R. Hooper

Seminario del OIEA/OPANAL

 J. Vidaurre-Henry

IAEA/OPANAL Seminar

STATE SYSTEMS OF ACCOUNTING AND CONTROL
Mr. Dirk Schriefer

INTRODUCTION

When a country embarks upon a program of nuclear activities, however modest, the government will generally find it necessary to establish a framework of controls to ensure that its safety and non-proliferation objectives are met. Usually a separate governmental body, such as a Nuclear Regulatory Authority, is established and given the authority to oversee the nuclear programme. Aspects to be controlled are:

· radiation protection of radiation workers and the population;
· use and transportation of radioactive and nuclear material;
· radioactive waste management;
· licensing of nuclear installations and their engineered nuclear safety;
· physical protection of nuclear material and installations to prevent theft, sabotage and other misuse; and
· safeguards.

Although these functions have a tendency to reinforce one another, in practice they might be carried out by one single body or by several. Most of them satisfy primarily national needs. The assurance that the nuclear programme serves exclusively peaceful purposes is an international objective which is achieved through implementation of IAEA safeguards.

Organizational and technical arrangements to be made by a State in achieving both, national objectives and international safeguards objectives, form the State System of Accounting For and Control of Nuclear Material (SSAC). Such a system consists usually of three major components: a legal framework, a State-level component and facility-level components. Objectives and principal requirements for the State System of Accounting for and Control of Nuclear Material, that arise from the Treaty for the Prohibition of Nuclear Weapons in Latin America and the Caribbean (“Tlatelolco Treaty”), the Treaty on the Non-Proliferation of Nuclear Weapons (“NPT”) and Safeguards Agreements with the IAEA, will be discussed here.

A safeguards agreement conforming to INFCIRC/153 (Corrected) is required to provide that “... the State shall establish and maintain a system of accounting for and control of all nuclear material subject to safeguards under the agreement” which calls for arrangements between the IAEA and the State on a “system of records” and a “system of reports”. The establishment of an SSAC is a vital element in carrying out international safeguards. Also as an important tool to improve the operations of nuclear facilities an SSAC assists facility operators to improve their effectiveness and efficiency. An SSAC may have, inter alia, the following objectives:

1. A national objective, to account for and control nuclear material in the State and to contribute to the detection of possible losses, or unauthorized removal of nuclear material.

2. An international objective, in particular, to provide the essential basis for the application of IAEA safeguards pursuant to the provisions of an agreement between the State and the IAEA.

While systems designed specifically for one or the other of these objectives may differ in some details, many technical elements are the same and would contribute to the attainment of both objectives. The basic elements of an SSAC are set forth in paragraph 32 of INFClRC/153 (Corrected) which calls for an SSAC to be based on a structure of material balance areas and includes measures to be specified in the Subsidiary Arrangements.

ELEMENTS OF A STATE SYSTEM

In outlining the State level component of an SSAC, the organizational and functional elements of an SSAC can be addressed in the following six major areas, each of these will be discussed briefly:

1. Authority and Responsibility
2. Laws, Regulations and Other Measures
3. SSAC Information System
4. Establishment of Requirements for Nuclear Material Accounting and Control
5. Ensuring Compliance
6. Technical Support.

Authority and Responsibility

A State will formulate policy, define objectives and assign responsibilities appropriate for both national and international objectives. IAEA/SG/INF/2 outlines quite clearly the authority and responsibilities of a State with respect to the SSAC.

A State should:

1. Define its objectives in establishing an SSAC.

2. Designate a nuclear material accounting and control authority with the responsibility for:

· establishing provisions governing the possession, transfer and use of nuclear material;
· ensuring that the State’s nuclear material accounting and control objectives are met;
· serving as the point of contact in implementing Safeguards Agreements concluded with the IAEA and
· developing and implementing nuclear material accounting and control procedures for the State to discharge its obligations under IAEA Safeguards Agreements.

3. Establish appropriate arrangements for the prompt notification of responsible Government authorities in the event of losses, unauthorized use or removal of nuclear material.

Laws and Regulations

Given an SSAC objective to detect loss, theft or diversion of nuclear material, a State needs to have clear knowledge of what material is under its jurisdiction, where it is located, what use is being made of it and who is responsible for it. Further, the State will need measures to assure that this information about the material is accurate. The basis of obtaining this information and for providing assurance of the accuracy of the information can be provided through laws and regulations in the following area:

1. definition of the starting point for accounting for and control of nuclear material and the conditions for termination or exemption from accounting and control.

2. establishment of conditions for possession and use of nuclear material, including establishment of criteria and requirements for a system of accounting for and control of the material.

3. establishment of requirements for both routine and special reports to the state of information pertinent to nuclear material, including reports of changes in the facility and incidents affecting material accounting and control and reports of incidents involving loss of nuclear material.

The State should make and regularly review the necessary laws, regulations or other measures to ensure that the requirements for nuclear material accounting and control are met throughout the area within its jurisdiction. These measures should include the requirements in respect of nuclear material, facilities, international transfers.

Information System

The State should establish and maintain an SSAC information system with the following main activities:

1. recording and processing of information on nuclear material, provided by facility operators and reported to the State Authority;

2. collecting, processing and recording of the information by the State Authority and preparing of reports for evaluation internally and for submission to satisfy international and possibly national obligations;

3. handling of other information to be received from and sent to the IAEA and others such as shippers or receivers in other states.

The State Authority will need to handle various kinds of information1 to exercise control of the possession, use and disposition of the nuclear material under its jurisdiction. Regardless of size and complexity, however, a State Authority information system will need to include at least four categories of information:

· Design information records;
· Nuclear material inventory and transaction records;
· Activity and operations reports and records and
· Records and reports to and from the IAEA.

Establishment of Requirements for Nuclear Material Accounting and Control

While the functional separation between the State level and the facility level may vary from State to State, in general the State level establishes the requirements and criteria for the SSAC and the facility operator implements the system in compliance with the State requirements and criteria. These technical requirements and criteria to be established are outlines in IAEA/SG/INF/2 and include the following:

1. Starting point, termination and exemption of accounting and control
2. Categorization of nuclear material
3. Material balance areas
4. Records and reports system
5. Measurement system
6. Nuclear material flow
7. Physical inventory taking
8. Shipper/receiver differences
9. Application of containment and surveillance measures
10. International transfers of nuclear material.

Ensuring Compliance

Assurance of operator compliance with the requirements and criteria established for an SSAC by the State Authority can be achieved only by a comprehensive audit and inspection programme2. Such a programme should have the following objectives:

1. ensure that the capability and performance of the facility SSAC satisfy the requirements and criteria established by the State Authority to meet the State’s international obligations as well as to meet national objectives for accounting for and control of nuclear material and

2. assure through verification by the State Authority that the accounting and control measures implemented by the facility operator are effective and to conclude that there has been no unauthorized removal or use of nuclear material.

Technical Support

Training of staff

Training of personnel responsible for accounting for and nuclear material, at State and facility levels, is critical for the successful operation of an SSAC. In many countries, first the State Authority needs to train its own staff, to be able to achieve its selected objectives. In this connection, much use can be made of the training courses, fellowships and scientific visits offered by the IAEA. When the training of the State Authority is completed, the facility personnel can also make use of the training courses offered by the IAEA at its Headquarters or in other Member States.

Technical Assistance to the Plant Operator

The State should facilitate the provision of adequate technical assistance, from external sources if necessary, to facility operators in the area of material accounting and control in order to enable the operator to fulfill the requirements placed on him by the State3. This assistance could, for example, help in establishing adequate records systems and measurement systems which may incorporate non-destructive assay techniques as well as data processing and analysis procedures. Assistance should be given also to acquire international standards and to establish containment and surveillance measures.

TECHNICAL REQUIREMENTS FOR NUCLEAR MATERIAL ACCOUNTING AND CONTROL SYSTEMS


The technical requirements of an SSAC will depend, among other things, on the types of nuclear activity and on the form and quantity of nuclear material. A State with extensive bulk handling facilities (enrichment, conversion, fabrication, reprocessing) should have a large SSAC including all of necessary requirements, while States with only research reactors or power reactors would not have such extensive requirements.

Starting point, termination and exemption of accounting and control

The Authority should consider the following:

1. the starting point for the application of accounting for and control of nuclear material should be at least as early in the nuclear fuel cycle as is required by the State’s international obligations;

2. accounting and control should be terminated on nuclear material upon determination under the State’s international obligations that the material has been consumed or has been diluted in such a way that it is no longer usable for any nuclear activity or has become practicably irrecoverable and

3. the conditions for exemptions from and termination of accounting and control should be specified, consistent with the State’s international obligations.

In the case of a Safeguards Agreement based on the Tlatelolco Treaty or the NPT, safeguards are not applied to material during mining or ore processing activities. When nuclear material of a composition and purity suitable for fuel fabrication or for isotopic enrichment leaves the plant or the process stage in which it has been produced, or is imported into the State, the nuclear material becomes subject to the full safeguards procedures specified in the Safeguards Agreement.

The provisions for termination and exemption of accounting and control are specified in the Safeguards Agreements4.

Categorization of nuclear material

Categorization of nuclear material should be established in order to enable an appropriate balance to be maintained among the significance of different materials. This categorization should consider characteristics such as the material type and isotopic composition (including in particular the content of fissile isotopes), the irradiation level and the measurement methods and uncertainties associated with the material. The categorization should be used, in conjunction with information on quantities of nuclear material involved, in specifying the intensity if accounting and control measures, including the taking of physical inventories and the determination of MUF. For example, plutonium and high enriched uranium could be in the highest category, followed by low enriched uranium, then natural uranium and finally depleted uranium and thorium.

Materials which can be converted to nuclear explosives without transmutation or further enrichment are defined as direct-use materials, while materials which must be enriched or transmuted to form direct-use materials are defined as indirect-use materials.

Direct-use materials include plutonium (all isotopes), uranium-233, uranium enriched to 20% or higher of the isotope uranium-235, and mixtures of these. Indirect-use materials include forms of uranium enriched to less than 20% uranium-235, thorium and mixtures of these. Categorization of nuclear materials is strongly related to the concepts of quantity of safeguards significance and conversion time.

Material Balance Areas

In order to organize a system of nuclear material accountancy, the concept of material balance area (MBA) is applied. An MBA is, exactly as its name would suggest, a physical area in which a balance of the nuclear materials can be made.

The SSAC should establish the factors to be taken into account and the criteria to be met in the determination of each MBA. This must include the Key Measurement Points (KMP), containment and surveillance possibilities (particularly to help ensure the completeness of flow measurement) and the accuracy with which the material balance can be established. The Authority should approve the facility MBAs. States which concluded a Safeguards Agreement with the IAEA based on INFCIRC/153 (e.g., Tlatelolco, NPT) should use a system of MBAs which is compatible with the system agreed in the Subsidiary Arrangements to the Safeguards Agreement between the IAEA and the State.

Records and Reports System

The Authority should establish the requirements for accounting and operating records and reports for each MBA to provide relevant data on nuclear material transactions and operations that affect the accounting for and control of nuclear material.

Accounting records - a set of documents kept at each nuclear facility, showing the quantity of each type of nuclear material present, its distribution within the facility and any changes affecting it. This includes the records showing measurement results.

Operating records - a set of documents kept at each facility consisting of organized data on the operation of the facility in connection with the use or handling of nuclear material. The operating records of a nuclear reactor show, for example, the integrated thermal power produced by the reactor for a given period and the associated data of the reactor operation for that period. The operating records of a bulk handling facility include quality control on the measurements.

Accounting report - a statement to the IAEA on the status of nuclear materials subject to safeguards in a defined environment and on the changes in that status since the previous report. Accounting reports are submitted by the State at times specified in the agreements or subsidiary arrangements.

For Tlatelolco and NPT safeguards three types of routine accounting reports for each MBA are called for: Inventory Change Reports (ICR), Material Balance Reports (MBR), Physical Inventory Listings (PIL).

Measurement System and Control

The Authority should establish requirements for a measurement system and measurement uncertainties, including provisions for the determination of nuclear material received, produced, shipped, lost or otherwise removed from inventory and for the determination of inventory quantities based on sampling and chemical or non-destructive analysis, as appropriate.

The measurement system includes personnel, procedures and apparatus used for accounting measurements and should provide for:

· Identification of the key measurement points in the process and the characteristics of the nuclear material to be measured;
· Specification of measurement performance desired;
· Specification of the measurement technique(s) to be employed;
· Equipment maintenance provisions and procedures;
· Operator’s qualifications and provision for training;
· Calibration standards and procedures;
· Routine measurement and data analysis procedures;
· Procedures to control the quality of measurements and to maintain performance at the desired level.

A measurement control programme is to be established with the objectives of ensuring that the routine operation of the measurement systems is adequate; that measurement components are re-calibrated at appropriate intervals; that random and systematic errors are properly estimated for propagation so that the limits of measurement uncertainties associated with any “material unaccounted for” (MUF) can be established; and that clerical errors are, as far as practicable, detected and corrected. The Agency’s technical conclusion depends, among other things, on these measurement uncertainties.

Nuclear Material Flow

The Authority should establish requirements, when relevant, for the accounting and control of the flows of nuclear material, taking into account the degree of assurance to be obtained from containment and surveillance measures. Requirements for measuring, including corresponding uncertainties, and for identifying receipts, shipments, and transfers within a facility should be defined as necessary to provide for periodic material balances.

Physical Inventory Taking

The physical inventory taking is the bench mark of nuclear material accounting and control since it provides conclusive evidence of the physical presence of the material.

The Authority should establish the requirements, including the completeness, frequency and allowable limits of measurement uncertainty, for the different categories of material, of the physical inventories to be taken by the facility operators, taking into account the degree of assurance to be obtained from containment and surveillance measures. Provisions should be made to notify the IAEA in advance of dates when physical inventories will be taken. Authority requirements for physical inventories should include:

1. a system of stratification of the nuclear material in the inventory;
2. criteria for accepting measurements already made, including provision for the use of seals to assure the validity of the previous measurements;
3. criteria for limiting the quantity of nuclear material in difficult-to-measure forms;
4. criteria for complete or partial clean-out of plants, including criteria to determine the degree of completeness of the clean-out required and methods to assure that those criteria are met and
5. criteria for taking of a special physical inventory in case, for example, unusually large MUF, an operating accident or unusual loss.

While the physical inventory taking provides the evidence of the physical presence of the nuclear material, the material balance based on this inventory permits the determination of whether significant losses or discrepancies have occurred undetected. It is usually immediately after the physical inventory taking (and verification) that the material balance will be “closed”. All data from all components of the material balance must be used, and all data must be based on measurements of known uncertainties, so that any discrepancy may be evaluated and meaningful conclusions reached.

Shipper/Receiver Differences

The difference between the quantity of nuclear material as stated by the shipping material balance area and as measured at the receiving material balance area is called the “shipper/receiver difference”. The Authority should:

1. establish the requirements for identifying, reviewing, evaluating and resolving differences in all shipper/receiver measurements and for deriving the limits of measurement uncertainty of transfers between MBAs within its control and

2. describe the procedures to be followed when shipper/receiver differences or their limits of measurement uncertainty exceed specified values.

Containment and Surveillance Measures

Containment and surveillance measures are necessary or convenient in some situations to enable the Authority, as part of its nuclear material control function, to monitor flows, to confirm the integrity of stores, and in general to detect when material present in an MBA or facility is removed without appropriate accounting action. When containment and surveillance or accountancy measures have failed or indicate possible unauthorized removal of nuclear material, the facility operator should be required to conduct a comprehensive investigation and to take appropriate corrective actions which may include re-measuring of corresponding inventories.

Review of the design of facilities permits the most cost effective combination of accountancy, containment and surveillance procedures, equipment and features of facilities to be determined. C/S measures will become more important for large facilities of the future where safeguards objectives cannot be realized exclusively through nuclear material accountancy measures.

International Transfers of Nuclear Material

The Authority should establish requirements for international transfer of nuclear material with time specifications on necessary arrangements for advance notifications, accounting and control responsibility, and reporting on nuclear material shipped and received.

There are some practical problems involved in international transfers especially from the international safeguards viewpoint of the IAEA. Two of these in particular are transfer of accounting and control responsibility and continuity of material identity.

States involved in international transfers should agree upon the point of the transfer of accountability and control responsibility. Shipping states will provide shipment identification, i.e. batch identity, which will be reported to the IAEA in ICRs. Receiving states should use this same identification in reporting receipt of the material in their ICRs even though the receiving state may use a different identity for domestic purposes. This will enable the IAEA to close the record on an international shipment.

ACKNOWLEDGMENT

This paper is based on previous documents on the same or similar subjects. Recently, sessions in a regional training course in Japan, 1995, addressed a similar subject: IAEA Requirements to SSAC, by K. Murakami, and: Principal Elements of an SSAC at State and facility-levels, by J. Hill.


REFERENCES

1. IAEA Safeguards Glossary, IAEA, Vienna, 1987, IAEA/SG/INF/1 (Rev. l )
2. Guidelines for States’ Systems of Accounting for and Control of Nuclear Material, IAEA, Vienna, 1980, IAEA/SG/INF/2
3. The Structure and Content of Agreements between the Agency and States required in connection with the Treaty on the Non-Proliferation of Nuclear Weapons, INFCIRC/153 (Corrected)
4. Systems of Accounting for and Control of Nuclear Material, IAEA Bulletin, Vienna, 1975


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1 The size, cost and type (i.e. manual or computer) of such a system will depend on the volume of information to be handled which will, in turn, depend on the type and variety of nuclear materials and facilities in a State. One measure that has been used in this context is the number of entry lines reported to the IAEA each year. This number is obtained by summing the lines in the relevant reports to the IAEA for a year (i.e. Inventory Change Reports and Physical Inventory Lists). A rough indication of the need for a computer system is that if the entry lines in the IAEA report are more than 10,000, some type of computer may be needed for effective data handling.

2 The objectives adopted by the State depends upon the degree that the State wishes to delegate accounting and control responsibilities. Some States, for example, may limit inspections to routine examination of records; others may integrate State inspection activity with those of the IAEA in order to minimize overall cost and maximize effectiveness of particular inspections; and others may elect to carry out an inspection program that provides independent assurance. Inspection activities associated with safety, radiation protection and construction might to some extent be coordinated with accounting and control inspections in order to minimize intrusiveness and cost and to improve effectiveness. In any case, the State should recognize that the IAEA includes both objectives in its inspection programmes and does conduct independent verification activities in its inspections as well as the initial design reviews. IAEA/SG/INF/2 provides some inspection activity guidelines to assist States in achieving both of the states objectives.

3 At the facilities which perform measurements related to safeguards objectives, especially measurements for nuclear material accounting for in bulk-handling facilities, considerable assistance to the operator may be necessary. Measurements and measurement control programmes at such facilities on which much of the success of the SSAC depends can be quite complex. Evaluation of SSAC programme results also can be complex. The IAEA has published several volumes of the Safeguards Technical Manual which could be of assistance to States and facility operators. In addition a series of Safeguards Technical Reports is being prepared to provide assistance in establishing SSACs at various types of facilities. Some of these documents are listed in the references.

4 See also paragraphs 11 and 13 of INFCIRC/153.

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