On April 10, 2020, Russian Ministry of Justice registered new revision of Basic Rules of Accounting and Control of Nuclear Materials also known by its Russian acronym OPUK. The revision was prepared by Russian nuclear regulator, Rostechnadzor. Rostechnadzor approved the revision in November 2019. Registration by the Ministry of Justice and subsequent official publication are final steps of enactment process. New OPUK, NP-030-19, will be effective starting April 20th
and replace previous version, NP-030-12 enacted in 2012.
OPUK is key regulation governing MC&A of all civil nuclear material in Russia. The document is mandatory for all organizations handling nuclear material, regardless organizations legal form and ownership of nuclear material.
OPUK-19 is the third OPUK revision. Rostechnadzor developed the original OPUK approved in 2001 and two subsequent revisions, OPUK-2005 and OPUK-2012, with financial and expert support from the U.S. OPUK-19 is the first revision developed without such support.
OPUK-19 defines the same key requirements to MC&A at sites as previous OPUK revision, OPUK-2012. However, Rostechnadzor added a number of additional details, codified certain established practices and partially reflected recent regulatory changes. Below are details on key changes introduced to new OPUK compared to previous version. Changes include:
- Clarifying procedure for investigating potential and confirmed MC&A anomalies and establishing clear requirement for long-term storage of data on the anomalies.
- Defining approach to MC&A in case if both "civil" and "military" nuclear material is handled within single material balance area.
- Defining objectives for self-monitoring MC&A status and introducing requirement for planning elimination of identified deficiencies and storing monitoring results.
- Establishing explicit requirement for storing data from surveillance systems used for MC&A.
- Clarifying requirements to material custody, e.g. prohibiting to include custodians in inventory committees.
- Establishing explicit requirement for regular review and revision of key site MC&A documents.
- Adding details regarding the establishment of MC&A responsibilities at a site.
- Improving OPUK structure.
Despite positive changes referred to above, new OPUK, as well as OPUK-2012, omits certain issues essential to effectiveness and sustainability of MC&A, including:
- Trending inventory difference (ID trending). ID trending is an analysis of results of sequential physical inventories of nuclear material aimed at detecting protracted theft of small amounts of nuclear material. Once sites are not obliged to implement ID trending, there is a risk of undetected protracted theft of nuclear material.
- Applying two-person rule anytime when category 1 and 2 nuclear material are accessed and processed. Two-person rule, joint access and continuous mutual observation by at least two duly authorized officials, is only required when accessing rooms with nuclear material and processing nuclear material in storage rooms. Once site personnel are not obliged to observe each other anytime when category 1 and 2 nuclear material are accessed and processed, there is a risk of unauthorized actions against nuclear material by insiders.
The development of OPUK-2019 included development of the first draft, public review, anticorruption review, and preparation of final draft taking into account comments received during the reviews. As a result of public review, Rostechnadzor released summary of comments received during the review. Although both nuclear sites and independent experts submitted their comments, the summary only included comments from sites.
During the public review certain nuclear sites suggested revisions to OPUK that would reduce burden on sites, but also reduce MC&A effectiveness. Rostechnadzor declined all of these suggestions. The example of declined suggestions is adding a statement that allows taking physical inventory for part of nuclear material in material balance area, and not all nuclear material. Regular and complete physical inventories in material balance areas is one of MC&A cornerstones. Partial physical inventory creates the risk that potential anomaly, including associated with unauthorized use or theft of nuclear material, is not timely detected.
The other interesting insight from the public review is nuclear sites' concern re lack of clear criteria and requirements to transferring nuclear material from accounting within the state system for control and accounting of nuclear material used for defense purposes to the system for state control and accounting of civil nuclear material. However, this issue is outside OPUK scope and should be regulated by other documents. Valid text of new OPUK
is available at government web-site for official publication of regulations.