INDEX
CHAPTER I
BASIC REQUIREMENTS
1. GENERAL. This chapter provides minimum requirements for the control and
accountability of nuclear materials.
a. Special nuclear material shall not be received, processed, or
stored at a facility until facility approval has been granted in
accordance with the requirements of DOE 5634.1B, FACILITY APPROVAL,
SECURITY SURVEYS, AND NUCLEAR MATERIALS SURVEYS.
b. Nuclear materials (Figure I-1) shall be controlled and accounted
for as required by this Order. A graded material control and
accountability program shall be implemented by Managers, Operations
Offices, using requirements for Category IV as the minimum for
nuclear materials. See page I-9, paragraph 3c, for requirements
for depleted uranium. The level of control and accountability
shall be consistent with the economic and strategic value of these
materials. Figure I-1 provides a list of nuclear materials and
reportable quantities. Page I-6, paragraph 2b defines
categorization of nuclear materials for implementation of DOE's
graded safeguards program. Detailed information on reporting
requirements for materials accounting data and information can be
found on page II-19, paragraph 7.
c. A management official responsible for the control and
accountability of nuclear materials shall be designated for each
facility. This official shall be organizationally independent from
responsibility for other programs. A Nuclear Materials
Representative responsible for nuclear materials reporting and data
submission to the Nuclear Materials Management and Safeguards
System shall be designated for each facility or site having a
Reporting Identification Symbol.
d. For each facility, facility management shall maintain documentation
defining authorities and responsibilities for materials control and
accountability functions (e.g., accounting system, measurements,
measurement control, inventories, audit, material access controls,
and surveillance). For each facility, there shall be a program to
assure that personnel performing materials control and
accountability functions are trained and qualified to perform their
duties and responsibilities, and are knowledgeable of requirements
and procedures related to their functions.
e. A Materials Control and Accountability Plan shall be developed for
each facility possessing nuclear materials (including facility
review and frequency and change control), and approved by the
cognizant Manager, Operations Office. The Materials Control and
Accountability Plan may, at the option of the cognizant Manager,
Operations Office, be a separate document or a part of an existing
document such as a Site Safeguards and Security Plan.
============================================================================
| MATERIAL | SNM, | REPORTABLE | WEIGHT FIELDS USED |MATERIAL|
| TYPE | SOURCE,| QUANTITY* | FOR REPORTING | TYPE |
| | OR OTHER| | ELEMENT ISOTOPE | CODE |
|------------------|---------|---------------|--------------------|--------|
| Depleted Uranium | SOURCE | Kilogram | Total U | U-235 | 10 |
|------------------|---------|---------------|----------|---------|--------|
|Enriched Uranium/1| SNM | Gram | Total U | U-235 | 20 |
|------------------|---------|---------------|----------|---------|--------|
| Normal Uranium | SOURCE | Kilogram | Total U | - | 81 |
|------------------|---------|---------------|----------|---------|--------|
| Uranium-233 | SNM | Gram | Total U | U-233 | 70 |
|------------------|---------|---------------|----------|---------|--------|
| Plutonium-242/2 | SNM | Gram | Total Pu | Pu-242 | 40 |
|------------------|---------|---------------|----------|---------|--------|
| Plutonium-239- | SNM | Gram | Total Pu | Pu-239+ | 50 |
| 241 | | | | Pu-241 | |
|------------------|---------|---------------|----------|---------|--------|
| Plutonium-238/3 | SNM |Tenth of a Gram| Total Pu | Pu-238 | 83 |
|------------------|---------|---------------|----------|---------|--------|
| Americium-241 | OTHER | Gram | Total Am | Am-241 | 44 |
|------------------|---------|---------------|----------|---------|--------|
| Americium-243 | OTHER | Gram | Total Am | Am-243 | 45 |
|------------------|---------|---------------|----------|---------|--------|
| Berkelium | OTHER | Microgram | - | Bk-249 | 47 |
|------------------|---------|---------------|----------|---------|--------|
| Californium-252 | OTHER | Microgram | - | Cf-242 | 48 |
|------------------|---------|---------------|----------|---------|--------|
| Curium | OTHER | Gram | Total Cm | Cm-246 | 46 |
|------------------|---------|---------------|----------|---------|--------|
| Deuterium | OTHER | Tenth of a | D2O | D2 | 86 |
| | | Kilogram | | | |
|------------------|---------|---------------|----------|---------|--------|
| Lithium-6 | OTHER | Kilogram | Total Li | Li-6 | 60 |
|------------------|---------|---------------|----------|---------|--------|
| Neptunium-237 | OTHER | Gram | Total Np | - | 82 |
|------------------|---------|---------------|----------|---------|--------|
| Thorium | SOURCE | Kilogram | Total Th | - | 88 |
|------------------|---------|---------------|----------|---------|--------|
| Tritium/4 | OTHER | Hundredth of | Total/3H | - | 87 |
| | | a Gram | | | |
|==================|=========|===============|==========|=========|========|
Figure I-1
Nuclear Materials
* For reporting purposes: materials are reported to the nearest whole
unit except for plutonium-238, deuterium, and tritium.
/1 Uranium in cascades is treated as enriched uranium. For reporting
purposes uranium in cascades should be reported as material type 89.
/2 Report as plutonium-242 if the contained Pu-242 is 20% or greater of
total plutonium by weight; otherwise report as plutonium 239-241.
/3 Report as plutonium-238 if the contained Pu-238 is 10% or greater of the
total by weight plutonium; otherwise report as plutonium 239-241.
/4 Tritium contained in water (H2O or D2O) used as a moderator in a nuclear
reactor is not an accountable material. For reporting purposes: if in
the form of heavy water, both the element and isotope weight fields will
be used; otherwise report isotope weight only.
(1) Category I and II. For facilities possessing Category I and
II quantities of special nuclear material, the plan shall
reflect requirements for materials control and accountability
program planning and management, threat considerations,
performance criteria, the accounting system, physical
inventories, measurement control, control limits, loss
detection elements, training, response to nuclear material
alarms, access control, anomaly resolution, containment, and
surveillance.
(2) Category III and IV. For Category III and IV facilities,
requirements for the scope and content of Materials Control
and Accountability Plans are to be determined by the Manager,
Operations Office.
f. Planning for materials control and accountability shall consider
the potential of an insider threat, as detailed in "DESIGN BASIS
THREAT POLICY FOR THE DEPARTMENT OF ENERGY (DOE) PROGRAMS AND
FACILITIES (U)", issued by the Office of Security Affairs.
Planning shall address the theft and diversion of special nuclear
material, and the unauthorized control of a weapon, test device, or
improvise nuclear device, where appropriate. The materials control
and accountability program shall support activities to mitigate
sabotage.
g. For each facility, facility management shall have and require
compliance with one or more current procedural directive(s) for
implementing its Materials Control and Accountability Plan. These
procedures shall be compatible with the physical protection and
security requirements of DOE 5632.1C, PROTECTION AND CONTROL OF
SAFEGUARDS AND SECURITY INTERESTS, to provide an effective
integrated safeguards system. These procedural directives shall be
transmitted to the cognizant Manager, Operations Office, when
issued and when revised.
h. Reportable occurrences shall be reported in accordance with the
notification and reporting requirements contained in DOE 5000.3B,
OCCURRENCE REPORTING AND PROCESSING OF OPERATIONS INFORMATION.
i. Facility emergency plans shall address conditions that indicate
possible loss of control of special nuclear material. The
emergency plan shall be consistent with safeguards and security
directives, and shall specify materials control and accountability
measures to be taken prior to resumption of operations following
emergency operations. Other requirements for facility emergency
plans are specified in DOE 5500.1B, EMERGENCY MANAGEMENT SYSTEM.
j. For Category I facilities and for Category II facilities within the
same Protected Area for which rollup to a Category I quantity is
possible, each facility's safeguards and security system shall
provide defense-in-depth to assure that the failure or defeat of a
single component will not increase the level of risk for the system
above an acceptable level. A part of the vulnerability assessment
process shall be to determine the extent to which the failure or
defeat of a single component increases this risk and if the
increase in risk is acceptable. When the increase in risk exceeds
an acceptable level, compensatory measures shall be immediately
taken and upgrades to the system shall be initiated. The
acceptability of the risk shall be documented as a part of the
Master Safeguards and Security Agreement or Site Safeguards and
Security Plan for the facility.
k. For each facility a materials control and accountability program
shall be established for all nuclear materials on inventory under a
three letter Reporting Identification Symbol, including those
designated as uneconomical to recover. For Attractiveness Level D
or higher special nuclear material that has been removed from
inventory as waste and for which a vulnerability resulting in an
unacceptable level of risk has been identified, the Manager,
Operations Office, or the cognizant Head of a Headquarters Element
may require that applicable nuclear material safeguards measures as
outlined in this Order be maintained and/or implemented.
Otherwise, materials previously removed from inventory that meet
all of the following conditions are exempt from the requirements of
this Order:
(1) They have been declared as waste prior to issuance of this
Order;
(2) They have been written off the materials control and
accountability records; and
(3) They are under the control of a waste management organization.
l. To terminate safeguards for nuclear materials currently on
inventory and to exempt that material from the requirements of this
Order, all of the following conditions must be met:
(1) If the material is special nuclear material, it must meet the
definition of Attractiveness Level E material. (In some
cases, it may be necessary to dispose of higher attractiveness
level materials. Concurrence of both the appropriate Head of
a Headquarters Element and Office of Safeguards and Security
is required for termination of safeguards on materials which
meet the definition of Attractiveness Level D or greater.
Additionally, whenever termination of safeguards on a Category
II or greater quantity of special nuclear material is being
considered, a vulnerability assessment must be conducted.)
(2) The material must be determined to be discardable by the
Manager, Operations Office in accordance with guidelines
provided by the Office of Nuclear Weapons Management, the
Departmental nuclear materials managers.
(3) The material must be written off the materials control and
accountability books and removed from its nuclear processing
area (or material balance area) to a storage or disposal area
containing only discardable material.
m. Identification of a facility for decommissioning, closure, or
deactivation shall not exempt the facility from compliance with
requirements stated in this Order. The facility's materials
control and accountability program shall be maintained at a level
appropriate to the category and attractiveness level of the nuclear
material on inventory until a termination survey determines that
there is no nuclear material remaining at the facility. Such a
determination may be made if there is no material or the only
material is waste material that meets the definition of
Attractiveness Level E and that material has been written off the
materials control and accountability books. Requirements for
termination surveys are contained in DOE 5634.1B. 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
offsite waste-handling areas. In such cases, the capacity shall be
maintained for generating DOE/NRC F 741 for these shipments until
the waste management program puts into use its own accounting
system for transfers.
n. A vulnerability assessment shall be performed for each facility to
evaluate the potential for unauthorized accumulation of a Category
I quantity of special nuclear material from multiple locations
within the same Protected Area through either a single occurrence
or protracted diversion. The vulnerability assessment shall
include consideration of the attractiveness level of the material
and the credibility of the removal scenarios. For protracted
diversion, the vulnerability assessment shall also include
consideration of the number of removal events and the total elapsed
time required to accumulate the target quantity during the
inventory period. Credible accumulation scenarios shall be
documented in DOE-approved Site Safeguards and Security Plans.
o. Procedures, techniques, and standards as promulgated by the
American Society for Testing and Materials (ASTM) and the American
National Standards Institute (ANSI) shall be used, when such
standards exist, in developing the basis for nuclear material
control, measurements and measurement control, accounting, and
statistical methods that are employed by a facility for
safeguarding of nuclear material, unless otherwise directed by DOE
directives. Standards issued by the International Atomic Energy
Agency and the Nuclear Regulatory Commission should also be used
when appropriate and when consistent with DOE regulatory goals.
p. Materials control and accountability requirements contained in this
Order shall apply to all DOE facilities, including new and
renovated DOE nuclear facilities. The planning, design,
construction, and operation of new or renovated facilities should
incorporate the latest materials control and accountability
technologies, systems, and approaches. Using modern techniques and
equipment to maximize material loss detection sensitivity and to
increase the quality of accountability measurements will reduce the
magnitude of inventory difference control limits calculated as a
part of inventory difference evaluations and will increase the
quality of other analyses. Performance requirements for inventory
difference control limits for such facilities are contained on page
I-10, paragraph 4.
q. The "Guide for Implementation of DOE 5633.3A" shall be considered
in developing materials control and accountability programs. This
guide does not establish or originate policy. Instead, it
describes methods for meeting requirements of this Order.
r. Nuclear materials designated as radioactive waste are subject to
the requirements of this Order unless exempted from its
requirements by paragraphs 1k or l above. In addition to
requirements of this Order, the handling, disposal, and management
of nuclear materials designated as radioactive waste must be in
compliance with DOE environmental and waste management regulations
including DOE 5820.2A, RADIOACTIVE WASTE MANAGEMENT.
2. GRADED SAFEGUARDS. The following presents basic information and
requirements for graded safeguards. Additional requirements will be
found throughout this Order.
a. Operations Offices and facilities shall establish and follow a
graded safeguards program for nuclear materials. Graded safeguards
is the concept of providing the greatest relative amount of control
and effort to the types and quantities of special nuclear material
that can be most effectively used in a nuclear explosive device.
Categories of nuclear material for implementation of DOE's graded
safeguards program are shown in Figure I-2. The "Guide for
Implementation of DOE 5633.3A" contains more descriptive guidance
for material attractiveness and examples of category determination.
b. Determination of material category for a special nuclear material
location (Materials Balance Area, Material Access Area, Protected
Area, facility, etc.) is required for a variety of safeguards and
security purposes. In many cases, the material category is
determined directly from Figure I-2. In cases where the material
category determination requires consideration of multiple material
types and attractiveness, directions for determining the material
category are given in the following subparagraphs. When a facility
can demonstrate that the accumulation of smaller quantities of
special nuclear material from within a Materials Balance Area is
not credible, the summation of these quantities need not be used to
define the category quantity. Determination of category involves
grouping materials by special nuclear material 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:
(1) One Special Nuclear Material Type, One Attractiveness Level:
Sum the material in the attractiveness level and determine the
category from Figure I-2.
(2) One Special Nuclear Material Type, Multiple Attractiveness
Levels, a Category III or greater quantity of B level material
included:
(a) Determine the amounts of special nuclear material for
materials in each of Attractiveness Levels B, C, and D.
FIGURE I-2
Nuclear Material Safeguards Categories
==================================================================
| | | | OTHER |
|Attrac| PUB/U-233 | CONTAINED U-235 |NUCLEAR|
|-tive-| Category | Category | MATE- |
|ness | (QUANTITIES IN KGS) | (QUANTITIES IN KGS) | RIAL |
|Level |------------------------|------------------------|-------|
| | I | II | III | IV/1| I | II | III | IV/1| IV/2 |
==========|======|======|=====|=====|=====|======|=====|=====|=====|=======|
|WEAPONS | | | | | | | | | | |
|Assembled| | All | | | | All | | | | |
|weapons | A | Quan-| N/A | N/A | N/A | Quan-| N/A | N/A | N/A | N/A |
|and test | |tities| | | |tities| | | | |
|devices | | | | | | | | | | |
|---------|------|------|-----|-----|-----|------|-----|-----|-----|-------|
|PURE | | | | | | | | | | |
|PRODUCTS | | | | | | | | | | |
|Pits, | | | | | | | | | | |
|major com| B | >/=2 | >or=| >or=| <0.2| >or=5| >or=| >or=| <0.4| N/A |
|-ponents,| | |0.4<2| 0.2<| | | 1<5 |0.4<1| | |
|buttons, | | | | 0.4 | | | | | | |
|ingots, | | | | | | | | | | |
|recast- | | | | | | | | | | |
|able | | | | | | | | | | |
|metal, | | | | | | | | | | |
|directly | | | | | | | | | | |
|conver- | | | | | | | | | | |
|tible | | | | | | | | | | |
|materials| | | | | | | | | | |
|---------|------|------|-----|-----|-----|------|-----|-----|-----|-------|
|HIGH- | | | | | | | | | | |
|GRADE | | | | | | | | | | |
|MATERIAL | | | | | | | | | | |
|Carbides,| | | | | | | | | | |
|oxides | C | >/=6 | >or=| >or=| <0.4|>or=20| >or=| >or=| <2 | N/A |
|solutions| | | 2<6 |0.4<2| | | 6<20| 2<6 | | |
|(>or=25 | | | | | | | | | | |
|g/l) | | | | | | | | | | |
|nitrates,| | | | | | | | | | |
|etc., | | | | | | | | | | |
|fuel, | | | | | | | | | | |
|elements | | | | | | | | | | |
|and as- | | | | | | | | | | |
|semblies,| | | | | | | | | | |
|alloys | | | | | | | | | | |
|and | | | | | | | | | | |
|mixtures,| | | | | | | | | | |
|UF4 or | | | | | | | | | | |
|UF6 (>or=| | | | | | | | | | |
|50% | | | | | | | | | | |
|U-235) | | | | | | | | | | |
|---------|------|------|-----|-----|-----|------|-----|-----|-----|-------|
|LOW-GRADE| | | | | | | | | | |
|MATERIAL | | | | | | | | | | |
|Solutions| | | | | | | | | | |
|(1-25g/l)| D | N/A | >or=| >or=| <3 | N/A | >or=| >or=| <8 | N/A |
|process | | | 16 | 3<16| | | 50 | 8<50| | |
|residues | | | | | | | | | | |
|requiring| | | | | | | | | | |
|extensive| | | | | | | | | | |
|reproces-| | | | | | | | | | |
|sing, mod| | | | | | | | | | |
|-erately | | | | | | | | | | |
|irradi- | | | | | | | | | | |
|ated | | | | | | | | | | |
|material,| | | | | | | | | | |
|Pu-238 | | | | | | | | | | |
|(except | | | | | | | | | | |
|waste), | | | | | | | | | | |
|UF4 or | | | | | | | | | | |
|UF6 (>or=| | | | | | | | | | |
|20%<50% | | | | | | | | | | |
|U-235) | | | | | | | | | | |
|---------|------|------|-----|-----|-----|------|-----|-----|-----|-------|
|ALL OTHER| | | | | | | | | | |
|MATERIALS| | | | | | | | | | |
|Highly | | | | | | | | | | |
|irradiat-| E | N/A | N/A | N/A |Re- | N/A | N/A | N/A |Re- |Report-|
|ed forms,| | | | |port-| | | |port-|able |
|solutions| | | | |able | | | |able |Quanti-|
|(>or= 1 | | | | |Quan-| | | |Quan-|ties |
|g/l), | | | | |ti- | | | |ti- | |
|uranium | | | | |ties | | | |ties | |
|contain- | | | | | | | | | | |
|ing <20% | | | | | | | | | | |
|U-235 | | | | | | | | | | |
|(any form| | | | | | | | | | |
|or | | | | | | | | | | |
|quantity)| | | | | | | | | | |
|=========|======|======|=====|=====|=====|======|=====|=====|=====|=======|
/1 The lower limit for category IV is equal to reportable quantities in
this Order.
/2 See paragraphs 3b and 3c for MC&A requirements for tritium and depleted
uranium.
(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 Figure I-3.
(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 Figure I-2.
(e) Compare the amount of Attractiveness Level D to Figure
I-2.
(f) The material category is the highest level of material
category determined in subparagraphs (a) through (d) or
in subparagraph (e).
===================================================
| Attractiveness | Pu/U-233 Factor | U-235 Factor |
| Level | | |
|-----------------|-----------------|--------------|
| B | 1 | 1 |
|-----------------|-----------------|--------------|
| C | 1/3 | 1/4 |
|=================|=================|==============|
Figure I-3
Effective Quantities
(3) One Special Nuclear Material Type, Multiple Attractiveness
Levels, less than a Category III quantity of B level material
included:
(a) Determine the amounts of special nuclear material for all
attractiveness levels.
(b) Compare the total amounts in each level to the amounts in
Figure I-2.
(c) The material category level is the highest level of the
material categories determined in subparagraphs (a) and
(b).
(4) Multiple Special Nuclear Material Types:
(a) Determine the category for each special nuclear material
type following the above procedures.
(b) The category is that determined for the individual
special nuclear material type that requires the highest
level of protection.
3. MATERIALS CONTROL AND ACCOUNTABILITY REQUIREMENTS FOR SOURCE AND OTHER
NUCLEAR MATERIALS.
a. Except for tritium and depleted uranium, source and other nuclear
materials shall be treated as Attractiveness Level E materials.
Therefore, the requirements for a Materials Balance Area containing
only source and other nuclear materials shall be that of Category
IV. When source and other nuclear materials are present in
Materials Balance Areas containing special nuclear material, only
the special nuclear material is used to determine the category of
the Materials Balance Area. However, source and other materials
are subject to Category IV requirements.
b. Tritium is a nuclear material of strategic importance; therefore,
graded safeguards programs for tritium shall 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.
c. Depleted uranium is a material of limited strategic and monetary
value, therefore, the requirements of this Order do not apply to
depleted uranium except as follows:
(1) For Materials Balance Areas containing more than 10 metric
tons of depleted uranium or having transactions of depleted
uranium totaling more than 10 metric tons per year, the
depleted uranium shall be treated as Category IV,
Attractiveness Level E, material.
(2) For reporting identification symbols containing more than 10
metric tons of depleted uranium or having transactions of
depleted uranium totaling more than 10 metric tons per year,
documentation and reporting of depleted uranium transactions
and inventories shall be in accordance with page II-19,
paragraph 7.
(3) For depleted uranium not required to be handled as Category
IV, Attractiveness Level E, material, the following minimum
requirements apply:
(a) Procedures shall be developed and implemented to detect
unauthorized internal transfers of depleted uranium.
(b) An accounting system shall be maintained that describes
depleted uranium transactions and inventories.
(c) For external transfers, the shipper shall obtain written
verification and maintain documentation that the intended
receiver is authorized to accept the material before the
material is transferred.
(4) Facilities selected under DOE 1270.2B, SAFEGUARDS AGREEMENT
WITH THE INTERNATIONAL ATOMIC ENERGY AGENCY, are required to
meet requirements for depleted uranium defined in the Facility
Attachment document. Additionally, transfers of depleted
uranium involving either (a) exports or imports of depleted
uranium or (b) movements of depleted uranium within the U.S.
in which any part of the country control code represents a
foreign country shall be tracked and reported in accordance
with requirements on page II-19, paragraph 7.
4. LOSS DETECTION ELEMENT EVALUATION.
a. Vulnerability Assessment. Detailed vulnerability assessments
identifying and evaluating the capability for detection of a loss
of a Category I quantity of special nuclear material shall be
developed by each Category I facility and approved by the head of
the Operations Office materials control and accountability
organization. Requirements for preparation of the Site Safeguards
and Security Plan documents shall be used as the basis for these
assessments. Vulnerability assessments shall cover the full threat
spectrum specified in Office of Safeguards and Security guidance.
Potential targets shall include all Category I areas and any
Category II or III areas for which a credible scenario for
unauthorized accumulation of a Category I quantity has been
identified. Performance testing programs shall be developed to
support and verify vulnerability assessments. Vulnerability
assessments shall 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 special nuclear material. Results of reviews including changes
in vulnerability assessments shall be documented and classified in
accordance with CG-SS-3.
b. Performance Testing. DOE 5630.16A, SAFEGUARDS AND SECURITY
ACCEPTANCE AND VALIDATION TESTING PROGRAM, contains requirements
for the design, planning, and documentation of performance tests.
Materials control and accountability performance testing programs
shall meet the requirements of DOE 5630.16A. For each facility,
management shall establish and implement a documented testing
program to verify materials control and accountability procedures
and practices and to demonstrate that material controls are
effective.
(1) These tests shall be designed to demonstrate that the system
is functional and to assure that the system performs as
specified and/or required. In addition, facilities shall:
(a) Identify those components of the materials control and
accountability system that provide the greatest
effectiveness against theft and diversion;
(b) Design, conduct, and document tests which substantiate
component effectiveness; and
(c) Integrate the results of these component tests into
safeguards and security vulnerability assessments.
(2) Performance testing shall include not only those elements that
can detect-in-time-to-prevent but also those elements that can
effectively account for special nuclear material in order to
provide assurance that safeguards and security systems are
functioning properly.
(3) The design of the performance testing program shall be focused
on testing individual detection elements. Elements identified
in a vulnerability assessment that contribute to detection
capability shall 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 with the testing program
including more testing for higher category facilities
than for lower category facilities.
(b) Guidance for performing testing is contained in DOE's
Master Safeguards and Security Agreement Verification
Guide (Section 4.0, Performance Testing; Appendix F.,
Checklist for Performance Requirements; and Appendix G.,
Materials Control and Accountability Checklist). In
addition, Office of Safeguards and Security has provided
guidance for the evaluation of the detection elements of
the materials control and accountability system which
will facilitate the design and validation of the
performance testing program in the "Guide to the
Evaluation of Selected Materials Control and
Accountability (MC&A) Detection Elements."
(5) Testing data and results shall be classified in accordance
with CG-SS-3.
(6) Corrective actions shall be taken for vulnerabilities
identified during system testing.
c. Materials Control and Accountability Performance Requirements.
Minimum performance requirements for selected materials control and
accountability system elements are given in Figure I-4 on page
I-12. Validation of these system elements shall be accomplished by
performance testing. Testing shall be established at a frequency
which, at a minimum, shall be in accordance with DOE 5630.16A and
shall be documented in the Materials Control and Accountability
Plan. When these system elements fail to meet performance
requirements, a corrective action plan shall be developed and where
necessary compensatory measures shall be taken. Testing of access
controls and material surveillance shall be facility-specific with
the scope and the extent of the testing documented by facility
management and approved by the Manager, Operations Office. A
sufficient number of items and tamper-indicating devices shall be
tested to assure that on an annual basis the performance
requirements for tamper-indicating devices and accounting records
are met with 95% confidence for Category I and II items.
Confidence levels for Category III and IV items shall be approved
by the Manager, Operations Office. Testing to assure that
tamper-indicating devices are properly in place shall include
checking to see that the tamper-indicating device has been properly
applied and there is no indication that the integrity of the
tamper-indicating device has been violated. (The testing for this
requirement is not intended to require destruction of properly
applied tamper-indicating devices whose integrity has not been
violated.) Additional guidance for testing metal detectors is
given in the "Metal Detector Guide." In the performance
requirement for inventory differences, "throughput" means measured
output including waste, and "active inventory" means those
materials in the Materials Balance Area that enter into the
limit-of-error calculation. Additional or more stringent
performance requirements for system elements may be established by
the Manager, Operations Office, or the responsible Head of
Headquarters Element. Paragraphs 6d(2) of this Chapter; 2c(3) and
4e(1)(f) in Chapter II; 2b, 3b(1), and 5c in Chapter III of this
Order contain requirements that can be readily performance tested.
Testing of system elements associated with these requirements
should be included as a regular part of the performance testing
program.
____________________________________________________________________________
| |
| Access Controls. Performance tests shall be designed and conducted to |
| fully evaluate the effectiveness of access controls for Category I and |
| II quantities of special nuclear material. In at least 95% of the tests |
| conducted, the tests shall demonstrate the detection of unauthorized |
| access to Category I and II quantities of special nuclear material. |
| |
| Material Surveillance. Performance tests shall be designed and |
| conducted to fully evaluate the effectiveness of material surveillance |
| activities for Category I and II quantities of special nuclear material. |
| In at least 95% of tests conducted, the tests shall demonstrate the |
| detection of unauthorized actions related to the control of Category I |
| and II quantities of special nuclear material. |
| |
| Tamper-Indicating Devices. The tamper-indicating device record system |
| shall accurately reflect the location and identity of tamper-indicating |
| devices in at least 99% of the cases. The tamper-indicating device |
| program shall assure that tamper-indicating devices are properly in |
| place in at least 95% 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 (special nuclear |
| material and metal) shall include all applicable tests described in |
| American Society for Testing and Materials guides unless otherwise |
| directed by Office of Safeguards and Security. When standards set in |
| applicable American Society for Testing and Materials guides are not |
| met, compensatory actions shall be taken. |
| |
| Accounting Record Systems. The accounting record system shall |
| accurately reflect item identity and location in at least 99% 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 shall be based on the |
| standard deviation for the measurement method under operating |
| conditions. The control limits for such criteria shall be set at no |
| wider than three times the standard deviation for the method. The |
| Managers, Operations Offices, should review and approve the control |
| limits. When limits based on three standard deviations are unreasonably |
| large, the Manager, Operations Office, may require tighter limits. |
| |
| Inventory Difference Control Limits. Limits-of-error for inventory |
| differences of processes in new Category I and II facilities shall be no |
| larger than the smaller of a Category II quantity of special nuclear |
| material or 2% of total throughput and active inventory. |
| |
|__________________________________________________________________________|
Figure I-4
Performance Requirements for Materials Control and Accountability Elements
d. Performance Requirements Compliance Schedule. Factors for
determining when facilities must demonstrate full compliance with
the materials control and accountability performance requirements
include the following:
(1) Timelines for implementing performance testing requirements in
DOE 5630.16A;
(2) Requirements for the development of and availability of
testing data used to support the Site Safeguards and Security
Plans/Master Safeguards and Security Agreements; and
(3) Effective and implementation dates that were established by
DOE 5633.3A. That Order required the development of a
document, within 9 months of 2-12-93, that specifies how the
requirements in that Order and those specified by the Manager,
Operations Office, are being met.
Based upon the above, facilities should be demonstrating compliance
with performance requirements for those materials control and
accountability elements that detect-in-time-to-prevent as of the
effective date of this Order. For all other elements, compliance
should be demonstrated no later than 11-12-94.
5. OCCURRENCE INVESTIGATION AND REPORTING. Each facility shall identify
materials control and accountability loss detection elements for each
Materials Balance Area and shall establish a graded program for
monitoring these elements and associated data to determine the status of
nuclear material inventories and to identify reportable occurrences.
Reportable occurrences involving Category I, II, and III nuclear
materials shall be reported as an Emergency, Unusual Occurrence, or
Off-Normal Occurrence in accordance with DOE 5000.3B. For reportable
occurrences involving Category IV nuclear materials, the Manager,
Operations Office, will define the extent of the investigation required
to resolve the occurrence. When losses of Category IV nuclear materials
which have been identified as credible radiological sabotage targets or
when radiological sabotage events involving Category IV materials have
occurred, reporting and investigation under DOE 5000.3B may be required.
The categorization of materials control and accountability occurrences
are contained in DOE 5000.3B. In addition to the reporting required by
DOE 5000.3B, the DOE facility representative, as defined in DOE 5000.3B,
shall notify the head of the appropriate division within the cognizant
Operations Office responsible for the implementation of this Order. 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 an indication of a loss of nuclear material and evidence
of a malevolent act. In addition, the Operations Office shall
independently evaluate the occurrence based upon its significance.
Information related to monitoring and assessment activities shall be
documented and retained.
6. ADMINISTRATIVE CONTROLS. For each facility, management shall establish
a graded program to ensure the integrity and quality of materials
control and accountability systems and procedures, and to periodically
review and evaluate these systems. This program shall be described in
the facility's Materials Control and Accountability Plan and
specifically address the following criteria:
a. Facility materials control and accountability procedures shall be
reviewed and approved (prior to implementation) by facility
operations management at a level of authority sufficient to ensure
compliance by operations personnel. Procedures shall be consistent
with the approved facility Materials Control and Accountability
Plan, and procedures shall be distributed to all applicable
organizations and individuals in the facility having materials
control and accountability responsibilities.
b. For each facility, management shall establish procedures for
emergency conditions and periods when materials control and
accountability system components are inoperative. These procedures
shall be designed to assure that access to or removal of special
nuclear material would be detected during these periods.
c. For each facility, management shall establish controls that limit
access to the accounting system and nuclear materials accounting
data. For automated systems, controls shall be designed to deter
and detect unauthorized access to the data bases and data
processing systems that, through tampering, modification, or
alteration could lead to defeat of the accounting system. Nuclear
materials accounting data shall be protected in accordance with
applicable classification, automated data processing, and computer
security regulations.
d. The facility nuclear materials accounting system shall include
checks and balances, and be structured to ensure:
(1) Identification of omission(s) of data for any reportable
transaction.
(2) Timely detection (normally within 24 hours but in no case
later than the subsequent inventory reconciliation) of errors/
discrepancies in records associated with a Category I or II
quantity of special nuclear material including where possible
detecting falsified data and identifying the responsible
person(s).
(3) Detection of data discrepancies and errors to ensure that no
discrepancies exist in control indicator accounts.
(4) The completeness of the nuclear materials accounting system
records.
e. For each facility possessing nuclear materials, facility management
shall establish a program to periodically review and assess the
integrity and quality of the materials control and accountability
system. The assessment program shall address normal operations and
emergency conditions. The frequency of these assessments shall be
on a graded basis, consistent with requirements of DOE 5634.1B, and
approved by the Manager, Operations Office. The results of all
assessments shall be classified if appropriate, reported to
facility management, and each noted deficiency shall be addressed
and corrected. The assessment shall be performed by personnel who
are knowledgeable in materials control and accountability.
Assessments shall be on a graded safeguards basis; at a minimum,
the assessment program shall address the following:
(1) Identification of abnormal situations.
(2) Loss mechanisms, loss detection capabilities, and the
localization of inventory differences.
(3) Selection, maintenance, calibration, and testing functions to
assure proper equipment and system performance.
(4) Materials control and accountability system checks and
balances, including separation of duties and responsibilities,
that are used to identify irregularities and detect tampering
with materials or materials control and accountability system
components.
(5) Change controls, including authorization requirements, to
detect unauthorized or inappropriate modification of system
components, procedures, or data. The change control system
shall address requirements for review, authorization,
documentation, notification, and controls on equipment
selection, procurement, and maintenance.
(6) Procedures and/or checks to assure the reliability and
accuracy of materials control and accountability data and
information.
(7) 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.
(8) Procedures for emergency conditions and for periods when
materials control and accountability system components are
inoperative.
(9) Material containment, material access, and material
surveillance procedures.
(10) The physical inventory program and reconciliation practices.
(11) Accounting system procedures, capabilities and sensitivities.
(12) Identification of personnel with materials control and
accountability responsibilities who should be included in the
facility personnel security assurance program, consistent with
national security requirements and DOE 5631.6A, PERSONNEL
SECURITY ASSURANCE PROGRAM.
(13) Measurement control program.
(14) Tamper-indicating device programs.
f. Reviews shall be conducted prior to startup of new facilities or
operations, and whenever changes are made in facilities,
operations, or materials control and accountability features that
might alter the performance of the materials control and
accountability system.
g. In addition to the assessments in subparagraph f above, internal
audits of the facility's materials control and accountability
function shall be conducted by an organization independent of
materials control and accountability to assess compliance with
internal plans and procedures. The frequency of these audits shall
be approved by the Manager, Operations Office.