ML20009A112
| ML20009A112 | |
| Person / Time | |
|---|---|
| Issue date: | 05/12/1981 |
| From: | Sanders K NRC |
| To: | |
| References | |
| NUDOCS 8107080528 | |
| Download: ML20009A112 (14) | |
Text
ADVANCED INTERNATIONAL TRAINING COURSE
~
ON STATE SYSTEMS OF ACCOUNTING FOR L-AND CONTROL OF NUCLEAR MATERIALS April 27-May 12,1981 SESSION 6b:
NATIONAL SAFEGUARDS SYSTEM OPERATIONS AT A BULK-HANDLING FACILITY e-g3 9
DETAILS OF INTERNATIONAL MATERIAL CONTROL AND ACCOU; G {yr 4[.3
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W IW KENNETH E.
SANDERS U.S. NUCLEAR REGULATORY COMMISSION JUN25G315 i va u.s.,yua I.
PURPOSE
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c The State Authority is expected to establish the p'oropria national regulations for the nuclear material control and a'c5dd ting (MC&A) program.
(See Reference 1. )
These regulations take"Into account, of course, the requirements of a State's International Safe-guards Agreement with the IAEA and any applicable national laws.
The puipose of this paper is to provide an example of how one State Authority has fulfilled this responsibility by developing the national regulations necessary for implementing its International Safeguards Agreement with the IAEA.
Related State responsibilities regarding the national MC&A program are addressed in Session 6a.
In particular, this paper discusses the national regulations, for private sector nuclear ^ facilities in the U.S.,
that enable imple-mentation of the NPT-type U.S./IAEA Safeguards Agreemcnt.
Since the U.S./IAEA Safeguards Agreement corresponds, for the most part, exactly to INFCIRC/153 and most course participants are more familiar with INFCIRC/153, the regulations in Table 1 are referenced to INFCIRC/153, which is the general model for NPT-type Agreements.
This table shows how each article of INFCIRC/153 has corresponding U.S.
national regu-lations (Reference 2) which establish a system of nuclear material control and accounting for purposes of international safeguards and enable implementation of the international safeguards at nuclear facilities licensed by the U.S. Nuclear Regulatorv Commission (NRC).
It should be noted that related to these national regulations regarding international safeguards there are more detailed national regulations for national safeguards (Reference 4) for licensing, inspection, accounting, and controlling of special nuclear material.
These two sets of regulations ccmplement each other and are inter-related.
How the requirements for national safeguards are implemented by facility operators is addressed in Session 5.
II.
BACKGROUND Historically, the development of a comprehensive national MC&A program in the U.S. began about 10 years ago.
National MC&A regula-tions were developed by the NRC for comnercial facilities in the private sector.
These regulations (Reference 3) apply to special nuclear material.
8107080528 810512 PDR ORG EFGIAEA PDR
6b-2 With regard to international safeguards, the U.S.
as a party to the NPT, has actively joined with other nations in an effort to limit the spread of nuclear weapons.
The U.S. president signed the instru-ment of ratification of the U.S./IAEA Safeguards Agreement on July 31, 1980.
To encourage widespread adherence to the NPT by Non-Nuclear Weapon States (NNWS), the IAEA is being permitted to apply its safe-guards to nuclear activities in the U.S.
The instrument for applying IAEA safeguards in the U.S.,
i.e. the NPT-type U.S./IAEA Safeguards Agreement, entered into force on December 9, 1980.
National regula-tions enabling the U.S. NRC to implement this Agreement at facilities in the private sector entered into force December 24, 1980.
(The Department of Energy plays a role parallel to the NRC for DOE con-tractor facilities in the U.S.)
The IAEA has received the list of U.S.
facilities which are eligible for IAEA safeguards and has already selected three of them for the application of international safeguards.
The first IAEA ad hoc physical inventory verification in the U.S. was conducted at the end of March, 19 81, at a low enriched uranium bulk handling facility.
III.
O3JECTIVES OF THE STATE SYSTEF FOR ACCOUNTING AND CONTROL (SSAC)
An SSAC may have two distinct, but interrelated, objectives (1).
The SSAC national objective, for national safeguards, is addressed in Session 5.
The SSAC international objective is to provide the essen-tial basis for the application of IAEA safeguards, which in the case of the U.S.,
is pursuant to the U.S./IAEA Safeguards Agreement.
For borh objectives, the facility operators in the U.S.
are recuired to maintain certain material control and accounting (MC&A) procedures.
Many of these procedures contribute to the attainment of both object-ives.
Since the NRC has established a combined system to meet the two objectives, it is necessary to distinguish clearly those require-ments which are necessary for the application of IAEA safeguards.
Table 1 in this paper focuses attention to the national regulations and requirements that are appropriate te the SSAC's international objective.
IV.
SSAC AUTHORITY AND RESPONSIBILITIES In the U.S.,
the NRC historically has been designated as a U.S.
authority that has responsibilities for nuclear material accounting and control, as well as health and safety, physical protection, etc.
It has responsibilities for establishing provisions, or regulations, regarding the possession, transfer, or use of nuclear materials by the commercial operators in the U.S. private sector, taking into account the U.S. obligations under the U.S./IAEA Safeguards Agreement, and ensuring that the objectives related to MC&A are met.
The NRC also has responsibilities for serving as a point of contact in imple-menting the U.S./IAEA Safeguards Agreement with the IAEA, and for developing, approving and implementing MC&A procedures necessary to enable the U.S.
to discharge its obligations under the U.S./IAEA Safeguards Agreement.
In the NRC, these responsibilities are under-taken by the four main Offices for licensing, inspection, research, and standards development.
In particular, this includes authority for enforcement of the regulations, For example, the operator is required to promptly notify the NRC in the event that evaluation of accounting and control information suggests losses, unauthorized use or removal of nuclear material.
Penalties for non-compliance with this and other regulations for the MC&A program have been specified by the NRC.
i
y 6b-3 V.
BASIC ELEMENTS OF THE INTERNATIONAL MC&A PROGRAM The U.S./IAEA Safeguards Agreement, which conforms to INFCIRC/
153 (Reference 4), provides that "...the State shall establish and maintain a system of accounting for and control of all nuclear material subject to safeguards under the Agreement...", and "the Agency, in its verification, shall take due account cf the technical effectiveness of the State's system."
The basic elements of this system are identified in paragraph 32 of INFCIRC/153.
These eight elements, paraphrased below, are addressed by the NRC's national regulations (Reference 2) for implementing international safeguards:
1.
A measurement system for determination of the quantities of nuclear material transferred and on inventory; 2.
The evaluation and estimation of measurement uncertainty; 3.
Procedures for evaluating shipper / receiver differences; 4.
Procedures for taking a physical inventory; 5.
Procedures for evaluating unmeasured inventory and losses; 6.
A records and reports system showing the inventory and inventory changes for each material balance area; 7.
Provisions to ensure that the armounting procedures are being operated correctly; 8.
Procedures for submitting reports to the IAEA.
It is noted here that Safeguards Agreements conforming to INFCIRC/
66/Rev.
2, on the other hand, do not explicitly call for States to establish and maintain a system of accounting for and control of nuclear material.
(See Reference 5.)
However, the fact that it calls for agreement between the IAEA and the State on a " system of records" and a " system of reports" is considered to imply the need for a State svstem.
Thus, it is recogniced that the establishment of an SSAC can s'erve a useful purpose in all IAEA Safeguards Agreements, whether or not such a system is explicitly required.
VI.
NATIONAL REGULATIONS FOR IMPLEMENTI"G THE U.S./IAEA INTERNATIONAL SAFEGUARDS AGREEMENT Taking into account the requirements of the U.S./IAEA Safeguards Agreement, the NRC has established national regulations enabling the l
IAEA to implement its international safeguards for establishing in a timely f ashion whether there has been any diversion of significant quantities of nuclear material.
l Table 1 lists each article fror INFCIRC/153 which was used as a model for the U.S./IAEA~ Safeguards Agreement, which for the most part corresponds exactly to the model.
Articles in the national regula-tions (i.e.,
10 CFR Part 75) that correspond to the Safeguards Agree-ment articles and give force to the Agreement are listed in parallel by general heading and particular subject.
The 10 CFR 75 regulations (Reference 2) recently were developed as national requirements for purposes of international safeguards; whereas, other regulations (Reference 3) were originally developed as national requirements for domestic safeguards.
There is, however, a relationship between these two sets of national requirements.
In particular, many, but not all, of the material control and accounting procedures that already have been implemented far national safeguards in the U.S. will also be made use of for purposes of international safeguards.
This double use i
6b-4 b:comse appcrent upon detailed analysis of tho implemnntation of tha regulations for domestic safeguards.
It is expected to becoma clearer as more experience is gained with implementation of the new regula-tions for international safeguards.
In particular, the national regulations in 10 CFR Part 75 include requirements for the operator's MC&A program in the following areas:
1.
Starting point, termination, and exemption from MC&A requirements.
The regulations apply to all operators licensed to possess source or special nuclear material (SNM) at an installation identified on the U.S.
eligibility list.
Excluded from this list are mining and ore processing activities and activities having direct national security significance.
10 CFR 75.3 identifies specific types of nuclear material that may be exempted from the requirements.
This corresponds to the same types of nuclear material that may be exempted from IAEA safeguards in Nuclear Weapon States (NWS) with INFCIRC/153 type Agreements.
2.
Categorization of nuclear material.
10 CFR 75.22 requires that the records show for each material balance area a separate listing for each type of nuclear material, i.e., plutonium, enriched uranium, natural uraniun.. depleted uranium, and thorium (including isotopic composition for SNM).
3.
Material balance areas (MBAs).
10 CFR 75.11 requires operators to submit sufficient design information to enable the IAEA to determine MBAs and select strategic.pcints for key measurement points (EMPs) (for flow and inventory) and for application of contain ent and surveillance measures.
4.
Records system.
A system cf accounting and operating records is required by 10 CFR 75.21.
Further, the accounting records are required by 10 CFR 75.22 for each MSA to include the inventory changes, measurement results, source, and batch data.
- Whereas, the operating records are required by 10 CFR 75.23 for each MBA to l
include measurement data, calibration data, physical inventory i
taking procedures, and other actions.
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o.
Reports system.
The regulations in 10 CFR 75.33 through 10 CFR 75.36 identify requirements fcr the reporting forms and procedures for Inventory Change Reports (ICRs), Material Balance Reports (MBRs), Physical Inventory Listings (PILs), and Special Reports.
t I
6.
Measurement system.
Operators are required by 10 CFR 75.21 l
to establish, maintain, and follow written MCRA procedures, including a measurerent system for the determination of nuclear material transfer and inventory.
Procedures for evaluation of precision and accuracy of measurements and estimation of measurement uncertainty are required also.
7.
Nuclear material flow.
The measurement system, measurement uncertainty evaluation, requirements of 10 CFR 75.21(b) apply to nuclear material flow as well as nuclear material inventory.
6b-5 b
8.
Physical inventory taking.
10 CFR 75.21(b) (4) requires the operators to establish, maintain, and follow written MC&A procedures which include the frequency and taking of a physical inventory.
9.
Shipper / receiver differences.
10 CFR 75.21(b) (3) requires facility operators to establish, maintain, and follow written MC&A procedures for the identification, review, and evaluation of differences in shipper and receiver measurements.
a 10.
Material balance closing.
Using the required measurement system, the operating and accounting records are kept for each M3A (re 10 CFR 75. 22-23).
Accounting reports are also based on the MBA structure (re 10 CFR 75.33).
11.
Measurement Control.
10 CFR 75. 21(a)-(b) require operators to establish, maintain, and follow written MC&A procedures.
.This i
requirement. includes, in particular, a measurement system for nuclear i
material inventory and transfers.
It also includes the evaluation of reasurement precision and accuracy, estimation of measurement uncertainty, and evaluation of unmeasured inventory and losses.
In conjunction with this, operating reccrds are required by 10 CFR 75.23 to include calibration data for the measurement system, measure-ment quality control procedures, and random and systematic error estimates.
12.
Application of containment and surveillance.
Each licensee is required by 10 CFR 75.11 to submit sufficient design information to enable the determination and selecticn of containment and sur-veillance methods and techniques at appropriate strategic points.
In particular, these techniques migh; include, for example, use of seals.on items, containers, doors, e c., and the use of cameras during physical inventory verifications by the IAEA.
In the past, the IAEA has used these techniques to monitor nuclear material flows and to i
confirm the integrity of stered.
l 13.
International transfers of nuclear material.
10 CFR 75.43 rectires licensees to crovide to the NRC advance notification for l
ex5crts and imoorts as'well as domestic transfers between facilities l
in he U.S.
T'hese advance notifications must include information
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regarding notification time, sh:.pping arrangements, operator l
authorication, and reporting in:ormation such as material description anc quantity.
l VII.
ENFORCEMENT OF THE NATIONAL REGULATIONS BY THE SSAC Briefly, the NRC enforcement of 10 CFR 75 relies heavily on the functions identified earlier - information system, licensing, compliance, and technical support.
First, an SSAC information system has been established (jointly by NRC and Dept. of Energy) and is being maintained to handle the extensive information, reports, and other communications required by 10 CFR 75.
The information, etc.,
is provided by the operators per 10 CFR 75.6 and related sections.
cphis information is collected, processed, recorded, and prepared for internal evaluation as well as for submission to other organizations; e.g.,
to the IAEA to satisfy international obligations.
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6b-6 In particular, the NRC maintains a list of nuclear facilities eligible under.the US/IAEA Safeguards Agreement.
Facilities having f acility attachments ' (re 10 CFR 75. 8) and being inspected by the IAEA (re 10 CFR 75.42) have provided detailed design information (re 10 CFR 75.11), including extensive MC&A procedures, and continue routinely to provide accounting reports on nuclear material inventory and transfers.
Second, the NRC maintains a comprehensive licensing, audit, and inspection program to assure the operator's compliance with the regulations and to assure continued effectiveness of the SSAC.
such a program helps assure that each operator's capability and
~
performance for MC&A satisfies the requirements of the US/IAEA Safeguards Agreement.
Additional assurance is derived frcm indepen-dent verification at facilities by NRC inspectors that the MC&A measures implemented by the operators are effective.
These assurances contribute to the establishment by the IAEA, through its own indepen-dent verification activities, whether there has been any diversion of significant quantities of nuclear material.
Particular licensing and inspection activities re 10 CFR 75 include the following:
1.
Examination of the operator's design informaticn presented in the license application (re 10 CFR 75.8 and 10 CFR 75.11) in order to determine the capability of the applicant to perform the required MCIA functions.
License amendments are issued vis 1 vis the facility attachments.
I i
2.
Periodic insoections at t'he facilities to determine whether the operator's MC&A [rogram meets performance standards.
These may be performed during construction, start-up, or full operation and may include independent verification activities by the NRC.
3.
Evaluation of MC&A data routinely reported by the operators t
I to the NRC.
d "o secure compliance with 10 CFR 75, the NRC licensees may be subject to license modification, suspension or revocation (re 10 CFR 75.51).
Finally, the NRC has provided technical support to help develop and establish national (and international) standards and procedures for adequate measurement systems, non-destructive assay techniques, data processing, and data analysis techniques.
(It is also noted that the Dept. of Energy, in addition, has for many years undertaken extensive technical support and training in MC&A through its contractor laboratories.)
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6b-7 V.
REFERENCES 1.
IAEA Safeguards:
Guidelines for States' Systems of Accounting for and Control of Nuclear Materials, December 1980, IAEA/SG/INF/2.
2.
Title 10 of the U.S. Code of Federal Regulations, Part 75, Safeguards on Nuclear Material--Implementation of US/IAEA Agreement, Final Rule, Federal Register (45 FR 50705), July 31, 1980.
3.
Title 10 of the U.S. Code of Federal Reculations, Part 70, Domestic Licensing of Special Nuclear Material, Fiifal Rule, Federal Register.
4.
The Structure and Content of Agreements Between the Agency and States Required in Connection with the Treaty on the Nonproliferation of Nuclear Weapons, IAEA/INFCIRC/153 (corrected),
June 1972.
5.
The Agency's Safeguards System (1965, as provisionally extended in 1966 and 1968), INFCIRC/66/Rev. 2.
I
6b-8 TABLE 1: HPT AGREEMENI ARilCLES AND STAIL AulHORI' 'IGULA110NS INFCIRC/153 10 CFR 75 Article INFCIRC/153 Heading (-Subject)
Article 10 CFR 75 lleading Part I 1
Basic Undertaking Part 75 in toto (1)
(especially 75.1)
(Purpose) 2 Appilcation of Safeguards Part 75 in tota (1)
(especially 75 2 (Scope and and 75.41)
Designation) 3 Co-operation Between the Agency and the State 75.1 Purpose 75.2 Scope 75.42 Inspections 4
Implementation of Safeguards - interference (2) 5 Implementation of Safeguards - information protection (2), (7) 6 Implementation of Safeguards - IAFA ef fectiveness (2)
~ ft) 7 SSAC - establish and maintain Part 15 in toto (especially 75.1) i arpose) 8 Provirion of Information to the Agency 15.6 Delivery of Information, Reports, and Other Communications (R) 75.12(a)
Communication of Information to IAEA 75.12(b)
Communication of Information to IATA 75.14 Supplemental Information 75.37 Disclosure of Reports to IAEA (5) 9 Agency Inspectors - inspection 75.7 IAEA Representatives 75.;9 Verification 15.42 Inspections
- information protection 75.12(b)
Communication of Information to ;AEA (5), (7) 10 Privlieges and Immunities (9) 11 Termination of Safeguards - consumption or dilution 12 Termination of Safeguards - international transfers 75.43(b)
Circumstances Requiring Advance Notification (also 15.44)
(Timing of Advance Notification)
(also 75.45)
(Content of Advance Notificatien) 13 Termination of Safeguards - non-nuclear use 75.3(b)(2)
Exemptions 14 Non-Application of Safeguards (6)
-~
6b-9 l
TABLE 1: HPT AGREEMENT ARTICLES AND STATE AUTHORITY REGULA110NS INFCIRC/153 10 CFR 75 Article INFCIRC/153 Heading (-Subject)
Article 10 CFR 75 Heading 15 Finance 75.46 Expenses (21) 16 Third Party Liability for Nuclear Damage (10) 17 International Responsibility (11) 18 Verification of Non-Diversion - State action (2)
(2) 19 Verification of Non-Diversion - inability 20 Interpretation and Application of Argreement - consult 75.5 Interpretations 21 Interpretation and Application ni Agreement - requests 75.5 Interpretations 22 Interpretation and Application of Agreement - disputes 75.5 Interpretation 3
91 Final Clauses - amendments (12) 24 Final Clauses - suspension (13)
]
25 Final Clauses - entry into force (14) 2G final Clauses - duration j
Part II 27 Introduction - specify procedures Part 75 in toto (1) l 28 Objective of Safeguards - timely detection (2) 29 Objective of Safeguards - material accountancy; Part 75 in toto (1),(2) containment & surveillance 30 Objective of Safeguards - technical conclusions (2) 31 SSAC - used by IAEA (2) 32 SSAC - established measures 75.21(a)
Haterial Accounting and Control:
General Requirements (a) measurement system' 75.21(b)(1)
General Requirements (b) measurement uncertainty 75.21(b)(2)
General Requirements (c) shipper / receiver differences 75.21(b)(3)
General Requirements (d) physical inventory 75.21(b)(4)
General Requirements (e) unmeasured inventory and losses 75.21(b)(5)
General Requirements (f) reports and records system 75.21(b)(6)
General Requirements (g) accounting procedures 75.22 Accounting Records (h) reporting to IAEA 75.31 Reports: General Requirements q.;
n.
j
6b-10 TABLE 1: NPT AGRFEMFNT ARTICtFS AND STATE Ailill0RITY RFGtil ATIONS INFCIRC/153 10 CFR 75 Article INFCIRC/153 ileading (-Subject)
Article 10 CFR 75 lleading 33 Starting Point of Safeguards - mining and ore processing 75.2(b)(2)
Scope 34 Starting Point of Safeguards - transfers 75.2(b)(1) & (2)
Scope 75.41 Designation 35 Termination of Safeguards 75.41 Designation 36 Exemptions from Safeguards - use 75.3(b)(l')-(3)
Exemptions 37 Exemptions from Safeguards quantity 75.3(a)
Exemptions 38 Exemptions from Safeguards - mixed (7)
(24) 39 Subsidiary Arrangements - detailed 75.8(a)-(e)
Facility Attachments (22) 40 Subsidiary Arrangements - entry into fore.e (4) 41 Inventory - unified by IAEA (2) 42 Design Information provided 75.11(a)
Installation Information (5) 43 Design Information - specified 75.11(b)
Installation Information (5) 44 Design Information other information 75.14 Su;)plemental Information (5) 45 Design Information - modifications 75.11(c)
Installation Information (5) 46 Design Information purposes 75.11(d)
Installation Information (5) 46(b)(iv)
Design Information - special MBA 75.11(b)(4)
Installation Information (5) 47 Design Information re-examination (2) 48 Design Information - verification 75.13(a)-(c)
Verification (5) 49 Information Outside of facilities (6) 50 Information Outside of facilities (6) 51 Records System - MBA 75.22(a)
Accounting Records 75.23 Operating Records 52 Records System - examination 75.42(d)(1)
Inspections l
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6b-11 TADtt 1: HPT AGPI(MLNI ARTICLES AND SIAIL AUINORIIY REGULATIONS INFCIRC/153 10 CFR 75 Article INFCIRC/153lieading(-Subject)
Article 10 CFR 75 lleading 53 Records System.- retention 75.24 Retention of Records 54 Records System - accounting and operating 75.2i(b)(6)
Haterial Accounting & Control:
General Requirements 55 Records System - measurements basis (23) 56 Accounting Records each MBA 75.22(a)
Accounting Records (a) Inventory changes 75.22(a)(1)
Accounting Records (b) measurement results 75.22(a)(2)
Accounting Records (c) adjustments & corrections 75.22(a)(3)
Accountino Records 57 Accounting Records -
- batch / source data 75.22(b)
Accounting Records
- dates /MBAs 75.22(c)(1)-(2)
Accounting Records 50 Operating Records -
15.23 Operating Records (a) chanqcs 75.2.1(a)
Operating Records (b) calibrations, etc.
15.23(b)
Operating Records (c) pli procedures 15.23(c)
Operating Records (d) Inss actions
- 75. 71(d)
Oparating Records 59 Reports System provided to IAIA 15.31 Repnrts: General Requirements 75.71 Di< closure of Reports to IAFA 60 Reports System - in English 61 Reports System - based on records 75.31 Reports: General Requirements 62 Accounting Reports - initial 75.31 Reports: General Requirements 75.32(a)-(c)
Initial Inventory Report 63 Accounting Reports -
(15)
(a) inventory chanqe reports 75.11(a)(1) and (b) Arrountinq Reports (b) material balance reports IS.33(a)(2) and (b) Accounting Reports 15.35(h)
Haterial Status Reports 64 Accounting Reports - inventory change reports 75.34(a)-(5)
Inventory Change Reports (16) 65 Accounting Reports - inventory changes 75.34(a)-(b)
Inventory Change Reports (16) 66 Accounting Reports - :emi annual (2) 67 Accounting Reports entries 75.35(a)
Haterial Status Reports 68 Accounting Reports - special reports 75.36 Special Reports w.
6b-12 TABLE 1: NPI AGR((f t[Ni ARilCLES AND SIAlf Allill0RilY REGULAIIONS INFCIRC/153 10 CIR 75 Article INFCIRC/153lleading(-Subject)
Article 10 CFR 75 Ifeading 69 Ampitfication and clarification of Reports 75.31 Reports: General Requirements 70 Inspections general 75.42(a)-(h)
Inspections 71 Inspections - ad hoc (a) initial report 75.42(c)(1)
Inspections (b) changes 75.42(c)(1)
Inspections (c) transfers 75.42(c)(2)
Inspections 72 Inspections - routine 75.42(c)(3)
Inspections 73 Inspections - special 75.4?(c)(4)
Inspections 74 Inspections - scope 75.42(d)(1),(3),(5) Inspections (17) 75.42(e)(2) 75 Inspections - scope 75.42(d)(2)
Inspections (17) 75.4?(d)(4)-(5)
In'.pections (11)
IS.42(e)(1)-(2)
Inspections (11) 76 Inspections - access (a) ad hoc 15.42(c)(1)
Inspections (b) ad hoc 75.42(c)(2)
Inspections (c) routine 75.47(c)(3)
Inspections (d) unusual circumstances 77 Inspections - access (special) 75.42(c)(4)
Inspections 78 Inspections - frequency and intensity (2) 79 Inspections - frequency and intensity (2) 80 Inspections - frequency and inten<ity (2) 81 Ins' actions - frequency and intensity (18)
~
82 Inspections - frequency and intensity (10) 83 Notice of Inspections - Advanced 75.42(h)
Inspect'ons 84 Notice of Inspections - Unannounced 75.42(h)
Inspections 85 esignation of Inspectors (2), (3) 86
.ssignation of Inspectors (3)
6b-13 TABLE 1: HPT AGREEMENI ARilCLES AND STATE AUlil0R11Y REGUl'.TIONS INFCIRC/153 10 CFR 75 Article INFCIRC/153 lleading (-Subject)
Article 10 CFR 75 lleading 87 Conduct & Visits of Inspectors - direct operation (19) 88 Conduct & Visits of Inspectors - services (3),(19) 89 Conduct & Visits of Inspectors - escort 75.42(g)
Inspections 90 Agency's Statements (2) 91 International Transfers - exports and imports (3), (20) 92 International Transfers - exports 15.43(a)-(b)
Circumstances Requiring Advance Notification (20) 93 International Transfers - exports (2),(20) 94 International Transfers - exports (3),(20)
?
95 International Transfers - imports 75.43(a) and (c)
Circumstances Requiring Advance Notification (20) 96 International Transfers - imports (2), (20) 97 Internatinnal Transfers -losses 75.3ri(c)(1)
Special Reports98-116 Definitions 75.4(a)-(r)
Definitions Footnotes (1)
Title:
"Part 75 - Safeguards on Nuclear Material - Implementation of US/X AEA Agreement," final Rule, 31 July 1980.
(2) This is an obligation of the IAEA.
(3) This is an obligation of the State Authorities.
(4) See US/IAEA Argreement for specific schedule.
(5) See also articles 40.31(g), 50.78, 70.21.
(6) Due to the nature of the Volundary Offer by the U.S. as a NWS, there is no corresponding article in US/IAEA Agreer'nt.
(7) See, for example, 10 CFR 95, " Security facility Approval & Safeguarding of National $ecurity Information & Restricted Data," Final Rule.
(8) See referenced articles:
75.7, 8, 11, 12, 13, 14, 31, 32, 34, 35, 36, 42, 43, and 44.
e.
6h-14 I Anl E 1: HPI AGRIlit[HI AR11Cl[S AND SIAL [ Atilit0RI1Y RIGtH All0NS F:otnotes (continued)
(9) See INFCIRC/9/Rev. 2 and International Organization Immunities Act of the U.S.
(10) See the Price-Anderson Act of the U.S.
(11) There is recourse to international law.
(12) Regulations (e.g. 10 CIR 75) may be correspondingly amended.
(13) See, for example, USA / Japan /IAEA Safeguards Transfer Agreement (IAEA INFCIRC/119).
(14) 10 CFR 75 enters into force the same date that the US/IAEA Agreement enters into force.
(15) See also articles 40.64, 70.53, 70.54.
(16) See also articles 40.64(e), 70.53(a), & 70.54.
(17) In particular:
INFCIRC/153 10 CFR 75.42 74[5]
(d)(1) 74(b)
(d)(5) 74(c)
(d)(3) 74(d)
(d)(5), (3) (2)(i)-(ii) 74(c)
(e)(2) 75(a)
(d)(4) 75(b)
(d)(2) j 75(c)(1)
(e)(2)(lii) 75(c)(li)
(e)(2)(iv) 75(c)(lii)
(e)(2)(v) 75(c)(iv)
(e)(2)(vi) 75(d)
(d)(5), (e)(2)(1) 75(e)
(e)(2)(li) 75(f)
(e)(1)
(18) Details are negotiated between the IAEA and the State Authorities.
(19) Note, hownser, article 75.42(f).
(20) for the US/IAEA Agreement, in particular, see INFCIRC/207.
(21) See also article 170.ll(a)(10).
(22) See also Subsidiary Arrangements for US/IAEA Safeguards Agreement.
(23) See 10 CFR 70.57, Heasurement Control Program for Special Nuclear Materials Control and Accounting."
(24) This situation does not exist under US/IAEA Agreement.
s?i
,y