DOE M 474.1-1, Manual for Control And Accountability of Nuclear Materials

MANUAL FOR CONTROL AND ACCOUNTABILITY OF NUCLEAR MATERIALS U.S. DEPARTMENT OF ENERGY Office of Nonproliferation and National Security Distribution: Initiated By: All Departmental Elements Office of Nonproliferation and National Security DOE M 474.1-1 Approved: 8-11-99 Sunset Review: 8-11-01 CANCELE D DOE M 474.1-1 i 8-11-99 MANUAL FOR CONTROL AND ACCOUNTABILITY OF NUCLEAR MATERIALS 1. PURPOSE. To prescribe Department of Energy (DOE) requirements and procedures for nuclear material control and accountability (MC&A). This Manual supplements DOE O 474.1, CONTROL AND ACCOUNTABILITY OF NUCLEAR MATERIALS. 2. APPLICABILITY. a. General. This Manual applies to nuclear materials at DOE- owned and -leased facilities and DOE-owned nuclear material at other facilities which are exempt from licensing by the Nuclear Regulatory Commission (NRC). b. Contractors. Except for the exclusions in Paragraph 2c, this Manual applies to covered contractors to the extent implemented under a contract or other agreement. A covered contractor is a seller of supplies or services that is awarded a procurement contract or subcontract and either possesses, uses, or ships nuclear materials at DOE-owned or -leased facilities or possesses, ships, or uses DOE-owned nuclear material at an off-site facility exempt from NRC licensing and regulation. c. Exclusions. This Manual does not apply to DOE-owned nuclear materials at Department of Defense facilities or foreign facilities. To avoid duplicative or conflicting requirements, DOE facilities, projects, and programs under the cognizance of the Office of Civilian Radioactive Waste Management and subject to NRC regulation must use the rules, standards, and criteria specified by the NRC or NRC Agreement State in lieu of this Order. d. Deviations. Deviations from the requirements in this Manual must be processed in accordance with DOE O 470.1, SAFEGUARDS AND SECURITY PROGRAM. 3. DEFINITIONS. Definitions of commonly used terms are provided in the Safeguards and Security Glossary of Terms which is maintained by the Office of Safeguards and Security. 4. REFERENCES. a. Title 42, U.S. Code, Section 2011, et. seq., Atomic Energy Act of 1954, as amended, which establishes a program for Government control of the possession, use, and production of nuclear energy and special nuclear material, whether owned by the Government or others. CANCELE D ii DOE M 474.1-1 8-11-99 b. Title 10, Code of Federal Regulations, Chapter I, “Nuclear Regulatory Commission,” which contains the regulations applicable to NRC and Agreement State licensees involved in activities concerning nuclear materials not subject to DOE requirements. c. DOE O 151.1, COMPREHENSIVE EMERGENCY MANAGEMENT SYSTEM, dated 9-25-95, which establishes requirements and responsibilities for development, coordination, and direction of emergency planning, preparedness, readiness assurance, response, and recovery operations. d. DOE O 232.1A and DOE M 232.1A-1, OCCURRENCE REPORTING AND PROCESSING OF OPERATIONS INFORMATION, dated 7-21-97, which establish a DOE system for identification, categorization, notification, analysis, reporting, follow-up, and closeout of occurrences. e. DOE O 460.1A, PACKAGING AND TRANSPORTATION SAFETY, dated 10-2- 96, which establishes safety requirements and responsibilities for the proper packaging and transportation of DOE offsite shipments and onsite transfers of hazardous materials and for modal transport.

f. DOE O 470.1, SAFEGUARDS AND SECURITY PROGRAM, dated 9-28-95, which establishes requirements and responsibilities for the DOE Safeguards and Security Program. g. DOE O 472.1B, PERSONNEL SECURITY ACTIVITIES, dated 3-24-97, which establishes requirements, objectives, procedures, responsibilities, and authorities for the DOE Personnel Security Program. h. DOE M 474.1-2, NUCLEAR MATERIALS MANAGEMENT AND SAFEGUARDS SYSTEM REPORTING AND DATA SUBMISSION, to be published concurrently with this Manual, which details the data elements and procedures required to document and report nuclear materials transactions, material balances, and inventories to the Nuclear Materials Management and Safeguards System. i. DOE 1270.2B, SAFEGUARDS AGREEMENT WITH THE INTERNATIONAL ATOMIC ENERGY AGENCY, dated 6-23-92, which prescribes policies and responsibilities for compliance with the agreement, including the associated protocol, between the Federal Government and the International Atomic Energy Agency for the application of safeguards in the United States. j. DOE 205.1, UNCLASSIFIED COMPUTER SECURITY PROGRAM, dated 7-26-99, which establishes requirements, policies, responsibilities, and procedures for developing and sustaining the DOE Unclassified Security Program. CANCELE D DOE M 474.1-1 iii 8-11-99 k. DOE 5400.1, GENERAL ENVIRONMENTAL PROTECTION PROGRAM, dated 11-9-88, which establishes the Environmental Protection Program for DOE operations. l. DOE 5480.20A, PERSONNEL SELECTION, QUALIFICATION, AND TRAINING REQUIREMENTS AT DOE NUCLEAR FACILITIES, dated 11-15-94, which establishes the selection, qualification, and training requirements for contractor personnel involved in the operation, maintenance, and technical support of DOE-owned reactors and nonreactor nuclear facilities. m. DOE 5484.1, ENVIRONMENTAL PROTECTION, SAFETY, AND HEALTH PROTECTION INFORMATION REPORTING REQUIREMENTS, dated 2-24-81, which establishes the requirements and procedures for the investigation of occurrences having environmental protection, safety, or health protection significance for DOE operations. n. DOE 5632.1C, PROTECTION AND CONTROL OF SAFEGUARDS AND SECURITY INTERESTS, of 7-15-94, and DOE 5632.1C-1, MANUAL FOR PROTECTION AND CONTROL OF SAFEGUARDS AND SECURITY INTERESTS, dated 7-15-94, which establish requirements and procedures related to the physical protection of DOE safeguards and security interests o. DOE 5639.6A-1, MANUAL OF SECURITY REQUIREMENTS FOR THE CLASSIFIED AUTOMATED INFORMATION SYSTEM SECURITY PROGRAM, dated 7-15-94, which establishes requirements and responsibilities for the development and implementation of a DOE program for the security of classified information processed, stored, transferred, or accessed on computer systems. p. DOE 414.1, QUALITY ASSURANCE, dated 11-24-98, which establishes quality assurance requirements for DOE. q. DOE 435.1, RADIOACTIVE WASTE MANAGEMENT, dated 7-9-99, which establishes requirements for managing radioactive and mixed waste. r. ANSI N15.19-89, Nuclear Material Control—Volume Calibration Techniques, American National Standards Institute, Inc., 1430 Broadway, New York, NY 10018 (1989). s. ANSI N15.36-83, Nuclear Materials—Nondestructive Assay Measurement Control and Assurance, American National Standards Institute, Inc., 1430 Broadway, New York, NY 10018 (1983). t. ANSI N15.41-84, Nuclear Facilities—Derivation of Measurement Control Programs—General Requirements, American National Standards Institute, Inc., 1430 Broadway, New York, NY 10018 (1984).

CANCELE D iv DOE M 474.1-1 8-11-99 u. ANSI N15.51-90, Measurement Control Programs Nuclear Materials Analytical Chemistry Laboratory, American National Standards Institute, Inc., 1430 Broadway, New York, NY 10018 (1991). v. ANSI N15.54-90, Instrumentation—Radiometric Calorimeters Measurement Control Program, American National Standards Institute, Inc., 1430 Broadway, New York, NY 10018 (1991). w. ASTM Standard C993-92, Guide for In-Plant Performance of Automatic Pedestrian SNM Monitors, American Society for Testing and Materials, 1916 Race Street, Philadelphia, PA 19103 (July 1993). x. ASTM Standard C1112-93, Guide for Application of Radiation Monitors to the Control and Physical Security of Special Nuclear Material, American Society for Testing and Materials, 1916 Race Street, Philadelphia, PA 19103 (June 1993). y. ASTM Standard C1169-92, Guide for Laboratory Evaluation of Automatic Pedestrian SNM Monitor Performance, American Society for Testing and Materials, 1916 Race Street, Philadelphia, PA 19103 (May 1993). z. ASTM Standard C1189-91, Guide to Procedures for Calibrating Automatic Pedestrian SNM Monitor, American Society for Testing and Materials, 1916 Race Street, Philadelphia, PA 19103 (July 1991). aa. ASTM Standard C1236-93, Guide for In-Plant Performance Evaluation of Automatic Vehicle SNM Monitors, American Society for Testing and Materials, 1916 Race Street, Philadelphia, PA 19103 (June 1993). bb. ASTM Standard C1237-93, Guide to In-Plant Performance Evaluation of Hand-Held SNM Monitors, American Society for Testing and Materials, 1916 Race Street, Philadelphia, Pa 19103 (June 1993). cc. CG-SS-3, Classification Guide for Safeguards and Security Information, dated August 1994, issued by the DOE Office of Declassification, which provides original classification determinations for National Security Information concerning nuclear safeguards and security and guidance for derivatively classifying documents and materials containing such National Security Information or Restricted Data and Formerly Restricted Data. dd. Design Basis Threat for Department of Energy Programs and Facilities (U), dated 1-4-96, DOE Office of Security Affairs, which identifies and characterizes potential adversary threats to DOE’s programs and facilities that could adversely affect national security, the health and safety of employees, the public, or the environment. CANCELE D DOE M 474.1-1 v 8-11-99 ee. DOE/NRC F 741/741A, NUCLEAR MATERIAL TRANSACTION REPORT, Office of Management and Budget Control Number 1910-1800, dated October 1988, which is used for reporting values to the Nuclear Materials Management and Safeguards System for external transfers of nuclear material. ff. Guidance on Meeting DOE Order Requirements for Traceable Nondestructive Assay Measurements, DOE, Office of Safeguards and Security (May 1994). gg. DOE G 474.1-1, Guide for Implementation of DOE O 474.1, which provides guidance in the understanding of MC&A requirements contained in this Manual. hh. Guide to the Evaluation of Selected Materials Control and Accountability (MC&A) Detection Elements, DOE, Office of Safeguards and Security (May 1994). ii. Measurement Control Guide, DOE, Office of Safeguards and Security which provides guidance to assist in the implementation of measurement control requirements (March 1993). jj. Performance Assurance Program, Protection Program Supplement, DOE, Office of Safeguards and Security (November 1996).

kk. Safeguards and Security Glossary of Terms, DOE, Office of Safeguards and Security, which provides standardized definitions of terms used in the Safeguards and Security Program (12-18-95). ll. Safeguards Seal Reference Guide, DOE, Office of Safeguards and Security, which provides guidance to nuclear facility personnel in selecting, procuring, and applying the proper seals for safeguarding nuclear material (September 1993). 5. IMPLEMENTATION. This Manual will be implemented within 60 days after the effective date, or as required by contract. 6. CONTACT. Questions concerning this Manual should be directed to the Manager, Materials Control and Accountability Program (NN-512.4), at 301-903-2536. BY ORDER OF THE SECRETARY OF ENERGY: David M. Klaus Director of Management and Administration CANCELE D vi DOE M 474.1-1 8-11-99 CONTENTS CHAPTER I: PROGRAM ADMINISTRATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-1 1. GENERAL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-1 2. GRADED SAFEGUARDS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-8 3. MC&A REQUIREMENTS FOR SOURCE AND OTHER NUCLEAR MATERIALS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-10 4. LOSS DETECTION ELEMENT EVALUATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-11 5. OCCURRENCE INVESTIGATION AND REPORTING . . . . . . . . . . . . . . . . . . . . . . . . I-11 6. ADMINISTRATIVE CONTROLS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-14 CHAPTER II: MATERIALS ACCOUNTABILITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-1 1. GENERAL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-1 2. ACCOUNTING SYSTEMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-1 a. Accounting Systems Data Base and Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-1 b. Account Structure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-2 c. Records and Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-2 3. PHYSICAL INVENTORIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-3 a. Periodic Physical Inventories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-3 b. Special Inventories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-6 c. IAEA Inventories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-6 d. Inventory Verification/Confirmation Measurements . . . . . . . . . . . . . . . . . . . . . . . . . II-6 4. MEASUREMENT AND MEASUREMENT CONTROL . . . . . . . . . . . . . . . . . . . . . . . . . II-7 a. Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-8 b. Selection and Qualification of Measurement Methods . . . . . . . . . . . . . . . . . . . . . . . II-8 c. Training and Qualification of Measurement Personnel . . . . . . . . . . . . . . . . . . . . . . . II-8 d. Measurement Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-8 e. Measurement Control Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-10

5. NUCLEAR MATERIAL TRANSFERS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-12 a. External Transfers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-12 b. Internal Transfers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-16 6. MATERIAL CONTROL INDICATORS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-17 a. Shipper/Receiver Difference Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-17 b. Inventory Difference Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-19 c. Evaluation of Other Inventory Adjustments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-20 CHAPTER III: MATERIALS CONTROL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-1 1. GENERAL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-1 2. ACCESS CONTROLS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-1 a. Materials Access . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-1 b. Data Access . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-1 c. Equipment Access . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-2 CANCELE D DOE M 474.1-1 vii (and viii) 8-11-99 CONTENTS (continued) d. Other Considerations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-2 e. Unclassified Computer Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-2 3. MATERIAL SURVEILLANCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-2 a. Material Surveillance Mechanisms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-2 b. Material Surveillance Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-2 4. MATERIAL CONTAINMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-4 a. Material Access Area and Protected Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-4 b. Material Balance Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-4 c. Storage Repositories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-5 d. Processing Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-5 5. DETECTION/ASSESSMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-5 a. TIDs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-5 b. Portal Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-6 c. Waste Monitors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-6 d. Daily Administrative Checks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-7 e. Other Detection/Assessment Mechanisms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-7

CANCELE D DOE M 474.1-1 I-1 8-11-99 CHAPTER I PROGRAM ADMINISTRATION 1. GENERAL. This chapter provides minimum requirements for implementing a nuclear material control and accountability (MC&A) program. a. Special nuclear material (SNM) must not be received, processed, or stored at a facility until facility approval has been granted in accordance with the requirements of DOE O 470.1, SAFEGUARDS AND SECURITY PROGRAM. b. Facilities must control and account for nuclear materials (Table I-1) as required by this Manual and its associated Order. Field Elements must implement an MC&A program using requirements contained in this Manual as the minimum for nuclear materials. The level of control and accountability must be graded according to the economic and strategic value of these materials and the consequences of their loss. c. Each facility must designate a management official responsible for MC&A. This official must be organizationally independent from responsibility for other programs. Each facility or site that has a reporting identification symbol (RIS) must designate a Nuclear Materials Representative who will be responsible for nuclear materials reporting and data submission to the Nuclear Materials Management and Safeguards System (NMMSS). The NMMSS is used to accumulate and distribute information concerning nuclear materials transactions and inventories. The objective of the system is to report accurate and complete data as soon as possible after the events described by the data occur. The national data base must provide nuclear materials information relating to safeguards, materials management and production, inventory quantities and valuations, and other programs requested or required by DOE or the Nuclear Regulatory Commission (NRC). d. Each facility must maintain documentation that defines authorities and responsibilities for MC&A functions (e.g., accounting system, measurements, measurement control, inventories, audit, material access controls, and surveillance). Each facility must have a program to ensure that personnel performing MC&A functions are trained and qualified to perform their duties and responsibilities and are knowledgeable of requirements and procedures related to their functions. e. Each facility possessing nuclear materials must develop an MC&A Plan that specifies review frequency and change control and is approved by the cognizant CANCELE D I-2 DOE M 474.1-1 8-11-99 Table I-1. Nuclear Materials. Material Type SNM, Source, or Other Reportable Quantity* Weight Field Used for Element Weight Field Used for Isotope Material Type Code Depleted Uranium (U) source kilogram total U U-235 10 Enriched Uranium1 SNM gram total U U-235 20 Normal Uranium source kilogram total U -- 81 Uranium-233 SNM gram total U U-233 70 Plutonium-2422 (Pu) SNM gram total Pu Pu-242 40 Plutonium-239-241 SNM gram total Pu Pu-239 + Pu-241 50 Plutonium-2383 SNM tenth of a gram total Pu Pu-238 83 Americium-2414 (Am) other gram total Am Am-241 44 Americium-2434 other gram total Am Am-243 45 Berkelium (Bk) other microgram -- Bk-249 47 Californium-252 (Cf) other microgram -- Cf-252 48 Curium (Cm) other gram total Cm Cm-246 46 Deuterium5 (D) other tenth of a kilogram D2O D2 86 Lithium-6 (Li) other kilogram total Li Li-6 60 Neptunium-237 (Np) other gram total Np -- 82 Thorium (Th) source kilogram total Th -- 88 Tritium6 (H-3) other hundredth of a gram total H-3 -- 87

* Materials are reported to the nearest whole unit, except for Pu-238, deuterium, and tritium. 1 Uranium in cascades is treated as enriched uranium. Uranium in cascades should be reported as material type 89. 2 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. 3 Report as Pu-238 if the contained Pu-238 is 10 percent or greater of the total by weight plutonium; otherwise, report as Pu-239-241. 4 Americium only reportable when separated from plutonium 5 For deuterium in the form of heavy water, both the element and isotope weight fields will be used; otherwise, report isotope weight only. 6 Tritium contained in water (H2O or D2O) used as a moderator in a nuclear reactor is not an accountable material. CANCELE D DOE M 474.1-1 I-3 8-11-99 operations office manager. The MC&A Plan may, at the option of the cognizant operations office manager, be either a separate document or part of an existing document such as a site safeguards and security plan. Each facility must have and require compliance with one or more procedures for implementing its MC&A Plan. These procedures must be compatible with the physical protection and security requirements of DOE 5632.1C, PROTECTION AND CONTROL OF SAFEGUARDS AND SECURITY INTERESTS, and must be transmitted to the cognizant operations office manager when issued and when revised. f. Facility emergency plans must address conditions that indicate possible loss of control of SNM. The emergency plan must be consistent with Safeguards and Security directives and must specify MC&A measures to be taken prior to resumption of operations following emergency operations. Each facility must establish procedures for emergency conditions and periods when MC&A systems are inoperative. These procedures must ensure that access to or removal of SNM would be detected during these periods. Other requirements for facility emergency plans are specified in DOE O 151.1, COMPREHENSIVE EMERGENCY MANAGEMENT SYSTEM. g. For all facilities for which roll-up (i.e., the accumulation of smaller quantities of SNM) to a Category I quantity is credible, the safeguards and security system must provide graded protection sufficient to ensure that the failure or defeat of a single component will not increase the level of risk for the system above an acceptable level. The vulnerability assessment process must include a determination of the extent to which the failure or defeat of a single component would increase this risk and if the increase in risk is acceptable. When the increase in risk exceeds an acceptable level, compensatory measures must be taken immediately, and upgrades to the system must be initiated. The level and acceptability of the risk must be documented in the facility site safeguards and security plan. h. An MC&A program must be established for all nuclear materials on inventory under a three-letter RIS. The operations office manager or the cognizant head of a Headquarters Element may require that applicable nuclear material safeguards measures (outlined in this Manual and DOE O 474.1) be maintained and/or implemented for SNM of Attractiveness Level D or higher that has been removed from inventory as waste and for which a vulnerability resulting in an unacceptable level of risk has been identified. Materials previously removed from inventory that meet all of the following conditions are exempt from the requirements of this Manual and DOE O 474.1:

(1) They were declared waste prior to issuance of this Manual and DOE O 474.1; (2) They have been written off the MC&A records; and (3) They are under the control of a waste management organization. CANCELE D I-4 DOE M 474.1-1 8-11-99 i. To terminate safeguards for nuclear materials currently on inventory and to exempt these materials from the requirements of this Manual and DOE O 474.1, facilities must meet all of the following conditions: (1) If the material is SNM, it must meet the definition of Attractiveness Level E material. [In some cases, it may be necessary to dispose of nuclear materials of a higher attractiveness level. The appropriate head of a Headquarters Element and the Office of Safeguards and Security must concur before safeguards on materials that meet the definition of Attractiveness Level D or greater can be terminated. Additionally, a vulnerability assessment must be conducted whenever termination of safeguards on a Category II or greater quantity of SNM is being considered.] (2) The operations office manager must determine that the material is discardable in accordance with guidelines provided by the Office of Nuclear Weapons Management. (3) The material must be written off the MC&A books and removed from its nuclear processing area (or material balance area) to a storage or disposal area containing only discardable material. Table I-2 contains additional and more descriptive information on lower- grade forms of SNM that can be classified as Attractiveness Level E for purposes of determining levels of safeguards protection. In most cases, materials that meet the criteria contained in the table can be exempted from materials accountability requirements such as measurements and physical inventories, if all other conditions described in Chapter I, Paragraph 1i of this Manual are met. j. SNM generated by processing activities or operational accidents which is deemed not worthy of recovery or which is deemed not currently recoverable but does not meet the above criteria can be considered retained waste and can be subjected to reduced protection controls as defined here. Table I-3 contains criteria for retained waste, based on material descriptions, that apply to such materials when they are removed from a processing material balance area. Reduced safeguards and security program controls for the material forms and concentration ranges in Table I-3 are as follows: (1) Physical protection of retained waste must be commensurate with the safeguards category of the material defined in Table I-4. NOTE: Protection measures against other risks such as radiological sabotage and information security may still be required based on results of vulnerability or risk assessments. CANCELE D DOE M 474.1-1 I-5 8-11-99 Table I-2. Additional Attractiveness Level E Criteria for SNM. Description/Form Complies with DOE M 474.1-1, Chapter I, Paragraph 1i 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, chloride solutions contaminated/ impure oxides, metal fines and turnings, glovebox 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 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 (To Be Determined) CANCELE D I-6 DOE M 474.1-1 8-11-99 Table I-3. Technical Criteria for Retained Waste. Description and Form SNM Concentration Range (Wt %) SNM solutions and oxides >0.1 < 0.5 SNM amenable to dissolution and subsequent separation >0.2 < 1.0 SNM alloyed with aluminum, thorium, zirconium spent fuel < 1.0 SNM in organic matrixes; SNM requiring mechanical separation/disassembly and multiple recovery operations >1.0 < 5.0 SNM bound in matrix of solid, sintered, or agglomerated refractory metals >2.0 < 7.5 SNM microencapsulated in refractory compounds or in solid-dilution > 5.0 < 10.0 (2) Nuclear materials accountability information (e.g., material type, quantity, location) must remain on the site’s inventory records and within the Nuclear Materials Management and Safeguards System. (3) Measurements and physical inventory requirements for the material identified in Table I-3 can be deferred to a time when— (a) the material is removed from site or (b) the material is reintroduced into a processing material balance area. The site must provide sufficient physical control over the material to ensure that the contents of items or containers are not altered [e.g., use of tamper- indicating devices (TIDs), controls commensurate with the safeguards category level of the location, and limited personnel access]. (4) With respect to current and potential SNM-bearing inventory or byproduct material selected for International Atomic Energy Agency (IAEA) safeguards, such materials meeting the criteria contained in Table I-3 can be transferred to the retained waste category. k. A facility that has been identified for decommissioning, closure, or deactivation is not exempt from compliance with requirements stated in this Manual. CANCELE D DOE M 474.1-1 I-7 8-11-99 T ab le I -4 . G ra de d Sa fe gu ar ds . A tt ra ct iv en es s L ev el P u /U -2 33 C at eg or y (q u an ti ti es in k gs ) C on ta in ed U -2 35 C at eg or y (q u an ti ti es in k gs ) A ll E M at er ia ls C at eg or y IV I II II I IV 1 I II II I IV 1 W E A P O N S A ss em bl ed w ea po ns a nd te st de vi ce s A A ll N /A N /A N /A A ll N /A N /A N /A P U R E P R O D U C T S P it s, m aj or c om po ne nt s, b ut to n in go ts , r ec as ta bl e m et al , di re ct ly c on ve rt ib le m at er ia ls B > 2 > 0. 4< 2 > 0. 2< 0. 4 < 0. 2 > 5 > 1< 5 > 0. 4< 1 < 0. 4 H IG H -G R A D E M A T E R IA L S C ar bi de s, o xi de s, s ol ut io ns (> 25 g/ L ) ni tr at es , e tc ., fu el el em en ts a nd a ss em bl ie s, a ll oy s an d m ix tu re s, U F 4 o r U F 6 (> 50 % e nr ic

he d) C > 6 > 2< 6 > 0. 4< 2 < 0. 4 > 20 > 6< 20 > 2< 6 < 2 L O W -G R A D E M A T E R IA L S S ol ut io ns ( 1 to 2 5g /L ), p ro ce ss re si du es r eq ui ri ng e xt en si ve re pr oc es si ng , m od er at el y ir ra di at ed m at er ia l, P u- 23 8 (e xc ep t w as te ), U F 4 o r U F 6 (> 2 0% < 5 0% e nr ic he d) D N /A > 16 > 3< 16 < 3 N /A > 50 > 8< 50 < 8 A L L O T H E R M A T E R IA L S H ig hl y ir ra di at ed f or m s, so lu ti on s (< 1 g/ L ), u ra ni um co nt ai ni ng < 2 0% U -2 35 ( an y fo rm , a ny q ua nt ity ) E R ep or ta bl e Q ua nt it ie s 1 T he lo w er li m it f or C at eg or y IV is e qu al to r ep or ta bl e qu an ti ti es in th is M an ua l. CANCELE D I-8 DOE M 474.1-1 8-11-99 The facility’s MC&A program must be maintained at a level appropriate to the category and attractiveness level of the nuclear material on inventory until a termination survey determines that no nuclear material remains at the facility. Such a determination may be made if no material remains or the only remaining material is waste material that meets the definition of Attractiveness Level E and that material has been written off the MC&A books. Requirements for termination surveys are contained in DOE O 470.1. Prior to decommissioning, all nuclear material holdup (i.e., the amount of nuclear material remaining in process equipment and facilities after the in- process material stored, materials, and product have been removed) must be measured and credited to the accountability books. Until demonstrated to be otherwise, all nuclear material holdup must be considered Category I. After a facility has transferred all its nuclear material except waste to another facility, the inventory balance is zero, and the termination survey has been completed, DOE/NRC F 741, “Nuclear Material Transaction Report,” may still be needed for reporting shipment of waste to off-site waste-handling areas. In such cases, the capacity for generating DOE/NRC F 741 for these shipments must be maintained until the waste management program puts into use its own accounting system for transfers. l. Unless otherwise directed by DOE directives, procedures, techniques, and standards promulgated by the American Society for Testing and Materials (ASTM) and the American National Standards Institute (ANSI), when such documents exist, must be used to develop the basis for facility MC&A programs. Standards issued by the IAEA and the NRC can also be used when appropriate and when consistent with DOE regulatory goals. 2. GRADED SAFEGUARDS. Graded safeguards is the concept of providing the greatest relative amount of control and effort to the types and quantities of SNM that can be most effectively used in a nuclear explosive device. The following subparagraphs present basic information and requirements for graded safeguards. Additional requirements are included throughout this Manual. a. Operations offices and facilities must establish and follow a graded safeguards program for nuclear materials. Categories of nuclear material for implementation of DOE’s graded safeguards program are shown in Table I-4.

b. The material category of an SNM location (e.g., material balance area, material access area, protected area, facility) must be determined to establish the required protection level. In many cases, the material category is determined directly from Table I-4. Directions for determining the material category when multiple material types and attractiveness levels must be considered are provided in the following paragraphs. When a facility can demonstrate that the accumulation of small quantities of SNM is not credible, the summation of these quantities need not be used to define the category quantity. Determination of category involves grouping materials by SNM type, attractiveness level, and quantity. Material quantities are element weights for plutonium and U-233 and isotope weights for U-235. Procedures for determining material category are as follows: CANCELE D DOE M 474.1-1 I-9 8-11-99 (1) One SNM Type, One Attractiveness Level: Sum the material in the attractiveness level and determine the category from Table I-4. (2) One SNM Type, Multiple Attractiveness Levels (a Category III or greater quantity of B-level material included): (a) Determine the amounts of SNM for materials in each of Attractiveness Levels B, C, and D. (b) 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 I-5. (c) Sum the effective amounts in Attractiveness Levels B and C. (d) Compare the total effective amount as calculated in subparagraph (c) above to the amounts in Attractiveness Level B from Table I-4. (e) Compare the amount of Attractiveness Level D to Table I-4. (f) The material category is the highest level of material category determined in subparagraphs (a) through (d) or in subparagraph (e). (3) One SNM Type, Multiple Attractiveness Levels (less than a Category III quantity of B-level material included): (a) Determine the amounts of SNM for all attractiveness levels. (b) Compare the total amounts in each level to those in Table I-4. (c) The material category level is the highest level of the material categories determined in subparagraphs (a) and (b). Table I-5. Effective Quantities. Attractiveness Level Pu/U-233 Factor U-235 Factor B 1 1 C 1/3 1/4 (4) Multiple SNM Types: CANCELE D I-10 DOE M 474.1-1 8-11-99 (a) Determine the category for each SNM type following the above procedures. (b) The category is that determined for the individual SNM type that requires the highest level of protection. 3. MC&A REQUIREMENTS FOR SOURCE AND OTHER NUCLEAR MATERIALS. a. Except for tritium, source and other nuclear materials listed in Table I-1 are subject only to the following requirements: (1) The accounting system must document inventories and material transfers at the RIS level. (2) Reporting to NMMSS must be in accordance with DOE M 474.1-2, NUCLEAR MATERIALS MANAGEMENT AND SAFEGUARDS SYSTEM REPORTING AND DATA SUBMISSION. (3) Physical inventories must be conducted at a frequency and in a manner approved by the operations office manager and must be documented in the site MC&A Plan. (4) Minimum MC&A requirements for potential substitution materials (materials that could be substituted for strategic material during physical inventories) collocated with SNM of significant strategic value are specified in Chapter II, Paragraph 3.a(2) of this Manual. (5) The operations office manager will determine all other MC&A requirements and document them in the site MC&A Plan.

b. Tritium is a nuclear material of strategic importance; therefore, graded safeguards programs for tritium must be established and followed equivalent to the following categorizations: (1) Category III. Weapons or test components containing reportable quantities of tritium. Deuterium-tritium mixtures, or metal tritides that can be easily decomposed to tritium gas, containing greater than 50 grams of tritium (isotope) with a tritium isotopic fraction of 20 percent or greater. (2) Category IV. All other reportable quantities, isotopic fractions, types, and forms of tritium. 4. LOSS DETECTION ELEMENT EVALUATION. a. Vulnerability Assessment. Each Category I facility must develop detailed vulnerability assessments for identifying and evaluating the facility’s capability of detecting the loss of a Category I quantity of SNM. The head of the operations office MC&A organization must approve the vulnerability assessment before it is submitted as part of CANCELE D DOE M 474.1-1 I-11 8-11-99 the Site Safeguards and Security Plan. The vulnerability assessment must address the same points established for preparation of the Site Safeguards and Security Plan. Vulnerability assessments must cover the full threat spectrum specified in Office of Safeguards and Security guidance. Potential targets must include all Category I locations and any other areas for which a credible scenario for unauthorized accumulation of a Category I quantity of SNM has been identified. Vulnerability assessments must be reviewed annually and updated when system changes or new information indicate a potentially significant change in the risk of unauthorized removal of Category I quantities of SNM. Results of reviews, including changes in vulnerability assessments, must be documented in the facility Vulnerability Analysis Report. b. Performance Testing. Each facility must develop a performance testing program to support and verify vulnerability assessments. DOE O 470.1 contains requirements for the design, planning, and documentation of performance tests. MC&A performance testing programs must comply with the requirements of DOE O 470.1. (1) Performance tests must be designed to demonstrate that the system is functional and to ensure that the system performs as specified and/or required. In addition, facilities must— (a) identify those components of the MC&A system that provide the greatest effectiveness against theft and diversion; (b) design, conduct, and document tests that substantiate component effectiveness; and (c) integrate the results of these component tests into safeguards and security vulnerability assessments. (2) Performance testing must include not only those elements that can detect a threat in time to prevent it but also those elements that can effectively account for SNM to ensure that safeguards and security systems are functioning properly. (3) Performance testing program design must focus on testing individual detection elements. Elements identified in a vulnerability assessment that contribute to detection capability must be tested on a frequency based on the level-of-threat risk established by the vulnerability assessment. (4) The design of performance tests should consider prudent judgment and use of resources. (a) The scope and extent of testing should be based on the graded safeguards concept; the testing program should include more testing for higher-category facilities than for lower-category facilities. CANCELE D

I-12 DOE M 474.1-1 8-11-99 (b) The Office of Safeguards and Security’s Guide to the Evaluation of Selected Materials Control and Accountability Detection Elements provides guidance for evaluating the detection elements of the MC&A system. (5) Testing data and results must be classified in accordance with Classification Guide for Safeguards and Security Information (CG-SS-3). (6) Facilities must take corrective actions for vulnerabilities identified during system testing. c. MC&A Performance Requirements. Table I-6 contains minimum performance requirements for the following MC&A system elements: • access controls, • material surveillance, • TIDs, • portal monitoring, • accounting record system, • inventory confirmation/verification measurements, and • inventory difference control limits. The selected system elements must be validated through performance testing. Testing must be established at a frequency that, at a minimum, is in accordance with DOE O 470.1 and must be documented in the MC&A Plan. If these system elements fail to meet performance requirements, a corrective action plan must be developed and, where necessary, compensatory measures must be taken. Access control and material surveillance testing must be facility-specific; the scope and the extent of the testing must be documented by facility management and approved by the operations office manager. The accounting systems performance requirement must be verified against all items checked as part of the inventory requirements stated in Chapter II, Paragraphs 3(a) and (d).CANCELE D DOE M 474.1-1 I-13 8-11-99 Table I-6. Performance Requirements for MC&A Elements. Access Controls. Performance tests must be designed and conducted to fully evaluate the effectiveness of access controls for Category I and II quantities of SNM. In at least 95 percent of the tests conducted, the tests must demonstrate the detection of unauthorized access to Category I and II quantities of SNM. Material Surveillance. Performance tests must be designed and conducted to fully evaluate the effectiveness of material surveillance activities for Category I and II quantities of SNM. In at least 95 percent of tests conducted, the tests must demonstrate the detection of unauthorized actions related to the control of Category I and II quantities of SNM. TIDs. The TID record system must accurately reflect the location and identity of TIDs in at least 99 percent of the cases. The TID program must ensure that TIDs are properly in place in at least 95 percent of the cases. Portal Monitoring. In addition to performance testing necessary to verify that vulnerability assessment or operations office detection requirements are being met, testing of portal monitors (SNM and metal) must include all applicable tests described in ASTM guides unless otherwise directed by Office of Safeguards and Security. When standards set in applicable ASTM guides are not met, compensatory actions must be taken. Accounting Record System. The accounting record system must accurately reflect item identity and location in at least 99 percent of the cases. Inventory Confirmation/Verification Measurements. For Category I and II items, the acceptance/rejection criteria for verification measurements and, where possible, 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. Operations office manager should review and approve the control limits. When limits based on three standard deviations are unreasonably large, the operations office manager, may require tighter limits.

Inventory Difference Control Limits. Limits-of-error for inventory difference for each material balance area must not exceed 2 percent of total throughput during the inventory period, to a maximum of a Category II quantity. CANCELE D I-14 DOE M 474.1-1 8-11-99 To comply with the TID performance requirement, facilities must verify all TIDs on the items required to be checked as well as TIDs used to control access to those items. Testing to ensure that 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. [Testing for this requirement is not intended to require destruction of properly applied TIDs whose integrity has not been violated.] Additional guidance for testing metal detectors is given in Performance Assurance Program, Protection Program Supplement (Office of Safeguards and Security 1996). In the performance requirement for inventory differences, “throughput” means measured output (including waste), and “active inventory” means those materials in the material balance area that enter into the limit-of-error calculation. The operations office manager or the responsible head of a Headquarters Element may establish additional or more stringent performance requirements for system elements. Other paragraphs in this Manual contain requirements that can be readily performance tested. Testing of system elements associated with these requirements should be a regular part of the performance testing program. 5. OCCURRENCE INVESTIGATION AND REPORTING. Each facility must identify MC&A loss detection elements for each material balance area and must establish a graded program for monitoring these elements and associated data to determine the status of nuclear material inventories and to identify reportable occurrences. A reportable occurrence involving Category I, II, or III nuclear materials must be reported as an emergency, unusual occurrence, or off-normal occurrence in accordance with DOE O 232.1A, OCCURRENCE REPORTING AND PROCESSING OF OPERATIONS INFORMATION. The operations office manager will define the extent of investigation required to resolve an occurrence involving Category IV nuclear materials. Reporting and investigation under DOE O 232.1A may be required when the following events have occurred: (1) losses of Category IV nuclear materials that have been identified as credible radiological sabotage targets or (2) radiological sabotage events involving Category IV materials. In addition to the reporting required by DOE O 232.1A, the DOE facility representative must notify the head of the appropriate division within the cognizant operations office responsible for implementation of this Manual. The head of the appropriate operations office division is responsible for notifying Office of Safeguards and Security and the local office of the Federal Bureau of Investigation of reportable occurrences for which there is both indication of a loss of nuclear material and evidence of a malevolent act. In addition, the operations office must independently evaluate the significance of the occurrence. Information related to monitoring and assessment activities must be documented and retained. 6. ADMINISTRATIVE CONTROLS. Each facility possessing nuclear materials must establish a program to periodically review and assess the integrity and quality of its MC&A program and practices. The assessment program must address both normal operations and emergency conditions. The frequency and content of these assessments must be on a graded basis,

CANCELE D DOE M 474.1-1 I-15 8-11-99 consistent with requirements of DOE O 470.1, and approved by the operations office manager. The results of all assessments must be classified, if appropriate, and reported to facility management. Each noted deficiency must be addressed and corrected. The assessment must be performed by personnel who are knowledgeable in MC&A. Reviews must be conducted prior to startup of new facilities or operations and when changes occur in facilities, operation, or MC&A features that might alter the performance of the MC&A system. At a minimum, the assessment program must address the following issues: a. Identification of abnormal situations. b. Loss mechanisms, loss detection capabilities, and localization of inventory differences. c. Selection, maintenance, calibration, and testing functions to ensure proper equipment and system performance. d. 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. e. 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. f. Procedures or checks to ensure the reliability and accuracy of MC&A data and information. g. Performance testing conducted by the facility. This portion of the assessment should address the design of performance tests and the results obtained by the testing program since the last assessment. h. Procedures for emergency conditions and for periods when MC&A system components are inoperative. i. Material containment, material access, and material surveillance procedures. j. Physical inventory program and reconciliation practices. k. Accounting system procedures, capabilities, and sensitivities. l. Identification of personnel with MC&A responsibilities who should be included in the facility personnel security assurance program, consistent with DOE O 472.1B, PERSONNEL SECURITY ACTIVITIES. m. Measurement control program. n. TID programs. CANCELE D I-16 DOE M 474.1-1 8-11-99 In addition to the assessments described above, an organization independent of MC&A must conduct internal audits of the facility’s MC&A function to assess compliance with internal plans and procedures. The operations office manager must approve the frequency of these audits. CANCELE D DOE M 474.1-1 II-1 8-11-99 CHAPTER II MATERIALS ACCOUNTABILITY 1. GENERAL. This chapter describes the requirements for nuclear materials accountability. These requirements must be applied in a manner consistent with the graded safeguards concept. The chapter is divided into five functional areas: accounting systems, physical inventories, measurements and measurement control, nuclear material transfers, and material control indicators. 2. ACCOUNTING SYSTEMS. Each facility must have a system for tracking nuclear material inventories; documenting nuclear material transactions; issuing periodic reports; and assisting with the detection of unauthorized system access, data falsification, and material gains or losses. The accounting system must provide a complete audit trail for all nuclear material from receipt through disposition. Each facility must use the Generally Accepted Accounting Principles promulgated by the Financial Accounting Standards Board in the design and operation of the nuclear material accounting system, unless otherwise specified in DOE directives.

The facility nuclear materials accounting system must include checks and balances and be structured to ensure timely detection (normally within 24 hours, but in no case later than in the subsequent inventory reconciliation) of errors or discrepancies in records associated with a Category I or II quantity of SNM, including, where possible, detecting falsified data and identifying the responsible person(s). The system must also be capable of detecting omissions and other data discrepancies and ensuring completeness of accounting records. a. Accounting Systems Data Base and Procedures. Each facility must maintain procedures that describe the structure and operation of the nuclear materials accounting system. The procedures must accurately reflect current nuclear material accounting practices. Specific requirements for accounting procedures include the following: (1) Descriptions of the inventory data base (including procedures for updating and reconciling inventory data with the results of physical inventories) and the required data elements for each applicable material type. (2) Identification of the accounting reports and their frequency, distribution, and timeliness consistent with accounting requirements. (3) Identification of the organizational responsibilities for management and operation of the accounting system. (4) Recording, reporting, and submitting data to the NMMSS, by material type and reporting unit, as specified in DOE M 474.1-2. b. Account Structure. CANCELE D II-2 DOE M 474.1-1 8-11-99 (1) A facility must consist of one or more material balance areas established to identify the location and quantity of nuclear materials in the facility. Each facility must maintain readily retrievable accountability data by material balance area that reflects quantities of nuclear materials on inventory, quantities of nuclear material received and shipped, and other adjustments to inventory. (2) The material balance area account structure must sort data by material types, processes, and functions; provide the capability to localize inventory differences; and provide a system of checks and balances for verifying the accuracy of the accountability data and records. (3) A material balance area boundary must not cross a materials access area boundary. Each material balance area must consist of a single geographical area and be an integral operation. (4) Facility management must designate an individual in each material balance area to ensure that MC&A requirements are implemented in that material balance area. (5) The material balance area custodian is responsible for controlling nuclear material located in the material balance area, preparing and signing internal material transfer documents, and conducting and reconciling material balance area physical inventories. (6) A material balance area custodian must not be responsible for multiple material balance areas when transfers of nuclear material occur between those material balance areas (i.e., a single custodian must not serve as both shipper and receiver for material transfers). c. Records and Reports. (1) Each facility must maintain records, submit data, and issue reports as required by this Manual and facility procedures. The reports must accurately describe all nuclear material transactions and inventories. Inventory adjustments must be identified by material balance area and must be reported as required in this Manual.

(2) Nuclear materials records must be updated by authorized personnel only. The records system must provide an audit trail for all transactions affecting the nuclear materials data base. (3) The material balance area records system must be capable of being updated daily or on demand for all nuclear materials transactions. (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 CANCELE D DOE M 474.1-1 II-3 8-11-99 measurements.) The records system also must be capable of generating book inventory listings of all SNM within 3 hours. For all other nuclear material, the records system must be able to generate book inventories within 24 hours. The accuracy of the accounting record system must be validated according to testing methodology, testing frequency, and record maintenance requirements contained in DOE O 460.1A, PACKAGING AND TRANSPORTATION SAFETY, and applicable DOE guidance. Performance requirements for accounting record system accuracy are contained in Chapter I, Paragraph 4. 3. PHYSICAL INVENTORIES. Each facility must implement a physical inventory program for nuclear materials that complies with the following requirements. a. Periodic Physical Inventories. (1) Conduct of Physical Inventories. Inventories must be based on measured values, including measurements or technically justifiable estimates of holdup. Process monitoring techniques may be used for material that is undergoing processing and recovery operations and is inaccessible for measurements. Facilities must have documented plans and procedures that define responsibilities for performing inventories and specify criteria for conducting, verifying, and reconciling inventories of nuclear material. Facilities may use statistical sampling, based on graded safeguards, to verify the presence of items during inventories. Parameters for statistical sampling plans must be defined by the facility and approved by the cognizant operations office. Facilities must specify in their sampling plans the population, confidence level, minimum detectable defect, definition of a defect, and action to be taken if a defect is encountered. The following are minimum sampling parameters for safeguards categories: Category Confidence Level Minimum Detectable Defect I 95% 3% II 95% 5% III & IV 95% 10% The inventory population must be stratified according to item category as shown above. Separate samples must be derived for each inventory stratum. (2) Physical Inventory Frequencies. Each facility must perform physical inventories of Category I and II material balance areas that involve activities other than processing at a frequency determined by the operations office manager, but at least semiannually. Management must perform physical inventories bimonthly in Category I and II material balance areas CANCELE D II-4 DOE M 474.1-1 8-11-99 where processing occurs. In processing areas where process controls provide equivalent levels of theft and diversion detection, physical inventories may be performed upon completion of the material campaign. In such cases, the cognizant operations office must approve a processing plan prior to starting the campaign. The process plan must identify compositions and quantities of material to be processed, projected processing timetable, process control measures employed, and procedures necessary for material controls during process interruptions. Other factors to be considered for frequency determination include personnel radiation exposure, the operational mode of the facility, and credible protracted diversion scenarios.

At least annually, each facility must perform a simultaneous physical inventory of all Category I and II Material Balance Areas for which the established inventory frequency is annual or more frequent. Material Balance Areas with extended inventory frequencies of greater than one year are excluded from this requirement. For each facility, physical inventories must be performed for Category III and IV material balance areas at a frequency to be determined by the operations office manager, but at least biennially. Category IV source and other nuclear material in Category I and II material balance areas must be inventoried on a schedule defined by the operations office manager, but at least biennially, except when the source and/or other nuclear material is a credible substitution material. When substitution materials are collocated with SNM, facilities must inventory substitution materials with the same frequency as the SNM and use inventory measurement methods that can distinguish between SNM source and other nuclear material. In addition to the above requirements, inventory checks for Category IA items not in storage must be performed weekly for physical count verification and monthly for serial number verification. Inventory checks for stored Category IA items must consist of a physical count whenever the storage area is accessed and a serial number verification on a monthly basis. (3) Deviations from Inventory Frequency Requirements. Deviations from inventory frequency requirements may be approved in accordance with DOE O 470.1 and the alternative inventory control provisions in Table II-1. Facilities must determine inventory values in time to complete inventory computation and reconciliation and determine inventory differences within the DOE reporting requirements in this Manual and CANCELE D DOE M 474.1-1 II-5 8-11-99 Table II-1. Inventory Periods Based on Alternative Measures for Category I and II Storage Locations. Alternative Inventory Control Measures* Inventory Periods 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 (e.g., video/image, laser surveillance) 2 years Continuous item monitoring (e.g., monitoring of serial number, TIDs, movement) 2 years Mass (load cell) 2 years Confirmatory measurements on individual items (e.g., thermal, gamma, or neutron emission) 3 years Quantitative measurements on individual items May qualify as a continuous inventory** * Inventory periods do not determine physical inventory intervals in lieu of required physical inventory frequencies. These time periods are the basis for “credits” when multiple measures are employed for storage materials balance areas. The credits are additive as long as the alternative measures function independently. ** 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. CANCELE D II-6 DOE M 474.1-1 8-11-99

approved inventory frequencies. For Category I and II storage areas, Table II-1 may be used to determine the frequency of physical inventories based on the successful implementation of alternative inventory control measures. Time periods specified for each alternative measure are additive, so long as the measures function independently. Total credit is equal to the summation of time periods for all alternative measures employed, with a maximum allowable period of 5 years. Table II-1 is designed so that most credit is given for measures that provide material attribute information. Items added to these storage areas must have appropriately measured values. (4) The cognizant operations office manager may extend inventory periods beyond 2 years, with a maximum inventory period of 5 years, for Category III and IV storage areas that have alternative inventory control measures. (5) Physical Inventory Reconciliation Program. Each facility must implement a physical inventory reconciliation program in which the book inventory for each material balance area is compared with and, if necessary, adjusted to the physical inventory. Any inventory differences must be identified and reported as required. b. Special Inventories. At each facility, management must establish and implement procedures for conducting special inventories as a result of routine disassembly of critical assemblies, changes in custodial responsibilities, missing items, inventory differences exceeding established control limits, abnormal occurrences, or at the request of authorized facility personnel or the cognizant operations office. c. IAEA Inventories. Physical inventories performed during IAEA inspections may, with the concurrence of the operations office manager, serve in place of a scheduled physical inventory. d. Inventory Verification/Confirmation Measurements. (1) Each facility must establish and implement a system for performing measurements as part of a physical inventory. Verification measurements must be made on SNM items that are not tamper indicating. Confirmation measurements must be made on items that are tamper-indicating. Such measurements may use a statistically based sampling plan applied in a manner consistent with the graded safeguards concept. Facilities must develop sampling plans, which the cognizant operations office must approve. [NOTE: These plans must be based on the defined population and must not be a subset of sample selected for physical inventory. Separate sampling plans must be implemented for verification and confirmation measurements to ensure that a sufficient number of non-tamper-indicating items are measured.] Sampling plans must specify the population, confidence level, minimum detectable defect, definition of a defect, and CANCELE D DOE M 474.1-1 II-7 8-11-99 action to be taken if a defect is encountered. Minimum sampling parameters for safeguards categories are as follows: Category Confidence Level Minimum Detectable Defect I 95% 3% II 95% 5% III & IV 95% 10% The inventory population must be stratified according to item category as shown above. Separate samples must be derived for each stratum. Sampling plans for performing verification and confirmation measurements may supplement physical inventories that are conducted to verify the presence of 100 percent of inventory items. The operations office manager may establish a nuclear material quantity threshold for requiring inventory verification and confirmation measurements. For nuclear materials not amenable to verification measurements, confirmatory measurements of two material attributes must be substituted for the verification measurement. Nuclear materials not amenable to measurement must be identified and documented in the MC&A Plan.

(2) Each facility must establish documented acceptance or rejection criteria for inventory confirmation and verification measurements based on valid technical and statistical principles. For Category I and II items, acceptance and rejection criteria must be consistent with performance requirements for confirmation and verification measurements stated in Table I-6. Each facility must prepare and implement a response plan for evaluating and resolving all verification and confirmation measurements that fail acceptance criteria. Items that fail the confirmation or verification measurement criteria must not be processed before the discrepancy is resolved. 4. MEASUREMENT AND MEASUREMENT CONTROL. Measurement and measurement control programs must be implemented at all facilities possessing nuclear material. Measurement programs used to determine Category I or II inventories of SNM or used to determine a Category I or II SNM throughput over a 6-month period must address the topics identified in this paragraph and must be consistent with facility-specific measurement program objectives. The operations office manager must approve the scope and content of the measurement and measurement control programs used to determine Category III or IV inventories. Nuclear materials not amenable to measurement by the site must be identified in the facility’s MC&A Plan. Inventory values for these materials must be based on measured values made at other sites or technically justified estimates. Justification and supporting documentation CANCELE D II-8 DOE M 474.1-1 8-11-99 for these inventory values must be included as part of the MC&A Plan. Additional guidance on measurement control is provided in the Measurement Control Guide published by the Office of Safeguards and Security. a. Organization. The measurement and measurement control programs must be independent from operations. b. Selection and Qualification of Measurement Methods. Each facility must select, qualify, and validate measurement methods capable of providing the required levels of precision and accuracy. Facility management is responsible for selecting and qualifying a measurement method. Target values for precision and accuracy of nuclear material measurements endorsed by recognized national and international nuclear organizations must be used as goals for performance of facility measurement systems. The operations office manager must approve facility precision and accuracy requirements. Each facility must have procedures to ensure that only qualified measurement methods are used for accountability purposes. c. Training and Qualification of Measurement Personnel. Individuals responsible for performing nuclear material measurements must have sufficient knowledge to perform the measurements in an acceptable manner. (1) Training. Each facility must have a documented plan for training measurement personnel. The plan must be reviewed annually and updated as necessary to reflect changes in measurement technology and must specify training qualification and requalification requirements for each measurement method. (2) Qualification. Each facility must have a documented qualification program to ensure that measurement personnel demonstrate acceptable levels of proficiency before performing measurements and that measurement personnel are requalified according to requirements in the training plan. Measurement personnel must demonstrate proficiency in destructive analysis of nuclear material, at a minimum, once per day for each method they will use that day.

d. Measurement Systems. Nuclear material measurement systems must provide accurate nuclear material values for inventories and transactions. (1) Sampling. Sampling programs must be implemented to ensure that portions of bulk material taken for measurement are representative of the bulk material. Each facility must have a documented sampling plan for each measurement point used for accountability purposes. The plans must be based on valid technical and statistical principles and must take into account material type, measurement requirements, and any special process or operational considerations. CANCELE D DOE M 474.1-1 II-9 8-11-99 (a) The basis of the sampling plan must be documented and validated through studies of the materials or items being sampled. (b) The sampling plan must specify, at a minimum, the sampling procedure, number of samples required, size of samples, mixing time and procedure (when applicable), provisions for retaining archive samples, and estimates of variance associated with the sampling method. (c) Sampling procedures must be documented and reviewed annually or whenever changes are made to the sampling process or in material type or composition of the material being sampled. (2) Measurement Methods. Each facility must develop, document, and maintain measurement methods for all nuclear material on inventory, except those materials not amenable to measurement. These methods must be written to provide clear direction to the analyst or operator and must be validated initially and revalidated whenever changes are made. (a) In determining inventory values, and consistent with the graded safeguards concept, measurement methods must be selected in a manner that minimizes the contribution of measurement error to the uncertainty of the inventory difference. (b) Verification measurements, when used to adjust accountability records, must have accuracy and precision comparable to, or better than, the original measurement method. (c) The measurement method used for confirmatory measurements must be capable of determining the presence or absence of a specific attribute of the material, consistent with valid acceptance and rejection criteria. (d) All measurement methods must be calibrated using standard reference materials, certified reference materials, or secondary standards traceable to the national measurement base and revalidated as necessary. (e) Measurement equipment and instrumentation must meet precision and accuracy requirements under in-plant conditions. (f) Documentation of measurement data must be maintained to provide an audit trail from source data to accounting records. e. Measurement Control Programs. Each facility must develop and implement measurement control programs for all measurement systems used for accountability purposes. Measurement control programs must ensure the effectiveness of measurement systems and the quality of measured values used for accountability purposes. Measurement control programs must also produce precision and accuracy CANCELE D II-10 DOE M 474.1-1 8-11-99 values for use in determining inventory difference control limits and shipper/receiver limits of error. A measurement control program, as referred to herein, must include, at a minimum, the following elements: (1) Scales and Balances Program. All scales and balances used for accountability purposes must be maintained in good working condition, recalibrated according to an established schedule, and checked for accuracy and linearity on each day that the scale or balance is used for accountability purposes.

(2) Analytical Quality Control. Data from routine measurements must be analyzed statistically to determine and ensure accuracy and precision of the measurements. (3) Sampling Variability. The uncertainty associated with each sampling method, or combination of sampling and measurement method, must be determined and maintained on a current basis. (4) Physical Measurement Control. The precision and accuracies of volume, temperature, pressure, and density measurements must be determined and assured. (5) Instrument Calibration. Instrumentation must be calibrated using appropriate standards, when available. At a minimum, measurement values must be compared with more accurate measurement system values on a prescribed basis; the frequency is defined by demonstrated instrument performance. (6) Reference Materials (Standards). All calibration and working standards used in a measurement control program must be traceable to the national measurement base through the use of standard reference materials or certified reference materials and must have smaller uncertainties associated with their reference values than the uncertainties of the measurement method in which they are used. Working standards used in a measurement control program must be representative of the type and composition of the material being measured when the material matrix affects the measured values. For additional information see Guidance on Meeting DOE Order Requirements for Traceable Nondestructive Assay Measurements. (7) Sample Exchange Programs. Each facility’s measurement control program must include participation in appropriate interlaboratory control programs to provide independent verification of internal analytical quality control. (8) Statistical Controls. For each measurement method used for accountability purposes, control limits must be calculated and monitored, and documented procedures must exist to correct out-of-limits conditions. Control limits CANCELE D DOE M 474.1-1 II-11 8-11-99 must be established at the two-Sigma level (warning limits) and three- Sigma level (alarm limits). Control data exceeding the two-Sigma limits must be investigated, and, when warranted, timely corrective action must be taken. If a single data point exceeds the three-Sigma level, the measurement system in question must not be used for an accountability measurement until the measurement system has been demonstrated to be within statistical control. For measurement methods relying substantially on operator technique, control limits must include uncertainties for each analyst/method combination. Statistical control limits must be monitored to ensure that they are consistent with target values approved by the operations office manager. (9) Measurement Method Qualification. Each facility must have a documented method qualification program which ensures that a measurement method must demonstrate acceptable performance before being used for accountability measurements. For destructive analysis and nondestructive assay of nuclear material, this performance must be demonstrated, at a minimum, once per day that each method is used. For nondestructive analysis measurement systems for which meeting this requirement is impractical or unnecessary, the control measurement frequency must be at least one of every five measurements, unless otherwise approved by the operations office manager.

(10) Measurement Control Procedures. Each facility must develop documented measurement control procedures for all measurement methods used for accountability. Each facility must have a program to ensure that measurement control procedures are followed. (11) Statistical Programs. Each facility must have a documented program for the statistical evaluation of measurement data for determining control limits and precision and accuracy levels for each measurement system used for accountability. The program must ensure the quality of measurement and measurement control data and provide estimates of uncertainty on inventory and inventory control statements. The statistical program, at a minimum, must contain the following elements: (a) Valid statistical techniques to determine the total random error and the measurement biases generated for each measurement system or sampling/measurement system and to determine control limits, rejection limits, and outlier criteria. (b) A valid statistical technique to develop sampling plans for inventory and measurement of nuclear material. CANCELE D II-12 DOE M 474.1-1 8-11-99 (c) Analysis of measurement control data and reporting to the responsible organization at specified times and frequencies. (d) Documentation of all major assumptions made in each data evaluation process. 5. NUCLEAR MATERIAL TRANSFERS. Each facility must have a program to control and account for both internal and external facility transfers of nuclear materials. This program must include documented procedures that specify requirements for authorization, documentation, tracking, verification, and response to abnormal situations that may occur during transfer of nuclear materials. See DOE M 474.1-2 for directions on preparing and submitting DOE/NRC F 741, “Nuclear Material Transaction Report,” and DOE forms required for documenting external transfers for materials accounting purposes. a. External Transfers. (1) The shipper must obtain written verification and maintain documentation that the intended receiver is authorized to accept the material before the material is transferred. (2) Transfers of nuclear material between facilities having different RISs must be documented on DOE/NRC F 741. These forms must be prepared and distributed to the principals of the transaction and the cognizant operations office, preferably on the day of the transfer but within 24 hours or on the first workday after the transfer if it occurs on a non-workday. Operations office managers may direct DOE contractors to discontinue routine distribution of DOE/NRC F 741 to their offices. (3) Immediately after receipt, shipments must be subjected to a transfer check. Transfer checks must consist of confirmation of shipping container or item count, validation of TID integrity and identification, and comparison with shipping documentation to ensure the shipment was received intact. For purposes of transfer checks, receipt occurs when the transfer vehicle is unloaded or the transfer vehicle’s integrity is breached (TIDs removed or broken) at the receiving facility. Each facility must have documented procedures that specify actions to be taken in the event discrepancies are detected. Records of transfer checks are subject to audit and must be retained at least until the next annual DOE safeguards survey. (For accountability purposes, material in transit at the end of a reporting period must be included in the receiver’s reported inventory, even though physical receipt of the material has not yet occurred.)

(4) All unirradiated Category I and II quantities of SNM transferred between facilities that have different RISs must have independently measured values determined by the shipper and receiver, except when (1) the RISs are both located on the same site and have the same site contractor, and (2) the CANCELE D DOE M 474.1-1 II-13 8-11-99 transfer involves nuclear material items that have been produced to program specifications and are intrinsically tamper indicating. Such items, which can include but are not limited to weapons, weapon components, fuel elements, critical assemblies, and sealed sources, may be transferred shipper’s values, providing provisions in Paragraphs 5a(4)(d) and 5a(4)(e) are met. Such items must also be documented in a DOE-approved MC&A Plan. The operations office manager may require measured values for other categories of nuclear material transfers, consistent with the strategic and/or monetary value of the material, or as required for environmental, safety, and operational controls. Material received must not be put into the process until the required accountability measurements have been completed, unless a deviation is approved or the criteria defined in Paragraph 5a(4)(f) apply. When accountability measurements are required and materials are to be put in the process before the accountability measurements have been made, an agreement should be reached between the shipper and receiver as to how significant shipper/receiver differences will be handled. (a) The shipper must independently determine the measured values prior to shipment, unless the integrity of the item and of the existing measured values have been ensured. The shipper’s measured values must be documented on DOE/NRC F 741 and DOE/NRC F 741A, if applicable. (b) When required, the receiver’s accountability measurements for Category I and II quantities of SNM transfers must be accomplished in accordance with the requirements contained in Table II-2. The receiver’s accountability measurements for transfers involving other categories of nuclear material, when required by the operations office manager [see Paragraph 5a(4)], must be performed in accordance with the requirements shown in Table II-2. The operations office manager may require that precision and accuracy goals be met for measurement of shipments and receipts. If the receiver’s accountability measurements cannot be accomplished consistent with requirements in Table II-2, the confirmatory measurements outlined in Paragraph 5a(4)(e) apply. (c) For shipments of unirradiated SNM containing greater than 250 grams of a single SNM type and for each discrete item exceeding 250 grams, limits of error at the 95 percent confidence level must be assigned to their measurements by the shipper/ receiver, for both the element and isotope values. Limits of error need not be reflected on the DOE/NRC F 741 for external transfers for which accountability measurements cannot be performed [refer to Paragraph 5a(4)]. For other shipments, the shipper and receiver may estimate the limits of error. Limits of error are also required for all measurements of external transfers of tritium that exceed 2 grams, except as noted above. CANCELE D II-14 DOE M 474.1-1 8-11-99

(d) Shippers and receivers must provide a system for performing confirmatory measurements on external transfers of SNM. If accountability measurements cannot be performed within time frames specified in Table II-1, confirmatory measurements are required for all transfers of Category I and II SNM and for any other materials for which the operations office manager requires shipper/receiver accountability measurements. Documented acceptance/rejection criteria, based on valid statistical principles, must be established and used to evaluate confirmatory measurement data. A response plan for investigation and resolution of confirmatory measurements that fail acceptance criteria must be developed and implemented; all outliers must be investigated and resolved. (e) If delays in completing the receiver’s measurement will result in a protracted delay in closure of the transaction, a confirmatory measurement may be used to effect a “safeguards closure” of the transaction. The transaction is documented by an “A-S” entry on the DOE/NRC F 741 and DOE/NRC F 741A, if required. A safeguards closure may be used when the integrity of the shipment is assured and only accountability measurement differences are possible between shipper and receiver. If the receiver’s accountability measurement performed subsequent to a safeguards closure indicates a shipper/receiver difference, the difference may be resolved by mutual agreement of the managers of shipper’s and receiver’s operations offices and an adjustment (correcting entry) to the DOE/NRC F 741 and/or DOE/NRC F 741A, if required. CANCELE D DOE M 474.1-1 II-15 8-11-99 Table II-2. Shipper/Receiver Measurement Requirements. Material Category and Attractiveness Level Material1 Confirmation Accountability2 Measurements IA 3 working days Shipper’s value IB 5 working days 30 calendar days IC, II 10 working days 30 calendar days III 10 working days 120 calendar days or on input to process IV 10 working days On statistical bases within 180 days or on input to process 1 Material Confirmation. Confirmatory measurement by nondestructive analysis, gross weight check, and item count (if not done in transfer check). Confirmatory measurements are not required for all materials. When confirmatory measurements are required, they must be performed within the time frames of this table. Amounts less than 50 grams fissile may be accepted at shipper’s values. 2 Accountability Measurements. Quantitative determination of material quantities (generally within designated measurement uncertainty limits); resultant measurement values are entered into receiver’s accountability records with the exception of those materials described in Paragraph 5a(4)(d),(e), and (f). Accountability measurements are not required for all materials. When accountability measurements are required, they must be performed within the time frames of this table. Amounts less than 50 grams fissile may be accepted at shipper’s values. The safeguards closure may be applied only when all of the following conditions have been met: 1 No discrepancies are found in the verification of the piece count, identification number and integrity of the TIDs, and gross weight of the items or containers received, and there is no evidence indicating theft or diversion of the material. 2 The shipper’s and receiver’s confirmation measurements measure the same nuclear material attribute, the results of the methods can be compared on a technically valid basis, and the results of the measurements are within the established limits of agreement.

CANCELE D II-16 DOE M 474.1-1 8-11-99 3 A shipper/receiver agreement establishing the criteria for closing transactions based on confirmatory measurements, approved by both operations offices managers, is in effect for the transaction. (f) Limited processing is acceptable for materials not amenable to nondestructive assay in order to perform a receipt measurement, as approved by the managers of the shipper’s and receiver’s operations offices with Office of Safeguards and Security concurrence. Limited processing can include homogenization and dissolution. b. Internal Transfers. (1) Each facility must provide a graded system of measurements and records to reflect the flow of material between material balance areas within that facility and between it and other facilities on the same site. (2) The facility control system must be designed to monitor transfer activities and to deter and detect unauthorized removal of material during transfers. It should flag abnormal situations (e.g., inappropriate transfers of quantities or materials or unauthorized personnel receiving or shipping materials). (3) Transfers must be documented on nuclear material transfer forms, or an electronic equivalent, that contain required information, are prepared and distributed within established time frames, and are signed by authorized custodians or their alternates. (4) Materials must be subjected to a transfer check within 1 workday after receipt. These checks must include verification of shipping container or item count, TID integrity, and identification number. These transfer checks must be compared with appropriate documentation. All irradiated SNM requires only a transfer check. (5) If the isotope content of SNM (excluding uranium enriched below 20 percent U-235) transferred between material balance areas is 50 grams (fissile) or more, the transfer must be measured or the receiver must make a confirmatory measurement. Measurements are not required for transfers that— (a) consist of assembled components in which the SNM is physically inaccessible; (b) are sent to laboratories or nondestructive analysis measurement areas for analysis or examination under conditions that provide CANCELE D DOE M 474.1-1 II-17 8-11-99 adequate internal controls to maintain a continuous awareness of the location and integrity of the SNM until it is returned; (c) are tamper-safed and contain only Category III or IV quantities of nuclear material; or (d) consist entirely of small items containing less than 25 grams each and for which unauthorized accumulation of a Category III quantity of nuclear material is not credible. Measurements must be accomplished in accordance with the schedules shown in Table II-1. Materials not amenable to measurement may be subject to measurement requirements in accordance with Paragraph 5a(4)(e). (6) Each facility must establish and use document acceptance/rejection criteria to evaluate measurement data for internal material transfers. In addition, procedures must specify notification and response requirements if nuclear material removal or another abnormal situation is detected. These requirements must be consistent with those contained in DOE O 232.1A. 6. MATERIAL CONTROL INDICATORS. Each facility must implement a program to assess the material control indicators described below and ensure detection of losses and unauthorized removals of nuclear materials. Facilities also must have documented plans that specify responsibilities and procedures for evaluating material control indicators.

a. Shipper/Receiver Difference Assessment. Each facility must have written procedures for evaluating shipper/receiver differences and for investigating and reporting significant shipper/receiver differences. (1) A shipper/receiver difference is defined to be significant when it meets the following criteria: (a) It involves a discrepancy in the number of items, regardless of the quantity of nuclear material. (b) It is statistically significant. (Determination of whether shipper/ receiver difference is statistically significant is only required for those shipments for which accountability measurements are made by both the shipper and receiver.) A shipper/receiver difference is defined to be statistically significant when the magnitude of the difference exceeds either of the following: 1 The limit obtained by a statistical combination of the valid limits of error for the shipper’s and receiver’s measured values CANCELE D II-18 DOE M 474.1-1 8-11-99 or 2 The square root of two (approximately 1.4) times a single valid limit of error when either the shipper’s or receiver’s limit of error is not valid. (When both shipper’s and receiver’s limits of error are determined not to be valid, the limits of error must be recalculated and the statistical significance of the shipper/receiver difference must be reevaluated.) (2) Shipper/receiver difference data must be subjected to trend analysis to detect measurement bias or material loss. Analyses must be designed to detect statistically significant cumulative shipper/receiver differences and to trigger investigations when these differences are detected. (3) The receiver must notify its operations office and the shipper of any shipper/receiver difference determined to be significant. Both shipper and receiver must investigate their measurements and limits of error. Such investigations must be completed as required by DOE O 232.1A. All investigations must be documented. (4) Significant shipper/receiver differences involving a discrepancy in the number of items must be reported in accordance with DOE O 232.1A. (5) When shipper/receiver differences are determined to be statistically significant, but the quantities and strategic or monetary values are insufficient to warrant an investigation and subsequent correction to transfer documents, and when the receiver is DOE or one of its contractors or subcontractors, the difference need not be investigated and each party must record its own quantitative value. For the purposes of this paragraph, differences of less than 50 grams fissile or less than 5 grams of tritium are considered to be insufficient to require an investigation, unless there are special circumstances. Authority to invoke the stipulations of this paragraph must rest mutually with the managers of the shipper’s and receiver’s operations offices. (6) Statistically significant shipper/receiver differences may be resolved through any of the following methods: (a) If both the shipper’s and receiver’s operations offices obtain adequate assurance that the measurements and limits of error are valid, and the investigation indicates that theft or diversion has not occurred, each facility must record its own quantitative values. or CANCELE D DOE M 474.1-1 II-19 8-11-99 (b) If either the shipper or receiver agrees to accept the other’s value, the shipper or receiver must prepare a corrected copy of the shipping document using the other’s data. or

(c) If the investigation does not result in a satisfactory resolution, the Office of Safeguards and Security must arbitrate the matter and recommend the action to be taken. (7) The receiving facility must not process SNM contained in a shipment involving an unresolved significant shipper/receiver difference unless a shipper/receiver agreement allowing this has been approved by the managers of both the shipper’s and receiver’s operations offices. b. Inventory Difference Evaluation. (1) Each facility must have a documented 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 the operations office manager. Each facility must have procedures for establishing control limits and requiring investigation when those limits are exceeded. Limits of error for inventory difference must not exceed 2 percent of total throughput during the inventory period, to a maximum of a Category II quantity. All inventory differences that exceed control limits must be reported in accordance with DOE O 232.1A and the requirements of this Manual and DOE O 474.1. Assessments of inventory differences must include statistical tests (e.g., tests of trends and biases) and 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 material balance area. (2) Procedures for establishing control limits for inventory differences must be based on variance propagation using current data. The data should reflect operating conditions for the material balance period of the inventory. Other statistically valid techniques may be used but must be justified on the basis of factors such as limited data, low transfer rates, categories, and major process variations. The cognizant operations office manager must approve the methodology. Facilities must compare historical inventory difference data with the statistically based limits and attempt to resolve the discrepancies between the two. (3) Each facility must have documented procedures for responding to and reporting missing items and inventory differences in excess of control limits. The reporting and investigation of inventory differences must be consistent with the requirements specified in Chapter I, Paragraph 5. CANCELE D II-20 DOE M 474.1-1 8-11-99 c. Evaluation of Other Inventory Adjustments. (1) Each facility must establish a documented program for evaluating all inventory adjustments entered in the accounting records. The program must have written procedures, including equations for applying radioactive decay and fission transmutation adjustments. A program for holdup adjustments must be justified on the basis of measurements or other factors. Facilities must outline procedures for the statistical review of inventory adjustments using techniques such as tests of trends, biases, and correlation. (2) Facilities must implement procedures to ensure that all inventory adjustments are supported by measured values or other technically justifiable bases. The program must include procedures for measuring and monitoring environmental waste such as stack effluent and liquid waste streams as required by DOE 5400.1, GENERAL ENVIRONMENTAL PROTECTION PROGRAM. (3) Facilities must establish procedures for reporting reviews of inventory adjustments, including abnormal situations, to the operations office manager.

CANCELE D DOE M 474.1-1 III-1 8-11-99 CHAPTER III MATERIALS CONTROL 1. GENERAL. This chapter describes the requirements for nuclear material control, consisting of four functional areas: access controls, material surveillance, material containment, and detection/assessment. Facilities must formally document the graded nuclear materials control program in the MC&A Plan. Requirements for the control of SNM are stated in both DOE 5632.1C-1 and this Manual. Some requirements stated are in one directive, but not both. Facilities must comply with all DOE requirements, regardless of the document in which they appear. When facilities are precluded from performing physical inventories as required by this Manual, material control and protection features must be enhanced to ensure inventory integrity. 2. ACCESS CONTROLS. Each facility must have a graded program for controlling personnel access to nuclear materials; nuclear materials accountability, inventory, and measurement data; data-generating equipment, and other items/equipment where misuse could compromise the safeguards system. Facilities that have multiple Category III and IV locations containing Attractiveness Level B and C material outside a protected area must ensure that these areas do not possess a total inventory of Category II or greater quantity of SNM, unless a vulnerability assessment demonstrates that an unauthorized accumulation of a Category I quantity of material from these facilities is not credible. Facilities must incorporate personnel security assurance programs as a component in the prevention of SNM theft or diversion. Personnel security assurance programs also must be considered in assessments of vulnerabilities related to theft of Category I quantities of SNM. Facilities must test access control systems and procedures according to requirements in DOE O 470.1 and applicable DOE guidance. a. Materials Access. Each facility must have a documented program to ensure that only properly authorized personnel have access to nuclear materials. This program must address procedures and mechanisms to detect and respond to access by unauthorized personnel. To minimize the potential for unauthorized access to nuclear material, the amount of material in use must be limited to that necessary for operational requirements, and excess material must be stored in repositories or kept in enclosures designed to ensure that access will be limited to authorized individuals. See DOE 5632.1C; Table II-1; and DOE O 472.1B, Attachment 13, for additional access control and storage requirements for SNM. See DOE 5632.1C-1 for access authorization requirements for SNM categories. b. Data Access. Each facility must have a graded program to ensure that only authorized persons have the ability to enter, change, or access MC&A data and information. CANCELE D III-2 DOE M 474.1-1 8-11-99 c. Equipment Access. Each facility must have a graded program to control access to data-generating and other equipment used in material control activities. Such equipment includes measurement equipment, data-recording devices, and TIDs. d. Other Considerations. Access control programs similar to those described in Paragraphs 2b and c above must protect against data and equipment falsification or manipulation and must detect unauthorized activities during emergency or other unusual conditions.

e. Unclassified Computer Systems. Where MC&A data and data-generating equipment involve unclassified computer systems, these systems must meet the requirements of DOE 205.1, UNCLASSIFIED COMPUTER SECURITY PROGRAM. 3. MATERIAL SURVEILLANCE. Each facility must establish a graded nuclear materials surveillance program capable of detecting unauthorized activities or anomalous conditions and reporting material status. The surveillance program must address both normal and emergency conditions and must provide for periodic testing. Facilities must plan and document testing for material surveillance systems and procedures in accordance with DOE O 470.1. a. Material Surveillance Mechanisms. Specific material surveillance methodologies used must consist of either automated means (e.g., monitoring devices, sensors, or other instrumentation) or visual surveillance/direct observation (e.g., two-person rule, monitoring by external personnel). Visual surveillance procedures must ensure that activities are observable and that observers will recognize, correctly assess, and report activities that are unauthorized or inconsistent with established safeguards requirements. Procedures for implementing the two-person rule must be documented. Where available, process logs, inventory records, or other information must be used to detect anomalies and trigger investigatory actions. b. Material Surveillance Programs. Surveillance procedures must describe the methodologies and operational/control points on which the program is based and must provide for investigation, notification, and reporting of anomalies. (1) Category I and II. Material surveillance programs for Category I and II quantities of SNM must ensure that materials are in authorized locations and detect unauthorized material flows and transfers. Category I locations must be evaluated to determine the ability of the system to assess material losses from material access area and protected area boundaries. Category II locations must be evaluated to determine the ability of the system to assess material losses from the protected area boundary. CANCELE D DOE M 474.1-1 III-3 8-11-99 Material surveillance programs for all areas having Category I or II quantities of SNM must include the following: (a) Only appropriately authorized and knowledgeable personnel (i.e., individuals who are capable of detecting incorrect or unauthorized actions) must be assigned responsibility for surveillance of SNM. (b) Controls must be sufficient to ensure that one individual cannot gain access to a secure storage area. (c) Procedures to ensure constant surveillance of all persons in secure storage areas (e.g., two-person rule or equivalent surveillance procedures) must be in effect at any time the storage area is not locked and protected by an active alarm system. (d) Surveillance must be sufficient to ensure that unauthorized or unaccompanied authorized personnel cannot enter the storage area undetected when the door is unlocked or open. (e) When two persons are assigned responsibility for maintaining direct control of the item(s) outside an alarmed storage area within a materials access area or protected area, either the two authorized persons must be physically located such that they have an unobstructed view of the item(s) and can positively detect unauthorized or incorrect procedures, or there must be a system of hardware, procedures, and administrative controls sufficient to ensure no unauthorized accumulation of a Category I quantity without timely detection.

(f) SNM in use or process must be under material surveillance procedures, under alarm protection, or (with the approval of responsible heads of Field Elements) protected by alternative means which can be demonstrated to provide equivalent protection. (2) Category III. The material surveillance program for Category III quantities must ensure that when materials are not in locked storage, they are attended, are in authorized locations, and are not accessed by unauthorized persons. (3) Category IV. The material surveillance program for Category IV quantities must be site-specific and approved by the operations office manager. 4. MATERIAL CONTAINMENT. Each facility must have a documented program to provide controls for nuclear materials operations relative to materials access areas, protected areas, material balance areas, other authorized storage repositories, and processing areas. CANCELE D III-4 DOE M 474.1-1 8-11-99 a. Material Access Area and Protected Area. The facility must have controls to ensure that Category I quantities of SNM are used, processed, or stored only within a material access area contained in a protected area and that Category II quantities of SNM are used, processed, or stored only within a protected area. The containment program must— (1) identify authorized activities and locations for nuclear materials; (2) identify mechanisms used to detect unauthorized activities; (3) identify material types, forms, and amounts authorized to be removed from the materials access area or protected area; (4) identify containment controls for normal and emergency conditions; and (5) require a periodic audit of the containment program to ensure compliance and system effectiveness. b. Material Balance Area. Each facility must have controls to ensure that nuclear materials used, processed, or stored within a material balance area are controlled in accordance with the graded safeguards concept. Additionally, these controls must ensure that materials are removed only through authorized pathways/portals and are subject to transfer and verification procedures identified in Chapter II, Paragraph 5. Controls for material balance areas must— (1) be formally documented; (2) identify geographical boundaries and functions of the material balance areas; (3) identify material types, forms, and quantities permitted in each material balance area; (4) describe the administrative controls for each material balance area; (5) define custodial responsibilities for nuclear materials contained within a material balance area; (6) identify personnel authorized to receive or ship nuclear material; (7) identify the material flows into and out of the material balance area; (8) ensure that material transfer procedures are followed; and CANCELE D DOE M 474.1-1 III-5 8-11-99 (9) ensure that material quantities transferred across material balance area boundaries are based on measured values consistent with Chapter II, Paragraph 5b(5). c. Storage Repositories. Requirements for controls on storage repositories are in DOE 5632.1C-1. d. Processing Areas. The facility must have controls for nuclear materials being used or stored in processing areas. The controls for in-process areas must— (1) describe activities and locations for storing material; (2) identify components used to detect unauthorized activities or conditions; (3) include procedures for moving material into or out of the processing area;

(4) describe control procedures for both normal and emergency conditions; (5) describe response actions to be taken in abnormal situations; and (6) provide for audit of the processing controls on a periodic basis to ensure system effectiveness. 5. DETECTION/ASSESSMENT. Each facility must have the capability to detect and assess the unauthorized removal of nuclear materials, consistent with the graded safeguards concept. The system must be interfaced with the facility’s physical protection and other organizational systems, as appropriate, and must be able to detect removal of SNM from its authorized location (theft/diversion/errors) and notify the protective force and other organizations to respond when such events are detected. a. TIDs. Each facility must have a documented program, administered by the MC&A organization, to control TIDs and ensure that TIDs are used to the extent possible to detect violations of container integrity. Testing of TID integrity, location, and application and the TID record system must be conducted according to requirements contained in DOE O 470.1 and other applicable DOE directives and guidance. The TID control program must specify, as a minimum, the following elements: (1) acquisition/procurement/destruction; (2) types of TIDs used; (3) assurance of unique TID identification; (4) storage; (5) issuance; (6) personnel authorized to apply, remove, and dispose of TIDs; (7) containers on which TIDs are to be applied; (8) procedures for application of TIDs; CANCELE D III-6 DOE M 474.1-1 8-11-99 (9) frequency and method of TIDs verification; (10) response procedures for TIDs violations; (11) assurance that TIDs cannot be reused after violation; (12) frequency and method of internal program audits; (13) procedures for reporting TID violations; and (14) Field Element approved listing of all containers considered to be intrinsically tamper indicating. b. Portal Monitoring. The minimum portal monitoring requirements are in DOE 5632.1C- 1. In addition to those requirements, the detection level of the monitors must be based upon detection of the typical SNM product in the area and the credible number of removals associated with theft of a Category I quantity of material. All detectors and related calibration standards must be maintained and controlled to ensure that portal monitors are capable of meeting detection requirements. Periodic performance testing of portal monitors must be conducted in accordance with Chapter I, Paragraph 4b. Planning and documentation of performance testing must meet the requirements of DOE O 470.1, Chapter II. Performance requirements for portal monitors (both SNM and metal) are contained in Chapter I, Paragraph 4b. Controls must be established to prevent unauthorized access to portal monitor instrumentation and cabling. A written response plan must be prepared and implemented to provide evaluation and resolution of all alarm conditions, including requirements for notification in accordance with DOE O 232.1A (and the requirements contained in Chapter I, Paragraph 5,) in the event of unresolved alarms or malevolent actions. Controls must be established to ensure detection capabilities during emergency conditions. c. Waste Monitors.

(1) All liquid, solid, and gaseous waste streams leaving a materials access area must be monitored to detect the theft or diversion of SNM. Facility waste- monitoring equipment must be maintained and controlled to ensure that the equipment is capable of detecting specified amounts of SNM. Instrumentation used to monitor waste and equipment removed from a materials access area must be 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. (2) Each facility must establish and implement a response plan for evaluating and resolving situations involving any discharge exceeding facility-specific limits. The plan, which must be approved by the operations office manager, must include procedures for reporting in accordance with DOE O 232.1A and the requirements contained in Chapter I, Paragraph 5 of this Manual, if the situation is not satisfactorily resolved or if there is an indication of malevolent action. CANCELE D DOE M 474.1-1 III-7 (and III-8) 8-11-99 d. Daily Administrative Checks. A facility-specific daily administrative checks program must be implemented for each Category I material balance area (or multiple material balance areas where roll-up to a Category I quantity of SNM is credible). The operations office must determine and approve the scope and extent of the checks on the basis of recognized vulnerabilities. The administrative checks program must specify the detection objectives, performance procedures, documentation requirements, and response actions. e. Other Detection/Assessment Mechanisms. Each facility must establish systems capable of detecting and/or assessing SNM removals consistent with the loss detection elements evaluation requirements of this Manual. These monitoring and control systems must provide sufficient information to correctly assess the alarm, localize the removal, and estimate the quantity and form of the diverted or stolen material. CANCELE D DOE M 474.1-1 Attachment 1 8-11-99 Page 1-1 (and 1-2) CONTRACTOR REQUIREMENTS DOCUMENT MANUAL FOR CONTROL AND ACCOUNTABILITY OF NUCLEAR MATERIALS Contractors must comply with DOE M 474.1-1, MANUAL FOR CONTROL AND ACCOUNTABILITY OF NUCLEAR MATERIALS, as required by contract. CANCELE D DOE M 474.1-1 (Cover) Purpose, Applicability, Definitions, References Contents Chapter I (Program Administration) Chapter II (Materials Accountability) Chapter III (Materials Control) Contractor Requirements Document Print: