Download:
pdf |
pdfNUREG/BR- 0096
Revision 0
January 1992
United States
Nuc lear Regulatory Commission
Instruct ions and Guidance for
Completing Physical Inventory
Summary Reports
(NRC
Form 327)
Office of Nuclear Material Safety and Safeguards
Division of Safeguards and Transportation
20555
Washinton, DC
Donald R. Joy
-
-
TABLE OF CONTENTS
Page
I.
Purpose and Scope ........................................... 1
II.
Definitions ................................................. 2
III. General Guidance
IV.
Specific Instructions:
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
V.
Beginning Inventory (Line 1) ........................... 16
Additions to Inventory (Line 2) ........................ 16
Shipments (Line 3) ...................................... 17
Measured Discards (Line 4) ............................. 17
Ending Inventory (Line 5) .............................. 17
Inventory Difference (Line 6) .......................... 17
17
Bias Correction to Inventory Difference (Line 7) ........
Prior-Period Adjustments (Line 8) ...................... 18
Adjusted Inventory Difference (Line 9) ................. 18
19
Standard Error of the Inventory Difference (Line 10a)
19
Limit of Error of the Inventory Difference (Line lOb)
Active Inventory (Line Ila) ............................ 19
... 19
"Additions to" or "Removals from Process" (Line lib)
SEID Limit (Line 12a) .................................. 19
LEID Limit (Line 12b) .................................. 19
Inventory Difference Limit (Line 13) ................... 20
Response Actions for Excessive Inventory Differences:
1.
2.
3.
4.
VI
........................................... 12
For
For
For
For
10
10
10
10
CFR
CFR
CFR
CFR
70.51(e)(3) Licensees ....................... 21
74.31 Licensees ............................. 22
74.33 Licensees ............................. 22
74.59(f) Licensees .......................... 23
Reporting Requirements
VII. NRC Form 327 (Sample)
..................................... 24
....................................... 25
TABLES:
.......... 13
I. Material Types to be Inventoried Separately ...
24
.............................
Requirements
Reporting
II. MC&A
-
I.
PURPOSE AND SCOPE
U.S. Nuclear Regulatory Commission (NRC) regulations [as specified in
10 CFR 74.17(a), (b), and (c)] require that certain licensees use NRC
Form 327 to report inventory differences MIDs), and associated information needed to evaluate IDs, resulting from any physical inventory
required by 10 CFR 70.51(e)(3), 74.31(c)(5), 74.33(c)(4), or
74.59(f).
The use of Form 327 is
intended to:
(1) eliminate the need for a licensee to report the same information more than once, by informal means, to different NRC organizational units;
(2) standardize the type of information and format used in reporting physical inventory results; and
(3) allow a more efficient and meaningful evaluation of ID results.
The initial Form 327, which was initiated in October 1986, was found
to be confusing in several regards, such as (1) the proper use of "+"
signs; (2) the exact meaning and determination of "Net Sum of
and "-"
Biases"; and (3) the exact meaning and determination of "Prior-Period
The initial Form 327 also needed to be expanded to
Adjustments"'.
incorporate the terminology and data reporting requirements associated
with 10 CFR 74.59, which became effective in January 1990, and with
the new 10 CFR 74.33 material control and accounting (MC&A) requirements for low enriched uranium (LEU) enrichment facilities. Thus, NRC
has decided to revise Form 327 and to issue this NUREG document to
provide more specific guidance and instructions with respect to
completing the form.
-1-
DEFINITIONS
II.
The following terms are used either directly or indirectly with
respect to physical inventories, and thus, within the scope of this
NUREG, have the meanings as presented in this section.
ACTIVE INVENTORY (AI) --- The sum of beginning inventory (BI), additions to inventory (A), removals from inventory (R), and ending
inventory (EI), after all common terms have been totally excluded.
A common term is any source material (S) or special nuclear
material (SNM) value (or item) that appears in both BI and EI, or
both BI and R, or both A and R, or both A and EI, with both values
derived from the same measurement (and thus does not contribute to
the uncertainty associated with the current-period inventory diffThe active inventory is used as an indicator of processerence).
and/or measurement activity.
throughput
ing
ADDITIONS TO INVENTORY (A)
---
ADDITIONS TO PROCESS (ATP)
---
SM and SNM which a "plant"
receives,
and which, prior to such receipt, was not part of the plant's
total possessed SM or SNM quantity.
(1)
SM or SNM receipts
(or "additions
to inventory") that are opened except for receipts (or "additions
to inventory") opened only for sampling and subsequently maintained
under tamper-safing; (2) opened sealed sources (i.e. encapsulated
SM or SNM that has lost its sealed integrity); and (3) SNM removed
from process for nonconformance with chemical or physical specifications that is subsequently reprocessed, measured for contained
[NOTE: "Additions to
SNM, and resubjected to normal processing.
have the same
process"
in
process" and "additions to material
meaning.]
ADJUSTED INVENTORY DIFFERENCE
(AID)
---
An inventory difference that
has been adjusted (corrected) for both (1) the net sum of prior
period adjustments; and (2) the net sum of bias corrections that
It is the adjusted ID that
were not applied to individual items.
the acceptability
determining
for
limits
is evaluated against ID
of the ID.
BEGINNING INVENTORY (BI)
---
The total itemized quantity of SNM (or
SM) of a given material type code possessed by a "plant" at the
The BI
start of a material balance period (inventory period).
definition)
(by
is
period
balance
quantity for any given material
exactly equal to the ending inventory quantity for the immediately
previous period.
BIAS ---
See "MEASUREMENT BIAS'
BIAS CORRECTION TO ID
(BC) ---
The net algebraic sum of all measure-
ment biases (from measurement control program data) that have not
Such net sum
been applied as corrections to individual items.
is
appropriate)
as
isotope,
(expressed as grams element or grams
ID.
calculated
applied as a correction to the initially
-2-
code)
BOOK INVENTORY --- The total SM or SNM (of a given material type
ledgers.
accountability
its
by
possessed by a "plant" as indicated
a
COMBINED LIMIT OF ERROR --- A measurement uncertainty band (at
of
limit
respective
the
from
specified confidence level) derived
measurements
two
of
error (LE) values associated with each
(usually independent of each other) performed on a given material
For both measurement values to be regarded as being in
quantity.
the
agreement, they must not differ from each other by more than
the
taking
by
calculated combined LE, which is normally calculated
is:
That
LEs.
square root of the sum of the squared individual
Comb. LE
=
tILE0))
+
(LE)
LI
Any uranium-bearing material whose uranium isoDEPLETED URANIUM --topic distribution can be characterized as being (1) less than
at
0.700 percent by weight in combined U-233 plus U-235, and (2)
least 99.200 percent by weight U-238.
DETECTION QUANTITY
(DQ) ---
A
site-specific U-235 quantity for
The DQ is normally a
licensees subject to 10 CFR 74.31 or 74.33.
function of annual throughput, but for low throughput LEU
facilities, the DQ need not be less than 25 kilograms of U-235.
theft
The DQ can also be described as a goal quantity, the loss or
of
power
better)
(or
percent
90
a
with
of which must be detected
taken.
is
inventory
physical
detection whenever a
An inventory difference
DETECTION THRESHOLD (DT) ---
(ID)
limit that
an
will be exceeded, with a 90 percent or higher probability, by
whenever
inventory)
physical
a
of
ID (resulting from the taking
The DT is
there has been an actual loss of a detection quantity.
as
(SEID),
ID
of
error
standard
the
and
DQ
the
a function of both
shown by the following equation:
DT = DQ -
1.3(SEID)
EFFECTIVE KILOGRAMS OF SNM ---
(1)
For plutonium and U-233,
their
weight in kilograms; (2) for uranium with an enrichment in the
isotope U-235 of 1.00 percent (0.01 weight fraction) and above,
its element weight in kilograms multiplied by the square of its
enrichment expressed as a decimal weight fraction; and (3) for
uranium with an enrichment in U-235 below 1.00 percent, but above
0.71 percent, its element weight in kilograms multiplied by .0001.
ELEMENT --- Either the chemical element uranium (U) or plutonium (Pu).
-3-
ENDING INVENTORY (EI) --- The total-itemized quantity of SNM (or SM)
of a given material type code possessed by a "plant" at the end of
a material balance period, as determined by a physical inventory.
The EI quantity for any given material balance period is (by
definition) exactly equal to the beginning inventory quantity for
Physical inventories for source material
[NOTE:
the next period.
(specifically, normal and depleted uranium) are only required for
uranium enrichment facilities.]
ENRICHED URANIUM ---
Any uranium-bearing material which does not
qualify as natural or normal uranium, and whose combined U-233
percent or higher by weight,
plus U-235 isotopic content is 0.725
content.
relative to total uranium element
ENRICHMENT LEVEL CODES ---
Codes used in lieu of,
or in conjunction
with, material type code "20" (enriched uranium) to designate the
Enrichment level codes are used in connecrange of enrichment.
tion with reports, primarily DOE/NRC Form 742, submited to the
Nuclear Materials Management and Safeguards System (NMMSS), and
For Form 742, there are
NRC Form 327 sent to NRC Headquarters.
For Form 327,
four enrichment level codes (El, E2, E3, and E4).
with
associated
HEU)
there are just two enrichment codes (LEU and
material code 20.
FORMULA KILOGRAM (FKG)
---
1,000 formula grams of strategic special
nuclear material (SSNM) computed by the following equation:
Grams = (grams U-235 contained in HEU) + 2.5(grams U-233 + Pu)
Strategic special nuclear material in any combinFORMULA QUANTITY --ation that amounts to 5,000 formula grams or more, as computed by
the same equation as given above for the definition of "formula
kilogram".
HIGH ENRICHED URANIUM (HEU)
---
Any uranium-bearing material
whose
combined U-233 plus U-235 isotope content is 20.00 percent or more
by weight relative to total uranium element content.
HOLDING ACCOUNT ---
IN-PROCESS HOLDUP ---
See "WASTE HOLDING ACCOUNT"
Process related SM or SNM that has not been
drained or discharged from its processing equipment at the time of
The quantity of any in-process holdup must be
physical inventory.
[NOTE: The term
included in the physical inventory determination.
term "residual
the
with
confused
be
not
should
holdup"
"in-process
holdup".]
-4-
INVENTORY DIFFERENCE (ID) --- The arithmetic difference between a book
inventory and the corresponding physical inventory, calculated by
subtracting ending inventory (EI) plus shipments (S) and measured
discards (MD) from beginning inventory (BI) plus additions to
Mathematically, this can be expressed as:
inventory (A).
ID
=
(BI + A)
-
(EI + S
+
MD)
The above defined inventory difference is used in an accounting
sense to reconcile the book inventory to the results of the physFor
ical inventory, but is normally regarded as an unadjusted ID.
and
biases
measurement
both
for
adjustments
purposes,
regulatory
prior period adjustments are made to the initially calculated ID
It is the AID
to obtain an "adjusted inventory difference" (AID).
limits.
ID
to
compared
and
assessed
that is
(1) For licensees that conduct physical inventories
pursuant to 10 CFR 70.51(e)(3), the ID limit is the greater of Ci)
200 grams Pu or U-233, 300 grams HEU or U-235 contained in HEU, or
9,000 grams U-235 contained in LEU, as appropriate, or (ii) 1.50
times the limit for LEID.
(2) For licensees that conduct physical inventories pursuant to
10 CFR 74.59(f), the ID limit is the greater of (i) 200 grams Pu
or U-233, 300 grams HEU or U-235 contained in HEU, as appropriate,
or (ii) 3.00 times SEID.
(3) For licensees that conduct physical inventories pursuant to
10 CFR 74.31(c)(5), the ID limit is the detection threshold (DT).
The DT is calculated by subtracting 1.3 times SEID from the
licensee's applicable detection quantity (DQ).
(4) For licensees that conduct 12-month static physical inventories pursuant to 10 CFR 74.33(c)(4), associated with any
material-type code other than "uranium in cascades", the ID limit
is the detection threshold (where DT equals DQ minus 1.3 times
For bimonthly dynamic physical inventories required by
SEID).
10 CFR 74.33(c)(4) for "uranium in cascades", the ID limit is the
DT minus the cumulative ID for the ten-month period just prior to
the current two-month period.
ID LIMIT ---
INVENTORY RECONCILIATION ---
The adjustment of the book-record quan-
tity of both element and fissile isotope, to reflect the results
of a physical inventory, and calculating (1) the ID for the
material balance period in question; (2) the uncertainty value
(SEID or LEID) associated with the ID; (3) the AI for the period;
and (4) any bias adjustment and/or prior period adjustment (PPA)
associated with the ID value.
LIMIT OF ERROR OF THE ID (LEID) ---
The uncertainty (due to measure-
ment uncertainty), at the 95 percent confidence level, associated
with an ID value. Thus, if measurement uncertainty were the only
contributor to a non-zero ID, there would be a 95 percent probability that the ID would be within the range of zero plus or
[NOTE: Just as "ID" and "MUF" are interchangeable
minus LEID.
terms, so are "LEID" and "LEMUF".]
-5-
LEID LIMIT --- For licensees subject to 10 CFR 70.51(e)(5), the regulatory limit for LEID is the greater of (1) 200 grams of plutonium
or U-233, 300 grams of HEU or U-235 contained in HEU, or 9,000
grams of U-235 contained in LEU, as appropriate; or (2) 0.50
percent of the larger of "additions to material in process" or
"removals from material in process".
LOW ENRICHED URANIUM (LEU) --- Any uranium-bearing material whose
U-233 plus U-235 isotope content is greater than 0.724 percent,
but less than 20.00 percent by weight (relative to total uranium
element content).
MATERIAL BALANCE --- A comparison, on a measured basis, of beginning
inventory (BI) plus additions to inventory (A) to ending inventory
(EI) plus removals from inventory (R), for a given control area
(or combination of control areas) over a specified period of time.
MATERIAL BALANCE PERIOD --- The time span to which a material balance
or physical inventory pertains.
MATERIAL-TYPE CODES ---
Number codes for identifying basic material
types with respect to source material, special nuclear material,
The codes are used by the Nuclear
and by-product materials.
Materials Management and Safeguards System (NMMSS) for tracking
For SNM and uranium SM, there are seven
materials nation-wide.
material type codes as follows:
CODE
MATERIAL TYPE
10
81
20
89
Depleted Uranium
Normal Uranium
(*)
Enriched Uranium
Uranium in Cascades
70
Uranium-233
50
Plutonium
83
Plutonium-238
(**)
(***)
(*) For DOE/NRC Form 742 purposes, material code 20 has four
sub-codes, El, E2, E3, and E4, to denote enrichment range.
For NRC Form 327 purposes, code 20 has two sub-codes, namely
LEU and HEU.
(**)
(***)
Uranium materials should be regarded as material code 70 if
the U-233 isotopic distribution is greater than (1) 10.00
weight percent relative to total uranium element content, or
(2) both the U-235 isotopic concentration and 5.00 percent
by weight of the total uranium; otherwise report as material
code 10, 20, or 81, as appropriate.
Plutonium materials should be regarded as material code 83
if the Pu-238 isotopic distribution is greater than 10.00
weight percent relative to total plutonium element content.
Otherwise, report as material code 50.
-6-
MATERIAL UNACCOUNTED FOR (MUF) --- A term previously used for
"Inventory Difference"
MEASURED DISCARD (MD) --- A measured quantity of gaseous, liquid, or
solid waste that is no longer possessed by a facility, or which
has been transferred (accounting-wise) to a waste holding-account
via a DOE/NRC Form 741 transaction.
MEASUREMENT ---
The process of determining
(1) a uranium or plutonium
element concentration; (2) a specific isotope content; (3) an isotopic concentration or distribution; (4) a bulk material mass or
Measurement values are
item mass; or (5) a bulk-material volume.
derived through a calibration process which establishes the relationship between instrument (device) response and the parameter
being determined.
An unidirectional component of error that affects
MEASUREMENT BIAS --A
all members of a measurement data set.
degree)
same
(to the
of
mean
the
of
deviation
the
from
estimated
be
thus
bias can
several measurements of a representative standard from the
If a bias
reference value (or assigned value) of such standard.
of SNM or
value
recorded
the
on
effect
an
have
to
-is large enough
be
should
items
such
values-of
accountability
SM items, the
indiaffect
to
small
too
is
bias
a
If
adjusted.
appropriately
material
(or
items
measured
all
across
effect
its
vidual items,
quantities) should be determined as an absolute quantity (e.g., as
The net sum of all biases (as absolute
grams U and grams U-235).
corrections to individual items is
as
applied
quantities) not
to inventory difference.
correction
bias
a
then applied as
MEASUREMENT SYSTEM ---
Any instrument or device,
or combination of
devices, used to derive a (1) bulk-material mass or item mass; (2)
bulk-material volume; (3) plutonium or uranium element concentration; (4) isotope quantity; or (5) isotopic distribution or contration; and which can be characterized by systematic and random
Each measurement system can also be defined or
error components.
identified by its unique set of the following parameters:
(a)
(b)
(c)
(d)
(e)
(f)
Device or equipment utilized
Standards used for calibration
Representative standards used for control
Sampling technique and equipment utilized (if applicable)
Sample aliquoting technique (if applicable)
Sample aliquot pre-treatment methodology (if applicable)
Any uranium-bearing material whose uranium isoNATURAL URANIUM --topic distribution has not been altered from its natural occurring
state. Natural uranium is nominally 99.283% U-238, 0.711% U-235,
and 0.006% U-234 (by weight relative to total uranium element).
-7-
NORMAL URANIUM ---
Any uranium-bearing material having a uranium iso-
topic weight distribution that can be described as being (1) 0.700
to 0.724% in combined U-233 plus U-235; and (2) at least 99.200%
in U-238.
[NOTE:
All "natural uranium" having a U-235 isotopic
concentration in the range of 0.700 to 0.724 percent is "normal
uranium", but not all "normal uranium" is "natural uranium".]
PHYSICAL INVENTORY ---
A determination by physical means
(visual
and
measurement) of the quantity of source material or special
nuclear material (of a given material-type code) on-hand within a
given "plant" at a specified point in time.
The primary purpose
for a physical inventory is to confirm the absence of (or detect)
a loss or diversion of nuclear material.
For a meaningful conclusion to be drawn from a physical inventory, the physical presence
of all items and any significant quantities of material not in
item form needs to be visually confirmed, and the quantities of
material on inventory need to be measured or assurance provided
that prior measurements are still valid.,
PLANT ---
For SM and SNM control and accounting purposes,
a plant
is
defined as a set of processes or operations (on the same site, but
not necessarily all in the same building) coordinated into a
single manufacturing, R&D, or testing effort.
A scrap-recovery
operation, or an analytical laboratory, serving both on-site and
off-site customers (or more than one on-site manufacturing effort)
must be treated as a separate plant.
Physical inventories are to
be conducted on a "plant" basis, as well as on a "material-type
code" basis.
PRIOR-PERIOD ADJUSTMENT
(PPA) ---
For Form 327 purposes,
PPAs are
limited to corrections (adjustments) applied to an inventory
difference (ID) value due to a correction applied to a component
of beginning inventory (BI), after the inventory period started.
PPAs can arise only from (1) corrections of recording or measurement errors associated with material on BI; (2) resolution within
the current period of statistically significant shipper-receiver
differences involving material that was on BI; and (3) adjustments
to initial receipt values pertaining to scrap, received in a prior
period, due to better measurement following dissolution of such
scrap in the current period.
Since these type of corrections have
nothing to do with the current-period losses or errors, and since
the official BI value is not adjusted, an adjustment to the ID
value
(derived from the equation
ID = BI + A -
R -
EI)
is
necessary to obtain an ID that reflects only current-period
activity.
RECEIPT --A quantity of SM or SNM received by a "plant", via a shipment from an off-site source.
A receipt is also an "addition to
inventory".
-8-
REMOVALS FROM INVENTORY (R) --- All measured quantities of SNM or SM
falling within the categories of (1) shipments; (2) measured
discards released to the environment; (3) declared and measured
waste stored on-site and formally transferred (accounting-wise) to
a waste holding account via a DOE/NRC Form 741 transaction; and
(4) measured discards transported off-site, other than waste
[NOTE: " Removals from inshipped from a "waste holding account".
that
ventory" is equal to "shipments" plus "measured discards" --is,
R = S + MD.]
REMOVALS FROM PROCESS
(RFP)
---
Includes all SM or SNM which falls
within the categories of (1) generation of ultimate product that
sealed
is maintained under tamper-safing; (2) generation of
sources or encapsulated material; (3) generation of measured
discards released to the environment; (4) generation of declared
and measured waste remaining on site (but not stored within any
processing area); and (5) shipment of any materials not described
[NOTE: "Removals from
by categories (1), (2), (3), or (4).
process" and 'removals of material from process" have the same
meaning.]
RESIDUAL HOLDUP ---
Any SM or SNM that remains within processing
equipment (including ventilation filters and ductwork) after
system draindown and/or cleanout.
If, at the time of physical
inventory, the total quantity of residual holdup is significant,
such holdup must be measured (or estimated on the basis of partial
measurements and engineering calculations) and included in the
physical inventory listing.
The uncertainty associated with a
total measured or estimated residual holdup quantity must be included in the calculation of SEID or LEID.
SEID LIMIT ---
For 10 CFR 74.31 licensees,
the
limit for SEID is the
greater of (1) 6,400 grams U-235 for isotope and 200,000 grams
uranium for element, when asuming that the measurement and
non-measurement contributions to SEID are equal; or (2) 0.177
percent of active inventory (for both element and isotope), when
asuming that the measurement and non-measurement contributions to
SEID are equal.
For licensees subject to 10 CFR 74,33, SEID limit
is the greater of (1) 3,500 grams for U-235 and 120,000 grams for
uranium element, when asuming that measurement and non-measurement
contributions to SEID are equal; or (2) 0.177 percent of active
inventory (for both element and isotope), when asuming that
measurement and non-measurement contributions to SEID are equal.
For 10 CFR 74.51 licensees, the limit for SEID is the greater of
(1) 200 grams for plutonium and U-233 (both element and isotope),
and 300 grams for both HEU and U-235 isotope; or (2) 0.100 percent
The term
of active inventory (for both element and isotope).
"SEID LIMIT" does not apply to licensees subject to 10 CFR
70.51(e).
-9-
SHIPMENT --- Any transfer of SM or SNM, other than measured waste
discards, to another on-site "plant" or to an off-site location.
SHIPPER-RECEIVER DIFFERENCE (SRD) --- The difference between what a
sending facility (shipper) claims was contained in a shipment (of
SM or SNM) and what the receiving facility claims was received,
where both shipper's and receiver's values are based on measurements.
SOURCE MATERIAL (SM) ---
Natural uranium,
depleted uranium, natural
thorium, or any combination thereof, provided the combined thorium
plus uranium content is at least 0.05 percent by weight.
(1) Plutonium, uranium-233, uranium
SPECIAL NUCLEAR MATERIAL (SNM) --U-235, and any other material
and/or
enriched in the isotope U-233
that NRC, pursuant to the provisions of Section 51 of the Atomic
Energy Act of 1954 (as amended), determines to be SNM; and (2) any
uranium material artificially enriched in U-233 and/or U-235
(e.g., by blending normal or depleted uranium with enriched
uranium to form a homogeneous mixture).
There are three levels of strategic significance applied to SNM,
depending on the type and quantity, defined as follows:
FORMULA QUANTITY ---
The highest
level of strategic signif-
icance --- see definitions for "Formula Quantity" and
"Strategic Special Nuclear Material".
SNM OF MODERATE STRATEGIC SIGNIFICANCE
---
(1) Less
than a
formula quantity, but more than 1,000 grams of U-235 contained in HEU, or more than 500 grams of U-233 or plutonium,
or more than a combined quantity of 1,000 formula grams,
when computed by the equation:
Grams = (grams U-235 in HEU) + 2(grams U-233 + grams Pu)
or (2) 10,000 grams or more of U-235 contained in LEU enriched from 10.00 to 19.99 percent by weight in U-235.
SNM OF LOW STRATEGIC SIGNIFICANCE ---
(1) Less than an amount
of SNM of moderate strategic significance, but more than 15
grams of (i) U-235 contained in HLEU, (ii) U-233, (iii) plutonium, or (iv) any combination thereof; (2) less than
10,000 grams but more than 1,000 grams of U-235 contained in
LEU enriched from 10.00 to 19.99 percent by weight in the
U-235 isotope; or (3) 10,000 grams or more of U-235 contained in LEU enriched from 0.725 to 9.999 percent by weight
in the U-235 isotope.
-10-
STANDARD DEVIATION --- The random error (at the 67 percent confidence
level) associated with a single value of a data set, which in turn
is also a measure (or indication) of the precision relating to a
set of measurements (or set of data) pertaining to the same item
Standard deviation is calculated as
or sample of material.
follows:
Std. Dev.
Where:
n
Xi
3
L
=
_(xi
= number of measurements performed
= the value obtained for the i th measurement for i = 1, 2, 3 ......... n
= the average value for all n measurements
STANDARD ERROR OF INVENTORY DIFFERENCE (SEID) --- (1) For licensees
subject to 10 CFR 74.31 or 74.33, SEID is equal to the square
root of the sum of both measurement and non-measurement variances
assciated with an inventory difference.
(2) For licensees subject to 10 CFR 74.51 Cand hence to 74.59),
SEID is equal to the square root of the measurement variance
(only) associated with an inventory difference.
STRATEGIC SPECIAL NUCLEAR MATERIAL (SSNM)
uranium-233,
---
U-235 contained in HEU,
or plutonium.
Any SM or SNM that (1) is not suitable (in its present form)
WASTE --for the production of product material, and (2) is not regarded as
economically recoverable for reuse.
WASTE HOLDING ACCOUNT ---
An accounting
ledger,
separate
from a
facility's book-inventory account, which shows the total current
quantity of declared and measured waste stored on site (but not
within any processing area) and awaiting final disposition. All
such waste must have been generated while being part of the
facility's book inventory, and transferred to the waste holding
[NOTE: Waste holding
account via a DOE/NRC Form 741 transaction.
accounts for liquid waste stored in ponds or lagoons are sometimes
designated as "LAGOON ACCOUNTS" or "LAGOON HOLDING ACCOUNTS".
-11-
GENERAL GUIDANCE
SNM licensees that are required to use NRC Form 327 to report the
results of physical inventories are those that are subject to any of
the following regulations within Chapter One, Title 10 of the Federal
Code of Regulations:
(a)
(b)
(c)
(d)
10
10
10
10
CFR
CFR
CFR
CFR
70.51(e)(3)
74.31(c)(5)
74.33(c)(4)
74.59(f)(1)
10 CFR 74.17(a), (b), and (c) specifically require such licensees to
Such report forms should be completed in
submit Form 327 reports.
provided in this NUREG document.
instructions
accordence with the
A separate 327 form report is to be used for each material-type code
within each plant (see definitions for "material type codes" and
"iplant"). For example, let's assume that XYZ Nuclear Corporation
conducts the following operations under a single license at a single
site:
OPERATION A ---
Conversion of high enriched uranium hexafluoride
to high enriched uranium metal.
OPERATION B ---
Fabrication of mixed plutonium oxide/uranium
oxide fuel rods, in which some of the uranium
oxide is enriched between 1.00 and 3.50 percent
in U-235, while the remaining is either normal or
depleted uranium.
OPERATION C ---
Recovery of high enriched uranium scrap generated
from both operation A and from off-site facilities.
---
Analytical laboratory which provides sample
analyses on samples generated from operations A, B,
and C.
OPERATION D
Operations A and B are separate and independent of each other (with no
Thus, A and B must be
SNM flowing between the two operations).
Although part of the uranium processed
regarded as separate plants.
by operation C relates to operation A, operation C must be considered
as a separate plant because it is processing scrap generated from both
on-site and off-site operations (i.e., from more than one plant).
Likewise, operation D must be regarded as a separate plant because it
Thus, the four
receives samples (i.e., SNM) from more than one plant.
above operations can be designated as Plants A, B, C, and D, and in
this hypothetical example, a separate Form 327 report would be necessary for each of the following:
-12-
(a) any HEU physical inventory conducted in Plant
(b) any plutonium physical inventory conducted in
any LEU physical inventory conducted in Plant
(c)
(d) any HEU physical inventory conducted in Plant
(e) any LEU physical inventory conducted in Plant
Cf) any HEU physical inventory conducted in Plant
(g) any plutonium physical inventory conducted in
A
Plant B
B
C
D
D
Plant D.
In addition to LEU, HEU and plutonium, as used in the example above,
separate 327 forms are to be used for reporting any physical inventories associated with (1) uranium-233, (2) plutonium-238, (3) uranium
in cascades, (4) normal uranium at an enrichment facility, and (5)
For each SM or SNM
depleted uranium at an enrichment facility.
for both element
reported
be
to
are
results
material type, inventory
below.
I,
in
Table
shown
and isotope as
MATERIAL TYPES TO BE INVENTORIED SEPARATELY
TABLE I ---
MATERIAL TYPE
MATERIAL
CODE
REPORTING
WEIGHT UNIT
(to nearest)
10
(1)
Depleted Uranium
(1)
Normal Uranium
Low Enr. Uranium
(2)
ELEMENT
WEIGHT
ISOTOPE
Kilogram
Uranium
U-235
81
Kilogram
Uranium
U-235
20
Gram
Uranium
WEIGHT
U-235 or
U-233
High Enr. Uranium (2)
Gram
20
Uranium
+ U-235
U-235 or
U-233 + U-235
Uranium in Cascades
Uranium-233
Plutonium-238
(1)
(3)
(4)
Plutonium
89
Gram
Uranium
U-235
70
Gram
Uranium
U-233
83
0.1 Gram
Plutonium
Pu-238
50
Gram
Plutonium
Pu-239 + 241
(1) Only uranium enrichment facilities subject to 10 CFR 74.33(c)(4)
are required to conduct physical inventories for material codes
10, 81, and 89.
(2) For Form 327 purposes, LEU and HEU are two sub-codes of material
code 20, and physical inventories for LEU and HEU must be conducted and reported separately.
(3) To be regarded as
than 10.00 weight
greater than both
the total uranium
10, 81, or 20, as
material code 70, the U-233 must be greater
percent of the total uranium content, or
the U-235 content and 5.00 weight percent of
Otherwise, report as material code
content.
appropriate.
-13-
(4) To be regarded as plutonium-238, the Pu-238 isotopic distribution must be greater than 10.00 weight percent relative to total
Otherwise, report as material code
plutonium element content.
50.
All the blocks ("A" through "I")
to be filled in as follows:
on the upper portion of Form 327 are
Block A
"Licensee Name" --- Name of corporation or company to
which license is issued.
Block B
"Facility Location" --Nearest town to which facility
site is located, or licensee' s mailing address.
Block C
"Docket No."
Block D
---
---
List appropriate Part 70 docket number.
'SNM License No." ---
List SNM license number under which
possession and use of SNM is authorized.
Block E --- "Plant Designation" --- For licensees conducting only a
For
single operation, enter "Single plant operation".
licensees that are authorized to operate two or more
plants, as described within their approved Fundamental
Nuclear Material Control Plan (FNMCP), designate the plant
(by code or name as given in the FNMCP) to which the 327
form report pertains.
BLOCK F ---
"Beginning Date" &
"Ending Date" ---
For the ending date,
enter the cut off date for the physical inventory in
question.
For the beginning date, enter the cut off date
for the physical inventory just previous to the one in
question. [NOTE: If the cut off time for the previous
physical inventory was midnight or 11:59 P.M. of a given
day, the beginning date for the current period should be
regarded as having started at 12:01 A.M. of the following
day.]
Block G --- "Material Type" --- Place an "X" in one of the eight
boxes, to indicate which material type the 327 form report
pertains.
[NOTE: Do not mark more than one box per form,
except in the case of a total material balance inventory
difference report associated with a uranium enrichment
facility, which must be reported in addition to the
individual material type reports.]
The printed
Block H --- "Licensee's Certifying Official and Date" --name and signature of a licensee supervisor or manager is
to be entered in this block.
By signing this block, an
individual is certifying that he/she has reviewed and
checked all entries, and that to the best of their
knowledge, all entries are correct.
The date on which the
327 Form is signed should also be entered.
-14-
For lines one through thirteen, enter the appropriate value for both
Immediately under
the "Grams Element" and "Grams Isotope" columns.
the grams isotope heading, enter a "O", 7121,"31, "5", or "8" within
The
the isotope code box, to indicate the isotope being reported.
isotope codes are as follows:
0 = Pu-239 plus Pu-241 content
2 = U-233 plus U-235 content
3 = U-233 content
5 = U-235 content
8
=
Pu-238 content
For physical inventories of either depleted uranium or normal uranium
at uranium enrichment facilities, both element and isotope quantities
For physical inventories
are to be reported to th4 nearest kilogram.
pertaining to plutonium-238, both element and isotope quantities are
All other material
to be reported to the nearest tenth of a gram.
When reporting the
types are to be reported to the nearest gram.
results of depleted uranium or normal uranium physical inventories (at
enrichment facilities), either (1) cross out the "GRAMS" at the top of
both column headings and write in "KG", or (2) add three zeros after
each rounded kilogram quantity.
For lines 6, 7, 8, and 9, a plus ("+") or minus ("-") sign, as appropriate, must precede each entered quantity for both element and
isotope. The specific instructions given in the next section provide
guidance for determining whether a sign should be positive or
negative.
Transmittal of Completed Forms:
Completed 327 forms are to be mailed to the NRC and addressed as
follows:
U.S. Nuclear Regulatory Commission
Office of Nuclear Material Safety and Safeguards
ATTENTION: Branch Chief
Domestic Safeguards Branch
Division of Safeguards and Transportation
Mail Stop: 4E4, WFN
20555
Washington, DC
To satisfy the time frame cited by 10 CFR 74.17(a), (b), or (C), as
appropriate, for transmitting the completed form, the transmital
letter must be postmarked on or before the last day of the specified
time period.
Any 327 form which is reporting information associated with an SSNM
physical inventory must be properly identified as "CONFIDENTIAL,
National Security Information" (see 10 CFR Part 95, Appendix A).
-15-
SPECIFIC INSTRUCTIONS
Line 1 --- Beginning Inventory (BI):
The "beginning inventory" value must be identical to the previous
If, after the start of the
period's "ending inventory" value.
to items that were on BI (due
made
were
adjustments
period,
current
to discovered errors in recording or measurement, or due to a resolution of one or more shipper-receiver differences), the net sum of
such adjustments is to be reflected in Line 8 rather than adjusting
the BI value itself.
(1) Do not include in the BI quantity any waste material
NOTES:
that was on hand at the start of the inventory period, but which
had been measured and transferred to a waste holding account prior
(See definition for "Waste Holding Account").
to the BI date.
(2) As used in these instructions, the term "current period" means
the material balance period that ended on the cut off date for the
physical inventory being reported.
Line 2 --- Additions to Inventory (A):
"Additions to inventory" represent the total of all SNM (or SM in
the case of enrichment facilities) of a particular material-type
either from off-site
code received during the current period --are not being covered
(that
suppliers or from other on-site plants
For enrichment
by the specific 327 form report in question).
facility reports dealing with uranium in cascades, "additions to
inventory" include any SM (either depleted or normal uranium) or
any SNM (low enriched uranium) fed into the cascade system, except
for material withdrawn from the cascade system and recycled back to
For
the cascade(s) during the same material balance period.
"additions
LEU,
with
dealing
enrichment facility 327 form reports
to inventory" represents all LEU withdrawn from the cascade system
during the material balance period, plus any LEU received as a
shipment from an off-site supplier.
(1) For LEU reports, "additions to inventory" should also
NOTES:
include any normal, depleted,or high enriched uranium that was
blended with LEU (during the current period within the plant to
which the 327 form pertains), if the resulting blend is greater
than 0.724 weight percent, but less than 20.00 weight percent in
combined U-233 plus U-235, relative to total uranium content.
(2) For HEU reports, "additions to inventory" should also include
any normal, depleted, or low enriched uranium that was blended with
HEU (during the current period within the plant to which the 327
report pertains), if the resulting blend is 20.00 weight percent or
higher in combined U-233 plus U-235, relative to total uranium content.
-16-
Line 3 --- Shipments (S):
"Shipments" represents the total of all SNM or SM, of a given
material-type code, shipped off-site or to other on-site plants
during the current period with the exception of (1) prior-period
waste shipped from a "waste holding account"; and (2) any currentIf a correction (adjustment)
NOTE:
period waste that was shipped.
was
is made in the current period to an SNM (or SM) quantity that
as
regarded
be
to
not
is
shipped in a prior period, such adjustment
period.
current
part of the "shipments" (Line 3) total for the
Line 4 ---
Measured Discards
(MD):
and
"Measured discards" include all SNM or SM waste (solid, liquid,
measgaseous), of a given material-type code, that was generated,
ured, and removed from the accounting ledgers during the current
Whether the waste was shipped, discharged to the environperiod.
is
ment, or stored on-site as part of a waste holding account
NOTE: Any waste
irrelevant with respect to this line entry.
which has not been
but
on-site,
stored
is
that
(liquid or solid)
part
transferred to a waste holding account, is to be regarded as
of ending inventory.
Line 5 ---
Ending Inventory
(EI):
a
The "ending inventory" value is the total of all SNM or SM, of
given material-type code, on hand at the cut off time, as determined by the physical inventory, except for any waste stored
on-site as part of a waste holding account.
Line 6 ---
Inventory Difference
(ID):
The "inventory difference" is the mathematical combination of the
That is, ID = BI + A - S - MD - EI.
five preceding lines.
i.e., the physical
in material --gain
a
ative ID suggests
A neg-
invenbooks.
tory total was more than the amount shown on the accounting
i.e., the physical inA positive ID implies a loss of material --ventory total was less than that indicated by the accounting
Some prefer to define ID as being equal to book inventory
ledgers.
minus physical inventory, which is identical to the ID equation
A
given above. That is, the book inventory is the same as BI plus
EI.
as
minus S minus MD, and the physical inventory is the same
Line 7 ---
Bias Correction to the Inventory Difference
(BC):
accordBias corrections to inventory difference are to be made in
correction
bias
Any
commitments.
Plan
ance with a licensee's FNMC
that has been applied to individual SNM or SM items (thus resulting
applied
in the changing of accounting ledger entries) must not be
indiaffect
to
small
too
are
biases
Most
as a correction to ID.
signifia
have
can
items
many
over
effect
vidual items, but their
For those biases that are to be
cant effect on the ID value.
the
applied as adjustments to ID, the methodology used to derive
-17-
overall net bias correction adjustment
mate) the following model:
BC
=
KNet Bias
LCorr. BIj
+
Net Bias
LCorr.
should satisfy (or approxi-
et Bias
orr.
A
_
SJ
ret
Bias
LCorr.
MDJ
_
Net Bias
Lorr. El
NOTE:
If bias is negative (causing an understatement), the bias
If bias is positive (causing an overstatecorrection is positive.
The BI bias correction is
ment), the bias correction is negative.
The S and EI bias
due to biases that existed during prior periods.
corrections can be a combination of prior and current period
biases.
The A and MD bias corrections are due to biases that
existed during the current period only.
Line 8 ---
Prior Period Adjustments
(PPA):
Prior period adjustments are changes (made during the current
period) to accountability values that were assigned during previous
periods and which pertain to items or material that are part of BI.
PPAs can arise only from:
error associated
(1)
Corrections of a recording or measurement
with material on BI,
(2)
Resolution within the current period of a statistically
nificant shipper-receiver difference involving material
was on BI, and
(3)
receipt value pertaining to
An adjustment to the initial
scrap, received in a prior period, due to better measurement
following dissolution of such scrap in the current period.
NOTE:
Line 9 ---
sigthat
If an accountability value generated in a prior period
causes BI to be overstated, the associated PPA is given a
negative sign.
If BI is understated, the PPA is positive.
Adjusted Inventory Difference
(AID):
The adjusted inventory difference is the algebraic sum of the
It is this final AID value
amounts entered on Lines 6, 7, and 8.
that is compared to:
Ci) a licensee's Detection Threshold Value when subject to either
10 CFR 74.31(c)(5) or 74.33(c)(4),
(ii)
(iii)
three times SEID when subject to 10 CFR 74.59(f)(1)(i),
and
one and a half times LEID limit (i.e.,
0.75 percent of
throughput as indicated by additions to or removals from
process) when subject to 10 CFR 70.51(e).
The AID value is
also used with regard to 10 CFR 74.13(b)(1).
-_1 n _
Lines 10a & 10b --- SEID and LEID:
Licensees subject to 10 CFR 74.51 are to complete Line 10a, with
SEID meaning the square root of measurement variance associated
Licensees subject to 10 CFR 74.31 or 74.33 are to
with the ID.
complete both Lines 10a and 10b, with SEID meaning the square root
of the sum of both measurement and non-measurement variances
associated with the ID, and with LEID meaning two times the square
Licensees
root of the measurement variance associated with the ID.
LEID
with
10b,
Line
complete
to
are
70.51(e)
CFR
10
to
subject
variance
measurement
the
of
root
square
the
times
meaning two
associated with the ID.
Lines 11a & l1b --- Active Inventory and Throughput:
Licensees subject to 10 CFR 74.31, 74.33, or 74.51 are to complete
Active inventory is the summation of BI plus A plus S
Line 11a.
plus MD plus EI after deducting all covariant items (or material
That is, any item
quantities) from each of the preceeding terms.
listings based on
both
(with
terms
five
appearing twice among the
not to be included
is
measurements)
of
set
the same measurement, or
inventory.
active
determining
within any of the terms when
See
Licensees subject to 10 CFR 70.51(e) are to complete Line 11b.
from
"removals
and
process"
to
the definitions for "additions
process" in the DEFINITIONS section.
Lines 12a & 12b ---
SEID and LEID Limits:
Licensees subject to 10 CFR 74.51 are to complete Line 12a, whereas
licensees subject to 10 CFR 74.31 or 74.33 are to complete both
Lines 12a and 12b, and 70.51(e) licensees are to complete line 12b.
For 74.31 licensees, SEID limit is the greater of (1) 6,400 grams
U-235 for isotope and 200,000 grams uranium for element, when
asuming that measurement and non-measurement contributions to SEID
are equal; or (2) 0.177 percent of Line 11a (for both element and
isotope), when assuming that measurement and non-measurement
For licensees subject to 74.33,
contributions to SEID are equal.
SEID limit is the greater of (1) 3,500 grams U-235 for isotope and
120,000 grams uranium for element, when asuming that the measurement and non-measurement contributions to SEID are equal; or (2)
0.177 percent of Line 11a (for both element and isotope), when
asuming that measurement and non-measurement contributions to SEID
For 74.51 licensees, SEID limit is the greater of (1)
are equal.
200 grams for plutonium and U-233 (both element and isotope), and
300 grams for both HEU element and U-235 isotope; or (2) 0.100
percent of Line 1a (for both element and isotope).
For 74.31 licensees, LEID limit is the greater of (1) 9,000 grams
U-235 for isotope and 300,000 grams uranium for element; or (2)
For 74.33 licensees, LEID limit is the
0.25 percent of Line 11a.
greater of (1) 5,000 grams U-235 for isotope and 170,000 grams
For 70.51(e)
uranium for element; or (2) 0.25 percent of Line 11a.
HEU
for
licensees, LEID limit is the greater of (1) 300 grams
300,000
and
element and isotope, 9,000 grams U-235 for LEU isotope,
lib.
Line
grams uranium for LEU element; or (2) 0.50 percent of
-19-
Line 13 --- Inventory Difference Limit:
Licensees subject to 10 CFR 70.51(e) should enter the greater of:
(i) 200 grams Pu or U-233, 300 grams HEU or U-235 contained in
HEU, or 9,000 grams U-235 contained in LEU, as appropriate, or
(ii) 1.50 times the LEID limit, where LEID limit is 0.50 percent of
Line lib.
NOTE: When the U-235 ID limit for LEU inventories is 9,000 grams,
Thus, in this situathere is no uranium element ID limit.
for Line 13.
column
element
tion, enter 'NA" in the
When conducting 12-month physical inventories, licensees subject to
either 10 CFR 74.31 or 74.33 should enter their U-235 Detection
Threshold CDT) value, where DT equals the site-specific U-235
For
Detection Quantity (DQ) minus 1.30 times the U-235 SEID.
conducted
cascades")
in
bimonthly dynamic inventories (for "uranium
cumulathe
DT
minus
by 10 CFR 74.33 licensees, the ID limit is the
twotive ID for the ten-month period just prior to the current
For
The limits just described are U-235 ID limits.
month period.
10 CFR 74.31 and 74.33 licensees, there are no uranium element ID
Thus, always enter "NA" in the element column for Line 13.
limits.
Licensees subject to 10 CFR 74.51 land thus 74.59 (f)] should enter
the larger of: (1) 200 grams Pu or U-233, 300 grams HEU or U-235
contained in HEU, as appropriate, or (2) three times SEID.
-20-
RESPONSE ACTIONS FOR EXCESSIVE INVENTORY DIFFERENCES
excess
Whenever a finally determined inventory difference value is in
a
as
of its regulatory limit, the licensee should (not necessarily
course
regulatory requirement, but as a responsible and professional
of action) do the following:
(a) Immediately notify the appropriate NRC safeguards licensing
authority by telephone of such a situation, even if the
has
regulatory time limit for reconciling and reporting the ID
not expired.
of
(b) Initiate an investigation to determine the probable cause
the excessive ID,* even though the regulatory time limit for
reconciling and reporting the ID has not yet expired.
an
(c) When officially reporting the ID on NRC Form 327, attach
the
that
acknowledges
(1)
that
form
official letter to the 327
investigative
that
confirms
(2)
ID limit has been exceeded;
NRC
activities, as required by the licensee's FNMC plan and/or
status
the
provides
(3)
and
regulations, have been initiated;
of the investigation, and investigative findings, if the
investigation has been completed.
physical
The actual regulatory ID limit will depend on which MC&A
of
amount
the
and
to,
inventory regulation a licensee is subject
in
period
inventory
the
for
throughput and/or processing activity
question.
For 10 CFR 70.51(e)(3) licensees:
requirement
Licensees subject to 10 CFR 70.51(e) must respond to the
grams of
200
(1)
both
of 10 CFR 74.13(b)(1) whenever an ID exceeds
HEU, or
in
contained
U-235
plutonium or U-233, 300 grams of HEU or
its
(2)
and
appropriate;
9,000 grams U-235 contained in LEU, as
to be
not
is
LEID
that
however,
It should be noted,
associated LEID.
both
exceeds
ID
an
if
Thus,
regarded as a regulatory limit for ID.
no
the de minimus level and LEID, but is less than the ID limit,
The
required.
is
74.13(b)(1)
response other than that called for by
times
1.50
is
327
Form
of
13
ID limit which is to be indicated on Line
an
Whenever
Section).
the LEID limit (see "LEID Limit" in Definitions
initiate
to
is
licensee
the
official ID result exceeds the ID limit,
It should be noted that although both element and
a reinventory.
U-233
isotope IDs are to be reported for plutonium, Pu-238, and
those
for
limits
ID
physical inventories, there are no isotope
material types (i.e., for material codes 50, 70, and 83).
than 2.00
If the ID exceeds 1.50 times LEID limit, but is no greater
manner
same
the
in
times LEID limit, the reinventory may be conducted
following
period
as a regular physical inventory (including a 30-day
the reinthe reinventory date to reconcile and report the results of
or less
to
equal
is
If the ID resulting from a reinventory
ventory).
-21-
than 1.50 times the LEID limit for the combined initial inventory plus
If the
reinventory period, no further corrective action is required.
reinventory ID is, however, greater than 1.50 times the combined
period LEID limit, the appropriate NRC safeguards licensing authority
is to be notified by phone or other telephonic means as soon as such
ID result has been finalized (i.e., don't wait until the 30-day reconciliation period is used up).
If an ID exceeds twice the LEID limit, the reinventory is to be conducted on the basis of a complete plant-process shutdown and cleanout,
and restarting the process is not to be initiated without prior
Details of the shutdown and cleanout
written approval from the NRC.
in the licensee's FNMC plan.
defined
well
be
must
activities
For 10 CFR 74.31 licensees:
The ID limit for licensees subject to 74.31 is the calculated U-235
detection threshold (DT) value for the inventory period in question
(see "Detection Threshold", "Detection Quantity", and "Standard Error
74.31
of the Inventory Difference" in the Definitions Section).
are to
IDs
isotope
and
element
licensees should note that while both
low
the
to
Due
limit.
ID
be reported, only the isotope ID has an
the ID
licensees,
74.31
by
strategic significance of the SNM possessed
SEID).
times
five
than
limit is very liberal (in most cases greater
However, if an ID (either positive or negative) equals or exceeds the
ID limit, the NRC would normally regard such a situation as very
serious, and a lengthly process shutdown and extensive NRC investigaIn any event, the licensee's
tion would be a likely consequence.
response actions for an ID that equals or exceeds its associated DT
should be well defined in its FNMC plan.
Additionally, any isotope ID (of positive sign) that exceeds twice its
associated SEID by more than 500 grams U-235, or by more than 250
grams U-233 or Pu-239 + Pu-241, or Pu-238, must be regarded as an
indicator of possible loss, and as such must be subject to the investigation and resolution commitments (pertaining to loss indicators)
contained in the licensee's FNMC plan.
For 10 CFR 74.33 licensees:
With respect to 12-month static physical inventories, associated with
any material-type code other than "uranium in cascades", the ID limit
is equal to the detection threshold (DT) value for the inventory
period in question (see "Detection Threshold", "Detection Quantity",
and "Standard Error of the Inventory Difference" in the Definitions
For bi-monthly dynamic physical inventories (for "uranium
Section).
in cascades"), the ID limit is the DT minus the cumulative ID for the
Because
ten-month period just prior to the current two-month period.
74.33
by
of the low strategic significance of LEU being produced
licensees, the ID limits are very liberal (in most cases greater than
However, if an ID equals or exceeds its ID limit,
five times SEID).
the NRC would normally regard such a situation as very serious, and,
depending on circumstances, a complete process shutdown might be
-22-
In any event, the licensee's response actions for
deemed necessary.
an ID that equals or exceeds its associated DT should be well defined
in its FNMC plan.
Additionally, any U-235 ID (of positive sign) that exceeds twice its
associated SEID by more than 500 grams U-235 must be regarded as an
indicator of possible loss, and as such must be subject to the investigation and resolution commitments (pertaining to loss indicators)
contained in the licensee's FNMC plan.
For 10 CFR 74.59(f) licensees:
The ID limit for those licensees subject to the physical inventory requirements of 74.59(f) is the larger of (1) 200 grams of plutonium or
U-233, or 300 grams-of HEU or U-235 contained in HEU, as appropriate;
or (2) three times SEID. Whenever an ID result (regardless of its
algebraic sign) exceeds its limit, an investigation is to be initiThe investigation must include a
ated, pursuant to 74.59(f)(1)(i).
of the historical standard
74.59(f)(1)(ii),
to
determination, pursuant
Such
guidance).
specific
more
for
deviation of ID (see NUREG-1280
ID
official
final,
a
as
soon
as
investigation should be initiated
ID
an
reporting
When
limit.
its
of
result is known to be in excess
the
accompany
should
letter
cover
a
value that has exceeded its limit,
of
status
the
and
acknowledged,
is
ID
Form 327, in which the excessive
exhas
ID
an
that
determining
If, after
the investigation noted.
ceeded its limit, it is also determined that the ID also exceeds three
times the historical standard deviation of ID, that fact must be
reported to the NRC, pursuant to 74.59(f)(1)(iii).
-23-
TABLE II
APPLIES TO LICENSEES
1
tU.s.
'n
Ace ...
Ntt
I rn ,r q
QWEffiLA
&W
%DUI%.
nowt 4AAU%
REQUIREMENT SPECIFIED
1nX
4
E1s
LU
^
dw.1
I
b~rm
74.11(a)
MC&A REPORTING REQUIREMlENTS
---
70.51(e), 74.31(c),
74.59(f)
& (b)
a.;;- ..AJ
n. d
|
Io
UWe
74.33(c) &
____________________________________
74.13(o)
70.51(e), 74.31(c),
74.59(f)
74.13(b)(1)
74.33(c)
&
both LEID and de minimus
exceeds
LEID limit
LEID exceeds
70.51(e)
…____________________________________
70.51(e), 74.31(c),
74.59(f)
& (b) or (c)
…____________________________________
Semi-annual submital of Form 742
…____________________________________
____________________________________
74.15(a)
DVs
loss or theft
Discovery of any
ID
70.51(e)
____________________________________
74.13(b)(2)
nuav
VQTjTD1?1Z9r
D1WlT~nV'TTNI:
nro
sr
AV
MJA'lIlDR
74.33(c),
&
Form 741
Completing and distributing
…____________________________________
74.17(a)
74.31(c)
& 74.33(c)
Submittal of NRC Form 327
…____________________________________
74.17(b)
of NRC Form 327
Submittal
70.51(e)
…____________________________________
74.31(c)(5)
of NRC Form 327
Submittal
74.59(f)
74.17(c)
- - - - - - - - - - - - -- - - - - - - - - - - - - - - - - - - - - -
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
I 74.31(c)
…____________________________________
to resolve any ID that
Inability
DT value
equals or exceeds its
…____________________________________
any ID that
its
DT value
to resolve
Inability
equals or exceeds
74.33(c)
74.33(c)(4)
…____________________________________
74.57(f)(2)
________ _____________ ____________ __
________________________
74.59(f)(1)(i)
________________________
74.59(f)(1)(ii)
procedure
of resolution
Initiation
for abrupt loss detection indicator involving 5 or more FKG
74.59(f)
I
…____________________________________
SEID equals or exceeds 0.10 % of
active inventory, and/or any ID
limit
exceeds its
that
74.59(f)
- - - - - - - - - - - - -- - - - - - - - - - - - - - - - - - - - - - - -
I 74.59(f)
…_
_
ID
-24-
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
exceeds both (i) ID limit,
three times the std.
(ii)
IDs determined
historical
sequential analysis
_
_
_
_
_
_
_
and
dev.of
from
_
| File Type | application/pdf |
| File Modified | 2005-01-03 |
| File Created | 2005-01-03 |