values and acceptable confirmation measurements of two attributes of
the nuclear material. Material is considered “not amenable to measurement” when the size,
configuration, or characteristics of the nuclear material are such that a quantitative
measurement with acceptable precision and accuracy is not possible with measurement
equipment and techniques that are commercially available. Limited processing to obtain an
accountability measurement is permitted, provided it is approved by the DOE cognizant
security authorities for both the shipper and receiver.
6.3.1. Types of Measurements
Three types of measurements are used for accountability purposes:
(1) Accountability measurements shall be used to establish initial values for nuclear
materials and to replace existing values with more accurate measured values. These
measurements must be of the highest quality, consistent with the graded safeguards
concept for the highest potential material attractiveness level, and the contribution of
the uncertainty of the measurement to the overall measurement uncertainty of the
inventory or transfer values.
(2) Verification measurements shall be used to validate the accounting system values when
necessary, e.g., at time of physical inventory for non-tamper-indicating items or in
response to a security anomaly that could have resulted in a theft or diversion of
nuclear material. Verification measurements do not need to use highly accurate or
precise methods, however, when these measurements are used to adjust accounting
DOE-STD-1194-2011
44
values, they shall have accuracy and precision comparable to, or better than the original
measurement method.
(3) Confirmation measurements shall be used to validate the presence of nuclear material
for transfers, and to determine nuclear material presence under anomalous conditions.
In order to validate nuclear material presence, a characteristic of the nuclear material,
not just the item, must be measured. However, when an item has been stored in a
Category I or II area under TID protection, and an effective material surveillance
program for that area, item gross weight may be used for as a confirmation
measurement.
6.3.2. Measurement Methods and Procedures.
6.3.2.1 The quantity of all nuclear material present on inventory shall be determined using
measurement methods or measurement services described in the MC&A Plan,
unless shipper’s values are accepted with DOE approval. The site/facility operator
shall develop and maintain methods for confirming the presence of nuclear
materials and verifying material quantities.
6.3.2.2 Procedures for each measurement method shall provide clear direction to
the analyst or operator, and must be validated initially and revalidated
whenever changes are made.
6.3.2.3 Measurement procedures shall be approved by the MC&A manager or designee,
the manager of the organizational unit responsible for performing the
measurement, and the person overseeing the measurement control program. The
site/facility operator shall have a change control program for measurement
procedures and a mechanism for ensuring an MC&A review of all changes to
measurement procedures.
6.3.2.4 When a weight or mass measurement method is used for accountability purposes, a
daily check of both accuracy and linearity shall be performed. The check must use
standards that bracket the range typical of measurements performed for the material
being measured.
6.3.2.5 When a volume measurement method is used for accountability purposes, the
following shall be specified in measurement documentation:
Vessel identification (e.g., tank, column)
Capacity of the vessel to which the measurement applies
Material being measured
Volume measuring device and instrumentation
Sensitivity of each device and system
Range of operation and/or calibration, and
Calibration frequency.
6.3.2.6 Calibration frequency shall be determined by documented studies of system
stability or defined by alternative approaches documented by the site. Recalibration
DOE-STD-1194-2011
45
shall be performed whenever there is a change that could impact the calibration,
e.g., replacement of an agitator or heating element in the tank.
6.3.2.7 When an analytical measurement method is used for accountability purposes, the
following shall be specified in measurement documentation:
Type of material or chemical compound (e.g., UF
6
, uranium alloy, UO
2
,
uranyl nitrate solution) being sampled and measured
Sampling technique
Sample handling (i.e., pre-analysis sample storage and treatment)
Analytical method used
Characteristics measured (e.g., grams of uranium per gram sample, U-235
isotopic concentration)
Measurement interferences
Expected measurement uncertainty (precision and accuracy goals).
Measurement uncertainties in the sampling and analysis can be quantified
either separately or in combination.
Whether the measurement method can be influenced by the person performing
the measurement. If a method can be influenced by the person making the
measurement, the measurement control program must evaluate that person’s
performance.
Calibration standard(s) and calibration frequency.
6.3.2.8 When an NDA measurement method is used for accountability purposes, the
following shall be specified in measurement documentation:
The NDA equipment package (type and size of detector and type of associated
electronics and computer interface, as appropriate)
The type of container or location measured
Nuclear material type within the container or location
Attribute(s) measured
Measurement configuration (including source-to-detector distance)
Calculation method
Modeling assumptions
Expected measurement uncertainties (precision and accuracy goals)
Calibration standard(s) and calibration frequency.
Which material types/material form for which the standards are applicable
6.3.2.9 When sampling of bulk material is required to obtain a measurement, the
site/facility operator shall develop a sampling plan and a corresponding
background document outlining studies and validation of the sampling plan for
DOE-STD-1194-2011
46
each sampling method. The sampling plan shall be written as a technical
procedure and include:
Justification of sampling technique
Physical characteristics of the material being sampled
Description of equipment and supplies required
Discussion of sampling procedure
Number of samples required
Size of samples
Mixing procedures, including times
Instructions for storing and transporting a sample
Estimates of the variance.
6.3.2.10 The sampling plan shall be reviewed annually or when necessary to adapt to
changes in sampling procedures or the material being sampled.
6.3.3. Selection and Qualification of Measurement Methods
6.3.3.1 The site/facility operator, through documented procedures, shall ensure that only
qualified measurement methods are used for accountability measurements.
6.3.3.2 Accountability measurement methods shall be selected to minimize the uncertainty
of the inventory difference, maximize the loss detection sensitivity of the MC&A
system, and assure the quality of the measurement results consistent with the
consequences of the loss of the material.
6.3.3.3 Measurement methods, including the measurement instruments and operators, shall
be qualified, periodically validated, and approved by the MC&A organization.
Qualification shall demonstrate how well the method performs under workplace
conditions. The frequency of method validation shall be based on qualification
studies that demonstrate system stability.
Target values for precision and accuracy, established and approved by DOE line management,
shall be used as performance goals. Performance during qualification shall be documented to
validate that the method can be performed with the material types for which the method is
qualified. A reference for target values is: International Target Values 2000 for
Measurement Uncertainties in Safeguarding Nuclear Materials, IAEA Report STR-327,
published April 2001.
DOE-STD-1194-2011
47
6.3.4. Measurement Control Program
Controls on measurements are used to:
Maintain the limit of error of the inventory difference (LEID) within DOE –approved
limits;
Minimize the error contribution resulting from nuclear material measurements; and
Ensure that accountability values have known accuracy and precision.
6.3.4.1 All measurement systems generating accountability values shall be in the
measurement control program.
6.3.4.2 A measurement control program shall quantify the random and systematic errors in
all quantitative measurements used to assess the statistical significance of
inventory differences and shipper/receiver differences. The long term
characteristics of measurement errors are typically quantified via an estimated
range, an estimated standard deviation, or other expression of uncertainty in the
error’s value. The measurement of a standard is required for estimating the bias in
a measurement instrument, or the standard deviation of the systematic error.
Replicate measurements of process materials can be used to quantify the standard
deviation of random errors.
EXAMPLES:
Systematic Error: Estimate the relative standard deviation of the systematic
error (a unidirectional error that affects all measurements of a data set) using
eight measurements taken during an inventory period of a standard having a
known value of 87.000.
1
87.798
2
87.793
3
87.793
4
87.815
5
87.794
6
87.805
7
87.802
8
87.797
Sample average (Xbar)
87.800
Known
87.000
Relative Std Dev%
0.919%
The bias is estimated as Xbar-Known, having the value 87.800 – 87.000 = 0.8.
DOE-STD-1194-2011
48
Assuming that the process measurements will not corrected for the estimated
bias, the relative standard deviation (in percent) for the systematic error can be
expressed as:
((Xbar-Known)/Known)*100%
Numerically, the estimated relative standard deviation is
((87.800 – 87.000)/87.000)*100% = 0.919%
Random Error: Estimate the relative standard deviation of the random error
using the analysis of seven batches of process material that were sampled in
duplicate.
Duplicate Measurement Results
d
d*d
1
4.156
4.158
-0.002
0.0000
2
4.236
4.325
-0.089
0.0079
3
4.345
4.354
-0.009
0.0001
4
4.175
4.275
-0.100
0.0100
5
4.386
4.410
-0.024
0.0006
6
4.189
4.091
0.098
0.0096
7
4.312
4.247
0.065
0.0042
Sum d*d
0.0324
Sum d
i
*d
i
/(2*7)
0.0023
Xbar
4.2614
Xbar*Xbar
18.1592
Relative Std Dev%
1.129%
The estimated relative standard deviation (in percent) for the random error is
Sqrt (((Sum d
i
*d
i
)/2k)/Xbar
2
)*100%, where
d
i
is the difference between the first and second duplicate
analyses of the i
th
batch,
k is the number of paired analyses,
Xbar is the overall average of all measurement, and
Sum and Sqrt represent the respective summation and square
root functions.
Numerically, the estimated relative standard deviation is
Sqrt ((0.0324/(2*7)))/18.1592)*100% = 1.129%
Determining Systematic and Random Error for Holdup
Calculating the systematic and random error for holdup can be
difficult. A conservative approach to the systematic error would
be to assume a value of 0. An approach to determining
systematic error would involve putting a known standard in
various places in a glove box or location similar to where the
DOE-STD-1194-2011
49
actual holdup is to be measured. The NDA measurement is
performed several times and the nuclear material value is
determined. The systematic error is then determined in a manner
similar to that shown above.
The random error would be determined by making repeated
measurements of the holdup and calculating the nuclear material
values. The methodology shown above would then be used. An
alternate approach would be to make a measurement of holdup
and use a different assumption of the modeling of the nuclear
material quantity, and then calculate the random error between
the two models. Regardless of the method used, complete
documentation should be maintained.
6.3.4.3 When accountability measurements are used to routinely evaluate inventory and
shipper/receiver differences, the measurement control program shall be capable of
ensuring the quality of measurements to a level acceptable to DOE line
management.
6.3.4.4 The site/facility operator shall ensure accountability measurement systems have
adequate calibration frequencies, control of biases, and adequate measurement
precision to achieve predefined goals for detecting material loss.
6.3.4.5 The error estimates shall reflect the measurement process in existence at the time
of the measurement of process materials.
6.3.4.6 Measurement control program procedures shall be established and maintained in a
manual that is kept current and readily available. Responsibility for preparing,
revising, and approving procedures shall be specified. The procedures must
address:
Calibration frequencies and methods.
Standards used for calibration (description and storage controls).
Standards used for control (method of obtaining or preparation, and
tractability).
Control standard measurements.
Replicate sampling and replicate measurements.
Statistical analysis for evaluation of measurement control data to determine
control limits and precision and accuracy estimates for each measurement
system used for accountability. This data should be maintained on a current
basis.
Verification of process control and inventory quantification instrumentation
through comparison with other process instruments.
Control limits and control responses.
Generation, collection, and maintenance of control data to provide an audit
trail from source data to accounting records.
Software quality assurance.
Record keeping controls and requirements.
DOE-STD-1194-2011
50
6.3.4.7 If measurement services, such as instrument calibration are provided by an outside
contractor or offsite laboratory, the site/facility operator shall describe how this
program is monitored to ensure that the contractor or laboratory has an acceptable
measurement control program—that is, the measurements made with instruments
under their program meet the site/facility operator’s measurement control program
commitments.
6.3.4.8 A person in charge of the measurement control program shall have the authority to
enforce all applicable measurement control requirements, including the authority to
terminate and restart measurement systems.
6.3.5. Calibration and Standards
6.3.5.1 Each method shall be calibrated using standards traceable to the National Institute
of Standards and Technology (NIST) Standard Reference Materials or the New
Brunswick Laboratory (NBL) Certified Reference Materials. Standards shall have
smaller uncertainties associated with their reference values than the uncertainties
of the measurement method in which they are used. Standards shall be recertified
at a frequency that ensures their uncertainties are valid.
6.3.5.2 The method, including the entire measurement system, shall be calibrated with a
control standard, or set of standards that are representative of the process material
being measured by the system, to the extent possible. To be representative, any
constituent of the process material, or any factor associated with a process item,
that produces a bias effect on the measurement shall be present to a similar degree
in the control standards. Control standard measurements serve the dual purpose of
monitoring the stability of a previously determined calibration factor, and
estimating the average system bias over a period of time (e.g., an inventory
period). A control standard can be any combination of primary, secondary,
reference, or working standards used to calibrate or verify the calibration of a
measurement system. The minimum total number of control standard
measurements during the time period, as well as the typical frequency, shall be
specified for each measurement system.
6.3.5.3 Measurement system performance shall be demonstrated at least once each day the
system is used for accountability measurements. For calorimeters and other
measurements requiring an extended measurement time, the performance shall be
demonstrated at least one of every five measurements or weekly. Measurement
control data, such as control standard measurement results and the differences
between measurement values of replicate pairs, shall be plotted manually on
graphs or entered into a computer database for generating control charts.
6.3.5.4 A minimum of two control standard measurements should be made during each
week that a key measurement system is used. Key measurement systems are those
systems that account for >30 percent of the total measurement variance
contribution to the LEID. When key measurement system are used less than eight
weeks during a 2 month material balance period, more than two control standards
DOE-STD-1194-2011
51
per week of system use may be necessary. The site/facility operator should strive
to achieve a minimum of twenty (20) control standard measurements during the
inventory period for each measurement system.
6.3.5.5 Measurements shall be used for accountability purposes only when standards cover
the range of measurements.
6.3.5.6 Calibration determinations that use mathematical models shall include assumptions
of the model in measurement documentation that are based on calibration methods
and controls used to ensure that measurements fit the calibration model.
6.3.6. Control Limits
6.3.6.1 Warning and alarm (out-of-control) limits shall be established and used for control
standard measurements for measurement systems that are used for nuclear material
accountability. Warning limits shall be set at two standard deviations and alarm
limits shall be set at three standard deviations.
6.3.6.2 A measurement system is out-of-control when:
Two consecutive control standard or replicate measurements exceed two
standard deviations;
One control standard measurement exceeding three standard deviations;
Two of three consecutive control standard or replicate measurements
exceeding two standard deviations;
Eight consecutive control standard or replicate measurements are biased high
or low.
6.3.6.3 Activity response required for a measurement system that is out-of-control is as
follows:
Take the measurement system out of service with respect to accountability
measurements.
Either the analyst or the operator performing a control measurement or their
supervisor should have the responsibility for promptly reporting any control
standard, or replicate measurement that exceeds an out-of-control limit.
Such reporting shall be made to the person responsible for the measurement
control program.
Perform at least two additional control measurements and those should be
within two standard deviations.
Perform additional control measurements, if results do not show the system
to be back in control, using a different control standard or different replicate
sample (as appropriate) or recalibrating the measurement system, or making
any necessary system repairs.
Re-measure of any samples (or items) that were measured before the out-of-
control condition but after the last within-control measurement. The validity
DOE-STD-1194-2011
52
of the previous measurements can be established without a complete re-
measurement of all the samples (or items) involved if re-measurement on a
“last in, first out” basis is used. That is, the last sample (or item) measured
before the out-of-control measurement should be the first to be re-measured,
and continuing in reverse order until two consecutive re-measurements are
found to be in agreement with their initial measurement at the 95 percent
confidence level.
6.3.6.4 All control charts shall be reviewed by a person responsible for measurement
control at least monthly, unless the measurement system was not used during that
period. The review shall assess how often the control data exceeds either the
warning or the out-of-control limits and evaluate any significant trends.
EXAMPLE:
Control charts should be periodically reviewed (at least monthly)
or software developed to identify out-of-control situations. The
review should consider some or all of the following situations:
1 point outside the 3s line-(Chart A)
2 out of 3 points outside the 2s line-(Chart B)
8 consecutive points all above or below the centerline-(Chart C)
6 consecutive points trending upward or downward-(Chart D)
15 consecutive points alternating above and below the centerline-(Chart
E)
Examples of out of control situations are shown in the charts
below:
DOE-STD-1194-2011
53
C+3s
C-3s
C+2s
C-2s
C
Alarm Limit
Alarm Limit
Warning Limit
Warning Limit
1 point outside the 3s line
Chart A
C+s
C+s
C+3s
C-3s
C+2s
C-2s
C
Alarm Limit
Alarm Limit
Warning Limit
Warning Limit
2 out of 3 points outside the 2s line
Chart B
C+s
C+s
C+3s
C-3s
C+2s
C-2s
C
Alarm Limit
Alarm Limit
Warning Limit
Warning Limit
8 consecutive points all above or
below the center line
Chart C
C+s
C+s
DOE-STD-1194-2011
54
C+3s
C-3s
C+2s
C-2s
C
Alarm Limit
Alarm Limit
Warning Limit
Warning Limit
6 consecutive points trending
upward or downward
Chart D
C+s
C+s
C+3s
C-3s
C+2s
C-2s
C
Alarm Limit
Alarm Limit
Warning Limit
Warning Limit
Chart E
C+s
C+s
DOE-STD-1194-2011
55
6.4 ACCOUNTING
The functions and objectives of a nuclear materials accounting system are:
(1) Accurate records of nuclear materials inventory are maintained and transactions and
adjustments are made.
(2) The accounting system provides data and reports on nuclear material sufficient to
support local, national, and international commitments.
(3) The accounting system must accurately reflect the nuclear material inventory and
have sufficient controls to ensure data integrity.
(4) The accounting system provides data for reporting on accountable nuclear material
to NMMSS and Nuclear Materials Inventory Assessments.
(5) The accounting system must use material balance areas as the basis of the
accounting structure with key measurement points established to localize and
identify inventory differences.
The accounting records provide a means for assessing performance of the MC&A system
and determining compliance with regulatory requirements.
6.4.1 General Accounting Practices
Each DOE facility possessing reportable quantities of accountable nuclear materials listed
in Appendix C and /or Appendix D shall establish and maintain procedures that describe
the structure and operation of the system used to account for the nuclear materials. The
procedures must accurately reflect current accounting practices and follow generally
accepted accounting principles promulgated by the Financial Accounting Standards Board.
6.4.1.1 Shipments, receipts, transfers, changes in physical form, chemical/isotopic
composition, location, and adjustments, of the nuclear material inventory must be
approved and accurately recorded and entered into the accounting system within a
timeframe approved in the MC&A Plan.
6.4.1.2 The accounting system shall include checks and balances to deter any one person
or organization from affecting changes in the status of nuclear material and
making unapproved changes to the accounting system.
Separation of duties to reduce errors and deter improper transactions -
Duties for recording accounting information should logically separate
process operations, material change authorization, and accounting record
updates.
Transactions are properly authorized - Controls must be sufficient to assure
that all transactions are recorded.
Recorded transactions are reasonable and valid - The transaction must appear
by all its characteristics to be reasonable to MC&A accounting management,
and controls exist to identify potentially false transactions. Flagged
transactions are reviewed prior to acceptance into the system.
DOE-STD-1194-2011
56
When accounting systems allow a single individual to make item adjustments,
procedures should be in place to ensure a source document as backup for the
transaction is generated and an independent technical review of all inventory
adjustments is performed. An inventory adjustment that is not reviewed may be
a potential source of a masked diversion.
6.4.2. Account Structure
6.4.2.1 At least one reporting identification symbol (RIS) must be established for the
facility with an assigned nuclear material representative who is responsible for
reporting data to NMMSS. Additional RISs can be established for waste
accounts, material under International Atomic Energy Agency (IAEA) agreement,
or for another reason identified by the DOE.
6.4.2.2 For each RIS the facility shall establish one or more accounts called material
balance areas (MBAs), and all nuclear material shall be assigned to an MBA
unless safeguards have been terminated in accordance with safeguards termination
requirements. An MBA must have the following characteristics:
An integral operation within a single geographical area that does not
cross a material access area or a protected area boundary.
An identified nuclear material category, along with a description of the
authorized operations.
An assigned MBA custodian who controls nuclear material movement,
approves transfers, and conducts physical inventories. A custodian can
be responsible for multiple MBAs but must not be responsible for
multiple MBAs when transfers of nuclear material occur between those
MBAs (i.e., a single custodian must not serve as both shipper and
receiver for material transfers).
Defined key measurement points for inputs, outputs, and inventory that
facilitate localization of inventory difference.
6.4.3. Accounting Systems
6.4.3.1 The accounting system shall provide continuity of knowledge for all nuclear
material from receipt through disposition by maintaining an audit trail that
includes documentation of transfers, adjustments, measurement results with
measurement method, and the identity of individuals making changes to the
accounting system (date and time stamp). Entries are fully supported by source
documentation.
6.4.3.2 The accounting system shall provide detection capability for data falsification and
unauthorized access to the accounting system and source documents.
The accounting system, whether a paper system or computer-based, should have
checks and balances that ensure data entered is authorized, reasonable, appropriate,
and matches source documents. If a computer system is used to generate
DOE-STD-1194-2011
57
accountability records, a brief overview of the hardware and software
configuration should be provided, along with a description of how the system is
controlled. Information technology systems used for MC&A will be certified in
accordance with DOE requirements. System documentation should include a
general description of the computer security measures in place and should refer to
relevant computer security documents.
For Example:
A description of the database(s) and operating system (including classification,
where applicable).
Description of security measures in place to protect information from
unauthorized access (e.g., secure local area networks, unclassified/sensitive
networks, or encryption devices).
Responsibility for authorizing access to system.
Responsibility for maintaining the system and associated software.
System assurances (e.g., backup and/or reconstruction capabilities).
Change control; password control; data access control.
The Local Area Nuclear Material Accountability Software (LANMAS) is a DOE
standard, network-based accounting software used to satisfy essential records and
reporting requirements established by DOE policy for the control and
accountability of nuclear materials. While not required, LANMAS provides the
necessary framework for establishing MBAs, reporting all required nuclear
material, and transmitting data to NMMSS.
6.4.3.3 To meet emergency needs the accounting system shall be capable of being
updated daily or on demand, and a book inventory listing of all SNM must be
generated within 3 hours of the request.
This requirement is for updating records based on reports or information; it does
not pertain to how quickly a facility must be able to complete measurements. The
listing must differentiate between SNM and other nuclear material.
6.4.3.4 Data integrity shall be assured by backing up accountability data at a frequency
approved in the MC&A Plan by DOE line management and periodically testing
disaster recovery capability.
6.4.4. Accounting Data and Records
6.4.4.1 Accounting records and source documents shall include permanent/indelible item
identification to the extent practicable, material type, form, quantity, location,
gross weight, net weight, isotope, element concentration, enrichment for nuclear
materials in all MBAs. (If available)
DOE-STD-1194-2011
58
Source documents are the forms or reports documenting a transaction. A source
document is required for every activity; such as item creation, transfer, removal,
process holdup adjustments, change in form or location, or measurement, which
alters the accountability status of nuclear materials. Source documents may be
hand-generated paper documents, computer-generated paper documents, or
computer generated data files, and are used to update the database. The MC&A
Plan should describe the types of source documents generated and the permissions
or controls required to generate, prepare, approve and file the documents.
6.4.4.2 The site/facility operator shall establish a documented program to evaluate all
inventory adjustments entered in the accounting records. Procedures must be
developed and implemented to ensure that all inventory adjustments are supported
by measured values or other technically justifiable bases. Holdup adjustments
must be justified on the basis of measurements or other factors. The program must
include documented procedures for the statistical review of inventory adjustments
using techniques such as tests of trends, biases, and correlation. The inventory
adjustment program shall address:
Shipper/Receiver Differences, including a discrepancy in the number of items, a
statistically significant measurement result, trending of difference data, and
reporting requirements.
Inventory Differences, including reporting of missing items, inventory
differences that exceed control limits, and reporting requirements.
Evaluation of Other Inventory Adjustments, including procedures for applying
radioactive decay, fission transmutation, adjustments for re-measurement of
items, and reporting of abnormal situations to DOE line management.
6.4.4.3 Accounting information shall be sufficient for calculating shipper/receiver and
inventory differences, evaluating their significance, and investigating and resolving
significant differences. For consistency, material in-transit at the end of a
reporting period must be included in the receiver’s reported inventory.
6.4.4.4 Nuclear material activities shall be reported in the same accounting period in
which they occurred.
In nuclear material accounting, this means that transactions and inventory
adjustments are recognized during the accounting period in which they occur. For
example, a shipment made on the last day of the month should be shown as a
transaction by both the shipper and the receiver for that month, even though the
receiver may not receive the material until the following month. As this example
shows, care is needed in recording each event for the purpose of reporting its effects
in the inventory statements.
Inventory adjustments should be addressed in the MC&A Plan and additional
details should be provided in accounting procedures. For those facilities using
LANMAS the system requires that all data entries be “balanced” and an
inventory difference may be generated as part of a transaction.
DOE-STD-1194-2011
59
6.4.4.5 In addition to an itemized listing of all nuclear material on inventory, the
accounting system shall maintain a separate record referred to as the Material
Balance Report (MBR) or General Ledger.
This ledger keeps track of total quantities on hand since the previous physical
inventory (or beginning accounting period), additions to the site, removal from the
site, adjustments to site accounting records, and the ending inventory (or ending
accounting period).
6.4.4.6 Accounting system data shall be sufficiently accurate and timely to confirm that a
planned material movement would not exceed the approved category level of the
MBA or exceed site-wide rollup constraints.
Rollup refers to the accumulation of quantities of nuclear material to a higher
category. Facilities should require advance approval of MBA transfers, or the
accounting system should determine a priori that a planned material movement
will not exceed the approved category levels.
6.4.4.7 Source documents and records are considered quality records and shall be retained
and protected in accordance with DOE O 200.1, Information Management
Program.
Records retention should exist in order to facilitate reconstruction of events. The
records should reflect the needs of the accounting office, management and review
groups, both internal and external. The DOE Administrative Records Schedule 18:
Security, Emergency Planning, and Safety Records, published by the Chief
Information Officer, provides a list of documents that includes MC&A records and
their associated retention schedule.
6.4.5 Accounting Reports
6.4.5.1 Data fields shall be defined and nuclear material information on shipments,
receipts, internal changes, and inventory data sufficient to comply with national
and international reporting objectives shall be reported to NMMSS within
established timeframes.
NMMSS is the U.S. Government's information system containing current and
historic data on the possession, use and shipment of nuclear materials. This
centralized database contains information collected from government and
commercial nuclear facilities, and provides output reports to those facilities and
other interested parties, primarily U.S. Government offices charged with the
management and safeguarding of nuclear materials. To accomplish their mission,
NMMSS requires facilities to provide two types of information:
Transaction data
Inventory summary data.
DOE-STD-1194-2011
60
The transaction data is coded information for the MBR and the inventory summary
data are the beginning and ending accounting period inventory information. Data
collected and submitted to NMMSS is site summary level data, and not MBA or
item specific data. Timely and accurate inventory and transaction data is required.
For most facilities with Category I quantities, information is submitted monthly
due to the volume of transactions. Other facilities that are less active may submit
quarterly. NMMSS closes its records system monthly and has reports available for
facilities. NMMSS is required to reconcile the national system to each facility’s
data on an annual basis, based on transaction and inventory summary data as of
September 30 of each year.
The NMMSS User Guide provides detailed instructions on completing forms and
submitting data to NMMSS. Electronic submission of data is required, unless
manual submission is coordinated with DOE line management. The manual
includes reporting formats for transaction data, MBR data, inventory data, Foreign
Obligations Reporting and IAEA reporting. The NMMSS program provides a
number of means for submitting data electronically to NMMSS including
SIPRANET, SECURENET, SIMEX, and encrypted unclassified e-mail. The
NMMSS Operator can provide additional information about submitting data
electronically. Contact information for the NMMSS Operator is available at
www.hss.doe.gov/NMMSS. NMMSS also provides its users with the Safeguards
Management Software (SAMS), a software package that facilities can use to
validate data. Sites should use SAMS to screen data before submitting it to
NMMSS, thus reducing the time needed to reconcile facility and NMMSS data.
6.4.5.2 Material Balance Reports (MBRs) are to be submitted annually to NMMSS for the
September 30th accounting period and reconciled with the NMMSS data. More
frequent data submission and reconciliation of MBRs may be required by DOE line
management. DOE facilities selected under the U.S./IAEA Safeguards Agreement
will also be required to meet any additional or more frequent reporting requirements
for MBRs and other data reports as specified in the facility attachment.
The MBR can be prepared by either the NMMSS operator or by the site/facility
operator. The site/facility operator may place a standing request with NMMSS to
have NMMSS generate an MBR (DOE/NRC Form 742) in lieu of submission of
reports by the site/facility operator. The use of previously reported inventory data
and transaction data enables the NMMSS system to generate the material balance
report. Reconciling transactions must be submitted if NMMSS balances are to be
changed.
6.4.5.3 Radioactive decay shall be reported on MBRs annually when the decay has
reached reportable quantities, or more frequently if required by DOE line
management. Normal operating losses (NOLs) and write-offs shall be reported
individually, or with approval of DOE line management, entered monthly.
DOE-STD-1194-2011
61
6.5 PHYSICAL INVENTORY
6.5.1 General Inventory Procedures
The objectives of a physical inventory are:
(1) The physical inventory in conjunction with other MC&A elements assures that
accountable nuclear materials are not missing.
(2) The physical inventory program ensures that discrepancies between the physical
inventory and the accounting records system are detected and resolved.
Performance of a physical inventory consists of the following steps:
1. Determination of what is on inventory at the required frequency (the materials on
hand at the time of the inventory),
2. Ensure that process MBAs are prepared prior to the conduct of the actual physical
inventory (i.e. equipment cleaned out),
3. Comparison of materials on hand to the records (book inventory), and
4. Investigation and resolution of any differences resulting from step 3.
Determining what is on inventory involves observations and measurements of materials
present at the time of the inventory. The list of materials on hand during physical inventory is
then compared to the records. The records are the listings of all materials from the previous
physical inventory, plus materials moved into and out of the MBA. Anomalies may develop
in this comparison that requires investigation and resolution; for example, items may be
missing, or the inventory difference (calculation from step 3) may be significantly different
from zero.
The book inventory records keep track of what materials went into and out of the MBA,
and thus indicate what materials should be on hand at the physical inventory. Some of
these materials may be present as discrete items that could easily be traced to individual
entries in the records. Other materials may be present as bulk quantities that result from
some portion or all of many entries in the records.
Ideally, during a physical inventory, all materials (bulk or item) are located, have
quantitative values, or quantitatively measured to assure their presence and quantity, and
all areas are inspected to assure that there are no materials present that are not reflected in
the records. The bulk materials are either moved to a location where they can be
measured, as in the case of liquids being moved to an accountability tank, or they are
converted to a stable form for measurement, such as conversion to an oxide or metal.
6.5.1.1 The site/facility operator shall implement a physical inventory program for
accountable nuclear materials to demonstrate that materials are present in their
stated quantities and to detect unauthorized removals or discrepancies.
DOE-STD-1194-2011
62
The physical inventory provides data for two forms of anomaly detection: records
checks and calculation of a material balance (and the resultant inventory
difference). To provide these anomaly detection capabilities, a physical inventory
must be able to relate the materials on hand to the records, and to determine
accurately how much material is present (as well as how much has moved through
the MBA and if this represents a loss of material.
6.5.1.2 The physical inventory procedure may use either a pre-list of the book inventory
generated by the accountability computer to locate items, or a hand list of items
may be generated during the inventory, and the list compared to the accountability
records.
6.5.1.3 In lieu of a 100 percent item inventory, a statistical sampling plan may be defined
by the site/facility operator and approved by DOE line management. A plan must
meet the parameters of Table 6.5-1. Sampling plans should be developed for each
MBA category, and MBAs may be combined. A formula similar to that shown in
Example 6.2.4-3 may be used.
6.5.1.4 Inventories must be based on measured values including measurements or
technically justifiable estimates of holdup.
It may not be practical to measure all items due to radiation exposure or time
required. Therefore, items that are tamper-indicating or have been sealed with a
TID and have been continually under an effective material surveillance program do
not need inventory measurements. If there is no indication that an item has been
altered, the previous measured value may be used in calculating the material
balance.
Items that are not tamper-indicating or sealed with an effective TID must be
measured to quantify the nuclear material. When a large number of these items
exist, a statistical sampling plan with parameters stated in Table 6.5-1 may be used.
Justification for using a sampling plan for these materials must be provided to
DOE line management who must approve the plan.
6.5.1.5 The physical inventory is also used to show that TIDs are present in their assigned
locations, applied to the item indicated in the accounting record, are intact, and that
the intact TID has served its function (indicating tampering or altering). During
physical inventory, applied TIDs must be compared to the accounting records
system and to TID records. Each item should be inspected for penetration and for
integrity of both the item packaging and the TIDs. Tag checks, also called location
checks (each item is located), are used during a physical inventory to identify gross
defects in the inventory. Missing items, missing tamper-indicating devices and
broken, falsified, or violated tamper-indicating devices are all examples of gross
defects.
DOE-STD-1194-2011
63
Table 6.5-1, Minimum Sampling Parameters for Physical Inventories
Category
Confidence Level
Minimum Detectable Defect
I
95%
3%
II
95%
5%
III & IV
95%
10%
6.5.1.6 Acceptance/rejection criteria shall be established and documented in the MC&A
Plan for both item inventories and measurements. The statistical sampling plan
must state how inventories or measurements that fail the criteria are resolved.
6.5.2. Scheduling and Planning Inventories
6.5.2.1 Physical inventories of accountable nuclear materials shall be conducted at
frequencies commensurate with the Category and operations conducted in each
MBA in accordance with Table 6.5-2.
Table 6.5-2 Physical Inventory Frequencies
6.5.2.2 Inventory frequencies may be extended using alternative measures specified in
Table 6.5-3 after review and approval by DOE line management.
Security analysis shall be performed, and if necessary vulnerability/risk
assessments, to provide assurance that the risk associated with the extended
inventory period or automated inventories is acceptable. Safeguards and security
systems should be integrated to achieve protection system effectiveness.
Multidisciplinary teams shall perform independent assessments.
6.5.3. Automated Physical Inventories
As technology advances, automation may be applied to physical inventory methods.
Automated physical inventories should accomplish the same objectives as manual physical
inventories listed above in Section 6.5.1. As with manual inventories, automated
measurements are allowed on a statistical basis for storage locations where a 100% inventory
is not feasible. However, in most cases where inventories are automated, it should be
practical to do a 100% inventory within approved inventory timeframes.
Category
Processing MBA
Storage MBA
I
2 months
6 months
II
2 months
6 months
III
6 months
2 years
IV
6 months
2 years
DOE-STD-1194-2011
64
Table 6.5-3, Inventory Periods Based on Alternative Measures
for Category I and II Storage Locations
Alternative Inventory Control Measures
1
Inventory Period
Formidable barriers
1 year
Hazardous environment
1 year
Bulk containment
1 year
Vault enhancement above baseline requirements
9 months
Continuous monitoring of physical or mechanical parameters
1 year
General (area-wide) confirmatory measurements
1 year
Continuous item observation
2
(e.g., video/image, laser
surveillance)
2 years
Continuous item monitoring
2
(e.g., monitoring of serial
number, TIDs, movement)
2 years
Mass
2
(load cell)
2 years
Confirmatory measurements
2
on individual items (e.g.,
thermal, gamma, or neutron emission)
3 years
Quantitative measurements on individual items
May qualify as a
continuous inventory
2
1
When multiple measures are used for storage MBAs, the inventory periods are additive as
long as the alternative measures function independently.
2
If the measurements are both item- and material-specific and there is a level of confidence that the
measurements are correct, the monitoring may qualify as a continuous physical inventory. To be
considered a continuous physical inventory, automated measurements must be made on all items on a
second-to-second basis.
6.5.4 Inventory of Unmeasured, Poorly-Measured, Irradiated, and Inaccessible
Materials
The term, “not amenable to measurement”, is not equivalent to “not convenient to measure” or
“challenging to measure.” Where at all possible, material should always be measured.
Applicability of “not amenable to measurement” is determined on a case-by-case basis and
requires approval by DOE line management. Appropriate accountability measurement
programs should be developed for material that is received on a continuing basis, even if it is
unusual in chemical composition or physical form.
6.5.4.1 Nuclear materials not amenable to verification measurement shall be identified in
the facility’s MC&A plan. Inventory values for these materials must be based on
measured values or technically justified estimates. Justification and supporting
documentation for these inventory values must be maintained and readily
retrievable for review.
When materials cannot be measured because of size or composition, this does NOT
mean that no attempt should be made to characterize these items. Any available
information should be used to confirm these materials prior to any limited
processing or packaging operations. As soon as possible, a good measurement
should be obtained for use prior to any other operations or in preparation for
storage. The last measurement prior to storage should be compared to initial data,
DOE-STD-1194-2011
65
and differences should be resolved where at all possible, taking into account the
reliability and quality of the initial information.
6.5.4.2 For nuclear material that is not amenable to measurement at time of physical
inventory, confirmation measurements of two attributes may be substituted. The
two attributes chosen for confirmation shall be measured using independent
methods that positively confirm the presence of the nuclear material.
6.5.5 Evaluating Inventory Programs
6.5.5.1 The site/facility operator shall develop, document and implement a program for
evaluating all SNM inventory differences, including those involving missing items.
Programs for evaluation of inventory differences for other nuclear materials may be
established at the option of DOE line management.
6.5.5.2 The site/facility operator shall develop and implement procedures for establishing
control limits and requiring an investigation when those limits are exceeded.
Procedures for establishing control limits for inventory differences of SNM must
be based on variance propagation using current data. The data should reflect
operating conditions for the material balance period of the inventory. Other
methodologies may be used, but they must be approved by DOE line management
and must be justified based on factors such as limited data, low transfer rates,
and/or material category. For Category IV MBAs, control limits may be based on
professional judgment with the approval of DOE line management. Significant
differences between historical limits and limits based on variance propagation
must be investigated for the purpose of validating, revising, and refining the
variance propagation model.
6.5.5.3 Assessments of inventory differences shall be conducted and include statistical tests
(e.g., tests of trends and biases), which must be applied, as appropriate, to both total
inventory difference and actual inventory difference on both an individual and a
cumulative basis for each processing MBA. Inventory records, process logs (where
available), or other information may also be used to detect anomalies and trigger
investigations.
6.5.5.4 Limits of error for IDs (LEID) of processes in new or existing facilities should
be used to trigger the need to evaluate and improve measurement systems to
determine if reduction in uncertainty can be achieved.
DOE-STD-1194-2011
66
6.5.6 Inventory Reconciliation
6.5.6.1 Procedures must be established and approved to reconcile physical inventory
with the book inventory (and adjusted if necessary) within 30 calendar days
following receipt of all inventory information (including sample and analysis
data). The procedures must address responding to and reporting missing items
and inventory differences in excess of control limits. (See Section 6.1.8)
Inventory reconciliation must be completed before starting the next physical
inventory.
6.5.6.2 Reconciliation must consist of the following activities:
Comparison of Accounting System values with physical inventory observed
values.
Verification that all receipts and shipments were properly documented and
reflected in the Accounting System.
Investigate all IDs that are greater than the associated LEID.
Where statistical sampling is used to validate the physical inventory items
that are not tamper indicating, the reconciliation shall include extrapolation to
the total physical inventory.
Resolution of any discrepancies identified in the two actions above prior
to release of the MBA for resumption of operations.
6.5.7 Special (Emergency) Inventories
6.5.7.1 Special inventories may be conducted upon request of the personnel identified in
the MC&A Plan. Examples include, but are not limited to, DOE line management,
the contractor MC&A manager, etc.
Special inventories are those conducted in addition to those conducted at the
required intervals for a particular MBA. Situations in which special inventories are
conducted include, but are not limited to:
Turnover of the Primary MBA Custodian duties from one individual to another,
Transition of contractor responsibility,
Verification that all materials are present following an emergency involving an
evacuation of an MBA,
When doubt exists associated with the holdings of a particular MBA,
For Performance Testing purposes during management assessments, Surveys,
and Office of Independent Oversight Inspections.
These inventories differ from periodic inventories in that they are performed to
address objectives that may not include all elements of periodic inventories. A
specific plan shall be developed for these inventories to address the scope of the
DOE-STD-1194-2011
67
inventory. For example, a post-emergency special inventory may only require the
verification of the presence of the items outside secure storage.
6.5.7.2 Physical inventories performed during IAEA inspections may, with the
concurrence of DOE line management, serve in place of a scheduled physical
inventory.
DOE-STD-1194-2011
A- 1
Appendix A: Suggested MC&A Plan Format
1. Introduction
a.
Purpose
b.
MC&A Goals
c.
Review, Revision, and Change Control
d.
Approvals
2. Program Management
a.
Program Management Objectives
b.
Site Name, Location, and Mission/Programs
c.
MC&A Threat Considerations
d.
Reporting Identification Symbol (RIS)
e.
Plant and MBA Descriptions
f.
Organizational Structure
g.
MC&A Responsibilities and Authorities
h.
MC&A Procedures
i.
Emergency Plans
j.
Incident Investigation and Reporting
k.
MC&A Training and Qualification
l.
MC&A Element Testing
m.
Program Review and Assessment
n.
System Performance Evaluation
3. Nuclear Material Control
a.
Material Control Objectives
b.
Nuclear Material Categorization
c.
Access Controls
d.
Material Containment
e.
Material Surveillance
f.
Material Transfer Controls
4. Measurements and Measurement Control
a.
Measurement and Measurement Control Objectives
b.
Selection and Qualification of Measurement Methods
c.
Measurement Systems
d.
Measurement Controls
5. Nuclear Material Accounting
a.
Material Accounting Objectives
b.
Account Structure
c.
Accounting System Description
d.
Records and Reports
e.
System Assurance
6. Physical Inventory
a.
Physical Inventory Objectives
b.
Plans and Procedures
c.
Inventory Frequency
d.
Reconciliation and Anomaly Resolution
e.
Special Inventories
DOE-STD-1194-2011
B-1
Appendix B: Graded Safeguards Table
s
Attractiveness
Level
Pu/U-233 Category
(kg)
Contained U-235/Separated
Np-237/Separated Am-241 and
Am-243 Category (kg)
All E
Materials
Category IV
I
II
III
IV
1
I
II
III
IV
1
WEAPONS
Assembled weapons and test devices
A
All
N/A
N/A
N/A
All
N/A
N/A
N/A
N/A
PURE PRODUCTS
Pits, major components, button ingots,
recastable metal, directly convertible
materials
B
≥2
≥0.4<2
≥0.2<0.4
<0.2
≥5
≥1<5
≥0.4<1
<0.4
N/A
HIGH-GRADE MATERIALS
Carbides, oxides, nitrates, solutions
(≥25 g/L) etc.; fuel elements and
assemblies; alloys and mixtures; UF
4
or
UF
6
(≥50% enriched)
C
≥6
≥2<6
≥0.4<2
<0.4
≥20
≥6<20
≥2<6
<2
N/A
LOW-GRADE MATERIALS
Solutions (1 to 25 g/L), process residues
requiring extensive reprocessing;
Pu-238 (except waste); UF
4
or UF
6
(≥
20% < 50% enriched)
D
N/A
≥16
≥3<16
<3
N/A
≥50
≥8<50
<8
N/A
ALL OTHER MATERIALS
Highly irradiated
3
forms, solutions (<1
g/L), compounds; uranium containing
<20% U-235 or <10% U-233
2
(any
form, any quantity)
E
N/A
N/A
N/A
Reportable
Quantities
N/A
N/A
N/A
Reportable
Quantities
Reportable
Quantities
1
The lower limit for Category IV is equal to reportable quantities in DOE O 474.2.
2
The total quantity of U-233 = (Contained U-233 + Contained U-235). The category is determined by using the Pu/U-233 side of this table.
3
In this Technical Standard “highly irradiated is defined in the definitions.
DOE-STD-1194-2011
C-1
Appendix C
Special Nuclear Materials**
Special nuclear materials in this table must be controlled and accounted for in a graded manner
consistent with the Graded Security Protection policy and Graded Safeguards Table.
Material Type
Reportable
Quantity*
Weight Field
Used for
Element
Weight Field
Used for Isotope
Material Type
Code
Enriched Uranium
gram
total U
U-235
20
Uranium-233
gram
total U
U-233
70
Plutonium-242
1
(Pu)
gram
total Pu
Pu-242
40
Plutonium-239-241
gram
total Pu
Pu-239 + Pu-241
50
Plutonium-238
2
tenth of a gram
total Pu
Pu-238
83
Uranium in Cascades
gram
total U
U-235
89
*Reportable quantity is the minimum amount of material subject to the requirements of DOE O 474.2. Facilities
with less than a reportable quantity of a material are exempt from the requirements of DOE O 474.2 for that
material. Facilities with a reportable quantity or more of a material are to report transactions and inventories to
NMMSS. A reporting unit is the mass unit that site/facility accounting systems must use for reporting inventories
and transactions.
1
Report as Pu-242 if the contained Pu-242 is 20 percent or greater of total plutonium by weight; otherwise, report as
Pu-239-241.
2
Report as Pu-238 if the contained Pu-238 is 10 percent or greater of total plutonium by weight; otherwise, report as
Pu-239-241.
**
Although classified as other accountable nuclear material, separated Am-241, separated Am-243, and separated
Np-237 must be controlled and accounted for as SNM.
DOE-STD-1194-2011
D-1
Appendix D
Other Accountable Nuclear Materials
Other Accountable Nuclear Materials in this list must be controlled and accounted for financial
and materials management purposes and being protected in a graded manner consistent with their
strategic and monetary importance or as required by international agreements.
Material Type
Reportable
Quantity*
Weight
Field Used
for Element
Weight Field
Used for
Isotope
Material Type
Code
Depleted Uranium (U)
kilogram
total U
U-235
10
Normal Uranium
kilogram
total U
-
81
Americium-241
4
(Am)
gram
total Am
Am-241
44
Americium-243
4
gram
total Am
Am-243
45
Californium-252 (Cf)
microgram
-
Cf-252
48
Berkelium
3
(Bk)
microgram
-
Bk-249
47
Curium (Cm)
gram
total Cm
Cm-246
46
Deuterium
1
(D)
tenth of a kilogram
D
2
O
D
2
86
Enriched Lithium (Li)
kilogram
total Li
Li-6
60
Neptunium-237
4
(Np)
gram
total Np
-
82
Thorium (Th)
kilogram
total Th
-
88
Tritium
2
(H-3)
gram
total H-3
-
87
*Reportable quantity is the minimum amount of material reportable to the NMMSS.
1
For deuterium in the form of heavy water, both the element and isotope weight fields will be used; otherwise, report
isotope weight only.
2
Tritium contained in water (H
2
O or D
2
O) used as a moderator in a nuclear reactor is not an accountable material.
3
Berkelium must be accounted for at the site level. It is not required that it be reported to NMMSS
.
4
Americium and Np-237 contained in plutonium as part of the natural in-growth process are not required to be
accounted for or reported until separated from the plutonium. If separated, these materials must be controlled and
accounted for as SNM.
DOE-STD-1194-2011
72
CONCLUDING MATERIAL
Review Activity: Preparing Activity:
EM Office of Security Policy (HS-51)
HSS
MA
NE Project Number
NNSA SANS-0006
SC
Field and Operations Offices
CH
ID
NNSA Service Center
ORO
RL
SRO
Site Offices:
ANL
INL
LASO
LLSO
NSO
OR
PSO
RLSO
SRSO
SSO
YSO
External Agency
Defense Nuclear Facilities Safety Board
