REGDOC-2.13.1, Safeguards and Nuclear Material Accountancy

Preface

This regulatory document is part of the Canadian Nuclear Safety Commission’s (CNSC) safeguards and non-proliferation series of regulatory documents. The full list of regulatory document series is included at the end of this document and can also be found on the CNSC’s website.

Regulatory document REGDOC-2.13.1, Safeguards and Nuclear Material Accountancy, sets out requirements and guidance for safeguards programs for applicants and licensees who possess nuclear material, carry out specified types of nuclear fuel-cycle related research and development work, or carry out specified types of nuclear-related manufacturing activities. The requirements and guidance in this document are essential to Canadian compliance with the safeguards agreements entered into with the International Atomic Energy Agency (IAEA), and are consistent with modern national and international practices.

This document supersedes RD-336, Accounting and Reporting of Nuclear Material, and GD-336, Guidance for Accounting and Reporting of Nuclear Material, which were both published in June, 2010.

REGDOC-2.13.1 is intended to form part of the licensing basis for a regulated facility or activity within the scope of the document. It is intended for inclusion in licences as either part of the conditions and safety and control measures in a licence, or as part of the safety and control measures to be described in a licence application and the documents needed to support that application.

For new applicants: This document will be used to assess new licence applications.

Guidance contained in this document exists to inform the applicant, to elaborate further on requirements or to provide direction to licensees and applicants on how to meet requirements. It also provides more information about how CNSC staff evaluate specific problems or data during their review of licence applications. Licensees are expected to review and consider guidance; should they choose not to follow it, they should explain how their chosen alternate approach meets regulatory requirements.

For existing licensees: The requirements contained in this document do not apply unless they have been included, in whole or in part, in the licence or licensing basis.

A graded approach, commensurate with risk, may be defined and used when applying the requirements and guidance contained in this regulatory document. The use of a graded approach is not a relaxation of requirements. With a graded approach, the application of requirements is commensurate with the risks and particular characteristics of the facility or activity.

An applicant or licensee may put forward a case to demonstrate that the intent of a requirement is addressed by other means and demonstrated with supportable evidence.

Important note: Where referenced in a licence either directly or indirectly (such as through licensee-referenced documents), this document is part of the licensing basis for a regulated facility or activity.

The licensing basis sets the boundary conditions for acceptable performance at a regulated facility or activity, and establishes the basis for the CNSC’s compliance program for that regulated facility or activity.

Where this document is part of the licensing basis, the word "shall" is used to express a requirement to be satisfied by the licensee or licence applicant. "Should" is used to express guidance or that which is advised. "May" is used to express an option or that which is advised or permissible within the limits of this regulatory document. "Can" is used to express possibility or capability.

Nothing contained in this document is to be construed as relieving any licensee from any other pertinent requirements. It is the licensee’s responsibility to identify and comply with all applicable regulations and licence conditions.

1. Introduction
2. Nuclear Material Classification
- 2.1 Group 1 material
  - 2.1.1 Group 1A material – Full-scope safeguards
  - 2.1.2 Group 1B material – Exemption from safeguards
- 2.2 Group 2 material – Ore concentrates
3. Categorization of Licensees
4. Safeguards Program
5. Safeguards Equipment and Seals
6. International Atomic Energy Agency Access
7. Nuclear Material Accountancy
8. Provision of Information
9. Retention of Records
Appendix A: List of Declarable Nuclear-Related Manufacturing Activities
Appendix B: List of Nuclear Fuel Cycle-Related Research and Development Activities
Appendix C: Guidance on Materials Not Subject to Safeguards
Appendix D: Nuclear Material Accountancy Reference Tables
Glossary
References

1. Introduction

The Treaty on the Non-Proliferation of Nuclear Weapons (NPT) [1] is the cornerstone of the global nuclear non-proliferation regime. States that are party to the NPT have commitments and obligations in the areas of non-proliferation, disarmament, and the peaceful use of nuclear material and technology.

To fulfil commitments made under the NPT, Canada has concluded binding safeguards agreements with the International Atomic Energy Agency (IAEA), which provide for the application of IAEA safeguards in Canada. Under the safeguards agreements, Canada has an obligation to report to the IAEA on all nuclear material and on certain types of nuclear research and manufacturing in Canada, and to accept IAEA inspections of those areas.

Under the Nuclear Safety and Control Act (NSCA), the Canadian Nuclear Safety Commission (CNSC) has the mandate to achieve Canadian conformity with these agreements. To do so, the CNSC imposes obligations on its licensees for reporting required by the IAEA and for the access necessary for IAEA verification of this reporting.

(i)	the manufacture of centrifuge rotor tubes or the assembly of gas centrifuges for use in isotopic separation processes
(ii)	the manufacture of gaseous diffusion barriers for use in isotopic separation processes
(iii)	the manufacture or assembly of laser-based systems for isotopic separation
(iv)	the manufacture or assembly of electromagnetic isotope separators
(v)	the manufacture or assembly of columns or extraction equipment especially designed or prepared for use in isotopic separation systems using chemical exchange or ion exchange
(vi)	the manufacture of aerodynamic separation nozzles or vortex tubes for use in isotopic separation processes
(vii)	the manufacture or assembly of uranium plasma generation systems
(viii)	the manufacture of zirconium tubes
(ix)	the manufacture or upgrading of heavy water or deuterium
(x)	the manufacture of nuclear grade graphite, having a purity level better than 5 parts per million boron equivalent and with a density greater than 1.50 g/cm³
(xi)	the manufacture of flasks for the transportation and/or storage of irradiated fuel
(xii)	the manufacture of reactor control rods
(xiii)	the manufacture of criticality safe (e.g. small diameter, annular or slab) tanks and vessels.
(xiv)	the manufacture of irradiated fuel element chopping machines
(xv)	the construction of hot cells, meaning a cell or interconnected cells outfitted with equipment for remote operations, totalling at least 6 m³ in volume, and with shielding equal to or greater than the equivalent of 0.5 m of concrete with a density of 3.2 g/cm³ or greater

**Table D1: Reporting frequency for nuclear material accountancy reports**
Report type	Group 1 material		Group 2 material
Report type	1A	1B	Group 2 material
Inventory change document (ICD)	Next business day following the inventory change^{Footnote 1}
General ledger	For facilities: By the seventh business day after the end of the reporting month, only in months in which an inventory change occurred	Not required	Not required
Split general ledger (for months in which a physical inventory taking [PIT] occurs but where the PIT date is not the end of the month)	For facilities: First report: by the seventh business day after a PIT is conducted, only if an inventory change occurred in the period between the beginning of the month and the PIT date For facilities: Second report: by the seventh business day after the end of the reporting month, only if an inventory change occurred in the period between the PIT date and the end of the month	Not required	Not required
List of inventory items	Required to be submitted by the seventh business day after a PIT, or upon the CNSC’s request	Upon request by the Canadian Nuclear Safety Commission (CNSC)	Not required
Physical-KMP inventory summary	Required to be submitted by seventh business day after a PIT	Not required	Not required
Obligated material inventory summary	Annually on January 31 for any year in which foreign-obligated material was possessed, and upon the CNSC’s request
Reconciliation statement	Required to be submitted by the seventh business day after a PIT	Not required	Not required

**Table D2: Labels and data elements used in nuclear material accountancy reports**
Label	Data element	Applicable reports	Description^{Footnote 2}
N/A	Report type	Inventory change document (ICD)	Enter the report type for the inventory change; there are six options: internal, domestic, import, export, retransfer, and from holding account.
N/A	Licensee reference no.	ICD, Physical-key measurement point inventory summary (P-KMPIS)	Optionally enter a licensee reference number.
N/A	Location identification (LOC ID)	ICD	If applicable, enter the LOC ID provided by the Canadian Nuclear Safety Commission (CNSC).
N/A	Tracking identifier	ICD	Enter tracking identifier provided by the CNSC when reporting exempted/de-exempted material.
N/A	Facility name	General ledger (GL), list of inventory items (LII), obligated material inventory summary (OMIS), reconciliation statement (RS)	Enter the facility name.
N/A	Revision date	GL, LII, OMIS, RS	Enter the date the report is first issued or is revised.
015	Reporting period/date	GL, LII, P-KMPIS, OMIS, RS	GL: 1. FROM: the date of the first day of the ledger, usually the first day of the month 2. TO: the date of the last day of the period, usually the last day of the month (If a physical inventory taking (PIT) is conducted on any day other than the last of the month, split GLs are required, one covering the period from the 1st of month to the PIT date, and one covering the day after the PIT date to the last of the month.) LII, P-KMPIS, and RS: Enter the PIT date. OMIS: 1. FROM: the first day of the calendar year and 2. TO: the last day of the calendar year
207	Facility code	GL, LII, OMIS, RS	Enter the appropriate code for the reporting facility or location outside facility; codes are available on the CNSC website.
307	Material balance area (MBA) code	GL, LII, P-KMPIS, OMIS, RS	Enter the appropriate code for the reporting facility or location outside facility; codes are available on the CNSC website.
309	Entry status	ICD, P-KMPIS	Use "N" for a new report, "C" to correct a previous report, and "D" to delete a previous report. ICD: Use "U" when reporting the following inventory change codes: L+, L-, R+ and R-.
370	MBA/country code/facility code from	ICD, GL	Enter the code for the shipping MBA for domestic transfers and the country code for imports. For domestic shippers who do not have an MBA code, enter "NA". Codes are available on the CNSC website. ICD: The facility code is optional (foreign facility codes are provided by the CNSC).
372	MBA/country code/facility code to	ICD, GL	Enter the code for the receiving MBA for domestic transfers and the country code for exports; for an internal inventory change, enter the MBA reporting the change; for domestic receivers who do not have an MBA code, enter "NA". Codes are available on the CNSC website. ICD: The facility code is optional (foreign facility codes are provided by the CNSC).
407	Key measurement point (KMP) code	ICD, GL, LII, P-KMPIS	For this label there are two fields to complete, one for the shipper and one for the receiver; flow-KMP and physical-KMP codes are specified in the design information for facilities and locations outside facilities. In all other cases, codes are provided by the CNSC. ICD: Enter the appropriate code: For transfers between MBAs, the shipper enters their flow-KMP code under the shipper’s name and the receiver enters their flow-KMP code under the receiver’s name. The shipper/receiver also enters the physical-KMP code for transfers involving the Canada location outside facility. Such entities are listed on the CNSC website. For internal inventory changes, enter the flow-KMP in the internal/receiver field, and For movements of Group 1B or Group 2 material, use "2" for the shipper and "1" for the receiver. LII: Enter the physical-KMP code where the item resides at the date of the PIT. P-KMPIS: List each physical-KMP for the reporting MBA.
411	Inventory change code	ICD, GL	For shipments/receipts, the shipper and receiver each enter the applicable inventory change code, in the appropriate field. For internal inventory changes, the initiating MBA enters the applicable code in the receiver’s field. Inventory change codes are listed in Table D3.
412	Shipped date and internal/received date	ICD, GL	Enter the date on which the inventory change occurred or was established. ICD: Use the internal/receiver field when reporting internal inventory changes.
430	Material description code (MDC)	ICD, LII, P-KMPIS	This label consists of a four character code indicating the physical and chemical form, type of container, and irradiation status of the material. Enter the code using Table D4; each batch can have only one MDC.
436	Chemical and physical description	ICD	Enter a textual description of the batch of material (maximum 100 characters).
446	Batch name (internal/receiver inventory changes)	ICD, GL, P-KMPIS	Enter the batch name in alphanumeric format (up to 16 characters). ICD and GL: This label is used for reporting batch names related to receipts and internal inventory changes. When reporting a receipt, the batch name can be either one assigned by the receiver or the same one used by the shipper as reported in label 447. If the inventory change code in label 411 is "DI" (shipper/receiver difference), and the batch name is the same as that reported in label 446 for the original ICD receipt. P-KMPIS: For each physical-KMP, enter batch names covering all material present at the time of a PIT.
447	Shipper’s batch name (shipper inventory changes)	ICD, GL	The batch name is entered in alphanumeric format, up to a maximum of 16 characters. This label is used for reporting batch names related to shipments. For imports, enter the foreign shipper’s batch name or enter the keyword "unknown".
469	Measurement basis code	ICD, LII, P-KMPIS	Enter the appropriate measurement basis code to describe where the mass has been determined, and whether or not it has been reported previously. Measurement basis codes are listed in Table D6.
470	Number of items	ICD, GL, LII, P-KMPIS	ICD and GL: Enter the number of items involved in the inventory change. LII: If more than one item is included on the line entry, enter the total number. In the case of bulk material, and generally when a number would not be meaningful, the number "1" should be placed in label 470. The label cannot be left blank. P-KMPIS: Enter the total number of items for each batch of items.
610	Element weight – natural uranium	ICD, GL, LII, P-KMPIS, OMIS, RS	Report the element weight of each category of nuclear material in the item or batch, with not less than one decimal place and up to six decimal places. ICD: Enter the element weight of the item or batch, subdivided by countries of origin if applicable (see label 2003). LII: Enter the element weights of individual items. P-KMPIS: Enter the element weight for each batch. RS: Enter the element weights for BE, taken from the ending balance of the GL, which ends on the PIT date, and the element weights for the physical ending inventory (PE), taken from the totals of each element as reported on the P-KMPIS or LII. OMIS: Enter the opening and ending balances for each element by country of obligation.
620	Element weight – depleted uranium	ICD, GL, LII, P-KMPIS, OMIS, RS	See description for label 610.
630	Element weight – enriched uranium	ICD, GL, LII, P-KMPIS, OMIS, RS	See description for label 610.
640, 660, 670	Isotope weight – enriched uranium	ICD, GL, LII, P-KMPIS, OMIS, RS	Report the isotope weight of each category of nuclear material in the item or batch, with not less than one decimal place and up to six decimal places. ICD: Enter the isotope weight of the item or batch, subdivided by countries of origin if applicable (see label 2003). LII: Enter the isotope weights of individual items on the LII. P-KMPIS: Enter the isotope weight for each batch. RS: Enter the element weights for BE, taken from the ending balance of the GL, which ends on the PIT date, and the element weights for PE, taken from the totals of each element as reported on the P-KMPIS or LII. OMIS: Enter the opening and ending balances for each element by country of obligation.
700	Element weight – plutonium	ICD, GL, LII, P-KMPIS, OMIS, RS	See description for label 610.
800	Element weight – thorium	ICD, GL, LII, P-KMPIS, OMIS, RS	See description for label 610.
1000	Line number	GL	Number each line entry consecutively with an integer. The first line number is "0" (zero) and the opening balance is reported on that line. The ending balance for the reporting period is reported on the last line.
1001	Item identification (item ID)	LII	Enter the item ID for individual items. For example, bundle serial number, drum number, or source serial number.
1002	Corrections – previous date	GL	For corrections, enter the date that the ICD being corrected was originally reported or the date of the most recent correction to it.
1003	Corrections – line number	GL	In the case of corrections, enter the line number of the general ledger on which the original ICD, or the most recent correction to it, was reported.
1004	Comments/remarks	ICD, GL, LII, P-KMPIS, OMIS	Enter any additional information to explain or assist in identifying the batch or items reported, as applicable. Use a maximum of 2000 characters.
1006	Element code	ICD, GL, LII, P-KMPIS	Enter the appropriate element code for the material on the report, from Table D5.
1020	Safeguards status	ICD, P-KMPIS	Enter the safeguards status of the material. Label 1020 has 4 options: "1A" for Group 1A material, "2" for Group 2 material, "Exempt U" for material exempted from safeguards under Article 36 of the Safeguards Agreement, and "Exempt Q" for material exempted from safeguards under Article 37 of the Safeguards Agreement.
1021	Correction/report revision no.	ICD, GL, LII, P-KMPIS, OMIS, RS	Enter "0" for original reports and increase the number by 1 for each subsequent report.
1023	Units	ICD, GL, LII, P-KMPIS	Enter the appropriate weight unit for the element/isotope reported. Units for reporting shall be in grams for enriched uranium (both element and isotope weights) and plutonium, and in kilograms for natural uranium and thorium, and depleted uranium.
1024	Isotope code	ICD, GL, LII, P-KMPIS	Enter the appropriate isotope code for the material on the report, from Table D5. Isotope codes are only reported for enriched uranium.
1025	Unique identifier (optional)	ICD, GL, LII	Optionally enter batch or item identification information such as the lot number or storage location. This data is intended to supplement that supplied under labels 446, 447 or 1001. Use a maximum of 20 characters.
1027	Shipper company	ICD	Enter the company name, contact name and address of the shipper.
1028	Internal/receiver company	ICD, P-KMPIS	Enter the company name and contact name. ICD: Additionally enter address of receiver or the initiator of an internal inventory change.

**Table D3: Inventory Change Codes**
Keyword	Code	Explanation	Internal Inventory Change?	Applicable Material Groups
Accidental gain	GA	Nuclear material unexpectedly found to be present in the Material Balance Area (MBA). GA cannot be used for material unexpectedly detected in the course of a Physical Inventory Taking (PIT) – in that case, the found material must be reported as ID.	Yes	Group 1A
Accidental loss	LA	Irreversible and inadvertent loss of a known quantity of nuclear material. LA cannot be used for material unexpectedly found to be missing in the course of a PIT – in that case, the missing material must be reported as inventory difference (ID).	Yes	Group 1A
Category change	DE DN ED EN ND NE	Quantity of uranium that has changed category as a result of blending, enrichment, depletion, or burn-up. The first letter denotes the original category, the second letter the resulting category: (E = enriched, N = natural, D = depleted uranium).	Yes	Group 1A
De-exemption quantity	DQ	Reapplication of safeguards on Group 1B material previously exempted from safeguards under Article 37 of the Safeguards Agreement.	Yes	Group 1B
De-exemption use	DU	Reapplication of safeguards on Group 1B material previously exempted from safeguards under Article 36 of the Safeguards Agreement.	Yes	Group 1B
Exemption quantity	EQ	Exemption of Group 1A material from safeguards under Article 37 of the Safeguards Agreement. This code can only be used with advance permission from the Canadian Nuclear Safety Commission (CNSC) and the International Atomic Energy Agency (IAEA), obtained by submitting the form found on the CNSC website.	Yes	Group 1A
Exemption use	EU	Exemption of Group 1A material from safeguards under Article 36 of the Safeguards Agreement. This code can only be used with advance permission from the CNSC and IAEA, obtained by submitting the form found on the CCNSC website.	Yes	Group 1A
Measured discard	LD	Loss of a measured or estimated quantity of nuclear material that has been consumed or disposed of in such a way that it is not suitable for further nuclear use.	Yes	Group 1A
Nuclear loss	LN	Consumption of nuclear material due to its transformation into other elements or isotopes as a result of nuclear reactions.	Yes	Group 1A
Nuclear production	NP	Production of plutonium-239 or uranium-233 in a nuclear reactor.	Yes	Group 1A
Receipt domestic	RD	A receipt of nuclear material from a domestic shipper.	No	Group 1, Group 2
Receipt foreign	RF	A receipt of nuclear material imported into Canada.	No	Group 1A, Group 2
Receipt at starting point	RS	A receipt of nuclear material at the starting point of detailed nuclear material accountancy.	Yes	Group 1A
Re-batching – decrease in batch content	RM	Quantity by which the batch mentioned in the entry is diminished due to re-batching.	Yes	Group 1A
Re-batching – increase in batch content	RP	Quantity of material added to the batch mentioned in the entry from another batch due to re-batching.	Yes	Group 1A
Retained waste – transfer to	TW	The transfer of Group 1A material to retained waste, after receipt of approval from the CNSC and IAEA. Material to be designated as retained waste must contain nuclear material which is unrecoverable, and it must be stored separately from other nuclear material. Material designated as retained waste remains Group 1A material but is not subject to routine IAEA verification and so must not appear on the list of inventory items (LII) or Physical-key measurement point inventory summary (P-KMPIS) for the storing MBA. A separate LII covering only retained waste must be available on CNSC request. Material designated as retained waste cannot be processed or transferred out of the MBA, without first being transferred back from retained waste.	Yes	Group 1A
Retained waste – transfer from	FW	Transfer of material that had been stored as retained waste back to the main Group 1A material inventory. Such material once again becomes subject to routine IAEA verification and so must be included on the LII and P-KMPIS of the storing MBA.	Yes	Group 1A
Shipment domestic	SD	A shipment of nuclear material to a domestic receiver.	No	Group 1, Group 2
Shipment foreign	SF	An export of nuclear material out of Canada.	No	Group 1A, Group 2
Shipper-Receiver Difference	DI	Difference between the quantity reported by the shipper and the quantity measured by the receiver. DI should only be reported in cases where the shipper and receiver cannot agree on revising the weight of the shipment. Only the receiver can report DI. DI = (shipper's declared weight) – (receiver's measured weight)	Yes	Group 1A
Termination	TU	Termination of safeguards on nuclear material which has been consumed or diluted in such a way that it is no longer useable for any nuclear activity, or has become practicably irrecoverable. This code can only be used with advance permission from the CNSC and IAEA.	Yes	Group 1A
Positive ID	L-	To report a positive ID. In label 309, use "U" when using this code.	Yes	Group 1A
Negative ID	L+	To report a negative ID. Use the absolute value of ID, i.e. enter the negative ID as a positive value on the inventory change document (ICD). In label 309, use "U" when using this code.	Yes	Group 1A
Rounding	R+	To report rounding up. In label 309, use "U" when using this code.	Yes	Group 1A
Rounding	R-	To report rounding down. Use the absolute value, i.e. enter the rounding down as a positive value on the ICD. In label 309, use "U" when using this code.	Yes	Group 1A

REGDOC-2.13.1, Safeguards and Nuclear Material Accountancy

Preface

Table of Contents

1. Introduction

1.1. Purpose

1.2. Scope

1.3. Relevant legislation and obligations

1.3.1 Legislation and regulations

1.3.2 International Atomic Energy Agency safeguards agreements

2. Nuclear Material Classification

2.1 Group 1 material

2.1.1 Group 1A material – Full-scope safeguards

2.1.2 Group 1B material – Exemption from safeguards

2.2 Group 2 material – Ore concentrates

3. Categorization of Licensees

3.1 Facilities

3.2 Locations outside facilities

3.3 Other licensees

4. Safeguards Program

Guidance

5. Safeguards Equipment and Seals

Guidance

6. International Atomic Energy Agency Access

Guidance

6.1 Inspections

Guidance

6.2 Design information verification

6.3 Complementary access

Guidance

6.4 Access to IAEA equipment

Guidance

7. Nuclear Material Accountancy

7.1 Measurement of nuclear material

Guidance

7.2 Inventory tracking

7.3 Physical inventory taking

Guidance

7.4 Inventory differences

7.5 Foreign obligations

Guidance

8. Provision of Information

8.1 Nuclear material accountancy reports

8.1.1 Information security and electronic reporting

Guidance

8.1.2 Inventory change document

Correcting or deleting an inventory change document

8.1.3 General ledger

Correcting a general ledger

Recording a correcting or deleting ICD on a general ledger

8.1.4 List of inventory items

Correcting a list of inventory items

8.1.5 Physical-key measurement point inventory summary

Correcting or deleting a physical-key measurement point inventory summary

8.1.6 Reconcilliation statement

Correcting a reconciliation statement

8.1.7 Obligated material inventory summary

Correcting an obligated material inventory summary

8.2 Design information

Guidance

8.3 Operational information

Guidance

8.4 Information required by the Additional Protocol

Guidance

9. Retention of Records

Appendix A: List of Declarable Nuclear-Related Manufacturing Activities

Appendix B: List of Nuclear Fuel Cycle-Related Research and Development Activities

Appendix C: Guidance on Materials Not Subject to Safeguards

Appendix D: Nuclear Material Accountancy Reference Tables

Glossary

References

Footnotes

CNSC Regulatory Document Series

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