Infrastructure Necessary for Additional Protocol (AP)
Reporting
Part of the infrastructure necessary for AP reporting is
establishing a process for identifying, tracking, reviewing, and
submitting declarable
activities to the IAEA. This could also involve development of a
beginning-to-end timeline so that process steps can be monitored to
ensure the declaration will be completed and submitted on
time.
This infrastructure could be based on three areas:
- Decision making and implementation (Who decides? Who
implements?)
- Expertise (e.g., technical, legal, commercial, etc.), not
necessarily full-time members of the infrastructure
- Feedback (Who verifies that what was decided has been
implemented? Who gathers and integrates lessons learned?)
Infrastructure support may also require laws and regulations to be
developed. These may involve regulatory provisions for any or all of
the following:
- Elements and requirements of the AP
- Types of information a State needs to declare
- Timing of declaration provisions to IAEA
- Granting access to private locations to IAEA inspectors
(for example, Complementary Access)
- Logistics for receiving notification of and conduction of a
CA
- State provision for IAEA inspectors to use multi-entry visas
The expertise and capabilities acquired by the infrastructure
can be shared with other national bodies or organizations (such as
expertise for granting an export license in the area of nuclear trade,
optimization of national nuclear R&D programs).
Internal Procedures and Policies
- Entry into force (EIF) Sequence
of Events - activities and events necessary
for the AP to be entered into force including timelines and responsible
personnel for the overall implementation process.
- Data Call (request for declaration information
from
industry, universities, etc.) Sequence of Events - similar to
the EIF
Sequence of Events, but includes specific activities that must occur to
notify affected entities and to collect declaration data. Timelines,
responsible parties, sequencing, inter- intra-
agency reviews/approvals, and dependencies (if any) may be specified.
- Data Sensitivity - consideration of
proprietary and/or sensitive information that may be included in a
declaration. Industries are especially concerned about how the
information will be used and who will have access to it. Having a good
plan on how to meet AP reporting requirements without revealing
proprietary information can be crucial. This may include
specific reviews by export control agencies.
Roles and Responsibilities
- State Interface - identify the
ministry/office of the government responsible for communicating with
the IAEA. This communication channel is important not only to establish
which office submits declarations, but also if there are questions to
or from the State. This may include specific individuals and their
alternates, if applicable.
- Interagency Interface - similar to the
State Interface, but identifies the organization responsible for
communications and notifications the AP with industry, universities,
and other government agencies. Identification of the individual or
organization responsible for interpreting the provisions of the AP is
very important. How the information is communicated (outreach,
websites, brochures) may also be considered.
- Declaration Review - addresses possible
reviews performed prior to submission of declarations to the IAEA.
Technical, security, export, and administrative reviews are the most
common. At what point the reviews are performed, by whom, and how
issues are resolved are specified. The individual/organization with
final signoff authority and responsibility for the declaration is
identified.
Tools for Compiling a Declaration
- Activity/Location Identification -
identifies the resources (such as government organizations, funding
databases, or research project lists) available to assist in
identifying declarable items. Who owns the resources, how they are to
be used, and the steps necessary to obtain access are typical
components.
- Software Applications for Reporting AP Activities
- identifies readily accessible software applications (such as the IAEA
Protocol Reporter and the US Department of Energy’s AP Declaration
Helper). How they are to be used, hardware, software, and networking
requirements, and who will be the operator are described.