Retired IAEA staff subcontracted through Haselwood Services and Manufacturing, Inc., Lenoir City, Tennessee, USA

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1 IAEA-CN-220/193 Transit Matching for International Safeguards K. V. Gilligan a, J. A. Oakberg b, and J. M. Whitaker a a Oak Ridge National Laboratory, Oak Ridge, Tennessee, USA b Retired IAEA staff subcontracted through Haselwood Services and Manufacturing, Inc., Lenoir City, Tennessee, USA Abstract. In 2013 the U.S. Department of Energy / National Nuclear Security Administration Office of Nonproliferation and International Security (NIS) supported a study of the International Atomic Energy Agency s (IAEA) processes and procedures for ensuring that shipments of nuclear material correspond to (match) their receipts (i.e., transit matching). Under Comprehensive Safeguards Agreements (CSAs), Member States are obliged to declare such information within certain time frames. Nuclear weapons states voluntarily declare such information under INFCIRC/207. This study was funded by the NIS Next Generation Safeguards Initiative (NGSI) Concepts and Approaches program. Oak Ridge National Laboratory led the research, which included collaboration with the U.S. Nuclear Regulatory Commission, the U.S. Nuclear Materials Management and Safeguards System (NMMSS), and the IAEA Section for Declared Information Analysis within the Department of Safeguards. The project studied the current transit matching methodologies, identified current challenges (e.g., level of effort and timeliness), and suggested improvements. This paper presents the recommendations that resulted from the study and discussions with IAEA staff. In particular, it includes a recommendation to collaboratively develop a set of good reporting practices for nuclear weapons states under INFCIRC/ Introduction In 2013 the U.S. Department of Energy / National Nuclear Security Administration Office of Nonproliferation and International Security (NIS) sponsored a study of the International Atomic Energy Agency s (IAEA) processes and procedures related to Treaty on the Non- Proliferation of Nuclear Weapons (NPT) transit matching. The expression NPT transit matching, commonly referred to more simply as transit matching, is used to define the IAEA activities ensuring (i.e., matching) nuclear material transfers. It is performed by matching the corresponding reports of shipments and receipts, both foreign and domestic. The IAEA has been performing transit matching since the initial receipt of NPT nuclear material accounting reports, beginning in the early 1970s. From the late 1970s into the early 1980s, the number of States joining NPT grew significantly, with a corresponding increase in the number of nuclear material accounting records being reported. In 1981 and 1984, meetings of experts addressed transit matching to establish the principles and provide recommendations. Those recommendations are still being applied. This manuscript has been authored by Oak Ridge National Laboratory, managed by UT-Battelle LLC under contract no. DE-AC05-00OR22725 with the US Department of Energy. The US Government retains and the publisher, by accepting the article for publication, acknowledges that the US Government retains a nonexclusive, paid-up, irrevocable, worldwide license to publish or reproduce the published form of this manuscript, or allow others to do so, for US Government purposes. 1

2 As a part of the IAEA safeguards information system, the IAEA has developed software to perform transit matching, a process referred to as machine matching. For those transfers that cannot be matched automatically by the software, human intervention is necessary, called human matching. In view of limited staff resources, it is a clear advantage to have the software make as many matches as possible. Transit matching is a component of other IAEA safeguards activities, including drawing facility safeguards conclusions, preparing the Safeguards Implementation Report (SIR), and as input for state evaluations. This transit matching study was funded by the NIS Next Generation Safeguards Initiative (NGSI) Concepts and Approaches program. Oak Ridge National Laboratory led the research, which included collaboration with the U.S. Nuclear Regulatory Commission, the U.S. Nuclear Material Management and Safeguards System (NMMSS), and the IAEA Section for Declared Information Analysis within the Department of Safeguards. The project studied the current transit matching methodologies, identified current challenges (e.g., level of effort and timeliness), and suggested improvements. This paper describes the state reporting obligations and reviews current IAEA transit matching practices. This is followed by a review of the challenges being faced. Finally, recommendations on strengthening transit matching at the IAEA are offered and conclusions are drawn. 2. Transit matching and current IAEA practices 2.1. State reporting The model safeguards agreement under the Treaty on the Non-Proliferation of Nuclear Weapons (NPT) is published as INFCIRC/153 (Corrected) and specifies safeguards measures for transfers of nuclear material. [1] All Comprehensive Safeguards Agreements (CSAs) are based on INFCIRC/153, which requires that Subsidiary Arrangements be agreed upon between the State and the IAEA. Those arrangements specify in detail how the procedures laid down by the CSA will be applied in a State. Under CSAs, Member States are obliged to declare such information within specified time frames. Nuclear Weapons States (NWS) voluntarily declare such information under INFCIRC/207. [2] The Subsidiary Arrangements require the IAEA to provide a semi-annual statement on domestic and international transfers of nuclear material. There are two basic types of safeguarded nuclear material transit accounts, one for exports/imports (foreign transfers) and the other for domestic transfers. Reports on nuclear material transfers are submitted to the IAEA as inventory change reports (ICRs). ICRs indicate increases, decreases, and adjustments in nuclear material balances. There are different types of changes to inventories, but transit matching is implemented only for those reports that indicate material has been shipped from or received into a material balance area. The timeliness requirement for sending ICRs to the IAEA is normally specified in the safeguards agreement, but it can also be defined in the Subsidiary Arrangements. The standard requirement is for the State to dispatch ICRs within 30 days after the end of the month in which a change occurs. For States in the European Union (all of which report through the 2

3 European Atomic Energy Community [Euratom]), the limit is 60 days. The requirement is for the dispatch of reports, regardless of the time needed for the reports to reach the IAEA. The five nuclear weapon States recognized by the NPT (China, France, Russia, United Kingdom, USA) are active nuclear material trading partners and report transfers with Non- Nuclear Weapons States (NNWS) under the provisions of INFCRC/207. All five States meet the basic requirements of INFCIRC/207, but there can be different implementations of reporting. In 2012 there were approximately 600,000 inventory change report entries generated by 55 States. The actual number of reported entries is published in the SIR each year. Of these 600,000 ICR entries, approximately 400,000 involve a NWS in the transfer. About 3,000 4,000 records remain unmatched each quarter, including those defined by the IAEA as being of small (de minimis) quantities. There are transfers of depleted uranium in shipping containers that are not required to be reported unless there is a change of ownership, such as the receiver purchases the container. For unmatched records, Quarterly Import Communications and Semi-annual Statements are sent and State responses are used to assist in resolving the open matches. Not all records can be matched, even after these communications. Approximately 85 90% of communications and statements are responded to, resolving most issues within 4 6 months. The items stay open until matched, and there is no systematic writing off of older unmatched records. The country Safeguards Authorities and State systems of accounting for and control of nuclear materials have varying internal requirements that may result in different ways of reporting nuclear material batches to the IAEA. While the total material quantities are consistent, these reports can result in there not always being a one-to-one association of shipment and receipt records. For some materials (e.g., light water reactor fuel assemblies, UF 6 cylinders), one nuclear material accounting entry is reported for each batch, resulting in one shipment record and one receipt record. It is possible, however, for a shipment to be reported as consisting of several batches but with the corresponding receipt being reported with a different number of batches. The result is there can be a one-to-one, one-to-many, many-to-one, or many-to-many relationship of batches (reported records) between the shipper and receiver for a transfer of nuclear material. Another factor is there are two different Code 10 record structures in use for reporting nuclear material accounting reports, referred to as fixed and labeled formats. Both provide the necessary information for the implementation of IAEA safeguards, but each format has features that may result in more than one record being needed to report a single batch of nuclear material, thereby generating more records, simply because of the reporting format being used. For NWS, INFCIRC/207 requires them to report only those greater than one effective kilogram (EKG). The EKG is a special unit used in safeguarding nuclear material. For a definition of EKG, see INFCIRC/153 (Corrected), paragraph 104 or the IAEA Safeguards Glossary, 2001 Edition, paragraph Some NWS have established the practice of reporting all transfers, even those less than 1 EKG. 3

4 2.2. IAEA Transit Matching Process Upon receiving shipment and receipt nuclear material reports, the IAEA processes the reports into its safeguards information system. Approximately every 14 days, the staff initiates software algorithms to perform machine matching. This means an algorithm determines which shipper and receiver records should be matched and connects the necessary matching information in the database. IAEA staff review and confirm the results of machine matching, and a manual process is started for those remaining records that are not matched by the software algorithms. In the process of reviewing machine matches or performing manual matching, it is possible that a previous match may be determined to be incorrect; in such cases, a process is used to de-match the records, which then become eligible again for matching. More information about the process is available in the article International Transfers of Nuclear Material, published in the winter 1986 issue of the IAEA Bulletin. [3] Internally, the IAEA applies a set of de minimis quantities in the transit matching process. The basic principle is to attempt machine matching on all transfers; and for unmatched records with small (de minimis) quantities, human matching is held in abeyance. However, if the total amount of unmatched de minimis quantities for a State exceeds a set level, the IAEA then begins to manually match the records. If the unmatched amount cannot be brought below the maximum limits, correspondence will be initiated with the State. Nevertheless, all de minimis quantity transfers are always available for the implementation of safeguards and analysis purposes. It is important that the IAEA keep States informed of the transit matching status for all foreign and domestic transfers of nuclear material. Periodically, reports are sent to the States, advising them of any unmatched records and requesting additional information that may assist the IAEA in completing the transit matching process. The IAEA dispatches semi-annual transit matching statements to each State, based on a shipper perspective. A statement shows all unmatched transfers for which the State is indicated as a shipper: The State has reported a shipment, and the corresponding receipt report has not yet been received by the IAEA. A receiver has indicated the State as the shipper, but the corresponding shipment report has not yet been received by the IAEA. The State is requested to provide information to assist the IAEA in associating a declared shipment with receipts reported by the receiver. Quarterly, the IAEA sends an Import Communication to States, which presents the status of transfers based on a receiver perspective. An Import Communication shows all unmatched transfers for which the State is indicated as the receiver: The State has reported a receipt, and the corresponding shipment report has not yet been received by the IAEA. A shipper has indicated the State as the receiver, but the corresponding receipt report has not yet been received by the IAEA. The State is requested to provide information to assist the IAEA in associating a declared receipt with shipments reported by the shipper. 4

5 3. Challenges facing transit matching All challenges need to be weighed against the objectives of NPT transit matching (confirming receipts of nuclear material shipments), which is a component of the overall safeguards approach. The immediate detection of material that has gone missing may not be possible through transit matching because the reporting timelines can vary greatly. Nevertheless, transit matching remains viable because it gives the IAEA the ability to identify unmatched transfers. Nonetheless, the time frames involved with transit matching, and resolving cases of unmatched transfers specifically, raise the question of whether further investment in improving transit matching, vs. investing in enhancing other safeguards measures, offers a greater return on that investment. There is an inherent delay built into safeguards agreements that allows time for the State to obtain the relevant information from facilities. If a transfer occurs on the last day of a month, the State has 30 days to dispatch the report to the IAEA before it is considered to be late. For transfers on the first day of a month, a State has 60 days to report. As mentioned earlier, for countries in the European Union, all of which report through Euratom, a 60 day time period is allowed from the end of the month in which a transaction occurs. That allows at least 60 days for an ICR to be reported, and up to 90 days for Euratom countries, depending upon when in the month a transfer is made. These time frames do not take into account the additional time needed to pursue and resolve cases of mismatched transfers. These timelines are explained indepth and with visuals in ORNL/TM-2013/160, IAEA NPT Transit Matching: Current Methodologies and Challenges.[4] The timelines themselves are a challenge. The deadlines specified in safeguards agreements are fixed: it is not a viable possibility to change the dispatch requirement to less than 30 days for non-euratom countries. Likewise, it is not a viable possibility to change Euratom countries from a 60 to a 30 day dispatch requirement. While the dispatch deadlines for reporting are specified, the NPT safeguards agreements do not indicate a time period within which reports are to reach the IAEA; therefore, there is no definite measure to indicate excessive transmittal times for reports. Those transmittal times can vary from those States that provide all information through their diplomatic missions in Vienna (potentially the slowest means), to those that use regular mail, to those that send encrypted reports via the Internet (generally the fastest means). If excessive transmittal delays are noted by the IAEA, communications are initiated to resolve the issue; this is the case especially if the delays are causing a ripple effect in safeguards activities, which include transit matching. There are some transfers of nuclear materials, such as UF 6 cylinders, that involve transport from the producing facility to a seaport, an ocean voyage, and then transfer from the receiving port to the relevant facility. In such cases, the movement could take a month or more. With transit matching, if the shipping and receiving ICR records are matched, there is a reasonable conclusion that material was not diverted, but there is no indication whether undeclared activities were performed on the material or if the material received is actually the same as that which was shipped. Other safeguards measures, such as containment and surveillance including tamper-indicating devices, add additional assurances of non-diversion and the absence of undeclared activities. If a State should choose to purposely delay reporting receipt of material so that an undeclared use could be made and then the receipt reported, the primary indication would be the reporting 5

6 delay itself. Information from the IAEA on timeliness of reporting for shipments and receipts, as well as on the transit time of reports, would give some indication if a problem is at hand. The IAEA sends timeliness-of-reporting statements to States on a semi-annual schedule, and reporting timeliness is a component of the SIR. Reports of exports and imports provided by NWS under INFCIRC/207 are a critical component of transit matching. Some NWS provide more information than others while still meeting reporting requirements. More information could be provided, either as additional data elements within records that are reported (e.g., detailed batch descriptions) or reporting of more transfers (e.g., those below 1 EKG). Depending on how a NWS elects to implement INFICRC/207 export/import notifications beyond what is required, the quantity and quality of what is reported can vary yet still remain within what is required. The software in use by the IAEA for transit matching (i.e., machine matching) was developed and implemented in about 2005 or 2006 and is still in use. The manual matching process was also updated at the same time. The next expected changes would be expected along with the development of a new information system for safeguards information. Nevertheless, the algorithms themselves function well and no changes to them are expected. Although improvements have been made in information processing systems and for the electronic transfer of data, domestic regulations remain that are based on earlier information processing technologies. This has an effect on how quickly reports can be provided and, to some degree, on report content. State regulations on the transfer of confidential information vary, and some countries do not send safeguards information as attachments to (even with encryption) across international borders. There may also be limitations within a country that restrict the electronic transfer of nuclear material accounting information from facilities to the State accounting system. There are countries with domestic regulations that allow facilities up to 30 days to report their nuclear material accounting information to the State accounting system. In such a case, nuclear material accounting reports are by definition already late with respect to the dispatch requirements of the safeguards agreement. If the State wishes to perform any additional processing, such as quality assurance (a good practice), then reports could be delayed even more. 4. Recommendations to strengthen transit matching It is first necessary to identify improvements that can be accomplished within the confines of reporting requirements and practices. Another necessary step would be to define areas where changes are essentially not possible within the current reporting confines and to identify areas where recommendations can be made for both domestic and international improvements. This will need to be addressed on a global basis to begin with member States, and then the IAEA could also identify individual States that need specific attention. Even though changing safeguards agreements is a significant undertaking (if possible at all), there are recommendations that can be made, with voluntary participation. Some basic examples would be for States to send ICRs to the IAEA more frequently, such as twice a month; 6

7 review and respond to IAEA statements and communications on transit matching in a timely manner (perhaps 30 days); adopt the same batch reporting structure (maybe by moving towards a standardized batch identification system); report INFCIRC/207 transfers that are equal to or below the 1 EKG limit (NWS only) and include additional batch information; and use the same batch name for shipments and receipts of the same material. One area that should also be addressed is the IAEA staff needed to ensure that the transit matching efforts can be completed as needed for the safeguards mission. A necessary approach to help address staffing concerns is to make sure that all related processes, procedures, and information systems are well documented. From what can be determined, it appears that this area needs attention to implement knowledge management in transit matching. This would ease future transitions in staffing resources. This would also assist the IAEA if/when the volume of reported data increased under voluntary participation by States as suggested above. Currently, the machine matching software developed and implemented by the IAEA is not a primary issue of concern. The software works well and performs the required tasks, although it is correct that more machine matches could be made. However, to achieve that, the information used by the algorithms would need enhancement, not the software itself. Finally, a working group of experts should be assembled to review transit matching. This would be a follow-on group to the 1986 meetings mentioned above. The experts would review in-depth transit matching practices and procedures and seek to strengthen safeguards by making recommendations. It has been almost 30 years since this topic has received attention by a group of experts. 5. Conclusions The challenges and limitations associated with current transmit matching processes and practices pose a number of questions to which further thought should be given. In light of the time-lags inherent in current transit matching practices, in particular for resolving unmatched transfers, several initial questions arise: What improvements to transit matching would enhance IAEA safeguards? Would such transit matching improvements enhance the IAEA state-level evaluation? Would improvements in the timing of transit matching translate into more robust state-level analysis or targeting of inspection activities, and if so, what steps are needed to accomplish this? Or would the gains come primarily in terms of some improvements in the efficiency of transit matching processes the resources applied to this task at IAEA Headquarters? It is necessary to engage the IAEA to see at what level transit matching is an interest and to obtain additional information about the Agency s current methods and practices. The information provided can be used to determine, with the IAEA, the next steps that can be taken. 7

8 There is room for changes, some voluntary, that could improve IAEA transit matching activities, including documentation. One viable option would be to initiate discussions with the IAEA and perhaps to convene a group of experts to review the current process and make recommendations. This may be the best approach, considering the last such group met about 30 years ago. Acknowledgments The authors thank the U.S. Department of Energy s National Nuclear Security Administration (DOE/NNSA) Office of Nonproliferation and International Security (NA-24) for the support given to this transit matching project. In particular, encouragement and approval by Dunbar Lockwood and Karyn Durbin of NA-24 are greatly appreciated. A special thank you to the Nuclear Regulatory Commission s Brian Horn and NNSA s Gary Hirsch. The International Atomic Energy Agency s Declared Information Analysis Section input was invaluable. References [1] The Structure and Content of Agreements between the Agency and States Required in Connection with the Treaty on the Non-Proliferation of Nuclear Weapons [INFCIRC/153 (Corrected)]. [2] Notification to the Agency of Exports and Imports of Nuclear Material (INFCIRC/207). [3] Nardi, Joseph, "International Transfers of Nuclear Material." IAEA Bulletin (Winter 1986). [4] IAEA NPT Transit Matching: Current Methodologies and Challenges, ORNL/TM- 2013/160, Oak Ridge National Laboratory, Oak Ridge, Tennessee (May 2013). 8