Status of the revision to ANSI N15.8, "Nuclear Material Control Systems for Nuclear Power Plants"

1. Status of the revision to ANSI N15.8, "Nuclear Material Control Systems for Nuclear Power Plants" Thomas Morello, Constellation Energy

2. Summary of Changes to N15.8 • The revised Standard: • establishes overall responsibility for implementing the MC&A program. • emphasizes the importance of complete records. • describes in detail the minimum requirements for adequate procedures. • clarifies that internal control of SNM should be adequately covered by procedures.

3. Summary of Changes to N15.8 • The revised Standard: • describes in detail what constitutes an acceptable physical inventory. • clearly states that the physical inventory should be compared with and reconciled against the book inventory (the inventory of record). • defines a “fuel component container” as an item similar to a fuel assembly in form/fit/function. • states that personnel responsible for MC&A of SNM should have training appropriate to their functions.

4. Summary of Changes to N15.8 • Renamed ANSI N15.8 “Special Nuclear Material Control and Accounting Systems for Nuclear Power Plants” • Added “and Accounting Systems” to emphasize importance of accurate records

5. Summary of Changes to N15.8 • Clarified MC&A terminology • Book inventory / Physical inventory • Dry storage canister / ISFSI • Fuel component / Fuel component container • Item count • Material control records • Non-fuel SNM / Non-fuel SNM container • Sealed container / Tamper-safing

6. Summary of Changes to N15.8 • Enhanced guidance • Characterization and identification of items as SNM or non-SNM to prevent loss of control over SNM items • Procedures for internal transfers • Configuration control over procedures • Corrective action program • Receipt of SNM, internal control, and shipment • Use of tamper-indicating devices • Non-fuel SNM (instruments) • Periodic assessment of the MC&A program

7. Status of ANSI N15.8 • Steps completed • Draft standard approved by working group members • Draft standard reviewed by ANSI editor • Revised standard submitted to the N15 ballot roster for approval • Presented at the 8th International Conference on Facility Operations – Safeguards Interface in Portland Oregon in April of 2008 • Presented at 2008 NMMSS users meeting in San Antonio in May of 2008

8. Current Status of ANSI N15.8 Approved by ANSI on Feb 18, 2009!!!!!!

10. What’s the Next Step? • Awaiting publication of the standard as of early April • Need NRC endorsement… • 1974 revision of N15.8 was endorsed by the NRC via Regulatory Guide 5.29 • However… Revision 1 of Regulatory Guide 5.29, "Nuclear Material Control Systems for Nuclear Power Plants," was published in 06/1975 and subsequently withdrawn on 01/15/1998. • We need the NRC to revise Reg. Guide 5.29 to endorse the new N15.8-2009 standard!!!

12. What’s the Next Step? • Licensees, and the NMMSS user community in particular, need to push the NRC to revise Reg. Guide 5.29 to endorse the standard prior to the next round of MC&A inspections!!! • Martha Williams has retired, so we’ve lost her as an insider advocate. • Both Dori Votolato and Brian Horn are advocates of the new standard within the NRC, but they have not been tasked with revising the Reg. Guide.