NRC INSPECTION GUIDELINES UNDER THE MC&A REFORM RULE

An overview is presented on the NRC approach for inspecting and enforcing performance-based requirements under the material control and accounting (MC&A) Reform Rule of 1987 (10 CFR Part 74, Subpart C - Special Nuclear Material of Low Strategic Significance). The paper centers on regulatory guidelines for licensed low-enriched uranium (LEU) facilities that must be met by licensee Fundamental Nuclear Material Control (FNMC) Plans. Licensee procedures and practices which implement those Plans undergo comprehensive NRC inspection defined by a modular inspection and enforcement manual. Of paramount importance are statistical methods traceable to Jaech (TID-26298, 1973)' and Bowen and Bennett (NUREG/CR-4604, 1988)2. A perspective is offered on how those two primary references should be used to establish and maintain prescribed detection thresholds (DT) and other statistical controls. Furthermore, the application of nonmeasurement error concepts in determining the standard errors of inventory differences (SEID) - first suggested by Tingey (INMM Annual Meeting Proceedings, Vol. XIV, 1986)3'4 - is discussed.